ML17208A130

Ltp Ch 7 Rev 1 021517 Redacted L

ML17208A130
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Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/27/2017
From:	EnergySolutions, ZionSolutions
To:	Division of Decommissioning, Uranium Recovery and Waste Programs
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ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN SECTION 7, REVISION 1 UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 TABLE OF CONTENTS

7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS .............................. 7-1 7.1. Introduction ................................................................................................................... 7-1 7.1.1. Cost Estimates Previously Docketed with the NRC .............................................. 7-2 7.2. Decommissioning Cost Estimate .................................................................................. 7-2 7.2.1. Cost Estimate Description and Methodology ........................................................ 7-3 7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate........................... 7-3 7.2.3. Radiological Decommissioning Costs ................................................................... 7-4 7.2.3.1. Class A Large Components ............................................................................. 7-6 7.2.3.2. Class A Bulk Materials .................................................................................... 7-6 7.2.3.3. Class A Containerized Wastes ......................................................................... 7-6 7.2.3.4. Class B/C Waste .............................................................................................. 7-6 7.2.4. Spent Fuel Management Costs............................................................................... 7-7 7.2.5. Site Restoration Costs ............................................................................................ 7-8 7.2.6. Contingency ........................................................................................................... 7-9 7.3. Decommissioning Funding Plan ................................................................................... 7-9 7.4. References ................................................................................................................... 7-11 LIST OF TABLES Table 7-1 Cost for Radiological Decommissioning, Spent Fuel Management, and Site Restoration............................................................................................................. 7-4 Table 7-2 Estimated Base Radiological Decommissioning Cost by Resource Category ...... 7-5 Table 7-3 Estimated Radiological Decommissioning Cost by Major Project Activity ......... 7-5 Table 7-4 Estimated Base Spent Fuel Management Cost by Major Resource....................... 7-8 Table 7-5 Estimated Site Restoration Cost by Major Resource Category ............................. 7-9 Table 7-6 Detailed Breakdown of Radiological Decommissioning Costs by Resource Requirement ........................................................................................................ 7-12 Table 7-7 Detailed Breakdown of Radiological Decommissioning Costs by Decommissioning Activity .................................................................................. 7-13 Table 7-8 Detailed Breakdown of Spent Fuel Management Costs by Resource Requirement ........................................................................................ 7-14 Table 7-9 Detailed Breakdown of Site Restoration Costs by Resource Requirement ......... 7-15 7-i

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 1 LIST OF ACRONYMS AND ABBREVIATIONS 2 ComEd Commonwealth Edison 3 Exelon Exelon Corporation 4 FRS Final Radiation Survey 5 FSAR Final Safety Analysis Report 6 GTCC Greater Than Class C 7 ISFSI Independent Spent Fuel Storage Installation 8 LTP License Termination Plan 9 NRC Nuclear Regulatory Commission 10 PSDAR Post-Shutdown Decommissioning Activities Report 11 TLG TLG Services, Inc.

12 WCS Waste Control Specialists 13 ZNPS Zion Nuclear Power Station 14 ZSRP Zion Station Restoration Project 7-ii

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 15 7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS 16 7.1. Introduction 17 In accordance with 10 CFR 50.82(a)(9)(ii)(F) (Ref 7-1) and Regulatory Guide 1.179 (Ref 7-2),

18 the updated site specific cost estimates and funding plans for the Zion Station Restoration Project 19 (ZSRP) are provided. Regulatory Guide 1.179 provides guidance on the details of the 20 information to be presented in the License Termination Plan (LTP).

21 The LTP must provide an estimate of the remaining decommissioning costs at the time of LTP 22 submittal and also compare these estimated costs with the present funds set aside for 23 decommissioning. If it is determined that there is a deficit in the present funding, the LTP must 24 indicate the means for ensuring that adequate funds are available to complete the 25 decommissioning.

26 The decommissioning cost estimate, at a minimum, needs to include an evaluation of the 27 following cost elements:

28

• Cost assumptions used, including contingency factor; 29

• Major decommissioning activities and tasks; 30

• Unit cost factors; 31

• Estimated costs of decontamination and removal of equipment and structures; 32

• Estimated costs of waste disposal, including disposal site surcharges; 33

• Estimated Final RadiationStatus Survey (FRSFSS) costs; and 34

• Estimated total costs.

35 The cost estimate should focus on the remaining work, detailed activity by activity, including 36 costs of labor, materials, equipment, energy, and services. The cost estimate should include the 37 cost of the planned remediation activities as well as the cost of the transportation and disposal of 38 the waste generated by the remedial work conducted.

39 Historical Perspective 40 By 1998, Exelon Corporation (Exelon), formerly Commonwealth Edison Company, or ComEd, 41 had completely shut down the two unit Zion Nuclear Power Station (ZNPS) and made plans to 42 implement a delayed-DECON decommissioning scenario, with decommissioning expected to 43 commence at the original license expiration date (November 14, 2013). As part of its post 44 shutdown planning, Exelon contracted a specialty decommissioning consultant, TLG Services, 45 Inc. (TLG) to develop a decommissioning cost estimate for the ZNPS Units 1 and 2. This cost 46 estimate was provided with the Post-Shutdown Decommissioning Activities Report (PSDAR) 47 (Ref 7-3) Exelon submitted in 2000 to the NRC.

48 Exelon later entered into discussions with EnergySolutions for the possible transfer of the ZNPS 49 licenses and the decommissioning fund to EnergySolutions to accelerate the decommissioning of 50 the plant. As part of its application for the license transfers, ZionSolutions, LLC, a wholly 51 owned subsidiary of EnergySolutions, amended the PSDAR and submitted it to the NRC in 52 2008. This amended PSDAR provided significant decommissioning cost milestone changes and 53 an estimate of expected decommissioning costs.

7-1

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 54 The license transfers were completed and ZionSolutions started decommissioning operations by 55 September 2010. In compliance with 10 CFR 50.75(f)(1) (Ref 7-4) and 10 CFR 50.82(a)(8)(v)-

56 (viii), ZionSolutions continues to demonstrate financial assurance on an annual basis.

57 7.1.1. Cost Estimates Previously Docketed with the NRC 58 Exelon submitted its PSDAR to the NRC on February 14, 2000. As previously noted, in 59 accordance with 10 CFR 50.82(a)(8)(iii), a Zion site-specific decommissioning cost estimate was 60 also prepared and submitted in a letter dated February 14, 2000 (Ref 7-5). This submittal, 61 docketed with the NRC, included an Attachment, Zion Nuclear Power Station Units 1 and 2 62 Site-Specific Decommissioning Cost Estimate which was the cost estimate study prepared by 63 TLG.

64 During the process of ZionSolutions, LLCs application to take over the licenses of Zion Units 1 65 and 2 from Exelon, ZionSolutions submitted an Amended PSDAR, including an estimate of 66 expected decommissioning costs, on March 18, 2008. This submittal was also docketed with the 67 NRC.

68 7.2. Decommissioning Cost Estimate 69 The decommissioning cost estimate presented herein represents the cost to complete the 70 remaining decommissioning work as of the end of the 3rd quarter 2014. This estimate was 71 prepared based upon the schedule of the remaining work, incorporating the experience that has 72 been gained while performing similar decommissioning tasks over the past four years. To a large 73 extent, this decommissioning cost estimate is based upon an existing and operating 74 decommissioning organization, in which actual contracts for services are already in place. As 75 such, there is a high degree of certainty regarding expected work productivity, the cost of labor 76 and the cost of services required to support the remainder of the project. The decommissioning 77 cost estimate also includes application of contingency, as specific provision for unforeseeable 78 elements of cost within the defined project scope. Contingencies are particularly important 79 where previous experience has shown that unforeseeable events, which may increase costs, are 80 likely to occur. The contingency, as used in this estimate, does not account for price escalation 81 and inflation in the costs of decommissioning over the remaining project duration.

82 The cost estimate was prepared to include all costs associated with the decommissioning and 83 unrestricted release of the Zion site other than the area bounded by the Independent Spent Fuel 84 Storage Installation (ISFSI), and includes radiological decommissioning (i.e., those costs 85 required to accomplish such unrestricted release), spent fuel management (transfer of the spent 86 fuel to the ISFSI and operation of the ISFSI until the partial site release is achieved, at which 87 time the released portion of the site and the remaining ISFSI will be transferred back to Exelon),

88 and site restoration (i.e., non-radiological remediation aimed at leaving the site in a safe and 89 stable condition). As was reflected in the Application relating to the transfer of the Zion licenses 90 to ZionSolutions, Exelon has retained title to the spent fuel and Greater Than Class C (GTCC) 91 waste, as well as the obligation for ultimate disposition of the spent fuel and the GTCC waste in 92 the ISFSI and the decommissioning of the ISFSI.

93 The site-specific decommissioning cost estimate provided with this LTP has been prepared as a 94 collaborative effort by ZionSolutions and TLG and presents a breakdown of the remaining costs 7-2

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 95 to complete the decommissioning process and release all portions of the site for unrestricted 96 release, with the exception of the area bounded by the ISFSI.

97 The following subsections present a description of how the cost estimate was prepared and a 98 summary and breakdown of the estimated costs.

99 7.2.1. Cost Estimate Description and Methodology 100 During the summer and fall of 2014, the ZionSolutions decommissioning project organization 101 undertook an effort to update the baseline schedule, risks and the costs to complete the 102 decommissioning project. This resulted in a revised work breakdown structure that provided a 103 detailed listing of the remaining work activities and support services needed to complete the 104 project. Task durations, crew compositions and material and contracted services needs were 105 derived from the results of detailed process planning carried out by each of the decommissioning 106 and support organizations (e.g., decommissioning operations, engineering, security, radiation 107 protection, radiological engineering, waste management, safety, FRSFSS, etc.).

108 Additionally, ZionSolutions performed a contingency and risk analysis so that the potential 109 additional costs due to expected but undefined risks and uncertainties could be addressed and 110 included in the cost estimate.

111 The resulting information was then compiled into a decommissioning cost estimate by TLG. The 112 following sections provide a summary of those results.

113 7.2.2. Summary of the Site-Specific Decommissioning Cost Estimate 114 The overall remaining decommissioning cost (including scope risk contingency) was estimated 115 to be $389 Million (in year of expenditure dollars), with a base estimated cost of $358 Million 116 (without the scope risk contingency). The cost estimates include provisions for cost escalation 117 based upon the following assumptions:

118

• Labor costs are assumed to escalate at 1.992% per year, this cost escalation factor being 119 based on the forecast of the Consumer Price Index, Services, CUSASNS as published by 120 Global Insight Company, and applied per the Zion project Asset Sale Agreement.

121

• Non-Labor costs that are not covered by fixed prices, fixed rates or escalation provisions 122 in contractual agreements, are similarly assumed to escalate at 1.992% per year, this cost 123 escalation factor being based on the Consumer Price Index, Services, CUSASNS as 124 published by Global Insight Company, and applied per the Zion project Asset Sale 125 Agreement.

126

• For Class A and Class B&C waste costs, ZionSolutions has largely mitigated this 127 escalation risk by having a fixed price arrangement with EnergySolutions (Class A) and 128 contractually defined costs for B/C waste.

129 The cost estimate includes the costs for radiological decommissioning, spent fuel management, 130 and site restoration. A breakout of the cost for each part of the decommissioning program is 131 provided in Table 7-1.

7-3

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 132 Table 7-1 Cost for Radiological Decommissioning, Spent Fuel Management, 133 and Site Restoration Radiological Spent Fuel Site Restoration*

Decommissioning Management*

Base

$284.3 Million $37.4 Million $36.2 Million Amount

$24.7 Million $3.3 Million $3.2 Million Contingency Total $309.0 Million $40.7 Million* $39.4 Million*

134 *included for completeness, but not required for license termination funding purposes.

135 Detailed breakdowns of the estimated costs for radiological decommissioning, spent fuel 136 management and site restoration programs are provided in sections 7.2.3, 7.2.4 and 7.2.5, 137 respectively. Section 7.2.6 presents the estimated contingency costs for each of these programs.

138 7.2.3. Radiological Decommissioning Costs 139 Consistent with the NRC definition of decommissioning under 10 CFR 50.2, the radiological 140 decommissioning costs under this category consider only those costs associated with normal 141 decommissioning activities necessary for release of the site (other than the ISFSI) for 142 unrestricted use. It does not include costs associated with the disposal of non-radiological 143 materials or structures beyond those necessary to terminate the Part 50 license or the costs 144 associated with construction or operation of an ISFSI.

145 As summarized in section 7.2.2 above, the total estimated cost for radiological decommissioning, 146 including contingency is $309 Million. The estimated cost for the anticipated base work scope is 147 $284.3 Million. Application of a contingency of $24.7 Million results in a total estimated cost of 148 $309 Million.

149 The remaining decommissioning scope of work included in this estimate is described in detail in 150 other chapters of this LTP. Overall, that work scope includes completion of the removal, 151 transportation and disposal of the major components; completion of the removal, transportation 152 and disposal of the remaining equipment; decontamination and/or bulk demolition of 153 radiological impacted structures and transportation and disposal of the resulting radioactive 154 wastes; performance of the FRS FSS and associated license termination activities. The estimated 155 costs include the labor, equipment, materials, services and fees needed to conduct the work. The 156 estimated cost also includes all of the program support activities and services necessary to 157 manage and safely carry out a large scale dismantlement and demolition project. These program 158 support activities include project management, work controls and site administration; technical 159 support services, such as radiation protection, safety, engineering, security, QA/QC, 160 environmental monitoring, waste management and decommissioning subject matter experts 161 needed to support the project.

162 A high level breakdown of the estimated base radiological decommissioning cost, by major 163 resource category, is provided in Table 7-2.

7-4

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 164 Table 7-2 Estimated Base Radiological Decommissioning Cost by Resource Category Labor 1,407,354 person-hours (a) $119.8 Million (b)

Equipment, Materials and Supplies $24.9 Million Fixed- Price Contracts, Services & Fees $55.5 Million Radioactive Waste Packaging, Transportation & Disposal $84.1 Million Total (c) $284.3 Million 165 (a) Does not include contracted specialty service labor hours 166 (b) Includes contracted specialty labor costs 167 (c) Columns may not add due to rounding 168 A high level breakdown of the estimated radiological decommissioning cost, alternatively by 169 major project activity, is provided in Table 7-3.

170 Table 7-3 Estimated Radiological Decommissioning Cost by Major Project Activity Major Component Removal $30.8 Million Equipment and Structure Decontamination / Removal $63.8 Million Waste Disposition $84.1 Million Program Management and Support Services (excluding Final Status $75.7 Million Survey and License Termination Activities)

Final Radiation Status Survey and License Termination Activities $8.0 Million Other Lump-Sum Costs (e.g., regulatory fees, financing) $21.9 Million Total (a) $284.3 Million 171 (a) Columns may not add due to rounding 172 A more detailed breakdown of the costs by resource requirements (e.g., labor, materials, 173 services, etc.) and by decommissioning activity (e.g., component removal, structural 174 decontamination, program support functions, waste management functions, etc.) are provided in 175 Tables 7-6 and 7-7 respectively.

176 The total estimated cost for radioactive waste disposition (containers, transportation and 177 disposal) is $84.1 Million. As presented in Table 7-7, these waste management costs are 178 comprised of four distinct categories; Class A Large Components, Class B/C Waste, Class A 179 Containerized Wastes and Class A Bulk Materials. Costs for on-site handling of GTCC waste 180 (i.e., reactor vessel internals) are included in the Major Component Removal category shown 7-5

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 181 on Table 7-7. However, no costs for disposal of this waste is included in the estimate, as it is 182 assumed that disposal of this waste will be included as a part of spent fuel disposition.

183 The project has in place a unique contracting approach for disposal of the resulting radioactive 184 wastes that eliminates much of the cost uncertainty and waste volume estimation risk that is 185 often associated with decommissioning projects. As such, the reported waste management costs 186 are unlikely to vary due to waste volume uncertainties. The resulting radioactive waste streams 187 and the disposal and transportation contracts that are in place can be categorized by the 188 following:

189 7.2.3.1. Class A Large Components 190 This category of waste includes equipment that will be transported and disposed of intact, 191 enclosed in rail cars or prepared to serve as its own waste container. These items have been 192 radiologically and physically characterized. As such, the inventory of these items and their 193 disposal volumes are known. The associated waste management costs are covered by existing 194 fixed-price contracts with EnergySolutions. Therefore, the waste management costs for these 195 items are well known and not likely to vary. The cost for transportation and disposal of the large 196 components is included in the $68.8 Million fixed-price Class A bulk material disposal contract 197 (see Class A Bulk Materials). An additional cost of $0.206 Million is estimated for preparation 198 of the rail cars to accommodate the large components.

199 7.2.3.2. Class A Bulk Materials 200 This category of waste primarily consists of concrete rubble or similar materials contaminated 201 with very low levels of radioactivity (and large components described above). This material will 202 be transported in covered gondola rail cars to the EnergySolutions disposal site in Clive, Utah.

203 The cost for disposal and transportation of this material is covered by a fixed-price contract that 204 covers any and all material of this type from this decommissioning project, without regard to the 205 total mass or volume. Therefore, these costs are known and are unlikely to vary. This category of 206 waste comprises > 95% of the total volume and mass and > 80% of the estimated waste 207 management costs for all radioactive waste expected to be generated by this decommissioning 208 effort. The total cost for transportation and disposal of this material is $68.8 Million.

209 7.2.3.3. Class A Containerized Wastes 210 This category of waste primarily consists of material that will need to be packaged in strong-tight 211 / Industrial containers, such as intermodals or steel boxes. Typically, this would include small 212 pieces of contaminated equipment, pipe or debris which require containerization to meet DOT 213 regulations or mitigate radiological handling concerns. This material will be transported by rail, 214 for disposal at the EnergySolutions disposal site in Clive, Utah. The total cost for packaging, 215 transportation and disposal of this material is $1.2 Million.

216 7.2.3.4. Class B/C Waste 217 This category of waste is primarily composed of segmented pieces of the activated reactor 218 internals and, to a much lesser extent, higher radioactivity level resins, filters, sludge and cutting 219 fines. These materials will require packing in liners or high integrity containers, and transported 7-6

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 220 in shielded licensed transportation casks by truck to the Waste Control Specialists (WCS) facility 221 in Andrews, Texas. The volume (or mass) of this waste material is well known, characterized, 222 and will be generated from a limited set of reactor components. The total cost for packaging, 223 transportation and disposal of this material is $13.8 Million. Disposal cost variability for this 224 category of waste has been largely mitigated by established contractual terms in place with 225 WCS.

226 7.2.4. Spent Fuel Management Costs 227 ZionSolutions acknowledges that the costs to construct and operate an ISFSI (previously defined) 228 and other spent fuel related management costs are not considered by the NRC staff as part of 229 decommissioning costs. Nevertheless, as there is significant interest by many stakeholders in 230 these costs, they are presented herein. As presented in Section 7.2.2 above, the estimated cost for 231 the anticipated base work scope is $37.4 Million. A contingency of $3.3 Million was applied 232 resulting in total spent fuel management costs of $40.7 Million.

233 Overall, the spent fuel management work scope includes transfer of the remaining spent fuel to 234 the ISFSI and operation of the ISFSI until termination of the reactor license, with the exception 235 of the area bounded by the ISFSI, projected to take place in 2019.

236 Construction of the ISFSI was completed in April 2013 and spent fuel transfer operations were 237 started by December 2013 with the first spent fuel cask being placed on the ISFSI in early 238 January 2014. As of the end of September 2014, approximately 64% of the spent fuel has been 239 transferred to the ISFSI, contained in 39 dry storage casks on the ISFSI pad. Note that spent fuel 240 transfer was completed on January 10, 2015.

241 The estimated costs include the labor, equipment, materials, services, fees, and program support 242 activities necessary to safely manage the spent nuclear fuel. ISFSI operational costs are 243 estimated through mid-year 2019, when partial site release and the transfer of the site and ISFSI 244 back to Exelon are expected, and subsequent management of the spent fuel is consistent with the 245 Irradiated Fuel Management Plan for Zion under 10 CFR 50.54 (bb) (Ref 7-6). Exelon has 246 provided a decommissioning funding plan to the NRC for the Zion ISFSI (Ref 7-7).

247 A high level breakdown of the estimated base spent fuel management cost, by major resource 248 category, is provided in Table 7-4.

249 7-7

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 250 Table 7-4 Estimated Base Spent Fuel Management Cost by Major Resource Labor 117,668 person-hours (a) $29.9 Million (b)

Equipment, Materials and Supplies $1.3 Million Fixed- Price Contracts, Services & Fees $6.2 Million Radioactive Waste Packaging, Transportation & Disposal $0 Total (c) $37.4 Million 251 252 (a) Does not include contracted specialty service labor hours 253 (b) Includes contracted specialty labor costs 254 (c) Columns may not add due to rounding 255 A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, 256 etc.) is provided in Table 7.8.

257 7.2.5. Site Restoration Costs 258 ZionSolutions acknowledges that the costs to restore the Zion Plant property are not considered 259 by the NRC staff as part of decommissioning costs. Nevertheless, there is significant interest by 260 many stakeholders in these costs and they are presented herein. The estimated cost for the 261 anticipated work scope is $36.2 Million. A contingency of $3.2 Million was estimated, bringing 262 the total to $39.4 Million. Overall, that work scope includes removal of any remaining hazardous 263 materials, demolition of remaining structures, backfilling of any open excavations or void 264 spaces, and final grading and stabilization against erosion.

265 The estimated costs include the labor, equipment, materials, services and fees needed to conduct 266 the work. In general, most of this work is anticipated to be performed by contractors; however 267 the estimated cost also includes all of the program support activities and services necessary to 268 manage and safely carry out project.

269 A high level breakdown of the estimated site restoration cost, by major resource category, is 270 provided in Table 7-5.

271 7-8

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 272 Table 7-5 Estimated Site Restoration Cost by Major Resource Category Labor 53,541 person-hours (a) $58.8 Million (b)

Equipment, Materials and Supplies $0.71 Million Fixed- Price Contracts, Services & Fees $29.7 Million Radioactive Waste Packaging, Transportation & Disposal $0 Total (c) $36.2 Million 273 274 (a) Does not include contracted specialty service labor hours 275 (b) Includes contracted specialty labor costs 276 (c) Columns may not add due to rounding 277 278 A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, 279 etc.) is provided in Table 7.8.

280 7.2.6. Contingency 281 Uncertainty associated with the decommissioning cost estimate, and the need to allocate 282 additional funding to cover contingency for this project has been included in this estimate.

283 Accounting for contingency has been evaluated from two standpoints, operational efficiency and 284 scope expansion risk. Within the context of this cost estimate, operational efficiency contingency 285 is defined as the occurrence of events or circumstances that can prolong project duration or make 286 the execution of a given work scope more difficult. Examples of these types of events include 287 weather related delays, equipment or tool breakage or unavailability, and interferences from 288 other work activities. Scope expansion risk within the context of this estimate is defined as the 289 need to perform unplanned work activities or expansion of the work activities that were planned.

290 Examples of this type of project risk would be discovering new or additional contaminated media 291 requiring remediation, or a need to perform work in a different manner due to unforeseen 292 conditions or changes in requirements.

293 As was initially shown in section 7.2.2, contingency was estimated at $31.1 Million; apportioned 294 as $24.7 Million for radiological decommissioning, $3.3 Million for spent fuel management and 295 $3.2 Million for site restoration. This contingency was estimated using a quantitative Monte 296 Carlo type probability analysis, with the $31.1 Million amount corresponding to the resulting 85 297 percent confidence level amount.

298 7.3. Decommissioning Funding Plan 299 As indicated in section 7.2, the estimated cost to complete the radiological decommissioning of 300 the Zion nuclear station, including contingency, is $309 Million (year of expenditure dollars) as 301 of Sept 30, 2014. These decommissioning costs will be paid for with funds from the stations 302 nuclear decommissioning trust fund (NDT). Discounting those escalated costs at the rate of cost 303 inflation described in section 7.2.2 yields a cost of radiological decommissioning at constant 304 2014 dollars of $306.8 Million.

7-9

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 305 The actual cash balance of the NDT, as recorded by the ZionSolutions trustee as of Sept 30, 306 2014, was $344.9 Million. Recognizing that there were project costs incurred and recorded on 307 Sept 30, 2014 that had not been paid for from the NDT (outstanding disbursements), plus other 308 transactions in the last quarter of 2014 that have a bearing on these outstanding disbursements, 309 the net balance of the NDT available to cover the future costs of radiological decommissioning 310 was $317.1 Million.

311 Based on a time phased cash flow analysis of the radiological decommissioning costs, and 312 assuming NDT returns at an annual 2% real, after tax rate of return, the required minimum 313 funding assurance amount to fund the future radiological decommissioning costs equals $302.6 314 Million, which is below the $317.1 Million available balance described above.

315 This NDT position, together with EnergySolutions resources and the $200 Million Letter of 316 Credit backup for the NDT agreed with Exelon in the Zion Nuclear Power Station Unit 1 and 2 317 Asset Sale Agreement, that are available but are not relied upon here, provides for sufficient 318 funding and financial assurance for completion of radiological decommissioning of the Zion 319 Project.

320 On or before March 31, 2015, as required by 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)-

321 (viii), ZionSolutions will be submitting the annual demonstration of financial assurance for the 322 year ending Dec 31, 2014. That submission will be based upon future project costs of 323 radiological decommissioning and the NDT balance as of that date.

324 7-10

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 325 7.4. References 326 7-1 Code of Federal Regulations, Title 10, Part 50.82, Termination of License 327 7-2 US Nuclear Regulatory Commission Regulatory Guide 1.179, Revision 1, Standard 328 Format and Content of License Termination Plans for Nuclear Power Reactors, June 329 2011 330 7-3 Letter from ZionSolutions ,LLC to the U.S. Nuclear Regulatory Commission, 331 Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) 332 for Zion Nuclear Power Station, Units 1 and 2 in Accordance with 10 CFR 50.82(a)(7),

333 dated March 18, 2008 334 7-4 Code of Federal Regulations, Title 10, Part 50.75, Reporting and Recordkeeping for 335 Decommissioning Planning 336 7-5 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, 337 Submittal of the Zion Nuclear Power Station Site-Specific Decommissioning Cost 338 Estimate, dated February 14, 2000 339 7-6 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, 340 Submittal of the Zion Nuclear Power Station Irradiated Fuel Management Plan, dated 341 February 14, 2000 342 7-7 Letter from Exelon Generation to the U.S. Nuclear Regulatory Commission, Proposed 343 Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for 344 Zion, dated October 17, 2013 345 346 7-11

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 347 Table 7-6 Detailed Breakdown of Radiological Decommissioning Costs 348 by Resource Requirement Labor: TOTAL (1,407,354 person-hrs) $119.8 Million Craft (558,121 person-hrs) $38.6 Million Technician (214,828 person-hrs) $14.3 Million Professional (Sci. & Eng.) (455,015 $36.8 Million person-hrs)

Management (179,390 person-hrs) $18.1 Million Other - contract service labor $11.9 Million (Hours not reported)

Equipment & Materials: TOTAL $24.9 Million Durable Equipment $5.3 Million Consumable Supplies $16.0 Million Utilities and Energy $3.6 Million Contracts, Services & Fees: TOTAL $55.5 Million Equipment Rental <$0.1 Million Contracted Services $27.9 Million Laboratory & Analytical Services $1.8 Million Travel & Living $1.5 Million Insurance and Finance Fees $20.1 Million Licensee Fees & Permits $4.2 Million Radioactive Waste Packaging, TOTAL $84.1 Million Transportation & Disposal: Class A Waste $70.2 Million Class B/C Waste $13.8 Million TOTAL $284.3 Million 349 Columns may not add due to rounding 350 7-12

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 351 Table 7-7 Detailed Breakdown of Radiological Decommissioning Costs 352 by Decommissioning Activity Major Component TOTAL $30.8 Million Removal Reactor Vessels and Internals $21.1 Million Steam Generators $9.0 Million Pressurizers $0.7 Million SSC Removal and TOTAL $27.2 Million Decontamination Equipment Removal / Structural Decontamination $18.4 Million Bulk Structural Material Removal $7.9 Million In-process Characterization and Remedial Action $0.9 Million Support Waste Management TOTAL $84.1 Million Class B/C Waste: Packaging, Transportation and $13.8 Million Disposal Surveys and Sampling Class A Waste: Rail Car Preparation for $0.21 Million Large Components Class A Bulk Waste: Rail Car Transportation $68.8 Million and Disposal Class A Packaged Waste: Containers, $1.3 Million Transportation and Disposal Program Management TOTAL $120.3 Million and Support Services Program and Project Management and Site $32.1 Million Administration Technical Services and Services- (e.g., $47.9 Million Engineering, Rad. Protection, Environmental Monitoring, Site Characterization, Waste Mgmt, QA/QC, Safety, Worker Qualifications)

Security $7.7 Million Site O&M $4.9 Million Special Projects (Cold & Dark, Bld. Mods.) $8.5 Million Equipment, Materials, Consumable Supplies and $11.2 Million Utilities FSS, LT and Material Release Program $8.0 Million Other Lump-Sum Costs TOTAL $21.9 Million Financing $9.8 Million Regulatory Fees $12.1 Million TOTAL $284.3 Million 353 Columns may not add due to rounding 7-13

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 354 355 Table 7-8 Detailed Breakdown of Spent Fuel Management Costs 356 by Resource Requirement Labor: TOTAL (117,668 person-hrs) $29.9 Million Craft (43,045 person-hrs) $3.7 Million Technician (19,793 person-hrs) $1.5 Million Professional (Sci. & Eng.) (34,783 person-hrs) $3.7 Million Management (20,046 person-hrs) $1.8 Million Other (contract service labor, primarily security - $19.2 Million exclusive of management) (Hours not reported)

Equipment & TOTAL $1.7 Million Materials:

Durable Equipment <$0.1 Million Consumable Supplies $1.2 Million Utilities and Energy $0.4 Million Contracts, Services & TOTAL $5.8 Million Fees:

Equipment Related Services $1.3 Million Contracted Services (excluding security provided $2.2 Million in labor above)

Laboratory & Analytical Services <$0.1 Million Travel & Living <$ 0.1 Million Insurance, Finance, Licensee and Permit fees $2.3 Million Radioactive Waste TOTAL $0 Packaging, Transportation & Class A Waste $0 Disposal:

Class B/C Waste $0 TOTAL $37.4 Million 357 Columns may not add due to rounding 7-14

ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 358 Table 7-9 Detailed Breakdown of Site Restoration Costs by Resource Requirement Labor: TOTAL (53,541 person-hrs) $5.8 Million Craft (31,285 person-hrs) $2.2 Million Technician (2,963 person-hrs) $0.16 Million Management and Professional (Sci. & Eng.)

$1.9 Million (19,295 person-hrs)

Other- contract service labor (Hours not reported) $1.6 Million Equipment & Materials: TOTAL $1.2 Million Durable Equipment <$0.1 Million Consumable Supplies $0.7 Million Utilities and Energy $0.5 Million Contracts, Services & TOTAL $29.2 Million Fees:

Equipment Rental <$0.1 Million Contracted Services $27.6 Million Laboratory & Analytical Services <$0.1 Million Travel & Living <$0.1 Million Insurance, Finance, Licensee & Permit fees, $1.6 Million

$0 Radioactive Waste TOTAL Packaging, Transportation & Class A Waste $0 Disposal:

Class B/C Waste $0 TOTAL $36.2 Million 359 Columns may not add due to rounding 360 7-15