ULNRC-05796, Application for Approval of Decommissioning Cost Estimate for Callaway Plant and Funding Level of Nuclear Decommissioning Trust Fund, Enclosure 2
| ML111540140 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/02/2011 |
| From: | Ameren Missouri |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111540136 | List: |
| References | |
| ULNRC-05796 | |
| Download: ML111540140 (159) | |
Text
ULNRC-05796 Page 1 of 18 Application for Approval of Decommissioning Cost Estimate for Callaway Plant and Funding Level of Nuclear Decommissioning Trust Fund
BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI Application of Union Electric Company d/b/a AmerenUE for Approval of Decommissioning Cost Estimate for Callaway Plant and Funding Level of Nuclear Decommissioning Trust Fund.
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Case No. EO-2009-APPLICATION FOR APPROVAL OF DECOMMISSIONING COST ESTIMATE FOR CALLAWAY PLANT AND FUNDING LEVEL OF NUCLEAR DECOMMISSIONING TRUST FUND COMES NOW Union Electric Company, d/b/a AmerenUE (AmerenUE or the Company), and pursuant to 4 CSR 240-3.185(3), hereby respectfully requests that the Missouri Public Service Commission (Commission) approve AmerenUE's decommissioning cost estimate and the continuation of the funding level of its nuclear decommissioning trust fund at the current $6,486,378 annual amount. AmerenUE further requests that the Commission find that the $6,486,378 annual funding level of its decommissioning trust fund is included in AmerenUE's current cost of service for ratemaking purposes and confirm that this funding level is based on the parameters and assumptions stated in this Application.
In support thereof, AmerenUE states the following:
BACKGROUND
- 1.
AmerenUE is a Missouri corporation, in good standing in all respects, with its principal office and place of business located at 1901 Chouteau Avenue, St. Louis, Missouri 63103. AmerenUE is engaged in providing electric and gas service in portions of Missouri as a public utility under the jurisdiction of the Commission. AmerenUE is the owner and operator of the Callaway Plant, a nuclear generating unit whose decommissioning trust fund is the subject of this Application.
- 2.
There is already on file with the Commission a certified copy of AmerenUE's Restated Articles of Incorporation (see Commission Case No. EA-87-105), and a copy of AmerenUE's Fictitious Name Registration as filed with the Missouri Secretary of State's Office (see Commission Case No. GO-98-486).
Said documents are incorporated herein by reference and made a part hereof for all purposes.
- 3.
Pleadings, notices, orders and other correspondence concernIng this Application should be addressed to:
Wendy Tatro Associate General Counsel Ameren Services Company 1901 Chouteau Avenue P.O. Box 66149 (MC 1310)
St. Louis, MO 63166-6149 (314) 554-3484 Fax: (314) 554-4014 wtatro@ameren.com
- 4.
AmerenUE does not have any pending action or unsatisfied judgments or decisions against it from any state or federal agency or court which involve customer service or rates, which action, judgment or decision has occurred within the last three (3) years. Furthermore, AmerenUE does not have any annual report or assessment fees that are overdue.
BASIS FOR FILING
- 5.
4 CSR 240-3.185(3) states, in part, the following:
On or before September 1, 1990, and every three (3) years after that, utilities with decommissioning trust funds shall perform and file with the commission cost studies detailing the utilities' latest cost estimates for decommissioning their nuclear generating unites) along with the funding levels necessary to defray these decommissioning costs. These studies shall be filed along with appropriate tariff( s) effectuating the change in rates necessary to accomplish the funding required.
2
2008 COST STUDY
- 6.
AmerenUE contracted with TLG Services, Inc. (TLG) to perform, under the direction of AmerenUE, the site specific cost study to determine the estimated cost for decommissioning the Callaway Plant. Since 1982, TLG has provided engineering and field services for contaminated facilities including estimates of decommissioning costs for nuclear generating units.
In fact, TLG is an industry leader in nuclear power plant decontamination and decommissioning planning, cost estimating, and project field supervision and they have prepared and updated decommissioning cost estimates for the vast majority of nuclear generation units in the country. TLG also is the company that prepared the decommissioning cost estimate that was filed with and approved by the Commission in 1999, 2002 and 2005., which is attached hereto and made a part hereof for all
- purposes, IS the updated decommissioning cost estimate prepared by TLG, titled Decommissioning Cost Analysis for the Callaway Plant.
TLG estimates the cost to decommission the Callaway Plant employing the DECON alternative as $693,907,000 in 2008 dollars.
NECESSARY ANNUAL FUNDING LEVEL
- 7.
AmerenUE' s analysis of the required annual funding level for the Missouri jurisdictional sub account is based on the premise that the current annual contribution to the decommissioning trust should be changed only if that annual contribution continued over the licensed life at Callaway Plant does not result in a final trust account balance which is just sufficient to cover the estimated decommissioning cost given in Attachment 1 under a reasonable set of economic, financial, and investment assumptions. As one would expect, 3
the calculation of an annual decommissioning expense and contribution amount adequate to cover future deconlillissioning liabilities is sensitive to varying forecasts of future decommissioning inflation and investment returns. Forecasted nominal investment returns are dependent on future investment policy and on forecasts of real returns on bond investments, equity premiums over and above bond investment returns and on general inflation levels. Since the determination of an annual decommissioning contribution can be sensitive to these various factors, the Company and the Commission Staff have jointly developed a "Zone of Reasonableness" model that computes the required annual decommissioning contribution within a "reasonable" range of economic and financial parameters., AmerenUE's analysis of the required funding level (a five-page document entitled "AmerenUE Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection - Missouri Jurisdiction") is attached hereto and made a part hereof for all purposes.
ZONE OF REASONABLENESS MODEL ASSUMPTIONS
- 8.
The jointly-developed "Zone of Reasonableness" model computes "Optimistic", "Expected" and "Conservative" annual funding levels required for the future decommissioning liability to be fully funded at various decommissioning inflation rates.
Previously, the Commission ordered AmerenUE to contributed $6,486,378 to the Missouri jurisdictional sub account. In support of this application, the "Zone of Reasonableness" model was used to verify the adequacy of that annual funding level. Basic input parameters regarding the computation of the "Optimistic", "Expected" and "Conservative" contribution boundaries that form the "Zone of Reasonableness" include:
4
Beginning value of the Missouri jurisdictional sub account (as of 06/30/2008):
Total decommissioning cost estimate:
Base year of the cost estimate:
Missouri jurisdictional demand allocator (June 30, 2008)
Federal incOlne tax rate:
State income tax rate:
Projected investment management and trust fees:
Asset allocation:
$ 264,089,093
$ 693,907,000 2008 98.38%
20%
0%
15.00 basis points 65% equities and 35% bonds Three different sets of assumptions were made for the following parameters, from which the "Conservative", "Expected" and "Optimistic" contribution boundaries were derived:
Real rate of return on bonds:
3.650 % for the "Conservative" contribution boundary, 3.900 % for the "Expected" contribution boundary, 4.125 % for the "Optimistic" contribution boundary.
General inflation level (CPI):
2.050 % for the "Conservative" contribution boundary, 2.400 % for the "Expected" contribution boundary, 2.750 % for the "Optimistic" contribution boundary.
Equity premium over bonds:
4.000 % for the "Conservative" contribution boundary, 4.500 % for the "Expected" contribution boundary, 5
5.000 % for the "Optimistic" contribution boundary.
Year in which divestiture from equity investments occurs:
2021 for the "Conservative" contribution boundary, 2022 for the "Expected" contribution boundary, 2023 for the "Optimistic" contribution boundary.
ZONE OF REASONABLENESS MODEL RESULTS
- 9.
As a basis for recommending that the current annual contribution amount remain unchanged, the Company calculated the decommissioning inflation values for which an annual funding level of $6,486,378 would be adequate under the economic and financial assumptions associated with the "Optimistic", "Expected" and "Conservative" contribution boundaries of the zone of reasonableness model. These decommissioning inflation values are, respectfully, 3.450%, 2.7420/0 and 2.044%.
Thus, if the economic and financial conditions assumed for the "Optimistic" scenario are actually experienced, an annual contribution of $6,486,378 would be adequate up to a decommissioning inflation rate of 3.450%. Should the economic and financial conditions assumed for the "Conservative" scenario be experienced, an annual contribution of $6,486,378 would be adequate up to a decommissioning inflation rate of 2.044%.
If the economic and financial conditions assumed for the "Expected" scenario are actually experienced, an annual contribution of
$6,486,378 would be adequate up to a decommissioning inflation rate of 2.7420/0.
The "Zone of Reasonableness" model used in this analysis is presented in. Page I of Attachment 2 details the basic input assumptions on which the proposed annual contribution is based. Page 2 of Attachment 2 illustrates the escalation of the decommissioning expense cash flows at the 2.742% decommissioning inflation rate, 6
which is the maximum rate at which the proposed annual contribution level of $6,486,378 would be adequate under the "Expected" contribution boundary assumptions. Page 3 of contains a spreadsheet illustrating how the proposed annual contribution amount will adequately cover decommissioning expenses with a $0 balance upon completion at a decommissioning inflation rate of 2.742% and the economic and financial assumptions associated with the "Expected" contribution boundary. Page 4 of Attachment 2 illustrates the assumptions applicable to the "Optimistic", the "Expected" and to the "Conservative" contribution boundaries and the decommissioning inflation rates for which the proposed annual contribution would be adequate under each of these sets of assumptions. Page 5 of Attachment 2 again illustrates the assumptions applicable to the "Optimistic", "Expected" and "Conservative" contribution boundaries and the annual contributions that would be required under each of these sets of assumptions at varying decommissioning inflation levels.
In conclusion, the calculations set forth in Attachment 2 validate AmerenUE's request to continue funding the decommissioning trust fund using the same annual amount previously authorized by the Commission in Case No. EO-2006-0098.
Because AmerenUE is not seeking a change to the funding level, there is no need for AmerenUE to file new tariffs.
- 8.
Because it is unnecessary for AmerenUE to change the funding level of the decommissioning trust, and unnecessary to file new tariffs, AmerenUE does not request a hearing, nor does it believe one is required.
7
- 9.
In its Order in the early cases regarding the establishment of the decommissioning trust fund (Case No. EO-85-17 and Case 1~0. ER-85-160), the Commission states:
"The Commission, though, requires that UE establish the external fund to take the maximum advantage of the 1984 tax law and follow the requirements of the tax law in making investments for the fund."
Consequently, AmerenUE is required by Commission order to fund the future decommissioning liability through contributions to the tax -qualified trust fund. In order to make the proposed contributions to the tax-qualified trust fund, AmerenUE must demonstrate to the Internal Revenue Service (IRS) that the proposed contributions are consistent with sections 468A of the Internal Revenue Code and area based on reasonable assumptions. See Treasury regulations § 1.468A-3T(a)(3). Under Treasury Regulations, section 1.468A-3T(a)(4), which was promulgated in December 2007, AmerenUE can satisfy this obligation by documenting that the proposed contributions are calculated using the decommissioning assumptions used by the Commission in its most recent order.
Specifically, Treasury regulations, section 1.468A-3T( e )(2)(v), provides that a taxpayer such as AmerenUE must disclose to the IRS:
Where applicable, an identification of each public utility commission that establishes or approves rates for the furnishing or sale by the taxpayer of electric energy generated by the nuclear power plant, and, for each public utility commission identified -
(A)
Whether the public utility commission has determined the amount of decommissioning costs to be included in the taxpayer's cost of service for ratemaking purposes; (B)
The amount of decommissioning costs that are to be included in the taxpayer's cost of service for each taxable year under the current determination and amounts that otherwise are required to be included in the taxpayer's income under section 88 and the regulations; 8
(C)
A description of the assumptions, estimates and other factors used by the public utility commission to determine the amount of decommissioning costs; (D)
A copy of such portions of any order or opinion of the public utility commission as pertain to the public utility commission's most recent determination of the amount of decommissioning costs to be included in cost of service; and (E)
A copy of each engineering or cost study that was relied on or used by the public utility commission in determining the amount of decommissioning costs to be included in the taxpayer's cost of service under the current determination.
In order for AmerenUE to comply with the requirements of the foregoing Treasury Regulations, AmerenUE requests that the Commission state in its Report and Order for this case that the annual decommissioning expense and contribution to the Callaway Plant Tax Qualified Nuclear Decommissioning Trust Fund in the amount of $6,486,378 is included in AmerenUE's cost of service for ratemaking purposes and acknowledge that this annual decommissioning expense and contribution amount is based on Attachment 1, the August 28, 2008, Decommissioning Cost Analysis for the Callaway Plant, and on the parameters and assumptions contained in Attachment 2 and summarized below:
The after-tax value of Missouri jurisdictional sub-account of the Callaway Plant Tax Qualified Nuclear Decommissioning Trust Fund as of June 30, 2008 was
$264,089,092.97.
The proposed expense and contribution amount is to be effective as of January 1,2009.
The present, total decommissioning cost estimate is $693,907,000 in terms of 2008 dollars.
The Missouri jurisdictional allocator is 98.38%.
9
The Missouri jurisdictional decommissioning cost estimate is $682,665,707 in terms of 2008 dollars.
The federal income tax rate is 20%.
The state income tax rate is 0%.
Investment management and trust fees are estimated at 15 basis points annually.
The real return on bonds is assumed to be 3.900%.
The equity premium is assumed to be 4.5000/0.
An asset allocation of 65% equities and 35% bonds is assumed to exist through 2022, at which time all equity investments will be divested.
An inflation rate of 2.400% is assumed for general (CPI) inflation.
Decommissioning cost escalation is assumed to be 2.742%.
Pre-tax and expense nominal returns on the fund's investments will be 9.2250/0 through 2022, and 6.300% thereafter. The average pre-tax and expense nominal return over the life of the fund will be 8.3962%.
WHEREFORE, AmerenUE requests that the Commission:
(l) approve Attachments 1 and 2, which are AmerenUE's estimate of decommissioning costs and the funding level necessary to defray said costs, and (2) specifically find that the annual funding level contributed to the decommissioning trust fund is included in AmerenUE' s current cost of service for rate-making purposes and is based on the underlying assumptions contained in Attachments 1 and 2, as summarized above.
Respectfully submitted, 10
Isl Wendy Tatro Steven R. Sullivan, # 33102 Sf. Vice President, General Counsel and Secretary Wendy K. Tatro, # 60261 Assoc. General Counsel Ameren Services Company P.O. Box 66149 St. Louis, MO 63166-6149 (314) 554-3484 (phone)
(314) 554-4014 (fax) ssullivan@ameren.com wtatro@ameren.com 11
CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and copy of the foregoing Notice of Dismissal was served on all parties of record via United States first-class mail, postage pre-paid, or by electronic mail (e-mail) on this 2nd day of September, 2008.
Missouri Public Service Commission P.O. Box 360 Jefferson City, Missouri 65102 gencounsel@psc.state.mo.us Office of Public Counsel P.O. Box 2230 200 Madison Street, Suite 650 Jefferson City, MO 65102 opcservice@ded.n1o.gov
/s/ Wendy Tatro Wendy Tatro
08/27/2008 I
AmerenUE I
I Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection I
Missouri Jurisdiction I
j--------------------------------------------------------------------------~
1 Current Year:
2 Year Decommissioning Begins:
3 Year Decommissioning Ends:
4 End-Of-Year Fund Balances June 30, 2008 End-Of-Year Fund Balance:
2033 End-Of-Year Fund Balance:
5 Annual Contribution to Fund Current:
Revised:
Effective Date of Revised Annual Contribution Year:
Quarter:
6 Portfolio Return Assumptions Asset Allocation Equities:
Bonds:
Real Return on Bonds:
CPI Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch Out of Equities at End-Of-Year:
7 Investment Management & Trust Fees (Basis Points):
8 Federal & State Tax Assumptions Federal Tax Rate:
Missouri State Income Tax Rate:
Percentage of Federal Taxes Deductible on MO Taxes:
Composite Tax Rate:
2008 2024 2033
~fhl",*81!1
.,.,. After entering all data, manually set this cell U equal to the Final, Ending Balance of Fund, located on "Fund Projections" worksheet!
$6,486,378
$6,486,378 2009 1
15.00 20.0000%
0.0000%
50.0000%
Page 1 of 5
08/27/2008 r---------------------------------------A~;;;_~UE---------------------------------------1 Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction
~ _______________________________________________________________________________________ J 1
Decommissioning Expense Estimates Original, Total Decommissioning Cost Estimate:
Original Estimate Based On:
Current, Total Decommissioning Cost Estimate:
Demand Allocator (Missouri):
MO Jurisdictional, Total Decommissioning Cost Estimate:
Decommissioning Inflation:
$693,906,000 Aug. 2008 TLG Study
$693,907,000 98.38%
$682,665,707 2.742%
Decommissioning Expense Calculation Year TOTAL 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 Aug. 2008 TLG Study Aug. 2008 TLG Study Total Decommissioning Expenses
$693,906,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$13,632,000
$79,435,000
$142,958,000
$133,219,000
$79,170,000
$78,953,000
$60,639,000
$42,131,000
$52,331,000
$ 11,438,000 Decommissioning Expenses
% OF TOTAL 100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.96%
11.45%
20.60%
19.20%
11.41 %
11.38%
8.74%
6.07%
7.54%
1.65%
Missouri Jurisdictional Decommissioning Expenses 2008 I
$682,665,707
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$13,411,181
$78,148,266
$140,642,283
$131,061,041
$77,887,558
$77,674,073
$59,656,734
$41,448,538
$51,483,312
$11,252,721
- of Years of Inflation 0
1 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Inflation Factor At 2.742%
Decommissioning Inflation Rate 1.0000 1.0274 1.0556 1.0845 1.1143 1.1448 1.1762 1.2085 1.2416 1.2756 1.3106 1.3465 1.3835 1.4214 1.4604 1.5004 1.5415 1.5838 1.6272 1.6719 1.7177 1.7648 1.8132 1.8629 1.9140 1.9664 Missouri Jurisdictional Decommissioning Expenses (Inflated $$)
$1,169,334,207
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$20,673,977
$123,772,359
$228,858,763
$219,115,230
$133,787,135
$137,078,599
$108,168,390
$77,214,243
$98,537,603
$22,127,908 Page 2 0[5
08127/2008 r------------------------------------------------------------------------~;;;_~UE------------------------------------------------------------------------l I
Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection i
L ____________________________________________________________________ ~~~~~!lJ~~~!~!~~ ____________________________________________________________________ J Cu rrent Year:
2008 Year Decommissioning Begins:
Year Decommissioning Ends:
June 30, 2008 End-Of-Qtr Fund Balancel
$264,089,0931 2033 EOY Fund Balance:
$0 Current Contribution:
Revised contribution:
Year TOTAL June 30, 2008 Beginning-of-Year Balance 2008 264,089,093 $
_._.. ~~9~ ____. __. ____ ~~~~~!l_3 2010 303,788,532 2011 332,548,4 19 2012 363,394,681
$6,486,378
$ 6,486,378 Annual Contributions To Fund 107,025,237 3,243,189 $
6,486,378 6,486,378 6,486,378 6,486,378 Equities:
Bonds:
Real Return on Bonds:
CPI Inflation:
Norrrinal Return on Bonds:
Equity Prerrrium over Bonds:
Norrrin al Return on Equities:
Weighted Average Return:
Switch Out of Equities at EOY:
Management & Trust Fees: (BP)
.( ** :i **
T....-.
Pre Tax & Fee Income 1,017,631,309 12,255,905 $
25,850,027 28,323,676 30,976,776 Investment Manageme nt
& Trust Fees 19,856,463 203,879 $
439,7 13 481,790 526,920 33,822,344 575,324 2013 396,478,675 6,486,378 36,874,342 627,239 65.00%
Federal Tax Rate:
35.00%
Missouri State Income Tax Rate:
3.90%
Percentage of Federal Taxes Deductible on MO Taxes:
2.40%
6.30%
4.50%
10.80%
9.225%
Composite Taxe Rate:
Original, Total Decomrrrissioning Cost Est:
Current, Total Decomrrrissioning Cost Est:
Demand Allocator (Missouri):
Aug. 2008 TLG Study 2008 2022 MO Jurisdictional, Total Decommissioning Cost Estimate:
Decomrrrissioning Inflation Assumption:
15.001 Federal & State Income Taxes 199,554,969 After Tax & Fee Income 798,219,877 2,410,405 $
9,641,621 $
5,082,063 20,328,251 5,568,377
--22,273,509 6,089,971 24,359,885 6,649,404 26,597,6 16 7,249,421 28,997,683 Missouri Jurisdictional Decommissioning Ex penses (Inflated $ $)
1,169,334,207 End-Of-Year Balance
$264,089,093 276,973,903 303,788,532
332,548,419 363,394,681 396,478,675 431,962,736
2Ci14------------431,962,7-3'6------ 6,486,378
--- 40, 147,i47-----~:920 -----
7,892,965 31,571,862 470,020,976 2015 2016 2017 470,020,976 510,840,137 554,620,510 6,486,378 6,486,378 6,486,378 43,658,619 742,640 47,424,187 806,693 51,462,926 875,393 8,583,196 34,332,783 9,323,499 37,293,995 10,117,507 40,470,027 510,840,137 554,620,510 601,576,915
____. __ ~O'_!? ___.. ____. ___________.?Q~~~.!.~~ ________. ____ ~4:~~~?~_. ________. __
~?-'794,~?.? _________ ~<?~ ________ 10,969, 1}_~ ____
4:~~76,'1:..~ ____________________ _ ?...?_~~~_,_~_?.._
2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 651,939,755 705,956,151 763,89~~
826,029,016 892,674,656 943,206,327 975,040,079 896,160,374 705,733,227 515,927,302 6,486,378 6,486,378 6,486,378 6,486,378 6,486,378 6,486,378 60,440,627 65,423,639
___ ~~8,14 2 76,500,361 56,442,824 58,975,089 57,528,696 49,249,053 37,559,064 28,289,125 1,028,105 1,112,867 1,203,778 1,301,284 1,386,209 1,448,400 1,412,877 1,209,533 922,433 694,767 11,882,504 47,530,017 12,862,154 51,448,6 18 13,912,873 55,651,492 15,039,815 60,159,262 11,011,323 44,045,292 11,505,338 46,021,351 11,223,164 44,892,655 9,607,904 38,431,6 15 7,327,326 29,309,305 5,518,872 22,075,486 20,673,977 123,772,359 228,858,763 219,115,230 133,787,135 705,956,15 1 763,891,147 826,029,016 892,674,656 943,206,327 975,040,079 896,160,374 705,733,227 515,927,302 404,215,653 2029 404,2 15,653 2 1,147,610 519,375 4,125,647 16,502,588 137,078,599 283,639,642
_____ 3Q~~ __________________
.3~~~39,~~~ __ _________________________ ~~~~~
_____ ~~
180 ____ ~ 1,36_~
__..2~.!.285,4~ _____
.r~~!l.!.~.9 ____ ~~! 756, :.~
2031 186,756,703 2032 116,825,820
_____.3.2.?_~ ______________ 3 1, 609,468 9,333,424 4,256,092 664,367 229,224 104,528 16,317 1,820,840 830,313
____ 129,610 7,283,359 3,321,252
______ 518,441 77,2 14,243 98,537,603 22,127,908 _
116,825,820 21,609,468
_!<2L 20.00%
0.00%
50.00%
20.0000%
$693,906,000
$693,907,000 98.38%
$ 682,665,707 2.742%
Page 3 or5
08/2712008 i
A~re~
I I
Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction
~------------------------------------------------------------------------~
1 Portfolio Return Assumptions Equity Allocation:
Bond Allocation:
Real Return on Bonds:
CPI Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch out of Equities at End-Of-Year:
2 Decommissioning Expense Estimates Decommissioning Inflation:
Revised Annual Contribution:
Contribution Boundary Estimates Optimistic Estimate Expected Estimate Conservative Estimate 3.450%1 2.742%
2.044%
Optimistic Expected Conservative
$6,486,378 1
$6,486,378 1
$6,486,378 1
$6,486,378
$6,486,378
$6,486,378 Page 4 of5
AmerenUE Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction Zone of Reasonableness Analysis Contribution Boundary Estimates 08/27/2008 Portfolio Return Assumptions Optimistic Estimate Expected Estimate Conservative Estimate Equity Allocation:
Bond Allocation:
Real Return on Bonds:
cpr Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch out of Equities at End-Of-Year:
Decommissioninl! Inflation:
65.00%
65.00%
65.00%
35.00%
35.00%
35.00%
4.13%
3.90%
3.65%
2.75%
2.40%
2.05%
6.88%
6.30%
5.70%
5.00%
4.50%
4.00%
11.88%
10.80%
9.70%
10.13%
9.23%
8.30%
2023 2022 2021 Required Contribution Amounts Optimistic Estimate Expected EstImate Conservative EstImate
.............................................................................................................................. ~:!~.~(~........ ~................................ J~.??~~?~.?!... ~.................................... ~? ~~~. !.~.?~g!.... ~................................... Q.~~~.?:.~~.?2.
tg.9.~....... J................................
J?!§.?~.!.!.??.)... ~....................................
(2.1~}.~1???.2.. ~......................................... }.~g.'.?§.§...
1.:.? ?.~........ ~....................................<§.!~.??&?..~L~....................................
(?l~.??l?.~D.. ~......................................!. ? ?~.?&~}...
1.50%
(5,266,435) $
(1,206,8 15) $
3,025,773
- :: ::::: ::::::::: :: ::::: :::::::: :::::: ::: ::: :: :: :: : : ::: : :::::::: : ::::: : : ::: ::: :::::::::: : : :: :: :: : : :: : ::::: ::: : :::::::: :::: : : :C?:~%: ::: : : ::~:::::::::: : ::: :: : : :::::::::::::::::~~:;?':?'§';Q~:~i. I::: ::: ::: : : ::: : : : :: : ::: : ::: : : : : ::: : :: :jQ:?;:i.~I ::~: :: : ::::::::: :::::::::: ::::::: : ::: :: : :~;:~?:?;:~?I:
............................................................................................................................. ?:g.~~........ ~................................... ~~.,~.~~~7?~!...
~......................................
~.~~.!.?:~.~.?.... ~...................................... ?:.!.?~:.~7?..
~:.??.~........ ~................................. JL~.?2.1~.?.U §.................................... }1 ~.~.~1}.~.1.... ~...................................... ? 1.?~.?.'.?.?.?....
2.50%
23 1,563 4,846,259 9,667,764
~:::~~::::::~~::: ::: :::::: : ::::::
- :::::::::: til~:::] :: ~::;:~::;:-:;:::::Ulj:iil] :::::::: :: : :::::::: ~::]:n~:,~i[l : ::::; ::: :: :jj:;.I~:llr
}:.?.9.~....... t....................................§.1~.1.~1.!.9.?... ~................................. J?1.~.?2.19.??....
~.................................... ~.??~§.9..'.?~.~...
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$0 3.75%
8,697,277 14,168,948 19,900,114 Missouri Jurisdiction Required Annual Contribution AmerenUE Callaway Plant Tax Qualified Nuclear Decommissioning Trust Fund
($5,000,000) __ =--.:;::...-----==:::*-~=-------------------"------I
($10,000,000) -+-----------------------------------1
($15,000,000) -' ___________________
.....o.-______
~_~~
......:-___...I 0.75% 1.00% 1.25% 1.50% 1.75% 2.00% 2.25% 2.50% 2.75% 3.00% 3.25% 3.50% 3.75% 4.00% 4.25%
Decommissioning Inflation
-+- Optimistic Estimate ___ Expected Estimate -.- Conservative Estimate -*- Current Contribution ___ Proposed Contribution Page 5 of 5
ULNRC-05796 Page 1 of 19 Unanimous Stipulation and Agreement
BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI Application of Union Electric Company d/b/a AmerenUE for Approval of Decommissioning Cost Estimate and Funding Level ofNucIear DecOlnmissioning Trust Fund.
)
)
)
)
Case No. EO-2009-008I UNANIMOUS STIPULATION AND AGREEMENT COME NOW Union Electric Company d/b/a AmerenUE (AmerenUE), the Staff of the
. Missouri Public Service Commission (Staff), and the Office of the Public Counsel (OPC), and submit this Unanimous Stipulation and Agreement (Agreement) to the Missouri Public Service Commission (Commission) in resolution of Case No. EO-2009-0081.
INTRODUCTION The Legislature provided, in Section 393.292 RSMo, that the Commission may authorize changes to the rates and charges of an electrical corporation as a result of a change in the level or
. annual accrual of funding necessary for'its nuclear power plant decommissioning trust fund.
This statute creates a narrow exception to the general requirement that the Commission must consider "all relevant factors," prior to changing any rate charged by a utility under its jurisdiction.
See State ex. reI. Utility Consunlers Council of Missouri, Inc. v. Public Serv.
Comm'n, 585 S.W.2d 41 (Mo. banc 1979). Under Section 393.292, the Commission may limit its review in nuclear deconnnissioning trust fund cases to only those factors relevant to the*
. funding level or accrual rate of the trust fund when deciding matters related to the rates and charges assoCiated with that fund. Further, Section 393.292 gives the Commission authority to adopt rules and regulations governing the procedures associated with these tariff changes as well as to ensure that the anl0unts contained in the trust funds will be neither "greater nor lesser than
the amounts necessary to cany out the purposes of the trust." In Case No. EX-90-IIO, the Commission adopted the original decommissioning rule, 4 CSR 240-20.070.
4 CSR 240-3.185(3) states, in part: "On or before September 1, 1990 and every three (3) years after that, utilities with decommissioning trust funds shall perform and file with the commission cost studies detailing the utilities' latest cost estimates for decommissioning their nuclear generating unites) along with the funding levels necessary to defray these decommissioning costs."
AmerenUE established an external nuclear decommissioning trust fund as a result of its Callaway Plant (Callaway) rate case decided by the COITl111ission in 1985. Re Union Electric Co., Case Nos. EO-85-17 and ER-85-160, 27 Mo.P.S.C. (N.S.) 183, 249, 256-57 (1985); See
. also, Re Union Elechic Co., Case Nos. ER-84-168 and EO-85-17, 27 Mo.P.S.C. (N.S.) 164 (1984).
On August 31, 2005, AmerenUE filed an Application (Case No. EO-2006-0098) with the
. Commission for approval of its then-current decommissioning cost estimate and continuation of
.. the then-current authorized funding level for its nuclear decommissioning trust fund for Callaway. A Unanimous Stipulation and Agreement, which settled all issues pertaining to Case No. EO-2006-0098, was filed on December 15, 2005. Among other things, the Unanimous Stipulation and Agreement maintained the annual decommissioning expense accrual and trust fund payment at $6,486,378.
THE 2008 COST STUDY On September 2, 2008, ArnerenUE, pursuant to 4 CSR 240-3.185(3), filed its Application for Approval of Decommissioning Cost Estimate for Callaway Plant and Funding Level of Nuclear Decommissioning Trust Fund (the Application). Attachment 1 to the Application is a 2
cost study (the 2008 Study) detailing AInerenUE's latest cost estimate for decommissioning Callaway entitled "Deconlmissioning Cost Analysis for the Callaway Plant," dated August 2008.
TLG Services, Inc. (TLG), a consulting engineering finn, prepared the 2008 Study for AmerenUE 1* Attachment 2 to the Application is AmerenUE's analysis of the current funding level for the decotmnissioning trust, as set forth in a five-page document entitled "Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection, Missouri Jurisdiction" (the Economic Analysis).
In the Application, AmerenUE requested that the Connnission: (1) approve the 2008 Study and the Economic Analysis, which are AmerenUE's estimate of decommissioning costs and the funding level necessary to defray said costs, and (2) specifically find that the annual funding level contributed to the decommissioning trust fund is included in AmerenUE's current cost of service for rate-making purposes and is based on the underlying assumptions contained in the Economic Analysis.
In the 2008 Study, TLG examined two decommissioning options; DECON2 and SAFSTOR.3 A third option, ENTOMB 4, was considered in prior deconnnissioning cost studies I Since 1982, TLG has provided engineering and field services for contaminated facilities including estimates of decommissioning costs for nuclear geneni.ting units. TLG also prepared the decommissioning cost estimate for Callaway that was filed with and approved by the Commission in 1999,2002 and 2005.
2 DECON assumes decontaminating and decommissioning (D&D) immediately following conclusion of power operations in 2024, when the 40 year operating license expires. Work is anticipated to be completed by 2034.
DECON consists of removal of fuel assemblies) source material, radioactive fission and corrosion products, and other radioactive materials immediately after cessation of power operations. Total estimated cost to decommission in 2008 Dollars is $ 693,907,000.
3 SAFSTOR places the facility in protective storage for deferred decontamination to levels that permit release for umestricted use. Delayed decontamination and dismantling activities are initiated once spent fuel and source material are removed such that license tennination is accomplished within the 60-year time period set by the NRC. This process is anticipated to be completed by 2087. Total estimated cost to decommission in 2008 Dollars is
$ 929,568,000.
4 ENTOMB is defmed as "the alternative in which radioactive contaminants are encased in a structurally
. long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level pennitting umestricted release of the property." As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years. The 60-year (Footnote continued on the next page.)
3
but was not included in the 2008 study. For the purposes of the 2008 Study, the final shutdown date of Callaway is projected to occur in 2024.5 The Economic Analysis summarizes a detailed analysis by AmerenUE based on the premise that the current contribution to the decommissioning trust should be changed only if it does not result in a final trust account balance which is just sufficient to cover the predicted decommissioning costs under a reasonable set of economic, financial, and investment assumptions.
The calculations called for in the Economic Analysis were perfonned in a manner consistent with previous filings. AmerenUE owns 100 percent of Callaway and the Economic Analysis allocated 98.38 percent of Callaway to AmerenUE's Missouri retail operations.
AmerenUE perfonned its Economic Analysis to velifY the adequacy of the current annual funding level ($6,486,378), given the revised prediction of decommissioning costs from the 2008 Study ($693,907,000). Based 011 this analysis, AmerenUE has concluded that its current funding level should result in a fmal decommissioning trust amount which is sufficient to cover the costs estimated in the 2008 Study under what AmerenUE believes are a reasonable set of economic, financial and investment assumptions. Consequently, AmerenUE does not seek any changes to its funding level, and asks the Commission to approve the current funding level amount.
Because AmerenUE is not proposing a change in the funding level, AmerenUE has not filed new restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material. In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations, however, mlemaking has been deferred pending the completion of additional research studies, for example, on engineered barriers.
5 If decommissioning fmancial assurance is provided by an external sinking fund, 10 CFR 50.75(e)(1)(ii) requires that "the total amount of funds would be sufficient to pay decommissioning costs at the time tem1ination of operation is expected. " Because AmerenUE does not contemplate shutting down Callaway prior to the end of its license life, the shutdown date used in the Economic Analysis is 2024, the year in which Callaway'S NRC Operating license expires.
4
tariffs regarding its funding of decommissioning, is not requesting a hearing, and does not believe that a heari..ng is required respecting its decomrr.tissioning cost study filing.
STIPULATIONS AND AGREEMENTS AmerenUE, the Staff, and Public Counsel, the only parties to this case, have reached certain understandings, and therefore stipulate and agree as follows:
- 1.
AtnerenUE's Missouri retail jurisdiction annual decommissioning expense accrual and trust fund payment was set by the Commission at $6,214,184, first in Case No. EO-91-300, Re Union Electric Co., Mo.P.S.C.3d 356 (1992), again in Case No. EO-94-81, Re Union Electric Co., 3 Mo.P.S.C.3d 68 (1994), again in Case No. EO-97-86, again in Case No. EO-2000-205, and again in Case No. EO-2003-0083.6 In Case No. EO-2004-0108, the Commission addressed decommissioning trust funding along with the transfer of AmerenUE's MetroEast property to AmerenCIPS. In its Report And Order On Rehearing in that case, the Commission 6 In 1984 in AmerenUE's Callaway rate case, AmerenUE and the Staff stipulated that the decommissioning cost of Callaway was $120,000,000 in 1983 Dollars. As a result of the Commission's Callaway Report And Order, AmerenUE's Missouri jurisdictional a1ll1uaI trust fund payment requirement was set at $2.9 million. Re Union Electric Co., Case Nos. EO-85-17 and ER-85-160, 27 Mo.P.S.C.(N.S.) 183,249 (1985). In Case No. EO-91-300, which was AmerenUE's first filing pursuant to 4 CSR 240-20.070, a Unanimous Stipulation And Agreement was accepted by the Commission which identified the cost in 1990 Dollars to inunediately decommission Callaway, as if it had completed 40 years of service, as being $347 million and set AmerenUE's Missouri retail jurisdiction annual
. trust fund accrual and payment requirement as $6,214,184. The great increase in the cost estimate was due principally to a major increase in the projected cost charged by licensed facilities for disposal of low-level radioactive waste. (Low-level radioactive waste should not be confused with high-level radioactive waste and spent nuclear fuel. The federal fee, which is collected with each kilowatt hour of electricity generated by Callaway, relates to disposal facilities for high-level radioactive waste and spent nuclear fuel, not disposal facilities for low-level radioactive waste.)
In Case Nos. EO-94-81, EO-97-86, EO-2000-205 and EO-2003-0083, Unanimous Stipulation And Agreements were accepted by the Commission which identified the costs in 1993, 1996, 1999 and 2002 Dollars, respectively, to immediately decommission Callaway, as if it had completed 40 years of service, as being $371,511,680, $419,975,000, $509,451,856 and $515,339,000, respectively. In all four cases, AmerenUE's Missouri retail jurisdiction arumal bust fund accrual and payment requirement remained at $6,214,184, as that amount was determined to be adequate for the funding of future decommissioning expenses. In Case No. EO-2004-0108, the Missouri retail jurisdiction annual trust fund accrual and payment requirement was increased to
$6,486,378 to reflect the increased liability for decommissioning costs assumed by the Missouri ratepayers as a result of the MetroMEast Property Transfer. In Case No. EO-2006-0098, a Unanimous Stipulation And Agreement was accepted by the Commission which identified the costs in 2005 Dollars to immediately decommission Callaway, as if it had completed 40 years of service, as being $586,515,200.
AmerenUE's Missouri retail jurisdiction annual trust fund accrual and payment requirement remained at $6,486,378, as that amount was determined to be adequate for the funding of future decommissioning expenses.
5
ordered an increase in the annual Missouri decommissioning expense and contribution anlount from $6,214,184 to $6,486) 78 7 to reflect the increased liability for decommissioning costs assumed by the Missouri ratepayers. Now, in the instant Application, AmerenUE requested the Commission continue the annual accruals at $6,486,378, the amount ordered by the Commission in Case No. EO.. 2004.. 0108.
- 2.
On September 2, 2008, AmerenUE filed its Application along with the 2008 Study and Economic Analysis. AmerenUE, the Staff and Public Counsel request that the Commission recognize in its Order for this case that AmerenUE's Application, 2008 Cost Study and Economic Analysis meet the requirements of 4 CSR 240-3.185(3).
- 3.
The 2008 Study estimates the decommissioning cost for the DECON alternative to be $693,907,000 in 2008 dollars, which is 18.3% higher than the 2005 estimate of
.. $586,515,200 and represents approximately a 5.76% annualized escalation rate over the 3-year period.
- 4.
AmerenUE deems the current contribution of $6,486,378 to be reasonable inasmuch as it results from a set of economic, financial and investment assumptions, including inflation rates, which are themselves considered reasonable by AmerenUE. (See Attachment 2 to the Application.) Therefore, AmerenUE believes that it is reasonable and prudent to continue the annual Missouri jurisdictional accruals at the current level of$6,486,378.
- 5.
AmerenUE shall continue its Missouri retail jurisdiction expense accn1als and trust :fund payments at current levels without any change in its Missouri retail jurisdictional rates.
7 Report And Order On Rehearing in Case No. EO-2004-0108 contains a typographical error that transposed the second and third digits in the annual contribution amount to the Missouri jurisdictional subaccount.
Because this error has an insignificant impact on trust fund funding, AmerenUE used iliis actual ordered amount as its present annual contribution amount.
6
- 6.
Annual decommissioning costs in the amount of $6,486,378 are, and should continue to be, included in.A...... 11lerenlJE's cost of seI'Vice ru1.d reflected in its current rates for ratemaking purposes. AmerenUE, the Staff and Public Counsel request that this finding be specifically recognized in the Commission's Report and Order and note that this finding is required in order for the decommissioning fund to utilize the sinking fund methodology of decommissioning funding.
- 7.
AmerenUE, the Staff and Public Counsel request that. the Commission in its Report and Order in this case approve, pursuant to 4 CSR 240-20.070( 4) (C), the use of a
. jurisdictional delnand allocator of98.38%.
- 8.
While the quarterly reports required by 4 CSR 240-3.185(1) and the annual reports required by 4 CSR 240-3.185(2) are required to be filed with the Commission, and this has been accomplished in the past by filing them in the most recent case established for a tariff filing by AmerenUE under 4 CSR 240-3.185(4) "which proposes any change in rates due to
.changes. in the estimate of decommissioning cost or the funding level of its nuclear decommissioning trust fund(s)," AmerenUE, Staff and OPC agree it would promote administrative efficiency for all if these quarterly and annual report filings were maintained at the Commission in a single file; therefore, AmerenUE, Staff and OPC propose the Commission grant variances from the 4 CSR 240-3.185(1) and 4 CSR 240-3.185(2) and order those filings be made in the Commission's Electronic Filing and Information System (EFIS) as non-case related submissions under the EFIS category, Nuclear Plant Decommissioning Report, for Union Electric Company-Investor (Electric), commencing with the next filing due after the effective date of the Commission's order granting variances. Additionally, AmerenUE shall file the quarterly Nuclear Decommissioning Trust Fund Performance Report provided by the trustee, 7
The Bank of New York, under the same category in EFIS. Further, with access to these filings available through EFIS, AmerenUE, Staff and ope agree neither AmerenUE nor the trustee of the decommissioning fund shall provide service copies of the filings to Staff. Because Staff receives from EFIS e-mail notice of such filings, those making the filings shall not be required to serve copies or notice of the filings on Staff Payments to the trustee of the external trust fund are made on a quarterly basis in the month following the end of the quarter to which the payment applies.
9.
None of the parties to this Agreement shall be deemed to have approved or acquiesced in any question of Commission aut~ority, decommissioning methodology, ratemaking principle, valuation methodology, cost of service methodology or determination,
. depreciation principle or method, rate design methodology, cost allocation, cost recovery, or
- .*prudence that may underlie this Agreement or for which provision is made in this Agreement.
- 10.
If the Commission does not unconditionally approve this Agreement without modification, and notwithstanding its provision that it shall become void thereon, neither this Agreement nor any matters associated with its consideration by the Commission shall be considered or argued to be a waiver of the rights that any party has to a hearing 011 the issues presented by the Agreement, regarding cross-examination or a decision in accordance with Section 536.080.1 RSMo or Art. V, Section 18 Mo. Canst. The parties shall retain all procedural and due process rights as fully as though this Agreement had not been presented for approval, and any testimony or exhibits that nlay have ~een offered or received in support of or in
.opposition to this Agreement shall thereupon become privileged as reflecting the substantive content of settlement discussions:> and shall be stricken from and not be considered as part of the administrative or evidentiary record before the Conunission for any further purpose whatsoever.
8
- 11.
To assist the Commission in its review of this Agreement, the parties also request that the Commission advise them of any additional infonnation that the COIT'.Jllission nlay desire
. from the parties related to the matters addressed in this Agreement, including any procedures for furnishing such information to the Commission.
- 12.
If requested by the Commission, the Staff shall have the right to submit to the Commission a memorandunl responsive to the Commission's request. Each party of record shall be served with a copy of any memorandum and shall be entitled to submit to the Comnussion within five (5) days of receipt of the Staffs memorandum, a responsive memorandum which shall also be served on all parties. The contents of any memorandum provided by any party are
. its own and are not acquiesced in or otherwise adopted by the other signatories to this Agreement, whether or not the Commission approves and adopts this Agreement.
- 13.
Representatives of the Signatory Parties agree that they will appear at any on-the-
. record presentation the Commission may schedule to address the issues resolved by this Agreement and to respond to any questions by the Commission. The parties agree to cooperate in presenting this Agreenlent to the Commission for approval, and will take no action, direct or indirect:> in opposition to the request for approval of this Agreement.
- 14.
Because this is an Agreement with the sole purpose of addressing the authority
. requested by the Application of AmerenUE, except as specified herein, the parties to the Agreement shall not be prejudiced, bound by, or in any way affected by the tenns of this Agreement:
(a) in any future proceeding; (b) in any proceeding currently pending under a separate docket; and/or (c) in this proceeding, should the Commission decide not to approve the Agreement or in any way condition its approval of the same, except as stated herein. Because this is an Agreement for the purpose of settling matters in this case, it shall not be cited as 9
precedent or referred to in testimony as an assertion of the particular position of any party in any subsequent or pending judicial or administrative proceeding, except that this shall not be construed to prohibit reference to its existence in future proceedings, including proceedings to enforce compliance with its tenns.
- 15.
The 2008 Study and the Economic Analysis shall be received into evidence.
- 16.
Pursuant to 393.292 RSMo and 4 CSR 240-3.l85, the parties agree that the Commission may review for good cause, including a change of circumstances of a material nature, and authorize changes to AmerenUE's rates and charges as a result of a change in the annual accrual of funding. for the Missouri jurisdictional sub-account of the Callaway decommissioning trust, after a full hearing, including but not limited to any general rate increase case or excess earnings complaint case, and after considering all facts relevant to such accrual
. rate.
- 17.
The provisions of this Agreement have resulted from numerous discussions/negotiations among the signatory parties and are interdependent. In the event that the Commission does not approve and adopt the terms of this Agreement in total, it shall be void
. and no party hereto shall be bound by, prejudiced, or in any way affected by any of the agreements or provisions hereof unless otherwise provided herein.
- 18.
In the event the Commission accepts the specific tenus of this Agreement, the signatories waive their respective rights: a) to cross-exatnine witnesses pursuant to Section 536.070(2) RSMo; b) to present oral argument and written briefs pursuant to Section 536~080.1 RSMo; and c) to judicial review pursuant to Section 386.510 RSMo. These waivers apply only
. to a Commission Order respecting this Agree:r:nent issued in this proceeding, and does not apply 10
to any matters raised in any subsequent Commission proceeding, or any matters not explicitly addressed by this Agreement.
WHEREFORE, the signatories hereto request that the Commission issue a.1J order:
- 1.
Approving the Unanimous Stipulation And Agreement;
- 2.
Receiving into evidence this Unanimous Stipulation And Agreement, the 2008
. Study, and the Economic Analysis;
- 3.
Finding, pursuant to this Unanimous Stipulation and Agreement, that AmerenUE's retail jurisdiction annual decommissioning expense accruals and trust fund payments shall continue at the current level of $6,486,378;
- 4.
Finding, in order for the Callaway decommissioning fund to continue to utilize*
the sinking fund method of deconnnissioning funding, that the current decommissioning costs for Callaway are included in AmerenUE's current cost of service and are reflected in its current rates for ratemaking purposes;
- 5.
Recognizing that AmerenUE's 2008 Cost Study meets the requirements of 4 CSR 240-3.185(3);
- 6.
Granting AmerenUE variances from the filing requirements of rules 4 CSR 240-3.185(1) and 4 CSR 240-3.185(2) to allow the filings required by those rules to be made as non-case related submissions under the EFIS category, Nuclear Plant Decommissioning Report and directing that AmerenUE or its trustee file, on a prospective basis the quarterly reports required by 4 CSR 240-3.185(1)~ the annual reports required by 4 CSR 240-3.185(2) and the quarterly Nuclear Decommissioning Trust Fund Performance Reports in the Commission's Electronic Filing and Infonnation System (EFIS) as non-case related submissions under the EFIS category, 11
Nuclear Plant Decommissioning Report, for Union Electric Company d/bla *AmerenUE-Investor (Electric), commencing with the next filing due after the effective date of this order; and
- 7.
Approving, pursuant to 4 CSR 240-20.070(4)(C), the use of a jurisdictional demand allocator of98.38%.
lsi Lewis Mills Lewis Mills, # 35275
. Office Of Public Counsel 200 Madison Street, Suite 650 P.O. Box 2230 Jefferson City, MO 65102 opcservi~e(t'2ded.mo.gov 12 Respectfully submitted, lsi Wendy K. Tatro Steven R. Sullivan, # 33102 Sr. Vice President, General COlllSe1 and Secretary Wendy K. Tatro, # 60261 Associate General Counsel Ameren Services Company P.O. Box 66149 St. Louis, MO 63166-6149 ssullivan(~ameren.conl
~iatro(c~ameren.com lsi Nathan Williams Nathan Williams, # 35512 Deputy General Counsel Missouri Public Service Connnission PO Box 360 Jefferson City, MO 65102 nathanwill iruTIsCtilpSC.lTIo.gov
'\\ !
~.
i-I
Certificate of Service I hereby certifY that copies of the foregoing have been mailed or hand-delivered to all counsel of record as shown on the attached service list this 23rd day of April 2009.
fsl.Wendj 1(, q'atro Wendy K. Tatro 13
,---~--~---.~--------."
08/27/2008 I
AmerenUE I
I Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection I
Missouri Jurisdiction I
j--------------------------------------------------------------------------~
1 Current Year:
2 Year Decommissioning Begins:
3 Year Decommissioning Ends:
4 End-Of-Year Fund Balances June 30, 2008 End-Of-Year Fund Balance:
2033 End-Of-Year Fund Balance:
5 Annual Contribution to Fund Current:
Revised:
Effective Date of Revised Annual Contribution Year:
Quarter:
6 Portfolio Return Assumptions Asset Allocation Equities:
Bonds:
Real Return on Bonds:
CPI Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch Out of Equities at End-Of-Year:
7 Investment Management & Trust Fees (Basis Points):
8 Federal & State Tax Assumptions Federal Tax Rate:
Missouri State Income Tax Rate:
Percentage of Federal Taxes Deductible on MO Taxes:
Composite Tax Rate:
2008 2024 2033
~fhl",*81!1
.,.,. After entering all data, manually set this cell U equal to the Final, Ending Balance of Fund, located on "Fund Projections" worksheet!
$6,486,378
$6,486,378 2009 1
15.00 20.0000%
0.0000%
50.0000%
Page 1 of 5
08/27/2008 r---------------------------------------A~;;;_~UE---------------------------------------1 Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction
~ _______________________________________________________________________________________ J 1
Decommissioning Expense Estimates Original, Total Decommissioning Cost Estimate:
Original Estimate Based On:
Current, Total Decommissioning Cost Estimate:
Demand Allocator (Missouri):
MO Jurisdictional, Total Decommissioning Cost Estimate:
Decommissioning Inflation:
$693,906,000 Aug. 2008 TLG Study
$693,907,000 98.38%
$682,665,707 2.742%
Decommissioning Expense Calculation Year TOTAL 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 Aug. 2008 TLG Study Aug. 2008 TLG Study Total Decommissioning Expenses
$693,906,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$13,632,000
$79,435,000
$142,958,000
$133,219,000
$79,170,000
$78,953,000
$60,639,000
$42,131,000
$52,331,000
$ 11,438,000 Decommissioning Expenses
% OF TOTAL 100.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
1.96%
11.45%
20.60%
19.20%
11.41 %
11.38%
8.74%
6.07%
7.54%
1.65%
Missouri Jurisdictional Decommissioning Expenses 2008 I
$682,665,707
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$13,411,181
$78,148,266
$140,642,283
$131,061,041
$77,887,558
$77,674,073
$59,656,734
$41,448,538
$51,483,312
$11,252,721
- of Years of Inflation 0
1 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Inflation Factor At 2.742%
Decommissioning Inflation Rate 1.0000 1.0274 1.0556 1.0845 1.1143 1.1448 1.1762 1.2085 1.2416 1.2756 1.3106 1.3465 1.3835 1.4214 1.4604 1.5004 1.5415 1.5838 1.6272 1.6719 1.7177 1.7648 1.8132 1.8629 1.9140 1.9664 Missouri Jurisdictional Decommissioning Expenses (Inflated $$)
$1,169,334,207
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$20,673,977
$123,772,359
$228,858,763
$219,115,230
$133,787,135
$137,078,599
$108,168,390
$77,214,243
$98,537,603
$22,127,908 Page 2 0[5
08127/2008 r------------------------------------------------------------------------~;;;_~UE------------------------------------------------------------------------l I
Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection i
L ____________________________________________________________________ ~~~~~!lJ~~~!~!~~ ____________________________________________________________________ J Cu rrent Year:
2008 Year Decommissioning Begins:
Year Decommissioning Ends:
June 30, 2008 End-Of-Qtr Fund Balancel
$264,089,0931 2033 EOY Fund Balance:
$0 Current Contribution:
Revised contribution:
Year TOTAL June 30, 2008 Beginning-of-Year Balance 2008 264,089,093 $
_._.. ~~9~ ____. __. ____ ~~~~~!l_3 2010 303,788,532 2011 332,548,4 19 2012 363,394,681
$6,486,378
$ 6,486,378 Annual Contributions To Fund 107,025,237 3,243,189 $
6,486,378 6,486,378 6,486,378 6,486,378 Equities:
Bonds:
Real Return on Bonds:
CPI Inflation:
Norrrinal Return on Bonds:
Equity Prerrrium over Bonds:
Norrrin al Return on Equities:
Weighted Average Return:
Switch Out of Equities at EOY:
Management & Trust Fees: (BP)
.( ** :i **
T....-.
Pre Tax & Fee Income 1,017,631,309 12,255,905 $
25,850,027 28,323,676 30,976,776 Investment Manageme nt
& Trust Fees 19,856,463 203,879 $
439,7 13 481,790 526,920 33,822,344 575,324 2013 396,478,675 6,486,378 36,874,342 627,239 65.00%
Federal Tax Rate:
35.00%
Missouri State Income Tax Rate:
3.90%
Percentage of Federal Taxes Deductible on MO Taxes:
2.40%
6.30%
4.50%
10.80%
9.225%
Composite Taxe Rate:
Original, Total Decomrrrissioning Cost Est:
Current, Total Decomrrrissioning Cost Est:
Demand Allocator (Missouri):
Aug. 2008 TLG Study 2008 2022 MO Jurisdictional, Total Decommissioning Cost Estimate:
Decomrrrissioning Inflation Assumption:
15.001 Federal & State Income Taxes 199,554,969 After Tax & Fee Income 798,219,877 2,410,405 $
9,641,621 $
5,082,063 20,328,251 5,568,377
--22,273,509 6,089,971 24,359,885 6,649,404 26,597,6 16 7,249,421 28,997,683 Missouri Jurisdictional Decommissioning Ex penses (Inflated $ $)
1,169,334,207 End-Of-Year Balance
$264,089,093 276,973,903 303,788,532
332,548,419 363,394,681 396,478,675 431,962,736
2Ci14------------431,962,7-3'6------ 6,486,378
--- 40, 147,i47-----~:920 -----
7,892,965 31,571,862 470,020,976 2015 2016 2017 470,020,976 510,840,137 554,620,510 6,486,378 6,486,378 6,486,378 43,658,619 742,640 47,424,187 806,693 51,462,926 875,393 8,583,196 34,332,783 9,323,499 37,293,995 10,117,507 40,470,027 510,840,137 554,620,510 601,576,915
____. __ ~O'_!? ___.. ____. ___________.?Q~~~.!.~~ ________. ____ ~4:~~~?~_. ________. __
~?-'794,~?.? _________ ~<?~ ________ 10,969, 1}_~ ____
4:~~76,'1:..~ ____________________ _ ?...?_~~~_,_~_?.._
2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 651,939,755 705,956,151 763,89~~
826,029,016 892,674,656 943,206,327 975,040,079 896,160,374 705,733,227 515,927,302 6,486,378 6,486,378 6,486,378 6,486,378 6,486,378 6,486,378 60,440,627 65,423,639
___ ~~8,14 2 76,500,361 56,442,824 58,975,089 57,528,696 49,249,053 37,559,064 28,289,125 1,028,105 1,112,867 1,203,778 1,301,284 1,386,209 1,448,400 1,412,877 1,209,533 922,433 694,767 11,882,504 47,530,017 12,862,154 51,448,6 18 13,912,873 55,651,492 15,039,815 60,159,262 11,011,323 44,045,292 11,505,338 46,021,351 11,223,164 44,892,655 9,607,904 38,431,6 15 7,327,326 29,309,305 5,518,872 22,075,486 20,673,977 123,772,359 228,858,763 219,115,230 133,787,135 705,956,15 1 763,891,147 826,029,016 892,674,656 943,206,327 975,040,079 896,160,374 705,733,227 515,927,302 404,215,653 2029 404,2 15,653 2 1,147,610 519,375 4,125,647 16,502,588 137,078,599 283,639,642
_____ 3Q~~ __________________
.3~~~39,~~~ __ _________________________ ~~~~~
_____ ~~
180 ____ ~ 1,36_~
__..2~.!.285,4~ _____
.r~~!l.!.~.9 ____ ~~! 756, :.~
2031 186,756,703 2032 116,825,820
_____.3.2.?_~ ______________ 3 1, 609,468 9,333,424 4,256,092 664,367 229,224 104,528 16,317 1,820,840 830,313
____ 129,610 7,283,359 3,321,252
______ 518,441 77,2 14,243 98,537,603 22,127,908 _
116,825,820 21,609,468
_!<2L 20.00%
0.00%
50.00%
20.0000%
$693,906,000
$693,907,000 98.38%
$ 682,665,707 2.742%
Page 3 or5
08/2712008 i
A~re~
I I
Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction
~------------------------------------------------------------------------~
1 Portfolio Return Assumptions Equity Allocation:
Bond Allocation:
Real Return on Bonds:
CPI Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch out of Equities at End-Of-Year:
2 Decommissioning Expense Estimates Decommissioning Inflation:
Revised Annual Contribution:
Contribution Boundary Estimates Optimistic Estimate Expected Estimate Conservative Estimate 3.450%1 2.742%
2.044%
Optimistic Expected Conservative
$6,486,378 1
$6,486,378 1
$6,486,378 1
$6,486,378
$6,486,378
$6,486,378 Page 4 of5
AmerenUE Callaway Plant Tax-Qualified Nuclear Decommissioning Trust Fund Projection Missouri Jurisdiction Zone of Reasonableness Analysis Contribution Boundary Estimates 08/27/2008 Portfolio Return Assumptions Optimistic Estimate Expected Estimate Conservative Estimate Equity Allocation:
Bond Allocation:
Real Return on Bonds:
cpr Inflation:
Nominal Return on Bonds:
Equity Premium over Bonds:
Nominal Return on Equities:
Weighted Average Return:
Switch out of Equities at End-Of-Year:
Decommissioninl! Inflation:
65.00%
65.00%
65.00%
35.00%
35.00%
35.00%
4.13%
3.90%
3.65%
2.75%
2.40%
2.05%
6.88%
6.30%
5.70%
5.00%
4.50%
4.00%
11.88%
10.80%
9.70%
10.13%
9.23%
8.30%
2023 2022 2021 Required Contribution Amounts Optimistic Estimate Expected EstImate Conservative EstImate
.............................................................................................................................. ~:!~.~(~........ ~................................ J~.??~~?~.?!... ~.................................... ~? ~~~. !.~.?~g!.... ~................................... Q.~~~.?:.~~.?2.
tg.9.~....... J................................
J?!§.?~.!.!.??.)... ~....................................
(2.1~}.~1???.2.. ~......................................... }.~g.'.?§.§...
1.:.? ?.~........ ~....................................<§.!~.??&?..~L~....................................
(?l~.??l?.~D.. ~......................................!. ? ?~.?&~}...
1.50%
(5,266,435) $
(1,206,8 15) $
3,025,773
- :: ::::: ::::::::: :: ::::: :::::::: :::::: ::: ::: :: :: :: : : ::: : :::::::: : ::::: : : ::: ::: :::::::::: : : :: :: :: : : :: : ::::: ::: : :::::::: :::: : : :C?:~%: ::: : : ::~:::::::::: : ::: :: : : :::::::::::::::::~~:;?':?'§';Q~:~i. I::: ::: ::: : : ::: : : : :: : ::: : ::: : : : : ::: : :: :jQ:?;:i.~I ::~: :: : ::::::::: :::::::::: ::::::: : ::: :: : :~;:~?:?;:~?I:
............................................................................................................................. ?:g.~~........ ~................................... ~~.,~.~~~7?~!...
~......................................
~.~~.!.?:~.~.?.... ~...................................... ?:.!.?~:.~7?..
~:.??.~........ ~................................. JL~.?2.1~.?.U §.................................... }1 ~.~.~1}.~.1.... ~...................................... ? 1.?~.?.'.?.?.?....
2.50%
23 1,563 4,846,259 9,667,764
~:::~~::::::~~::: ::: :::::: : ::::::
- :::::::::: til~:::] :: ~::;:~::;:-:;:::::Ulj:iil] :::::::: :: : :::::::: ~::]:n~:,~i[l : ::::; ::: :: :jj:;.I~:llr
}:.?.9.~....... t....................................§.1~.1.~1.!.9.?... ~................................. J?1.~.?2.19.??....
~.................................... ~.??~§.9..'.?~.~...
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$0 3.75%
8,697,277 14,168,948 19,900,114 Missouri Jurisdiction Required Annual Contribution AmerenUE Callaway Plant Tax Qualified Nuclear Decommissioning Trust Fund
($5,000,000) __ =--.:;::...-----==:::*-~=-------------------"------I
($10,000,000) -+-----------------------------------1
($15,000,000) -' ___________________
.....o.-______
~_~~
......:-___...I 0.75% 1.00% 1.25% 1.50% 1.75% 2.00% 2.25% 2.50% 2.75% 3.00% 3.25% 3.50% 3.75% 4.00% 4.25%
Decommissioning Inflation
-+- Optimistic Estimate ___ Expected Estimate -.- Conservative Estimate -*- Current Contribution ___ Proposed Contribution Page 5 of 5
ULNRC-05796 Page 1 of 4 Order Approving Stipulation and Agreement
Application of Union Electric Company d/b/a AmerenUE for Approval of Decommissioning Cost Estimate and Funding Level of Nuclear Decommissioning Trust Fund
)
)
)
)
STATE OF MISSOURI PUBLIC SERVICE COMMISSION At a session of the Public Service Commission held at its office in Jefferson City on the 29th day of April, 2009.
File No. EO-2009-0081 ORDER APPROVING STIPULATION AND AGREEMENT Issue Date April 29, 2009 Effective Date: May 9, 2009 This order approves the Unanimous Stipulation and Agreement between the Union Electric Company, d/b/a AmerenUE, Staff of the Commission and the Office of the Public Counsel regarding AmerenUE's funding for the decommissioning of its Callaway nuclear power plant.
Commission rule 4 CSR 240-3.185(3) states, in part, that:
On or before September 1, 1990, and every three years after that, utilities with decommissioning trust funds shall perform and file with the commission costs studies detailing the utilities' latest cost estimates for decommissioning their nuclear generating unit(s) along with the funding levels necessary to defray these decommissioning costs. These studies shall be filed along with appropriate tariff(s) effectuating the change in rates necessary to accomplish the funding required.
On September 2, 2008, AmerenUE filed an application requesting that the Missouri Public Service Commission approve its cost estimate and current funding level of
$6,486,378 of its nuclear decommissioning trust fund. Ameren also requests that the Commission specifically find that the annual funding level contributed to the
decommissioning trust fund is included in Ameren's current cost of service for rate-making purposes.
On April 23, 2009, the parties filed a Unanimous Stipulation and Agreement and requests that the Commission:
Find that Ameren's retail jurisdiction annual decommissioning expense accrual and trust fund payments shall continue at the current level of $6,486,378.
Find, in order for the Callaway decommissioning fund to continue to utilize the sinking fund method of decommissioning funding, that the current decommis-sioning costs for Callaway are included in Ameren's current cost of service and are reflected in its current rates for ratemaking purposes.
Recognize that Ameren's 2008 Cost Study meets the requirements of 4 CSR 240-3.185 (3).
Grant Ameren variances from the filing requirements of rules 4 CSR 240-3.185 (1) and (2) to allow the filings required by those rules to be made as non-case related submissions under the EFIS category, Nuclear Plant Decommissioning Report for Union Electric Company d/b/a AmerenUE-lnvestor (Electric) and directing that Ameren file, on a prospective basis the quarterly reports required by 4 CSR 240-3.185 (1), the annual report required by 4 CSR 240.3.185 (2) and the quarterly Nuclear Decommissioning Trust Fund Performance Reports in the Commission's EFIS as non-case related submissions, commencing with the next filing due after the effective date of this order.
Approve, pursuant to 4 CSR 240-20.070(4)(C), the use of a jurisdictional demand allocator of 98.38%.
The Commission has reviewed the Unanimous Stipulation and Agreement and will approve it. In doing so, the Commission finds that Ameren's retail jurisdictional annual decommissioning expense accruals and trust fund payments shall continue at the current level of $6,486,378. The Commission further finds that the current decommissioning costs for Callaway are included in Ameren's current cost of service and are reflected in its current rates for ratemaking purposes. The Commission also recognizes that Ameren's Costs Study meets the requirements of 4 CSR 240-2.185(3).
2
THE COMMISSION ORDERS THAT:
- 1.
The Unanimous Stipulation and Agreement filed by Union E!ectric Company, d/b/a AmerenUE, Staff of the Commission and the Office of the Public Counsel regarding AmerenUE's funding for the decommissioning of its Callaway nuclear power plant is approved.
- 2.
The parties shall comply with the terms of the Unanimous Stipulation and Agreement.
- 3.
Union Electric Company, d/b/a AmerenUE is granted a variance from the requirements of 4 CSR 240-3.185(1) and (2) to file reports as case related filing and instead shall file those reports as non-case related submissions.
- 4.
The use of a jurisdictional demand allocator of 98.38%) is approved.
- 5.
This order shall become effective on May 9, 2009.
- 6.
This case shall be closed on May 10,2009.
(SEAL)
Clayton, Chm., Murray, Davis, Jarrett, and Gunn, CC., concur.
Jones, Senior Regulatory Law Judge 3
BY THE COMMISSION Colleen M. Dale Secretary
ULNRC-05796 Page 1 of 2 Statement of Net Assets Available for Benefits
THE BANK OF NE\\V YORK MELLON~
TRDA56 A56G28172000 ANNUAL A56 G281720 AMEREN OVERALL COMBINED AMEREN OVERALL COMBINED ASSETS INVESTMENTS:
FINAL 083648 STATEMENT OF NET ASSETS AVAILABLE FOR BENEFITS 31 DECEMBER 2010 INVESTMENTS AT IDENTIFIED COST UNREALIZED APPREC IATION-I NVEST 245,666,088.91 89,860,121.75 2010-12-31 CYCLE 3 12:29:46 RUN DATE: 12-JAN-11 PAGE:
1 NA100 335,526,210.66 RECEIVABLES:
INTEREST DIVIDENDS LIABILITIES NET ASSETS TOTAL ASSETS TOTAL LIABILITIES 1,033,455.62 261,690.49 1,295,146.11 336,821,356.77 0.00 336,821,356.77
ULNRC-05796 Page 1 of 116 2008 Decommissioning Cost Study for the Callaway Plant
Document A22-1599-002, Rev. 0 DECOMMISSIONING COST ANALYSIS for the CALLAWAY PLANT prepared for AmerenUE p repared by TLG Services, Inc.
Bridgewater, Connecticut August 2008 Callaway Plant Decommissioning Cost Analysis Project Manager Proj ect Engineer Technical Manager Quality Assurance Manager TLG Services, Inc.
Document A22-1599-002, Rev. 0 Page ii of xvi APPROVALS c{/~~~(}
William A. Cloutier, J/.
ThOlllas /.Garrett
~~
ranClS W. Se ore 27 Aut" 08 Date DatJ
"@7/0lf Date
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page iii of xvi TLG Services, Inc.
TABLE OF CONTENTS SECTION PAGE EXECUTIVE
SUMMARY
...................................................................................vii-xvi
- 1.
INTRODUCTION.....................................................................................................1-1 1.1 Objectives of Study...........................................................................................1-1 1.2 Site Description.................................................................................................1-1 1.3 Regulatory Guidance........................................................................................1-2 1.3.1 Nuclear Waste Policy Act......................................................................1-4 1.3.2 Low-Level Radioactive Waste Acts......................................................1-5 1.3.3 Radiological Criteria for License Termination....................................1-6
- 2.
DECOMMISSIONING ALTERNATIVES..............................................................2-1 2.1 DECON..............................................................................................................2-1 2.1.1 Period 1 - Preparations.........................................................................2-2 2.1.2 Period 2 - Decommissioning Operations..............................................2-4 2.1.3 Period 3 - Site Restoration....................................................................2-7 2.2 SAFSTOR..........................................................................................................2-8 2.2.1 Period 1 - Preparations.........................................................................2-8 2.2.2 Period 2 - Dormancy..............................................................................2-9 2.2.3 Periods 3 and 4 - Delayed Decommissioning.....................................2-10 2.2.4 Period 5 - Site Restoration..................................................................2-11
- 3.
COST ESTIMATE.....................................................................................................3-1 3.1 Basis of Estimate..............................................................................................3-1 3.2 Methodology......................................................................................................3-1 3.3 Financial Components of the Cost Model.......................................................3-3 3.3.1 Contingency...........................................................................................3-3 3.3.2 Financial Risk........................................................................................3-5 3.4 Site-Specific Considerations.............................................................................3-6 3.4.1 Spent Fuel Management.......................................................................3-6 3.4.2 Reactor Vessel and Internal Components...........................................3-8 3.4.3 Primary System Components...............................................................3-9 3.4.4 Retired Components............................................................................3-10 3.4.5 Main Turbine and Condenser.............................................................3-10 3.4.6 Transportation Methods.....................................................................3-10 3.4.7 Low-Level Radioactive Waste Disposal.............................................3-11 3.4.8 Site Conditions Following Decommissioning....................................3-12
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page iv of xvi TLG Services, Inc.
TABLE OF CONTENTS (continued)
SECTION PAGE 3.5 Assumptions....................................................................................................3-13 3.5.1 Estimating Basis.................................................................................3-13 3.5.2 Labor Costs..........................................................................................3-14 3.5.3 Design Conditions................................................................................3-14 3.5.4 General.................................................................................................3-15 3.6 Cost Estimate Summary...............................................................................3-17
- 4.
SCHEDULE ESTIMATE........................................................................................4-1 4.1 Schedule Estimate Assumptions.....................................................................4-1 4.2 Project Schedule................................................................................................4-2
- 5. RADIOACTIVE WASTES........................................................................................5-1
- 6.
RESULTS.................................................................................................................6-1
- 7.
REFERENCES..........................................................................................................7-1 TABLES DECON Cost Summary, Decommissioning Cost Elements............................ xv SAFSTOR Cost Summary, Decommissioning Cost Elements....................... xvi 3.1 DECON Alternative, Schedule of Total Annual Expenditures.................... 3-18 3.1a DECON Alternative, Schedule of License Termination Expenditures....... 3-19 3.1b DECON Alternative, Schedule of Spent Fuel Management Expenditures. 3-20 3.1c DECON Alternative, Schedule of Site Restoration Expenditures............... 3-21 3.2 SAFSTOR Alternative, Schedule of Total Annual Expenditures................ 3-22 3.2a SAFSTOR Alternative, Schedule of License Termination Expenditures.... 3-24 3.2b SAFSTOR Alternative, Schd. of Spent Fuel Management Expenditures... 3-26 3.2c SAFSTOR Alternative, Schedule of Site Restoration Expenditures........... 3-28
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page v of xvi TLG Services, Inc.
TABLE OF CONTENTS (continued)
SECTION PAGE TABLES 5.1 DECON Alternative, Decommissioning Waste Summary............................. 5-3 5.2 SAFSTOR Alternative, Decommissioning Waste Summary.......................... 5-4 6.1 DECON Alternative, Summary of Decommissioning Cost Elements............ 6-4 6.2 SAFSTOR Alternative, Summary of Decommissioning Cost Elements........ 6-5 FIGURES 4.1 Activity Schedule.............................................................................................. 4-3 4.2 Decommissioning Timelines............................................................................ 4-4 APPENDICES A.
Unit Cost Factor Development............................................................................. A-1 B.
Unit Cost Factor Listing...................................................................................... B-1 C.
Detailed Cost Analysis, DECON.......................................................................... C-1 D.
Detailed Cost Analysis, SAFSTOR...................................................................... D-1
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page vi of xvi TLG Services, Inc.
REVISION LOG No.
CRA No.
Date Item Revised Reason for Revision 0
08-27-08 Original Issue
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page vii of xvi TLG Services, Inc.
EXECUTIVE
SUMMARY
This report presents estimates of the cost to decommission the Callaway Plant (Callaway) for the selected decommissioning scenarios following the scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an evaluation prepared in 2005,[1] updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The current estimates are designed to provide AmerenUE with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear unit.
The currently projected cost to decommission the station, assuming the DECON alternative, is estimated at $693.9 million, as reported in 2008 dollars. An estimate for the SAFSTOR alternative is also provided.
The estimates are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements.
The estimates incorporate a
minimum cooling period of approximately 51/2 years for the spent fuel that resides in the storage pool when operations cease. During this period, it is assumed the U.S. Department of Energy (DOE) will complete the transfer of the residual spent fuel inventory to a DOE repository. The estimates also include the dismantling of non-essential structures and limited restoration of the site.
Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material so that the license can be terminated. The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.[2] 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.
1 Decommissioning Cost Analysis for the Callaway Plant, Document No. A22-1534-002, Rev. 0, TLG Services, Inc., August 2005 2
U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page viii of xvi TLG Services, Inc.
DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations."[3]
SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[4]
Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.
ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[5] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.
The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material. In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations, however, rulemaking has been deferred pending the completion of additional research studies, for example, on engineered barriers.
In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[6] The amendments allow for greater public participation and better define the transition process from operations to decommissioning.
3 Ibid. Page FR24022, Column 3.
4 Ibid.
5 Ibid. Page FR24023, Column 2.
6 U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, (p 39278 et seq.), July 29, 1996.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page ix of xvi TLG Services, Inc.
Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. The format and content of the estimates is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.[7]
Methodology The methodology used to develop the estimates described within this document follows the basic approach originally presented in the cost estimating guidelines[8] developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning.
The estimates also reflect lessons learned from TLGs involvement in the Shippingport Station decommissioning, completed in 1989, and 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, Connecticut Yankee and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and technical challenges of decommissioning commercial nuclear units.
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.
Contingency 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 7
Standard Format and Content of Decommissioning Cost Estimates of Decommissioning Cost Estimates for Nuclear Power Reactors, Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 8
T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Page x of xvi TLG Services, Inc.
unforeseeable events which will increase costs are likely to occur.[9] The cost elements in the estimates are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.
Contingency funds are expected to be fully expended throughout the program. As such, inclusion of contingency is necessary 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 classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. With the passage of the Low-Level Radioactive Waste Policy Act in 1980,[10] and its Amendments of 1985,[11] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.
Until recently, there were two facilities available to AmerenUE for the disposal of low-level radioactive waste generated by Callaway. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal.
For the purpose of this analysis, the EnergySolutions facility is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [12]).
EnergySolutions does not have a license to dispose of the more highly radioactive waste (Classes B and C), for example, generated in the dismantling of the reactor vessel. As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility.
9 Project and Cost Engineers Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239.
10 Low-Level Radioactive Waste Policy Act of 1980, Public Law 96-573, 1980.
11 Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, 1986.
12 U.S. Code of Federal Regulations, Title 10, Part 61, Licensing Requirements for Land Disposal of Radioactive Waste
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The dismantling of the components residing closest to the reactor core generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.
For purposes of this study, GTCC is packaged in the same canisters used for spent fuel. The GTCC material is shipped directly to a DOE facility, as it is generated.
A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates for Callaway reflect the savings from waste recovery/volume reduction.
High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act[13] (NWPA) in 1982, assigning the federal governments long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities spent fuel and high-level radioactive waste and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.
Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to accept any spent fuel or high level waste, as required by the NWPA and utility contracts. Delays continue and, as a 13 Nuclear Waste Policy Act of 1982 and Amendments, DOEs Office of Civilian Radioactive Management, 1982.
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result, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOEs breach of contract.
Operation of DOEs yet-to-be constructed repository is contingent upon the review and approval of the facilitys license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application to the NRC on June 3, 2008, seeking authorization to construct the repository at Yucca Mountain, Nevada.
Assuming a timely review, and adequate funding, the DOE expects that receipt of fuel could begin by 2020.[14]
It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor site until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[15] This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimates, for example, associated with the isolation and continued operation of the spent fuel pool.
At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the following 51/2 years the assemblies are packaged into multipurpose canisters for transfer to the DOE. It is assumed that this period provides the necessary cooling for the final core to meet the transportation system requirements for decay heat.
DOEs contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. For estimating purposes, AmerenUE has assumed that all spent fuel will be removed to the DOE high-level waste repository within 51/2 years after shutdown. Interim storage of the fuel, until the DOE has completed the transfer, will be in the pool located in the Fuel Building. The pool will be isolated, allowing AmerenUE to proceed with decommissioning (or safe-storage preparations) in the shortest time possible.
Site Restoration Prompt dismantling of site structures (once the facilities are decontaminated) 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 14 Testimony of Edward Sproat, Director, Office of Civilian Radioactive Waste Management, before a U.S. House of Representatives subcommittee on the status of Yucca Mountain, July 15, 2008.
15 U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses.
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work force already mobilized on site is more efficient than if the process is deferred.
Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force.
Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized.
Summary The costs to decommission Callaway assumes the removal of all contaminated and activated plant components and structural materials such that the owner may then have unrestricted use of the site with no further requirements for an operating license.
Low-level radioactive waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or to a controlled disposal facility.
Decommissioning is accomplished within the 60-year period required by current NRC regulations. Regardless of the timing of the decommissioning activities, the estimates assume the eventual removal of all the contaminated and activated plant components and structural materials, such that the facility operator may then have unrestricted use of the site with no further requirement for an operating license.
The decommissioning scenarios are described in Section 2. The assumptions are presented in Section 3, along with schedules of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendices C and D. The major cost components are also identified in the cost summary provided at the end of this section.
The cost elements in the estimates are assigned to one of three subcategories: NRC License Termination, Spent Fuel Management, and Site Restoration. The subcategory NRC License Termination is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e.,
10 CFR Part 50.75). The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.
The Spent Fuel Management subcategory contains costs associated with the transfer of the spent fuel to the DOE as well as the operation of the spent fuel pool until such time that the transfer is complete.
Site Restoration is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities
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that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.
It should be noted that the costs assigned to these subcategories are allocations.
Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.
As noted within this document, the estimates were developed and costs are presented in 2008 dollars. As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the reactor or during the decommissioning period.
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DECON COST
SUMMARY
DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)
Cost Element Cost Decontamination 17,593 Removal 146,429 Packaging 16,531 Transportation 12,505 Waste Disposal 75,885 Off-site Waste Processing 22,814 Program Management [1]
297,742 Corporate Allocations 10,098 Spent Fuel Pool Isolation 10,819 Spent Fuel Management [2]
34,647 Insurance and Regulatory Fees 11,469 Energy 9,144 Characterization and Licensing Surveys 19,093 Property Taxes 2,780 Miscellaneous Equipment 6,359 Total [3]
693,907 Cost Element License Termination 572,236 Spent Fuel Management 34,647 Site Restoration 87,024 Total [3]
693,907
[1]
Includes engineering and security costs
[2] Direct costs only. Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
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SAFSTOR COST
SUMMARY
DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)
Cost Element Costs Decontamination 15,473 Removal 146,469 Packaging 13,753 Transportation 9,747 Waste Disposal 53,525 Off-site Waste Processing 25,137 Program Management [1]
476,544 Corporate Allocations 13,464 Spent Fuel Pool Isolation 10,819 Spent Fuel Management [2]
34,647 Insurance and Regulatory Fees 51,122 Energy 18,872 Characterization and Licensing Surveys 20,627 Property Taxes 20,296 Miscellaneous Equipment 19,074 Total [3]
929,568 Cost Element License Termination 774,447 Spent Fuel Management [4]
68,084 Site Restoration 87,037 Total [3]
929,568
[1]
Includes engineering and security costs
[2] Direct costs only. Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
[4] Includes percentage of Period 2a (dormancy) plant operating costs until spent fuel pool is emptied, in addition to the direct costs.
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- 1. INTRODUCTION This report presents estimates of the costs to decommission the Callaway Plant, (Callaway) following a scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,[1]* updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The supporting analysis was designed to provide AmerenUE with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.
1.1 OBJECTIVES OF STUDY The objectives of this study were to prepare comprehensive estimates of the costs to decommission Callaway, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.
An operating license was issued for Callaway in 1984. For the purposes of this study, the final shutdown date (license expiration) is projected to be October of 2024, based upon a 40 year operating life. This date was used as input to scheduling the decommissioning activities.
1.2 SITE DESCRIPTION The nuclear unit is located in Callaway County, Missouri, approximately 80 miles west of the St. Louis metropolitan area. The nearest population center is Jefferson City, 25 miles west-southwest of the plant site. The station is an 1,171 MWe (net design electrical rating) pressurized water reactor with supporting facilities.
Westinghouse Electric Company designed the nuclear steam supply system (NSSS). The NSSS consists of a pressurized water reactor with four independent primary coolant loops, each of which contains a reactor coolant pump and a steam generator. An electrically heated pressurizer and connecting piping complete the system. The NSSS is rated at a thermal power level of 3,579 MWt (3,565 MWt reactor core plus 14 MWt for reactor coolant pumps), with a corresponding turbine-generator gross output of 1284 MWe.
- References provided in Section 7 of the document
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The system is housed within a containment structure, a pre-stressed, post-tensioned concrete structure with cylindrical wall, a hemispherical dome, and a flat foundation slab. The wall and dome form a pre-stressed post-tensioned system. The inside surface of the structure is covered with a carbon steel liner, providing a leak tight membrane.
A power conversion system converts heat produced in the reactor to electrical energy. This system converts the thermal energy of the steam into mechanical shaft power and then into electrical energy. The turbine-generator is a tandem-compound, six-flow, four element, 1800-rpm unit. The unit consists of one high pressure and three low-pressure turbine elements driving a directly coupled generator. The turbine is operated in a closed feedwater cycle that condenses the steam; the feedwater is returned to the steam generators. Heat rejected in the main condensers is removed by the circulating water system.
The circulating water system supplies cooling water to the main condenser, condensing the steam exhausted from the turbine. Cooling for the condenser circulating water system is supplied by a large natural draft cooling tower.
Makeup water for the cooling tower is drawn from the Missouri River.
1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[2] This rule set forth financial criteria for decommissioning licensed nuclear power facilities.
The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose.
Subsequent to the rule, the NRC issued Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors,[3] which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.
The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plants systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations.
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The rule also placed limits on the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of decommissioning. At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination.
The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with rulemaking permitting the controlled release of a site,[4] the NRC has re-evaluated this alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[5] However, the NRCs staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.
In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.[6] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facilitys operating licensed life.
Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process from operations to decommissioning.
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Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel.
Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and
- schedule, and an estimate of expected costs.
Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which will include a license termination plan (LTP).
1.3.1 Nuclear Waste Policy Act Congress passed the Nuclear Waste Policy Act[7] (NWPA) in 1982, assigning the federal governments long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the U.S. Department of Energy (DOE). The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities spent fuel and high-level radioactive waste and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.
Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to accept any spent fuel or high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOEs breach of contract.
Operation of DOEs yet-to-be constructed repository is contingent upon the review and approval of the facilitys license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application to the NRC on June 3, 2008, seeking authorization to construct the repository at Yucca Mountain, Nevada. Assuming a timely review, and adequate funding, the DOE expects that receipt of fuel could begin by 2020.[8]
It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the
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NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).[9] This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool.
At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the following 51/2 years the assemblies are packaged into multipurpose canisters (provided by the DOE) for transfer to the DOE. It is assumed that this period provides the necessary cooling for the final core to meet the transport system requirements for decay heat.
For estimating purposes, AmerenUE has assumed that all spent fuel will be removed to a DOE high-level waste repository within 51/2 years after shutdown. Interim storage of the fuel, until the DOE has completed the transfer, will be in the storage pool located in the Fuel Building. The pool will be isolated, allowing AmerenUE to proceed with decommissioning (or safe-storage preparations) in the shortest time possible.
1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. With the passage of the Low-Level Radioactive Waste Policy Act in 1980,[10] and its Amendments of 1985,[11] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.
Until recently, there were two facilities available to AmerenUE for the disposal of low-level radioactive waste generated by Callaway. As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of the states of Connecticut, New Jersey and South Carolina). This leaves the facility in Clive, Utah, operated by EnergySolutions, as the only available destination for low-level radioactive waste requiring controlled disposal.
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For the purpose of this analysis, the EnergySolutions facility is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A[12]). EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C), for example, generated in the dismantling of the reactor vessel. As a proxy, the disposal cost for this material is based upon the last published rate schedule for non-compact waste for the Barnwell facility.
The dismantling of the components residing closest to the reactor core generates radioactive waste considered unsuitable for shallow land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste.
However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.
For purposes of this study, GTCC is packaged in the same canisters used for spent fuel. The GTCC material is shipped directly to a DOE facility as it is generated.
A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates for Callaway reflect the savings from waste recovery/volume reduction.
1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, Radiological Criteria for License Termination,[13] amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use.
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The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).
The decommissioning estimates assume that the Callaway site will be remediated to a residual level consistent with the NRC-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).[14]
An additional and separate limit of 4 millirem per year, as defined in 40 CFR §141.16, is applied to drinking water.[15]
On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU)[16] provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.
The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.
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- 2. DECOMMISSIONING ALTERNATIVES Detailed cost estimates were developed to decommission the Callaway nuclear unit for the approved decommissioning alternatives: DECON and SAFSTOR. Although the alternatives differ with respect to technique, process, cost, and schedule, they attain the same result: the ultimate release of the site for unrestricted use.
The following sections describe the basic activities associated with each alternative.
Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e., engineering and planning at the time of decommissioning.
The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e., power production) to facility de-activation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee is then prohibited from reactor operation.
The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimates developed for Callaway are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures.
2.1 DECON The DECON alternative, as defined by the NRC, is "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations." This study does not address the cost to dispose of the spent fuel residing at the site; such costs are funded through a surcharge on electrical generation. However, the study does estimate the costs incurred with the interim on-site storage of the fuel pending shipment by the DOE to an off-site disposal facility.
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2.1.1 Period 1 - Preparations In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a staffing transition plan, the organization required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, a
characterization of the facility and major components, and the development of the PSDAR.
Engineering and Planning The PSDAR, required within two years of the notice to cease operations, provides a description of the licensees planned decommissioning activities, a timetable, and the associated financial requirements of the intended decommissioning program. Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local hearing to be held in the vicinity of the reactor site. Ninety days following submittal and NRC receipt of the PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR §50.59 procedure, i.e., without specific NRC approval. Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR §61. Major components are further defined as comprising the reactor vessel and internals, large bore reactor coolant system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the §50.59 process in decommissioning. The proposed activity must not:
- foreclose release of the site for possible unrestricted use,
- significantly increase decommissioning costs,
- cause any significant environmental impact, or
- violate the terms of the licensees existing license.
Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations. The environmental impact associated with the planned decommissioning activities is also considered.
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Typically, a licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements.
In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report.
The decommissioning program outlined in the PSDAR will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR §20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the PSDAR, activity specifications, cost-benefit and safety analyses, work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities.
Site Preparations Following final plant shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:
- Characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and primary shield cores.
- Isolation of the spent fuel storage pool and fuel handling systems, such that decommissioning operations can commence on the balance of the plant. The pool will remain operational for approximately 51/2 years following the cessation of operations before the inventory resident at shutdown can be transferred to the DOE.
- Specification of transport and disposal requirements for activated materials and/or hazardous materials, including shielding and waste stabilization.
- Development of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety.
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2.1.2 Period 2 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR §50 operating license. Significant decommissioning activities in this phase include:
- Construction of temporary facilities and/or modification of existing facilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.
- Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on-and off-site) to facilitate hauling and transport. Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction.
- Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.
- Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages for the disposition of low-level radioactive waste.
- Decontamination of components and piping systems as required to control (minimize) worker exposure.
- Removal of piping and components no longer essential to support decommissioning operations.
- Removal of control rod drive housings and the head service structure from the reactor vessel head. Segmentation of the vessel closure head.
- Removal and segmentation of the upper internals assemblies.
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.
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- Disassembly and segmentation of the remaining reactor internals, including the core shroud and lower core support assembly. Some material is expected to exceed Class C disposal requirements. As such, the segments will be packaged in modified 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 activated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated cubicles necessary for access and component extraction are removed.
- Removal of the steam generators and pressurizer for material recovery and controlled disposal. The generators will be moved to an on-site processing center, the steam domes removed and the internal components segregated for recycling. The lower shell and tube bundle will be packaged for direct disposal. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized, e.g.,
with grout. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations. The pressurizer is disposed of intact.
At least two years prior to the anticipated date of license termination, an LTP is required. Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local 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:
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- Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).
- Removal of the steel liners from refueling canal, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/ contaminated concrete.
- Surveys of the decontaminated areas of the containment structure.
- Remediation and removal of the contaminated equipment and material from the Fuel Building and any other contaminated facility.
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 and components (both clean and contaminated) located within these buildings. This activity facilitates surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.
- Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.
Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).[17] 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.
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The NRC will terminate the operating license if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.
2.1.3 Period 3 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures.
Although performed in a controlled, safe manner, blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the reactor, fuel handling, and radioactive waste buildings. Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.
Prompt dismantling of site structures is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.
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.
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Non-contaminated concrete rubble produced by demolition activities is processed to remove reinforcing steel and miscellaneous embedments.
The processed material is then used on site to backfill foundation voids.
Excess non-contaminated materials are trucked to an off-site area for disposal as construction debris.
2.2 SAFSTOR The NRC defines SAFSTOR as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use." The facility is left intact (during the dormancy period), with structures maintained in a sound condition. Systems that are not required to support the spent fuel pool or site surveillance and security are drained, de-energized, and secured. Minimal cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed. Access to contaminated areas is secured to provide controlled access for inspection and maintenance.
The engineering and planning requirements are similar to those for the DECON alternative, although a shorter time period is expected for these activities due to the more limited work scope. Site preparations are also similar to those for the DECON alternative. However, with the exception of the required radiation surveys and site characterizations, the mobilization and preparation of site facilities is less extensive.
2.2.1 Period 1 - Preparations Preparations for long-term storage include the planning for permanent defueling of the reactor, revision of technical specifications appropriate to the operating conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.
The process of placing the plant in safe-storage includes, but is not limited to, the following activities:
- Isolation of the spent fuel storage services and fuel handling systems so that safe-storage operations may commence on the balance of the plant. This activity may be carried out by plant personnel in accordance with existing operating technical specifications. Activities are scheduled around the fuel handling systems to the greatest extent possible.
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- Transfer of the spent fuel from the storage pool to the DOE following the minimum required cooling period in the spent fuel pool.
- Draining and de-energizing of the non-contaminated systems not required to support continued site operations or maintenance.
- Disposing of contaminated filter elements and resin beds not required for processing wastes from layup activities for future operations.
- Draining of the reactor vessel, with the internals left in place and the vessel head secured.
- Draining and de-energizing non-essential, contaminated systems with decontamination as required for future maintenance and inspection.
- Preparing lighting and alarm systems whose continued use is required; de-energizing portions of fire protection, electric power, and HVAC systems whose continued use is not required.
- Cleaning of the loose surface contamination from building access pathways.
- Performing an interim radiation survey of plant, posting warning signs where appropriate.
- Erecting physical barriers and/or securing all access to radioactive or contaminated areas, except as required for inspection and maintenance.
- Installing security and surveillance monitoring equipment and relocating security fence around secured structures, as required.
2.2.2 Period 2 - Dormancy The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phases of the deferred decommissioning alternatives. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.
Resident maintenance personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating, and ventilation, and periodic preventive maintenance on essential site services.
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An environmental surveillance program is carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented and/or detected and controlled. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.
Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of its own actions. The security fence, sensors, alarms, and other surveillance equipment provide security. Fire and radiation alarms are also monitored and maintained.
Consistent with the DECON scenario, the spent fuel storage pool is emptied within 51/2 years of the cessation of operations. The pool is secured for storage and decommissioned along with the power block structures in Period 4.
After an optional period of storage (such that license termination is accomplished within 60 years of final shutdown), it is required that the licensee submit an application to terminate the license, along with an LTP (described in Section 2.1.2), thereby initiating the third phase.
2.2.3 Periods 3 and 4 - Delayed Decommissioning Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for activities and the writing of activity specifications and detailed procedures are also initiated at this time.
Much of the work in developing a termination plan is relevant to the development of the detailed engineering plans and procedures. The activities associated with this phase and the follow-on decontamination and dismantling processes are detailed in Sections 2.1.1 and 2.1.2. The primary difference between the sequences anticipated for the DECON and this deferred scenario is the absence, in the latter, of any constraint on the availability of the fuel storage facilities for decommissioning.
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Variations in the length of the dormancy period are expected to have little effect upon the quantities of radioactive wastes generated from system and structure removal operations. Given the levels of radioactivity and spectrum of radionuclides expected from thirty to forty years of plant operation, no plant process system identified as being contaminated upon final shutdown will become releasable due to the decay period alone, i.e., there is no significant reduction in the waste generated from the decommissioning activities. However, due to the lower activity levels, a greater percentage of the waste volume can be designated for off-site processing and recovery.
The delay in decommissioning also yields lower working area radiation levels. As such, the estimate for this delayed scenario incorporates reduced ALARA controls for the SAFSTOR's lower occupational exposure potential.
Although the initial radiation levels due to 60Co will decrease during the dormancy period, the internal components of the reactor vessel will still exhibit sufficiently high radiation dose rates to require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Therefore, the dismantling procedures described for the DECON alternative would still be employed during this scenario. Portions of the biological shield will still be radioactive due to the presence of activated trace elements with long half-lives (152Eu and 154Eu). Decontamination will require controlled removal and disposal. It is assumed that radioactive corrosion products on inner surfaces of piping and components will not have decayed to levels that will permit unrestricted use or allow conventional removal. These systems and components will be surveyed as they are removed and disposed of in accordance with the existing radioactive release criteria.
2.2.4 Period 5 - Site Restoration Following completion of decommissioning operations, site-restoration activities can begin.
Dismantling, as a
continuation of the decommissioning process, is clearly the most appropriate and cost-effective option, as described in Section 2.1.3. The basis for the dismantling cost in this scenario is consistent with that described for DECON, presuming the removal of structures and site facilities to a nominal depth of three feet below grade and the limited restoration of the site.
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- 3. COST ESTIMATE The cost estimates prepared for decommissioning Callaway consider the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimates, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.
3.1 BASIS OF ESTIMATE The estimates were developed using the site-specific, technical information from the 2005 analysis. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.
3.2 METHODOLOGY The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[18]
and the DOE "Decommissioning Handbook."[19]
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) are developed using local labor rates. The activity-dependent costs are estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures rely upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[20]
The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.
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This analysis reflects lessons learned from TLGs involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.
Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment. WDFs are assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments.
The ranges used for the WDFs are as follows:
- Access Factor 10% to 20%
- Respiratory Protection Factor 10% to 50%
- Radiation/ALARA Factor 10% to 37%
- Protective Clothing Factor 10% to 30%
- Work Break Factor 8.33%
The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication.
Scheduling Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiologically controlled areas.
The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is 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
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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 costs.
3.3 FINANCIAL COMPONENTS OF THE COST MODEL TLGs proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration.
Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.
3.3.1 Contingency The activity-and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers Project and Cost Engineers' Handbook[21] 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, contingency is included. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.
Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk a
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successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a
contingency. Individual activity contingencies ranged from 10% to 75%,
depending on the degree of difficulty judged to be appropriate from TLGs actual decommissioning experience. The contingency values used in this study are as follows:
- Decontamination 50%
- Contaminated Component Removal 25%
- Contaminated Component Packaging 10%
- Contaminated Component Transport 15%
- Low-Level Radioactive Waste Disposal 25%
- Reactor Segmentation 75%
- NSSS Component Removal 25%
- Reactor Waste Packaging 25%
- Reactor Waste Transport 25%
- Reactor Vessel Component Disposal 50%
- GTCC Disposal 15%
- Non-Radioactive Component Removal 15%
- Heavy Equipment and Tooling 15%
- Supplies 25%
- Engineering 15%
- Energy 15%
- Characterization and Termination Surveys 30%
- Construction 15%
- Taxes and Fees 10%
- Insurance 10%
- Staffing 15%
The contingency values are applied to the appropriate components of the estimates on a line item basis. A composite value is then reported at the end of each detailed estimate (as provided in Appendix C and D). For example, the composite contingency value reported for the DECON alternative in Appendix C is approximately 18.6%.
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3.3.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk.
Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur.
Consideration is sometimes necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term financial risk. Included within the category of financial risk are:
- Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel.
- Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings.
- Changes in the project work scope from the baseline estimate, involving the discovery of unexpected levels of contaminants, contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous material contamination), variations in plant inventory or configuration not indicated by the as-built drawings.
- Regulatory changes, for example, affecting worker health and safety, site release criteria, waste transportation, and disposal.
- Policy decisions altering national commitments (e.g., in the ability to accommodate certain waste forms for disposition), or in the timetable for such, for example, the start and rate of acceptance of spent fuel by the DOE.
- Pricing changes for basic inputs such as labor, energy, materials, and disposal. Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited access to services is available.
It has been TLGs experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicate
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that the chances of the base decommissioning estimates being too high is a low probability, and the chances that the estimate is too low is a higher probability. This is mostly due to the pricing uncertainty for low-level radioactive waste burial, and to a lesser extent due to schedule increases from changes in plant conditions and to pricing variations in the cost of labor (both craft and staff). This cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.
3.4 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.
3.4.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimates to decommission Callaway. Ultimate disposition of the spent fuel is within the province of the DOEs Waste Management System, as defined by the Nuclear Waste Policy Act. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOEs waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimates, as described below.
For estimating purposes, AmerenUE has assumed that all spent fuel will be removed to the DOE high-level waste repository within 51/2 years after shutdown. Interim storage of the fuel, until the DOE has completed the transfer, will be in the spent fuel pool located in the Fuel Building on the Callaway site. This will allow AmerenUE to proceed with decommissioning (or safe-storage) operations in the shortest time possible. A delay in the startup of the repository, or a decrease in the spent fuel acceptance rate, will correspondingly prolong the transfer process and result in the fuel remaining at the Callaway site longer.
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It is assumed that the 51/2 years also provides the necessary cooling period for the final core to meet DOEs transport system requirements for decay heat. Once the pool is emptied, the spent fuel storage and handling facilities are available for decommissioning. Operation and maintenance costs for the spent fuel pool are included within the estimate as well as the costs to transfer the spent fuel to the DOE.
Canister Loading and Transfer A cost of $220,000 is used for the labor to load/transport the spent fuel from the pool to a DOE transport vehicle (assuming the DOE casks are multi-purpose canister designs within a storage or transportation overpack).
Operations and Maintenance An annual cost (excluding labor) of approximately $941,000 is used for operation and maintenance of the spent fuel pool. Pool operations are expected to continue approximately 51/2 years after the cessation of operations.
GTCC The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the Commission for Class C radioactive waste (GTCC). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.
For purposes of this study, GTCC is packaged in the same canisters used to transport spent fuel. It is not anticipated that the DOE would accept this waste prior to completing the transfer of spent fuel. Therefore, the GTCC waste is assumed to be stored in the spent fuel storage pool (for the DECON alternative) until all the fuel has been transferred to the DOE (for the DECON alternative). In the SAFSTOR scenario, the GTCC
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material is generated after the fuel has been removed. As such, the GTCC is assumed to be disposed of as it is generated during reactor vessel segmentation operations.
3.4.2 Reactor Vessel and Internal Components The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation 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 dictate the segmentation and packaging methodology.
Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites currently being decommissioned.
Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel.
Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals). However, its location on the Columbia River simplified the transportation analysis since:
- 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.
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It is not known whether this option will be available when the Callaway unit ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensees ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition.
With lower levels of activation, the vessel shell can be packaged more efficiently than the curie-limited internal components. This will allow the use of more conventional waste packages rather than shielded casks for transport (although some shielded casks are still required).
3.4.3 Primary System Components In the DECON scenario, the reactor coolant system components are assumed to be decontaminated using chemical agents prior to the start of dismantling operations. This type of decontamination can be expected to have a significant ALARA impact, since in this scenario the removal work is done within the first few years of shutdown. A decontamination factor (average reduction) of 10 is assumed for the process. Disposal of the decontamination solution effluent is included within the estimate as a "process liquid waste" charge. In the SAFSTOR scenario, radionuclide decay is expected to provide the same benefit and, therefore, a chemical decontamination is not included.
The following discussion deals with the removal and disposition of the steam generators, but the techniques involved are also applicable to other large components, such as heat exchangers, component coolers, and the pressurizer. The steam generators size and weight, as well as their location within the reactor building, will ultimately determine the removal strategy.
A trolley crane is set up for the removal of the generators. It can also be used to move portions of the steam generator cubicle walls and floor slabs from the reactor building to a location where they can be decontaminated and transported to the material handling area.
Interferences within the work area, such as grating, piping, and other components are removed to create sufficient laydown space for processing these large components.
The generators are rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area where they are lowered onto a dolly. Each generator is rotated into the horizontal position for extraction from the containment and placed onto
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a multi-wheeled vehicle for transport to an on-site processing and storage area.
The generators are disassembled on-site with the steam dome and lightly contaminated subassemblies designated for off-site recycling. The more highly contaminated tube sheet and tube bundle are packaged for direct disposal. The interior volume is filled with low-density cellular concrete for stabilization of the internal contamination.
Reactor coolant piping is cut from the reactor vessel once the water level in the vessel (used for personnel shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzle zone. The piping is boxed and transported by shielded van. The reactor coolant pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.
3.4.4 Retired Components The estimates include the cost to dispose of the retired steam generators expected to be in storage at the site upon the cessation of plant operations. The components are size-reduced to facilitate transportation.
3.4.5 Main Turbine and Condenser The main turbine is dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled demolition. The main condensers are also disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it is surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.
3.4.6 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.[22] The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to
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be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.
Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.
Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.
The transport of large intact components (e.g., large heat exchangers and other oversized components) will be by a combination of truck, rail, and/or multi-wheeled transporter.
Transportation costs for material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah.
Transportation costs for off-site waste processing are based upon the mileage to Memphis, Tennessee. Truck transport costs are estimated using published tariffs from Tri-State Motor Transit.[23]
3.4.7 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Any material leaving the site is subject to a survey and release charge, at a minimum.
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The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendices C and D, and summarized in Section 5. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.
The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.
Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the majority of the material generated from the decontamination and dismantling activities is based upon the current cost for disposal at EnergySolutions facility in Clive, Utah. Disposal costs for the higher activity waste (Class B and C) were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy).
3.4.8 Site Conditions Following Decommissioning The NRC will terminate the site license when it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRCs involvement in the decommissioning process will end at this point. Local building codes and state environmental regulations will dictate the next step in the decommissioning process, as well as the owners own future plans for the site.
The estimates presented herein include the dismantling of the major structures to just below ground level, backfilling and the collapsing of below grade voids, and general terra-forming such that the site upon
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which the power block and supplemental structures are located is transformed into a grassy plain.
The existing electrical switchyard and access roads will remain in support of the electrical transmission and distribution system. Site restoration does not include the remediation of the water treatment plants settling basins, if required.
Sludge removed from the sewage treatment plant lagoon was assumed to contain low levels of contamination that would require controlled disposal. As such, 3,600 cubic feet of material from the lagoon was designated for disposition at EnergySolutions facility.
The existing and replacement cooling tower discharge pipes will be left in place and flow filled with suitable material to prevent the pipes from collapsing. The intake line will also be filled.
The estimates do not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.
3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimates for decommissioning the site.
3.5.1 Estimating Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.
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3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear unit is acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis.
AmerenUE, as the operator, will continue to provide site operations support, including decommissioning program management, licensing, radiological protection, and site security. A Decommissioning Operations Contractor (DOC) will provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors needed to perform the work required for the decontamination and dismantling effort. The DOC will also provide the engineering services needed to develop activity specifications, detailed procedures, detailed activation analyses, and support field activities such as structural modifications.
Personnel costs are based upon average salary information provided by AmerenUE. Overhead costs are included for site and corporate support, reduced commensurate with the staffing of the project.
Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel.
3.5.3 Design Conditions Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements.
The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.[24] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Callaway components, projected operating life, and different periods of decay. Additional short-lived isotopes were derived from CR-0130[25] and CR-0672,[26] and benchmarked to the long-lived values from CR-3474.
The control elements are disposed of along with the spent fuel, i.e., there is no additional cost provided for their disposal.
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Activation of the containment building structure is confined to the biological shield. More extensive activation (at very low levels) of the interior structures within containment has been detected at several reactors and the owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the containment building will depend upon the site release criteria selected, as well as the designated end use for the site.
3.5.4 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by AmerenUE and its subcontractors. The plants operating staff performs the following activities at no additional cost or credit to the project during the transition period:
- Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.
- Drain and collect acids, caustics, and other chemical stores for recycle and/or sale.
- Process operating waste inventories, i.e., the estimates do not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.
Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. AmerenUE will make economically reasonable efforts to salvage equipment following final plant shutdown.
However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.
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It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimates do not include the additional cost for size reduction and preparation to meet furnace ready conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.
Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also made available for alternative use.
Energy For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage.
Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.
Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRCs proposed rulemaking Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors.[27] The NRCs financial protection requirements are based on various reactor (and spent fuel) configurations.
Taxes Property tax payments are included for the land only and will continue through the decommissioning project.
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Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.
3.6 COST ESTIMATE
SUMMARY
Schedules of expenditures are provided in Tables 3.1 and 3.2. The tables delineate the cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).
The cost elements are also assigned to one of three subcategories: License Termination, Spent Fuel Management, and Site Restoration. The subcategory License Termination is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR §50.75). The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.
The Spent Fuel Management subcategory contains costs associated with the five and one-half years of post-shutdown pool operations, and the management of the spent fuel until such time that the transfer of all fuel from this facility to an off-site location (e.g., geologic repository) is complete.
Site Restoration is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet and backfilled to conform to local grade.
As discussed in Section 3.4.1, while designated for disposal at the geologic repository along with the spent fuel, GTCC waste is still classified as low-level radioactive waste and, as such, included as a License Termination expense.
Decommissioning costs are reported in 2008 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendices C and D, along with the timeline presented in Section 4.
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TABLE 3.1 DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other [1]
Total [2]
2024 11,042 1,068 320 10 1,192 13,632 2025 58,763 9,187 1,877 2,475 7,134 79,435 2026 67,944 25,027 1,967 30,611 17,409 142,958 2027 61,458 21,980 1,411 31,737 16,633 133,219 2028 54,046 10,531 1,171 7,310 6,111 79,170 2029 53,898 10,503 1,168 7,290 6,094 78,953 2030 41,726 6,640 772 6,643 4,857 60,639 2031 32,102 7,549 267 28 2,185 42,131 2032 28,133 22,979 156 0
1,063 52,331 2033 6,149 5,023 34 0
232 11,438 415,261 120,486 9,144 86,104 62,911 693,907
[1] Includes property taxes, insurance, fees, surveys, and GTCC disposal
[2] Columns may not add due to rounding
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TABLE 3.1a DECON ALTERNATIVE SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 10,669 327 320 10 868 12,194 2025 56,714 5,549 1,877 2,475 5,558 72,172 2026 64,536 21,255 1,967 30,611 16,003 134,372 2027 57,970 18,216 1,411 31,737 15,306 124,640 2028 50,965 6,799 1,171 7,310 4,806 71,051 2029 50,826 6,780 1,168 7,290 4,793 70,857 2030 40,817 5,539 772 6,643 4,472 58,243 2031 24,224 1,082 224 28 2,091 27,648 2032 142 0
0 0
726 868 2033 31 0
0 0
159 190 356,894 65,546 8,910 86,104 54,781 572,236
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TABLE 3.1b DECON ALTERNATIVE SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 247 741 0
0 324 1,312 2025 1,213 3,638 0
0 1,576 6,427 2026 1,243 3,728 0
0 1,383 6,354 2027 1,236 3,708 0
0 1,301 6,246 2028 1,234 3,703 0
0 1,305 6,242 2029 1,231 3,693 0
0 1,301 6,225 2030 364 1,093 0
0 385 1,842 2031 0
0 0
0 0
0 2032 0
0 0
0 0
0 2033 0
0 0
0 0
0 6,768 20,303 0
0 7,576 34,647
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TABLE 3.1c DECON ALTERNATIVE SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 127 0
0 0
0 127 2025 836 0
0 0
0 836 2026 2,165 44 0
0 23 2,232 2027 2,252 55 0
0 26 2,333 2028 1,846 30 0
0 0
1,876 2029 1,841 30 0
0 0
1,871 2030 545 9
0 0
0 554 2031 7,877 6,467 44 0
95 14,483 2032 27,991 22,979 156 0
337 51,463 2033 6,118 5,023 34 0
74 11,249 51,599 34,637 234 0
554 87,024
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TABLE 3.2 SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other [1]
Total [2]
2024 9,057 978 320 10 1,152 11,517 2025 46,322 7,386 1,557 433 5,948 61,646 2026 27,404 11,085 683 596 4,251 44,020 2027 12,103 4,005 311 34 2,767 19,221 2028 12,137 4,016 312 34 2,774 19,273 2029 12,103 4,005 311 34 2,767 19,221 2030 5,658 1,381 202 32 1,636 8,909 2031 2,950 278 156 31 1,161 4,575 2032 2,958 278 156 31 1,164 4,588 2033 2,950 278 156 31 1,161 4,575 2034 2,950 278 156 31 1,161 4,575 2035 2,950 278 156 31 1,161 4,575 2036 2,958 278 156 31 1,164 4,588 2037 2,950 278 156 31 1,161 4,575 2038 2,950 278 156 31 1,161 4,575 2039 2,950 278 156 31 1,161 4,575 2040 2,958 278 156 31 1,164 4,588 2041 2,950 278 156 31 1,161 4,575 2042 2,950 278 156 31 1,161 4,575 2043 2,950 278 156 31 1,161 4,575 2044 2,958 278 156 31 1,164 4,588 2045 2,950 278 156 31 1,161 4,575 2046 2,950 278 156 31 1,161 4,575 2047 2,950 278 156 31 1,161 4,575 2048 2,958 278 156 31 1,164 4,588 2049 2,950 278 156 31 1,161 4,575 2050 2,950 278 156 31 1,161 4,575 2051 2,950 278 156 31 1,161 4,575 2052 2,958 278 156 31 1,164 4,588 2053 2,950 278 156 31 1,161 4,575 2054 2,950 278 156 31 1,161 4,575 2055 2,950 278 156 31 1,161 4,575 2056 2,958 278 156 31 1,164 4,588
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TABLE 3.2 (continued)
SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other [1]
Total [2]
2057 2,950 278 156 31 1,161 4,575 2058 2,950 278 156 31 1,161 4,575 2059 2,950 278 156 31 1,161 4,575 2060 2,958 278 156 31 1,164 4,588 2061 2,950 278 156 31 1,161 4,575 2062 2,950 278 156 31 1,161 4,575 2063 2,950 278 156 31 1,161 4,575 2064 2,958 278 156 31 1,164 4,588 2065 2,950 278 156 31 1,161 4,575 2066 2,950 278 156 31 1,161 4,575 2067 2,950 278 156 31 1,161 4,575 2068 2,958 278 156 31 1,164 4,588 2069 2,950 278 156 31 1,161 4,575 2070 2,950 278 156 31 1,161 4,575 2071 2,950 278 156 31 1,161 4,575 2072 2,958 278 156 31 1,164 4,588 2073 2,950 278 156 31 1,161 4,575 2074 2,950 278 156 31 1,161 4,575 2075 2,950 278 156 31 1,161 4,575 2076 2,958 278 156 31 1,164 4,588 2077 2,950 278 156 31 1,161 4,575 2078 22,606 997 720 36 1,476 25,836 2079 42,441 3,074 1,557 48 3,937 51,057 2080 54,819 23,699 1,491 35,976 20,187 136,173 2081 47,468 10,044 1,229 13,367 7,893 80,000 2082 45,331 6,139 1,168 6,845 4,444 63,926 2083 45,331 6,139 1,168 6,845 4,444 63,926 2084 32,776 6,101 315 311 2,388 41,891 2085 28,056 22,916 156 0
1,060 52,188 2086 8,378 6,844 46 0
316 15,585 590,727 131,871 18,872 66,068 122,030 929,568
[1] Includes property taxes, insurance, fees, surveys, and GTCC disposal
[2] Columns may not add due to rounding
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TABLE 3.2a SAFSTOR ALTERNATIVE SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 8,810 237 320 10 828 10,205 2025 45,109 3,748 1,557 433 4,372 55,219 2026 20,609 7,366 574 596 2,669 31,815 2027 2,950 305 156 34 1,182 4,627 2028 2,958 306 156 34 1,185 4,639 2029 2,950 305 156 34 1,182 4,627 2030 2,950 286 156 32 1,167 4,590 2031 2,950 278 156 31 1,161 4,575 2032 2,958 278 156 31 1,164 4,588 2033 2,950 278 156 31 1,161 4,575 2034 2,950 278 156 31 1,161 4,575 2035 2,950 278 156 31 1,161 4,575 2036 2,958 278 156 31 1,164 4,588 2037 2,950 278 156 31 1,161 4,575 2038 2,950 278 156 31 1,161 4,575 2039 2,950 278 156 31 1,161 4,575 2040 2,958 278 156 31 1,164 4,588 2041 2,950 278 156 31 1,161 4,575 2042 2,950 278 156 31 1,161 4,575 2043 2,950 278 156 31 1,161 4,575 2044 2,958 278 156 31 1,164 4,588 2045 2,950 278 156 31 1,161 4,575 2046 2,950 278 156 31 1,161 4,575 2047 2,950 278 156 31 1,161 4,575 2048 2,958 278 156 31 1,164 4,588 2049 2,950 278 156 31 1,161 4,575 2050 2,950 278 156 31 1,161 4,575 2051 2,950 278 156 31 1,161 4,575 2052 2,958 278 156 31 1,164 4,588 2053 2,950 278 156 31 1,161 4,575 2054 2,950 278 156 31 1,161 4,575 2055 2,950 278 156 31 1,161 4,575 2056 2,958 278 156 31 1,164 4,588
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TABLE 3.2a (continued)
SAFSTOR ALTERNATIVE SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2057 2,950 278 156 31 1,161 4,575 2058 2,950 278 156 31 1,161 4,575 2059 2,950 278 156 31 1,161 4,575 2060 2,958 278 156 31 1,164 4,588 2061 2,950 278 156 31 1,161 4,575 2062 2,950 278 156 31 1,161 4,575 2063 2,950 278 156 31 1,161 4,575 2064 2,958 278 156 31 1,164 4,588 2065 2,950 278 156 31 1,161 4,575 2066 2,950 278 156 31 1,161 4,575 2067 2,950 278 156 31 1,161 4,575 2068 2,958 278 156 31 1,164 4,588 2069 2,950 278 156 31 1,161 4,575 2070 2,950 278 156 31 1,161 4,575 2071 2,950 278 156 31 1,161 4,575 2072 2,958 278 156 31 1,164 4,588 2073 2,950 278 156 31 1,161 4,575 2074 2,950 278 156 31 1,161 4,575 2075 2,950 278 156 31 1,161 4,575 2076 2,958 278 156 31 1,164 4,588 2077 2,950 278 156 31 1,161 4,575 2078 22,088 997 720 36 1,476 25,317 2079 41,545 3,074 1,557 48 3,937 50,161 2080 51,854 23,629 1,491 35,976 20,157 133,107 2081 45,529 10,007 1,229 13,367 7,886 78,018 2082 43,701 6,113 1,168 6,845 4,444 62,270 2083 43,701 6,113 1,168 6,845 4,444 62,270 2084 26,973 1,391 283 311 2,319 31,277 2085 141 0
0 0
724 865 2086 42 0
0 0
216 258 500,647 76,938 18,015 66,068 112,779 774,447
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TABLE 3.2b SAFSTOR ALTERNATIVE SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 247 741 0
0 324 1,312 2025 1,213 3,638 0
0 1,576 6,427 2026 6,795 3,719 109 0
1,582 12,205 2027 9,154 3,700 156 0
1,585 14,594 2028 9,179 3,710 156 0
1,589 14,634 2029 9,154 3,700 156 0
1,585 14,594 2030 2,708 1,095 46 0
469 4,318 2031 0
0 0
0 0
0 2032 0
0 0
0 0
0 2033 0
0 0
0 0
0 2034 0
0 0
0 0
0 2035 0
0 0
0 0
0 2036 0
0 0
0 0
0 2037 0
0 0
0 0
0 2038 0
0 0
0 0
0 2039 0
0 0
0 0
0 2040 0
0 0
0 0
0 2041 0
0 0
0 0
0 2042 0
0 0
0 0
0 2043 0
0 0
0 0
0 2044 0
0 0
0 0
0 2045 0
0 0
0 0
0 2046 0
0 0
0 0
0 2047 0
0 0
0 0
0 2048 0
0 0
0 0
0 2049 0
0 0
0 0
0 2050 0
0 0
0 0
0 2051 0
0 0
0 0
0 2052 0
0 0
0 0
0 2053 0
0 0
0 0
0 2054 0
0 0
0 0
0 2055 0
0 0
0 0
0 2056 0
0 0
0 0
0
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 27 of 29 TLG Services, Inc.
TABLE 3.2b (continued)
SAFSTOR ALTERNATIVE SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2057 0
0 0
0 0
0 2058 0
0 0
0 0
0 2059 0
0 0
0 0
0 2060 0
0 0
0 0
0 2061 0
0 0
0 0
0 2062 0
0 0
0 0
0 2063 0
0 0
0 0
0 2064 0
0 0
0 0
0 2065 0
0 0
0 0
0 2066 0
0 0
0 0
0 2067 0
0 0
0 0
0 2068 0
0 0
0 0
0 2069 0
0 0
0 0
0 2070 0
0 0
0 0
0 2071 0
0 0
0 0
0 2072 0
0 0
0 0
0 2073 0
0 0
0 0
0 2074 0
0 0
0 0
0 2075 0
0 0
0 0
0 2076 0
0 0
0 0
0 2077 0
0 0
0 0
0 2078 0
0 0
0 0
0 2079 0
0 0
0 0
0 2080 0
0 0
0 0
0 2081 0
0 0
0 0
0 2082 0
0 0
0 0
0 2083 0
0 0
0 0
0 2084 0
0 0
0 0
0 2085 0
0 0
0 0
0 2086 0
0 0
0 0
0 38,448 20,303 623 0
8,709 68,084
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 28 of 29 TLG Services, Inc.
TABLE 3.2c SAFSTOR ALTERNATIVE SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2024 0
0 0
0 0
0 2025 0
0 0
0 0
0 2026 0
0 0
0 0
0 2027 0
0 0
0 0
0 2028 0
0 0
0 0
0 2029 0
0 0
0 0
0 2030 0
0 0
0 0
0 2031 0
0 0
0 0
0 2032 0
0 0
0 0
0 2033 0
0 0
0 0
0 2034 0
0 0
0 0
0 2035 0
0 0
0 0
0 2036 0
0 0
0 0
0 2037 0
0 0
0 0
0 2038 0
0 0
0 0
0 2039 0
0 0
0 0
0 2040 0
0 0
0 0
0 2041 0
0 0
0 0
0 2042 0
0 0
0 0
0 2043 0
0 0
0 0
0 2044 0
0 0
0 0
0 2045 0
0 0
0 0
0 2046 0
0 0
0 0
0 2047 0
0 0
0 0
0 2048 0
0 0
0 0
0 2049 0
0 0
0 0
0 2050 0
0 0
0 0
0 2051 0
0 0
0 0
0 2052 0
0 0
0 0
0 2053 0
0 0
0 0
0 2054 0
0 0
0 0
0 2055 0
0 0
0 0
0 2056 0
0 0
0 0
0
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 29 of 29 TLG Services, Inc.
TABLE 3.2c (continued)
SAFSTOR ALTERNATIVE SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)
Equipment &
Year Labor Materials Energy Burial Other Total 2057 0
0 0
0 0
0 2058 0
0 0
0 0
0 2059 0
0 0
0 0
0 2060 0
0 0
0 0
0 2061 0
0 0
0 0
0 2062 0
0 0
0 0
0 2063 0
0 0
0 0
0 2064 0
0 0
0 0
0 2065 0
0 0
0 0
0 2066 0
0 0
0 0
0 2067 0
0 0
0 0
0 2068 0
0 0
0 0
0 2069 0
0 0
0 0
0 2070 0
0 0
0 0
0 2071 0
0 0
0 0
0 2072 0
0 0
0 0
0 2073 0
0 0
0 0
0 2074 0
0 0
0 0
0 2075 0
0 0
0 0
0 2076 0
0 0
0 0
0 2077 0
0 0
0 0
0 2078 519 0
0 0
0 519 2079 896 0
0 0
0 896 2080 2,965 70 0
0 30 3,065 2081 1,939 37 0
0 7
1,982 2082 1,630 26 0
0 0
1,657 2083 1,630 26 0
0 0
1,657 2084 5,803 4,710 32 0
69 10,614 2085 27,915 22,916 156 0
336 51,322 2086 8,336 6,844 46 0
100 15,326 51,632 34,630 234 0
541 87,037
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page 1 of 4 TLG Services, Inc.
- 4. SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow the sequences presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.4.1.
A schedule or sequence of activities for the DECON alternative is presented in Figure 4.1. The scheduling sequence assumes that fuel is removed from the spent fuel pool within 51/2 years. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect divid-ing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional 2003" computer software.[28]
4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program Evaluation and Review Technique) Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:
- The Fuel Building is isolated until such time that all spent fuel has been transferred from the spent fuel pool to the DOE. Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel is complete (DECON option).
- All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.
- Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift.
- Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 4 TLG Services, Inc.
- For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.
4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedules for decommissioning. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is shown for the spent fuel storage period, which determines the release of the Fuel Building for final decontamination.
Project timelines are provided in Figures 4.2 and 4.3 with milestone dates based on a 2024 shutdown date. The fuel pool is emptied approximately 51/2 years after shutdown. Deferred decommissioning in the SAFSTOR scenarios is assumed to commence so that the operating license is terminated within a 60-year period from the cessation of plant operations.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE Task Name Callaway Plant Decon Project Schedule I
~'-;;;down plant_
Period 1a. Shutdown through transition I-I-
I-I--
Certificate of permanent cessation of operations submitted Fuel stor"'.ge pool operations Reconfigure plant Prepare activity specifications Perform site characterization PSDAR submitted Written certificate of permanent removal of fuel submitted Site specific deco~missioning cost estimate submitted DOC staff mobilized 1-Period 1b. Decommissioning preparations 1
Fuel storage pool operations I
Rec~~fiiure pl~t (c~ntinu;d)
Prepare detailed work procedures I -
-D;~;;;;
- NSSS*
I 5scl;;:t~ ~-=-~fuel p~~ --
Period 2a. Large component removal 1
Fuel storage pool operations 1-Preparation for reactor.... essel remo*~
1- -
Reactor vessel & internals I
Re;nai-;ing l';';"g;NSSS components disposltion I
Non*essential systems I
I
~ain turbine/:.:~erator Main condenser I
Lic~se..!~~.::.n~n.,,:ti~n ~~~.:u~~itted I
Period 2b. Decontamination (wet fuel) 1_
-Fu;lsto-r~;-P~~Cop;;ti~~*;;
1 Remove systems not supporting we~rage 1
Decon buildings not supporting wet fuel storage Lice-;;se t,;;~~~ti~n -i)l~;pproved I
.F~~ stor"'.ge po~l avai!~!.: for deco0~~s.~n~~~_
1 Period 2c. Decontru::ination fo!! owing wet fuel storage Remove remaining systems r
Deco; ;~~
T~l;tor~_~~;~
I Period 2e. Plant license termination I-I I Fin",l Site Survey NRC revie... & approval Part 50 license terminated Period Sb. Site restoratio;;'
Building demolitlons, backfill and lancisc",.ping
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Legend: 1.
Red text and/or shaded scheduling bars indicate critical path activities
- 2.
- 3.
Shaded scheduling bIDes associated with major decommissioning periods, e.g., Period la, indicate overall duration of that period Blue text and/or diamond symbols indicate major milestones TLG Services, Inc.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page 4 of 4 TLG Services, Inc.
FIGURE 4.2 DECOMMISSIONING TIMELINES (not to scale)
DECON Alternative SAFSTOR Alternative Pool Operations Storage Pool Empty 04/2030 Period 1 Transition and Preparations 10/2024 04/2026 09/2031 03/2033 Period 2 Decommissioning Period 3 Site Restoration Storage Pool Empty 04/2030 Period 1 Transition and Preparations 10/2024 04/2026 10/2084 04/2086 02/2080 Period 2 Dormancy 08/2078 Period 3 Delayed Preparations Period 4 Decommissioning Period 5 Site Restoration
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 1 of 4 TLG Services, Inc.
- 5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[29] the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.
Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR
§173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.
The volumes of radioactive waste generated during the various decommissioning activities at the site are shown on a line-item basis in Appendices C and D, and summarized in Tables 5.1 and 5.2. The quantified waste volume summaries shown in these tables are consistent with Part 61 classifications. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.
The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.
In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),
where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.
No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone (i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides).
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 4 TLG Services, Inc.
While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.
The waste material produced in the decontamination and dismantling of the nuclear units is primarily generated during Period 2 of DECON and Period 4 of SAFSTOR. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.
For purposes of constructing the estimates, the cost for disposal at the EnergySolutions facility was used as a proxy for future disposal facilities. Separate rates were used for containerized waste and large components, including the steam generators and reactor coolant pump motors. Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste.
Since EnergySolutions is not currently able to receive the more highly radioactive components generated in the decontamination and dismantling of the reactor, disposal costs for the Class B and C material were based upon the last published rate schedule for non-compact waste for the Barnwell facility (as a proxy).
Additional surcharges were included for activity, dose rate, and/or handling added as appropriate for the particular package.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 3 of 4 TLG Services, Inc.
TABLE 5.1 DECON ALTERNATIVE DECOMMISSIONING WASTE
SUMMARY
Waste Cost Basis Class [1]
Waste Volume (cubic feet)
Mass (pounds)
EnergySolutions A
141,483 12,114,319 Low-Level Radioactive Waste (near-surface disposal)
Barnwell B
4,668 570,124 Barnwell C
459 48,448 Greater than Class C (geologic repository)
Spent Fuel Equivalent GTCC 499 104,146 Processed/Conditioned (off-site recycling center)
Recycling Vendors A
411,681 10,682,990 Totals [2]
558,790 23,520,027
[1]
Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55
[2]
Columns may not add due to rounding.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 4 of 4 TLG Services, Inc.
TABLE 5.2 SAFSTOR ALTERNATIVE DECOMMISSIONING WASTE
SUMMARY
Waste Cost Basis Class [1]
Waste Volume (cubic feet)
Mass (pounds)
EnergySolutions A
139,840 10,482,398 Low-Level Radioactive Waste (near-surface disposal)
Barnwell B
3,330 350,113 Barnwell C
470 47,758 Greater than Class C (geologic repository)
Spent Fuel Equivalent GTCC 499 104,146 Processed/Conditioned (off-site recycling center)
Recycling Vendors A
437,494 11,780,860 Totals [2]
581,632 22,765,175
[1]
Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55
[2]
Columns may not add due to rounding.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 1 of 5 TLG Services, Inc.
- 6. RESULTS The analysis to estimate the costs to decommission Callaway relied upon the site-specific, technical information developed for a previous analysis prepared in 2005.
While not an engineering study, the estimates provide the plant owner 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, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenarios assume continued operation of the stations spent fuel pool for a minimum of 51/2 years following the cessation of operations for continued cooling of the assemblies. Once sufficiently cooled, the assemblies will be transferred to a DOE facility (e.g., geologic repository).
The cost projected to promptly decommission (DECON) Callaway is estimated to be
$693.9 million. The majority of this cost (approximately 82.5%) is associated with the physical decontamination and dismantling of the nuclear unit so that the operating license can be terminated. Another 5.0% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 12.5% is for the demolition of the designated structures and limited restoration of the site.
The cost projected for deferred decommissioning (SAFSTOR) is estimated to be
$929.6 million. The majority of this cost (approximately 83.3%) is associated with placing the unit in storage, ongoing caretaking of the unit during dormancy, and the eventual physical decontamination and dismantling of the nuclear unit so that the operating license can be terminated. Another 7.3% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 9.4% is for the demolition of the designated structures and limited restoration of the site.
The primary cost contributors, identified in Tables 6.1 and 6.2, are either labor-related or associated with the management and disposition of the radioactive waste.
Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning, as well as the duration of the program. It is assumed, for purposes of this analysis, that AmerenUE 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
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of 5 TLG Services, Inc.
organization varies with the decommissioning phase and associated site activities.
However, once the operating license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site (for the DECON alternative).
As described in this report, the spent fuel pool will remain operational for a minimum of 51/2 years following the cessation of operations. The pool will be isolated and an independent spent fuel island created. This will allow decommissioning operations to proceed in and around the pool area. Over the 51/2-year period, the spent fuel will be packaged into transportable canisters for loading into a DOE-provided transport cask.
The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposition of the low-level radioactive material required controlled disposal is at the EnergySolutions facility. Highly activated components, requiring additional isolation from the environment (GTCC), are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.
A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at one of the currently operating facilities. The cost identified in the summary tables for processing is all-inclusive, incorporating the ultimate disposition of the material.
Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program.
Decontamination and packaging costs also have a large labor component that is based upon prevailing union wages. Non-radiological demolition is a natural extension of the decommissioning process.
The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage.
With a
work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 3 of 5 TLG Services, Inc.
The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the general expense, e.g., labor and fuel, of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.
Decontamination is used to reduce the plants radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear unit.
License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will also require confirmation and will add to the expense of surveying the facilities alone.
The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 4 of 5 TLG Services, Inc.
TABLE 6.1 DECON ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)
Cost Element Total Percentage Decontamination 17,593 2.5 Removal 146,429 21.1 Packaging 16,531 2.4 Transportation 12,505 1.8 Waste Disposal 75,885 10.9 Off-site Waste Processing 22,814 3.3 Program Management [1]
297,742 42.9 Corporate Allocations 10,098 1.5 Spent Fuel Pool Isolation 10,819 1.6 Spent Fuel Management [2]
34,647 5.0 Insurance and Regulatory Fees 11,469 1.7 Energy 9,144 1.3 Characterization and Licensing Surveys 19,093 2.8 Property Taxes 2,780 0.4 Miscellaneous Equipment 6,359 0.9 Total [3]
693,907 100 Cost Element Total Percentage License Termination 572,236 82.5 Spent Fuel Management 34,647 5.0 Site Restoration 87,024 12.5 Total [3]
693,907 100
[1]
Includes engineering and security costs
[2] Direct costs only. Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 5 of 5 TLG Services, Inc.
TABLE 6.2 SAFSTOR ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)
Cost Element Total Percentage Decontamination 15,473 1.7 Removal 146,469 15.8 Packaging 13,753 1.5 Transportation 9,747 1.0 Waste Disposal 53,525 5.8 Off-site Waste Processing 25,137 2.7 Program Management [1]
476,544 51.3 Corporate Allocations 13,464 1.4 Spent Fuel Pool Isolation 10,819 1.2 Spent Fuel Management [2]
34,647 3.7 Insurance and Regulatory Fees 51,122 5.5 Energy 18,872 2.0 Characterization and Licensing Surveys 20,627 2.2 Property Taxes 20,296 2.2 Miscellaneous Equipment 19,074 2.1 Total [3]
929,568 100 Cost Element Total Percentage License Termination 774,447 83.31 Spent Fuel Management [4]
68,084 7.32 Site Restoration 87,037 9.36 Total [3]
929,568 100
[1]
Includes engineering and security costs
[2] Direct costs only. Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees
[3] Columns may not add due to rounding
[4] Includes percentage of Period 2a (dormancy) plant operating costs until spent fuel pool is emptied, in addition to the direct costs.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 1 of 3 TLG Services, Inc.
- 7. REFERENCES
- 1.
Decommissioning Cost Analysis for the Callaway Plant, Document No. A22-1534-002, Rev. 0, TLG Services, Inc., August 2005
- 2.
U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988
- 3.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 2003
- 4.
U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination
- 5.
U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, Entombment Options for Power Reactors, Advanced Notice of Proposed Rulemaking, Federal Register Volume 66, Number 200, October 16, 2001
- 6.
U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors,"
Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996.
- 7.
Nuclear Waste Policy Act of 1982 and Amendments, U.S. Department of Energys Office of Civilian Radioactive Management, 1982
- 8.
Testimony of Edward Sproat, Director, Office of Civilian Radioactive Waste Management, before a U.S. House of Representatives subcommittee on the status of Yucca Mountain, July 15, 2008
- 9.
U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses
- 10.
Low Level Radioactive Waste Policy Act, Public Law 96-573, 1980
- 11.
Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, 1986
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of 3 TLG Services, Inc.
- 7. REFERENCES (continued)
- 12.
Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55
- 13.
U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination, Federal Register, Volume 62, Number 139 (p 39058 et seq.), July 21, 1997
- 14.
Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination, EPA Memorandum OSWER No. 9200.4-18, August 22, 1997.
- 15.
U.S. Code of Federal Regulations, Title 40, Part 141.16, Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in community water systems
- 16.
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
- 17.
Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),
NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000
- 18.
T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986
- 19.
W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.
Department of Energy, DOE/EV/10128-1, November 1980
- 20.
"Building Construction Cost Data 2008," Robert Snow Means Company, Inc.,
Kingston, Massachusetts
- 21.
Project and Cost Engineers Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984
- 22.
U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2007
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of 3 TLG Services, Inc.
- 7. REFERENCES (continued)
- 23.
Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, February 2006
- 24.
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
- 25.
R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"
NUREG/CR-0130 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1978
- 26.
H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1980
- 27.
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
- 28.
"Microsoft Project Professional 2003," Microsoft Corporation, Redmond, WA.
- 29.
Atomic Energy Act of 1954, (68 Stat. 919)
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 1 of 4 TLG Services, Inc.
APPENDIX A UNIT COST FACTOR DEVELOPMENT
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 2 of 4 TLG Services, Inc.
APPENDIX A UNIT COST FACTOR DEVELOPMENT Example:
Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.
- 1.
SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist. They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.
- 2.
CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes)
(minutes)*
a Remove insulation 60 (b) b Mount pipe cutters 60 60 c
Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e
Cap openings 20 (d) f Rig for removal 30 30 g
Unbolt from mounts 30 30 h
Remove contamination controls 15 15 i
Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):
+ Respiratory protection adjustment (50% of critical duration) 128
+ Radiation/ALARA adjustment (37% of critical duration) 95 Adjusted work duration 478
+ Protective clothing adjustment (30% of adjusted duration) 143 Productive work duration 621
+ Work break adjustment (8.33 % of productive duration) 52 Total work duration (minutes) 673
- Total duration = 11.217 hr ***
- alpha designators indicate activities that can be performed in parallel
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 3 of 4 TLG Services, Inc.
APPENDIX A (continued)
- 3.
LABOR REQUIRED Duration Rate Crew Number (hours)
($/hr)
Cost Laborers 3.00 11.217
$34.72
$1168.36 Craftsmen 2.00 11.217
$52.38
$1175.09 Foreman 1.00 11.217
$54.86
$615.36 General Foreman 0.25 11.217
$55.89
$156.73 Fire Watch 0.05 11.217
$34.72
$19.47 Health Physics Technician 1.00 11.217
$58.57
$656.98 Total Labor Cost
$3,791.99
- 4.
EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs
-Blotting paper 50 @ $0.52 sq ft {1}
$26.00
-Plastic sheets/bags 50 @ $0.16/sq ft {2}
$8.00
-Gas torch consumables 1 @ $9.35/hr x 1 hr {3}
$9.35 Subtotal cost of equipment and materials
$43.35 Overhead & profit on equipment and materials @ 14.23 %
$6.17 Total costs, equipment & material
$49.52 TOTAL COST:
Removal of contaminated heat exchanger <3000 pounds:
$3,841.51 Total labor cost:
$3,791.99 Total equipment/material costs:
$49.52 Total craft labor man-hours required per unit:
81.88
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4 of 4 TLG Services, Inc.
- 5.
NOTES AND REFERENCES
- Work difficulty factors were developed in conjunction with the Atomic Industrial Forums (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.
- References for equipment & consumables costs:
- 1. McMaster-Carr, Item 7193T88, Spill Control
- 2. R.S. Means (2008) Division 01 56, Section 13.60-0200, page 20
- 3. R.S. Means (2008) Division 01 54 33, Section 40-6360, Reference-10
- Material and consumable costs were adjusted using the regional indices for Columbia, Missouri.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 1 of 8 TLG Services, Inc.
APPENDIX B UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of clean instrument and sampling tubing, $/linear foot 0.40 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.16 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 6.04 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 12.19 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 23.21 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 30.14 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 44.35 Removal of clean pipe >36 inches diameter, $/linear foot 52.71 Removal of clean valve >2 to 4 inches 79.92 Removal of clean valve >4 to 8 inches 121.89 Removal of clean valve >8 to 14 inches 232.12 Removal of clean valve >14 to 20 inches 301.35 Removal of clean valve >20 to 36 inches 443.46 Removal of clean valve >36 inches 527.10 Removal of clean pipe hanger for small bore piping 25.90 Removal of clean pipe hanger for large bore piping 92.23 Removal of clean pump, <300 pound 204.60 Removal of clean pump, 300-1000 pound 578.66 Removal of clean pump, 1000-10,000 pound 2,277.30 Removal of clean pump, >10,000 pound 4,400.68 Removal of clean pump motor, 300-1000 pound 243.45 Removal of clean pump motor, 1000-10,000 pound 948.62 Removal of clean pump motor, >10,000 pound 2,134.39 Removal of clean heat exchanger <3000 pound 1,221.71 Removal of clean heat exchanger >3000 pound 3,070.43
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of clean feedwater heater/deaerator 8,663.61 Removal of clean moisture separator/reheater 17,822.02 Removal of clean tank, <300 gallons 263.32 Removal of clean tank, 300-3000 gallon 832.15 Removal of clean tank, >3000 gallons, $/square foot surface area 7.08 Removal of clean electrical equipment, <300 pound 112.03 Removal of clean electrical equipment, 300-1000 pound 396.37 Removal of clean electrical equipment, 1000-10,000 pound 792.74 Removal of clean electrical equipment, >10,000 pound 1,895.66 Removal of clean electrical transformer < 30 tons 1,316.51 Removal of clean electrical transformer > 30 tons 3,791.31 Removal of clean standby diesel generator, <100 kW 1,344.70 Removal of clean standby diesel generator, 100 kW to 1 MW 3,001.45 Removal of clean standby diesel generator, >1 MW 6,213.61 Removal of clean electrical cable tray, $/linear foot 10.45 Removal of clean electrical conduit, $/linear foot 4.56 Removal of clean mechanical equipment, <300 pound 112.03 Removal of clean mechanical equipment, 300-1000 pound 396.37 Removal of clean mechanical equipment, 1000-10,000 pound 792.74 Removal of clean mechanical equipment, >10,000 pound 1,895.66 Removal of clean HVAC equipment, <300 pound 112.03 Removal of clean HVAC equipment, 300-1000 pound 396.37 Removal of clean HVAC equipment, 1000-10,000 pound 792.74 Removal of clean HVAC equipment, >10,000 pound 1,895.66 Removal of clean HVAC ductwork, $/pound 0.42
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 4 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of contaminated instrument and sampling tubing, $/linear foot 1.39 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 18.04 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 31.36 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 51.68 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 100.00 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 120.27 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 166.85 Removal of contaminated pipe >36 inches diameter, $/linear foot 197.40 Removal of contaminated valve >2 to 4 inches 397.26 Removal of contaminated valve >4 to 8 inches 478.56 Removal of contaminated valve >8 to 14 inches 961.12 Removal of contaminated valve >14 to 20 inches 1,222.45 Removal of contaminated valve >20 to 36 inches 1,629.62 Removal of contaminated valve >36 inches 1,935.16 Removal of contaminated pipe hanger for small bore piping 96.84 Removal of contaminated pipe hanger for large bore piping 306.03 Removal of contaminated pump, <300 pound 851.64 Removal of contaminated pump, 300-1000 pound 1,971.83 Removal of contaminated pump, 1000-10,000 pound 6,281.66 Removal of contaminated pump, >10,000 pound 15,299.93 Removal of contaminated pump motor, 300-1000 pound 834.62 Removal of contaminated pump motor, 1000-10,000 pound 2,554.70 Removal of contaminated pump motor, >10,000 pound 5,735.58 Removal of contaminated heat exchanger <3000 pound 3,841.51 Removal of contaminated heat exchanger >3000 pound 11,116.28
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of contaminated tank, <300 gallons 1,414.77 Removal of contaminated tank, >300 gallons, $/square foot 27.75 Removal of contaminated electrical equipment, <300 pound 663.38 Removal of contaminated electrical equipment, 300-1000 pound 1,603.50 Removal of contaminated electrical equipment, 1000-10,000 pound 3,087.01 Removal of contaminated electrical equipment, >10,000 pound 6,023.00 Removal of contaminated electrical cable tray, $/linear foot 31.98 Removal of contaminated electrical conduit, $/linear foot 14.71 Removal of contaminated mechanical equipment, <300 pound 738.56 Removal of contaminated mechanical equipment, 300-1000 pound 1,772.89 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,407.64 Removal of contaminated mechanical equipment, >10,000 pound 6,023.00 Removal of contaminated HVAC equipment, <300 pound 738.56 Removal of contaminated HVAC equipment, 300-1000 pound 1,772.89 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,407.64 Removal of contaminated HVAC equipment, >10,000 pound 6,023.00 Removal of contaminated HVAC ductwork, $/pound 1.96 Removal/plasma arc cut of contaminated thin metal components, $/linear in.
3.46 Additional decontamination of surface by washing, $/square foot 7.01 Additional decontamination of surfaces by hydrolasing, $/square foot 32.83 Decontamination rig hook up and flush, $/ 250 foot length 6,268.70 Chemical flush of components/systems, $/gallon 14.51 Removal of clean standard reinforced concrete, $/cubic yard 121.20 Removal of grade slab concrete, $/cubic yard 159.05 Removal of clean concrete floors, $/cubic yard 317.14
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of sections of clean concrete floors, $/cubic yard 938.18 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 213.33 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,904.04 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 269.76 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,520.31 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 409.36 Removal of below-grade suspended floors, $/cubic yard 317.14 Removal of clean monolithic concrete structures, $/cubic yard 794.02 Removal of contaminated monolithic concrete structures, $/cubic yard 1,901.68 Removal of clean foundation concrete, $/cubic yard 623.54 Removal of contaminated foundation concrete, $/cubic yard 1,771.66 Explosive demolition of bulk concrete, $/cubic yard 27.64 Removal of clean hollow masonry block wall, $/cubic yard 83.08 Removal of contaminated hollow masonry block wall, $/cubic yard 304.42 Removal of clean solid masonry block wall, $/cubic yard 83.08 Removal of contaminated solid masonry block wall, $/cubic yard 304.42 Backfill of below-grade voids, $/cubic yard 15.71 Removal of subterranean tunnels/voids, $/linear foot 98.03 Placement of concrete for below-grade voids, $/cubic yard 132.20 Excavation of clean material, $/cubic yard 2.67 Excavation of contaminated material, $/cubic yard 38.37 Removal of clean concrete rubble (tipping fee included), $/cubic yard 201.42 Removal of contaminated concrete rubble, $/cubic yard 23.69 Removal of building by volume, $/cubic foot 0.27 Removal of clean building metal siding, $/square foot 0.94
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 7 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Removal of contaminated building metal siding, $/square foot 3.72 Removal of standard asphalt roofing, $/square foot 1.87 Removal of transite panels, $/square foot 1.90 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 12.92 Scabbling contaminated concrete floors, $/square foot 7.25 Scabbling contaminated concrete walls, $/square foot 18.70 Scabbling contaminated ceilings, $/square foot 63.74 Scabbling structural steel, $/square foot 6.24 Removal of clean overhead crane/monorail < 10 ton capacity 565.17 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,697.01 Removal of clean overhead crane/monorail >10-50 ton capacity 1,356.39 Removal of contaminated overhead crane/monorail >10-50 ton capacity 4,072.11 Removal of polar crane > 50 ton capacity 5,686.94 Removal of gantry crane > 50 ton capacity 23,695.67 Removal of structural steel, $/pound 0.19 Removal of clean steel floor grating, $/square foot 4.12 Removal of contaminated steel floor grating, $/square foot 12.48 Removal of clean free standing steel liner, $/square foot 10.62 Removal of contaminated free standing steel liner, $/square foot 32.48 Removal of clean concrete-anchored steel liner, $/square foot 5.31 Removal of contaminated concrete-anchored steel liner, $/square foot 37.84 Placement of scaffolding in clean areas, $/square foot 14.76 Placement of scaffolding in contaminated areas, $/square foot 24.53 Landscaping with topsoilout, $/acre 1,091.13 Cost of CPC B-88 LSA box & preparation for use 1,654.23
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 8 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor Cost/Unit($)
TLG Services, Inc.
Cost of CPC B-25 LSA box & preparation for use 1,456.03 Cost of CPC B-12V 12 gauge LSA box & preparation for use 1,425.53 Cost of CPC B-144 LSA box & preparation for use 8,778.65 Cost of LSA drum & preparation for use 131.90 Cost of cask liner for CNSI 14 195 cask 152.36 Cost of cask liner for CNSI 8 120A cask (resins) 6,825.54 Cost of cask liner for CNSI 8 120A cask (filters) 922.30 Decontamination of surfaces with vacuuming, $/square foot 0.58
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 1 of 11 TLG Services, Inc.
APPENDIX C DETAILED COST ANALYSIS DECON
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 2 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 1a - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 Prepare preliminary decommissioning cost 154 23 177 177 1,300 1a.1.2 Notification of Cessation of Operations a
1a.1.3 Remove fuel & source material n/a 1a.1.4 Notification of Permanent Defueling a
1a.1.5 Deactivate plant systems & process waste a
1a.1.6 Prepare and submit PSDAR 237 36 273 273 2,000 1a.1.7 Review plant dwgs & specs.
545 82 627 627 4,600 1a.1.8 Perform detailed rad survey a
1a.1.9 Estimate by-product inventory 118 18 136 136 1,000 1a.1.10 End product description 118 18 136 136 1,000 1a.1.11 Detailed by-product inventory 154 23 177 177 1,300 1a.1.12 Define major work sequence 889 133 1,022 1,022 7,500 1a.1.13 Perform SER and EA 367 55 422 422 3,100 1a.1.14 Perform Site-Specific Cost Study 592 89 681 681 5,000 1a.1.15 Prepare/submit License Termination Plan 485 73 558 558 4,096 1a.1.16 Receive NRC approval of termination plan a
Activity Specifications 1a.1.17.1 Plant & temporary facilities 583 87 670 603 67 4,920 1a.1.17.2 Plant systems 494 74 568 511 57 4,167 1a.1.17.3 NSSS Decontamination Flush 59 9
68 68 500 1a.1.17.4 Reactor internals 841 126 967 967 7,100 1a.1.17.5 Reactor vessel 770 116 886 886 6,500 1a.1.17.6 Biological shield 59 9
68 68 500 1a.1.17.7 Steam generators 370 55 425 425 3,120 1a.1.17.8 Reinforced concrete 190 28 218 109 109 1,600 1a.1.17.9 Main Turbine 47 7
55 55 400 1a.1.17.10 Main Condensers 47 7
55 55 400 1a.1.17.11 Plant structures & buildings 370 55 425 213 213 3,120 1a.1.17.12 Waste management 545 82 627 627 4,600 1a.1.17.13 Facility & site closeout 107 16 123 61 61 900 1a.1.17 Total 4,482 672 5,154 4,538 616 37,827 Planning & Site Preparations 1a.1.18 Prepare dismantling sequence 284 43 327 327 2,400 1a.1.19 Plant prep. & temp. svces 2,700 405 3,105 3,105 1a.1.20 Design water clean-up system 166 25 191 191 1,400 1a.1.21 Rigging/Cont. Cntrl Envlps/tooling/etc.
2,100 315 2,415 2,415 1a.1.22 Procure casks/liners & containers 146 22 168 168 1,230 1a.1 Subtotal Period 1a Activity Costs 13,538 2,031 15,569 14,953 616 73,753 Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer 4,180 627 4,807 4,807 1a.3 Subtotal Period 1a Collateral Costs 4,180 627 4,807 4,807 Period 1a Period-Dependent Costs 1a.4.1 Insurance 1,662 166 1,828 1,828 1a.4.2 Property taxes 300 30 330 330 1a.4.3 Health physics supplies 432 108 540 540 1a.4.4 Heavy equipment rental 424 64 488 488 1a.4.5 Disposal of DAW generated 11 6
41 12 70 70 675 13,531 22 1a.4.6 Plant energy budget 1,354 203 1,557 1,557 1a.4.7 NRC Fees 706 71 776 776 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 3 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 1a Period-Dependent Costs (continued) 1a.4.8 Emergency Planning Fees 450 45 495 495 1a.4.9 INPO Fees 256 38 295 295 1a.4.10 Spent Fuel Pool O&M 940 141 1,082 1,082 1a.4.11 Corporate Allocations 900 90 990 990 1a.4.12 Security Staff Cost 5,658 849 6,507 6,507 157,471 1a.4.13 Utility Staff Cost 26,966 4,045 31,011 31,011 423,400 1a.4 Subtotal Period 1a Period-Dependent Costs 856 11 6
41 39,192 5,862 45,967 44,391 1,576 675 13,531 22 580,871 1a.0 TOTAL PERIOD 1a COST 856 11 6
41 56,911 8,519 66,343 59,345 6,383 616 675 13,531 22 654,624 PERIOD 1b - Decommissioning Preparations Period 1b Direct Decommissioning Activities Detailed Work Procedures 1b.1.1.1 Plant systems 561 84 645 580 64 4,733 1b.1.1.2 NSSS Decontamination Flush 118 18 136 136 1,000 1b.1.1.3 Reactor internals 296 44 341 341 2,500 1b.1.1.4 Remaining buildings 160 24 184 46 138 1,350 1b.1.1.5 CRD cooling assembly 118 18 136 136 1,000 1b.1.1.6 CRD housings & ICI tubes 118 18 136 136 1,000 1b.1.1.7 Incore instrumentation 118 18 136 136 1,000 1b.1.1.8 Reactor vessel 430 65 495 495 3,630 1b.1.1.9 Facility closeout 142 21 164 82 82 1,200 1b.1.1.10 Missile shields 53 8
61 61 450 1b.1.1.11 Biological shield 142 21 164 164 1,200 1b.1.1.12 Steam generators 545 82 627 627 4,600 1b.1.1.13 Reinforced concrete 118 18 136 68 68 1,000 1b.1.1.14 Main Turbine 185 28 213 213 1,560 1b.1.1.15 Main Condensers 185 28 213 213 1,560 1b.1.1.16 Auxiliary building 323 49 372 335 37 2,730 1b.1.1.17 Reactor building 323 49 372 335 37 2,730 1b.1.1 Total 3,939 591 4,529 3,678 852 33,243 1b.1.2 Decon primary loop 523 261 784 784 1,067 1b.1 Subtotal Period 1b Activity Costs 523 3,939 852 5,313 4,461 852 1,067 33,243 Period 1b Additional Costs 1b.2.1 Site Characterization 3,160 948 4,108 4,108 19,100 7,852 1b.2.2 Spent Fuel Pool Isolation 9,407 1,411 10,819 10,819 1b.2 Subtotal Period 1b Additional Costs 12,567 2,359 14,927 14,927 19,100 7,852 Period 1b Collateral Costs 1b.3.1 Decon equipment 831 125 956 956 1b.3.2 DOC staff relocation expenses 1,423 213 1,636 1,636 1b.3.3 Process liquid waste 51 104 535 4,754 1,305 6,749 6,749 324 1,512 187,252 358 1b.3.4 Small tool allowance 2
0 2
2 1b.3.5 Pipe cutting equipment 1,000 150 1,150 1,150 1b.3.6 Decon rig 1,400 210 1,610 1,610 1b.3.7 Spent Fuel Capital and Transfer 2,200 330 2,530 2,530 1b.3 Subtotal Period 1b Collateral Costs 2,282 1,002 104 535 4,754 3,623 2,333 14,634 12,104 2,530 324 1,512 187,252 358 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 26 6
32 32 1b.4.2 Insurance 838 84 922 922 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 4 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 1b Period-Dependent Costs (continued) 1b.4.3 Property taxes 151 15 166 166 1b.4.4 Health physics supplies 245 61 306 306 1b.4.5 Heavy equipment rental 214 32 246 246 1b.4.6 Disposal of DAW generated 6
4 24 7
41 41 399 7,988 13 1b.4.7 Plant energy budget 1,365 205 1,570 1,570 1b.4.8 NRC Fees 356 36 391 391 1b.4.9 Emergency Planning Fees 227 23 249 249 1b.4.10 Spent Fuel Pool O&M 474 71 545 545 1b.4.11 Corporate Allocations 900 90 990 990 1b.4.12 Security Staff Cost 2,852 428 3,280 3,280 79,383 1b.4.13 DOC Staff Cost 5,420 813 6,233 6,233 64,137 1b.4.14 Utility Staff Cost 13,667 2,050 15,717 15,717 214,491 1b.4 Subtotal Period 1b Period-Dependent Costs 26 459 6
4 24 26,250 3,921 30,689 29,894 795 399 7,988 13 358,011 1b.0 TOTAL PERIOD 1b COST 2,830 1,461 111 539 4,778 46,379 9,465 65,562 61,386 3,325 852 722 1,512 195,240 20,538 399,106 PERIOD 1 TOTALS 2,830 2,317 122 545 4,819 103,289 17,984 131,906 120,730 9,708 1,467 1,397 1,512 208,772 20,560 1,053,731 PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 2a.1.1.1 Reactor Coolant Piping 173 175 19 27 418 241 1,054 1,054 1,157 139,959 6,838 2a.1.1.2 Pressurizer Relief Tank 29 25 5
8 109 50 225 225 328 36,395 1,068 2a.1.1.3 Reactor Coolant Pumps & Motors 88 84 41 151 119 914 338 1,736 1,736 198 3,386 897,754 3,772 2a.1.1.4 Pressurizer 43 52 595 417 1,019 412 2,539 2,539 3,882 240,508 2,502 1,875 2a.1.1.5 Steam Generators 367 4,634 2,769 2,181 2,322 6,068 3,812 22,153 22,153 40,262 23,116 3,566,316 23,233 3,500 2a.1.1.6 Retired Steam Generator Units 2,017 1,530 2,322 5,893 2,253 14,013 14,013 40,262 22,448 3,346,591 10,800 2,250 2a.1.1.7 CRDMs/ICIs/Service Structure Removal 147 85 193 47 257 185 914 914 3,881 86,025 4,285 2a.1.1.8 Reactor Vessel Internals 115 2,599 4,470 967 7,055 230 6,927 22,362 22,362 1,377 903 459 326,029 27,883 1,247 2a.1.1.9 Vessel & Internals GTCC Disposal 10,634 1,595 12,229 12,229 499 104,146 2a.1.1.10 Reactor Vessel 87 5,324 1,567 699 7,668 230 8,472 24,048 24,048 6,511 2,254 948,723 27,883 1,247 2a.1.1 Totals 1,050 12,978 11,676 6,027 4,763 40,035 461 24,284 101,274 101,274 80,722 66,086 3,156 459 499 9,692,446 108,265 10,120 Removal of Major Equipment 2a.1.2 Main Turbine/Generator 477 316 36 770 696 446 2,741 2,741 4,921 2,740 664,183 9,888 2a.1.3 Main Condensers 1,308 163 64 638 609 601 3,383 3,383 7,701 2,270 550,231 27,762 Cascading Costs from Clean Building Demolition 2a.1.4.1 Reactor 840 126 966 966 10,575 2a.1.4.2 Auxiliary 422 63 486 486 5,551 2a.1.4.3 Hot Machine Shop 1
0 1
1 16 2a.1.4.4 Radwaste 88 13 101 101 1,108 2a.1.4.5 Fuel Building 206 31 236 236 2,395 2a.1.4 Totals 1,557 233 1,790 1,790 19,645 Disposal of Plant Systems 2a.1.5.1 100 Aux.Bldg Non-System Specific RCA 655 10 22 570 253 1,510 1,510 7,629 309,812 13,471 2a.1.5.2 100 Auxiliary Bldg Non-System Specific 109 4
5 35 53 47 253 253 474 199 37,110 2,280 2a.1.5.3 AB - Main Steam 241 36 277 277 5,833 2a.1.5.4 AB - Main Steam RCA 73 3
6 161 44 286 286 2,156 87,550 1,495 2a.1.5.5 AC - Main Turbine 237 36 273 273 5,641 2a.1.5.6 AD - Condensate 264 40 303 303 6,144 2a.1.5.7 AE - Feedwater 181 27 208 208 4,271 2a.1.5.8 AF - Feedwater Heater Extraction 221 33 255 255 5,352 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 5 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Disposal of Plant Systems (continued) 2a.1.5.9 AK - Condensate Demineralizer 82 12 94 94 1,944 2a.1.5.10 AL - Auxiliary Feedwater 36 5
41 41 852 2a.1.5.11 AQ - Condensate & Feedwater Chem Addtn 20 3
23 23 468 2a.1.5.12 BM - Steam Generator Blowdown 106 4
5 67 36 47 264 264 892 140 48,310 2,220 2a.1.5.13 BM - Steam Generator Blowdown - RCA 336 5
12 307 132 793 793 4,109 166,857 6,849 2a.1.5.14 BN - Borated Refueling Water Storage 325 14 22 412 101 173 1,047 1,047 5,512 416 257,593 6,819 2a.1.5.15 CA - Steam Seal 19 3
22 22 455 2a.1.5.16 CB - Main Turbine Lube Oil 54 8
62 62 1,207 2a.1.5.17 CC - Generator Hydrogen Seal & CO2 9
1 10 10 198 2a.1.5.18 CD - Generator Seal Oil 12 2
14 14 287 2a.1.5.19 CE - Stator Cooling Water 11 2
12 12 241 2a.1.5.20 CF - Lube Oil Storage Xfer & Prfication 34 5
40 40 812 2a.1.5.21 CG - Condenser Air Removal 28 4
32 32 657 2a.1.5.22 CH - Main Turbine Control Oil 55 8
64 64 1,219 2a.1.5.23 DA - Circulating Water 311 47 358 358 7,502 2a.1.5.24 DB - Cooling Tower Makeup & Blowdown 53 8
61 61 1,260 2a.1.5.25 DD - Cooling Water Chemical Control Sys 46 7
53 53 1,073 2a.1.5.26 DD - Cooling Wtr Chem Control RCA 251 5
10 266 105 636 636 3,555 144,376 4,866 2a.1.5.27 EJ - Residual Heat Removal 355 33 38 205 457 243 1,331 1,331 2,744 1,715 264,214 7,550 2a.1.5.28 EM - High Pressure Coolant Injection 278 11 12 98 123 118 639 639 1,315 458 94,439 5,793 2a.1.5.29 EN - Containment Spray 196 4
9 226 85 519 519 3,026 122,874 4,005 2a.1.5.30 EP - Accumulator Safety Injection 155 7
8 119 53 72 414 414 1,599 208 82,796 3,207 2a.1.5.31 FA - Auxiliary Steam Generator 21 3
24 24 521 2a.1.5.32 FB - Auxiliary Steam 87 13 100 100 2,106 2a.1.5.33 FB - Auxiliary Steam RCA 74 1
2 61 28 167 167 816 33,148 1,492 2a.1.5.34 FC - Auxiliary Turbines 57 9
65 65 1,320 2a.1.5.35 FE - Auxiliary Steam Chemical Addition 4
1 5
5 105 2a.1.5.36 GE - Turbine Building HVAC 152 23 174 174 3,792 2a.1.5.37 GS - Containment Hydrogen Control 70 3
3 49 20 31 175 175 658 73 33,309 1,464 2a.1.5.38 HE - Boron Recycle 368 444 25 25 194 267 397 1,720 1,720 2,600 1,111 194,922 15,831 2a.1.5.39 HF - Secondary Liquid Waste 675 894 55 57 462 606 796 3,545 3,545 6,186 2,522 453,942 30,614 2a.1.5.40 JA - Auxiliary Oil & Transfer 29 4
33 33 687 2a.1.5.41 KS - Bulk Chemical Storage 86 8
18 482 97 691 691 6,449 261,890 1,808 2a.1.5.42 LE - Oily Waste 161 24 186 186 3,865 2a.1.5.43 LE - Oily Waste RCA 213 3
6 169 80 471 471 2,256 91,628 4,181 2a.1.5.44 Turbine Bldg Non-System Specific 677 101 778 778 15,405 2a.1.5 Totals 1,043 7,720 193 261 3,884 1,716 3,211 18,028 14,462 3,566 51,976 6,842 2,684,769 187,162 2a.1.6 Scaffolding in support of decommissioning 1,490 21 5
102 12 394 2,024 2,024 1,233 69 62,010 35,883 2a.1 Subtotal Period 2a Activity Costs 2,093 25,529 12,369 6,394 10,156 43,069 461 29,170 129,240 125,674 3,566 146,552 78,008 3,156 459 499 13,653,640 388,605 10,120 Period 2a Collateral Costs 2a.3.1 Process liquid waste 244 117 582 664 387 1,994 1,994 2,052 143,192 400 2a.3.2 Small tool allowance 311 47 357 321 36 2a.3.3 Spent Fuel Capital and Transfer 6,380 957 7,337 7,337 2a.3.4 Survey and Release of Scrap Metal 753 113 866 866 2a.3 Subtotal Period 2a Collateral Costs 244 311 117 582 664 7,133 1,504 10,555 3,182 7,337 36 2,052 143,192 400 Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 75 19 94 94 2a.4.2 Insurance 846 85 931 931 2a.4.3 Property taxes 444 44 489 440 49 2a.4.4 Health physics supplies 2,212 553 2,765 2,765 2a.4.5 Heavy equipment rental 3,022 453 3,475 3,475 2a.4.6 Disposal of DAW generated 102 57 382 114 656 656 6,366 127,579 209 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 6 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 2a Period-Dependent Costs (continued) 2a.4.7 Plant energy budget 1,907 286 2,192 2,192 2a.4.8 NRC Fees 976 98 1,073 1,073 2a.4.9 Emergency Planning Fees 296 30 326 326 2a.4.10 Spent Fuel Pool O&M 1,394 209 1,603 1,603 2a.4.11 Corporate Allocations 2,970 297 3,267 3,267 2a.4.12 Security Staff Cost 7,127 1,069 8,196 8,196 195,533 2a.4.13 DOC Staff Cost 19,507 2,926 22,433 22,433 234,949 2a.4.14 Utility Staff Cost 28,469 4,270 32,739 32,739 437,437 2a.4 Subtotal Period 2a Period-Dependent Costs 75 5,234 102 57 382 63,935 10,453 80,239 78,262 1,929 49 6,366 127,579 209 867,919 2a.0 TOTAL PERIOD 2a COST 2,412 31,074 12,588 7,034 10,156 44,116 71,529 41,126 220,034 207,118 9,266 3,650 146,552 86,427 3,156 459 499 13,924,410 389,214 878,038 PERIOD 2b - Site Decontamination Period 2b Direct Decommissioning Activities Disposal of Plant Systems 2b.1.1.1 200 Reactor Bldg Non-System Specific 86 2
3 20 35 34 180 180 269 131 22,692 1,758 2b.1.1.2 200 Reactor Bldg Non-System Specific RCA 521 6
14 356 186 1,084 1,084 4,768 193,612 10,425 2b.1.1.3 300 Control Bldg Non-System Specific 167 3
6 160 67 403 403 2,139 86,849 3,413 2b.1.1.4 300 Control Bldg Non-System Specific Cln 1,361 204 1,566 1,566 29,076 2b.1.1.5 700 Radwaste Bldg Non-Sys Specific RCA 1,071 16 36 948 417 2,489 2,489 12,684 515,103 21,919 2b.1.1.6 700 Radwaste Bldg Non-System Specific 175 6
8 53 94 77 413 413 705 351 60,095 3,649 2b.1.1.7 AN - Demineralized Wtr Storage & Xfer 136 20 156 156 3,283 2b.1.1.8 AN - Demineralized Wtr Strg & Xfer RCA 36 0
1 23 13 73 73 314 12,759 711 2b.1.1.9 AP - Condensate Storage & Transfer 81 12 93 93 1,794 2b.1.1.10 BB - Reactor Coolant System 291 25 26 135 319 179 976 976 1,812 1,399 180,294 6,251 2b.1.1.11 BG - Chemical & Volume Control 705 828 71 75 368 933 866 3,847 3,847 4,931 3,562 512,267 26,126 2b.1.1.12 BL - Reactor Makeup Water 274 16 16 144 161 134 744 744 1,928 700 132,091 5,684 2b.1.1.13 DE - Intake & Water Treatment 107 16 123 123 2,478 2b.1.1.14 DE - Intake & Water Treatment RCA 238 15 34 891 200 1,378 1,378 11,923 484,206 4,993 2b.1.1.15 EA - Service Water 130 19 149 149 3,145 2b.1.1.16 EA - Service Water RCA 41 2
4 93 25 165 165 1,248 50,693 829 2b.1.1.17 EB - Closed Cooling Water 52 8
60 60 1,267 2b.1.1.18 EF - Essential Service Water 301 45 346 346 7,244 2b.1.1.19 EF - Essential Service Water RCA 184 7
15 398 109 713 713 5,326 216,287 3,802 2b.1.1.20 EG - Component Cooling Water RCA 220 33 253 253 5,335 2b.1.1.21 GA - Plant Heating 78 12 90 90 1,912 2b.1.1.22 GA - Plant Heating RCA 85 1
2 48 29 165 165 638 25,924 1,698 2b.1.1.23 GB - Central Chilled Water 74 11 85 85 1,803 2b.1.1.24 GB - Central Chilled Water RCA 23 0
1 14 8
46 46 187 7,591 463 2b.1.1.25 GD - Essential Serv Wtr Pumphouse HVAC 16 2
19 19 414 2b.1.1.26 GF - Miscellaneous Building HVAC 117 3
6 152 53 331 331 2,034 82,602 2,026 2b.1.1.27 GH - Radwaste Building HVAC 181 4
8 181 19 79 472 472 2,425 69 104,668 3,445 2b.1.1.28 GK - Control Building HVAC 151 23 174 174 3,900 2b.1.1.29 GL - Auxiliary Building HVAC 450 9
17 378 43 183 1,081 1,081 5,064 161 220,066 8,474 2b.1.1.30 GM - Diesel Generator Building HVAC 27 4
31 31 692 2b.1.1.31 GN - Containment Cooling 484 16 29 550 122 240 1,442 1,442 7,367 454 339,907 9,410 2b.1.1.32 GP - Containment Intgratd Leak Rate Test 36 1
2 43 16 98 98 580 23,570 737 2b.1.1.33 GR - Containment Atmospheric Control 19 2
4 81 8
20 133 133 1,086 29 46,679 392 2b.1.1.34 GT - Containment Purge HVAC 115 4
8 146 32 60 365 365 1,948 120 89,887 2,239 2b.1.1.35 HA - Gaseous Radwaste 320 15 16 208 126 147 832 832 2,782 486 155,095 6,500 2b.1.1.36 HB - Liquid Radwaste 740 788 51 50 415 519 772 3,335 3,335 5,560 2,205 399,479 29,834 2b.1.1.37 HC - Solid Radwaste 326 22 24 158 282 181 993 993 2,114 1,099 180,002 6,786 2b.1.1.38 HD - Decontamination 97 4
5 73 32 44 256 256 983 125 50,772 1,983 2b.1.1.39 JE - Emergency Fuel Oil 56 8
65 65 1,260 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 7 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Disposal of Plant Systems (continued) 2b.1.1.40 KA - Compressed Air 171 26 196 196 4,187 2b.1.1.41 KA - Compressed Air RCA 115 1
2 60 38 216 216 801 32,538 2,242 2b.1.1.42 KB - Breathing Air 21 3
24 24 516 2b.1.1.43 KB - Breathing Air RCA 17 0
0 5
5 28 28 71 2,874 376 2b.1.1.44 KC - Fire Protection 338 51 389 389 8,376 2b.1.1.45 KC - Fire Protection RCA 365 6
13 330 143 857 857 4,411 179,151 6,953 2b.1.1.46 KD - Domestic Water 157 24 181 181 3,837 2b.1.1.47 KD - Domestic Water RCA 23 0
1 18 9
52 52 247 10,039 448 2b.1.1.48 KE - Fuel Handling & Storage Rctor vssl 18 3
4 49 30 20 124 124 661 111 36,859 374 2b.1.1.49 KH - Service Gas (CO2 N2 H2 & O2) 50 7
57 57 1,226 2b.1.1.50 KH - Service Gas (CO2 N2 H2 & O2) RCA 229 3
7 182 86 507 507 2,433 98,813 4,378 2b.1.1.51 KJ - Standby Diesel Engine 298 45 343 343 6,749 2b.1.1.52 LA - Sanitary Drains 40 6
46 46 972 2b.1.1.53 LA - Sanitary Drains RCA 98 2
4 95 39 238 238 1,273 51,684 1,811 2b.1.1.54 LB - Roof Drains 53 8
61 61 1,276 2b.1.1.55 LB - Roof Drains RCA 131 3
6 160 58 358 358 2,139 86,858 2,628 2b.1.1.56 LD - Chemical & Detergent Waste 63 102 3
4 38 40 74 323 323 504 150 33,812 3,234 2b.1.1.57 LF - Floor & Equipment Drains 1,306 72 82 279 1,084 659 3,482 3,482 3,739 4,073 514,287 27,095 2b.1.1.58 RM - Process Sampling & Analysis 130 6
5 49 45 53 288 288 661 169 42,010 2,724 2b.1.1.59 SJ - Nuclear Sampling 73 4
3 32 35 33 179 179 423 130 28,862 1,539 2b.1.1.60 UB - Servces Stores Site Security Bldg 151 23 174 174 3,571 2b.1.1.61 Yard Non-System Specific 27 4
31 31 603 2b.1.1 Totals 1,508 13,657 404 540 7,336 3,958 5,970 33,374 28,663 4,711 98,179 15,523 5,310,975 312,263 2b.1.2 Scaffolding in support of decommissioning 1,862 26 6
128 15 492 2,530 2,530 1,541 86 77,513 44,853 Decontamination of Site Buildings 2b.1.3.1 Reactor 1,184 1,076 129 164 448 1,169 1,258 5,428 5,428 5,995 7,662 967,209 44,561 2b.1.3.2 Auxiliary 618 380 56 76 154 180 489 1,953 1,953 2,058 3,318 411,803 19,512 2b.1.3.3 Communication Corridor - Contaminated 14 7
1 2
1 4
10 38 38 17 72 7,852 397 2b.1.3.4 Hot Machine Shop 17 14 1
2 5
14 52 52 89 8,892 599 2b.1.3.5 RAM Storage Building 42 16 3
4 1
10 29 105 105 19 185 19,133 1,167 2b.1.3.6 Radioactive and Personnel Tunnel 6
12 1
1 3
7 29 29 50 5,022 336 2b.1.3.7 Radwaste 329 184 29 40 63 95 253 993 993 844 1,754 208,503 10,044 2b.1.3.8 Radwaste Drum Storage 37 19 3
4 5
11 28 107 107 66 196 22,234 1,097 2b.1.3.9 Steam Generator Replacement Bldgs 235 117 352 352 4,358 2b.1.3 Totals 2,481 1,708 224 293 672 1,475 2,204 9,057 9,057 8,999 13,326 1,650,649 82,070 2b.1 Subtotal Period 2b Activity Costs 3,990 17,227 655 839 8,136 5,449 8,666 44,961 40,250 4,711 108,720 28,936 7,039,137 439,186 Period 2b Additional Costs 2b.2.1 Sanitary Treatment Lagoon LLW 5
60 783 183 152 1,184 1,184 3,600 345,600 388 2b.2.2 Cooling Tower Asbestos Panel Removal 4,554 105 365 683 5,706 5,706 136,405 101,822 2b.2 Subtotal Period 2b Additional Costs 4,559 60 888 365 183 835 6,890 6,890 136,405 3,600 345,600 102,210 Period 2b Collateral Costs 2b.3.1 Process liquid waste 260 173 873 1,152 566 3,023 3,023 3,045 248,183 594 2b.3.2 Small tool allowance 403 60 463 463 2b.3.3 Spent Fuel Capital and Transfer 10,780 1,617 12,397 12,397 2b.3.4 Survey and Release of Scrap Metal 875 131 1,006 1,006 2b.3 Subtotal Period 2b Collateral Costs 260 403 173 873 1,152 11,655 2,375 16,889 4,492 12,397 3,045 248,183 594 Period 2b Period-Dependent Costs 2b.4.1 Decon supplies 1,139 285 1,424 1,424 2b.4.2 Insurance 1,437 144 1,581 1,581 2b.4.3 Property taxes 755 75 830 830 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 8 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 2b Period-Dependent Costs (continued) 2b.4.4 Health physics supplies 3,267 817 4,083 4,083 2b.4.5 Heavy equipment rental 5,097 765 5,861 5,861 2b.4.6 Disposal of DAW generated 115 65 430 129 739 739 7,169 143,667 236 2b.4.7 Plant energy budget 2,557 384 2,940 2,940 2b.4.8 NRC Fees 1,657 166 1,823 1,823 2b.4.9 Emergency Planning Fees 503 50 554 554 2b.4.10 Spent Fuel Pool O&M 2,368 355 2,723 2,723 2b.4.11 Liquid Radwaste Processing Equipment/Services 472 71 543 543 2b.4.12 Corporate Allocations 2,610 261 2,871 2,871 2b.4.13 Security Staff Cost 12,107 1,816 13,923 13,923 332,153 2b.4.14 DOC Staff Cost 31,940 4,791 36,731 36,731 383,354 2b.4.15 Utility Staff Cost 46,454 6,968 53,422 53,422 711,569 2b.4 Subtotal Period 2b Period-Dependent Costs 1,139 8,363 115 65 430 102,860 17,076 130,048 126,772 3,277 7,169 143,667 236 1,427,076 2b.0 TOTAL PERIOD 2b COST 5,388 30,552 1,004 2,664 8,501 7,214 114,515 28,951 198,789 178,404 15,674 4,711 245,125 42,750 7,776,586 542,225 1,427,076 PERIOD 2c - Decontamination Following Wet Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Remove spent fuel racks 778 79 233 87 1,323 776 3,277 3,277 4,933 442,623 1,925 Disposal of Plant Systems 2c.1.2.1 600 Fuel Bldg Non-Specific Systems RCA 289 4
9 239 110 651 651 3,200 129,974 5,859 2c.1.2.2 600 Fuel Bldg Non-System Specific 46 2
2 13 23 20 104 104 170 85 14,545 953 2c.1.2.3 EC - Fuel Pool Cooling & Cleanup 355 17 21 194 206 174 967 967 2,602 770 174,682 7,394 2c.1.2.4 GA-Plant Heating Fuel Building 19 1
1 4
8 7
39 39 50 29 4,646 395 2c.1.2.5 GG - Fuel Building HVAC 248 6
13 279 29 114 688 688 3,729 109 161,237 4,671 2c.1.2.6 KC-Fire Protection Fuel Building 108 2
4 93 42 248 248 1,239 50,329 2,084 2c.1.2 Totals 1,065 31 49 821 266 466 2,698 2,698 10,991 994 535,413 21,356 Decontamination of Site Buildings 2c.1.3.1 Fuel Building 764 833 19 26 202 55 640 2,540 2,540 2,705 902 199,149 31,582 2c.1.3 Totals 764 833 19 26 202 55 640 2,540 2,540 2,705 902 199,149 31,582 2c.1.4 Scaffolding in support of decommissioning 372 5
1 26 3
98 506 506 308 17 15,503 8,971 2c.1 Subtotal Period 2c Activity Costs 1,542 2,349 288 163 1,049 1,648 1,981 9,021 9,021 14,004 6,846 1,192,688 63,833 Period 2c Additional Costs 2c.2.1 License Termination Survey Program Management 1,467 440 1,907 1,907 12,480 2c.2 Subtotal Period 2c Additional Costs 1,467 440 1,907 1,907 12,480 Period 2c Collateral Costs 2c.3.1 Process liquid waste 146 57 283 280 191 957 957 1,004 60,265 196 2c.3.2 Small tool allowance 65 10 75 75 2c.3.3 Decommissioning Equipment Disposition 103 30 497 100 114 844 844 6,000 373 303,507 88 2c.3.4 Survey and Release of Scrap Metal 173 26 199 199 2c.3 Subtotal Period 2c Collateral Costs 146 65 160 313 497 380 173 341 2,076 2,076 6,000 1,378 363,772 284 Period 2c Period-Dependent Costs 2c.4.1 Decon supplies 164 41 206 206 2c.4.2 Insurance 332 33 366 366 2c.4.3 Property taxes 200 20 220 220 2c.4.4 Health physics supplies 517 129 647 647 2c.4.5 Heavy equipment rental 1,348 202 1,550 1,550 2c.4.6 Disposal of DAW generated 37 21 138 41 236 236 2,294 45,975 75 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 9 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 2c Period-Dependent Costs (continued) 2c.4.7 Plant energy budget 361 54 415 415 2c.4.8 NRC Fees 438 44 482 482 2c.4.9 Liquid Radwaste Processing Equipment/Services 250 37 287 287 2c.4.10 Corporate Allocations 450 45 495 495 2c.4.11 Security Staff Cost 974 146 1,120 1,120 20,829 2c.4.12 DOC Staff Cost 5,791 869 6,659 6,659 69,429 2c.4.13 Utility Staff Cost 8,807 1,321 10,128 10,128 131,220 2c.4 Subtotal Period 2c Period-Dependent Costs 164 1,865 37 21 138 17,602 2,983 22,810 22,810 2,294 45,975 75 221,477 2c.0 TOTAL PERIOD 2c COST 1,853 4,280 486 496 1,546 2,166 19,242 5,746 35,813 35,813 20,004 10,518 1,602,435 64,193 233,957 PERIOD 2e - License Termination Period 2e Direct Decommissioning Activities 2e.1.1 ORISE confirmatory survey 156 47 203 203 2e.1.2 Terminate license a
2e.1 Subtotal Period 2e Activity Costs 156 47 203 203 Period 2e Additional Costs 2e.2.1 License Termination Survey 8,311 2,493 10,804 10,804 152,357 6,240 2e.2 Subtotal Period 2e Additional Costs 8,311 2,493 10,804 10,804 152,357 6,240 Period 2e Collateral Costs 2e.3.1 DOC staff relocation expenses 1,423 213 1,636 1,636 2e.3 Subtotal Period 2e Collateral Costs 1,423 213 1,636 1,636 Period 2e Period-Dependent Costs 2e.4.1 Insurance 378 38 415 415 2e.4.2 Property taxes 227 23 249 249 2e.4.3 Health physics supplies 875 219 1,093 1,093 2e.4.4 Disposal of DAW generated 6
4 23 7
40 40 391 7,826 13 2e.4.5 Plant energy budget 205 31 235 235 2e.4.6 NRC Fees 534 53 587 587 2e.4.7 Corporate Allocations 360 36 396 396 2e.4.8 Security Staff Cost 1,103 165 1,268 1,268 18,926 2e.4.9 DOC Staff Cost 4,874 731 5,605 5,605 57,566 2e.4.10 Utility Staff Cost 5,510 826 6,336 6,336 74,914 2e.4 Subtotal Period 2e Period-Dependent Costs 875 6
4 23 13,188 2,129 16,225 16,225 391 7,826 13 151,406 2e.0 TOTAL PERIOD 2e COST 875 6
4 23 23,078 4,883 28,869 28,869 391 7,826 152,370 157,646 PERIOD 2 TOTALS 9,653 66,780 14,083 10,198 20,202 53,518 228,364 80,706 483,505 450,204 24,940 8,361 411,681 140,086 3,156 459 499 23,311,260 1,148,002 2,696,717 PERIOD 3b - Site Restoration Period 3b Direct Decommissioning Activities Demolition of Remaining Site Buildings 3b.1.1.1 Reactor 4,769 715 5,484 5,484 60,047 3b.1.1.2 Auxiliary 3,801 570 4,371 4,371 49,968 3b.1.1.3 Auxiliary Boiler 34 5
39 39 619 3b.1.1.4 Barge Facility 1,423 214 1,637 1,637 18,771 3b.1.1.5 Circulating & Service Water Pumphouse 286 43 329 329 4,345 3b.1.1.6 Communication Corridor - Clean 1,227 184 1,411 1,411 17,215 3b.1.1.7 Communication Corridor - Contaminated 52 8
60 60 674 3b.1.1.8 Cooling Tower Basemat 812 122 933 933 13,472 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 10 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Demolition of Remaining Site Buildings (continued) 3b.1.1.9 Diesel Generator 454 68 522 522 5,492 3b.1.1.10 Essential Service Water Pumphouse 270 41 311 311 3,938 3b.1.1.11 Fire Water Pumphouse 25 4
29 29 382 3b.1.1.12 Hot Machine Shop 21 3
25 25 417 3b.1.1.13 Intake 342 51 393 393 4,224 3b.1.1.14 Misc. Structures 2,177 327 2,504 2,504 27,921 3b.1.1.15 Miscellaneous Site Foundations 337 51 388 388 5,478 3b.1.1.16 Outage Maintenance 167 25 192 192 3,190 3b.1.1.17 RAM Storage Building 62 9
72 72 1,081 3b.1.1.18 Radioactive and Personnel Tunnel 25 4
29 29 383 3b.1.1.19 Radwaste 1,696 254 1,951 1,951 21,798 3b.1.1.20 Radwaste Drum Storage 249 37 287 287 3,840 3b.1.1.21 Security Additions 2,076 311 2,387 2,387 20,977 3b.1.1.22 Service 462 69 531 531 6,045 3b.1.1.23 Sludge Pump Station & Lagoon 23 3
26 26 313 3b.1.1.24 Steam Generator Replacement Bldgs 1,080 162 1,242 1,242 15,693 3b.1.1.25 Turbine Building 3,407 511 3,918 3,918 55,694 3b.1.1.26 Turbine Pedestal 983 147 1,130 1,130 10,928 3b.1.1.27 U.H.S. Cooling Tower 595 89 685 685 6,681 3b.1.1.28 Water Treatment Plant 1
0 1
1 9
3b.1.1.29 Fuel Building 1,898 285 2,183 2,183 22,580 3b.1.1 Totals 28,754 4,313 33,068 33,068 382,172 Site Closeout Activities 3b.1.2 BackFill Site 4,694 704 5,398 5,398 17,928 3b.1.3 Grade & landscape site 121 18 139 139 592 3b.1.4 Final report to NRC 185 28 213 213 1,560 3b.1 Subtotal Period 3b Activity Costs 33,570 185 5,063 38,818 213 38,605 400,692 1,560 Period 3b Additional Costs 3b.2.1 Concrete Crushing 1,125 8
170 1,303 1,303 5,830 3b.2.2 Mine Area Backfill 4,179 627 4,806 4,806 15,960 3b.2.3 Cooling Tower Discharge & Intake Pipe Flow Fill 3,937 590 4,527 4,527 9,588 3b.2.4 Cooling Tower Demolition 3,706 556 4,262 4,262 19,680 3b.2 Subtotal Period 3b Additional Costs 12,946 8
1,943 14,897 14,897 51,058 Period 3b Collateral Costs 3b.3.1 Small tool allowance 374 56 430 430 3b.3 Subtotal Period 3b Collateral Costs 374 56 430 430 Period 3b Period-Dependent Costs 3b.4.1 Insurance 3b.4.2 Property taxes 451 45 496 496 3b.4.3 Heavy equipment rental 4,080 612 4,692 4,692 3b.4.4 Plant energy budget 204 31 234 234 3b.4.5 Corporate Allocations 990 99 1,089 1,089 3b.4.6 Security Staff Cost 1,625 244 1,869 1,869 37,646 3b.4.7 DOC Staff Cost 9,431 1,415 10,845 10,845 106,663 3b.4.8 Utility Staff Cost 4,458 669 5,127 5,127 61,174 3b.4 Subtotal Period 3b Period-Dependent Costs 4,080 17,158 3,114 24,352 1,089 23,263 205,483 3b.0 TOTAL PERIOD 3b COST 50,970 17,351 10,176 78,496 1,302 77,195 451,750 207,043 PERIOD 3 TOTALS 50,970 17,351 10,176 78,496 1,302 77,195 451,750 207,043 TOTAL COST TO DECOMMISSION 12,483 120,067 14,205 10,742 20,202 58,337 349,004 108,866 693,907 572,236 34,647 87,024 411,681 141,483 4,668 459 499 23,520,030 1,620,312 3,957,490 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix C, Page 11 of 11 Table C Callaway Plant DECON Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:37:14 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours TOTAL COST TO DECOMMISSION WITH 18.61% CONTINGENCY:
$693,907 thousands of 2008 dollars TOTAL NRC LICENSE TERMINATION COST IS 82.47% OR:
$572,236 thousands of 2008 dollars SPENT FUEL MANAGEMENT COST IS 4.99% OR:
$34,647 thousands of 2008 dollars NON-NUCLEAR DEMOLITION COST IS 12.54% OR:
$87,024 thousands of 2008 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):
146,611 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:
499 cubic feet TOTAL SCRAP METAL REMOVED:
70,304 tons TOTAL CRAFT LABOR REQUIREMENTS:
1,601,212 man-hours End Notes:
n/a - indicates that this activity not charged as decommissioning expense.
a - indicates that this activity performed by decommissioning staff.
0 - indicates that this value is less than 0.5 but is non-zero.
a cell containing " - " indicates a zero value TLG Services, Inc.
Callaway Plant Document A22-1599-002, Rev. 0 Decommissioning Cost Analysis Appendix D, Page 1 of 13 TLG Services, Inc.
APPENDIX D DETAILED COST ANALYSIS SAFSTOR
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 2 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 1a - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 SAFSTOR site characterization survey 447 134 581 581 1a.1.2 Prepare preliminary decommissioning cost 154 23 177 177 1,300 1a.1.3 Notification of Cessation of Operations a
1a.1.4 Remove fuel & source material n/a 1a.1.5 Notification of Permanent Defueling a
1a.1.6 Deactivate plant systems & process waste a
1a.1.7 Prepare and submit PSDAR 237 36 273 273 2,000 1a.1.8 Review plant dwgs & specs.
154 23 177 177 1,300 1a.1.9 Perform detailed rad survey a
1a.1.10 Estimate by-product inventory 118 18 136 136 1,000 1a.1.11 End product description 118 18 136 136 1,000 1a.1.12 Detailed by-product inventory 178 27 204 204 1,500 1a.1.13 Define major work sequence 118 18 136 136 1,000 1a.1.14 Perform SER and EA 367 55 422 422 3,100 1a.1.15 Perform Site-Specific Cost Study 592 89 681 681 5,000 Activity Specifications 1a.1.16.1 Prepare plant and facilities for SAFSTOR 583 87 670 670 4,920 1a.1.16.2 Plant systems 494 74 568 568 4,167 1a.1.16.3 Plant structures and buildings 370 55 425 425 3,120 1a.1.16.4 Waste management 237 36 273 273 2,000 1a.1.16.5 Facility and site dormancy 237 36 273 273 2,000 1a.1.16 Total 1,920 288 2,208 2,208 16,207 Detailed Work Procedures 1a.1.17.1 Plant systems 140 21 161 161 1,183 1a.1.17.2 Facility closeout & dormancy 142 21 164 164 1,200 1a.1.17 Total 282 42 325 325 2,383 1a.1.18 Procure vacuum drying system 12 2
14 14 100 1a.1.19 Drain/de-energize non-cont. systems a
1a.1.20 Drain & dry NSSS a
1a.1.21 Drain/de-energize contaminated systems a
1a.1.22 Decon/secure contaminated systems a
1a.1 Subtotal Period 1a Activity Costs 4,699 772 5,471 5,471 35,890 Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer 4,180 627 4,807 4,807 1a.3 Subtotal Period 1a Collateral Costs 4,180 627 4,807 4,807 Period 1a Period-Dependent Costs 1a.4.1 Insurance 1,662 166 1,828 1,828 1a.4.2 Property taxes 300 30 330 330 1a.4.3 Health physics supplies 432 108 540 540 1a.4.4 Heavy equipment rental 424 64 488 488 1a.4.5 Disposal of DAW generated 11 6
41 12 70 70 675 13,531 22 1a.4.6 Plant energy budget 1,354 203 1,557 1,557 1a.4.7 NRC Fees 706 71 776 776 1a.4.8 Emergency Planning Fees 450 45 495 495 1a.4.9 INPO Fees 256 38 295 295 1a.4.10 Spent Fuel Pool O&M 940 141 1,082 1,082 1a.4.11 Corporate Allocations 720 72 792 792 1a.4.12 Security Staff Cost 5,658 849 6,507 6,507 157,471 1a.4.13 Utility Staff Cost 26,966 4,045 31,011 31,011 423,400 1a.4 Subtotal Period 1a Period-Dependent Costs 856 11 6
41 39,012 5,844 45,769 44,193 1,576 675 13,531 22 580,871 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 3 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 1a.0 TOTAL PERIOD 1a COST 856 11 6
41 47,892 7,243 56,048 49,665 6,383 675 13,531 22 616,761 PERIOD 1b - SAFSTOR Limited DECON Activities Period 1b Direct Decommissioning Activities Decontamination of Site Buildings 1b.1.1.1 Reactor 1,166 583 1,749 1,749 24,102 1b.1.1.2 Auxiliary 582 291 872 872 12,527 1b.1.1.3 Communication Corridor - Contaminated 13 6
19 19 276 1b.1.1.4 Fuel Building 754 377 1,131 1,131 14,371 1b.1.1.5 Hot Machine Shop 16 8
24 24 344 1b.1.1.6 RAM Storage Building 40 20 60 60 865 1b.1.1.7 Radioactive and Personnel Tunnel 4
2 6
6 89 1b.1.1.8 Radwaste 273 137 410 410 5,831 1b.1.1.9 Radwaste Drum Storage 31 15 46 46 656 1b.1.1 Totals 2,879 1,440 4,319 4,319 59,062 1b.1 Subtotal Period 1b Activity Costs 2,879 1,440 4,319 4,319 59,062 Period 1b Collateral Costs 1b.3.1 Decon equipment 831 125 956 956 1b.3.2 Process liquid waste 178 69 341 337 231 1,155 1,155 1,210 72,602 236 1b.3.3 Small tool allowance 48 7
56 56 1b.3.4 Spent Fuel Capital and Transfer 1,100 165 1,265 1,265 1b.3 Subtotal Period 1b Collateral Costs 1,009 48 69 341 337 1,100 528 3,432 2,167 1,265 1,210 72,602 236 Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 1,057 264 1,321 1,321 1b.4.2 Insurance 419 42 461 461 1b.4.3 Property taxes 76 8
83 83 1b.4.4 Health physics supplies 346 87 433 433 1b.4.5 Heavy equipment rental 107 16 123 123 1b.4.6 Disposal of DAW generated 13 7
48 15 83 83 808 16,189 27 1b.4.7 Plant energy budget 341 51 392 392 1b.4.8 NRC Fees 178 18 196 196 1b.4.9 Emergency Planning Fees 113 11 125 125 1b.4.10 Spent Fuel Pool O&M 237 36 273 273 1b.4.11 Corporate Allocations 270 27 297 297 1b.4.12 Security Staff Cost 1,426 214 1,640 1,640 39,691 1b.4.13 Utility Staff Cost 6,797 1,020 7,817 7,817 106,720 1b.4 Subtotal Period 1b Period-Dependent Costs 1,057 453 13 7
48 9,857 1,807 13,243 12,846 397 808 16,189 27 146,411 1b.0 TOTAL PERIOD 1b COST 4,945 502 82 348 385 10,957 3,775 20,994 19,332 1,662 2,018 88,791 59,324 146,411 PERIOD 1c - Preparations for SAFSTOR Dormancy Period 1c Direct Decommissioning Activities 1c.1.1 Prepare support equipment for storage 410 61 471 471 3,000 1c.1.2 Install containment pressure equal. lines 37 5
42 42 700 1c.1.3 Interim survey prior to dormancy 733 220 953 953 11,778 1c.1.4 Secure building accesses a
1c.1.5 Prepare & submit interim report 69 10 79 79 583 1c.1 Subtotal Period 1c Activity Costs 446 802 297 1,546 1,546 15,478 583 Period 1c Additional Costs 1c.2.1 Spent Fuel Pool Isolation 9,407 1,411 10,819 10,819 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 4 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 1c.2 Subtotal Period 1c Additional Costs 9,407 1,411 10,819 10,819 Period 1c Collateral Costs 1c.3.1 Process liquid waste 198 77 380 376 258 1,289 1,289 1,351 81,050 263 1c.3.2 Small tool allowance 3
1 4
4 1c.3.3 Spent Fuel Capital and Transfer 1,100 165 1,265 1,265 1c.3 Subtotal Period 1c Collateral Costs 198 3
77 380 376 1,100 423 2,558 1,293 1,265 1,351 81,050 263 Period 1c Period-Dependent Costs 1c.4.1 Insurance 419 42 461 461 1c.4.2 Property taxes 76 8
83 83 1c.4.3 Health physics supplies 172 43 215 215 1c.4.4 Heavy equipment rental 107 16 123 123 1c.4.5 Disposal of DAW generated 3
2 10 3
18 18 170 3,411 6
1c.4.6 Plant energy budget 341 51 392 392 1c.4.7 NRC Fees 178 18 196 196 1c.4.8 Emergency Planning Fees 113 11 125 125 1c.4.9 Spent Fuel Pool O&M 237 36 273 273 1c.4.10 Corporate Allocations 360 36 396 396 1c.4.11 Security Staff Cost 1,426 214 1,640 1,640 39,691 1c.4.12 Utility Staff Cost 6,797 1,020 7,817 7,817 106,720 1c.4 Subtotal Period 1c Period-Dependent Costs 279 3
2 10 9,947 1,497 11,737 11,340 397 170 3,411 6
146,411 1c.0 TOTAL PERIOD 1c COST 198 729 80 382 386 21,257 3,629 26,660 24,998 1,662 1,521 84,461 15,747 146,995 PERIOD 1 TOTALS 5,144 2,086 172 736 812 80,105 14,646 103,702 93,994 9,708 4,214 186,783 75,093 910,168 PERIOD 2a - SAFSTOR Dormancy with Wet Spent Fuel Storage Period 2a Direct Decommissioning Activities 2a.1.1 Quarterly Inspection a
2a.1.2 Semi-annual environmental survey a
2a.1.3 Prepare reports a
2a.1.4 Bituminous roof replacement 241 36 277 277 2a.1.5 Maintenance supplies 503 126 629 629 2a.1 Subtotal Period 2a Activity Costs 743 162 905 905 Period 2a Collateral Costs 2a.3.1 Spent Fuel Capital and Transfer 17,160 2,574 19,734 19,734 2a.3 Subtotal Period 2a Collateral Costs 17,160 2,574 19,734 19,734 Period 2a Period-Dependent Costs 2a.4.1 Insurance 2,283 228 2,511 2,197 314 2a.4.2 Property taxes 1,199 120 1,319 1,319 2a.4.3 Health physics supplies 401 100 501 501 2a.4.4 Disposal of DAW generated 29 16 110 33 188 188 1,828 36,637 60 2a.4.5 Plant energy budget 1,083 162 1,246 623 623 2a.4.6 NRC Fees 806 81 887 887 2a.4.7 Emergency Planning Fees 799 80 879 879 2a.4.8 Spent Fuel Pool O&M 3,762 564 4,326 4,326 2a.4.9 Corporate Allocations 990 99 1,089 270 819 2a.4.10 Security Staff Cost 16,460 2,469 18,929 6,727 12,203 444,257 2a.4.11 Utility Staff Cost 21,189 3,178 24,367 4,889 19,478 329,543 2a.4 Subtotal Period 2a Period-Dependent Costs 401 29 16 110 48,572 7,115 56,244 17,602 38,642 1,828 36,637 60 773,800 2a.0 TOTAL PERIOD 2a COST 401 29 16 110 66,476 9,851 76,883 18,507 58,376 1,828 36,637 60 773,800 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 5 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours PERIOD 2c - SAFSTOR Dormancy without Spent Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Quarterly Inspection a
2c.1.2 Semi-annual environmental survey a
2c.1.3 Prepare reports a
2c.1.4 Bituminous roof replacement 2,908 436 3,344 3,344 2c.1.5 Maintenance supplies 6,076 1,519 7,595 7,595 2c.1 Subtotal Period 2c Activity Costs 8,984 1,955 10,939 10,939 Period 2c Period-Dependent Costs 2c.4.1 Insurance 24,136 2,414 26,549 26,549 2c.4.2 Property taxes 14,490 1,449 15,939 15,939 2c.4.3 Health physics supplies 3,822 956 4,778 4,778 2c.4.4 Disposal of DAW generated 323 181 1,207 361 2,072 2,072 20,108 402,961 661 2c.4.5 Plant energy budget 6,544 982 7,526 7,526 2c.4.6 NRC Fees 8,820 882 9,702 9,702 2c.4.7 Corporate Allocations 2,970 297 3,267 3,267 2c.4.8 Security Staff Cost 70,682 10,602 81,284 81,284 1,512,171 2c.4.9 Utility Staff Cost 51,374 7,706 59,080 59,080 882,100 2c.4 Subtotal Period 2c Period-Dependent Costs 3,822 323 181 1,207 179,016 25,648 210,197 210,197 20,108 402,961 661 2,394,271 2c.0 TOTAL PERIOD 2c COST 3,822 323 181 1,207 187,999 27,603 221,136 221,136 20,108 402,961 661 2,394,271 PERIOD 2 TOTALS 4,223 352 198 1,316 254,475 37,454 298,018 239,643 58,376 21,937 439,598 721 3,168,071 PERIOD 3a - Reactivate Site Following SAFSTOR Dormancy Period 3a Direct Decommissioning Activities 3a.1.1 Prepare preliminary decommissioning cost 154 23 177 177 1,300 3a.1.2 Review plant dwgs & specs.
545 82 627 627 4,600 3a.1.3 Perform detailed rad survey a
3a.1.4 End product description 118 18 136 136 1,000 3a.1.5 Detailed by-product inventory 154 23 177 177 1,300 3a.1.6 Define major work sequence 889 133 1,022 1,022 7,500 3a.1.7 Perform SER and EA 367 55 422 422 3,100 3a.1.8 Perform Site-Specific Cost Study 592 89 681 681 5,000 3a.1.9 Prepare/submit License Termination Plan 485 73 558 558 4,096 3a.1.10 Receive NRC approval of termination plan a
Activity Specifications 3a.1.11.1 Re-activate plant & temporary facilities 873 131 1,004 904 100 7,370 3a.1.11.2 Plant systems 494 74 568 511 57 4,167 3a.1.11.3 Reactor internals 841 126 967 967 7,100 3a.1.11.4 Reactor vessel 770 116 886 886 6,500 3a.1.11.5 Biological shield 59 9
68 68 500 3a.1.11.6 Steam generators 370 55 425 425 3,120 3a.1.11.7 Reinforced concrete 190 28 218 109 109 1,600 3a.1.11.8 Main Turbine 47 7
55 55 400 3a.1.11.9 Main Condensers 47 7
55 55 400 3a.1.11.10 Plant structures & buildings 370 55 425 213 213 3,120 3a.1.11.11 Waste management 545 82 627 627 4,600 3a.1.11.12 Facility & site closeout 107 16 123 61 61 900 3a.1.11 Total 4,713 707 5,420 4,771 649 39,777 Planning & Site Preparations 3a.1.12 Prepare dismantling sequence 284 43 327 327 2,400 3a.1.13 Plant prep. & temp. svces 2,700 405 3,105 3,105 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 6 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 3a.1.14 Design water clean-up system 166 25 191 191 1,400 3a.1.15 Rigging/Cont. Cntrl Envlps/tooling/etc.
2,100 315 2,415 2,415 3a.1.16 Procure casks/liners & containers 146 22 168 168 1,230 3a.1 Subtotal Period 3a Activity Costs 13,414 2,012 15,426 14,777 649 72,703 Period 3a Period-Dependent Costs 3a.4.1 Insurance 252 25 277 277 3a.4.2 Property taxes 151 15 166 166 3a.4.3 Health physics supplies 190 48 238 238 3a.4.4 Heavy equipment rental 214 32 246 246 3a.4.5 Disposal of DAW generated 5
3 17 5
30 30 287 5,756 9
3a.4.6 Plant energy budget 683 102 785 785 3a.4.7 NRC Fees 126 13 138 138 3a.4.8 Corporate Allocations 360 36 396 396 3a.4.9 Security Staff Cost 1,305 196 1,501 1,501 32,857 3a.4.10 Utility Staff Cost 8,449 1,267 9,716 9,716 130,377 3a.4 Subtotal Period 3a Period-Dependent Costs 404 5
3 17 11,325 1,739 13,492 13,492 287 5,756 9
163,234 3a.0 TOTAL PERIOD 3a COST 404 5
3 17 24,739 3,751 28,918 28,269 649 287 5,756 9
235,937 PERIOD 3b - Decommissioning Preparations Period 3b Direct Decommissioning Activities Detailed Work Procedures 3b.1.1.1 Plant systems 561 84 645 580 64 4,733 3b.1.1.2 Reactor internals 296 44 341 341 2,500 3b.1.1.3 Remaining buildings 160 24 184 46 138 1,350 3b.1.1.4 CRD cooling assembly 118 18 136 136 1,000 3b.1.1.5 CRD housings & ICI tubes 118 18 136 136 1,000 3b.1.1.6 Incore instrumentation 118 18 136 136 1,000 3b.1.1.7 Reactor vessel 430 65 495 495 3,630 3b.1.1.8 Facility closeout 142 21 164 82 82 1,200 3b.1.1.9 Missile shields 53 8
61 61 450 3b.1.1.10 Biological shield 142 21 164 164 1,200 3b.1.1.11 Steam generators 545 82 627 627 4,600 3b.1.1.12 Reinforced concrete 118 18 136 68 68 1,000 3b.1.1.13 Main Turbine 185 28 213 213 1,560 3b.1.1.14 Main Condensers 185 28 213 213 1,560 3b.1.1.15 Auxiliary building 323 49 372 335 37 2,730 3b.1.1.16 Reactor building 323 49 372 335 37 2,730 3b.1.1 Total 3,820 573 4,393 3,541 852 32,243 3b.1 Subtotal Period 3b Activity Costs 3,820 573 4,393 3,541 852 32,243 Period 3b Additional Costs 3b.2.1 Site Characterization 3,160 948 4,108 4,108 19,100 7,852 3b.2 Subtotal Period 3b Additional Costs 3,160 948 4,108 4,108 19,100 7,852 Period 3b Collateral Costs 3b.3.1 Decon equipment 831 125 956 956 3b.3.2 DOC staff relocation expenses 1,423 213 1,636 1,636 3b.3.3 Pipe cutting equipment 1,000 150 1,150 1,150 3b.3 Subtotal Period 3b Collateral Costs 831 1,000 1,423 488 3,742 3,742 Period 3b Period-Dependent Costs 3b.4.1 Decon supplies 51 13 64 64 3b.4.2 Insurance 499 50 549 549 3b.4.3 Property taxes 300 30 330 330 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 7 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 3b Period-Dependent Costs (continued) 3b.4.4 Health physics supplies 416 104 520 520 3b.4.5 Heavy equipment rental 424 64 488 488 3b.4.6 Disposal of DAW generated 10 6
39 12 66 66 645 12,916 21 3b.4.7 Plant energy budget 1,354 203 1,557 1,557 3b.4.8 NRC Fees 249 25 274 274 3b.4.9 Corporate Allocations 630 63 693 693 3b.4.10 Security Staff Cost 2,589 388 2,978 2,978 65,179 3b.4.11 DOC Staff Cost 9,835 1,475 11,310 11,310 116,800 3b.4.12 Utility Staff Cost 16,759 2,514 19,273 19,273 258,629 3b.4 Subtotal Period 3b Period-Dependent Costs 51 840 10 6
39 32,215 4,940 38,102 38,102 645 12,916 21 440,607 3b.0 TOTAL PERIOD 3b COST 882 1,840 10 6
39 40,619 6,949 50,345 49,493 852 645 12,916 19,121 480,702 PERIOD 3 TOTALS 882 2,244 15 8
56 65,357 10,701 79,263 77,763 1,501 932 18,672 19,131 716,639 PERIOD 4a - Large Component Removal Period 4a Direct Decommissioning Activities Nuclear Steam Supply System Removal 4a.1.1.1 Reactor Coolant Piping 33 155 19 14 118 209 129 677 677 579 579 134,210 3,867 4a.1.1.2 Pressurizer Relief Tank 6
22 5
4 33 54 28 152 152 164 164 36,395 581 4a.1.1.3 Reactor Coolant Pumps & Motors 19 84 41 151 119 914 304 1,632 1,632 198 3,386 897,754 3,464 4a.1.1.4 Pressurizer 8
52 490 412 1,019 383 2,365 2,365 3,882 240,508 1,866 1,500 4a.1.1.5 Steam Generators 69 4,634 1,961 2,135 2,322 5,893 3,531 20,545 20,545 40,262 22,448 3,346,591 20,508 2,250 4a.1.1.6 Retired Steam Generator Units 2,017 1,530 2,322 5,893 2,253 14,013 14,013 40,262 22,448 3,346,591 10,800 2,250 4a.1.1.7 CRDMs/ICIs/Service Structure Removal 28 82 190 33 51 161 106 651 651 753 2,947 81,666 2,120 4a.1.1.8 Reactor Vessel Internals 48 2,147 3,844 492 3,381 163 4,433 14,507 14,507 2,312 376 470 326,129 18,767 883 4a.1.1.9 Vessel & Internals GTCC Disposal 10,634 1,595 12,229 12,229 499 104,146 4a.1.1.10 Reactor Vessel 4,873 959 278 3,718 163 5,848 15,839 15,839 6,481 2,955 954,563 18,767 883 4a.1.1 Totals 210 12,050 9,525 5,050 4,966 31,876 326 18,609 82,612 82,612 82,217 64,646 3,330 470 499 9,468,553 80,740 7,765 Removal of Major Equipment 4a.1.2 Main Turbine/Generator 408 316 36 770 696 429 2,656 2,656 4,921 2,740 664,183 8,457 4a.1.3 Main Condensers 1,141 163 64 638 609 559 3,174 3,174 7,701 2,270 550,231 24,132 Cascading Costs from Clean Building Demolition 4a.1.4.1 Reactor 840 126 966 966 10,575 4a.1.4.2 Auxiliary 422 63 486 486 5,551 4a.1.4.3 Fuel Building 206 31 236 236 2,395 4a.1.4.4 Hot Machine Shop 1
0 1
1 16 4a.1.4.5 Radwaste 88 13 101 101 1,108 4a.1.4 Totals 1,557 233 1,790 1,790 19,645 Disposal of Plant Systems 4a.1.5.1 100 Aux.Bldg Non-System Specific RCA 655 10 22 570 253 1,510 1,510 7,629 309,812 13,471 4a.1.5.2 100 Auxiliary Bldg Non-System Specific 95 1
3 62 6
35 201 201 824 22 35,448 1,970 4a.1.5.3 AB - Main Steam 241 36 277 277 5,833 4a.1.5.4 AB - Main Steam RCA 73 3
6 161 44 286 286 2,156 87,550 1,495 4a.1.5.5 AC - Main Turbine 237 36 273 273 5,641 4a.1.5.6 AD - Condensate 264 40 303 303 6,144 4a.1.5.7 AE - Feedwater 181 27 208 208 4,271 4a.1.5.8 AF - Feedwater Heater Extraction 221 33 255 255 5,352 4a.1.5.9 AK - Condensate Demineralizer 82 12 94 94 1,944 4a.1.5.10 AL - Auxiliary Feedwater 36 5
41 41 852 4a.1.5.11 AQ - Condensate & Feedwater Chem Addtn 20 3
23 23 468 4a.1.5.12 BM - Steam Generator Blowdown 93 1
3 86 37 221 221 1,157 46,993 1,915 4a.1.5.13 BM - Steam Generator Blowdown - RCA 336 5
12 307 132 793 793 4,109 166,857 6,849 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 8 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Disposal of Plant Systems (continued) 4a.1.5.14 BN - Borated Refueling Water Storage 283 8
18 467 144 921 921 6,255 254,024 5,898 4a.1.5.15 CA - Steam Seal 19 3
22 22 455 4a.1.5.16 CB - Main Turbine Lube Oil 54 8
62 62 1,207 4a.1.5.17 CC - Generator Hydrogen Seal & CO2 9
1 10 10 198 4a.1.5.18 CD - Generator Seal Oil 12 2
14 14 287 4a.1.5.19 CE - Stator Cooling Water 11 2
12 12 241 4a.1.5.20 CF - Lube Oil Storage Xfer & Prfication 34 5
40 40 812 4a.1.5.21 CG - Condenser Air Removal 28 4
32 32 657 4a.1.5.22 CH - Main Turbine Control Oil 55 8
64 64 1,219 4a.1.5.23 DA - Circulating Water 311 47 358 358 7,502 4a.1.5.24 DB - Cooling Tower Makeup & Blowdown 53 8
61 61 1,260 4a.1.5.25 DD - Cooling Water Chemical Control Sys 46 7
53 53 1,073 4a.1.5.26 DD - Cooling Wtr Chem Control RCA 251 5
10 266 105 636 636 3,555 144,376 4,866 4a.1.5.27 EJ - Residual Heat Removal 311 20 27 335 221 189 1,102 1,102 4,481 825 255,781 6,506 4a.1.5.28 EM - High Pressure Coolant Injection 242 3
6 165 86 502 502 2,214 89,903 4,932 4a.1.5.29 EN - Containment Spray 196 4
9 226 85 519 519 3,026 122,874 4,005 4a.1.5.30 EP - Accumulator Safety Injection 136 2
6 149 57 350 350 1,989 80,762 2,775 4a.1.5.31 FA - Auxiliary Steam Generator 21 3
24 24 521 4a.1.5.32 FB - Auxiliary Steam 87 13 100 100 2,106 4a.1.5.33 FB - Auxiliary Steam RCA 74 1
2 61 28 167 167 816 33,148 1,492 4a.1.5.34 FC - Auxiliary Turbines 57 9
65 65 1,320 4a.1.5.35 FE - Auxiliary Steam Chemical Addition 4
1 5
5 105 4a.1.5.36 GE - Turbine Building HVAC 152 23 174 174 3,792 4a.1.5.37 GS - Containment Hydrogen Control 61 1
2 60 25 149 149 801 32,539 1,265 4a.1.5.38 HE - Boron Recycle 389 16 20 259 150 178 1,012 1,012 3,460 583 190,724 7,930 4a.1.5.39 HF - Secondary Liquid Waste 784 33 44 630 301 375 2,166 2,166 8,431 1,173 442,934 16,163 4a.1.5.40 JA - Auxiliary Oil & Transfer 29 4
33 33 687 4a.1.5.41 KS - Bulk Chemical Storage 86 8
18 482 97 691 691 6,449 261,890 1,808 4a.1.5.42 LE - Oily Waste 161 24 186 186 3,865 4a.1.5.43 LE - Oily Waste RCA 213 3
6 169 80 471 471 2,256 91,628 4,181 4a.1.5.44 Turbine Bldg Non-System Specific 677 101 778 778 15,405 4a.1.5 Totals 7,376 124 215 4,454 677 2,416 15,263 11,697 3,566 59,608 2,604 2,647,241 160,738 4a.1.6 Scaffolding in support of decommissioning 1,320 21 5
102 12 351 1,811 1,811 1,233 69 62,010 31,913 4a.1 Subtotal Period 4a Activity Costs 210 23,853 10,149 5,370 10,929 33,871 326 22,598 107,306 103,741 3,566 155,680 72,330 3,330 470 499 13,392,220 325,624 7,765 Period 4a Collateral Costs 4a.3.1 Process liquid waste 31 14 70 69 45 230 230 249 14,949 49 4a.3.2 Small tool allowance 250 37 287 258 29 4a.3.3 Survey and Release of Scrap Metal 753 113 866 866 4a.3 Subtotal Period 4a Collateral Costs 31 250 14 70 69 753 195 1,383 1,354 29 249 14,949 49 Period 4a Period-Dependent Costs 4a.4.1 Decon supplies 56 14 70 70 4a.4.2 Insurance 549 55 603 603 4a.4.3 Property taxes 329 33 362 326 36 4a.4.4 Health physics supplies 1,771 443 2,214 2,214 4a.4.5 Heavy equipment rental 2,240 336 2,576 2,576 4a.4.6 Disposal of DAW generated 79 44 294 88 505 505 4,905 98,285 161 4a.4.7 Plant energy budget 1,413 212 1,625 1,625 4a.4.8 NRC Fees 723 72 795 795 4a.4.9 Liquid Radwaste Processing Equipment/Services 412 62 474 474 4a.4.10 Corporate Allocations 2,160 216 2,376 2,376 4a.4.11 Security Staff Cost 2,845 427 3,271 3,271 71,607 4a.4.12 DOC Staff Cost 12,947 1,942 14,890 14,890 158,109 4a.4.13 Utility Staff Cost 18,523 2,778 21,301 21,301 286,429 4a.4 Subtotal Period 4a Period-Dependent Costs 56 4,011 79 44 294 39,901 6,678 51,063 51,027 36 4,905 98,285 161 516,144 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 9 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours 4a.0 TOTAL PERIOD 4a COST 297 28,114 10,242 5,485 10,929 34,235 40,980 29,471 159,753 156,122 3,631 155,680 77,484 3,330 470 499 13,505,450 325,834 523,910 PERIOD 4b - Site Decontamination Period 4b Direct Decommissioning Activities 4b.1.1 Remove spent fuel racks 687 79 233 87 1,323 730 3,140 3,140 4,933 442,623 1,925 Disposal of Plant Systems 4b.1.2.1 200 Reactor Bldg Non-System Specific 75 1
2 38 4
26 144 144 502 13 21,587 1,521 4b.1.2.2 200 Reactor Bldg Non-System Specific RCA 521 6
14 356 186 1,084 1,084 4,768 193,612 10,425 4b.1.2.3 300 Control Bldg Non-System Specific 167 3
6 160 67 403 403 2,139 86,849 3,413 4b.1.2.4 300 Control Bldg Non-System Specific Cln 1,361 204 1,566 1,566 29,076 4b.1.2.5 600 Fuel Bldg Non-Specific Systems RCA 289 4
9 239 110 651 651 3,200 129,974 5,859 4b.1.2.6 600 Fuel Bldg Non-System Specific 40 1
1 24 2
14 82 82 322 9
13,827 825 4b.1.2.7 700 Radwaste Bldg Non-Sys Specific RCA 1,071 16 36 948 417 2,489 2,489 12,684 515,103 21,919 4b.1.2.8 700 Radwaste Bldg Non-System Specific 153 2
4 99 9
56 324 324 1,329 35 57,135 3,158 4b.1.2.9 AN - Demineralized Wtr Storage & Xfer 136 20 156 156 3,283 4b.1.2.10 AN - Demineralized Wtr Strg & Xfer RCA 36 0
1 23 13 73 73 314 12,759 711 4b.1.2.11 AP - Condensate Storage & Transfer 81 12 93 93 1,794 4b.1.2.12 BB - Reactor Coolant System 252 18 21 193 214 150 849 849 2,586 903 176,605 5,351 4b.1.2.13 BG - Chemical & Volume Control 721 45 55 612 490 407 2,330 2,330 8,192 1,842 496,399 14,848 4b.1.2.14 BL - Reactor Makeup Water 240 10 12 189 79 111 641 641 2,529 315 129,173 4,917 4b.1.2.15 DE - Intake & Water Treatment 107 16 123 123 2,478 4b.1.2.16 DE - Intake & Water Treatment RCA 238 15 34 891 200 1,378 1,378 11,923 484,206 4,993 4b.1.2.17 EA - Service Water 130 19 149 149 3,145 4b.1.2.18 EA - Service Water RCA 41 2
4 93 25 165 165 1,248 50,693 829 4b.1.2.19 EB - Closed Cooling Water 52 8
60 60 1,267 4b.1.2.20 EC - Fuel Pool Cooling & Cleanup 309 5
12 308 126 760 760 4,119 167,293 6,330 4b.1.2.21 EF - Essential Service Water 301 45 346 346 7,244 4b.1.2.22 EF - Essential Service Water RCA 184 7
15 398 109 713 713 5,326 216,287 3,802 4b.1.2.23 EG - Component Cooling Water RCA 220 33 253 253 5,335 4b.1.2.24 GA - Plant Heating 78 12 90 90 1,912 4b.1.2.25 GA - Plant Heating RCA 85 1
2 48 29 165 165 638 25,924 1,698 4b.1.2.26 GA-Plant Heating Fuel Building 17 0
0 8
5 31 31 107 4,351 338 4b.1.2.27 GB - Central Chilled Water 74 11 85 85 1,803 4b.1.2.28 GB - Central Chilled Water RCA 23 0
1 14 8
46 46 187 7,591 463 4b.1.2.29 GD - Essential Serv Wtr Pumphouse HVAC 16 2
19 19 414 4b.1.2.30 GF - Miscellaneous Building HVAC 117 3
6 152 53 331 331 2,034 82,602 2,026 4b.1.2.31 GG - Fuel Building HVAC 218 5
11 295 101 630 630 3,945 160,195 4,031 4b.1.2.32 GH - Radwaste Building HVAC 159 3
7 191 70 431 431 2,561 104,012 2,973 4b.1.2.33 GK - Control Building HVAC 151 23 174 174 3,900 4b.1.2.34 GL - Auxiliary Building HVAC 396 7
15 402 162 983 983 5,381 218,514 7,311 4b.1.2.35 GM - Diesel Generator Building HVAC 27 4
31 31 692 4b.1.2.36 GN - Containment Cooling 426 10 24 618 204 1,281 1,281 8,264 335,602 8,118 4b.1.2.37 GP - Containment Intgratd Leak Rate Test 36 1
2 43 16 98 98 580 23,570 737 4b.1.2.38 GR - Containment Atmospheric Control 16 1
3 85 18 124 124 1,143 46,407 341 4b.1.2.39 GT - Containment Purge HVAC 101 3
6 163 51 324 324 2,185 88,746 1,933 4b.1.2.40 HA - Gaseous Radwaste 282 5
11 276 114 688 688 3,699 150,219 5,633 4b.1.2.41 HB - Liquid Radwaste 694 33 39 550 274 334 1,924 1,924 7,362 1,077 390,669 14,095 4b.1.2.42 HC - Solid Radwaste 285 15 19 223 163 150 855 855 2,985 618 175,776 5,831 4b.1.2.43 HD - Decontamination 85 4
5 73 32 41 241 241 983 125 50,772 1,722 4b.1.2.44 JE - Emergency Fuel Oil 56 8
65 65 1,260 4b.1.2.45 KA - Compressed Air 171 26 196 196 4,187 4b.1.2.46 KA - Compressed Air RCA 115 1
2 60 38 216 216 801 32,538 2,242 4b.1.2.47 KB - Breathing Air 21 3
24 24 516 4b.1.2.48 KB - Breathing Air RCA 17 0
0 5
5 28 28 71 2,874 376 4b.1.2.49 KC - Fire Protection 338 51 389 389 8,376 4b.1.2.50 KC - Fire Protection RCA 365 6
13 330 143 857 857 4,411 179,151 6,953 4b.1.2.51 KC-Fire Protection Fuel Building 108 2
4 93 42 248 248 1,239 50,329 2,084 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 10 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Disposal of Plant Systems (continued) 4b.1.2.52 KD - Domestic Water 157 24 181 181 3,837 4b.1.2.53 KD - Domestic Water RCA 23 0
1 18 9
52 52 247 10,039 448 4b.1.2.54 KE - Fuel Handling & Storage Rctor vssl 16 1
3 66 14 100 100 882 35,813 323 4b.1.2.55 KH - Service Gas (CO2 N2 H2 & O2) 50 7
57 57 1,226 4b.1.2.56 KH - Service Gas (CO2 N2 H2 & O2) RCA 229 3
7 182 86 507 507 2,433 98,813 4,378 4b.1.2.57 KJ - Standby Diesel Engine 298 45 343 343 6,749 4b.1.2.58 LA - Sanitary Drains 40 6
46 46 972 4b.1.2.59 LA - Sanitary Drains RCA 98 2
4 95 39 238 238 1,273 51,684 1,811 4b.1.2.60 LB - Roof Drains 53 8
61 61 1,276 4b.1.2.61 LB - Roof Drains RCA 131 3
6 160 58 358 358 2,139 86,858 2,628 4b.1.2.62 LD - Chemical & Detergent Waste 89 1
2 60 32 183 183 797 32,369 1,828 4b.1.2.63 LF - Floor & Equipment Drains 1,141 50 64 498 687 546 2,985 2,985 6,660 2,567 500,138 23,236 4b.1.2.64 RM - Process Sampling & Analysis 113 1
3 74 40 231 231 990 40,200 2,335 4b.1.2.65 SJ - Nuclear Sampling 62 1
2 51 24 139 139 677 27,501 1,312 4b.1.2.66 UB - Servces Stores Site Security Bldg 151 23 174 174 3,571 4b.1.2.67 Yard Non-System Specific 27 4
31 31 603 4b.1.2 Totals 13,883 294 488 9,404 1,955 5,063 31,087 26,376 4,711 125,856 7,504 5,764,757 291,021 4b.1.3 Scaffolding in support of decommissioning 1,980 32 8
153 18 527 2,717 2,717 1,849 104 93,015 47,869 Decontamination of Site Buildings 4b.1.4.1 Reactor 1,034 865 119 152 448 1,138 1,120 4,875 4,875 5,995 7,069 907,911 37,506 4b.1.4.2 Auxiliary 530 217 30 41 154 94 375 1,441 1,441 2,058 1,700 250,031 14,928 4b.1.4.3 Communication Corridor - Contaminated 12 3
1 1
1 2
8 27 27 17 36 4,294 300 4b.1.4.4 Fuel Building 665 689 12 17 202 33 547 2,165 2,165 2,705 487 157,587 26,845 4b.1.4.5 Hot Machine Shop 15 6
1 1
2 10 34 34 44 4,446 412 4b.1.4.6 RAM Storage Building 36 8
2 2
1 5
22 76 76 19 93 9,971 901 4b.1.4.7 Radioactive and Personnel Tunnel 5
5 0
1 1
4 16 16 25 2,532 190 4b.1.4.8 Radwaste 282 100 15 21 63 49 193 723 723 844 893 122,355 7,650 4b.1.4.9 Radwaste Drum Storage 32 10 2
2 5
5 21 77 77 66 99 12,556 833 4b.1.4.10 Steam Generator Replacement Bldgs 204 102 306 306 3,780 4b.1.4 Totals 2,813 1,904 182 237 875 1,330 2,400 9,741 9,741 11,704 10,447 1,471,684 93,345 4b.1 Subtotal Period 4b Activity Costs 3,500 17,846 741 820 10,432 4,626 8,720 46,685 41,974 4,711 139,409 22,988 7,772,079 434,160 Period 4b Additional Costs 4b.2.1 Sanitary Treatment Lagoon LLW 5
60 783 183 152 1,184 1,184 3,600 345,600 388 4b.2.2 Cooling Tower Asbestos Panel Removal 4,554 105 365 683 5,706 5,706 136,405 101,822 4b.2.3 License Termination Survey Program Management 1,467 440 1,907 1,907 12,480 4b.2 Subtotal Period 4b Additional Costs 4,559 60 888 365 183 1,467 1,275 8,797 8,797 136,405 3,600 345,600 102,210 12,480 Period 4b Collateral Costs 4b.3.1 Process liquid waste 84 38 190 187 121 620 620 673 40,404 131 4b.3.2 Small tool allowance 410 61 471 471 4b.3.3 Decommissioning Equipment Disposition 103 30 497 100 114 844 844 6,000 373 303,507 88 4b.3.4 Survey and Release of Scrap Metal 1,048 157 1,205 1,205 4b.3 Subtotal Period 4b Collateral Costs 84 410 142 219 497 288 1,048 454 3,141 3,141 6,000 1,047 343,911 219 Period 4b Period-Dependent Costs 4b.4.1 Decon supplies 1,189 297 1,486 1,486 4b.4.2 Insurance 1,420 142 1,562 1,562 4b.4.3 Property taxes 853 85 938 938 4b.4.4 Health physics supplies 3,341 835 4,176 4,176 4b.4.5 Heavy equipment rental 5,757 863 6,620 6,620 4b.4.6 Disposal of DAW generated 116 65 435 130 747 747 7,248 145,249 238 4b.4.7 Plant energy budget 2,888 433 3,321 3,321 4b.4.8 NRC Fees 1,872 187 2,059 2,059 4b.4.9 Liquid Radwaste Processing Equipment/Services 1,067 160 1,227 1,227 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 11 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Period 4b Period-Dependent Costs (continued) 4b.4.10 Corporate Allocations 2,430 243 2,673 2,673 4b.4.11 Security Staff Cost 7,364 1,105 8,468 8,468 185,357 4b.4.12 DOC Staff Cost 32,688 4,903 37,591 37,591 397,406 4b.4.13 Utility Staff Cost 45,482 6,822 52,304 52,304 699,909 4b.4 Subtotal Period 4b Period-Dependent Costs 1,189 9,098 116 65 435 96,062 16,207 123,172 123,172 7,248 145,249 238 1,282,671 4b.0 TOTAL PERIOD 4b COST 4,772 31,912 1,060 1,992 11,293 5,532 98,577 26,656 181,795 177,084 4,711 281,814 34,883 8,606,838 536,828 1,295,151 PERIOD 4e - License Termination Period 4e Direct Decommissioning Activities 4e.1.1 ORISE confirmatory survey 156 47 203 203 4e.1.2 Terminate license a
4e.1 Subtotal Period 4e Activity Costs 156 47 203 203 Period 4e Additional Costs 4e.2.1 License Termination Survey 8,311 2,493 10,804 10,804 152,357 6,240 4e.2 Subtotal Period 4e Additional Costs 8,311 2,493 10,804 10,804 152,357 6,240 Period 4e Collateral Costs 4e.3.1 DOC staff relocation expenses 1,423 213 1,636 1,636 4e.3 Subtotal Period 4e Collateral Costs 1,423 213 1,636 1,636 Period 4e Period-Dependent Costs 4e.4.1 Insurance 378 38 415 415 4e.4.2 Property taxes 227 23 249 249 4e.4.3 Health physics supplies 875 219 1,093 1,093 4e.4.4 Disposal of DAW generated 6
4 23 7
40 40 391 7,826 13 4e.4.5 Plant energy budget 205 31 235 235 4e.4.6 NRC Fees 534 53 587 587 4e.4.7 Corporate Allocations 360 36 396 396 4e.4.8 Security Staff Cost 817 123 939 939 18,926 4e.4.9 DOC Staff Cost 4,874 731 5,605 5,605 57,566 4e.4.10 Utility Staff Cost 5,510 826 6,336 6,336 74,914 4e.4 Subtotal Period 4e Period-Dependent Costs 875 6
4 23 12,903 2,086 15,897 15,897 391 7,826 13 151,406 4e.0 TOTAL PERIOD 4e COST 875 6
4 23 22,793 4,840 28,540 28,540 391 7,826 152,370 157,646 PERIOD 4 TOTALS 5,070 60,900 11,308 7,480 22,222 39,790 162,350 60,967 370,088 361,747 8,342 437,494 112,757 3,330 470 499 22,120,120 1,015,032 1,976,707 PERIOD 5b - Site Restoration Period 5b Direct Decommissioning Activities Demolition of Remaining Site Buildings 5b.1.1.1 Reactor 4,769 715 5,484 5,484 60,047 5b.1.1.2 Auxiliary 3,801 570 4,371 4,371 49,968 5b.1.1.3 Auxiliary Boiler 34 5
39 39 619 5b.1.1.4 Barge Facility 1,423 214 1,637 1,637 18,771 5b.1.1.5 Circulating & Service Water Pumphouse 286 43 329 329 4,345 5b.1.1.6 Communication Corridor - Clean 1,227 184 1,411 1,411 17,215 5b.1.1.7 Communication Corridor - Contaminated 52 8
60 60 674 5b.1.1.8 Cooling Tower Basemat 812 122 933 933 13,472 5b.1.1.9 Diesel Generator 454 68 522 522 5,492 5b.1.1.10 Essential Service Water Pumphouse 270 41 311 311 3,938 5b.1.1.11 Fire Water Pumphouse 25 4
29 29 382 5b.1.1.12 Fuel Building 1,898 285 2,183 2,183 22,580 5b.1.1.13 Hot Machine Shop 21 3
25 25 417 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 12 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours Demolition of Remaining Site Buildings (continued) 5b.1.1.14 Intake 342 51 393 393 4,224 5b.1.1.15 Misc. Structures 2,177 327 2,504 2,504 27,921 5b.1.1.16 Miscellaneous Site Foundations 337 51 388 388 5,478 5b.1.1.17 Outage Maintenance 167 25 192 192 3,190 5b.1.1.18 RAM Storage Building 62 9
72 72 1,081 5b.1.1.19 Radioactive and Personnel Tunnel 25 4
29 29 383 5b.1.1.20 Radwaste 1,696 254 1,951 1,951 21,798 5b.1.1.21 Radwaste Drum Storage 249 37 287 287 3,840 5b.1.1.22 Security Additions 2,076 311 2,387 2,387 20,977 5b.1.1.23 Service 462 69 531 531 6,045 5b.1.1.24 Sludge Pump Station & Lagoon 23 3
26 26 313 5b.1.1.25 Steam Generator Replacement Bldgs 1,080 162 1,242 1,242 15,693 5b.1.1.26 Turbine Building 3,407 511 3,918 3,918 55,694 5b.1.1.27 Turbine Pedestal 983 147 1,130 1,130 10,928 5b.1.1.28 U.H.S. Cooling Tower 595 89 685 685 6,681 5b.1.1.29 Water Treatment Plant 1
0 1
1 9
5b.1.1 Totals 28,754 4,313 33,068 33,068 382,172 Site Closeout Activities 5b.1.2 BackFill Site 4,694 704 5,398 5,398 17,928 5b.1.3 Grade & landscape site 121 18 139 139 592 5b.1.4 Final report to NRC 185 28 213 213 1,560 5b.1 Subtotal Period 5b Activity Costs 33,570 185 5,063 38,818 213 38,605 400,692 1,560 Period 5b Additional Costs 5b.2.1 Concrete Crushing 1,125 8
170 1,303 1,303 5,830 5b.2.2 Mine Area Backfill 4,179 627 4,806 4,806 15,960 5b.2.3 Cooling Tower Discharge & Intake Pipe Flow Fill 3,937 590 4,527 4,527 9,588 5b.2.4 Cooling Tower Demolition 3,706 556 4,262 4,262 19,680 5b.2 Subtotal Period 5b Additional Costs 12,946 8
1,943 14,897 14,897 51,058 Period 5b Collateral Costs 5b.3.1 Small tool allowance 374 56 430 430 5b.3 Subtotal Period 5b Collateral Costs 374 56 430 430 Period 5b Period-Dependent Costs 5b.4.1 Insurance 5b.4.2 Property taxes 451 45 496 496 5b.4.3 Heavy equipment rental 4,080 612 4,692 4,692 5b.4.4 Plant energy budget 204 31 234 234 5b.4.5 Corporate Allocations 990 99 1,089 1,089 5b.4.6 Security Staff Cost 1,625 244 1,869 1,869 37,646 5b.4.7 DOC Staff Cost 9,431 1,415 10,845 10,845 106,663 5b.4.8 Utility Staff Cost 4,458 669 5,127 5,127 61,174 5b.4 Subtotal Period 5b Period-Dependent Costs 4,080 17,158 3,114 24,352 1,089 23,263 205,483 5b.0 TOTAL PERIOD 5b COST 50,970 17,351 10,176 78,496 1,302 77,195 451,750 207,043 PERIOD 5 TOTALS 50,970 17,351 10,176 78,496 1,302 77,195 451,750 207,043 TOTAL COST TO DECOMMISSION 11,096 120,424 11,848 8,422 22,222 41,974 579,638 133,944 929,568 774,447 68,084 87,037 437,494 139,840 3,330 470 499 22,765,170 1,561,727 6,978,627 TLG Services, Inc.
Callaway Plant Decommissioning Cost Analysis Document A22-1599-002, Rev. 0 Appendix D, Page 13 of 13 Table D Callaway Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2008 dollars)
Costs run: Mon, Aug 25, 2008 at 15:53:18 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial /
Utility and Activity DECCER Version 2007.02.18 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term.
Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs.
Manhours Manhours TOTAL COST TO DECOMMISSION WITH 16.84% CONTINGENCY:
$929,568 thousands of 2008 dollars TOTAL NRC LICENSE TERMINATION COST IS 83.31% OR:
$774,447 thousands of 2008 dollars SPENT FUEL MANAGEMENT COST IS 7.32% OR:
$68,084 thousands of 2008 dollars NON-NUCLEAR DEMOLITION COST IS 9.36% OR:
$87,037 thousands of 2008 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):
143,640 cubic feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:
499 cubic feet TOTAL SCRAP METAL REMOVED:
70,304 tons TOTAL CRAFT LABOR REQUIREMENTS:
1,561,727 man-hours End Notes:
n/a - indicates that this activity not charged as decommissioning expense.
a - indicates that this activity performed by decommissioning staff.
0 - indicates that this value is less than 0.5 but is non-zero.
a cell containing " - " indicates a zero value TLG Services, Inc.