View source for ZS-2015-0034, License Termination Plan Update of the Site-Specific Decommissioning Costs

{{Adams
| number = ML15061A230
| issue date = 02/26/2015
| title = License Termination Plan Update of the Site-Specific Decommissioning Costs
| author name = Vannoordennen G
| author affiliation = ZionSolutions, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS
| docket = 05000295, 05000304
| license number = DPR-039, DPR-048
| contact person = 
| case reference number = ZS-2015-0034
| package number = ML15061A281
| document type = Letter type:ZS
| page count = 23
}}

=Text=
{{#Wiki_filter:ZIONSOLUTIONSLLC     An EnergySodtona Comp.ny 10 CFR  50.82 (a)(9)(i) 10 CFR  50.82 (a)(9)(ii)(F) 10 CFR  50.4(b)(1) 10 CFR  2.390(a)(4)
February 26, 2015                                                                         ZS-2015-0034 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

==Subject:==
License Termination Plan Update of the Site-Specific Decommissioning Costs

==Reference:==
: 1) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "License Amendment Request for the License Termination Plan", dated December 19, 2014 Portions of this submittal provide the Nuclear Regulatory Commission (NRC) with financial information owned by ZionSolutions, LLC (ZS) to aid in the review of the Zion Nuclear Power Station (ZNPS) License Termination Plan (LTP). ZS considers this proprietary financial information to be confidential and requests NRC to withhold it from public disclosure under 10 CFR 2.390(a)(4). of this submittal consists of ZionSolutions Proprietary Financial Information Affidavit pursuant to 10 CFR 2.390. The Affidavit sets forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). All documents within the scope of this affidavit are marked as "withhold from public disclosure under 10 CFR 2.390."
As committed to in Reference 1, ZionSolutions is submitting proposed Chapter 7 of the ZNPS LTP titled, "Update of the Site-Specific Decommissioning Costs." The submittal is due no later than February 27, 2015. All other ZNPS LTP Chapters were previously submitted in the Reference 1 correspondence. The associated TLG Services, Inc. decommissioning cost estimate will be available upon request by the NRC staff. provides Chapter 7 of the ZNPS LTP for NRC review and approval. In accordance with 10 CFR 50.82(a)(9)(i), Chapter 7 of the ZNPS LTP is being submitted as a supplement to the Defueled Safety Analysis Report (DSAR), and is being maintained accordingly. In accordance with 10 CFR 50.82 (a)(9)(ii)(F), Chapter 7 provides an updated site-specific estimate of the remaining decommissioning costs.
101 Shiloh Boulevard, Zion - IL60099 (224) 789-4016 - Fax: (224) 789-4008 - www.zionsolutionscompany.com

ZionSolutions, LLC ZS-2015-0034 Page 2 of 2  of this submittal contains the proprietary financial information ZS is providing to the NRC and seeks to have withheld from public disclosure in its entirety. The information provided includes updated financial data to aid in the NRC's review of the ZNPS LTP. of this submittal contains a redacted version of ZNPS LTP Chapter 7 for public disclosure.
There are no regulatory commitments made in this submittal. If you should have any questions regarding this submittal, please contact me at (224) 789-4025.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 26, 2015.
Respectfully, Gerard van Noordennen Vice President Regulatory Affairs Attachments:
: 1) Attachment 1: ZionSolutions, LLC Proprietary Financial Information Affidavit
: 2) Attachment 2: LTP Chapter 7, "Update of the Site-Specific Decommissioning Costs" (Proprietary)
: 3) Attachment 3: LTP Chapter 7 Redacted Version, "Update of the Site-Specific Decommissioning Costs" (Non-Proprietary) cc: John Hickman, U.S. NRC Senior Project Manager Service List (without Attachment 2)

Attachment 1 ZIONSOLUTIONS, LLC PROPRIETARY FINANCIAL INFORMATION AFFIDAVIT Affidavit of Gerard van Noordennen, Vice President Regulatory Affairs, ZionSolutions, LLC. of this submittal consists of proprietary financial information that ZionSolutions, LLC considers confidential. Release of this information would cause irreparable harm to the competitive position of ZionSolutions, LLC. The basis for this declaration is:
: i. This information is owned and maintained as proprietary by ZionSolutions, LLC, ii. This information is routinely held in confidence by ZionSolutions,LLC and not disclosed to the public, iii. This information is being requested to be held in confidence by the NRC by this petition, iv. This information is not available in public sources,
: v. This information would cause substantial harm to ZionSolutions, LLC if it were released publicly, because it would reveal confidential pricing information that competitors could use to the detriment of ZionSolutions and its affiliates in bidding for decommissioning work, or that could be used to the detriment of ZionSolutions in contract negotiations, and vi. The information to be withheld is being transmitted to NRC in confidence.
I, Gerardvan Noordennen , being duly sworn, state that I am the person who subscribes my name the foregoing statement, I am authorized to execute the Affidavit on behalf of ZionSolutions, LLC, and that the matters and facts set forth in the statement are true to the best of my knowledge, information, and belief.
Name:            Gerard van Noordennen

==Title:==
Vice President Regulatory Affairs Company:         ZionSolutions, LLC SWORN TO AND SUBSCRIBED BEFORE ME THIS 26th DAY of February 2015                                LNDA CHOU OFFICIAL SEAL Notary Public, Stats of Illinois My Commission Expires December 07. 2015 LINDA CHOU

Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service List cc:
John Christian                                Alwyn C. Settles President Logistics Processing and            Section Head, Nuclear Facility Inspection Disposal Group                                Bureau of Nuclear Facility Safety EnergySolutions                               Illinois Emergency Management Agency 1750 Tysons Boulevard, Suite 1500              1011 North St., PO Box 250 McLean, VA 22102                             Mazon, IL 60444 John Sauger                                   Kelly F. Grahn Executive VP & General Manager                Senior Health Physicist, Unit Supervisor ZionSolutions, LLC                            Bureau of Radiation Safety, Environmental 101 Shiloh Boulevard                               Management Zion, IL 60099                                Illinois Emergency Management Agency 245 W Roosevelt Road, Building 8, Suite 55 Gerard van Noordennen                         West Chicago, IL 60185 VP Regulatory Affairs ZionSolutions, LLC                            Kent McKenzie 101 Shiloh Boulevard                          Emergency Management Coordinator Zion, IL 60099                                Lake County Emergency Management Agency Anthony Orawiec                                1303 N. Milwaukee Avenue Decommissioning Plant Manager                 Libertyville, IL 60048-1308 ZionSolutions, LLC 101 Shiloh Boulevard                          Regional Administrator Zion, IL 60099                                U.S. NRC, Region III 2443 Warrenville Road Dan Shrum                                     Lisle, IL 60532-4352 Senior VP Regulatory Affairs EnergySolutions                               John E. Matthews 423 West 300 South, Suite 200                 Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Salt Lake City, UT 84101 Washington, DC 20004 Russ Workman General Counsel EnergySolutions 423 West 300 South, Suite 200 Salt Lake City, UT 84101

REDACTED VERSION FOR PUBLIC DISCLOSURE Attachment 3 LTP Chapter 7, "Update of the Site-Specific Decommissioning Costs" REDACTED VERSION FOR PUBLIC DISCLOSURE

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN SECTION 7 UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                                                            ZIONSOLUTIONSr--
TABLE OF CONTENTS
: 7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS ...............................                                                       7-1 7 .1. In tro ductio n ................................................................................................................... 7-1 7.1.1. Cost Estimates Previously Docketed with the NRC ..............................................                                7-2 7.2. D ecom m issioning Cost Estim ate ..................................................................................                  7-2 7.2.1. Cost Estimate Description and Methodology ........................................................                            7-3 7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate ...........................                                           7-3 7.2.3. Radiological Decommissioning Costs ...................................................................                           7-4 7.2.3.1. C lass A Large C omponents .............................................................................                    7-6 7.2.3.2. C lass A B ulk M aterials ....................................................................................              7-6 7.2.3.3. C lass A Containerized W astes .........................................................................                    7-6 7.2.3.4. C lass B/C W aste ..............................................................................................            7-6 7.2.4. Spent Fuel M anagem ent Costs ...............................................................................                 7-7 7.2.5. Site R estoration C osts ............................................................................................            7-8 7.2 .6. C ontingency ...........................................................................................................        7-9 7.3. D ecom missioning Funding Plan ...................................................................................                    7-9 7 .4. R eferen ces ................................................................................................................... 7-1 1 LIST OF TABLES Table 7-1       Cost for Radiological Decommissioning, Spent Fuel Management, and Site R estoration ............................................................................................................. 7-4 Table   7-2     Estimated Base Radiological Decommissioning Cost by Resource Category ...... 7-5 Table   7-3     Estimated Radiological Decommissioning Cost by Major Project Activity ......... 7-5 Table   7-4     Estimated Base Spent Fuel Management Cost by Major Resource ....................... 7-8 Table   7-5     Estimated Site Restoration Cost by Major Resource Category ............................. 7-9 Table   7-6     Detailed Breakdown of Radiological Decommissioning Costs by Resource R equirem ent ........................................................................................................       7-12 Table 7-7       Detailed Breakdown of Radiological Decommissioning Costs by D ecomm issioning Activity ..................................................................................                7-13 Table 7-8       Detailed Breakdown of Spent Fuel Management Costs by R esource R equirem ent ........................................................................................             7-14 Table 7-9       Detailed Breakdown of Site Restoration Costs by Resource Requirement ......... 7-15 7-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                   :ZIONSOLUTIONS-=-
LIST OF ACRONYMS AND ABBREVIATIONS ComnEd     Commonwealth Edison Exelon     Exelon Corporation FRS        Final Radiation Survey FSAR       Final Safety Analysis Report GTCC       Greater Than Class C ISFSI      Independent Spent Fuel Storage Installation LTP        License Termination Plan NRC        Nuclear Regulatory Commission PSDAR      Post-Shutdown Decommissioning Activities Report TLG        TLG Services, Inc.
WCS        Waste Control Specialists ZNPS       Zion Nuclear Power Station ZSRP       Zion Station Restoration Project 7-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                   :ZIONSOLUTIONS&#xfd;,=
: 7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS 7.1. Introduction In accordance with 10 CFR 50.82(a)(9)(ii)(F) (Ref 7-1) and Regulatory Guide 1.179 (Ref 7-2),
the updated site specific cost estimates and funding plans for the Zion Station Restoration Project (ZSRP) are provided. Regulatory Guide 1.179 provides guidance on the details of the information to be presented in the License Termination Plan (LTP).
The LTP must provide an estimate of the remaining decommissioning costs at the time of LTP submittal and also compare these estimated costs with the present funds set aside for decommissioning. If it is determined that there is a deficit in the present funding, the LTP must indicate the means for ensuring that adequate funds are available to complete the decommissioning.
The decommissioning cost estimate, at a minimum, needs to include an evaluation of the following cost elements:
* Cost assumptions used, including contingency factor;
* Major decommissioning activities and tasks;
* Unit cost factors;
* Estimated costs of decontamination and removal of equipment and structures;
* Estimated costs of waste disposal, including disposal site surcharges;
* Estimated Final Radiation Survey (FRS) costs; and
* Estimated total costs.
The cost estimate should focus on the remaining work, detailed activity by activity, including costs of labor, materials, equipment, energy, and services. The cost estimate should include the cost of the planned remediation activities as well as the cost of the transportation and disposal of the waste generated by the remedial work conducted.
Historical Perspective By 1998, Exelon Corporation (Exelon), formerly Commonwealth Edison Company, or CoinEd, had completely shut down the two unit Zion Nuclear Power Station (ZNPS) and made plans to implement a delayed-DECON decommissioning scenario, with decommissioning expected to commence at the original license expiration date (November 14, 2013). As part of its post shutdown planning, Exelon contracted a specialty decommissioning consultant, TLG Services, Inc. (TLG) to develop a decommissioning cost estimate for the ZNPS Units I and 2. This cost estimate was provided with the Post-Shutdown Decommissioning Activities Report (PSDAR)
(Ref 7-3) Exelon submitted in 2000 to the NRC.
Exelon later entered into discussions with EnergySolutions for the possible transfer of the ZNPS licenses and the decommissioning fund to EnergySolutions to accelerate the decommissioning of the plant. As part of its application for the license transfers, ZionSolutions, LLC, a wholly owned subsidiary of EnergySolutions, amended the PSDAR and submitted it to the NRC in 2008. This amended PSDAR provided significant decommissioning cost milestone changes and an estimate of expected decommissioning costs.
7-1

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                  :ZIONSOLUTIONS             -
The license transfers were completed and ZionSolutions started decommissioning operations by September 2010. In compliance with 10 CFR 50.75(f)(1) (Ref 7-4) and 10 CFR 50.82(a)(8)(v)-
(viii), ZionSolutions continues to demonstrate financial assurance on an annual basis.
7.1.1. Cost Estimates Previously Docketed with the NRC Exelon submitted its PSDAR to the NRC on February 14, 2000. As previously noted, in accordance with 10 CFR 50.82(a)(8)(iii), a Zion site-specific decommissioning cost estimate was also prepared and submitted in a letter dated February 14, 2000 (Ref 7-5). This submittal, docketed with the NRC, included an Attachment, "Zion Nuclear Power Station Units I and 2 Site-Specific Decommissioning Cost Estimate" which was the cost estimate study prepared by TLG.
During the process of ZionSolutions, LLC's application to take over the licenses of Zion Units 1 and 2 from Exelon, ZionSolutions submitted an Amended PSDAR, including an estimate of expected decommissioning costs, on March 18, 2008. This submittal was also docketed with the NRC.
7.2. Decommissioning Cost Estimate The decommissioning cost estimate presented herein represents the cost to complete the remaining decommissioning work as of the end of the 3 rd quarter 2014. This estimate was prepared based upon the schedule of the remaining work, incorporating the experience that has been gained while performing similar decommissioning tasks over the past four years. To a large extent, this decommissioning cost estimate is based upon an existing and operating decommissioning organization, in which actual contracts for services are already in place. As such, there is a high degree of certainty regarding expected work productivity, the cost of labor and the cost of services required to support the remainder of the project. The decommissioning cost estimate also includes application of contingency, as specific provision for unforeseeable elements of cost within the defined project scope. Contingencies are particularly important where previous experience has shown that unforeseeable events, which may increase costs, are likely to occur. The contingency, as used in this estimate, does not account for price escalation and inflation in the costs of decommissioning over the remaining project duration.
The cost estimate was prepared to include all costs associated with the decommissioning and unrestricted release of the Zion site other than the area bounded by the Independent Spent Fuel Storage Installation (ISFSI), and includes radiological decommissioning (i.e., those costs required to accomplish such unrestricted release), spent fuel management (transfer of the spent fuel to the ISFSI and operation of the ISFSI until the partial site release is achieved, at which time the released portion of the site and the remaining ISFSI will be transferred back to Exelon),
and site restoration (i.e., non-radiological remediation aimed at leaving the site in a safe and stable condition). As was reflected in the Application relating to the transfer of the Zion licenses to ZionSolutions, Exelon has retained title to the spent fuel and Greater Than Class C (GTCC) waste, as well as the obligation for ultimate disposition of the spent fuel and the GTCC waste in the ISFSI and the decommissioning of the ISFSI.
The site-specific decommissioning cost estimate provided with this LTP has been prepared as a collaborative effort by ZionSolutions and TLG and presents a breakdown of the remaining costs 7-2

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                 :ZIONSOLUTIONS.-
to complete the decommissioning process and release all portions of the site for unrestricted release, with the exception of the area bounded by the ISFSI.
The following subsections present a description of how the cost estimate was prepared and a summary and breakdown of the estimated costs.
7.2.1. Cost Estimate Description and Methodology During the summer and fall of 2014, the ZionSolutions decommissioning project organization undertook an effort to update the baseline schedule, risks and the costs to complete the decommissioning project. This resulted in a revised work breakdown structure that provided a detailed listing of the remaining work activities and support services needed to complete the project. Task durations, crew compositions and material and contracted services needs were derived from the results of detailed process planning carried out by each of the decommissioning and support organizations (e.g., decommissioning operations, engineering, security, radiation protection, radiological engineering, waste management, safety, FRS, etc.).
Additionally, ZionSolutions performed a contingency and risk analysis so that the potential additional costs due to expected but undefined risks and uncertainties could be addressed and included in the cost estimate.
The resulting information was then compiled into a decommissioning cost estimate by TLG. The following sections provide a summaiy of those results.
7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate The overall remaining decommissioning cost (including scope risk contingency) was estimated to be $389 Million (in year of expenditure dollars), with a base estimated cost of $358 Million (without the scope risk contingency). The cost estimates include provisions for cost escalation based upon the following assumptions:
* Labor costs are assumed to escalate at 1.992% per year, this cost escalation factor being based on the forecast of the Consumer Price Index, Services, CUSASNS as published by Global Insight Company, and applied per the Zion project Asset Sale Agreement.
    " Non-Labor costs that are not covered by fixed prices, fixed rates or escalation provisions in contractual agreements, are similarly assumed to escalate at 1.992% per year, this cost escalation factor being based on the Consumer Price Index, Services, CUSASNS as published by Global Insight Company, and applied per the Zion project Asset Sale Agreement.
    " For Class A and Class B&C waste costs, ZionSolutions has largely mitigated this escalation risk by having a fixed price arrangement with EnergySolutions (Class A) and contractually defined costs for B/C waste.
The cost estimate includes the costs for radiological decommissioning, spent fuel management, and site restoration. A breakout of the cost for each part of the decommissioning program is provided in Table 7-1.
7-3

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                               :ZIONSOLUTIONS.=
Table 7-1        Cost for Radiological Decommissioning, Spent Fuel Management, 0
and Site Restoration Radiological                        Spent Fuel Decommissioning                      Management*
Base amu                          $284.3 Million                    $37.4 Million           $36.2 Million Amount
                                      $24.7 Million                   $3.3 Million             $3.2 Million Contingency Total                         $309.0 Million                  $40.7 Million*           $39.4 Million*
*included for completeness, but not required for license termination funding purposes.
Detailed breakdowns of the estimated costs for radiological decommissioning, spent fuel management and site restoration programs are provided in sections 7.2.3, 7.2.4 and 7.2.5, respectively. Section 7.2.6 presents the estimated contingency costs for each of these programs.
7.2.3. Radiological Decommissioning Costs Consistent with the NRC definition of decommissioning under 10 CFR 50.2, the radiological decommissioning costs under this category consider only those costs associated with normal decommissioning activities necessary for release of the site (other than the ISFSI) for unrestricted use. It does not include costs associated with the disposal of non-radiological materials or structures beyond those necessary to terminate the Part 50 license or the costs associated with construction or operation of an ISFSI.
As summarized in section 7.2.2 above, the total estimated cost for radiological decommissioning, including contingency is $309 Million. The estimated cost for the anticipated base work scope is
$284.3 Million. Application of a contingency of $24.7 Million results in a total estimated cost of
$309 Million.
The remaining decommissioning scope of work included in this estimate is described in detail in other chapters of this LTP. Overall, that work scope includes completion of the removal, transportation and disposal of the major components; completion of the removal, transportation and disposal of the remaining equipment; decontamination and/or bulk demolition of radiological impacted structures and transportation and disposal of the resulting radioactive wastes; performance of the FRS and associated license termination activities. The estimated costs include the labor, equipment, materials, services and fees needed to conduct the work. The estimated cost also includes all of the program support activities and services necessary to manage and safely carry out a large scale dismantlement and demolition project. These program support activities include project management, work controls and site administration; technical support services, such as radiation protection, safety, engineering, security, QA/QC, environmental monitoring, waste management and decommissioning subject matter experts needed to support the project.
A high level breakdown of the estimated base radiological decommissioning cost, by major resource category, is provided in Table 7-2.
7-4

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                               :ZIONSOLUTIONS;7, Table 7-2         Estimated Base Radiological Decommissioning Cost by Resource Category Labor                                                           $119.8 Million (b)
Equipment, Materials and Supplies                                $24.9 Million Fixed- Price Contracts, Services & Fees                          $55.5 Million Radioactive Waste Packaging, Transportation & Disposal           $84.1 Million Total (c)                                                       $284.3 Million (b) Includes contracted specialty labor costs (c)  Columns may not add due to rounding A high level breakdown of the estimated radiological decommissioning cost, alternatively by major project activity, is provided in Table 7-3.
Table 7-3         Estimated Radiological Decommissioning Cost by Major Project Activity Major Component Removal                                                       $30.8 Million Equipment and Structure Decontamination / Removal                             $63.8 Million Waste Disposition                                                             $84.1 Million Program Management and Support Services (excluding Final Status               $75.7 Million Survey and License Termination Activities)
Final Radiation Survey and License Termination Activities                       $8.0 Million Other Lump-Sum Costs (e.g., regulatory fees, financing)                       $21.9 Million Total (a)                                                                    $284.3 Million (a)  Columns may not add due to rounding A more detailed breakdown of the costs by resource requirements (e.g., labor, materials, services, etc.) and by decommissioning activity (e.g., component removal, structural decontamination, program support functions, waste management functions, etc.) are provided in Tables 7-6 and 7-7 respectively.
The total estimated cost for radioactive waste disposition (containers, transportation and disposal) is $84.1 Million. As presented in Table 7-7, these waste management costs are comprised of four distinct categories; Class A Large Components, Class B/C Waste, Class A Containerized Wastes and Class A Bulk Materials. Costs for on-site handling of GTCC waste (i.e., reactor vessel internals) are included in the "Major Component Removal" category shown 7-5

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                   :ZIONSOLUTIONSU---
on Table 7-7. However, no costs for disposal of this waste is included in the estimate, as it is assumed that disposal of this waste will be included as a part of spent fuel disposition.
The project has in place a unique contracting approach for disposal of the resulting radioactive wastes that eliminates much of the cost uncertainty and waste volume estimation risk that is often associated with decommissioning projects. As such, the reported waste management costs are unlikely to vary due to waste volume uncertainties. The resulting radioactive waste streams and the disposal and transportation contracts that are in place can be categorized by the following:
7.2.3.1. Class A Large Components This category of waste includes equipment that will be transported and disposed of intact, enclosed in rail cars or prepared to serve as its own waste container. These items have been radiologically and physically characterized. As such, the inventory of these items and their disposal volumes are known. The associated waste management costs are covered by existing fixed-price contracts with EnergySolutions. Therefore, the waste mana ement costs for these items are well known and not ie        ov 7.2.3.2. Class A Bulk Materials This category of waste primarily consists of concrete rubble or similar materials contaminated with very low levels of radioactivity (and large components described above). This material will be transported in covered gondola rail cars to the EnergySolutions disposal site in Clive, Utah.
The cost for disposal and transportation of this material is covered by a fixed-price contract that covers any and all material of this type from this decommissioning project, without regard to the total mass or volume. Therefore, these costs are known and are unlikely to vary. This category of waste comprises > 95% of the total volume and mass and > 80% of the estimated waste management costs for all radioactive waste expected to be generated by this decommissioning effort.
7.2.3.3. Class A Containerized Wastes This category of waste primarily consists of material that will need to be packaged in strong-tight
/ Industrial containers, such as intermodals or steel boxes. Typically, this would include small pieces of contaminated equipment, pipe or debris which require containerization to meet DOT regulations or mitigate radiological handling concerns. This material will be trans orted b rail, for disposal at the EnergySolutions disposal site in Clive, Utah.
I                                                            I 7.2.3.4. Class B/C Waste This category of waste is primarily composed of segmented pieces of the activated reactor internals and, to a much lesser extent, higher radioactivity level resins, filters, sludge and cutting fines. These materials will require packing in liners or high integrity containers, and transported 7-6

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                 :ZIONSOLUTIONS            -
in shielded licensed transportation casks by truck to the Waste Control Specialists (WCS) facility in Andrews, Texas. The volume (or mass) of this waste material is well known, characterized, and will be generated from a limited set of reactor components.
Disposal cost variability for this category of waste has been largely mitigated by established contractual terms in place with WCS.
7.2.4. Spent Fuel Management Costs ZionSohltions acknowledges that the costs to construct and operate an ISFSI (previously defined) and other spent fuel related management costs are not considered by the NRC staff as part of decommissioning costs. Nevertheless, as there is significant interest by many stakeholders in these costs, they are presented herein. As presented in Section 7.2.2 above, the estimated cost for the anticipated base work scope is $37.4 Million. A contingency of $3.3 Million was applied resulting in total spent fuel management costs of $40.7 Million.
Overall, the spent fuel management work scope includes transfer of the remaining spent fuel to the ISFSI and operation of the ISFSI until termination of the reactor license, with the exception of the area bounded by the ISFSI, projected to take place in 2019.
Construction of the ISFSI was completed in April 2013 and spent fuel transfer operations were started by December 2013 with the first spent fuel cask being placed on the ISFSI in early January 2014. As of the end of September 2014, approximately 64% of the spent fuel has been transferred to the ISFSI, contained in 39 dry storage casks on the ISFSI pad. Note that spent fuel transfer was completed on January 10, 2015.
The estimated costs include the labor, equipment, materials, services, fees, and program support activities necessary to safely manage the spent nuclear fuel. ISFSI operational costs are estimated through mid-year 2019, when partial site release and the transfer of the site and ISFSI back to Exelon are expected, and subsequent management of the spent fuel is consistent with the Irradiated Fuel Management Plan for Zion under 10 CFR 50.54 (bb) (Ref 7-6). Exelon has provided a decommissioning funding plan to the NRC for the Zion ISFSI (Ref 7-7).
A high level breakdown of the estimated base spent fuel management cost, by major resource category, is provided in Table 7-4.
7-7

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                 ZIONSOLUTIONS;T, Table 7-4           Estimated Base Spent Fuel Management Cost by Major Resource Labor                                 1$29.9                             Million (b)
Equipment, Materials and Supplies                                   $1.3 Million Fixed- Price Contracts, Services & Fees                             $6.2 Million Radioactive Waste Packaging, Transportation & Disposal                        $0 Total (c)                                              $37.4 Million (b) Includes contracted specialty labor costs (c) Columns may not add due to rounding A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, etc.) is provided in Table 7.8.
7.2.5. Site Restoration Costs ZionSolutions acknowledges that the costs to restore the Zion Plant property are not considered by the NRC staff as part of decommissioning costs. Nevertheless, there is significant interest by many stakeholders in these costs and they are presented herein. The estimated cost for the anticipated work scope is $36.2 Million. A contingency of $3.2 Million was estimated, bringing the total to $39.4 Million. Overall, that work scope includes removal of any remaining hazardous materials, demolition of remaining structures, backfilling of any open excavations or void spaces, and final grading and stabilization against erosion.
The estimated costs include the labor, equipment, materials, services and fees needed to conduct the work. In general, most of this work is anticipated to be performed by contractors; however the estimated cost also includes all of the program support activities and services necessary to manage and safely carry out project.
A high level breakdown of the estimated site restoration cost, by major resource category, is provided in Table 7-5.
7-8

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                 :ZIONSOLUTIONS- =-
Table 7-5           Estimated Site Restoration Cost by Major Resource Category Labor                                      1$58.8                             Million (b)
Equipment., Materials and Supplies                                      $0.71 Million Fixed- Price Contracts, Services & Fees                                $29.7 Million Radioactive Waste Packaging, Transportation & Disposal                             $0 Total (c)                                                              $36.2 Million (b) Includes contracted specialty labor costs (c) Columns may not add due to rounding A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, etc.) is provided in Table 7.8.
7.2.6. Contingency Uncertainty associated with the decommissioning cost estimate, and the need to allocate additional funding to cover contingency for this project has been included in this estimate.
Accounting for contingency has been evaluated from two standpoints, operational efficiency and scope expansion risk. Within the context of this cost estimate, operational efficiency contingency is defined as the occurrence of events or circumstances that can prolong project duration or make the execution of a given work scope more difficult. Examples of these types of events include weather related delays, equipment or tool breakage or unavailability, and interferences from other work activities. Scope expansion risk within the context of this estimate is defined as the need to perform unplanned work activities or expansion of the work activities that were planned.
Examples of this type of project risk would be discovering new or additional contaminated media requiring remediation, or a need to perform work in a different manner due to unforeseen conditions or changes in requirements.
As was initially shown in section 7.2.2, contingency was estimated at $31.1 Million; apportioned as $24.7 Million for radiological decommissioning, $3.3 Million for spent fuel management and
$3.2 Million for site restoration. This contingency was estimated using a quantitative Monte Carlo type probability analysis, with the $31.1 Million amount corresponding to the resulting 85 percent confidence level amount.
7.3. Decommissioning Funding Plan As indicated in section 7.2, the estimated cost to complete the radiological decommissioning of the Zion nuclear station, including contingency, is $309 Million (year of expenditure dollars) as of Sept 30, 2014. These decommissioning costs will be paid for with funds from the station's nuclear decommissioning trust fund (NDT). Discounting those escalated costs at the rate of cost inflation described in section 7.2.2 yields a cost of radiological decommissioning at constant 2014 dollars of                       f.
7-9

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                                :ZIONSOLUTIONS-7=-
The actual cash balance of the NDT, as recorded by the ZionSolutions trustee as of Sept 30, 2014, was                   . Recognizing that there were project costs incurred and recorded on Sept 30, 2014 that had not been paid for from the NDT (outstanding disbursements), plus other transactions in the last quarter of 2014 that have a bearing on these outstanding disbursements, the net balance of the NDT available to cover the future costs of radiological decommissioning was $317.1 Million.
Based on a time phased cash flow analysis of the radiological decommissioning costs, and assuming NDT returns at an annual 2% real, after tax rate of return, the required minimum funding assurance amount to fund the future radiological decommissioning costs equals $302.6 Million, which is below the $317.1 Million available balance described above.
This NDT position, together with EnergySolutions resources and the $200 Million Letter of Credit backup for the NDT agreed with Exelon in the Zion Nuclear Power Station Unit 1 and 2 Asset Sale Agreement, that are available but are not relied upon here, provides for sufficient funding and financial assurance for completion of radiological decommissioning of the Zion Project.
On or before March 31, 2015, as required by 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)-
(viii), ZionSolutions will be submitting the annual demonstration of financial assurance for the year ending Dec 31, 2014. That submission will be based upon future project costs of radiological decommissioning and the NDT balance as of that date.
0 7-10

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                              :ZIONSOLUTIONS;-m 7.4. References 7-1   Code of Federal Regulations, Title 10, Part 50.82, "Termination of License" 7-2   US Nuclear Regulatory Commission Regulatory Guide 1.179, Revision 1, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors", June 2011 7-3   Letter from ZionSolutions ,LLC to the U.S. Nuclear Regulatory Commission, "Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Zion Nuclear Power Station, Units 1 and 2 in Accordance with 10 CFR 50.82(a)(7)",
dated March 18, 2008 7-4   Code of Federal Regulations, Title 10, Part 50.75, "Reporting and Recordkeeping for Decommissioning Planning" 7-5   Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, "Submittal of the Zion Nuclear Power Station Site-Specific Decommissioning Cost Estimate", dated February 14, 2000 7-6   Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, "Submittal of the Zion Nuclear Power Station Irradiated Fuel Management Plan", dated February 14, 2000 7-7   Letter from Exelon Generation to the U.S. Nuclear Regulatory Commission, "Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Zion", dated October 17, 2013 7-11

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                              :ZIONSOLUTIONSz.
Table 7-6      Detailed Breakdown of Radiological Decommissioning Costs by Resource Requirement Labor:                                 TOTAL                                 $119.8 Million Craft                                  $38.6 Million Technician                             $14.3 Million Professional (Sci. & Eng.)             $36.8 Million Management                             $18.1 Million Other - contract service labor         $11.9 Million Equipment & Materials:                 TOTAL                                  $24.9 Million Durable Equipment                       $5.3 Million Consumable Supplies                    $16.0 Million Utilities and Energy                    $3.6 Million Contracts, Services & Fees:            TOTAL                                  $55.5 Million Equipment Rental                       <$0.1 Million Contracted Services                    $27.9 Million Laboratory & Analytical Services        $1.8 Million Travel & Living                         $1.5 Million Insurance and Finance Fees             $20.1 Million Licensee Fees & Permits                 $4.2 Million Radioactive Waste Packaging,           TOTAL                                  $84.1 Million Transportation & Disposal:             Class A Waste Class B/C Waste TOTAL                                                                        $284.3 Million Columns may not add due to rounding 7-12

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                              :ZIONSOLUTION&S=
Table 7-7      Detailed Breakdown of Radiological Decommissioning Costs by Decommissioning Activity Major Component              TOTAL                                              $30.8 Million Removal                      Reactor Vessels and Internals                      $21.1 Million Steam Generators                                      9.0 Million Pressurizers                                        $0.7 Million SSC Removal and              TOTAL                                              $27.2 Million Decontamination              Equipment Removal / Structural Decontamination     $18.4 Million Bulk Structural Material Removal                    $7.9 Million In-process Characterization and Remedial Action     $0.9 Million Support Waste Management             TOTAL                                              $84.1 Million Class B/C Waste: Packaging, Transportation and Disposal Surveys and Sampling Class A Waste: Rail Car Preparation for Large Components Class A Bulk Waste: Rail Car Transportation and Disposal Class A Packaged Waste: Containers, Transportation and Disposal Program Management           TOTAL                                             $120.3 Million and Support Services         Program and Project Management and Site            $32.1 Million Administration Technical Services and Services- (e.g.,            $47.9 Million Engineering, Rad. Protection, Environmental Monitoring, Site Characterization, Waste Mgmt, QA/QC, Safety, Worker Qualifications)
Security                                            $7.7 Million Site O&M                                            $4.9 Million Special Projects (Cold & Dark, Bld. Mods.)          $8.5 Million Equipment, Materials, Consumable Supplies and      $11.2 Million Utilities FSS, LT and Material Release Program                 $8.0 Million Other Lump-Sum Costs         TOTAL                                              $21.9 Million Financing                                           $9.8 Million Regulatory Fees                                    $12.1 Million TOTAL                                                                          $284.3 Million Columns may not add due to rounding 7-13

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                               :ZIONSOLUTIONS,.
Table 7-8       Detailed Breakdown of Spent Fuel Management Costs by Resource Requirement Labor:                      TOTAL-                                            $29.9 Million Craft                                               $3.7 Million Technician                                          $1.5 Million Professional (Sci. & Eng.)                          $3.7 Million Management                                          $1.8 Million Other (contract service lab                    -   $19.2 Million exclusive of management)
Equipment &                 TOTAL                                               $1.7 Million Materials:
Durable Equipment                                  <$0.1 Million Consumable Supplies                                 $1.2 Million Utilities and Energy                                $0.4 Million Contracts, Services &       TOTAL                                               $5.8 Million Fees:
Equipment Related Services                          $1.3 Million Contracted Services (excluding security provided    $2.2 Million in labor above)
Laboratory & Analytical Services                   <$0.1 Million Travel & Living                                   <$ 0.1 Million Insurance, Finance, Licensee and Permit fees        $2.3 Million Radioactive Waste           TOTAL                                                         $0 Packaging, Transportation &            Class A Waste                                                 $0 Disposal:
Class B/C Waste                                               $0 TOTAL                                                                         $37.4 Million Columns may not add due to rounding 7-14

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN                                              :ZIONSOLUTIONS.-
Table 7-9      Detailed Breakdown of Site Restoration Costs by Resource Requirement Labor:                       TOTAL                                             $5.8 Million Craft                                             $2.2 Million Technician                                       $0.16 Million Manrofessional                (Sci. & Eng.)       $1.9 Million Other- contract service labor                     $1.6 Million Equipment & Materials:       TOTAL                                             $1.2 Million Durable Equipment                               <$0.1 Million Consumable Supplies                               $0.7 Million Utilities and Energy                              $0.5 Million Contracts, Services &        TOTAL                                           $29.2 Million Fees:
Equipment Rental                                <$0.1 Million Contracted Services                              $27.6 Million Laboratory & Analytical Services                <$0.1 Million Travel & Living                                 <$0.1 Million Insurance, Finance, Licensee & Permit fees,       $1.6 Million Radioactive Waste            TOTAL                                                       $0 Packaging, Transportation &             Class A Waste                                               $0 Disposal:
Class B/C Waste                                             $0 TOTAL                                                                        $36.2 Million Columns may not add due to rounding 7-15}}