ML051100330

1 of PGE-1061. Trojan Nuclear Plant Defueled Safety Analysis Report and License Termination Plan (PGE-1078) (A.K.A.. Tnp Decommissioning Plan)

ML051100330
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/31/2005
From:	Quennoz S Portland General Electric Co
To:	Document Control Desk, NRC/FSME
References
PGE-1078, VPN-014-2005 PGE-1061, Rev 21
Download: ML051100330 (24)

Text

1/oN Portland General Electric Company Trojan Nuclear Plant March 31, 2005 71760 Columbia River Hwy Rainier, OR 97048 VPN-014-2005 (503) 556-3713 Trojan Nuclear Plant Docket 50-344 License NPF-1 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Revision 21 of PGE-1061. "Trojan Nuclear Plant Defueled Safety Analysis Report and License Termination Plan (PGE-1078)" (a.k.a.. TNP Decommissioning Plan)

The enclosure to this letter provides Revision 21 to Portland General Electric Company's PGE-1061, "Trojan Nuclear Plant Defueled Safety Analysis Report and License Termination Plan (PGE-1078)" (a.k.a., TNP Decommissioning Plan). The attachment to this letter provides a description of the changes incorporated into Revision 21. Revised portions of the TNP Decommissioning Plan are denoted by sidebars.

If you have any questions concerning this submittal, please contact Mr. Jerry D. Reid, of my staff, at (503) 556-7013.

Sincerely, Stephen M. Quennoz Vice President, Generation Attachment Enclosure c: Director, NRC, Region IV, DNMS J. T. Buckley, NRC, NMSS, DWM D. Stewart-Smith, ODOE A. Bless, ODOE 0 0-YSIS 0 I -

Connecting People, Power and Possibilities

Attachment to VPN-014-2005 March 31, 2005 Page 1 of 1 Description of Changes The following provides a description of the changes incorporated into PGE-1061, "Trojan Nuclear Plant Defueled Safety Analysis Report and License Termination Plan (PGE-1078)"

(a.k.a., TNP Decomnmissioning Plan), Revision 21. The changes were evaluated and determined to not require prior NRC approval pursuant to 10 CFR 50.59. The changes are listed under their corresponding Licensing Document Change Request (LDCR) number.

LDCR 2005-001 Section 3.1.3.4.2 was updated to address the use of default DCGLs rather than developing reduced DCGLs as previously described.

LDCR 2005-006 Chapter 5 and Tables 5-1 through 5-6 were revised to provide the required annual decommissioning cost estimate update.

PGE-1061, "TNP Decommissioning Plan" Revision 21 Pages to your Controlled Copy of PGE-1061, "TNP Decommissioning Plan," are to be replaced as indicated below:

Remove Insert Volume 1 of 2:

Table of Contents Pages xiv and xv Pages xiv and xv Section 3 Pages 3-15 through 3-19 Pages 3-15 through 3-19 Section 5 Pages 5-1 through 5-8 Pages 5-1 through 5-8 Tables 5-1 through 5-6 Tables 5-1 through 5-6 1 of 1

T7NP DECOMMISSIONING PLAN LIST OF EFFECTIVE PAGES Section/Page Revised Date Revision Number Title Page March 2001 Revision 9 Pages i through iii September 2003 Revision 18 Pages iv through xiii March 2004 Revision 19 Pages xiv through xv March 2005 Revision 21 Section 1 Page 1-1 March 2004 Revision 19 Pages 1-2 and 1-3 September 2003 Revision 18 Page 1-4 January 2005 Revision 20 Pages 1-5 through 1-10 September 2003 Revision 18 Pages 1-11 through 1-13 January 2005 Revision 20 Pages 1-14 March 2004 Revision 19 Pages 1-15 and 1-16 September 2003 Revision 18 Pages 1-17 and 1-18 March 2004 Revision 19 Page 1-19 and 1-20 September 2003 Revision 18 Page 1-21 March 2004 Revision 19 Page 1-22 September 2003 Revision 18 Table 1-1, Pages 1 through 17 March 2004 Revision 19 Section 2 Pages 2-1 through 2-3 September 2003 Revision 18 Page 2-4 March 2004 Revision 19 Pages 2-5 through 2-23 September 2003 Revision 18 Pages 2-24 through 2-29 March 2004 Revision 19 Pages 2-30 and 2-31 September 2003 Revision 18 Pages 2-32 through 2-34 March 2004 Revision 19 Table 2-1, Pages 1 through 3 September 2003 Revision 18 Table 2-2, Pages 1 through 8 September 2003 Revision 18 Table 2-3 March 2004 Revision 19 Table 2-4, Pages 1 through 3 September 2003 Revision 18 Figure 2-1 September 2003 Revision 18 Figure 2-la January 2005 Revision 20 Figures 2-lb through 2-9 September 2003 Revision 18 Figure 2-10 March 2004 Revision 19 Section 3 Pages 3-1 through 3-14 September 2003 Revision 18 Pages 3-15 through 3-19 March 2005 Revision 21 Pages 3-20 through 3-27 March 2004 Revision 19 Pages 3-28 and 3-29 January 2005 Revision 20 Pages 3-30 through 3-43 March 2004 Revision 19 Appendix 3-1, Pages 1 through 5 September 2003 Revision 18 X1V Revision 21

TNP DECOMMISSIONING PLAN LIST OF EFFECTIVE PAGES (Continued)

Section/Page Revised Date Revision Number Tables 3-1 through 3-4 September 2003 Revision 18 Table 3-5, Pages 1 through 8 September 2003 Revision 18 Table 3-6, Pages 1 and 2 September 2003 Revision 18 Table 3-7 September 2003 Revision 18 Figure 3-1 March 2004 Revision 19 Figures 3-2 through 3-5 September 2003 Revision 18 Figure 3-6 March 2004 Revision 19 Section 4 Pages 4-1 and 4-2 January 2005 Revision 20 Pages 4-3 through 4-59 September 2003 Revision 18 Appendix 4-1, Pages 1 through 3 September 2003 Revision 18 Appendix 4-2, Pages 1 through 6 September 2003 Revision 18 Appendix 4-3, Pages 1 and 2 September 2003 Revision 18 Tables 4-1 through 4-3 September 2003 Revision 18 Table 4-4, Pages 1 through 11 September 2003 Revision 18 Tables 4-5 through 4-9 September 2003 Revision 18 Section 5 Pages 5-1 through 5-8 March 2005 Revision 21 Tables 5-1 through 5-6 March 2005 Revision 21 Section 6 Pages 6-1 through 6-3 September 2003 Revision 18 Section 7 Pages 7-1 through 7-3 September 2003 Revision 18 Section 8 Pages 8-1 through 8-4 September 2003 Revision 18 List of Abbreviations and Acronyms September 2003 Revision 18 Index September 2003 Revision 18 Addendum September 2003 Revision 18 Appendix A September 2003 Revision 18 Appendix B September 2003 Revision 18 xv Revision 21

TNP DECOMMISSIONING PLAN The analytical results for each monitoring well were compared with background groundwater quality to determine if any radionuclides are present above background levels. The identification of groundwater moving toward the buried valley and the tritium in MW-8 met the requirements of the Trojan license condition to implement the second phase of the groundwater monitoring program.

Phase II The scope of the Phase II groundwater monitoring program was based on the Phase I results.

Phase II included the installation of additional monitoring wells in the buried valley (to the west of Trojan Hill).

Seven additional wells were planned and drilled to support Phase II activities. The wells were installed using the same procedures as described in the Phase I description above. Two groups of nested wells were installed in the buried valley just west of the Trojan access road. The nested wells consisted of two wells, a shallow well approximately 25 feet deep and a deep well approximately 55 feet deep. The intent of the nested wells is for the shallow well to target the top of the groundwater table and the deep well to reach the bedrock. Two wells were installed in the upper parking lot on the north and south end. A seventh well was installed on the east side of the Industrial Area near the area where the diesel fuel oil tanks were located. The well in the Industrial Area was drilled to approximately 22 feet to provide down gradient sampling for Phase I well MW-8. Sampling and analysis methods were repeated for Phase II wells. Phase I wells were also resampled to ensure the time period between sampling Phase I wells and Phase II wells would not lead to errors in radionuclide concentration determination due to the time elapsed between the Phase I and Phase II activities. A total of 17 wells were installed at Trojan.

Figure 3-2 shows the approximate locations of the wells.

Water samples collected during Phase II sampling (with the exception of samples analyzed for Tritium) were acidified to ensure that radioactivity would not plate out during the period of storage and transport of the samples for analysis. The Trojan groundwater sampling procedure provides the guidance for sample collection and treatment. The data collected during all phases of the study were combined to provide an overall assessment of the potential dose to a member of the public from residual radioactivity in the Trojan groundwater. If it had been required, PGE planned to subtract the potential dose from groundwater radioactivity from the allowable annual dose limit (25 mrem/year), and the default Derived Concentraiton Guideline Levels (DCGLs) would have been reduced by the fractional dose contribution from groundwater and used as site-specific DCGLs.

This reduction of the DCGLs was determined not to be necessary even though low concentrations of tritium had been detected in monitoring well MW-8 and in excavated site areas. This is because the groundwater tritium concentrations and potential doses are so low that reductions of the default soild DCGLs were not necessary to keep the total annual dose well below the 25 mrem unrestricted release criterion. On this basis, PGE adopted the default DCGLs for use as the Troja site-specific soil DCGLs.

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TNP DECOMMISSIONING PLAN 3.1.3.4.3 Surface Water Survey Surface water was sampled from indicator sites on PGE property surrounding TNP. A 1 gallon sample was obtained from each site for gamma and 9OSr analysis and a 60 ml sample for tritium analysis. The water samples were analyzed for gamma emitters using a gamma spectroscopy system located onsite. Water samples were analyzed for tritium in the onsite counting laboratory. Selected samples were analyzed for 90Sr.

To determine background, water samples were collected from four locations around TNP. The locations included:

1. Fishhawk Lake (approximately 18 miles west of TNP containment);

2. Ponds at the intersection of Goble and Bishop Roads (approximately 3 miles southwest of TNP containment);

3. Kress Lake (approximately 1 mile east-northeast of TNP containment); and

4. Deer Island ponds (approximately 7 miles south of TNP containment).

Analyses for gamma emitters and tritium were completed on the samples. No gamma emitters other than naturally occurring radionuclides were identified in the samples. Tritium values were less than detectable. The four samples analyzed for 9OSr were less than detectable. Minimum detectable activity (MDA) for 13'Cs, tritium, and 90Sr was approximately 4, 450, and 0.3 pCi/l, respectively.

For the survey of unaffected water areas, samples were collected from random locations in Whistling Swan and Reflection Lakes located on PGE-owned property surrounding the TNP site.

No nonnaturally occurring radionuclides were detected in the samples by gamma spectrometry.

Neither tritium nor 9OSr was detected in the samples.

For the biased survey, samples were taken from the potentially affected Recreation Lake, also located on PGE-owned property surrounding the TNP site. No nonnaturally occurring radionuclides were detected in the samples. MDAs for the biased and unbiased survey analyses were the same.

3.1.3.4.4 Bottom Sediment Survey Bottom sediment samples were taken from PGE property around TNP. Approximately 1 liter of sediment was obtained at each sampling site. The sediment samples were dried and analyzed for gamma emitters using a gamma spectroscopy system located onsite. Selected sediment samples were analyzed for 90Sr by TMA/Eberline.

Specific isotopic background sediment samples were not collected. Instead, soil background results were used as sediment background. Background soil samples were analyzed as part of the site characterization effort, and the mean 137Cs concentration was 0.49 pCi/g. A comparison of the 1 37CS concentration in preoperational sediment samples to the background soil samples 3-16 Revision 21

TNP DECOMMISSIONING PLAN showed a high correlation with the sediment mean equal to 0.51 pCi/g and the soil mean equal to 0.49 pCi/g.

In conducting the survey of unaffected sediment areas, samples were taken from Whistling Swan and Reflection Lakes. The mean value for 137 CS was 0.36 pCi/g with a standard deviation of 0.22 pCi/g and a range of 0.02 to 0.86 pCi/g. The unaffected area sediment samples contain 7

137 Cs at levels below the release value for 13Cs. 90Sr content of the two sediment samples sent to 90 TMA/Eberline were 0.05 and 0.03 pCi/g. The lower level of detectability for the Sr analysis was 0.02 pCi/g. These results are within thepreoperational range of 90Sr which was from 0.01 to 0.44 pCi/g with a mean of 0.08 pCi/g. The 9 Sr content of the sediment samples was also below the corresponding screening release level.

For the biased sediment survey sample population, samples were taken from the berm and main areas of Recreation Lake. Results of the analyses indicate a mean of 0.28 pCi/g with a standard deviation of 0.37 pCi/g and a range of 0.04 to 1.12 pCi/g. The affected area samples contain 137CS in amounts below the release level. No other gamma emitters were detected.

3.1.3.4.5 Pavement Survey Pavement scans and sampling were performed. Pavement was scanned for beta contamination.

In areas where there was interference from the RWST, a 1 ft2 sample was collected and analyzed using a gamma spectroscopy system located onsite.

No specific background pavement locations were monitored for this survey. Sample locations located in the TNP park and recreational areas were used to estimate background levels. Since these areas were unaffected by TNP operation, the survey data for these locations was determined to be an acceptable estimate of background levels of radioactive material in pavement. The mean gross beta reading was 610 dpm/100 cm2 with a standard deviation of 94 dpm/100 cm2 and a range of 456 to 764 dpm/100 cm2 .

For the survey of unaffected pavement areas, randomly selected 100 ft2 sections of pavement in other areas of the TNP site which were unaffected by operations were scanned with an ESP-2 and BP-100 detector. The mean value was 657 dpm/100 cm2 with a standard deviation of 74 dpm/100 cm2. The range of measurements was from 542 to 788 dpm/100 cm2 .

For the biased pavement survey, the affected areas consisted of pavement around the tank farm and its drainage to the west, pavement around the oily water separator, and the paved equipment laydown area around the cooling tower. Pavement samples were taken from affected areas with at least two samples from each affected area. The only detectable nonnaturally occurring radionuclide found in the pavement samples was 13 7CS in low concentrations. The results of the biased samples exhibited a mean of 0.16 pCi/g with a standard deviation of 0.40 pCi/g and a range of 0.019 to 1.5 pCi/g. 137 CS content of the biased pavement samples was similar to that found in background and indicator soil samples obtained for site characterization. One sample, taken from the curb at the southeast corner of the circulating water pump pit area, had the highest 13 7CS concentration of 1.5 pCi/g. For comparison, 3-17 Revision 21

TNP DECOMMISSIONING PLAN 2

conservatively assuming the 13 7 Cs was from the top 1 cm of the concrete and covered a 100 cm 2

area, then the calculated contamination level would be 799 dpm/100 cm .

3.1.3.4.6 Exposure Rate Survey Exposure rates were measured at locations where affected and unaffected site characterization indicator soil samples had been collected. The measurements were made with a Reuter-Stokes pressurized ion chamber instrument positioned 1 meter above the sample site.

Data for exposure rate background was collected during preoperational surveys at TNP using a high pressure ion chamber, the same type of instrument used during the site characterization survey. The preoperational mean reading was 7.1 1.Rfhr with a standard deviation of 1.0 VR/hr and a range of 5.6 to 9.4 piR/hr. The survey locations coincide with the Radiological Environmental Monitoring Program locations.

For the exposure rate survey of unaffected areas, surveys were taken at the unaffected soil sampling locations. Exposure rates ranged from 5.2 to 9.0 plRlhr at the unaffected area locations.

The mean exposure rate was 6.4 pRlhr. Data compared favorably with preoperational data, indicating no effect from TNP operation.

For the biased survey, exposure rates were measured at affected area soil sample sites where it was determined that radioactive content of surrounding structures would not influence the measurements. Measurements made at two locations were influenced by the RWST and were not included. Exposure rates at four locations were not measured because of radiation levels from the RWST. Exposure rates at two locations were not measured because of radiation levels from the Low-Level Radioactive Waste Storage and Fuel Buildings. The values at the remaining locations ranged from 6.0 to 8.3 pR/hr with a mean of 6.8 jtR/hr. This is consistent with background data.

3.1.4 SITE CHARACTERIZATION QUALITY ASSURANCE TNP site characterization activities are conducted under the auspices of PGE-8010, "Trojan Nuclear Plant Quality Assurance Program," as incorporated into Section 7 of this TNP Decommissioning Plan. TNP's Nuclear Quality Assurance Program ensures that survey activities are performed in a manner that assures the results are accurate and that uncertainties have been adequately considered. Surveys are performed by trained individuals who follow standard written procedures and are using properly calibrated and source-checked instruments.

The custody of samples is tracked from collection to analysis, with every step of the process documented in a way that can be audited. In addition, QA practices ensure that offsite laboratory analyses are conducted using approved Radiological Environmental Monitoring Program (Reference 3-12) procedures. Finally, characterization data, as well as calibration and source check documentation, are maintained as quality-related decommissioning records.

3.

1.5 CONCLUSION

In summary, several general overall conclusions regarding the site characterization survey can be made about the four sections: structures, systems, activation, and environment. First, plant 3-18 Revision 21

7NP DECOMMISSIONING PLAN structures contain radioactive material that will require removal prior to license termination. The contamination consists of radioactive material incorporated (fixed) into the upper layer of concrete/block and deposited on the surface (loose). Although the levels of radioactivity are generally low, structures within what was the RCA in 1993, including building surfaces and piping, are considered potentially contaminated and will require, as a minimum, a wipe or wash down.

Second, some plant systems contain deposited radioactive material due to plant operation. The majority of the radioactive material is contained in RCS piping and systems directly connected to the RCS (e.g., CVCS, safety injection system, and residual heat removal [RHR] system).

Although some systems contain contamination, the systems are not expected to be greater than Class A waste.

Third, activated components contain the vast majority of the radioactive material not contained in fuel. Most activity is primarily concentrated in the vessel internals and shield wall. The reactor vessel lower internals contain the highest activity. Although radionuclide distributions are provided for the reactor vessel and vessel internals, they will have been removed before final survey data collection begins in the Containment. Neutron activation products have been found in samples of containment concrete in various structures, including the reactor vessel shield wall, steam generator missile shields, and the containment wall itself. Remediation of the activated components will be required to meet the site release criteria and facilitate license termination.

Fourth, and finally, the environmental survey results indicated that no radioactive material requiring remediation is present in the various materials sampled, and that no radioactivity requiring remediation has been spread to the environment outside the TNP industrial area. The final survey may require additional background data for a number of the sample media.

Preliminary results indicate no radioactivity at TNP has been spread to the environment inside the industrial area in quantities requiring remediation.

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TNP DECOMMISSIONING PLAN

5. UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS In accordance with Paragraphs (a)(4) and (a)(9)(ii)(F) of 10 CFR 50.82 (Reference 5-1), and consistent with the guidance of Regulatory Guide 1.179 MReference 5-2), the TNP-specific cost estimate and funding plan as incorporated into this section provides:

1. An updated estimate of total and remaining TNP decommissioning costs;

2. A comparison of the estimated costs with present funds set aside for decommissioning; and

3. The plan for assuring the availability of adequate funds for completion of decommissioning and release of the TNP site for unrestricted use.

5.1 DECOMMISSIONING COST ESTIMATE This section provides the results of and basis for a site-specific cost estimate for the decommissioning of TNP. Incorporated into this cost estimate are costs of activities involved in radiological decommissioning necessary for termination of TNP's Part 50 license, as well as expenditures necessary to complete nonradiological site restoration activities. The costs of removal and disposal of nonradioactive structures and materials beyond that necessary for license termination have been identified separately from radiological decommissioning costs.

Also separately identified are costs incurred for construction of the Trojan Independent Spent Fuel Storage Installation (ISFSI), and cost projections and funding requirements for ISFSI storage operations and maintenance (O&M) until possession and title of the irradiated fuel is transferred to DOE for ultimate disposal. ISFSI decommissioning costs and associated funding and financial assurance requirements are provided in PGE-1069, Trojan ISFSI Safety Analysis Report.

5.1.1 COST ESTIMATE RESULTS Summarizing the results of the TNP cost estimate, Table 5-1 provides estimates of total decommissioning costs as well as decommissioning costs that remain as of January 1, 2005. As indicated in Table 5-1, the costs (in 1997 dollars) for the selected decommissioning alternative are estimated to total approximately $211,670,000 for radiological decommissioning activities, approximately $40,228,000 for nonradiological decommissioning activities (site restoration), and approximately $169,951,000 for ISFSI construction and storage O&M (hereafter referred to as spent fuel management). Costs associated with securing and maintaining decommissioning financial assurance and bridging funds are projected to total approximately $16,000. A detailed schedule of TNP's decommissioning and spent fuel management costs, totaling approximately

$421,865,000 of decommissioning fund-related expenditures, is provided in Table 5-2 and described in Section 5.1.2.

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TNP DECOMMISSIONING PLAN 5.1.2 COST ESTIMATE DESCRIPTION The initial Decommissioning Plan decommissioning cost estimate was based largely on the TNP-specific cost estimate performed for PGE by TLG Services, Inc. in May 1994. The methodology used to develop the cost estimate followed the approach presented in AIF/NESP-036, "Guidelines to Producing Decommissioning Cost Estimates" (Reference 5-3) and the DOE "Decommissioning Handbook" (Reference 5-4). These guidance documents utilize a unit cost factor method for estimating decommissioning activity costs. Unit cost factors incorporate site-specific considerations whenever practicable. Using plant drawings and inventory documents, quantities and volumes of the equipment and material to be removed during decommissioning were estimated. Unit cost factors were applied to the volumes and quantities to estimate the "activity dependent" costs. "Period dependent" costs were determined from a critical path schedule based on the removal activity duration.

At the end of each year, PGE updates the TNP decommissioning cost estimate based on actual decommissioning progress and with an estimate of remaining costs based on the best available information about the remaining scope of the decommissioning effort. The update generally results in changes to the timing of fund expenditures, and may reflect changes to the scope of major projects. The cost estimate reflects updated staffing requirements and work/activity schedules, remaining scheduled decommissioning equipment removal efforts, adjustments for current radioactive waste disposal volumes and costs, and an update of the estimate to disposition non-radiological hazards.

The results of PGE's decommissioning cost estimate have been incorporated into Table 5-2, which provides a comprehensive expenditure schedule for the decommissioning of TNP. This table incorporates an annual breakdown of projected costs associated with radiological and nonradiological decommissioning, spent fuel management, and decommissioning expenditure financing activities. The decommissioning cost estimate expenditure schedule contained in Table 5-2 is described in the remainder of this section.

5.1.2.1 Radiological Decommissioning Costs The cost schedule for radiological decommissioning activities is incorporated into Table 5-2, which reflects the results of the decommissioning cost estimate for TNP. Consistent with current NRC policy, the TNP decommissioning cost estimate considers radiological decommissioning costs to be only those costs associated with normal decommissioning activities necessary for termination of the Part 50 license and release of the site for unrestricted use. The decommissioning cost estimate does not include in radiological decommissioning costs those costs associated with spent fuel management or the disposal of nonradioactive structures and materials beyond that necessary to terminate TNP's Part 50 license.

Radiological decommissioning activity costs are separately identified in Table 5-2. Burial costs were derived from PGE modeling and analysis of low-level radioactive waste disposal costs as updated in early 1999, which more conservatively reflect projected burial rates. Contingencies were applied to each area of the cost estimate (i.e., decontamination and dismantlement, waste 5-2 Revision 21

TNP DECOMMISSIONING PLAN disposal, final survey, etc.) at appropriate rates. No credit was taken for equipment salvage value.

Standard ongoing financial controls have been established and executed to ensure funds are expended consistent with the provisions of 10 CFR 50.82(a)(8) and 10 CFR 50.75(h)(2)

(Reference 5-5). Throughout the budgetary process and budget year, costs associated with new projects or activities are evaluated to determine their correct cost classification, i.e., spent fuel management, radiological decommissioning, nonradiological decommissioning, capital, etc. As a result, only costs that meet the intent of this TNP Decommissioning Plan and the established decommissiioning trust fund are submitted for reimbursement from the decommissioning trust.

Periodically, variances between the estimate and actual costs are reviewed as they relate to the total cost estimate to provide assurance that the cost estimate continues to be reasonable. This complies with 10 CFR 50.82(a)(8)(i)(A). In addition, PGE corporate finance personnel review the TNP co-owners' trust fund activity and balance periodically, as applicable. Any significant activity which is inconsistent with this TNP Decommissioning Plan would be brought to the attention of TNP management.

The decommissioning cost estimate reflects costs in 1997 dollars, and has been updated to account for work performed through 2004 where TNP expended funds for decommissioning activities. The decommissioning cost estimate reflects updated staffing requirements and work/activity schedules, remaining scheduled decommissioning equipment removal efforts, and adjustments for radioactive waste disposal volumes and costs.

In accordance with 10 CFR 50.82(a)(8)(i)(C) and 10 CFR 50.75(e) (Reference 5-5), the TNP co-owners periodically assess the financial assurance amount required to complete radiological decommissioning. The established financial assurance mechanisms (e.g., external trust fund, statement of intent, and/or letter of credit, as applicable) are adjusted as necessary to ensure the completion of radiological decommissioning. Financial assurance is described in Section 5.2.

"Bridge" funds are also described in Section 5.2.

5.1.2.2 Nonradiological Decommissioning Costs Although not required by NRC regulations, the decommissioning cost estimate for TNP incorporates nonradiological decommissioning costs, as indicated in Table 5-2. The TNP decommissioning cost estimate considers nonradiological decommissioning costs to be those costs associated with site remediation and demolition and removal of uncontaminated structures.

The decommissioning cost estimate does not include in nonradiological decommissioning costs those costs associated with spent fuel management or radiological decommissioning activities.

5.1.2.3 Spent Fuel Management Costs Implementation costs associated with spent fuel management, including ISFSI construction and O&M, are reflected in the projected cost schedule detailed in Table 5-2. With ISFSI construction completed and the spent nuclear fuel now transferred from the TNP Spent Fuel Pool to the Trojan ISFSI, the remaining spent fuel management costs consist of expenditures associated with ongoing Trojan ISFSI storage O&M. Trojan ISFSI storage O&M will continue 5-3 Revision 21

TNP DECOMMISSIONING PLAN until possession and title of the irradiated fuel is transferred to the DOE for ultimate disposal (due to DOE delays, the revised estimate for completion is 2023). Costs and associated funding necessary for ISFSI decommissioning activities are detailed in PGE-1069, Trojan ISFSI Safety Analysis Report.

5.1.2.4 Financial Activity Costs Additional costs may be incurred by each TNP co-owner as necessary during decommissioning to secure and maintain assurance that adequate funds will be available to complete radiological decommissioning of the TNP site, and to secure loans or other "bridging" mechanisms to augment existing funds to cover near-term decommissioning costs. Financial assurance costs indicated in Table 5-2 were the costs associated with securing a letter of credit until PGE could pre-fund the external trust fund.

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TNP DECOMMISSIONING PLAN

5.2 DECOMMISSIONING FUNDING

PLAN 5.2.1 CURRENT DECOMMISSIONING FUNDING CAPABILITIES Each of the TNP co-owners separately collect through rates the funds for the decommissioning of TNP. PGE and PP&L deposit these funds in external trust funds in accordance with 10 CFR 50.75(e), while the BPA provides EWEB's portion of TNP decommissioning funds as necessary as described in Section 5.2.2.2. Because the TNP was shut down prematurely, the external trust funds established by PGE and PP&L may contain during some periods only a portion of the total amount needed for site radiological decommissioning. Table 5-3 summarizes the status of PGE's and PP&L's decommissioning trust funds as of December 31, 2004.

As indicated above, there may be periods during which the trusts established by PGE and PP&L for decommissioning do not contain the funds necessary for completion of radiological decommissioning. During such periods, PGE and PP&L are required to secure an additional financial assurance mechanism allowed by 10 CFR 50.75(e). If required, PGE and PP&L have each elected to use a letter of credit as the additional financial assurance mechanism. During any period prior to TNP license termination that a co-owner's external decommissioning trust fund does not contain the funds necessary to complete radiological decommissioning, the affected co-owner must maintain this additional financial assurance.

Furthermore, a decommissioning trust fund balance may be reduced to a point where it will be necessary in certain instances to borrow or otherwise provide "bridging" funds to complete decontamination activities and allow scheduled collections to restore the decommissioning trust fund balance.

5.2.2 TNP CO-OWNERS' DECOMMISSIONING FUNDING PLANS Each TNP co-owner maintains a decommissioning fund collection schedule which ensures that each co-owner's portion of the decommissioning activity expenditures will be fully funded.

These funding schedules are based on funding requirements for both radiological and nonradiological decommissioning costs, as well as financing costs and specific spent fuel management costs as discussed in Section 5.1.2. The decommissioning funding cash flow for each of the TNP co-owners, based on the expenditure schedule in Table 5-2 and the co-owner contribution schedules, is described below.

5.2.2.1 PGE Funding Table 5-4 provides PGE's decommissioning funding cash flow in nominal dollars (2.3 1% escalation) during decommissioning. Funded from an external trust fund, the expenditures described in this table are PGE's share (67.5%) of the expenditures described in Table 5-2. The funding schedule described in Table 5-4 ensures that PGE's portion of the decommissioning activity expenditures will be fully funded. This decommissioning funding schedule reflects projected needs, if any, and associated costs and funding for bridging funds and/or a letter of credit, if required.

5-5 Revision 21

7TNP DECOMMISSIONING PLAN As indicated in Section 5.2.1, during any period prior to TNP license termination that PGE's external trust fund does not contain the funds necessary for completion of radiological decommissioning, PGE must secure a letter of credit as an additional financial assurance mechanism for radiological decommissioning costs as allowed by 10 CFR 50.75. The methodology used to determine the size of the letter of credit ensures that if a given amount of the decommissioning trust fund is used for purposes other than radiological decommissioning activities during a current year, the portion of the financial assurance provided by the letter of credit must be increased by the same amount. This methodology can be summarized as follows:

La= T. - T2 + T3 where Lf. = Letter of Credit Portion of Financial Assurance Needed for Current Year T, = Total costs of remaining radiological decommissioning activities T2 = Current decommissioning trust fund balance T3 = Portion of trust balance planned for purposes other than radiological decommissioning costs during current year Financial assurance for remaining radiological decommissioning activities will be calculated at the beginning of each year and will be periodically reviewed during each year to ensure that an adequate level of financial assurance is maintained.

5.2.2.2 EWEB/BPA Funding BPA is obligated through Net Billing Agreements to pay costs associated with EWEB's share of TNP, including decommissioning and spent fuel management costs. BPA fulfills the decommissioning funding obligations of EWEB, including providing financial assurance for EWEB's portion of decommissioning costs in a manner stipulated in 10 CFR 50.75(e)(1)(iv) for Federal government licensees as detailed further below. Table 5-5 provides BPA/EWEB's decommissioning funding cash flow in nominal dollars (2.3 1% escalation) during decommissioning. The expenditures described in this table are BPA/E WEB's share (30%) of the expenditures described in Table 5-2. The funding schedule described in Table 5-5 ensures that BPA/EWEB's portion of the decommissioning activity expenditures will be fully funded.

As allowed by 10 CFR 50.75(e)(1)(iv), BPA, as a Federal government entity fulfilling the decommissioning funding obligations of EWEB, a licensee, provides financial assurance in the form of a statement of intent. The statement of intent contains a reference to the TNP decommissioning cost estimate described in Section 5.1, indicating that funds for radiological decommissioning of the TNP will be obtained when necessary.

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TIVP DECOMMISSIONING PLAN 5.2.2.3 PP&L Funding Table 5-6 provides PP&L's decommissioning funding cash flow in nominal dollars (2.3 1% escalation) during decommissioning. Funded from an external trust fund, the expenditures described in this table are PP&L's share (2.5%) of the expenditures described in Table 5-2. The funding schedule described in Table 5-6 ensures that PP&L's portion of the decommissioning activity expenditures will be fully funded. This decommissioning funding schedule reflects projected needs, if any, and associated costs and funding for bridging funds and/or a letter of credit, if required.

As indicated in Section 5.2.1, during any period pror to TNP license termination that PP&L's external trust fund does not contain the funds necessary for completion of radiological decommissioning, PP&L must secure a letter of credit as an additional financial assurance mechanism for radiological decommissioning costs as allowed by 10 CFR 50.75. The methodology for determining the size of the letter of credit is as described in Section 5.2.2.1, "PGE Funding."

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TNP DECOMMISSIONING PLAN

5.3 REFERENCES

FOR SECTION 5 5-1 Code of Federal Regulations, Title 10, Part 50.82, "Application for Termination of License," August 28, 1996.

5-2 Regulatorv Guide 1.179, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors," January 1999.

5-3 AIF/NESP-036, "Guidelines to Producing Decommissioning Cost Estimates."

5-4 U. S. Department of Energy DOE/EV/10128-1, "Decommissioning Handbook,"

November 1980.

5-5 Code of Federal Regulations, Title 10, Part 50.75, "Reporting and Recordkeeping for Decommissioning Planning."

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7NP DECOMMISSIONING PLAN Table 5-1 Estimate of Decommissioning Costs (1997 dollars)

Total Total Costs (Start-to-Finish) Remaining As of Costs January 1, 2005 l Radiological (NRC) Decommissioning Costs Reactor Vessel and Internals Removal and Disposal 21,495,000 0 Dismantlement, Decontamination, and Remediation 143,207,000 6,315,000 l Waste Disposal 39,391,000 61,000 Final Survey 7,577,000 0 l Total 211,670,000 6,376,000 l Nonradiological Decommissioning Costs Site Restoration 40,228,000 36,474,000 l Total 40,228,000 36,474,000 l Dry Spent Fuel Management Costs ISFSI Construction 74,161,000 0 l ISFSI Operation and Maintenance 95,790,000 88,768,000 l Total 169,951,000 88,768,000 Financing Costs Financial Assurance 16,000 0 I Total 16,000 0 I Total Decommissioning Expenditures $ 421,865,000 $ 131,618,000 I Revision 21

TNP DECOMMISSIONING PLAN Table 5-2 Decommissioning Cost estimate for Trojan Nuclear Plant Itemized Decommissioning Expenditure Schedule (1997 $ x 1000)

Total Decommissioning Expenditures Total Total Total Total Total Radiological Nonradiological Spent Fuel Financing Combined Decommissioning Decommissioning Management Activity Decommissioning Year Costs Costs Costs Costs Costs 1993 2.673 0 0 0 2.673 1994 X 5,320 68 0 _0 5.388 1995 15.896 45 1.100 0 17.041 1996 9087 243 3.144 0 12.474 1997 19.238 350 7.974 0 27.562 34.321 62 9.703 0 44.086 19937.970 1.313~- 17.980 57.263 2000 33.172 777 3354 0 37 2001 8.38 198 6.731 0 15.31 2028.329 (46) 15.608 023.8911 2 13876 244 12.896 ( 27.016 2004 17.030 500 2.692 16 20.23 2005 6.375 3.383 4.760 0_14_518 2006 0 186 3.970 0 4.15611 2007 0 0X 3.676 03.676 2008 a 0 3.849 3.849 2009 0 0 3.799 03.799 2010 0 0 3.750 03.70 2011 1 0 0 3.693 0 3.6 2012 0 0 374 0 3_704 2013 0C.69 0 3693 _3_693 2014 0C 3.6 336931 0 2015 C 0 3.693 0 3.

2016 0 C 3.6629 0 669 2017 0 C 3.693 0 3.M 2018 0 C 3.693 0 3.M 2019 C- C 3.693 0 3.693 2020 0 C 3.693 0 3.I 2021 0 C 3.693 0 3,693 2022 0 C 3.6933 0 69 2023 0 18.687 20.662 0 39.349 2024 0 14.218 0 0 14218 Total 211.670 40.228 169.951 16 421.865 Revision 21

TNP DECOMMISSIONING PLAN Table 5-3 Status of Decommissioning Trust Funds As of December 31, 2004 Trojan Co-Owner Fund Balance as of 12/31/04 I Portland General Electric (PGE) $19,259,000a Eugene Water & Electric (EWEB)/ NlAb Bonneville Power Administration (BPA)

Pacific Power & Light (PP&L) $1,223,000a I Total $20,482,000 I a The 2004 end-of-year trust fund balance includes an adjustment for trust expenditures incurred in November and December 2004 that were not paid out of the trust in 2004. I b BPA provides decommissioning funding from its operating budget as such funds are needed. Financial assurance is provided by a Statement of Intent, dated March 21, 2001. Therefore, no external trust fund is required.

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TVP DECOMMISSIONING PLAN Table 5-4 Portland General Electric Decommissioning Funding Cash Flow (Nominal $ x 1000)

PGE PGE PGE PGE Bridge Letter of Trust Fund Trust Fund Trust Fund Trust Fund Prefund Funds Letter of Credit Expenditures Contributions Net Earnings EOY Balance Refund Interest Credit Fee Year A B C D E F G H 1996 1997 <<A 1998 1999X 2000 2001 2002 2003 2004 19259 2005 (11.810i 13.343 835 21.627 2006 (3.458) 13.343 1.266 32.778 2007 13.130) 13.343 1.726 44.717 _

2008 (3 352) 13.343 2.550 57.258 2009 3..385) 13.343 3,135 703.51 2010 3..420) 6.934 3.442 77.307 2011 3..446* 3.432 77.293 2012 3..5341 3.420 77.179 2013 . 3f607) 3.411 76.983 2014 J3.690) 2.945 76.238 _

2015 J3.775) 2.912 75.375 2016 _3_837) 2.875 74.413 2017 23.952) 2.832 73.293 2018 4._043_ 2.784 72.034 2019 _4_136) 27730 70.628 2020.4.232) 2.669 69.065

.4.330L 2021 2.603 67.338 2022 .4,430) 2.530 65.438 2023 (48.280) 692 17.850 2024 (17.850) 0 0 Total (141.697) 73.649 48.789 . 0 0 O NOTE 1: Positive numbers Indicate cash flow Into trust fund; negative numbers indicate cash flow out of trust fund.

NOTE 2: Current EOY balance = previous year EOY balance + current year A + B + C + E + H.

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TNP DECOMMISSIONING PLAN Table 5-5 EWEB / BPA Decommissioning Funding Annual Cash Obligations (Nominal $ x 1000)

Eugene Water and Electric Board I Bonneville Power Administration Year Decommissioning Obligations 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 5.249 2006 1.537 2007 1.391 2008 1.490 2009 1.505 2010 1.520 2011 1.531 2012 1.571 2013 1.603 2014 1.640 2015 1.678 2016 1.705 2017 1.756 2018 1.797 2019 1.838 2020 1.881 2021 1.924 2022 1.969 2023 21.459 2024 7.933 Total 62.977 Note 1: BPA provides decommissioning funding from its operating budget as such funds are needed. Financial assurance is provided by a Statement of Intent, dated March 21, 2001. Therefore, no external trust fund is required.

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7NP DECOMMISSIONING PLAN Table 5-6 Pacific Power & Light Decommissioning Funding Cash Flow (Nominal $ x 1000)

Year PP&L PP & L PP&L PP&L Bridge Letter of Trust Fund Trust Fund Trust Fund Trust Fund Bridge Funds Letter of Credit Expenditures Contributions Net Earnings EOY Balance Funds Interest Credit Fee A B C D E F G H 1996 1997 1998 1999X 2000 = =

2002 2003 2004 1_J223< __

2005 (437) 349 25 1.160 2006 (128) 349 34 1.415 2007 (1616 349 50 1.698 2008 (124) 349 61 1.984 2009 (125) 349 72 2_280 2010 (127 1 349 83 2_585 2011 1128) 350 95 2.902 2012 (311 1.77 2.878 2013 (1341 105 - 2.849 2014 (137) 104 2.816 2015 (140) 103 2.779 2016 (142_ 101 2 _738 2017 (146) 100 2_692 2018 ( 511198 2,640 2019 (153) 96 2.583 2020 (157_ 94 2_52_

2021 (1601 91 2.451 2022 (1641 88 2.375 2023 (1.7881 62 649 2024 (6611 12 0 Total _(5.24811 2672 1_581 NOTE 1: Positive numbers indicate cash flow Into trust fund; negative numbers Indicate cash flow out of trust fund.

NOTE 2: Current EOY balance = previous year EOY balance + current year A + B + C Revision 21