TMI-15-036, Decommissioning Funding Status Report

Decommissioning Funding Status Report

ML15086A337
Person / Time
Site:	Crane
Issue date:	03/27/2015
From:	Halnon G GPU Nuclear
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TMI-15-036
Download: ML15086A337 (150)

Text

{{#Wiki_filter:CPU GPU Nuclear, Inc.Three Mile lsland Nuclear StationRoute 441 SouthPost Office Box 480Middletown, PA 1 7057-0480Tel 71 7-948-846110 cFR 50.751O CFR 50.82 NUCLEASMarch 27.2015 TMI-15-036ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

SUBJECT:

Three Mile lsland Nuclear Station, Unit 2Docket No. 50-320. License No. DPR-73 Decommissioninq Fundinq Status Report for the Three Mile lsland NuclearStation. Unit 2Pursuant to 10 CFR 50.75 and 10 CFR 50.82, GPU Nuclear, lnc. is hereby submitting three (3) reports to the Nuclear Regulatory Commission (NRC) for Three Mile lsland NuclearStation, Unit 2 for the year ending December 31, 2014. Attachment 1 provides a decommissioning funding status report based on the Nuclear Regulatory Commission (NRC)formula described in 10 CFR 50.75(c). Attachment 2 provides a decommissioningfunding status report based upon a site-specific decommissioning cost estimate.Attachment 3 contains a financial assurance status report as required by10 CFR 50.82(a)(B)(v).Enclosure A provides a copy of the Decommissioning Cost Analysis for Three Mile lslandUnit 2, December 2014. Enclosure B provides a copy of the Escalation Analysis for Three Mile lsland Unit 2 2013 Sife-Specific Decommissioning Cosf Esfimafe, February 2015.There are no regulatory commitments contained in this letter. lf there are any questions or ifadditional information is required, please contact Mr. Thomas A. Lentz, Manager - FirstEnergyNuclear Operating Company Fleet Licensing, at (330) 315-6810.Grdgory Sincerely,Director,Fleet Regulatory Affairs 2.3.Three Mile lsland Nuclear Station, Unit 2 TMt-15-036Page 2 Attachments:

1. Three Mile lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC FormulaThree Mib lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report -Site-Specific Decommissioning Cost Estimate Three Mile lsland Nuclear Station. Unit 2 FinancialAssurance Status Report

Enclosures:

A. Decommissioning Cost Anatysis for Three Mile lsland Unit 2, December 2014 B. Escatation Anatylis forThree Mile tstand tJnit 2 2013 Sife-specific Decommissioning Cost Estimate, February 2015 cc: NRC Region lAdministrator NRC Project ManagerNRC Resident Inspector Attachment 1 TMt-15-036Three Mile lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report - NRC FormulaPage 1 of 3 This report reflects the FirstEnergy Corp. subsidiary ownership interests in the Three Milef sland Nuclear Station, Unit 2 as of December 31,2014.1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(b) and (c) (see Schedule 1): Metropolitan Edison Company Pennsylvania Electric CompanyJersey Central Power & Light CompanyFirstEnergy Corp. Consolidated $252,161,563 126,08A,782 126.080,782 $5q4j23J120 After Tax$338,038,657 182,710,464 211.780,107 ve-sn-ru2. The amount accumulated in external trust funds as of December 31,2014: 3.4.There are no longer any funds to be collected from the ratepayers.The assumptions used regarding escalation in decommissioning cost, rates of earningson decommissioning fundi, and rates of other factors used in funding projections: 1A0o/o 2.A0o/o 2053 2034 Metropolitan Edison CompanyPennsylvania Electric CompanyJersey Central Power & Light CompanyFirstEnergy Corp. Consolidated Consolidated Ownership lnterest in Unit Estimated Net Investment RateYear of Site Restoration CompletionYear of Three Mib lsland Nuclear Station, Unit 1 OperatingLicense Expiration 5.6.An additional assumption is that the decommissioning activities for Three Mile lslandNuclear Station, Unit 2 will commence after the shutdown of Three Mile lsland Nuclear Station, Unit 1. Three Mile lsland Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in2040'There are no contracts upon whlch the owners/licensees are relying pursuant to 10 cFR 50.75(e)(1)(v). There are no modifications to the licensee's current method of providing financial assurance since the last submitted report. Attachment 1 TMr-15-036Page 2 of 3 7.8.There were no amendments to the trust agreements for the above-mentioned owners of Three Mile lsland Nuclear Station, Unit 2.Mathematical rounding was performed during the development of the supporting calculations. Attachment 1 TMr-15-036Page 3 of 3 Schedule 1 FIRSTENERGY CORP.Calculation of Minimum Financial Assurance AmountDecember 31,2014 THREE MILE ISLAND NUCLEAR STATION, UNIT 2Pennsvlvania Regions Labor (L) = Northeast EnergY (E) = NationalWaste Burial (B) = Generic For PWR Unit l=f=$=Adjustment Factor 2.661 2.222 13.885 Ratio 0.65 0.13 0.22$126,080,782 $126,080,782 $252.161,563 $504,323,126 Escalation Factorl 1.73 0.289 3.055 5.074$99,393,600 $504,323,126PWR Escalation Factor =Base Amount for PWR between 1200 MWt and 3400 MWt = ($ZS + 0'00BBP) million (P = power level in megawatts thermal = 2772)($7S + 0.0088(2772)) million =Escalated Amount for unitl =99,393,600 x 5.074 Owner/Licenseel Ownership Pennsylvania Electric Company 25o/o Jersey Central Power & Light Company 25o/o Metropolitan Edison Company 50o/o FirstEnergy Corp. Consolidated 10Qo/oNote 1: Mathematical rounding was performed during the development of the supporting calculations. Attachment 2 TMt-15-036 Three Mile lsland Nuclear Station, Unit 2 Decommissioning Funding Status Report - Site-specific Decommissioning Cost Estimate Page 1 of 4 1. Decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c) arebased upon a site-specific decommissioning cost study, Decommissioning Cost Analysis forThree Mile lsland lJnit 2, dated December 2014, and escalated to 2014 dollars: Radiological Non-Radiological

FirstEnergy Corp. Consolidated2. The amount accumulated in external trust funds as of December 31,2014:$1,180,928,000 40.560.000 gl2zLt88*000After Tax$338,038,657 192,710,464 211,780.107 s732529.228 100o/o 2.77o/o 2.00o/o 2053 2034 Metropolitan Edison ComPanY Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated

3. There are no longer any funds to be collected from the ratepayers' Consolidated Ownership Interest in Unit Estimated Rate of Escalation in Decommissioning Costs Estimated After-Tax Rate of Return Year of Site Restoration Completion Year of Three Mile lsland Nuclear Station. Unit 1 end of license4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds, and rates of other factors used in funding projections:

5.6.An additional assumption is that the decommissioning activities for Three Mib lsland Nuclear Station, Unit 2 will commence after the shutdown of Three Mile lsland NuclearStation, Unit 1. Three Mile lsland Nuclear Station, Unit 2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040.There are no contracts upon which the owners/licensees are relying pursuant to10 cFR 50.75(eX1Xv). There are no modifications to the licensee's current method of providing financialassurance since the last submitted report. Attachment 2 TMt-15-036 Page 2 of 4 7.8.9.10.There were no amendments to the trust agreements for the above-mentioned owners of Three Mile lsland Nuclear Station, Unit 2.Site-Specific Cost Analysis Assumptions10 CFR 50.75(eX1)(i), states, in part, that: A licensee that has prepaid funds based on a site-specific estimate under 50.75(bX1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that thesite-specific estimate G based on a period of safe storage that is specifically described in the estimate.In accordance w1h Regulatory Guide 1.159, Revision 2, afacility specific analysis may be used to demonstrate the adequacy of decommissioning funds, provided that: NRC-required cost estimate for decommissioning costs, as defined in10 CFR -50.2, is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(cX1) and (2).The site-specific radiological decommissioning cost estimate is $1,180,928,000 which is greater than the 10 CFd5O.75(c) cost estimate of $504,323,126. The analysis assumes a 2 percent yearly rate of return. 'The analysis also assumes a period of safe storage. Thecash flows were contained in a decommissioning cost estimate that was prepared for Three Mile lsland Nuclear Station, Unit 2. The cash flow analysis assumes the yearlyexpenses are incurred at the beginning of year.Schedule 1 provides the site-specific analysis. The analysis values are in 2014 dollars.The analysis includes both the radiological and site restoration costs.Mathematical rounding was performed during the development of the supporting calculations.

References:

A. Decommissioning Cost Anatysis for Three Mite lstand lJnit 2, December 2014 B. Esca/a tion Anatysis for Three Mite tstand lJnit 2 2013 Sife-Specrfrc Decommissioning Cost Estimafe, February 2015 Attachment 2 TMt-15-036Page 3 of 4 Schedule 1 FIRSTENERGY CORP.Funding Analysis December 31,2014 THREE MILE ISLAND NUCLEAR STATION, UNIT 2Estimated Net Investment Rate Estimated Escalation Rate Estimated After-Tax Rate of Return Qualified Trust Balance on December 31,2014 Non-Qualified Trust Balance on December 31,2014 Total After-Tax 2.00o/o 2.00%$732,529,228 $732,529,228 Year Beginning Balance Deposits Earnings Withdrawall Ending Balance 2015 732.529.228 14,463,385 (9.360.000)2 737,632,613 2016 737.632,613 14.690.092 (3.128.000) 749,194,705 2017 749,194,705 14.921.494 (3.120.000) 760,996,199 2018 760,996,199 15.157.524 (3.120,000) 773.033.723 2019 773,033,723 15.398.274 (3.120.000) 785.311.997 2020 785,311,997 15.643.680 (3.128.000) 797.827.677 2021 797.827.677 15.894.154 (3.120.000) 810,601,831 2022 810,601,831 16.149,637 (3.120.000) 823.631.467 2023 823,631,467 16.410.229 (3.120.000) 836.921.697 2024 836.921.697 16.675.874 (3.128.000) 850.469.571 2025 850.469,571 16.946,991 (3.120,000) 864.296.562 2A26 864.296,562 't7.223,531 (3.120,000) 878.400,093 2027 878.400.093 17.505.602 (3.120,000) 892,785,695 2028 892.785.695 17.793.154 (3.128,000) 907.450,849 2029 907.450,849 18,086,617 (3.120,000) 922.417,466 2030 922.417.466 18,385,949 (3,120,000) 937.683.415 2031 937.683,415 18,691,268 (3.120.000) 953,254,684 2032 953.254,684 19,002,534 (3.128.000) 969,129,217 2033 969,129,217 19.320.184 (3.120.000) 985,329,402 2034 985,329,402 19.644.188 (3.120,000) 1.001.853,590 2035 1.001.853.590 19.974.672 (3,120,000) 1.018.708.262 2036 1.018.708,262 20,311,605 (3.128,000) 1.035,891,867 2037 1,035.891.867 20.655.437 (3,120,000) 1.053.427,304 TMt-15-036 Page 4 of 4 Schedule 1 (Continued) Notes:1. Withdrawal are assumed to be made at the beginning of the period.2. The Decommissioning Cost Analysis for Three Mile lsland Unit 2, December 2014, hadwithdrawals for the years 2013 and 2014. Those withdrawals were included in the 2015 period.Year Beginning Balance Deposits Earnings Withdrawall Ending Balance 2038 1.053,427,304 21.006.146 (3,120,000) 1.071.313,450 2039 1.071.313,450 21,363,869 (3.120,000) 1.089.557.319 2040 1,089,557,319 20.693,006 (54.907.000) 1,055,343,326 2041 1.055,343.326 19,291,187 (90,784,000) 983.850.512 2042 983.850.512 17.396,970 (114.002,000) 887,245,482 2043 887.245.482 15.464.870 (114,002,000) 788.708.352 2044 788.708.352 13,487,887 (114.314,000) 687,882,239 2045 687,882,239 11.477.605 (114.002.000) 585,357,844 2046 585.357.844 9.695.777 (100.569.000) 494.484.621 2047 494.484.621 8,387,952 (75.087,000) 427.785.573 2048 427,785,573 7.049.871 (75,292,000) 359.543.445 2049 359.543.445 5,689,129 (75,087,000) 290.145.574 2050 290.145.574 4,301,171 (75,087,000) 219.359.745 2051 219,359,745 2.934,615 f2.629.000) 149.665.360 2052 149.665,360 2.348.847 rc2,223,000) 119.791.207 2053 119.791.207 1,811,724 (29,205,000) 92.397.931 TOTAL n.221.478.000) 1.2.Attachment 3 TMt-15-036Three Mib lsland Nuclear Station, Unit 2 FinancialAssurance Status Report Page 1 of 1Formal decommissioning has not started at the Three Mile lsland Nuclear Station, Unit 2.A special disbursement of decommissioning trust funds occurred in 2005 for $416,400.00.Notification of this use of decommissioning funds was made to the NRC by letter datedFebruary 1, 2005 (Accession No. ML050380143). No funds were spent ondecommissioning activities tn 2014.Decommissioning funds estimated to be required are based upon a site-specificdecommissioning cost study, Decommissioning Cost Analysis for Three Mile lsland Unit 2, dated December 2014. and escalated to 2014 dollars:3. The amount accumulated in external trust funds as of December 31,2014: Radiological Non-Radiological FirstEnergy Corp. Consolidated Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company FirstEnergy Corp. Consolidated $1,180,928,000 40,560,000 $l-2ZlJtE8*000 After Tax$338,038,657 182,710,464 211.780.107 wj2*w.229 4.5.There are no longer any funds to be collected from the ratepayers.There are no modifications to the licensee's current method of providing financialassurance since the last submitted report.There were no amendments to the trust agreements for the above-mentioned owners ofThree Mile lsland Nuclear Station, Unit 2.Mathematical rounding was performed during the development of the supporting calculations.

8.

References:

A. Decommissioning Cost Anatysis for Three Mile lsland Unit 2, December 2414B. Escalation Analysis for Three Mile lsland lJnit 2 2013 Site-Specific Decommissioning Cost Estimafe, February 2015 6.7. Enclosure A TMt-15-036 Decommissioning Cost Analysis for Three Mile lsland Unit 2, December 2014(123 pages follow) Document F07-1676-001, Rev, 0 DECOMMISSIOMNG COST ANALYSIS forTHREE MILE ISLAND UNIT 2 prepared for FirstEnergy Corporation prepared byTLG Services,Inc.Bridgewater, Connecticut December 2014 Three Mile Island. Unit 2D e c ontni e sion ing Co st An aly si s Fr*je*t*Iaqqg*r Project Engineer Sechnisal &fnmqsrer Document F07-1676-001, Rev. 0 Page ii of xuiii APPROVALS I&at*"*C 14 ,,L'n{ft,et I{,#i$,#'",, iSatc nl",lwvy D.tGTLG Sen:ices, Inc. Three Mile Island. Unit 2 Decommissioning Cost Analysia Document F07-1676-001, Reu. 0Page iii of xuiii 1.TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

"'..."""'vii'xviii INTRODUCTION 

................ 1-1 1.1 Objectives of Study ......1'1 L.2 Site Description....... .....I'21.3 Regulatory Guidance ...L'4 1.3.1 Nuclear Waste Policy Act........... ........ 1'5 I.3.2 low-Level Radioactive Waste Acts......... .....-.....L'7 1.3.3 Radiological Criteria for License Termination.......... .....-... 1'9 DECOMMISSIONING ALTERNATI\'ES ...........2.I2.L DECON... .....2-2 2.I.t Period 2 - Dormancy........... -....-..........2-2 2.L.2 Period 3 - Preparations .....2'3 2.I.3 Period 4 - Decommissioning Operations -..........2-5 2.L.4 Period 5 - Site Restoration............... ...................2-82.2 SAFSTOR and Delaved DECON ...........-......2-9cosr ESTIIVIATE.............. ................... 3- 13.1 Basis of Estimate .........3-1 3.2 Methodology............. ..--3-13.3 Impact of Decommissioning Multiple Reactor Units ...3-3 3.4 Financial Components of the Cost Model............... ......3-4 3.4.L Contingency ..-...3'4 3.4.2 Financial Risk......... ...........3-73.5 Site-Specific Considerations......... ....'............3'8 3.5.1 Spent FueI Management..... ...............3-8 3.5.2 Reactor Vessel and Internal Components........... ...............3'93.5.3 Steam Generators............... ..............3'10 3.5.4 Other Primary System Components............... .3-11 3.5.5 Other Systems Known to Contain High Levels of Radioactivity.....3-12 3.5.6 Reactor Building Structures Decontamination..... ...........3.133.5.7 Demolition of Other Contaminated Structures ......... ......3'14 3.5.8 MainTurbine and Condenser.......... .................3'14 2.3.TLG Seruices, Inc. Three Mile Island Unit 2 Decommissioning Cost Ana,lysie Document F07-1676-001, Reu. 0Page iu of xuiiiTABLE OF CONTENTS (continued) SECTION PAGE3.5.9 Transportation Methods .3'I43.5.10 Low-Level Radioactive Waste Disposal ...........3'153.5.11 Additional Decommissioning Facilities ...........3-16 3.5.12 Remediation of Soil and Underground Piping .................3'173.5.13 Site Conditions Following Decommissioning ..3'17 Assumptions............. ..3-L73.6.1 Estimating Basis .............3'17 3.6.2 Labor Costs .....3-193.6.3 Design Conditions ............3-183.6.4 General... .........3-19 Cost Estimate Summarv .......... .3-20 SCHEDULE ESTIMATE ............. .......4.1 4.I Schedule Estimate Assumptions............. .....4'L 4.2 Project Schedule.. .........4'2 RADIOACTIVE WASTES ...5.1 RESLTLTS ...........6-1 REFERENCES......... ...........7-r 3.6 3.7 5.6.7.TLG Seruices, Inc. Three Mile Island Unit 2 D ecommissioning Cost Analysis SECTION 1.1 L.2 1.3 3.1 3.2 3.3 5.1 5.2 5.3 6.1 6.2 6.3 4.r 4.2 4.3 4.4 A.B.C.D.E.TABLE OF CONTENTS (continued) Document F07-1676-001, Rev. 0 Pa,ge v of xviii PAGE TABLES Summary of Decommissioning Cost Elements, DECON.......... .... xvi Summary of Decommissioning Cost Elements, Delayed DECON................ xvii Summary of Decommissioning Cost Elements, SAFSTOR...... ... xviii Inventory of Spent Fuel, Auxiliary and Fuel Handling Buildings ..............1'10 Inventory of Spent Fuel, Reactor Building ................. 1-12 Inventory of Spent Fuel, Reactor Coolant System ..... 1'13 Schedule of Total Annual Expenditures, DECON............. ..........3-2LSchedule of Total Annual Expenditures, Delayed DECON ........3'23Schedule of Total Annual Expenditures, SAFSTOR........ ...........3'25 Decommissioning Waste Summary, DECON ................5'5 Decommissioning Waste Summary, Delayed DECON... ...............5-6 Decommissioning Waste Summary, SAFSTOR.............. ...............5-7 Summary of Decommissioning Cost Elements, DECON.......... ....6'3 Summary of Decommissioning Cost Elements, Delayed DECON.................6-4 Summary of Decommissioning Cost Elements, SAFSTOR...... .....6-5 FIGURES Activity Schedule ..........4'3 Decommissioning Timeline, DECON ...........4'4Decommissioning Timeline, Delayed DECON... ...........4'5Decommissioning Timeline, SAFSTOR .......4'6 TMI-2 Waste Streams Summary ..................5'3Decommissioning Waste Destinations fr,adiological) ...................5-4 APPENDICESUnit Cost Factor Development............ .............. A'1Unit Cost Factor Listing..... ............. B-1 Detailed Cost Analysis, DECON.............. ......... C-l Detailed CostAnalysis, Delayed DECON ........D-l Detailed Cost Analysis, SAFSTOR........... ........ E-l 5.1 5.2 TLG Sensices, Inc. Three MiIe Island. Unit 2 D e cotnmi esionin g Co st An a Iy si s Document F07-1676-001, Reu. 0Page vi of xviii REVISION LOGItem nevisCd .0 T2.TT.L4 Original Issue TLG Serttices, Inc. Three Mile Island, Unit 2D e commissioning Co st An aly sie Document F0 7-1 6 76-00 7' Reu. 0Page vii of xuiiiE)GCUTIVE

SUMMARY

This report presents estimates of the cost to decommission the Three Mile Island, Unit2 nuclear unit (TMI-2) for the selected decommissioning scenarios following thescheduled cessation of plant operations at the adjacent Unit 1 reactor. This analysisrelies upon site-specific, technical information, originally developed in an evaluationfor the GPU Nuclear Corporation in 1995-96,t11 and last updated in 2008 for FirstEnergy.tzl fhs analysis has been further updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The updated estimates are designed to provide the FirstEnerry Corporation with suffi.cient information to assess its financial obligations,as they pertain to the eventual decommissioning of the nuclear unit.The decommissioning of TMI-2 is a continuation of the decontamination efforts startedin the 1980s, following its accident. The ultimate goal of the decommissioning is toremove the radioactive material from the site that would preclude its release forunrestricted use.The estimates are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, radioactive waste disposal options, and siteremediation requirements. The estimates also include the dismantling of non-essentialstructures and limited restoration of the site.Alternatives and Reeulations The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.t31 In this rule, theNRC set forth financial criteria for decommissioning licensed nuclear power facilities.The regulations addressed planning needs, timing, funding methods, andenvironmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB."Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. G01'1196-003, TLG Services, Inc., February 1996."Decommissioning Cost Estimate for Three Mile Island lJnit 2," Document No. F07-1601-002,TLG Services, Inc., January 2009.U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "GeneralRequirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988.TLG Seruices, Inc, Three MiIe Island. Unit 2D ecorntnissioning Co st Analysis Docurnent F07-1676-001, Rev. 0 Page uiii of xuiii DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a levet that permits the property to bereleased for unrestricted use shortly after cessation of opel'4f,ieng.r'[41SAFSTOR is defined as "the alternative in which the nuclear facility is placedand maintained in a condition that allows the nuclear facility to be safelystored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted usg."[5] Decommissioning is to becompleted within 60 years, although longer time periods will be consideredwhen necessary to protect public health and safety.ENTOMB is defi.ned as "the alternative in which radioactive contaminantsare encased in a structurally long-Iived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permittingunrestricted release of the property."t6l As with the SAFSTOR alternative,decommissioning is currently required to be completed within 60 years.The 60-year restriction has limited the practicality of the ENTOMBalternative at commercial reactors that generate significant amounts of long'lived radioactive material. In 1997, the Commission directed its staff to re'evaluate this alternative and identifr the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations,however, rulemaking has been deferred pending the completion of additional research studies, e.9., on engineered barriers.In 1996, the NRC published revisions to the general requirements fordecommissioning nuclear power plants to clarify ambiguities and codifr procedures and terminology as a means of enhancing effrciency and uniformity in the decommissioning process. tzl The amendments allow for greater public participationand better define the transition process from operations to decommissioning. Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC stafffor implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning Ibid. Page FR24022, Column 3.Ibid Ibid. Page FR24023, Column 2.U.S. Code of Federal Regulations, Title 10, Parts 2,50, and.51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61, (p 39278 et seq.), July 29,1996. 4 5 7TLG Serttices, Inc. Three MiIe Island Unit 2 D e c otnmissioning Co st An aly eis Docurnent F07-1676-001, Reu. 0 Page ix of rviii process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. Decommissionine Scenarios Three decommissioning scenarios were evaluated for the nuclear unit. The two delayeddismantling scenarios, Delayed DECON and SAFSTOR, include some consideration ofthe decommissioning activities planned at the adjacent Unit 1. The scenarios selected are representative of alternatives available to the owner and are defined as follows: DECON: The adjacent TM-l is promptly decommissioned upon the scheduledcessation of operations in 2034. TM-2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040. The decommissioning program for TMI-2 runs independently from the TMI-I decommissioning effort;license termination of Unit 2 occurs in 2053, approximately 10 years after Unit1 completes its decommissioning program (exclusive of the on-site ISFSIoperations for Unit 1 fuel).Delayed DECON: One of the decommissioning alternatives for Unit 1 is to defer decommissioning until the spent fuel has been removed from the site.t8l This scenario assumes that the decontamination and dismantling activities at TMI-2are synchronized with the adjacent unit such that the licenses for both units are terminated concurrently.SAFSTOR: In the second scenario, TMI-1 is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit 1. As with the first scenario, termination of the licenses is coordinated. The scenarios consider that Exelon Generation has extended the operating license atthe adjacent Unit I to 2034. The scenarios are also based upon the premise thatdecommissioning work at Unit 2 would not begin prior to final shutdown of Unit I in 2034, consistent with the agreement between Exelon and FirstEnerry. MethodoloeVThe methodology used to develop the estimates described within this document followsthe basic approach originally presented in the cost estimating guidelines tsl developedby the Atomic Industrial Forum (now Nuclear Enerry Institute). This referenceTimelines for the Unit 1 decommissioning scenarios are included in Section 4 of this report.T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.1.2.3.TLG Sentices, Inc. Three Mile Island Unit 2 De commissioning Cost Analysis Document F07-1676-001, Reu. 0Page x of xuiiidescribes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest availableinformation on worker productivity in decommissioning.An activity duration critical path is used to determine the total decommissioning program sched.ule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental,and support services such as quality control and security. This systematic approach forassembling decommissioning estimates ensures a high degree of confidence in thereliability of the resulting cost estimate.ContinsencvConsistent with cost estimating practice, contingencies are applied to thedecontamination and. dismantling costs developed as "specific provision forunforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown thatunforeseeable events which will increase costs are likely to occur."tt0l The costelements in the estimates are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based onind.ustry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and. demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and in{lation in the cost of decommissioning over the time intervals identified for each scenario.The use and role of contingency within decommissioning estimates is not a safetyfactor issue. Safety factors provide additional security and address situations that maynever occur. Contingency funds, by contrast, are expected to be fi'rlly expendedthroughout the program. Inclusion of contingency is necessarT to provide assurancethat sufficient funding will be available to accomplish the intended tasks.Low-Level Radioactive Waste DisposalThe contaminated. and activated material generated in the decontamination anddismantling of a commercial nuclear reactor is generally classified as low'levelradioactive waste, although not all of the material is suitable for shallow-land disposal.With the passage of the "Low-Level Radioactive Waste Disposal Act' in 1980 and its ro Project and Cost Engineers' Handbook, Second Edition, American Association of Cost Engineers,Marcel Dekker, Inc., New York, New York, p. 239.TLG Seruices" Inc. Three Mile Island, Unit 2 D e commi ssioning Co st An aly sis Docurnent F07-1676-001, Reu. 0Pa.ge xi of xuiii Amendments of 1985, tttl the states became ultimately responsible for the dispositionof low-level radioactive waste generated within their own borders. It was expected that groups of states would combine together to jointly deal with their radioactive wastes;these organizations are referred to as waste disposal compacts.Few approved facilities for the disposal of LLW are currently available. Construction of the newest facility, in Texas, is now complete and the facility was declared operational by the operator, Waste Control Specialists 0MCS), in November zOLl. The facility will be able to accept limited quantities of non-Compact waste; however, at this time the cost for non-Compact generators is being negotiated on an individual basis. All options and services currently available to FirstEnerry for disposition of the various waste streams produced by the decommissioning process were considered. The majority of the low-level radioactive waste designated for direct disposal (Class A t121) can be sent to Enerrysolutions'facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon FirstEnergy's agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream.The Texas facility is licensed to receive the higher activity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C wastebased upon the preliminary and indicative information on the cost for such WCS.Waste exceeding Class C limits Qimited to material closest to the reactor core, or material contaminated with spent fueI debris from the March 1979 accident) is generally not suitable for shallow-Iand disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for ClassC radioactive waste, referred to as Greater Than Class C (GTCC)). The Low'Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal governmentthe responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bearall reasonable costs of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance."Low-Level Radioactive Waste Poliry Amendments Act of 1985," Public Law 99-240, January 15, 1986Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55 were from n TLG Services, Inc. Three Mile Island. Unit 2D e corntni ssioning Co st An aly sisDocument F07-1670-001, Reu. 0Page xii of xuiii For purposes of this analysis, this material is packaged in the same multipurposecanisters used for spent fuel storage/transport (e.g., at TMI-I) and designated for geologic disposal. The GTCC is shipped directly to a disposal facility as it is generated.A significant portion of the metallic waste generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be surveyedon site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-Ievel radioactivewaste requiring disposal in a licensed low-level radioactive waste disposal facility canbe accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimates reflect thesavings from waste recovery/volume reduction.Material removed during decommissioning that is free of contamination will bedesignated for conventional disposal or reuse / recovery. Fuel-Bearine Waste ManagementThere will be some wastes generated in the decommissioning of TMI-2 that are not suitable for shallow land burial and therefore cannot be shipped for disposal to EnergySolutions. This material, primarily associated with systems and structurescontaminated with fuel debris, requires greater isolation from the environment. For estimating purposes, a geologic waste repository, or some interim storage facility, isassumed to be available for the disposal of this material.Congress passed the "Nuclear Waste Policy Act" (NW.PA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclearfuel created by the commercial nuclear generating plants to the DOE. The DOE wasto begin accepting spent fuel by January 31, 1998; however, to date no progress inthe removal of spent fuel from commercial generating sites has been made.Today, the country is at an impasse on high-level waste disposal, even with theLicense Application for a geologic repository submitted by the DOE to the NRC in 2008. The current administration has cut the budget for the repository program while promising to "conduct a comprehensive review of policies for managing theback end of the nuclear fuel cycle ... and make recommendations for a new plan."[l3] Towards this goal, the administration appointed a Blue Ribbon Commission onAmerica's Nuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commission's charter 13 Blue Ribbon Commission on America's Nuclear Future Charter, http://cvbercemeterv.unt.edu/archive/brc/20120620215336/httn:l/brc.eov/index.php?q=paee/charter TLG Services, Inc. Three Mile Island. Unit ZD e commission ing Co st An aly si s Docurnent F07-1676-001, Rev. 0Page xiii of xviii includes a requirement that it consider "[o]ptions for safe storage of used nuclearfuel while final disposition pathways are selected and deployed."tt4lOn January 26, 2OI2, the Blue Ribbon Commission issued its "Report to the Secretary of Enerry" containing a number of recommendations on nuclear waste disposal. Two of the recommendations that may impact decommissioning planning are: o "[T]he United States [should] establish a program that leads to the timely development of one or more consolidated storage fsgilfliss"ttrl o "[T]he United States should undertake an integrated nuclear waste management program that leads to the timely development of one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear 1ryasf,s."[16l In January 2013, the DOE issued the "strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Blue Ribbon Commission and as 'oa framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear f11s1..."[171"With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next L0 years that: o Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2O2l with an initial focus on accepting used nuclear fuel from shut-down reactor sites;. Advances toward. the siting and licensing of a larger interim storage facility to be available by 2O25 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance ofenough used nuclear fuel to reduce expected government liabilities; and 14 Ibid."Blue Ribbon Commission on America's Nuclear Future, Report to the Secretary of Energy,"http://www.brc.gov/sites/default/files/documents/brc finalreoort ian2012.pdf, p. 32, January 2012 Ibid., p.27"strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013 16 17TLG Seruices,Inc. Three MiIe Island. Unit 2D ecommissioning Cost AnalysisDocutnent F07-rc7e-001' Reu, 0Page xiv of xuiii o Makes demonstrable progress on the siting and characterization repository sites to facilitate the availability of a geologic repository 2049.Dt18t Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program hadassumed that spent fuel allocations would be accepted for disposal from the nation'scommercial nuclear plants, with timited exceptions, in the order (the "queue") in which it was discharged from the 1sssfe1.[lelThe estimates for TMI-2 assume the timely removal of waste designated for geologicdisposal, without the need for interim on site storage (once containerized).Site RestorationThe effi.cient removal of the contaminated materials at the site may result in damage to many of the site structures. Blasting, coring, drilling, and the other decontamination activities will substantially damage power block structutes, potentially weakening the footings and structural supports. Prompt demolition oncethe license is terminated is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with awork force already mobilized is more efficient and less costly than if the process weredeferred. Experience at shutdown generating stations has shown that plant facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force. Consequently, thisanalysis assumes that non-essential site structures within the restricted access areaare removed. The site is then backfilled, graded and stabilized. Summarv The costs to decommission TMI-2 are evaluated for three decommissioning scenarios. Regardless of the timing of the decommissioning activities, the estimates assume theeventual removal of all the contaminated and neutron-activated plant components and Ibid., p.2U.S. Code of Federal Regulations, Title 10, Part 961. 11, Article IV - Responsibilities of theParties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority rankingfor receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based onthe age of SNF and/or HLW as calculated from the date of discharge of such materials from thecivilian nuclear power reactor. The oldest fuel or waste will have the highest priority foracceptance ..." of by 18 19TLG Seruices, Ine. Three Mile Ieland Unit 2 D e c omtni ssion ing Co st An aly sis Docutnent F07-1676-001' Reu. 0Page xv of xuiii structural materials, such that the facility operator may then have unrestricted use of the site with no further requirement for an license.The scenarios analyznd for the purpose of generating the estimates are described in Section 2. The assumptions are presented in Section 3, along with schedules of annual expenditures. The major cost contributors are identifi.ed in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendices C, D, and E. Cost summaries for the various scenarios are provided at theend of this section for the major cost components. TLG Seruiees, Inc. Three Mile Island Unit 2 D e commi seioning Co st An aly sisDocum.ent F07-1676-001, Reu. 0 Page xui of xviiiDECON COST SUMMARI DECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars)Cost Element Total Decontamination 35,403 Removal 189.064 Packaeine 28.008 Transportation 26,427Waste Disnosal 276.1.L2Off-site Waste Processine 11.053Program Managemsnf ttl 484.509 Securitv 55,590Insurance and ReEulatorv Fees r5.766 Enererv 18.061 Characterization and Licensins Surveys L0.844Propertv Taxes 0 Miscellaneous Equipment 23.851Site O&M 4,968PDMS MonitorinE 8"908 fefal tzl 1.188,564Cost ElementNRC License Termination 1.149.098Site Restoration 39.467 fsfsl tzl 1.188.564 trl I2lIncludes engineering costsColumns may not add due to rounding TLG Seruices,Inc. Three Mile Island Unit 2D e commissioning Co st An aly si sDocurnent F07-1676-007, Reu, 0Page xvii of xuiii DELAYED DECON COST

SUMMARY

DECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars) l1l l2l 131 Includes dormancy costs following TMI-1 shutdown in 2034 Includes engineering costsColumns may not add due to rounding Cost Element fgfalttl Decontamination 35.321 Removal 190.858 Packasine 28.007 Transportation 26.310Waste Disposal 276.022Off-site Waste ProcessinE 11.053Program Managemsnf I2l 472.755 Securitv 46.850 Insurance and ReEulatorv Fees 21.899 Energy L9.459 Characterization and Licensins Surveys L0.844Propertv Taxes 0 Miscellaneous Eouinment 26.259Site O&M 4.968 PDMS Monitorine 6.949 Total t31 1,L77,554Cost ElementLicense Termination 1,139,536Site Restoration 38.018 Total t31 L.r77.554TLG Sentices, Inc. Three fuIiIe Island. Unit 2D e commissioning Co st An aly si s Docurnent F07-167G001, Reu, 0 Page xuiii of xuiiiSAFSTOR COST

SUMMARY

DECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars) t{t2)t3I Includes dormanry costs following TMI-1 shutdown in2034 Includes engineering costsColumns may not add due to roundingCost Element Totalttl Decontamination 35,286 Removal 196.595 Packaeine 28.065 Transportation 26.298Waste Disnosal 275.884Off-site Waste Processins 11,206 Prosram Manasemsnf [21 482.930 Securitv 56.699Insurance and Reeulatory Fees 4t.497 EnerEv 28,227Characterization and Licensing Surveys 1,0,844Pronertv Taxes 0Miscellaneous Equipment 33,617 Site O&M 4,968PDMS Monitorins 6,949 Total t3I 1,239,065Cost ElementLicense Termination L,20L,047Site Restoration 38.018 Total tsl 1.239.065TLG Seruices,Inc. Three Mile Island. Unit 2 D ecomtniesioning Co et Analyeis Document F07-1670-001, Reu. 0Section 1, Page I of 131. INTRODUCTIONThis report presents estimates of the cost to decommission the Three Mile Island Unit2 nuclear unit (lMI -2) fot the scenarios described in Section 2. This analysis relies upon site-specific, technical information, originally developed in an evaluation for theGPU Nuclear Corporation in 1995-96 [1]*, and last updated in 2008 for FirstEnergy Corporation.tzl Jhs analysis is designed to provide the FirstEnerry Corporation with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear unit. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be requiredto carry out the decommissioning. 1.1 OBJECTIVES OF STUDY The objective of this study was to prepare estimates of the cost, schedule, and waste volumes generated to decommission TMI-Z, including all areas affected by the March 1979 accident. Three decommissioning scenarios were evaluated for TMI-2. In the delayed scenarios (Delayed DECON and SAFSTOR) decommissioning activities are coordinated to some extent with the adjacent operating unit (TMI-1 or Unit 1).The scenarios consider that Exelon Generation has extended the operating license for Unit I to 2034. The three scenarios are also based upon the premise that decommissioning work at Unit 2 would not begin prior to final shutdown of Unit 1 in 2034, consistent with the agreement between Exelon and FirstEnergy. DECON The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a Post-Defueling Monitored Storage status to decommissioning in 2040. The decommissioning program for TMI-2 runs independent from the TMI-I decommissioning effort;license termination of Unit 2 occurs in 2053, approximately 10 years after Unit 1 completes its decommissioning program (exclusive of the on-site ISFSI operations for Unit I fuel).Delayed DECON Decommissioning of TMI-2 commences upon the removal of TMI-1's spent fuel from the site in 2051. The decommissioning program for TMI-2 runs concurrently with the TMI-I decommissioning effort and concludes with the termination of both licenses." Annotated references for citations in Sections 1-6 are provided in Section 7. TLG Serpices, Inc. Three Mile Island Unit 2D ecomrnissioning Cost Analysis Docutnent F07-1670-001' Reu. 0Section 7,Page 2 of 13 SAFSTOR TMI-I is placed into safe-storage with decommissioning deferred 60 years. TMI-2 remains in storage with decommissioning deferred until it canbe sequenced with TMI-I. The decommissioning program for TMI-2 runs concurrently with the TMI-I decommissioning effort and concludes with the termination of both licenses.L.2 SITE DESCRIPTIONTMI-Z is located on the northern-most section of Three Mile Island near theeast shore of the Susquehanna River in Dauphin County, Pennsylvania. Thestation is comprised of two pressurized water reactors. This study specifically addresses the decommissioning requirements for Unit 2, although the timing of each scenario is dependent upon the associated activities at the adjacent unit.The nuclear steam supply system (NSSS) consists of a pressurized waterreactor rated at a core thermal power level of 2772MWth with a corresponding turbine-generator gross output of 959 MWe. The NSSS consists of the reactor with two independent primary coolant loops, each containing two reactor coolant pumps and a steam generator. An electrically heated pressurizer and connecting piping complete the system. The system is housed within a steel'lined, post-tensioned concrete structure (reactor building) in the shape of aright, vertical cylinder with a hemispherical dome and a flat, reinforcedconcrete basemat. A welded steel liner plate, anchored to the inside face of the reactor building, serves as a leak-tight membrane.Heat produced in the reactor was converted to electrical energy by the turbine generator system. This system converted the thermal energy of the steam into mechanical shaft power and then into electrical energy. The turbine-generator is a tandem-compound design, consisting of one double-flow, high pressureturbine and two double-flow, low-pressure turbines driving a directly coupled generator at 1800 rpm. The turbine operated in a closed feedwater cycle where steam was condensed, feedwater heated, and ultimately returned to the steam generators. Heat rejected in the main condensers was removed by thecondenser circulating and river water systems.The condenser circulating water was cooled in two hyperbolic natural draftcooling towers located to the east of the station. The towers provided the heatsink required for removal of waste heat in the power plant's thermal cycle.Cooling tower blowdown was discharged to the Susquehanna River.TMI-2's operating license was issued on February 8, 1978, with commercial operation declared on December 30, 1978. On March 28, 1979, the unit TLG Seruices, Inc. Three Mile Island Unit 2 D e c otnmi seionin g Co st,4n alyeie Document F07-1676-007, Reu. 0 Section 7,Page 3 of I3 experienced an accident initiated by interruption of secondary feedwater flow.The steam generator boiled dry, resulting in the reducti.on of primary-to-secondary heat exchange. This caused an increase in the primary coolanttemperature, creating a surge into the pressurizer, and an increase in system pressure. The pilot operated relief valve (POR\D opened to relieve the pressure, but failed to close when the pressure decreased. The reactor coolant pumpswere turned off and a core heat-up began as the water level decreased to uncover the top of the core. The melting temperature of the zircaloy fuelcladding was exceeded, resulting in relocation of the molten zfucaloy and some liquefied fuel to the lower core regions, solidifying near the coolant interface.Based on the end-state core and core support assembly configuration and supporting analysis of the degraded core heat-up, it is believed that as the crust failed, molten core material migrated to the lower internals. The majorityof the molten material flowed down through the region of the southeastern assemblies and into the core bypass region. A portion of the molten core material flowed around the bypass region and migrated down into the lower internals and lower head region. Limited damage to the core support assembly occurued as the core material flowed to the lower plenum. It is estimated that about L7 - 20 tons of material relocated to the lower internals and lower headregion. Several in-core instrument guide tubes were melted but overall vessel integrity was maintained throughout the accident. As a result of this accident, small quantities of core debris and fission products were transported through the RCS and the reactor building as a result of thecoolant flow through the PORV and the makeup and purification system (X{U&P) during the accident. In addition, a small quantity of core debris wastransported to the auxiliary and fuel handling buildings (AFHB) via the MU&P. Further spread of the debris also occurred as part of the post-accident water processing cleanup activities. GPU Nuclear conducted a substantial program to defuel the reactor vessel and decontaminate the facility. As a result, TMI-2 has been placed in a safe, inherently stable condition suitable for long-term management, and any threatto the public heatth and safety has been eliminated. Fuel and core materialremoved in the defueling has been shipped off site. The current long-term management condition is termed Post-Defueling Monitored Storage (PDMS).The costs for maintaining TMI-2 in this state from 2013 until the shutdown ofUnit 1 in 2034 (PDMS is continued until 204O for the DECON scenario) isincluded in the cost estimates in this analysis.Substantial contaminated areas still exist on site, as well as trace quantities ofspent nuclear fuel (SNF). Several cubicles in the auxiliary and fuel handling buildings remain locked, and the basement of the reactor building has been TLG Sentices, Ine. Three Mile Island, Unit 2 Decomm.issioning Cost Analysis Document F07-1676-001, Rev. 0 Seeti'on I, Page 4 of I3 uninhabitable since the accident. The quantity of fuel remaining at TMI'2 is a small fraction of the initial fuel load; approximately 99% was successfully removed in the defueling. Additionally large quantities of radioactive fi.ssion products were released into various systems and structures. Most of this radioactivity was removed as part of the waste processing activities during theTMI-2 Clean-up Program which concluded with entry into Post-DefuelingMonitored Storage in December 1993. Significant quantities of radioactive fission products were removed from the reactor coolant system in preparation for the PDMS. However, the remaintng Lo/o of the fuel and the remaining fission products pose unique problems in completing the decommissioning of TMI-2. A summary of the quantity and suspected location of the remaining fuel debris is provided in Tables 1.1 through 1.3.1.3 REGULATORY GUIDANCEThe Nuclear Regulatory Commission (NRC or Commission) provided initial d.ecommissioning requirements in its rule "General Requirements forDecommissioning Nuclear Facilities," issued in June 1988 t31. This rule set forth fi.nancial criteria for decommissioning licensed nuclear power facilities.The regulation ad.dressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule wasto ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose.Subsequent to the rule, the NRC issued Regulatory Guide 1.159, 'Assuring theAvailability of Funds for Decommissioning Nuclear Reactors,"[al which provided additional guidance to the licensees of nuclear facilities on thefinancial methods acceptable to the NRC staff for complying with therequirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financialassurance mechanisms indicated in the rule.The rule defi.ned three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative, the optionevaluated. for this analysis, assumes that any contaminated or activated portion of the plant's systems, structures, and facilities are removed or d.econtaminated to levels that permit the site to be released for unrestricteduse shortly after the cessation of plant operations. The rule also placed limitson the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient Ieverage and flexibility to ensure that these deferred options are only used insituations where it is reasonable and consistent with the defrnition of TLG Seruices, Inc. Three Mile Island. Unit 2D e c ommi ssionin g Co st An aly ei eDocument F07-1676-001, Rev. 0 Section 7, Page 5 of I3 decommissioning. At the conclusion of a 60-year dormancy period (or longer for ENTOMB if the NRC approves such a case), the site would still require signifrcant remediation to meet the unrestricted release limits for licensetermination. To use a decommissioning scenario in which the license has notbeen terminated within 60 years of the frnal shutdown date, FirstEnergy will need Commission approval pursuant to 10 CFR 50.82(a)(3) for completion of decommissioning beyond 60 years.The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-livedradionuclides for decay to permissible levels. However, with recent rulemaking permitting the controlled release of a site, the NRC has re-evaluated this alternative.Fl The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most, reactors.[6] However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. Rulemaking has been deferred pending the completion of additional research studies, e.g., on engineered barriers.However, this study assumes that the ENTOMB alternative is a viable option for TMI-2 and that a storage period of 100 years would be acceptable. The NRC published revisions to the general requirements for decommissioning nuclear power plants in 1996.t71 When the regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end ofthe facility's licensed life. Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codifu procedures and terminology as a meansof enhancing efficiency and uniformity in the decommissioning process. The new amendments allow for greater public participation and better define the transition process from operations to decommissioning. 1.3.1 Nuclear Waste Policv Act Congress passed the Nuclear Waste Policy Actt8l in 1982, assigning the federal government's long-standing responsibility for disposal of thespent nuclear fuel created by the commercial nuclear generating plantsto the DOE. The DOE was to begin accepting spent fuel by January 31,1998; however, to date no progress in the removal of spent fuel from commercial generating sites has been made.TLG Services, Inc. Three MiIe Island. Unit 2 De commissioning Co st Anabeis Docutnent F07-1676-001' Reu. 0 Section I, Page 6 of 18Today, the country is at an impasse on high-level waste disposal, evenwith the License Application for a geologic repositoly submitted by the DOE to the NRC in 2008. The current administration has cut the budgetfor the repository program while promising to "conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle ...and make recommendations for a new plan."[e] Towards this goal, the administration appointed a Blue Ribbon Commission on America'sNuclear Future (Blue Ribbon Commission) to make recommendations for a new plan for nuclear waste disposal. The Blue Ribbon Commission's charter includes a requirement that it consider "[o]ptions for safe storage of used nuclear fuel while final disposition pathways areselected and deployed."On Januaty 26,2012, the Blue Ribbon Commission issued its "Report tothe Secretary of Enerry" containing a number of recommendations onnuclear waste disposal. Two of the recommendations that may impact decommissioning planning are: o "[T]he United States [should] establish a program that leads tothe timely development of one or more consolidated storage facilities"[10] o "[T]he United States should undertake an integrated nuclearwaste management program that leads to the timely developmentof one or more permanent deep geological facilities for the safe disposal of spent fuel and high-level nuclear waste."In January 2013, the DOE issued the "strategy for the Management andDisposal of Used Nuclear Fuel and High-Level Radioactive Waste," inresponse to the recommendations made by the Blue Ribbon Commissionand as "a framework for moving toward a sustainable program to deployan integrated system capable of transporting, storing, and disposing ofused nucls6l fus1..."[l11"With the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next L0 years that:. Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021, with an initial focus on accepting used nuclear fuel from shut-down reactor sites;o Advances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficientcapacity to provide flexibility in the waste management system TLG Seruices, Inc. Three MiIe Island, Unit 2 D e comnt ission ing Co st An aly si s Docurnent F07-1670-001' Reu. 0 Section 1, Page 7 of 13and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities; and o Makes demonstrable progress on the siting and characterizationof repository sites to facilitate the availability of a geologic repository by 2O48." Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner.DOE's repository program had assumed that spent fuel allocationswould be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the lsssfsr.u2l The estimates for TMI-2 assume the timely removal of waste designated for geologic disposal, without the need for interim on site storage (once containerized). 1.3.2 Low-Level Radioactive Waste ActsThe contaminated and activated material generated in thedecontamination and dismantling of a commercial nuclear reactor is generally classified as low-level radioactive waste, although not all of the material is suitable for shallow-land disposal. With the passage ofthe "Low-Level Radioactive Waste Disposal Acl"[13] 111 1980 and itsAmendments of 1985, ttal the states became ultimately responsible forthe disposition of low-level radioactive waste generated within their own borders. It was expected that groups of states would combine together to jointly deal with their radioactive wastes; these organizations are referred to as waste disposal compacts.Few approved facilities for the disposal of LLW are currently available.Construction of the newest facility, in Texas, is now complete and thefacility was declared operational by the operator, Waste Control Specialists flMCS), in November 2011. The facility will be able to accept limited quantities of non-Compact waste; however, at this time the costfor non-Compact generators is being negotiated on an individual basis.AII options and services currently available to FirstEnergy ford.isposition of the various waste streams produced by the decommissioning process were considered. The majority of the low'level radioactive waste designated for direct disposal (Class A t15l) can be sentto Energy Solutions' facility in Clive, Utah. Therefore, disposal costs for Class A waste were based upon FirstEnergy's agreement with TLG Serpicee, Inc. Three Mile IslandUnit 2D ecommissioning Cost Analysie Document F07-1676-001, Reu, 0 Section I, Page 8 of I3EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream.The Texas facility is licensed to receive the higher activity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicativeinformation on the cost for such from WCS.Waste exceeding Class C limits (imited to material closest to the reactorcore, or material contaminated with spent fuel debris from the March 1979 accident) is generally not suitable for shallow-land disposal (i.e.,low-level radioactive waste with concentrations of radionuclides thatexceed the limits established by the NRC for Class C radioactive waste, referred to as Greater Than Class C (GTCC). The Low-LevelRadioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material. The Actalso stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs ofdisposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance. For purposes of this analysis, this material is packaged in the same multipurpose canisters used for spent fuel storage/transport (e.g.' atTMI-I) and designated for geologic disposal. The GTCC is shipped directly to a disposal facility as it is generated. A significant portion of the metallic waste generated during decommissioning may only be potentially contaminated by radioactivematerials. This waste can be surveyed on site or shipped off site tolicensed facilities for further analysis, for processing and./or for conditioning/recovery. Reduction in the volume of low-level radioactivewaste requiring disposal in a licensed low-Ievel radioactive waste disposal facility can be accomplished through a variety of methods,including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste,compaction, incineration or metal melt. The estimates reflect the savings from waste recovery/volume reduction. TLG Services, Inc. Three Mile Island. Unit 2 D e c ommi.ssion ing Co at .$t alyeia Document F07-1676-007, Reu. 0 Section 1, Page I of 13 1.3.3 Radioloeical Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria forLicense Termination," amending 10 CFR S20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use ifradioactivity levels are such that the average member of a critical groupwould not receive a Total Effective Dose Equivalent (TEDE) in excess of25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (AI"ARA).The decommissioning estimates for TMI-2 assume that the site will be remediated to a residual level consistent with the NR0-prescribed level.It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The EPA has two limits that apply toradioactive materials. An EPA limit of 15 millirem per year is derivedfrom criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).ttelAn additional limit of 4 millirem per year, as defined in 40 CFR S141.16,is applied to drinking water.trzl On October 9,2OO2, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-Iicensedsites. The Memorandum of Understanding (N{OID ttel provides that EPAwill defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceedsEPA-permitted levels; (2) NRC contemplates restricted release of thesite; and/or (3) residual radioactive soil concentrations exceed levelsdefined in the MOU.The MOU does not impose any new requirements on NRC licensees andshould reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria forunrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees. The present study does not include any costs for this occurrence.TLG Seruices, Inc. Three Mile Island. Unit 2D ecomrnissioning Coet AnalysisDocument F07-1676-007, Reu. 0 Sectinn 7, Page 10 of 13TABLE 1.1 INI\MNTORY OF SPENT FUEL AI.XILIARYAND FUEL HANDLING BUILDINGS I19]SNF Cubical Location Quantity (s)AX004 Seal Injection Valve Room 30AX006 Make-up Pump 18 70AX007 Make-up Pump 1A 230AX015a Cleanup Filters 50AX015b Cleanup Filters 50AX114 MU&P Demineralizer 1A 1,060AX115 MU&P Demineralizer 18 130AX019 Waste Disposal Liquid Valve Room 10FH001 MU Suction Valve Room 460AX012 AB Sump Tank Room 100AX020 Reactor Coolant Bleed Tank 18 I,754AX020 Reactor Coolant Bleed Tank lC L,754AX021 Reactor Coolant Bleed Tank 1A 310AX024 AB Sump Filters 20AX112 Seal Return Coolers and Filter Room 300AX116 Makeup Tank Room 310 AX117 MU&P Filter Room 60AX131 Miscellaneous Waste Tank Room 100 AX128 Instrument and Valve Room 10AX218 Concentrated Waste Storage Tanks 10AX501 RB Spray Pump 1A 10AX502 RB Spray Pump 18 10AX503 DHR Pump 1A 10AX504 DHR Pump 18 10 FH003a MU Discharge Valves 10 FH003b MU Discharge Valves 100 FH004 Westinghouse Valve Room 160TLG Services, Inc. Three MiIe Island Unit 2 Decommissioning Co st Analysis Cubical FH101 FH112 FH1O9TABLE 1.1 (continued) INVENTORY OF SPENT FUELAI.XILIARY AND FUEL HANDLING BUILDINGS Document F07-1676-001, Rev. 0 Seetion l,Page 11 of 13 SNF Quantity (.e\324 10 3,800 L70 40 I1,460 LocationMU&P Valve Room AnnulusSpent Fuel Pool "A" Embedded Valves &([tIU System)Embedded Valves &(WDL System)TOTAL Piping PipingTLG Seruices, Inc. Three MiIe laland. Unit 2D e c omnr.issioning Co st An aly sis Document F07-1676401, Reu, 0Section I,Page 12 of 13 TABLE 1.2II\IVENTORY OF SPENT FUEL REACTOR BUILDING Area/ComponentReactor VesselRV Head Assembly RV Upper Plenum Assembly FueI Transfer CanalCore Flood System"A" D-ringUpper Endfitting Storage Area Reactor Coolant Drain Tank Letdown Coolers RB Basement and Sump Tool Decontamination Facility (347')Defueling Water Cleanup SystemDefueling Tool Rack Temp React Vessel Filtration System RB Drains Total SNF Quantity (g)925,000 1,300 2,r00 18,900 4,900 21,000 5,900 100 3,700 1,300 100 3,700 600 4,400 5,100 998,100TLG Seruices, Inc. Three Mile Island Unit 2 Decommissioning Coet AnolysisTABLE 1.3 INVENTORY OF SPENT FUELREACTOR COOLANT SYSTEM Docwnent F07-1676-001, Reu. 0 Section 7,Page 13 of I3 SNF Quantitv (s)500 1,500 1,400 1,700 4,000 900 7,200 600 36,000 9,100 10,100 1,800 2,400 400 4,600 6,200 88,400 Component Pressurizer (including surge line)Decay Heat Drop Line"A" SIDEOTSG Upper TubesheetTube Bundle Lower Head and J-legsHot LegsCold LegsCore Flood Line UB" SIDEOTSG Upper Tubesheet Tube BundleLower Head and J-legs Hot Legs CoId Legs Core Flood LineRCS Surface FilmsReactor Coolant Pumps TotaI TLG Sert:ices, Inc. Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1676407, Reu. 0 Section 2, Page I of I 2. DECOMMISSIOMNG ALTERNATIVESDetailed cost estimates were developed to decommission TMI-2 for three scenarios. Although the alternatives differ with respect to technique, process, cost, andschedule, they attain the same result: the ultimate release of the site forunrestricted use.Three decommissioning cost scenarios were evaluated for the nuclear unit. The scenarios assume that Exelon will operate the adjacent Unit 1 until its license expiration date in 2034. The scenarios are defrned as follows: DECON: The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a PDMS status to decommissioning in 2040. The decommissioning program for TMI'2 runs concurrently with the TMI-1 decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 10 years after Unit 1completes its decommissioning program (exclusive of the on-site ISFSIoperations for Unit 1 fuel).Delayed DECON: Unit 1 defers decommissioning until its spent fuel has beenremoved from the site. This scenario assumes that the decontamination anddismantling activities at TMI-2 are synchronized with the adjacent unit suchthat the licenses for both units are terminated concurrently.SAFSTOR: TMI-I is placed into long-term storage. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit1. As with the first scenario. termination of the licenses is coordinated. The nomenclature for these three scenarios is consistent with the Unit 1 decommissioning cost estimate. For each of the scenarios, Post-Defueling Monitored Storage (PDMS) costs of approximately $3.1 million per year have been includedfrom 2013 until Unit 1 shutdown in 2034 (DECON continues the PDMS chargesuntil 2040). Other decommissioning costs (including dormancy costs for the Delayed DECON and SAFSTOR scenarios) are only accrued following TMI-1 shutdown.The conceptual approach that the NRC has described in its regulations dividesdecommissioning into three phases. The initial phase addresses the transition of reactor operations (i.e., power production) to facility de-activation and closure. The second phase encompasses activities during the storage period or during majordecommissioning activities, or a combination of the two. The third phase pertains tothe activities involved in license termination. 1.2.3.TLG Serwices, Inc, Three Mile Island. Unit 2D ecotnmissioning Co st Analysis Docurnent F07-1676-001' Rev. 0 Section 2, Page 2 of IThe decommissioning estimates developed for TMI-Z are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures. The following sections describe the basic activities associated with each alternative.The three scenarios are essentiatly identical; all being variations of the NRC'sSAFSTOR scenario following a dormancy period. The technical assumptions are unchanged with the only difference in the second and third scenarios being thedelay in start of decommissioning expenditures and the additional storage costduring the delay period.Although detailed procedures for each activity identified are not provided, and theactual sequence of work may vary, the activity descriptions provide a basis not onlyfor estimating but also for the expected scope of work, i.e., engineering and planningat the time of decommissioning. The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effectivedate of permanent cessation of operations and involves the transition of bothnuclear unit and licensee from reactor operations (i.e., power production) tofacilitate de-activation and closure. This phase was completed when TMI-2 began the PDMS phase; the plant is in SAFSTOR dormancy.The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains tothe activities involved in license termination. The decommissioning estimates developed for TMI-2 are also divided into phases or periods; however, demarcationof the phases is based upon major milestones within the project or significantchanges in the projected expenditures.2.1 DECON As stated previously, the naming convention of the three Unit 2 decommissioning scenarios is consistent with the Unit 1 decommissioning scenarios. This scenario runs concurrent with the Unit 1 DECON scenario, and therefore is referred to as DECON for Unit 2, even though the unit is currentlyin SAFSTOR dormancy.2.7.7 Period 2 - Dormancy The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the PDMS phase from 2013 to 2040 for the DECON alternative (the delayed scenariosTLG Seruices, Inc. Three Mile Island. Unit 2D ecomtnissioning Co st Analysis Docurnent F07-1676-001, Reu. 0 Seetion 2, Page 3 of Iterminate PDMS with Unit 1 shutdown, and begin a standard SAFSTOR dormancy program in 2034). TMI-2 has been in a dormantcondition since entry into PDMS in December 1993. This estimate includes the yearly g3.1 million PDMS costs for maintaining TMI-2 until the start of decommissioning in 2040.Dormancy activities during PDMS includ.e a 24-hour security force(primarily provided by the operating Unit 1), preventive and corrective maintenance on security systems, area lighting, general buildingmaintenance, heating and ventilation of buildings, routine radiologicalinspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.Maintenance personnel perform equipment maintenance, inspectionactivities, routine services to maintain safe conditions, adequatelighting, heating, and ventilation, and periodic preventive maintenance on essential site services. Most site labor activities are provided by Exelon personnel under contract to FirstEnergy. An environmental surveillance program is carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented and/or detected and controlled. Appropriate emergency procedures are established and initiated for potentialreleases that exceed prescribed limits.Security during the dormancy period is conducted primarily to preventunauthorized entry and to protect the public from the consequences ofits own actions. Security is provided by fences, sensors, alarms, and other surveillance equipment. Fire and radiation alarms are also monitored.2.L.2 Period 3 - PreparationsPreparations include the planning for the removal of the remaining fuel'bearing components, decontamination of the structures and thedismantling of the remaining equipment and facilities. Typically, the process is described within a Post-Shutdown Decommissioning Activities Report (PSDAR) or a Decommissioning Plan (DP). Although the exact format and content of the decommissioning planning document has not been identified, as a minimum Technical Specification 3.2.l.L requires NRC approval prior to removal of greater than 42 kilograms of fuel fromthe reactor vessel. Thus in addition to the planning document, changes may be required to the existing technical specifications prior to the startof major decommissioning activities. TLG Seruices, Inc. Three Mile Island. Unit 2D e conm.issioning Co st An aly si sEneineerine and PlannineThe decommissioning program outlined in the PSDAR or DP will bedesigned to accomplish the required tasks within the AI,ARA guidelines (as defined in 10 CFR S20) for protection of personnel from exposure toradiation hazards. It wiII also address the continued protection of the health and safety of the public and the environment during thedismantling activity. Consequently, with the development of the decommissioning plan, activity specifrcations, cost-benefit and safetyanalyses, and work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities. The estimate assumes that FirstEnergy will provide project oversight.However, the majority of the professional, managerial, technical and administrative support staff will be provided by a decommissioningoperations contractor @OC).Document F07-1676-001, Reu. 0 Section 2, Page 4 of I areSite Preparations In preparation for active decommissioning, the following initiated:Characterization of the site and surrounding environs. Thisincludes radiation surveys of the reactor building including: thebasement and elevator block wall area, areas surrounding major components (including the reactor vessel and its internals, steam generators), internal piping, and primary shield cores. Surveys ofthe auxiliary and fuel handling building with emphasis on areaswith known and potential alpha contamination and know fission products. Surveys and sample analysis will also be performed onexterior buildings, land areas surrounding the facility, subsurfacesoil and groundwater.Specification of transport and disposal requirements for highlyradioactive waste and/or hazardous waste, including shielding andwaste stabilization.Development of procedurescontrol and release of liquid radwaste (including dry-active waste, resins, filter media, metallicand non-metallic components generated in decommissioning), sitesecurity and emergency programs, and industrial safety.for occupational exposure control, and gaseous effluent, processing ofTLG Senticee, Inc. Three Mile Island Unit 2D ecommissioning Co st Analysis Document F07-1676-001, Reu. 0 Section 2, Page 5 of I2.L.3 Period 4 - Decommissionine Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and highly radioactive components and structures, including the successful termination of the license. Significant decommissioning activities in this phase include: Construction of temporary facilities and/or modification of existingfacilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.Refurbishment of the containment air control envelope buildinglocated outside the reactor building equipment hatch. A prefabricated metal containment building located on the 305' level of the reactor building will be required for the handling of highly contaminated material being removed from the basement or the operating deck elevations.Modification of the containment structure to facilitate handling of large equipment. This will include an evaluation to determinewhether a temporary crane should be installed or whether the existing polar crane should be refurbished (the reactor vessel headwiII be the heaviest lift under the current removal scenario with thein-situ segmentation of the reactor vessel and steam generators).Reconfiguration and modification of site structures and facilities asneeded to support decommissioning operations. This may include the upgrading of roads and rail facilities (on' and off'site) tofacilitate hauling and transport. Modifications may also be requiredto the refueling area of the building to support the segmentation ofthe reactor vessel internals and component extraction.Design and fabrication of temporary and permanent shielding tosupport removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.Procurement Qease or purchase) of shipping canisters, cask liners, and industrial packages.Decontamination of components and structures as required to control (minimize) worker exposure. Decontamination of the reactor building so as to reduce workingarea dose rates and improve working conditions. The reactor building basement is known to be highty contaminated and willTLG Services, Inc. Three Mile Island Unit 2D ecommissioning Cost Analysia Document F07-1676-001' Reu. 0 Section 2, Page 6 of I require remote operations and tooling for the initialde contamination effort.Inventory, decontamination and removal of legacy equipmentinventory lefb over from the defueling campaign.Installation of a water processing system to filter and treat water from the reactor coolant system and fuel handling pool.Removal of piping and components no longer essential to supportdecommissioning operations. Removal of control rod drive housings and the head servicestructure from reactor vessel head. Segmentation of the vesselclosure head.Segmentation of the upper internals assemblies. The plenum iscurrently stored in the fuel transfer canal. Segmentation willmaximize the loading of the shielded transport casks, i.e., by weightand activity. The operations are conducted under water using remotely operated tooling and contamination controls.Disassembly and segmentation of the remaining reactor internals,including the core former and lower core support assembty. Allinternals components below the top of the fuel are expected to exceed Class C disposal requirements due to fuel contamination. Assuch, the segments will be packaged in modifi.ed fuel storage canisters for geologic disposal.Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air usingremotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in'air to containers that are stored under water, for example, in an isolated area of the refueling canal.Removal of the steam generators and pressurizer for materialrecovery and controlled disposal. Due to the high internal andexternal radioactivity, these components can not serve as their ownshipping containers. The steam generators are assumed to be segmented in-place. The pressurizer is assumed to be cut in half and shipped in a sealed and shielded shipping and burial container. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations.Removal of free standing concrete structures in the reactor building.TLG Services, Inc. Three Mile Island Unit 2 D ecom,missioning Co st Analysis Document F07-1676-001, Rev, 0 Section 2, Page 7 of IRemoval of the remaining internal structures within the reactor building including: the polar crane, inner pools and waII liners,biological shield, D-rings, floors and walls.At least two years prior to the anticipated date of license termination' a License Termination Plan (LTP) is required. Submitted as a supplementto the FSAR or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey,designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmentalconcerns. The NRC wiII notice the receipt of the plan, make the planavailable for public comment, and schedule a local hearing. LTPapproval will be subject to any conditions and limitations as deemedappropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:Removal of remaining plant systems and associated components asthey become nonessential to the decommissioning program orworker health and safety (e.g., waste collection and treatmentsystems, electrical power and ventilation systems).Processing of the structural material in the reactor, auxiliary andfuel handling buildings. Approximately 90% of the concrete removed at this stage is assumed to meet free release criteria. Theremainder is sent to a waste processor. The free-released concrete is available as fill. Excess concrete is disposed of in an industrial landfill.Removal of contaminated yard piping and. any contaminated soil.Transfer of greater-than-Class C (GTCC) material to the DOE.Surveys of the decontaminated areas not designated for complete removal and disposal.Remediation and removal of the contaminated equipment and mateiial from the auxiliary and fuel buildings and any other contaminated facility. Certain areas in the auxiliary and spent fuel handling buildings contain very high contamination and radiation levels and will require additional resource and increased radiological protection to complete the decontamination. Radiationand. contamination controls will be utilized until residual levelsindicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems TLG Seruices, Inc.o a a Three Mile Island, Unit 2 Decomrnissioning Co st Ana,lysis Doeument F07-1676-001, Rev. 0 Section 2, Page I of Iand components (both clean and contaminated) located within these buildings. This activity facilitates surface decontamination andsubsequent verifi.cation surveys required prior to obtaining releasefor demolition.Most of the power block structures @eactor, Auxiliary and FuelHandling) will be removed to below the building foundations /basemat to ensure that no radioactive material remains on site.Material that is designated as scrap or general disposal (survey andrelease) is transferred to a designed waste processing vendor for aconfirmatory survey and, if permitted, released for unrestricteddisposition. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and./or packaged forcontrolled disposal at a low-level radioactive waste disposal facility.Incorporated into the LTP is the Final Survey Plan. This plan identifiesthe radiological surveys to be performed once the decontaminationactivities are completed and is developed using the guidance provided inthe "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSI[0'"[20] This document incorporates the statistical approachesto survey design and data interpretation used by the EPA. It also identifies state-of-the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidanceensures that the surveys are conducted in a manner that provides a highdegree of confidence that applicable NRC criteria are satisfied. Once thesurvey is complete, the results are provided to the NRC in a format thatcan be verified. The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on final termination of the license.The NRC wiII terminate the license if it determines that siteremediation has been performed in accordance with the LTP, and thatthe terminal radiation survey and associated documentationdemonstrate that the facilitv is suitable for release.2.I.4 Period 5 - Site RestorationFollowing completion of decommissioning operations, site restorationactivities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits wiII result in substantial damage to many of the remaining structures. TLG Serttices, Inc. Three Mile Island, Unit 2De cornmissioning Co st Analysis Docurnent F07-fi7e00\ Reu. 0 Section 2, Page I of I This cost study presumes that non-essential structures and site facilitiesare dismantled as a continuation of the decommissioning activity.Foundations and exterior walls are removed to a nominal depth of threefeet below grade. The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established forerosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.Concrete rubble produced by demolition activities is processed to removerebar and miscellaneous embedments. The processed material is then used on site to backfill voids. Excess materials are trucked to an off-sitearea for disposal as construction debris.2.2 SAFSTOR and Delayed DECON The decontamination and. dismantling activities in this scenario are identicalto those described in Section 2.L for DECON. However, the start of active decommissioning is deferred to coordinate with the timing of the Unit 1 Delayed DECON and SAFSTOR scenarios. As such, the presence of the dormancy period incurs storage costs (correspondingly greater for the SAFSTOR scenario, with its longer dormancy period).While it is expected that radiation dose levels will decrease over the durationof the longer dormancy period, the nature of radionuclides involved and the difficulties in working in plant areas contaminated with these radionuclideswill require similar operational and radiological controls to those envisioned for earlier scenario. As such, there have been no changes incorporated into the costs to perform the field decommissioning activities identified in Section 2.1for this scenario. Note that, with Unit I permanently shut down, there are dormancy costs for Unit 2 included in the estimate following the cessation ofthe PDMS charges in 2034.TLG Services, Inc. Three Mile Island Unit 2 D e c omrn i ssi oning Co st An aly si s Document F07-1676-001, Reu, 0 Section 3, Page I of 27 3. COST ESTIMATE The cost estimates prepared for decommissioning TMI-2 consider the radiological status, unique conditions of the site, including the NSSS, power generationsystems, support services, site buildings, and ancillary facilities. The basis of theestimates, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.3.1 BASIS OF ESTIMATE The estimates rely upon site-specific, technical information originally developed in an evaluation prepared for the GPU Nuclear Corporation in 1995'96, and last updated for FirstEnergy in 2008. The information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluation were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.Some of the technical assumptions that were used are due to the unique nature and characteristics of the plant as a result of the March 1979 accident. Following the accident, TMI-2 was defueled and extensive decontamination activities were performed. This successfully removed approximately 99o/o of the original fuel and resulting fuel debris. Removal of the residual 1% was neithercost effective nor warranted due to the high radiation fields in the reactor building and adjoining auxiliary and fuel handling buildings. The remaining equipment and components containing spent nuclear fuel (SNF) will be removed, sealed and./or encapsulated in preparation for disposal during the decommissioning program.3.2 METHODOLOGYThe methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost pgf,imafss,r'[21] and the DOE "Decommissioning Handbook."t22] These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations. Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch)were developed using local labor rates. The activity-dependent costs were estimated with the item quantities (cubic yards and tons), developed from TLG Seruices, Inc, Three Mile Island Unit 2D ecommissioning Co st Analyeis Document F0 7- 16 76-00 1, Rev. 0 Section 3, Page 2 of 27 plant drawings and inventory documents. Removal rates and material costs forthe conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.t2sl This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well asthe decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and SanOnofre-l nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioningcommercial nuclear units.The unit factor method provides a demonstrable basis for establishing reliablecost estimates. The detail provided in the unit factors, including activityduration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the valuescontained within one set of factors developed for this analysis.Work Difficultv Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment and increase the time required to perform the activity. WDFs were assigned toeach unique set of unit factors, commensurate with the inefficienciesassociated with working in confrned, hazardous environments. The WDF sets were developed considering the extremely difficult working conditions associated with working in high radiation areas and in areas with high alpha particle contamination. The same work difficulty factor sets were used for all three scenarios. This assumption was based upon the relatively high levels oflong-lived radioactivity that exists today plus the high levels of alpha contamination. The factors and their associated range of values were developed in conjunctionwith the AIFA{ESP-036 study. The application of the factors is discussed in more detail in that publication. Given the radiological status of some areas at TMI-2, the range of the WDF's was increased. The ranges used for the WDFsare identified in the following table.TLG Serpices, Inc. Three Mile Island, Unit 2D e c onrniseion ing Co st An oly aie Document F07-1676-001' Reu. 0 Section S, Page 3 of 27 Work Difficulty Factors OtherPower Block FueUAux Buildings Reactor Building NSSS Components Access Respiratory Protection Radiation/ALARA

Protective Clothing Work Break 20o/o 0-25o/o L0-25o/o 0-30%8.33o/o 30%200o/o 40%50o/o 8.33%30%50%40%50o/o 8.33o/o 40o/o 200%l00o/o 50%8.33%Schedulins Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiologically controlled areas.As shown above, higher WDF's sets were assigned to systems located in the reactor building and to systems which contain SNF and/or high levels of radioactive materials. The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities are based upon productivity information available from the "Building Construction Cost Data" publication. An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.3.3 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS The DECON scenario for TMI-2 decommissioning operates independently from the adjacent Unit 2. The delayed decommissioning modes, Delayed DECON and SAFSTOR, consider opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities. There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. A summary of the principal impacts are listed below.TLG Seruices, Inc. Three MiIe Island. Unit 2D e c otnm i s sion in g C o st An aly si e Doeument F0 7-I 676-00 l, Reu. 0 Section 3, Page 4 of 27 Consistent with the agreement between FirstEnergy and Exelon regarding the timing of decommissioning activities at TMI'2, it isassumed that decommissioning at TMI-2 will not begin prior to 2O34.Under the terms of this agreement, decommissioning activities at Unit 2 cannot begin while Unit 1 is still in commercial operation. The decommissioning scenarios used in this analysis are structured to integrate to the extent possible with a Unit 1 decommissioning scenario.Since the security program for the site is likely to be an integrated approach, the security guard force is assumed to be shared to varyingdegrees between the units, depending upon the level of activities at eachunit. This reduces the security costs for the decommissioning estimatesfor both units on site.The final radiological survey schedule is also affected by a two-unit decommissioning schedule. It would be considered impractical to try to complete the final status survey of Unit 1, while Unit 2 still has ongoingradiological remediation work and waste handling in process. As such, this analysis has structured the decommissioning scenarios for Unit 2 tocoordinate the final status survev for the station.3.4 FINANCIAL COMPONENTS OF THE COST MODEL TLG's proprietary decommissioning cost model, DECCER, produces a numberof distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal, i.e., license termination and site restoration. 3.4.1 Contineency Inherent in any cost estimate that does not rely on historical data is theinability to specify the precise source of costs imposed by factors such astool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency isadded to each line item to account for costs that are difficult orimpossible to develop analytically. Such costs are historically inevitableover the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.The activity-and period-dependent costs are combined to develop thetotal decommissioning cost. A contingency is then applied on a line-itembasis, using one or more of the contingency types listed in the AIF/NESP-036 study. "Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' TLG Services, Inc. Three MiIe Island Unit 2 D e c otnnt i ssi onin g Co et An a ly si s Docunrent F07-1676-001, Rev, 0 Section 3, Page 5 of 27Handbook"[24] as "specific provision for unforeseeable elements of costwithin the defined project scope; particularly important where previous experience relating estimates and actual costs has shown thatunforeseeable events which will increase costs are likely to occur." Thecost elements in this analysis are based upon ideal conditions andmaximum efficiency; therefore, consistent with industry practice, a contingency factor has been applied. In the AIF/NESP-036 study, thetypes of unforeseeable events that are likely to occur in decommissioningare discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in thisanalysis, does not account for price escalation and inflation in the cost ofdecommissioning over the time intervals identffied for each scenario.The use and role of contingency within decommissioning estimates is not a "safety factor issue." Safety factors provide additional security andaddress situations that may never occur. Contingency funds are expected to be fully expended throughout the program. They also provide assurance that sufficient funding is available to accomplish theintended tasks. An estimate without contingency, or from which contingency has been removed, can disrupt the orderly progression ofevents and jeopardize a successful conclusion to the decommissioning process.For example, the most technologically challenging task indecommissioning a commercial nuclear station is the disposition of thereactor vessel and internal components, highly radioactive following the accident. The disposition of these components forms the basis of the critical path (schedule) for decommissioning operations. Cost andschedule are interdependent, and any deviation in schedule has a significant impact on cost for performing a specific activity.Disposition of the reactor vessel internals involves the underwatercutting of complex components that are radioactive and highlycontaminated with fuel debris. Costs are based upon optimumsegmentation, handling, and packaging scenarios. The schedule is primarily dependent upon the turnaround time for the heavily shieldedshipping casks, including preparation, loading, and decontamination ofthe containers for transport. The number of casks required is a functionof the pieces generated in the segmentation activity, a value calculatedon optimum performance of the tooling employed in cutting the various subassemblies. The expected optimization, however, may not be achieved, resulting in delays and additional program costs. For thisreason, contingency must be included to mitigate the consequences ofTLG Seruices, Inc, Three Mile Island Unit 2D ecommissioning Coet Analysis DecontaminationContaminated Component RemovalContaminated Component PackagingContaminated Component Transport Low-Level Radioactive Waste DisposalReactor SegmentationNSSS Component Removal Reactor Waste Packaging Reactor Waste TransportReactor Vessel Component Disposal GTCC Disposal Non-Radioactive Component RemovalHeavy Equipment and Tooling Supplies Engineering EnergyCharacterization and Termination Surveys ConstructionTaxes and Fees Insurance Staffing Operations and Maintenance Expenses Document F07-1676-001, Reu. 0 Seetian 3, Page 6 of 27 50o/o 25o/o to%L5o/o 25% 75%25o/o 25%25%5oo/o I5o/o t5%L5%25o/o 15%$%30%L5%L0%10%rc%L5%the expected inefficiencies inherent in this complex activity, along withrelated concerns associated with the operation of highly specializedtooling, field conditions, and water clarity. Contingency funds are an integral part of the total cost to complete the decommissioning process. Exclusion of this component puts at risk asuccessful completion of the intended tasks and, potentially, subsequentrelated activities. For this study, TLG examined the major activity'related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from I0o/o to 75Yo,depending on the degree of difficulty judged to be appropriate foom TLG's actual decommissioning experience. The contingency values usedin this study are as follows: The contingency values are applied to the appropriate components of theestimates on a line item basis. A composite value is then reported at theend of each estimate. For example, the composite contingency value TLG Sentices, Inc. Three Mile Island Unit 2D e c o tnrni s sion ing Co st An aly ei s Docurnent F07-1676-001' frev, 0 Section 3, Page 7 of 27 national commitments, e.g., in the ability waste forms for disposition or in thethe start and rate of acceptance of spent reported for the DECON alternative is 20.3%. Values for the otheralternatives are delineated within the detailed cost tables in AppendicesD and E.3.4.2 Financial RiskIn addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider whenbounding decommissioning costs relates to uncertainty, or risk.Examples can include changes in work scope, pricing, job performance,and other variations that could conceivably, but not necessarily, occur.Consideration is sometimes necessarT to generate a level of confidencein the estimate, within a range of probabilities. TLG considers thesetypes of costs under the broad term "frnancial risk." Included within thecategory offinancial risk are:Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, Iegal challenges, and national and local hearings. Changes in the project work scope from the baseline estimate,involving the discovery of unexpected levels of contaminants,contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous materialcontamination), variations in plant inventory or configuration notindicated by the as-built drawings.Regulatory changes, e.g., affecting worker health and safety, siterelease criteria, waste transportation, and disposal. Policy decisions alteringto accommodate certaintimetable for such, e.g.,fuel by the DOE.Pricing changes for basic inputs, such as labor, energ'y, materials,and burial. Some of these inputs may vary slightly, e.g. 'L0o/o to+20%; burial could vary from -50% ta+204o/o or more.It has been TLG's experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicatethat the chances of the base decommissioning estimate's being too high is a low probability, and the chances that the estimate is too low is a higher probability. This is mostly due to the pricing uncertainty for low'level radioactive waste burial. and to a lesser extent due to schedule TLG Seruices,Inc. Three Mile Island Unit 2D e c ommi ssionin g Co st An aly sis Doeurnent F0 7-1676-00 I, Reu. 0 Section 3, Page 8 of 27increases from changes in plant conditions and to pricing variations in the cost of labor (both crafb and staft). This cost study, however, does not include any additional costs for financial risk since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk should be revisited periodically and addressed through repeated revisions or updates ofthe base estimate.3.5 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study. Unless otherwise noted, these assumptions are applicable to all three scenarios.3.5.1 Spent Fuel Manaeement The cost to dispose of spent fuel generated from plant operations is not reflected within the estimates to decommission the TMI-2 site. The majority of the spent fuel was removed during the TMI'2 Clean'up Program's reactor vessel defueling effort which concluded in January 1990. Title to the spent fueI that was removed was transfened to the DOE.The remainder of the fuel (about lo/o) is dispersed within the primarysystem and to a lesser extent in other systems and structures. This residual material will be removed as radioactive waste and is included in the waste disposal volumes discussed in Section 5.Repository Availabilitlz There will be some wastes generated in the decommissioning of TMI-Z that are not suitable for shallow land burial and therefore cannot beshipped for disposal to either Waste Control Specialists or EnergySolutions. This material, primarily associated with systems andstructures contaminated with fuel debris, requires greater isolation from the environment. The estimates for TMI-2 assume the timely removal of waste designated for geologic disposal, without the need for interim on site storage (once containerized).TLG Services, Inc. Three Mile Island Unit 2 D ecornrnissioning Cost Analysis Document F07-1676-001, Rev. 0 Section 3, Page I of 27 3.5.2 Reactor Vessel and Internal ComoonentsThe majority of the reactor internal components have already been removed as a result of the accident recovery effort in the 1980's. These components are currently being stored within the reactor building. Thisestimate assumes that these components are segmented and shipped in shielded, reusable transportation casks commensurate with the start ofmajor reactor vessel removal activities, i.e., Period 4a of each scenario.The reactor pressure vessel and remaining internal components (essentially the core barrel, core former, thermal shield, and flowdistributor) are segmented and packaged for disposal in shielded, reusable transportation casks. Segmentation of the remaining internal components is performed in the refueling canal, where a turntable andremote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from ashielded work platform installed overhead in the reactor cavity.Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.It is anticipated that all neutron-activated components in the reactorvessel and internals would meet existing disposal requirements as delineated in 10 CFR 561, due to the short operating history. However,the fission products and transuranic material present on all surfaces inthe vessel and internals are expected to exceed Class C limits, in particular for those components located below the top of the core. Thereactor vessel and the upper portions of the internals are assumed tomeet Class A limits following decontamination.The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., GTCC. Althoughthe material is not classifi.ed as high-level waste, the DOE has indieatedit will accept this waste for disposal at the future high-Ievel waste repository.t2sl However, the DOE has not been forthcoming with anacceptance criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and wasteform requirements. For purposes of this analysis, the GTC0 has been packaged anddisposed of as high-level waste. It is also assumed that the DOE willaccept the GTCC material in a timely manner so as not to affect the TMI-2 decommissioning schedule. No additional costs are included forthe temporary storage of GTCC material.TLG Seruices, Inc. Three Mile Island. Unit 2 D e c omm i s sion ing Co st An aly ai s Document F07-1676-001, Reu. 0 Section 3, Page 10 af 27 Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complexsegmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric GGE) was able to dispose of the Trojan reactor as an intact package. However, its location on the Columbia River simplified the transportation analysis since:the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport;there were no man,made or natural terrain features between the plant site and the disposal location that could produce a large drop;andtransport speeds were very low, limited by the overland transportvehicle and the river barge.As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State.The characteristics of this arid site proved favorable in demonstratingcompliance with land disposal regulations.It is not known whether this option will be available for TMI-2. Futureviability of this option will depend upon the ultimate location of thedisposal site, as well as the disposal site licensee's ability to accepthighly radioactive packages and effectively isolate them from the environment. Consequently, the study assumes the reactor vessel willrequire segmentation, as a bounding condition.3.5.3 Steam GeneratorsWith the high levels of radioactivity and contamination both in thereactor building and within the steam generators, this estimate assumesthat the steam generators will be segmented in place instead of one piece removal.The removal sequence assumed for the estimate is as follows: Remove the upper steam generator channel head by wire sawingthe shell and tubes immediately below the upper tube sheet.Segment and decontaminate the upper channel head in the fuel transfer pool.TLG Seruices, Inc. Three Mile Island. Unit 2 D ecom.missioning Co st Analyeis Docurnent F07-1676-001, Reu. 0 Section 3,Page 11of27Install a steam generator work platform to allow in'place underwater segmentation of the steam generator internals. Remove the steam generator tubing and associated shroud and support plates.Remove the steam generator cylindrical shell.Remove the lower steam generator channel head.Segment and decontaminate the lower channel head in the fuel transfer pool.The steam generator tubing is packaged and shipped and buried as Class B waste. Steam generator tube support plates, shrouds, and shell plates are transported and buried as Class A waste. The estimateassumes that the steam generator channel heads will be decontaminatedusing a combination of machining and ultra high pressure (UHP) water sprays such that the components can be shipped and buried as Class A waste.Waste that is generated as a result of the machining and normalfiltering of the water in the steam generators and the fuel transfer pool is assumed to be highly radioactive and is packaged and transferred to the DOE as GTCC waste.3.5.4 Other Primarv Svstem ComponentsThe following discussion deals with the decontamination, removal and disposition of the pressurizer, reactor coolant piping, reactor coolant pumps and motors, and the core flood tanks. A combination of in-place decontamination, and remote decontaminationof components in the fuel transfer pool was assumed in the estimate.The pressurizer and the core flood tanks are decontaminated in'placeusing UHP. Once decontaminated, the pressurizer is cut in half, removed from the reactor building, grouted, and packaged in a shielded container for rail shipment and burial as Class A waste. The core floodtanks are assumed to be segmented, packaged and shipped as Class A waste.Hot leg piping is accessed by cutting a hole in the core barrel. A combination of underwater remote retrieval and vacuuming is used to remove fuel and fi.ssion product material. Hot and cold leg piping andTLG Seruices, Inc.a o a Three Mile Island. Unit 2D ecommissioning Co st Analysie Docurnent F07-1676-001, Reu. 0 Section 3, Page 12 of 27fittings are removed and placed in the fuel transfer pool for additional decontamination. Hydrolasing is used to remove radioactive materials. Removed material is collected using filters and demineralizers, packaged, and transferred to the DOE as GTCC material.Decontaminated piping is packaged, shipped and buried as Class A waste.The reactor coolant pump motors are removed intact and placed inshielded containers for rail transport and burial as Class A material.Reactor coolant pumps are disassembled and placed in the fuel transfer pool for decontamination. Pump components are decontaminated usingUHP to remove the majority of the radioactive material. Following decontamination, the components are packaged in shielded containersfor rail transport and buried as Class A material. Material removed as aresult of the decontamination process is collected using frlters andshipped as GTCC material. The estimates also assume that processwater used. for reactor coolant system decontamination and in the fuel transfer pool is processed using cesium/strontium preferential cation demineralizers. The resin waste is processed and buried as Class C radioactive waste.3.5.5 Other Svstems Known to Contain Hieh Levels of Radioactivity Systems in the reactor building and portions of systems in the auxiliary and fuel handling buildings are known to contain high levels of rad.ioactivity and potentially spent fuel material from the accident. The estimates recognize the difficulty in removing these components byincreasing the work difficulty factors associated with removal of these systems. The estimates also assume that these components will be packaged for direct disposal (no recycling). The disposal costs of these waste streams were also adjusted, as appropriate, to include curiesurcharges commensurate with the higher radioactivity levels.These systems and. components will be decontaminated with UHPsprays to removal fuel solids and sludge from fuel bearing components in the fuel and auxiliary buildings. Solids and sludge resulting from the UHP process will be transferred to the reactor building to be packagedin canisters used for NSSS decontamination.TLG Services, Inc. Three Mile Island Unit 2 D ecommissioning Cost Analysis Docurnent F07-1676-001, Reu. 0 Section 8, Page 13 of 27 3.5.6 Reactor Buildine Structures DecontaminationSignificant radioactive contamination exists throughout the TMI'2 reactor building. This contamination is due to fission products (eoSr and 137Cs in particular) released from the damaged fuel. The radiation levelsare not expected to decrease significantly from current levels due to thelong half lives of these elements. The dispersion of spent fuel within the reactor buitding includes alpha-decaying isotopes in addition to the beta and gamma radiation normally encountered during decommissioning. These unusual conditions require additional controls and moreengineered decommissioning methods to perform the structure decontamination and demolition. Based upon these conditions, the estimates assume that the entire interior structure of the reactor building is removed and disposed as potentially contaminated material.The lower elevations of the reactor building are highly contaminated. Significant activity has been absorbed in the concrete block walls, in the four-foot thick D-ring concrete walls, and on the lower level concrete floors. Initial decontamination of this area (Period 4a) is assumed to be performed using remotely-operated machines. Surface material will be bulk removed from the concrete walls, packaged in shielded casks and, on average concentration, buried as Class B waste (i.e., most of the debris mass will be Class A, but there will be hot spots ranging to ClassC or GTCC).Once the highly contaminated surfaces are decontaminated, free standing concrete walls will be removed (in Period 4b using moreconventional means) and shipped for direct burial as radioactive waste.The upper portion of the containment inner steel liner and the entire polar crane will be removed using conventional radioactive demolition techniques (in Period 4b) and packaged, shipped and buried asrad.ioactive waste. Following liner removal, the outer reactor building concrete walls wiII be demolished. This remaining structural material from the reactor building will be surveyed on site, with 90% of theconcrete volume assumed to meet free release criteria. The remaining 10% is sent to a waste processor. The free released concrete is acceptable for use as frll. Excess material will be sent to an industrial landfill.TLG Services, Inc. Three Mile Island Unit 2D ecommissioning Cost Analysis Doeument F07-1676-001, Reu. 0 Section 3, Page 14 of 27 3.5.7 Demolition of Other Contaminated StructuresSignificant contamination exists within the auxiliary and fuel buildings. Similar to the reactor building, locations within these buildings will require special engineered methods to safely decontaminate and disposeofthe structures. The estimate assumes that the entire auxiliary and fuel building structures (all walls and floors down to the footings) will be removed and the resultant structural material monitored and processed with the same criteria as the reactor building.Selected areas of the buildings will require remote operated machines and dedicated engineered ventilation systems and enclosures to allowdecontamination and material removal.3.5.8 Main Turbine and Condenser

The main turbine will be dismantled using conventional maintenance procedures. The remaining turbine internals wiII be removed to a laydown area. The lower turbine casings will be removed from their anchors by controlled demolition. This study recognizes that one of the Iow pressure turbine rotors and the main electrical generator hasalready been removed from the site. The main condensers will also be disassembled and moved to a laydown area. Material is then prepared for transportation to an off-site recycling facility where it will besurveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components will be packaged and readied for transport in accordance with the intended disposition. 3.5.9 Transportation Methods Contaminated piping, components, and structural material other than the highly contaminated reactor coolant system components and reactorbuilding structures will qualifr as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.tza1 The contaminated material will be packaged in Industrial Packages (IP'l,IP-z or IP-3, as defined in subpart t73.4LL) for transport unless demonstrated to qualifu as their own shipping containers. It is anticipated that the reactor vessel, after decontamination with UHP water sprays, and due to its limited operating lifetime, will qualify asLSA II or III, once the reactor internals and remaining fuel debris is TLG Seruices,Inc. Three Mile Island Unit 2D e c onr,m,i s si onin g C o st An aly sis Document F07-1676-001' Rev. 0 Section 3, Page 15 of 27removed. Portions of the reactor vessel internal components ateexpected to be transported to the DOE's geologic repository in spent fuelcasks bv rail. Waste resulting from fi.ltering and demineralization of the reactorcoolant system, and processing the fuel transfer pool water is assumed to require shipment in shielded truck casks. Transport of other highly radioactive waste such as reactor coolant system components, and waste from the decontamination of the reactor building basement are byshielded truck cask. Truck cask shipments may exceed 95,000 pounds, including payload, supplementary shielding, cask tie-downs, and tractor'trailer. The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internalsegments is designed to meet these limits.The transport of large intact components, e.g., large heat exchangersand other oversized components are by a combination of truck, rail, and/or multi-wheeled transporter.Truck transportation costs are estimated using published tariffs fromTri-State Motor Transit.t271The low-level radioactive waste requiring controlled disposal will be sentto the EnergySolutions facility in Clive, Utah. Memphis, Tennessee, isused as the destination for off-site processing. BuIk material shipped offsite to the waste processor or to EnergySolutions is primarily moved via gondola railcars.3.5.10 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in thedecontamination and dismantling processes is treated to reduce the totalvolume requiring controlled disposal. The treated material, meeting theregulatory and"/or site release criterion, is released as scrap, requiring nofurther cost consideration. Conditioning and recovery of the waste stream is performed off site at a licensed processing center.All options and. services currently available to FirstEnergy ford.isposition of the various waste streams produced by the decommissioning process were considered. The majority of the low-Ievelradioactive waste designated for direct disposal can be sent toEnergySolutions' facility in Clive, Utah. Therefore, disposal costs for TLG Seruices,Inc. Three Mile Island. Unit 2 D ecommissioning Cost Analysis Docurnent F0 7- I 6 76-00 I, Reu. 0 Section 3, Page 16 of 27 Class A waste were based upon Firstfinergy's agreement with EnergySolutions. This facility is not licensed to receive the higher activity portion (Classes B and C) of the decommissioning waste stream.Very low-level radioactive waste, e.g., structural steel and contaminated concrete, is sent to a waste processing facility. More highty contaminated and activated material is sent to EnergySolutions.Disposal fees are based upon current charges for operating waste.Waste Control Specialists (WCS) is licensed to receive the higheractivity waste forms (Classes B and C). As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicative information on the cost for such from WCS.The Idaho National Engineering and Environmental Laboratory (INEEL) is currently storing waste from the TMI-2 defueling operation.Costs have been included in this estimate to pay INEEL for the final disposal of this waste; the timing of when this payment occurs will be dependent upon the DoE's schedule for cleanup of INEEL. Thisestimate assumes that the payment occurs during Period 4 of each cost scenario.This study assumes that most of the concrete resulting from thedemolition of the reactor, auxiliary and fueI handling buildings can be surveyed and" released on site for fill of below grade voids, or shipped offsite to a local construction debris landfill. Should there be restrictions tothis approach; the cost impact on the decommissioning program could become quite large, potentially up to tens of millions of dollars.3. 5. 1 1 Additional Decommissionine FacilitiesAdditional specialized facilities are required in support of the d.ecommissioning. These include refurbishment of the containment aircontrol envelope building located outside the reactor building equipmenthatch, and the contamination control cubicle located outside the other personnel airlock, for reactor building radiological control and access.Construction of a prefabricated metal enclosure at the 305 foot elevationwithin the reactor build.ing for the handling of highly-contaminatedmaterial will be required. A radioactive waste packaging and processingfacility will also be required (Note that such a facility already exists onsite, but wiII require refurbishment).TLG Seruices, Inc. Three Mile Island Unit 2D e c omrnissionin g C o st An aly ei s Document F07-1676-001' Reu. 0 Section 3, Page 17 of 273.5.12 Remediation of Soil and Undersround Pipine The estimates include the cost to remove certain underground piping.An allowance is also included for the removal, packaging, transportation and disposal of approximately 49,000 cubic feet of contaminated soil.3.5. 13 Site Conditions Following Decommissionine The NRC will terminate (or amend) the site licenses if it determines thatsite remediation has been performed in accordance with the license termination plan, and that the termination survey and associateddocumentation d.emonstrate that the facility is suitable for release. The NRC's involvement in the decommissioning process will end at this point. Building codes and environmental regulations will dictate thenext step in the decommissioning process, as well as the owner's own future plans for the site. Non-essential structures or buildings severely damaged in decontamination process are removed to a nominal depth of three feet below grade. Concrete rubble generated from demolition activities is processed and made available as clean fill. The excavations will beregrad.ed such that the power block area will have a frnal contour consistent with adjacent surroundings.This estimate assumes the reactor, auxiliary, fuel buildings will beremoved completely, i.e., down to and including their foundations and basemats. Concrete from these buildings will be surveyed on-site using conventional monitoring equipment; concrete which meets the releasecriteria will be disposed of either on site as fill, or in an off'site landfill.3.6 ASSUMPTIONSThe following are the major assumptions made in the development of theestimates for decommissioning the site.3.6.1 Estimatine BasisThe study follows the principles of AI"ARA through the use of work duration ad.justment factors. These factors address the impact ofactivities such as radiological protection instruction, mock'up training,and the use of respiratory protection and protective clothing. The factorsIengthen a task's duration, increasing costs and lengthening the overall schedule. AT.ARA planning is considered in the costs for engineering andTLG Services, Inc. Three Mile Island. Unit 2 D e c omrnissioning Co st Ana,ly si s Document F07-1676-001, Rev. 0 Section 3, Page 18 of 27 planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.All costs are reported in 2013 dollars.No costs have been included for the preparation of an environmentalimpact statement, should it be required.3.6.2 Labor CostsThe craft labor required to decontaminate and dismantle the nuclear units will be acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis. Costs forsite administration, operations, construction, and maintenance personnel are based upon average salary information provided by FirstEnergy or from comparable industry information. FirstEnergy will provide limited oversight support staff in the areas of overall management, licensing, radiological and industrial safety and engineering. It will also hire a DOC to provide the balance of the professional, management, administrative and physical staff.This study assumes that there is some sharing of security staffing positions with the adjacent Unit 1. This has the effect of lowering site security costs.3.6.3 Desien Conditions Fuel cladding failure as a result of the accident will most likely prevent shipment of untreated major NSSS components under current transportation regulations and disposal requirements. Therefore, thisestimate assumes that aggressive mechanical decontamination ofreactor coolant system components is required prior to shipment.The estimated curie contents of the vessel and internals are neutron activation products derived from those listed in NIIREGICP,'3474.I281Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the TMI-2 components,the operating history of 95 effective full-power days, and different period.s of decay. Additional short-Iived isotopes were derived from CR-0130 t2e1 and CR-0672t301and benchmarked to the long-lived values from CR-3474. The activation products present in the reactor vessel baseTLG Seruices, Ine. Three Mile Island Unit 2 D e c ommi ssi onin g C o st An aly eis Docurnent F0 7-I 6 76-00 1, Rev. 0 Section 3, Page 19 of 27metal are assumed to be the controlling factor in their disposal,following surface decontamination of fuel debris. Reactor vessel internals whose elevation in the reactor places them at or below the original top of the fuel assemblies are assumed to be both sufficiently geometrically complex to preclude effective decontamination and contaminated with spent fuel so as to require disposal as GTCC material.Control elements and incore detector assemblies are assumed to have been removed with the damaged fuel.Neutron activation of the reactor building structure and the biological shield is considered minimal due to the short operating life of TMI'2.3.6.4 General The plant staff will perform the following activities (FirstEnergy wiII be augmented as necessary, eitherby direct hiring, orsubcontracting to fulfiIl the staff requirements):Drain and collect lubricating oils for recycle and./or sale.Process defueling waste inventories, i.e., the estimates include costsfor the removal of lead shielding and spent fuel handling equipment that remains in the reactor building.Scrap and Salvase Material located within the rad.iation controlled area, and not shipped for direct disposal, is sent off-site for survey and release. Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers,and other property owned by FirstEnergy (and outside the radiationcontrolled area) is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also available for alternative use.EnereigFor estimating purposes, the plant is assumed to be de-energized, withthe exception of those facilities associated with long term dormancy.Replacement power costs are used for the cost of energy consumptionTLG Seruices, Inc, staff:by a a Three MiIe Island Unit 2D e c ommi ssionin g Co st An aly sis Docurnent F07-1676-001, Reu. 0 Section 3, Page 20 of 27 during decommissioning for tooling, lighting, ventilation, and essential services.InsuranceCosts for continuing coverage (nuclear liability and property insurance) during dormancy and decommissioning are included and based uponcurrent PDMS premiums and anticipated shared costs with the adjacent Unit 1. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage definedin the NRC's proposed rulemaking "Financial Protection Requirementsfor Permanently Shutdown Nuclear Power Reactors."tsll The NRC's financial protection requirements are based on various reactor configurations. Taxes Property taxes are not included. Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages ofthe project.3.7 COST ESTIMATE

SUMMARY

A schedule of expenditures for each scenario is provided in Tables 3.1 through3.3. Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in thousands of 2013 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure. The annual expenditures are based upon the detailed activity costs reported in Appendices C through E, along with the schedule discussed in Section 4.TLG Services, Inc. Three Mile Island, Unit 2D e c omrn i ssion ing Co st An aly si s Docutnent F07-1676-001, Reu. 0 Section 3, Page 21 of 27 TABLE 3.1DECON ALTERNATIVESCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars) Y Equipment &Labor Materials E BuriaI ear ne 20L3 2,486 0 224 0 326 3,036 20t4 2.486 0 224 0 326 3,036 20L5 2.486 0 224 0 326 3.036 20L6 2.493 0 224 0 327 3.044 2017 2,486 0 224 0 326 3.036 2018 2.486 0 224 0 326 3.036 2019 2.486 0 224 0 326 3.036 2020 2.493 0 224 0 327 3.044 2021 2.486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3.036 2024 2.493 0 224 0 327 3.044 2025 2,486 0 224 0 326 3,036 2026 2.486 0 224 0 326 3.036 2027 2,486 0 224 0 326 3,036 2028 2.493 0 224 0 327 3.444 2029 2,486 0 224 0 326 3.036 2030 2.486 0 224 0 326 3.036 2031 2.486 0 224 0 326 3.036 2032 2.493 0 224 0 327 3.044 2033 2.486 0 224 0 326 3.036 2034 2.486 0 224 0 326 3,036 2035 2.486 0 224 0 326 3.036 2036 2.493 0 224 0 327 3.044 2037 2,486 0 224 0 326 3,036 2038 2,486 0 224 0 326 3.036 2039 2.486 0 224 0 326 3.036 TLG Services, Inc. Three Mile Island. Unit 2 Decommissioning Cost Analysis Docutnent F07-1676-001, Reu. 0 Section 3, Page 22 of 27 TABLE 3.1 (continued)DECON ALTERNATIVESCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands, 2013 dollars)Y Equipment &Labor Materials E Burial ea a 2040 42,184 1.311 854 22 9.056 53.427 204L 57,835 6.878 1.r22 r4.512 7,989 88.337 2042 50.240 15.149 L.122 33.610 10.808 110.929204350.240 15.149 L.L22 33.610 10.808 110.929 2044 50,377 15.191 t.L25 33,702 10.838 111.233 2045 50.240 15.149 r,t22 33.610 10,808 110.929 2046 47.661 12.938 t.024 27.5L7 8.718 97,858 2047 42.77L 8.743 838 15,960 4.752 73.063 204842.8888.767 840 16.004 4,765 73.263 2049 42.7778.743838 15.960 4,752 73.063 2050 42,77r 8.743 838 15.960 4.752 73,063 2051 4L.768 8,391 810 15,131 4.570 70.671 205224.33L4,863 255 814 1,091 31.354 2053 18,079 7.945 t04 1.820 47L 28.4r8Total67I,323 137.959 18.061 258.232 102.989 1.188,564 TLG Seruices, Inc. Three Mile leland. Unit 2 D e c otnmiseionin g Co st An a ly si e Document F07-1676-001' Reu, 0 Section 3, Page 23 of 27 TABLE 3.2 DELAYED DE CON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DGENDITURES (thousands, 2013 dollars)Equipment &Year Labor Materials Burial 2013 2.486 0 224 0 326 3.036 20r4 2,486 0 224 0 326 3.036 2015 2.486 0 2240326 3.036 2016 2.493 0 2240327 3.044 20L7 2.486 0 224 0 326 3,036 2018 2.486 0 224 0 326 3.036 2019 2.486 0 224 0 326 3,036 2020 2,493 0 224 0 327 3.044 202L 2.486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3,036 2024 2.493 0 2240327 3.044 2025 2,486 0 224 0 326 3.036 2026 2,486 0 224 0 326 3,036 2027 2.486 0 224 0 326 3.036 2028 2.493 0 224 0 327 3.044 2029 2,486 0 224 0 326 3.03620302,486 0 2240326 3,036 2031 2.486 0 224 0 326 3.036 2032 2,493 0 224 0 327 3.044 2033 2.486 0 224 0 326 3.036 2034 1,150 240 236 4 482 2.r12 2035 588 341 242 6 547 L.724 2036 590 342 242 6 548 r.728 2037 588 341 242 6 547 1,7242038588 341 242 6 547 L.7242039588 341 242 6 547 r.724TLG Services, Ine. Three Mile Island. Unit 2D e c onmi ssion in g Co st An aly si s Docurnent F07-1676-001, Reu. 0 Section 3, Page 24 of 27TABLE 3.2 (continued)DELAYED DECON ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DPENDITURES (thousands, 2013 dollars)Equipment &Year,abor Materials t 2040 590 342 242 6 548 r.728 2041 588 341 242 6 547 L,724 2042 588 341 242 6 547 1..724 2443 588 34L 242 6 547 t.724 2044 590 342 242 6 548 r.728 2045 2t.420 885 Dbb 15 4.901 27.776 2046 59.4r2 3.573 T.T22 5.6L7 9.680 79.404 2047 51.713 13.861 I.t22 30,900 9,785 107.381 2048 50.377 15.181L.L2533,687 ro.8241 1 1.194 2049 50.239 15.140 1.t22 33.595 10,795 110.890 2050 50.239 15.140 I,T22 33.595 10,795 110.890 205L 50,239 15.140L.L2233.595 10.795 110,890 2052 40.986 8.757 840 15.988 4.75r 71.322 2053 40.874 8.733 838 t5.945 4.738 7r.r28205440.874 8.733 838 r5.9454.7387L,L28 2055 40.874 8.733 838 t5,945 4.738 7t,L28 2056 40.986 8.757 840 15.9884.75L7L.322 2057 28.r32 3,949 456 4.649 2.275 39,461 2058 24.464 11.029 156 2,509 700 38.859 2059 1.008 469 6 L07 28 1.619 Total 65t.L22 L4L.727 19,459 258.t43 107,103 L.L77.554TLG Seruices,Inc. Three Mile Island. Unit 2 Decommissioning Cost Anolyeia Doeurnent F07-1676-001, Rev. 0 Section 3, Page 25 of 27TABLE 3.3SAFSTOR ALTERNATIVESCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars) Y LaborEquipment &Materials E ear 2013 2,486 0 224 0 326 3.036 20r4 2.486 0 224 0 326 3.036 2015 2.486 0 224 0 326 3.036 20t6 2.493 0 224 0 327 3.044 2017 2,486 0 224 0 326 3.036 2018 2,486 0 224 0 326 3,036 20L9 2.486 0 224 0 326 3.036 2020 2.493 0 224 0 327 3.O44 202t 2,486 0 224 0 326 3.036 2022 2.486 0 224 0 326 3.036 2023 2.486 0 224 0 326 3.036 2024 2,493 0 224 0 327 3.044 2025 2.486 0 224 0 326 3.036 2026 2.486 0 224 0 326 3.036 2027 2.486 0 224 0 326 3.036 2028 2,493 0 224 0 327 3,044 2029 2.486 0 224 0 326 3.03620302,486 0 224 0 326 3.036 203I 2.486 0 224 0 326 3.036 2032 2,493 0 224 0 327 3,04420332.486 0 224 0 326 3.036 2034 L.T47 239 236 4 48r 2.t07 2035 584 339 242 6 546 L.716 2036 585 340 242 6 548 1.72t 2037584339 242 6 546 1.716 2038 584 339 242 6 546 L,7L62039584339 242 6 546 1.716 2040 585 340 242 6 548 t.721 204t584339 242 6 546 I.7T6 2042 584 339 242 6 546 L.7L6 2043 584 339 242 6 546 1.716 2044 585 340 242 6 548 r.72LTLG Seruices, hr.c. Three Mile Island Unit 2D e c ornrni s sionin g Co st An aly si s Docurnent F0 7-16 76-00 1, Reu, 0 Section 3, Page 26 of 27 TABLE 3.3 (continued) SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2013 dollars)Equipment & YearLabor Materials Burial2045584 339 242 6 546 1.7162046584 339 242 6 546 t.7L6 2047 584 339 242 6 546 r.716 2048 585 340 242 6 548 t.721 2049 584 339 242 6 546 1,716 2050 584 339 242 6 546 r.716 205r584339 242 6 546 L.716 2052 585 340 242 6 548 I.72I 2053 584 339 242 6 546 1.716 2054 584 339 242 6 546 1.7162055584 339 242 6 546 1.716 2056 585 340 242 6 548 L.7272057584 339 242 6 546 1.716 2058 584 339 242 6 546 1.716 2059 584 339 242 6 546 1.716 2060 585 340 242 6 548 L.72L 2061 584 339 242 6 546 t.716 2062 584 339 242 6 546 t.7L6 2063 584 339 242 6 546 T,7L6 2064 585 340 242 6 548 t.72L 2065 584 339 242 6 546 L.7t6 2066 584 339 242 6 546 t,7L6 2067 584 339 242 6 546 1.716 2068 585 340 242 6 548 1.721 2069 584 339 242 6 546 1,7t6 2070 584 339 242 6 546 1,716 207r 584 339 242 6 546 1.716 2072 585 340 242 6 548 L.72r2073584 339 242 6 546 1.716 2074 584 339 242 6 546 L.7t62075584 339 242 6 546 L.716 2076 585 340 242 6 548 L.721TLG Serttices, Inc, Three Mile Island Unit 2D e c ommi s sioning Co st An aly sis Document F0 7-1 6 76-00 1, Reu. 0Section 3, Page 27 of 27 Y TABLE 3.3 (continued)SAFSTOR ALTERNATIVE SCHEDULE OF TOTAL ANNUAL DGENDITURES (thousands, 2013 dollars) Equipment &terials ear Labor Ma 2077 584 339 242 6 546 1.716 2078 584 339 242 6 546 t.7L6 2079 584 339 242 6 546 1.716 2080 585 340 242 6 548 L.72L20815.872 477 321 8 1,651 8.330 2082 59.162 2,301 L.L22 L.449 11,987 76.02r 2083 54.3L2 11.604 1.T22 26,L47 7.999 101.178 2084 50.377 15,L77 t.125 33,673 10.81811 1.171 2085 50.239 15.136 L.L22 33.581 10.789 110.867208650,239 15.136 L.L22 33.581 10.789 110.867 2087 50.239 15,136 t.t22 33,581 10.789 110.867 2088 43,42L 10.455 916 20.657 6,353 81.802 208940.8018.729 838 15.920 4.729 7L,017 2090 40.801 8.729 838 15.920 4.729 7t.0r7 209140,9018.729 838 15.920 4.729 7T,OL?209240.9138,753 840 15.963 4.742 7L,2LT 2093 32.864 5.738 599 8,866 3.193 5I.259209424.035 8.524 196 1.821 857 35.434 2095 7.527 3.503 46 803 207 12.086 Total l 671.870i L53,977 1 28,227 258.L57 l 126,834 1.239,065 TLG Services, Inc. Three Mile Island Unit Z Decommissioning Cost Analysis Docurnent F07- 1676-00 7, Rev. 0 Section 4, Page I of 6

4. SCHEDULE ESTIMATE The schedules for the decommissioning scenarios considered in this study follow the sequence presented in the AIFAIESP-036 study, with minor changes to reflect recent experience and site-specific constraints.A schedule or sequence of activities is presented in Figure 4.1 through 4.3 for the threedecommissioning scenarios.

The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividingsome activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project 2010' computer seft"'r4rc.[3214.I SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the sitedecommissioning activities, i.e., a PERT @rogram Evaluation and Review Technique) Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost tables, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of thedecommissioning schedule:The DECON alternative begins decommissioning of TMI'2 in 2040. The existing PDMS yearly costs of $3.1 million are continued until that date.The existing PDMS yearly costs cease upon the shutdown of the adjacentUnit 1 on April 19, 2034 for the Delayed DECON and SAFSTORscenarios; normal SAFSTOR dormancy costs will commence at that dateuntil decommissioning begins.The Delayed DECON alternative defers decommissioning of TMI-2 untilTMI-1's spent fuel has been removed from the site. This scenario assumesthat the decontamination and dismantling activities at TMI-2 are synchronized with the adjacent unit such that the licenses for both unitsare terminated concurrently. The SAFSTOR alternative places TMI-2 into long-term storage along withTMI-I. TMI-2 remains in storage until such time that decommissioning activities can be coordinated with Unit

1. As with the second scenario,termination of the licenses is concurrent.AII work (except vessel and internals removal and some of the decontamination of NSSS components in the refueling canal) is per'TLG Serttices, Inc.

Three Mile Island Unit 2D e c ommi ssionin g C o st An oly eis Document F07-1676-001' Reu. 0 Section 4, Pa,ge 2 of 6formed during an 8-hour workday, 5 days per week, with noThere are eleven paid holidays per year.Steam generator removal activities are performed with limited parallelwork on the A and B steam generators.Reactor and internals removal activities are performed by using separatecrews for different activities working on different shifts, with acorresponding backshift charge for the second shift.Multiple crews work parallel activities to the maximum extent possible,consistent with optimum efficiency, adequate access for cutting, removaland laydown space, and with the stringent safety measures necessalyduring demolition of heavy components and structures.Reactor building basement decontamination using remote equipment will occur prior to the start of reactor coolant system component removal.4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based uponthe durations developed in the schedule for decommissioning TMI'2. Durationsare established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical pathduration for each period is used as the basis for determining the period'dependent costs.Project timelines are provided in Figures 4.2 through 4.4.TLG Seruices,Inc. Three Mile Island Unit 2D ecommissioning Cost Analysis Document F07-1676-001, Reu. 0 Section 4, Page 3 of 6 FIGURE 4.1 DECON ACTIVITY SCHEDULElask Name ,oa'ral,rsl'l,rl'se '&'3s l '44'49'gIAtr Urxit ? DECOI{ B*hoduh!F E I@w!-@I w-W t i , , ffi i,......:; i'M,ri,,, ', i,i,, K i, f si wi:li: ,, d;;;. @'!it li li'ri ,li*{$,$,il :: ,il ,,,,F i'iF iE.i,w :., iF:::i w',,i ffi w w K F m M@W,,, i, I I@,@.i,,'-is ic i,t, rll iw P*iod t&c - PDMBDolmenoy P;isil;;;td"i -st.;'i;Poiod fu - n""*tir-t f.'"ii SHea*fir"ate {Jnit I i*;;it-d;;;d;;6 "ariscoN p*t#*.i"# A" D-l*3",t bEcoNParisil,ta lTnit ? - Large cmponrnt renrsvalF}:IAB, Coutrnol, guttn* Blai. O&D*acsag*.:rrixate Rc.retor Bldg Leqt.r latcl* oecoata;;;ilr pr"*' dtdc u;p"t t*Rcroo!"e PB,, RCP's g nCg pirn"ti (Ire p*"tt"iiO. tr-i""t NSSS C"-p*""-i;A Stean Geoefrtor Bamo:ralRemar-e icsulaiionEre.*t nork pl*tfu::c I*trll t-*p **rppott* g C/H lif*i"g t"g"C"r & raruor-r "pe"i"l""""i h;;a -----Cut & rrmow ffC;b*a*---- L;ii,'g src-Gb-#

'"f";"."""i'#n

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*c*ndnrg:i{e, *ut & rer**ll;e *bell wallRe:nor'e lot*er ch*n:rel L**d **nbl"B Etea:n a.*rt"r i"*oirlReactcr l'eesel Rssovil 9re,ry1*1]qy-

&r Reler*r'*.es*el yye+'al&te.cisr $ressurr l'agssl r*lgeyal Feriod 4b Unit Z . sit* Deao;ta-i"itl"*ti;n'"t &'6."*; BHs Deb "'"-Fuel llaadli:rg Auxiliars Elde B&DLiaercr T"tei""dm S"rtrt Ph&id---- -O".uit" sorr.tg & r.elea* of plant conmoditiesD-Rd; & Bi*t.,ld

'";;iAeactec El.dg . Lines r*uror,*

'-" *;;i*-Bt{c & B"**;'iffi;iis"* Llnilergmun& giping & soil reurediatienP*riod {e L'nit t . Pldnt Uoe""e t t*laa*oI'ilrs! iisams $rr',e3*\]fi,C Ttai&ca{i*rrr arrd retiewFart 5O Soeqse tffiilrrtedi;'i"d 5tdnit's]sil n sto'iti* ---Rexsre rr m ainin g b"rtdid;--- 9,:*-:m3*PxF-y*4rod Landec,ap*TLG Seruices, Inc. Three Mile Island. Unit 2D e c ornm.issionin g C o st An aly sis DecommissioningAcouals BeginPeriod 0aPDMS Mmitorirg Document F07-1676-001, Reu. 0 Section 4, Page 4 of 6 FIGURE 4.2DE COMMISSIONING TIMELINE DECON (not to scale)Period 5 Site RestcationTLG Services, Ine. Three Mile Island Unit 2D e c ommi ssionin g C o st An aly sis Period 1 SAFSTOR TMI-2 DecommlsslonlntAccruals Bedn Period 2 TMF2 Delayed DECON Dormancy A Apr-2034 FIGURE 4.3 DECOMMISSIONING TIMELINE DELAYED DECON (not to scale)Period 3 De@mmissioning Preparations Document F07-1676-001, Reu. 0 Section 4, Page 5 of 6 Period 4 Decommissionlng OpeEtionsPeriod 2 DormancyPeriod 5 Site Restoratlon TMI.2 Re6ctlv!tlon TLG Seruices, Inc. Three Mile Island. Unit 2D e c ornm i ssion ing Co st An aly sis TMI.2 DecommissionlntAeruals BeginPeriod 2 TMI.2 custodial sAFsToR Dormancl Document F07-1676-001, Rev, 0 Section 4, Page 6 of 6FIGURE 4.4 DECOMMISSIONING TIMELINE SAFSTOR (not to scale)TMFl Shutdom Period 2 Dormancy Period 3 D*commissioning Preparations Period 4 Decommissioning OperationsPeriod 5 Site Restoration TMI.2 R*actlvatlonTLG Seruices, Ine, Three Mile Island. Unit 2 Decommissioning Cost Analysis disposal of radioactive materials and radioactive material as it pertains tospecifies its disposition. Docutnent F07-1676-001, Reu. 0 Seetion 5, Page I of 7 processes. In particular, $71 defines packaging and transportation and 5615. RADIOACTIVE \ryASTESThe objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. This currently requires the remediation of all radioactive material atthe site in excess of applicable legal limits. Under the Atomic Energy Act,t33l 16" NRC is responsible for protecting the public from sources of ionizing radiation. Title10 of the Code of Federal Regulations delineates the production, utilization, andMost of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR 5173-178. Shipping containers are required to be Industrial Packages (IP-l, IP-2 or IP-3, as defined in subpart 173.411). For this study, commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Largercomponents can serve as their own containers, with proper closure of all openings, access ways, and penetrations. Figure 5.1 summarizes the categories of radioactive waste streams and theirdisposition. Figure 5.2 identifies of the intended disposal site and processing center.The volumes of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendices C, D, and E andsummarized in Tables 5.1 through 5.3. The quantified waste volume summariesshown in these tables are consistent with $61 classifications. The volumes calculated based on the exterior dimensions for containerized material and on displaced volume of components serving as their own waste containers. The reactor vessel, internals, other reactor coolant system components, and certainstructural materials are categorized. as large quantity shipments and, accordingly,will be shipped in reusable, shielded truck casks with disposable liners or LSA boxes shipped within shielded vans. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload.Most of the waste generated by the decommissioning process appears to be Class Cor less, based. upon the available information regarding the amount of fission products and transuranics present in the buildings, and the quantities of building materials assumed shipped as radioactive waste. This basis should be reexamined if TLG Seruices,Inc. are the Three Mile laland. Unit 2D ecommissioning Cost Ana.lysis Doeument F07-1676-001, Reu, 0 Section 5, Page 2 of 7additional characterization information becomes available in the future regarding the quantities of fission products and transuranics in more localized surveys.No process system containing/handling radioactive substances at the time of decommissioning is presumed to meet material release criteria by decay alone, i.e., systems radioactive in 2013 will still be radioactive over the time period duringwhich the decommissioning is accomplished, due to the presence of long-lived radionuclides. While the dose rates decrease with time, radionuclides such as 137Cswill still control the disposition requirements.The waste material generated in the decontamination and dismantling of TMI'2 isprimarily generated during Period 4 of the defined alternatives.Disposal fees are calculated using current disposal agreements, with surcharges added for the highly activated components, for example, generated in thesegmentation of the reactor vessel. The cost to dispose of the majority of the material generated. from the d.econtamination and dismantling activities is basedupon FirstEnergy's disposal agreement with EnetgySolutions for its facility in Clive, Utah.EnergySolutions is not able to accept the higher activity waste (Class B and C)generated in the decontamination of the reactor vessel and segmentation of thecomponents closest to the core. As such, for this analysis, disposal costs for the Class B and C waste were based upon the preliminary and indicative information on the cost for such from WCS.TLG Seruices, Inc, Three Mile Island, Unit 2D ecommissioning Cost Analyeis i ; ti"*"g---\ tow-iild RadiDactivt waste'r--*"...::-T.: Document F0 7- I 6 76-00 7, Reu. 0 Section 5, Page 3 of 7 FIGURE 6.1TMI.2 WASTE STREAMS

SUMMARY

Resin N5S5 D*contamlnatlon , (OassB/!i,, ,TLG Servicea, Inc. Three Mile Island. Unit 2D e c ommi ssio n ing Co st An a,ly ei s Doeument F07-1676-001, Rev. 0 Seetion 5, Page 4 of 7 FIGURE 5.2DE COMMISSIONING WASTE DESTINATIONS RADIOLOGICALTLG Services, Inc. Three Mile Island. Unit 2D e c orntnission in g C o st An aly sis Docurnent F07-1676-001, Rev. 0 Section 5, Page 5 of 7 tUTABLE 5.1DECON ALTERNATIVE DECOMMISSIOMNG WASTE

SUMMARY

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 Columns may not add due to rounding WasteCost Basis Class It1 Waste Volume (cubic feet)Weight (nounds)Geolosic RepositorySpent Fuel GTCC 2.856 564.685 Equivalent 357 20,5r4 Primary waste stream wcs C 2,734 237,772 WCS B 26,9L8 1.928,673 Secondary waste stream EnerEvSolutions A r77.759 13.891,318Tertiarv waste stream Concrete EnerEySolutions A 613,465 66,003,571 SoiI EnerEvSolutions A 48.992 3.723,4L4 DAW EnerwSolutions A 17,010 340.195 Survev & Release 61,736 3.704,L37Processed Waste (Off-Site)Recycling Vendors 67,958 2.843,938 Totalt2l 1.019.785 93,258,2L7 TLG Seruiees, Inc. Three Mile Island Unit 2 Decommissioning Cost Analysis Document F07-1676'001, Reu. 0 Section 5, Page 6 of 7 t1l I2l TABLE 5.2DELAYED DECON ALTERNATIVE DECOMMISSIONING WASTE

SUMMARY

Waste is classifred according to the requirements as delineated in Title10 CFR, Part 61.55 Columns may not add due to rounding Waste Cost Basis Ql2sg ttl Waste Volume (cqbis tp.pt)_"" Weight (oounds)Geolosic RepositorvSpent Fuel GTCC 2.856 564.685 Equivalent 357 24,5t4 Primarv waste stream WCS c 2.734 237.772 WCS B 26,918 1,928,673Secondary waste stream EnersySolutions A L77.438 13.872.058Tertiarv waste stream Concrete EnersvSolutions A 613.465 66,003,572 Soil EnercySolutions A 48.992 3.723.4L4 DAW EnersySolutions A 18.060 361.194Survev & Release 61,736 3.704,L37Processed Waste (Off-Site)Recycling Vendors 67.958 2.843.938 fefsltzl L,020,5L4 93,259,957TLG Seruices, Inc. Three Mile Island. Unit 2D e c ommi ssi onin g Co st An aly ei s Docurnent F07-1676-001, Reu, 0 Section 5, Page 7 of 7 IU TABLE 6.3 SAFSTOR ALTERNATIVEDE COMMISSIONING WASTE

SUMMARY

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 Columns may not add due to rounding.Waste Cost Basis Qlssg ttl Waste Volume (cubic feet)Weight (pounds)Geoloeic RepositorvSpent Fuel GTCC 2,856 564,685 Equivalent 357 20.5L4Primarv waste stream wcs C 2,734 237,772 WCS B 26.918 1.928.673Secondary waste stream EnergySolutions A 176.490 13.805.128 Tertiarv waste stream Concrete EnerEvSolutions A 613.465 66,003,568 Soil EnergySolutions A 48,992 3.723.474 DAW EnercvSolutions A 2L,4L5 428.298 Survev & Release 61,736 3,7A4,137 Processed Waste (Off-Site)Recycling Vendors 68,950 2.895.277 Totalt2l 1"023,913 93.311.466TLG Services, Inc. Three Mile Island Unit 2 D e c omm. i ssion ing Co st An aly si e Document F0 7-16 76-00 I, Reu. 0 Section 6, Page 7 of 56. RESULTS The analysis to estimate the costs to decommission TMI-2 relied upon the site'specific, technical information developed in 1995-96 and last updated in 2008. While not an engineering study, the estimates provide FirstEnergy with sufficient information to assess its financial obligations, as they pertain to the eventualdecommissioning of the nuclear station. The estimates described in this report are based on numerous fundamental assumptions, including regulatory requirements, project contingencies, radioactive waste disposal options, and site remediation requirements. The decommissioning scenarios assume that the remainder of the spent fuel (less than 1%), which isdispersed throughout the reactor coolant and support systems, is packaged, shippedand buried as radioactive waste. Some of the waste that is generated is assumed tobe GTCC. This waste is assumed to be transferred to the DOE at the time that it is processed and collected during the decommissioning. No costs have been includedfor the temporary storage of GTCC material.The cost projected to decommission TMI-2, i.e., by the DECON alternative, is estimated to be g1.19 billion. The majority of this cost (approximately 97%) is associated with the physical decontamination and dismantling of the nuclear unitso that the lieense can be terminated. The remaining 3% is for the demolition of the designated structures and limited restoration of the site. The costs for the other decommission alternatives, Delayed DECON and SAFSTOR, are estimated at $1.18 billion and $1.24 billion, respectively. The primary cost contributors, identified in Tables 6.1 through 6.3, are either labor'related or associated with the management and disposition of the radioactive waste.Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the d.ecommissioning, as well as the duration of the program. It isassumed, for purposes of this analysis, that FirstEnergy will oversee the decommissioning program, using a DOC to manage the decommissioning labor forceand the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities. However, once the license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site.The cost for waste d.isposal includes only those costs associated with the controlled disposition of the radioactive waste generated from decontamination and d"ismantling activities, includ.ing plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposal of TLG Seruices,Inc. Three Mile Island Unit 2 D ecommissioning Cost Analysis Docurnent F07-1676-001' Reu, 0Section 6, Page 2 of 5 the lower level material, including concrete and structural steel, is at theEnergySolutions facility. The more highly radioactive waste is sent to WasteControl Specialists in Texas. Highly contaminated components, requiring additionalisolation from the environment, are packaged for geologic disposal.Removal costs reflect the labor-intensive nature of the decommissioning process, asweII as the management controls required to ensure a safe and suecessful program.Decontamination and packaging costs also have a large labor component that is based upon prevailing union wages. Non-radiological demolition is a naturalextension of the decommissioning process. The methods employed indecontamination and dismantling are generally destructive and indiscriminate ininflicting collateral damage. With a work force mobilized to supportdecommissioning operations, non-radiological demolition can be an integratedactivity and a logical expansion of the work being performed in the process ofterminating the license.The reported cost for transport includes the tariffs and surcharges associated withmoving large component. ,rrd/o" overweight shielded casks overland, as well as the general expense, e.g., Iabor and fuel, of transporting material to the destinationsidentified in this report.License termination survey costs are associated with the labor intensive andcomplex activity of verifuing that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematicsurvey of all remaining plant surface areas and surrounding environs, sampling,isotopic analysis, and documentation of the findings. The status of any plant components and materials not removed in the decommissioning process will alsorequire confirmation and will add to the expense of surveying the facilities alone.Due to the complete removal of the reactor, auxiliary and fuel buildings, the finaltermination survey effort is reduced.The remaining costs include allocations for heavy equipment and temporaryservices, as well as for other expenses such as regulatory fees and the premiums fornuclear insurance.TLG Seruices, Inc, Three Mile Island. Unit 2 D e c omm issionin g Co st An a ly sie Docutnent F07-1676-001, Reu, 0 Section 6, Page 3 of 5 TABLE 6.1 DECON ALTERNATIVE DECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars)l1l I2l Includes engineering costs Columns may not add due to roundingCost Element Total Percentage Decontamination 35,403 3.0 Removal 189,064 15.9 Packaeine 28.008 2.4 Transportation 26,427 2.2Waste Disposal 276,LLz 23.2 Off-site Waste Processins 11.053 0.9ProEram Management [11 484.509 40.8 Securitv 55,590 4.7Insurance and Reeulatory Fees L5,766 1.3 EnerEv 18.061 1.5Characterization and Licensing Surveys 10.844 0.9 Property Taxes 0 0.0 Miscellaneous Equipment 23,851 2.OSite O&M 4,968 0.4PDMS MonitorinE 8.908 0.8 Total tzl 1",188,564 100.0 Cost Element Total PercentageLicense Termination 1,1-491099 96.7Site Restoration 39.467 3.3 Total tzl 1.188,564 100.0TLG Services, Inc, Three Mile Island Unit 2 Decommiesioning Cost Analysis Document F07-1676-001, Reu. 0 Section 6, Page 4 of 5 TABLE 6.2DELAYED DECON ALTERNATIVEDECOMMISSIONING COST ELEMENTS (thousands of 2013 dollars) trl I2l 131Includes dormancy costs following TM-l shutdown in 2034Includes engineering costsColumns may not add due to roundingCost Element Total ttl Percentage Decontamination 35,321 3.0 Removal 190.858 t6.2 Packaeine 28,007 2.4 Transnortation 26.310 2.2Waste Disposal 276.022 23.4 Off-site Waste Processins 11.053 0.9 Prosram Managemsnl tzl 472.755 40.2 Securitv 46,850 4.0 Insurance and Regulatorv Fees 21,899 1.9 Enersv 19"459 L.7 Characterization and Licensins Survevs 10.844 0.9Pronertv Taxes 0 0.0 Miscellaneous Equipment 26.259 2.2 Site O&M 4,968 0.4PDMS Monitorine 6.949 0.6 Total t31 L,L77,554 100.0Cost Element Total PercentaseLicense Termination 1,139,536 96.8Site Restoration 38.018 3.2 Total t31 L.I17,554 100.0 TLG Services, Inc. Three Mile Island. Unit 2 Decommissioning Cost AnalysisDocum.ent F0 7-1 6 76-00 1, Rev. 0 Sectian 6, Page 5 of 5TABLE 6.3SAFSTOR ALTERNATIVEDECOMMISSIOMNG COST ELEMENTS (thousands of 2013 dollars)lll 12)t31Includes dormancy costs following TMI-I shutdown in 2034Includes engineering costsColumns may not add due to roundingCost Element Total [tl Percentage Decontamination 35.286 2.9 Removal 196,595 15.9 Packaeine?8pQq, 2.3 Transportation 26.298 2.1Waste Disposal 275.884 22.3Off-site Waste Processins 11.206 0.9 Program ManaEement t2l 482.930 39.0 Securitv 56,699 4.6 Insurance and Regulatory Fees 4L.497 3.4 Energy 28.227 2.3Characterization and Licensine Survevs 10.844 0.9Propertv Taxes 0 0.0Miscellaneous Equipment 33.617 2.7 Site O&M 4,968 0.4PDMS Monitorine 6.949 0.6 Total t31 1.239.065 100.0Cost Element Total PercentageLicense Termination r.20t.o47 96.9 Site Restoration 38.018 3.1 fef2l tsl 1.239.065 100.0 TLG Seruicea, Inc. Three Mile Island. Unit 2 D ecommissioning Co et Analysis Document F07-1676-001' Reu. 0Section TPage 1of3 1.7. REFERENCES"Decommissioning Cost Estimate for the Three Mile Island, Unit 2," Document No. G01-1196-003, TLG Services, Inc., February 1996"Decommissioning Cost Estimate for Three Mile Island Unit 2," Document No.F07-1601-002, TLG Services, Inc., January 20093. U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and,72,"General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 etseq.), June 27, 1988 4. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 20035. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "RadiologicalCriteria for License Termination." Federal Register, Volume 62, Number L39 (p 39058 et seq.), July 21, 1997U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, "EntombmentOptions for Power Reactors," Advanced Notice of Proposed Rulemaking, FederalRegister Volume 66, Number 200, October 16,200L7. U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51,"Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 6L G,39278 et seq.), JuIy 29, 1996"Nuclear Waste Policy Act of 1982 and Amendments," IJ.S. Department of Energy's Offrce of Civilian Radioactive Management, 1982 BIue Ribbon Commission on America's Nuclear Future's Charter, http://cvbercemetery.unt.edn/archive/brc/201206?0215336/http://brc.eov/indgx.p hP?q=Pae./.h.*,.t"Blue Ribbon Commission on America's Nuclear Future, Report to the Secretaryof Energy," http://www.brc.eov/sites/defaulUfiIes /documents /brc finalreport ian2012.pdf, January 2012 Stratery for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013 8.9.10.11.TLG Seruices, Inc. Three Mile Island, Unit 2 Decommissioning Cost Analysis Dacurnent FA7-rc76-007, Rev, 0 Section 7 Page 2 of 3 13.t4.12.15.16. 17.18.19.20.21.,,7. REFERENCES (continued) 'Acceptance Priority Ranking & Annual Capacity ll.eport," DOE/RW-0567, July 2004"Low-Level Radioactive Waste Policy Act," Public Law 96-573, 1980"Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, January/ 15, 1986Waste is classified in accordance with U.S. Code of Federal Regulations, Title 10, Part 61.55"Establishment of Cleanup Levels for CERCI"A Sites with Radioactive Contamination " EPA Memorandum OSWER No. 9200.4-18, August 22, 1997 U.S. Code of Federal Regulations, Title 40, Part 141.1"6, "Maximum contaminant levels for beta particle and photon radioactivrty from man-made radionuclides in community water systems.""Memorandum of Understanding between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality onDecommissioning and Decontamination of Contaminated Sites," OSWER 9295.8-06a, October 9, 2002 Three Mile Island Unit 2 Post Defueling Monitored Storage Safety AnalysisReport, 1995 Update, Chapter 4 (Fuel), GPU Nuclear Corporation 1995"Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIIVD," NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIFATESP-036, May 1986W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.Department of Energy, DOE/EV/10128-1, November 1980 TLG Services, Inc. Three MiIe Island. Unit 2 D e c ornmi ssionin g C o st An aly si s Doeument F0 7- 16 7 6-00 I' Reu. 0 Section 7 Page 3 of 3 REFERENCES (continued)"Building Construction Cost Data 2013," Robert Snow Means Company, Inc.,Kingston, Massachusetts Project and Cost Engineers' Handbook, Second Edition, p. 239, AmericanAssociation of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984"Strategy for Management and Disposal of Greater-Than-Class C Inw-Level Radioactive Waste," Federal Register Volume 60, Numbet 48 k, 13424 et seq.), March 1995 U.S. Department of Transportation, Title 49 of the Code of Federal Regulations,"Transportation," Parts 173 through 178, 1996Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-109397 and Supplements, 2000J.C. Evans et al., "Long-Lived Activation Products in Reactor Materials"NUREG/CR-3474, Pacific Northwest Laboratory for the Nuclear RegulatoryCommission. August 1984 R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"NIIREG/CR-0l3O and addenda, Pacific Northwest Laboratory for the NuclearRegulatory Commission. June 1978H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a ReferenceBoiling Water Reactor Power Station," NIIREG/CR-A672 and addenda, PacificNorthwest Laboratory for the Nuclear Regulatory Commission. June 1980"Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors," 10 CFR Parts 50 and 140, Federal Register Notice, Vol. 62, No. 210,October 30, 1997"Microsoft Project 2010," Microsoft Corporation, Redmond, WA, 2010'Atomic Enerry Act of 1954," (68 Stat. 919) 7.23.24.25.26.27.28. 29.30.31.32.33.TLG Seruices, Inc. Three MiIe Island Unit 2 D e c ommi ssioning Co st An aly si s Document F07-1676-001, Reu, 0 Append.ix A, Page I of 4 APPENDD( AUNIT COST FACTOR DEVELOPMENTTLG Seruices, Inc. APPENDD(AUMT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.1. SCOPEThree Mile Island. Unit 2 Decornmissioning Co st AnalysisHeat exchangers weighing < 3,000 lbs. will be removed small hoist. They will be disconnected foom the inlet exchanger will be sent to the waste processing area.2. CALCULATIONS Act Activity ID DescriptionDocum.ent F07-1676-001, Rev, 0 Append,ix 4 Page 2 of 4 rn one plece usrng a crane orand outlet piping. The heat Activity Duration (minutes)Critical Duration (minutes)* a b c d e f o b h iRemove insulation Mount pipe cutters Install contamination controls Disconnect inlet and outlet linesCap openings Rig for removalUnbolt from mounts

Remove contamination controlsRemove, wrap, send to waste processing area Totals (Activity/Critical) 60 60 2A 60 20 30 30 15 60 355 (b)60 (b)60 (d)30 30 15 60 255 64 64 383 115 498 42 544 Duration adjustment(s) : + Respiratory protection adjustment (25o/o of.cntical duration)+ RadiatiodAl\IL\ adjustment (25% of ctitical duration)Adjusted work duration

• Protective clothing adjustment (30% of adjusted duration)Productive work duration+ Work break adjustment (8.33 % of productive duration)Total work duration (minutes)** Total duration

= 9.000 hr {'R* alpha designators indicate activities that can be performed in parallel TLG Serttices, Inc. Three Mile Isla,nd Unit 2 Decotnmissioning Cost Analysis

3. LABOR REQUIRED Crew Document F07-1676-001, Reu. 0 Append.ix 4 Poge 3 of 4 APPENDXA (continued)

Number Duration (hours)Rate ($ihr)Cost ($)Laborers Craftsmen ForemanGeneral ForemanFire WatchHealth Physics Technician Total Labor Cost 3.00 2.00 1.00 0.25 0.05 1.00 9.000 9.000 9.000 9.000 9.000 9.000 33.92 59.98 6r.79 65.28 33.92 48.84$915.84 r,079.64 556.11 r46.88 L5.26 439.56$3,153.29$24.50 $11.00$13.49$48.ee$7.84$56.834. EQUIPMENT & CONSUMABLES COSTS Equipment CostsConsumable s/lVlaterials Costs' universal sorbent 50 @ $o'49 sq ft {tl- Tarpaulins (oil resistant/fire retardant) 50 @ $0.22lsq ft {zt-Gas torch consumables 1@ $13.49/hr x t hr {3}Subtotal cost of equipment and materialsOverhead & profi"t on equipment and materials @ L6.00 o/o Total costs, equipment & materialTOTAL COST:Removal of contaminated heat exchanger <3000 pounds:Total labor cost:Total equipment/material costs:Total craft labor man-hours required per unit:$3,210.12$3,153.29$56.83 65.700TLG Sentices, Inc. Three Mile Island. Unit 2 De commiesioning Co st Analysis Document F07-1676-001, Rev. 0 Appendix 4 Page 4 of 4 D.NOTES AND REFERENCES r Work difficulty factors were developed in conjunction with the Atomic Industrial Forum's (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5of the "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIFAIESP-036, May 1986.* References for equipment & consumables costs:1. www.mcmas.ter.com online catalog, McMaster Carr Spill Control (71e3T88)2. R.S. Means (2013) Division 01 56, Section 13.60-0600, page 223. R.S. Means (2013) Division 01 54 33, Section 40'6360, page 688Material and consumable costs were adjusted using the regional indices for Harrisburg, Pennsylvania.TLG Seruices, Inc. Three Mile Island. Unit 2 D e cotnmi ssioning Co st An a.ly si s Docutnent F07-1670-001, Reu. 0 Appendix B, Page I of 7 APPENDD( BUNIT COST FACTOR LISTING (SAFSTOR: Power Block Structures Only)TLG Seruices, Inc. Three Mile Island. Unit 2 Decotnm.iesioning Cost AnolyeiaUnit Cost Factor APPENDD( BUNIT COST FACTOR LISTING (Power Block Structures Only)Docurnent F07-1670-001, Rev. 0 Append.ix B, Page 2 of 7 Cost/Unit($) Removal of clean instrument and sampling tubing, $/linear foot Removal of clean pipe 0.25 to 2 inches diameter, $Ainear foot Removal of clean pipe >2 to 4 inches diameter, $llinear foot Removal of clean pipe >4 to 8 inches diameter, $/linear foot Removal of clean pipe >8 to 14 inches diameter, $Ainear foot Removal of clean pipe >14 to 20 inches diameter, $/linear foot Removal of clean pipe >20 to 36 inches diameter, $/linear foot Removal of clean pipe >36 inches diameter, $llinear foot Removal of clean valve >2to 4 inches Removal of clean valve >4to 8 inchesRemoval of clean valve >8 to 14 inches Removal of clean valve >l4to 20 inches Removal of clean valve >20 to 36 inches Removal of clean valve >36 inches Removal of clean pipe hanger for small bore piping Removal of clean pipe hanger for large bore piping Removal of clean pump, <300 poundRemoval of clean pump, 300-1000 pound Removal of clean pump, 1000-10,000 pound Removal of clean pump, >10,000 pound Removal of clean pump motor, 300-1000 poundRemoval of clean pump motor, 1000-10,000 pound Removal of clean pump motor, >10,000 poundRemoval of clean heat exchanger <3000 pound Removal of clean heat exchanger >3000 pound Removal of clean feedwater heater/deaeratorRemoval of clean moisture separator/reheater Removal of clean tank, <300 gallons Removal of clean tank, 300-3000 gallonRemoval of clean tank, >3000 gallons, $/square foot surface area TLG Seruiceq Inc. 0.65 5.73 8.28 18.2r 32.80 42.69 62.52 74.66 L22.0r t82.L4 328.42 426.90 625.24 746.63 41.06 128.91 307.22 837.90 2,992.23 5,785.54 358.40 r,246.71 2,802.79 1,685.84 4,237.90 11,387.33 22,925.30 395.46 r,240.33 10.06 Three Mile Island, Unit 2D e c ornm,i ssionin g Co st Analy si sUnit Cost Factor APPENDD( BUNIT COST FACTOR LISTING (Power Block Structures Only)Document F07-1676-001, Rev. 0 Append,ixB, Page 3 of 7 Cost/Unit($)Removal of clean electrical equipment, <300 poundRemoval of clean electrical equipment, 300-1000 poundRemoval of clean electrical equipment, 1000-10,000 poundRemoval of clean electrical equipment, >10,000 poundRemoval of clean electrical transformer < 30 tonsRemoval of clean electrical transformer > 30 tonsRemoval of clean standby diesel generator, <100 kWRemoval of clean standby diesel generator, 100 kW to 1MWRemoval of clean standby diesel generator, >1 IVIWRemoval of clean electrical cable tray, $/linear foot Removal of clean electrical conduit, $Ainear foot Removal of clean mechanical equipment, <300 poundRemoval of clean mechanical equipment, 300-1000 poundRemoval of clean mechanical equipment, 1000-10,000 pound Removal of clean mechanical equipment, >10,000 poundRemoval of clean HVAC equipment, <300 poundRemoval of clean HVAC equipment, 300-1000 pound Removal of clean IIVAC equipment, 1000-10,000 pound Removal of clean IIVAC equipment, >10,000 poundRemoval of clean IIVAC ductwork, $/poundRemoval of contaminated instrument and sampling tubing, $/linear foot Removal of contaminated pipe 0.25 to 2 inches diameter, $llinear footRemoval of contaminated pipe >2 to 4 inches diameter, $/linear footRemoval of contaminated pipe >4 to 8 inches diameter, $Ainear footRemoval of contaminated pipe >8 to L4 inches diameter, $llinear footRemoval of contaminated pipe >14 to 20 inches diameter, $Ainear footRemoval of contaminated pipe >20 to 36 inches diameter, $llinear footRemoval of contaminated pipe >36 inches diameter, $/linear footRemoval of contaminated valve >2to 4 inchesRemoval of contaminated valve >4to 8 inchesTLG Seruices,Inc. 172.57 578.96 L,L48.82 2,659.64 1,878.11 5,319.28 1,888.50 4,212.30 9,7L8.57 IO.DD 6.65 L72.57 578.96 t,148.82 2,659.64 201.26 680.14 1,360.00 2,659.64 0.69 1.10 L5.52 26.I4 43.62 83.77 loa.79 138.62 164.58 329.26 398.41 Three Mile Island. Unit 2Decommissioning Cost AnalysisUnit Cost Factor APPENDD( BUMT COST FACTOR LISTING (Power Block Structures Only)Docutnent F07-1676-001, Rev. 0 Append.ix B, Page 4 of 7 Cost/Unit($)Removal of contaminated valve >8 to 14 inches Removal of contaminated valve >14 to 20 inches Removal of contaminated valve >20 to 36 inchesRemoval of contaminated valve >36 inches Removal of contaminated pipe hanger for small bore pipingRemoval of contaminated pipe hanger for large bore piping Removal of contaminated pump, <300 pound Removal of contaminated pump, 300-1000 pound Removal of contaminated pump, 1000-10,000 pound Removal of contaminated puop, >10,000 poundRemoval of contaminated pump motor, 300-1000 poundRemoval of contaminated pump motor, 1000-10,000 pound Removal of contaminated pump motor, >10,000 poundRemoval of contaminated heat exchanger <3000 poundRemoval of contaminated heat exchanger >3000 pound Removal of contaminated tank, <300 gallons Removal of contaminated tank, >300 gallons, $/square foot Removal of contaminated electrical equipment, <300 pound Removal of contaminated electrical equipment, 300-1000 pound Removal of contaminated electrical equipment, 1000-10,000 poundRemoval of contaminated electrical equipment, >10,000 pound Removal of contaminated electrical cable tray, $/linear footRemoval of contaminated electrical conduit, $/Iinear foot Removal of contaminated mechanical equipment, <300 poundRemoval of contaminated mechanical equipment, 300-1000 poundRemoval of contaminated mechanical equipment, 1000-10,000 poundRemoval of contaminated mechanical equipment, >10,000 pound Removal of contaminated IIVAC equipment, <300 pound Removal of contaminated IIVAC equipment, 300-1000 poundRemoval of contaminated IIVAC equipment, 1000-10,000 poundTLG Sentiees, Inc.796.48 L,0L2.72 1,345.01 1,604.65 r06.09 326.47 696.25 1,655.34 5,414.54 13,160.39 7rL.77 2,L99.r7 4,965.06 3,2L0.12 9,308.12 L,L62.67 23.76 545.67 1,339.76 2,573.65 5,2r0.82 26.68 L2.65 614.05 1,5t4.27 2,9L3.58 5,2L0.82 614.05 L,5L4.27 2,913.58 Three Mile Island Unit 2D ecomrnissioning Co at AnalysieUnit Cost Factor APPENDD( BUNIT COST FACTOR LISTING (Power Block Structures Only)Document F07-1676-001' Reu. 0 Append.ixB,Page 5of 7 Cost/Unit($)Removal of contaminated IIVAC equipment, >10,000 poundRemoval of contaminated IIVAC ductwork, $/pound RemovaVplasma arc cut of contaminated thin metal components, $/linear in.Additional decontamination of surface by washing, $/square footAdditional decontamination of surfaces by hydrolasing, $/square footDecontamination rig hook up and flush, $/ 250 foot length Chemical flush of components/systems, $/gallonRemoval of clean standard reinforced concrete, $/cubic yardRemoval of grade slab concrete, $/cubic yardRemoval of clean concrete floors, $/cubic yardRemoval of sections of clean concrete floors, $/cubic yard Removal of clean heavily rein concrete wI#9 rebar, $/cubic yardRemoval of contaminated heavily rein concrete wf#9 rebar, $/cubic yardRemoval of clean heavily rein concrete wfi#18 rebar, $/cubic yardRemoval of contaminated heavily rein concrete wI#18 rebar, $/cubic yardRemoval heavily rein concrete wi#18 rebar & steel embedments, $/cubic yardRemoval of below-grade suspended floors, $/cubic yardRemoval of clean monolithic concrete structures, $/cubic yardRemoval of contaminated monolithic concrete structures, $/cubic yard Removal of clean foundation concrete, $/cubic yardRemoval of contaminated foundation concrete, $/cubic yardExplosive demolition of bulk concrete, $/cubic yardRemoval of clean hollow masonry block wall, $/cubic yardRemoval of contaminated hollow mason-ry block wall, $/cubic yardRemoval of clean solid masonry block wall, $/cubic yardRemoval of contaminated solid masoruy block wall, $/cubic yardBackfiIl of below-grade voids, $/cubic yardRemoval of subterranean tunnels/voids, $/linear footPlacement of concrete for below-grade voids, $/cubic yardExcavation of clean material, $/cubic yardTLG Seruices, Inc. 5,zLO.82 t.57 3.03 5.90 29.59 5,166.38 15.07 r6L.72 204.76 384.77 L,r72.57 246.65 1,631.53 3L2.r7 2,15L.28 472.38 384.77 970.85 r,625.26 773.t2 L,5L2.45 34.4r L27.29 225.66 L27.29 225.66 29.40 140.98 106.48 3.72 Three Mile Island. Unit 2 Decomm.issioning Co st Ana,lysisUnit Cost Factor APPENDD( B UNIT COST FACTOR LISTING (Power Block Structures Only)Document F0 7-1 6 7 6-00 1, Reu. 0 AppendixB, Page 6 of 7 Cost/Unit($) Excavation of contaminated material, $/cubic yardRemoval of clean concrete rubble (tipping fee included), $/cubic yardRemoval of contaminated concrete rubble, $/cubic yardRemoval of building by volume, $/cubic foot Removal of clean building metal siding, $/square foot Removal of contaminatedbuilding metal siding, $/square footRemoval of standard asphalt roofing, $/square foot Removal of transite panels, $/square footScariffing contaminated concrete surfaces (drill & spall), $/square foot Scabbling contaminated concrete floors, $/square footScabbling contaminated concrete walls, $/square foot Scabbling contaminated ceilings, $/square foot Scabbling structural steel, $/square foot Removal of clean overhead crane/monorail < 10 ton capacityRemoval of contaminated overhead crane/monorail < 10 ton capacity Removal of clean overhead crane/monorail >10-50 ton capacity Removal of contaminated overhead crane/monorail >10'50 ton capacityRemoval of polar crane > 50 ton capacityRemoval of gantry crane > 50 ton capacity Removal of structural steel, $/pound Removal of clean steel floor grating, $/square footRemoval of contaminated steel floor grating, $/square foot Removal of clean free standing steel liner, $/square footRemoval of contaminated free standing steel liner, $/square footRemoval of clean concrete-anchored steel liner, $/square footRemoval of contaminated concrete-anchored steel liner, $/square foot Placement of scaffolding in clean areas, $/square foot Placement of scaffolding in contaminated areas, $/square footLandscaping with topsoil, $/acre Cost of CPC B-88 LSA box & preparation for useTLG Seruiees, Inc.32.49 23.55 22.75 0.34 r.67 2.95 2.60 2.56 9.36 5.46 t4.71 50.37 4.69 850.33 t,454.77 2,042.99 3,473.58 7,581.02 30,668.72 0.24 6.t7 10.94 1,5.27 27.59 ,.oo 32.10 13.55 18.24 2r,3L2.72 L,727.27 Three Mile Isla.nd Unit 2D ecornmissioning Cost Analysis Unit Cost Factor APPENDD( BUNIT COST FACTOR LISTING (Power Block Structures Only)Document F07-1676-001' Reu. 0 Append,ixB,Page 7of 7 Cost/Unit($)Cost of CPC B-25 LSA box & preparation for useCost of CPC B-12V 12 gauge LSA box & preparation for use Cost of CPC 8-144 LSA box & preparation for use Cost of LSA drum & preparation for useCost of cask liner for CNSI 8 120A cask (resins)Cost of cask liner for CNSI 8 120.A cask (frlters)Decontamination of surfaces with vacuuming, $/square foot L,584.45 1,301.09 8,595.11 192.13 7,110.93 6,993.18 0.96 TLG Seruiees, Inc. Three Mile Island. Unit 2 Decomnt issioning Cost Analysis Docurnent F07-1676-001, Reu. 0 Append,ix C, Page l of 8 APPENDX CDETAILED COST ANALYSIS DECONTLG Sercices, Inc. 3365 6F6iE+-_d ddaddd E .6 ' ii ad8:x RB gF5s.;_9-SeeEFBx ridj -FBEgp,: 3;s;3d J F jdjd BfiRFEqR*CEqgE. $FRE6 8B E3.33:8sS. j ddjd8S ?3Frt;N{ NacN-q--psqgess66g$E;iidi i d s SgFEeiEd@a$eg. EggF,sg$334835 B$igeF" EagEg EgPR*F BF.C,R.S NN3 6Ba g E85 P d I d'F I ts8," i .t i a*EEiitE;sEs giiiciE;EEE$gtx ':99:99 ?iNo! eF;;;;;; 5ii$Bi EE q gI I F r5s E $ {? se { A,e "*E i t "1 F,ii r-iEE ;, E* telilsl,gg.tii l g, r :5s f:ffB* E i EiilgiiEgif e i$jig3*i*lgia ! ! e : : :qo-oosoo9ll = l- !-N6' ; t-Ne!6@F6o: i.i--i--.a'1-.-.H iEE issEsi ! 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Document F07-1676-003, Reu. 0 ESCALATION ANALY$S for THREE MILE ISLAND UNIT 220 1 3 SITE-S PE CIFI C DE COMMISSIONING COST ESTIMATE prepared for FirstEnergy Corporation prepared byTLG Services,Inc. Bridgewater, Connecticut February 2015 Three MiIe Island. Unit 2 Escalation Analyeis Project M*,nnger Tschnicsl Manager Docurnent No. F07-1676-003, Rev.0 Page ii of iii{#b APPROVALS TLG Seruices, Inc. Three Mile Island, Unit 2 Escalation Ana,Iysis Docurnent No, F07-1676-003, Reu.0 Page iii of iii REVISION LOG TLG Sentices,Inc. Three Mile Island. Unit 2Escalation Analysis Document No. F07-1676-003, Reu.0 Page I of 12 DECOMMISSIOMNG COST ESCALATION STUDY PurposeThis report presents escalated costs for the estimates of the costs to decommissionThree Mile Is1and Unit 2 (TMI-2) for the selected decommissioning scenarios. Theestimates, escalated to the year of expenditure dollars, are designed to provide FirstEnergy Corporation @irstEnergy), with the information to assess its current decommissioning liability, as it relates to TMI-2.Basis This escalation analysis is based upon the recent decommissioning cost analysis performed for Three Mile Island Unit 2.r Explanatory information from this report is provided below.Three decommissioning scenarios were evaluated for Three Mile Island Unit 2 (TMI-2). The scenarios selected are representative of alternatives available to theowners and are defined as follows: DECON The adjacent TMI-I is promptly decommissioned upon the scheduled cessation of operations in 2034. TMI-2 transitions from a Post-DefuelingMonitored Storage (PDMS) status to decommissioning in 2A40. The decommissioning program for TMI-2 commences after TMI-1 shutdown and ismanaged independently from the TMI-I decommissioning effort; license termination of Unit 2 occurs in 2053, approximately 60 years after TMI'2 flrstentered PDMS. Delayed DECON Decommissioning of TMI-2 commences upon the removal ofTMI-l's spent fuel from the site in 205f . The decommissioning program for TMI'2 runs concurrently with the TMI-I decommissioning effort and concludes withthe termination of both licenses.SAFSTOR TMI-I is placed. into safe-storage with decommissioning deferred 60 years. TMI-2 remains in storage with decommissioning deferred until it can besequenced. with TMI-I. The decommissioning program for TML? mns concurrently with the TM-l decommissioning effort and concludes with thetermination of both licenses.t "Decommissioning Cost Analysis for Three Mile Island lJnit2," Document F07'1676-001, Rev. 0, TLG Services, Inc., December 2014.TLG Seruices, Inc.2.3. Three Mile Island, Unit 2Escalation Analysie Document No. F07-1676-003, Reu.0 Page 2 of 12The site-specific cost estimate was prepared by TLG Services, Inc. (TLG) in year 2013 (i.e., nominal) dollars. Because the actual decommissioning will not occur for many years and may continue for decades, the nominal-dollar estimates must be escalated into the year of expenditure. That is, we must determine the dollar valueof each year's expenditure at the time it is expected to be incurred. Those escalated dollars then provide the basis for fi.nancial planning and asset management.Because many of the decommissioning activities occur long in the future, smallfluctuations in escalation on the cost side, and investment earnings on the trustbalance side, have an exponential impact on the resources required over the long periods of time typically associated with decommissioning scenarios.In this analysis, TLG reviewed each applicable cost component separately tod"etermine the rate by which each component was expected to escalate annually.Using an accepted aggregation methodolog:y TLG determined the overall averagerate the decommissioning costs were expected to escalate annually for each unit and each scenario. The average rates are provided in the results section.The following narrative describes the methodology used to escalate the schedule of decommissioning expenditures. BackEround TLG developed the cost to decommission TMI-2 in year 2013 dollars; themathematics to transform those costs to the year in which they will actually be incurred is relatively straightforward,. The key to the analysis is selecting the appropriate forecasting indices for each of the major cost components. For that,TLG has relied. upon guidance from the Nuclear Regulatory Commission (NRC) and the industry-wide recognized expertise of IHS Global Insight.The NRC divides its reference costs for decommissioning into categories of labor,energy, and Low Level Radioactive Waste (LLR!V) disposal. To provide guidance tooperators and regulators and promote uniformity, the NRC periodically reissues NUREG-1307, "Report on Waste Burial Charges." NUREG-1307 is helpful in that itid.entifi.es the appropriate ind.ices that should be used to escalate the labor and energy cost components and provides historical changes in low level radioactivewaste disposal costs.TLG also allocates its costs for decommissioning into categories, with the NRC'slabor category further subdivided into "labor" and "equipment and materials," and an "other' category added for regulatory fees, property taxes and other unique orone-time expenditures.TLG Sercices,Inc. Three Mile Island. Unit 2Escalation Analysis Docurnent No. F07-1676-003, Reu.0 Page 3 of 12 Consistent with standards defrned in the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC), Topic 4L0-20,121 TLG develops future cash flows by escalating four of the cost categories (abor, equipment andmaterials, energy and other) with indices provided by IHS Global Insight ofLexington, MA. IHS Global Insight is a privately held company which acquiredGlobal Insight in 2008. The combined company includes well-known businessessuch as Cambridge Energy Research Associates (CERA), Jane's Information Group, and IHS Herold; it also includes the former companies known as DRI (DataResources, Inc.) and WEFA (Mharton Econometric Forecasting Associates). Since Global Insight has no direct index for escalation of low level radioactive wastedisposal costs, the escalation rate for LLRW disposal has been established using a broad-based inflation index (CPI, Services) combined with a comparative retrospective LLRW disposal cost escalation analysis.The timeframe of decommissioning typically exceeds that of the published indices; therefore for years beyond. the published index, the inflation factor is determinedusing a "moving-average" method, averaging the most recent 25 years of indices todetermine the future year index. This is a well-accepted methodology for determining longer-term projections and one that appropriate by IHS Global Insight as well.Assumntions and Methodolow has been reviewed and deemedThe base year (2013) costs were extracted from the "Decommissioning Cost Analysis for Three Mile Island Unit 2," issued in December 20L4, specifi.cally the Total costs cash flows from Tables 3.1 through 3.3.The decommissioning cost analysis analyzed the DECON, Delayed DECON andSAFSTOR scenarios. The primary objectives of the TMI-2 decommissioning projectare to remove the facility from service, reduce residual radioactivity to levels permitting unrestricted release, restore the site, perform this work safely, and complete the work in a cost effective manner. The selection of a preferred decommissioning alternative is influenced by a number of factors. These factorsinclude the cost of each decommissioning alternative, minimization of occupational rad.iation exposure, availability of low-Ievel waste disposal facilities, regglatory requirements, and public concerns. In addition, the existing agreement betweenFirstEnergy and the NRC requires decommissioning to be completed within 60 years of the beginning of the Post-Defueling Monitored Storage period, which beganin 1993. The DECON scenario in the cost estimate meets this requirement. 2 Accounting Standards Codification, Topic 4LO-20, Financial Accounting Standards Board, JuIy2009. ASC 410-20-55-14 states: "It is expected that uncertainties about the amount and timing of future cash flows can be accommodated by using the expected present value technique andtherefore will not prevent the determination of a reasonable estimate of fair value." TLG Seruices,Inc. Under the agreement with the owners of the adjacent Unit 1, TMI-Z wiII not begin d,ecommissioning prior to the final shutdown of Unit 1. The Delayed DECON and SAFSTOR methodology coordinates the Unit 1 and Unit 2 decommissioningoperations to a limited extent for cost sharing. The DECON methodology assumes that TMI-2 decommissions independent of Unit 1 activities. Contaminatedmaterials are removed, packaged, shipped and disposed of offsite. Clean materialsare surveyed for radioactive contamination and released as scrap metal orconstruction debris. In accordance with 10 CFR 50.S2(a)(9), a license termination plan will be developed and submitted for NRC approval at least two years prior to termination of the license. Following the license termination survey andtermination of the NRC license, all remaining site structures are removed to threefoot below grad.e elevation, and the subgrade voids backfilled with concrete rubble and structural frll. The site is frnally graded to conform to the surrounding area, and native vegetation placed for erosion control.Under the SAFSTOR methodolory, the facility is placed in a safe and stablecondition and maintained in that state, allowing levels of radioactivity to decrease through rad.ioactive decay, followed by decontamination and dismantlement. After the safe storage period., the facility will be decontaminated and dismantled to levels that permit license termination, similar to the DECON methodology. Decommissioning costs were divided into the five escalation categories, for which future rate of inflation factors were established. The five categories are:Three MiIe Island. Unit 2Escalation Analysis LaborEquipment & Material Energy LLRW Disposal Other Document No. F07-1676-003, Reu.0 Page 4 of 12 Wages, fringes and benefits for craft, salaries and benefits for professional workers, clerical, administrative, service, contract workers, as well as for certain trades Heavy equipment, specialty tooling, packaging, small tools, construction materials, consumables, rental equipment and temporary construction facilities (trailers) Electrical power purchases (as a large industrial customer) to support site operations Costs for the processing of low'Ievel radioactive waste asweII as for the controlled disposal of material that cannot be recovered (released for unrestricted use)Site operating costs (not already accounted for), for example, taxes, fees, and costs for specialized services and project support activities (may include unspecified contributions from labor, equipment and materials, andTLG Seruices, Inc. Three Mile Island, Unit 2Escalation Analysis Docurnent No. F07-1676-003, Rev,0Page 5 of 12transportation), and payments for one'time disposal services (e.g., Greater-than-Class-C radioactive waste, or GTCC)The currently projected total costs (in thousands of 20L3 dollars) to decommission the nuclear station, with the two scenarios analyzed, are as follows: DECON$1.188,564 Delayed DECON$L,177,554 SAFSTOR s1.239.065 The costs include the monies anticipated to be spent for operating license termination (radiological remediation) and site restoration activities. The costs arebased on several key assumptions in areas of regulation' component characterization, high-level radioactive waste management, Iow'level radioactive waste disposal, performance uncertainties (contingency) and site remediation andrestoration requirements. The following table reflects the percentage of each cost component relative to the total costs to decommission TMI-2: Escalation The following escalation indices were established for each of the five cost categories.The escalation indices for Labor, Equipment and Material, Energy and Other were provided by IHS Global Insight Company via their Datalnsight-Web online service.The indices used show the last update as 13 October 2OL4. Global Insight does not provide historical or projected costs for disposal of radioactive waste. As such, a TlG-developed LLRW Disposal/Recycling index was used in this escalationTLG Seruices, Ine. DECON Delaved DECON SAFSTOR Escalation Category Costs (Thousands of 201 3$)o/o of Total Cost Costs (Thousands of 2013$)%of Total Cost Costs (Thousands of 2013$)%of Total Cost Labor 67t.323 oo.D 65r.r22 OD.J 67L.870 54.2Equipment & Material 137.959 11.6 r4r.727 L2.0 r53.977 12.4 Enerey 18.061 1.5 19.459 L.7 28,227 2.3 LLRW Disposal 258.232 2L.7 258.143 2L.9 258,r57 20.8 Other Items 102.989 8.7 107.103 9.1 126.834 IQ.2 Three MiIe leland. Unit 2Escalation Analysis Docurnent No. F07-1676-003, Reu, 0 Page 6 of 12 analysis. This index is a combination of historical information through 20t4 fuom NRC publications for disposal site rates and projections using the Consumer PriceIndex, Services information provided by Global Insight as discussed previously.Forecast data for labor, equipment/ materials, energy, and general inflation were available through 2O39.In order to extrapolate beyond the available Global Insight data, TLG calculated a 25-year moving average inflation factor to extend the GlobalInsight indices through 2095, the end point of the TMI-2 decommissioning scenarios.Index Selection The following table identifies the Global Insight forecast data sets used for the four cost categories (exclusive of LLRW disposal). Consistent with the NRC's guidance,TLG escalates the labor component of its decommissioning cost estimates using anEmployment Cost Index (ECI) and the energ:y cost component with a Producer Price Index (PPD.Use of the Consumer Price Index, Services (CUSASNS) for general services, site operating costs and one-time expenditures is consistent with the intent of the index (the measure of the average change in prices over time of goods and services). Global Insight Forecast Database TLG Cost CategoryECI Total Compensation @CIPCTNS)Labor Expenditures Infl ation Producer Price Index, Machinery & Eouipment (WPIP11)Equipment/Nlaterial Expenditures Inflation Producer Price Index, Fuels and RelatedProducts and Power (WPIP05)Energy Expenditures Inflation Consumer Price Index. Services (CUSASNS)Other Items Expenditures Inflation TlG-Developed LLRW Disposal Price Index[Historical data based upon Barnwell published tari{fs; forecast data based uponthe Consumer Price Index, Services(CUSASNS) plus 1% additional to reflect above-inflation increases observed at theBarnwell burial sitel LLRW Disposal / RecyclingTLG Seruices, Inc. Three MiIe Island. Unit 2Escalation Analyeis Document No. F07-1676-003, Reu.0Page 7 of 12 LaborThe decommissioning process is labor intensive, with labor representing more thanhalf of the total cost. The estimates for TMI-2 include the cost of the craft labor performing field activities, the field supervision and support services, projectmanagement, administration, security, and costs for specialty contractors. TheEmployment Cost Index (ECI) is a measure of changes in labor costs. It is one of the principal economic indicators used by the Federal Reserve Bank. The index shows changes in wages and. salaries and benefit costs, as well as changes in totalcompensation. The ECIPCTNS index, provided by Global Insight, is a forecast of future changes in the cost of labor, defrned as compensation per employee hour worked. The self-employed, owners-managers, and unpaid family workers are excluded. from coverage. The ECI is designed as a fixed-weight index at the occupational level, thus eliminating the effects of employment shifts amongoccupations. Both components of compensation, wages/salaries, and benefits, are covered.In addition to TLG's judgment, IHS Global Insight has confi.rmed that the selected ind.ex is appropriate to use in determining the rate at which the labor costs will escalate over time.Equipment and Material Equipment and material costs in the decommissioning estimates include small toolsand consumables as well as the heavy construction equipment involved in thedismantling, d.emolition and movement of materials around the site. The Producer Price Indexes ePI) measures monthly average changes in selling prices received by d.omestic producers for their output. Most of the information used in the PPI is obtained by sampling of industries in the mining and manufacturing sectors of the economy. The indexes reflect price trends for a constant set of goods and servicesrepresenting the total output of an industry.TLG uses a broad-based escalation index, the Producer Price Index for Machinery and Equipment WPIP1l).In addition to TLG's judgment, IHS Global Insight has confirmed that the selectedindex is appropriate to use in determining the rate at which the equipment and material costs will escalate over time. EnergyEnerry costs in the decommissioning estimate include only direct energy purchases, primarily electric power and fuel oil for heating. TLG uses a broad'based power escalation index, ihe Producer Price Ind.ex for Fuels and Related Products and Power (WPP05). While the WPIPO5 index has some volatility (since it tracks inTLG Seruices,Inc. Three Mile Island, Unit 2Escalation Analysis Docutnent No. F07-1676-003, Reu.0 Poge 8 of 12 part the price of oil), the cost of energy in the decommissioning estimates is a small percentage and therefore has little effect on the overall escalation rate for decommissioning cost.In addition to TLG's judgment, IHS Global Insight has confirmed that the selectedindex is appropriate to use in determining the rate at which energT costs willescalate over time.Low Level Radioactive Waste Disposal The inflation index used for radioactive waste burial costs is the Global Insight Consumer Price Index, Services (CUSASNS), with an additional lo/o per year to account for differences observed (over the past 14 years) between low-level waste disposal rates reported in NRC NUREG-1307 documents and general servicesinllation rate (CUUR0000SAS) reported by the Bureau of Labor Statistics. Other"Othey costs in the decommissioning estimates include such items as licensing fees, taxes, special services (for example, a fee for the geologic disposal of GTCC waste),as well as labor-intensive activities such as radiological surveys that include costsfor off-site analytical services. Because the "Other" costs contain this variety of cost components, TLG uses a Consumer Price Index to project future expenditures. The CPI, Services index (CUSASNS) measures changes in the prices of goods and services. It is therefore more representative of the non-labor cost elements includedin the decommissioning estimates. Accordingly, the use of the CPI for "Other' costs reflects more accurately the cost components with the "Other category than the useof the "Labor" escalation factor as a proxy.In addition to TLG's judgment, IHS Global Insight has confirmed that the selected index is appropriate to use in determining the rate at which the "other" costs will escalate over time. ResultsWith the proper escalation indices identified, TLG escalated the cost per year for the five escalation categories using the Global Insight index corresponding to that year and escalation .uiegory. Tables 1 through 3 provide escalated schedules of annual expenditures for the DECON, Delayed DECON and SAFSTOR scenarios for TMI-2. The schedules detail each of the five escalation categories through to the endof each scenario's decommissioning period for Total Costs, as well as the costcategories of License Termination and Site Restoration.TLG Seruices, Ine, Three MiIe Island. Unit 2 Escalation Analysis Document No. F07-1676-003, Reu,0 Page I of 12No discounting of the escalated dollars was performed. Using the escalated cash flows for each unit, TLG determined the single-value yearly escalation rate which yielded the same sum of escalated dollars for each ofthe four tables. The rate, referred to as a composite average annual escalation rate,is tabulated for the four decommissioning cost cash flows as follows: DECON 2.77%Delaved DECON 2.78%SAFSTOR 2.85%In a similar fashion, the composite average annual escalation rates for each of the five escalation categories can be developed. The following table details thecomposite annual average rates for the three decommissioning scenarios. Composite Average Annual Rate (%o)Escalation Categorv DECON Delayed DECON SAFSTOR Labor 2.7L3 2.707 2.687 Equipment/ & Material 1.146 1.153 1.176 Enersv 2.200 2.L93 2.r49LLRW Disnosal 3.599 3.607 3.632 Other Items 2.628 2.631 2.644 Overall 2.774 2.784 2.853Similarly, the composite average annual escalation rates for the three costcategories identifred in the decommissioning cost estimate can also be developed. The values for the three d.ecommissioning scenarios are provided in lhe following table.Composite AveraEe Annual Rate ( )Escalation Category DECON Delayed DECON SAFSTORLicense Termination 2.795 2.805 2.87rSite Restoration 2.331 2.324 2.381 Overall 2.774 2.784 2.853TLG Seruices,Inc. sqlsr.dj' \S9 sta*^B (o\l sl{o o I gc fl EE EE 9Er E;i sit-gg iEE g*!3Ei a;!Egl;i!E tt EE'H!Eg ET tr&-s.I 6 t 5 t q f i rI rt 6 I i oooooo0 ooooooooooo)oooooo ooooooooooS ao6ooooooNooooo$)ooooooooooooooo.$HRRfr

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