View source for 3F1111-01, Document P23-1651-001, Rev. 0, Preliminary Decommissioning Cost Estimate for the Crystal River, Unit 3 Nuclear Generating Plant

{{Adams
| number = ML11339A041
| issue date = 11/21/2011
| title = Document P23-1651-001, Rev. 0, Preliminary Decommissioning Cost Estimate for the Crystal River, Unit 3 Nuclear Generating Plant
| author name = Cloutier W
| author affiliation = TLG Services, Inc
| addressee name = 
| addressee affiliation = NRC/NRR, Progress Energy Florida, Inc
| docket = 05000302
| license number = DPR-072
| contact person = 
| case reference number = 3F1111-01
| document report number = P23-1651-001, Rev 0
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70
| page count = 103
}}

=Text=
{{#Wiki_filter:Document P23-1651-001, Rev. 0 PRELIMINARY DECOMMISSIONING COST ESTIMATE for the CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT preparedfor Progress Energy Florida, Inc.
preparedby TLG Services, Inc.
Bridgewater, Connecticut November 2011

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001,Rev. 0 PreliminaryDecommissioning Cost Estimate                               Page ii of xxii APPROVALS Project Manager                                                          It//e'iolI William A. Cloutier, J.<       Date Project Engineer Thomas/J. Garrett              Date/
Technical Manager Francis W. Sey*mot/            Date TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                                                    Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                                                                 Page iii of xxii TABLE OF CONTENTS SECTION                                                                                                                           PAGE SU M MVLARY ...........................................................................................................       vi-xxii
: 1. INTRODU CTION .....................................................................................................               1-1 1.1 Objectives of Study ...........................................................................................              1-1 1.2 Site Description .................................................................................................           1-2 1.3 Regulatory Guidance ........................................................................................                 1-3 1.3.1 N uclear W aste Policy Act ......................................................................                     1-4 1.3.2 Low -Level Radioactive W aste Acts ......................................................                             1-6 1.3.3 Radiological Criteria for License Term ination ....................................                                   1-8
: 2. SAFSTOR DECOMMISSIONING ALTERNATIVE ..............................................                                                2-1 2.1 Period 1 - Preparations .....................................................................................                 2-1 2.2 Period 2 - Dorm ancy .........................................................................................                2-2 2.3 Period 3 - Preparations for Decom m issioning ................................................                                2-3 2.4 Period 4 - Deferred Decom m issioning .............................................................                           2-4 2.5 Period 5 - Site Restoration ...............................................................................                   2-7
: 3. COST ESTIM ATE .....................................................................................................              3-1 3.1 Basis of Estim ate ..............................................................................................             3-1 3.2 M ethodology ......................................................................................................           3-1 3.3 Financial Com ponents of the Cost M odel .......................................................                              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 M anagem ent .......................................................................                       3-6 3.4.2 Reactor Vessel and Internal Com ponents ...........................................                                   3-8 3.4.3 Prim ary System Com ponents ...............................................................                           3-9 3.4.4 Retired Com ponents ............................................................................                    3-10 3.4.5 M ain Turbine and Condenser .............................................................                           3-11 3.4.6 Transportation M ethods .....................................................................                       3-11 3.4.7 Low -Level Radioactive W aste Disposal .............................................                                3-12 3.4.8 Site Conditions Following Decom m issioning ....................................                                    3-13 3.5 Assum ptions ....................................................................................................           3-13 3.5.1 Estim ating Basis .................................................................................                 3-14 3.5.2 Labor Costs ..........................................................................................              3-14 3.5.3 Design Conditions ................................................................................                  3-14 3.5.4 General .................................................................................................            3-15 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                                                     Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate                                                                                    Page iv of xxii TABLE OF CONTENTS (continued)
SECTION                                                                                                                             PAGE 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. R E S ULT S .................................................................................................................      6-1
: 7. R E FE RE NC E S ..........................................................................................................        7-1 TABLES
: 1. Decommissioning Cost Elements ...................................................................                               xvii
: 2. Schedule of License Termination Expenditures ...........................................                                       xviii
: 3. Funding Requirements for License Termination, 2016 Shutdown .............. xx 3.1    Schedule of Total Annual Expenditures .......................................................                                  3-19 3.2    Schedule of License Termination Expenditures ...........................................                                       3-21 3.3    Schedule of Spent Fuel Management Expenditures .................................... 3-23 3.4    Schedule of Site Restoration Expenditures ..................................................                                   3-25 5.1    Decommissioning Waste Summary .................................................................                                  5-4 6.1    Decommissioning Cost Element Contribution ................................................                                       6-4 FIGURES 4.1    Activity Schedule ..............................................................................................                 4-3 4.2    Decommissioning Timeline ..............................................................................                          4-4 5.1    Decommissioning Waste Disposition ..............................................................                                 5-3 APPENDICES A. Unit Cost Factor Development .........................................................................                          A-1 B. Unit Cost Factor Listing ..................................................................................                     B-1 C. Detailed Cost Analysis .......................................................................................                  C-1 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant        Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate                           Page v of xxii REVISION LOG No.       CRA No.        Date      Item Revised Reason for Revision 0                    11-21-2011                    Original Issue TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                Page vi of xxii

==SUMMARY==

Florida Power Corporation, doing business as Progress Energy Florida, Inc.
(Progress Energy), a subsidiary of Progress Energy, Inc., is seeking renewal of the operating license for the Crystal River Unit 3 Nuclear Generating Plant (Crystal River), currently set to expire at midnight on December 3, 2016. An application for the renewal of Facility Operating License No. DPR-72, for an additional 20-year period, was submitted to the Nuclear Regulatory Commission (NRC) on December 16, 2008. The application is currently under review.
However, pursuant to 10 CFR 50.75(f)(3), each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission. This report presents an estimate of the cost to decommission the Crystal River assuming a cessation of operations after a nominal 40-year operating life in 2016. The cost estimate includes an assessment of the major factors that could affect the cost to decommission the Crystal River nuclear unit.
Progress Energy is submitting this estimate to comply with the requirements of 10 CFR 50.75(f)(3). Progress Energy has not determined or committed to a specific decommissioning approach for Crystal River at this time. However, it is Progress Energy's current plan for purposes of demonstrating the adequacy of funding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date. License renewal is likely to require a need to revise this preliminary plan.
The currently projected total cost to decommission the nuclear unit, assuming the SAFSTOR alternative, is estimated at $1,077.6 million, as reported in 2011 dollars.
The cost includes the monies anticipated to be spent for operating license termination, spent fuel storage and site remediation activities. The cost is based on several key assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, performance uncertainties (contingency) and site remediation and restoration requirements. The assumptions are discussed in more detail in this document.
Decommissioning Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material to levels at or below the site release criteria so that the license can be terminated. The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                             DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                                Page vii of xxii June 27, 1988.111 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.
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 21 released for unrestricted use shortly after cessation of operations."[
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."[31 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."[41 As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.
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.[51 The amendments allow for greater public participation and better define the transition process from operations to decommissioning.
Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 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 1   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.
2   Ibid. Page FR24022, Column 3.
3   Ibid.
4   Ibid. Page FR24023, Column 2.
5   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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                        Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                           Page viii of xxii and content of the estimate is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.[J]
Bases of the Cost Estimate For the purpose of the analysis, Crystal River was assumed to cease operations in December 2016, after 40 years of operations. The unit would then be placed into safe-storage (SAFSTOR), with the spent fuel relocated to an Independent Spent Fuel Storage Installation (ISFSI) to await transfer to a Department of Energy (DOE) facility. Based upon a 2020 start date for the pickup of spent fuel from the commercial nuclear power generators, Progress Energy anticipates that the removal of spent fuel from the site could be completed by the year 2057. For purposes of this analysis, the plant remains in safe-storage until 2071, at which time it will be decommissioned and the site released for alternative use without restriction, i.e., the license is terminated within the required 60-year time period.
The analysis relies upon site-specific, technical information from an evaluation prepared in 2008,[7] updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The economic basis was reviewed for the current analysis and updated to reflect current site costs and budgets. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available.
Methodology The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the plant's operating license can be terminated. The analysis recognizes that spent fuel will be stored at the site in the plant's storage pool and/or in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to the U.S. Department of Energy (DOE).
Consequently, the estimate includes those costs to manage and subsequently decommission these interim storage facilities.
The estimate is based on numerous fundamental assumptions, including regulatory requirements, low-level radioactive waste disposal practices, high-level radioactive waste management options, project contingencies, and site restoration requirements. The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Any residual fuel 6   "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors,"
Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 7   "Decommissioning Cost Analysis for the Crystal River Plant, Unit 3," Document No. P23-1597-002, Rev. 0, TLG Services, Inc., October 2008 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                      Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                          Page ix of xxii remaining in the pool after the cooling period is relocated to the ISFSI to await transfer to a DOE facility. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site.
The methodology used to develop the estimate followed the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[8 ] and the DOE "Decommissioning Handbook."[9] These documents present a unit cost factor method for estimating decommissioning activity costs that simplifies the calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton),
and cutting costs ($/inch) were developed using local labor rates. The activity-dependent costs were then estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[101 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.
An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services, such as quality control and security.
This analysis reflected lessons learned from TLG's involvement in the Shippingport Station decommissioning, 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, 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.
8   T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.
9   W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980.
10  "Building Construction Cost Data 2011," Robert Snow Means Company, Inc., Kingston, Massachusetts.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                         Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                             Page x of xxii 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 unforeseeable events which will increase costs are likely to occur."["]1 The cost elements in the estimate 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,[121 and its Amendments of 1985,[131 the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. With the exception of Texas, no new compact facilities have been successfully sited, licensed, and constructed.
The disposal facility in Barnwell, South Carolina is currently closed to generators outside the Atlantic Compact (comprising the states of Connecticut, New Jersey and South Carolina). The commercial disposal facility on the Hanford Nuclear Reservation near Richland, Washington accepts low-level radioactive waste from the Northwest (Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Washington and Wyoming) and Rocky Mountain (Colorado, Nevada, and New Mexico) Compact states. This leaves EnergySolutions' disposal facility in Clive, Utah as the only available option for the disposal of the majority of the low-level radioactive waste generated in 11  Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239.
12  "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980.
13  "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                         Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                             Pagexi of xxii decommissioning Crystal River (the Texas facility has limited the importation of waste from outside the Texas Compact).
For the purpose of this analysis, Progress Energy's "Life of Plant Agreement" with EnergySolutions is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [141). 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.
The Texas Commission on Environmental Quality (TCEQ), the environmental agency for the state, is responsible for the licensing of a low-level radioactive waste disposal facility for the Texas Compact. The agency granted Waste Control Specialists (WCS) a disposal license in 2009 and approval to commence construction in early 2011.
Construction of the disposal facility is now essentially complete and the facility was declared operational in November 2011. However, to date, the TCEQ has only published interim disposal rates for the facility, in advance of the formal disposal rate-setting process, and only for Compact generators. As a proxy, disposition of the Class B and C waste 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 that may be 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 (Greater-than-Class C or GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance.
For purposes of this 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 14  U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                         Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                           Page xii of xxii decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Crystal River reflects the savings from waste recovery/volume reduction.
High-Level Radioactive Waste Management Congress passed the "Nuclear Waste Policy Act"[151 (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The 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 DOE's breach of contract.
Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Progress Energy's current spent fuel management plan for the Crystal River spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility and 2) expectations for spent fuel receipt by the DOE for the Crystal River fuel. Fuel could be completely removed from the site as early as 2057, based on an oldest fuel first priority, and the DOE achieving an annual rate of transfer (3,000 metric tons of uranium year) as reflected in DOE's latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567).
The assumed 2020 DOE start date is nominally based on the last position stated by the DOE. On July 15, 2008, the then-Director of the DOE's Office of Civilian Radioactive Waste Management testified before Congress that DOE "could be ready to begin accepting spent nuclear fuel by 2020," but his statement was based on continued program funding.[16 ] The current administration has cut the budget for the geological 15  "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982 16  Statement of Edward F. Sproat, III, Director Office of Civilian Radioactive Waste Management, U.S. Department of Energy, Before the Subcommittee on Energy and Air Quality Committee on TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                            Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                              Pagexiii of xxii repository program, but the administration has also appointed a Blue Ribbon Commission on America's Nuclear Future to make recommendations for a new plan for nuclear waste disposal. That Commission's charter includes a requirement that the Commission consider "options for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." Progress Energy believes that one or more monitored retrievable storage facilities could be put into place following a Blue Ribbon Commission recommendation for the same, within a relatively short time frame, at least by 2020. For example, a facility such as that licensed by the NRC to Private Fuel Storage could be used by the DOE to store fuel until a final disposition is determined.
It is generally necessary that spent fuel be 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).[1 71 This requirement is prepared for through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.
The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following six and one half years the assemblies are packaged into multipurpose canisters for transfer to the DOE or to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the transport and/or storage requirements for decay heat.
An ISFSI, operated under a Part 50 General License (in accordance                    with 10 CFR 72, Subpart K[18]), is in the process of being constructed to support                    continued plant operations. The facility is assumed to be available to support future               decommissioning operations. Once the wet storage pool is emptied, the auxiliary                      building can be prepared for long-term storage.
Progress Energy's position is that the DOE has a contractual obligation to accept Crystal River's 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 claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of Energy and Commerce U.S. House of Representatives, July 15, 2008.
17  U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," Subpart 54 (bb), "Conditions of Licenses."
18  U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                         Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                            Page xiv of xxii sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier.
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 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.
Decommissioning Trust Funds As of September 30, 2011, the aggregate trust fund balance for Crystal River was approximately $578.0 million. The total includes Progress Energy Florida's share (91.8%), as well as that of the nine minority owners.[19]
Financial Assurance Progress Energy intends to fund the expenditures for license termination (comprising approximately 70% of the total cost) from the decommissioning trust fund currently held by Progress Energy as well as the nine minority owners. The management of the spent fuel, until it can be transferred to the DOE, may be funded from excess trust fund earnings and from proceeds from spent fuel litigation against the Department of Energy (DOE). Expenditures from the trust fund for the management of the spent fuel will not reduce the value of the decommissioning trust fund to below the amount necessary to place and maintain the reactor in safe storage. The licensee would make the appropriate submittals for an exemption, in accordance with 10 CFR 50.12, from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.
The total cost projected for license termination (in accordance with 10 CFR 50.75) for the deferred decommissioning alternative (SAFSTOR) is shown at the bottom of Table 19  Total decommissioning funds available include Progress Energy Florida's share (91.8%) as well as that of the nine minority owners: City of Alachua, City of Bushnell, City of Gainesville, City of Kissimmee, City of Leesburg, City of Ocala, Orlando Utilities Commission, Seminole Electric Cooperative, and City of New Smyrna Beach TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                  Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                  Pagexv of xxii 1 ($753.717million). The schedule of expenditures for license termination activities is provided in Table 2. Table 3 provides the details of the proposed funding plan for decommissioning Crystal River based on a 2% real rate of return on the decommissioning trust fund. As shown in Table 3, the current trust funds (as of September 30, 2011) are sufficient to accomplish the intended tasks and terminate the operating license for Crystal River. The analysis also shows a surplus in the fund at the completion of decommissioning. This surplus could be made available to fund other activities at the site (e.g., spent fuel management and/or restoration activities),
recognizing that the licensee would need to make the appropriate submittals for an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for non-decommissioning related expenses, as defined by 10 CFR 50.2.
Summary The cost to decommission Crystal River 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. In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the storage facilities are also decommissioned.
The decommissioning scenario is 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 Appendix C. The major cost components are also identified in the cost summary provided at the end of this section.
The cost elements in the estimate 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). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.
The "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel to the ISFSI and the management of the TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                 Page xvi of xxii ISFSI 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 three feet below grade and backfilled.
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 estimate is developed and costs are presented in 2011 dollars. As such, the estimate does 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                                Page xvii of xxii TABLE 1 DECOMMISSIONING COST ELEMENTS (thousands of 2011 dollars)
Cost Element                                                                    Cost [I' Decontamination                                                                 12,409 Removal                                                                       101,075 Packaging                                                                       22,681 Transportation                                                                  11,922 Waste Disposal                                                                  46,245 Off-site Waste Processing                                                       23,246 Program Management [2]                                                        306,020 Site Security                                                                 183,679 Spent Fuel Pool Isolation                                                       11,822 Spent Fuel Management [3]                                                     129,013 Insurance and Regulatory Fees                                                   61,040 Energy                                                                          13,491 Characterization and Licensing Surveys                                          15,110 Property Taxes                                                                  87,216 Utility Site Indirect                                                           19,326 Corporate Allocations                                                           14,257 Miscellaneous Equipment                                                         19,045 Total  [4]                                                                  1,077,596 Cost Element License Termination                                                           753,717 Spent Fuel Management                                                         271,910 Site Restoration                                                               51,969 Total  [41                                                                  1,077,596
[1J Total costs reported (i.e., there is no cost allocation by ownership share)
[21 Includes engineering and security costs
[31   Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees
[41 Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                              Page xviii of xxii TABLE 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                 LLRW Year         Labor       Materials     Energy      Disposal      Other          Total 2016            3,035           103          94           3         823         4,058 2017          38,811         2,388        1,179         418      10,610       53,405 2018          19,075         3,990          568       1,335      18,447       43,415 2019            2,862          438          118          14       2,175         5,607 2020            2,870          439          118          14       2,181         5,622 2021            2,862.         438          118          14       2,175         5,607 2022            2,862          438          118          14       2,175         5,607 2023            2,862          362          118          10       2,174         5,525 2024            2,869          307          118           7       2,179         5,479 2025     1      2,862          306          118           7       2,173         5,465 2026            2,862          306          118           7       2,173         5,465 2027            2,862          306          118           7       2,173         5,465 2028            2,869          307          118           7       2,179         5,479 2029            2,862          306          118           7       2,173         5,465 2030            2,862          306          118           7       2,173         5,465 2031            2,862          306          118           7       2,173         5,465 2032            2,869          307          118           7       2,179         5,479 2033            2,862          306          118           7       2,173         5,465 2034            2,862          306          118           7       2,173         5,465 2035            2,862          306          118           7       2,173         5,465 2036     1      2,869          307          118           7       2,179         5,479 2037            2,862          306          118           7       2,173         5,465 2038            2,862          306          118           7       2,173         5,465 2039            2,862          306          118           7       2,173         5,465 2040     1      2,869          307          118           7       2,179         5,479 2041            2,862          306          118           7       2,173         5,465 2042            2,862          306          118           7       2,173         5,465 2043            2,862          306          118           7       2,173         5,465 2044            2,869          307          118           7       2,179         5,479 2045            2,862          306          118           7       2,173         5,465 2046            2,862          306          118           7       2,173         5,465 2047            2,862          306          118           7       2,173         5,465 2048            2,869          307          118           7       2,179         5,479 2049            2,862          306          118           7       2,173         5,465 2050     1      2,862          306          118           7       2,173         5,465 2051     1      2,862          306          118           7       2,173         5,465 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                           Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate                                             Pagexix of xxii TABLE 2 (continued)
SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                            LLRW Year        Labor       Materials           Energy          Disposal        Other          Total 2052           2,869             307              118                7        2,179        5,479 2053           2,862             306              118                7        2,173        5,465 2054           2,862             306              118                7        2,173        5,465 2055           2,862             306              118                7        2,173        5,465 2056           2,869             307              118                7        2,179        5,479 2057           2,862             306              118                7        2,173        5,464 2058           2,862            298               118                6        2,150        5,434 2059           2,862            298               118                6        2,150        5,434 2060           2,869            299               118                6        2,156        5,448 2061           2,862            298               118                6        2,150        5,434 2062           2,862            298               118                6        2,150        5,434 2063           2,862            298               118                6        2,150        5,434 2064           2,869            299               118                6        2,156        5,448 2065           2,862            298               118                6        2,150        5,434 2066           2,862            298               118                6        2,150        5,434 2067           2,862            298               118                6        2,150        5,434 2068           2,869            299               118                6        2,156        5,448 2069           2,862            298               118                6        2,150        5,434 2070           2,862            298               118                6        2,150        5,434 2071           4,621            472               176                8        2,276        7,553 2072         35,366           3,622            1,182               32         4,470       44,672 2073         43,439          21,970            1,146          18,390         13,820       98,766 2074         44,947          23,086            1,014          24,109         14,794      107,949 2075         43,442           8,421               884         12,763          6,699       72,209 2076         28,520           2,641               327           2,189         3,239       36,916 2077             121               0                0                0            0          121 2078              74               0                0                0            0           74 Total        410,355          83,088           12,703          59,624       187,946       753,717 Note:    Total costs reported (i.e., there is no cost allocation by ownership share)
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                       Page xx of xxii TABLE 3 FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year                                    2011 Fund Balance (9/30/2011)                 $578.026   (millions)
Annual Escalation                           0.00%
Annual Earnings                             2.00%
A                 B                       C Decommissioning License      Escalated License         Trust Fund Termination     Termination Cost        Escalated at 2%
Cost         Escalated at 0%       (minus expenses)
Year         (millions)        (millions)             (millions) 2011                                                    $    578.026 2012                                                    $    589.586 2013                                                    $    601.378 2014                                                    $    613.406 2015     _                                    -         $    625.674 2016                4.058                4.058          $    634.129 2017               53.405              53.405           $     593.407 2018               43.415              43.415           $     561.859 2019                5.607                5.607          $     567.490 2020                5.622                5.622          $     573.217 2021                5.607                5.607          $     579.074 2022                5.607                5.607          $     585.049 2023                5.525                5.525          $     591.225 2024                5.479                5.479          $     597.570 2025                5.465                5.465          $    604.057 2026                5.465                5.465          $    610.674 2027                5.465                5.465          $    617.423 2028                5.479                5.479          $    624.292 2029                5.465                5.465          $    631.313 2030                5.465                5.465          $    638.475 2031                5.465                5.465          $    645.780 2032                5.479                5.479          $    653.216 2033                5.465                5.465          $    660.816 2034                5.465                5.465          $    668.567 2035                5.465                5.465          $    676.474 2036                5.479                5.479          $    684.524 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                  Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                     Page xxi of xxii TABLE 3 (continued)
FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year                                   2011 Fund Balance (9/30/2011)                $578.026  (millions)
Annual Escalation                          0.00%
Annual Earnings                            2.00%
A                  B                     C Decommissioning License       Escalated License       Trust Fund Termination      Termination Cost      Escalated at 2%
Cost         Escalated at 0%     (minus expenses)
Year         (millions)         (millions)            (millions) 2037                5.465                5.465         $     692.750 2038                5.465                5.465         $     701.141 2039                5.465                5.465         $     709.699 2040                5.479                5.479         $     718.413 2041                5.465                5.465         $     727.317 2042                5.465                5.465         $     736.399 2043                5.465                5.465         $     745.662 2044                5.479                5.479         $     755.096 2045                 5.465                5.465         $     764.734 2046                 5.465                5.465         $     774.564 2047                 5.465                5.465         $     784.591 2048                 5.479                5.479         $     794.803 2049                 5.465                5.465         $    805.234 2050                 5.465                5.465         $    815.875 2051                 5.465                5.465         $    826.728 2052                 5.479                5.479         $    837.783 2053                 5.465                5.465         $    849.074 2054                 5.465                5.465         $    860.591 2055                 5.465                5.465         $    872.338 2056                 5.479                5.479         $    884.305 2057                 5.464                5.464         $    896.527 2058                 5.434                5.434         $    909.024 2059                 5.434                5.434         $    921.771 2060                 5.448                5.448         $    934.758 2061                 5.434                5.434         $    948.019 2062                 5.434                5.434         $    961.546 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                          Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                             Page xxii of xxii TABLE 3 (continued)
FUNDING REQUIREMENTS FOR LICENSE TERMINATION 2016 SHUTDOWN Basis Year                                           2011 Fund Balance (9/30/2011)                      $578.026      (millions)
Annual Escalation                                  0.00%
Annual Earnings                                    2.00%
A                       B                        C Decommissioning License          Escalated License            Trust Fund Termination        Termination Cost           Escalated at 2%
Cost            Escalated at 0%          (minus expenses)
Year           (millions)              (millions)              (millions) 2063                  5.434                     5.434           $      975.344 2064                  5.448                     5.448           $      989.402 2065                  5.434                     5.434           $    1,003.757 2066                  5.434                     5.434           $    1,018.398 2067                  5.434                     5.434           $    1,033.333 2068                  5.448                     5.448           $    1,048.551 2069                  5.434                     5.434           $    1,064.088 2070                  5.434                     5.434           $    1,079.936 2071                  7.553                     7.553           $    1,093.982 2072                 44.672                   44.672            $    1,071.190 2073                 98.766                   98.766            $      993.848 2074                107.949                  107.949            $      905.775 2075                 72.209                   72.209            $      851.682 2076                 36.916                   36.916            $      831.799 2077                  0.121                     0.121           $      848.313 2078                  0.074                     0.074           $      865.206 Total               753.717                   753.717 Note: Total costs reported (i.e., there is no cost allocation by ownership share)
September 30, 2011 balance also used as year-end 2011 balance Calculations:
Column B= (A)*(1+.00)^(current year - 2011) or for 0%, B = A Column C = (Previous year's fund balance) * (1 + .02) - B (current year's decommissioning expenditures)
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                       Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                  Section 1, Page 1 of 9
: 1. INTRODUCTION This report presents an estimate of the cost to decommission the Crystal River Unit 3 Nuclear Generating Plant, (Crystal River) following a scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2008,[1]* updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects.
Pursuant to 10 CFR 50.75(f)(3),[ 21 each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission. Progress Energy Florida, Inc. (Progress Energy) is submitting this estimate to comply with the requirements of 10 CFR 50.75(f)(3).
Progress Energy has not determined or committed to a specific decommissioning approach for Crystal River at this time. However, it is Progress Energy's current plan for purposes of demonstrating the adequacy of finding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date. License renewal is likely to require a need to revise this preliminary plan.
The current estimate is designed to provide Progress Energy, the plant's majority owner, 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 a comprehensive estimate of the costs to decommission Crystal River, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.
The plant was issued its operating license in December 1976. The license currently expires in 2016. An application for the renewal of Facility Operating License No. DPR-72, for an additional 20-year period, was submitted to the Nuclear Regulatory Commission (NRC) on December 16, 2008. The application is currently under review. So, for the purposes of this study, the final
* References provided in Section 7 of the document TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 1, Page 2 of 9 shutdown date (license expiration) is assumed to on December 3, 2016 or 40 years from the original license issue.
1.2 SITE DESCRIPTION The Crystal River site is located in Citrus County, Florida, approximately 70 miles north of Tampa on the shore of the Gulf of Mexico. The generating site is comprised of four fossil-fired units and one nuclear unit. The Gulf of Mexico provides the heat sink for both Units 1 and 2 fossil-fired units, and the nuclear unit (natural draft towers provide the cooling for Units 4 and 5).
The nuclear steam supply system (NSSS) consists of a pressurized water reactor and a two-loop reactor coolant system, designed by Babcock & Wilcox.
The generating unit has a reference core design of 2609 MWt (thermal), with a corresponding net dependable capability electrical rating of 860 megawatts (electric) with the reactor at rated power.
The reactor coolant system is comprised of the reactor vessel and two heat transfer loops, each loop containing a vertical once-through type steam generator, and two single speed centrifugal reactor coolant pumps. In addition, the system includes an electrically heated pressurizer, a reactor coolant drain tank and interconnected piping. The system is housed within the reactor containment building or reactor building, a seismic Category I reinforced concrete structure. The reactor building is a reinforced concrete structure composed of a vertical cylinder with a shallow dome and flat circular foundation slab. The cylinder wall is prestressed with a post-tensioning system in the vertical and horizontal directions. The dome roof is prestressed utilizing a three-way post-tensioning system. The foundation slab is reinforced with conventional mild steel. The inside surface of the reactor building is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.
Heat produced in the reactor is converted to electrical energy by the steam and power conversion system. A turbine-generator system converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The unit's turbine generator consists of high-pressure and low-pressure turbine sections driving a direct-coupled generator at 1800 rpm. The turbines are operated in a closed feedwater cycle, which condenses the steam; the heated feedwater is returned to the steam generators. Heat rejected in the main condensers is removed by the circulating water system. The condenser circulating water is taken from and returned to the Gulf of Mexico through the intake and discharge canals, respectively.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 1, Page 3 of 9 1.3  REGULATORY GUIDANCE The NRC provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[31 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, 4
     "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"[ 1 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 plant's systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations.
The rule also placed limits on the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of decommissioning. At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require significant remediation to meet the unrestricted release limits for license termination.
The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. With rulemaking permitting the controlled release of a site,[5I 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. 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                             Section 1, Page 4 of 9 entombments.[61 However, the NRC's 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 NRC's 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.[7 ] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facility's 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.
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"[8] (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The 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, TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate                            Section 1, Page 5 of 9 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 DOE's breach of contract.
Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner.
DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Progress Energy's current spent fuel management plan for the Crystal River spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility and 2) expectations for spent fuel receipt by the DOE for the Crystal River fuel. Fuel could be completely removed from the site as early as 2057, based on an oldest fuel first priority, and the DOE achieving an annual rate of transfer (3,000 metric tons of uranium year) as reflected in DOE's latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567).
The assumed 2020 DOE start date is nominally based on the last position stated by the DOE. On July 15, 2008, the then-Director of the DOE's Office of Civilian Radioactive Waste Management testified before Congress that DOE "could be ready to begin accepting spent nuclear fuel by 2020," but his statement was based on continued program funding.[91 The current administration has cut the budget for the geological repository program, but the administration has also appointed a Blue Ribbon Commission on America's Nuclear Future to make recommendations for a new plan for nuclear waste disposal. That Commission's charter includes a requirement that the Commission consider "options for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." Progress Energy believes that one or more monitored retrievable storage facilities could be put into place following a Blue Ribbon Commission recommendation for the same, within a relatively short time frame, at least by 2020. For example, a facility such as that licensed by the NRC to Private Fuel Storage could be used by the DOE to store fuel until a final disposition is determined.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                             Section 1, Page 6 of 9 It is generally necessary that spent fuel be 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).[ 101 This requirement is prepared for through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and the ISFSI.
The spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core at shutdown. Over the following six and one half years the assemblies are packaged into multipurpose canisters for transfer to the DOE or to the ISFSI for interim storage. It is assumed that this period provides the necessary cooling for the final core to meet the transport and/or storage requirements for decay heat.
An ISFSI, operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K [111), is in the process of being constructed to support continued plant operations. The facility is assumed to be available to support future decommissioning operations. Once the wet storage pool is emptied, the auxiliary building can be prepared for long-term storage.
Progress Energy's position is that the DOE has a contractual obligation to accept Crystal River's 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 claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the station's life if, contrary to its contractual obligation, the DOE has not performed earlier.
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,[121 and its Amendments of 1985,[131 the states became ultimately responsible for the TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 1, Page 7 of 9 disposition of low-level radioactive waste generated within their own borders.
The disposal facility in Barnwell, South Carolina is currently closed to generators outside the Atlantic Compact (comprising the states of Connecticut, New Jersey and South Carolina). The commercial disposal facility on the Hanford Nuclear Reservation near Richland, Washington accepts low-level radioactive waste from the Northwest (Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Washington and Wyoming) and Rocky Mountain (Colorado, Nevada, and New Mexico) Compact states. This leaves EnergySolutions' disposal facility in Clive, Utah as the only available option for the disposal of the majority of the low-level radioactive waste generated in decommissioning Crystal River (the Texas facility has limited the importation of waste from outside the Texas Compact).
For the purpose of this analysis, Progress Energy's "Life of Plant Agreement" with EnergySolutions is used as the basis for estimating the disposal cost for the majority of the radioactive waste (Class A [141).
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.
The Texas Commission on Environmental Quality (TCEQ), the environmental agency for the state, is responsible for the licensing of a low-level radioactive waste disposal facility for the Texas Compact. The agency granted Waste Control Specialists (WCS) a disposal license in 2009 and approval to commence construction in early 2011. Construction of the disposal facility is now essentially complete and the facility was declared operational in November 2011. However, to date, the TCEQ has only published interim disposal rates for the facility, in advance of the formal disposal rate-setting process, and only for Compact generators.
As a proxy, disposition of the Class B and C waste 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 that may be 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 (Greater-than-Class C or 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                              Section 1, Page 8 of 9 resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance.
For purposes of this 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 estimate for Crystal River reflects 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,"[151 amending 10 CFR Part 20. This subpart provides radiological criteria for releasing a facility for unrestricted use.
The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).
The decommissioning estimate assumes that the Crystal River site will be remediated to the levels specified in 10 CFR 20.1402, "Radiological criteria for unrestricted use," although the remediation measures included in this estimate are believed to be sufficient to result in substantially lower levels than required by the foregoing regulation.
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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 1, Page 9 of 9 16 Response, Compensation, and Liability Act (CERCLA or Superfund).[ 1 An additional and separate limit of 4 millirem per year, as defined in 40 17 CFR &sect; 141.16, is applied to drinking water.[ 1 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)[18 ] provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.
The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                             Section 2, Page I of 8
: 2. SAFSTOR DECOMMISSIONING ALTERNATIVE A detailed cost estimate was developed to decommission the Crystal River nuclear unit for the SAFSTOR decommissioning alternative. The following narrative describes the basic activities associated with the 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 estimate developed for Crystal River is 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   PERIOD 1 - PREPARATIONS 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.
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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                             Section 2, Page 2 of 8 The process of placing the plant in safe-storage includes, but is not limited to, the following activities:
* Defueling of the reactor vessel.
     " Isolation of the spent fuel pool and fuel handling systems so that safe-storage operations may commence on the balance of the plant. The pool will remain operational for approximately six and one-half years following the cessation of operations before the inventory resident at shutdown can be completely transferred to the ISFSI. 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.
* 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 or for future dormancy 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  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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 2, Page 3 of 8 structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating, and ventilation, and periodic preventive maintenance on essential site services.
An environmental surveillance program is carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented and/or detected and controlled. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.
Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of its own actions. The security fence, sensors, alarms, and other surveillance equipment provide security. Fire and radiation alarms are also monitored and maintained.
The spent fuel storage pool is emptied within six and one-half years of the cessation of operations. The transfer of the spent fuel from the ISFSI to a DOE facility begins in 2024 and continues throughout the dormancy period until completed in 2057. Once emptied, the ISFSI 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, thereby initiating the third phase.
2.3  PERIOD 3 - PREPARATIONS FOR 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.
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, TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant               Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                          Section 2, Page 4 of 8 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.
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 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.
2.4  PERIOD 4 - DEFERRED DECOMMISSIONING 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 &sect;50 operating license. 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 remote dismantling procedures 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.
Significant decommissioning activities in this phase include:
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 2, Page 5 of 8
* 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 reactor building to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the reactor 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.
* 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate                             Section 2, Page 6 of 8 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 and prepared for transport to the disposal site. To facilitate transport, the generators are cut in half, across the tube bundle. The exposed ends are capped and sealed. The segments can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized. A similar process will be used to prepare the retired units for disposal. The pressurizer is disposed of intact.
     " 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 reactor building.
* Remediation and removal of the contaminated equipment and material from the auxiliary 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)."[19] This document incorporates the statistical approaches to survey design and data TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 2, Page 7 of 8 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 the requested change to the operating license (that would release the property, exclusive of the ISFSI, for unrestricted use).
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.
2.5  PERIOD 5 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures. Although performed in a controlled and safe manner, the blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures. 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                          Section 2, Page 8 of 8 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.
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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 3, Page 1 of 26
: 3. COST ESTIMATE The cost estimate prepared for decommissioning Crystal River considers the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimate, 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 estimate was developed using the site-specific, technical information from the 2008 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 estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[20 1 and the DOE "Decommissioning Handbook."[ 21] 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.[221 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                         Section 3, Page 2 of 26 This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-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 radiological 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                          Section 3, Page 3 of 26 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 TLG's proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration.
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"[2 3] 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 TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant               Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                        Section 3, Page 4 of 26 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 TLG's 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 estimate on a line item basis. A composite value is then reported at the end of the detailed estimate (Appendix C). For example, the composite contingency value reported in Appendix C is approximately 16.1%.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 3, Page 5 of 26 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.
This cost study does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                          Section 3, Page 6 of 26 project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate.
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 estimate to decommission Crystal River. Ultimate disposition of the spent fuel is within the province of the DOE's 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 DOE's 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 estimate, as described below.
Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site. The timing for removal of spent fuel from the site is based upon the DOE's most recently published annual acceptance rates of 400 MTU/year for year 1, 3,800 MTU total for years 2 through 4 and 3,000 MTU/year for year 5 and beyond.[241 The DOE contracts provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst utilities and the option of providing priority acceptance from permanently shutdown nuclear reactors.
Because it is unclear how these mechanisms may operate once DOE begins accepting spent fuel from commercial reactors, this study assumes that DOE will accept spent fuel in an oldest fuel first order.
ISFSI The ISFSI, constructed to support plant operations, will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. Assuming that DOE commences repository operation in TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 3, Page 7 of 26 2020, Crystal River fuel is projected to be first removed from the site beginning in 2024. The process is expected to be completed by the year 2057, based upon the current shutdown date. Based upon the expected completion date for fuel transfer, the ISFSI will be emptied prior to the commencement of decommissioning operations.
Operation and maintenance costs for the ISFSI are included within the estimate and address the cost for staffing the facility, as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters. Costs are also provided for the final disposition of the facility once the transfer is complete.
Storage Canister Design DOE has not identified any cask systems it may use. As such, for the purpose of this analysis, the design and capacity of the ISFSI is based upon the NUHOMS system, with a 32 fuel assembly capacity. A unit cost of approximately $1.46 million is used for pricing the internal multi-purpose canister (MPC) and the horizontal concrete storage module.
Canister Loading and Transfer An average cost of $700,000 is used for the labor and equipment to seal each spent fuel canister once it is loaded and to load/transport the spent fuel from the pool to the ISFSI pad. For estimating purposes, $100,000 is used to estimate the unit cost to transfer the fuel from the ISFSI into a DOE transport cask.
Operations and Maintenance An annual cost (excluding labor) of approximately $764,000 and $89,000 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively. Pool operations are expected to continue approximately six and one-half years after the cessation of operations.
ISFSI operating costs are based upon a 41 year period of operations following plant shutdown.
ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analysis. The final core off load, equivalent to 6 modules, are TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 3, Page 8 of 26 assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel (i.e., to levels exceeding free-release limits). The steel support structure is assumed to be removed from these modules for controlled disposal. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimate.
GTCC The dismantling of the reactor internals 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. Although there are strong arguments that GTCC waste is covered by the spent fuel contract with DOE and the fees being paid pursuant to that contract, DOE has taken the position that GTCC waste is not covered by that contract or its fees and that utilities, including Progress Energy, will have to pay an additional fee for the disposal of their GTCC waste. However, to date, the Federal Government has not identified a cost for disposing of GTCC or a schedule for acceptance. For purposes of this estimate, the GTCC radioactive waste has been assumed to be packaged in the same canisters used to store spent fuel and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.
The GTCC material is assumed to be shipped directly to a DOE facility as it is generated from the segmentation of the reactor vessel internals.
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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                         Section 3, Page 9 of 26 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.
It is not known whether this option will be available when the Crystal River unit ceases operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition. 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.
3.4.3 Primary System Components Due to the natural decay of radionuclides over the dormancy period, a chemical decontamination is not included.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                          Section 3, Page 10 of 26 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 reactor building and placed onto a multi-wheeled vehicle for transport to an on-site processing and storage area.
The generators are segmented on-site to facilitate transportation. Each unit is cut in half, across the tube bundle. The exposed ends are capped and sealed. The interior volume is filled with low-density cellular concrete for stabilization of the internal contamination. Each component is then loaded onto a rail car for transport to the disposal facility.
Reactor coolant piping is cut from the reactor vessel once the water level in the ve'ssel (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 estimate includes the cost to dispose of the retired reactor closure head expected to be in storage at the site upon the cessation of plant operations. The component is segmented, with the segments placed in sea-land containers or custom containers for disposal. The retired steam generators, currently in storage at the site, will be segmented to facilitate transportation.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 3, Page 11 of 26 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 49.1251 The contaminated material will be packaged in Industrial Packages (IP-1, IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with 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., 137 Cs, 9 0Sr, 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                          Section 3, Page 12 of 26 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 and the Waste Control Specialist facility in Andrews County, Texas.
Transportation costs for off-site waste processing are based upon the mileage to Memphis, Tennessee. Truck transport costs are estimated 261 using published tariffs from Tri-State Motor Transit.[
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.
The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendix C, 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 3, Page 13 of 26 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. As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.
3.4.8 Site Conditions Following Decommissioning The NRC will terminate the site license if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRC's 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 owner's own future plans for the site.
Non-essential      structures or buildings         severely damaged in decontamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is processed and made available as clean fill for the power block foundations. Excess construction debris is trucked off site as an alternative to onsite disposal. The excavations will be regraded such that the power block area will have a final contour consistent with adjacent surroundings. Certain facilities, which have continued use or value (e.g., the switchyard) are left intact.
The estimate includes the remediation of the west settling pond (approximately (500 cubic yards). This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria. Costs are also included for the remediation of the firing range (i.e., removal of soil containing lead residue).
3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning the site.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate                           Section 3, Page 14 of 26 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.
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.
Progress Energy, as the licensee, 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 Progress Energy. 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., 137 Cs, 9 0Sr, or transuranics) has been prevented from reaching levels exceeding those TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 3, Page 15 of 26 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.[271 Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Crystal River components, projected operating life, and period of decay. Additional short-lived isotopes were derived from NUREG/CR-0130[28] and NUREG/CR-0672,[291 and benchmarked to the long-lived values from NUREG/CR-3474.
The control elements are disposed of along with the spent fuel, i.e., there is no additional cost provided for their disposal.
Activation of the reactor building is confined to the biological shield.
More extensive activation (at very low levels) of the interior structures within reactor buildings 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 reactor 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 Progress Energy and its subcontractors. The plant's 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 estimate does not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                          Section 3, Page 16 of 26 Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Progress Energy 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.
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 estimate 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 3, Page 17 of 26 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 NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."[30&deg; The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.
Taxes The tax model is based upon the current tax obligation by the owers.
Taxes on plant systems and structures are included (at a reduced level) and further reduced as dismantling operations proceed. Taxes are included on the land and the ISFSI (during its operation), throughout the decommissioning timeframe.
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 through 3.4. 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 &sect;50.75). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.
The "Spent Fuel Management" subcategory contains costs associated with the construction of an ISFSI, the containerization and transfer of spent fuel to the ISFSI over the six and one-half years of post-shutdown pool operations, and TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                              Section 3, Page 18 of 26 the management of the ISFSI 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.
Decommissioning costs are reported in 2011 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant). The schedule is based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4.
TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant               Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                        Section 3, Page 19 of 26 TABLE 3.1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2011 dollars)
Equipment &                 LLRW Year         Labor      Materials      Energy     Disposal      Other          Total 2016            3,035          103           94           3         969        4,204 2017          38,811         2,388        1,179         418      12,447       55,243 2018          24,371         6,630          636       1,335     28,746        61,718 2019          12,067         5,027          236          14      18,718       36,062 2020          12,100         5,040          236          14      18,769       36,160 2021          12,067         5,027          236          14      18,718       36,062 2022          12,067         5,027          236          14      18,718       36,062 2023            8,019        2,367          168          10       9,719       20,281 2024            5,078          426          118           7       3,159        8,788 2025            5,064          425          118           7       3,150        8,764 2026            5,064          425          118           7       3,150        8,764 2027            5,064          425          118           7       3,150        8,764 2028            5,078          426          118           7       3,159        8,788 2029            5,064          425          118           7       3,150        8,764 2030            5,064          425          118           7       3,150        8,764 2031            5,064          425          118           7       3,150        8,764 2032            5,078          426          118           7       3,159        8,788 2033            5,064          425          118           7       3,150        8,764 2034            5,064          425          118           7       3,150        8,764 2035            5,064          425          118           7       3,150        8,764 2036     1      5,078          426          118           7       3,159        8,788 2037            5,064          425          118           7       3,150        8,764 2038            5,064          425          118           7       3,150        8,764 2039            5,064          425          118           7       3,150        8,764 2040     1      5,078          426          118           7       3,159        8,788 2041            5,064          425          118           7       3,150        8,764 2042            5,064          425          118           7       3,150        8,764 2043            5,064          425          118           7       3,150        8,764 2044     1      5,078          426          118           7       3,159        8,788 2045            5,064          425          118           7       3,150        8,764 2046            5,064          425          118           7       3,150        8,764 2047            5,064          425          118           7       3,150        8,764 2048     1      5,078          426          118           7       3,159        8,788 2049            5,064          425          118           7       3,150        8,764 2050            5,064          425          118           7       3,150        8,764 2051            5,064          425          118           7       3,150        8,764 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 3, Page 20 of 26 TABLE 3.1 (continued)
SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2011 dollars)
Equipment &                     LLRW Year        Labor      Materials      Energy        Disposal      Other           Total 2052          5,078            426         118              7      3,159         8,788 2053          5,064            425         118              7      3,150         8,764 2054          5,064            425         118              7      3,150         8,764 2055          5,064            425         118              7      3,150         8,764 2056          5,078            426         118              7      3,159         8,788 2057          5,058            425         118              7      3,148         8,755 2058          2,862            298         118              6      2,150          5,434 2059          2,862            298         118              6      2,150          5,434 2060          2,869            299         118              6      2,156          5,448 2061          2,862            298         118              6      2,150          5,434 2062          2,862            298         118              6      2,150          5,434 2063          2,862            298         118              6      2,150          5,434 2064          2,869            299         118              6      2,156          5,448 2065          2,862            298         118              6      2,150          5,434 2066          2,862            298         118              6      2,150          5,434 2067          2,862            298         118              6      2,150          5,434 2068          2,869            299         118              6      2,156          5,448 2069          2,862            298         118              6      2,150          5,434 2070          2,862            298         118              6      2,150          5,434 2071          4,656            472         176              8      2,276          7,587 2072          36,052          3,622       1,182             32      4,470        45,358 2073          45,234         22,009       1,146        18,390      13,878       100,657 2074          46,421         23,157       1,014        24,118      15,270       109,980 2075          44,354          8,495         884        12,783       7,629        74,145 2076          30,089          3,499         337          2,193      3,450        39,568 2077          17,331         10,279         118              0        655        28,382 2078          10,541          6,252          72              0        398        17,263 Total        566,727       127,742       13,491        59,657     309,979     1,077,596 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear Generating Plant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                         Section 3, Page 21 of 26 TABLE 3.2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                  LLRW Year        Labor      Materials      Energy      Disposal      Other          Total 2016           3,035           103          94           3         823         4,058 2017         38,811         2,388        1,179         418      10,610       53,405 2018         19,075         3,990          568       1,335      18,447       43,415 2019           2,862          438          118          14       2,175         5,607 2020           2,870          439          118          14       2,181         5,622 2021           2,862          438          118          14       2,175         5,607 2022           2,862          438          118          14       2,175         5,607 2023           2,862          362          118          10       2,174         5,525 2024    1      2,869          307          118           7       2,179         5,479 2025            2,862          306          118           7       2,173         5,465 2026            2,862          306          118           7       2,173         5,465 2027           2,862          306          118           7       2,173         5,465 2028    1      2,869          307          118           7       2,179         5,479 2029           2,862          306          118           7       2,173         5,465 2030           2,862          306          118           7       2,173         5,465 2031           2,862          306          118           7       2,173         5,465 2032    1      2,869          307          118           7       2,179         5,479 2033           2,862          306          118           7       2,173         5,465 2034           2,862          306          118           7       2,173         5,465 2035           2,862          306          118           7       2,173         5,465 2036    1      2,869          307          118           7       2,179         5,479 2037           2,862          306          118           7       2,173         5,465 2038           2,862          306          118           7       2,173         5,465 2039           2,862          306          118           7       2,173         5,465 2040    1      2,869          307          118           7       2,179         5,479 2041           2,862          306          118           7       2,173         5,465 2042           2,862          306          118           7       2,173         5,465 2043           2,862          306          118           7       2,173         5,465 2044           2,869          307          118           7       2,179         5,479 2045           2,862          306          118           7       2,173         5,465.
2046           2,862          306          118           7       2,173         5,465 2047           2,862          306          118           7       2,173         5,465 2048           2,869          307          118           7       2,179         5,479 2049           2,862          306          118           7       2,173         5,465 2050           2,862          306          118           7       2,173         5,465 2051           2,862          306          118           7       2,17          5,465 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   DocumentP23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate                              Section 3, Page22 of 26 TABLE 3.2 (continued)
SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                    LLRW Year        Labor      Materials       Energy       Disposal       Other           Total 2052          2,869             307         118             7        2,179         5,479 2053          2,862             306         118             7        2,173         5,465 2054          2,862             306         118             7        2,173         5,465 2055          2,862             306         118             7        2,173         5,465 2056          2,869             307         118             7        2,179         5,479 2057          2,862             306         118             7        2,173         5,464 2058          2,862            298          118             6        2,150         5,434 2059          2,862            298          118             6        2,150         5,434 2060          2,869            299          118             6        2,156         5,448 2061          2,862            298          118             6        2,150         5,434 2062          2,862            298          118             6        2,150         5,434 2063          2,862            298          118             6        2,150         5,434 2064          2,869            299          118             6        2,156         5,448 2065          2,862            298          118             6        2,150         5,434 2066          2,862            298          118             6    2,150             5,434 2067          2,862            298          118             6        2,150         5,434 2068          2,869            299          118             6        2,156         5,448 2069          2,862            298          118             6        2,150         5,434 2070          2,862            298          118             6        2,150         5,434 2071          4,621            472          176             8        2,276         7,553 2072         35,366          3,622        1,182            32        4,470       44,672 2073         43,439         21,970        1,146        18,390       13,820       98,766 2074         44,947         23,086        1,014       24,109        14,794      107,949 2075         43,442          8,421          884        12,763        6,699       72,209 2076         28,520          2,641          327         2,189        3,239       36,916 2077             121              0           0             0            0           121 2078              74              0           0             0            0            74 Total        410,355         83,088      12,703        59,624      187,946       753,717 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                      Section 3, Page 23 of 26 TABLE 3.3 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2011 dollars)
Equipment &                 LLRW Year        Labor      Materials     Energy      Disposal    Other          Total 2016               0            0           0          0         146           146 2017               0            0           0          0      1,838          1,838 2018           5,296        2,640          68          0     10,298        18,302 2019           9,205        4,589         118          0     16,543        30,455 2020           9,231        4,601         118          0     16,588        30,538 2021           9,205        4,589         118          0     16,543        30,455 2022           9,205        4,589         118          0     16,543        30,455 2023           5,157        2,005          50          0      7,545        14,757 2024           2,208          120           0          0         980         3,309 2025           2,202          120           0          0         978         3,300 2026           2,202          120           0          0         978         3,300 2027           2,202          120           0          0         978         3,300 2028           2,208          120           0          0         980         3,309 2029           2,202          120           0          0         978         3,300 2030           2,202          120           0          0         978         3,300 2031           2,202          120           0          0         978         3,300 2032           2,208          120           0          0         980         3,309 2033           2,202          120           0          0         978         3,300 2034           2,202          120           0          0         978         3,300 2035           2,202          120           0          0         978         3,300 2036           2,208          120           0          0         980         3,309 2037           2,202          120           0          0         978         3,300 2038           2,202          120           0          0         978         3,300 2039           2,202          120           0          0         978         3,300 2040           2,208          120           0          0         980         3,309 2041           2,202          120           0          0         978         3,300 2042           2,202          120           0          0         978         3,300 2043           2,202          120           0          0         978         3,300 2044           2,208          120           0          0         980         3,309 2045           2,202          120           0          0         978         3,300 2046           2,202          120           0          0         978         3,300 2047           2,202          120           0          0         978         3,300 2048           2,208          120           0          0         980         3,309 2049           2,202          120           0          0         978         3,300 2050           2,202          120           0          0         978         3,300 2051           2,202          120           0          0         978         3,300 TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant                    Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 3, Page 24 of 26 TABLE 3.3 (continued)
SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2011 dollars)
Equipment &                    LLRW Year         Labor      Materials      Energy        Disposal      Other          Total 2052            2,208          120            0              0        980         3,309 2053            2,202          120            0              0        978         3,300 2054            2,202          120            0              0        978         3,300 2055            2,202          120            0              0        978         3,300 2056            2,208          120            0              0        980         3,309 2057            2,196          119            0              0        975         3,290 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              124            82           0             29      1,347          1,583 2073                0             0           0              0           0             0 2074                0             0           0              0           0             0 2075                0             0           0              0           0             0 2076              156          435            0              3         193           788 2077                0             0           0              0           0             0 2078               79          239            0              0          20           338 Total        122,583        27,839          589             32    120,866       271,910 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                       Section 3, Page 25 of 26 TABLE 3.4 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                 LLRW Year         Labor      Materials      Energy     Disposal    Other          Total 2016                0            0           0          0           0            0 2017                0            0           0          0           0            0 2018                0            0           0          0           0            0 2019                0            0           0          0           0            0 2020                0            0           0          0           0            0 2021                0            0           0          0           0            0 2022                0            0           0          0           0            0 2023                0            0           0          0           0            0 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 TLG Services, Inc.

CrystalRiver Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 3, Page 26 of 26 TABLE 3.4 (continued)
SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2011 dollars)
Equipment &                    LLRW Year        Labor      Materials      Energy        Disposal      Other          Total 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 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              34             0            0             0           0           34 2072             686             0            0             0           0          686 2073           1,794            38            0             0          58        1,890 2074           1,436            46            0             0          58        1,540 2075             827            17            0             0           0          844 2076           1,544           815          10              0          51        2,420 2077          17,079         9,886         118              0        622        27,705 2078          10,388         6,013          72              0        378        16,850 Total         33,789        16,814         199              0      1,167        51,969 Note: Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant                  Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                              Section 4, Page I of 4
: 4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario 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 deferred decommissioning portion of the SAFSTOR alternative is presented in Figure 4.1. The scheduling sequence assumes that fuel has been removed from the site prior to the start of decontamination and dismantling activities. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was 31 prepared using the "Microsoft Project Professional 2010" computer software.[ 1 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 person-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 spent fuel handling area in the auxiliary building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the ISFSI.
* 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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                              Section 4, Page 2 of 4 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.
The project timeline is provided in Figure 4.2 with milestone dates based on a 2016 shutdown date. The fuel pool is emptied approximately six and one-half years after shutdown, while ISFSI operations continue until the DOE can complete the transfer of assemblies to its geologic repository. Deferred decommissioning is assumed to commence so that the operating license is terminated within a 60-year period from the cessation of plant operations.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                                                        Document P23-1651-001,Rev. 0 PreliminaryDecommissioning Cost Estimate                                                                            Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE 2075            2076            2077         2078 STask Name2074                 2Q   Q1QI Q2 1 3 104 1 1. Q2 IQ3 1(4 1Q2I Q2 IQ3 IQ4 IQ1I Q2 IQ3 IQ4 IQ1I Q2 IQ3 IQ4 IQ1I IQ21 1OTs~meQ 1 PERIOD 3a - Reactivate Site 2    Reconfigure plant 3    Prepare activity specifications 4    Perform site characterization 5    DOC staff mobilized 6 PERIOD 3b - Decommissioning Prep 7    Reconfigure plant a     Prepare detailed work procedures 9     Decon NSSS 10 PERIOD 4a - Large Component Removal                          --
11    Prep for reactor vessel removal 12    Reactor vessel & internals 13    Remaining large NSSS components 14    Non-essential systems 15    Main turbine/generator 16    Main condenser 27    Reactor building systems removal 18    Systems removal not supporting RPV 19 PERIOD 4b - Site Decontamination 20    Reactor building systems removal 21    Reactor building Decon 22    Remaining Decom Activities 23    Removal of remaining systems 24    License termination plan approved 25    Decontamination of remaining buildings 26 PERIOD 4e- Ucense Termination 27    Final site survey 28    NRC review & approval 29    Part 50 license terminated 30 PERIOD 5b- site restoration 31    Building demoltions, backfill, landscape 32    Decommissioning Complete Legend:                1. Blue bars indicate overall duration of activity
: 2.      Red bars indicate critical path activities
: 3.      Diamond symbols indicate major milestones TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                                 Section 4, Page 4 of 4 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)
Shutdown                                                                                           Operating License December 3, 2016                                                                                         Terminated 1                                                                                                       I Period 1                        Period 2                        Period 3             Period 4          Period 5 SAFSTOR                        Dormancy                     Decommissioning          Deferred            Site Preparations                                                    Preparations       Decommissioning     Restoration 12/2016         06/2018                                      12/2071              06/2073             12/2076        08/2078 Wet Transfer Complete Transfer of Irradiated Fuel from Pool to ISFS1 Dry Transfer 06/2023                      Complete T
Transfer of Irradiated Fuel from ISFSI to DOE 2023                       2057 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                           Section 5, Page I of 4
: 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,[321 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
&sect;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 Appendix C, and summarized in Table 5.1. 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).
While the dose rates decrease with time, radionuclides such as 13 7Cs will still control the disposition requirements.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Section 5, Page 2 of 4 The waste material produced in the decontamination and dismantling of the nuclear unit is primarily generated during Period 4. The assumed disposition of waste material is shown in Figure 5.1. 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.
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. 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. As a proxy, disposition of the Class B and C waste is based upon the last published rate schedule for non-compact waste for the Barnwell facility.
TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant     Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate               Section 5, Page 3 of 4 FIGURE 5.1 DECOMMISSIONING WASTE DISPOSITION TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                                 Section 5, Page 4 of 4 TABLE 5.1 DECOMMISSIONING WASTE 

==SUMMARY==

Waste Volume            Mass Waste                  Cost Basis       Class [1]   (cubic feet)        (pounds)
Low-Level Radioactive Waste (near-surface            EnergySolutions        A              133,758         9,951,211 disposal)
Barnwell           B                   250           27,400 Barnwell           C                   501           57,900 Greater than Class C              Spent Fuel (geologic repository)             Equivalent        GTCC                2,142          423,646 Processed/Conditioned              Recycling (off-site recycling center)        Vendors            A             234,503         11,217,670 Total [21                                                           371,154        21,677,830
[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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant               Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 6, Page 1 of 4
: 6. RESULTS The analysis to estimate the cost to decommission Crystal River relied upon the site-specific, technical information developed for a previous analysis prepared in 2008. While not an engineering study, the estimate provides Progress Energy with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.
The estimate described in this report is 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 station's spent fuel pool for a minimum of six and one half years following the cessation of operations for continued cooling of the assemblies. An ISFSI will be used to safeguard the spent fuel, once sufficiently cooled, until such time that the DOE can complete the transfer of the assemblies to its repository.
The cost projected for deferred decommissioning (SAFSTOR) is estimated to be
$1,077.6 million. The majority of this cost (approximately 70.0%) 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 25.2% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 4.8% is for the demolition of the designated structures and limited restoration of the site.
The primary cost contributors, identified in Table 6.1, 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 Progress Energy will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities.
However, once the operating license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site.
As described in this report, the spent fuel pool will remain operational for a minimum of six and one half years following the cessation of operations. The pool will be isolated and an independent spent fuel island created. Over the six and one-TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 6, Page2 of 4 half-year period, the spent fuel will be packaged into transportable steel canisters for interim storage at the ISFSI. Dry storage of the fuel provides additional flexibility in the event the DOE is not able to meet the current timetable for completing the transfer of assemblies to an off-site facility and minimizes the associated caretaking expenses.
The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, the EnergySolutions facility in Utah is the assumed destination for the majority of the low-level radioactive material required controlled disposal, with the remaining, high-activity waste destined for the newly opened Waste Control Specialists facility in Texas. Components, requiring additional isolation from the environment (i.e.,
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.
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.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                            Section 6, Page 3 of 4 Decontamination is used to reduce the plant's 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.
TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant                        Document P23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate                                        Section 6, Page 4 of 4 TABLE 6.1 DECOMMISSIONING COST ELEMENT CONTRIBUTION (thousands of 2011 dollars)
Cost Element                                          Total            Percentage Decontamination                                            12,409               1.2 Removal                                                   101,075               9.4 Packaging                                                  22,681               2.1 Transportation                                             11,922               1.1 Waste Disposal                                             46,245               4.3 Off-site Waste Processing                                  23,246               2.2 Program Management [1]                                   306,020              28.4 Site Security                                            183,679             17.0 Spent Fuel Pool Isolation                                 11,822               1.1 Spent Fuel Management [21                                 129,013             12.0 Insurance and Regulatory Fees                              61,040               5.7 Energy                                                     13,491               1.3 Characterization and Licensing Surveys                    15,110               1.4 Property Taxes                                             87,216               8.1 Utility Site Indirect                                      19,326               1.8 Corporate Allocations                                     14,257               1.3 Miscellaneous Equipment                                    19,045               1.8 Total  [31                                             1,077,596               100 Cost Element                                            Total           Percentage License Termination                                       753,717             70.0 Spent Fuel Management                                     271,910             25.2 Site Restoration                                           51,969               4.8 Total [31                                              1,077.,596              100
[1] Includes engineering and security costs
[21 Excludes program management costs (staffing) but includes costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees
[31 Columns may not add due to rounding TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 7, Page 1 of 3
: 7. REFERENCES
: 1.    "Decommissioning Cost Analysis for the Crystal River Plant, Unit 3," Document No. P23-1597-002, Rev. 0, TLG Services, Inc., October 2008
: 2. U.S. Code of Federal Regulations, Title 10, Part 50.75, "Reporting and recordkeeping for decommissioning planning," Subpart (f0(3)
: 3. U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988
: 4. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 2003
: 5. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "Radiological Criteria for License Termination"
: 6. 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
: 7. U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996.
: 8.    "Nuclear Waste Policy Act of 1982 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982
: 9. 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
: 10. U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities," Subpart 54 (bb), "Conditions of Licenses"
: 11. U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant             Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                        Section 7, Page 2 of 3
: 7. REFERENCES (continued)
: 12.   "Low Level Radioactive Waste Policy Act," Public Law 96-573, 1980
: 13.   "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986
: 14. Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55
: 15. 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
: 16.   "Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination," EPA Memorandum OSWER No. 9200.4-18, August 22, 1997.
: 17. 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"
: 18.   "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
: 19.   "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),"
NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000
: 20. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986
: 21. W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook,"                U.S.
Department of Energy, DOE/EV/10128-1, November 1980
: 22.   "Building Construction Cost Data 2011," Robert Snow Means Company, Inc.,
Kingston, Massachusetts
: 23. Project and Cost Engineers' Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984 TLG Services, Inc.

CrystalRiver Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Section 7, Page 3 of 3
: 7. REFERENCES (continued)
: 24. Civilian Radioactive Waste Management System Waste Acceptance System Requirements Document, Revision 5" (DOE/RW-0351) issued May 31, 2007
: 25. U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178
: 26. Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, August 2011
: 27. 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
: 28. 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
: 29. 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
: 30.   "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
: 31.   "Microsoft Project Professional 2010," Microsoft Corporation, Redmond, WA.
: 32.   "Atomic Energy Act of 1954," (68 Stat. 919)
TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant    Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate            Appendix A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                           Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                                     Appendix A, Page 2 of 4 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 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   DocumentP23-1651-001, Rev. 0 PreliminaryDecommissioningCost Estimate                              Appendix A, Page 3 of 4 APPENDIX A (continued)
: 3. LABOR REQUIRED Duration        Rate Crew                              Number           (hours)        ($Ihr)           Cost Laborers                            3.00             11.217        $28.05          $943.91 Craftsmen                           2.00             11.217        $51.72        $1,160.92 Foreman                             1.00             11.217        $60.83          $682.33 General Foreman                     0.25             11.217        $63.09          $176.92 Fire Watch                          0.05             11.217        $28.05           $15.73 Health Physics Technician           1.00             11.217        $44.00          $493.55 Total Labor Cost                                                                 $3,472.73
: 4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs                                                                       none Consumables/Materials Costs
 -Universal Sorbent 50 @ $0.62 sq ft {(}                                            $31.00
 -Tarpaulins (oil resistant/fire retardant) 50 @ $0.46/sq ft 12}                    $23.00
 -Gas torch consumables 1 @ $11.84/hr x 1 hr {(3                                    $11.84 Subtotal cost of equipment and materials                                            $65.84 Overhead & profit on equipment and materials @ 16.00 %                              $10.53 Total costs, equipment & material                                                   $76.37 TOTAL COST:
Removal of contaminated heat exchanger <3000 pounds:                             $3,549.10 Total labor cost:                                                                $3,472.73 Total equipment/material costs:                                                     $76.37 Total craft labor man-hours required per unit:                                       81.88 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant              Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                        Appendix A, Page 4 of 4
: 5. NOTES AND REFERENCES
* Work difficulty factors were developed in conjunction with the Atomic Industrial Forum's (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.
       " References for equipment & consumables costs:
: 1. www.mcmaster.com online catalog, McMaster Carr Spill Control (7193T88)
: 2. R.S. Means (2011) Division 01 56, Section 13.60-0600, page 20
: 3. R.S. Means (2011) Division 01 54 33, Section 40-6360, page 664
* Material and consumable costs were adjusted using the regional indices for Tampa, Florida.
TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant         Document P23-1651-001,Rev. 0 Preliminary Decommissioning Cost Estimate                 Appendix B, Page I of 7 APPENDIX B UNIT COST FACTOR LISTING (SAFSTOR: Power Block Structures Only)
TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                            Cost/Unit($)
Removal   of clean instrument and sampling tubing, $/linear foot                      0.36 Removal   of clean pipe 0.25 to 2 inches diameter, $/linear foot                      3.62 Removal   of clean pipe >2 to 4 inches diameter, $/linear foot                        5.50 Removal   of clean pipe >4 to 8 inches diameter, $/linear foot                       11.41 Removal   of clean pipe >8 to 14 inches diameter, $/linear foot                      21.18 Removal   of clean pipe >14 to 20 inches diameter, $/linear foot                     27.56 Removal   of clean pipe >20 to 36 inches diameter, $/linear foot                     40.54 Removal   of clean pipe >36 inches diameter, $/linear foot                           48.16 Removal   of clean valve >2 to 4 inches                                              76.72 Removal   of clean valve >4 to 8 inches                                            114.08 Removal   of clean valve >8 to 14 inches                                           211.82 Removal   of clean valve >14 to 20 inches                                          275.56 Removal   of clean valve >20 to 36 inches                                          405.40 Removal   of clean valve >36 inches                                                481.61 Removal   of clean pipe hanger for small bore piping                                 24.48 Removal   of clean pipe hanger for large bore piping                                 82.23 Removal   of clean pump, <300 pound                                                192.65 Removal   of clean pump, 300-1000 pound                                            550.51 Removal   of clean pump, 1000-10,000 pound                                       2,149.11 Removal   of clean pump, >10,000 pound                                           4,156.91 Removal   of clean pump motor, 300-1000 pound                                      230.87 Removal   of clean pump motor, 1000-10,000 pound                                   894.31 Removal   of clean pump motor, >10,000 pound                                     2,012.19 Removal   of clean heat exchanger <3000 pound                                    1,164.56 Removal   of clean heat exchanger >3000 pound                                    2,932.13 Removal   of clean feedwater heater/deaerator                                    8,191.42 Removal   of clean moisture separator/reheater                                  16,745.08 Removal   of clean tank, <300 gallons                                              247.78 Removal   of clean tank, 300-3000 gallon                                           780.85 Removal   of clean tank, >3000 gallons, $/square foot surface area                    6.76 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                              Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                             Cost/Unit($)
Removal   of clean electrical equipment, <300 pound                                  104.76 Removal   of clean electrical equipment, 300-1000 pound                              375.90 Removal   of clean electrical equipment, 1000-10,000 pound                           751.80 Removal   of clean electrical equipment, >10,000 pound                             1,841.91 Removal   of clean electrical transformer < 30 tons                                1,279.18 Removal   of clean electrical transformer > 30 tons                                3,683.82 Removal   of clean standby diesel generator, <100 kW                               1,306.57 Removal   of clean standby diesel generator, 100 kW to 1 MW                        2,916.36 Removal   of clean standby diesel generator, >1 MW                                 6,037.46 Removal   of clean electrical cable tray, $/linear foot                                9.82 Removal   of clean electrical conduit, $/linear foot                                   4.29 Removal   of clean mechanical equipment, <300 pound                                  104.76 Removal   of clean mechanical equipment, 300-1000 pound                              375.90 Removal   of clean mechanical equipment, 1000-10,000 pound                           751.80 Removal   of clean mechanical equipment, >10,000 pound                             1,841.91 Removal   of clean HVAC equipment, <300 pound                                        126.69 Removal   of clean HVAC equipment, 300-1000 pound                                    451.67 Removal   of clean HVAC equipment, 1000-10,000 pound                                 900.18 Removal   of clean HVAC equipment, >10,000 pound                                   1,841.91 Removal   of clean HVAC ductwork, $/pound                                              0.38 Removal   of contaminated    instrument and sampling tubing, $/linear foot              1.19 Removal   of contaminated    pipe 0.25 to 2 inches diameter, $/linear foot            18.15 Removal   of contaminated    pipe >2 to 4 inches diameter, $/linear foot              30.28 Removal   of contaminated    pipe >4 to 8 inches diameter, $/linear foot              49.50 Removal   of contaminated    pipe >8 to 14 inches diameter, $/linear foot             93.16 Removal   of contaminated    pipe >14 to 20 inches diameter, $/linear foot           110.95 Removal   of contaminated    pipe >20 to 36 inches diameter, $/linear foot           151.69 Removal   of contaminated    pipe >36 inches diameter, $/linear foot                 178.39 Removal   of contaminated    valve >2 to 4 inches                                    370.40 Removal   of contaminated    valve >4 to 8 inches                                    437.70 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                   Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                            Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                             Cost/Unit($)
Removal   of contaminated  valve >8 to 14 inches                                     868.96 Removal   of contaminated  valve >14 to 20 inches                                  1,098.06 Removal   of contaminated  valve >20 to 36 inches                                  1,454.27 Removal   of contaminated  valve >36 inches                                        1,721.27 Removal   of contaminated  pipe hanger for small bore piping                         115.54 Removal   of contaminated  pipe hanger for large bore piping                         370.99 Removal   of contaminated  pump, <300 pound                                          783.33 Removal   of contaminated  pump, 300-1000 pound                                    1,841.28 Removal   of contaminated  pump, 1000-10,000 pound                                5,810.90 Removal   of contaminated  pump, >10,000 pound                                   14,145.54 Removal   of contaminated  pump motor, 300-1000 pound                                810.42 Removal   of contaminated  pump motor, 1000-10,000 pound                          2,394.87 Removal   of contaminated  pump motor, >10,000 pound                              5,376.99 Removal   of contaminated  heat exchanger <3000 pound                             3,549.10 Removal   of contaminated  heat exchanger >3000 pound                            10,358.57 Removal   of contaminated  tank, <300 gallons                                      1,310.02 Removal   of contaminated  tank, >300 gallons, $/square foot                          25.36 Removal   of contaminated  electrical equipment, <300 pound                          596.45 Removal   of contaminated  electrical equipment, 300-1000 pound                    1,488.20 Removal   of contaminated  electrical equipment, 1000-10,000 pound                2,867.82 Removal   of contaminated  electrical equipment, >10,000 pound                    5,776.36 Removal   of contaminated  electrical cable tray, $/linear foot                       28.72 Removal   of contaminated  electrical conduit, $/linear foot                          14.91 Removal   of contaminated  mechanical equipment, <300 pound                          662.99 Removal   of contaminated  mechanical equipment, 300-1000 pound                    1,641.54 Removal   of contaminated  mechanical equipment, 1000-10,000 pound                3,158.03 Removal   of contaminated  mechanical equipment, >10,000 pound                    5,776.36 Removal   of contaminated  HVAC equipment, <300 pound                                662.99 Removal   of contaminated  HVAC equipment, 300-1000 pound                          1,641.54 Removal   of contaminated  HVAC equipment, 1000-10,000 pound                      3,158.03 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                 Document P23-1651-001, Rev. 0 PreliminaryDecommissioning Cost Estimate                           Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                           Cost/Unit($)
Removal of contaminated HVAC equipment, >10,000 pound                           5,776.36 Removal of contaminated HVAC ductwork, $/pound                                       1.80 Removal/plasma arc cut of contaminated thin metal components, $/linear in.           3.23 Additional decontamination of surface by washing, $/square foot                      6.53 Additional decontamination of surfaces by hydrolasing, $/square foot                31.91 Decontamination rig hook up and flush, $/ 250 foot length                       5,548.30 Chemical flush of components/systems, $/gallon                                      19.54 Removal of clean standard reinforced concrete, $/cubic yard                        129.38 Removal of grade slab concrete, $/cubic yard                                       162.13 Removal of clean concrete floors, $/cubic yard                                     341.10 Removal   of sections of clean concrete floors, $/cubic yard                       995.12 Removal   of clean heavily rein concrete w/#9 rebar, $/cubic yard                  229.00 Removal   of contaminated heavily rein concrete w/#9 rebar, $/cubic yard        1,919.93 Removal   of clean heavily rein concrete w/#18 rebar, $/cubic yard                 289.56 Removal   of contaminated heavily rein concrete w/#18 rebar, $/cubic yard       2,536.65 Removal   heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 429.87 Removal   of below-grade suspended floors, $/cubic yard                            341.10 Removal   of clean monolithic concrete structures, $/cubic yard                    817.52 Removal   of contaminated monolithic concrete structures, $/cubic yard          1,904.47 Removal   of clean foundation concrete, $/cubic yard                               643.51 Removal of contaminated foundation concrete, $/cubic yard                        1,774.63 Explosive demolition of bulk concrete, $/cubic yard                                 29.38 Removal of clean hollow masonry block wall, $/cubic yard                            77.50 Removal of contaminated hollow masonry block wall, $/cubic yard                    265.37 Removal of clean solid masonry block wall, $/cubic yard                             77.50 Removal of contaminated solid masonry block wall, $/cubic yard                     265.37 Backfill of below-grade voids, $/cubic yard                                         34.32 Removal of subterranean tunnels/voids, $/linear foot                                96.84 Placement of concrete for below-grade voids, $/cubic yard                          137.89 Excavation of clean material, $/cubic yard                                           3.36 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant                  Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate                             Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                            Cost/Unit($)
Excavation of contaminated material, $/cubic yard                                    40.38 Removal   of clean concrete rubble (tipping fee included), $/cubic yard              24.09 Removal   of contaminated concrete rubble, $/cubic yard                              23.97 Removal   of building by volume, $/cubic foot                                         0.29 Removal   of clean building metal siding, $/square foot                               0.86 Removal of contaminated building metal siding, $/square foot                          3.17 Removal of standard asphalt roofing, $/square foot                                    1.70 Removal of transite panels, $/square foot                                             1.88 Scarifying contaminated concrete surfaces (drill & spall), $/square foot             11.67 Scabbling contaminated concrete floors, $/square foot                                 6.61 Scabbling contaminated concrete walls, $/square foot                                 17.02 Scabbling contaminated ceilings, $/square foot                                       57.99 Scabbling structural steel, $/square foot                                             5.54 Removal of clean overhead crane/monorail < 10 ton capacity                          551.82 Removal of contaminated overhead crane/monorail < 10 ton capacity                 1,560.67 Removal   of clean overhead crane/monorail >10-50 ton capacity                    1,324.37 Removal   of contaminated overhead crane/monorail >10-50 ton capacity             3,744.98 Removal   of polar crane > 50 ton capacity                                        5,680.92 Removal   of gantry crane > 50 ton capacity                                      23,023.90 Removal   of structural steel, $/pound                                                0.19 Removal   of clean steel floor grating, $/square foot                                 4.27 Removal   of contaminated steel floor grating, $/square foot                         12.24 Removal   of clean free standing steel liner, $/square foot                          10.13 Removal   of contaminated free standing steel liner, $/square foot                   29.57 Removal   of clean concrete-anchored steel liner, $/square foot                       5.06 Removal of contaminated concrete-anchored steel liner, $/square foot                 34.44 Placement of scaffolding in clean areas, $/square foot                               17.33 Placement of scaffolding in contaminated areas, $/square foot                        25.14 Landscaping with topsoil, $/acre                                                 31,052.99 Cost of CPC B-88 LSA box & preparation for use                                    2,330.58 TLG Services, Inc.

Crystal River Unit 3 Nuclear GeneratingPlant             Document P23-1651-001, Rev. 0 Preliminary Decommissioning Cost Estimate                     Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)
Unit Cost Factor                                                       Cost/Unit($)
Cost of CPC B-25 LSA box & preparation for use                              2,128.87 Cost of CPC B- 12V 12 gauge LSA box & preparation for use                   1,720.00 Cost of CPC B- 144 LSA box & preparation for use                           12,064.98 Cost of LSA drum & preparation for use                                         198.16 Cost of cask liner for CNSI 8 120A cask (resins)                            8,331.49 Cost of cask liner for CNSI 8 120A cask (filters)                           8,734.69 Decontamination of surfaces with vacuuming, $/square foot                        0.68 TLG Services, Inc.

Crystal River Unit 3 NuclearGeneratingPlant       Document P23-1651-001, Rev. 0 Preliminary DecommissioningCost Estimate              Appendix C, Page I of 12 APPENDIX C DETAILED COST ANALYSIS TLG Services, Inc.

C-y*atl River Unit 3 Nuclear Generting Plant                                                                                                                                                                                                                      Document P23-16I1-001, Ret. 0 Preliinuey Deo.Iealuning Cat EatlU-te                                                                                                                                                                                                                                  Appendix C. Page 2f      12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (tht.uusnds of 2011 dollar.)
I eoon Rmeoual Pack.giog  Trenopon  Off-site Po..iog      LLRW Dihpu..l     Other        Totl          Tutul       NRC LIe-T.erm     . Sp-n Fuel gent       S te ReM.oraeio. Pr-se Vol.oe,,r-a1 Cl.ss A  Cl.ss B V.I.e Cl... -Bur'alI/
C      OTCC    P-e--d       Craft     Ufflky-ad Co--tror IA[-dwtp                                         .......... Co.. C.t"     Co.-.      Cu-e. Cute.       Cste.      Cute. Contiogeocy      Cut.        Cut.           Cute.      Co.-       Cu. Feet     Cu. Fot  Cu. Feet  C.. Fee       Cu. Feet W., Lh.. M.nhoour. 3M.ihou PERIOD 1. - Shutdowo though T'r.osiioo Perosd HoDir-etDeooooie.iooiogdi      Aetirlid 1.1.1     SAFSTOR      sith.e e6 .- er i-ti.o-uuy                                                                         347               2N        451          451 a.1.2   Prupte prelimrinaryd           oi-sirm gsotot                                                                    149                         171          171                                                                                                                 13600 I,. '.3   Notifirtioo of Ceation of      r Qerau.os
    .1.4    Ro--      f..u & .o..ur m Ic.1.5    No.ifi.Uisr of P-sre-t          Defuelsog la.1.6                  peo
                            .,i -,tep.tosy.suo
                                          & p-ro     -aote 1a.l.7    Prrtepe uod -ubmitPSDAR                                                                                         229                    4    263          263                                                                                                                  2. I0 IsI8  Reviewpl-n dwgp& spo.                                                                                            149              22         171          171                                                                                                                 1.30M
   ]Ia]        tPrforrederoiled rtd .ursso Is IS   OIerrtlmtu by-prodootloornoory                                                                                   114              17         M97          197 odprols d-esriplon ad1.11                                                                                                          1]4              17         132          132 Is 7 S2uDcidby.produs indenlory                                                                                       172              27         197          i97 le.t.l3   Deu moj.or -ok-oque...                                                                                           114              17         132          132                                                                                                                 5.00o S14     PtrformSER .. d EA                                                                                               M35              5M        408          408 le.t.15   P-rfsrro Sisa-SpeoiflrCostStudy                                                                                                   86         01          658 AdritalySpci-ilo-s                                                                                                                          ole     3142          2132 le.N.I6. Prepe  - plit t-d Sidbie, f., SAF,33 R                                                                                             M8        N48          G48                                                                                                                  4.920 Ia.1.162 'lest eyeetoo 277               72        59           N49                                                                                                                  4.167 1I..1.16.3 'I~to tsrturets od buldiog,                                                                                     M57              54        411           ,11                                                                                                                 3.120 le.1.6.4 I, We          o s.emtl                                                                                            29                          %3           263                                                                                                                  2."00 1a.1.16.5 Pacdhty  oedsiteadsrronoy                                                                                                         M4          M          203                                                                                                                  2.600 Ia 1.16 Tostal                                                                                                                             27,8     2.133         2.133                                                                                                                16207 DetuitedWorhPornleea*
l1,1.17.1 l'leseyrsrso                                                                                                                                                                                                                                                                  1,183 l,..7.3   F.dscis  d.o. t & d.-otry                                                                                    137 273               41        314          311                                                                                                                  2.a33 Ia 1.17   Total I, 1.10   Pros-os,,sumorrdresinesytrste                                                                                      I1I             2          13            13                                                                                                                   10M l1 1.19   Prtiolde-orsrgize    oosnorret   s    oa I 1.20  Dri. & dey NSSS 10.l.21   Srsirtide-rrrrSizeuossrausnrtedyurer l 1.22    Deoolsure ooramrodroody          Cea' laot      SubloralPuriod laeAcliisty      Csos                                                                           145               720      5 173         5175 Period1t Colle.er.l Co.s.
    ..,3.1  Florid, LLRWlospectiroFee Is3       Subot] Poriod l. CellaerI Co.s-Period I, Poriod.DjpoedrrtCo-1 l4 4.1     r-rsur                                                                                                        1.334             1043     1.457         1.007 1 42      Propertytrato.                                                                                                 3.715             372      4007          4.007 1.4.3    Health phycio tuppht                                                                                                                  in    127          627 la.4.4    H_ y eruipmoentrenat                                        490                                                                   73         W`3         5%3 1.4.5   Dspoalof DAWgeoertatd                                                                                                                                                                                      610                                      12.1W0         20 la 4.6    Ptoener.-budge.                                                                                                1,025             15        1.179        1,179 l1a..7    NRCF1                                                                                                                              7          45         846 l,4.0        rer.--oS PluooingFe                                                                                                            7.        .157          -
la.4.9    UsiblySitu Trdiers                                                                                             1,871             2M1      2 152         2,152 Is.4.10   Sport FPolPost O&M                                                                                               763             1]4        878 1,.4.11   ISPSI OptebratnCosla                                                                                              89              13         I03M                        13 1.4.12    Co-r=ote A2l6'ons                                                                                                                214      1.602         1.642 le.4.13   INI'ClFers                                                                                                       135 la.4 14   Soerity SsuftCot                                                                                               6598              600      7.588         7.508                                                                                                               157.471 le 4.15    -l1oitySaffCost                                                                                          S   22 197           3330      25.526        22.526                                                                                                               423.40W I0.4      Subhes] Poriod It Period-L*S.psrdrrs      i.oe                          14           W                30      40705           .5 95      47.735        45897                                               610                                      12190          20       580.871 991 10.0      TOTALPERIOD1.5l          COST                                                        I&#xfd;30                     45 16t           6705      52911         51.074                                              61W                                      ]1- 1          20       616.761 14 TLG SeniceInc.

Cryetal Ricer Unit 3 Nuclear Generatin Plant                                                                                                                                                                                                                          Docinent P23-1651-001, Rev. 0 Preliminay Decommiaioning Cot &timnmte                                                                                                                                                                                                                                     Appendi. C, Page3 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (tlnu,,ndof      2011 dollses)
IActivity                                                Devon   Removsl  Pcksaging   Trsnsport    Possiog          VNRC thberLL~t, Tot-1 Disp.ossI Off-Site                             Total       Lie.Term. M.n.ge-t Sp-n Fuel    Setorutioo Site     Volume P-o-sd      ClIss A    lans  B VolmsBrilIUilt-n
                                                                                                                                                                                                                                   .-uria    luss
                                                                                                                                                                                                                                              . C         TC   Prom      d   Lt Crf         Contrsctor AInden                           Actvity DlescripuionLu  Ct      Cout      Lost.       Losts        Cout-      CLout       CLots      Continr         Ln ost.
                                                                                                                                                            -         Co.           Cots         Ctost     Cu. Fet    C Feet    Cu. Feet   C. Feet     C. Feet Wt.. Lbs. M.nhobr.      Mnhsour.
PERIOD I1 - SAFSTORLimited DECONAtlultlu.
peritd lb DireDt DnmoomiuitoiotAcsioitis DecontaminstjonotSitn Btildiogs
:b.l.I,   Rnottr                                            980                                                                                 490      1.470           1.400 lb.t.t.2 Auuliery Buddig                                    329                                                                                 1"4         493           493                                                                   -    -     -         -         7.527 1b.t..3 Fuslisodling Attn(un Bldo)                         80&                                                                                 ,01      1-204           1.204 lb.l.t.4 Inte     datne Bldg                                 67                                                                                  34         10l           101                                                                   -      .   -         -         1.557 tb.t.l.5  MachineSao. - Hot                                   46                                                                                  23          69            69                                                                                                  1.031,
:b.t.1.6 R"tW.b..o.2                                                                                                                             14          43             4 lb.t.1.7 RVCHStorge Bnuildog                                  4                                                                                                                                                                                                                   9061 tI.i.i    Total.                                           2.258                                                                               1.12       3,386          3.386 lb.t     Subotal PeriodIb Adti&#xfd;to C-t.                    2.258                                                                               1,12       33&6           3.386 Psriol lb Addiu.on.l Lot Ib2.1   MiscWnta                                                                425         w-0          681                                   241      1,987           1.987                                2.343                                            1I.4 253        2892 lb.3     Subtotal Poodli      Addti..onl Cot                                     422        633           681                                   211      1,987           1.987                                2.343                                            158,W53.        2.892 Ptriod lb CLllabursl CLos lb.3.t   D-tnteutcmeot                                      964                                                     -           -               145      1.109           1.109 lb.3.2   Pr-      ds-tooomouiiog ut-rne~ta                   33                                                    318                          254      1.057           1.057                                           841                                      5O.433         Iq4 tb.3.4   Stoal tool sllowuooo                                                                                                                     6          47             47 41                    3141                                   7              1           8               a lb.3 5    Gopids  L+/-5Wlapnclou Fo                                                                                                                                                                                                                                                184 lb.3     Subtotal Periodlb Contol C-ost                   1.097                                                    318             2            355      2222           2.=2                                             841                                      58.433 Psriod Ib Priod-Dopendot Louts
:b.4.l    Dtoo upplits                                       901                                                                                 225      1.126           1.126 lb.4.2    lootrsom                                                                           344                                       36        34         370             7 tb.4.3   Propertytout.                                                                                                          &M8              64         701           261 Ib..s     lltbh phbito     -upplin                                  YA'                                                    -92                              458           ,58 tb.4.5    l&#xfd;my nquipmeot     rentol                                                                                  S           -                9         142           142 lb.4.6   Dipusl f DAWgooerstod                                                                                      -30          -                0o          1            61                                            602                                      12.041          20 lb.4.7   Plut eoergybtdgst                                                                                                                       39         297           257 lb.4.l   NRC Fo.                                                                                                                194              19         213           213 1b.4.9    cE,r         lsoo ing Ions Pec                                                                                                       13               .2o        21G                          216 1   2 1b..0    UtilityS-te 1Idto*,t                                                                                                   472              71,        542           &12 192              29         221 b:.4.11 Sptot FuelPool.. &                                                                                                                                                              221 lb..12   JSFSIOperUtiogLots                                                                                                       23              3          26 tb.s.13  Corptorsto
                    '    lt'onsu                                                                                                  3w0              64         414           414 lbs. I4  Snotity StaffCt                                                                                                       1.663            249      ],913           1.913                                                                                                              39*9]
tb.4.15  UtilityStff Lout                                                                                                                       M5595 69       60.34          6.4341                                                                                                              106.720 ib.4     Subttl Ptood Ib Ptriol.-D~eodtyt Lust.             Sol     490           14         10                     -302      9927            1.767    13.138          12,675            4Q*                    -        602                                      12 41           20        146.411 lb.2     TOTALFERIODlb,LST                                4.5       531          1.         99977         601      348        9934            3.491    20.734          20270             463                  2343      14,13                                  1.610.727      51.216        146.411 PERIOD t. - Preprut ion. fto SAPFTORD....,y Priod k Ditet Demtvtisstodtn          titmilis le.].l   Preprn supporttequipmetnt     rot stuorge                  4",                                                                          64         489           489                                                                                                  3.060 le.].2   Installtotaiveoot pressoo equsIlines                                                                                                     5          42             42 e1v13   ioterit sut"ey p-orttot  dtormny                                                                                       733             220           353         953                                                                                                 15,678 l.] .4   S--re buildiog           s
: 1. 1b     Prepar & sbrtttrmrpr                                                                                                     1,7            to          77              77                                                                                                                583
: l. I     Subtotal PeriodI Aftivity Cout.                                                                                        800             .299     1,5W            1,560                                                                                                                  W8 Period IeAdditioul CLt.
le 2 I    Spt, FotI Inolsuoo                                                                                                   12.280          1.542'     1.022         11.022 lc 2      Subtotal Petid Ik AdditiuoslCLout                                                                                    10.280           ,542    11.022          I 1.822 P.rted k Coll.teral Lost,
:e.3.1   Pr-ss de.mmwssinionstar wsste                                            71        41s                    386                          247      1.2s3           1283                                                                                                   199 33    Smell
              -   to] .l                                                 4                                                                          3           4               4                                        1,020                                      0],230
:,3 4     Florids LLIRW    Inespetio F.t                                                                                                                       3               3
                                                                                                                     .68 2            24s      1.29.             9                                                                                                     199 1s3      Subtotal PFriudIt L            Lout
                                             -ll1tursI                              71 TLG Se1ices, Inc.

Crystal Rier Unit 3 Nuclear Genermain Plant                                                                                                                                                                                                                        Document P23-1651-001.R.t. 0 PreliminaryDecommiioning Coat Estimate                                                                                                                                                                                                                                   Appendix C, Page 4of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousa.nds   f 2011 d,11a-)
I Off-Sit. LLRW                                                NRC       S-1n              Sit Iue    Pr-ed                 Bur0al -o1.-e             -ri. I                 UIit Y.d I 3tdm                                ...... ...........
De-on Cost Iemotal Cost P-1bagoig Costs Tr.nsport Costs Pcosstg Costs Disposal Costs Otthet Co-Costs Costt Toa l        Total       loTerm.
Co(tt Maoagsent Costs Re.stortioo Co.ss VRolIn C.. Feet Class A C.Feet Class 5 CuFeet Class C C.Feet OTCC C.Feet Poross-d Wt., Lhs.
Cru-Mtanhtoura Contr.ctor Mahouo PttM 1,  t    H drid-OtpeodcotCosts 6,4.1       lotosoc                                                                                                                                   14       370           370 1e.4.2     Procortytotts It 4.3      Hlotth phytt* topplies                                          217                                                                       54        272          272 93 19         P,03 142           142 lo.4.4      HZ- tcotptet t-ot,1 le 4        L5         fpotolof D9W -geort.d                                                          4      3                                                                                                                                                          3 73           5 238 lol4        Pl-t eergybudgt                                                                                                                           39        297          9 97
    -c.4.7    NRCFstt                                                                                                                  194              19        213           213 1c48       Emere-c Plannlng Fee                                                                                                     19%              20        216                        216 lc.4.9      UtilitySile lodi-ot                                                                                                      472                                     542 kl.0       Sp.t Ful PtolO&M                                                                                                         192              29         M.
to 4t1      lSFSlOpertannosCosts                                                                                                                                 2*
1 to.4.t2     Ctro-ts .Slotioos                                                                                                                            54     41 1414 olt13      Stortty Sff Cot                                                                                                       1663              249       h9&#xfd;11                                                                                                                      39.,91 839         43,1        6434                                                                                                       *1 .721 t-.14       UtilityStf r"o"t t.4         Subtotl Petiod 1t Prottd.-ptdeot Costs                          Mi4           1           3                           .120             1.526    12 NoO        11,6,,7          463                                                                  3 073           5       143311 Ic.0        TOTALPERIODt, COST                                     16,      806          74        4.0                  194      21302            3414      26 772                         463                                                                 4,0220      7319 582       146 PERIOD I TOTALS                                                  4.417     2,328        584       IM7,             GI   772      76.397          13811     lM.417         ,7.65.3        2764                     2343    3.226                                .672201     71318        9LO168 PERIOD 2a - SAFSTORDoorancy with WtoSpet Fool SIotos Perod 2o Fh[2rt t D o        iooiog At-io 2a.lI.I     Q ..toly Ittpettioo 2t.13       Prtpatrttrepor 2o14        Rttotuinoooorfreplstometot                                                                                              347               37       2114           134 2t.1.5      Mioao.ntetnc upplim                                                                                                     925                                      843 92       269 206        842 1.127         1 127 2t..        Subtotat Potiot 2oAotivityCosa Piod 2a Collatel Cos..
: 2. 3 I      Sp-nt FoolCapital sd Tsotrr                                                                                          24.400                                                  05w0 2a32        [IFSMlapittl   E-poodotot                                                                                                             0069      67.997                      67997 2o33        Florida LLRW1nsp-t.o. Fto                                                                                                                             2 0
lt 3        Su.Mot P-.ld 2. 'olla tdrlcs                                                                                       09.730           125M9      98.590                      98587 PoeolJ2a. PEiod.Dtpoodot Cos-3508              351      3,859         3 487           372
: 2. 4 2      Prooertytatet                                                                                                         9881              908     10 M9          5 2N           5*2 4.t 3     H-tlth phtsi* sopplios                                         1,005                                                                    251       1,257         1,257 2o44  4     D,--oosalofDAW -- ertd                                                       27          2                                                20        123           123                                          1.110                               23.w08          38 2I 45       Pltt to-ty bodoet                                                                                                     1 025              154      1.171          589           589 20426       NRCF.os                                                                                                               1.102              1t0      :.212         1,212 2a47        mErey Plannin F-                                                                                                      999             too      I1093 2.8  I t~t      I=e[dr-t                                                                                                   1 732             200       h.992          52, 24 9        Spont Fue PloolO&M                                                                                                    1816              573      4.309                         5438
: 2. 110      [SFSIOpertttiCgCt.t                                                                                                     447              07        510 40.
11    tooport .loa t ioot                                                                                                   1389                                       354         1,244
: 2. 4 12     Se 'tryStaff C-t                                                                                                     50743            3561      27.304          5.1,        IS8286                                                                                          555121 2.4 13      SholotyStffloI t                                                                                                       2911                                                 20."I 3327      a'.198                                                                                                                      411929 2s 4        Sobtotal Pettod 23 Period-DopendentCostt                       1005           7          20                   56     Q9553            9 930     80,59t                      13 X6                              1 150                               23,900          38       967.250 2..0        TtITALP0RttD 2. C1OST                                          1.05          2                                5%    156,205          229&#xfd;95     W80308        280335       152273                              1.150                               23.900          38       907250 PERIOD 2b- SAFSPItO)R       Do-maooy itbhDry Spot Fool Storuge Potiod21,Dtro Doootonttt            Attootii 26.1 I      Qoartotrlyo[spoctiooo 2b 1.2      Serti.sooual nrobo eonotoltoooo Tb.]I3      Poeparetrepoot 2h.l.4      Ottotinoustrooftrtltooentt                                                                                            1 711             27        1.947         7.N7 26 1.5      Mlaiottensnosupplits                                                                                                  4.              1, 167     3.035         5 :135 21..I       Subtotal Pottolr2bAotioityCoota*
4370             1.424     7.002         7.80 Peroiod 2b toOllattra/Cotst 2b.3.1      Spent FootCtpiltMatd Trostert                                                                                         48090             721      5.5211 2h632       lISFSIl*.apitoltpendlttoes                                                                                            &#xfd;3.0,             45.      3.45                         3.45
                                                                                                                                                                                            .4520 2b.3.3      FI..tida FF010lospctttoo oet                                                                                                      7I TLG Saniees, Inc.

C"1.ta Rier Unit 3 N-clear Gene. ti                Piant                                                                                                                                                                                              DIocment P23-1651-001,Ret. 0 Preiminaey Decommissioning Cot Estimate                                                                                                                                                                                                                    Appendix C, Page S of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thooaonds of 2011 dollars)
Z..ttoit lode.                           At~itity Description De-on Cost Removat Coo P.oksging Cost.
Transpntt Cost.
P.ssing Co.a Disposat Casts Other Costs Tot-t Contingenoy Total Costs Lit. Term.
Cos Management Costs e.Restoion Costs Voluie C. Feet Class A C. Feet Clh"sB C. Feet Cl... C C.. Fee GTCC C. Feet P eo d Wt., Lbs.
C-st M.nhoou Contrsotnr Mjnhouh I
2b3         Sobtotal P'tol 215  Coll2tbrslCott                                                                             7.807            I,171      8.978               8        8.970 Period2b Ptriod-Deptod-r Costa 2b4.f1      1-sts                                                                                                         22478            2.2N8     24.729        24,132            503 2b 4 2      Proprty tost.                                                                                                 45845            4.585     50.430        36.236          14.t93 2b 4 3      Hsthh phyios spphls                                     3.375                                                                    844       4.219        4219 2b.4.4      Dispose1ofDAW -t-ootttd                                               90           65                   187      -                6&#xfd;         408           408                                      3.824                              76.481        125 Sb4.5       Plt etorgy bodget                                                                                              3546              532       4.778        4,078 2b 4.6      NRCFos.                                                                                                        7.625             792       8.M87        8387 2b 4.7      Em-rgencyP]ot- Fo s                                                                                            6915              692       7,607            -           7.607 2b 48       Ubtty Sit, lodirect                                                                                            5238              784       6,M24        3,37            2.395 2b4.        ISFSIOpsrttng Co.tt                                                                                            3095              464       3.559           -            3.559 2b4.t0      CorportetAltoaos                                                                                               3894              584       4.478        2.449           2.029 2b 4.tt     Se     tfyStaff Cost                                                                                          88783          13.318     102.101        62,402          39.699                                                                                I.lt8,4.01 2b4.12 Ubty StaffCost                                                                                                     6t1M1            9.188      70,438       3W.321          35.117                                                                                1.t51.,51 2b 4        Subtoti Period2bPtrioi-Oependeot Costa                  3.375         w                                 187  20.677          04,27      286.450       181,262         105,194                       3.82M                              79.51         325    3.103126 2b.0        TOTALPERIOD        21bCOOT                              3.375         SO                                187  292.M57         20.663     303.236       189,072         114,164                       3.824                              798.81        32     Sf19 PERIOD t - SAFOTORDormsnoy without Spent Faet Storage Pooa SoDtra-oDooototog              AdUt.to
 '.          Qotrttry Iopsotioo a .] 2      Seri..n..sltoiroo.        talosroy So3.3       Fropoosrtpoot 2o.t.4      Bitumnousroof r-plo--ot I
990             344         784           794 20.1.5      MOf -tooosupphit                                                                                               1,883             471       2,323        2353 2,.1        SubtotolPorod 2oAotivityCosts                                                                                  3.573             574       3.147        3.1M  7 Pertod2SCo.latersl Cott-20.3.1      Florid, LLRW opspetioo      Feo                                                                                    3               0    0      33 2o.3        Sobtotal Poriot 2e Cofltorsl C.,
Period2oPod. DopodettCo.ts 2     1.4.t fosor-                                                                                                         8,849             8M5       9.734         M.734 2o.4.2      Propottytato                                                                                                  13287            1.329      14.616        14.616 2o4.3A       sslth physioaspplies                                                                                                            3W        I'M0          I.MO 2o.4.4      Dipas ofDAWgeotratd                                                   34           24                   70
* 24         152           152                                       1.421                             25.412         46 20.4.5      Plst t..erg bodeto                                                                                             1.430             215       1.645         1365 2a.4.6      NrRCFP                                                                                                         2,787             279       3.099        3095 2.4.7        Wtay Ott Iodtret,                                                                                             1.273             391       1.464         1.464 2     '.4.8 Co-o-ratadl       tlonbos                                                                                       859              32M         903          950 2o4.9       SeoaoityStff Cost                                                                                             21.M07           3.M03     2M,174        25.170                                                                                                  436.929 So4.10      ttlity Staff Cost                                                                                             12,349           1.858      14247         14,247                                                                                                 254.700 2o.4        SObtotalPooiod2, Ptriod-D-ptodentCostt                  I28M          34           24                   70    62,761           8.513     72.681        72.681                                        t.12t                             28.412         46       6913329 1.281         34           24 21.0        TOTALPERIOD        SoCOST                                                                               70    93.337           9.707     75831         75.831                                        1.421                             28.412         46       6919.3-2 PERIOD 2tT~rALS3                                                    5.,1          151         109                  313   484398          68.743     559,376       292,939         2%437                         6.39%                              127.9M        209     4.761,704 PERIOD 3.. llestivste SitelF.nI.ooogOSAPcOR Dorosooy Poriod3. Di-rool                 Atibti&#xfd; A,,Mmossiooiog 3t.3.t      CIropso  po..tti      oory oi~tio gri do-.t          st                                                                          149              22         171           L71                                                                                                    1.377 3s.t.2      Rta so plsot dots & sps.                                                                                        527               79         60%            -0                                                                                                   4.700 3.13        Perfor detaldod todooy 3s.1.4      ERdprodootdotript ioo                                                                                                             17         132           132                                                                                                    iWoo 23.1.5      Detailedby-prodoutionoetoro                                                                                                          S       171           173 0                                                                                                              149 3.i.9       Doino major.ook sntuooo                                                                                                           29         487          487                                                                                                     7.0oo t.t .7      Psrfor SER -d EA                                                                                                 149              53         403          403                                                                                                    3.3IM 3s.3 8      Perofot Sita.Spoflo CostSOtod 3.1.9       Poopattobot Lao Torooo              Pba                                                                                           70         &#xfd;9           539 3.3.I1      ReoeioeNRCspproosiof t               pIS prin.tioo A'dtySped-eUon 3s.3.tf t Ro.sottoataplsnt&tteoporsoyfooliooa                                                                               A44              17          970          873                         97                                                                          7.370 3s.t.t .2 Pltnt"sstso                                                                                                       477               72         549          494                                                                                                    4.167 3t 1.113 Rastori.taro-a&#xfd;                                                                                                    813                2         935          93                                                                                                      7,1W0 TLG So-1ice,       Inc.

Crytal River Unit 3 Nuclear Gene ating Plant                                                                                                                                                                                                                              DIoeent P23-1651-001. Rev. 0 Preliminary Devnmissioning Cost FRttate                                                                                                                                                                                                                                           Appendix C, Page of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thoussnds of 2011 dollars) tn... ....   .....                                                       .   ..        to....
                                                                                                                                                                                                     .                       A.           .. .. ......                    ..
Aotiv 'itv                                                   Dnvxn  Re mottvsl r v ksgtng  Tvsn spxrt Pvxv   ing       Dlspxss l     Othee     To tls       Tot l    Li Te
: e. rtx. M axsget e nt 5e-t   restloe   Volo me Cl ass A   Clsss a            'lassC  C GTCC Pvo xssed        C rsfD        svtxe r C ent led es                           Avitity    Desl ripti on C.o st Cost         Coets       C ostt     Costs           Costs       Costs    C onti ngenoy  Cosa       Cots        Cost s       Costs        C . F et  C u.
Ftt   C.. F et       C.. Feet   C . Fee Wt., Lbs.. Ml nhto urs M .nh o urs Ativity Spedf1iotlos (Onxliuxd) 3a.l.l1.4 Ret-o nsse]                                                                                                                   744            112      856         856
: 3. 1115S Soaloevolsbield 57 3a.l.l 1.6 Sos., gtxteroato                                                                                                            337              54      111         411 3a 11.7      Moloford- d     ot                                                                                                         183             27      211         105 3a.l.l1.8  Maix Ttbin.                                                                                                                   46                                                              53 3s.l.ll.S  Maio Cx do._e                                                                                                                 46&#xfd;                     53                                      53 3.1.11.10  Pl'lte        -troto & bSoidiogs                                                                                            357                                                             2O                                                                                          3.12o 3a.I.Il.Il W~t~elavatgtvoent                                                                                                           527               7      606         Goo
* 4.600
: 3. 1 11.12wFdhty& stedcout                                                                                                                              15     118          59                          59 4,55w            61i3   5.23        4,609                        627
: 3. 1 11    TotI                                                                                                                                                                                                                                                                                   "9.777 Planoog & Site Poep=stiot 3.1.12      Preparedisxttxioesevuen                                                                                                    275              41      316         316                                                                                                                    2400 3a.113      Planoprep &oopxsve                                                                                                        2.800            4_20   3.210       3.2-20 3a. 14      De o atorvl*.upestlm
                       -rn                                                                                                               10              24      is,         184 3e.1.15    Rigglg/Con. Col Enalpvtloxltoleto                                                                                          2.2o)            330    2.530       2.530 3.1 16     Prxt-k.4.-koers & -xt-ie-                                                                                                    141             21      162         162                                                                                                                     1,230 3..1       Sobtota Period3. Aciity Cott                                                                                              13.322          1998     15.321     1169'                         627,                                                                                       72 7W Ptriod 3, Adduoo...lCott 3t2.1      Sit Ch-txeoielxon Sovey                                                                                                    2.771            831    3.602       3.602                                                                                                       19.100       7,852 3a.2       Sobtotal Ptriod 3. AdditioxalCots                                                                                          2.771            .31    3,602       3.602                                                                                                       19.100       7.852 Petitd 3UC.llstersl Cott 3:.3 I     Flotd L W Ilpeotio F.t                                                                                                               I0                 I 3s.3       Sobtotal Period3e Collaterl Cots Perod 3 Period.Depxd.t Coe-3.4 1       lxeosxron                                                                                                                  934              03    1.0-5       1,705 3o.0.2     Propt~ly tates                                                                                                              930 3e.4 3      Ieltth 1 ph         ti vvppht-                                438                                                                            Ito      "I3         54 3t.4.4      Ilxy tqolpmo t tentsl                                       49o                                                                             73      563         602 3.4 5      Dsposal o D- W gdenert-d D                                                                            12                                    25                         9       55          55                                                                                        to 2ft.'17 3a.4 6     Plattene-        budgel                                                                                                    1.025            154     1.179      1.179 3,.47       NRCF-, t                                                                                                                   272              27      299         2-9 3a.4 8     Uoliey S.. Ildi-et                                                                                                         1,215            182    1,397       1,397 33.4.9      C--otto All-,...s                                                                                                          872             131    1W63        1.0Z3 3S.4 IS    Sevoity Staff cxt                                                                                                          2.919            435    3357        3.357                                                                                                                   G5,900 3atl1      UtilibtySff Co-t                                                                                                          13.6M5          2.044   15Go        15.669                                                                                                                  2.5.629 25     21.513                                                                                 514                                        102117             17     3M807 3,.1        SobtotalPeti)d 3. Ptriod.LDpeodet Cot.                      920             12                                                           3.326   25813       2.033 3.0        TOTALPERIOD          3a COST                                 9M8             12                                    25     37608           6.156    14.737     41110                               627,           514                                        10.2117        19.117     404362 PERIOD 8b - Deeomlsion-g Prepration Peritd 3b [orv Doxoioiooite           AL-i-ilid DetailedWorkProctd-3b.l.:.I   PlIteeotexo                                                                                                                 362              81      6M3         561 3b.1.1.2 Retctor iateelo                                                                                                                                43      3_29        3N                                                                                                                     2.500 155 3b.lI 3 Pe-siixaboildite,                                                                                                                                       178          44 3b.I.14    CRD       1itg -sembly                                                                                                       114             02      132         132                                                                                                                     1000 3b.1.1.5 CRDhlooix & ICI          tobs                                                                                                                            32         32                                                                                                                     I.000 3b.1.16     lovoreiotldmettai                                                                                                                           17      132         132                                                                                                                     I.000 3b.1.1.7 I        lettolr -.- I                                                                                                             416                                                                                                                                                         3.430 3I..1.8 IS   Fality        -l.ote                                                                                                         137             27                                                                                                                                          1,200 3b.1.1.9 M1issilextbields                                                                                                                12                      59         I59                                                                                                                      450 35.1.1.10 Siologixal    shield                                                                                                                                  158          M5 3b.1.1.11 Steto genxertots 27       306        606                                                                                                                     IO-3b.1.1.12 Rootrorctdtnxos ,                                                                                                                             17                                                                                                                                          1560&#xfd;
                                                                                                                                         '79                     V05 3b.1.1.13 Wmin    Torbine                                                                                                                               27                                                                                                                                           1w5*
3b51.1.14Matin(otd~oeser                                                                                                                179                     20, 47                                               23 3b1.1.15 Ao-liry boodh.g                                                                                                               313                                                                                                                                                         273M 47                                             133 3b.1.1.16Ieator. boildiog                                                                                                              313                     0.24       3.00 2.730 547 3b 1.1     TolaI                                                                                                                      3.601                                                                                                                                                       32243 4.214 3b1        Sobooal Priod A3Aerily C-.to                                                                                               3.691           554                 3,421                                                                                                                   32Z43 TLG Serices, Ic.

C091tal RiUer Uit 3 Neleor Ge                 ting Plant                                                                                                                                                                                                                         D-o.      .eneP23-1651-001,Rev. 0 Peliminae7 De...iyioing                  Coat timsate                                                                                                                                                                                                                                  Appendio C, Page 7 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousaands of2011 dollars)
Indez                   ~A&#xfd;li-y D-serptor.H D-.ve Cost RemovsI C
Psokaging Coss Tra. spora Coats P=so ot.
s i
I;g
                                                                                                                         .T02t50LK Dispoal Costs t1hter Cost.
Total Cotngrvy TotlI Costs 0002 LIe.T Coats openota*el Mr.. 8aoaget Coot.
eno tote Re-.ora.io.
Co.-
Yroveslra Voluee C.. Feet Class A C. Feet teurtat olumes Class Co. Fe ClasaC C. F-t OTCC C. Fet eaurial Pro.-s.sd Wat.,Lb.
Crate Macboors
                                                                                                                                                                                                                                                                                           .. ho.l-banoapa Utlt Co ntraot r o
I Period3bColtterl Cott 1b.3.
1    D-oo oqip"eot                                   964
* 145         ill0       IH09 3b.3.2       DOC   staff roi-U.tioo aaseooa                                                                                            1,58            ill      1.416          1446 lb.33      Cpaetbog   "    iolpmt                                                                                                                    165      1.265          1265 2b.3.1     FloridaLLRWio-evtio Pso                                   LIN110                                                              18              0          1           1 3b 3         Sobtotl Piod 31b    Collaoal Coot                                                                                        1,7,8            498      3.821         3821 Period3b Period-Dopeoderl     Cot.
3b.4.1       D-oo s-pp ia                                      3w                                                                                          7        37          317 3b.4.3       PropatiytW..                                                                                                                                48       531           531 3b.4 4       H thhpvh,.. ovpplii                                         245                                                                             61       3M6           30N 3b.4.5       Heyquipmeot...ntaW                                                                                                                          37       285           215 3b.4s        Dopooi of DAWgeerated                                                                                            14                                    31 3            '1                                                                                             5.898               10 3b.1.7       Plot energy bodgot                                                                                                         519              7.       597           597 3b.4.8       NRC Peeso                                                                                                                                    11      152           152 3b.4I        UtOhtyS-t. id-ooo*t                                                                                                                         92       7W00          708 616 3b.4.10      Corpotet Allotios                                                                                                          442 3b.4.ii      SecueityStaff Cot                                                                                                        1.480            222      1.702         1.702                                                                                                                         33036 3b4 12       DOC'SffCot                                                                                                               5049             757      5800          5.800                                                                                                                         59.2.
3b.4.13      Utility Stall Co-t                                                                                                                       1.136     7842          7,942                                                                                                                        131.086 3b.1         Sobtot] Period 3bPoel.Dvepodoet Coat.             3.        493             7            5                       14     15.988           1.40         N8.998    18.M8                                                    29%                                       5898                10     22I3.31 3b.0         TOTALPERIOD        SbCOST                       994       1,593                          5                       14     20937            3.512    27063         26.240                                                   295                                       5.898               10    753564 PERIOD83    TOTALS                                         994       2,521            19           14                       40     58545            9.668    71 801        70.350                          823                      809                                      16.185          19.126      659.936 PER10D 4. - LarIe Co-tpoaen Re-ota.
Patiod 4laDire- Dloeomieioniog Alivil No-iest Swtea SopplySy-tet Roetoos 4a.1.i.i1oactor       Coolant Ppiog                                                                              126                                   1IN        580                                                    5G4          597                                          W13787       2771 20         97            27          24                       17S                                                580
                                                                          .22            4            4                                                  I5         86           80 is .1.2 Presst..ee RilMf Tk                                                                                     21          27                                                                                           9-           94                                     20.849             310 4s.i.i.3     Roector Colat Coops& MSttrs                       22         74            47          3                                                  669      2947          2,947                                                 7.016                                   1,122318            2755             80 ls.iAi.1 Pseteiror                                                      52           412         162                                                 209      1 649         1."49                                                 2 Q24                                     353593            ].19          1.700 4a.i.i.5     Sloes C~earstors                                  36      4,703         1.072       2.M4                       S831                                                                                                   23.908         .1,92,167                                    10,251         2750 3,355    18301         [8.304 is.1.1.A   Ret-redS. t ooratr oiUt.                        .                       1072        2.3M            -         6.831                      2,164    17.392        12.392                                                2%. .98                                  ] 889 1W7           5 10          2.250 is.i.i.7   CRDNbleC]ieier       oSt-_uoo Re.otou             29         80           312          71            56           3                       122        553           853                                      753        M.100                                      91.378           2371 I4a .8       R-ottor Vassel loternsi                           36      2316         12,373         470                     2.114        182           6045     03525         0.52                                                   1.32  9        5         01               217.620          18.750          982 Ia.i.l1.S  CesoI& Ioteroale GTCCLMsptei                                                                             -                               1.180     9,049         %.019                                                    -.                           2112     423,                  *5 7.80W
: 4. i 1.10   R-actor Vessel                                  -         5341          1.158                       -         2.1617       182          5.515     111718        14,718                                      -          9.626                    -        -       9 978.700          18.750          882 4a.i.I      Totas                                           157      12.688        1G,376       6.137          004       28.20         364         19,346     84.184        81.181                                    1.411       72.327         2)         w51    2 142  0.697.382           62,933         7.841 Ro-votalofMj-orEquiptoso 4a.1.2      MSi TtrbtooG        -eoeatar                                244           101          26          521                                    161      1.133         1,133                                    2.931                                                  257.966           6.378 4a. 1.3     Ma.inCoodensers                                             77,1          128           M          493                                    284      1.7N0         1.704                                    5.419                                                  2M.3865          17.298 Caaodioa Co flet CleIo BuildiogDeoltt.on 4:.1.4.1 Rea-t                                                          69w                                                                           104        790           7N4                                                                                                             8.169 Ia.l.4 2 Aueislr Boddog                                                 170                                                                                                                                                                                                           -        2.063 26      121           124 4a. 1.4.3 PosI,     odliogArea lA.o B1da                                108                                                                                                                                                                                                                    1.252 4a. 1.4.4 lotretodieat Bhle                                              4G                                                                               7        5w 1          4                                                                                                                           557 4a.I.4. M-hioe Shlop.Hot                                               3                                                                                                      4 4.i .46     RMWehaoous                                                      I                                                                                        1            1 0
4a. 1.4     T te.
l                                                     1.1120                                                                          153      1.173         1.153                                                                                                            12.121 Disposalof Pivt Sotao 4a.I.5.1 A.az-er Sbras                                            -      53                                                                               3        61          -
* 1391 31                                      13        76           76                 -          1         -7           -                                        1525M              6M5 4a. 1.52 Ateiiaey Stao - RCA                                                                         2 4a.l1.53 Cbreleal Addtuoon.Coot                                                                                                                         22                                                                 ,59 56                                      49                                              130           130                                                                                            24.217           1.127 4a.1.S C         -ealdddition.
1            Cent.-slated                                                                                                              3       17           12 61                                                   2.461             159 4: 1.55 Cboolti-oAd-ditio- [estdd - RCA 4a 1.50 ChemikalAddtiOo - RCA                                            41 0            3           51                                     21 3
12' 15           15 12&#xfd; 61                                                   2.401 26.704 12, 903 4a.1.5 7 Cheiool evi Srtondoy *Cd.                                                                                54                                                                                                     "14                                                                     331 4a.1.58      ie        FeedlSoodeyoCyIe-oRCA F.ieol                                            I12                         0                                                                   13      13                                                                                            2.0.7             107 "68
* 4.1.5 9 ChdAed      Watr                                                                                                                                                                                                                                                                        .520 61.
55                                     n        1.4           18
                                                                                                                                                                                                                 -      62 4a.1.5I0 Chiod Wtr          - RCA                                                                                                                                                                                                                                            27.273            1,229 4.1.5.11 Croltiaig Wa.st                                                                                                                                 14      104                                        104                                                                  S -           2318 TLG Set-iva, I-a.

Cryatal Rite Unit 3 Nuclear Generting Plant                                                                                                                                                                                                                       Doument P23-1651-001, Rev. 0 PrIiminat Deeomtitioning Cast                     timate                                                                                                                                                                                                                Appendix C, Page 8 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of2011 dollars) lo.de I=:~. Atity     Desiption De-n C
Remos-l    Packaging Cost CoCts Tranapor Coats Presaiog Coats Disposi Coats uthber Cost.
Tull Contlngeno' Total Costa Lie, Teem.
Custs Managemeot Coats Restoratiou Coats Volome Cu. et Class A Cu.Fe Cl... B CuFeet Class C Cu.Fet GTCC Cu. Feet I7d' Proeeed Wt.. Lbs.
Crsft nhours Contractor Mnlhours Duapinlsof PIvot Sstu.s lmoned) 4a.l.5.l2 CoodiDemnR bonorall          to                            43                                                                                                                              49                                                                       1.049 1          49 "t 15 1 C.odootso                                                   1w9 4         127             -                                                                                                    2868 40.l.5li     Coondesloe&I    De.lnWta Supply                                                                                                                                                         27 t 1.515   Codtostu& Oool W.sltoeruply -Coo                                                   2           40                                 2         127             127                                                                                   19.101         1,284 4a.1.5 t-    Conde1ta & SIolnWatr, Supply.-RCA                                                              72                                35         205            205                                      875                                          35538           1.773 4t.l.5.l7    Coodensate-Cent                                        161                                   2.5"                                    3      528            5.                               -     3.m6                                          131.415          3.586 4s IS5IS     Codoioatsl Detinort.1zor                                94                                                                       14         108
* 108 1.tI5 19 CondtouseDeolnertlioro-Cenl                                              3             7         132                                 55         3&0            330                                                                                   65131           2.800 IM is15SO Coodouse AleRemoval&Pr'.-o                                 *o                                                                       14         1014 4s 1521 I                    Do kyloMsketp  Wltor                                                                                                                                                                                                -                                    1 *472 4a.l.522     Cyle MokeupDe-n Wte. RCA                                                          2            12                                                                                            134                                                 29841           1.125 it     523   C.7lASttop                                                8                                                                       1          2o io.1.524      ylt S-ortp. RCA                                                                  2            35 68 51                                                  L7,515           101 211                                                                                      8 i45 25       F',-] Jsckot CI] t                                                                                                               I4 1          2 438 4S 95    2o  0,ool-AIr         CleClst                                24                                                                                                                                                                                                         los Io.1.527     RRAPFO&C resead .r&Eohousl                              42                                                                        I 1            S5 45 4i 1528 ED3 jLhn.1i                                                                                                                                                                                                                                                             .1028 I
4I.l.529 REFPS      C3opreuad sodSlteoouno,                          ]I                                                                        2           12                                         12 4a .5.30 EP.3 Fool0,1Trer                                                                                                                      7           19                                         19 4I 15.3 EPB  R      Sop Diaehaoe                                                                                                                                                                      w it 1.5.32 E_,ere::y F-odoer,                                         69 4 Is.        R5Eerenocy     todwato,.RCA                            121                                                                       52         32              32o                                   1,640 4t.1.5 Ni Etjacon Soe,                                              113                                                                       17 a .535 FWHote R'eIhdVent& Drais                                     46                                                                        7         I3 53                                                                                                                       21.2 13          860              8 53 Ia 536 FWH       Rater  -Rlier Va-a&    aDs-t   -Coot                                                                                         19         107            3158                                                            -1
                                                                                                                                                                                                                                          - -         -           481 N-          1.187 1.222 4a 15.37 Fodnlator                                                                                                                            13                                                                223*                                                          2.106 l.5.38 Feolwater - Inslad                                                                                                                   7          291 152 4i 539 Fondwo                    1r.Ioooattd
* RCA                                              4      o          18                                  54         353               5                                     572                                          9331M9          1,964 IsIi 4 Fon-wat ,RCA                                                                   1     2            47                                13                                                                                                              - 3.243           453 26                                         19                                                                          40*
4a..5.41 HVAC.MmOutbtdi                                              15                                                                        2           19              86 4: 1 512 LP & HP F&#xfd;onwar Draisa & V.o                                                                                                         129        219             ,                          219                                                            S5.018 Ia.I.5.13 LP & HP F&#xfd;eloso Dsa & VVnt - Cent                                                    10         192                                 83         478            498                                    2m46                                           95.269          4.,14 4e.1.i.44 LUqd Sampliog.Coot                                                                        t       26                                2m         112             112                                     313                                           12.721         1.396 517 4s 15I5,       L4qAdSomolog- RCA                                    194 1       28                                18         102             102                                                                                   13.,5.         1.10o 4a.I SIR6Lola 0,I                                                                                                                                   2       2I                                        12 4a.1547 Malt & RoheatS-am                                           209                                                                       13           %6
                                                                                                                                             ,135       2.98l          2981 96   22779 4a.1.5." Memn      & Rehot Soe,. Coot                                                                                                                                                                                                  -   -                 9m2.077         1I.999 4a.I 5.19 Mlin & Rohot Soe-. RCA                                                         0      1           19                                 1          40o              40                                    226                                            9.182           27 4:.I 5.50 Uis,ToebtnaRlomSta* ralm                                                                                                                                                                        54   1,405                                               -          1.332
: 4. 1 5.51 MIss7oebt.,b R o S.e. Drsim Coot                                        2                         1                                 67         MI3             Ml                                                                                   57.049          2,735 46 Ia.l 5.52 Niitrounulydromen]Caroot Diotlda                                                                                                     t          30                                                                                                                    736 4 .1.5.53 No-Soc& Dm RHust             Sa Wata.                                                                                                7           M3                                                                                                     -           1.172 I:.1 5.5 N-oSo & DRoy ttt St Wtr *.Cent                             B34                                  3W7                                             459 4              459                                                                                  151890           1.438 Is.1.5.55 NSeSe- & D., HRatSnaWa.r -RCA                                           46           16                                             wo         340            340                                                                                  - 101697         1.45 In.1.5.56 RC & Ma_ Waat Es poraor                                     46         20                        25 498        -                        IN(       1.176           1.176                                   6,075       w6                                275.377          7.952 1
4a.I.5.57 RC& Mesa&#xfd; e E--          aorotor.       ala-                                                                                        1Is         8                84                                     62       92                                  -1.030           633 Is.1.5.58 SormnW'ah W-at,                                            7*                                                                            S      47 1989 4a.I..       SeI & Spray Wate Is. .5.      Se"l &SprayWlte        Coot                                                                                                       IM        202            202                                                                                   33.041          1.877 4I.I5.       Soul& Sp'ay WRuer,RCA                                                                                                            29         174             174                                     7.3                                          31,81           1,379 is.I-S.
Is-I.S       seoodoyCdSsels 63 Sseooaey     CycAe Saooclio -oo                                                                                                                                                                                                                                     622 4:.1.5 63i eodery Cycle        9    liot - CeOt                                                                                                     3       7               17                                                                                  2.419            IG9 1       6                6                                                                                   810              57 Is-I. 65 SA              CAt Samplie roiy                 [nased In                         44                     276 I       7 4a.1.S.66    S ondtrySort Clos.dCyoleColiog                                       19                                                          -*         219                                                                                                                  4.978 4.1.5 67     Tob BidgSu        & Odly  Water Sopastoo               21n                                                                            3      22                                                                                                                    491 Os.1.5   68  T b-o GeneratlorSe (Oil                                                                                                           3          26 it.IS59      Toboe Clod St-a & Draies                                                                                                                                                                17           26       3 4-.1 M   7   T~bl- Lub.&#xa2;]                                          5.19
* 1.107 lb1.7 1 Waste Drumln                                                                                   2          9                                  3I               35                                                                                   4.667           268 4.1.5 72     W-soes   .,spos-    l                                                                                                           127         736            736                              -     2374      481                                 138.892          5321 40.1.5       Total                                                              124                    4.787        213                    1 889      1236            M0,in                      2.1IM        58,350     980                               2 452.901        113,990 4s-IA        Scsfildioe t aspportofdoeooooeioniot                  784                         5            71         5                    211        1 097          1.097 2130 4.It         SobIetsl PCoild4i AelotpyCost-                  57  20518                     6.,,19      6.076     29.138       361         22915      101.597         99.413                      2.191        68896    73,391      no      501     2.142  9.691.321        233907            7.811 TLG Sen-,ee         I.
1,

C(ntal Riter Unit 3 Nulear tenettng Plant                                                                                                                                                                                                                                      Document P23-1651-001, R-y. 0 Prlininoey Derontaloning Con Ptitnate                                                                                                                                                                                                                                                Appendix C, Page 9 f 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thouaands of 2011 dollars)
I=...       ..                                               .t.             peotae Site                       a.
ae                         .1     .....                ma                    I Utiles A"at"                                                   Decono   eoant Reol        Pahkaging   Transport  Pressieg    Disposal     Other      Total        Total      be. Term.      Maoagen.et Restoration    ooete      Cas. A    Class B      Cl... C      GTCC
                                                                                                                                                                                                                                                                  ?     P.-d           Craft       Cootraetnr niea                         Aotylnt Desripttion          Coat     Co.t        Cott        Costs      Coats      Cost.       Coats   Cootineno       Coat.       Cost.              Coat. Cotta       Co. Free    Cu. Feet  Cu. Feet     Cu. Feet    Ca. Feat  Wt., Lb.. M.nhotu,. M.anhno poriod a.Addilootl Costs 4:.2.1      RVCHSegmentationed Dispotal                                                                                                              255       1.562         1.565                                            2.,78                                       308.9(3        2.092           2.000 4.22       OTSCHot Itoa                                                                  158         '9' 41                                            217       1.102         1.102                                            2 940                                        172.000           -
4a.2        SobtototPeriod4t AdditionalCosta                                              158        M5                    1.,493                    471       2.667         2.667                                            54118                                       48t,903        2.092           2M00 Period to Coltateal Co-ta 4a.3.1      Pr    tsdeommtinoing eat-rwasta                          3                      4          n                      21                       t          01 3             63                                              5*                                          3,379 1t 3t3      Sahol      ai]
loHsn                                                194                                                                     29         223             M-                       22 4t.3.4      FloridaLLRWinspeoionFaa                                                                                                    315            32         347           347 4          23                     21       315            71         032           ti10                       22                     56 Ia3         Subotal Prod 4a CoIatoral Cos-Periodo.      in-Detndot C.-oa 4a.4.1      1t*n oopplioa                                           G5                                                                                 16         01             81 773            77         850           850 4t.4 3     PMropotyon                                                                                                                                105      1.154         1039                         115 4a.4.4     Heialhphyea arpphlm                                             1,640                                                                    410       2.050         2050 4i.4.5      H11v euipment rental                                            2346                                                                     352       2.618         2690 4.4.6       DsoposalofDAWgtnerated                                                         82          59                    171                      60         372           372                                                                                                          -14 4-.l.7      Fi. t energybudgt                                                                                                        1.072            11       1.233         1233 4a.l4.      NRCFaet                                                                                                                                   75         869           869 ta.4.t      Uity Sito [ndoet                                                                                              *1.347                    202       1,550         1,550 4t It0      UiqoidRednwata    Ptroting Uqotpmtonitroires                                                                               427            se         49!           491 "a..11t     Corpotamt  Aultat ient                                                                                                     96S           145       1.113         1.113 t 4At2    SoeootyStaffCot                                                                                                          3.215           482       3.698         3998                                                                                                                       71.7186 4a.l.t3     DO StaffCot                                                                                                             12.969          Lots5     14.914        14,914                                                                                                                     M58,03 a.4.14    UtilityStattCost                                                                                                        15.096          2264      171361        17.361                                                                                                           -         287.143 4, 4        Sobtotat Feod 4a Porind.Dtpendent(otto                  65      3.987          82          59                    171    37.707          6364      48.435            i8.319                    115                 3.4U3       -9,-6                               .67           114       517.431 tat.        TOTALPERIOD       ts COST                              226    24,698       17.075       71096       6.076       ev 304       33,387        28.%1      153.331      151.009                       2.32!     60.896    82.352       2D             5so1     2 142  10.215270      236.121        527.275 PERIOD4b - Sitoleroteiostto Period4b Sint DDtomtiaioning AtiitiM 4b t.t      Romoetspent ftol tsd.o                                                                                                                                                                                                                                        2N0.532           989 Disp 1 ofFItot Sotto 4b.t 1.4    dG Dittol Son.                                                     16                                                                        2        18                                                                                                                        36 12                                   8         43             43 ib.t 22     ChoemlZClteningStoemn -oCent                                                    0                                                                                                                        151                                                     6.144 4b.t.2 3    ChonoaoCteaoingStem    -     - RCA                                 21           0                      15                                    4        45             45                                                                                          7642           399 4i.1 2.4 Cnntaineet Mooitring                                                                                                                          18        103           103                                  351                                                     14.268       1.o68 lb t 2.1 Cott Flooding                                                                                            113                                 40         250           25                                  1,373                                                    55,7.43 3.-
710        -o        -                                                                                                                                  351.3011       4,555 4b. 2t6 DReayHSat Cosed (NA.             hmgn                                311                                                                     191       1.261         .26!                                  8.651 4bhi2       Deay Hot R--mo]al                                                  07                                                                     M31      1.141         1.441                                 7.317        98                                        3801.145       6.106 4b1 I       D-ee Ful oIhilTanta-USTSs                                          22                                                                          3      25           -                                                                                                           493 Sb.12.S DeomoticeWater                                                                                                                                  6         42            -
37                                                                                                                         42 4b 1t2      DI -6eatiW--ator.RCA                                               61                                                                     13         119           129                                  5*                                                      21.339 4bl 2.I
       ' II        iM=. C"e"                                                                                                                           82          w3                                     63()                                                                           13208 4b.! it12 E] rln.1-Contoodnttd                                                                                                                       183       1.073         1.073                                 1.3941                                                  178.159      10259 4b.! 2 13 Ele.t.l - Dtoontim-natod                                          3.5,18         69                                                       4.433      8.614        8.644                                  1.69         -                                        1.693.,54      U3.485 4b.1.2 14 F-r Srvi*t /a*t                                                    271                                                                      41         312            -                        312                                                                             6.727 4b.! 145 FirSe&m     4iWetot - RCA                                           497           12                                                        218       1.340         1.34L                                 7.126                                                  289.375        9.742 4b.1.2 6 Fl*r & EqoipD[aa - Ado& Rte- Bldg                                   1 7                       32         214       14                       257         604           049 603                                 2.614        604                                        162.020       3.472 209                                 342                                 &#xfd;II         491                                               4,174 tb.1.2.17 HVAC     -xAoiary Bldg                                                                       17                                                                                                                                                                  169.50W       4.279 4b 1 2 t8 HSAG. Clon MaeoinoShop                                                                                                                                                                           9 th.1.2 S SVAG-Coononi       Conli                                                                                                                       6         44                                      41                                                                                  14 9168 4b 1 2 20 HVAC.-     D-ai NonRBld ob1.221 HVAC       - Fio Pmp H.oos                                                                                                                                                                         3                                                                                  72 fl.        5433          '43                                                                                          12l 88             476 ob.! 222 HVAC      - FoelHandJlingDre                                                       5          13         216                                                                                                                                                                    3690 4b 1 223 HVAC      - Hot thtint Shop                                           33 I           2          12                                  13         93             M3                                                                                         2o.735           662 oh.! 224 HVAC      .nt=tBnoditt Hid,                                           63           ,t          8         148                                 39         262           No0                                 1,799                                                    73,076       1291 4b.! 225 HVAC      - Maintnene Soppot                                                                                                                   5I        36 s            -                          7                                                                                 162 4b.1.226 HVAC      - CC-lioBld,                                                                                                                                                                            8                                                                                 176 7,751                                                  314 7.0 4b.1.227 HVAC-R-a1to Bldg                                                    lt9           12                    634                                 199       [271          1 271                                                                                                        7743 4b.: 228 HVAG.TorbmeBlde                                                                                                                                                                                 1&#xfd;5                                                                             3059 4b l2.29 [MIIn&#xfd;' _ aln                                                                                  3          64                                                                                                                                                                    1J883 I                                                                                                                       740                                                     30.061 4b.t 2.32 Indostoal CoI:i Watnt                                                31                                                                                                                         36 4                                                           s8       472           472 73 4b 1231 IndotiaG       Colot Watte. RCA                                        M9                                                                                                                                  Z320                                                     91.222 bb.1.2.32 Inttroent &USttiotSeAo"elit                                                                                                                                                                   so 4b t233 Iostrment&                      AtattonSornimoir-Cn-1                              2                                                         53         3O5           305                                 1 160                                                    47.115       3 121 TLG Senipea, In.

Crystal River Unit 3 N-.lear Generating Plant                                                                                                                                                                                                                                                                      Dacsnent P23-1651-001,Ret'. 0 PreliminaryDermolslonlng                 Cost Estimate                                                                                                                                                                                                                                                                  Appsndix C, Page 10 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2011 dollar-)
Artiit                              -    -y...........   ..-..-..
De -on C......-[
R o vaos l   Pslksglog T r-n pore
                                                                                                                    -      P r=o i.ng    Dlspo sI Othse C....
Tosli Tosl       L,   ;el T s. M - ,ogo mes t   R o srtoioo  Vola. s C...-.......
CIl.s A C lasts C lsssC C.u........
GTCC Ptot ss d C raf Co ntra tors Dsposlotr Plnts tsty-       (-..t.o.dt 4b.1.2.34 Instrt1ooo & Sttion Seroto At, - RCA                                             271                                                                                      94            5.12           542                                  2.012                                                      81.728            5162 3            0            659          -
4b ' 2.35 Lst. RFt=Toot.C-ot                                                                                                                                                        31            178            178                                                                                             29.355             1,775 4b 1.2.36 Loakl.ateTst -RCA                                                                                    S       4            78                                              32            192            192                                      945                                                    30.385             I1 4b , 2.37 Lqttd Ws.- Dtspos                                                                827                                                                                    3M4            .998          1.998                                  3.528        1675                                        - 963566 2                  17.036
: b. 1.2.38 Makelp & Pootfiltion                                                            570            7           18          357                                               M06        1,152            1.152                                 4.355                                                    176876             11.685 4b.1.2.39 Mabkep & PAfrioftioo- tosatetd                                                    144           2            4            77                                              48            274            274                                      941                                                    38.212             2994 4b I 2.40 Nit-o-/o0-.doro/C.arbon Doode - Coot                                                            0            0            12                                               7              12            12                                      148                                                     6028                419 4b.1.2.41 Nittroso/Hydrooeo/CarbooDiowmds.              RCA                                 80                                                                                                                                                            A44                                                    26.153             1402 tb 1.2.t2 Nob!eGsaEflloot Mtonittoring
* Ceot                                                                                                                                                                                                      152
                                                                                   -        277                                                                                                                                                                                                                   6,172               3M9 4b I 2.43 Nob's tas Efllent onloMtonn.
* RCA                                                       0            I             4                                               6             3M             32                                      152                                                     6,172 4b.I.2.44 N-v S- Cloed C.de Cobg - C-ot                                                                   0          526         .0              -0                               302          2069            2.049                                 12.315                                                   -500136             13.503 4b.1.2.45 Not Sor Clood Cyle Coltog -RCA                                                                 26          65                                                           3N6 1,281                                                         2284            2.284                                 15.611                                                    6,33.9M3           11.323 4b.l.246 PASSCootsto= Moobltornog              - Coot                                                     3                           4                                                                                                                     14                                                    1777                147 4b.t.2.47 PASSCoott         ent Mooniwtg - RCA                                                             -           3            79           -                                                                                                                                                                5 207               3W6 16 27           30 4b.! 2.00 Post A-&#xfd;doot Sa pitog - Cot                                                                     0            0              2                                              Io            57             57                                                                                              8 339               57.9 4b.1.2.29 P.st Aoldoot d-Saphog          - RCA                                                               o            1            19                                                             5 ZO             5.1                                     237                                                     - 629               560 4b.t.2 0 Po.t A=otdoot    Ventog - Cot                                                                     I           2            34                                                                                                                    411                                                    16,678               680 4b.t.231 Post Aodoot Vontng - RCA                                                           '12           11           1                                                                                                                                                                                          6 581               24 2            4            13, 79 38 4b.I.0.32 RB PF.ett-o Coliog - RCA                                                                                                                                                   5 45          3332            2233                                                                                             S 3.005            2,178
                                                                                             '4 4b.t.2.53 RCP LobsOd  0 t-Cot                                                                                  0                      5o                                             2 06           387                                                                                                             2,361                85 11             302                                                                                              2361                 15 4b.l.2 54 RCP L*bs        - RCA                                                               3                                                                                                   122              10 142 4b.t1.2.96RadaosstDoottosrstttsr                                                                          2            3            [5             1 4b.! 236 RsoBttdtPtos*utSeoiog&Tsst                                                                                                                                                                                                                       177          54                                        12,173               M.
lb.! 257 Rnt 2ld Pressre           .S.sig & Tt - RCA                                                                                                                                 13            13             73                                                                                             - 11.906             673 4      12                                                              2                                                      S-       2.75 4b.1.2.58 Reato.rBilding Spray                                                             129
* 13                                                                                                         S 111.740            4.454 2In
* 4l. 2.59 Rofslting Eqttp..nt                                                                                   7      14          116             54 1.412        230                                          78.597             3.003 4b.I.2.60 Sewsae                                                                                                                                                                                                                             13           -          .                                                                M22 4II           w*         61           3232M lb.! 261 Speot FoI'Cloo7tot                                                                                                                                                       13           0.6               7.38                                 3.930         985                                        251.108            10,0!)
lb.! 2.62-Wste GAsSstorhbo                                                                  62                 1       2            M                                               71            122            122.                                     443                                                     a8005             1.190 4b.! 2 63 Wst Layp/N2 Blatkotiog                                                                                                                                                                                                                                                                                                      112 4b.! 24    W4t     opoN2Bt-k..., - Coos                                                       7I          0            0              3                                                                                                                    '40                                                    1.626               132 4b I 265 Wet LbptN2 Blsnkobog - RCA                                                                                                                                                   1              7              7                                       24       -
4b, 2      Totals                                                                     12573             359          S!        U M21           1o67                             5 2714             719            "19 32 ,254                                     136      148.708         4.530                                    - 15,713 6              257.974 n0.8 8 '
4b 13      S-Mitdtogtosopport ofNd.--.sso                 g                             1 176            31            a          1M7                7                            316          1,&#xfd;4o           16ot6                                                                                             U8817           33321 1.,-176       131 Do~tooooooottoo   o!Suto Bottdtogs 4b 14I      Ro.tr                                                                                        31                       186          1080                                       968    ,1*I          4.161                                               9.759                                       8M2S28            32    10 897             M8                                                                                                                                                        2.269 2b.t.4.2   AuoioAsoBilding                                                  308                                     W.              41            55                              206             757            757 IM0                                                                                                                                                            497      1,173                                       111.373             8.770 4b 113     Foot Hlodho A,.. (A-s Bldg)                                      729            5Q3                                                                                     -8          2.344           2.3 4 167                                                                                                                                          4.376         947                                        M231390           27.183 4b.l.l.1   Intoroedtste Btdg                                                                                          42                                                            14            170            170                                      -,08      242                                 -        23.998             1.823 4b 1 5     Machin Shop, Hst                                                   48 1.
30             N0            104                                         3       181                                         15.752             1230 4b 14      RB                 BauitetoootBldg d HP O!Sr                                                                                                     2                               5             19              1, t422                                                          ,9                                                                               1:4 tb.t.4.7   RN!Wehbos-                                                                                                                                                                              63             65                                                                                     -        9.906               773 4b 1 4     RVCHSorso Building                                                   4       132                                           2              1                               3             '                                                           '27      3                                         2 176               130 2.0.84            9.5          590                                                                    1.85.,         7,6X)               3 7.6XI lb 1.4     Totals                                                                                                                 605          1.213                                                                                                  7.30       12.408                                      1,     M487         72.622 4b t       Subtotl Peritd 4lbAttoity Csta                                 2,A21       15.182            624          2*        12.911        2867                               7.7%9         43 105         41.7,39                     1.30      157.2"4       19.517                                     7.995898            34C Period4b Additioa Cots-4b.2.I     Liln     Temoionto Soeoy Ptsnioog                                                                                                     -          1.445                134           1.79            1.879                                                                                                                                12.480 35                       "4                          136                                47            2-6            25o 4b.2.2     Asbostos Reooals Pssrsog                                                                                                                                                                                                                                                                             25,066                940 lb 2.3     IStM Ltt-ot Teroostion                                                          ISn                                                    26        1.276                 248          1769
* 1.768                                   ,77                                         N6.514            5.133 4b.2.4     Westatttiog Peod                                                                                                                     770            -                 207           1,065           1.065                                             13.513                                      1,053.006               309 4b 2       Sobt-tal Fritod4b Additioa Costa                                                                                                     932        2.722                 937.          4.60            3.230         1.7,8                               14.577                                      1 174,514             6.383            15.040 PerotdlbCollateral Costa                                                                                 lo 4b3.!      Fross dsooo ssto wto wasto I-                                     ste                                      2o6                                                    d2                                32            182            182                                                                                              9.8n*                32 4b.3.3     Soot1 to*o sltovso 4b.3.4     DooMooottg ERuipmentDispstlioo                                                                                         545             38          -                   114            903             903                                  6.000         667                                        300,00                  88 169 b.3.5     FlooIdsLLRWIopaoton          F.m                                                                                       -                           373                   37            410            410 4b.3.6      o-st ooo   s -d o-rstsas of 134.9tao Iolo ostattllo    wst.                                                           5              -            148                   15            L.3           1I99o lb.3       Sobta.W Period4b Colist.r.I Costa                                                                                      545           tO0           521                242           I'm9            1.999                                                                                            W09825                120 6."O          83M poriot lb Portod-DopsodstCo-ta lb.l.tI    Don sopplto                                                      982                                                                               -                  215            .=27           1.2W7 4b.42                                                                                                                                                       1.136                 111          1256            1M250 4b.4.3     Frsr   ty -lts                                                                                                                                   1.449                 145          1.594           1.594 TLG Serices, Inc.

Crystal River Unit 3 Nuclear Generting Plant                                                                                                                                                                                                                             Document P23-1651-001, Ret. 0 P-liminaryfDecammissIaln                  Cast Et inate                                                                                                                                                                                                                      Appendia C, Page 11 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousands of 2011 dollars)
                                                                                                                       . .s                                             ....        pant a.....                --      d.                     a..                      a                  I   itypu Asteivtity                                                asesaona-R-al       .IPk.giag      Tr..pan-    =     1%sstnDis.p...l    Othss        T-t.                    ier.Ta.
T.]       .anaent       s*.rasian     Volume      Cl... A     M. . B -0. C E   GTCC     P-aaed        Crft        Contsactta Iadet                               Aetiity Descrpttian Pust    Cast          Pots.        Co.st       .          C.Ptt       Ca.t. Coatinenscy      C.t.       Cous.         Cost         Co.t.       Cu. Fea     Pa. Fat   Cu. Fast   Ca. FPe  Cu. Fan   Wt. Lbs. M.ahour.      M.nanhu peait 4b Ceri*l.Depaedeet       Cet- (--nnttd, 4b 44       Health phbtin suppliat                                    2.513                                                                         S2,8      3 142       3 142 4b.4.5      H-y t       tqipmeat
                            -      vets]                               3.421           -                                                             513       3935        3,935 4b 463            apet,1fDAW nenerattd                                                1835          9                    279      3                                                                                          5.701                                   1]4.015          I86 4b.4.7       Fla, a.tten btdgat                                                                                                   1245              1t7       1.431       1L431 4b 4 8      NRCFe                                                                                                                 tl161             116        1278       1 278 4b 4 9      Utlity Stt Iadteat                                                                                                    L887              2113      2 170       2 170 ib.4.10 LiquidRadnastaPrFesiag Eqtipm-enSarsau                                                                                                        94        722         722 4b 4 11     CorpteAllatliat                                                                                                       L31,1             202        1,545      I 545 4b.4.l2     Ssity       Staff Cast                                                                                                4.727             709       5436        5.436 4b.4.13 DOCStaf C0t"                                                                                                             18601            2.790      21.391      21.391                                                                                                                21.3269 4b4 4             lityStaff Cet                                                                                                  21.4119          3.163      24.253      24,253                                                                                                                398.W03 4b.4        Subtatal Periodlb PFritd-DependtatCoas           982      5,9Z15          13M           97        -          279     53 2G6           9.287      69.981      69.981                                              5,701                                   114.015          186      73,.307 4b.0        TOTALPERIOD         41,COST                    3.415    21.&#xa2;x            951         1,Q7      13457       t.178     565WI,           18.26. IM0.054     IS 919            .768         1.366     163.263   40.6M5                                  9.594.252     371.595       745.347 PERIOD0    4f1-Li--eaTvvsaiesle Pa.o.d4f Di-a             e tee-e* i Asctittei
: 41. .1      ORISE -vetsasryesee_                                                                                                    154               46        20W         2WO 4 .I.2      Termieattle a--
4.1         Sabtal Pasied tf Astity C.t..                                                                                           154               46        200         2WO Ported4f Addil... Cost 41.2.1      Lnsest Tetiatije St-ey                                                                                                6048             1.815      7.863       7,863                                                                                                  123.073          6240 41.2        Sebtetal Ptriod 4f Addition.lCosta                                                                                    0048             1.815      7.863       7863                                                                                                   123.073          6.240 P.]     4fOC.1atera. osl0t 413.1l      Decs f re*fnnepr                                                                                                      1,M8              189       1.146       1.446 43.]        FloaidaLLRW     Ilpao.iee F-                                                                                               1              9         1              1 41`3        Stb.tel PeeledlfCellaterl Cesta                                                                                       1,258             189        1.447      1.447 Period4f Ploaia.DependentC t 41.4.1      Ie[ teta-4114.2      Propere tmy    aa                                                                                                                         61        639         639 41.4.3      Heasthphy*al supphl                                         654                                                                          M6         117         817 4".4.4      Disp-al f DAW--nratd                                                        8            6                     17                          6         37          37 1t 41.4        Platr            budgeet                                                                                                                                                                                                                                  6.9M             tII 154               3         177         177 41.46       PaCt              a                                                                                                     W77 63         S3t         SO]
4f14]7      Uity Site Ind-ee                                                                                                        436                         w5 01         501 41.48       Ce"pert't A]ll-aiee                                                                                                     251                         M828        HS5 4f 4 9      Seett       Staff Cat                                                                                                   935             140        1.076      1.076                                                                                                                  Ie.709 41.4 10     DO,'Sta!] 11-t                                                                                                        5.ffi4            760       5823        5.823                                                                                                                  57.149 4f4 II      UlihlyStaff 'o.t                                                                                                      4,42              666       5,108       5.108                                                                                                                  74.321 41.4        Stbtotal Pastd 4f PCerAd.Depaedent    Cts.                  654             8            6                     17       412.4          1980      15.131      15131                                                750                                      6999            I        150309 4].]        TOTALPERIOD4fCOST                                           65t             8            6                     17    19.92G           4029       24.641      746&#xfd;4]                                               350                                     6.999      123.085       156549 PERIOD4 TOTALS                                             3.6"1    47003          18031         8.72-     19.632     35.019    114.822          51.246    298.000      M9.570           1.768       387        232.10    123.327       7           00     2 142  1986.530       730004       1,429.171 PERIOD55tb      - Sits lteaavsiee Peiodtb 5irvti       Daaeea         aAetieitia nieg rteteltit fem.atini Site Btildiep 5b.l.t I     Raeat                                                    4.063                                                                                   4.672                                  4.672                                                                        47.8M0 5b.l. 2     AACDi-v G -eerto           Butilling                         19                                                                                      22                                      22 5b. .t.3    AWSReatd W-tabhtte                                          154                                                                           23        177                                      17]                                                                       2.786 5b.t I 4    Atttltey Btfidtg                                           .552                                                                         23M       1.782                                    1.782                                                                      19.,011 5b.t.1.5    Cent-I A]ee Statio                                                                                                                         0           3                                      3                                                                            46 5b.t I 6    Cvrc  -"l Storag 5biI]       C1ottroComple-                                                                                                                          114         874                                     874                                                                        9432 5b.l.t S    Stesa]PeeOil Tankt USTD                                                                                                                    2          17                                                                                                                  133 F9 Ise T-1 IM D .::I GeaOil                                                                                                                              14       3I 5b. I10 io         P Ceetp Buddlg                                       12                                                                            19        147                                     1173 5b.l.I II PiraPeetpbeete                                                                                                                               2          18 "38 5b.].1.12 Peel tedlee - vg(A-t Bid&)                                                                                                                i63       1.173                                                                                                               12.445 Sb.]1.13 lntabkt DithbtgeStecetta,                                                                                                                        65    496                                                                                                                "06I 5b.1.1.14 IBdteretabte mdg                                              73]                                                                                                                                                                                                        ii -6 TLG Snticei           Inc.

Crynata River Unit 3 No-car Generating Plant                                                                                                                                                                                                                                            Doeomeot P23-1651-001,R.        0 PrelimiryDLvmmiaoiooiog Cot Estimate                                                                                                                                                                                                                                                         Appendix C, Page 12 of 12 Table C Crystal River Unit 3 Nuclear Generating Plant SAFSTOR Decommissioning Cost Estimate (thousand. of 2011 dollar.)
Off.ti-       LLtW                                              NRC      Speot Fool      St.          Pressed              Burial Voo-es               Sorial'                  Utility .od D.ov    Rvmoval   Paikagiog   Tr-anport     Poosing       Disposal    Other       Total         Total     Li.. Term. Management   R.oaotion        Voolum   Cla.s A  Cla.. B    Class.C      TCC  Pvovo-ad       Cr-ft      Contraior Avtroitv                                                                     Coat    Co-t       Coat.       Coat.         Costt        Ctoo       Cos.-    Contingen        Coat.       Coat.        Coot.        Co.t.         C. Fot   C. Fot    oFt Cu.        Cu. Ft        o Cu. F-e     .. Lb.. M.ohoov. Manouo        I I  ..............                             * ...... p .....
ODemohlon       of ReatoiniogSita 8tuildiogslmo6nutdl 51b1.1.15 MachineShop. Cold                                                                                                                                             12         93                                       93 51, 1 IS MahinooSltop-Hot                                                                                                                                               I1         88                                                                                                               1.396 1.4*0 88 I.678 5b.l.l.17 MitoYardStu.est& F&             odotioo                                                                                                                     219       1.678                                                                                                             12.067
 ,b I1 18 OTSGS--ragoBuild..g                                                              489                                                                           73        562                                      562                                                                     6.060 Sb.l.l.I9 RSo       Mintoo -o-Blid, d HP CCio                                                                                                                                                                               '2                                                                     1.077 Sb.l.l 20            t W51   h-ouoo                                                                                                                                         6         Z3                                                                                                                445 Sb 1.121 RVCHSt-ogoBu.lding                                                                 74                                                                          11         86                                                                                                        -     1.090 5b.t.l 22 Rsoty Bldg                                                                      228                                                                           31        263                                                                                                        -     3.770 2,101                                                                                                                           2.416                                                                     27 791 5b.!.' 23 Ttbtoo Build~og                                                                                                                                             315       2.416 Sb.!.' 24 Turbtoe Fodoatal                                                                442
                                                                                                                                                                                                                           .43 0 2                                                                        04.739 Sb.!.!         Totalt                                                                  14.288                                                                        2,143     16,431          -                                                                                                170,921 5b 1.2          BockFilS1o 830                                                                         125         955                                                                                                              1.4I1 Sb.13           0radeo&  ltodtvpaltto                                                                                                                                   28        214 h.1.4         Finorepor toNRC                                                                                                                                                                                            -14 179             27        205          205                                                                                                                1.560 Sb.l            SubtotalPCootd   51 Ao-oty Coat.                                       15,304                                                           179          2.322     17.80G          205                     17,600                                                                   172,608           1,560 Period51AdditionalCo..
hb2.'1        Cootroo 0:olhmo                                                                                                                                                                                            654                                                                     2.511 48 185 Z23        554 040                       90 5h.2.2           SfST Domolitioo-d Rstooation                                                                                                                                                                                                                                                      4.410            IGO 51 2.3          lotoke& DitchargoStruotuo Cofferda-                                       !18                                                                           78         9                                       59%                                                                     4.436 5b.2.4          Firing         'aogeolo`-                                                 782                                                                         117         899                            -          90 5b.2           Sobtotal Poriod SbAddtloon.lCoo.                                         2.G33                                                                         407       2.000                       940         2,119                                                                     11360             160 PFotod5bColIttoral Co.ts S5h.!.          Small tooalown                                                            161                                                                 -2l                 ]as                                        A8 5b.3.2         Corporatilolion.                                                                                                                         232             35        276                                      267 5b.3.3          Uihty Silo Iodirtv                                                                                                                      248             37        283 5h.3           Subtotal Period5b Collater.l Co                                            161                                                           478             96        796                                      736 Periotd51Poriod-Daptndm Co-tt 5h.4.l          loooto 55.4 2          Propertytatv                                                               -                                                            451             45        496                                      495 5b.4.3         Hoyeqouipment -Wol                                                       5.119          ..                                               .70                     5N70                        .           5 887                   .        ..
54 4            Plot ooeoy bodgot                                                                                                                       173             28        199           .                          199                  .        .          .
5b.4.5         SoottotyStat Cml                                                                                                                       2.106           316       2.423                                   2,122                                                                                   12309 Sb.4.6          DOCStalFCot                                                                                                                          I1.038          1.555     '2,093                                  12.693                                                                                  119.874 b 427          Utihty Staff Cot                                                           -                                                          4.044           607       4.-50                                   4.650                                                                                   as5173 5b.4           Sobtol Poriod5b Prodi-DvptodoolCott                                      5.119                                                        17 ]1t         3.417      26.=48                                  2.338                                                                                    =230.93I 5b.0           TOTALPERIOD51b        COST                                              23.218                                                        18.521         6 238      47.978          206          960        46.832                                                                    184048        232.654 PERIOD8G        TOTALS                                                                23218                                                         18,521         6.238      47.978          200          940        46.032                                                                    184048        232.654 FOTALCOSTTo 8ICOSMMISSION                                                     9.052   80,730       18.788      10.280        20,214      36,143   752,683        149.706   1.077,596      763.717      271.910        51,969      234803  133.758      288        801    1.142  21.677,830    1.005,605     7.993.623 TOTAL     COSiTTO      DECOSIISSION"ITK 16.13%             CONTINGENf'CY:                                $1,077.596   lhot...d.of 2011 dollara lOTALN5C LICENSETERMINATION COSTIS 0.4!; 08:                                                                 $753,717 thloo..dtof 2011 dollars ISPENT      FUELMANAOFM           ENTCOSTIS26.23%OR:                                                         $271.10ltbootodtof      20811dollav INON-SUCLUA48           DEMO1LITION     COSTIS4.82% OR:                                                       151.969 tltooadt of 201t dollar.
TOTAL FSIMARYSITERADWASTEVOLUM                        E BURlIED:                                               134,09 tobloFeat TOTALGREATERTHANCLASSC R.8DWASTEVOLUMEGENERATED:                                                                2,142 tobio f-o
[LOTAL     SCHAAP     METALREMOVED:                                                                            39,30 too.
KrOTAL     CRAFT LABORREtUIREME8NTS:                                                                         L.80,505 mao-h-oo.
Eod No.a.
oft - ondloot    otht thoobotootynootcohargdttsdtoootiationi s                                     gttxpenso.
o - indlt         thbatthia ttioity porformtdbydoeoommsti.ningttalf.
0ioidwaooteobtht       thosalueoltlosstthea05bhutia ono.tro.
a calloontaiinhg".-",divooaootsazrotvloe TLG Service., 1-y.}}