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#REDIRECT [[L-15-327, ISFSI; Davis-Besse, Unit 1 & ISFSI and Perry, Unit 1 & ISFSI - Triennial ISFSI Decommissioning Funding Plans]]
| number = ML15343A350
| issue date = 12/09/2015
| title = Beaver Valley, Units 1, 2 & ISFSI; Davis-Besse, Unit 1 & ISFSI and Perry, Unit 1 & ISFSI - Triennial ISFSI Decommissioning Funding Plans
| author name = Halnon G H
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS/DSFM
| docket = 05000334, 05000346, 05000412, 05000440, 07200014, 07200069, 07201043
| license number =
| contact person =
| case reference number = L-15-327
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70, Letter
| page count = 32
}}
 
=Text=
{{#Wiki_filter:FENOCFir'. AsW rwry 4paugcdrpary-\341 White Pond Dr.Akron. Ohio 44320December 9,2015L-15-327ATTN: Document Control DeskDirector, Division of Spent Fuel ManagementOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001
 
==SUBJECT:==
Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSIDocket No. 72-1043Davis-Besse Nuclear Power Station, Unit No. 1 ISFSIDocket No.72-14Perry Nuclear Power Plant, Unit No. 1 ISFSIDocket No. 72-69Triennial ISFSI Decommissionino Fundinq Plans10 CFR 72.30(c\Pursuant to the requirements of 10 CFR 72.30(cl, FirstEnergy Nuclear OperatingCompany (FENOC) is submitting the triennial decommissioning funding plans for theBeaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Independent Spent FuelStorage Installation (lSFSl); the Davis-Besse Nuclear Power Station, Unit No. 1(DBNPS) ISFSI; and the Perry Nuclear Power Plant, Unit No. 1 (PNPP) ISFSI(Attachments 1 through 3, respectively). Enclosures A through C contain the ISFSIdecommissioning cost estimates for BVPS, DBNPS, and PNPP, respectively.The initial DBNPS and PNPP ISFSI funding plans were submitted to the NuclearRegufatory Commission (NRC) on December 17,2012 (Accession No. ML123524194).The initial BVPS ISFSI funding plan was submitted to the NRC on December 8,2014(Accession No. ML14342A707). FENOC is submitting the triennial BVPS ISFSI fundingplan early in order to align its submittal date with the triennial ISFSI funding plansubmittal date of the other two FENOC facilities.On December 8, 2015, the DBNPS operating license was renewed for 20 years. Inaccordance with 10 CFR 72.30(cl, DBNPS is required to submit a revised ISFSIdecommissioning funding plan upon the renewal of the operating license. The revisedDBNPS ISFSI decommissioning funding plan will be submitted by the end of firstquarter 2016.
Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSIDavis-Besse Nuclear Power Station, Unit No. 1 ISFSIPerry Nuclear Power Plant, Unit No. 1 ISFSIL-15-327Page 2There are no regulatory commitments contained in this letter. lf there are any questionsor if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at 330-315-6810.Vice President, Regulatory Affairs and Lab ServicesAttachments:1. Decommissioning Funding Plan for Beaver Valley Power Station, Unit Nos. 1 and2, Independent Spent Fuel Storage InstallationDecommissioning Funding Plan for Davis-Besse Nuclear Power Station, Unit No. 1Independent Spent Fuel Storage lnstallationDecommissioning Funding Plan for Perry Nuclear Power Plant, Unit No. 1Independent Spent Fuel Storage Installation2.3.
 
==Enclosures:==
A. Beaver Valley Power Station, Unit Nos. 1 and 2,Installation Decommissioning Cost EstimateB. Davis-Besse Nuclear Power Station, Unit No. 1,Installation Decommissioning Cost EstimateIndependent Spent Fuel StorageIndependent Spent Fuel StorageC. Perry Nuclear Power Plant, Unit No. 1, Independent Spent Fuel StorageInstallation Decommissioning Cost Estimatecc: NRC Region lAdministratorNRC Region lll AdministratorNRC Resident Inspector (Beaver Valley Power Station, Unit Nos. 1 and 2)NRC Resident Inspector (Davis-Besse Nuclear Power Station, Unit No. 1)NRC Resident Inspector (Perry Nuclear Power Plant, Unit No. 1)NRC Project Manager (Beaver Valley Power Station, Unit Nos. 1 and 2)NRC Project Manager (Davis-Besse Nuclear Power Station, Unit No. 1)NRC Project Manager (Perry Nuclear Power Plant, Unit No. 1)NRC Project Manager (FENOC Fleet)Director BRP/DEPSite BRP/DEP RepresentativeUtility Radiological Safety BoardSincerely, 1.2.Attachment 1L-15-327Decommissioning Funding Plan forBeaver Valley Power Station, Unit Nos. 1 and2,Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC), hereby, provides theupdated decommissioning funding plan for the Beaver Valley Power Station,Unit Nos. 1 and 2 (BVPS), lSFSl.The initial BVPS ISFSI funding plan was submitted to the Nuclear RegulatoryCommission on December 8,2014 (Accession No. ML14342A707). FENOC issubmitting the triennial BVPS ISFSI funding plan early in order to align its submittal datewith the triennial ISFSI funding plan submittal date of the other two FENOC facilities,Davis-Besse Nuclear Power Station, Unit No. 1 and Perry Nuclear Power Plant, UnitNo. 1, respectively.Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to ltem 4 below provides the method of financial assurancepursuant to 10 CFR 72.30(e).A detailed cost estimate for decommissioning:By letter dated December 8,2014 (Accession No. ML14342A707), FENOCsubmitted the initial BVPS ISFSI decommissioning funding plan. The plan isbased on a BVPS ISFSI decommissioning cost estimate that was enclosed in theletter. For ease of review, the BVPS ISFSI decommissioning cost estimate isprovided in Enclosure A. The cost estimate assumes that an independentcontractor will perform the decommissioning activities, assumes a contingencyfactor of 25 percent (%), and includes the cost of meeting 10 CFR 20.1402 forlicense termination for unrestricted use. The total decommissioning cost withcontingency is $8,018,000 (2014 dollars).Changes in the responses to the four criterion listed in 10 CFR 72.30(c) for theperiod between the initial plan submittal and this submittal are as follows:Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: NoneFacili$ modifications: NoneChanges in authorized possession limits: NoneActual remediation costs that exceed the previous cost estimate: None1.2.3.4. L-15-327Page 2 of 33.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure A.A description of the method of assuring funds for decommissioning from10 CFR 72.30(el, including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $9,250,000 for the decommissioning of theBVPS ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and ML151814323) that support the lSFSlslocated at BVPS, Davis-Besse Nuclear Power Station, and Perry Nuclear PowerPlant. These guarantees will be payable to the existing nuclear decommissioningtrust funds established for BVPS pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:BVPS uses the Transnuclear NUHOMS system for spent fuel storage. TheNUHOMS system has been designed, fabricated, and tested to be leak tight. Asa result, FENOC assumes the volume of onsite subsurface material containingresidual radioactivity that will require remediation to meet the criteria for licensetermination to be zerc.4.5. L-15-327Page 3 of 36. A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. M1141838295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning.
1.2.Attachment 2L-15-327Decommissioning Funding Plan forDavis-Besse Nuclear Power Station, Unit No. 1Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides theupdated decommissioning funding plan for the Davis-Besse Nuclear Power Station, UnitNo. 1 (DBNPS) lSFSl.Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to number 4 below discusses the appropriate method of financialassurance contemplated under 10 CFR 72.30(e).A detailed cost estimate for decommissioning:In a report dated March 2,2015, TLG Services, Inc. prepared a DBNPS ISFSIdecommissioning cost estimate for FENOC. This report is included asEnclosure B. This revises the decommissioning cost estimate described in theinitial ISFSI decommissioning funding plan submitted to the NRC by FENOCfetter dated December 17,2012 (Accession No. ML12352A194). The revisedcost estimate, like the original cost estimate, assumes that an independentcontractor will perform the decommissioning activities and includes the cost ofmeeting 10 CFR 20.1402 for license termination for unrestricted use. Therevised estimate assumes a contingency factor of 25o/o. The totaldecommissioning cost with contingency is $5,493,000 (2014 dollars).Below is the effect of the following on the detailed cost estimate since theprevious report:Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: NoneFacility modifications: NoneChanges in authorized possession limits: NoneActual remediation costs that exceed the previous cost estimate: None1.2.3.4. L-15-327Page 2 of 33.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure B.A description of the method of assuring funds for decommissioning from10 CFR 72.30(e), including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $6,000,000 for the decommissioning of theDBNPS ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and M115181A323) that support the lSFSlslocated at Beaver Valley Power Station, DBNPS, and Perry Nuclear Power Plant.These guarantees will be payable to the existing nuclear decommissioning trustfunds established for DBNPS pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:DBNPS uses the Transnuclear NUHOMS system for spent fuel storage. TheNUHOMS system has been designed to be a no effluent system. As a result,FENOC assumes the volume of onsite subsurface material containing residualradioactivity that will require remediation to meet the criteria for licensetermination to be zero.4.5. L-15-327Page 3 of 3A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. M1141838295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning. L-15-327Decommissioning Funding Plan forPerry Nuclear Power Plant, Unit No. 1Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides theupdated decommissioning funding plan for the Perry Nuclear Power Plant, Unit No. 1(PNPP) tSFSt.1. Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to number 4 below discusses the appropriate method of financialassurance contemplated under 10 CFR 72.30(e).2. A detailed cost estimate for decommissioning:In a report dated March 3,2015, TLG Services, Inc. prepared a PNPP ISFSIdecommissioning cost estimate for FENOC. This report is included asEnclosure C. This revises the decommissioning cost estimate described in theinitial ISFSI decommissioning funding plan submitted to the NRC by FENOCletter dated December 17,2012 (Accession No. ML12352A194). The revisedcost estimate, like the original cost estimate, assumes that an independentcontractor will perform the decommissioning activities and includes the cost ofmeeting 10 CFR 20.1402 for license termination for unrestricted use. Therevised estimate assumes a contingency factor of 25o/o. The totaldecommissioning cost with contingency is $7,891,300 (2014 dollars).Below is the effect of the following on the detailed cost estimate since theprevious report:1. Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: None2. Facility modifications: None3. Changes in authorized possession limits: None4. Actual remediation costs that exceed the previous cost estimate: None  L-15-327Page 2 of 33.4.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure C.A description of the method of assuring funds for decommissioning from10 CFR 72.30(e), including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $9,250,000 for the decommissioning of thePNPP ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and ML151814323) that support the lSFSlslocated at Beaver Valley Power Station, Davis-Besse Nuclear Power Station, andPNPP. These guarantees will be payable to the existing nuclear decommissioningtrust funds established for PNPP pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:PNPP uses the Holtec International HI-STORM system for spent fuel storage.The HI-STORM cask has been designed to assure that there is no release ofradioactive materials to the environment. As a result, FENOC assumes thevolume of onsite subsurface material containing residual radioactivity that willrequire remediation to meet the criteria for license termination to be zero.5. L-15-327Page 3 of 3A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. ML14183B295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning.
Enclosure AL-15-327Beaver Valley Power Station, Unit Nos. 1 and 2, Independent Spent Fuel StorageInstallation Decommissioning Cost Estimate(Six Pages Follow)
Fir stE ner gy C orp oratio nBeaver Vallev Power Station ISFSIF07- 1 69 1 -1 4002 ; Attiichment IPage l of 61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June 17 ,20ll,t'l with the rule becoming effective on December 17 ,2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning,'o requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Beaver Valley Power Station (Beaver Valley) in anamount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.Spent Fuel Management StrategyBeaver Valley's operating licenses were renewed effective November 9, 2009. Thescheduled license termination dates for Beaver Valley Units I and2 are January 29,2036, andMay 27,2047, respectively. Currently, 5,010 spent fuel assemblies areprojected to be discharged over the operating life of the two units. If DOE is able toinitiate acceptance of commercial spent fuel in 2025,2,346 assemblies are projected to beshipped during plant operations or within seven years following the cessation ofoperations (during which time the spent fuel pools are operational). For the purpose ofthis analysis, the remaining2,664 assemblies would be placed in dry storage at an on-siteISFSI. The ISFSI would operate (under a Part 50 General License) until the transfer ofspent fuel to the DOE is completed. At that time, the ISFSI could be decommissioned.U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 20 I I .2.TLG Semices,Inc.
3.Fir stE nergt Co rp o r atia nBeaver VaUey Power Station ISFSIF 0 7- 1 69 1 - 1 4 0 0 2 ; Attachment 1Page 2 of 6Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations 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 thereactor.l'l FirstEnergy Corporation's current spent fuel management plan for the BeaverValley spent fuel is based in general upon completion of spent fuel receipt by no laterthan the year 2075.ISFSI Decom missioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing of residual radioactivity and veriffing that remaining materialssatisff NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning alternative identified for the nuclear power plant.ISFSI DescriptionThe Beaver Valley ISFSI currently uses a Transnuclear NUHOMS system (with a 37-fuelassembly capacity) for spent fuel storage. The system consists of a multi-purpose (storageand transport) dry shielded storage canister (DSC) and a horizontal storage module(HSIO. The DSCs are assumed to be transferred directly to the DOE and not returned tothe station. Some of the remaining HSMs are assumed to have residual radioactivity dueto some minor level of neutron-induced activation as a result of the long-term storage ofthe spent fuel. The cost to dispose of residual radioactivity, and verify that the remainingfacility and surrounding environs meet the NRC's radiological limits established forunrestricted use, form the basis of the ISFSI decommissioning estimate.In addition to the spent fuel casks located on the ISFSI pad after shutdown there may beadditional casks used for Greater-than-Class-C (GTCC) storage. The HSMs used to storethe GTCC canisters (estimated quantity of 8) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final stafus survey.Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.' U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) "... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfrom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ..."TLG Services,Inc.4.
5.F irstE n eryyt C orp o r ati.o nBeaver Valley Power Station ISFSI' Email Matt Minniti to Francis Seymore, November 18,2014.TLG Sewices,Inc.F07-1 69 1-1 4002; Attachment IPage 3 of 6Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (Beaver Valley IJnit? operating until2047 , and the assumptionsassociated with DOE's spent fuel acceptance, as previously described).The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 90 feet in width, and 400 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a t00Yo survey of the concrete HSMsurfaces, and a significant fraction of the ISFSI pad and the immediate area surroundingthe pad, and the other ISFSI structures.It is not expected that the HSMs will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelysmall. To validate this assumption, the estimate accounts for further characterization of10% of the HSMs; it is likely that some of this characterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefinitive decommissioning scope.The decommissioning estimate conservatively assumes that l0 HSMs (equivalent to thenumber of casks to store the final full core offloads for both units) will contain low levelsof neutron-induced residual radioactivity that would necessitate remediation at the timeof decommissioning. For purposes of this estimate, these HSMs are designated forcontrolled disposal as lowlevel radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the HSMs are removed, the cask transporter, or other facilities at the BeaverValley ISFSL IT is expected that these assumptions would be confirmed as a result ofgood radiological practice of surveying potentially impacted areas after each spent fueltransfer campaign. As such, only verification surveys are included for the other facilitiesin the decommissioning estimate.The ISFSI was constructed upon part of the property that was released as a result of thedecommissioning of the Shippingport Atomic Power Station by the U.S. Department ofEnergy in 1989. The pad area was excavated down approximately 15 feet, and backfilledwith clean engineered fill. The surrounding ISFSI areas were not disturbed, and remain asleft by the DOE, other than a topcoat of gravel. As such, the decommissioning estimateassumes that no soil remediation is required [3], to meet the unrestricted use criteria of 10cFR 20.1402.
Fir stE ner gt C orp o r ationBeaver Valley Power Station ISFSIF07-1 69 1- 1 4 002 ; Attachment IPage 4 of 66.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergyCorporation, as licensee, will oversee the site activities; the estimate includes FirstEnergyCorporation's labor and overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corporation's existing contracted disposal rates.Costs are reported in20l4 dollars.Contingency has been added at an overall rate of 25o/o. This is consistent with thecontingincy evaluation criteria referenced by the NRC in NUREG-1757.I41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 criteriafor unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.The cost has been organized into three phases, including:An initial planning phase - empty HSMs are characterized and the specifications andwork procedures for the decontamination (liner removal) developed.The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as lowlevel waste.The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningservices, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorporation's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2076,the year following the last of the spent fuel removal.4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l,February 2012.TLG Services,Inc.
FirstEn ergt CorporationBewer Vallev Power StationTLG Semices, Inc.F07-1 69 1 -l 4002 : Afrachmmt 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLensth (ft)widrh (ft)ResidualRadioactivitvISFSI Pad (dimensions are for current pad)30090NoISFSI Pad Exoansion (dimensions are for exoansion)10090NoISFSI Horizontal Storage ModulesltemValueNotes (all dimensions are nominal)Overall Length (inches)244HSM dimensions based uponOverall Width (inches)116Transnuclear HSM-H desienOverall Heieht (inches)2226uantitv (f.nfsl)72Quantity (with residual radioactivity)t0Equivalent to the number of HSMsneeded to store the last core ofrloadsfrom both units at Beaver VallevTotal Surface Area of HSM interior with ResidualRadioactivitv (so uare feet)7,500Low-Level Radioactive Waste (cubic feet)21.853low-Level Radioactive Waste (packaged density)151Most weight shipped as concrete slabsOther Potentially Impacted ItemsItemValueNotesCask TransoorterINo residual radioactivityISFSI Equipment Storaee BuildineINo residual radioactivityNumber of HSMs used for GTCC storaee8No residual radioactivitv Firx,t E n e rg) C o rp o r ali onBeaver Valley Power StaionTable 2ISFSI Decomrnissioning Costsr and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2076TLG Semiceg Inc.F0 7 - 1 69 1 - 1 4002 ; Attachment IPage 6 of 6(Thousande, 2014 dollars)Person-HoursDeconRemovalTransnortDisnosalOtherTotalWasteVolume1fr3\CraftOversight andDecommissioningCnntmr.fnrPlanning (characterization,cnacc qnrl n:nnartrrroc\2182r8t,096Remediation/oar'irrorod lfSMo\25048532.1065283.7412r,8532.O921861.1869.234Srrhlolal26048632-1061.9326.14621.8631.fl27r.096Sunoortino CostsNRC and NRC CrntractorFees and Costs384384lnsurance65ODProDertv taxesffir331Cornorate A&Ga282Securitv (industrial)481485.020FirstEnergy CorporationOwcrsicht Staff2592593.803Subtotal7-2701.2709.699Total (w/o continEenev)26048682.1063.2026.4162r.868r1.327r0.696T otal (w 1260/" ontinpeno)8.0r8 Enclosure BL-15-327Davis-Besse Nuclear Power Station, Unit No. 1 Independent Spent Fuel StorageInstallation Decommissioning Cost Estimate(Six Pages Follow)
FirstEnergt Corp.Davis-Besse Nuclear Power Station.LSf',SIF07-1 698-1 5003 ; Attachment 1Page I of61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June 17,20ll,t'l with the rule becoming effective on December 17,2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Davis-Besse Nuclear Power Station (Davis-Besse) in anamount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in l0CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.2. Spent Fuel Management StrategyDavis-Besse's scheduled license termination date is April 22, 2017 . Currently , l ,452spent fuel assemblies are projected to be discharged over the operating life of the unit. IfDOE is able to initiate acceptance of commercial spent fuel in 202l,the first spent fuelassemblies from Davis-Besse are projected to be shipped by 2026. For the purpose of thisanalysis, all of the 1,452 assemblies would be placed in dry storage at an on-site ISFSI.The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, theISFSI could be decommissioned.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelt U.S. Code of Federal Regulations, Title 10, Parts 20,30,40, 50, 70 andT2 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June I 7, 201 I .TLG Semices,Inc.
3.FirstEnergt Corp.Davis-Besse Nuclear Power Station.LsffSlF 07- 1 69 8- 1 5 00 3 ; Attac hment IPage 2 of 6allocations 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 thereactor.[2] FirstEnergy Corp. current spent fuel management plan for the Davis-Bessespent fuel is based in general upon completion of spent fuel receipt by no later than theyear 2056.ISFSI Decom missioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing oiresidual radioactivity and verifying that remaining materialssatis$ NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning altemative identified for the nuclear power plant.ISFSI DescriptionThe dry fuel storage system consists of a TransnuclearNUHOMS multi-purpose (storageand transport) dry shielded storage canister (DSC) and a horizontal storage module(HSM). The Davis-Besse ISFSI expects to use three different versions of the system.There are three modules currently on the ISFSI pad with 24-assembly capacity DSCs. Ascheduled 2017 campaign will load four 32-assembly capacity DSCs. All subsequentspent fuel DSC loadings are planned using a 37-fuel assembly capacity DSC. The DSCsaie assumed to be transfened directly to the DOE and not returned to the station. Some ofthe remaining HSMs are assumed to have residual radioactivity due to some minor levelof neutron-induced activation as a result of the long-term storage of the spent fuel. Thecost to dispose of residual radioactivity, and veriff that the remaining facility andsurrounding environs meet the NRC's radiological limits established for unrestricted use,form the basis of the ISFSI decommissioning estimate.In addition to the spent fuel modules located on the ISFSI pad after shutdown there maybe additional HSMs used for Greater-than-Class-C (GTCC) storage. The HSMs used tostore the GTCC canisters (estimated quantity of 4) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final status survey.Table I provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.t U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) "... DOg shall issue an annual acceptance prioriry ranking for recerpt 9f SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfiom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ...'oTLG Services,Inc.4.
FirstEnergy Corp.Davis-Besse Nuclear Power Statinn ISF,SIF0 7- 1 69 8- 1 5 0 03 ; Attachment IPage 3 of 65. Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (operating until 2017), and the assumptions associated with DOE'sspent fuel acceptance, as previously described.The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 88 feet in width, and344 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a l00o/o survey of the concrete HSMsurfaces, and a significant fraction of the ISFSI pad and the immediate area surroundingthe pad, and the other ISFSI structures.It is not expected that the HSMs will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelystnail. To validate this assumption, the estimate accounts for further characteization of10% of the HSMs; it is likely that some of this charucterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefinitive decommissioning scope.The decommissioning estimate conservatively assumes that 5 HSMs (equivalent to thenumber of HSMs to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning. For purposes of this estimate, these HSMs are designated forcontrolled disposal as low-level radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the HSMs are removed, the transfer cask and transporter, or other facilities atthe Davis-Besse ISFSI. It is expected that these assumptions would be confirmed as aresult of good radiological practice of surveying potentially impacted areas after eachspent fuel transfer campaign. As such, only verification surveys are included for the otherfacilities in the decommissioning estimate.A review of drawing and pictures taken during the pad construction identified no pipingrunning under the pad. A duct bank going East-West under the pad can be identified.The area of the pad plus five feet on each side was excavated down to undisturbed soiland then refilled with an engineered backfill prior to pouring the pad. At this time thereis no reason to believe the soil under the pad has been contaminated. As such, thedecommissioning estimate assumes that no soil remediation is required t3l, to meet theunrestricted use criteria of 10 CFR 20.1402.3 Email Matt Minniti to Francis Seymore, February 25,2015.TLG Services,Inc.
FirstEnergt Corp.Davis-Besse Nuclear Power Station.LSESlF 0 7- 1 69 8- 1 5 003 ; Attachment 1Page 4 of 66.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergy Corp.,as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. laborand overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.Costs are reported in20l4 dollars.Contingency has been added at an overall rate of 25o/o. This is consistent with thecontinfency evaluation criteria referenced by the NRC in NUREG-I757.t41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 critefiafor unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.T\e cost has been organized into three phases, including:An initial planning phase - empty HSMs are characterized andthe specifications andwork procedures for the decontamination (heat shields and rails) developed.The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as low-level waste.The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningservices, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorp's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2057,the year following the last of the spent fuel removal.4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l, February 2012.TLG Services,Inc.
FintEnergt Corp.Davis-Besse Nuclear Power StationTLG Semices, Inc.F07-1 698-1 5003 : Afrachment 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLeneth (ft)width (ft)ResidualRadioactivifwISFSI Pad (dimensions are for current pad)22988NoISFSI Pad Flxnansion (dimensions are for exnansion)11588NoISFSI Horizontal Storage ModulesItemValueNotes (all dimensions are nominal)Overall Lencth (inches)248HSM dimensions based uponOverall Width (inches)116Transnuclear HSM-H desisnOverall HeiEht (inches)222Ouantitv (total)45Quantity (with residual radioactivity)oEquivalent to the number of HSMsneeded to store the last core offloadfrom Davis-BesseTotal Surface Area of HSM interior with ResidualRadioactivitv (souare feet)3.750Low-Level Radioactive Waste (cubic feet)r 1,356low-l,evel Radioactive Waste (packaeed densitv)lDoMost weieht shipped as concrete slabsOther Potentially Impacted ltemsItemValueNotesCask TlansoorterNo residual radioactivitvISFSI Eouioment Storase BuildinsINo residual radioactivitvNumber of HSMs used for GTCC storage4No residual radioactivity FirstEnergt Corp.Dwis-Besse Nuclear Power StalionTable 2ISFSI Decomrnissioning Costsl and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2057TLG Semices, Inc.F0 7 - 1 69 8- I 500 3 ; Attachment IPage 6 ot6(Ihoueands. 2014 dollars)Person-HoursDeconRemovalPackasinsTransoortDisnosalOtherTotalWasteVolumel/frc\CraftOversight andDecomissioningContrac-torPlanning (characterization,snec-s and nrocedures)r86186L,024Rerrecliationlsctiwaf.pd HSMs\516t.t425632.442l.doo1.880License Terrnination(radiologica l srrrocls)8058056.434Subtotal21735161.1121.6643.452r1.3568.3131.024Supportins CostsNRC and NRC ContractorFees and Costs384384a aoInsumncebDooProDertv tiles6262Comorate A&G4444Secuitv (industrial)t481485.013FirstEnergy Corp.Oversieht StaffqRo2593.803Subtotal962s629.5922173616r.1422-6164.395r13668.31310.616T otal (w I 260/o contin gencv)5-493 Enclosure CL-15-327Perry Nuclear Power Plant, Unit No. 1 Independent Spent Fuel Storage InstallationDecommissioning Cost Estimate(Six Pages Follow)
FirstEnergt Corp.Perry Nuclear Power Plant ISFSIF07-1 699-1 5003 ; Attachment IPage 1 of 61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June l7,207l,tll with the rule becoming effective on December 17,2012.Subpart 72.30,"Financial assurance and recordkeeping for decommissioning," requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Perry Nuclear Power Plant (Perry) in an amount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.2, Spent Fuel Management StrategyPerry's scheduled license termination date is March 18,2026. Currently, 6,233 spent fuelassemblies are projected to be discharged over the operating life of the unit. If DOE isable to initiate acceptance of commercial spent fuel in 2025,the first spent fuelassemblies from Perry are projected to be shipped by 2034. For the pulpose of thisanalysis, all of the 6,233 assemblies would be placed in dry storage at an on-site ISFSI.The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, theISFSI could be decommissioned.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations will be accepted for disposal from the nation's commercial nuclear plants,t U.S. Code of Federal Regulations, Title 10, Paxts 20,30,40, 50, 70 and 72 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 201 I .TLG Semices,Inc.
3.FirstEnergt Corp.Perry Naclear Power Plant ISFSIF07- 1 699- 1 5003 ; Attachment IPage 2 of 6with limited exceptions, in the order (the "queue") in which it was discharged from thereactor.[2] FirstEnirgy Corp. current spent fuel management plan for the Perry spent fuelis based in general upon completion of spent fuel receipt by no later than the year 2064.ISFSI Decommissioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing of residual radioactivity and verifuing that remaining materialssatisfu NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning alternative identified for the nuclear power plant.ISFSI DescriptionThe dry fuel storage system consists of a Holtec Intemational HI-STORM 100S System(with a 68-fuel assembly capacity). The system consists of a multi-purpose (storage andtransport) canister (MPC) and a concrete shield (overpack). The MPCs are assumed to betransferred directly to the DOE and not returned to the station. Some of the remainingconcrete overpacks are assumed to have residual radioactivity due to some minor level ofneutron-induced activation as a result of the long-term storage of the spent fuel. The costto dispose of residual radioactivity, and verif that the remaining facility and surroundingenvirons meet the NRC's radiological limits established for unrestricted useo form thebasis of the ISFSI decommissioning estimate.In addition to the spent fuel casks located on the ISFSI pad after shutdown there may beadditional casks used for Greater-than-Class-C (GTCC) storage. The overpacks used tostore the GTCC canisters (estimated quantity of 5) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final status survey.Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.2 U.S. Code of Federal Regulations, Title 10, Part 96l.ll, Article IV - Responsibilities of the Parties, B' DOEResponsibilities, 5.(a) '.. . IOB shall issue an annual acceptance priority ranking for receipt of SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfrom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ..."TLG Services,Inc.4.
FirstEnergy Corp.Perry Nuclear Power Plant ISFSIF07- 1 699- 1 5 003 ; Attachment 1Page 3 of 65. Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (operating until2026), and the assumptions associated with DOE'sspent fuel acceptance, as previously described.The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 75 feet in width, and 453 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a l00Yo survey of the concreteoverpack surfaces, and a significant fraction of the ISFSI pad and the immediate ateasurrounding the pad, and the other ISFSI structures.It is not expected that the overpacks will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelysmall. To validate this assumption, the estimate accounts for further chatactetization of10% of the overpacks; it is likely that some of this characterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefrnitive decommissioning scope.The decommissioning estimate conservatively assumes that 11 overpacks (equivalent tothe number of casks to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning. For purposes of this estimate, these overpacks are designated forconholled disposal as low-level radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the overpacks are removed, the cask transporter, or other facilities at the PerryISFSI. It is expected that these assumptions would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. As such, only verification surveys are included for the other facilities in thedecommissionine estimate.FENOC Ct"-irlw reviewed the I0CFR 50.7SgfiIes that it maintains and found nomention of any contaminated soil found as a result of building the ISFSI pad. As such,the decommissioning estimate assumes that no soil remediation is requi..d t'1, to meet theunrestricted use criteria of 10 CFR 20.1402.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data' Email Matt Minniti to Francis Seymore, March 3, 2015.TLG Services,Inc.
FirstEnerglt Corp.Perry Nuclear Power Plant ISFSIF07-I 699-1 5 003 ; Attachment IPage 4 ot6(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergy Cotp.,as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. laborand overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.Costs are reported in2014 dollars.Contingency has been added at an overall rate of 25%o. This is consistent with thecontingincy evaluation criteria referenced by the NRC in NUREG-I757.t41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 criteria for unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.6. Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.T\e cost has been organized into three phases, including:o An initial planning phase - empty overpacks are characterized and the specificationsand work procedures for the decontamination (steel liner removal) developed.o The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as low-level waste.o The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningserviceso the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorp's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2065,the year following the last of the spent fuel removal.a "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S'Nuclear Regulatory Commission's Offrce of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l,February 2012.TLG Services,Inc.
FirctEnergt Corp.Perry Nuclear Planl StationTLG Semices, Inc.F0 7- 1 69 9- 1 5 00 3 ; Attachment 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLeneth (ft)width (ft)ResidualRadioactivitvISFSI Pad (dimensions are for current pad)347toNoISFSI Pad Expansion (dimensions are for expansion)105.5toNoISFSI Storage OverpackItemValueNotes (all dimensions are nominal)Overall Heieht (inches)2t8.5Outside Diameter (inches)r32.5Inside Diameter (inches)73.5Inner Liner Thickness (inches)1.0Chrqntifv (fnfsl)9792 spent fuel + 5 GTCCQuantity (with residual radioactivity)11Equivalent to the number ofOverpacks needed to store the lastcore offload from PerrvTotal Surface Area of Overpack Liner with ResidualRadioactiwitv (souare feet)3.750Iow-Level Radioactive Waste (cubic feet)11.356Low-Level Radioactive Waste (packased densitv)rooAverase weisht densitvOther Potentially Impacted ltemsItemValueNotesCask ThansoorterINo residual radioactivitvISFSI Eouioment Storaee BuildineINo residual radioactivitvNumber of Overpacks used for GTCC storaseaNo residual radioactivitv FirstEnergt Corp.Perry Nuclear Plant StationTable 2ISFSI Decomrnissioning Costst and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2065TLG Semices. Inc.F07-1699-1 5003; Attachment IPage 6 of 6fThousands. 2014 dollars)Pe.rson-HourgDeconRemovalPackaeineTransnortDisnosalOf.herTotalWasteVolume/+t\Cra-ftOversight andConf.raelnrDecommissioningContractorPlanning (characterization,cnono and nrmodrrros\322.21.144.0Remediahon/a.fivot6.l ^tral521 2319 5450 61747.43.033.115.766.01.204.1Liense Terminationhdialnoiool orrnrorro\r.670_31.670.3Suhtntal621-2319_6,t50^6r.741-a1.992.66.026.616.766.01.204.r,144.0NRC and NRC Contractortrroao oni f'lnefo408.7408.7150.3150.3Prooertv taxes276.427A.8Cnmovatn A&G43.843.8Sperrritw ainductrial)407 A407.85,013FirstEnergy Corp.C)vprsishf. Staff1.247.5r.287.53,803Subtotal3.280.06-313.19.592Total (do mntinEencv)621.2319.6460.61.741.83.280.06-313-l15.766-Ot-204-l6.932.9T otal ( w D6o/" contincend)7.891.3 FENOCFir'. AsW rwry 4paugcdrpary-\341 White Pond Dr.Akron. Ohio 44320December 9,2015L-15-327ATTN: Document Control DeskDirector, Division of Spent Fuel ManagementOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001
 
==SUBJECT:==
Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSIDocket No. 72-1043Davis-Besse Nuclear Power Station, Unit No. 1 ISFSIDocket No.72-14Perry Nuclear Power Plant, Unit No. 1 ISFSIDocket No. 72-69Triennial ISFSI Decommissionino Fundinq Plans10 CFR 72.30(c\Pursuant to the requirements of 10 CFR 72.30(cl, FirstEnergy Nuclear OperatingCompany (FENOC) is submitting the triennial decommissioning funding plans for theBeaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Independent Spent FuelStorage Installation (lSFSl); the Davis-Besse Nuclear Power Station, Unit No. 1(DBNPS) ISFSI; and the Perry Nuclear Power Plant, Unit No. 1 (PNPP) ISFSI(Attachments 1 through 3, respectively). Enclosures A through C contain the ISFSIdecommissioning cost estimates for BVPS, DBNPS, and PNPP, respectively.The initial DBNPS and PNPP ISFSI funding plans were submitted to the NuclearRegufatory Commission (NRC) on December 17,2012 (Accession No. ML123524194).The initial BVPS ISFSI funding plan was submitted to the NRC on December 8,2014(Accession No. ML14342A707). FENOC is submitting the triennial BVPS ISFSI fundingplan early in order to align its submittal date with the triennial ISFSI funding plansubmittal date of the other two FENOC facilities.On December 8, 2015, the DBNPS operating license was renewed for 20 years. Inaccordance with 10 CFR 72.30(cl, DBNPS is required to submit a revised ISFSIdecommissioning funding plan upon the renewal of the operating license. The revisedDBNPS ISFSI decommissioning funding plan will be submitted by the end of firstquarter 2016.
Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSIDavis-Besse Nuclear Power Station, Unit No. 1 ISFSIPerry Nuclear Power Plant, Unit No. 1 ISFSIL-15-327Page 2There are no regulatory commitments contained in this letter. lf there are any questionsor if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at 330-315-6810.Vice President, Regulatory Affairs and Lab ServicesAttachments:1. Decommissioning Funding Plan for Beaver Valley Power Station, Unit Nos. 1 and2, Independent Spent Fuel Storage InstallationDecommissioning Funding Plan for Davis-Besse Nuclear Power Station, Unit No. 1Independent Spent Fuel Storage lnstallationDecommissioning Funding Plan for Perry Nuclear Power Plant, Unit No. 1Independent Spent Fuel Storage Installation2.3.
 
==Enclosures:==
A. Beaver Valley Power Station, Unit Nos. 1 and 2,Installation Decommissioning Cost EstimateB. Davis-Besse Nuclear Power Station, Unit No. 1,Installation Decommissioning Cost EstimateIndependent Spent Fuel StorageIndependent Spent Fuel StorageC. Perry Nuclear Power Plant, Unit No. 1, Independent Spent Fuel StorageInstallation Decommissioning Cost Estimatecc: NRC Region lAdministratorNRC Region lll AdministratorNRC Resident Inspector (Beaver Valley Power Station, Unit Nos. 1 and 2)NRC Resident Inspector (Davis-Besse Nuclear Power Station, Unit No. 1)NRC Resident Inspector (Perry Nuclear Power Plant, Unit No. 1)NRC Project Manager (Beaver Valley Power Station, Unit Nos. 1 and 2)NRC Project Manager (Davis-Besse Nuclear Power Station, Unit No. 1)NRC Project Manager (Perry Nuclear Power Plant, Unit No. 1)NRC Project Manager (FENOC Fleet)Director BRP/DEPSite BRP/DEP RepresentativeUtility Radiological Safety BoardSincerely, 1.2.Attachment 1L-15-327Decommissioning Funding Plan forBeaver Valley Power Station, Unit Nos. 1 and2,Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC), hereby, provides theupdated decommissioning funding plan for the Beaver Valley Power Station,Unit Nos. 1 and 2 (BVPS), lSFSl.The initial BVPS ISFSI funding plan was submitted to the Nuclear RegulatoryCommission on December 8,2014 (Accession No. ML14342A707). FENOC issubmitting the triennial BVPS ISFSI funding plan early in order to align its submittal datewith the triennial ISFSI funding plan submittal date of the other two FENOC facilities,Davis-Besse Nuclear Power Station, Unit No. 1 and Perry Nuclear Power Plant, UnitNo. 1, respectively.Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to ltem 4 below provides the method of financial assurancepursuant to 10 CFR 72.30(e).A detailed cost estimate for decommissioning:By letter dated December 8,2014 (Accession No. ML14342A707), FENOCsubmitted the initial BVPS ISFSI decommissioning funding plan. The plan isbased on a BVPS ISFSI decommissioning cost estimate that was enclosed in theletter. For ease of review, the BVPS ISFSI decommissioning cost estimate isprovided in Enclosure A. The cost estimate assumes that an independentcontractor will perform the decommissioning activities, assumes a contingencyfactor of 25 percent (%), and includes the cost of meeting 10 CFR 20.1402 forlicense termination for unrestricted use. The total decommissioning cost withcontingency is $8,018,000 (2014 dollars).Changes in the responses to the four criterion listed in 10 CFR 72.30(c) for theperiod between the initial plan submittal and this submittal are as follows:Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: NoneFacili$ modifications: NoneChanges in authorized possession limits: NoneActual remediation costs that exceed the previous cost estimate: None1.2.3.4. L-15-327Page 2 of 33.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure A.A description of the method of assuring funds for decommissioning from10 CFR 72.30(el, including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $9,250,000 for the decommissioning of theBVPS ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and ML151814323) that support the lSFSlslocated at BVPS, Davis-Besse Nuclear Power Station, and Perry Nuclear PowerPlant. These guarantees will be payable to the existing nuclear decommissioningtrust funds established for BVPS pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:BVPS uses the Transnuclear NUHOMS system for spent fuel storage. TheNUHOMS system has been designed, fabricated, and tested to be leak tight. Asa result, FENOC assumes the volume of onsite subsurface material containingresidual radioactivity that will require remediation to meet the criteria for licensetermination to be zerc.4.5. L-15-327Page 3 of 36. A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. M1141838295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning.
1.2.Attachment 2L-15-327Decommissioning Funding Plan forDavis-Besse Nuclear Power Station, Unit No. 1Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides theupdated decommissioning funding plan for the Davis-Besse Nuclear Power Station, UnitNo. 1 (DBNPS) lSFSl.Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to number 4 below discusses the appropriate method of financialassurance contemplated under 10 CFR 72.30(e).A detailed cost estimate for decommissioning:In a report dated March 2,2015, TLG Services, Inc. prepared a DBNPS ISFSIdecommissioning cost estimate for FENOC. This report is included asEnclosure B. This revises the decommissioning cost estimate described in theinitial ISFSI decommissioning funding plan submitted to the NRC by FENOCfetter dated December 17,2012 (Accession No. ML12352A194). The revisedcost estimate, like the original cost estimate, assumes that an independentcontractor will perform the decommissioning activities and includes the cost ofmeeting 10 CFR 20.1402 for license termination for unrestricted use. Therevised estimate assumes a contingency factor of 25o/o. The totaldecommissioning cost with contingency is $5,493,000 (2014 dollars).Below is the effect of the following on the detailed cost estimate since theprevious report:Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: NoneFacility modifications: NoneChanges in authorized possession limits: NoneActual remediation costs that exceed the previous cost estimate: None1.2.3.4. L-15-327Page 2 of 33.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure B.A description of the method of assuring funds for decommissioning from10 CFR 72.30(e), including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $6,000,000 for the decommissioning of theDBNPS ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and M115181A323) that support the lSFSlslocated at Beaver Valley Power Station, DBNPS, and Perry Nuclear Power Plant.These guarantees will be payable to the existing nuclear decommissioning trustfunds established for DBNPS pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:DBNPS uses the Transnuclear NUHOMS system for spent fuel storage. TheNUHOMS system has been designed to be a no effluent system. As a result,FENOC assumes the volume of onsite subsurface material containing residualradioactivity that will require remediation to meet the criteria for licensetermination to be zero.4.5. L-15-327Page 3 of 3A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. M1141838295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning. L-15-327Decommissioning Funding Plan forPerry Nuclear Power Plant, Unit No. 1Independent Spent Fuel Storage InstallationPage 1 of3Pursuant to 10 CFR 72.30(c), each licensee of an independent spent fuel storageinstallation (lSFSl) is required to triennially submit a decommissioning funding plan forthe lSFSl. FirstEnergy Nuclear Operating Company (FENOC) hereby provides theupdated decommissioning funding plan for the Perry Nuclear Power Plant, Unit No. 1(PNPP) tSFSt.1. Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI:The response to number 4 below discusses the appropriate method of financialassurance contemplated under 10 CFR 72.30(e).2. A detailed cost estimate for decommissioning:In a report dated March 3,2015, TLG Services, Inc. prepared a PNPP ISFSIdecommissioning cost estimate for FENOC. This report is included asEnclosure C. This revises the decommissioning cost estimate described in theinitial ISFSI decommissioning funding plan submitted to the NRC by FENOCletter dated December 17,2012 (Accession No. ML12352A194). The revisedcost estimate, like the original cost estimate, assumes that an independentcontractor will perform the decommissioning activities and includes the cost ofmeeting 10 CFR 20.1402 for license termination for unrestricted use. Therevised estimate assumes a contingency factor of 25o/o. The totaldecommissioning cost with contingency is $7,891,300 (2014 dollars).Below is the effect of the following on the detailed cost estimate since theprevious report:1. Spills of radioactive material producing additional residual radioactivity inonsite subsurface material: None2. Facility modifications: None3. Changes in authorized possession limits: None4. Actual remediation costs that exceed the previous cost estimate: None  L-15-327Page 2 of 33.4.ldentification of and justification for using the key assumptions containedin the decommissioning cost estimate:The ISFSI decommissioning cost estimate key assumptions and justifications areprovided in Enclosure C.A description of the method of assuring funds for decommissioning from10 CFR 72.30(e), including means for adjusting cost estimates andassociated funding levels periodically over the life of the facility:Financial assurance in the amount of $9,250,000 for the decommissioning of thePNPP ISFSI is provided through two parent guarantees totaling $24.5 million(Accession Nos. ML141838295 and ML151814323) that support the lSFSlslocated at Beaver Valley Power Station, Davis-Besse Nuclear Power Station, andPNPP. These guarantees will be payable to the existing nuclear decommissioningtrust funds established for PNPP pursuant to the nuclear decommissioning mastertrust agreements. The guarantees will provide for the ISFSI decommissioningamounts to be deposited into a separate subaccount to be maintained by theTrustee.10 CFR 30, Appendix A, "Criteria Relating to Use of Financial Tests and ParentCompany Guarantees for Providing Reasonable Assurance of Funds forDecommissioning," provides guidance for establishing parent guarantees toprovide assurance for decommissioning funding. The test includes the currentcost estimate for decommissioning and the amount to be guaranteed. Theregulation requires the test to be performed annually. The performance of thetest, with the current decommissioning cost estimate, provides information suchthat the values of the parent guarantees can be adjusted to ensure that adequatefunding will be available to decommission the lSFSl.The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination:PNPP uses the Holtec International HI-STORM system for spent fuel storage.The HI-STORM cask has been designed to assure that there is no release ofradioactive materials to the environment. As a result, FENOC assumes thevolume of onsite subsurface material containing residual radioactivity that willrequire remediation to meet the criteria for license termination to be zero.5. L-15-327Page 3 of 3A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning:The submission of this report in conjunction with the two parent guaranteestotaling $24.5 million (Accession Nos. ML14183B295 and ML15181A323) servesas certification that financial assurance has been provided in the amount of thecost estimate for ISFSI decommissioning.
Enclosure AL-15-327Beaver Valley Power Station, Unit Nos. 1 and 2, Independent Spent Fuel StorageInstallation Decommissioning Cost Estimate(Six Pages Follow)
Fir stE ner gy C orp oratio nBeaver Vallev Power Station ISFSIF07- 1 69 1 -1 4002 ; Attiichment IPage l of 61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June 17 ,20ll,t'l with the rule becoming effective on December 17 ,2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning,'o requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Beaver Valley Power Station (Beaver Valley) in anamount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.Spent Fuel Management StrategyBeaver Valley's operating licenses were renewed effective November 9, 2009. Thescheduled license termination dates for Beaver Valley Units I and2 are January 29,2036, andMay 27,2047, respectively. Currently, 5,010 spent fuel assemblies areprojected to be discharged over the operating life of the two units. If DOE is able toinitiate acceptance of commercial spent fuel in 2025,2,346 assemblies are projected to beshipped during plant operations or within seven years following the cessation ofoperations (during which time the spent fuel pools are operational). For the purpose ofthis analysis, the remaining2,664 assemblies would be placed in dry storage at an on-siteISFSI. The ISFSI would operate (under a Part 50 General License) until the transfer ofspent fuel to the DOE is completed. At that time, the ISFSI could be decommissioned.U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 20 I I .2.TLG Semices,Inc.
3.Fir stE nergt Co rp o r atia nBeaver VaUey Power Station ISFSIF 0 7- 1 69 1 - 1 4 0 0 2 ; Attachment 1Page 2 of 6Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations 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 thereactor.l'l FirstEnergy Corporation's current spent fuel management plan for the BeaverValley spent fuel is based in general upon completion of spent fuel receipt by no laterthan the year 2075.ISFSI Decom missioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing of residual radioactivity and veriffing that remaining materialssatisff NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning alternative identified for the nuclear power plant.ISFSI DescriptionThe Beaver Valley ISFSI currently uses a Transnuclear NUHOMS system (with a 37-fuelassembly capacity) for spent fuel storage. The system consists of a multi-purpose (storageand transport) dry shielded storage canister (DSC) and a horizontal storage module(HSIO. The DSCs are assumed to be transferred directly to the DOE and not returned tothe station. Some of the remaining HSMs are assumed to have residual radioactivity dueto some minor level of neutron-induced activation as a result of the long-term storage ofthe spent fuel. The cost to dispose of residual radioactivity, and verify that the remainingfacility and surrounding environs meet the NRC's radiological limits established forunrestricted use, form the basis of the ISFSI decommissioning estimate.In addition to the spent fuel casks located on the ISFSI pad after shutdown there may beadditional casks used for Greater-than-Class-C (GTCC) storage. The HSMs used to storethe GTCC canisters (estimated quantity of 8) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final stafus survey.Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.' U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) "... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfrom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ..."TLG Services,Inc.4.
5.F irstE n eryyt C orp o r ati.o nBeaver Valley Power Station ISFSI' Email Matt Minniti to Francis Seymore, November 18,2014.TLG Sewices,Inc.F07-1 69 1-1 4002; Attachment IPage 3 of 6Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (Beaver Valley IJnit? operating until2047 , and the assumptionsassociated with DOE's spent fuel acceptance, as previously described).The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 90 feet in width, and 400 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a t00Yo survey of the concrete HSMsurfaces, and a significant fraction of the ISFSI pad and the immediate area surroundingthe pad, and the other ISFSI structures.It is not expected that the HSMs will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelysmall. To validate this assumption, the estimate accounts for further characterization of10% of the HSMs; it is likely that some of this characterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefinitive decommissioning scope.The decommissioning estimate conservatively assumes that l0 HSMs (equivalent to thenumber of casks to store the final full core offloads for both units) will contain low levelsof neutron-induced residual radioactivity that would necessitate remediation at the timeof decommissioning. For purposes of this estimate, these HSMs are designated forcontrolled disposal as lowlevel radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the HSMs are removed, the cask transporter, or other facilities at the BeaverValley ISFSL IT is expected that these assumptions would be confirmed as a result ofgood radiological practice of surveying potentially impacted areas after each spent fueltransfer campaign. As such, only verification surveys are included for the other facilitiesin the decommissioning estimate.The ISFSI was constructed upon part of the property that was released as a result of thedecommissioning of the Shippingport Atomic Power Station by the U.S. Department ofEnergy in 1989. The pad area was excavated down approximately 15 feet, and backfilledwith clean engineered fill. The surrounding ISFSI areas were not disturbed, and remain asleft by the DOE, other than a topcoat of gravel. As such, the decommissioning estimateassumes that no soil remediation is required [3], to meet the unrestricted use criteria of 10cFR 20.1402.
Fir stE ner gt C orp o r ationBeaver Valley Power Station ISFSIF07-1 69 1- 1 4 002 ; Attachment IPage 4 of 66.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergyCorporation, as licensee, will oversee the site activities; the estimate includes FirstEnergyCorporation's labor and overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corporation's existing contracted disposal rates.Costs are reported in20l4 dollars.Contingency has been added at an overall rate of 25o/o. This is consistent with thecontingincy evaluation criteria referenced by the NRC in NUREG-1757.I41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 criteriafor unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.The cost has been organized into three phases, including:An initial planning phase - empty HSMs are characterized and the specifications andwork procedures for the decontamination (liner removal) developed.The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as lowlevel waste.The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningservices, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorporation's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2076,the year following the last of the spent fuel removal.4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l,February 2012.TLG Services,Inc.
FirstEn ergt CorporationBewer Vallev Power StationTLG Semices, Inc.F07-1 69 1 -l 4002 : Afrachmmt 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLensth (ft)widrh (ft)ResidualRadioactivitvISFSI Pad (dimensions are for current pad)30090NoISFSI Pad Exoansion (dimensions are for exoansion)10090NoISFSI Horizontal Storage ModulesltemValueNotes (all dimensions are nominal)Overall Length (inches)244HSM dimensions based uponOverall Width (inches)116Transnuclear HSM-H desienOverall Heieht (inches)2226uantitv (f.nfsl)72Quantity (with residual radioactivity)t0Equivalent to the number of HSMsneeded to store the last core ofrloadsfrom both units at Beaver VallevTotal Surface Area of HSM interior with ResidualRadioactivitv (so uare feet)7,500Low-Level Radioactive Waste (cubic feet)21.853low-Level Radioactive Waste (packaged density)151Most weight shipped as concrete slabsOther Potentially Impacted ItemsItemValueNotesCask TransoorterINo residual radioactivityISFSI Equipment Storaee BuildineINo residual radioactivityNumber of HSMs used for GTCC storaee8No residual radioactivitv Firx,t E n e rg) C o rp o r ali onBeaver Valley Power StaionTable 2ISFSI Decomrnissioning Costsr and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2076TLG Semiceg Inc.F0 7 - 1 69 1 - 1 4002 ; Attachment IPage 6 of 6(Thousande, 2014 dollars)Person-HoursDeconRemovalTransnortDisnosalOtherTotalWasteVolume1fr3\CraftOversight andDecommissioningCnntmr.fnrPlanning (characterization,cnacc qnrl n:nnartrrroc\2182r8t,096Remediation/oar'irrorod lfSMo\25048532.1065283.7412r,8532.O921861.1869.234Srrhlolal26048632-1061.9326.14621.8631.fl27r.096Sunoortino CostsNRC and NRC CrntractorFees and Costs384384lnsurance65ODProDertv taxesffir331Cornorate A&Ga282Securitv (industrial)481485.020FirstEnergy CorporationOwcrsicht Staff2592593.803Subtotal7-2701.2709.699Total (w/o continEenev)26048682.1063.2026.4162r.868r1.327r0.696T otal (w 1260/" ontinpeno)8.0r8 Enclosure BL-15-327Davis-Besse Nuclear Power Station, Unit No. 1 Independent Spent Fuel StorageInstallation Decommissioning Cost Estimate(Six Pages Follow)
FirstEnergt Corp.Davis-Besse Nuclear Power Station.LSf',SIF07-1 698-1 5003 ; Attachment 1Page I of61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June 17,20ll,t'l with the rule becoming effective on December 17,2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Davis-Besse Nuclear Power Station (Davis-Besse) in anamount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in l0CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.2. Spent Fuel Management StrategyDavis-Besse's scheduled license termination date is April 22, 2017 . Currently , l ,452spent fuel assemblies are projected to be discharged over the operating life of the unit. IfDOE is able to initiate acceptance of commercial spent fuel in 202l,the first spent fuelassemblies from Davis-Besse are projected to be shipped by 2026. For the purpose of thisanalysis, all of the 1,452 assemblies would be placed in dry storage at an on-site ISFSI.The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, theISFSI could be decommissioned.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelt U.S. Code of Federal Regulations, Title 10, Parts 20,30,40, 50, 70 andT2 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June I 7, 201 I .TLG Semices,Inc.
3.FirstEnergt Corp.Davis-Besse Nuclear Power Station.LsffSlF 07- 1 69 8- 1 5 00 3 ; Attac hment IPage 2 of 6allocations 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 thereactor.[2] FirstEnergy Corp. current spent fuel management plan for the Davis-Bessespent fuel is based in general upon completion of spent fuel receipt by no later than theyear 2056.ISFSI Decom missioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing oiresidual radioactivity and verifying that remaining materialssatis$ NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning altemative identified for the nuclear power plant.ISFSI DescriptionThe dry fuel storage system consists of a TransnuclearNUHOMS multi-purpose (storageand transport) dry shielded storage canister (DSC) and a horizontal storage module(HSM). The Davis-Besse ISFSI expects to use three different versions of the system.There are three modules currently on the ISFSI pad with 24-assembly capacity DSCs. Ascheduled 2017 campaign will load four 32-assembly capacity DSCs. All subsequentspent fuel DSC loadings are planned using a 37-fuel assembly capacity DSC. The DSCsaie assumed to be transfened directly to the DOE and not returned to the station. Some ofthe remaining HSMs are assumed to have residual radioactivity due to some minor levelof neutron-induced activation as a result of the long-term storage of the spent fuel. Thecost to dispose of residual radioactivity, and veriff that the remaining facility andsurrounding environs meet the NRC's radiological limits established for unrestricted use,form the basis of the ISFSI decommissioning estimate.In addition to the spent fuel modules located on the ISFSI pad after shutdown there maybe additional HSMs used for Greater-than-Class-C (GTCC) storage. The HSMs used tostore the GTCC canisters (estimated quantity of 4) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final status survey.Table I provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.t U.S. Code of Federal Regulations, Title 10, Part 961.1l, Article IV - Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) "... DOg shall issue an annual acceptance prioriry ranking for recerpt 9f SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfiom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ...'oTLG Services,Inc.4.
FirstEnergy Corp.Davis-Besse Nuclear Power Statinn ISF,SIF0 7- 1 69 8- 1 5 0 03 ; Attachment IPage 3 of 65. Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (operating until 2017), and the assumptions associated with DOE'sspent fuel acceptance, as previously described.The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 88 feet in width, and344 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a l00o/o survey of the concrete HSMsurfaces, and a significant fraction of the ISFSI pad and the immediate area surroundingthe pad, and the other ISFSI structures.It is not expected that the HSMs will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelystnail. To validate this assumption, the estimate accounts for further characteization of10% of the HSMs; it is likely that some of this charucterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefinitive decommissioning scope.The decommissioning estimate conservatively assumes that 5 HSMs (equivalent to thenumber of HSMs to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning. For purposes of this estimate, these HSMs are designated forcontrolled disposal as low-level radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the HSMs are removed, the transfer cask and transporter, or other facilities atthe Davis-Besse ISFSI. It is expected that these assumptions would be confirmed as aresult of good radiological practice of surveying potentially impacted areas after eachspent fuel transfer campaign. As such, only verification surveys are included for the otherfacilities in the decommissioning estimate.A review of drawing and pictures taken during the pad construction identified no pipingrunning under the pad. A duct bank going East-West under the pad can be identified.The area of the pad plus five feet on each side was excavated down to undisturbed soiland then refilled with an engineered backfill prior to pouring the pad. At this time thereis no reason to believe the soil under the pad has been contaminated. As such, thedecommissioning estimate assumes that no soil remediation is required t3l, to meet theunrestricted use criteria of 10 CFR 20.1402.3 Email Matt Minniti to Francis Seymore, February 25,2015.TLG Services,Inc.
FirstEnergt Corp.Davis-Besse Nuclear Power Station.LSESlF 0 7- 1 69 8- 1 5 003 ; Attachment 1Page 4 of 66.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergy Corp.,as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. laborand overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.Costs are reported in20l4 dollars.Contingency has been added at an overall rate of 25o/o. This is consistent with thecontinfency evaluation criteria referenced by the NRC in NUREG-I757.t41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 critefiafor unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.T\e cost has been organized into three phases, including:An initial planning phase - empty HSMs are characterized andthe specifications andwork procedures for the decontamination (heat shields and rails) developed.The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as low-level waste.The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningservices, the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorp's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2057,the year following the last of the spent fuel removal.4 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l, February 2012.TLG Services,Inc.
FintEnergt Corp.Davis-Besse Nuclear Power StationTLG Semices, Inc.F07-1 698-1 5003 : Afrachment 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLeneth (ft)width (ft)ResidualRadioactivifwISFSI Pad (dimensions are for current pad)22988NoISFSI Pad Flxnansion (dimensions are for exnansion)11588NoISFSI Horizontal Storage ModulesItemValueNotes (all dimensions are nominal)Overall Lencth (inches)248HSM dimensions based uponOverall Width (inches)116Transnuclear HSM-H desisnOverall HeiEht (inches)222Ouantitv (total)45Quantity (with residual radioactivity)oEquivalent to the number of HSMsneeded to store the last core offloadfrom Davis-BesseTotal Surface Area of HSM interior with ResidualRadioactivitv (souare feet)3.750Low-Level Radioactive Waste (cubic feet)r 1,356low-l,evel Radioactive Waste (packaeed densitv)lDoMost weieht shipped as concrete slabsOther Potentially Impacted ltemsItemValueNotesCask TlansoorterNo residual radioactivitvISFSI Eouioment Storase BuildinsINo residual radioactivitvNumber of HSMs used for GTCC storage4No residual radioactivity FirstEnergt Corp.Dwis-Besse Nuclear Power StalionTable 2ISFSI Decomrnissioning Costsl and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2057TLG Semices, Inc.F0 7 - 1 69 8- I 500 3 ; Attachment IPage 6 ot6(Ihoueands. 2014 dollars)Person-HoursDeconRemovalPackasinsTransoortDisnosalOtherTotalWasteVolumel/frc\CraftOversight andDecomissioningContrac-torPlanning (characterization,snec-s and nrocedures)r86186L,024Rerrecliationlsctiwaf.pd HSMs\516t.t425632.442l.doo1.880License Terrnination(radiologica l srrrocls)8058056.434Subtotal21735161.1121.6643.452r1.3568.3131.024Supportins CostsNRC and NRC ContractorFees and Costs384384a aoInsumncebDooProDertv tiles6262Comorate A&G4444Secuitv (industrial)t481485.013FirstEnergy Corp.Oversieht StaffqRo2593.803Subtotal962s629.5922173616r.1422-6164.395r13668.31310.616T otal (w I 260/o contin gencv)5-493 Enclosure CL-15-327Perry Nuclear Power Plant, Unit No. 1 Independent Spent Fuel Storage InstallationDecommissioning Cost Estimate(Six Pages Follow)
FirstEnergt Corp.Perry Nuclear Power Plant ISFSIF07-1 699-1 5003 ; Attachment IPage 1 of 61.10 CFR 72.30ISFSI Decommissioning Cost EstimateBackground and IntroductionThe Nuclear Regulatory Commission (NRC) issued its final rule on DecommissioningPlanning on June l7,207l,tll with the rule becoming effective on December 17,2012.Subpart 72.30,"Financial assurance and recordkeeping for decommissioning," requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).In accordance with the rule, this letter provides a detailed cost estimate fordecommissioning the ISFSI at Perry Nuclear Power Plant (Perry) in an amount reflecting:1. The work is performed by an independent contractor;2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This letter also provides:1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity,that will require remediation to meet the criteria for license termination.2, Spent Fuel Management StrategyPerry's scheduled license termination date is March 18,2026. Currently, 6,233 spent fuelassemblies are projected to be discharged over the operating life of the unit. If DOE isable to initiate acceptance of commercial spent fuel in 2025,the first spent fuelassemblies from Perry are projected to be shipped by 2034. For the pulpose of thisanalysis, all of the 6,233 assemblies would be placed in dry storage at an on-site ISFSI.The ISFSI would operate (under a Part 50 General License in accordance with 10 CFR 72Subpart K) until the transfer of spent fuel to the DOE is completed. At that time, theISFSI could be decommissioned.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations will be accepted for disposal from the nation's commercial nuclear plants,t U.S. Code of Federal Regulations, Title 10, Paxts 20,30,40, 50, 70 and 72 "Decommissioning Planning,"Nuclear Regulatory Commission, Federal Register Volume 76, Number ll7 (p 35512 et seq.), June 17, 201 I .TLG Semices,Inc.
3.FirstEnergt Corp.Perry Naclear Power Plant ISFSIF07- 1 699- 1 5003 ; Attachment IPage 2 of 6with limited exceptions, in the order (the "queue") in which it was discharged from thereactor.[2] FirstEnirgy Corp. current spent fuel management plan for the Perry spent fuelis based in general upon completion of spent fuel receipt by no later than the year 2064.ISFSI Decommissioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI can be decommissioned byremoving and disposing of residual radioactivity and verifuing that remaining materialssatisfu NRC release criteria.For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimatethe ISFSI decommissioning is considered an independent project, regardless of thedecommissioning alternative identified for the nuclear power plant.ISFSI DescriptionThe dry fuel storage system consists of a Holtec Intemational HI-STORM 100S System(with a 68-fuel assembly capacity). The system consists of a multi-purpose (storage andtransport) canister (MPC) and a concrete shield (overpack). The MPCs are assumed to betransferred directly to the DOE and not returned to the station. Some of the remainingconcrete overpacks are assumed to have residual radioactivity due to some minor level ofneutron-induced activation as a result of the long-term storage of the spent fuel. The costto dispose of residual radioactivity, and verif that the remaining facility and surroundingenvirons meet the NRC's radiological limits established for unrestricted useo form thebasis of the ISFSI decommissioning estimate.In addition to the spent fuel casks located on the ISFSI pad after shutdown there may beadditional casks used for Greater-than-Class-C (GTCC) storage. The overpacks used tostore the GTCC canisters (estimated quantity of 5) are not expected to have any interiorcontamination or residual activation and can be reused or disposed of by conventionalmeans after a final status survey.Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.2 U.S. Code of Federal Regulations, Title 10, Part 96l.ll, Article IV - Responsibilities of the Parties, B' DOEResponsibilities, 5.(a) '.. . IOB shall issue an annual acceptance priority ranking for receipt of SNF and/orHLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculatedfrom the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or wastewill have the highest priority for acceptance, except as ..."TLG Services,Inc.4.
FirstEnergy Corp.Perry Nuclear Power Plant ISFSIF07- 1 699- 1 5 003 ; Attachment 1Page 3 of 65. Key Assumptions / Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI at the cessationof plant operations (operating until2026), and the assumptions associated with DOE'sspent fuel acceptance, as previously described.The nominal size of the ISFSI pad to store the projected amount of spent fuel is expectedto be approximately 75 feet in width, and 453 feet in length.To support an application for License Termination, the estimate assumes that a FinalStatus Survey will be performed; this will include a l00Yo survey of the concreteoverpack surfaces, and a significant fraction of the ISFSI pad and the immediate ateasurrounding the pad, and the other ISFSI structures.It is not expected that the overpacks will have any interior or exterior radioactive surfacecontamination. It is expected that this assumption would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. Any neutron activation of the steel and concrete is expected to be extremelysmall. To validate this assumption, the estimate accounts for further chatactetization of10% of the overpacks; it is likely that some of this characterization will take place wellbefore the last of the fuel is removed from the ISFSI in order to establish a moredefrnitive decommissioning scope.The decommissioning estimate conservatively assumes that 11 overpacks (equivalent tothe number of casks to store the final full core offload) will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning. For purposes of this estimate, these overpacks are designated forconholled disposal as low-level radioactive waste.It is not expected that there will be any residual contamination left on the concrete ISFSIpad once the overpacks are removed, the cask transporter, or other facilities at the PerryISFSI. It is expected that these assumptions would be confirmed as a result of goodradiological practice of surveying potentially impacted areas after each spent fuel transfercampaign. As such, only verification surveys are included for the other facilities in thedecommissionine estimate.FENOC Ct"-irlw reviewed the I0CFR 50.7SgfiIes that it maintains and found nomention of any contaminated soil found as a result of building the ISFSI pad. As such,the decommissioning estimate assumes that no soil remediation is requi..d t'1, to meet theunrestricted use criteria of 10 CFR 20.1402.Decommissioning is assumed to be performed by an independent contractor. As such,essentially all labor, equipment, and material costs are based on national averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data' Email Matt Minniti to Francis Seymore, March 3, 2015.TLG Services,Inc.
FirstEnerglt Corp.Perry Nuclear Power Plant ISFSIF07-I 699-1 5 003 ; Attachment IPage 4 ot6(adjusted for regional variations), and laboratory service costs are based on vendor pricelists. Those craft labor positions are expected to be provided locally. FirstEnergy Cotp.,as licensee, will oversee the site activities; the estimate includes FirstEnergy Corp. laborand overhead costs.Low-level radioactive waste packaging and transport costs are based on industry data.Disposal costs are based on FirstEnergy Corp. existing contracted disposal rates.Costs are reported in2014 dollars.Contingency has been added at an overall rate of 25%o. This is consistent with thecontingincy evaluation criteria referenced by the NRC in NUREG-I757.t41The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meetthe $20.1402 criteria for unrestricted use. Disposition of released material and structuresis outside the scope of the estimate.6. Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2.T\e cost has been organized into three phases, including:o An initial planning phase - empty overpacks are characterized and the specificationsand work procedures for the decontamination (steel liner removal) developed.o The remediation phase - residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of as low-level waste.o The final phase - license termination surveys, independent surveys are completed, andan application for license termination submitted.In addition to the direct costs associated with a contractor providing the decommissioningserviceso the estimate also contains costs for the NRC (and NRC contractor), FirstEnergyCorp's oversight staff, site security (industrial), and other site operating costs.For estimating purposes it should be conservatively assumed that all expenditures will beincurred in the year 2065,the year following the last of the spent fuel removal.a "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," IJ.S'Nuclear Regulatory Commission's Offrce of Nuclear Material Safety and Safeguards, NUREG-1757, Volume3, Revision l,February 2012.TLG Services,Inc.
FirctEnergt Corp.Perry Nuclear Planl StationTLG Semices, Inc.F0 7- 1 69 9- 1 5 00 3 ; Attachment 1Page 5 of 6Table ISignificant Quantities and Physical DimensionsISFSI PadItemLeneth (ft)width (ft)ResidualRadioactivitvISFSI Pad (dimensions are for current pad)347toNoISFSI Pad Expansion (dimensions are for expansion)105.5toNoISFSI Storage OverpackItemValueNotes (all dimensions are nominal)Overall Heieht (inches)2t8.5Outside Diameter (inches)r32.5Inside Diameter (inches)73.5Inner Liner Thickness (inches)1.0Chrqntifv (fnfsl)9792 spent fuel + 5 GTCCQuantity (with residual radioactivity)11Equivalent to the number ofOverpacks needed to store the lastcore offload from PerrvTotal Surface Area of Overpack Liner with ResidualRadioactiwitv (souare feet)3.750Iow-Level Radioactive Waste (cubic feet)11.356Low-Level Radioactive Waste (packased densitv)rooAverase weisht densitvOther Potentially Impacted ltemsItemValueNotesCask ThansoorterINo residual radioactivitvISFSI Eouioment Storaee BuildineINo residual radioactivitvNumber of Overpacks used for GTCC storaseaNo residual radioactivitv FirstEnergt Corp.Perry Nuclear Plant StationTable 2ISFSI Decomrnissioning Costst and Waste VolumesNote 1: For funding planning purposes decommissioning costs can be assumed to be incurred in year 2065TLG Semices. Inc.F07-1699-1 5003; Attachment IPage 6 of 6fThousands. 2014 dollars)Pe.rson-HourgDeconRemovalPackaeineTransnortDisnosalOf.herTotalWasteVolume/+t\Cra-ftOversight andConf.raelnrDecommissioningContractorPlanning (characterization,cnono and nrmodrrros\322.21.144.0Remediahon/a.fivot6.l ^tral521 2319 5450 61747.43.033.115.766.01.204.1Liense Terminationhdialnoiool orrnrorro\r.670_31.670.3Suhtntal621-2319_6,t50^6r.741-a1.992.66.026.616.766.01.204.r,144.0NRC and NRC Contractortrroao oni f'lnefo408.7408.7150.3150.3Prooertv taxes276.427A.8Cnmovatn A&G43.843.8Sperrritw ainductrial)407 A407.85,013FirstEnergy Corp.C)vprsishf. Staff1.247.5r.287.53,803Subtotal3.280.06-313.19.592Total (do mntinEencv)621.2319.6460.61.741.83.280.06-313-l15.766-Ot-204-l6.932.9T otal ( w D6o/" contincend)7.891.3}}

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