L-HU-06-017, Supplement to Lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for the Monticello Nuclear Generating Plant

Supplement to Lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for the Monticello Nuclear Generating Plant

ML061380638
Person / Time
Site:	Monticello
Issue date:	05/05/2006
From:	Weinkam E Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-HU-06-017
Download: ML061380638 (93)

Text

1 Committed to Nuclear Excellence Nuclear Manaqement Company, LLC May 5,2006 L-HU-06-0 I7 10 CFR 50.75 10 CFR 50.54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 License No. DPR-22 Supplement to lrradiated Fuel Manaqement Plan and Preliminaw Decommissioning Cost Estimates for the Monticello Nuclear Generating Plant

Reference:

1) Nuclear Management Company, LLC (NMC) letter to the U.S. Nuclear Regulatory Commission (NRC), "lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for Monticello Nuclear Generating Plant," (L-HU-05-022) dated December 20, 2005, (ADAMS Accession No. ML053550522).

On December 20,2005, Nuclear Management Company, LLC (NMC) provided information concerning the lrradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for the Monticello Nuclear Generating Plant (MNGP)

(Reference 1). In response to questions raised during informal discussions with the NRC staff, Enclosure 1 provides supplemental cost information associated with an Independent Spent Fuel Storage Installation (ISFSI) planned for MNGP. Enclosure 2 provides a copy of "Decommissioning Cost Analysis for the Monticello Nuclear Generating Plant," dated October 2005, performed by TLG Services, Inc. for Northern States Power Co., d/b/a as Xcel Energy. The information in Enclosure 1 is based on the current operating license expiration date.

This letter contains no new commitments and no revisions to existing commitments.

h 700 First Street Hudson, Wisconsin 54016

Document Control Desk Page 2 of 2 Nuclear Management Company, LLC Enclosures (2) cc: Regional Administrator, USNRC, Region III NRR Project Manager, Monticello Nuclear Generating Plant, USNRC NRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC Xcel Energy (Attention: Charles Bomberger)

ENCLOSURE 1 Supplement to Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate On December 20, 2005, Nuclear Management Company, LLC (NMC) provided information describing the present Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for the Monticello Nuclear Generating Plant (MNGP) (Reference 1). This enclosure supplements Reference 1 in providing additional cost information associated with an Independent Spent Fuel Storage Installation (ISFSI) planned for MNGP. The information provided herein is drawn primarily from a study prepared by TLG Services, Inc. entitled, Decommissioning Cost Analysis for Monticello Nuclear Generating Plant, October 2005, included as Enclosure 2. NMC is submitting this financial information on behalf of the plant owner, Northern States Power Co., d/b/a as Xcel Energy. Inclusion of costs in this Supplement is not intended to acknowledge that these costs will ultimately be borne by Xcel Energy or NMC, as some (or all) are expected to be the responsibility of the U.S. Department of Energy as a result of the breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste.

1. What is the cost to load fuel into canisters and transfer the spent canister to the ISFSI?

The study assumes an approximate five year period to transfer spent nuclear fuel from wet (pool) storage to dry storage. The transfer to dry storage should begin with the plant MNGP shutdown in September 2010 and is projected to end in March 2016. Dry fuel transfer costs are estimated at $12.1 million and capital costs (purchase of canisters and overpacks) are estimated at $30.2 million. These cost values include contingency.

An average cost of $300,000 per cask was estimated for the labor to load/transport the spent fuel from the pool to the ISFSI pad, based upon industry experience. For estimating purposes, $100,000 of this cost represents the cost to transfer the fuel from the ISFSI to the U.S.

Department of Energy (DOE). This estimate did not include any costs for loading of canisters for fuel stored at the General Electric ISFSI pool facility in Morris, Illinois.

2. Define the start and completion of the construction of the ISFSI.

What is the cost to construct the ISFSI?

ISFSI construction is anticipated to commence in July 2007 and be completed by June 2008. Section 3.3 of the Final Environmental Impact Page 1 of 3

ENCLOSURE 1 Supplement to Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate Statement to Establish an Independent Spent Fuel Storage Installation at Monticello Nuclear Generating Plant, before the Minnesota Department of Commerce (Docket No. E002/CN-05-123) filed March 27, 2006, estimates the cost to construct the ISFSI at approximately $ 3.5 million.

3. What is the schedule for SNF transfer to DOE?

The Decommissioning Cost Analysis for MNGP (Enclosure 2) models transfer of spent nuclear fuel to DOE to begin in 2031 and end in 2039.

Total costs for DOE transfer are estimated at $4.6 million, including contingency.

4. What are the costs to operate both the wet and dry spent fuel storage facilities?

Annual costs (excluding labor) of approximately $630,576 and $75,353 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively. Operation of the spent fuel pool would be discontinued in 2016 after all fuel and greater-than-Class C (GTCC) waste materials are removed.

The Decommissioning Cost Analysis for MNGP (Enclosure 2, Table 3.1) estimates ISFSI operating costs average approximately $6.0 million per year. These costs include labor - $3.84 million, equipment and materials -

$0.168 million, energy - $0.059 million and other (NRC license, emergency planning, etc.) - $1.95 million. These values include contingency.

5. Explain the $10 million expenditure after fuel is removed from the ISFSI and the break out of the $5.2 million ISFSI expenditure.

The increase in expenditure for year 2039 in Table 1(Reference 1) includes approximately $8.8 million for disposal of GTCC waste with the balance for ISFSI operation. The estimated $5.2 million costs for year 2040 include ISFSI license termination, insurance, taxes, heavy equipment rental, energy, and labor costs. These values include contingency.

Page 2 of 3

ENCLOSURE 1 Supplement to Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate REFERENCE

1. Nuclear Management Company, LLC (NMC) letter to the U.S. Nuclear Regulatory Commission (NRC), Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for Monticello Nuclear Generating Plant, (L-HU-05-022) dated December 20, 2005, (ADAMS Accession No. ML053550522).

Page 3 of 3

ENCLOSURE 2 DECOMMISSIONING COST ANALYSIS FOR THE MONTICELLO NUCLEAR GENERATING PLANT PREPARED BY TLG SERVICES, INC.

OCTOBER 2005

Document X01-1526-003, Rev. 0 DECOMMISSIONING COST ANALYSIS for the MONTICELLO NUCLEAR GENERATING PLANT prepared for XCEL ENERGY SERVICES, INC.

prepared by TLG Services, Inc.

Bridgewater, Connecticut October 2005

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page iii of xiv TABLE OF CONTENTS SECTION PAGE EXECUTIVE

SUMMARY

...................................................................................vii-xiv

1. INTRODUCTION ..................................................................................................... 1-1 1.1 Objectives of Study ........................................................................................... 1-1 1.2 Site Description................................................................................................. 1-1 1.3 Regulatory Guidance ........................................................................................ 1-2 1.3.1 Nuclear Waste Policy Act...................................................................... 1-4 1.3.2 Low-Level Radioactive Waste Acts ...................................................... 1-6 1.3.3 Radiological Criteria for License Termination.................................... 1-6

2. DECON DECOMMISSIONING SCENARIO ......................................................... 2-1 2.1 Period 1 - Preparations..................................................................................... 2-2 2.2 Period 2 - Decommissioning Operations ......................................................... 2-4 2.3 Period 3 - Site Restoration ............................................................................... 2-8 2.4 ISFSI Operations and Decommissioning........................................................ 2-9

3. COST ESTIMATE..................................................................................................... 3-1 3.1 Basis of Estimate .............................................................................................. 3-1 3.2 Methodology ...................................................................................................... 3-1 3.3 Financial Components of the Cost Model ....................................................... 3-3 3.3.1 Contingency ........................................................................................... 3-3 3.3.2 Financial Risk........................................................................................ 3-6 3.4 Site-Specific Considerations............................................................................. 3-7 3.4.1 Spent Fuel Management....................................................................... 3-7 3.4.2 Reactor Vessel and Internal Components ......................................... 3-10 3.4.3 Primary System Components............................................................. 3-11 3.4.4 Main Turbine and Condenser............................................................. 3-12 3.4.5 Transportation Methods ..................................................................... 3-12 3.4.6 Low-Level Radioactive Waste Disposal ............................................. 3-13 3.4.7 Site Conditions Following Decommissioning .................................... 3-13 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page iv of xiv TABLE OF CONTENTS (continued)

SECTION PAGE 3.5 Assumptions.................................................................................................... 3-14 3.5.1 Estimating Basis ................................................................................. 3-14 3.5.2 Labor Costs .......................................................................................... 3-14 3.5.3 Design Conditions................................................................................ 3-15 3.5.4 General ................................................................................................. 3-15 3.6 Cost Estimate Summary ............................................................................... 3-18

4. SCHEDULE ESTIMATE ........................................................................................ 4-1 4.1 Schedule Estimate Assumptions ..................................................................... 4-1 4.2 Project Schedule................................................................................................ 4-2

5. RADIOACTIVE WASTES ........................................................................................ 5-1

6. RESULTS ................................................................................................................. 6-1

7. REFERENCES .......................................................................................................... 7-1 TABLES Summary of Decommissioning Cost Elements, DECON ............................... xiv 3.1 Schedule of Annual Expenditures, DECON ................................................. 3-19 5.1 Decommissioning Waste Summary, DECON ................................................. 5-3 6.1 Summary of Decommissioning Cost Elements, DECON ............................... 6-4 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page v of xiv TABLE OF CONTENTS (continued)

SECTION PAGE FIGURES 4.1 Activity Schedule .............................................................................................. 4-3 4.2 Decommissioning Timeline.............................................................................. 4-4 APPENDICES A. Unit Cost Factor Development............................................................................. A-1 B. Unit Cost Factor Listing...................................................................................... B-1 C. Detailed Cost Analysis, DECON.......................................................................... C-1 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page vi of xiv REVISION LOG No. CRA No. Date Item Revised Reason for Revision 0 10-05-05 Original Issue TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page vii of xiv EXECUTIVE

SUMMARY

This report presents an estimate of the cost to decommission the Monticello Nuclear Generating Plant (Monticello) for the DECON scenario following the scheduled cessation of plant operations. The analysis relies upon site-specific, technical information, originally developed in an evaluation in 2002-03,[1] updated to reflect current assumptions pertaining to the disposition of the nuclear unit and relevant industry experience in undertaking such projects. The updated estimate is designed to provide Xcel Energy Services, Inc., (Xcel) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The primary goal of the decommissioning is the removal and disposal of the contaminated systems and structures so that the plants operating license can be terminated. The analysis recognizes that spent fuel will be stored at the site in the plants storage pool and/or in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to a U.S. Department of Energy (DOE) facility. Consequently, the estimate also includes those costs to manage and subsequently decommission these storage facilities.

The estimate is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The estimate incorporates a minimum cooling period of approximately 51/2 years for the spent fuel that resides in the storage pool when operations cease. The estimate also includes the dismantling of non-essential structures and limited restoration of the site.

A single shutdown scenario was evaluated for the nuclear unit. The operating license for Monticello currently expires in September 2010. This date represents the expiration of the current NRC license; decommissioning activities at the unit begin on this date. An on-site ISFSI will be built to store spent fuel before the permanent plant shutdown. Spent fuel in the storage pool will be shipped to DOE or placed into the existing ISFSI within 51/2 years of shutdown so as to facilitate decontamination and dismantling activities within the fuel handling area of the reactor building.

Spent fuel storage operations continue at the site until the transfer of the fuel to the DOE is complete, assumed to be in the year 2039. Costs are included in the 1 Decommissioning Cost Study for the Monticello Nuclear Generating Plant, Document No. X01-1475-003, TLG Services, Inc., July 2003.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page viii of xiv estimate for this long-term caretaking activity. The decommissioning of the ISFSI is also included within the estimate.

Alternatives and Regulations The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.[2] In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning. The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

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 level that permits the property to be released for unrestricted use shortly after cessation of operations."[3]

SAFSTOR is defined as "the alternative in which the nuclear facility is placed and maintained in a condition that allows the nuclear facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."[4] Decommissioning is to be completed within 60 years, although longer time periods will be considered when necessary to protect public health and safety.

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."[5] As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material. In 1997, the Commission directed its staff to re-evaluate this alternative 2 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 et seq.), June 27, 1988.

3 Ibid. Page FR24022, Column 3.

4 Ibid.

5 Ibid. Page FR24023, Column 2.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page ix of xiv and identify 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.g., on engineered barriers.

In 1996, the NRC amended its decommissioning regulations to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.[6] The amendments allow for greater public participation and 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 staff for implementing the requirements of the 1996 amendments relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations.

Methodology The methodology used to develop the estimate described within this document follows the basic approach originally presented in the cost estimating guidelines[7]

developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning.

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.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for 6 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.

7 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page x of xiv unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur.[8] The cost elements in the estimate is based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry 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 inflation in the cost of decommissioning over the remaining operating life of the station.

The use and role of contingency within decommissioning estimates is not a safety factor issue. Safety factors provide additional security and address situations that may never occur. Contingency funds, by contrast, are expected to be fully expended throughout the program. Inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks.

Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. With the passage of the Low-Level Radioactive Waste Policy Act in 1980,[9] and its Amendments of 1985,[10] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

Monticello is currently able to access the disposal facility in Barnwell, South Carolina and the Envirocare facility in Clive, Utah (10 CFR 61 waste classification A only). However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation provides for South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. Despite the closing of one of the two currently accessible commercial disposal sites, it is reasonable to assume that additional disposal capacity will be available to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere. For estimating purposes, and as a proxy for future disposal facilities, waste disposal costs are 8

Project and Cost Engineers Handbook, Second Edition, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, p. 239.

9 Low-Level Radioactive Waste Policy Act of 1980, Public Law 96-573, 1980.

10 Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, 1986.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page xi of xiv estimated using available pricing schedules for the currently operating facilities, i.e., Barnwell and Envirocare.

High-Level Radioactive Waste Management Congress passed the Nuclear Waste Policy Act[11] (NWPA) in 1982, assigning the responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. Two permanent disposal facilities were envisioned, as well as an interim storage facility. To recover the cost, the legislation created a Nuclear Waste Fund through which money is collected from the sale of electricity generated by each nuclear power plant. The NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to initiate the disposal of spent nuclear fuel and high level waste, as required by the NWPA and the utility contracts. As a result, utilities have initiated legal action against the DOE. While legal actions continue, the DOE has no plans to receive spent fuel prior to completing the construction of its geologic repository.

Operation of DOEs yet-to-be constructed repository is contingent upon the review and approval of the facilitys license application by the NRC, and the development of a national transportation system. For comparison, the Private Fuel Storage consortium submitted an application for an interim storage facility in 1997. The NRC granted an operating license for the facility in September 2005, after eight years of review. With a more technically complex and politically sensitive application for permanent disposal, it is not unreasonable to expect that the NRCs approval to construct the repository at Yucca Mountain would require at least as long a review period. The DOE has no plans for receiving spent fuel from commercial nuclear plant sites prior to this date and startup operations may be phased in, creating additional delays. For estimating purposes, Xcel has assumed that the earliest date that the high-level waste repository, or some interim storage facility, will be fully operational is 2015. This timetable is consistent with the findings of an evaluation issued to Congress by the Government Accounting Office.[12]

11 Nuclear Waste Policy Act of 1982 and Amendments, U.S. Department of Energys Office of Civilian Radioactive Management, 1982.

12 Technical, Schedule, and Cost Uncertainties of the Yucca Mountain Repository Project, GAO-02-191, December 2001.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page xii of xiv The NRC requires that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE.[13] The fuel will be stored in the storage pool and/or an ISFSI located on the Monticello site until the DOE has completed the transfer.

Monticello also has 1,058 spent fuel assemblies stored at the General Electric facility in Morris, Illinois, that must be transferred to DOE. Xcel is not responsible for operation or decommissioning costs for the GE facility in Morris. Given the DOEs allocation/receipt schedules and priority ranking for Monticello spent fuel stored in the on-site ISFSI and at GE Morris, and an anticipated rate of transfer, spent fuel is projected to remain at the site for approximately 29 years after the cessation of operations in 2010.

Site Restoration The efficient 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 structures, potentially weakening the footings and structural supports. Prompt dismantlement once the 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 a work force already mobilized is more efficient and less costly than if the process were deferred. 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.

Xcel has identified some existing site structures as likely to remain in use following the decommissioning project; consequently, these structures have been removed from the site restoration portion of the estimate. This analysis assumes that all site structures not identified for reuse that are within the restricted access area are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then graded and stabilized.

Summary The costs to decommission Monticello were evaluated for the DECON decommissioning scenario. The estimate assumes the eventual removal of all the contaminated and activated plant components and structural materials, such that the facility operator may then have unrestricted use of the site with no further 13 Domestic Licensing of Production and Utilization Facilities, U.S. Code of Federal Regulations, Title 10, Part 50.54 (bb).

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page xiii of xiv requirement for an NRC license. The spent fuel remains in storage at the site until such time that the transfer to a DOE facility can be completed. Once the transfer is complete, the storage facilities are also decommissioned.

The scenario analyzed for the purpose of generating the estimate is described in Section 2. The assumptions are presented in Section 3, along with schedules of annual expenditures. The major cost contributors are identified in Section 6, with detailed activity costs, waste volumes, and associated manpower requirements delineated in Appendix C. A cost summary for the DECON scenario is provided at the end of this section for the major cost components.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Page xiv of xiv

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DECON (thousands of 2005 dollars)

Activity Total Decontamination 15,629 Removal 67,597 Packaging 9,987 Transportation 6,717 Waste Disposal 49,622 Off-site Waste Processing 41,732 Program Management [1] 317,226 Spent Fuel Pool Isolation 9,900 Spent Fuel Management 68,905 Insurance and Regulatory Fees 19,897 Energy 12,855 Characterization and Licensing Surveys 8,321 Property Taxes 25,999 Miscellaneous Equipment 8,733 Total [2] 663,122 NRC License Termination 446,819 Spent Fuel Management 188,889 Site Restoration 27,414

[1] Includes engineering and security

[2] Columns may not add due to rounding TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 1 of 7

1. INTRODUCTION This report presents an estimate of the cost to decommission the Monticello Nuclear Generating Plant (Monticello), for the scenario described in Section 2, following a scheduled cessation of plant operations. The analysis is designed to provide the Xcel Energy Services, Inc. (Xcel) with sufficient information to assess its financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.

1.1 OBJECTIVES OF STUDY The objectives of this study are to prepare a comprehensive estimate of the cost to decommission Monticello, to provide a sequence or schedule for the associated activities, and to develop waste stream projections from the decontamination and dismantling activities.

An operating license was issued on September 8, 1970 for Monticello. For the purposes of this study, the shutdown date used for scheduling the decommissioning activities for the DECON scenario is September 8, 2010, assuming a 40 year operating life (the current operating licenses expiration date).

1.2 SITE DESCRIPTION Monticello is located on the Mississippi River within the city limits of Monticello, in Wright County, Minnesota. The plant is located approximately 30 miles northwest of the Minneapolis-St. Paul area.

The Nuclear Steam Supply System (NSSS) consists of a single cycle, forced circulation, low power density boiling water reactor. This system was supplied by the General Electric Company and has a reference core design of 1775 MWt (thermal), with a corresponding (net dependable capability) electrical rating of 600 MWe (electric), with the reactor at rated power.

The reactor recirculation system is comprised of the reactor vessel; the two loop reactor recirculation system with its pumps, pipes, and valves; the main steam piping up to the main steam isolation valves; and the reactor auxiliary systems piping. The system is housed within a "containment system,"

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Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 2 of 7 consisting of a steel light bulb-shaped drywell, a steel doughnut-shaped pressure suppression chamber, and interconnecting vent pipes. This system provides the first containment barrier surrounding the reactor vessel and reactor primary system. The reactor building provides secondary containment and is designed as a controlled leakage structure.

The saturated steam leaving the reactor vessel flows through the four main steam lines to the main turbine located in the turbine building. After passing through the main turbine, low-pressure steam is condensed, the non-condensable gases are removed, and the condensate is demineralized before being returned to the reactor vessel through the reactor feedwater system heaters. The turbine-generator system converts the thermodynamic energy of the steam into electrical energy. The unit's turbine-generator consists of one single-flow, high-pressure, and two double-flow, low-pressure turbines driving a direct-coupled generator at 1800 rpm. Heat rejected in the main condenser is removed by the circulating water system.

The circulating water system has been designed for open cycle once-through cooling towers, closed cycle with cooling towers, or for variations of these modes, i.e., partial recirculation. The system for open cycle operation consists of an intake structure with two half-capacity circulating water pumps, piping river water through the condenser to a discharge structure where the water enters a 1000-foot long canal that returns the water to the river downstream from the intake. Two induced-draft cooling towers are used during the open and closed cycle operations. Cooled effluent returns by gravity to the intake structure from the cooling tower basins.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[1]* This rule set forth financial criteria for decommissioning licensed nuclear power facilities.

The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to 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 the Availability of Funds for Decommissioning Nuclear Reactors,[2] which provided additional guidance to the licensees of nuclear facilities on the

• Annotated references for citations in Sections 1-6 are provided in Section 7.

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Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 3 of 7 financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.

The rule defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated or activated portion of the plants systems, structures, and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations. The rule also placed limits on 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 leverage and flexibility to ensure that these deferred options are only used in situations where it is reasonable and consistent with the definition of 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 significant remediation to meet the unrestricted release limits for license termination.

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. However, with recent rulemaking permitting the controlled release of a site, the NRC has re-evaluated this alternative.[3] 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. However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative. The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombments.[4] However, the NRC staff has recommended that rulemaking be deferred, based upon several factors, e.g., no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRCs current priorities, at least until after the additional research studies are complete. The Commission concurred with the staffs recommendation.

The NRC published revisions to the general requirements for decommissioning nuclear power plants in 1996.[5] When the regulations were TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 4 of 7 originally adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facilitys operating 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 codify procedures and terminology as a means of 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.

Under the revised regulations, licensees will submit written certification to the NRC within 30 days after the decision to cease operations. Certification will also be required once the fuel is permanently removed from the reactor vessel. Submittal of these notices will entitle the licensee to a fee reduction and eliminate the obligation to follow certain requirements needed only during operation of the reactor. Within two years of submitting notice of permanent cessation of operations, the licensee is required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC. The PSDAR describes the planned decommissioning activities, the associated sequence and schedule, and an estimate of expected costs. Prior to completing decommissioning, the licensee is required to submit an application to the NRC to terminate the license, which will include a License Termination Plan (LTP).

1.3.1 Nuclear Waste Policy Act Congress passed the Nuclear Waste Policy Act[6] (NWPA) in 1982, assigning the responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the U.S.

Department of Energy (DOE). Two permanent disposal facilities and an interim storage facility were envisioned. To recover the cost, the legislation created a Nuclear Waste Fund through which money is collected from the sale of electricity generated by the power plants.

The NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

After pursuing a national site selection process, the NWPA was amended in 1987 to designate Yucca Mountain, Nevada, as the only TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 5 of 7 site to be evaluated for geologic disposal of high-level waste. Also in 1987, the DOE announced a five-year delay (1998 to 2003) in the opening date for the repository. Two years later, in 1989, an additional seven-year delay was announced, primarily due to problems in obtaining the permits necessary from the state of Nevada to perform the required characterization of the site. DOE announced in 2005 a further two year delay (2010 to 2012).

Generators have responded to this impasse by initiating legal action against the DOE and constructing supplemental storage as a means of maintaining necessary fuel storage operating margins. In an August 2000 ruling,[7] the U.S. Court of Appeals for the Federal Circuit reaffirmed the utility position that DOE had breached its contractual obligation. The DOE continues to maintain that its delayed performance is unavoidable because it does not have an operational repository and does not have authority to provide storage in the interim. Consequently the DOE has no plans to receive spent fuel from the commercial reactors until the repository is operational.

The NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to Title 10 of the Code of Federal Regulations (10 CFR),

§50.54 (bb).[8] This funding requirement is fulfilled through inclusion of certain high-level waste cost elements in the decommissioning estimate, as identified in Section 3.

Xcel will construct an independent spent fuel storage installation (ISFSI) on the Monticello site prior to final plant shutdown. As such, no costs for construction of an ISFSI are included in this estimate.

For estimating purposes, the DOE is assumed to initiate spent fuel receipt from commercial generators in the year 2015. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority, but licensees are granted the ability to reallocate their allotments within their contracts. Given this scenario and an anticipated rate of transfer, spent fuel is projected to remain at the Monticello site for approximately 29 years after the cessation of operations, or until the year 2039.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 6 of 7 1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for shallow-land disposal. Congress passed the Low-Level Radioactive Waste Policy Act in 1980,[9] declaring the states as being ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation. After little progress, the Low-Level Radioactive Waste Policy Amendments Act of 1985,[10] extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. However, to date, no new compact facilities have been successfully sited, licensed, and constructed.

Monticello is currently able to access the disposal facility in Barnwell, South Carolina and the Envirocare facility in Clive, Utah (for 10 CFR 61 Class A waste only). However, in June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allows South Carolina to gradually limit access to the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. It is reasonable to assume that additional disposal capacity will be required to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere.

However, for estimating purposes, and as a proxy for future disposal facilities, waste disposal costs are generated using available pricing schedules for the currently operating facilities, i.e., Barnwell and Envirocare.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, Radiological Criteria for License Termination,[11] amending 10 CFR §20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003 Rev. 0 Decommissioning Cost Analysis Section 1, Page 7 of 7 has been reduced to levels that are As Low As Reasonably Achievable (ALARA). The decommissioning estimate for Monticello assumes that the site will be remediated to a residual level consistent with the NRC-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 to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).[12]

An additional limit of 4 millirem per year, as defined in 40 CFR

§141.16, is applied to drinking water.[13]

On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU) [14] provides that EPA will 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 exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning. Most sites are expected to meet the NRC criteria for unrestricted 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.

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Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 1 of 9

2. DECON DECOMMISSIONING SCENARIO A detailed cost estimate was developed to decommission Monticello assuming the DECON method of decommissioning. The estimate assumes that Monticello operates until September 2010. This date represents the expiration of the current NRC license. The DECON scenario assumes that decommissioning activities begin on this date. Any residual spent fuel is transferred to the ISFSI so as to facilitate decontamination and dismantling activities within the fuel handling area of the reactor building. Spent fuel storage operations continue at the site and at the General Electric facility in Morris, Illinois until the transfer of the fuel to the DOE is complete, assumed to be in the year 2039.

The following sections describe the basic activities associated with the scenario.

Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work, i.e., engineering and planning at 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 effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e., power production) to facility deactivation and closure. During the first phase, notification is to be provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee would then be prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning cost estimate developed for Monticello is 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 cost scenario examined uses the DECON alternative, which is defined by the NRC, as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations." This study does not address the cost to dispose of the spent fuel residing at the site; such costs are funded through a surcharge on electrical generation from nuclear plants. However, the study does TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 2 of 9 estimate the costs incurred with the interim on-site storage of the fuel pending shipment by the DOE to an off-site disposal facility following permanent shutdown.

2.1 PERIOD 1 - PREPARATIONS In anticipation of the cessation of plant operations, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Through implementation of a staffing transition plan, the organization required to manage the intended decommissioning activities is assembled from available plant staff and outside resources. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to permanent shutdown conditions and requirements, a characterization of the facility and major components, and the development of the PSDAR.

This study assumes that Xcel builds an ISFSI to support continued plant operations prior to final shutdown; this ISFSI will continue to be used to store the spent fuel through and beyond decommissioning.

Engineering and Planning The PSDAR, required within two years of the notice to cease operations, provides a description of the licensees planned decommissioning activities, a timetable, and the associated financial requirements of the intended decommissioning program. Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local meeting to be held in the vicinity of the reactor site. Ninety days following submittal and NRC receipt of the PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR §50.59 procedure, i.e.,

without specific NRC approval. Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC material, as defined by 10 CFR §61. Major components are further defined as comprising the reactor vessel and internals, large bore reactor recirculation system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the §50.59 process in decommissioning. The proposed activity must not:

y foreclose release of the site for possible unrestricted use, y significantly increase decommissioning costs, TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 3 of 9 y cause any significant environmental impact, or y violate the terms of the licensees existing license.

Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations. The environmental impact associated with the planned decommissioning activities is also considered. Typically, a licensee will not be allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements. In this instance, the licensee would have to submit a license amendment for the specific activity and update the environmental report.

The decommissioning program outlined in the PSDAR will be designed to accomplish the required tasks within the ALARA guidelines (as defined in 10 CFR §20) for protection of personnel from exposure to radiation hazards. It will also address the continued protection of the health and safety of the public and the environment during the dismantling activity. Consequently, with the development of the PSDAR, activity specifications, cost-benefit and safety analyses, and work packages and procedures, would be assembled to support the proposed decontamination and dismantling activities.

Site Preparations Following final plant shutdown, and in preparation for actual decommissioning activities, the following activities are initiated:

y Characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and primary shield cores.

y Isolation of the spent fuel storage pool and fuel handling systems, such that decommissioning operations can commence on the balance of the plant. Decommissioning operations are scheduled around the fuel handling area to optimize the overall project schedule. The fuel is transferred to the DOE or the ISFSI as it decays to the point that it meets the heat load criteria of the containers. Consequently, it is assumed that the fuel pool remains operational for approximately 51/2 years following the cessation of plant operations.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 4 of 9 y Specification of transport and disposal requirements for activated materials and/or hazardous materials, including shielding and waste stabilization.

y Development of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active waste, resins, filter media, metallic and non-metallic components generated in decommissioning), site security and emergency programs, and industrial safety.

2.2 PERIOD 2 - DECOMMISSIONING OPERATIONS This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful termination of the 10 CFR §50 operating license. Significant decommissioning activities in this phase include:

y Construction of temporary facilities and/or modification of existing facilities to support dismantling activities. This may include a centralized processing area to facilitate equipment removal and component preparations for off-site disposal.

y Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on- and off-site) to facilitate hauling and transport.

Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction.

y Design and fabrication of temporary and permanent shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

y Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages for the disposition of low-level radioactive waste.

y Decontamination of components and piping systems as required to control (minimize) worker exposure.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 5 of 9 y Removal of piping and components no longer essential to support decommissioning operations.

y Transfer of the steam separator and dryer assemblies to the dryer-separator pool for segmentation. Segmentation by weight and activity maximizes the loading of the shielded transport casks. The operations are conducted under water using remotely operated tooling and contamination controls.

y Disconnection of the control blades from the drives on the vessel lower head. Blades are transferred to the spent fuel pool for packaging.

y Disassembly, segmentation, and packaging of the core shroud and in-core guide tubes. Some of the material is expected to exceed Class C disposal requirements. As such, those segments are packaged in a modified fuel storage canister for geologic disposal.

y Disassembly and segmentation of the remaining reactor internals, including the jet pump assemblies, fuel support castings, and core plate assembly.

y Draining and decontamination of the reactor well and the permanent sealing of the spent fuel transfer gate. Install a shielded platform for segmentation of the reactor vessel. Cutting operations are performed in air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Sections are transferred to the dryer-separator pool for packaging and interim storage.

y Disconnection of the control rod drives and instrumentation tubes from reactor vessel lower head. The lower reactor head and vessel supporting structure are then segmented.

y Removal of the reactor recirculation pumps. Exterior surfaces are decontaminated and openings covered. Components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized, e.g., with grout. Steel shielding will be added, as necessary, to those external areas of the package to meet transportation limits and regulations.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 6 of 9 y Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely 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 dryer-separator pool or the spent fuel pool.

y Demolition of the sacrificial shield activated concrete by controlled demolition.

y Expansion of the ISFSI and transfer of the spent fuel from the storage pool to the DOE and to the ISFSI pad for interim storage. Spent fuel storage operations continue throughout the active decommissioning period. Fuel transfer to DOE is expected to be completed by the end of the year 2039.

At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) is required. Submitted as a supplement to the Final Safety Analysis Report (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 environmental concerns.

The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local meeting. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission.

The licensee may then commence with the final remediation of site facilities and services, including:

y Removal of remaining plant systems and associated components as they become nonessential to the decommissioning program or worker health and safety (e.g., waste collection and treatment systems, electrical power and ventilation systems).

y Removal of the steel liners from the drywell, disposing of the activated and contaminated sections as radioactive waste. Removal of any activated/contaminated concrete.

y Removal of the steel liners from the steam separator and dryer pool, reactor well, and spent fuel storage pool.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 7 of 9 y Surveys of the decontaminated areas of the containment structures.

y Removal of the contaminated equipment and material from the turbine and radwaste buildings, and any other contaminated facility. Use radiation and contamination control techniques until radiation surveys indicate 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 and components (both clean and contaminated) located within these buildings.

This activity will facilitate surface decontamination and subsequent verification surveys required prior to obtaining release for demolition.

y Removal of the remaining components, equipment, and plant services in support of the area release survey(s).

y Routing of material removed in the decontamination and dismantling to a central processing area. Material certified to be free of contamination is released for unrestricted disposition, e.g., as scrap, recycle, or general disposal. Contaminated material is characterized and segregated for additional off-site processing (disassembly, chemical cleaning, volume reduction, and waste treatment), and/or packaged for controlled disposal at a low-level radioactive waste disposal facility.

y Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).[15] This document incorporates the statistical approaches to 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 guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the survey is complete, the results are provided to the NRC in a format that can 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 will terminate the operating license if it determines that site remediation has been performed in accordance with the LTP, and that the TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 8 of 9 terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.

2.3 PERIOD 3 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin. Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits will result in substantial damage to many of the structures. Although performed in a controlled, safe manner, blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the reactor and auxiliary buildings.

Under certain circumstances, verifying that subsurface radionuclide concentrations meet NRC site release requirements will require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity will be necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.

Prompt dismantling of site structures 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 a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers.

Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and exterior walls are removed to a nominal depth of three feet below grade.

The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion 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.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 2, Page 9 of 9 Concrete rubble produced by demolition activities is processed to remove rebar and miscellaneous embedments. The processed material is then used on site to backfill voids. Excess materials are trucked to an off-site area for disposal as construction debris.

2.4 ISFSI OPERATIONS AND DECOMMISSIONING The ISFSI will continue to operate under a separate and independent license (10 CFR §72) following the termination of the §50 operating license.

Assuming the DOE starts accepting fuel in 2015, transfer of spent fuel from Monticello and from the GE facility in Morris, Illinois is anticipated to continue through the year 2039.

At the conclusion of the spent fuel transfer process, the on-site ISFSI will be decommissioned. The Commission will terminate the §72 license if it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release. Once the requirements are satisfied, the NRC can terminate the license for the ISFSI.

The assumed design for the ISFSI is based upon the use of a multi-purpose canister and a concrete module for pad storage. For purposes of this cost analysis, it is assumed that once the inner canisters containing the spent fuel assemblies have been removed, any required decontamination performed, and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad will then be removed, and the area graded and landscaped to conform to the surrounding environment.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 1 of 19

3. COST ESTIMATE The cost estimate prepared for decommissioning Monticello considers the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities. The basis of the estimate, 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 estimate was developed with site-specific, technical information originally developed in 2002-03[16]. 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.

3.2 METHODOLOGY The methodology used to develop the estimate follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[17] and the DOE "Decommissioning Handbook."[18] 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 plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures relied upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means.[19]

This analysis reflects lessons learned from TLGs involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the 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, TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 2 of 19 and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

The unit factor method provides a demonstrable basis for establishing reliable cost estimates. The detail provided in the unit factors, including activity duration, 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 values contained within one set of factors developed for this analysis.

Work Difficulty Factors TLG has historically applied work difficulty adjustment factors (WDFs) to account for the inefficiencies in working in a power plant environment.

WDFs were assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined, hazardous environments. The ranges used for the WDFs are as follows:

y Access Factor 10% to 20%

y Respiratory Protection Factor 10% to 50%

y Radiation/ALARA Factor 10% to 40%

y Protective Clothing Factor 10% to 30%

y Work Break Factor 8.33%

The factors and their associated range of values were developed in conjunction with the AIF/NESP-036 study. The application of the factors is discussed in more detail in that publication.

Scheduling 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. 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 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 3 of 19 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 FINANCIAL COMPONENTS OF THE COST MODEL TLGs proprietary decommissioning cost model, DECCER, produces a number of 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.

Inherent in any cost estimate that does not rely on historical data is the inability to specify the precise source of costs imposed by factors such as tool breakage, accidents, illnesses, weather delays, and labor stoppages. In the DECCER cost model, contingency fulfills this role. Contingency is added to each line item to account for costs that are difficult or impossible to develop analytically. Such costs are historically inevitable over the duration of a job of this magnitude; therefore, this cost analysis includes funds to cover these types of expenses.

3.3.1 Contingency The activity- and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, 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' Handbook[20] as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, a contingency factor has been applied. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 4 of 19 escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

The use and role of contingency within decommissioning estimates is not a safety factor issue. Safety factors provide additional security and address 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 the intended tasks. An estimate without contingency, or from which contingency has been removed, can disrupt the orderly progression of events and jeopardize a successful conclusion to the decommissioning process.

For example, the most technologically challenging task in decommissioning a commercial nuclear station is the disposition of the reactor vessel and internal components, now highly radioactive after a lifetime of exposure to core activity. The disposition of these components forms the basis of the critical path (schedule) for decommissioning operations. Cost and schedule 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 underwater cutting of complex components that are highly radioactive. Costs are based upon optimum segmentation, handling, and packaging scenarios. The schedule is primarily dependent upon the turnaround time for the heavily shielded shipping casks, including preparation, loading, and decontamination of the containers for transport. The number of casks required is a function of the pieces generated in the segmentation activity, a value calculated on 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 this reason, contingency must be included to mitigate the consequences of the expected inefficiencies inherent in this complex activity, along with related concerns associated with the operation of highly specialized tooling, 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 a successful completion of the intended tasks and, potentially, TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 5 of 19 subsequent related 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 10% to 75%, depending on the degree of difficulty judged to be appropriate from TLGs actual decommissioning experience. The contingency values used in this study are as follows:

Decontamination 50%

Contaminated Component Removal 25%

Contaminated Component Packaging 10%

Contaminated Component Transport 15%

Low-Level Radioactive Waste Disposal 25%

Reactor Segmentation 75%

NSSS Component Removal 25%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

GTCC Disposal 15%

Non-Radioactive Component Removal 15%

Heavy Equipment and Tooling 15%

Supplies 25%

Engineering 15%

Energy 15%

Characterization and Termination Surveys 30%

Construction 15%

Taxes and Fees 10%

Insurance 10%

Staffing 15%

The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of the estimate. For this estimate, the composite contingency value is 17.8%.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 6 of 19 3.3.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding 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 necessary to generate a level of confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term financial risk. Included within the category of financial risk are:

y Transition activities and costs: ancillary expenses associated with eliminating 50% to 80% of the site labor force shortly after the cessation of plant operations, added cost for worker separation packages throughout the decommissioning program, national or company-mandated retraining, and retention incentives for key personnel.

y Delays in approval of the decommissioning plan due to intervention, public participation in local community meetings, legal challenges, and national and local hearings.

y 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 material contamination), variations in plant inventory or configuration not indicated by the as-built drawings.

y Regulatory changes, e.g., affecting worker health and safety, site release criteria, waste transportation, and disposal.

y Policy decisions altering national commitments, e.g., in the ability to accommodate certain waste forms for disposition or in the timetable for such, e.g., the start and rate of acceptance of spent fuel by the DOE.

y Pricing changes for basic inputs, such as labor, energy, materials, and burial. Some of these inputs may vary slightly, e.g. -10% to

+20%; burial could vary from -50% to +200% or more.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 7 of 19 It has been TLGs experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicate that the chances of the base decommissioning estimates 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 increases from changes in plant conditions and to pricing variations in the cost of labor (both craft and staff). This cost study, however, does not add any additional cost to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimate.

3.4 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.

3.4.1 Spent Fuel Management The cost to dispose of spent fuel generated from plant operations is not reflected within the estimate to decommission the Monticello site.

Ultimate disposition of the spent fuel is within the province of the DOEs Waste Management System, as defined by the NWPA. As such, the disposal cost is financed by a 1 mill/kWhr surcharge paid into the DOEs waste fund during operations. However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactors until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

The total inventory of assemblies that will require handling during decommissioning is based upon several assumptions. The pickup of commercial fuel is assumed to begin in the year 2015 and will proceed on an oldest fuel first basis. The maximum rate at which the fuel is removed from the commercial sites is based upon an annual capacity at the geologic repository of 3,000 metric tons of uranium (MTU). Any TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 8 of 19 delay in the startup of the repository or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in the fuel remaining at the site longer.

The spent fuel will be stored in an ISFSI until such time that the transfer of spent fuel to the DOE can be completed. Assuming that the DOE commences repository operation in 2015, fuel is projected to be removed from the Monticello site by the year 2039.

Operation and maintenance costs for the storage facilities are included within the estimate and address the cost for staffing the facilities, as well as security, insurance, and licensing fees. The estimate includes the costs to load, and transfer the fuel storage canisters. Costs are also provided for the final disposition of the facilities once the transfer is complete.

Repository Startup Operation of the DOEs yet-to-be constructed geologic repository is contingent upon the review and approval of the facilitys license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. For comparison, the Private Fuel Storage consortium submitted an application for an interim storage facility in 1997. The NRC granted an operating license for the facility in September 2005, after eight years of review. With a more technically complex and politically sensitive application for permanent disposal, it is not unreasonable to expect that NRC approval to construct the repository at Yucca Mountain will require at least as long a review period. Therefore, the spent fuel management plan described in this section is predicated upon the DOE initiating the pickup of commercial fuel in the year 2015. This timetable is consistent with the findings of an evaluation issued to Congress by the Government Accounting Office.[21]

Spent Fuel Management Model For estimating purposes, spent fuel will be removed from the Monticello site by the end of year 2039. This assumes the continued use of an ISFSI expected to be constructed prior to final plant shutdown to support operations. Fuel residing in the pool following the cessation of plant operations is relocated to the ISFSI so that TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 9 of 19 decommissioning can proceed on the fuel area of the reactor building.

The assemblies will be relocated during the first five years. Costs are included for the purchase of the 35 canisters and overpacks required to empty the pool (an additional three will be used to package the GTCC).

Operation and maintenance costs for the ISFSI are included within the estimate and address the cost for staffing the facility, security, insurance, and licensing fees. Costs are also provided for the final disposition of the facility once the transfer is complete.

The DOE's repository program assumes that spent fuel will be accepted for disposal from the nation's commercial nuclear plants in the order (the "queue") in which it was removed from service ("oldest fuel first").[22] Repository operations were based upon annual industry-wide acceptance rates of 400 MTU/year for year 1, 600 MTU/ year for year 2, 1200 MTU/year for year 3, 2000 MTU/year for year 4, and 3000 MTU/year for year 5 and beyond.[23]

Canister Design A multi-purpose storage canister with a 61-fuel assemblies capacity, is assumed for future cask acquisitions. A unit cost of $750,000 is used for pricing the internal multi-purpose canister (MPC) and concrete overpack. The DOE is assumed to provide the MPC for fuel transferred directly from the pool to the DOE at no cost to the owner.

Canister Loading and Transfer An average cost of $300,000 is used for the labor to load/transport the spent fuel from the pool to the ISFSI pad, based upon industry experience. For estimating purposes, $100,000 of this cost is used to estimate the cost to transfer the fuel from the ISFSI to the DOE. This estimate did not include any costs for loading of canisters at the GE facility in Morris.

Operations and Maintenance Annual costs (excluding labor) of approximately $630,576 and $75,353 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 10 of 19 ISFSI Design Considerations A multi-purpose (storage and transport) dry shielded storage canister with a horizontal, reinforced concrete storage module is used as a basis for the cost analysis. Approximately 50% of the overpacks are assumed to have some level of neutron-induced activation as a result of the long-term storage of the fuel, i.e., to levels exceeding free-release limits.

Approximately 10% of the concrete and steel is assumed to be removed from the overpacks for controlled disposal. The cost to dispose of this material, as well as the demolition of the ISFSI facility, is included in the estimate.

3.4.2 Reactor Vessel and Internal Components The NSSS (reactor vessel and reactor recirculation system components) will be decontaminated using chemical agents prior to the start of cutting operations. A decontamination factor (average reduction) of 10 is assumed for the process.

The reactor pressure vessel and internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed in the dryer-separator pool, where a turntable and remote cutter are installed. The vessel is segmented in place, using a mast-mounted cutter supported off the lower head and directed from a shielded work platform installed overhead in the reactor cavity.

Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

The dismantling of the reactor internals will generate radioactive waste considered unsuitable for shallow land disposal, i.e., GTCC.

Although the material is not classified as high-level waste, the DOE has indicated it will accept this waste for disposal at the future high-level waste repository.[24] However, the DOE has not been forthcoming with an acceptance criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel. It is not anticipated that the DOE would accept this waste prior to completing the transfer of spent fuel. Therefore, until such time the DOE is ready to accept TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 11 of 19 GTCC waste, it is reasonable to assume that this material would remain in storage at the Monticello site.

Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package. However, its location on the Columbia River simplified the transportation analysis since:

y the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport, y there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and y transport speeds were very low, limited by the overland transport vehicle 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 demonstrating compliance with land disposal regulations.

It is not known whether this option will be available when Monticello ceases operation. Future viability of this option will depend upon the burial sites ability to accept highly radioactive packages and effectively isolate them from the environment. Additionally, with BWRs, the diameter of the reactor vessel may severely limit overland transport. Consequently, the study assumes the reactor vessel will require segmentation, as a bounding condition.

3.4.3 Primary System Components Reactor recirculation piping is cut from the reactor vessel once the water level in the vessel (used for personnel shielding during dismantling and cutting operations in and around the vessel) is dropped below the nozzle zone. The piping is boxed and transported by shielded van. The reactor recirculation pumps and motors are lifted out intact, packaged, and transported for processing and/or disposal.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 12 of 19 3.4.4 Main Turbine and Condenser The main turbine will be dismantled using conventional maintenance procedures. The turbine rotors and shafts will be removed to a laydown area. The lower turbine casings will be removed from their anchors by controlled demolition. 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 be surveyed 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.

3.4.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I, II or III or Surface Contaminated Object, SCO-I or II, as described in Title 49.[25] The contaminated material will be packaged in Industrial Packages (IP-1, 2, or 3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with §71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), 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 internal segments is designed to meet these limits.

The transport of large intact components, e.g., large heat exchangers and other oversized components will be by a combination of truck, rail, and/or multi-wheeled transporter.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 13 of 19 Transportation costs are based upon the mileage to the Envirocare facility in Clive, Utah. Memphis, Tennessee, is used as the destination for off-site processing. Transportation costs are estimated using published tariffs from Tri-State Motor Transit.[26]

3.4.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is treated to reduce the total volume requiring controlled disposal. The treated material, meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning and recovery of the waste stream is performed off site at a licensed processing center.

Material requiring controlled disposal is packaged and transported to the Envirocare facility. Since Envirocare is currently unable to receive Class B and C waste, Barnwell rates are used as a proxy. Surcharges are added for the highly-activated components, e.g., generated in the segmentation of the reactor vessel.

3.4.7 Site Conditions Following Decommissioning The NRC will terminate (or amend) the site licenses if it determines that site remediation has been performed in accordance with the license termination plan, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. The NRCs involvement in the decommissioning process will end at this point. Building codes and environmental regulations will dictate the next step in the decommissioning process, as well as the owners own future plans for the site.

Xcel Energy has identified certain structures and site features that are candidates for reuse by a potential follow-on generating plant at the Monticello site. These structures are excluded from the scope of the estimate for decommissioning or site restoration.

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 be TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 14 of 19 regraded such that the power block area will have a final contour consistent with adjacent surroundings.

The estimate does not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.

3.5 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning the site.

3.5.1 Estimating Basis The study follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures. Changes to worker exposure limits may impact the decommissioning cost and project schedule.

3.5.2 Labor Costs The craft labor required to decontaminate and dismantle the nuclear unit will be acquired through standard site contracting practices. The current cost of labor at the site is used as an estimating basis. Costs for site administration, operations, construction, and maintenance personnel are based upon average salary information provided by Xcel or from comparable industry information.

Xcel will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. The owner will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases.

Contract personnel will provide engineering services, e.g., for preparing the activity specifications, work procedures, activation, and structural analyses, under the direction of Xcel.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 15 of 19 3.5.3 Design Conditions Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major NSSS components to be shipped under current transportation regulations and disposal requirements.

The curie contents of the vessel and internals at final shutdown are derived from those listed in NUREG/CR-3474.[27] Actual estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Monticello components, projected operating life, and different periods of decay. Additional short-lived isotopes were derived from CR-0130[28] and CR-0672,[29] and benchmarked to the long-lived values from CR-3474.

The disposal cost for the control blades removed from the vessel with the final core load is included within the estimate. Disposition of any blades stored in the pool from operations is considered an operating expense and therefore not accounted for in the estimate.

Activation of the reactor building structure is confined to the sacrificial shield. More extensive activation (at very low levels) of the interior structures within containment has been detected at several reactors and the owners have elected to dispose of the affected material at a controlled facility rather than reuse the material as fill on site or send it to a landfill. The ultimate disposition of the material removed from the reactor building will depend upon the site release criteria selected, as well as the designated end use for the site.

3.5.4 General Transition Activities Existing warehouses will be cleared of non-essential material and remain for use by Xcel and its subcontractors. The plants operating staff will perform the following activities at no additional cost or credit to the project during the transition period:

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 16 of 19 y Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.

y Drain and collect acids, caustics, and other chemical stores for recycle and/or sale.

y Process operating waste inventories, i.e., the estimate does not address the disposition of any legacy wastes; the disposal of operating wastes during this initial period is not considered a decommissioning expense.

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Xcel will make economically reasonable efforts to salvage equipment following final plant shutdown. However, dismantling techniques assumed by TLG for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.

It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimate do not include the additional cost for size reduction and preparation to meet furnace ready conditions. For example, the recovery of copper from electrical cabling may require the removal and disposition of any contaminated insulation, an added expense. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. This assumption is an implicit recognition of scrap value in the disposal of clean metallic waste at no additional cost to the project.

Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property owned by Xcel will be removed at no cost or credit TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 17 of 19 to the decommissioning project. Disposition may include relocation to other facilities. Spare parts will also be made available for alternative use.

Energy For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage.

Replacement power costs are used for the cost of energy consumption during decommissioning for tooling, lighting, ventilation, and essential services.

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRCs proposed rulemaking Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors.[30]

NRCs financial protection requirements are based on various reactor (and spent fuel) configurations.

Taxes Property taxes are included for all decommissioning periods.

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 of the project.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 18 of 19 3.6 COST ESTIMATE

SUMMARY

A schedule of expenditures for the DECON scenario is provided in Table 3.1.

Decommissioning costs are reported in the year of projected expenditure; however, the values are provided in thousands of 2005 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 Appendix C, along with the schedule discussed in Section 4.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 3, Page 19 of 19 TABLE 3.1 SCHEDULE OF ANNUAL EXPENDITURES DECON (thousands, 2005 dollars)

Equipment &

Year Labor Materials Energy Burial Other Total 2010 14,695 1,714 619 13 4,710 21,751 2011 48,871 8,091 2,583 609 13,528 73,681 2012 48,907 20,287 2,255 36,608 8,692 116,749 2013 42,242 14,579 1,639 23,119 5,679 87,257 2014 38,299 9,390 1,473 7,573 3,792 60,528 2015 38,299 9,390 1,473 7,573 3,792 60,528 2016 32,209 4,418 891 7,002 3,781 48,300 2017 17,364 1,846 331 29 6,897 26,468 2018 14,488 4,470 196 0 1,958 21,113 2019 8,331 1,983 117 0 1,956 12,387 2020 3,848 169 59 0 1,960 6,035 2021 3,837 168 59 0 1,954 6,019 2022 3,837 168 59 0 1,954 6,019 2023 3,837 168 59 0 1,954 6,019 2024 3,848 169 59 0 1,960 6,035 2025 3,837 168 59 0 1,954 6,019 2026 3,837 168 59 0 1,954 6,019 2027 3,837 168 59 0 1,954 6,019 2028 3,848 169 59 0 1,960 6,035 2029 3,837 168 59 0 1,954 6,019 2030 3,837 168 59 0 1,954 6,019 2031 3,837 168 59 0 1,954 6,019 2032 3,848 169 59 0 1,960 6,035 2033 3,837 168 59 0 1,954 6,019 2034 3,837 168 59 0 1,954 6,019 2035 3,837 168 59 0 1,954 6,019 2036 3,848 169 59 0 1,960 6,035 2037 3,837 168 59 0 1,954 6,019 2038 3,837 168 59 0 1,954 6,019 2039 3,829 488 59 3 10,424 14,803 2040 1,164 1,095 97 369 2,397 5,122 381,652 80,951 12,855 82,898 104,767 663,122 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 4, Page 1 of 4

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.4.1.

A schedule or sequence of activities is presented in Figure 4.1 for the DECON decommissioning alternative. The scheduling sequence assumes that fuel is removed from the spent fuel pool within the first 51/2 years after operations cease.

The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost tables, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project 2002" computer software.[31]

4.1 SCHEDULE ESTIMATE ASSUMPTIONS The schedule reflects the results of a precedence network developed for the site decommissioning activities, i.e., a PERT (Program 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 the decommissioning schedule:

y The fuel handling area of the reactor building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the DOE or to the ISFSI. Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel to the ISFSI or DOE is complete.

y All work (except vessel and internals removal) is performed during an 8-hour workday, 5 days per week, with no overtime. There are eleven paid holidays per year.

y Reactor and internals removal activities are performed by using separate crews for different activities working on different shifts, with a corresponding backshift charge for the second shift.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 4 y Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.

y For plant systems removal, the systems with the longest removal durations in areas on the critical path are considered to determine the duration of the activity.

4.2 PROJECT SCHEDULE The period-dependent costs presented in the detailed cost tables are based upon the durations developed in the schedule for decommissioning Monticello. Durations are 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 path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also shown for the spent fuel cooling period, which determines the release of the fuel handling area of the reactor building for final decontamination.

A project timeline is provided in Figure 4.2. Milestone dates are based on a shutdown date of September 8, 2010.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 4, Page 3 of 4 FIGURE 4.1 ACTIVITY SCHEDULE TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 4, Page 4 of 4 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale) 40 Year Operation (Shutdown September 8, 2010)

Pool and ISFSI Operations ISFSI Operations Period 1 Period 3 Transition and Period 2 ISFSI ISFSI Site Preparations Decommissioning Operations D&D Restoration 09/2010 03/2012 09/2017 06/2019 12/2039 06/2040 Storage Pool Empty 03/2016 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 5, Page 1 of 3

5. RADIOACTIVE WASTES The 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(s). This currently requires the remediation of all radioactive material at the site in excess of applicable legal limits. Under the Atomic Energy Act,[32] the NRC is responsible for protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, §71 defines radioactive material and §61 specifies its disposition.

Most 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 §173-178. Shipping containers are required to be Industrial Packages (IP-1, 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. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.

The volumes of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in Appendix C and summarized in Table 5.1. The quantified waste volume summaries shown in this table are consistent with §61 classifications. The volumes are calculated based on the exterior dimensions for containerized material and on the displaced volume of components serving as their own waste containers.

The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners.

In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste),

where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone, i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 3 While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.

The waste material generated in the decontamination and dismantling of Monticello is primarily generated during Period 2. Material that is considered potentially contaminated when removed from the radiologically controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.

For the Envirocare facility, an average disposal rate of approximately $1.47 per pound was used. This schedule was used to estimate the disposal fees for most plant components and all activated concrete unsuitable for processing or recovery.

For the reactor vessel and internals and wastes resultant from liquid waste processing, the rate schedule for the Barnwell facility was used as a proxy for this higher activity waste, with additional surcharges for activity, and/or handling added as appropriate for the particular package.

The remaining volume of contaminated metallic and concrete debris is processed and conditioned at a Duratek facility. The contaminated metallic waste stream includes the lower activity components such as miscellaneous steel, metal siding, scaffolding, and structural steel. Metals are recycled at a unit rate of $3.00 per pound. Concrete, soil, asbestos and other bulk debris are disposed of at a rate of

$0.82 per pound or approximately $82 per cubic foot. Dry active wastes, e.g., cloth, paper and plastics, are sent to the Envirocare facility for direct disposal from the site at $4.10 per pound or $82.00 per cubic foot, at an assumed density of 20 pounds per cubic foot.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 5, Page 3 of 3 TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

DECON Waste Volume Weight Class1 (cubic feet) (pounds)

Low-Level Radioactive Waste Containerized A 59,212 5,137,316 Bulk A 31,276 2,098,905 B 7,970 1,157,713 C 804 54,884 Geologic Repository (Greater-than Class C)

>C 408 83,570 Total 2 99,670 8,532,388 Processed Waste (Off-Site) 12,088,970 Scrap Metal 29,922,913 1 Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55 2 Columns may not add due to rounding.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 6, Page 1 of 4

6. RESULTS The analysis to estimate the costs to decommission Monticello relied upon the site-specific, technical information developed for a previous analysis prepared in 2002-

03. While not an engineering study, the estimate provides Xcel Energy with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear station.

The estimate described in this report is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenario assumes continued operation of the plants spent fuel pool for a minimum of 51/2 years following the cessation of operations for continued cooling of the assemblies. An ISFSI will be used to safeguard the spent fuel, once sufficiently cooled, until such time that the DOE can complete the transfer of the assemblies to its repository.

The cost projected to promptly decommission the nuclear unit upon the currently scheduled cessation of operations is estimated to be $663.1 million. The majority of this cost (approximately 67.4%) is associated with the physical decontamination and dismantling of the nuclear unit so that the license can be terminated. Another 28.5% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 4.1% is for the demolition of the designated structures and limited restoration of the site.

The primary cost contributors, identified in Table 6.1, 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 decommissioning, as well as the duration of the program. It is assumed, for purposes of this analysis, that Xcel Energy will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors. The size and composition of the management organization varies with the decommissioning phase and associated site activities.

However, once the operating license is terminated, the staff is substantially reduced for the conventional demolition and restoration of the site, and the long-term care of the spent fuel.

As described in this report, the spent fuel pool will remain operational for a minimum of 51/2 years following the cessation of operations. The pool will be isolated TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of 4 and an independent spent fuel island created. This will allow decommissioning operations to proceed in and around the pool area. Over the 51/2-year period, the spent fuel will be packaged into transportable steel canisters and either loaded into a DOE-provided transport cask or transferred to the ISFSI until the DOE is able to receive them. Dry storage of the fuel under a separate license provides additional flexibility in the event the DOE is not able to meet the current timetable for completing the transfer of assemblies to an off-site facility and minimizes the associated caretaking expenses.

The cost for waste disposal includes only those costs associated with the controlled disposition of the low-level radioactive waste generated from decontamination and dismantling activities, including plant equipment and components, structural material, filters, resins and dry-active waste. As described in Section 5, disposal of all low-level radioactive material, including concrete and structural steel, is at the Envirocare facility. Highly activated components, requiring additional isolation from the environment, are packaged for geologic disposal. The cost of geologic disposal is based upon a cost equivalent for spent fuel.

A significant portion of the metallic waste is designated for additional processing and treatment at an off-site facility. Processing reduces the volume of material requiring controlled disposal through such techniques and processes as survey and sorting, decontamination, and volume reduction. The material that cannot be unconditionally released is packaged for controlled disposal at one of the currently operating facilities. The cost identified in the summary table for processing is all-inclusive, incorporating the ultimate disposition of the material.

Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program.

Decontamination and packaging costs also have a large labor component that is based upon prevailing union wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can be more cost effective than deferral, due to the deterioration of the facilities (and therefore the working conditions) with time.

The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 6, Page 3 of 4 general expense, e.g., labor and fuel, of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.

Decontamination is used to reduce the plants radiation fields and minimize worker exposure. Slightly contaminated material or material located within a contaminated area is sent to an off-site processing center, i.e., this analysis does not assume that contaminated plant components and equipment can be decontaminated for uncontrolled release in-situ. Centralized processing centers have proven to be a more economical means of handling the large volumes of material produced in the dismantling of a nuclear unit.

License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey 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 also require confirmation and will add to the expense of surveying the facilities alone.

The remaining costs include allocations for heavy equipment and temporary services, as well as for other expenses such as regulatory fees and the premiums for nuclear insurance. While site operating costs are greatly reduced following the final cessation of plant operations, certain administrative functions do need to be maintained either at a basic functional or regulatory level.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 6, Page 4 of 4 TABLE 6.1

SUMMARY

OF DECOMMISSIONING COST ELEMENTS DECON Cost 2005$ Percent of Work Category (thousands) Total Cost Decontamination 15,629 2.4 Removal 67,597 10.2 Packaging 9,987 1.5 Transportation 6,717 1.0 Waste Disposal 49,622 7.5 Off-site Waste Processing 41,732 6.3 Program Management [1] 317,226 47.8 Spent Fuel Pool Isolation 9,900 1.5 Spent Fuel Management 68,905 10.4 Insurance and Regulatory Fees 19,897 3.0 Energy 12,855 1.9 Characterization and Licensing Surveys 8,321 1.3 Property Taxes 25,999 3.9 Miscellaneous Equipment 8,733 1.3 Total [2] 663,122 100.0 NRC License Termination 446,819 67.4 Spent Fuel Management 188,889 28.5 Site Restoration 27,414 4.1

[1] Includes engineering and security

[2] Columns may not add due to rounding TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 7, Page 1 of 3

7. REFERENCES

1. 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 et seq.), June 27, 1988.

2. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," October 2003.

3. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination.

4. U.S. Code of Federal Regulations, Title 10, Parts 20 and 50, Entombment Options for Power Reactors, Advanced Notice of Proposed Rulemaking, Federal Register Volume 66, Number 200, October 16, 2001.

5. 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.

6. Nuclear Waste Policy Act of 1982 and Amendments, U.S. Department of Energys Office of Civilian Radioactive Management, 1982.

7. Maine Yankee Atomic Power Company, Connecticut Yankee Atomic Power Company, and Yankee Atomic Power Company v. United States, U.S. Court of Appeals for the Federal Circuit decision, Docket No. 99-5138, -5139, -5140, August 31, 2000.

8. U.S. Code of Federal Regulations, Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities, Subpart 54 (bb), Conditions of Licenses.

9. Low-Level Radioactive Waste Policy, Public Law 96-573, 1980.

10. Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99-240, January 15, 1986.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of 3

7. REFERENCES (continued)

11. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, Radiological Criteria for License Termination, Federal Register, Volume 62, Number 139 (p 39058 et seq.), July 21, 1997.

12. Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination, EPA Memorandum OSWER No. 9200.4-18, August 22, 1997.

13. U.S. Code of Federal Regulations, Title 40, Part 141.16, Maximum contaminant levels for beta particle and photon radioactivity from man-made radionuclides in community water systems.

14. Memorandum of Understanding Between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites, OSWER 9295.8-06a, October 9, 2002.

15. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),

NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000.

16. Decommissioning Cost Study for the Monticello Nuclear Generating Plant, Document No. X01-1475-003, TLG Services, Inc., July 2003.

17. T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

18. W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S.

Department of Energy, DOE/EV/10128-1, November 1980.

19. "Building Construction Cost Data 2005," Robert Snow Means Company, Inc.,

Kingston, Massachusetts.

20. Project and Cost Engineers Handbook, Second Edition, p. 239, American Association of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984.

21. Technical, Schedule, and Cost Uncertainties of the Yucca Mountain Repository Project, GAO-02-191, December 2001.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of 3

7. REFERENCES (continued)

22. Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004.

23. Civilian Radioactive Waste Management System Total System Description, Revision 02 (TDR-CRW-SE-000002), DOE/RW-0500, September 2001.

24. "Strategy for Management and Disposal of Greater-Than-Class C Low-Level Radioactive Waste, Federal Register Volume 60, Number 48 (p 13424 et seq.), March 1995.

25. U.S. Department of Transportation, Title 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 1996.

26. Tri-State Motor Transit Company, published tariffs, Interstate Commerce Commission (ICC), Docket No. MC-427719 Rules Tariff, March 2004, Radioactive Materials Tariff, January 2004.

27. J.C. Evans et al., "Long-Lived Activation Products in Reactor Materials" NUREG/CR-3474, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. August 1984.

28. R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr., "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station,"

NUREG/CR-0130 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1978.

29. H.D. Oak, et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672 and addenda, Pacific Northwest Laboratory for the Nuclear Regulatory Commission. June 1980.

30. 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.

31. "Microsoft Project 2002," Microsoft Corporation, Redmond, WA, 2002.

32. Atomic Energy Act of 1954, (68 Stat. 919).

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 1 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 2 of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example: Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1. SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist. They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.

2. CALCULATIONS Activity Critical Act Activity Duration Duration ID Description (minutes) (minutes)*

---

a Remove insulation 60 (b) b Mount pipe cutters 60 60 c Install contamination controls 20 (b) d Disconnect inlet and outlet lines 60 60 e Cap openings 20 (d) f Rig for removal 30 30 g Unbolt from mounts 30 30 h Remove contamination controls 15 15 i Remove, wrap, send to waste processing area 60 60 Totals (Activity/Critical) 355 255 Duration adjustment(s):

+ Respiratory protection adjustment (50% of critical duration) 128

+ Radiation/ALARA adjustment (37% of critical duration) 95 Adjusted work duration 478

+ Protective clothing adjustment (30% of adjusted duration) 143 Productive work duration 621

+ Work break adjustment (8.33 % of productive duration) 52 Total work duration (minutes) 673

• • • Total duration = 11.217 hr ***

• alpha designators indicate activities that can be performed in parallel TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 3 of 4 APPENDIX A (continued)

3. LABOR REQUIRED Crew Number Duration Rate Cost (hours) ($/hr)

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Laborers 3.00 11.217 $39.86 $1,341.33 Craftsmen 2.00 11.217 $52.66 $1,181.37 Foreman 1.00 11.217 $53.21 $596.86 General Foreman 0.25 11.217 $55.21 $154.82 Fire Watch 0.05 11.217 $39.86 $22.36 Health Physics Technician 1.00 11.217 $51.87 $581.83 Total labor cost $3,878.57

4. EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs

-Blotting paper 50 @ $0.39/sq ft {1} $19.50

-Plastic sheets/bags 50 @ $0.09/sq ft {2} $4.50

-Gas torch consumables 1 @ $6.69 x 1 /hr {3} $6.69 Subtotal cost of equipment and materials $30.69 Overhead & profit on equipment and materials @ 16.5 % $5.06 Total costs, equipment & material $35.75 TOTAL COST:

Removal of contaminated heat exchanger <3000 pounds: $3,914.32 Total labor cost: $3,878.57 Total equipment/material costs: $35.75 Total craft labor man-hours required per unit: 81.884 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4 of 4

5. NOTES AND REFERENCES

• Work difficulty factors were developed in conjunction with the Atomic Industrial Forums (now NEI) program to standardize nuclear decommissioning cost estimates and are delineated in Volume 1, Chapter 5 of the Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

• References for equipment & consumables costs:

1. McMaster-Carr: Spill Control (7193T85),

www.mcmaster.com online catalog

2. R.S. Means (2005) Division 01540 Section 800-0200

3. R.S. Means (2005) Division 01590 Section 400-6360

• Material and consumable costs were adjusted using the regional indices for Minneapolis, Minnesota.

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 1 of 8 APPENDIX B UNIT COST FACTOR LISTING (DECON: Power Block Structures Only)

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of clean instrument and sampling tubing, $/linear foot 0.43 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.62 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 6.57 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 12.93 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 24.99 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 32.40 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 47.69 Removal of clean pipe >36 inches diameter, $/linear foot 56.70 Removal of clean valve >2 to 4 inches 84.71 Removal of clean valve >4 to 8 inches 129.29 Removal of clean valve >8 to 14 inches 249.94 Removal of clean valve >14 to 20 inches 323.95 Removal of clean valve >20 to 36 inches 476.87 Removal of clean valve >36 inches 567.03 Removal of clean pipe hanger for small bore piping 27.32 Removal of clean pipe hanger for large bore piping 100.69 Removal of clean pump, <300 pound 215.96 Removal of clean pump, 300-1000 pound 604.40 Removal of clean pump, 1000-10,000 pound 2,397.06 Removal of clean pump, >10,000 pound 4,628.41 Removal of clean pump motor, 300-1000 pound 255.04 Removal of clean pump motor, 1000-10,000 pound 999.53 Removal of clean pump motor, >10,000 pound 2,248.92 Removal of clean heat exchanger <3000 pound 1,281.29 Removal of clean heat exchanger >3000 pound 3,215.05 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of clean feedwater heater/deaerator 9,104.71 Removal of clean moisture separator/reheater 18,772.41 Removal of clean tank, <300 gallons 278.04 Removal of clean tank, 300-3000 gallon 880.76 Removal of clean tank, >3000 gallons, $/square foot surface area 7.38 Removal of clean electrical equipment, <300 pound 118.95 Removal of clean electrical equipment, 300-1000 pound 415.24 Removal of clean electrical equipment, 1000-10,000 pound 830.48 Removal of clean electrical equipment, >10,000 pound 1,966.02 Removal of clean electrical transformer < 30 tons 1,365.37 Removal of clean electrical transformer > 30 tons 3,932.02 Removal of clean standby diesel generator, <100 kW 1,394.61 Removal of clean standby diesel generator, 100 kW to 1 MW 3,112.84 Removal of clean standby diesel generator, >1 MW 6,444.23 Removal of clean electrical cable tray, $/linear foot 11.04 Removal of clean electrical conduit, $/linear foot 4.82 Removal of clean mechanical equipment, <300 pound 118.95 Removal of clean mechanical equipment, 300-1000 pound 415.24 Removal of clean mechanical equipment, 1000-10,000 pound 830.48 Removal of clean mechanical equipment, >10,000 pound 1,966.02 Removal of clean HVAC equipment, <300 pound 118.95 Removal of clean HVAC equipment, 300-1000 pound 415.24 Removal of clean HVAC equipment, 1000-10,000 pound 830.48 Removal of clean HVAC equipment, >10,000 pound 1,966.02 Removal of clean HVAC ductwork, $/pound 0.46 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 4 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of contaminated instrument and sampling tubing, $/linear foot 1.42 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 17.75 Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 31.53 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 51.08 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 100.86 Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 121.75 Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 169.85 Removal of contaminated pipe >36 inches diameter, $/linear foot 201.42 Removal of contaminated valve >2 to 4 inches 395.49 Removal of contaminated valve >4 to 8 inches 479.71 Removal of contaminated valve >8 to 14 inches 980.60 Removal of contaminated valve >14 to 20 inches 1,250.08 Removal of contaminated valve >20 to 36 inches 1,670.51 Removal of contaminated valve >36 inches 1,986.21 Removal of contaminated pipe hanger for small bore piping 96.62 Removal of contaminated pipe hanger for large bore piping 312.95 Removal of contaminated pump, <300 pound 851.53 Removal of contaminated pump, 300-1000 pound 1,972.62 Removal of contaminated pump, 1000-10,000 pound 6,448.35 Removal of contaminated pump, >10,000 pound 15,708.68 Removal of contaminated pump motor, 300-1000 pound 822.01 Removal of contaminated pump motor, 1000-10,000 pound 2,608.28 Removal of contaminated pump motor, >10,000 pound 5,855.79 Removal of contaminated heat exchanger <3000 pound 3,914.32 Removal of contaminated heat exchanger >3000 pound 11,286.93 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of contaminated feedwater heater/deaerator 27,567.00 Removal of contaminated moisture separator/reheater 60,366.13 Removal of contaminated tank, <300 gallons 1,411.28 Removal of contaminated tank, >300 gallons, $/square foot 27.99 Removal of contaminated electrical equipment, <300 pound 670.49 Removal of contaminated electrical equipment, 300-1000 pound 1,614.87 Removal of contaminated electrical equipment, 1000-10,000 pound 3,108.31 Removal of contaminated electrical equipment, >10,000 pound 6,029.67 Removal of contaminated electrical cable tray, $/linear foot 32.32 Removal of contaminated electrical conduit, $/linear foot 14.50 Removal of contaminated mechanical equipment, <300 pound 746.69 Removal of contaminated mechanical equipment, 300-1000 pound 1,786.32 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,432.81 Removal of contaminated mechanical equipment, >10,000 pound 6,029.67 Removal of contaminated HVAC equipment, <300 pound 746.69 Removal of contaminated HVAC equipment, 300-1000 pound 1,786.32 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,432.81 Removal of contaminated HVAC equipment, >10,000 pound 6,029.67 Removal of contaminated HVAC ductwork, $/pound 1.90 Removal/plasma arc cut of contaminated thin metal components, $/linear in. 3.52 Additional decontamination of surface by washing, $/square foot 7.09 Additional decontamination of surfaces by hydrolasing, $/square foot 32.11 Decontamination rig hook up and flush, $/ 250 foot length 6,354.78 Chemical flush of components/systems, $/gallon 10.30 Removal of clean standard reinforced concrete, $/cubic yard 110.62 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of grade slab concrete, $/cubic yard 151.95 Removal of clean concrete floors, $/cubic yard 282.56 Removal of sections of clean concrete floors, $/cubic yard 855.38 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 182.50 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,753.92 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 230.83 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,323.56 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 361.12 Removal of below-grade suspended floors, $/cubic yard 282.56 Removal of clean monolithic concrete structures, $/cubic yard 729.17 Removal of contaminated monolithic concrete structures, $/cubic yard 1,755.22 Removal of clean foundation concrete, $/cubic yard 569.94 Removal of contaminated foundation concrete, $/cubic yard 1,634.52 Explosive demolition of bulk concrete, $/cubic yard 25.55 Removal of clean hollow masonry block wall, $/cubic yard 76.06 Removal of contaminated hollow masonry block wall, $/cubic yard 275.65 Removal of clean solid masonry block wall, $/cubic yard 76.06 Removal of contaminated solid masonry block wall, $/cubic yard 275.65 Backfill of below-grade voids, $/cubic yard 13.78 Removal of subterranean tunnels/voids, $/linear foot 90.74 Placement of concrete for below-grade voids, $/cubic yard 91.85 Excavation of clean material, $/cubic yard 2.10 Excavation of contaminated material, $/cubic yard 33.46 Removal of clean concrete rubble (tipping fee included), $/cubic yard 77.81 Removal of contaminated concrete rubble, $/cubic yard 20.82 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 7 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

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Removal of building by volume, $/cubic foot 0.24 Removal of clean building metal siding, $/square foot 0.99 Removal of contaminated building metal siding, $/square foot 3.68 Removal of standard asphalt roofing, $/square foot 2.04 Removal of transite panels, $/square foot 1.97 Scarifying contaminated concrete surfaces (drill & spall), $/square foot 11.49 Scabbling contaminated concrete floors, $/square foot 6.77 Scabbling contaminated concrete walls, $/square foot 7.45 Scabbling contaminated ceilings, $/square foot 67.03 Scabbling structural steel, $/square foot 5.88 Removal of clean overhead crane/monorail < 10 ton capacity 580.74 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,683.07 Removal of clean overhead crane/monorail >10-50 ton capacity 1,393.76 Removal of contaminated overhead crane/monorail >10-50 ton capacity 4,038.66 Removal of polar crane > 50 ton capacity 5,792.86 Removal of gantry crane > 50 ton capacity 24,575.11 Removal of structural steel, $/pound 0.33 Removal of clean steel floor grating, $/square foot 4.05 Removal of contaminated steel floor grating, $/square foot 12.04 Removal of clean free standing steel liner, $/square foot 11.07 Removal of contaminated free standing steel liner, $/square foot 32.83 Removal of clean concrete-anchored steel liner, $/square foot 5.54 Removal of contaminated concrete-anchored steel liner, $/square foot 38.24 Placement of scaffolding in clean areas, $/square foot 12.62 Placement of scaffolding in contaminated areas, $/square foot 22.54 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 8 of 8 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit

---

Landscaping with topsoil, $/acre 16,177.97 Cost of CPC B-88 LSA box & preparation for use 1,151.62 Cost of CPC B-25 LSA box & preparation for use 915.21 Cost of CPC B-12V 12 gauge LSA box & preparation for use 785.92 Cost of CPC B-144 LSA box & preparation for use 4,417.99 Cost of LSA drum & preparation for use 110.58 Cost of cask liner for CNSI 14 195 cask 7,841.84 Cost of cask liner for CNSI 8 120A cask (resins) 5,576.01 Cost of cask liner for CNSI 8 120A cask (filters) 5,576.01 Decontamination of surfaces with vacuuming, $/square foot 0.59 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 1 of 12 APPENDIX C DETAILED COST ANALYSIS DECON TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 2 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours PERIOD 1a - Shutdown through Transition Period 1a Direct Decommissioning Activities 1a.1.1 Prepare preliminary decommissioning cost - - - - - - 122 18 141 141 - - - - - - - - - 1,300 1a.1.2 Notification of Cessation of Operations a 1a.1.3 Remove fuel & source material n/a 1a.1.4 Notification of Permanent Defueling a 1a.1.5 Deactivate plant systems & process waste a 1a.1.6 Prepare and submit PSDAR - - - - - - 188 28 216 216 - - - - - - - - - 2,000 1a.1.7 Review plant dwgs & specs. - - - - - - 433 65 498 498 - - - - - - - - - 4,600 1a.1.8 Perform detailed rad survey a 1a.1.9 Estimate by-product inventory - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1a.1.10 End product description - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1a.1.11 Detailed by-product inventory - - - - - - 122 18 141 141 - - - - - - - - - 1,300 1a.1.12 Define major work sequence - - - - - - 705 106 811 811 - - - - - - - - - 7,500 1a.1.13 Perform SER and EA - - - - - - 292 44 335 335 - - - - - - - - - 3,100 1a.1.14 Perform Site-Specific Cost Study - - - - - - 470 71 541 541 - - - - - - - - - 5,000 1a.1.15 Prepare/submit License Termination Plan - - - - - - 385 58 443 443 - - - - - - - - - 4,096 1a.1.16 Receive NRC approval of termination plan a Activity Specifications 1a.1.17.1 Plant & temporary facilities - - - - - - 463 69 532 479 - 53 - - - - - - - 4,920 1a.1.17.2 Plant systems - - - - - - 392 59 451 406 - 45 - - - - - - - 4,167 1a.1.17.3 NSSS Decontamination Flush - - - - - - 47 7 54 54 - - - - - - - - - 500 1a.1.17.4 Reactor internals - - - - - - 668 100 768 768 - - - - - - - - - 7,100 1a.1.17.5 Reactor vessel - - - - - - 611 92 703 703 - - - - - - - - - 6,500 1a.1.17.6 Sacrificial shield - - - - - - 47 7 54 54 - - - - - - - - - 500 1a.1.17.7 Moisture separators/reheaters - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1a.1.17.8 Reinforced concrete - - - - - - 150 23 173 87 - 87 - - - - - - - 1,600 1a.1.17.9 Main Turbine - - - - - - 196 29 226 226 - - - - - - - - - 2,088 1a.1.17.10 Main Condensers - - - - - - 196 29 226 226 - - - - - - - - - 2,088 1a.1.17.11 Pressure suppression structure - - - - - - 188 28 216 216 - - - - - - - - - 2,000 1a.1.17.12 Drywell - - - - - - 150 23 173 173 - - - - - - - - - 1,600 1a.1.17.13 Plant structures & buildings - - - - - - 293 44 337 169 - 169 - - - - - - - 3,120 1a.1.17.14 Waste management - - - - - - 433 65 498 498 - - - - - - - - - 4,600 1a.1.17.15 Facility & site closeout - - - - - - 85 13 97 49 - 49 - - - - - - - 900 1a.1.17 Total - - - - - - 4,015 602 4,617 4,215 - 402 - - - - - - - 42,683 Planning & Site Preparations 1a.1.18 Prepare dismantling sequence - - - - - - 226 34 260 260 - - - - - - - - - 2,400 1a.1.19 Plant prep. & temp. svces - - - - - - 2,419 363 2,782 2,782 - - - - - - - - - -

1a.1.20 Design water clean-up system - - - - - - 132 20 151 151 - - - - - - - - - 1,400 1a.1.21 Rigging/Cont. Cntrl Envlps/tooling/etc. - - - - - - 2,048 307 2,355 2,355 - - - - - - - - - -

1a.1.22 Procure casks/liners & containers - - - - - - 116 17 133 133 - - - - - - - - - 1,230 1a.1 Subtotal Period 1a Activity Costs - - - - - - 11,861 1,779 13,640 13,238 - 402 - - - - - - - 78,609 Period 1a Additional Costs 1a.2.1 Spent Fuel Pool Isolation - - - - - - 8,609 1,291 9,900 9,900 - - - - - - - - - -

1a.2 Subtotal Period 1a Additional Costs - - - - - - 8,609 1,291 9,900 9,900 - - - - - - - - - -

Period 1a Collateral Costs 1a.3.1 Spent Fuel Capital and Transfer - - - - - - 5,034 755 5,789 - 5,789 - - - - - - - - -

1a.3 Subtotal Period 1a Collateral Costs - - - - - - 5,034 755 5,789 - 5,789 - - - - - - - - -

Period 1a Period-Dependent Costs 1a.4.1 Insurance - - - - - - 1,080 108 1,188 1,188 - - - - - - - - - -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 3 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 1a Period-Dependent Costs (continued) 1a.4.2 Property taxes - - - - - - 1,970 197 2,167 2,167 - - - - - - - - - -

1a.4.3 Health physics supplies - 209 - - - - - 52 262 262 - - - - - - - - - -

1a.4.4 Heavy equipment rental - 277 - - - - - 42 319 319 - - - - - - - - - -

1a.4.5 Disposal of DAW generated - - 5 3 - 33 - 9 51 51 - - - 404 - - - 8,103 99 -

1a.4.6 Plant energy budget - - - - - - 1,708 256 1,964 1,964 - - - - - - - - - -

1a.4.7 NRC Fees - - - - - - 265 27 292 292 - - - - - - - - - -

1a.4.8 Emergency Planning Fees - - - - - - 450 45 495 - 495 - - - - - - - - -

1a.4.9 Railtrack Maintenance Fee - - - - - - 80 12 92 92 - - - - - - - - - -

1a.4.10 Spent Fuel Pool O&M - - - - - - 630 95 725 - 725 - - - - - - - - -

1a.4.11 ISFSI Operating Costs - - - - - - 75 11 87 - 87 - - - - - - - - -

1a.4.12 Security Staff Cost - - - - - - 2,403 360 2,763 2,763 - - - - - - - - - 58,921 1a.4.13 Utility Staff Cost - - - - - - 25,480 3,822 29,302 29,302 - - - - - - - - - 440,086 1a.4 Subtotal Period 1a Period-Dependent Costs - 487 5 3 - 33 34,141 5,036 39,705 38,399 1,306 - - 404 - - - 8,103 99 499,007 1a.0 TOTAL PERIOD 1a COST - 487 5 3 - 33 59,645 8,862 69,035 61,537 7,095 402 - 404 - - - 8,103 99 577,616 PERIOD 1b - Decommissioning Preparations Period 1b Direct Decommissioning Activities Detailed Work Procedures 1b.1.1.1 Plant systems - - - - - - 445 67 512 461 - 51 - - - - - - - 4,733 1b.1.1.2 NSSS Decontamination Flush - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1b.1.1.3 Reactor internals - - - - - - 376 56 433 433 - - - - - - - - - 4,000 1b.1.1.4 Remaining buildings - - - - - - 127 19 146 37 - 110 - - - - - - - 1,350 1b.1.1.5 CRD housings & NIs - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1b.1.1.6 Incore instrumentation - - - - - - 94 14 108 108 - - - - - - - - - 1,000 1b.1.1.7 Removal primary containment - - - - - - 188 28 216 216 - - - - - - - - - 2,000 1b.1.1.8 Reactor vessel - - - - - - 341 51 393 393 - - - - - - - - - 3,630 1b.1.1.9 Facility closeout - - - - - - 113 17 130 65 - 65 - - - - - - - 1,200 1b.1.1.10 Sacrificial shield - - - - - - 113 17 130 130 - - - - - - - - - 1,200 1b.1.1.11 Reinforced concrete - - - - - - 94 14 108 54 - 54 - - - - - - - 1,000 1b.1.1.12 Main Turbine - - - - - - 196 29 225 225 - - - - - - - - - 2,080 1b.1.1.13 Main Condensers - - - - - - 196 29 226 226 - - - - - - - - - 2,088 1b.1.1.14 Moisture separators & reheaters - - - - - - 188 28 216 216 - - - - - - - - - 2,000 1b.1.1.15 Radwaste building - - - - - - 257 39 295 266 - 30 - - - - - - - 2,730 1b.1.1.16 Reactor building - - - - - - 257 39 295 266 - 30 - - - - - - - 2,730 1b.1.1 Total - - - - - - 3,174 476 3,650 3,311 - 339 - - - - - - - 33,741 1b.1.2 Decon NSSS 142 - - - - - - 71 213 213 - - - - - - - - 1,067 -

1b.1 Subtotal Period 1b Activity Costs 142 - - - - - 3,174 547 3,862 3,524 - 339 - - - - - - 1,067 33,741 Period 1b Additional Costs 1b.2.1 Site Characterization - - - - - - 2,187 656 2,843 2,843 - - - - - - - - - -

1b.2.2 Mixed Waste - - 2 10 21 - - 5 39 39 - - - - - - - - - -

1b.2.3 RCRA Waste - - 0 4 1 - - 1 6 6 - - - - - - - - - -

1b.2 Subtotal Period 1b Additional Costs - - 2 15 22 - 2,187 662 2,888 2,888 - - - - - - - - - -

Period 1b Collateral Costs 1b.3.1 Decon equipment 596 - - - - - - 89 685 685 - - - - - - - - - -

1b.3.2 DOC staff relocation expenses - - - - - - 1,306 196 1,502 1,502 - - - - - - - - - -

1b.3.3 Process liquid waste 35 - 47 117 - 700 - 215 1,114 1,114 - - - - 726 - - 112,256 59 -

1b.3.4 Small tool allowance - 1 - - - - - 0 1 1 - - - - - - - - - -

1b.3.5 Pipe cutting equipment - 957 - - - - - 143 1,100 1,100 - - - - - - - - - -

1b.3.6 Decon rig 1,243 - - - - - - 186 1,430 1,430 - - - - - - - - - -

1b.3.7 Spent Fuel Capital and Transfer - - - - - - 3,681 552 4,234 - 4,234 - - - - - - - - -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 4 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours 1b.3 Subtotal Period 1b Collateral Costs 1,874 957 47 117 - 700 4,987 1,382 10,065 5,832 4,234 - - - 726 - - 112,256 59 -

Period 1b Period-Dependent Costs 1b.4.1 Decon supplies 18 - - - - - - 5 23 23 - - - - - - - - - -

1b.4.2 Insurance - - - - - - 276 28 304 304 - - - - - - - - - -

1b.4.3 Property taxes - - - - - - 988 99 1,086 1,086 - - - - - - - - - -

1b.4.4 Health physics supplies - 108 - - - - - 27 135 135 - - - - - - - - - -

1b.4.5 Heavy equipment rental - 139 - - - - - 21 160 160 - - - - - - - - - -

1b.4.6 Disposal of DAW generated - - 3 2 - 18 - 5 27 27 - - - 219 - - - 4,394 54 -

1b.4.7 Plant energy budget - - - - - - 1,713 257 1,970 1,970 - - - - - - - - - -

1b.4.8 NRC Fees - - - - - - 133 13 146 146 - - - - - - - - - -

1b.4.9 Emergency Planning Fees - - - - - - 225 23 248 - 248 - - - - - - - - -

1b.4.10 Railtrack Maintenance Fee - - - - - - 40 6 46 46 - - - - - - - - - -

1b.4.11 Spent Fuel Pool O&M - - - - - - 316 47 363 - 363 - - - - - - - - -

1b.4.12 ISFSI Operating Costs - - - - - - 38 6 43 - 43 - - - - - - - - -

1b.4.13 Security Staff Cost - - - - - - 1,205 181 1,385 1,385 - - - - - - - - - 29,541 1b.4.14 DOC Staff Cost - - - - - - 3,966 595 4,561 4,561 - - - - - - - - - 63,789 1b.4.15 Utility Staff Cost - - - - - - 12,775 1,916 14,691 14,691 - - - - - - - - - 220,646 1b.4 Subtotal Period 1b Period-Dependent Costs 18 247 3 2 - 18 21,674 3,228 25,190 24,535 655 - - 219 - - - 4,394 54 313,976 1b.0 TOTAL PERIOD 1b COST 2,034 1,205 52 134 22 718 32,022 5,819 42,006 36,779 4,888 339 - 219 726 - - 116,650 1,179 347,717 PERIOD 1 TOTALS 2,034 1,691 57 137 22 752 91,667 14,680 111,041 98,316 11,984 741 - 624 726 - - 124,753 1,278 925,333 PERIOD 2a - Large Component Removal Period 2a Direct Decommissioning Activities Nuclear Steam Supply System Removal 2a.1.1.1 Recirculation System Piping & Valves 79 65 8 16 - 144 - 95 407 407 - - - 811 - - - 98,041 2,887 -

2a.1.1.2 Recirculation Pumps & Motors 28 43 13 27 31 148 - 72 362 362 - - 96 945 - - - 111,100 1,563 -

2a.1.1.3 CRDMs & NIs Removal 138 107 170 72 - 137 - 158 782 782 - - - 3,741 - - - 93,194 4,779 -

2a.1.1.4 Reactor Vessel Internals 118 2,202 4,524 1,470 - 9,033 199 7,755 25,301 25,301 - - - 626 1,033 804 - 238,482 25,526 1,153 2a.1.1.5 Reactor Vessel 58 5,059 1,240 564 - 6,441 199 7,524 21,084 21,084 - - - 8,512 1,502 - - 1,071,860 25,526 1,153 2a.1.1 Totals 422 7,475 5,954 2,148 31 15,903 399 15,604 47,936 47,936 - - 96 14,635 2,536 804 - 1,612,677 60,282 2,306 Removal of Major Equipment 2a.1.2 Main Turbine/Generator - 255 408 245 5,257 151 - 968 7,285 7,285 - - 38,944 1,148 - - - 1,855,487 5,201 -

2a.1.3 Main Condensers - 911 182 110 2,348 68 - 632 4,250 4,250 - - 17,396 513 - - - 828,816 18,831 -

Cascading Costs from Clean Building Demolition 2a.1.4 Totals - - - - - - - - - - - - - - - - - - - -

Disposal of Plant Systems 2a.1.5.1 Automatic Press Relief - 80 3 6 98 19 - 41 247 247 - - 803 145 - - - 45,632 1,653 -

2a.1.5.2 Chemistry Sampling - 19 0 1 19 3 - 9 52 52 - - 156 26 - - - 8,670 400 -

2a.1.5.3 Chemistry Sampling - Insulated - 1 - - - 0 - 0 2 2 - - - 1 - - - 69 28 -

2a.1.5.4 Circulating Water - RCA - 138 7 35 811 - - 162 1,154 1,154 - - 6,656 - - - - 270,307 2,843 -

2a.1.5.5 Combustible Gas Control - Insul - RCA - 19 0 1 26 - - 9 55 55 - - 212 - - - - 8,617 370 -

2a.1.5.6 Combustible Gas Control - RCA - 12 0 2 35 - - 8 57 57 - - 285 - - - - 11,577 242 -

2a.1.5.7 Condensate & Feedwater - 664 71 181 2,430 681 - 735 4,762 4,762 - - 19,947 5,167 - - - 1,273,602 13,956 -

2a.1.5.8 Condensate & Feedwater - Insulated - 325 13 35 509 112 - 192 1,186 1,186 - - 4,176 852 - - - 245,987 6,772 -

2a.1.5.9 Condensate Demin - 353 11 28 408 93 - 178 1,071 1,071 - - 3,346 712 - - - 199,184 7,274 -

2a.1.5.10 Condensate Storage - 496 14 46 869 74 - 281 1,781 1,781 - - 7,131 615 - - - 339,959 10,225 -

2a.1.5.11 Control Rod Drive - 2 - 0 2 0 - 1 6 6 - - 19 3 - - - 1,003 41 -

2a.1.5.12 Control Rod Drive Hydraulic - 286 6 15 202 52 - 118 678 678 - - 1,658 398 - - - 102,941 5,874 -

2a.1.5.13 Core Spray - 54 8 29 534 48 - 111 784 784 - - 4,384 368 - - - 211,032 1,146 -

2a.1.5.14 Core Spray - Insulated - 93 3 7 100 25 - 46 273 273 - - 818 186 - - - 49,915 1,935 -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 5 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Disposal of Plant Systems (continued) 2a.1.5.15 Demin Water - Insulated - RCA - 10 - 0 10 - - 4 24 24 - - 85 - - - - 3,445 180 -

2a.1.5.16 Demin Water - RCA - 27 0 1 31 - - 12 71 71 - - 253 - - - - 10,278 507 -

2a.1.5.17 Diesel Oil - RCA - 1 - 0 3 - - 1 5 5 - - 23 - - - - 931 25 -

2a.1.5.18 Drywell Atmosphere Cooling - RCA - 26 1 3 67 - - 17 114 114 - - 548 - - - - 22,244 550 -

2a.1.5.19 EDG Emerg Service Water - Insul - RCA - 0 - - 0 - - - 1 1 - - 2 - - - - 84 4 -

2a.1.5.20 Electrical - Clean - 8 - - - - - 1 10 - - 10 - - - - - - 182 -

2a.1.5.21 Emergency Service Water - Insul - RCA - 14 0 1 17 - - 6 37 37 - - 137 - - - - 5,544 277 -

2a.1.5.22 Emergency Service Water - RCA - 1 - - 2 - - 1 3 3 - - 13 - - - - 512 22 -

2a.1.5.23 GEZIP - RCA - 2 0 1 13 - - 3 18 18 - - 103 - - - - 4,184 48 -

2a.1.5.24 Generator Physical Design - RCA - 3 - 0 4 - - 1 9 9 - - 31 - - - - 1,250 67 -

2a.1.5.25 H2-O2 Control Analyzing - 4 0 0 1 1 - 1 8 8 - - 6 9 - - - 1,048 80 -

2a.1.5.26 H2-O2 Control Analyzing - Insulated - 4 0 0 1 1 - 1 8 8 - - 6 9 - - - 1,048 80 -

2a.1.5.27 High Pressure Coolant Injection - 45 3 7 118 19 - 35 228 228 - - 972 147 - - - 52,675 953 -

2a.1.5.28 High Pressure Coolant Injection - Insula - 145 5 13 195 45 - 79 483 483 - - 1,598 340 - - - 95,346 3,009 -

2a.1.5.29 Hydrogen Cooling - 5 - - - - - 1 6 - - 6 - - - - - - 118 -

2a.1.5.30 Hydrogen Cooling - RCA - 4 - 0 5 - - 2 11 11 - - 39 - - - - 1,600 79 -

2a.1.5.31 Hydrogen Seal Oil - RCA - 11 0 1 23 - - 6 42 42 - - 189 - - - - 7,669 211 -

2a.1.5.32 Hydrogen Water Chemistry - RCA - 16 0 1 17 - - 7 40 40 - - 140 - - - - 5,672 304 -

2a.1.5.33 Instrument & Service Air - RCA - 144 2 9 215 - - 70 440 440 - - 1,768 - - - - 71,810 2,730 -

2a.1.5.34 Main Condenser - 128 5 11 162 38 - 68 413 413 - - 1,333 290 - - - 80,131 2,652 -

2a.1.5.35 Main Steam - 164 7 18 262 55 - 97 603 603 - - 2,148 422 - - - 124,831 3,415 -

2a.1.5.36 Main Turbine - 689 79 194 2,407 809 - 773 4,951 4,951 - - 19,760 6,143 - - - 1,352,621 14,578 -

2a.1.5.37 Main Turbine - Insulated - 144 7 20 308 62 - 102 644 644 - - 2,530 471 - - - 144,976 3,026 -

2a.1.5.38 Miscellaneous - 30 0 2 37 - - 13 82 82 - - 302 - - - - 12,283 622 -

2a.1.5.39 Off Gas Recombiner - 128 7 17 219 71 - 86 528 528 - - 1,795 539 - - - 121,307 2,664 -

2a.1.5.40 Off Gas Recombiner - Insulated - 246 7 15 166 66 - 106 606 606 - - 1,366 500 - - - 100,350 5,078 -

2a.1.5.41 Post Accident Sampling - 17 0 1 6 3 - 6 34 34 - - 53 23 - - - 4,251 344 -

2a.1.5.42 Post Accident Sampling - Insulated - 11 0 0 2 3 - 4 21 21 - - 17 26 - - - 3,024 212 -

2a.1.5.43 RHR Service Water - Insulated - RCA - 55 2 8 181 - - 42 287 287 - - 1,485 - - - - 60,293 1,117 -

2a.1.5.44 RHR Service Water - RCA - 3 - 0 4 - - 1 9 9 - - 35 - - - - 1,410 57 -

2a.1.5.45 Reactor Feedwater Pump Seal - 36 1 2 24 9 - 15 86 86 - - 193 68 - - - 13,952 732 -

2a.1.5.46 Residual Heat Removal 178 172 60 96 780 559 - 409 2,256 2,256 - - 6,406 4,244 - - - 640,605 4,053 -

2a.1.5.47 Residual Heat Removal - Insulated 336 376 23 45 410 243 - 393 1,826 1,826 - - 3,367 1,840 - - - 301,810 10,294 -

2a.1.5.48 Rx Core Isolation Cooling - 33 1 2 32 7 - 15 89 89 - - 259 53 - - - 15,315 677 -

2a.1.5.49 Rx Core Isolation Cooling - Insulated - 67 2 4 35 18 - 27 154 154 - - 288 140 - - - 24,227 1,383 -

2a.1.5.50 Rx Recirculation 40 38 2 2 5 18 - 35 140 140 - - 43 134 - - - 13,773 1,577 -

2a.1.5.51 Snubbers - 120 1 3 46 8 - 40 218 218 - - 377 63 - - - 20,991 2,547 -

2a.1.5.52 Standby Liquid Control - Insul - RCA - 2 - 0 3 - - 1 6 6 - - 22 - - - - 904 48 -

2a.1.5.53 Standby Liquid Control - RCA - 17 0 1 30 - - 9 58 58 - - 245 - - - - 9,969 340 -

2a.1.5.54 Stator Cooling - RCA - 5 0 1 15 - - 4 25 25 - - 126 - - - - 5,135 97 -

2a.1.5.55 Traversing Incore Probe - 2 - - - 1 - 1 4 4 - - 1 4 - - - 372 51 -

2a.1.5 Totals 554 5,499 354 866 11,897 3,147 - 4,387 26,705 26,689 - 16 97,654 23,940 - - - 6,106,371 117,747 -

2a.1.6 Scaffolding in support of decommissioning - 1,601 11 7 139 4 - 424 2,187 2,187 - - 1,030 51 - - - 51,492 22,564 -

2a.1 Subtotal Period 2a Activity Costs 976 15,742 6,910 3,376 19,673 19,273 399 22,015 88,363 88,347 - 16 155,119 40,288 2,536 804 - 10,454,840 224,624 2,306 Period 2a Additional Costs 2a.2.1 Curie Surcharge (excluding RPV) - - - - - 581 - 145 726 726 - - - - - - - - - -

2a.2 Subtotal Period 2a Additional Costs - - - - - 581 - 145 726 726 - - - - - - - - - -

Period 2a Collateral Costs 2a.3.1 Process liquid waste 79 - 188 426 - 2,576 - 766 4,035 4,035 - - - - 2,759 - - 441,895 161 -

2a.3.2 Small tool allowance - 156 - - - - - 23 180 162 - 18 - - - - - - - -

2a.3.3 Spent Fuel Capital and Transfer - - - - - - 9,086 1,363 10,448 - 10,448 - - - - - - - - -

2a.3 Subtotal Period 2a Collateral Costs 79 156 188 426 - 2,576 9,086 2,152 14,663 4,197 10,448 18 - - 2,759 - - 441,895 161 -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 6 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 45 - - - - - - 11 56 56 - - - - - - - - - -

2a.4.2 Insurance - - - - - - 690 69 759 759 - - - - - - - - - -

2a.4.3 Property taxes - - - - - - 2,439 244 2,683 2,415 - 268 - - - - - - - -

2a.4.4 Health physics supplies - 904 - - - - - 226 1,130 1,130 - - - - - - - - - -

2a.4.5 Heavy equipment rental - 1,673 - - - - - 251 1,924 1,924 - - - - - - - - - -

2a.4.6 Disposal of DAW generated - - 60 35 - 381 - 107 583 583 - - - 4,650 - - - 93,174 1,142 -

2a.4.7 Plant energy budget - - - - - - 2,009 301 2,311 2,311 - - - - - - - - - -

2a.4.8 NRC Fees - - - - - - 406 41 446 446 - - - - - - - - - -

2a.4.9 Emergency Planning Fees - - - - - - 557 56 613 - 613 - - - - - - - - -

2a.4.10 Railtrack Maintenance Fee - - - - - - 99 15 113 113 - - - - - - - - - -

2a.4.11 Spent Fuel Pool O&M - - - - - - 780 117 897 - 897 - - - - - - - - -

2a.4.12 ISFSI Operating Costs - - - - - - 93 14 107 - 107 - - - - - - - - -

2a.4.13 Security Staff Cost - - - - - - 3,713 557 4,269 4,269 - - - - - - - - - 91,046 2a.4.14 DOC Staff Cost - - - - - - 11,863 1,779 13,642 13,642 - - - - - - - - - 196,297 2a.4.15 Utility Staff Cost - - - - - - 17,497 2,625 20,122 20,122 - - - - - - - - - 282,177 2a.4 Subtotal Period 2a Period-Dependent Costs 45 2,577 60 35 - 381 40,145 6,412 49,656 47,770 1,617 268 - 4,650 - - - 93,174 1,142 569,520 2a.0 TOTAL PERIOD 2a COST 1,100 18,475 7,158 3,837 19,673 22,811 49,630 30,724 153,408 141,040 12,066 302 155,119 44,937 5,294 804 - 10,989,910 225,926 571,826 PERIOD 2b - Site Decontamination Period 2b Direct Decommissioning Activities Disposal of Plant Systems 2b.1.1.1 ALARA/Radiological - 13 0 0 4 1 - 4 23 23 - - 35 7 - - - 2,055 277 -

2b.1.1.2 Alternate N2 - RCA - 10 - 0 11 - - 4 26 26 - - 93 - - - - 3,765 185 -

2b.1.1.3 Decontamination Projects - 1 - - 0 - - 0 1 1 - - 2 0 - - - 128 17 -

2b.1.1.4 Electrical - Contaminated - 304 3 14 291 8 - 124 744 744 - - 2,389 64 - - - 102,708 6,324 -

2b.1.1.5 Electrical - Decontaminated - 1,800 24 124 2,844 - - 897 5,689 5,689 - - 23,344 - - - - 948,013 37,100 -

2b.1.1.6 Fire - RCA - 66 1 3 75 - - 28 173 173 - - 614 - - - - 24,917 1,315 -

2b.1.1.7 HVAC Ductwork - 216 3 15 325 9 - 108 677 677 - - 2,665 71 - - - 114,579 4,110 -

2b.1.1.8 HVAC/Chilled Water - RCA - 207 3 15 335 - - 104 664 664 - - 2,752 - - - - 111,779 3,956 -

2b.1.1.9 Heating & Ventilation - 339 7 34 733 21 - 206 1,341 1,341 - - 6,018 160 - - - 258,746 7,097 -

2b.1.1.10 Heating Boiler - Insulated - RCA - 2 - 0 3 - - 1 6 6 - - 26 - - - - 1,058 35 -

2b.1.1.11 Liquid Radwaste 407 463 19 34 374 161 - 423 1,881 1,881 - - 3,073 1,377 - - - 234,130 17,065 -

2b.1.1.12 Makeup Demin - RCA - 70 2 8 179 - - 46 305 305 - - 1,471 - - - - 59,747 1,411 -

2b.1.1.13 Non-Essential Diesel Generator - RCA - 19 1 8 173 - - 32 234 234 - - 1,424 - - - - 57,832 394 -

2b.1.1.14 Off Gas Holdup - 228 8 21 336 59 - 126 778 778 - - 2,755 458 - - - 151,726 4,673 -

2b.1.1.15 Primary Containment - 308 17 48 755 140 - 234 1,504 1,504 - - 6,201 1,066 - - - 347,223 6,404 -

2b.1.1.16 Process Radiation Monitors - 32 1 1 17 5 - 12 68 68 - - 142 36 - - - 9,040 648 -

2b.1.1.17 Rx Bldg Closed Clng Water - Insul - RCA - 73 1 5 119 - - 37 235 235 - - 977 - - - - 39,675 1,459 -

2b.1.1.18 Rx Bldg Closed Clng Water - RCA - 121 7 38 864 - - 166 1,196 1,196 - - 7,093 - - - - 288,031 2,463 -

2b.1.1.19 Rx Component Handling Equip 19 99 7 15 141 77 - 77 434 434 - - 1,158 585 - - - 99,571 2,455 -

2b.1.1.20 Rx Pressure Vessel 20 32 2 3 9 21 - 25 112 112 - - 75 162 - - - 17,616 1,048 -

2b.1.1.21 Rx Water Cleanup 115 175 6 8 16 69 - 122 511 511 - - 130 523 - - - 51,929 5,671 -

2b.1.1.22 Secondary Containment - 85 3 8 124 24 - 47 290 290 - - 1,017 180 - - - 57,431 1,754 -

2b.1.1.23 Service & Seal Water - Insulated - RCA - 78 1 6 144 - - 42 272 272 - - 1,180 - - - - 47,917 1,554 -

2b.1.1.24 Service & Seal Water - RCA - 103 2 10 220 - - 60 395 395 - - 1,809 - - - - 73,453 2,000 -

2b.1.1.25 Service Air Blower - RCA - 10 0 1 25 - - 6 43 43 - - 206 - - - - 8,364 203 -

2b.1.1.26 Solid Radwaste 225 327 14 27 291 128 - 275 1,288 1,288 - - 2,387 1,063 - - - 184,304 10,555 -

2b.1.1.27 Structures & Buildings - 54 1 3 44 8 - 23 132 132 - - 357 60 - - - 19,916 1,127 -

2b.1.1.28 Wells & Domestic Water - 6 - - - - - 1 7 - - 7 - - - - - - 144 -

2b.1.1.29 Wells & Domestic Water - RCA - 33 0 2 42 - - 15 92 92 - - 342 - - - - 13,874 628 -

2b.1.1 Totals 785 5,276 135 450 8,496 731 - 3,249 19,122 19,115 - 7 69,735 5,814 - - - 3,329,527 122,074 -

2b.1.2 Scaffolding in support of decommissioning - 2,002 14 9 174 5 - 530 2,734 2,734 - - 1,287 64 - - - 64,365 28,205 -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 7 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Decontamination of Site Buildings 2b.1.3.1 Reactor Building 3,682 2,216 102 302 5,857 375 - 3,423 15,958 15,958 - - 48,077 4,597 - - - 2,410,318 115,483 -

2b.1.3.2 Admin 72 4 1 1 - 6 - 39 123 123 - - - 68 - - - 6,840 1,601 -

2b.1.3.3 HPCI Room 20 20 1 2 14 5 - 19 80 80 - - 118 61 - - - 10,724 785 -

2b.1.3.4 Hot Shop 11 3 0 1 - 4 - 8 27 27 - - - 49 - - - 4,860 287 -

2b.1.3.5 LLRW Storage & Shipping 39 17 2 4 4 17 - 29 112 112 - - 31 205 - - - 21,698 1,131 -

2b.1.3.6 Offgas Stack 257 170 5 12 164 26 - 204 838 838 - - 1,343 321 - - - 86,523 8,429 -

2b.1.3.7 Offgas Storage & Compressor 27 12 2 3 3 12 - 21 80 80 - - 25 150 - - - 15,942 789 -

2b.1.3.8 Radwaste 82 43 5 8 21 35 - 66 260 260 - - 172 434 - - - 49,892 2,513 -

2b.1.3.9 Radwaste Material Storage Warehouse 43 17 2 4 - 19 - 32 118 118 - - - 234 - - - 23,400 1,203 -

2b.1.3.10 Recombiner 18 17 1 3 24 8 - 20 92 92 - - 199 105 - - - 18,354 697 -

2b.1.3.11 Turbine 479 249 27 51 156 206 - 387 1,554 1,554 - - 1,283 2,525 - - - 302,816 14,499 -

2b.1.3.12 Turbine Building Addition 40 15 2 4 - 17 - 28 105 105 - - - 205 - - - 20,478 1,092 -

2b.1.3 Totals 4,771 2,784 149 395 6,244 730 - 4,275 19,348 19,348 - - 51,247 8,953 - - - 2,971,846 148,508 -

2b.1 Subtotal Period 2b Activity Costs 5,556 10,061 298 853 14,913 1,467 - 8,054 41,203 41,196 - 7 122,269 14,831 - - - 6,365,737 298,787 -

Period 2b Collateral Costs 2b.3.1 Process liquid waste 113 - 70 225 - 1,065 - 364 1,837 1,837 - - - - 1,251 - - 176,286 171 -

2b.3.2 Small tool allowance - 206 - - - - - 31 237 237 - - - - - - - - - -

2b.3.3 Spent Fuel Capital and Transfer - - - - - - 18,949 2,842 21,791 - 21,791 - - - - - - - - -

2b.3 Subtotal Period 2b Collateral Costs 113 206 70 225 - 1,065 18,949 3,237 23,865 2,074 21,791 - - - 1,251 - - 176,286 171 -

Period 2b Period-Dependent Costs 2b.4.1 Decon supplies 741 - - - - - - 185 926 926 - - - - - - - - - -

2b.4.2 Insurance - - - - - - 1,539 154 1,693 1,693 - - - - - - - - - -

2b.4.3 Property taxes - - - - - - 1,861 186 2,047 2,047 - - - - - - - - - -

2b.4.4 Health physics supplies - 1,437 - - - - - 359 1,796 1,796 - - - - - - - - - -

2b.4.5 Heavy equipment rental - 3,757 - - - - - 564 4,321 4,321 - - - - - - - - - -

2b.4.6 Disposal of DAW generated - - 78 46 - 497 - 139 759 759 - - - 6,058 - - - 121,401 1,487 -

2b.4.7 Plant energy budget - - - - - - 3,541 531 4,072 4,072 - - - - - - - - - -

2b.4.8 NRC Fees - - - - - - 906 91 996 996 - - - - - - - - - -

2b.4.9 Emergency Planning Fees - - - - - - 1,243 124 1,367 - 1,367 - - - - - - - - -

2b.4.10 Railtrack Maintenance Fee - - - - - - 220 33 253 253 - - - - - - - - - -

2b.4.11 Spent Fuel Pool O&M - - - - - - 1,742 261 2,003 - 2,003 - - - - - - - - -

2b.4.12 Radwaste Processing Equipment/Services - - - - - - 512 77 589 589 - - - - - - - - - -

2b.4.13 ISFSI Operating Costs - - - - - - 208 31 239 - 239 - - - - - - - - -

2b.4.14 Security Staff Cost - - - - - - 6,642 996 7,638 7,638 - - - - - - - - - 162,881 2b.4.15 DOC Staff Cost - - - - - - 25,464 3,820 29,284 29,284 - - - - - - - - - 420,897 2b.4.16 Utility Staff Cost - - - - - - 38,494 5,774 44,269 44,269 - - - - - - - - - 618,373 2b.4 Subtotal Period 2b Period-Dependent Costs 741 5,194 78 46 - 497 82,373 13,325 102,253 98,643 3,610 - - 6,058 - - - 121,401 1,487 1,202,151 2b.0 TOTAL PERIOD 2b COST 6,410 15,461 447 1,124 14,913 3,029 101,322 24,616 167,322 141,913 25,401 7 122,269 20,889 1,251 - - 6,663,424 300,445 1,202,151 PERIOD 2c - Decontamination Following Wet Fuel Storage Period 2c Direct Decommissioning Activities 2c.1.1 Remove spent fuel racks 444 41 53 79 - 713 - 428 1,757 1,757 - - - 5,402 - - - 484,706 906 -

Disposal of Plant Systems 2c.1.2.1 Cranes/Heavy Loads/Rigging - RCA - 2 0 1 13 - - 3 18 18 - - 103 - - - - 4,184 48 -

2c.1.2.2 Electrical - Contaminated Fuel Pool - 32 0 1 29 1 - 13 77 77 - - 240 6 - - - 10,332 665 -

2c.1.2.3 Electrical - Decontam. Fuel Pool Area - 198 3 13 299 - - 97 610 610 - - 2,457 - - - - 99,783 4,090 -

2c.1.2.4 Fire - RCA - Fuel Pool Area - 7 - 0 7 - - 3 18 18 - - 62 - - - - 2,499 142 -

2c.1.2.5 Fuel Pool Cooling & Cleanup 155 271 12 20 144 125 - 203 930 930 - - 1,179 965 - - - 132,799 7,976 -

2c.1.2.6 Fuel Pool Cooling & Cleanup - Insulated 17 26 1 2 8 11 - 19 84 84 - - 67 83 - - - 10,106 801 -

2c.1.2.7 HVAC Ductwork - Fuel Pool Area - 24 0 2 36 1 - 12 75 75 - - 296 8 - - - 12,731 457 -

2c.1.2.8 HVAC/Chilled Water - RCA Fuel Pool Area - 21 0 1 27 - - 9 59 59 - - 223 - - - - 9,072 394 -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 8 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Disposal of Plant Systems (continued) 2c.1.2.9 Instrument & Service Air-RCA-Fuel Pool - 19 0 1 33 - - 10 62 62 - - 267 - - - - 10,841 356 -

2c.1.2 Totals 173 600 17 41 596 138 - 368 1,933 1,933 - - 4,894 1,062 - - - 292,347 14,928 -

Decontamination of Site Buildings 2c.1.3.1 Reactor (Post Fuel) 667 1,126 118 200 240 1,264 - 1,009 4,624 4,624 - - 1,969 11,766 - - - 1,194,890 34,978 -

2c.1.3 Totals 667 1,126 118 200 240 1,264 - 1,009 4,624 4,624 - - 1,969 11,766 - - - 1,194,890 34,978 -

2c.1.4 Scaffolding in support of decommissioning - 400 3 2 35 1 - 106 547 547 - - 257 13 - - - 12,873 5,641 -

2c.1 Subtotal Period 2c Activity Costs 1,283 2,167 191 322 871 2,115 - 1,910 8,861 8,861 - - 7,120 18,242 - - - 1,984,816 56,453 -

Period 2c Collateral Costs 2c.3.1 Process liquid waste 60 - 40 125 - 626 - 209 1,060 1,060 - - - - 699 - - 99,258 92 -

2c.3.2 Small tool allowance - 45 - - - - - 7 51 51 - - - - - - - - - -

2c.3.3 Decommissioning Equipment Disposition - - 64 48 810 25 - 141 1,088 1,088 - - 6,000 300 - - - 300,000 735 -

2c.3 Subtotal Period 2c Collateral Costs 60 45 104 173 810 651 - 357 2,200 2,200 - - 6,000 300 699 - - 399,258 827 -

Period 2c Period-Dependent Costs 2c.4.1 Decon supplies 115 - - - - - - 29 144 144 - - - - - - - - - -

2c.4.2 Insurance - - - - - - 420 42 461 461 - - - - - - - - - -

2c.4.3 Property taxes - - - - - - 507 51 558 558 - - - - - - - - - -

2c.4.4 Health physics supplies - 322 - - - - - 81 403 403 - - - - - - - - - -

2c.4.5 Heavy equipment rental - 1,024 - - - - - 154 1,178 1,178 - - - - - - - - - -

2c.4.6 Disposal of DAW generated - - 25 14 - 158 - 44 242 242 - - - 1,927 - - - 38,622 473 -

2c.4.7 Plant energy budget - - - - - - 515 77 592 592 - - - - - - - - - -

2c.4.8 NRC Fees - - - - - - 247 25 271 271 - - - - - - - - - -

2c.4.9 Emergency Planning Fees - - - - - - 151 15 166 - 166 - - - - - - - - -

2c.4.10 Railtrack Maintenance Fee - - - - - - 60 9 69 69 - - - - - - - - - -

2c.4.11 Radwaste Processing Equipment/Services - - - - - - 279 42 321 321 - - - - - - - - - -

2c.4.12 ISFSI Operating Costs - - - - - - 57 9 65 - 65 - - - - - - - - -

2c.4.13 Security Staff Cost - - - - - - 1,810 272 2,082 2,082 - - - - - - - - - 44,393 2c.4.14 DOC Staff Cost - - - - - - 4,805 721 5,526 5,526 - - - - - - - - - 78,571 2c.4.15 Utility Staff Cost - - - - - - 10,492 1,574 12,065 12,065 - - - - - - - - - 168,536 2c.4 Subtotal Period 2c Period-Dependent Costs 115 1,346 25 14 - 158 19,342 3,142 24,142 23,911 231 - - 1,927 - - - 38,622 473 291,500 2c.0 TOTAL PERIOD 2c COST 1,458 3,558 320 510 1,681 2,924 19,342 5,410 35,203 34,972 231 - 13,120 20,470 699 - - 2,422,697 57,753 291,500 PERIOD 2e - License Termination Period 2e Direct Decommissioning Activities 2e.1.1 ORISE confirmatory survey - - - - - - 126 38 163 163 - - - - - - - - - -

2e.1.2 Terminate license a 2e.1 Subtotal Period 2e Activity Costs - - - - - - 126 38 163 163 - - - - - - - - - -

Period 2e Additional Costs 2e.2.1 License Termination Survey - - - - - - 4,088 1,226 5,315 5,315 - - - - - - - - 72,073 -

2e.2 Subtotal Period 2e Additional Costs - - - - - - 4,088 1,226 5,315 5,315 - - - - - - - - 72,073 -

Period 2e Collateral Costs 2e.3.1 DOC staff relocation expenses - - - - - - 1,306 196 1,502 1,502 - - - - - - - - - -

2e.3 Subtotal Period 2e Collateral Costs - - - - - - 1,306 196 1,502 1,502 - - - - - - - - - -

Period 2e Period-Dependent Costs 2e.4.1 Insurance - - - - - - 381 38 419 419 - - - - - - - - - -

2e.4.2 Property taxes - - - - - - 505 51 556 556 - - - - - - - - - -

2e.4.3 Health physics supplies - 364 - - - - - 91 455 455 - - - - - - - - - -

2e.4.4 Disposal of DAW generated - - 4 2 - 25 - 7 38 38 - - - 304 - - - 6,083 75 -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 9 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 2e Period-Dependent Costs (continued) 2e.4.5 Plant energy budget - - - - - - 256 38 295 295 - - - - - - - - - -

2e.4.6 NRC Fees - - - - - - 246 25 270 270 - - - - - - - - - -

2e.4.7 Emergency Planning Fees - - - - - - 150 15 165 - 165 - - - - - - - - -

2e.4.8 Railtrack Maintenance Fee - - - - - - 60 9 69 69 - - - - - - - - - -

2e.4.9 ISFSI Operating Costs - - - - - - 57 8 65 - 65 - - - - - - - - -

2e.4.10 Security Staff Cost - - - - - - 990 148 1,138 1,138 - - - - - - - - - 24,269 2e.4.11 DOC Staff Cost - - - - - - 3,649 547 4,197 4,197 - - - - - - - - - 57,149 2e.4.12 Utility Staff Cost - - - - - - 6,129 919 7,048 7,048 - - - - - - - - - 83,374 2e.4 Subtotal Period 2e Period-Dependent Costs - 364 4 2 - 25 12,423 1,897 14,715 14,485 230 - - 304 - - - 6,083 75 164,791 2e.0 TOTAL PERIOD 2e COST - 364 4 2 - 25 17,943 3,357 21,695 21,465 230 - - 304 - - - 6,083 72,148 164,791 PERIOD 2 TOTALS 8,968 37,858 7,928 5,473 36,267 28,789 188,236 64,108 377,627 339,389 37,928 310 290,509 86,599 7,244 804 - 20,082,110 656,273 2,230,269 PERIOD 3b - Site Restoration Period 3b Direct Decommissioning Activities Demolition of Remaining Site Buildings 3b.1.1.1 Reactor Building - 3,506 - - - - - 526 4,032 - - 4,032 - - - - - - 52,969 -

3b.1.1.2 Condensate Tanks Foundation - 14 - - - - - 2 16 - - 16 - - - - - - 219 -

3b.1.1.3 Discharge Retention Basin - 6 - - - - - 1 7 - - 7 - - - - - - 110 -

3b.1.1.4 HPCI Room - 30 - - - - - 5 35 - - 35 - - - - - - 401 -

3b.1.1.5 Hot Shop - 15 - - - - - 2 18 - - 18 - - - - - - 298 -

3b.1.1.6 Hydrogen & Oxygen Storage - 1 - - - - - 0 1 - - 1 - - - - - - 21 -

3b.1.1.7 LLRW Storage & Shipping - 102 - - - - - 15 117 - - 117 - - - - - - 1,794 -

3b.1.1.8 MSIV - 3 - - - - - 0 3 - - 3 - - - - - - 59 -

3b.1.1.9 Offgas Stack - 166 - - - - - 25 191 - - 191 - - - - - - 2,668 -

3b.1.1.10 Offgas Storage & Compressor - 61 - - - - - 9 71 - - 71 - - - - - - 963 -

3b.1.1.11 Radwaste - 382 - - - - - 57 439 - - 439 - - - - - - 5,795 -

3b.1.1.12 Recombiner - 180 - - - - - 27 207 - - 207 - - - - - - 2,490 -

3b.1.1.13 Security Barrier - 258 - - - - - 39 297 - - 297 - - - - - - 4,083 -

3b.1.1.14 Tank Farm - 7 - - - - - 1 8 - - 8 - - - - - - 121 -

3b.1.1.15 Turbine - 1,755 - - - - - 263 2,019 - - 2,019 - - - - - - 30,441 -

3b.1.1.16 Turbine Building Addition - 49 - - - - - 7 56 - - 56 - - - - - - 971 -

3b.1.1.17 Turbine Pedestal - 288 - - - - - 43 332 - - 332 - - - - - - 3,762 -

3b.1.1 Totals - 6,826 - - - - - 1,024 7,850 - - 7,850 - - - - - - 107,166 -

Site Closeout Activities 3b.1.2 Remove Rubble - 1,134 - - - - - 170 1,304 - - 1,304 - - - - - - 1,996 -

3b.1.3 Grade & landscape site - 566 - - - - - 85 651 - - 651 - - - - - - 1,841 -

3b.1.4 Final report to NRC - - - - - - 147 22 169 169 - - - - - - - - - 1,560 3b.1 Subtotal Period 3b Activity Costs - 8,526 - - - - 147 1,301 9,974 169 - 9,805 - - - - - - 111,003 1,560 Period 3b Additional Costs 3b.2.1 Concrete Crushing - 210 - 6 - - - 32 248 - - 248 - - - - - - 1,402 -

3b.2 Subtotal Period 3b Additional Costs - 210 - 6 - - - 32 248 - - 248 - - - - - - 1,402 -

Period 3b Collateral Costs 3b.3.1 Small tool allowance - 77 - - - - - 11 88 - - 88 - - - - - - - -

3b.3 Subtotal Period 3b Collateral Costs - 77 - - - - - 11 88 - - 88 - - - - - - - -

Period 3b Period-Dependent Costs 3b.4.1 Insurance - - - - - - 880 88 968 - 968 - - - - - - - - -

3b.4.2 Property taxes - - - - - - 1,168 117 1,284 - 1,284 - - - - - - - - -

3b.4.3 Heavy equipment rental - 3,233 - - - - - 485 3,718 - - 3,718 - - - - - - - -

TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 10 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours Period 3b Period-Dependent Costs (continued) 3b.4.4 Plant energy budget - - - - - - 296 44 341 - 102 238 - - - - - - - -

3b.4.5 NRC ISFSI Fees - - - - - - 406 41 446 - 446 - - - - - - - - -

3b.4.6 Emergency Planning Fees - - - - - - 347 35 381 - 381 - - - - - - - - -

3b.4.7 Railtrack Maintenance Fee - - - - - - 138 21 159 159 - - - - - - - - - -

3b.4.8 ISFSI Operating Costs - - - - - - 131 20 150 - 150 - - - - - - - - -

3b.4.9 Security Staff Cost - - - - - - 2,286 343 2,629 - 1,788 841 - - - - - - - 56,066 3b.4.10 DOC Staff Cost - - - - - - 9,197 1,380 10,576 - - 10,576 - - - - - - - 142,877 3b.4.11 Utility Staff Cost - - - - - - 4,914 737 5,651 - 4,803 848 - - - - - - - 66,917 3b.4 Subtotal Period 3b Period-Dependent Costs - 3,233 - - - - 19,762 3,309 26,305 159 9,924 16,222 - - - - - - - 265,860 3b.0 TOTAL PERIOD 3b COST - 12,046 - 6 - - 19,909 4,654 36,615 328 9,924 26,363 - - - - - - 112,405 267,420 PERIOD 3c - Fuel Storage Operations/Shipping Period 3c Direct Decommissioning Activities Period 3c Collateral Costs 3c.3.1 Spent Fuel Capital and Transfer - - - - - - 4,000 600 4,600 - 4,600 - - - - - - - - -

3c.3 Subtotal Period 3c Collateral Costs - - - - - - 4,000 600 4,600 - 4,600 - - - - - - - - -

Period 3c Period-Dependent Costs 3c.4.1 Insurance - - - - - - 10,409 1,041 11,450 - 11,450 - - - - - - - - -

3c.4.2 Property taxes - - - - - - 13,806 1,381 15,187 - 15,187 - - - - - - - - -

3c.4.3 Plant energy budget - - - - - - 1,051 158 1,208 - 1,208 - - - - - - - - -

3c.4.4 NRC ISFSI Fees - - - - - - 4,799 480 5,279 - 5,279 - - - - - - - - -

3c.4.5 Emergency Planning Fees - - - - - - 4,099 410 4,508 - 4,508 - - - - - - - - -

3c.4.6 Railtrack Maintenance Fee - - - - - - 1,633 245 1,878 - 1,878 - - - - - - - - -

3c.4.7 ISFSI Operating Costs - - - - - - 1,544 232 1,776 - 1,776 - - - - - - - - -

3c.4.8 Security Staff Cost - - - - - - 18,313 2,747 21,060 - 21,060 - - - - - - - - 449,100 3c.4.9 Utility Staff Cost - - - - - - 49,109 7,366 56,475 - 56,475 - - - - - - - - 705,729 3c.4 Subtotal Period 3c Period-Dependent Costs - - - - - - 104,764 14,059 118,823 - 118,823 - - - - - - - - 1,154,829 3c.0 TOTAL PERIOD 3c COST - - - - - - 108,764 14,659 123,423 - 123,423 - - - - - - - - 1,154,829 PERIOD 3d - GTCC shipping Period 3d Direct Decommissioning Activities Nuclear Steam Supply System Removal 3d.1.1.1 Vessel & Internals GTCC Disposal - - 300 - - 7,353 - 1,133 8,786 8,786 - - - - - - 408 83,570 - -

3d.1.1 Totals - - 300 - - 7,353 - 1,133 8,786 8,786 - - - - - - 408 83,570 - -

3d.1 Subtotal Period 3d Activity Costs - - 300 - - 7,353 - 1,133 8,786 8,786 - - - - - - 408 83,570 - -

Period 3d Period-Dependent Costs 3d.4.1 Insurance - - - - - - 42 4 46 - 46 - - - - - - - - -

3d.4.2 Property taxes - - - - - - 55 6 61 - 61 - - - - - - - - -

3d.4.3 Plant energy budget - - - - - - 4 1 5 - 5 - - - - - - - - -

3d.4.4 NRC ISFSI Fees - - - - - - 19 2 21 - 21 - - - - - - - - -

3d.4.5 Emergency Planning Fees - - - - - - 16 2 18 - 18 - - - - - - - - -

3d.4.6 Railtrack Maintenance Fee - - - - - - 7 1 8 - 8 - - - - - - - - -

3d.4.7 ISFSI Operating Costs - - - - - - 6 1 7 - 7 - - - - - - - - -

3d.4.8 Security Staff Cost - - - - - - 73 11 84 - 84 - - - - - - - - 1,800 3d.4.9 Utility Staff Cost - - - - - - 197 30 226 - 226 - - - - - - - - 2,829 3d.4 Subtotal Period 3d Period-Dependent Costs - - - - - - 420 56 476 - 476 - - - - - - - - 4,629 3d.0 TOTAL PERIOD 3d COST - - 300 - - 7,353 420 1,189 9,263 8,786 476 - - - - - 408 83,570 - 4,629 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 11 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours PERIOD 3e - ISFSI Decontamination Period 3e Direct Decommissioning Activities Period 3e Additional Costs 3e.2.1 ISFSI License Termination - 461 8 48 - 298 1,393 407 2,614 - 2,614 - - 3,266 - - - 330,923 7,438 2,560 3e.2 Subtotal Period 3e Additional Costs - 461 8 48 - 298 1,393 407 2,614 - 2,614 - - 3,266 - - - 330,923 7,438 2,560 Period 3e Collateral Costs 3e.3.1 Small tool allowance - 4 - - - - - 1 4 - 4 - - - - - - - - -

3e.3 Subtotal Period 3e Collateral Costs - 4 - - - - - 1 4 - 4 - - - - - - - - -

Period 3e Period-Dependent Costs 3e.4.1 Insurance - - - - - - 168 17 185 - 185 - - - - - - - - -

3e.4.2 Property taxes - - - - - - 223 22 246 - 246 - - - - - - - - -

3e.4.3 Heavy equipment rental - 181 - - - - - 27 208 - 208 - - - - - - - - -

3e.4.4 Plant energy budget - - - - - - 57 8 65 - 65 - - - - - - - - -

3e.4.5 NRC ISFSI Fees - - - - - - 78 8 85 - 85 - - - - - - - - -

3e.4.6 Emergency Planning Fees - - - - - - 66 7 73 - 73 - - - - - - - - -

3e.4.7 Security Staff Cost - - - - - - 148 22 170 - 170 - - - - - - - - 3,630 3e.4.8 Utility Staff Cost - - - - - - 290 43 333 - 333 - - - - - - - - 2,420 3e.4 Subtotal Period 3e Period-Dependent Costs - 181 - - - - 1,030 155 1,365 - 1,365 - - - - - - - - 6,050 3e.0 TOTAL PERIOD 3e COST - 645 8 48 - 298 2,422 562 3,983 - 3,983 - - 3,266 - - - 330,923 7,438 8,610 PERIOD 3f - ISFSI Site Restoration Period 3f Direct Decommissioning Activities Period 3f Additional Costs 3f.2.1 ISFSI Demolition & Site Restoration - 558 - - - - 41 90 689 - 689 - - - - - - - 1,934 160 3f.2 Subtotal Period 3f Additional Costs - 558 - - - - 41 90 689 - 689 - - - - - - - 1,934 160 Period 3f Collateral Costs 3f.3.1 Small tool allowance - 1 - - - - - 0 1 - 1 - - - - - - - - -

3f.3 Subtotal Period 3f Collateral Costs - 1 - - - - - 0 1 - 1 - - - - - - - - -

Period 3f Period-Dependent Costs 3f.4.1 Insurance - - - - - - - - - - - - - - - - - - - -

3f.4.2 Property taxes - - - - - - 113 11 124 - 124 - - - - - - - - -

3f.4.3 Heavy equipment rental - 62 - - - - - 9 71 - 71 - - - - - - - - -

3f.4.4 Plant energy budget - - - - - - 29 4 33 - 33 - - - - - - - - -

3f.4.5 Security Staff Cost - - - - - - 75 11 86 - 86 - - - - - - - - 1,830 3f.4.6 Utility Staff Cost - - - - - - 146 22 168 - 168 - - - - - - - - 1,220 3f.4 Subtotal Period 3f Period-Dependent Costs - 62 - - - - 362 58 482 - 482 - - - - - - - - 3,050 3f.0 TOTAL PERIOD 3f COST - 622 - - - - 402 148 1,172 - 1,172 - - - - - - - 1,934 3,210 PERIOD 3 TOTALS - 13,313 308 54 - 7,651 131,917 21,212 174,455 9,114 138,978 26,363 - 3,266 - - 408 414,493 121,777 1,438,697 TOTAL COST TO DECOMMISSION 11,002 52,862 8,293 5,664 36,289 37,191 411,820 100,000 663,122 446,819 188,890 27,414 290,509 90,489 7,970 804 408 20,621,360 779,328 4,594,298 TLG Services, Inc.

Monticello Nuclear Generating Plant Document X01-1526-003, Rev. 0 Decommissioning Cost Analysis Appendix C, Page 12 of 12 Table C Monticello Nuclear Generating Plant DECON Decommissioning Cost Estimate (Thousands of 2005 Dollars)

Costs run: Wed, Aug 3, 2005 at 10:30:20 Off-Site LLRW NRC Spent Fuel Site Processed Burial Volumes Burial / Utility and Activity DECCER Version 2004.09.13 Decon Removal Packaging Transport Processing Disposal Other Total Total Lic. Term. Management Restoration Volume Class A Class B Class C GTCC Processed Craft Contractor Index Activity Description Cost Cost Costs Costs Costs Costs Costs Contingency Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet Wt., Lbs. Manhours Manhours TOTAL COST TO DECOMMISSION WITH 17.76% CONTINGENCY: $663,122 thousands of 2005 dollars TOTAL NRC LICENSE TERMINATION COST IS 67.38% OR: $446,819 thousands of 2005 dollars SPENT FUEL MANAGEMENT COST IS 28.48% OR: $188,889 thousands of 2005 dollars NON-NUCLEAR DEMOLITION COST IS 4.13% OR: $27,414 thousands of 2005 dollars TOTAL RADWASTE VOLUME BURIED (without GTCC): 99,263 Cubic Feet TOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED: 408 Cubic Feet TOTAL SCRAP METAL REMOVED: 14,961 Tons TOTAL CRAFT LABOR REQUIREMENTS: 779,328 Man-hours End Notes:

n/a - indicates that this activity not charged as decommissioning expense.

a - indicates that this activity performed by decommissioning staff.

0 - indicates that this value is less than 0.5 but is non-zero.

a cell containing " - " indicates a zero value TLG Services, Inc.