ML19095A010

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

ML19095A010
Person / Time
Site:	Three Mile Island
Issue date:	04/05/2019
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TM-19-024
Download: ML19095A010 (49)

Text

Michael P. Gallagher Exelon Generation ~

Exelon Nuclear Vice President License Renewal and Decommiss1onmg 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.82(a)(4)(i)

TM-19-024 April 5, 2019 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR 50 NRG Docket No. 50 289

Subject:

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

References:

1) Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (ML17171A151)

2) Letter from Patrick Simpson, (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations,"

dated April 1, 2019 (ML19091A140)

Pursuant to 10 CFR 50.82(a)(4)(i), Exelon Generation Company, LLC (Exelon) is submitting the site-specific decommissioning cost estimate (DCE) for Three Mile Island Nuclear Station, Unit 1 (TMl-1). On June 20, 2017, in accordance with 10 CFR 50.82(a)(1)(i), Exelon informed the U.S. Nuclear Regulatory Commission (NRG) that TMl-1 will permanently cease power operations on or about September 30, 2019 (Reference 1). In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), Exelon is required to submit a Spent Fuel Management Plan (SFMP), Site Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations. The TMl-1 PSDAR and SFMP are being submitted under separate cover letters. to this letter provides the TMl-1 DCE. The latest Decommissioning Funding Report for TMI was submitted in Reference 2, Attachment 30. The minimum formula cost amount using the formula in 10CFR50.75(c) has been calculated assuming the labor, energy, and burial factors described in Attachment 1 of Reference 2. The site-specific cost amount reported in the DCE is greater than the minimum formula cost amount, as required by 10 CFR 50.75(b)(1 ). to this letter contains the projected annual cash flow from the Nuclear Decommissioning Trust Fund (NDTF) for TMl-1 radiological decommissioning. The cost in

U.S. Nuclear Regulatory Commission Site-Specific Decommissioning Cost Estimate Docket Nos. 50-289 April 5, 2019 Page2 for radiological decommissioning (including decommissioning for the proposed Independent Spent Fuel Storage Installation (ISFSI)) are from Attachment 1, Table 6-2, which have been escalated from June 2018 dollars in Attachment 1, to December 31, 2018 dollars using an escalation rate of 1.42% (which corresponds to an APR of 2.8638%). The NDTF balance as of December 31, 2018 was $669,617,225. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention). demonstrates that adequate funding is available in the NDTF to complete radiological decommissioning.

Pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually. The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (applicable revision at the time) and will be used to demonstrate funding assurance. If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 1o CFR 50.75(e) and the guidance provided in the Regulatory Guide, will be put in place at an appropriate time.

The DCE (Attachment 1) and the Decommissioning Annual Cash Flows (Attachment 2) were inputs to the PSDAR, with the PSDAR providing summaries of the conclusions.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

Respectfully, Attachment 1: Three Mile Island Nuclear Station - Unit 1 - Site-Specific Decommissioning Cost Estimate Attachment 2: Three Mile Island Nuclear Station - Unit 1 - Annual Decommissioning Fund Cash Flow cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector-Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 2 Director, Bureau of Radiation Protection - PA Department of Environmental Resources

Attachment 1 :

Three Mile Island Nuclear Station - Unit 1 Site-Specific Decommissioning Cost Estimate

Michael P. Gallagher Exelon Generation ~

Exelon Nuclear Vice President License Renewal and Decommiss1onmg 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.82(a)(4)(i)

TM-19-024 April 5, 2019 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR 50 NRG Docket No. 50 289

Subject:

Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1

References:

1) Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (ML17171A151)

2) Letter from Patrick Simpson, (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations,"

dated April 1, 2019 (ML19091A140)

Pursuant to 10 CFR 50.82(a)(4)(i), Exelon Generation Company, LLC (Exelon) is submitting the site-specific decommissioning cost estimate (DCE) for Three Mile Island Nuclear Station, Unit 1 (TMl-1). On June 20, 2017, in accordance with 10 CFR 50.82(a)(1)(i), Exelon informed the U.S. Nuclear Regulatory Commission (NRG) that TMl-1 will permanently cease power operations on or about September 30, 2019 (Reference 1). In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), Exelon is required to submit a Spent Fuel Management Plan (SFMP), Site Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations. The TMl-1 PSDAR and SFMP are being submitted under separate cover letters. to this letter provides the TMl-1 DCE. The latest Decommissioning Funding Report for TMI was submitted in Reference 2, Attachment 30. The minimum formula cost amount using the formula in 10CFR50.75(c) has been calculated assuming the labor, energy, and burial factors described in Attachment 1 of Reference 2. The site-specific cost amount reported in the DCE is greater than the minimum formula cost amount, as required by 10 CFR 50.75(b)(1 ). to this letter contains the projected annual cash flow from the Nuclear Decommissioning Trust Fund (NDTF) for TMl-1 radiological decommissioning. The cost in

U.S. Nuclear Regulatory Commission Site-Specific Decommissioning Cost Estimate Docket Nos. 50-289 April 5, 2019 Page2 for radiological decommissioning (including decommissioning for the proposed Independent Spent Fuel Storage Installation (ISFSI)) are from Attachment 1, Table 6-2, which have been escalated from June 2018 dollars in Attachment 1, to December 31, 2018 dollars using an escalation rate of 1.42% (which corresponds to an APR of 2.8638%). The NDTF balance as of December 31, 2018 was $669,617,225. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention). demonstrates that adequate funding is available in the NDTF to complete radiological decommissioning.

Pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually. The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" (applicable revision at the time) and will be used to demonstrate funding assurance. If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 1o CFR 50.75(e) and the guidance provided in the Regulatory Guide, will be put in place at an appropriate time.

The DCE (Attachment 1) and the Decommissioning Annual Cash Flows (Attachment 2) were inputs to the PSDAR, with the PSDAR providing summaries of the conclusions.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

Respectfully, Attachment 1: Three Mile Island Nuclear Station - Unit 1 - Site-Specific Decommissioning Cost Estimate Attachment 2: Three Mile Island Nuclear Station - Unit 1 - Annual Decommissioning Fund Cash Flow cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector-Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station - Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island - Unit 2 Director, Bureau of Radiation Protection - PA Department of Environmental Resources

Attachment 1 :

Three Mile Island Nuclear Station - Unit 1 Site-Specific Decommissioning Cost Estimate

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report DECOMMISSIONING COST ANALYSIS REPORT Three Mile Island Nuclear Station Unit 1 April 2019 DECOM-2018-DCE-TMI-1 Rev. 0

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPROVALS Decommissioning Engineer ~~1fld.

Chf'Stopher w~ff jf.

4/.:i/19 Date Decommissioning Engineer q;f_ ~~ Ll/~r Adam DOJ1eii Date Senior Manager Decommissioning ~°'d:

Jeffrey Dunlap 4/2/2019 Date DECOM-2018-DCE-TMl-1 Rev. 0 Page i of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report EXECUTIVE

SUMMARY

This report presents estimates of the cost to decommission the Three Mile Island Nuclear Station, Unit 1 (TMI-1) based on a permanent shut down no later than September 30, 2019. This report constitutes the TMI-1 Site-Specific Decommissioning Cost Estimate (DCE).

The primary objectives of the decommissioning project are to remove the facility from service and reduce residual radioactivity to levels permitting unrestricted release, so that the plants operating license can be terminated within 60-years after permanent cessation of operations. The costs to restore the site are also included in the DCE.

Exelon evaluated three alternative decommissioning scenarios: DECON, Shortened SAFSTOR, and SAFSTOR. In all three scenarios the spent fuel that is stored in the spent fuel pool is transferred to the Independent Spent Fuel Storage Installation (ISFSI) shortly after shutdown, however the timeframe in which the decommissioning and dismantlement (D&D) begins differs.

In the DECON scenario, D&D begins shortly after the spent fuel is transferred to the ISFSI. In the Shortened SAFSTOR scenario, D&D is deferred approximately 30 years after permanent shutdown. In the SAFSTOR scenario, D&D is deferred for as long as possible while still meeting the required 60-year license termination.

The selection of a preferred decommissioning alternative is influenced by numerous factors including the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, regulatory requirements, and public concerns. Based on these factors the SAFSTOR alternative has been selected.

The cost elements are assigned to one of three subcategories: Radiological Decommissioning (radiological remediation), Spent Fuel Management, or Site Restoration. The Radiological Decommissioning subcategory is used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR 50.75). The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management. The Radiological Decommissioning cost subcategory is further broken down to separately address costs to perform radiological decommissioning of the ISFSI (as required by 10 CFR 72.30).

The methodology used to develop the estimated costs, including financial aspects, is discussed in Section 3, Cost Estimate Methodology. Section 4, Assumptions, provides a discussion of the assumptions used in developing the various costs elements and considerations; including the cost associated with decontamination and component removal, waste disposal, and labor. These assumptions serve as the foundation in the development of the anticipated cost to decommission TMI-1.

Based on the SAFSTOR alternative the major milestones associated with the decommissioning time periods are discussed in Section 5, Schedule Estimate.

The following tables summarize the estimated costs for the SAFSTOR alternative reflecting the various cost elements. Additional detail regarding the estimated costs are provided in Section 6 and in the Appendices of this report.

DECOM-2018-DCE-TMI-1 Rev. 0 Page ii of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report SAFSTOR Alternative for TMI-1 (thousands of 2018 dollars)

Cost Element Total Decontamination 7,999 Removal 158,354 Packaging 21,793 Transportation 16,436 Waste Disposal 57,647 Off-Site Waste Processing 7,510 Program Management1 487,732 Security 193,944 System and Security Modifications 10,350 Spent Fuel Storage and Management2 123,036 Insurance and Regulatory Fees 52,822 Energy 23,903 Characterization and Licensing Surveys 26,419 Property Taxes 13,243 Miscellaneous Equipment 27,671 Total3 1,228,858 Cost Element Total Site Radiological Decommissioning 980,304 ISFSI Radiological Decommissioning 7,207 Spent Fuel Management 156,408 Site Restoration 84,939 Total3 1,228,858 1

Includes engineering costs.

2 Includes costs for the dry storage system components, spent fuel loading and transfer, spent fuel pool operations and maintenance and Emergency Planning fees, but excludes program management costs (staffing), security and other related costs.

3 Columns may not add up due to rounding.

DECOM-2018-DCE-TMI-1 Rev. 0 Page iii of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report ACRONYMS AIF/NESP Atomic Industrial Forum/National Environmental Studies Project CFR Code of Federal Regulations DCE Decommissioning Cost Estimate DOC Decommissioning Operations Contractor DOE Department of Energy Exelon Exelon Generation Company FEMA Federal Emergency management Agency GTCC Greater than Class C [Waste]

ISFSI Independent Spent Fuel Storage Installation LLRW Low Level Radioactive Waste LSA Low Specific Activity LTP License Termination Plan MPC Multi-Purpose Canister NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Report (NRC)

PSDAR Post Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor SCO Surface Contaminated Object TMI-1 Three Mile Island Nuclear Station, Unit 1 TMI-2 Three Mile Island Nuclear Station, Unit 2 U.S. United States WDF Work Difficulty [Adjustment] Factor DECOM-2018-DCE-TMI-1 Rev. 0 Page iv of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table of Contents EXECUTIVE

SUMMARY

........................................................................................................... ii ACRONYMS ..............................................................................................................................iv

1. OVERVIEW ........................................................................................................................ 1

2. DECOMMISSIONING SCENARIO...................................................................................... 3 2.1. Decommissioing Methods ............................................................................................ 3 2.2. Decommissioning Method Selected - SAFSTOR ......................................................... 3

3. COST ESTIMATE METHODOLOGY.................................................................................. 6 3.1. Methodology Bases ..................................................................................................... 6 3.2. Financial Components of the Cost Model..................................................................... 6

4. ASSUMPTIONS.................................................................................................................. 9 4.1. General........................................................................................................................ 9 4.2. Labor Costs ................................................................................................................. 9 4.3. Transition Activities .....................................................................................................10 4.4. Non-Radioactive Waste ..............................................................................................10 4.5. Radioactive Waste ......................................................................................................10 4.6. Site Specific Considerations .......................................................................................11 4.7. Component Removal ..................................................................................................12 4.8. Contaminated Concrete and Metal Removal...............................................................13 4.9. Spent Fuel Management.............................................................................................13 4.10. Independent Spent Fuel Storage Installation...............................................................13 4.11. Site Restoration ..........................................................................................................14 4.12. Site Conditions Following Decommissioning ...............................................................14

5. Schedule Estimate ...........................................................................................................17 5.1. Schedule Assumptions ...............................................................................................17 5.2. Project Schedule.........................................................................................................17

6. COST ESTIMATE ..............................................................................................................19 6.1. Cost Estimate Results.................................................................................................19

7. REFERENCES ..................................................................................................................23 DECOM-2018-DCE-TMI-1 Rev. 0 Page v of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Tables Table 4-1: Burial Volumes and Weights by Waste Type........................................................15 Table 4-2: Projected Staffing Levels for SAFSTOR...............................................................16 Table 6-1: SAFSTOR Alternative ..........................................................................................20 Table 6-2: SAFSTOR Alternative, Unit 1 Total Annual Expenditures .....................................21 Figures Figure 5-1: Decommissioning Timeline - SAFSTOR..............................................................18 Appendices APPENDIX A: DETAILED COST ESTIMATE APPENDIX B: ISFSI DECOMMISSIONING COST ESTIMATE DECOM-2018-DCE-TMI-1 Rev. 0 Page vi of vi

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

1. OVERVIEW This report presents estimates of the cost to decommission the Three Mile Island Nuclear Station, Unit 1 (TMI-1) based on a permanent shut down no later than September 30, 2019. TMI-1 is a Babcock & Wilcox pressurized water reactor (PWR), rated at 2568 megawatts-thermal (MWt).

This report constitutes the TMI-1 Site-Specific Decommissioning Cost Estimate (DCE).

The primary objectives of the TMI-1 decommissioning project are to remove the facility from service and reduce residual radioactivity to levels permitting unrestricted release, so that the plants operating license can be terminated within 60-years after permanent cessation of operations. The costs to restore the site are also included in the DCE.

This analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering processes required to carry out the decommissioning of the nuclear unit. It also may not reflect the actual plan to decommission the TMI-1; the plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.

The cost elements are assigned to one of three subcategories:

(1) Radiological Decommissioning - this subcategory is used to accumulate costs that are consistent with decommissioning as defined by the Nuclear Regulatory Commission (NRC) in its financial assurance regulations (i.e., 10 CFR 50.75) and separately address the cost of radiological decommissioning as defined by 10 CFR 50.2. The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.

The Radiological Decommissioning cost subcategory is further broken down to separately address costs to perform radiological decommissioning of the Independent Spent Fuel Storage Installation (ISFSI) (as required by 10 CFR 72.30).

(2) Spent Fuel Management - this subcategory contains costs associated with the containerization and transfer of spent fuel from the wet storage pool to a Department of Energy (DOE) transport cask or to the ISFSI for interim storage, as well as the transfer of the spent fuel in storage at the ISFSI to the DOE. Costs are included for the management of the ISFSI until such time that the transfer is complete. It does not include any spent fuel management expenses unrelated to decommissioning planning incurred prior to the cessation of plant operations, nor does it include any costs related to the final disposal of the spent fuel.

(3) Site Restoration - this subcategory is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet below grade and backfilled to conform to local surface elevation.

It should be noted that the costs assigned to these subcategories are allocations. Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, Exelon may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to a Radiological Decommissioning DECOM-2018-DCE-TMI-1 Rev. 0 Page 1 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

The estimates were developed, and costs are presented in June 2018 dollars. As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the station or during the decommissioning period.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 2 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

2. DECOMMISSIONING SCENARIO 2.1. DECOMMISSIOING METHODS Exelon evaluated the following decommissioning scenarios:

(1) DECON - spent fuel is transferred to the ISFSI shortly after shutdown and decommissioning and dismantlement begins shortly after that.

(2) Shortened SAFSTOR - the spent fuel is transferred to the ISFSI and decommissioning is deferred approximately 30 years after permanent shutdown.

(3) SAFSTOR - the spent fuel is transferred to the ISFSI and the plant facility is left intact until the decommissioning starts sometime in the future (dormancy phase), with structures maintained in a sound condition. Decommissioning commences such that license termination is completed within the required 60-years.

The scenarios also recognize that spent fuel will be stored at the site in the spent fuel storage pool and/or in an ISFSI until such time that it can be transferred to a DOE facility. The estimates also include the cost to operate and eventually decommission the ISFSI.

The selection of a preferred decommissioning alternative is influenced by numerous factors at the time of plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, regulatory requirements, and public concerns.

2.2. DECOMMISSIONING METHOD SELECTED - SAFSTOR The selection of a preferred decommissioning alternative is influenced by numerous factors including the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, regulatory requirements, and public concerns. Based on these factors the SAFSTOR alternative has been selected.

The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases; 1) the initial phase begins with the permanent shutdown and through the transition to storage or decommissioning activities, 2) the next phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two; and 3) the final phase pertains to the activities involved in radiological decommissioning and license termination. The decommissioning estimates developed herein are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures and differs from those presented by the NRC.

2.2.1. Period 0 (Pre-Shutdown) and Period 1 (Shutdown through Transition) -

Preparations Prior to the permanent shutdown and defueling, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Preparations include revision of technical specifications applicable to the operating conditions and requirements, characterization of the facility and major components, and the development of the Post Shutdown Decommissioning Activities Report (PSDAR).

DECOM-2018-DCE-TMI-1 Rev. 0 Page 3 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Following the final shutdown and defueling, the site will be prepared to minimize operation and maintenance to those systems/components/areas that are required to support the safe handling and management of spent fuel. Those systems/components that will not be required will be isolated and removed from service. Radiation controls will be put in place to reduce radiation and contamination in areas that will need to be accessed to support decommissioning. Areas not needed will have access restricted to minimize radiation/contamination exposure and potential safety hazards. Spent fuel in the spent fuel storage pool may begin to be transferred to the ISFSI, which is being constructed. The security area will be adjusted to reflect protection of equipment and areas necessary to support the safe handling and management of spent fuel.

2.2.2. Period 2 - Dormancy Phase The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phase of SAFSTOR. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, maintenance of necessary area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel will perform maintenance and inspection activities to maintain safe conditions. The transfer of the spent fuel from the spent fuel pool to the ISFSI continues during this period until complete.

Additionally, the transfer of the spent fuel to a DOE facility occurs during this period.

2.2.3. Period 3 - Site Reactivation and Decommissioning Preparations Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for decommissioning activities and the writing of work packages, activity specifications and decommissioning procedures are initiated. The environmental impact associated with the planned decommissioning activities is also considered. If the consequences of a planned decommissioning activity are predicted to be greater than what is bounded by previously evaluated environmental assessments or impact statements, a license amendment would have to be submitted to the NRC for the specific activity and the environmental report would have to be updated.

2.2.4. Period 4 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures. Existing facilities will be modified, and/or temporary facilities will be constructed to support decommissioning, decontamination, and dismantling activities. Components and piping systems will be decontaminated as necessary to control (minimize) worker exposure and facilitate packaging and transportation. Piping and components no longer essential to support decommissioning operations will be removed. The reactor internal and external components will be removed. Some larger Nuclear Steam Supply System (NSSS) components may be decontaminated and sealed in such a manner as to serve as their own shipping/burial containers. The reactor will be segmented, removed and placed in shielded casks. Activated portions of the reactor and other biological shield walls will be demolished by controlled processes.

The License Termination Plan (LTP), which includes the Final Survey Plan, is developed and submitted to the NRC. Once the survey is complete, the results are provided to the NRC for their review and evaluation. Once the NRC approves the LTP the final remediation of site facilities and DECOM-2018-DCE-TMI-1 Rev. 0 Page 4 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report services may start. Subsequently, the NRC independently confirms the radiological site conditions and approves a license amendment that releases the property, inclusive of the ISFSI, for unrestricted use.

2.2.5. Period 5 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin.

Remaining structures are removed, exterior walls and foundations are removed to a nominal depth of three feet below grade, and non-contaminated concrete rubble produced by demolition activities is processed and then used to backfill foundation voids. The plant area is graded and stabilized.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 5 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

3. COST ESTIMATE METHODOLOGY 3.1. METHODOLOGY BASES The systematic approach used herein for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs. The costs and schedules follow the general guidance and sequence in Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors (Reference 7.1). The format and content of the estimates is consistent with the recommendations of Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Reference 7.2). The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates" (Reference 7.3) and the DOE "Decommissioning Handbook" (Reference 7.4).

The unit cost factors used in this analysis incorporate site-specific costs and the latest available information about worker productivity in decommissioning. The detail provided in the unit cost factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. The activity-dependent costs were estimated with the item quantities based on plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures were based on "Building Construction Cost Data 2017" published by R.S. Means (Reference 7.5) escalated from 2017 $s to 2018 $s.

Critical path was used to determine the total decommissioning program schedule and establish carrying costs, which include program management, administration, field engineering, equipment rental, quality assurance, and security.

3.2. FINANCIAL COMPONENTS OF THE COST MODEL The cost model used provides distinct cost elements, however these distinct cost elements do not comprise the total estimated cost to accomplish the project goal. Additional factors as described below are also taken into consideration.

3.2.1. Contingency Contingencies are necessary to provide assurance that sufficient funding will be available since the cost elements are based on ideal conditions and maximum efficiency. They are an integral part of the total cost to complete the decommissioning process and are expected to be fully expended. The activity and period dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis. Contingency, in this analysis, does not include price escalation and inflation in the cost of decommissioning over the remaining operating life of the station, or duration of the decommissioning program and dry fuel storage period.

Exelon examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual DECOM-2018-DCE-TMI-1 Rev. 0 Page 6 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report activity contingencies ranged from 8% to 75%, depending on the degree of difficulty judged to be appropriate. 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%

Low-Level Radioactive Waste Processing 15%

Reactor Segmentation 75%

NSSS Component Removal 25%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

Greater Than Class C 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 10/15%

Spent Fuel Storage (Dry) Systems 8%

Spent Fuel Transfer Costs 15%

Operations and Maintenance Expenses 15%

ISFSI Decommissioning 25%

The contingency values are applied to the appropriate components of the estimate on a line item basis, except where actual budgets were provided or estimates for activities assumed to include contingency.

3.2.2. Financial Risk This cost study does not include any specific costs 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 estimates.

3.2.3. Work Difficulty Factors Work difficulty factor (WDF) adjustments have been applied 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 and/or hazardous environments. The study applies WDFs to account for use of radiological dose minimization practices (e.g., radiological protection instruction, mock-up training, and use of respiratory DECOM-2018-DCE-TMI-1 Rev. 0 Page 7 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report protection and protective clothing). Changes to worker exposure limits may also impact the decommissioning cost and project schedule.

The factors and their associated range of values were developed in conjunction with the process described in AIF/NESP-036 (Reference 7.3).

3.2.4. Scheduling Program Durations The WDF adjusted unit factors are applied against the inventory of materials to be removed in the radiologically controlled areas. The resulting work-hours are used to develop the decommissioning program schedule. The scheduling of conventional removal and dismantling activities are based upon productivity information from the RSMeans "Building Construction Cost Data 2017" publication (Reference 7.5).

The program schedule is used to determine the period-dependent costs for program management, administration, field engineering, equipment rental, contracted services, etc. The study relies upon regional or site-specific salary and wage rates for the personnel associated with the intended program.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 8 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

4. ASSUMPTIONS The current cost estimates assume that TMI-1 ceases operations in 2019 and that the shutdown is pre-planned (i.e., there is no delay in transitioning the plant and workforce from operations or in obtaining regulatory relief from operating requirements, etc.). This estimate includes additional resources to support the engineering, planning, and licensing efforts. This estimate assumes the continued operation of the spent fuel building as a wet fuel storage facility for approximately 3.2 years, until the spent fuel is transferred to the ISFSI. The ISFSI is assumed to remain operational until the DOE transfers the spent fuel offsite. The estimates also include the dismantling of non-essential structures and limited restoration of the site.

4.1. GENERAL 4.1.1. Energy The physical plant is assumed to be de-energized, except for those facilities associated with spent fuel storage. Minimal energy usage is assumed to support remaining plant staffing.

4.1.2. Emergency Planning Federal Emergency Management Agency (FEMA) fees associated with emergency planning are assumed to continue for approximately 1.3 years following the cessation of operations. After that the FEMA fees are discontinued. State and local fees associated with emergency planning are continued until all spent fuel is transferred out of the spent fuel pool.

4.1.3. 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, and subsequent reductions based on regulatory requirements.

4.1.4. Taxes Property taxes are included for all decommissioning periods. Tax payments decrease during decommissioning until reaching a minimum property tax payment for the site; this level is maintained for the balance of the decommissioning program.

4.1.5. NRC Fees NRC charges are included to support the decommissioning program. The license fee is reduced based on the NRC fees for a reactor in a decommissioning (possession-only) status. The charges associated with NRC professional services are based on the NRC hourly rate and the anticipated level of participation commensurate with the decommissioning alternative and schedule.

4.2. LABOR COSTS For purposes of this analysis, it is assumed that Exelon will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. Exelon 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, as necessary, under the direction of Exelon.

Average Exelon labor costs were provided by department or work group and include payroll overheads. DOC labor costs were based on utility labor costs with modified markups to account DECOM-2018-DCE-TMI-1 Rev. 0 Page 9 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report for employee benefits, DOC overhead, and profit. Labor costs are incorporated into the Unit Cost factor. A profile of the projected staffing level for decommissioning is provided in Table 4-2.

4.3. TRANSITION ACTIVITIES Those systems and components that are not needed for the safe storage and handling of spent fuel will be removed from service and deactivated. Hazardous fluids will be drained and removed from retired plant equipment.

Operation and maintenance costs for the spent fuel pool are included within the estimates until the spent fuel has been transferred to the ISFSI.

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.

4.4. NON-RADIOACTIVE WASTE 4.4.1. Processed Water It is assumed that all water released will meet the state and federal release limits. These estimates assume that processed water which meets state and federal release limits is disposed of without additional cost.

4.4.2. Asbestos Abatement This estimate assumes that approximately 59,935 cubic feet of asbestos or material containing asbestos will be present at the site at the time of final shutdown. The cost to properly remove and dispose of this material is included in the cost estimate.

4.4.3. Scrap and Salvage Metallic material generated is processed to the greatest extent possible to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration.

The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. No credit is taken for salvage value since it would be speculative, and any recovered value would be small in comparison to the overall decommissioning expenses.

4.5. RADIOACTIVE WASTE 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. 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 of radioactive material.

The waste material generated in the decontamination and dismantling of TMI-1 is primarily generated during Period 4, Decommissioning Operations. Material that is considered potentially contaminated is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal.

The volumes of radioactive waste generated during the various decommissioning activities are calculated based on the container size and are summarized consistent with 10 CFR 61 classifications. Appendix A provides a summary of the expected packaging costs, shipping costs, DECOM-2018-DCE-TMI-1 Rev. 0 Page 10 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report and burial costs by decommissioning activity. Table 4-1 provides the radwaste volumes by class expected to be generated during decommissioning.

4.5.1. Low-Level Radioactive Waste Disposal A significant portion of the waste material may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. The estimates reflect the savings from waste recovery/volume reduction.

All options and services currently available to Exelon were taken into consideration regarding the disposition of the various waste streams produced by the decommissioning process. Disposal fees are calculated using representative costs. The disposal costs for Class A, B and C waste were based upon a representative Exelon fleet cost. Class A waste is assumed to be disposed of at the EnergySolutions facility in Clive, Utah. This facility is not licensed to receive Class B and C wastes. Class B and C waste are assumed to be disposed of at Waste Control Specialists (WCS) facility in Andrews, Texas.

The waste volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

4.5.2. Greater Than Class C Radioactive Waste The dismantling of the components residing closest to the reactor core generally generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level waste with concentrations greater than the NRC limits for Class C waste (i.e., GTCC)). A small quantity of material generated during decommissioning will be GTCC waste; GTCC waste is expected to be a small percentage of the total waste volume. GTCC waste is assumed to be placed in spent fuel storage canisters and disposed of in a similar manner to that envisioned for spent fuel disposal.

The federal government has the responsibility for the disposal of this material. However, the federal government has not identified a cost for disposing of GTCC, a schedule for acceptance, nor acceptance criteria for this material. For purposes of this analysis, the GTCC radioactive waste is assumed to be packaged and disposed of in a similar manner as high-level waste and at a cost equivalent to that envisioned for the spent fuel.

GTCC material is assumed to be shipped directly to a DOE facility as it is generated, since the fuel will have been removed from the site prior to the start of decommissioning. GTCC costs have been segregated and included within the "Radiological Decommissioning expenditures.

4.5.3. Transportation Methods The transport of all waste material and components will be by a combination of rail, truck, and/or multi-wheeled transporter. Transportation costs for material requiring controlled disposal or processing are based upon the mileage to the respective disposal or processing site.

4.6. SITE SPECIFIC CONSIDERATIONS The cost estimates prepared for decommissioning TMI-1 consider the unique features of the site, including the NSSS, power generation systems, support services, site buildings, and ancillary facilities.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 11 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report 4.6.1. Design Conditions The curie contents of the reactor vessel and internals are derived from those listed in NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," (Reference 7.6) and adjusted for the different mass of the TMI-1 components, projected operating life, and different periods of decay.

Additional short-lived isotopes were derived from NUREG/CR-0130, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," (Reference 7.7) and benchmarked to the long-lived values from NUREG/CR-3474 (Reference 7.6).

Any control rod assemblies (CRAs) in the spent fuel pool at the cessation of operations are assumed to be disposed of along with the spent fuel at no additional cost.

4.6.2. Impact of Decommissioning Multiple Reactor Units TMI-1 shares the site with an adjacent and shutdown unit (TMI-2). This analysis does not consider any additional costs or savings that might be incurred or achieved in coordinating the decommissioning of the two units, in part, due to the unique decontamination and dismantling requirements for TMI-2.

4.6.3. Staffing Levels Staffing levels are assigned by sub-period and functional area. The types of positions and staffing levels are adjusted based upon the type of activity occurring in each sub-period.

Utility staffing levels will gradually decrease after completing the removal of physical systems.

Staffing levels and management support will vary based upon the amount and type of decommissioning work. Craft labor levels increase during systems removal and structure decontamination and then drop during the license termination survey period. Craft levels increase again during the site restoration period due to the work associated with structures demolition.

Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel. Once the fuel has been transferred to the DOE, the security organization will be further reduced.

A profile of the projected staffing level for decommissioning is provided in Table 4-2.

4.7. COMPONENT REMOVAL 4.7.1. Reactor Vessel and Internal Components The reactor pressure vessel and internal components are assumed to be segmented for disposal in shielded, reusable transportation casks. Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology. Due to the uncertainty in the viability of disposing of the reactor vessel and internals as a self-contaminated package, segmentation is assumed as a bounding condition.

4.7.2. System Components Reactor piping and other NSSS components will be removed. Specialized equipment will be brought in as necessary. With proper closure of all openings, access ways, and penetrations, some larger components may be use as their own shipping and burial containers.

Non-radioactive piping and components will be removed using methods appropriate for their potential contamination level. Non-contaminated piping and components will be removed using conventional dismantlement and removal processes.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 12 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Components will be packaged and readied for transport in accordance with the intended disposition.

4.7.3. Retired Components The estimates include the cost to dispose of:

• two retired steam generators

• one reactor coolant pump motor, and

• sections of the NSSS piping These components are expected to be in storage at the site upon the cessation of plant operations. The components are referred to as Legacy Waste in the estimate and are processed for disposal in the same manner as described for the installed units.

4.8. CONTAMINATED CONCRETE AND METAL REMOVAL Contaminated concrete and metal are considered waste and treated as described in Section 4.5, Radioactive Waste.

4.9. SPENT FUEL MANAGEMENT Since the DOE is ultimately responsible for spent fuel disposal, the cost to dispose of spent fuel is not reflected within the estimates. However, the costs for spent fuel management are included and identified separately as "Spent Fuel Management.

Exelon assumes, for the purposes of this estimate, that the DOE will accept fuel in canisters or the DOE will incur any costs to transfer the fuel to DOE-supplied containers. Once the ISFSI is completed, the spent fuel will be packaged into approximately 46 multi-purpose containers (MPCs) over the first 3.2 years after shutdown. It is assumed that this period provides the necessary cooling for the spent fuel from the final core to meet the transport and/or storage requirements for decay heat. The estimates include the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel containers from the ISFSI onto the transport vehicle.

Given the status of the DOE spent fuel program, Exelon estimates that 2030 will be the most likely year when the DOE begins spent fuel removal from the industry. Exelon assumed that the DOEs repository will have a maximum annual capacity of receiving 3,000 metric tons of uranium from the industry (Reference 7.8) and that the repository will accept spent fuel in the order in which it was removed (oldest fuel first). Additionally, Exelon assumes that it is able to re-assign its DOE spent fuel allocations between its large fleet of units to minimize on-site storage costs.

Based on the above, spent fuel is projected to remain at TMI-1 until 2035, approximately 16.2 years after the termination of operation. Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer.

4.10. INDEPENDENT SPENT FUEL STORAGE INSTALLATION 4.10.1. Construction, Operation and Maintenance Exelon has entered into a contract with a vendor for construction of an ISFSI and performing pool to pad services. The ISFSI is being constructed to support storage of all spent fuel. It is scheduled to be completed in early 2021.The ISFSI will continue to operate until such time that the transfer DECOM-2018-DCE-TMI-1 Rev. 0 Page 13 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report of spent fuel to the DOE can be completed. Operation and maintenance costs for the ISFSI are included as "Spent Fuel Management" expenditures in the estimates.

4.10.2. ISFSI Decommissioning The ISFSI site and associated facilities also must have a proposed decommissioning plan. The cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities, 2) an adequate contingency factor, and 3) the cost of meeting the criteria for unrestricted use. Appendix B provides the detailed cost estimate for the ISFSI.

4.11. SITE RESTORATION The cost for the site restoration of non-contaminated structures has been calculated and is separately presented as "Site Restoration expenditures in this report.

While some structures may be dismantled, and the costs included in the decontamination process, the dismantlement of the remaining site structures are included in the site restoration costs. All structures are assumed to be removed to a nominal depth of three feet below grade and the voids backfilled with clean debris then topped with soil. Bulk excavation of soil and material in the immediate vicinity of the reactor building is included to remove various duct banks, catch basins, and underground utilities that may exist. The site will then be graded to conform to the adjacent landscape and vegetation is established to inhibit erosion.

Site utility and service piping are abandoned in place and manholes are backfilled. Asphalt surfaces and facility roads, except for the site access road, will be broken up and the material used as backfill on site.

This estimate includes an allowance for the remediation of up to 40,011 cubic feet of contaminated soil at the site. The allowance is based on a review of TMIs 10 CFR 50.75(g) log. This portion of the estimate may be affected by continued plant operations and/or future regulatory actions.

4.12. SITE CONDITIONS FOLLOWING DECOMMISSIONING Once the NRC determines that site remediation has been performed in accordance with the LTP and the final radiation survey demonstrates that the facility is suitable for release, the NRC will terminate the facility license (or amend the license if an ISFSI is still present). Building codes and environmental regulations will dictate the remaining actions in the decommissioning process.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 14 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table 4-1: Burial Volumes and Weights by Waste Type Class / Type Volume (cf) Mass (lb)

A / Containerized 181,874 12,551,378 A / Bulk 165,902 6,547,422 B 1,252 96,000 C 518 60,743 GTCC 1,773 345,927 Total / Disposal 351,319 19,601,471 A / Processed 260,130 10,533,357 DECOM-2018-DCE-TMI-1 Rev. 0 Page 15 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table 4-2: Projected Staffing Levels for SAFSTOR Craft Utility DOC Security Other Total Period Description FTEs FTEs FTEs FTEs FTEs FTEs 0a Pre-Shutdown Planning 0.0 19.0 0.0 0.0 0.0 19.0 1a Shutdown through Transition 0.0 169.0 0.0 136.0 0.0 305.0 1c Limited D&D Activities 0.4 169.0 0.0 136.0 0.0 305.4 1d Preparation for Safe Storage 1.7 169.0 0.0 136.0 0.0 306.7 2a Dormancy with Wet Fuel 0.0 96.0 0.0 109.0 0.0 205.0 2b Dormancy with Dry Fuel 0.0 28.0 0.0 28.0 0.0 56.0 2d Fuel Shipping from ISFSI 0.0 28.0 0.0 28.0 0.0 56.0 2f Dormancy with No Fuel 0.0 8.8 0.0 15.0 0.0 23.8 3a Reactivate Site 0.0 124.0 0.0 31.3 33.0 188.3 3b Preparations for D&D 18.2 124.0 56.0 31.2 38.3 267.8 4a Large Component Removal 145.2 125.0 69.0 31.2 3.1 373.6 4c Site Decontamination (no wet fuel) 69.6 118.0 67.0 31.3 5.1 291.0 4e License Termination 78.3 47.5 36.5 12.0 4.0 178.3 5a Site Restoration 82.9 19.5 34.0 12.0 0.4 148.8 Note: The labor hour basis for this table excludes hours for some activities (e.g., spent fuel loading and transfer) since certain costs were included in the estimate without explicitly separating out labor and other costs.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 16 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

5. SCHEDULE ESTIMATE 5.1. SCHEDULE ASSUMPTIONS The schedules for the decommissioning scenarios follow 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 spent fuel management plans.

The work activity durations are based on adjusted actual person-hour estimates. Durations are established between several milestones in each decommissioning 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.

5.2. PROJECT SCHEDULE The project timeline is provided in Figure 5-1, with milestone dates based on a permanently defueled date of September 30, 2019. The Zirconium Fire window is assumed to end on January 31, 2021. The fuel pool is emptied approximately 3.2 years after shutdown. Decommissioning operations are assumed to commence so that the operating license is terminated within a 60-year period from the cessation of Unit 1 operations. The ISFSI operations continue until the DOE can complete the transfer of storage casks.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 17 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Figure 5-1: Decommissioning Timeline - SAFSTOR Approx.

Sub- Duration Period Period Description Start End (years) 0 Pre-Shutdown 1/1/2019 9/30/2019 0.7 0a Pre-Shutdown Early Planning 1/1/2019 9/30/2019 0.7 1 Shutdown through Transition 10/1/2019 1/31/2021 1.3 1a Shutdown through Transition 10/1/2019 9/30/2020 1.0 1c Limited D&D Activities 10/1/2020 12/31/2020 0.2 1d Preparation for Safe Storage 1/1/2021 1/31/2021 0.1 2 Dormancy Phase 2/1/2021 8/3/2073 52.5 2a Safe Storage Dormancy with Wet Fuel 2/1/2021 12/31/2022 1.9 2b Safe Storage Dormancy with Dry Fuel 1/1/2023 8/31/2034 11.7 2d Fuel Shipping from ISFSI 9/1/2034 12/30/2035 1.3 2f Dormancy without Fuel Onsite 12/31/2035 8/3/2073 37.6 3 Site Reactivation and Decommissioning Preparations 8/4/2073 2/3/2075 1.5 3a Reactivate Site 8/4/2073 8/3/2074 1.0 3b Preparations for D&D 8/4/2074 2/3/2075 0.5 4 Decommissioning Operations 2/4/2075 9/29/2079 4.7 4a Large Component Removal 2/4/2075 6/15/2076 1.4 4c Site Decontamination 6/16/2076 12/29/2078 2.5 4e License Termination 12/30/2078 9/29/2079 0.7 5 Site Restoration 9/30/2079 9/19/2081 2.0 5a Site Restoration 9/30/2079 9/19/2081 2.0 DECOM-2018-DCE-TMI-1 Rev. 0 Page 18 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

6. COST ESTIMATE 6.1. COST ESTIMATE RESULTS The estimates presented in this document reflect the total cost to decontaminate TMI-1, manage the spent fuel until the DOE transfers it to a federal facility, dismantle the plant and restore the site for alternative use. The cost projected to place the station in safe-storage with decommissioning deferred approximately 53.8 years, is estimated to be $1,229 million (2018 dollars). Approximately 12.9% of the total estimated cost is contingency. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant).

The majority of this cost (approximately 80.4%) is associated with the physical decontamination and dismantling of the nuclear plant so that the operating license can be terminated. Another 12.7% is associated with the management, interim storage, and eventual transfer of the spent fuel. The remaining 6.9% is for the demolition of the designated structures and restoration of the site as described Section 4.11.

Table 6-1 summarizes the estimated costs for the SAFSTOR alternative reflecting the various cost elements. Table 6-2 provides yearly expenditures broken down by cost contributor. The detailed Cost Estimate is provided in Appendix A. Appendix B provides a further breakdown of the detailed cost estimate for the ISFSI.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 19 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table 6-1: SAFSTOR Alternative (thousands of 2018 dollars)

Cost Element Total Decontamination 7,999 Removal 158,354 Packaging 21,793 Transportation 16,436 Waste Disposal 57,647 Off-Site Waste Processing 7,510 Program Management1 487,732 Security 193,944 System and Security Modifications 10,350 Spent Fuel Storage and Management2 123,036 Insurance and Regulatory Fees 52,822 Energy 23,903 Characterization and Licensing Surveys 26,419 Property Taxes 13,243 Miscellaneous Equipment 27,671 Total3 1,228,858 Cost Element Total Site Radiological Decommissioning 980,304 ISFSI Radiological Decommissioning 7,207 Spent Fuel Management 156,408 Site Restoration 84,939 Total3 1,228,858 1

Includes engineering costs.

2 Includes costs for the dry storage system components, spent fuel loading and transfer, spent fuel pool operations and maintenance and Emergency Planning fees, but excludes program management costs (staffing), security and other related costs.

3 Columns may not add up due to rounding.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 20 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table 6-2:

SAFSTOR Alternative, Unit 1 Total Annual Expenditures (thousands of 2018 dollars)

Site Radiological ISFSI Radiological Spent Fuel Site Year Decommissioning Decommissioning Management Restoration Total 2019 20,203 0 27,092 0 47,295 2020 65,584 0 30,539 0 96,123 2021 45,005 0 25,039 0 70,045 2022 37,492 0 14,753 0 52,245 2023 9,945 0 121 0 10,066 2024 8,971 0 1,123 0 10,094 2025 5,972 0 4,094 0 10,066 2026 5,972 0 4,094 0 10,066 2027 5,972 0 4,094 0 10,066 2028 5,988 0 4,105 0 10,093 2029 5,972 0 4,094 0 10,066 2030 5,972 0 4,094 0 10,066 2031 5,972 0 4,094 0 10,066 2032 5,988 0 4,105 0 10,093 2033 5,972 0 4,094 0 10,066 2034 5,967 0 7,282 0 13,248 2035 5,955 0 13,591 0 19,546 2036 5,622 0 0 0 5,622 2037 5,607 0 0 0 5,607 2038 5,607 0 0 0 5,607 2039 5,607 0 0 0 5,607 2040 5,622 0 0 0 5,622 2041 5,607 0 0 0 5,607 2042 5,607 0 0 0 5,607 2043 5,607 0 0 0 5,607 2044 5,622 0 0 0 5,622 2045 5,607 0 0 0 5,607 2046 5,607 0 0 0 5,607 2047 5,607 0 0 0 5,607 2048 5,622 0 0 0 5,622 2049 5,607 0 0 0 5,607 2050 5,607 0 0 0 5,607 2051 5,607 0 0 0 5,607 2052 5,622 0 0 0 5,622 2053 5,607 0 0 0 5,607 2054 5,607 0 0 0 5,607 DECOM-2018-DCE-TMI-1 Rev. 0 Page 21 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report Table 6-2 (cont.):

SAFSTOR Alternative, Unit 1 Total Annual Expenditures (thousands of 2018 dollars)

Site Radiological ISFSI Radiological Spent Fuel Site Year Total Decommissioning Decommissioning Management Restoration 2055 5,607 0 0 0 5,607 2056 5,622 0 0 0 5,622 2057 5,607 0 0 0 5,607 2058 5,607 0 0 0 5,607 2059 5,607 0 0 0 5,607 2060 5,622 0 0 0 5,622 2061 5,607 0 0 0 5,607 2062 5,607 0 0 0 5,607 2063 5,607 0 0 0 5,607 2064 5,622 0 0 0 5,622 2065 5,607 0 0 0 5,607 2066 5,607 0 0 0 5,607 2067 5,607 0 0 0 5,607 2068 5,622 0 0 0 5,622 2069 5,607 0 0 0 5,607 2070 5,607 0 0 0 5,607 2071 5,607 0 0 0 5,607 2072 5,622 0 0 0 5,622 2073 24,363 0 0 323 24,686 2074 60,367 0 0 1,304 61,672 2075 148,194 0 0 2,404 150,598 2076 110,540 1,547 0 1,549 113,637 2077 71,961 2,838 0 793 75,592 2078 71,804 2,822 0 789 75,415 2079 32,353 0 0 10,037 42,390 2080 131* 0 0 39,481 39,612 2081 94* 0 0 28,258 28,352 Total 980,304 7,207 156,408 84,939 1,228,858

• Radiological decommissioning completed in 2079 to meet 60-year requirement in 10 CFR 50.82(a)(3). Costs are administrative expenses associated with submitting the final report to the NRC following license termination.

DECOM-2018-DCE-TMI-1 Rev. 0 Page 22 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report

7. REFERENCES 7.1. Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors, Revision 1, Nuclear Regulatory Commission, October 2013 7.2. Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Nuclear Regulatory Commission, February 2005 7.3. "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, T.S. LaGuardia et al.

7.4. "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980, W.J. Manion and T.S. LaGuardia 7.5. "Building Construction Cost Data with RSMeans Data 2017," (From the Gordian Group),

Rockland, Massachusetts 7.6. NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, August 1984, J.C. Evans et al.

7.7. NUREG/CR-0130 and addenda, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1978, R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr.

7.8. Civilian Radioactive Waste Management System Requirements Document, DOE/RW-0406, Revision 8, September 2007 DECOM-2018-DCE-TMI-1 Rev. 0 Page 23 of 23

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A:

DETAILED COST ESTIMATE SAFSTOR Three Mile Island Nuclear Station Unit 1 DECOM-2018-DCE-TMI-1 Rev. 0

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Period 0a - Pre-Shutdown Early Planning 0a.1.03 - Environmental Report - - - - - - 35 35 35 - - -

0a.1.04 - Emergency Plan Calculations - - - - - - 61 61 61 - - -

0a.1.05 - Prepare Preliminary Decommissioning Cost Estimate - - - - - - - a - - - -

0a.1.06 - Prepare and Submit PSDAR - - - - - - - a - - - -

0a.1.07 - Perform SER and EA - - - - - - - a - - - -

0a.1.08 - Perform Site-Specific Cost Study - - - - - - - a - - - -

0a.1.09 - Prepare/Submit Defueled Technical Specifications - - - - - - - a - - - -

0a.1.10 - Prepare/Submit ODCM Specifications - - - - - - - a - - - -

0a.1.11 - Prepare/Submit Irradiated Fuel Management Plan - - - - - - - a - - - -

0a.1.12 - Notification of Cessation of Operations - - - - - - - a - - - -

0a.1.13 - Fire Program Engineering and Mod/Abandonment Support - - - - - - 403 403 403 - - -

0a.2.06 - ISFSI Pad/Casks & P2P - - - - - - 20,319 20,319 - 20,319 - -

0a.4.01 - Utility Staff Cost - - - - - - 2,856 2,856 2,856 - - -

0a.4.10 - NRC Fees - - - - - - 634 634 634 - - -

Total Period 0a Costs - - - - - - 24,308 24,308 3,989 20,319 - -

Period 0 Costs - - - - - - 24,308 24,308 3,989 20,319 - -

Period 1a - Shutdown through Transition 1a.1.01 - SAFSTOR site characterization survey - - - - - - 650 650 650 - - -

1a.1.02 - Remove fuel & source material - - - - - - - a - - - -

1a.1.03 - Notification of Permanent Defueling - - - - - - - a - - - -

1a.1.04 - Deactivate plant systems & process waste - - - - - - - a - - - -

1a.1.05 - Review plant dwgs & specs. - - - - - - - a - - - -

1a.1.06 - Perform detailed rad survey - - - - - - - a - - - -

1a.1.07 - Estimate by-product inventory - - - - - - - a - - - -

1a.1.08 - End product description - - - - - - - a - - - -

1a.1.09 - Detailed by-product inventory - - - - - - - a - - - -

1a.1.10 - Define major work sequence - - - - - - - a - - - -

1a.1.16 - Procure vacuum drying system - - - - - - - a - - - -

1a.1.18 - Activity Specifications (SAFSTOR) - - - - - - - a - - - -

1a.1.19 - Detailed Work Procedures - - - - - - - a - - - -

1a.1.20 - Drain/de-energize non-cont. systems - - - - - - - a - - - -

1a.1.21 - Drain & dry NSSS - - - - - - - a - - - -

1a.1.22 - Drain/de-energize contaminated systems - - - - - - - a - - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-1 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs 1a.1.23 - Decon/secure contaminated systems - - - - - - - a - - - -

1a.2.03 - Fuel Sipping - - - - - - 1,725 1,725 1,725 - - -

1a.2.06 - ISFSI Pad/Casks & P2P - - - - - - 29,677 29,677 - 29,677 - -

1a.4.01 - Utility Staff Cost - - - - - - 25,379 25,379 25,379 - - -

1a.4.02 - Security Staff Cost - - - - - - 13,337 13,337 13,337 - - -

1a.4.04 - Independent Corporate Oversight Organization - - - - - - 29 29 29 - - -

1a.4.05 - Insurance - - - - - - 1,533 1,533 1,533 - - -

1a.4.06 - Property Taxes - - - - - - 1,229 1,229 1,229 - - -

1a.4.07 - Plant Energy Budget - - - - - - 3,872 3,872 3,872 - - -

1a.4.08 - Heavy Equipment Rental - 662 - - - - - 662 662 - - -

1a.4.09 - Emergency Planning Fees - - - - - - 2,032 2,032 2,032 - - -

1a.4.10 - NRC Fees - - - - - - 1,573 1,573 1,573 - - -

1a.4.14 - Spent Fuel Pool O&M - - - - - - 922 922 922 - - -

1a.4.15 - Health Physics Supplies - 662 - - - - - 662 662 - - -

1a.4.17 - Disposal of DAW Generated - - 14 3 45 - - 62 62 - - -

1a.4.18 - BSC Services - - - - - - 2,817 2,817 2,817 - - -

Total Period 1a Costs - 1,324 14 3 45 - 84,776 86,161 56,484 29,677 - -

Period 1c - Limited D&D Activities 1c.2.02 - System and Security Modifications - - - - - - 10,350 10,350 10,350 - - -

1c.2.06 - ISFSI Pad/Casks & P2P - - - - - - 7,635 7,635 - 7,635 - -

1c.3.03 - Process decommissioning water waste 249 - 107 464 478 - - 1,298 1,298 - - -

1c.3.05 - Small tool allowance - 176 - - - - - 176 176 - - -

1c.4.01 - Utility Staff Cost - - - - - - 6,393 6,393 6,393 - - -

1c.4.02 - Security Staff Cost - - - - - - 3,373 3,373 3,373 - - -

1c.4.04 - Independent Corporate Oversight Organization - - - - - - 7 7 7 - - -

1c.4.05 - Insurance - - - - - - 385 385 385 - - -

1c.4.06 - Property Taxes - - - - - - 309 309 309 - - -

1c.4.07 - Plant Energy Budget - - - - - - 973 973 973 - - -

1c.4.08 - Heavy Equipment Rental - 166 - - - - - 166 166 - - -

1c.4.09 - Emergency Planning Fees - - - - - - 511 511 511 - - -

1c.4.10 - NRC Fees - - - - - - 182 182 182 - - -

1c.4.14 - Spent Fuel Pool O&M - - - - - - 232 232 232 - - -

1c.4.15 - Health Physics Supplies - 854 - - - - - 854 854 - - -

1c.4.17 - Disposal of DAW Generated - - 11 3 38 - - 52 52 - - -

1c.4.18 - BSC Services - - - - - - 708 708 708 - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-2 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Total Period 1c Costs 249 1,196 119 466 515 - 31,058 33,604 25,969 7,635 - -

Period 1d - Preparation for Safe Storage 1d.1.04 - Secure building accesses - - - - - - - a - - - -

1d.1.05 - Prepare & submit interim report - - - - - - - a - - - -

1d.2.01 - Severance - - - - - - 3,361 3,361 3,361 - - -

1d.2.06 - ISFSI Pad/Casks & P2P - - - - - - 2,077 2,077 - 2,077 - -

1d.3.03 - Process decommissioning water waste 359 - 155 669 689 - - 1,872 1,872 - - -

1d.3.05 - Small tool allowance - 5 - - - - - 5 5 - - -

1d.4.01 - Utility Staff Cost - - - - - - 2,232 2,232 2,232 - - -

1d.4.02 - Security Staff Cost - - - - - - 1,175 1,175 1,175 - - -

1d.4.04 - Independent Corporate Oversight Organization - - - - - - 2 2 2 - - -

1d.4.05 - Insurance - - - - - - 130 130 130 - - -

1d.4.06 - Property Taxes - - - - - - 104 104 104 - - -

1d.4.07 - Plant Energy Budget - - - - - - 328 328 328 - - -

1d.4.08 - Heavy Equipment Rental - 56 - - - - - 56 56 - - -

1d.4.09 - Emergency Planning Fees - - - - - - 172 172 172 - - -

1d.4.10 - NRC Fees - - - - - - 61 61 61 - - -

1d.4.14 - Spent Fuel Pool O&M - - - - - - 78 78 78 - - -

1d.4.15 - Health Physics Supplies - 256 - - - - - 256 256 - - -

1d.4.17 - Disposal of DAW Generated - - 3 1 11 - - 16 16 - - -

1d.4.18 - BSC Services - - - - - - 128 128 128 - - -

Total Period 1d Costs 359 317 158 670 700 - 9,850 12,055 9,977 2,077 -

Period 1 Costs 608 2,837 291 1,139 1,261 - 125,684 131,820 92,430 39,389 - -

Period 2a - Safe Storage Dormancy with Wet Fuel 2a.1.01 - Quarterly Inspection - - - - - - - a - - - -

2a.1.02 - Semi-annual environmental survey - - - - - - - a - - - -

2a.1.03 - Prepare reports - - - - - - - a - - - -

2a.1.04 - Bituminous roof replacement - - - - - - 360 360 360 - - -

2a.1.05 - Maintenance supplies - - - - - - 306 306 306 - - -

2a.2.01 - Severance - - - - - - 5,088 5,088 5,088 - - -

2a.2.06 - ISFSI Pad/Casks & P2P - - - - - - 37,483 37,483 - 37,483 - -

2a.4.01 - Utility Staff Cost - - - - - - 27,952 27,952 27,952 - - -

2a.4.02 - Security Staff Cost - - - - - - 21,035 21,035 21,035 - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-3 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs 2a.4.04 - Independent Corporate Oversight Organization - - - - - - 55 55 55 - - -

2a.4.05 - Insurance - - - - - - 1,021 1,021 1,021 - - -

2a.4.06 - Property Taxes - - - - - - 1,733 1,733 1,733 - - -

2a.4.07 - Plant Energy Budget - - - - - - 5,379 5,379 5,379 - - -

2a.4.09 - Emergency Planning Fees - - - - - - 2,576 2,576 2,576 - - -

2a.4.10 - NRC Fees - - - - - - 553 553 553 - - -

2a.4.12 - ISFSI Operating Costs - - - - - - 232 232 - 232 - -

2a.4.14 - Spent Fuel Pool O&M - - - - - - 1,760 1,760 1,760 - - -

2a.4.15 - Health Physics Supplies - 1,063 - - - - - 1,063 1,063 - - -

2a.4.17 - Disposal of DAW Generated - - 21 5 68 - - 94 94 - - -

2a.4.18 - BSC Services - - - - - - 2,890 2,890 2,890 - - -

Total Period 2a Costs - 1,063 21 5 68 - 108,422 109,579 71,864 37,715 - -

Period 2b - Safe Storage Dormancy with Dry Fuel 2b.1.01 - Quarterly Inspection - - - - - - - a - - - -

2b.1.02 - Semi-annual environmental survey - - - - - - - a - - - -

2b.1.03 - Prepare reports - - - - - - - a - - - -

2b.1.04 - Bituminous roof replacement - - - - - - 2,194 2,194 2,194 - - -

2b.1.05 - Maintenance supplies - - - - - - 1,866 1,866 1,866 - - -

2b.4.01 - Utility Staff Cost - - - - - - 53,583 53,583 25,454 28,129 - -

2b.4.02 - Security Staff Cost - - - - - - 38,443 38,443 27,150 11,293 - -

2b.4.04 - Independent Corporate Oversight Organization - - - - - - 335 335 335 - - -

2b.4.05 - Insurance - - - - - - 6,223 6,223 6,223 - - -

2b.4.06 - Property Taxes - - - - - - 2,103 2,103 2,103 - - -

2b.4.07 - Plant Energy Budget - - - - - - 1,230 1,230 1,230 - - -

2b.4.10 - NRC Fees - - - - - - 3,201 3,201 3,201 - - -

2b.4.12 - ISFSI Operating Costs - - - - - - 1,415 1,415 - 1,415 - -

2b.4.15 - Health Physics Supplies - 1,712 - - - - - 1,712 1,712 - - -

2b.4.17 - Disposal of DAW Generated - - 33 8 109 - - 149 149 - - -

2b.4.18 - BSC Services - - - - - - 5,054 5,054 5,054 - - -

Total Period 2b Costs - 1,712 33 8 109 - 115,647 117,508 76,671 40,837 - -

Period 2d - Fuel Shipping from ISFSI 2d.1.01 - Quarterly Inspection - - - - - - - a - - - -

2d.1.02 - Semi-annual environmental survey - - - - - - - a - - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-4 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs 2d.1.03 - Prepare reports - - - - - - - a - - - -

2d.1.04 - Bituminous roof replacement - - - - - - 250 250 250 - - -

2d.1.05 - Maintenance supplies - - - - - - 213 213 213 - - -

2d.2.01 - Severance - - - - - - 909 909 - 909 - -

2d.3.01 - Spent Fuel Capital and Transfer - - - - - - 11,788 11,788 - 11,788 - -

2d.4.01 - Utility Staff Cost - - - - - - 6,112 6,112 2,337 3,774 - -

2d.4.02 - Security Staff Cost - - - - - - 4,385 4,385 2,869 1,515 - -

2d.4.04 - Independent Corporate Oversight Organization - - - - - - 38 38 38 - - -

2d.4.05 - Insurance - - - - - - 710 710 710 - - -

2d.4.06 - Property Taxes - - - - - - 220 220 220 - - -

2d.4.07 - Plant Energy Budget - - - - - - 140 140 140 - - -

2d.4.10 - NRC Fees - - - - - - 365 365 365 - - -

2d.4.12 - ISFSI Operating Costs - - - - - - 161 161 - 161 - -

2d.4.15 - Health Physics Supplies - 195 - - - - - 195 195 - - -

2d.4.17 - Disposal of DAW Generated - - 4 1 12 - - 17 17 - - -

2d.4.18 - BSC Services - - - - - - 576 576 576 - - -

Total Period 2d Costs - 195 4 1 12 - 25,866 26,079 7,931 18,147 - -

Period 2f - Dormancy without Fuel Onsite 2f.1.01 - Quarterly Inspection - - - - - - - a - - - -

2f.1.02 - Semi-annual environmental survey - - - - - - - a - - - -

2f.1.03 - Prepare reports - - - - - - - a - - - -

2f.1.04 - Bituminous roof replacement - - - - - - 7,069 7,069 7,069 - - -

2f.1.05 - Maintenance supplies - - - - - - 6,013 6,013 6,013 - - -

2f.4.01 - Utility Staff Cost - - - - - - 69,035 69,035 69,035 - - -

2f.4.02 - Security Staff Cost - - - - - - 84,756 84,756 84,756 - - -

2f.4.05 - Insurance - - - - - - 20,053 20,053 20,053 - - -

2f.4.06 - Property Taxes - - - - - - 6,203 6,203 6,203 - - -

2f.4.07 - Plant Energy Budget - - - - - - 3,962 3,962 3,962 - - -

2f.4.10 - NRC Fees - - - - - - 9,405 9,405 9,405 - - -

2f.4.15 - Health Physics Supplies - 4,070 - - - - - 4,070 4,070 - - -

2f.4.17 - Disposal of DAW Generated - - 76 19 253 - - 348 348 - - -

Total Period 2f Costs - 4,070 76 19 253 - 206,496 210,914 210,914 - - -

Period 2 Costs - 7,041 133 33 442 - 456,431 464,079 367,380 96,699 - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-5 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Period 3a - Reactivate Site 3a.1.01 - Prepare preliminary decommissioning cost - - - - - - 215 215 215 - - -

3a.1.02 - Review plant dwgs & specs. - - - - - - 759 759 759 - - -

3a.1.03 - Perform detailed rad survey - - - - - - - a - - - -

3a.1.04 - End product description - - - - - - 165 165 165 - - -

3a.1.05 - Detailed by-product inventory - - - - - - 215 215 215 - - -

3a.1.06 - Define major work sequence - - - - - - 1,238 1,238 1,238 - - -

3a.1.07 - Perform SER and EA - - - - - - 512 512 512 - - -

3a.1.08 - Perform Site-Specific Cost Study - - - - - - 825 825 825 - - -

3a.1.11 - Prepare dismantling sequence - - - - - - 396 396 396 - - -

3a.1.12 - Plant prep. & temp. svces - - - - - - 3,903 3,903 3,903 - - -

3a.1.13 - Design water clean-up system - - - - - - 231 231 231 - - -

3a.1.14 - Rigging/Cont. Cntrl Envlps/tooling/etc. - - - - - - 2,645 2,645 2,645 - - -

3a.1.15 - Procure casks/liners & containers - - - - - - 203 203 203 - - -

3a.1.17 - Activity Specifications - - - - - - 6,565 6,565 5,778 - 786 -

3a.4.01 - Utility Staff Cost - - - - - - 25,995 25,995 25,995 - - -

3a.4.02 - Security Staff Cost - - - - - - 4,194 4,194 4,194 - - -

3a.4.05 - Insurance - - - - - - 533 533 533 - - -

3a.4.06 - Property Taxes - - - - - - 165 165 165 - - -

3a.4.07 - Plant Energy Budget - - - - - - 1,587 1,587 1,587 - - -

3a.4.08 - Heavy Equipment Rental - 660 - - - - - 660 660 - - -

3a.4.10 - NRC Fees - - - - - - 385 385 385 - - -

3a.4.15 - Health Physics Supplies - 579 - - - - - 579 579 - - -

3a.4.17 - Disposal of DAW Generated - - 11 3 38 - - 52 52 - - -

Total Period 3a Costs - 1,239 11 3 38 - 50,729 52,020 51,234 - 786 -

Period 3b - Preparations for D&D 3b.1.01 - Detailed Work Procedures - - - - - - 5,321 5,321 4,289 - 1,032 -

3b.2.02 - Site Characterization - - - - - - 4,657 4,657 4,657 - - -

3b.3.02 - Decon Equipment 1,052 - - - - - - 1,052 1,052 - - -

3b.3.06 - DOC staff relocation expenses - - - - - - 1,762 1,762 1,762 - - -

3b.3.07 - Pipe cutting equipment - 1,380 - - - - - 1,380 1,380 - - -

3b.4.01 - Utility Staff Cost - - - - - - 13,104 13,104 13,104 - - -

3b.4.02 - Security Staff Cost - - - - - - 2,114 2,114 2,114 - - -

3b.4.03 - DOC Staff Cost - - - - - - 6,606 6,606 6,606 - - -

3b.4.05 - Insurance - - - - - - 269 269 269 - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-6 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs 3b.4.06 - Property Taxes - - - - - - 83 83 83 - - -

3b.4.07 - Plant Energy Budget - - - - - - 800 800 800 - - -

3b.4.08 - Heavy Equipment Rental - 333 - - - - - 333 333 - - -

3b.4.10 - NRC Fees - - - - - - 194 194 194 - - -

3b.4.15 - Health Physics Supplies - 320 - - - - - 320 320 - - -

3b.4.16 - Decon Supplies 44 - - - - - - 44 44 - - -

3b.4.17 - Disposal of DAW Generated - - 7 2 22 - - 30 30 - - -

Total Period 3b Costs 1,096 2,032 7 2 22 - 34,910 38,069 37,037 - 1,032 -

Period 3 Costs 1,096 3,271 18 4 60 - 85,639 90,088 88,270 - 1,818 -

Period 4a - Large Component Removal 4a.1.01 - Nuclear Steam Supply System Removal 293 33,713 17,582 8,918 38,965 40 715 100,226 100,226 - - -

4a.1.02 - Removal of Major Equipment - 2,271 269 66 - 386 - 2,993 2,993 - - -

4a.1.03 - Scaffolding in support of decommissioning - 1,266 15 5 5 19 - 1,310 1,310 - - -

4a.1.04 - Disposal of Plant Systems - 12,124 376 886 303 4,601 - 18,289 14,995 - 3,294 -

4a.1.05 - Cascading Costs from Clean Building Demolition - 919 - - - - - 919 919 - - -

4a.2.02 - Remedial Action Surveys - - - - - - 2,447 2,447 2,447 - - -

4a.2.05 - Legacy Waste 69 48 152 88 243 - - 599 599 - - -

4a.2.06 - Turbine Bldg. GIC Waste Disposal - - - 64 - 324 - 388 388 - - -

4a.2.08 - Asbestos Abatement - 9,761 29 915 2,881 - - 13,585 13,585 - - -

4a.3.03 - Process decommissioning water waste 7 - 8 34 35 - - 84 84 - - -

4a.3.05 - Small tool allowance - 359 - - - - - 359 323 - 36 -

4a.4.01 - Utility Staff Cost - - - - - - 35,887 35,887 35,887 - - -

4a.4.02 - Security Staff Cost - - - - - - 5,723 5,723 5,723 - - -

4a.4.03 - DOC Staff Cost - - - - - - 21,668 21,668 21,668 - - -

4a.4.04 - Independent Corporate Oversight Organization - - - - - - 39 39 39 - - -

4a.4.05 - Insurance - - - - - - 727 727 727 - - -

4a.4.06 - Property Taxes - - - - - - 225 225 225 - - -

4a.4.07 - Plant Energy Budget - - - - - - 2,057 2,057 2,057 - - -

4a.4.08 - Heavy Equipment Rental - 3,485 - - - - - 3,485 3,485 - - -

4a.4.10 - NRC Fees - - - - - - 859 859 859 - - -

4a.4.13 - Liquid Radwaste Processing Equipment/Services - - - - - - 645 645 645 - - -

4a.4.15 - Health Physics Supplies - 2,875 - - - - - 2,875 2,875 - - -

4a.4.16 - Decon Supplies 121 - - - - - - 121 121 - - -

4a.4.17 - Disposal of DAW Generated - - 103 25 341 - - 470 470 - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-7 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Total Period 4a Costs 489 66,821 18,534 11,000 42,773 5,371 70,991 215,980 212,650 - 3,330 -

Period 4c - Site Decontamination 4c.1.01 - Prepare/submit License Termination Plan - - - - - - 676 676 676 - - -

4c.1.02 - Receive NRC approval of termination plan - - - - - - - a - - - -

4c.1.03 - Scaffolding in support of decommissioning - 1,900 23 7 7 29 - 1,966 1,966 - - -

4c.1.04 - Disposal of Plant Systems - 14,425 1,920 2,039 5,649 1,639 - 25,671 23,656 - 2,015 -

4c.1.05 - Decontamination of Site Buildings 3,574 2,046 183 629 1,288 71 - 7,792 7,792 - - -

4c.1.06 - Remove spent fuel racks 637 73 182 112 359 - - 1,364 1,364 - - -

4c.2.02 - Remedial Action Surveys - - - - - - 4,555 4,555 4,555 - - -

4c.2.03 - Operational Tools & Equipment - - 19 49 - 209 - 277 277 - - -

4c.2.04 - Contaminated Soil Remediation - 74 59 257 2,984 - - 3,375 3,375 - - -

4c.2.05 - Underground Services Excavation - 1,749 - - - - - 1,749 1,749 - - -

4c.2.06 - License Termination Survey Planning - - - - - - 2,753 2,753 2,753 - - -

4c.2.07 - License Termination ISFSI - 162 139 976 2,287 - 3,643 7,207 - - - 7,207 4c.3.03 - Process decommissioning water waste 19 - 22 94 97 - - 232 232 - - -

4c.3.05 - Small tool allowance - 349 - - - - - 349 349 - - -

4c.3.08 - Decommissioning Equipment Disposition - - 151 53 48 193 - 445 445 - - -

4c.4.01 - Utility Staff Cost - - - - - - 63,315 63,315 63,315 - - -

4c.4.02 - Security Staff Cost - - - - - - 10,652 10,652 10,652 - - -

4c.4.03 - DOC Staff Cost - - - - - - 39,348 39,348 39,348 - - -

4c.4.04 - Independent Corporate Oversight Organization - - - - - - 73 73 73 - - -

4c.4.05 - Insurance - - - - - - 1,354 1,354 1,354 - - -

4c.4.06 - Property Taxes - - - - - - 419 419 419 - - -

4c.4.07 - Plant Energy Budget - - - - - - 3,023 3,023 3,023 - - -

4c.4.08 - Heavy Equipment Rental - 6,671 - - - - - 6,671 6,671 - - -

4c.4.10 - NRC Fees - - - - - - 1,598 1,598 1,598 - - -

4c.4.13 - Liquid Radwaste Processing Equipment/Services - - - - - - 1,201 1,201 1,201 - - -

4c.4.15 - Health Physics Supplies - 3,846 - - - - - 3,846 3,846 - - -

4c.4.16 - Decon Supplies 1,576 - - - - - - 1,576 1,576 - - -

4c.4.17 - Disposal of DAW Generated - - 110 27 366 - - 503 503 - - -

Total Period 4c Costs 5,806 31,295 2,810 4,244 13,086 2,139 132,611 191,991 182,769 - 2,015 7,207 Period 4e - License Termination 4e.1.01 - ORISE confirmatory survey - - - - - - 227 227 227 - - -

4e.1.02 - Terminate license - - - - - - - a - - - -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-8 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs 4e.2.01 - Severance - - - - - - 999 999 999 - - -

4e.2.02 - License Termination Survey - - - - - - 11,130 11,130 11,130 - - -

4e.3.06 - DOC staff relocation expenses - - - - - - 1,762 1,762 1,762 - - -

4e.4.01 - Utility Staff Cost - - - - - - 8,251 8,251 8,251 - - -

4e.4.02 - Security Staff Cost - - - - - - 1,310 1,310 1,310 - - -

4e.4.03 - DOC Staff Cost - - - - - - 6,727 6,727 6,727 - - -

4e.4.04 - Independent Corporate Oversight Organization - - - - - - 22 22 22 - - -

4e.4.05 - Insurance - - - - - - 400 400 400 - - -

4e.4.06 - Property Taxes - - - - - - 124 124 124 - - -

4e.4.07 - Plant Energy Budget - - - - - - 238 238 238 - - -

4e.4.10 - NRC Fees - - - - - - 473 473 473 - - -

4e.4.15 - Health Physics Supplies - 860 - - - - - 860 860 - - -

4e.4.17 - Disposal of DAW Generated - - 8 2 26 - - 36 36 - - -

Total Period 4e Costs - 860 8 2 26 - 31,662 32,558 32,558 - - -

Period 4 Costs 6,295 98,977 21,351 15,246 55,885 7,510 235,265 440,529 427,977 - 5,345 7,207 Period 5a - Site Restoration 5a.1.01 - Site Closeout Activities - 1,022 - - - - 257 1,280 257 - 1,022 -

5a.1.05 - Demolition of Remaining Site Buildings - 22,715 - - - - - 22,715 - - 22,715 -

5a.2.02 - Concrete Crushing - 1,595 - 13 - - - 1,608 - - 1,608 -

5a.2.03 - Construction Debris - 135 - - - - - 135 - - 135 -

5a.2.04 - Demolition and Site Restoration ISFSI - 2,091 - - - - 323 2,415 - - 2,415 -

5a.2.05 - Intake Cofferdam - 425 - - - - - 425 - - 425 -

5a.2.07 - Cooling Tower Demolition - 10,702 - - - - 1,007 11,709 - - 11,709 -

5a.3.05 - Small tool allowance - 315 - - - - - 315 - - 315 -

5a.4.01 - Utility Staff Cost - - - - - - 8,939 8,939 - - 8,939 -

5a.4.02 - Security Staff Cost - - - - - - 3,447 3,447 - - 3,447 -

5a.4.03 - DOC Staff Cost - - - - - - 17,180 17,180 - - 17,180 -

5a.4.06 - Property Taxes - - - - - - 326 326 - - 326 -

5a.4.07 - Plant Energy Budget - - - - - - 313 313 - - 313 -

5a.4.08 - Heavy Equipment Rental - 7,228 - - - - - 7,228 - - 7,228 -

Total Period 5a Costs - 46,228 - 13 - - 31,793 78,033 257 - 77,776 -

Period 5 Costs - 46,228 - 13 - - 31,793 78,033 257 - 77,776 -

DECOM-2018-DCE-TMI-1 Rev. 0 Page A-9 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX A: DETAILED COST ESTIMATE Three Mile Island Unit 1 SAFSTOR Decommissioning Cost Estimate (thousands of 2018 dollars)

Off-site Waste Waste Site Radiological Spent Fuel Site ISFSI Radiological Decon Removal Packaging Transport Disposal Processing Other Total Decommissioning Management Restoration Decommissioning Activity Description Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Costs Total Costs to Decommission 7,999 158,354 21,793 16,436 57,647 7,510 959,119 1,228,858 980,304 156,408 84,939 7,207 End Notes:

All costs are shown in thousands of 2018 $s a - indicates that this activity is performed by decommissioning staff A cell containing - indicates a zero value DECOM-2018-DCE-TMI-1 Rev. 0 Page A-10 of A-10

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX B:

ISFSI DECOMMISSIONING COST ESTIMATE Three Mile Island Nuclear Station Unit 1 DECOM-2018-DCE-TMI-1 Rev. 0

Three Mile Island Nuclear Station, Unit 1 Decommissioning Cost Analysis Report APPENDIX B: ISFSI DECOMMISSIONING COST ESTIMATE LLRW Burial Oversight and Removal Packaging Transport Disposal Other Total Volume Craft Contractor Class A Activity Description Costs Costs Costs Costs Costs Costs** (ft3) Manhours Manhours Decommissioning Contractor Planning (characterization, specs, and procedures) 246 246 1,024 Decontamination 129 112 781 1,829 42 2,894 30,626 1,312 License Termination (radiological surveys) 1,170 1,170 8,824 Subtotal 129 112 781 1,829 1,458 4,309 30,626 10,136 1,024 Supporting Costs NRC and NRC Contractor Fees and Costs 379 379 776 Insurance 68 68 Property Taxes 338 338 Plant Energy Budget 47 47 Security Staff Cost 266 266 4,958 Oversight Staff Cost 358 358 3,761 Subtotal 1,456 1,456 9,495 Total (w/o contingency) 129 112 781 1,829 2,914 5,765 30,626 10,136 10,519 Total (w/25% contingency) 162 139 976 2,287 3,642 7,207

• Costs in thousands of 2018 dollars

• • Total Costs may not add due to rounding DECOM-2018-DCE-TMI-1 Rev. 0 Page B-1 of B-1

Attachment 2:

Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow

Attachment 2:

Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow (December 31, 2018 dollars, thousands)

BOY BOY EOY Radiological Trust Trust Fund Trust Trust Decommissioning Fund Value Fund Fund Year Cost Value<bl Less Cost Earnings<c> Value 2019 $20,490 $669,617 $649,127 $12,983 $662,110 2020 $66,516 $662,110 $595,594 $11,912 $607,505 2021 $45,645 $607,505 $561,860 $11,237 $573,098 2022 $38,025 $573,098 $535,073 $10,701 $545,774 2023 $10,086 $545,774 $535,688 $10,714 $546,402 2024 $9,099 $546,402 $537,303 $10,746 $548,049 2025 $6,057 $548,049 $541,992 $10,840 $552,832 2026 $6,057 $552,832 $546,775 $10,936 $557,711 2027 $6,057 $557,711 $551,654 $11,033 $562,687 2028 $6,073 $562,687 $556,614 $11,132 $567,746 2029 $6,057 $567,746 $561,689 $11,234 $572,923 2030 $6,057 $572,923 $566,866 $11,337 $578,203 2031 $6,057 $578,203 $572,146 $11,443 $583,589 2032 $6,073 $583,589 $577,516 $11,550 $589,066 2033 $6,057 $589,066 $583,009 $11,660 $594,670 2034 $6,052 $594,670 $588,618 $11,772 $600,390 2035 $6,040 $600,390 $594,351 $11,887 $606,238 2036 $5,702 $606,238 $600,536 $12,011 $612,546 2037 $5,686 $612,546 $606,860 $12,137 $618,997 2038 $5,686 $618,997 $613,311 $12,266 $625,577 2039 $5,686 $625,577 $619,891 $12,398 $632,289 2040 $5,702 $632,289 $626,587 $12,532 $639,119 2041 $5,686 $639,119 $633,432 $12,669 $646,101 2042 $5,686 $646,101 $640,415 $12,808 $653,223 2043 $5,686 $653,223 $647,537 $12,951 $660,488 2044 $5,702 $660,488 $654,786 $13,096 $667,881 2045 $5,686 $667,881 $662,195 $13,244 $675,439 2046 $5,686 $675,439 $669,753 $13,395 $683,148 2047 $5,686 $683,148 $677,462 $13,549 $691,011 2048 $5,702 $691,011 $685,309 $13,706 $699,015 2049 $5,686 $699,015 $693,329 $13,867 $707,195 2050 $5,686 $707,195 $701,509 $14,030 $715,539 2051 $5,686 $715,539 $709,853 $14,197 $724,050 1

Attachment 2:

Three Mile Island Nuclear Station - Unit 1 Annual Decommissioning Fund Cash Flow (December 31, 2018 dollars, thousands)

BOY BOY EOY Radiological Trust Trust Fund Trust Trust Decommissioning Fund Value Fund Fund Year Cost Value<bl Less Cost Earnings<c> Value 2052 $5,702 $724,050 $718,348 $14,367 $732,715 2053 $5,686 $732,715 $727,029 $14,541 $741,570 2054 $5,686 $741,570 $735,883 $14,718 $750,601 2055 $5,686 $750,601 $744,915 $14,898 $759,813 2056 $5,702 $759,813 $754,111 $15,082 $769,193 2057 $5,686 $769,193 $763,507 $15,270 $778,777 2058 $5,686 $778,777 $773,091 $15,462 $788,553 2059 $5,686 $788,553 $782,866 $15,657 $798,524 2060 $5,702 $798,524 $792,822 $15,856 $808,678 2061 $5,686 $808,678 $802,992 $16,060 $819,052 2062 $5,686 $819,052 $813,366 $16,267 $829,633 2063 $5,686 $829,633 $823,947 $16,479 $840,426 2064 $5,702 $840,426 $834,724 $16,694 $851,418 2065 $5,686 $851,418 $845,732 $16,915 $862,647 2066 $5,686 $862,647 $856,960 $17,139 $874,100 2067 $5,686 $874,100 $868,413 $17,368 $885,782 2068 $5,702 $885,782 $880,080 $17,602 $897,681 2069 $5,686 $897,681 $891,995 $17,840 $909,835 2070 $5,686 $909,835 $904,149 $18,083 $922,232 2071 $5,686 $922,232 $916,545 $18,331 $934,876 2072 $5,702 $934,876 $929,174 $18,583 $947,758 2073 $24,709 $947,758 $923,049 $18,461 $941,510 2074 $61,226 $941,510 $880,284 $17,606 $897,890 2075 $150,301 $897,890 $747,589 $14,952 $762,541 2076 $113,681 $762,541 $648,859 $12,977 $661,837 2077 $75,862 $661,837 $585,975 $11,719 $597,694 2078 $75,687 $597,694 $522,007 $10,440 $532,447 2079 $32,813 $532,447 $499,634 $9,993 $509,626 2080 $133 $509,626 $509,494 $10,190 $519,684 2081 $95 $519,684 $519,589 $10,392 $529,981 Total<a> $1,001,552 (a) Cash flows may not add due to rounding (b) Reflects $0 annual amount remaining to be collected (c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i) 2