ULNRC-06447, ISFSI Decommissioning Funding Plan

ISFSI Decommissioning Funding Plan

ML18218A205
Person / Time
Site:	Callaway
Issue date:	08/06/2018
From:	Wink R Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
ULNRC-06447
Download: ML18218A205 (17)

Text

WAmerefi Caltawa3 Plant MISSOURI August 6. 2018 ULNRC-06447 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington. DC 20555-000 1 10 CFR 72.30 Ladies and Gentlemen:

DOCKET NUMBERS 50-483 AND 72-1045 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 ISFSI DECOMMISSIONING FUNDING PLAN In accordance with the requirements of 10 CFR 72.30 on financial assurance and recordkeeping for decommissioning. Union Electric Company (Ameren Missouri) is hereby submitting its updated Decommissioning funding Plan for the Independent Spent fuel Storage Installation (1Sf SI) located at the Callaway Energy Center. The updated plan is provided as an attachment to this letter.

Based on the date of Ameren Missouris last submittal for providing a funding plan update, the date of this submittal is consistent with the 10 CfR 72.30 requirement for pLan updates to be submitted at intervals not to exceed 3 years. It should be noted that the next 10 CFR 72.30 submittal will be made ahead of its August 2021 triennial due date (submittal is planned for the first quarter of 2021) in order to better coordinate it (and future submittals) with a separate submittal required for the State of Missouri, i.e., the triennial filing of updated decommissioning cost estimates and associated funding levels, as required by Missouri regulation 4 CSR 240-3.185. Submittal of Reports Pertaining to the Decommissioning of Electric Utility Plants. future 10 CFR 72.30 submittals (beyond 2021) will be made at the required triennial frequency, but their submittal dates will be based on the date of the 2021 submittal.

This letter does not contain any new commitments. If you have any questions on this report, please contact Mr. Tom Etwood at (3 14) 225-1905.

Wink Manager, Regulatory Affairs

Attachment:

Callaway Energy Center 10 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision I P.O. Box 620 : Fulton, MO 65251 : AmerenMjssouri.com

ULNRC-06447 August 6. 2018 Page 2 of 3 cc: Mr. Kriss M. Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington. TX 76011-4511 Director Division of Spent fuel Management Office of Nuclear Material and Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555-00001 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission

$201 NRC Road Steedman, MO 65077 Mr. L. John Kios Project Manager. Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O9E3 Washington, DC 20555-0001

ULNRC-06447 August 6,2018 Page 3 of 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place. Suite 1050 Fort Worth TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

F. M. Diya I. E. Herrmaim B. L. Cox S. P. Banker R. C. Wink T. B. Elwood K. Redhage B. F. Holderness G. P. Gary Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)

Mrs. Collette Linder, REP Manager (SEMA)

Mr. Chris Wieberg (DNR)

Mr. Steve Feeler (DNR)

Mr. Dru Buntin (DNR)

Ameren MISSOURI Callaway Energy Center 10 CFR 72.30 ISFSI Decommissioning Funding Plan Revision I Prepared by Ameren Services for Ameren Missouri 1901 Chouteau Avenue P0 Box 66149, MC 200 St. Louis, MO 63166-6149 July 31, 2018

Prepared by Ameren Missouri July37, 2018 Table of Contents BACKGROUND AND INTRODUCTION 3 SPENT FUEL MANAGEMENT STRATEGY 3 ISFSI DECOMMISSIONING STRATEGY 5 ISFSI DESCRIPTION 5 KEY ASSUMPTIONS I ESTIMATING APPROACH 7 COST ESTIMATE 8 FINANCIAL ASSURANCE 9 TABLE I SIGNIFICANT QUANTITIES AND PHYSICAL DIMENSIONS 13 TABLE 2 ISFSI DECOMMISSIONING COSTSI AND WASTE VOLUMES 14 70 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 7 2

Prepared by Ameren Missouri July31, 2078 Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, [1] with the rule becoming effective on December 17, 2012, Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, a detailed cost estimate is provided herein for decommissioning the ISFSI at Callaway Energy Center (Callaway) in an amount reflecting:

1. The work is performed by an independent contractor,

2. An adequate contingency factor, and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 The following are also provided herein:

1. Identification of the key assumptions contained in the cost estimate, and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

Spent Fuel Management Strategy The operating license for Callaway, renewed on March 6, 2015, is set to expire on October 18, 2044. Approximately 3,782 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed with spent fuel planned to be transferred to the dry storage modules located at the ISFSI, to support continued plant operations. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2)).

I U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 Decommissioning Planning, Nuclear Regulatory Commission, Federal Register Vo]ume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent fuel at Power Reactor Sites.

10 CFR 7230 ISFSI Decommissioning Funding Plan, Revision 1 3

Prepared byAmeren Missouri July 37, 2078 Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order in which it was discharged from the reactor.[3l In January 2013, the DOE issued a report, Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the Blue Ribbon Commission on Americas Nuclear Future and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[4] The report stated, [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that: ...[AJdvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; Based upon DOEs latest strategy, Ameren Missouri believes that one or more monitored interim storage facilities could be put into place within a reasonable time. Ameren Missouris current spent fuel management plan for the Callaway spent fuel is based in general upon the spent fuel being fully removed from the Callaway site by 2050. The estimates described in this analysis were developed based on this assumption that DOE would remove spent fuel from the site by 2050, thus allowing decommissioning of the ISFSI to proceed.

Ameren Missouris position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this position.

U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV Responsibilities of the Parties, B. DOE Responsibilities, 5(a) DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S. DOE, January 11,2013.

70 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 1 4

Prepared by Ameren Missouri July 37, 2078 ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISfSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

ISFSI Description The Callaway ISFSI is based upon Holtec Internationals (Holtec) HI-STORM UMAX underground system for the dry storage of used nuclear fuel. In this system, spent fuel is stored in a multi purpose container (MPC) and placed within an underground vertical ventilated module (VVM).

The ISFSI pad is designed for 48 WMs, although all the cells may not be needed, depending upon DOE performance.

In addition to the spent fuel stored at the ISFSI, there is projected to be five additional modules used for Greater-than-Class-C (GTCC) waste storage. The multi-purpose containers used for this GTCC waste canister are also expected to be transferred to the DOE at the same time as the spent fuel transfer.

The key constituent of a HI-STORM UMAX VVM is the Cavity Enclosure Container (CEC). The CEC is a closed bottom, open top, thick-walled cylindrical vessel that has no penetrations or openings. The closure lid completes the physical embodiment of the HI-STORM UMAX VVM once the loaded MPC is placed inside the CEC. The closure lid is a steel structure filled with plain concrete and is designed to protect the VVM from the impact of design basis missiles as well as to provide an inlet and outlet for air flow.

The wall thickness of the welded steel CEC is approximately 3/4 inches. The CEC rests on a foundation pad with a thickness of 2 feet 9 inches, approximately 16 feet 11 inches below the grade-level ISfSI pad.

70 CFR 7230 ISFSI Decommissioning Funding Plan, Revision 1 5

Prepared by Ameren Missouri July 37, 2078 A divider shell divides the CEC into an inlet flow downcomer and an outlet flow passage. It is a vertical cylindrical shell concentrically situated in the CEC and is not attached to the CEC, which allows its convenient removal for decommissioning.

All exposed surfaces of the CEC are made from ferritic steels that are painted and protected from corrosion. The inside surface of the CECs and the divider shells is protected by paint. In addition, one side of the divider shell is further protected by insulation.

The VVMs are surrounded by controlled low-strength material (CLSM), a self-compacted, cementitious material.

A reinforced concrete slab (ISfSI pad) surrounds the upper portion of the CEC and extends to the underside of the CEC flange. The ISFSI pad provides robust support for a toaded transporter and enables rainwater to flow away from the storage array. The concrete ISFSI pad is approximately 2 feet 6 inches thick.

Ameren Missouris current spent fuel management plan for the Callaway spent fuel would result in all 48 MPCs being placed at the ISFSI by the year 2044, excluding GTCC.

The storage modules used for the GTCC canisters (estimated quantity of 5] are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

70 CFR 7230 ISFSI Decommissioning Funding Plan, Revision 7 6

Prepared by Ameren Missouri 2: July 31, 2018 Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2044) and the DOEs spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec, does not expect the WMs to have any interior or exterior radioactive surface contamination.[5l It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small.[6l This assumption is adopted for this analysis.

The decommissioning estimate is based on the conservative premise that a small percentage of the WMs wouLd contain very low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 6 of the 48 MPCs are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of MPCs required for the final core off-load (i.e., 193 offloaded assemblies/unit, 37 assemblies per MPC) which results in a total of 6 VVMs that contain residual radioactivity. It is assumed that these are the final VVMs offloaded; consequently, they have the least time for radioactive decay of the neutron activation products.

ft is not expected that there will be any residual contamination left on the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISfSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

The ISFSI storage modules were constructed in the original Callaway unit 2 excavation, after the non-usable sediment was removed and replaced with clean fill. The clean fill was obtained from a borrow pit and suppliers located outside of the Owner Control Area and not radiologically Final Safety Analysis Report for the HI-STORM UMAX Canister Storage System, FSAR Report No. Hl-2 115090, Rev. 1, at page 2-120.

6 Ibid.

10 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 1 7

Prepared by Ameren Missouri July 31. 2016 affected by plant Operations. It is assumed that there is no subsurface soiL in the proximity of the ISfSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

Costs are reported in 2017 dollars and based upon the triennial decommissioning analysis prepared for Callaway in August, 2017.[]

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Ameren Missouri, as licensee, will oversee the site activities. The estimate includes Ameren Missouris labor and overhead costs.

Low-level radioactive waste packaging, transport and disposal costs are based on rates consistent with the most recently developed decommissioning cost estimate.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[81 The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the

§20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

Decommissioning Cost Analysis for the Callaway Energy Center, TLG Services, Inc. Document A22-1739-001, Rev. 0, dated August 2017.

Consolidated Decommissioning Guidance Financial Assurance, Recordkeeping, and Timeliness, U.S. Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 10 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 1 8

Prepared by Ameren Missouri July 31, 2018

• An initial planning phase - empty VVMs are characterized and the specifications and work procedures for the decontamination (MPC support structure removal) developed.

• The remediation phase - residual radioactivity is removed. The empty WMs are used as waste containers, transported to the low-level waste site, and disposed of at low-level waste.

• The final phase - license termination surveys and independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Ameren Missouris oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in years 2050 2051, following all spent fuel removal.

Financial Assurance This section describes the methodology by which Ameren Missouri is providing financial assurance for decommissioning the ISIFI at the end of its useful life.

ISFSI operations at Callaway are required due to the DOEs) failure to remove spent nuclear fuel from the Callaway Energy Center in a timely manner pursuant to a written agreement. The costs for management of the spent fttel are costs for which the DOE is responsible under federal law and the Standard Contract.

It is uncertain as to whether the DOE will acttially provide reimbursement for the ISFSI decommissioning costs: and if such reimbursement is provided, when it will occur. Consequently.

Ameren Missouri intends to provide financial assurance for the ISFSI decommissioning utilizing the External Sinking Fund methodology, as described in the following CFR paragraphs:

10 CFR 72.30(e) states (in part):

10 CFR 72.30 l$FSl Decommissioning Funding Plan, Revision 7 9

Prepared by Ameren Missouri :2 July 37. 2018 te,) .... Financial assurance for decommissioning nuest be provided by one or more of the following methods:

(5) In the case of licensees who are issued a power reactor license under part 50 of this chapter or 1SFSI licensees who are an electric ttilitv, as defined in part 50 of this chapter, with a specfIc license issued under this part, the methods of 10 CFR )0. 75(b), (e. and (1i,), as applicable. In the event tl7at funds remaining to be placed into the licensee s JSFSI decommissioning external sinking fund are no longer approvedfor recovery in rates by a competent rate making authority, the licensee must make changes to provide financial assurance using one or iiiore of the methods stated in paragraphs (1) through (4,) of this section.

As Arneren Missouri has been issued a power reactor license and is an electric utility, it meets the foregoing criteria and consequently is utitizing the External Sinking F und method of providing financial assurance for decommissioning the 1Sf SI. as defined in 10 CFR 50.75(e)(1)(ii). This is also the financial assurance method that Ameren Missouri currently uses for the Callaway Energy Center decommissioning.

Separate, segregated sub-accounts have been established within the external sinking fund to segregate the ISfSI decommissioning funding from the plant decommissioning funding.

Missouri regulations. cited below, require the triennial filing of tipdated decommissioning cost estimates and associated funding levels required for decommissioning funding assurance. Missouri regulations also provide for the changing of rates charged to ratepayers to recover any changes in funding levels necessitated by the triennial decommissioning cost estimate updates.

1 CSR 240-3.185 Stthmission ofReports Pertaining to the Decommissioning of Electric Utility Plants (3) On or before Septenther 1, 1990 and every three (3) years after that, utilities with decommissioning trust funds shall perform and/lie with the commission cost studies detailing the utilities latest cost estimatesfor decommissioning their nuclear generating unit(s) along with the funding levels necessan to defray these decommissioning costs. These stttdies sl7ail be filed along with appropriate tariffis,) effectuating the change in rates necessary to accomplish the fimding required. In addition, the commission, at any time forjust cause, may require a uttilTh to file an updated decommissioning cost study, fimding requirement and associated tariff(s).

4 CSR 240-20.070 Decommissioning Trust Funds (7.) Upon the filing of the appropriate tariff*j(s) as set in 4 CSR 240-3.180, the commission shalt establish a schedule ofproceedings which shalt be limited in scope to the following issues:

(A) The extent of any change in the level or annual accrual offmding necessary for the uttilitVs decommissioning trust find; and 70 CER 72.30 ISFSI Decommissioning Funding Plan, Revision 7 10

Prepared by Ameren Missouri : July 37, 2078 (3.) The changes in rates which wotdd reflect any change in the funding level or accrual rate.

To comply with the foregoing Missouri regulations, Ameren Missouri prepares an updated site-specific decommissioning cost estimate for the Callaway Energy Center every three (3) years and files this estimate and an updated funding level analysis with the Missouri Public Service Commission (MPSC). The site-specific estimate includes radiological license termination expenses. non-radiological site restoration expenses and spent fuel management expenses. The funding level analysis is based on this total decommissioning cost estimate amount. Although the external sinking fund described in 10 CFR 50.75 is for radiological decommissioning costs only, to the extent that the fund balance exceeds costs required for Part 50 radiological decommissioning, excess funds would be available for non-radiological site restoration expenses and spent fuel management expenses.

The most recent triennial update filing was made with the MPSC on September 1, 2017.

As part of this September 1, 2017 MPSC filing. Ameren Missouri had a decommissioning cost estimate for the ISFSI prepared by the same firm that prepared the cost estimate for the Callaway Energy Center decommissioning. The estimated cost for radiological decommission of the ISFSI and release of the facility for unrestricted use is $7,761,000 (2017$). Non-radiological site restoration costs for green fielding the site are estimated at an additional $1,408,000 (2017$). This estimate projects that radiological decommissioning of the ISFSI will take place in 2050 and site restoration in 2051.

On January 4. 2018. Arneren Missouri and the MPSC Staff entered into a Non-Unanimous Stipulation and Agreement regarding the cost estimates for decommissioning of the plant and ISFSI and the associated funding levels of the nuclear decommissioning trust fund. The MPSC approved the Non-Unanimous Stipulation and Agreement in an Order issued January 23. 20l8. Based on the approved cost estimate and funding plan. Ameren Missouri is making annual contributions of

$435,209 to the segregated ISFSI sub-accounts of the external sinking fund. This funding level commenced as of January 1. 2018, and will be effective until the next triennial MPSC update filing, required by September 1, 2020. At that time, funding adequacy will be reevaluated and the contribution level changed accordingly, as necessary.

Copies of the ISFSI decommissioning cost estimate, the Funding Adequacy Analysis, the Non-Unanimous Stipulation and Agreement and the September 1, 2017 MPSC Order are available on request.

10 CFR 72.30 ISF$l Decommissioning Funding Plan, Revision 1 . 11

Prepared by Ameren Missouri July 37, 2078 Ameren Missouri will refund to Missouri ratepayers any DOE reimbursement amounts received for costs of decommissioning the ISFSE whereby Ameren Missouri previously collected those decommissioning costs from Missouri ratepayers as Missouri rate tariffs.

As 10 CFR 72.30 (c) states, in part:

(c At the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan nuts! be resubmitted ititli adjustments as necessary to account for changes in costs and the extent of contamination.

To comply with this requirement. Ameren Missouri intends to obtain updated site-specific decommissioning cost estimates for the ISFSI concurrently with updated plant decommissioning cost estimates and file both on a triennial basis with the MPSC, along with updated funding level analyses.

as required by Missouri regulations. As previously indicated, the next filing will be made by September 1, 2020. and then every three (3) years thereafter. Concurrent with these MPSC filings, updated ISfSI cost estimates and funding level analyses will be submitted to the NRC in accordance with 10 CFR 72.30(c).

10 CFR 7230 ISFSI Decommissioning Funding Plan, Revision 7 12

Prepared by Ameren Missouri July 37, 2078 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Length Width Depth Item (feet) (feet) (feet) Residual Radioactivity ISfSI Pad 157.5 143.6 2.5 No ISFSI HI-STORM UMAX Notes Item Value (all dimensions are nominal)

Cavity Enclosure Container Inside Height (inches) 181 Cavity Enclosure Container Inside Diameter (inches) 86 Quantity (total) 48 Spent Fuel (43) + GTCC (5)

Equivalent to the number of VVMs used to store last Quantity (with residual radioactivity) 6 complete core offload)

Potentially Activated Steel and Concrete (potinds) 847.767 Misc. Low-Level Radioactive Waste (pounds) 3,289 Low-Level Radioactive Waste (cubic feet) 13,299 Excluding transfer cask Low-Level Radioactive Waste (packaged density) 64 Average weight density Other Potentially Impacted Items Item Value Notes Number of VVMs used for GTCC storage 5 No residual radioactivity 70 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 7 13

Prepared byAmeron Missouri :: July31, 2078 Tabe 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste Person-Hours (thousands. 2017 dollars) Volume Oversight and Removal Packaging Transport Disposal Other Total Cubic Feet Craft Contractor Decommissioning Contractor Planning (characterization.

specs and procedures) - - - 229 229 - - 1.024 Remediation (activated metal removal) 571 98 92 2.413 - 3,173 -

13,299 7.472 License Termination (radiological surveys) - - - 1,159 1.159 - 9.549 -

Subtotal 571 98 92 2,413 1,388 4,561 13,299 t7,021 1,024 Supporting Costs NRC and NRC Contractor Fees - - - - 364 364 - - 776 Insurance - - - -

149 149 -

Property Taxes - - - 85 - -

85 -

Plant Energy Budget - - - 61 - -

61 -

Corporate A&G - - - 329 - -

329 -

Security (industrial) - - - 294 - -

294 4.958 Amcien Missouri Oversight - - 366 -

366 - 3,761 Subtotal - - - -

1,647 1,647 - 9,495 Total (w/o contingency) 571 98 92 2,413 3,035 6,209 13,299 17,021 10,519 Total (w125% contingency) 714 123 114 3.01 6 3,794 7,761 Note I: for funding planning purposes decommissioning costs can be assumed to be incurred in years 2050 and 2051 10 CFR 72.30 ISFSI Decommissioning Funding Plan, Revision 1 14