ML17208A130

Zion Ltp Ch 7 Rev 1 021517 Redacted L

ML17208A130
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/27/2017
From:	EnergySolutions, ZionSolutions
To:	Division of Decommissioning, Uranium Recovery and Waste Programs
Shared Package
ML17208A121	List: ML17208A019 ML17208A113 ML17208A114 ML17208A115 ML17208A116 ML17208A117 ML17208A119 ML17208A120 ML17208A122 ML17208A123 ML17208A125 ML17208A126 ML17208A127 ML17208A130 ML17208A131 ML17208A139 ML17208A140 ML17208A141 ML17208A142 ML17208A143 ML17208A144 ML17208A145 ML17208A146 ML17208A147 ML17208A148 ML17208A149 ML17208A150 ML17208A151 ML17208A152 ML17208A153 ML17208A154 ML17208A155 ML17208A156 ML17208A167 ML17208A168 ML17208A170 ML17208A171 ML17208A172 ML17208A173 ML17208A174 ML17208A175 ML17208A176 ML17208A177 ML17208A179 ML17208A181 ML17208A183 ML17208A184 ML17208A253 ML17208A254 ML17208A255 ... further results
References
Download: ML17208A130 (18)

Text

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

11 WCS Waste Control Specialists 12 ZNPS Zion Nuclear Power Station 13 ZSRP Zion Station Restoration Project 14 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-1 7. UPDATE OF THE SITE

-SPECIFIC DECOMMISSIONING COSTS 15 7.1. Introduction 16 In accordance with 10 CFR 50.82(a)(9)(ii)(F)

(Ref 7-1) and Regulatory Guide 1.179 (Ref 7

-2), 17 the updated site specific cost estimates and funding plans for the Zion Station Restoration Project 18 (ZSRP) are provided. Regulatory Guide 1.179 provides guidance on the details of the 19 information to be present ed in the License Termination Plan (LTP)

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

25 The decommissioning cost estimate

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

27 Cost assumptions used, including contingency factor; 28 Major decommissioning activities and tasks

29 Unit cost factors

30 Estimated costs of decontamination and removal of equipment and structures

31 Estimated costs of waste disposal

, including disposal site surcharges

32 Estimated Final RadiationStatus Survey (FRSFSS) costs; and 33 Estimated total costs

. 34 The cost estimate should focus on the remaining work, detailed activity by activity, including 35 costs of labor, materials, equipment, energy, and services.

The cost estimate should include the 36 cost of the planned remediation activities as well as the cost of the transportation and disposal of 37 the waste generated by the remedial work conducted.

38 Historical Perspective 39 By 1998, Exelon Corporation (Exelon), formerly Commonwealth Edison Company, or ComEd

, 40 had completely shut down the two unit Zion Nuclear Power Station (ZNPS) and made plans to 41 implement a delayed

-DECON decommissioning scenario, with decommissioning expected to 42 commence at the original license expiration date (November 14, 2013).

As part of its post 43 shutdown planning, Exelon contracted a specialty decommissioning consultant, TLG Services, 44 Inc. (TLG) to develop a decommissioning cost estimate for the ZNPS Units 1 and

2. This cost 45 estimate was provided with the Post-Shutdown Decommissioning Activities Report (PSDAR) 46 (Ref 7-3) Exelon submitted in 2000 to the NRC.

47 Exelon later entered into discussions with EnergySolutions for the possible transfer of the ZNPS 48 licenses and the decommissioning fund to EnergySolutions to accelerate the decommissioning of 49 the plant. As part of its application for the license transfers, ZionSolutions, LLC, a wholly 50 owned subsidiary of EnergySolutions

, amended the PSDAR and submitted it to the NRC in 51 2008. This amended PSDAR provided significant decommissioning cost milestone changes and 52 an estimate of expected decommissioning costs.

53 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-2 The license transfers were completed and ZionSolutions started decommissioning operations by 54 September 20

10. In compliance with 10 CFR 50.75(f)(1)

(Ref 7-4) and 10 CFR 50.82(a)(8)(v)

-55 (viii), ZionSolutions continues to demonstrate financial assurance on an annual basis.

56 7.1.1. Cost Estimate s Previously Docketed with the NRC 57 Exelon submitted its PSDAR to the NRC on February 14, 2000. As previously noted, i n 58 accordance with 10 CFR 50.82(a)(8)(iii),

a Zion site

-specific decommissioning cost estimate was 59 also prepared and submitted in a letter dated February 14, 2000 (Ref 7-5). This submittal

, 60 docketed with the NRC, included an Attachment, "Zion Nuclear Power Station Units 1 and 2 61 Site-Specific Decommissioning Cost Estimate" which was the cost estimate study prepared by 62 TLG. 63 During the process of ZionSolutions, LLC's application to take over the licenses of Zion Units 1 64 and 2 from Exelon, ZionSolutions submitted an Amended PSDAR, including an estimate of 65 expected decommissioning costs, on March 18, 2008. This submittal was also docketed with the 66 NRC. 67 7.2. Decommissioning Cost Estimate 68 The decommissioning cost estimate presented herein represents the cost to complete the 69 remaining decommissioning work as of the end of the 3 rd quarter 2014. This estimate was 70 prepared based upon the schedule of the remaining work, incorporating the experience that has 71 been gained while performing similar decommissioning tasks over the past four years. To a large 72 extent, this decommissioning cost estimate is based upon an existing and operating 73 decommissioning organization, in which actual contracts for services are already in place. As 74 such, there is a high degree of certainty regarding expected work productivity, the cost of labor 75 and the cost of services required to support the remainder of the project.

The decommissioning 76 cost estimate also includes application of contingency, as specific provision for unforeseeable 77 elements of cost within the defined project scope. Contingencies are particularly important 78 where previous experience has shown that unforeseeable events, which may increase costs, are 79 likely to occur. The contingency, as used in this estimate, does not account for price escalation 80 and inflation in the costs of decommissioning over the remaining project duration.

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

87 and site restoration (i.e., non

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

92 The site-specific decommissioning cost estimate provided with this LTP has been prepared as a 93 collaborative effort by ZionSolutions and TLG and presents a breakdown of the remaining costs 94 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-3 to complete the decommissioning process and release all portions of the site for unrestricted 95 release, with the exception of the area bounded by the ISFSI.

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

98 7.2.1. Cost Estimate Description and Methodology 99 During the summer and fall of 2014, the ZionSolutions decommissioning project organization 100 undertook an effort to update the baseline schedule, risks and the costs to complete the 101 decommissioning project. This resulted in a revised work breakdown structure that provided a 102 detailed listing of the remaining work activities and support services needed to complete the 103 project. Task durations, crew compositions and material and contracted services needs were 104 derived from the results of detailed process planning carried out by each of the decommissioning 105 and support organizations (e.g., decommissioning operations, engineering, security, radiation 106 protection, radiological engineering, waste management, safety, FRSFSS, etc.).

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

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

112 7.2.2. Summary of the Site

-Specific Decommissioning Cost Estimate 113 The overall remaining decommissioning cost (including scope risk contingenc y) was estimated 114 to be $389 Million (in year of expenditure dollars), with a base estimated cost of $358 Million 115 (without the scope risk contingency)

. The cost estimates include provisions for cost escalation 116 based upon the following assumptions:

117 Labor costs are assumed to escalate at 1.992% per year, this cost escalation factor being 118 based on the forecast of the Consumer Price Index, Services, CUSASNS as published by 119 Global Insight Company, and applied per the Zion project Asset Sale Agreement

. 120 Non-Labor costs that are not covered by fixed prices, fixed rates or escalation provisions 121 in contractual agreements, are similarly assumed to escalate at 1.992% per year, this cost 122 escalation factor being based on the Consumer Price Index, Services, CUSASNS as 123 published by Global Insight Company, and applied per the Zion project Asset Sale 124 Agreement

. 125 For Class A and Class B&C waste costs

, ZionSolutions has largely mitigated this 126 escalation risk by having a fixed price arrangement with EnergySolutions (Class A) and 127 contractually defined costs for B/C waste

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

-1. 131 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-4 Table 7-1 Cost for Radiological Decommissioning, Spent Fuel Management, 132 and Site Restoration 133 Radiological Decommissioning Spent Fuel Management

• Site Restoration

• Base Amount $284.3 Million $37.4 Million $36.2 Million Contingency

$24.7 Million $3.3 Million $3.2 Million Total $309.0 Million $40.7 Million* $39.4 Million* *included for completeness, but not required for license termination funding purposes.

134 Detailed breakdowns of the estimated costs for radiological decommissioning

, spent fuel 135 management and site restoration programs are provided in sections 7.2.3, 7.2.4 and 7.2.5

, 136 respectively.

Section 7.2.6 presents the estimate d contingency costs for each of these programs.

137 7.2.3. Radiological Decommissioning Costs 138 Consistent with the NRC definition of decommissioning under 10 CFR 50.2, the radiological 139 decommissioning costs under this category consider only those costs associated with normal 140 decommissioning activities necessary for release of the site (other than the ISFSI) for 141 unrestricted use. It does not include costs associated with the disposal of non

-radiological 142 materials or structures beyond those necessary to terminate the Part 50 license or the costs 143 associated with construction or operation of an ISFSI.

144 As summarized in section 7.2.2 above, the total estimated cost for radiological decommissioning

, 145 including contingency is $309 Million. The estimated cost for the anticipated base work scope is 146 $284.3 Million. Application of a contingency of $24.7 Million results in a total estimated cost of 147 $309 Million. 148 The remaining decommissioning scope of work included in this estimate is described in detail in 149 other chapters of this LTP. Overall, that work scope includes completion of the removal, 150 transportation and disposal of the major components; completion of the removal, transportation 151 and disposal of the remaining equipment; decontamination and/or bulk demolition of 152 radiological impacted structures and transportation and disposal of the resulting radioactive 153 wastes; performance of the FRS FSS and associated license termination activities. The estimated 154 costs include the labor, equipment, materials, services and fees needed to conduct the work. The 155 estimated cost also includes all of the program support activities and services necessary to 156 manage and safely carry out a large scale dismantlement and demolition project. These program 157 support activities include project management, work controls and site administration; technical 158 support services, such as radiation protection, safety, engineering, security, QA/QC, 159 environmental monitoring, waste management and decommissioning subject matter experts 160 needed to support the project.

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

-2. 163 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-5 Table 7-2 Estimated Base Radiological Decommissioning Cost by Resource Category 164 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 (a) Does not include contracted specialty service labor hours 165 (b) Includes contracted specialty labor costs 166 (c) Columns may not add due to rounding 167 A high level breakdown of the estimated radiological decommissioning cost, alternatively by 168 major project activity

, is provided in Table 7

-3. 169 Table 7-3 Estimated Radiological Decommissioning Cost by Major Project Activity 170 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 Survey and License Termination Activities)

$75.7 Million 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 (a) Columns may not add due to rounding 171 A more detailed breakdown of the costs by resource requirements (e.g., labor, materials, 172 services, etc.)

and by decommissioning activity (e.g., component removal, structural 173 decontamination, program support functions, waste management functions, etc.)

are provided in 174 Tables 7-6 and 7-7 respectively. 175 The total estimated cost for radioactive waste disposition (containers, transportation and 176 disposal) is $84.1 Million

. As presented in Table 7-7, these waste management costs are 177 comprised of four distinct categories; Class A Large Components

, Class B/C Waste, Class A 178 Containerized Wastes and Class A Bulk Materials

. Costs for on-site handling of GTCC waste 179 (i.e., reactor vessel internals) are included in the "Major Component Removal" category shown 180 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-6 on Table 7

-7. However, no costs for disposal of this waste is included in the estimate, as it is 181 assumed that disposal of this waste will be included as a part of spent fuel disposition.

182 The project has in place a unique contracting approach for disposal of the resulting radioactive 183 wastes that eliminates much of the cost uncertainty and waste volume estimation risk that is 184 often associated with decommissioning projects

. As such, the reported waste management costs 185 are unlikely to vary due to waste volume uncertainties. The resulting radioactive waste stream s 186 and the disposal and transportation contracts that are in place can be categorized by the 187 following:

188 7.2.3.1. Class A Large Components 189 This category of waste includes equipment that will be transported and disposed of intact, 190 enclosed in rail cars or prepared to serve as its own waste container

. These items have been 191 radiologically and physically characterized. As such, the inventory of these items and their 192 disposal volumes are known

. The associated waste management costs are covered by existing 193 fixed-price contracts with EnergySolutions

. Therefore, the waste management costs for these 194 items are well known and not likely to vary.

The cost for transportation and disposal of the large 195 components is included in the

$68.8 Million fixed-price Class A bulk material disposal contract 196 (see Class A Bulk Materials).

An additional cost of $0.206 Million is estimated for preparation 197 of the rail cars to accommodate the large components

. 198 7.2.3.2. Class A Bulk Materials 199 This category of waste primarily consists of concrete rubble or similar materials contaminated 200 with very low levels of radioactivity (and large components described above). This material will 201 be transported in covered gondola rail cars to the EnergySolutions disposal site in Clive, Utah.

202 The cost for disposal and transportation of this material is covered by a fixed

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

. 208 7.2.3.3. Class A Containerized Wastes 209 This category of waste primarily consists of material that will need to be packaged in strong

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

. 215 7.2.3.4. Class B/C Waste 216 This category of waste is primarily composed of segmented pieces of the activated reactor 217 internals and

, to a much lesser extent

, higher radioactivity level resins, filters, sludge and cutting 218 fines. These materials will require packing in liners or high integrity containers, and transported 219 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-7 in shielded licensed transportation casks by truck to the Waste Control Specialist s (WCS) facility 220 in Andrews, Texas. The volume (or mass) of this waste material is well known, characterized

, 221 and will be generated from a limited set of reactor components.

The total cost for packaging, 222 transportation and disposal of this material is $13.8 Million

. Disposal cost variability for this 223 category of waste has been largely mitigated by established contractual terms in place with 224 WCS. 225 7.2.4. Spent Fuel Management Costs 226 ZionSolutions acknowledges that the costs to construct and operate an ISFSI (previously defined) 227 and other spent fuel related management costs are not considered by the NRC staff as part of 228 decommissioning costs. Nevertheless, as there is significant interest by many stakeholders in 229 these costs, they are presented herein. As presented in Section 7.2.2 above, the estimated cost for 230 the anticipated base work scope is $37.4 Million. A contingency of $3.3 Million was applied 231 resulting in total spent fuel management costs of $40.7 Million. 232 Overall, the spent fuel management work scope includes transfer of the remaining spent fuel to 233 the ISFSI and operation of the ISFSI until termination of the reactor license, with the exception 234 of the area bounded by the ISFSI

, projected to take place in 2019

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

Note that spent fuel 239 transfer was completed on January 10, 2015.

240 The estimated costs include the labor, equipment, materials, services, fees, and program support 241 activities necessary to safely manage the spent nuclear fuel

. ISFSI operational costs are 242 estimated through mid

-year 2019, when partial site release and the transfer of the site and ISFSI 243 back to Exelon are expected, and subsequent management of the spent fuel is consistent with the 244 Irradiated Fuel Management Plan for Zion under 10 CFR 50.54 (bb) (Ref 7-6). Exelon has 245 provided a decommissioning funding plan to the NRC for the Zion ISFSI (Ref 7

-7). 246 A high level breakdown of the estimated base spent fuel management cost, by major resource 247 category, is provided in Table 7

-4. 248 249 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-8 Table 7-4 Estimated Base Spent Fuel Management Cost by Major Resource 250 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 (a) Does not include contracted specialty service labor hours 252 (b) Includes contracted specialty labor costs 253 (c) Columns may not add due to rounding 254 A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, 255 etc.) is provided in Table 7.8. 256 7.2.5. Site Restoration Costs 257 ZionSolutions acknowledges that the costs to restore the Zion Plant property are not considered 258 by the NRC staff as part of decommissioning costs. Nevertheless, there is significant interest by 259 many stakeholders in these costs and they are presented herein. The estimated cost for the 260 anticipated work scope is $

36.2 Million. A contingency of $3.2 Million was estimated, bringing 261 the total to $39.4 Million. Overall, that work scope includes removal of any remaining hazardous 262 materials, demolition of remaining structures, backfilling of any open excavations or void 263 spaces, and final grading and stabilization against erosion

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

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

-5. 270 271 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-9 Table 7-5 Estimated Site Restoration Cost by Major Resou rce Category 272 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 (a) Does not include contracted specialty service labor hours 274 (b) Includes contracted specialty labor costs 275 (c) Columns may not add due to rounding 276 277 A more detailed breakdown of the cost by resource requirements (e.g., labor, materials, services, 278 etc.) is provided in Table 7.8. 279 7.2.6. Contingency 280 Uncertainty associated with the decommissioning cost estimate, and the need to allocate 281 additional funding to cover contingency for this project has been included in th is estimate.

282 Accounting for contingency has been evaluated from two standpoints, operational efficiency and 283 scope expansion risk. Within the context of this cost estimate, o perational efficiency contingency 284 is defined as the occurrence of events or circumstances that can prolong project duration or make 285 the execution of a given work scope more difficult. Examples of these types of events include 286 weather related delays, equipment or tool breakage or unavailability

, and interferences from 287 other work activities.

Scope expansion risk within the context of this estimate is defined as the 288 need to perform unplanned work activities or expansion of the work activities that were planned.

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

292 As was initially shown in section 7.2.2, contingency was estimated at

$31.1 Million; apportioned 293 as $24.7 Million for radiological decommissioning

, $3.3 Million for spent fuel management and 294 $3.2 Million for site restoration

. This contingency was estimated using a quantitative Monte 295 Carlo type probability analysis, with the

$31.1 Million amount corresponding to the resulting 85 296 percent confidence level amount

. 297 7.3. Decommissioning Funding Plan 298 As indicated in section 7.2, the estimated cost to complete the radiological decommissioning of 299 the Zion nuclear station, including contingency, is $309 Million (year of expenditure dollars) as 300 of Sept 30, 2014. These decommissioning costs will be paid for with funds from the station's 301 nuclear decommissioning trust fund (NDT). Discounting those escalated costs at the rate of cost 302 inflation described in section 7.2.2 yields a cost of radiological decommissioning at constant 303 2014 dollars of $306.8 Million

. 304 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-10 The actual cash balance of the NDT, as recorded by the ZionSolutions trustee as of Sept 30, 305 2014, was $344.9 Million. Recognizing that there were project costs incurred and recorded on 306 Sept 30, 2014 that had not been paid for from the NDT (outstanding disbursements), plus other 307 transactions in the last quarter of 2014 that have a bearing on these outstanding disbursements, 308 the net balance of the NDT available to cover the future costs of radiological decommissioning 309 was $317.1 Million.

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

314 This NDT position, together with EnergySolutions resources and the $200 Million Letter of 315 Credit backup for the NDT agreed with Exelon in the Zion Nuclear Power Station Unit 1 and 2 316 Asset Sale Agreement, that are available but are not relied upon here, provides for sufficient 317 funding and financial assurance for completion of radiological decommissioning of the Zion 318 Project. 319 On or before March 31, 2015, as required by 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

-320 (viii), Zion Solutions will be submitting the annual demonstration of financial assurance for the 321 year ending Dec 31, 2014. That submission will be based upon future project costs of 322 radiological decommissioning and the NDT balance as of that date.

323 324 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-11 7.4. Reference s 325 7-1 Code of Federal Regulations, Title 10, Part 50.82

, "Termination of License" 326 7-2 US Nuclear Regulatory Commission Regulatory Guide 1.179, Revision 1, "Standard 327 Format and Content of License Termination Plans for Nuclear Power Reactors", June 328 2011 329 7-3 Letter from ZionSolutions ,

LLC to the U.S. Nuclear Regulatory Commission, 330 "Notification of Amended Post

-Shutdown Decommissioning Activities Report (PSDAR) 331 for Zion Nuclear Power Station, Units 1 and 2 in Accordance with 10 CFR 50.82(a)(7)",

332 dated March 18, 2008 333 7-4 Code of Federal Regulations, Title 10, Part 50.75, "Reporting and Recordkeeping for 334 Decommissioning Planning" 335 7-5 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, 336 "Submittal of the Zion Nuclear Power Station Site

-Specific Decommissioning Cost 337 Estimate", dated February 14, 2000 338 7-6 Letter from Commonwealth Edison to the U.S. Nuclear Regulatory Commission, 339 "Submittal of the Zion Nuclear Power Station Irradiated Fuel Management Plan", dated 340 February 14, 2000 341 7-7 Letter from Exelon Generation to the U.S. Nuclear Regulatory Commission, "Proposed 342 Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for 343 Zion", dated October 17, 2013 344 345 346 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-12 Table 7-6 Detailed Breakdown of Radiological Decommissioning Costs 347 by Resource Requirement 348 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 person-hrs) $36.8 Million Management (179,390 person-hrs) $18.1 Million Other - contract service labor (Hours not reported)

$11.9 Million Equipment & Materials

TOTAL $24.9 Million Durable Equipment $5.3 Million Consumable Supplies

$16.0 Million Utilities and Energy

$3.6 Million Contracts, Services & Fees: TOTAL $55.5 Million Equipment Rental

<$0.1 Million Contracted Services

$27.9 Million Laboratory & Analytical Services

$1.8 Million Travel & Living

$1.5 Million Insurance and Finance Fees $20.1 Million Licensee Fees & Permits

$4.2 Million Radioactive Waste Packaging, Transportation & Disposal:

TOTAL $84.1 Million Class A Waste $70.2 Million Class B/C Waste $13.8 Million TOTAL $284.3 Million Columns may not add due to rounding 349 350 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-13 Table 7-7 Detailed Breakdown of Radiological Decommissioning Costs 351 by Decommissioning Activity 352 Major Component Removal TOTAL $30.8 Million Reactor Vessels and Internals

$21.1 Million Steam Generators

$9.0 Million Pressurizers

$0.7 Million SSC Removal and Decontamination TOTAL $27.2 Million Equipment Removal / Structural Decontamination

$18.4 Million Bulk Structural Material Removal

$7.9 Million In-process Characterization and Remedial Action Support $0.9 Million Waste Management TOTAL $84.1 Million Class B/C Waste: Packaging, Transportation and Disposal Surveys and Sampling

$13.8 Million Class A Waste: Rail Car Preparation for Large Components

$0.21 Million Class A Bulk Waste: Rail Car Transportation and Disposal

$68.8 Million Class A Packaged Waste: Containers, Transportation and Disposal $1.3 Million Program Management and Support Services TOTAL $120.3 Million Program and Project Management and Site Administration

$32.1 Million Technical Services and Services

- (e.g., Engineering, Rad. Protection, Environmental Monitoring, Site Characterization, Waste Mgmt, QA/QC, Safety, Worker Qualifications)

$47.9 Million Security $7.7 Million Site O&M

$4.9 Million Special Projects (Cold & Dark, Bld. Mods.)

$8.5 Million Equipment, Materials, Consumable Supplies and Utilities

$11.2 Million FSS, LT and Material Release Program

$8.0 Million Other Lump

-Sum Costs TOTAL $21.9 Million Financing

$9.8 Million Regulatory Fees

$12.1 Million TOTAL $284.3 Million Columns may not add due to rounding 353 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-14 354 Table 7-8 Detailed Breakdown of Spent Fuel Management Costs 355 by Resource Requirement 356 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 - exclusive of management) (Hours not reported)

$19.2 Million Equipment & Materials:

TOTAL $1.7 Million Durable Equipment <$0.1 Million Consumable Supplies

$1.2 Million Utilities and Energy

$0.4 Million Contracts, Services &

Fees: TOTAL $5.8 Million Equipment Related Services $1.3 Million Contracted Services (excluding security provided in labor above

) $2.2 Million Laboratory

& Analytical Services

<$0.1 Million Travel & Living <$ 0.1 Million Insurance

, Finance, Licensee and Permit fees

$2.3 Million Radioactive Waste Packaging, Transportation &

Disposal:

TOTAL $0 Class A Waste

$0 Class B/C Waste

$0 TOTAL $37.4 Million Columns may not add due to rounding 357 ZION STATION RESTORATION PROJECT LICENSE TERMINATION PLAN REVISION 1 7-15 Table 7-9 Detailed Breakdown of Site Restoration Costs by Resource Requirement 358 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.)

(19,295 person-hrs) $1.9 Million 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 & Fees: TOTAL $29.2 Million Equipment Rental <$0.1 Million Contracted Services $27.6 Million Laboratory

& Analytical Services

<$0.1 Million Travel & Living

<$0.1 Million Insurance

, Finance, Licensee & Permit fees,

$1.6 Million Radioactive Waste Packaging, Transportation &

Disposal:

TOTAL $0 Class A Waste

$0 Class B/C Waste

$0 TOTAL $36.2 Million Columns may not add due to rounding 359 360