NG-20-0027, Post Shutdown Decommissioning Activities Report

Post Shutdown Decommissioning Activities Report

ML20094F603
Person / Time
Site:	Duane Arnold
Issue date:	04/02/2020
From:	Dean Curtland NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-20-0027
Download: ML20094F603 (117)

Text

NEXTera ENERGY .

DU.ANE ARNOLD April 2, 2020 NG-20-0027 10 CFR 50 .82 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Renewed Facility Operating License No. DPR-49 Docket No. 50-331 Post Shutdown Decommissioning Activities Report

Reference:

Letter from NEDA (D. Curtland) to USNRC, "Certification of Permanent Cessation of Power Operations," NG-19-0136, dated March 2, 2020 (ML20062E489)

Pursuant to 10 CFR 50.82(a)(4), NextEra Energy Duane Arnold, LLC (NEDA), on behalf of itself and Central Iowa Power Cooperative and Corn Belt Power Cooperative, is submitting a Post Shutdown Decommissioning Activities Report (PSDAR) for the Duane Arnold Energy Center (DAEC). In the referenced letter, NEDA notified the NRC of its intention to permanently cease power operations at DAEC on October 30, 2020.

The enclosed PSDAR has been developed consistent with Regulatory Guide 1.185, Revision 1, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report." The PS DAR includes a description of the planned decommissioning activities, schedule for their accomplishment, a site-specific decommissioning cost estimate, and a discussion that provides the basis for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate, previously issued, environmental impact statements. The PSDAR also includes a discussion of the schedule and projected costs associated with spent fuel management and site restoration activities. Funding for spent fuel management activities is being addressed in a separate submittal as an update to the DAEC Spent Fuel Management Plan, pursuant to 10 CFR 50 .54(bb).

In accordance with 10 CFR 50.82(a)(4)(i), a copy of the DAEC PS DAR is being provided to the designated State of Iowa official.

There are no new regulatory commitments made in this submittal. If you have any questions regarding these exemption requests, please contact J. Michael Davis, Licensing Manager at 319-851-7032.

NextEra Energy Duane Arnold, LLC 3277 DAEC Road, Palo, IA 52324

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Post Shutdown Decommissioning Activities Report Docket No. 50-331 NG-20-0027 Page 2 of 2 Dean Curtland Site Director, Duane Arnold Energy Center NextEra Energy Duane Arnold , LLC Enclosure cc: Regional Administrator, USNRC, Region Ill Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT DUANE ARNOLD ENERGY CENTER April 2, 2020

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Table of Contents ACRONYMS 4

1.0 INTRODUCTION

AND

SUMMARY

5 1.1 Introduction 5 1.2 Background 5 1.3 Summary of Decommissioning Alternatives 6

2.0 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES 7 2.1 Detailed Description 7 2.2 Discussion of Decommissioning Activities 11 2.2.1 Preparations for Dormancy 11 2.2.2 Dormancy 13 2.2.3 Decommissioning Preparations 13 2.2.4 Decommissioning Operations (Decontamination and Dismantlement) 13 2.2.5 Site Restoration 15 2.3 General Decommissioning Considerations 15 2.3.1 Major Decommissioning Activities 15 2.3.2 Decontamination and Dismantlement Activities 16 2.3.3 Radioactive Waste Management 16 2.3.4 Removal of Mixed Wastes 17 2.3.5 Site Characterization 17 2.3.6 Groundwater Protection and Radiological Decommissioning Records Program 17 2.3. 7 Changes to Management and Staffing 18 Page 2 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 3.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES 19 3.1 Description of Planned Decommissioning Activities 19 4.0 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS 20 5.0 ENVIRONMENTAL IMPACTS 22 5.1 Environmental Impact of DAEC Decommissioning 22 5.2 Environment Impacts of License Termination - NUREG-1496 33 5.3 Discussion of Decommissioning in the Supplemental Environmental Impact Statement (SEIS) 33 5.4 Additional Considerations 33 5.5 Conclusions 34

6.0 REFERENCES

35 List of Tables Table 2.1 Decommissioning Schedule and Plant Status Summary 9 Table 2.2 Decommissioning Costs Summary 10 List of Attachments Attachment 1 2018 Decommissioning Cost Estimate for the Duane Arnold Energy Center Attachment 2 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Page 3 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report ACRONYMS ALARA As Low As Reasonably Achievable D&D Decontamination and Dismantlement activities DAEC Duane Arnold Energy Center. Also see NEDA.

DCE Decommissioning Cost Estimate DOE Department of Energy DTF Decommissioning Trust Fund EPA Environmental Protection Agency FSS Final Status Survey, also referred to as Final Status (radiation) Survey GEIS Generic Environmental Impact Statement (NUREG-0586)

GTCC Greater Than Class C (waste)

GW Ground Water ISFSI Independent Spent Fuel Storage Installation LLRW Low Level Radioactive Waste LLRWSF Low Level Radioactive Waste Storage Facility LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NEDA NextEra Energy Duane Arnold, LLC. Also see DAEC.

NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission ODAM Offsite Dose Assessment Manual OSHA Occupational Safety and Health Administration REMP Radiological Environmental Monitoring Program SAFSTOR Safe Storage SEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437), Supplement 42, "Regarding Duane Arnold Energy Center" (referred to as the "Supplemental Environmental Impact Statement")

SHPO State Historical Preservation Office TS Technical Specifications UFSAR Updated Final Safety Analysis Report Page 4 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report

1.0 INTRODUCTION

AND

1.1 INTRODUCTION

In accordance with the requirements of Title 1O of the Code of Federal Regulations (CFR) 50.82, "Termination of license," paragraph (a)(4)(i), this report constitutes the Post-Shutdown Decommissioning Activities Report (PSDAR) for the Duane Arnold Energy Center (DAEC). This PSDAR contains the following:

1. A description of the planned decommissioning activities along with a schedule for their accomplishment.

2. A discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements.

3. A site-specific decommissioning cost estimate (DCE), including the projected cost of managing irradiated fuel and the post-decommissioning site restoration cost.

The PSDAR has been developed consistent with Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report," (Reference 1). This report is based on currently available information and the plans discussed herein may be modified as additional information becomes available or conditions change. As required by 10 CFR 50.82(a)(7), NextEra Energy Duane Arnold (NEDA) will notify the Nuclear Regulatory Commission (NRC) in writing, with copies sent to the State of Iowa, before performing any I

decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR, including changes that significantly increase the decommissioning cost.

1.2 BACKGROUND

DAEC is located adjacent to the Cedar River approximately 2.5 miles northeast of the town of Palo, Iowa. The closest major city is Cedar Rapids with its outer boundary 8 miles to the southeast. The site, containing approximately 500 acres, is entirely owned by NEDA.

DAEC employs a General Electric boiling water reactor nuclear steam supply system licensed to generate 1,912 megawatts - thermal (MWth). The principal structures of DAEC are the reactor and turbine buildings, radwaste building, low-level radwaste storage facility, intake structure, switchyard, offgas stack, pump house, cooling towers, and administration buildings.

On January 27, 2006, FPL Energy Duane Arnold, LLC (a wholly owned subsidiary of FPL Energy) purchased 70% ownership of DAEC from Interstate Power & Light company. Operating authority was also transferred from Nuclear Management Company to FPL Duane Arnold, LLC.

On April 16, 2009, the name "FPL Energy Duane Arnold, LLC" was legally changed to "NextEra Energy Duane Arnold, LLC." The current operating license for DAEC will expire on midnight February 21, 2034.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report On July 27, 2018, NextEra Energy Duane Arnold (NEDA) announced its plans to cease operation of DAEC in the fourth quarter of 2020. On January 18, 2019, NEDA formally notified the Nuclear Regulatory Commission of its intent to cease operation (Reference 2).

1.3

SUMMARY

OF DECOMMISSIONING ALTERNATIVES The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," (GEIS) (Reference 3). The three general methods evaluated are summarized as follows:

• DEGON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

• SAFSTOR: After the plant is shut down and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

• ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report

2.0 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES 2.1 DETAILED DESCRIPTION NEDA will commence decommissioning of the DAEC after final plant shutdown on October 30, 2020. A list of milestone events in the decommissioning process is shown in Table 2.1. NEDA currently plans to decommission the DAEC using the SAFSTOR method.

SAFSTOR is broadly defined in Section 1.3 of this report. Use of the SAFSTOR method will include management of the spent fuel on site. This is necessary because the DOE has not, yet, met its obligations to remove and take possession of the spent fuel. To explain the basis for projecting the cost of managing spent nuclear fuel, a discussion of spent fuel management activities for the site is included herein.

The initial decommissioning activities to be performed after plant shutdown will entail preparing the plant for a period of safe-storage (also referred to as dormancy). This will include de-fueling the reactor and transferring the fuel into the Spent Fuel Pool; draining fluids and de-energizing systems; reconfiguring the electrical distribution, ventilation, heating, and fire protection systems; and minor deconstruction activities. Systems needed for continued operation of the Spent Fuel Pool may be reconfigured for operational efficiency. The dormancy period will begin when the buildings and systems have been sufficiently prepared for long-term safe storage and all spent fuel has been transferred to the Independent Spent Fuel Storage Installation (ISFSI) for dry storage.

During dormancy, the DAEC will be staffed with personnel that will monitor, maintain, and provide security for the ISFSI and plant facilities. Staffing and configuration requirements are expected to change during the phases of the decommissioning process for transitioning to dormancy. The required staffing levels during this transition period are principally dependent upon the status of the spent fuel being stored on-site. This can be characterized as one of three spent fuel conditions, as follows:

• Wet and dry storage of spent fuel

• On-site dry storage of all spent fuel

• No fuel on site Spent fuel will remain in the Spent Fuel Pool until it meets the criteria for transfer, and the spent fuel can be transferred in an efficient manner to the ISFSI. After all fuel has been transferred to the ISFSI, the pool and supporting systems will be drained and de-energized for the remainder of the dormancy period. The spent fuel will be stored in the ISFSI until transfer to the DOE.

Decontamination and dismantlement (D&D) activities will be scheduled to enable the license to be terminated within 60 years after permanent cessation of operations. Following completion of the D&D' activities and termination of the NRC license, site restoration will be performed to a condition such that the site may be re-used for beneficial purposes.

For the purposes of a current decommissioning cost estimate, it is assumed that remaining structures are to be demolished and the site restored to an appropriately graded and vegetated condition (green field).

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Decommissioning activities will be performed in accordance with written, reviewed, and approved site procedures. There are no identified or anticipated decommissioning activities that are unique to the DAEC site outside the bounds considered in the GEIS.

Radiological and environmental programs will be maintained throughout the decommissioning process to ensure occupational, public health and safety, and environmental compliance.

Radiological programs will be conducted in accordance with the facility's revised Technical Specifications, Facility Operating License, Updated Final Safety Analysis Report (UFSAR),

Radiological Environmental Monitoring Program (REMP), and the Offsite Dose Assessment Manual (ODAM). Non-radiological Environmental Programs will be conducted in accordance with applicable requirements and permits.

Tables 2.1 and 2.2 provide summaries of the schedule/plant status and costs for decommissioning the DAEC. The major decommissioning activities and the general sequence of activities are discussed in more detail in the sections that follow.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Table 2.1 Decommissioning Schedule and Plant Status Summary Plant Approximate Status/Decommissioning Start End Duration Activities (Years)

Pre-Shutdown Pre-Shutdown Planning Early 2019 October 2020 Preparations for Dormancy Plant Shutdown/Defueling October 2020 December 2020 0.17 Outage Preparations for Dormancy (completion of SAFSTOR January 2020 August2024 4.56 preparations)

Fuel Status Wet and Dry Fuel Storage October 2020 August 2023 2.82 Dry Fuel Storage August 2023 October 2059 36.15 Dormancy With No Fuel On Site November 2059 September 2080 20.83 Dismantling &

Decontamination (D&D)

Decommissioning Planning September 2073 March 2075 1.44 Internals Segmentation and Site March 2075 July 2076 1.36 Preparations Major Components and July 2076 May 2078 1.83 Systems Removal Building Decontamination May 2078 January 2080 1.62 License Termination January 2080 September 2080 0.71 Site Restoration Site Restoration January 2080 May 2080 0.34 Page 9 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning ,Activities Report Table 2.2 Decommissioning Costs Summary (Thousands of 2018 dollars)

License Spent Fuel Site Decommissioning Periods Termination Management Restoration Pre-Shutdown Pre-Shutdown Planning 11,509 443 Transition to Dormancy Wet and Dry Fuel Storage 91,762 129,601 Dry Fuel Storage 19,315 2,941 Dormancy Dormancy Period 102,171 121,582 Decommissioning Preparations Planning for D&D 50,840 1,640 Decommissioning Operations Internals Segmentation and Site 120,283 Preparations Major Component and Systems 221, 117 4,898 Removal and ISFSI demolition Building Decontamination 103,240 License Termination 4,451 Site Restoration Site Restoration 36,447 Totals a 724,688 261, 106 36,447 a Columns may not add due to rounding.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 2.2 DISCUSSION OF DECOMMISSIONING ACTIVITIES The following narrative describes the basic activities associated with decommissioning the DAEC. The site specific DCE (Attachment 1) is divided into phases or periods based upon major milestones within the project or significant changes in the annual projected expenditures.

The following sub-sections correspond to the five major decommissioning periods within the estimate.

2.2.1 Preparations for Dormancy The NRC defines SAFSTOR as, "A method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use."

The facility is left largely intact (during the dormancy period), with most structures maintained in a stable condition. Some outbuildings not related to power production may be removed. While fuel remains in the Fuel Pool, systems that support required functions (such as, spent fuel cooling, HVAC, Emergency Plan, or site security) are maintained operational. Systems that are not required to support required functions are drained, de-energized, and secured. Some cleaning/removal of loose contamination and/or fixation and sealing of remaining contamination is performed and access to contaminated areas is maintained secure to provide controlled access for inspection and maintenance.

The process of placing the plant in safe-storage will include, but is not limited to, the following activities:

• Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.

• Revision of technical specifications, plans and operating procedures appropriate to the operating conditions and requirements.

• Characterization of the facility and major components as may be necessary to plan and prepare for the dormancy phase.

• Management of the Spent Fuel Pool and reconfiguring Fuel Pool support systems so that draining and de-energizing may commence in other areas of the plant.

• Deactivation (de-energizing and or draining) of systems that are no longer required during the dormancy period.

• Processing and disposal of water and water filter and treatment media (resins) not required to support dormancy operation.

• Removal of select structures to improve safety and monitoring.

• Disposition of incidental waste that may be present and is ready to ship prior to the start of the dormancy period, such as excess tools and equipment and waste produced while deactivating systems and preparing the facility for dormancy.

• Reconfiguration of power, lighting, heating, ventilation, fire protection, and any other services needed to support long-term storage and periodic plant surveillance and maintenance.

• Stabilization by fixing or removing loose incidental surface contamination to facilitate future building access and plant maintenance Page 11 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report The following is a general discussion of the planned reconfiguration expected after plant shutdown.

2.2.1.1 Electrical Systems The electrical systems will undergo a series of reconfigurations between shutdown and the time all spent fuel has been transferred to dry storage. The reconfigurations will be performed to reduce operating and maintenance expenses, while maintaining adequate power for station loads, and backup power for Spent Fuel Pool-related systems and critical security equipment.

2.2.1.2 Mechanical Systems Following shutdown, as applicable, fluid filled systems will be drained and abandoned, and resins removed based on an evaluation of system category, functionality, and plant configuration. The plant configuration and functionality of each system within the plant configuration as it evolves will determine when a system can be drained and abandoned.

2.2.1.3 Ventilation and Heating Systems Ventilation will be reconfigured to support remaining systems and habitability. Fluid filled systems will either be drained or have freeze protection installed, with the building heating system secured. The ventilation system will be reconfigured to maintain building temperature to support habitability and to support the function of Fuel Pool Cooling systems, Fire Protection systems, and Security systems while they are required.

2.2.1.4 Fire Protection Systems Fire Protection systems will be reconfigured based on a fire risk analysis. The fire risk analysis provides a comprehensive evaluation of the facility's fire risk, the fire protection capability to mitigate hazards that pose a risk, and the ability to protect spent fuel and other radioactive materials from potential fire induced releases. The fire risk analysis will be reevaluated and revised as necessary to reflect the unique or different fire protection issues and strategies associated with decommissioning. It is expected that as the plant's systems are drained and the combustible loading footprint shrinks, the Fire Protection requirements will be reduced.

2.2.1.5 Maintenance of Systems Critical to Decommissioning There are no mechanical systems that will be critical to the final decommissioning process. As such, mechanical systems will be abandoned after all spent fuel has been transferred to Dry Fuel Storage, with the exception of systems required to maintain habitability during dormancy.

The site power distribution system will be abandoned with some exceptions, such as motor control centers that are required to support ventilation and lighting.

In order to support final dismantlement of the plant, temporary services, including but not limited to electrical and cranes, will be required.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 2.2.2 Dormancy Activities required during transition to the dormancy period while spent fuel is stored in the Fuel Pool will be substantially different than those activities required during dormancy, when all fuel is in dry fuel storage.

Early activities include operating and maintaining the Spent Fuel Pool and its associated systems, and transferring spent fuel from the pool to the ISFSI. Spent fuel transfer is expected to be complete in 2023. After the fuel transfer is completed, the Spent Fuel Pool and systems will be drained and de-energized for long-term storage.

Dormancy activities will include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general maintenance of buildings, freeze protection heating, ventilation of buildings for periodic habitability, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.

Security during the dormancy period will be conducted primarily to safeguard the spent fuel on site and prevent unauthorized entry. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security. Additionally, an environmental surveillance program will be carried out during the dormancy period to monitor for radioactive material in the environment. Appropriate procedures will be established and initiated for potential releases that exceed prescribed limits. The on-going environmental surveillance program will consist of a version of the program in effect during normal plant operations that will be modified to reflect the plant's conditions and risks at the time.

During the dormancy period, additional activities will include transferring the spent fuel from the ISFSI to the DOE. NEDA will seek to remove fuel from the site when the DOE commences performance. Following the spent fuel removal, the ISFSI pad and associated facilities will be decommissioned along with the power block structures during the decontamination and dismantlement phases.

2.2.3 Decommissioning Preparations Prior to the commencement of decommissioning operations, preparations may be undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a site characterization, and the assembly of a decommissioning management organization. This would likely include the development of work plans, specifications and procedures.

2.2.4 Decommissioning Operations (Decontamination and Dismantlement)

Following the preparations for decommissioning, physical decommissioning activities will take place. This includes the removal and disposal of contaminated and activated components and structures, leading to the termination of the 10 CFR 50 operating license. Although much of the radioactivity will decrease during the dormancy period due to decay of radionuclides, the internal components of the reactor vessel will still exhibit radiation dose rates that will likely Page 13 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report require remote sectioning under water due to the presence of long-lived radionuclides. Portions of the biological shield wall may also be radioactive due to the presence of activated trace elements. It is assumed that radioactive contamination on SSC surfaces will not have decayed to levels that will permit unrestricted release. These surfaces will be surveyed and items dispositioned in accordance with the license termination release criteria.

Significant decommissioning activities in this phase include, but not limited to:

• Reconfiguration and modification of site structures and facilities, as needed, to support decommissioning operations. Modifications may also be required to the reactor or other buildings to facilitate movement of equipment and materials, support the segmentation of the reactor vessel and reactor vessel internals, and for large component removal.

• Design and fabrication of temporary and longer-term shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

• Procurement or leasing of shipping cask, cask liners, and industrial packages for the disposition of low-level radioactive waste.

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

• Removal of piping and components no longer essential to support decommissioning operations.

• Removal of reactor head and segmentation as necessary.

• Removal and segmentation of the dryer, separator, and top guide. Segmentation will maximize the loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls.

• Disassembly and segmentation of the remaining reactor internals, including the core materials left above the core support guide, core shroud, fuel support castings, core support guide, and control rod drive guide tubes. Some material is expected to exceed Class C disposal requirements. As such, the segments will be packaged in modified fuel storage canisters for future geologic disposal.

• Segmentation of the reactor vessel as necessary. Cutting operations will likely be performed using remotely operated equipment within a contamination control envelope.

The water level is maintained to minimize the working area dose rates.

• Removal of the steel liners from the drywell, torus, refueling pool and Spent Fuel Pool, disposing of the activated and/or contaminated sections as radioactive waste.

• Removal of the activated portions of the concrete biological shield and accessible contaminated concrete surfaces. Removal of the recirculation piping and pumps for material recovery and controlled disposal.

• Surface soil, sub-surface media and groundwater will meet the unrestricted use criteria in 10 CFR 20.1402.

• Underground piping (or similar items) and associated soil will be removed as necessary to meet license termination criteria.

At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) will be submitted to the NRC. That plan will include: a site characterization, Page 14 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report description of the remaining dismantling I removal activities, plans for remediation of remaining radioactive materials, developed site-specific Derived Concentration Guideline Levels, methodology and criteria for the final status (radiation) survey (FSS), designation of the end use of the site, an updated cost estimate to complete the decommissioning, and associated environmental concerns.

The FSS plan will identify the radiological surveys to be performed once the decontamination activities are completed and will be developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Reference 6). The MARSSIM "provides information on planning, conducting, evaluating, and documenting building and surface soil final status radiological surveys for demonstrating compliance with dose or risk-based regulations or standards." The MARSSIM uses the Data Quality Objective/Analysis processes tool for data collection activities and provides a basis for balancing decision uncertainty with available resources. This document incorporates statistical approaches to survey design and data evaluation. It also identifies commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied.

Once the FSS is complete, the results will be submitted to the NRC, along with a request for termination of the NRC license.

NEDA may release unaffected portions of the site on a partial site release basis, as they become available, before all site decommissioning work has been completed.

2.2.5 Site Restoration After the NRC terminates the license, site restoration activities will be performed, at the licensee's discretion. NEDA currently assumes that remaining structures will be removed to restore the site to an appropriately graded and vegetated condition (green field). Suitable backfill material will be used where necessary and appropriate erosion controls established.

Non-contaminated concrete remaining after the demolition activities may be used for backfilling subsurface voids or may be transported to an offsite area for appropriate disposal as construction debris.

2.3 GENERAL DECOMMISSIONING CONSIDERATIONS 2.3.1 Major Decommissioning Activities As defined in 10 CFR 50.2, "Definitions," a "major decommissioning activity" is "any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than class C waste in accordance with§ 61.55 of this chapter." The following discussion provides a summary of the major decommissioning activities currently planned for decommissioning of the DAEC. These activities are envisioned to occur in the Dismantling and Decontamination Period. The schedule may be modified as conditions dictate.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Prior to starting a major decommissioning activity, the affected components will be surveyed and decontaminated, as required in order to minimize worker exposure, and a plan will be developed for the activity. Shipping casks and other equipment necessary to conduct major decommissioning activities will be procured.

The initial major decommissioning activity inside the containment building will be the removal, packaging, and disposal of systems and components attached to the reactor in order to provide access and allow it to be removed.

The reactor vessel internals will be removed from the reactor vessel and segmented, if necessary, for packaging, transport, and disposal, or to separate greater than Class C (GTCC) waste. Internals classified as GTCC waste will be segmented and packaged into containers similar to spent fuel canisters for transfer to the DOE. Removal of the reactor vessel follows the removal of the reactor internals. Industry experience indicates that there may be several options available for the removal and disposal of the reactor vessel (i.e., segmentation or disposal as an intact package). The viability of these options will be analyzed as a part of future planning and preparation activities. If segmented, it is likely that the work would be performed remotely, using a contamination control envelope.

Other major decommissioning activities that would be conducted include the removal and disposal of the turbine, condenser, main steam piping, feed water piping, pumps and heaters, Spent Fuel Pool support equipment, and neutron activated/contaminated concrete or metals.

In addition to the reactor and large components discussed above, all other plant components will be removed from the Reactor, Turbine, and associated support buildings, radiologically surveyed, and dispositioned appropriately.

2.3.2 Decontamination and Dismantlement Activities The overall objective of D&D is to ensure that radioactively contaminated or activated materials will be removed from the site to allow the site to be released for unrestricted use. This is achieved in part by radioactive decay during the SAFSTOR (dormancy) period which will significantly reduce the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement. The disposition of remaining radioactive materials will be accomplished by the decontamination and/or dismantlement of contaminated structures.

This may be accomplished by decontamination in place, off-site processing of the materials, or direct disposal of the materials as radioactive waste. A combination of these methods may be utilized. The methods chosen will be those deemed most appropriate for the particular circumstances. Low-level radioactive waste (LLRW) will be managed in accordance with approved procedures and commercial disposal facility requirements. This includes characterizing contaminated materials, packaging, transporting and disposal at a licensed LLRW disposal facility.

2.3.3 Radioactive Waste Management A major component of the decommissioning work scope for the DAEC is the packaging, transportation and disposing of primarily contaminated/activated equipment, piping, concrete, Page 16 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report and in some cases soil. A waste management plan will be developed to incorporate the most prudent disposal strategy, consistent with regulatory requirements and disposal/processing options for each waste type at the time of the D&D activities. Decommissioning wastes from the DAEC may be disposed of at any available licensed LLRW facilities that engage in an agreement with NEDA. Radioactive wastes from the DAEC will be transported by licensed transporters.

The waste management plan will be based on the evaluation of available methods and strategies for processing, packaging, and transporting radioactive waste in conjunction with the available disposal facility options and associated waste acceptance criteria.

2.3.4 Removal of Mixed Wastes If mixed wastes are generated, they will be managed in accordance with applicable Federal and State regulations.

If generated, mixed wastes will be transported by authorized and licensed transporters and shipped to authorized and licensed facilities. If technology, resources, and approved processes are available, the processes will be evaluated to render the mixed waste non-hazardous.

2.3.5 Site Characterization During the decommissioning process, site characterization will be performed in which radiological, regulated, and hazardous wastes will be identified, categorized, and quantified.

Surveys will be conducted to establish the contamination and radiation levels throughout the site. This information will be used in developing procedures, surveys and sampling plans to ensure that hazardous, regulated, and radiologically contaminated areas are remediated and to ensure that worker exposure is controlled. As decontamination and dismantlement work proceeds, surveys will be conducted to maintain a current site characterization and to ensure that decommissioning activities are adjusted accordingly.

As part of the site characterization process, a neutron activation analysis calculation study of the reactor internals and the reactor vessel will be performed. Using the results of this analysis (along with benchmarking surveys), neutron irradiated components will be classified (projected for the future D&D time-frame) in accordance with 10 CFR 61, "Licensing requirements for land disposal of radioactive waste." The results of the analysis form the basis of the plans for removal, segmentation, packaging and disposal.

2.3.6 Groundwater Protection and Radiological Decommissioning Records Program A groundwater (GW) protection program currently exists at the DAEC in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, "Industry Groundwater Protection Initiative - Final Guidance Document" (Reference 10). This program is directed by procedures and will continue during decommissioning.

A site hydrology study was completed as part of the ongoing monitoring program. Groundwater monitoring wells were installed at the plant to identify any radiological contaminants. In 2012, Page 17 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report measureable amounts of tritium began to be detected in some of the groundwater monitoring wells in an area immediately adjacent to the south side of the Turbine and Reactor buildings, continuing for a short distance to the southeast on the plant property. This area has been and continues to be mitigated through mitigation wells.

As a result of the ongoing mitigation and given a tritium half-life of 12.3 years, no tritium mitigation is expected to be required at the end of the SAFSTOR period. NEDA will also continue to maintain the existing radiological decommissioning records program required by 10 CFR 50. 75(g). The program is directed by procedures. None of the events noted in records required by 10 CFR 50. 75(g) indicate the presence of long-lived radionuclides in sufficient concentrations to preclude unrestricted release under 10 CFR 20.1402, "Radiological Criteria for Unrestricted Use", at the end of the SAFSTOR period.

2.3.7 Changes to Management and Staffing Throughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. Staffing levels and qualifications of personnel used to monitor and maintain the plant during the various periods after plant shutdown will be subject to appropriate Technical Specification and Emergency Plan requirements. Some of the staffing requirements may be filled by contract personnel used to provide general services, staff augmentation or replace permanent staff. These staffing levels, however, do not include contractor staffing that may be used to carry out the future fuel movements, plant modifications in preparation for SAFSTOR, and the D&D/license termination/site restoration work. The monitoring and maintenance staff will be comprised of radiation protection, radiological environmental monitoring program, plant engineering and craft workers as appropriate for the anticipated work activities.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 3.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES

3.1 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES NEDA intends to pursue the decommissioning of DAEC utilizing a SAFSTOR methodology and will make appropriate filings with the NRC to obtain authority prior to beginning radiological decommissioning. The SAFSTOR method involves removal of radioactively contaminated or activated material from the site following an extended period of dormancy. Work activities associated with the planning and preparation period have begun during the final operating cycle of the plant and will continue through 2023. The schedule of spent fuel management and major decommissioning activities is provided in Table 2.1. Additional detail is provided in the site-specific DCE (Attachment 1). Dates in the site-specific DCE are based on the October 30, 2020, shutdown date and have been adjusted as reflected in Table 2.1.

The schedule accounts for spent fuel being stored in the ISFSI until the assumed date of transfer to the DOE.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 4.0 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS 10 CFR 50.82(a)(8)(iii) requires that a site-specific decommissioning cost estimate be prepared and submitted within two years following permanent cessation of operations. 10 CFR 50.82(a)(4)(i) requires that the PSDAR contain a site-specific decommissioning cost estimate including the projected costs of managing irradiated fuel. A site-specific decommissioning cost analysis has been prepared for DAEC, which also provides projected costs of managing spent fuel, as well as non-radiological decommissioning and site restoration costs, accounted for separately.

The site-specific decommissioning cost analysis is provided in Attachment 1 and fulfills the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). A summary of the site-specific decommissioning cost analysis and projected cost of managing spent fuel is provided in Table 2-1. A summary of the annual costs, earnings, and trust balances associated with decommissioning, spent fuel management, and site restoration will be provided in an update to the Irradiated Fuel Management Plan being submitted as a separate document in accordance with 10 CFR 50.54(bb).

The methodology used to develop the site-specific decommissioning cost analysis follows the basic approach originally advanced by the Atomic Industrial Forum in their program to develop a standardized model for decommissioning cost estimates. The results of this program were published as AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Reference 12). This document presents a unit cost factor method for estimating direct activity costs, simplifying the estimating process. The unit cost factors used in the study reflect the latest available data at the time of the study concerning worker productivity during decommissioning.

10 CFR 50.82(c) states that for a facility that has permanently ceased operation before the expiration of its license, the collection period for any shortfall of funds will be determined, upon application by the licensee, on a case-by-case basis taking into account the specific financial situation of each licensee. At the time that operations cease at DAEC, sufficient funds will be available in the plant decommissioning fund to complete the planned decommissioning activities.

10 CFR 50.82(a)(6)(ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2, that would result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. No such activities have been identified, since adequate funding exists based on the site-specific decommissioning cost analysis in .

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 4.1 COST ESTIMATE ADJUSTMENTS The DAEC SAFSTOR schedule and the associated site-specific cost estimate summarized in Tables 2.1and2.2 and detailed in the DCE (Attachment 1) is reported in 2018 dollars using current pricing. NEDA will update the DAEC DCE as required by procedure and regulation. In calculating projected earnings, NEDA will apply a compounded 2% real rate of return on the trust fund per 10 CFR 50.75 (e). In accordance with 10 CFR 50.82(a)(8)(v)-(vii), NEDA will provide annual reports projecting the cost to complete decommissioning and spent fuel management costs.

4.2 MEANS OF ADJUSTING ASSOCIATED FUNDING LEVELS During the SAFSTOR period, the site-specific DCE will be periodically updated in compliance with NEDA procedures and applicable regulatory requirements. In accordance with 10 CFR 50.82(a)(8)(v), decommissioning funding assurance will be reviewed and reported to the NRG annually during the SAFSTOR period. The latest site-specific DCE adjusted for inflation, in accordance with applicable regulatory requirements, will be used to demonstrate funding assurance. In addition, actual radiological and spent fuel management expenses will be included in the annual report in accordance with the applicable regulatory requirements. If the funding assurance demonstration shows the DTF is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in Regulatory Guide 1.159 (Reference 11) will be put in place.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 5.0 ENVIRONMENTAL IMPACTS To support the PSDAR environmental impacts review, the environmental effects of decommissioning activities planned for DAEC, as currently understood, were evaluated to determine if potential environmental impacts are bounded by previously issued environmental impact statements. 10 CFR 50.82(a)(4)(i) requires that the PSDAR include" ... a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." To determine if the estimated potential environmental impacts associated with DAEC decommissioning activities are bounded, the potential environmental impacts were compared to those in:

• NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (Reference 3) (Referred to as the GEIS).

• Atomic Energy Commission, Final Environmental Statement related to the Operation of Duane Arnold Energy Center (Reference 7).

• NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 42, Regarding Duane Arnold Energy Center (Reference 4) (Referred to as the SEIS).

As required, site-specific assessments were conducted for threatened and endangered species and environmental justice. Site-specific assessments were also performed for offsite land use and impacts to aquatic ecology, terrestrial ecology, and cultural and historic resources for decommissioning activities beyond the operational area. For the purpose of assessing decommissioning environmental impacts, the operational area at DAEC consists of roughly the southern half of the approximately 500 acres on the west bank of a north-south reach of the Cedar River, approximately 2.5 miles north-northeast of the town of Palo. DAEC uses only a small portion of the area for power production.

The levels of significance assigned to site-specific environmental impacts are classified as small, moderate, or large, as defined by NRC in the Decommissioning GEIS (Reference 3, pgs.

4-1 and 4-2). NEDA has concluded that the environmental impacts associated with planned DAEC decommissioning activities are bounded by the impacts addressed by previously issued environmental impact statements. NEDA's decommissioning plans are consistent with the methods assumed by NRC in the GEIS. No unique site-specific features or unique aspects of the planned decommissioning have been identified.

5.1 ENVIRONMENTAL IMPACT OF DAEC DECOMMISSIONING The following is a summary of the reasons for reaching the conclusion that the environmental impacts of decommissioning DAEC are bounded by the GEIS. Each environmental impact standard in the GEIS is listed along with an explanation as to why NEDA concludes the GEIS analysis bounds the impacts of DAEC decommissioning on that standard. As a general matter, DAEC is smaller than the reference boiling water reactor used in the GEIS to evaluate the environmental impacts of decommissioning, and is therefore bounded by those assessments.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Further, no unique site-specific features or unique aspects of the planned decommissioning have been identified.

5.1.1 Onsite and Offsite Land Use As part of decommissioning activities, NEDA will utilize onsite land for laydown, staging, or handling of equipment. The DAEC has sufficient area onsite that has been previously disturbed (due to construction or operations activities) upon which to conduct all of these decommissioning activities. Section 4.3.1 of the GEIS concluded that the impacts on land use are not detectable or small for facilities having only onsite land use changes as a result of large component removal, structure dismantlement, and low-level waste packaging and storage.

NEDA will not require addition or modification to existing transportation links that could impact offsite land use. Based on the GEIS, the experience of plants that are being decommissioned has not included any needs for additional land offsite. Consistent with this determination, NEDA does not anticipate any changes in land use beyond the site boundary during decommissioning.

Therefore, NEDA concludes that the impacts of DAEC decommissioning on onsite/offsite land use are bounded by the GEIS.

5.1.2 Water Use After plant shutdown, the operational demand for cooling water and makeup water will dramatically decrease. Additionally, after the plant is shut down and defueled, the amount of water used by the service water system will be much less than during normal operation of the plant. The need for cooling water will continue to decrease as the heat load of spent fuel in the Spent Fuel Pool declines due to radioactive decay and as spent fuel is relocated from the Spent Fuel Pool to the ISFSI. During plant shutdown, the use of potable water will decrease commensurate with the expected decrease in plant staffing levels. For these reasons, Section 4.3.2.2 of the GEIS concluded that water use at decommissioning nuclear reactor facilities is significantly smaller than water use during operation.

The GEIS also concluded that water use during the decontamination and dismantlement phase will be greater than that during the storage phase. However, there are no unique aspects associated with the decommissioning of DAEC and water use for such activities as flushing piping, dust abatement, etc. Consequently, DAEC water use impacts were addressed by the evaluation of the reference facility in the GEIS.

Therefore, NEDA concludes that the impacts of DAEC decommissioning on water use are bounded by the GEIS.

5.1.3 Water Quality This section considers water quality impacts of nonradioactive material for both surface and groundwater during the decommissioning process. Table E-3 of the GEIS identifies decommissioning activities that may affect water quality. These activities include system deactivation activities (draining, flushing, and liquid processing) as well as facility decontamination and dismantlement activities (water spraying for dust suppression). The GEIS also emphasizes the need to minimize water infiltration during the SAFSTOR period.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report NEDA has chosen to decommission DAEC using the SAFSTOR method. During the SAFSTOR planning and actual storage periods, storm water runoff and drainage paths will be maintained in their current configuration. Regulatory mandated programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process.

Federal, state and local regulations and permits pertaining to water quality will remain in effect and no significant changes to water supply reliability are expected. The National Pollutant Discharge Elimination System (NPDES) permit, which regulates surface water discharges from the site will remain in place as will the Groundwater Discharge Permit for the DAEC Wastewater Treatment Facility. The GEIS makes a generic conclusion that for all facilities, the impacts on nonradioactive aspects of water quality are small. NEDA concludes that the impacts of DAEC decommissioning on water quality are bounded by the GEIS.

5.1.4 Air Quality There are many types of decommissioning activities listed in Section 4.3.4 of the GEIS that have the potential to affect air quality. NRC considered the potential for adverse impacts from these activities, the greatest of which would be fugitive dust, for the range of decommissioning plants and generically determined air quality impacts to be small. For those activities applicable to the SAFSTOR option, NEDA does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality. Also, reasonable and appropriate control measures such as wetting down unpaved areas, wetting of soil piles, covering loads and staging areas, and seeding of bare areas would be implemented to minimize fugitive dust. In addition, federal, state and local regulations pertaining to air quality will remain in effect to regulate emissions associated with criteria air pollutants, hazardous air pollutants, ozone-depleting gases and fugitive dust. Therefore, NEDA concludes that the impacts of DAEC decommissioning on air quality are bounded by the GEIS.

5.1.5 Aquatic Ecology Aquatic ecology encompasses the plants and animals in the Cedar River and wetlands near DAEC. Aquatic ecology also includes the interaction of those organisms with each other and the environment. Section 4.3.5 of the GEIS evaluates both the direct and indirect impacts from decommissioning on aquatic ecology.

Direct impacts can result from activities such as the removal of shoreline structures or active river dredging. The DAEC shoreline structures are similar to those of sites listed in Table E-2 of the GEIS, and there are no apparent discriminators based on characteristics (size and location) listed in Table E-5 of the GEIS. Removal of the intake structure and discharge canal will be conducted in accordance with best management practices outlined in government permits.

Intake structure dredging will be greatly reduced due to the diminished residual heat removal requirements.

As previously discussed in Section 5.1.2, the amount of cooling water withdrawn from the Cedar River will significantly decrease thus reducing the potential impacts from impingement and entrainment of aquatic species. Additionally, any significant potential for sediment runoff or erosion on disturbed areas will be controlled in accordance with best management practices outlined in the storm water permit. The GEIS concluded that impacts on aquatic ecology would be small if disturbance of lands beyond the operational areas of the plant. NEDA does not anticipate disturbance of lands beyond the current operational areas of the plant, so there Page 24 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report should not be any new impacts to aquatic ecology from runoff associated with land disturbance activities. Therefore, NEDA concludes that the impacts of DAEC decommissioning on aquatic ecology are consistent with the GEIS.

5.1.6 Terrestrial Ecology Terrestrial ecology considers the plants and animals in the vicinity of DAEC as well as the interaction of those organisms with each other and the environment. Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plant and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation. Section 4.3.6 of the GEIS evaluates the potential impacts from both direct and indirect disturbance of terrestrial ecology.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

NEDA does not anticipate any decommissioning activities will disturb habitat beyond the industrial area of the plant. All dismantlement, demolition, and waste staging activities are expected to be conducted within this industrial area of the site. Also the EPA controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust or noise. Any construction activities that would disturb one acre or greater of soil would require a permit from the EPA prior to proceeding with the activity. The storm water permit would contain best management practices to control sediment and the effects of erosion associated with the construction activity. Fugitive dust emissions would be controlled through the judicious use of water spraying.

The GEIS concluded that impacts to terrestrial ecology would be small if habitat was not disturbed beyond the operational area of the plant. NEDA, therefore, concludes that decommissioning of DAEC is consistent with the GEIS.

5.1. 7 Threatened and Endangered Species The GEIS lists stabilization, large component removal, decontamination and dismantlement (removal of contaminated soil), and structure dismantlement as activities with potential to impact threatened and endangered species.

Section 4.3.7 in the GEIS did not make a generic determination on the impact of decommissioning on threatened and endangered species, noting that impacts to these species are expected to be minor and non-detectable when activities are confined to the site operational area.

Impacts are to be determined on a site-specific basis, paying particular attention to activities outside of the developed operational area. Noise and dust generation from construction activity and increased truck traffic, rather than direct impacts such as habitat destruction, are the primary concerns.

With respect to the threatened and endangered aquatic species, the environmental impacts during decommissioning are expected to be minimal. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with best management practices outlined in permits issued by Linn County, the Iowa Department of Sovereign Lands, and the U.S. Army Corps of Engineers.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report , Table 1 identifies state and federally listed species potentially occurring in the vicinity of DAEC based on site-specific assessments conducted in support of license renewal, information collected from the Iowa DNR Iowa Natural Areas Inventory (INAI) interactive website. The Iowa Natural Areas Inventory (INAI) interactive website combines current technologies to bring threatened, endangered, special concern, and selected rare species data and maps to professional natural resource managers as well as to the public.

Section 4.3.7 of the GEIS also suggests that care be exercised in conducting decommissioning activities after an extended SAFSTOR period because there is a greater potential for rare species to colonize the disturbed portion of the site. However as previously discussed, administrative controls and federal and state regulations that will remain in effect would ensure that mitigation measures are implemented as appropriate to protect wildlife.

Based on the site-specific findings summarized above, NEDA concludes that DAEC decommissioning activities are unlikely to adversely affect any threatened or endangered species. Therefore, additional mitigation is not warranted. However, as decommissioning plans mature, if changes in threatened and endangered species listings or critical habitat designations occur that affect this conclusion, NEDA will update the PSDAR in accordance with applicable NRC regulations.

5.1.8 Radiological The GEIS considered radiological doses to workers and members of the public when evaluating the potential consequences of decommissioning activities.

Occupational Dose The occupational radiation exposure to DAEC plant personnel will be maintained As Low as Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR Part 20 during decommissioning. The need for plant personnel to routinely enter radiological areas to conduct maintenance, calibration, inspection, and other activities associated with an operating plant will be reduced, thus it is expected that the occupational dose to plant personnel will significantly decrease after the plant is shut down and defueled.

NEDA has elected to decommission DAEC using the SAFSTOR alternative. It is expected that the occupational dose required to complete the decommissioning activities at DAEC will be within the range of SAFSTOR dose estimates (326 - 834 person-rem) provided in Table 4-1 of the GEIS. This is based on the fact that DAEC is bounded by the BWRs evaluated in the GEIS as discussed in Appendix G, and because the ALARA program will be maintained to ensure that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits.

Public Dose Section 4.3.8 of the GEIS considered doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-15 of the GEIS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower. The GEIS also concluded that the collective dose and the dose to the maximally exposed individual from decommissioning activities are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report The expected radiation dose to the public from DAEC decommissioning activities will be maintained within regulatory limits and below comparable levels when the plant was operating through the continued application of radiation protection and contamination controls combined with the reduced source term available in the facility. Therefore, NEDA concludes that the impacts of DAEC decommissioning on public dose are small and are bounded by the GEIS.

5.1.9 Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety after DAEC is shut down and defueled is considerably lower than the likelihood of a release from the plant during power operation. This is because the majority of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor.

Furthermore, handling of spent fuel assemblies will continue to be controlled under work procedures designed to minimize the likelihood and consequences of a fuel handling accident.

In addition, emergency plans and procedures will remain in place to protect the health and safety of the public while the possibility of significant radiological releases exists.

Section 4.3.9 of the GEIS assessed the range of possible radiological accidents during decommissioning and separated them into two general categories; fuel related accidents and non-fuel related accidents. Fuel related accidents have the potential to be more severe and zirconium fire accidents, in particular, could produce offsite doses that exceed EPA's protective action guides (Reference 5). As part of its effort to develop generic, risk-informed requirements for decommissioning, the NRC staff performed analysis of the offsite radiological consequences of beyond-design-basis Spent Fuel Pool accidents using fission product inventories at 30 and 90 days and 2, 5, and 10 years. The results of the study indicate that the risk at Spent Fuel Pools is low and well within the Commission's Quantitative Health Objectives. The generic risk is low primarily due to the very low likelihood of a zirconium fire.

The potential for decommissioning activities to result in radiological releases not involving spent fuel (i.e., releases related to decontamination, dismantlement, and waste handling activities) will be minimized by use of procedures designed to minimize the likelihood and consequences of such releases.

Therefore, NEDA concludes that the impacts of DAEC decommissioning on radiological accidents are small and are bounded by the previously issued GEIS.

5.1.1 O Occupational Issues Occupational issues are related to human health and safety. Section 4.3.10 of the GEIS evaluated physical, chemical, ergonomic, and biological hazards and concluded that impacts due to occupational issues would be small for all plants based on strict adherence to NRC and Occupational Safety and Health Administration (OSHA) safety standards, practices and procedures. NEDA has reviewed these occupational hazards in the GEIS and concluded that the decommissioning approach chosen for DAEC poses no unique hazards from those evaluated in the GEIS. NEDA will continue to maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state and local occupational safety standards and requirements continue to be met. Therefore, NEDA concludes that the impacts of DAEC decommissioning on occupational issues are bounded by the GEIS.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 5.1.11 Cost Decommissioning costs for DAEC are discussed in Section 4.0 and in Attachment 1 to this report.

Section 4.3.11 of the GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act requirement. Therefore, a bounding analysis is not applicable.

5.1.12 Socioeconomics Decommissioning of DAEC is expected to result in minor socioeconomic impacts. As DAEC transitions from an operating plant to a shutdown plant and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff will result in decreases in revenues available to support the local economy and local tax authorities. Some employee relocation will occur. In 2018, there were approximately 600 employees working at DAEC. The majority of DAEC employees live in Linn County (2017 population: 224, 115). These relocations are not expected to impact the local cost of housing or availability of public services.

Section 4.3.12 of the GEIS evaluated changes in workforce and population, changes in local tax revenues, and changes in public services. The evaluation also examined plants that permanently shut down early and selected the SAFSTOR option. The GEIS determined that this situation is likely to have negative impacts. However, the GEIS concluded that socioeconomic impacts are neither detectable nor destabilizing and that mitigation measures are not warranted. Therefore, after review of the GEIS, NEDA concludes that the impacts of DAEC decommissioning on socioeconomic impacts are bounded by the GEIS analysis.

5.1.13 Environmental Justice Executive Order 12898, dated February 16, 1994, directs Federal executive agencies to consider environmental justice under the National Environmental Policy Act. It is designed to ensure that low-income and minority populations do not experience disproportionately high and adverse human health or environmental effects because of Federal actions.

Section 4.9.7 of the SEIS (Reference 4) analyzed 2000 census data within 50 miles of DAEC to identify minority and low income populations. The SEIS analysis determined there were 25 block groups having minority population percentages that exceeded the State percentage by 20 percentage points or more, or that were more than 50 percent minority. The majority of these block groups are concentrated in urban areas with high population densities in Black Hawk County, Linn County, and Johnson County. There are also minority population groups in Muscatine County and Tama County. The closest high density minority population to DAEC is located in the city of Cedar Rapids, Iowa.

There were also 15 block groups within the 50-mile radius of DAEC that exceeded the State average for low income households by 20 percentage points or more, or that were more than 50 percent low-income. The majority of census block groups with low-income populations were located in urban areas with high population densities in Black Hawk County, Johnson County, Page 28 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report and Linn County. The nearest high density low-income population to DAEC is located in Cedar Rapids, Iowa.

Section 4.13.3 of the GEIS reviewed environmental justice decommissioning impacts related to land use, environmental and human health, and socioeconomics. NEDA does not anticipate any offsite land disturbances during decommissioning, thus the land use impacts are not applicable for DAEC. In addition, as previously discussed in Section 5.1.12, it was determined that socioeconomic impacts from decommissioning are bounded by the GEIS. Potential impacts to minority and low-income populations would mostly consist of radiological effects.

Based on the radiological environmental monitoring program data from DAEC, the SEIS determined that the radiation and radioactivity in the environmental media monitored around the plant has no significant or measurable radiological impact on the environment. As a result, the SEIS found that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e., minority and/or low income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

Therefore, NEDA concludes that the impacts of DAEC decommissioning on environmental justice are small and are bounded by the GEIS.

5.1.14 Cultural, Historical, and Archeological Resources The GEIS states that "[i]n most cases, the amount of land required to support the decommissioning process is relatively small and is a small portion of the overall plant site.

Usually, the areas disturbed or utilized to support decommissioning are within the operational areas of the site and typically are within the protected area." It goes on to state that "[a]ctivities conducted within the operational areas are not expected to have a detectable effect on important cultural resources because these areas have normally been highly degraded during facility construction and operation. Activities conducted outside of the operational areas may have detectable impacts, depending on the size and type of impact, and the cultural resources potentially affected."

NEDA anticipates the decommissioning activities at DAEC will be confined to the operational area. Therefore, there would be no impact to cultural, historical, or archeological resources because this area was degraded during site construction. As a result, the impacts of DAEC decommissioning are small and are bounded by the GEIS.

As noted above, NEDA does not anticipate decommissioning activities outside the operational area. If NEDA's decommissioning plans change to involve significant activities with a potential for impacts outside the operational are, NEDA will notify the NRC in writing, in accordance with 10 CFR 50.82(a)(7). The following information would be relevant to an evaluation of impacts in that circumstance.

In the SEIS for the DAEC license renewal, the NRC concluded that "due to the dense concentration of cultural material in the area, there remains a high potential for undiscovered resources. Additionally, many of the resources found in the region are of high importance (e.g.,

mound groups)." As a result, the NRC concluded that "[i]f resources were encountered during plant activities, the effect would be expected to be MODERATE." This license renewal SEIS finding was based on a 2008 report by the Louis Berger Group, Inc. (ML092450278), which Page 29 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report covered the entire 500-acre DAEC property and identified nine locations on the DAEC property that could contain historic and archaeological remains. None of the nine sites were located within the operational area of the site. (See 2008 Berger report, App. A, Figure 2).

Section 4.9.6 of the SEIS determined that potential impacts to historic and archaeological resources were possible during the period of extended operations due to the potential richness of archaeological resources on the DAEC property. It stated that most impacts to historic and archaeological resources occur during ground disturbing activities. The SEIS acknowledged that, while known resources are considered in the excavation and trenching procedures, undiscovered historic and archaeological sites could be affected by plant activities. In coordination with the SHPO, NEDA developed and maintains excavation and trenching procedures for the DAEC which address potential impacts to both known and undiscovered resources. These procedures also include an inadvertent discovery (stop work) provision. The SEIS concluded that the any land disturbing activities would be considered through the DAEC revised excavation and trenching procedures and, although the potential impacts on historic and archaeological resources could be moderate, these impacts would be addressed through application of the mitigation measures.

As noted above, the decommissioning activities for DAEC are expected to be confined to the current DAEC operational area with no offsite impact and so are bounded by the GEIS. Based on the discussion in the SEIS, NEDA concludes that potential impacts on historic and archaeological resources from decommissioning activities outside the operational area at DAEC, which are not currently anticipated, could be MODERATE and that if necessary these potential impacts would be mitigated through application of controls for ground disturbance, as is fully described in the SEIS.

Therefore, NEDA has concluded that the environmental impacts associated with the DAEC decommissioning activities are bounded by the impacts addressed by previously issued environmental impact statements.

5.1.15 Aesthetic Issues Section 4.3.15 in the GEIS singles out structure dismantlement and entombment as the only activities that may have impacts on aesthetic resources. NEDA does not plan to utilize entombment for decommissioning any structures at DAEC. The aesthetic impacts of decommissioning fall into two categories: (a) impacts, such as noise, associated with decommissioning activities that are temporary and cease when decommissioning is complete and (b) the changed appearance of the site when decommissioning is complete. The NRC drew the generic conclusion that for all plants, the potential impacts from decommissioning on aesthetics are small and that the removal of structures is generally considered beneficial to the aesthetics of the site.

The GEIS concluded that the retention of structures during a SAFSTOR period or the retention of structures onsite at the time the license is terminated is likewise not an increased visual impact, but instead a continuation of the visual impact analyzed in the facility construction or operations final environmental statement.

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report During DAEC decommissioning, the impact of noise and dust would be temporary and controlled to minimize impacts. The appearance of DAEC will be altered as the buildings and structures are dismantled. The visual intrusion during dismantlement would be temporary and would serve to reduce the aesthetic impact of the site. Therefore, NEDA concludes that the impacts of DAEC decommissioning on aesthetics are small and generally considered beneficial.

Thus, such impacts are bounded by the analysis in the GEIS.

5.1.16 Noise Section 4.3.16 in the GEIS generically examined noise during decommissioning, concluding that noise impacts would be small. The NRC considered noise impacts for operation of DAEC in the SEIS for license renewal (Reference 4) and concluded the noise impact of plant operation would be small. The noise levels associated with the decommissioning activities are not expected to be any more severe than those that occur as a result of plant operational activities and are not expected to present an audible intrusion on the surrounding community and environment.

Decommissioning activities will be primarily limited to previously disturbed land surrounding the power block and isolated from both wildlife and members of the public. Therefore, because DAEC decommissioning activities are of the type previously considered by the NRC and DAEC has no site-specific conditions that would alter the NRC's prior findings, NEDA concludes that the noise impacts from decommissioning activities would be small and thus bounded by the analysis in the GEIS.

5.1.17 Transportation The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans. The shipments to and from the plant would primarily result from construction activities associated with relocation of the fuel to the ISFSI and shipments of radioactive wastes and non-radioactive wastes associated with dismantlement and disposal of structures, systems and components.

The estimated cubic feet of radioactive waste associated with DAEC decommissioning that will either be processed, destined for land disposal (Class A, Band C), or placed in a geologic repository (Greater than Class C) is summarized as follows:

• Class A: 503, 709 cubic feet

• Class B: 1,203 cubic feet

• Class C: 226 cubic feet

• Greater than Class C (GTCC): 128 cubic feet Table 4-7 of the GEIS estimated that the volume of land needed for LLRW (Class A, Band C) disposal from the referenced BWR was 636,000 cubic feet under the SAFSTOR alternative.

NEDA presently estimates the LLRW volume of Class A, B, and C for DAEC that is destined for shallow land disposal is approximately 505, 138 cubic feet using the SAFSTOR alternative which is below the GEIS bounding volume.

Page 31 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report The quantity of recycle/potentially contaminated waste reflects the volume of bulk material such as ductwork before it is processed. This recycle/potentially contaminated waste is shipped off-site to a licensed waste processing vendor for volume reduction, survey and release, decontamination, segregation, or other appropriate methods of waste minimization.

The NRC has concluded in Section 4.3.17 of the GEIS that these regulations are adequate to protect the public against unreasonable risk from the transportation of radioactive materials.

The number of GTCC waste shipments during decommissioning is expected to be below the number referenced in Table 4-6 of the GEIS. These shipments will occur over an extended period of time and will not result in significant changes to local traffic density or patterns, the need for construction of new methods of transportation, or significant dose to workers or the public. In addition, shipments of non-radioactive wastes from the site are not expected to result in measurable deterioration of affected roads or a destabilizing increase in traffic density.

Therefore, NEDA concludes that the impacts of DAEC decommissioning on transportation are bounded by the GEIS.

5.1.18 Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment. Since the DAEC site will be decommissioned under the provisions of 10 CFR 20 Subpart E, the land is not considered an irreversible resource. The only irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools),

and the fuel used for decommissioning activities and transportation of materials to and from the site. However, the use of these resources is minor.

While the GEIS does not specify quantitative bounds for commitment of irreversible and irretrievable resources, NEDA concludes that the impacts of DAEC decommissioning on these resources are negligible and consistent with the conclusions of the GEIS.

Page 32 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report 5.2 ENVIRONMENT IMPACTS OF LICENSE TERMINATION- NUREG-1496 As stated in the schedule provided in Table 2.1 of this report, a license termination plan for DAEC will not be developed until approximately five years prior to the final site decontamination which is currently assumed to be approximately the year 2080. At that time, a supplemental environmental report will be submitted as required by 10 CFR 50.82(a)(9). While detailed planning for license termination activities will not be performed until after the SAFSTOR dormancy period, the absence of any unique site-specific factors, significant groundwater contamination, unusual demographics, or impediments to achieving unrestricted release support an expectation that impacts resulting from license termination will be similar to those evaluated in NUREG-1496 (Reference 8).

5.3 DISCUSSION OF DECOMMISSIONING IN THE SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT (SEIS)

As part of the DAEC license renewal process, decommissioning was discussed in Section 7.0 of the SEIS (Reference 4). Identified were six issues related to decommissioning as follows:

• Radiation Doses

• Waste Management

• Air Quality

• Water Quality

• Ecological Resources

• Socioeconomic Impacts The NRC staff did not identify any new and significant information during their independent review of the DAEC license renewal environmental report (Reference 4), the site audit, or the scoping process for license renewal. The NRC concluded that there are no impacts related to these issues beyond those discussed in the SEIS for license renewal (Reference 4) or the GEIS for decommissioning (Reference 3). For the issues identified above, the license renewal and decommissioning GEISs both concluded the impacts are small. The NRC found no site-specific issues related to decommissioning. There are no contemplated decommissioning activities that would alt~r that conclusion.

5.4 ADDITIONAL CONSIDERATIONS The following considerations are relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed:

• The release of effluents will continue to be controlled by plant license requirements and plant procedures.

• NEDA will continue to comply with the Offsite Dose Assessment Manual, Radiological Environmental Monitoring Program, and the Groundwater Protection Initiative Program during decommissioning.

• Releases of non-radiological effluents will continue to be controlled per the requirements of the NPDES permit and applicable State of Iowa permits. Systems used to treat or Page 33 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report control effluents during power operation will either be maintained or replaced by temporary or mobile systems for the decommissioning activities.

• Radiation protection principles used during plant operations will remain in effect during decommissioning.

• Sufficient decontamination and source term reduction prior to dismantlement will be performed to ensure that occupational dose and public exposure will be maintained below applicable limits.

• Transport of radioactive waste will be in accordance with plant procedures, applicable Federal regulations, and the requirements of the receiving facility.

• Site access control during decommissioning will minimize or eliminate radiation release pathways to the public.

Additionally, NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, found that the generic environmental impacts of ongoing spent fuel storage are small (Reference 9).

5.5 CONCLUSION

S Based on the above discussions, NEDA concludes that the environmental impacts associated with planned DAEC site-specific decommissioning activities are less than and bounded by the impacts addressed by previously issued environmental impact statements. Specifically, the environmental impacts are bounded by the GEIS (Reference 3) and SEIS (Reference 4).

1. The postulated impacts associated with the decommissioning method chosen, SAFSTOR, have already been considered in the SEIS and GEIS.

2. There are no unique aspects of DAEC or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the SEIS and GEIS.

3. The methods assumed to be employed to dismantle and decontaminate DAEC are standard construction-based techniques fully considered in the SEIS and GEIS.

Therefore, it can be concluded that the environmental impacts associated with the site-specific decommissioning activities for DAEC will be bounded by appropriate previously issued environmental impact statements.

10 CFR 50.82(a)(6)(ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2, that result in significant environmental impacts not previously reviewed.

No such impacts have been identified.

Page 34 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report

6.0 REFERENCES

1. Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1. June 2013. (ML13143A259)

2. Letter, NextEra Energy Duane Arnold to USNRC, Certification of Permanent Cessation of Power Operations, January 18, 2019. (ML19023A196)

3. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, Final Report. November 2002. (ML180578048)

4. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 42, Regarding Duane Arnold Energy Center, October 2010.

(ML102790308)

5. PAG Manual, Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R-17/001, January 2017. (ML17129A150)

6. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual. August 2000.

(ML003761445)

7. Atomic Energy Commission, Final Environmental Statement related to the Operation of Duane Arnold Energy Center, March 1973 (ML091200609)

8. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRG-Licensed Nuclear Facilities, July 1997.

(ML042310492)

9. NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, Final Report, September 2014. (ML14196A105)

10. NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document, August 2007. (ML072600290)

11. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision 2. October 2011. (ML112160012)

12. Atomic Industrial Forum, Inc., Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, AIF/NESP-036, May 1986 Page 35 of 35

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 1 2018 Decommissioning Cost Estimate for the Duane Arnold Energy Center

~

ENERGYSOLUTIONS Document No. 164053-DCE-021 2018 Decommissioning Cost Estimate for the Duane Arnold Energy Center Project No. 164053 Revision 2 Prepared for:

NextEra Energy Duane Arnold, LLC Central Iowa Power Cooperative Corn Belt Power Cooperative Prepared by:

EnergySolutions, LLC 121 W. Trade Street, Suite 2700 Charfotte, NC 28202 Approved By: January 27, 2020 Mike Williams, Project Manager Date

/3; /j~

Prepared By: January 27, 2020 Barry Sims,, Senior Technical Advisor Date 0NewRepo1t D Title Change (XJ Report Revision D Report Rewrite Effective Date January 27, 2020

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 TABLE OF CONTENTS Section Page 1.0 EXECUTIVE

SUMMARY

................................................................................................ 1

2.0 INTRODUCTION

.............................................................................................................. 4 2.1 Study Objective ....................................................................................................... 4 2.2 Regulatory Framework ........................................................................................... 4 3.0 STUDY METHODOLOGY ............................................................................................... 7 3.1 General Description ................................................................................................ 7 3.2 Schedule Analysis ................................................................................................... 7 3.3 Decommissioning Staff........................................................................................... 8 3.4 Waste Disposal ........................................................................................................ 8 3 .5 Final Status Survey ............................................................................................... 10 3.6 Contingency .......................................................................................................... 11 3.7 Cost Reporting ...................................................................................................... 12 4.0 SITE SPECIFIC TECHNICAL APPROACH .................................................................. 13 4.1 Facility Description ............................................................................................... 13 4.2 Decommissioning Periods for SAFSTOR ............................................................ 13 4.3 Decommissioning Staff......................................................................................... 16 4.4 Spent Fuel Management Staff............................................................................... 16 4.5 Spent Fuel Shipments ........................................................................................... 16 5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS ................................................... 17 6.0 STUDY RESULTS ........................................................................................................... 22 6.1 SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage ......................................... 22

7.0 REFERENCES

................................................................................................................. 30 FIGURES Figure 1-1 Summary SAFSTOR Schedule ............................................................................. 3 Figure 6-1 Summary SAFSTOR Schedule ........................................................................... 23

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 TABLES Table 1-1 Decommissioning Cost Summary ............................................................................ 2 Table 6-1 Cost and Schedule Summary ................................................................................. 24 Table 6-2 Utility Staff Levels ............................................................................................ 25 Table 6-3 Decommissioning General Contractor Staff Levels .............................................. 27 Table 6-4 Waste Disposal Volumes ....................................................................................... 29 APPENDICES Appendix A List of Systems and Structures Appendix B Spent Fuel Shipping Schedule Appendix C Detailed Project Schedule Appendix D Detailed Cost Table Appendix E Annual Cost By Account Table 11

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 ACRONYMS AND ABBREVIATIONS AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable BWR Boiling Water Reactor CPR Code of Federal Regulations CPM Critical Path Method DAEC Duane Arnold Energy Center D&D Decontamination and Demolition DGC Decommissioning General Contractor DOE U.S. Department of Energy DSC Dry Shielded Canister FEMA Federal Emergency Management Agency PSS Final Status Survey GSA U.S. General Services Administration GTCC Greater Than Class C HP Health Physics HSM Horizontal Storage Modules ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LLW Low Level Waste LLWPA Low-Level Waste Policy Act LOP Life-of-Plant MARS SIM Multi-Agency Radiation Survey and Site Investigation Manual MPC Multi-Purpose Canister MWt Megawatt thermal NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System ORISE Oak Ridge Institute for Science and Education PCB Polychlorinated Biphenyl PS DAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RCRA Resource Conservation and Recovery Act TCEQ Texas Commission on Environmental Quality WBS Work Breakdown Structure UCF Unit Cost Factor 111

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 1.0 EXECUTIVE

SUMMARY

This report presents an update to "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center", Revision 1 (Ref. No. 1). The Duane Arnold Energy Center (DAEC) is 70%

owned by NextEra Energy Duane Arnold, LLC. The other owners of DAEC are Central Iowa Power Cooperative (20%) and Corn Belt Power Cooperative (10%). All numbers presented in this report are on a 100% basis.

This Decommissioning Cost Estimate (DCE) has been performed for financial planning purposes to determine costs for (I) decommissioning DAEC to the extent required to terminate the plant's operating license pursuant to 10 Code of Federal Regulations (CFR) 50.75(c), (2) post-shutdown management of spent fuel until acceptance by the U.S. Department of Energy (DOE) pursuant to 10 CFR 50.54(bb), (3) clean demolition of structures or Greenfield, and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CFR 72.30.

The DCE methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Ref. No. 2).

The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," (Ref. No. 3). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

NRC requirements, set forth in Title 10 of the CFR, differentiate between the post-shutdown costs associated with storage of spent fuel on site and those associated with the decommissioning of the facility. 10 CFR 50.75(c) requires funding by the licensee of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and the removal of clean structures. 10 CFR 50.75(c) also excludes the cost of site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license, which restores the site to either "Brownfield" or "Greenfield" conditions depending on the desired end-state. 10 CFR 50.54 (bb) requires funding by the licensee "for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."

Accordingly, the costs and schedules for all activities are segregated for regulatory purposes as follows: costs for "License Termination" (10 CPR 50.75(c)), costs for "Spent Fuel Management," (10 CFR 50.54(bb)), costs for "Greenfield" (clean removal and site restoration) final site conditions, and Independent Spent Fuel Storage (ISFSI) Decontamination and Demolition (D&D) (10 CFR 72.30). EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these four project accounts.

1

2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2 This DCE analyzes the following scenario, as defined by DAEC:

60 Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage

• Shutdown on October 30, 2020.

• DAEC's spent fuel shipping schedules based on a 2030 start date for DOE's acceptance of spent fuel.

• Termination of spent fuel pool operation approximately three years after permanent shutdown.

• Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transferred to Multi-Purpose Canisters (MPCs) for interim storage.

• SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

• Decommissioning will be performed by the utility staff and a Decommissioning General Contractor (DGC).

The cost estimate results are provided in 2018 dollars in Table 1-1. Table 1-1 gives License Termination costs (which correspond to 10 CFR 50.75 (c) requirements), Spent Fuel Management costs (which correspond to 10 CFR 50.54 (bb) requirements), Greenfield costs (which correspond to activities such as clean building demolition and site grading and re-seeding), and ISFSI D&D (which correspond to 10 CFR 72.30).

Table 1-1 Decommissioning Cost Summary (2018 Dollars in Thousands)

Account Total License Termination - 50.75 (c) $724,688 Spent Fuel 50.54 (bb) $259,466 Greenfield $36,447 ISFSI D&D 72.30 $1,640 Total $1,022,240 Note: Numbers may not add due to rounding.

The estimate is based on site-specific plant systems and buildings inventories. These inventories, and EnergySolutions' proprietary Unit Cost Factors (UCFs), were used to generate required manhours, activity schedule hours and costs, and waste volume, weight, and classification. Based on the activity schedule hours and a decommissioning activities analysis, a Critical Path Method (CPM) analysis was performed to determine the decommissioning schedules. These schedules reflect the effects of sequenced activity-dependent or distributed decommissioning elements such as planning and preparations, major component removal, building decontamination, and spent fuel shipping. The schedules are divided into project phases (periods) and presented, as noted previously, by cost account "License Termination," "Spent Fuel Management," "ISFSI D&D," or "Greenfield." The summary schedule is shown in Figure 1-1 and may also be found in Section 6.0 of this report.

2

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Figure 1-1 Summary SAFSTOR Schedule Spent FUel Managormnt 04'01120tD 01J12'207Q

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2

2.0 INTRODUCTION

2.1 Study Objective This report presents an update to "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center", Revision 1 (Ref. No. 1). The Duane Arnold Energy Center (DAEC) is 70%

owned by NextEra Energy Duane Arnold, LLC. The other owners of DAEC are Central Iowa Power Cooperative (20%) and Corn Belt Power Cooperative (10%). All numbers presented in this report are on a 100% basis.

This Decommissioning Cost Estimate (DCE) has been performed for financial planning purposes to determine costs for (I) decommissioning DAEC to the extent required to terminate the plant's operating license pursuant to 10 Code of Federal Regulations (CFR) 50.75 (c), (2) post-shutdown management of spent fuel until acceptance by the U.S. Department of Energy (DOE) pursuant to 10 CFR 50.54 (bb), (3) clean demolition of structures or Greenfield, and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to I 0 CFR 72.30.

The DCE methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Ref. No. 2).

The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," (Ref. No. 3). The estimate is based on compliance with cun-ent regulatory requirements and proven decommissioning technologies.

This DCE analyzes the following scenario, as defined by DAEC:

60 Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage

• Shutdown on October 30, 2020 .

• DAEC's spent fuel shipping schedules based on a 2030 start date for DOE's acceptance of spent fuel.

• Termination of spent fuel pool operation approximately three years after permanent shutdown.

• Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transferred to Multi-Purpose Canisters (MPCs) for interim.

• SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

• Decommissioning will be performed by the utility staff and a Decommissioning General Contractor (DGC).

2.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, and spent fuel management are as follows:

l. NRC regulations require a license for on-site storage of spent fuel. Wet storage in a spent fuel pool is authorized by a facility's 10 CFR Part 50 license. On-site dry 4

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 storage of spent fuel at an Independent Spent Fuel Storage Installation (ISFSI) is licensed by either: (a) the general license set forth in 10 CFR 72.210, which requires that a Part 50 license be in place; or (b) a site-specific ISFSI license issued pursuant to 10 CFR Part 72.

2. 10 CFR 50.75 (c) requires funding by the licensee of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and the removal of clean structures.

3. 10 CFR 50.54 (bb) requires the licensee, within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license, whichever occurs first, to submit written notification to the NRC for its review and preliminary approval of the program by which the licensee intends to manage and provide funding "for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." However, the NRC does not cmrently consider post-shutdown spent fuel management costs to be decommissioning costs.

4. 10 CFR 72.30 (b) requires that a licensee under Part 72 must submit a decommissioning funding plan that contains information that provides assurance that funds will be available to decommission the ISFSI.

Decommissioning Alternatives The three methods for decommissioning are DECON, SAFSTOR, and ENTOMB, which are summarized as follows:

1. DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license after cessation of operations.

2. SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. NRC regulations require decommissioning to be completed within 60 years of cessation of operation.

3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained and monitored until radioactivity decays to a level that permits termination of the license. Since entombment will exceed the requirement for decommissioning to be completed within 60 years of cessation of operation, NRC handles entombment requests on a case-by-case basis.

The selection of a preferred decommissioning alternative is influenced by a number of factors pertinent at the time of final plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a 5

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 low-level waste disposal facility, availability of a high-level waste (spent fuel) repository, regulatory requirements, and public comments.

Post-Shutdown Spent Fuel Management Alternatives Selection of a decommissioning strategy and the associated schedule for completion is in part contingent upon an assumed start date for DOE acceptance of spent fuel and an assumed end date for completion of the transfer of all spent fuel assemblies projected to be generated during a power reactor's operating life. The basic options for long-term post-shutdown spent fuel management currently available to power plant operators are (1) wet storage consisting of continued maintenance and operation of the spent fuel pool, and (2) dry storage consisting of transfer of spent fuel from the fuel pool to on-site dry storage modules after a cooling period.

Maintaining the spent fuel pool for an extended duration following cessation of operations prevents termination of the Part 50 license and typically has a higher annual maintenance and operating cost than the dry storage alternative. Transfer of spent fuel to an ISFSI requires additional capital expenditures for purchase and construction of the ISFSI and dismantlement and disposal of the ISFSI following completion of spent fuel transfer to DOE. In both cases the decommissioning and spent fuel management costs are significantly affected by the assumed start and end dates for DOE acceptance of spent fuel.

In January 2013, DOE released its "Strategy for Management and Disposal of Used Nuclear Fuel and High Level Radioactive Waste" (Ref. No. 5). The DOE Strategy contemplates building the capability to begin executing DOE's commitment to address waste disposal within the next ten years. Under this Strategy, by 2021, operation would begin of a "pilot storage facility" with an "initial focus on accepting spent fuel from shutdown reactor sites." By 2025, a "larger interim storage facility" would be available, and by 2048, a geologic repository would commence operations.

For purposes of this DCE, DAEC has conservatively assumed that the larger interim storage facility is delayed five years and commences operations in 2030. DAEC has further assumed that the DOE acceptance rate is consistent with the 2004 "Acceptance Priority Ranking &

Annual Capacity Report" (Ref. No. 6), which is the most current information regarding acceptance of fuel.

6

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 3.0 STUDY METHODOLOGY 3.1 General Description EnergySolutions maintains a proprietary decommissioning cost model based upon the fundamental technical approach established in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," dated May 1986 (Ref. No.

2). The cost model has been updated in accordance with regulatory requirements and industry experience. The cost model includes elements for estimating distributed and undistributed costs.

Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal, and removal of major components and systems. For example, the segmentation, packaging, and disposal of the reactor internals is a distributed cost.

Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs such as utility and DGC staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff.

The methodology for preparing cost estimates for a selected decommissioning alternative requires development of a site-specific detailed work activity sequence based upon the plant inventory. The activity sequence is used to define the labor, material, equipment, energy resources, and duration required for each activity. In the case of major components, individual work sequence activity analyses are performed based on the physical and radiological characteristics of the component and the packaging, transportation, and disposal options available.

In the case of structures and small components and equipment such as piping, pumps, and tanks, the work durations and costs are calculated based on Unit Cost Factors (UCFs). UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. They are developed using decommissioning experience, information on the latest technology applicable to decommissioning, and engineering judgment. The total cost of a specific decommissioning activity can be determined by multiplying the total number of units associated with that activity by the UCF, expressed as $/unit, for that activity. For example, the estimated demolition cost of a non-contaminated concrete structure can be obtained by multiplying the volume of concrete in the structure by the UCF for non-contaminated reinforced concrete demolition, expressed in $/unit volume. Each UCF has associated with it a man-hours/unit and schedule-hours/unit. From these values, total man-hours and total schedule-hours can be determined for a particular activity.

3.2 Schedule Analysis Once the work activity durations are calculated for all distributed act1v1t1es, a critical path schedule analysis is performed using Microsoft Project. The schedule accounts for constraints such as spent fuel cooling periods and regulatory reviews. The schedule is typically delineated into phases or time periods (hereinafter referred to as period or periods) that differentiate manpower requirements and undistributed costs.

In order to differentiate between License Termination, Spent Fuel, Greenfield, and ISFSI D&D elements of the entire decommissioning scope of work, EnergySolutions has established a Work Breakdown Schedule (WBS) and cost accounting system to treat each element as a subproject.

7

2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Accordingly, the overall project schedule is divided into interrelated periods with major milestones defining the beginning and ending of each period. The major milestones also serve as the basis for integrating the periods of the four subprojects.

3.3 Decommissioning Staff A site-specific staffing plan was developed by DAEC and EnergySolutions based on the existing DAEC operational staff and the assumption that the decommissioning will be performed by a DGC, with oversight and management of the DGC performed by DAEC staff. It was also assumed that DAEC staff would be supplemented by professional consulting engineering, particularly in the planning and preparation phase. The DAEC existing salary structure serves as the basis for calculating DAEC staff labor costs. The DGC salary costs are based on industry data.

Staffing levels for each project period are based on the AIF guidelines and industry experience.

The sizes of the DAEC and DGC staffs are varied in each period in accordance with regulatory requirements and work activities.

3.4 Waste Disposal Waste management costs comprise a significant portion of the decommissioning cost estimate.

Additionally, limited future access to disposal sites licensed for receipt of Class B and C wastes introduces a significant level of uncertainty with respect to the appropriateness of using existing rate structures to estimate disposal costs of these wastes. The approach used in this DCE to estimate waste disposal costs is discussed in the following paragraphs.

Waste Classification Regulations governing disposal of radioactive waste are stringent in order to ensure control of the waste and preclude adverse impact on public health and safety. At present, LLRW disposal is controlled by NRC regulation 10 CFR 61, which went into effect December, 1983. This regulation stipulates the criteria for the establishment and operation of shallow-land LLRW burial facilities. Embodied within this regulation are criteria and classifications for packaging LLRW such that it is acceptable for burial at licensed LLRW disposal sites.

For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemical properties that the LLRW must meet in order to be accepted at a licensed disposal site. The LLRW disposal criteria of 10 CFR 61 require that LLRW generators determine the proportional amount of a number of specific radioactive isotopes present in each container of disposable LLRW. This requirement for isotopic analysis of each container of disposable LLRW is met by employing a combination of analytical techniques such as computerized analyses based upon scaling factors, sample laboratory analyses, and direct assay methods. After performing an isotopic analysis of each container of disposable LLRW, the waste must then be classified according to one of the classifications (Class A, B, C, or Greater Than Class C (GTCC) as defined in 10 CFR 61.

The classification of LLRW resulting from decommissioning activities is based on AIF/NESP-036 (Ref. No. 2) and NUREG/CR-0672 for Boiling Water Reactors (BWRs) (Ref. No. 8), and 8

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 recent industry experience. The estimated curie content of the reactor vessel and internals at shutdown is derived from NUREG/CR-0672 and adjusted for the different mass of components as well as the pe1iod of decay.

Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on the most resttictive of the following constraints: curie content, dose-rate, container weight limit, or container volume limit. GTCC waste from segmentation of the reactor vessel internals is packaged in MPCs. The selection of container type for Class A waste is based on the transportation mode (rail, truck, barge, etc.) and waste form. The quantity of Class A waste containers is determined by the most restrictive of either container weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactor recirculation pumps, are shipped as their own container with shielding as required.

Container costs are obtained from manufacturers. Shielded transport cask and liner costs are obtained from the cask owners and operators.

Transportation Transportation routes to processing and disposal facilities are determined based on available transportation modes (truck, rail, barge, or combinations). Transportation costs for the selected routes and modes are obtained from vendor quotes or published taiiffs whenever possible.

Class A Disposal Options and Rates In accordance with the existing LOP Disposal Agreement (Ref. No. 9), all Class A waste that meets the Clive facility waste acceptance criteria is to be disposed of at Clive. All reported waste disposal costs include packaging, transportation, and any applicable surcharges.

Class B and C Disposal Options and Rates CmTently, within the United States, there are only three operational commercial disposal facilities licensed to accept Class B and C LLRW: the Barnwell facility, operated by EnergySolutions in Barnwell, South Carolina; the U.S. Ecology facility in Richland, Washington; and the facility in Andrews County, Texas operated by Waste Control Specialists.

Barnwell only accepts waste from states within the Atlantic Compact, and U.S. Ecology only accepts waste from states within the Northwest and Rocky Mountain Compacts. However, the WCS facility will accept waste from the Texas Compact (comprised of Texas and Vermont) and non-Compact generators. The Texas Compact Commission on March 23, 2012 approved amendments to rules allowing the import of non-compact generator LLRW for disposal at the Andrews County facility.

Greater Than Class C (GTCC)

Wastes identified as 10 CFR 61 Class A, B, and C may be disposed of at a near-surface disposal facility. Certain components are highly activated and may exceed the radionuclide concentration limitations for IO CFR 61 Class C waste. In accordance with 10 CFR 61, these components 9

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 cannot be disposed of in a near-surface LLRW disposal facility and must be transferred to a geologic repository or a similar site approved by the NRC.

Highly activated sections of the reactor vessel internals will result in GTCC waste. Presently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations. The courts have held that DOE is obligated to accept and dispose of GTCC and, therefore, this estimate assumes that the DOE will accept this waste along with spent fuel. Although there may be no additional costs for DOE disposal of GTCC, this estimate conservatively assumes a GTCC waste disposal cost. This estimate further assumes that the GTCC waste will be packaged in DSCs and will be shipped to a storage or disposal facility by DOE along with the spent fuel at a shipping costs equivalent to the commercial cost of shipping a Type B licensed, shielded cask such as the CNS 8-120B cask.

LLRW Volume Reduction Based on cmTent Class A LLRW disposal rates on-site volume reduction techniques such as waste compaction or an aggressive decontamination, survey and release effort are not currently considered to be cost effective over disposal.

Non-Radioactive Non-Hazardous Waste Disposal EnergySolutions assumes that recyclable, non-radioactive scrap metal. resulting from the decommissioning program will be transported to a scrap metal dealer. However, no credit is assumed in the estimate for the value of the scrap metal. Concrete debris is assumed to be processed by size reduction, with removal of structural reinforcing steel, and used on site as engineered fill for voids. Asphalt from parking lots and roadways is assumed to be stockpiled on site and removed, at no cost to the project, by a recycler. All other demolition debris is removed from the site and disposed of at a local construction debris landfill.

Hazardous and Industrial Waste Disposal Lead shielding remaining after shutdown is assumed to be removed from its installed locations and disposed of as a mixed waste. In accordance with information furnished by DAEC thirty percent of insulated systems in radiologically controlled areas are assumed to contain asbestos, therefore; this DCE includes a line item for asbestos abatement. The decommissioning estimate also includes an estimate for hazardous and industrial waste disposal based on information provided by DAEC. The cost of hazardous and industrial waste disposal includes DAEC's estimated cost for closure of Resource Conservation and Recovery Act (RCRA) storage areas.

Additionally, surfaces coated with lead based paint will be remediated as required for demolition.

3.5 Final Status Survey The cost of performing a final status survey (FSS) is based on NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Ref. No. 10). Estimates of MARSSIM Class I, II, and III survey designations are based on radiological characterization data furnished by DAEC and assumptions regarding contamination resulting from small and large component removal activities. The FSS activity cost calculation includes the in-place remote 10

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 survey of underground metal and concrete pipe, soil, and groundwater sampling and analysis.

Estimated costs for NRC and Oak Ridge Institute for Science and Education (ORISE) verification are also included, and the NRC review period is incorporated into the project schedule.

3.6 Contingency Contingencies are applied to cost estimates primarily to allow for unknown or unplanned occun-ences during the actual program, e.g. increased radioactive waste materials volumes over that expected, equipment breakdowns, weather delays, labor strikes, etc. This is consistent with the definition provided in the DOE Cost Estimating Guide, DOE G 430.1-1, 3-28-97 (DOE G)

(Ref. No. 11 ): Contingency "Covers costs that may result from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope. The amount of contingency will depend on the status of design, procurement, and construction; and the complexity and uncertainties of the component parts of the project. Contingency is not to be used to avoid making an accurate assessment of expected costs." EnergySolutions determines site-specific contingency factors to be applied to each estimate based on industry practices.

The DOE has established a recommended range of contingencies as a function of completeness of program design, DOE G. The ranges are:

Contingency Range Type of Estimate as a % of Total Estimate Planning Phase Estimate 20-30 Budget Estimate 15-25 Title I (Preliminary Design Estimate) 10-20 Title II (Definitive Design Estimate) 5-15 Energy Solutions' approach to assigning appropriate contingency rates is based on adaptations of published values for the specific decommissioning activities. One source for such published information is AIF/NESP-036 "Guidelines for Producing Nuclear Plant Decommissioning Cost Estimates" (Ref. No. 2). The AIF guideline identifies contingencies for activities specific to a nuclear power plant decommissioning, such as reactor internals removal. The contingencies presented in the AIF guideline are based on the assumption that the estimated costs are not well known; therefore, the recommended contingencies are greater than they would be if the estimated costs were well known. With the exception of the system decontamination, reactor vessel and reactor internals removal, and disposal, the contingencies presented in the AIF guideline are consistent with the values presented in DOE G 430.1-1 for a Budgetffitle I estimate. The system decontamination, reactor vessel and reactor internals removal, and disposal contingencies recommended in the AIF guideline are significantly higher than the ranges identified by the DOE, even for a planning phase document. This is due to the unique nature of these activities and the relatively small amount of historical data available at the time the AIF document was written.

This estimate applies site-specific contingency factors to each WBS element based on industry practices. The contingencies rates applied in this estimate are specific to decommissioning estimates consistent with information presented in AIF guideline and DOE G. The 11

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 decommissioning costs generated in the estimate are considered well known and, as such, the contingencies presented in AIF guideline were reduced for each category of costs. There have also been a number of large-scale decommissioning projects since AIF was published, providing some hist01ical information that has been used in prepaiing this estimate. This allows for additional reduction in contingency costs. The following table provides a summary of contingency values applied in this estimate where the plant structures, systems, and major component material inventories are well defined, as with this study.

Package Material & Ship &

Category Labor Egui2ment Bury Other Engineering 13%

Contaminated components/Concrete 23% 23% 23%

Clean components 13% 13% 13%

Reactor Vessel and Reactor Internals 50% 23% 25%

Other 15%

The above contingency categories address the difference in uncertainty associated with performance of the work. In the case of a power plant decommissioning project, the segmentation of the reactor internals and pressure vessel and removal of radiologically contaminated plant systems and structures have the highest degree of uncertainty and are therefore assigned the higher contingency rates.

3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into the following catego1ies - Labor, Materials and Equipment, Waste Disposal, and Other costs. Other costs include property taxes, insurance, license fees, permits, and energy. Waste Disposal costs are the summation of packaging, transportation, base disposal rate, and any applicable surcharges. Health physics (HP) supplies and small tool costs are calculated as a component of each distributed activity cost and included in the category of Material and Equipment, with the exception that HP supplies for third party HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2 4.0 SITE SPECIFIC TECHNICAL APPROACH 4.1 Facility Description DAEC is a nuclear powered electrical generating facility consisting of one BWR located on a site near Palo in Linn County, Iowa. The plant site comprises approximately 500 acres adjacent to the Cedar River approximately 2.5 miles northeast of the Village of Palo, Iowa.

The nuclear system includes a single-cycle, forced-circulation, General Electric (GE) BWR producing steam for direct use in the steam turbine. The nuclear steam supply system (NSSS) and the turbine-generator were furnished by GE. The balance of plant was designed and constructed by Bechtel Power Corporation (Bechtel) as architect engineer and constructor.

The unit was originally designed, analyzed, and licensed for a steady-state core power of 1,658 MWt, although the plant Technical Specifications restricted operation to a rated power of 1,593 MWt. In 1985, the Technical Specifications were amended to allow the DAEC to operate at a steady-state power level of 1,658 MWt (License Amendment #115). Then, in 2001, the rated power level was increased again to 1,912 MWt (License Amendment #243). The current shutdown date is October 30, 2020.

Spent fuel assemblies are stored in the spent fuel storage racks in the spent fuel pool or may, after appropriate decay, be transferred to an ISFSI for interim onsite storage. The re-rack project of 1994 increased the spent fuel pool capacity to 2,411 assemblies. In addition, racks were licensed for the cask pit to retain full-core offload capability. The cask pit racks have a storage capacity of 323 assemblies, but are not licensed for long term storage.

There is an ISFSI on site that houses 10 CFR 72 licensed spent fuel storage systems that can provide interim on-site storage of spent fuel and reactor-related GTCC waste.

Appendix A provides a list of the DAEC systems and structures included in the material inventory for this study.

4.2 Decommissioning Periods for SAFSTOR The project periods for SAFSTOR consist of eleven License Termination periods, seven Spent Fuel Management periods, two Greenfield periods, and two ISFSI D&D periods. The project periods defined for this site-specific study and the major activities performed during each period are as follows:

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 License Termination Periods Decon Pd I - SAFSTOR Planning Prior to Shutdown

• SAFSTOR Planning and Design

• Preparation of SAFSTOR Plan and License Documents Decon Pd 2 - Transition Following Shutdown

• Perform Historical Site Assessment and Site Characterization

• Flush, Drain, and De-Energize Non-Essential Systems

• Volume Reduce Control Rod Blades, Fuel Channels, and LPRMs

• General Area Cleanup Decon Pd 3 - SAFSTOR Preparation Delay During Spent Fuel Pool Operations

• Periodic Maintenance, Surveillance and Inspection of Non-fuel Related Systems and Structures Decon Pd 4 - Completion of SAFSTOR Preparations

• Flush and Drain Essential Systems Following Fuel Pool Closure

• Secure Site for Dormancy Period

• Drain and De-Energize Remaining Systems and Secure Site Decon Pd 5 - Dormancy With Dry Storage

• Periodic Maintenance, Surveillance, and Inspection of Non-fuel Related Systems and Structures

• Bituminous Roof Replacement - 20 year

• Bituminous Roof Replacement - 40 year Decon Pd 6 - Dormancy Only

• Periodic Maintenance, Surveillance and Inspection of Non-fuel Related Systems and Structures Decon Pd 7 - Decommissioning Planning During Dormancy

• Decommissioning Planning and Design

• Planning and Design of Site Revitalization Decon Pd 8 - Internals Segmentation and Site Preparations

• Revitalize Infrastructure and Re-Power Site

• Perform Post-SAFSTOR Baseline Radiation Survey

• Remove and Dispose of Spent Fuel Storage Racks

• Segment, Package, and Ship Reactor Internals

• Construct Site Modifications

• Preparation of License Termination Plan Decon Pd 9 - Major Component and Systems Removal

• Remove, Package, and Dispose of Non-Essential Systems

• Segment, Package, and Dispose of Nuclear Steam Supply System

• Perform Asbestos Abatement on Plant Systems

• Remove and Dispose of Control Rod Drives 14

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

• Package and Ship Reactor Pressure Vessel

• Remove, Package, and Dispose of Remaining Active Plant Systems Decon Pd 10 - Building Decontamination

• Decontaminate Structures

• Remove Underground Storm Drains and Manholes

• Final Status Survey for Structures

• Final Status Survey for Land Areas Decon Pd 11 - License Termination

• NRC Review and Approval of the Final Status Survey Spent Fuel Management Periods SNF Pd 1 -Fuel Pool Island Design

• Design Spent Fuel Support System Modification

• Design Control Room Relocation

• Design Spent Fuel Security Modification SNF Pd 2 - Spent Fuel Cooling During Zirc Fire Window

• Install Spent Fuel Pool, Control Room, and Security Modifications SNF Pd 3 - Spent Fuel Transfer to Dry Storage

• Fuel Pool Operation and Maintenance

• Construction of ISFSI Phase II and III Expansion

• Construction of ISFSI Monitoring Building

• Transfer Fuel Assemblies into MPCs SNF Pd 4 - Dry Storage During Completion SAFSTOR Preparations SNF Pd 5 - Dry Storage During Dormancy

• Periodic Fuel Shipments to DOE SNF Pd 6 - ISFSI Demolition Delay SNF Pd 7 - ISFSI and Support Structure Clean Demolition

• Demolition of HSMs and ISFSI Foundation

• Demolition of ISFSI Security Building and Support Structures

• Site Restoration of ISFSI site ISFSI D&D Periods (10 CFR 72.30)

ISFSI D&D Pd 1 - ISFSI D&D Planning

• Preparation and NRC Review of License Termination Plan ISFSI D&D Pd 2 - ISFSI Final Status Survey

• Final Status Survey of ISFSI

• Preparation of FSS Report and NRC Review 15

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Greenfield Periods Grn Pd 1 - Clean Building Demolition During Decommissioning

• Demolition of Structures Grn Pd 2 - Site Restoration

• Finish Grading and Re-Vegetate Site 4.3 Decommissioning Staff A site-specific staffing plan was developed by DAEC and EnergySolutions based on the existing DAEC operational staff and the assumption that the decommissioning will be performed by a DGC, with oversight and management of the decommissioning operations pe1formed by DAEC staff. It is also assumed that the DAEC staff will be supplemented by professional consulting engineering, particularly in the planning and preparation phase. The sizes of the staffs are varied in each period in accordance with regulatory requirements and the work activities. Details on the staff levels during each pe1iod are provided in Section 6.0.

4.4 Spent Fuel Management Staff The largest spent fuel staff is in place while the fuel pool is operational during the cooling period and when fuel assemblies are being transferred to dry storage. Once all spent fuel has been removed from the spent fuel pool, the staff is reduced. Details on the staff levels during each pe1iod are provided in Section 6.0.

4.5 Spent Fuel Shipments The spent fuel shipping schedule was provided by DAEC. The spent fuel shipping schedule is based on the DOE 2004 "Acceptance Priority Ranking & Annual Capacity Report" (Ref. No. 6).

The spent fuel shipping schedule is provided in Appendix B.

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2 5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below.

1. All cost data used in this study is current as of 2018 or has been escalated to 2018 dollars. Totals and subtotals have been rounded to significant figures.

2. The estimate is based on a shutdown date of October 30, 2020.

3. The decommissioning will be performed under the current regulations. These regulations require a Post-Shutdown Decommissioning Activities Report (PSDAR) to be submitted prior to, or within, two years after permanent shutdown. In addition, a certificate of permanent cessation of operations must be submitted to the NRC within 30 days of permanent cessation of operations. Certification of the final core off-load must also be submitted to the NRC upon completion of this activity. 90 days after the NRC receives the PSDAR and after submittal of both certifications, major decommissioning activities that meet the criteria of 10 CFR Part 50.59 may be performed, provided the NRC does not notify DAEC of any deficiencies.

4. The decommissioning will be performed using currently available technologies.

5. The spent fuel shipping schedule assumes DOE begins accepting spent fuel in 2030.

6. The material inventory for this estimate is based on prior EnergySolutions' take-offs and has been updated, based on information furnished by DAEC, to reflect major structural modifications.

7. All transformers on site following shutdown are assumed to be polychlorinated biphenyl (PCB)-free; therefore, this estimate does not include costs for disposition of PCB contaminated transformers.

8. Cost for transportation of clean scrap metal to a recycler is included in the estimate; however, no credit is taken for the value of the scrap metal. A portion of the concrete debris is assumed to be processed by size reduction, with removal of structural reinforcing steel, and used on site as engineered fill for voids. All other concrete and demolition debris is removed from the site and disposed of at a local off-site construction landfill.

9. This estimate is based on final site restoration to Greenfield conditions, in which all existing and proposed structures, with the exception of the switchyard, wiil be removed.

Clean demolition costs are based on structures removal to three feet below grade.

Clean topsoil will be imported and placed on the top three feet. The entire disturbed area of the site is to be graded, to restore the natural grade to the extent possible, and seeded.

10. Lead shielding remaining after shutdown is assumed to be disposed of as a mixed waste.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

11. A budget for hazardous material is included in the estimate, which is based on information provided by DAEC. All other chemicals and hazardous mateiials present at shutdown are assumed to be removed and disposed of by the plant staff prior to decommissioning, as a normal part of plant operations.

12. No known areas of radiologically contaminated soil have been identified. Additionally, documented tritium levels in groundwater are below drinking water standards.

Therefore, no soil or groundwater remediation costs will be assumed.

13. DAEC provided information on the current amount of asbestos insulation on systems piping. It is assumed that asbestos not replaced during an outage and still remaining at shutdown will be limited to areas with higher dose rates. Therefore, this study considers that 30% of the insulation on contaminated and insulated piping will be asbestos and disposed of as Class A waste.

14. Costs for disposition of greater than Class A LLRW either currently stored on site or anticipated to be on site at the time of decommissioning are included in this estimate.

The types and quantities of greater than Class A LLRW were provided by DAEC, and include, but are not limited to the following expected to be stored in the spent fuel pool at the time of shutdown:

27 control blades 24 Local Power Range Monitors 25 blade guides 6 half blade guides

15. All Class A waste is assumed to be disposed of at EnergySolutions' facility in Clive, Utah, in accordance with the existing LOP Disposal Agreement between EnergySolutions and DAEC (Ref. No. 9).

16. DAEC furnished Class Band C waste disposal rates.

17. DAEC provided costs used to estimate the assumed GTCC disposal cost.

18. GTCC waste generated from the segmentation of the reactor internals will be packaged in MPCs. In this estimate, the MPCs are assumed to be accepted by DOE at the time of the deferred decommissioning.

19. Vessel and internals cmie estimates were derived from the values for the Reference BWR vessel and internals in NUREG/CR-0672 (Ref. No. 8) and adjusted for mass and the SAFSTOR decay period.

20. The site-specific classification of radioactive wastes for DAEC identified one components within the reactor vessel (the Core Shroud) will exceed Class C limitations.

Two NUHOMs MPCs are assumed to be required and DAEC provided the estimated costs.

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2

21. Spent fuel will remain in the spent fuel pool for approximately three years before being transferred to the ISFSI.

22. Spent fuel management costs include the purchase of dry storage MPCs and HSMs required following shutdown. An estimated cost for labor, material, and equipment for the pool to pad transfer of spent fuel to the ISFSI was provided by DAEC.

23. The existing ISFSI will have to be expanded post-shutdown in order to accommodate all spent fuel. The cost for constructing the ISFSI expansion was furnished by DAEC.

24. The ISFSI pad and HSMs are assumed to have no activated concrete or surface contamination.

25. The 10 CFR Part 50 license will be maintained until DOE has taken possession of the spent fuel.

26. State emergency preparedness, Federal Emergency Management Agency (FEMA) fees, and Environmental Permits costs are based on data furnished by DAEC and were adjusted to meet the requirements of each period based on the status of on-site spent fuel.

27. An estimate of the annual property taxes was furnished by DAEC and included in the estimate.

28. Annual NRC 10 CFR 171.15 fees, for reactors in decommissioning, of $198,000 are included in the estimate.

29. The estimate includes annual NRC inspection fees during each decommissioning period based on the type and level of activities being performed along with NRC review fees for license amendment requests, exemption requests and the License Termination Plan based on NRC's hourly rate of $275 per hour.

30. Annual operating insurance premiums were supplied by DAEC. The premium amounts were adjusted to meet the requirements of each period based on information provided by DAEC.

31. DAEC provided an annual allowance for miscellaneous materials and services to account for costs such as communications, miscellaneous utilities and services, office supplies, and consumables not captured elsewhere in the estimate.

32. DAEC staff positions and average burdened salary data were supplied by DAEC and account for fringe benefits, overhead and payroll taxes.

33. DGC staff salaries, including overhead and profit, were determined by EnergySolutions and represent EnergySolutions' standard assumptions for these rates

34. DAEC staff severance and retention costs were supplied by DAEC.

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2

35. The current utility staff size is considered to be sufficiently stable to remain virtually unchanged to end of life. For this reason, the utility staff is assumed to be the same size at the time of shutdown.

36. The professional personnel used for the planning and preparation activities are assumed to be paid per diem at the rate of $93/day, based on per diem rates from U.S. General Services Administration (GSA) for Cedar Rapids, Iowa.

37. Craft labor rates were furnished by DAEC. Craft labor rates for disciplines not furnished by DAEC have been taken from the 2018 RS Means Labor Rates for the Construction Industry (Ref. No. 12), for Cedar Rapids, Iowa. Since the skilled laborers are assumed to be supplied by the local union hall, they will not be paid per diem.

38. The security guard force included in this DCE is in accordance with NRC security regulations as implemented by an NRC approved security plan and anticipated amendments to that plan applicable during each decommissioning period following shutdown.

39. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate such items as the use of respiratory protection and personnel protective clothing. These factors increase the work duration and cost.

40. The costs of all required safety analyses and safety measures for the protection of the general public, the environment, and decommissioning workers are included in the cost estimates. This reflects the requirements of:

10 CPR 20 Standards for Protection Against Radiation 10 CPR 50 Domestic Licensing of Production and Utilization Facilities 10 CPR 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CPR 71 Packaging of Radioactive Material for Transport 10 CPR 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 29 CPR 1910 Occupational Safety and Health Standards 49 CPR 170-189 Department of Transportation Regulations Governing the Transport of Hazardous Materials Regulatory guidance is also provided by Reg. Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

41. Activity labor costs do not include any allowance for delays between activities, nor is there any cost allowance for craft labor retained on site while waiting for work to become available.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 6.0 STUDY RESULTS 6.1 60-Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage Based on the following:

• Shutdown on October 30, 2020.

• DOE begins accepting spent fuel in 2030.

• Termination of spent fuel pool operation approximately three years after permanent shutdown.

• Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transfened to MPCs.

• SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

• Decommissioning will be performed by an independent Third Party.

Spent Fuel Shipping Schedule The spent fuel shipping schedule is provided in Appendix B. All spent fuel will be removed from the spent fuel pool by the end of 2023. All spent fuel will be removed from the ISFSI by the end of 2059.

Cost and Schedule A summary project schedule is shown in Figure 6-1. A detailed schedule is provided in Appendix C. Table 6-1 summarizes the period durations and total costs, including contingency, for License Termination, Spent Fuel, Greenfield and ISFSI D&D activities. A detailed cost table is provided in Appendix D, and a table of annual expenditures is provided in Appendix E.

Project Staffing Staffing is based on the assumption that decommissioning will be performed by the utility staff and a DGC. Utility staffing levels, by organizational department and function, for each period are provided in Table 6-2. DGC staffing levels, by organizational department and function, for each period are provided in Table 6-3.

Waste Disposal Volumes The estimated cubic feet of waste are summarized as follows:

Class A 503,709 Class B 1,203 Class C 226 GTCC 128 Waste disposal volumes and costs, itemized by packaging, transportation, surcharges, and disposal costs by waste class and facility, are provided in Table 6-4. The waste disposal costs provided in Table 6-4 do not include contingency.

22

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Figure 6-1 Summary SAFSTOR Schedule

' ..-------------=------

23

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Table 6-1 Cost and Schedule Summary (2018 Dollars in Thousands)

Period No. Period Description Start End Years Total Cost License Termination (50.75(c))

Decon Pd I SAFSTOR Planning Prior to Shutdown 41112019 10/30/2020 1.58 $11,509 Decon Pd 2 Transition Following Shutdown l 0/30/2020 l 0/30/2021 0.99 $71,649 SAFSTOR Preparation Delay During Spent Fuel Pool Decon Pd 3 10/30/2021 8/31/2023 1.83 $20,113 Operations Decon Pd4 Completion of SAFSTOR Preparations 8/31/2023 8/1/2024 0.91 $19,315 Decon Pd 5 Dormancy With Dry Storage 8/1/2024 10/30/2059 35.24 $64,860 Decon Pd 6 Dormancy Only 10/30/2059 9/26/2073 13.90 $37,311 Decon Pd 7 Decommissioning Planning During Dormancy 9/26/2073 317/2075 1.44 $50,840 Decon Pd 8 Internals Segmentation and Site Preparations 317/2075 7116/2076 1.36 $120,283 Decou Pd 9 Major Component and Systems Removal 7116/2076 5/19/2078 1.83 $221,117 Decon Pd 10 Building Decontamination 5/19/2078 1/3/2080 1.62 $103,240 Decon Pd 11 License Termination 1/3/2080 9/19/2080 0.71 $4,451 Account Total 61.41 $724,688 Spent Fuel (50.54(bb))

SNFPd 1 Spent Fuel Planning 41112019 10/30/2020 1.58 $443 SNFPd 2 Spent Fuel Cooling During Zirc Fire Window 10/30/2020 10/30/2021 0.99 $18,432 SNFPd 3 Spent Fuel Transfer to Dry Storage 10/30/2021 8/31/2023 1.83 $111,169 Dry Storage During Completion of SAFSTOR SNFPd4 8/31/2023 8/1/2024 0.91 $2,941 Preparations SNFPd 5 Dry Storage During Dormancy 811/2024 1013012059 35.24 $121,582 SNFPd 6 ISFSI Demolition Delay 1013012059 12/31/2077 18.17 $0 SNFPd 7 ISFSI and Support Structure Clean Demolition 12/31/2077 7/28/2078 0.57 $4,898

!Account Total 59.29 $259,466 Greenfield GrnPd 1 Clean Building Demolition During Decommissioning 6/22/2078 1/3/2080 1.53 $34,233 Grn Pd 2 Site Restoration 1/3/2080 5/8/2080 0.34 $2,214 Account Total 1.87 $36,447 ISFSID&D (72.30)

ISFSI D&D Pd l ISFSI D&D Planning 8/23/207 5 12/30/2077 2.35 $887 ISFSI D&D Pd 2 ISFSI Final Status Survey 12/30/2077 1/12/2079 1.03 $754 Account Total 3.38 $1,640 Scenario Total $1,022,240 Note: Numbers may not add due to rounding.

24

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-2 Utility Staff Levels 1 License Termination - 50.75(c) Utility Staff Decou Decou Decou Decon Decou Decon Decon Decou Decon Decou Decou Department Pd 1 Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Pd8 Pd9 Pd 10 Pd 11 Administration and Support 1 22 3 3 0 0 3.50 10 10 8.5 3 Emergency Preparedness 0.5 0 0 0 0 0 0 0 0 0 0 Engineering, Oversight and Licensing 9.75 43 3 3 0 0 12 16.75 15.25 II 2 Executive Management 0.25 10 1 1 2 2 2.50 3 3 3 1 Plant Maintenance 1.5 47 4 4 1 1 I 19 10 5 0 Plant Operations2 1.25 44.83 3 3 0 0 0 4 4 I 0 Quality Assurance 0 2 0 0 0 0 0 2 3 3 2 Radiation Protection & Chemistry 2.75 26 5 5 2 2 4.5 19 37 37 I Period Totals 17 194.83 19 19 5 5 23.75 73.75 82.25 68.5 9 s;pent Fuel

• 50.54(bb) Utility Staff SNF SNF SNF SNF SNF SNF SNF Department Pd 1 Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Administration and Support 0 0 0 0 0 0 0.5 Emergency Preparedness 0 4 4 0 0 0 0 Engineering, Oversight and Licensing 0.75 0 0 0 0 0 1.25 Plant Maintenance 0.25 0 0 0 0 0 0 Radiation Protection & Chemistry 0 0 0 0 0 0 0.5 Spent Fuel Pool Operations 0 45 45 0 0 0 0 Period Total 1 49 49 0 0 0 2.25 1

Security staff levels are safeguards information and theref01:e not included.

2 Plant Operations staff during Decon Pd 2 includes personnel required to defuel the reactor.

25

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Table 6-2 (Continued)

Utility Staff Levels G reen fi1eId - UT h1ty S taff GrnPd GrnPd Department 1 2 Administration and Support 0.5 0.5 Engineering, Oversight and Licensing 2.5 2 Executive Management 0 0.25 Quality Assurance 0.75 0 Radiation Protection & Chemistry 0 0.25 Period Totals 3.75 3

' D&D - U h1tv ISFSI T St a ff ISFSID&D ISFSID&D Depmtment Pdl Pd2 Engineering, Oversight and Licensing l l Quality Assurance 0 0.75 Radiation Protection & Chemistry 0.5 0.5 Period Totals 1.5 2.25 26

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-3 Decommissioning General Contractor (DGC) Staff Levels License Termination - 50.75(c) DGC Staff Decon Decon Decon Decon Decon Decon Decon Decon Decon Decon Decon Department Pdl Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Pd8 Pd9 PdlO Pdll Administration 0 0 0 0 0 0 4 9 9 9 l Decon Operations 0 0 0 0 0 0 2 6 18 14 0 Engineering 0 0 0 0 0 0 2.5 6 6 4.50 I Environmental Health & Safety 0 0 0 0 0 0 1.5 5 6 6 0 Executive 0 0 0 0 0 0 3 4 4 4 2 Project Controls Work Planning 0 0 0 0 0 0 4.5 7 7 5 I Quality Assurance 0 0 0 0 0 0 0.5 I 2 2 l Radiation Protection 0 0 0 0 0 0 I 13 33 24 l Site Closure 0 0 0 0 0 0 0.5 2 4 5 3 Waste Operations 0 0 0 0 0 0 I 4 II 10 0 Period Totals 0 0 0 0 0 0 19 57 99.5 84 8 S,pent F*ue l - 50 54(bb) DGC Staff SNF SNF SNF SNF SNF SNF SNF Department Pdl Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Administration 0 0 0 0 0 0 0 Decon Operations 0 0 0 0 0 0 I Engineering 0 0 0 0 0 0 I Environmental Health & Safety 0 0 0 0 0 0 l Executive 0 0 0 0 0 0 0 Project Controls Work Planning 0 0 0 0 0 0 0 Quality Assurance 0 0 0 0 0 0 0 Radiation Protection 0 0 0 0 0 0 0 Site Closure 0 0 0 0 0 0 I Waste Operations 0 0 0 0 0 0 0 Period Total 0 0 0 0 0 0 4 27

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-3 (Continued)

Decommissioning General Contractor (DGC) Staff Levels Greenfield - DGC Staff GrnPd GrnPd Department l 2 Administration 0.5 0.5 Decon Operations 2.5 2 Engineering 0 0.25 Environmental Health & Safety 0.75 0 Executive 0 0.25 Project Controls Work Planning 0 6 Quality Assurance 0 0 Radiation Protection 0 0 Site Closure 0 0 Waste Operations 0 0 Period Totals 3.75 9 ISFSI D&D - DGC Staff ISFSID&D ISFSID&D Department Pdl Pd2 Engineering, Oversight and Licensing 0 0 Quality Assurance 0 0 Radiation Protection & Chemistry 0 0 Period Totals 0 0 28

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Table 6-4 Waste Disposal Volumes Waste Waste Burial Weight Volume Volume Facility and Waste Class (LBs) (CF) (CF)

Commercial Disposal Facility for B & C Wastes Class B - Activated Hardware 47,110 308 384 Class C - Activated Hardware 91,009 226 1,670 Class B - Resin and Filters 54,926 895 1,311 193,045 1,429 3,365 GTCC 62,590 128 1,018 Enerf!,ySolutions Class A - Debris 18,599,692 329,908 456,435 Class A - Oversized Debris 7,824,790 112,378 166,355 Class A- Cask Shipment 75,416 154 1,502 Class A- Containerized Waste 207,054 2,307 4,974 Class A - Large Component 4,236,090 58,878 78,614 Mixed Waste (Lead) 30,000 85 288 30,973,042 503,709 708,169 Other Local Construction Debris Landfill 90,303,566 1,031,207 1,306,313 Process for On-Site Fill 193,657,230 2,969,411 2,969,411 Scrap Metal Recycler 26,106,954 310,382 310,382 310,067,750 4,311,000 4,586,106 Grand Total Note: Numbers may not add due to rounding.

29

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

7.0 REFERENCES

1. EnergySolutions, LLC, "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center," Document Number 82A9634, January 27, 20 I 0.

2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

3. U.S. Nuclear Regulatory Commission, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide I .202, February 2005.

4. Federal Register, Vol. 4, "Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste," NRC 10 CFR Part 961 (DOE), January 1, 1999.

5. U.S. Department of Energy, "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," January 26, 2013.

6. U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report,"

DOE/RW-0567, July 2004.

7. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NUREG/CR-0130, June 1978.

8. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672, June 1980.

9. Life-of-Plant Disposal Agreement, between EnergySolutions and FPL Energy Duane Arnold, LLC, January 1st, 2007.

10. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," NUREG-1575, Rev. 1, August 2000.

11. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.

12. RS Means, "Labor Rates for the Construction Industry," 2018 30

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Appendix A List of Systems and Structures

Duane Arnold Energy Center System and Structure List Unit 1 Type System Name or Description ESS Area Rad Monitoring ESS Breathing Air ESS C02 Fire Protection ESS Control Bldg HV AC ESS Diesel Generator HV AC ESS Diesel Oil System ESS Domestic Water ESS Drywell Sumps ESS Fire Protection ESS Fuel Pool Cooling & Cleanup ESS Instrument Air ESS Liquid Radwaste ESS LLRPSF Area HV AC ESS LLRPSF Area Sumps ESS Offgas Exhaust ESS Primary Containment ESS Primary Containment HV AC ESS Radwaste Bldg HV AC ESS Radwaste Bldg Sumps ESS Reactor Bldg HV AC ESS Reactor Bldg Sumps ESS Reliable Hard Pipe Vent Modification ESS RW Evaporator & Solid ESS SEDS Self Engaging Dewatering System ESS Service Air ESS Solid Radwaste ESS Spent fuel pool instrumentation ESS Stack Gas & Bldg Kaman Rad Monitoring ESS Standby Diesel Generator ESS Training Center & Equipment ESS Turbine Bldg HV AC ESS Turbine RB Radwaste Bldg Sampling ESS Well Water NON Admin Bldg Sumps NON Administration Bldg HV AC NON Aux Heating Sys Boiler NON Chlorination & Acid Feed NON Circulating Water NON Condensate & Demin Water NON Condensate Demineralizer NON Condenser Air Removal NON Containment Atm Dilution NON Containment Atmosphere Control NON Cooling Tower NON Data Acquisition Center HV AC NON Drywell Radiation Monitors Page 1of4

Duane Arnold Energy Center System and Structure List Unit I Type System Name or Description NON Electrical NON Extract Steam Htr-Vents-Drns NON Fcedwater NON General Service Water NON H2 Water Chemistry NON Hydrogen Seal Oil NON Intake Structure HV AC NON Lube Oil Transfer & Storage NON Mach Shop & OG Bldg HV AC NON Makeup Demineralizer NON MiscHVAC NON Nitrogen NON Offgas Bldg Sumps NON Offgas Recombiner NON Post Accident Sampling NON Pumphouse HV AC NON Reactor Bldg Closed Cooling Water NON Reactor Water Cleanup NON Residual Heat Removal NON RHR Service Water NON River Water Supply NON Sanitary Drains NON Standby Gas Treatment NON Stator Cooling NON Technical Suppor Center HV AC NON Torus Vacuum Breakers NON Turbine Bldg Sumps NSSS Condensate NSSS Condenser NSSS CRD Hydraulic NSSS Emergency Service Water NSSS High Pressure Coolant Injection NSSS Low Pressure Core Spray NSSS Main Steam NSSS Nuclear Boiler NSSS Reactor Core Isolation Cooling NSSS Reactor Vessel Recirculation NSSS Standby Liquid Control NSSS Traversing Incore Probe Cal NSSS Turbine NSSS Turbine Steam Seals & Drains STRUC Administration Building STRUC Badging Center STRUC Breathing Air Enclosure STRUC Circulating Water Pipe STRUC Circulating Water Tower No I Page 2 of 4

Duane Arnold Energy Center System and Structure List Unit I Type System Name or Description STRUC Circulating Water Tower No 2 STRUC Civil Shop STRUC Compressor Building STRUC Condensate Storage Tank Foundation STRUC Construction Support Center STRUC Control Building STRUC Cooling Tower Control & Valve Housel STRUC Cooling Tower Control & Valve House 2 STRUC Cooling Tower Training STRUC Data Acquisition Center STRUC Discharge Structure STRUC East Warehouse STRUC Electrical Equipment Building - ISFSI STRUC Electrical Maintenance STRUC Existing Concrete Slabs STRUC Existing Waste Water Treatment Plant STRUC FLEX Storage Building STRUC Guard Facility and Security Structures STRUC HPCI and RCIC Building STRUC Intake Structure STRUC ISFSI - Phase 3 STRUC ISFSI Electrical Equipment Bldg STRUC ISFSI Monitoring Building STRUC Kelly Building STRUC LLRPSF Transformer Foundation STRUC Low Level Radwaste Storage and Processing STRUC Machine Shop STRUC Mechanical Maintenance STRUC New Site Support Building STRUC Off Gas Retention Building STRUC Off Gas Stack STRUC Oil Drum Storage Building STRUC Plant Support Center STRUC Pump House STRUC Radwaste Building STRUC Railroad Air-Lock STRUC Reactor Building STRUC Security Mods and Upgrades STRUC Site Transformer Foundations STRUC Sluice Gate Structure STRUC Sulfuric Acid Tank Foundation STRUC Support Shop STRUC Technical Support Center STRUC Trailer Pad STRUC Training Center STRUC Turbine Building Page 3 of 4

Duane Arnold Energy Center System and Structure List Unit I Type System Name or Description STRUC Turbine Pedestal STRUC Underground Diesel Oil Tank STRUC Underground Fuel Oil Tank STRUC Waste Staging Area STRUC Waste Water Treatment Plant STRUC Well Water Pump House 1,2,3,4 STRUC West Warehouse Page 4 of 4

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 AppendixB Spent Fuel Shipping Schedule

Duane Arnold Energy Center Spent Fuel Shipping Schedule for October 30, 2020 Shutdown Based on 2030 DOE Acceptance Assemblies Assemblies Tran.,fered from Assemblies in Total Assemblies Shipped to DOE Cumulative Fuel No Dry Pool to Dry Fuel Pool A'semblies in Assemblies in Shipped to DOE from Dry A'5emblies Year Discharged Modules Storage Storage Dry Storage On Site Storage From Pool Storage Shipped to DOE 2008 0 IO 0 1758 610 2368 0 0 0 2009 152 0 0 19IO 610 2520 0 0 0 20IO 152 0 0 2062 6IO 2672 0 0 0 2011 0 IO 610 1452 1220 2672 0 0 0 2012 152 0 0 1604 1220 2824 0 0 0 2013 0 0 0 1604 1220 2824 0 0 0 2014 152 0 0 1756 1220 2976 0 0 0 2015 0 0 0 1756 1220 2976 0 0 0 2016 152 0 0 1908 1220 3128 0 0 0 2017 0 0 0 1908 1220 3128 0 0 0 2018 152 0 0 2060 1220 3280 0 0 0 2019 0 0 0 2060 1220 3280 0 0 0 2020 368 10 6!0 1818 1830 3648 0 0 0 2021 0 0 0 1818 1830 3648 0 0 0 2022 0 0 0 1818 1830 3648 0 0 0 2023 0 30 1818 0 3648 3648 0 0 0 2024 0 0 0 0 3648 3648 0 0 0 2025 0 0 0 0 3648 3648 0 0 0 2026 0 0 0 0 3648 3648 0 0 0 2027 0 0 0 0 3648 3648 0 0 0 2028 0 0 0 0 3648 3648 0 0 0 2029 0 0 0 0 3648 3648 0 0 0 2030 0 0 0 0 3648 3648 0 0 0 2031 0 0 0 0 3648 3648 0 0 0 2032 0 0 0 0 3526 3526 0 122 122 2033 0 0 0 0 3282 3282 0 244 366 2034 0 0 0 0 3099 3099 0 183 549 2035 0 0 0 0 2916 2916 0 183 732 2036 0 0 0 0 2794 2794 0 122 854 2037 0 0 0 0 2611 2611 0 183 1037 2038 0 0 0 0 2489 2489 0 122 1159 2039 0 0 0 0 2367 2367 0 122 1281 2040 0 0 0 0 2245 2245 0 122 1403 2041 0 0 0 0 2062 2062 0 183 1586 2042 0 0 0 0 1879 1879 0 183 1769 2043 0 0 0 0 1757 1757 0 122 1891 2044 0 0 0 0 1635 1635 0 122 2013 2045 0 0 0 0 1635 1635 0 0 2013 2046 0 0 0 0 1513 1513 0 122 2135 2047 0 0 0 0 1330 1330 0 183 2318 2048 0 0 0 0 1269 1269 0 61 2379 2049 0 0 0 0 1147 1147 0 122 2501 2050 0 0 0 0 1025 1025 0 122 2623 2051 0 0 0 0 903 903 0 122 2745 2052 0 0 0 0 781 781 0 122 2867 2053 0 0 0 0 659 659 0 122 2989 2054 0 0 0 0 598 598 0 61 3050 2055 0 0 0 0 476 476 0 122 3172 2056 0 0 0 0 354 354 0 122 3294 2057 0 0 0 0 232 232 0 122 3416 2058 0 0 0 0 110 110 0 122 3538 2059 0 0 0 0 0 0 0 110 3648

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Appendix C Detailed Project Schedule

Duane Arnold Energy Center Project Schedu le for SAFSTOR, 2030 DOE Acceptance, Dry Storage S~nl Fuel PJanagemenl 15600 ays 0..10112019 0111212079

--zlrconlumFlreWin&:m~-*------------- 0 ays 10 '30t202110/30/202f Spent Fuel Ship?ng ~ -~ 10.'30/2059 10/30J2059

-*--~mFPcrr.-spenrFLIMiiilnfog--*--*------- *---- -- --..i"J-days ---o:ii01i20"19" ---1"0i3012020 s _ .. ____SNF Pd t Begins - - - ----- ---~ - - b.tmt2019 04101/20 19

• • • • • • • • • • • • p;epa;eHra:Ciaied.FUeitfaii:aQemer1i*Ptan*** * ** *******220 *cfa.Y.i *** o.t.oi*&ff9 ****oi"iii/2020

---

*-submi1-ERtoAJOw-s;;enTFuerco*sistorakenF;orn-orF**---- -- --------o-aays -- 1111212019 --n7i2mT9

---

~s;gn-spenTFUeTPOOfSeWritY1l.o -dfiCci"tlOOS___ -------- ----------------- *.. ws-days* -- 05*01m20* .....{i:i/29ii020

• • • • • - ... S.NF-Pcrn~nc1s * * ** -*** - * ---* - - * -* * * *--*--*-***** **********--*-*--*-*---------- -- ---*crdays - - -,o~i9i2620 ---16/W2020

- SNFPd 2 - sp~nt i:uercoottng*ourrngZJrcF!fe*wrnJOW-- - - - 263 days - 101301202<1 -roamoit

• * *-* ** * - sN~Pd *2-&i -gins - *----**---*** * *--**- ---- - -- ** - -- - - -o-days *- 10,*2912020 - ;M9>2020 12 ----lmP[emencspe-nTFu!TPOOISeC"UiitYMOdifieitiOnS- - - - - - - - - - - 180days *-*0212 2 1'o130720if

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-*-sNFP02t~ *- *a days - 100072i.'i2T 1'ol30J202f

• • -* SNft p(f3:*speiifFli!1fra-n-SteTIOfiiY.SiOfig-e*-----* *******:i79"<faYS. -**10!30ii()2i --o-a/3fi2023 SNFPd3Be)jins --~ Oday$ - 10.i30/202t--,0!30f2021

- -Construc:t 1SFSI Phase 2 and 3 Pad Expansion 120 days 1110 1/2021 04115/2022

• • * * *** spenrFuerPoono*pa,rtransier--**** ****************** * * * ....360<<iaVS ****cw*i;Si2022 ****oat.rimia*

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- -sNFPd 3 Ends - -- - - -- - - -- -*- *------ *-- -odays - &r'01t2024 --OM5112o24

- sNFP<fT. Dry s1orag!:-DUriiig 0ormancy--- - --- - - - * * - 9 t95 daYS 08/0112024 ~i3 012os9

---

* -$NF-Pd-.n~~Tns-----*-------- ---- - *--:--*-o-aayi --Os "OT/202'4* - OMff/202.f

i1 *----spentFUil'lfansferTo-ooE- - - - - - - - - - - --- - -- 72sa days - *OT.'06no32 - 1oiXif2o59

....... ~i'NF " p(f,fE:ridS *--** * ... ....... ... ........ .. ........ *********************-** .. -*--. *-*- Odayi "1000/2059 *- i0.il0l20.5*9

• • • -sffFPcrs:1s;:sroemomfun-oeray---*----**----- **-**---------- - * -;74Qdays --1013012059 * -12i3112on

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" - -sNFPd5 ~Ins --~ - 1273*;12o11 - 1213112077

---

sNFPcf671SFSfandSupport S!ruclurecfea n DemollUon - 150 days 1213112077 --o"il2812078 SNFPdSBeglns - - - - - ~~---r2i°3 1 f2077

---

CJiiaiibi!iiidiiiOO Of ISFSI ..... . .. *120*days .... l2/:Hl2077 ***001i6!2018 Demolish JSFSI Support Struc:tures - - - -- 60113.VS 0.J7.!5l2078 --Wt8f2078 Badd\H and Grade I FS Site - ~ays 00117f2078 ----ci7f2BJ2078

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- -1sFsroa:o*pcfT: rsFSiO&DPiWiTn9____ _____ * *- *--*5*1sdays* --*o8.i2Ji2o75 --1mo12on

- - rsFSI D&D Pd I Begin!

... ...... Preparation of ISFSI POftion °' LTP ................. ........................ .........

- - - -o--aays - 08123f2075 08/2312075

• • 221fd*ays ***aai23/26i5 ... OiiliS"f.k17i:i

• • • • • - -*- r:iACfR&Vfo-;'..J"OffSrsrp*OftiOiiTTP""*- *-- - - *---****3&raays *-*o77f7!2076 --f2!JOfiiJT!

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• • • • • • • • • • • "isFSi"D".fl'f Pd"2"B&gins****************************** . ***********a*&ys """ "i2i"30i20i7 *****12iJ0/20ii 1

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--- lSFSfD&OPd2Be9inS----------- ---------------

NRG Re~ew ______ --~ -- -* ---1~~i~ -~ ~~i --},~~;~ 213

---odays - 0111212079 - 0tit2'2079 ucensererm1nat1ort-**-* ---*------*** -**--**---****--***** *-**-*-------- - - 1eoa1ctays - ommoT9 ---for.isnoao ""ti'~---------------------,..----------+-.,.-.

Uni! 1 ShutdOv.n ~ - 10 130/2020 10/30/2020 Oecon Pd 1

• SAFSTOR Plennlng Prfor to Shutdown ~day$ -0'4t0 t f20 i9 ---rofl0/2020

--~~ ------- ~)'! - 04:01/2019 -----o:fXll/20 19 Planning ol HistOric:.31' Site Assessment ( SA and Sc:oping Survey - - - 30 days Q.l,'01/2019 ~

Piirt0im8s"A .......____ *- - --*-*-- ****** ************* *** ***********oo*cia-.;s ****osy,3i2iirn ***m-ma&H9

- per;onn~- , ---------- - ooaays - 0911al2o19 01111/2020

- -Perform SAFSTOR am g Design 220 da)'! o.t.OOl2<l19 ---0-2"07!2020

~*-~'-.*-~*~~*re*p;;raiion *oi *sAFs*t61flicense *Documen 1s * ********* ******************* ***** ****:faCi"ifaYS ****iwt1;no19 ****o6i19i20i0"

• -perto;n;-sffeEnvi"oo-menraRe~&warnrenwonmaniarA:s-sessr,i; ***-*--rai'.fdaY5 *-*04;01noT9 **-*12.(56/2019 Prepare Decommlss!onlng Cost Estimate - -----r20days - 1273072(j19 ""Ci6/t2!2020

I L

Duane Arnold Energy Center Project Schedule for SAFSTOR, 2030 DOE Acceptance, Dry Storage Prepare Post-Shuid0'1>TI b econv111ss10n1ng ACW.ites ePQfl t ys 1 19 I 20 Prepa1e Post-ShutdOwn Technic.aJ Specification (TS)f.10dlfiati0rl ---Tao- &iys ~ oi'C:l t /201 9 ~~f9 Prepare De e Saety M 1sReport {OS A) - 320days ~ 06/19!2020

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Duane Arnold Energy Center Project Schedule for SAFSTOR , 2030 DOE Acceptance, Dry Storage in

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 AppendixD Detailed Cost Table

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total A. License Termination Decon Pd l SAFSTOR Planning Prior to Shutdown Distributed I.OJ Planning of Historical Site Assessment (HSA) and Scoping Survey $233 $4 $0 $0 $31 $269 l.02 Perform HSA $207 $2 $0 $0 $27 $236 l.03 Perform Scoping Survey $249 $122 $0 $565 $122 $1,058 l.04 Perform SAFSTOR Planning and Design $481 $29 $0 $0 $66 $576 1.05 NRC Review of PSDAR and DCE $0 $0 $0 $264 $34 $298 l.06 Preparation of SAFSTOR License Documents $2,741 $15 $0 $165 $380 $3,301 l.07 Prepare SAFSTOR Integrated Work Schedule $78 $9 $0 $0 $11 $97 l.08 Prepare SAFSTOR Activity Specifications $490 $4 $0 $0 $64 $558 l.09 Prepare Detailed SAFSTOR Work Procedures $764 $0 $0 $0 $99 $864 l.10 Petform Part 37 and SNM Assessment $0 $0 $0 S50 $7 $57 Distributed Subtotal $5,243 $185 $0 $1,044 $841 $7,314 Undistributed I.OJ Utility Staff $3,557 $0 $0 $0 $462 $4,020 l.03 Security $147 $0 $0 $0 $22 $169 1.16 Workers Comprehensive Insurance $0 $5 $0 $0 $1 S6 Undistributed Subtotal $3,705 $5 $0 $0 $485 $4,195 Decon Pd 1 Subtotal $8,948 $190 $0 $1,044 $1,327 $11,509 Page I of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 2 Transition Following Shutdown Distributed 2.01 Submit Notification of Cessation of Operations $0 $0 $0 $0 $0 so 2.02 Defuel Reactor $1.160 $0 $0 $0 $151 Sl,311 2.03 Submit Notification of Fuel Removal from Vessel $0 $0 $0 $0 $0 $0 2.04 NRC Review of Post-Shutdown LARs and ERs $0 $0 $0 $564 $73 $637 2.05 Perform Activation Analyses of Reactor and Internals $49 $4 $0 $308 $47 $408 2.06 Volume Reduce Control Rods, Fuel Channels and LPRMS $1,744 $672 $16,716 $0 $4,400 $23,533 2.07 Flush and Drain Non-Essential Systems $44 $8 $1,016 $0 $246 Sl,313 2.08 Remove and Dispose of Hazardous Waste $0 $0 $0 $185 $28 $213 2.09 Drain and Process Suppression Pool Water and Hydrolase Torus Walls $0 $0 $0 $0 $0 so Distributed Subtotal $2,996 $685 $17,732 $1,057 $4,945 $27,414 Undistributed 1.01 Utility Staff $23,471 $0 $0 $0 $3,051 $26,522 1.02 Utility Staff HP Supplies $0 $581 $0 $0 $87 $668 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $271 $41 $311 1.05 Non~Nuclear Insurance $0 $0 $0 $45 $7 $52 1.06 Propetty Taxes $0 $0 $0 $100 $15 $115 1.07 NRC Annual Fees - LT $0 $0 $0 $462 $69 $531 1.08 Materials and Services $0 $3,238 $0 $0 $486 $3,724 1.09 Energy $0 $0 $0 $2,408 $361 $2,769 1.10 Environmental Permits and Fees $0 $0 $0 $8 $1 S9 1.13 DAW Disposal $0 $0 $27 $0 $4 $31 1.14 Severance $7,786 $0 $0 $0 $1,168 $8,954 1.15 Retention $443 $0 $0 $0 $66 $509 1.16 Workers Comprehensive Insurance $0 $35 $0 $0 $5 $40 Undistributed Subtotal $31,699 $3,853 $27 $3,294 $5,362 $44,234 Decon Pd 2 Subtotal $34,695 $4,538 $17,759 $4,350 $10,306 $71,649 Page 2 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 1013012020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 11112030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 3 SAFSTOR Preparation Delay During Spent Fuel Pool Operations Undistributed l.01 Utility Staff $4,362 $0 $0 $0 $567 $4,929 l.02 Utility Staff HP Supplies $0 $199 $0 $0 $30 $229 l.04 Nuclear Property and Liability Insurance $0 $0 $0 $170 $25 $195 1.05 Non-Nuclear Insurance $0 $0 $0 $83 $13 $96 1.06 Property Taxes $0 $0 $0 $183 $28 $211 l.07 NRC Annual Fees - LT $0 $0 $0 $508 $76 $585 1.08 Materials and Services $0 $604 $0 $0 $91 $694 l.09 Energy $0 $0 $0 $1,879 $282 $2,161

l. l 0 Environmental Permits and Fees $0 $0 $0 $14 $2 $17 1.13 DAW Disposal $0 $0 $5 $0 $1 $6 l.14 Severance $9,550 $0 $0 $0 $1,433 $10,983 1.16 Workers Comprehensive Insurance $0 $6 $0 $0 $1 $7 Undistributed Subtotal $13,912 $810 $5 $2,839 $2,548 $20,113 Decon Pd 3 Subtotal $13,912 $810 $5 $2,839 $2,548 $20,113 Page 3 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd4 Completion of SAFSTOR Preparations Distributed 4.01 Drain Spent Fuel Pool and Process Liquid Waste $0 $0 $0 $0 $0 so 4.02 Flush and Drain Essential Systems Following Fuel Pool Closure 527 $14 $1,016 $0 $243 Sl,300 4.03 Removal and Disposal of Spent Resins, Filter Media and Tank Sludge $28 $28 $2,540 $0 $597 S3,194 4.04 Segment, Package and Dispose of Spent Fuel Pool Island Equipment $7 $2 $190 $0 $46 $245 4.05 General Area Cleanup $1,511 $694 $195 $0 $552 $2,952 4.06 Secure Site for Dmmancy Period $0 $0 $0 $1,845 $277 $2,122 Distributed Subtotal $1,574 $738 $3,941 $1,845 $1,715 $9,812 Undistributed I.OJ Utility Staff $2,187 $0 $0 $0 $284 $2,472 l.02 Utility Staff HP Supplies $0 $100 $0 $0 $15 $115 l.04 Nuclear Propetty and Liability Insurance $0 $0 $0 $73 $11 $84 l.05 Non-Nuclear Insurance $0 $0 $0 $42 $6 $48 l.06 Property Taxes $0 $0 $0 $92 $14 $106 l.07 NRC Annual Fees - LT $0 $0 $0 $425 $64 $489 1.08 Materials and Services $0 $303 $0 $0 $45 $348 l.09 Energy $0 $0 $0 $497 $75 $572 l.10 Environmental Permit'! and Fees $0 $0 $0 $7 $1 SS 1.13 DAW Disposal $0 $0 $22 $0 $3 $25 l.14 Severance $4,550 $0 $0 $0 $683 $5,233 1.16 Workers Comprehensive Insurance $0 $3 $0 $0 $0 S4 Undistributed Subtotal $6,737 $406 $22 $1,137 $1,202 $9,504 Decon Pd4 Subtotal $8,311 $1,144 $3,963 $2,981 $2,916 $19,315 Page 4 of 22

Tabkl Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit l Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon I'd 5 Dormancy With Dry Storage Distributed 5.01 Bituminous Roof Replacement - 20 year $421 $106 $31 $0 $84 $642 5.02 Bituminous Roof Replacement - 40 year $421 $106 $31 $0 $84 $642 Distributed Subtotal $842 $212 $61 $0 $167 $1,283 Undistributed l.01 Utility Staff $25,720 $0 $0 $0 $3,344 $29,063 1.02 Utility Staff llP Supplies $0 $1,607 $0 $0 $241 $1,848 l.04 Nuclear Property and Liability Insurance $0 $0 $0 $2,798 $420 $3,217 l.05 Non~Nuclear Insurance $0 $0 $0 $801 $120 $921 l.06 Property Taxes $0 $0 $0 $641 $96 $737 l.06 Property Taxes $0 $0 $0 $1,491 $224 $1,715 l.07 NRC Annual Fees - LT $0 $0 $0 $9,770 $1,466 $11,236 l.08 Materials and Services $0 $3,053 $0 $0 $458 $3,511 1.09 Energy $0 $0 $0 $8,841 $1,326 $10,167 1.10 Environmental Pennit' and Fees $0 $0 $0 $279 $42 $320 1.13 DAW Disposal $0 $0 $31 $0 $5 $36 l.14 Severance $668 $0 $0 $0 $100 $768 1.16 Workers Comprehensive Insurance $0 $33 $0 $0 $5 $38 Undistributed Subtotal $26,388 $4,693 $31 $24,620 $7,845 $63,577 Dccon Pd 5 Subtotal $27,229 $4,905 $93 $24,620 $8,013 $64,860 Page 5 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 1013012020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/112030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 6 Dormancy Only Undistribnted 1.01 Utility Staff $10,150 $0 $0 $0 $1,319 $11,469 1.02 Utility Staff HP Supplies $0 $634 $0 $0 $95 $729 1.03 Security $5,209 $0 $0 $0 $781 $5,991 1.04 Nuclear Prope1ty and Liability Insurance $0 $0 $0 $4,416 $662 $5,078 1.05 Non-Nuclear Insurance $0 $0 $0 $316 $47 $364 1.06 Prope1ty Taxes $0 $0 $0 $348 $52 $400 1.07 NRC Annual Fees - LT $0 $0 $0 $3,855 $578 $4,434 1.08 Materials and Services $0 $2,651 $0 $0 $398 $3,048 1.09 Energy $0 $0 $0 $4,299 $645 $4,944 1.10 Environmental Penni ts and Fees $0 $0 $0 $110 $16 $126 1.13 DAW Disposal $0 $0 $12 $0 $2 $14 1.14 Severance $592 $0 $0 $0 $89 $681 1.16 Workers Comprehensive Insurance $0 $28 $0 $0 $4 $33 Undistributed Subtotal $15,951 $3,313 $12 $13,345 $4,690 $37,311 Dccon Pd 6 Subtotal $15,951 $3,313 $12 $13,345 $4,690 $37,311 Page 6 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decou Pd 7 Decommissioning Planning During Dormancy Distributed 7.01 Install Office Trailer Complex $0 $0 $0 $3,543 $532 $4,075 7.02 Select Decommissioning General Contractor $351 $5 $0 $0 $46 $403 7.03 Post SAFSTOR Decommissioning Planning $225 $0 $0 $0 $29 $254 7.04 Planning Post SAFSTOR Site Characterization $131 $2 $0 $0 $17 $151 7.05 Planning for Asbestos Abatement $137 $2 $0 $0 $18 $157 7.06 Prepare Integrated Work Sequence and Schedule for Decommissioning $179 $0 $0 $0 $23 $202 7.07 Prepare Decommissioning Activity Specifications $2,201 $19 $0 $0 $289 $2,508 7.08 Prepare Detailed Work Procedures for Decommissioning $2,154 $0 $0 $0 $280 $2,434 7.09 Update Decommissioning Cost Estimate (DCE) $281 $1 $0 $0 $37 $318 7.10 Update Post-Shutdown Decommissioning Activities Report (PSDAR) $229 $1 $0 $0 $30 $259 7.11 Planning and Design of Site Revitiliwtion $1,038 $18 $0 $0 $137 $1,193 7.12 Planning and Design Rail Spur Upgrade $252 $10 $0 $0 $34 $296 7.13 Planning and Design Cold & Dark Site Repowering $593 $7 $0 $0 $78 $677 7.14 Develop Effluent Management Plan 593 $0 $0 $0 $12 $105 7.15 Design Liquid Radwaste Treatment and Demin Makeup Water Systems $175 $0 $0 $0 $23 $198 7.16 Prepare and Submit Environmental Permits $112 $0 $0 $0 $15 $126 7.17 Design Containment Access Modifications $227 $3 $0 $0 $30 $260 7.18 Design and Procure RPV/RVI Segmentation Tooling and Equipment $2,068 519,000 $0 $0 $2,739 $23,807 7.19 Select Shipping Casks and Obtain Shipping Permits 538 $0 $0 $0 $5 $43 7.20 Purchase Canisters for GTCC Waste $0 $1,588 $0 $0 $238 Sl,826 Distributed Subtotal $10,482 $20,656 $0 $3,543 $4,611 $39,293 Undistributed l.01 Utility Staff $4,470 $0 $0 $0 $581 $5,051 l.02 Utility Staff HP Supplies $0 $157 $0 $0 $23 $180 l.03 Secmity $540 $0 $0 $0 $81 $621 l.04 Nuclear Property and Liability Insurance $0 $0 $0 $458 $69 $527 Page 7 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Altemative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repositmy Opening Date: l/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.05 Non-Nuclear Insurance $0 $0 $0 $33 $5 $38 1.06 Property Taxes $0 $0 $0 $36 $5 $41 1.07 NRC Annual Fees - LT $0 $0 $0 $400 $60 $460 1.08 Materials and Services $0 $744 $0 $0 $112 $855 1.09 Energy $0 $0 $0 $661 $99 $760 I.JO Environmental Permits and Fees $0 $0 $0 $11 $2 $13 I.I I Decommissioning General Contractor Staff $2,599 $0 $0 $0 $338 $2,936 1.12 DGC HP Supplies $0 $43 $0 $0 $6 $50 1.13 DAW Disposal $0 $0 $4 $0 $1 $4 1.16 Workers Comprehensive Insurance $0 $8 $0 $0 $1 S9 Undistributed Subtotal $7,609 $951 $4 $1,600 $1,383 $11,547 Decon Pd 7 Subtotal $18,091 $21,607 $4 $5,143 $5,994 $50,840 Page 8 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 8 Internals Segmentation and Site Preparations Distributed 8.01 Revitalize Infrastructure $0 $0 $0 $17,683 $2,652 $20,336 8.02 Implement Cold & Dark $3,095 $5,023 $0 $0 $1,218 $9,336 8.03 Install Liquid Radwaste Treatment System $0 $0 $0 $1,750 $263 $2,013 8.04 Install Demin Makeup Water System for RV! Segementation $0 $0 $0 $313 $47 $360 8.05 Perform Post-SAFSTOR Site Characterization $367 $250 $0 $0 $80 $698 8.06 Prepare License Termination Plan (LTP) $331 $10 $0 $0 $44 $385 8.07 Remove and Dispose of Spent Fuel Storage Racks $124 $281 $1,683 $0 $480 $2,569 8.08 Segment and Dispose of Drywell Head $142 $31 $49 $0 $51 $274 8.09 Reflood RPV and Steam Separator Pool for RV! Segmentation $129 $80 $0 $0 $48 $257 8.10 Remove and Dispose of Rx Head $151 $26 $757 $0 $271 $1,205 8.11 Test Special Cutting and Handling Equipment and Train Operators $1,335 $217 $0 $0 $202 Sl,753 8.12 Finalize Internals and Vessel Segmenting Details $23 $0 $0 $0 $3 $26 8.13 Segment, Package and Ship Reactor Internals $4,247 $1,449 $12,486 $0 $5,578 $23,760 8.14 RV! GTCC Waste Transportation and Disposal $0 $0 $5,674 $2,288 $1,648 $9,610 8.15 Construct New Change Rooms, Hot Laundry, Waste Staging Area $0 $1,192 $0 $0 $179 Sl,371 8.16 Modify Containment Access $454 $837 $0 $0 $194 s1,484 8.17 Upgrade Rail Spur $0 $0 $0 $2,410 $362 $2,772 8.18 Install Truck Radiological Monitoring System $0 $0 $0 $500 $75 $575 Distributed Subtotal $10,397 $9,397 $20,649 $24,944 $13,395 $78,782 Undistributed I.OJ Utility Staff $12,716 $0 $0 $0 $1,653 $14,369 1.02 Utility Staff HP Supplies $0 $533 $0 $0 $80 $613 1.03 Secmity $510 $0 $0 $0 $76 $586 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $432 $65 $497 1.05 Non-Nuclear Insurance $0 $0 $0 $62 $9 $71 1.06 Property Taxes $0 $0 $0 $34 $5 $39 Page 9 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit 1Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 11112030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total l.07 NRC Annual Fees - LT $0 $0 $0 $629 $94 $723 l.08 Materials and Services $0 $1,880 $0 $0 $282 $2,162 l.09 Energy $0 $0 $0 $727 $109 $836 I.JO Environmental Penniti.; and Fees $0 $0 $0 $11 $2 $12 l.l l Decommissioning General Contractor Staff $18,350 $0 $0 $0 $2,386 $20,736 l.12 DOC HP Supplies $0 $598 $0 $0 $90 $687 l.13 DAW Disposal $0 $0 $127 $0 $19 $146 l.16 Workers Comprehensive Insurance $0 $20 $0 $0 $3 $23 Undistributed Subtotal $31,576 $3,031 $127 $1,894 $4,873 $41,501 Decon Pd 8 Subtotal $41,973 $12,428 $20,776 $26,838 $18,267 $120,283 Page 10 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Altemative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decou Pd 9 Major Component and Systems Removal Distributed 9.01 Procure Non-Engineered Standard Equipment $0 $8,303 $0 $0 $1,079 $9,382 9.02 NRC Review and Approval of License Termination Plan $0 $0 $0 $1,078 $140 $1,218 9.03 Remove, Package and Dispose of Non-Essential Systems $12,884 $3,111 $12,412 $0 $6,534 $34,941 9.04 Perform Asbestos Abatement on Plant Systems $750 $319 $1,096 $0 $498 $2,663 9.05 Removal and Disposal of Off Gas System Adsorber $28 $28 $3,175 $0 $743 $3,974 9.06 Segment, Package and Dispose of Nuclear Steam Supply System $4,432 $1,445 $39,047 $0 $10,333 $55,257 9.07 Remove, Package and Dispose of Remaining Active Plant Systems $4,379 $1,359 $4,451 $0 $2,344 $12,533 9.08 Remove and Dispose of Control Rod Drives $330 $79 $1,585 $0 $458 $2,452 9.09 Remove and Dispose of Shield Plugs, Pool Plugs and Stud Tensioners $82 $58 $1,774 $0 $440 $2,354 9.10 Reactor Vessel Insulation Removal and Disposal $123 $21 $384 $0 $122 $650 9.11 Segment, Package and Ship Reactor Pressure Vessel $3,328 $1,394 $5,761 $0 $3,425 $13,908 9.12 Drain Dryer Separator Pool and Process Liquid Waste $0 $0 $0 $0 $0 so 9.13 Transportation and Disposal of Liquid Radwaste Filters and Resins $13 $103 $272 $0 $89 $477 9.14 Removal and Disposal of Sacrificial Shield Wall and Reactor Pedestal $399 $606 $974 $0 $455 $2,433 9.15 Segment, Package and Dispose of Refueling Bridge $60 $13 $313 $0 $89 $475 9.16 Removal and Disposal of Lead Shielding $29 $8 $181 $0 $50 $267 Distributed Subtotal $26,836 $16,847 $71,426 $1,078 $26,799 $142,987 Undistributed I.OJ Utility Staff $18,319 $0 $0 $0 $2,381 $20,701 1.02 Utility Staff HP Supplies $0 $1,648 $0 $0 $247 Sl,895 1.03 Security $689 $0 $0 $0 $103 $792 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $584 $88 $672 1.05 Non-Nuclear Insurance $0 $0 $0 $84 $13 $96 1.06 Property Taxes $0 $0 $0 $46 $7 $53 1.07 NRC Annual Fees - LT $0 $0 $0 $850 $128 $978 1.08 Materials and Services $0 $2,813 $0 $0 $422 $3,235 Page 11 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit I Shut Down: 10/30/2020 Decommissioning Altemative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.09 Energy $0 $0 $0 $834 $125 $960 I.IO Environmental Permits and Fees $0 $0 $0 $15 $2 $17 I.II Decommissioning General Contractor Staff $39,987 $0 $0 $0 $5,198 $45,186 1.12 DGC HP Supplies $0 $2,807 $0 $0 $421 $3,228 l.13 DAW Disposal $0 $0 $247 $0 $37 $284 1.16 Workers Comprehensive Insurance $0 $30 $0 $0 $5 $35 Undistributed Subtotal $58,995 $7,298 $247 $2,413 $9,177 $78,131 Decon Pd 9 Subtotal $85,831 $24,146 $71,674 $3,491 $35,976 $221,117 Page 12 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit I Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decou Pd 10 Building Decontamination Distributed 10.01 Procure Non-Engineered Standard Equipment $0 $1,453 $0 $0 $189 SJ,642 10.02 Decou Reactor Building $4,057 $3,031 $9,241 $0 $3,756 $20,085 10.03 Decou Turbine Building $745 $1,046 $771 $0 $589 $3,151 10.04 Decon Radwaste Building $162 $201 $253 $0 $142 $758 I0.05 Decon HPCI and RCIC Building $35 $53 $35 $0 $29 $152 10.06 Decon Administration Building $13 $7 $14 $0 $8 $42 10.07 Decon Off-Gas Retention Building $60 $25 $29 $0 $26 $141 l 0.08 Decon Low Level Rad waste Storage and Processing $287 $426 $361 $0 $247 Sl,321 10.09 Decon Off-Gas Stack $69 $53 $188 $0 $71 $382 I 0.10 Segment, Package and Dispose of Contaminated Decon Equipment and Tooling $24 $6 $172 $0 $46 $249 JO.I I Remove Underground Storm Drains and Manholes $33 $30 $45 $0 $25 $133 I 0.12 Transportation and Disposal of Liquid Rad waste Filters and Resins $13 $3 $272 $0 $66 $354 10.13 Demolish Waste Staging Area $543 $322 $2,441 $0 $761 $4,067 10.14 Final Status Survey for Structures $4,564 $4,377 $0 $1,087 $1,304 $11,332 10.15 Final Status Survey for Land Areas $712 $392 $0 $0 $144 Sl,248 Distributed Subtotal $11,318 $11,426 $13,823 $1,087 $7,402 $45,056 Undistributed I.OJ Utility Staff $13,175 $0 $0 $0 $1,713 $14,888 1.02 Utility Staff HP Supplies $0 $1,457 $0 $0 $219 Sl,675 l.03 Secutity $609 $0 $0 $0 $91 $700 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $516 $77 $594 l.05 Non-Nuclear Insurance $0 $0 $0 $74 $11 $85 1.06 Propetty Taxes $0 $0 $0 $41 $6 $47 1.07 NRC Annual Fees - r:r $0 $0 $0 $751 $113 $864 l.08 Matetials and Services $0 $2,099 $0 $0 $315 $2,414 1.09 Energy $0 $0 $0 $690 $104 $794 Page 13 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: l0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.10 Environmental Permits and Fees $0 $0 $0 $I3 $2 $I5 I.II Decommissioning General Contractor Staff $29,651 $0 $0 $0 $3,855 $33,506 1.12 DGC HP Supplies $0 $2,07I $0 $0 $31I $2,382 1.13 DAW Disposal $0 $0 $168 $0 $25 $194 1.16 Workers Comprehensive Insurance $0 $23 $0 $0 $3' $26 Undistributed Subtotal $43,435 $5,650 $168 $2,086 $6,844 $58,184 Decon Pd IO Subtotal $54,754 $17,076 $13,991 $3,173 $14,246 $103,240 Decon Pd 11 License Termination Distributed 11.0I Prepare Final Status Smvey Report $64 $2 $0 $0 $9 $74 11.02 NRC Review and Approval of PSS Report $0 $0 $0 $539 $70 $609 Distributed Subtotal $64 $2 $0 $539 $79 $683 Undistributed I.OJ Utility Staff $828 $0 $0 $0 $!08 $936 1.03 Security $267 $0 $0 $0 $40 $307 l.04 Nuclear Property and Liability Insurance $0 $0 $0 $226 $34 $260 l.05 Non-Nuclear Insurance $0 $0 $0 SI6 $2 $I9 1.06 Property Taxes $0 $0 $0 $18 $3 $20 1.07 NRC Annual Fees - LT $0 $0 $0 $14I $21 $I62 1.08 Materials and Se1vices $0 $I85 $0 $0 $28 $213 l.09 Energy $0 $0 $0 $4 $I $5 I.II Decommissioning General Contractor Staff $I,632 $0 $0 $0 $212 SI,844 1.16 Workers Comprehensive Insurance $0 $2 $0 $0 $0 $2 Undistributed Subtotal $2,727 $187 $0 $405 $449 $3,768 Decon Pd 11 Subtotal $2,791 $189 $0 $944 $527 $4,451 A. License Termination Subtotal $312,486 $90,346 $128,277 $88,768 $104,811 $724,688 Page 14 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repositmy Opening Date: 1/1/2030 2018 Dollars in Thousands No Hem Description Labor Equipment Disposal Other Contingency Total B. Spent Fuel SNF Pd 1 Spent Fuel Planning Distributed 12.01 Prepare Inadiated Fuel Management Plan $101 $1 $0 $0 $13 $115 12.02 Submit ER to Allow Spent Fuel Costs to Taken From DTF $0 $0 $0 $0 $0 so 12.03 Design Spent Fuel Storage Security Modifications $50 $0 $0 $0 $7 $57 Distributed Subtotal $151 $1 $0 $0 $20 $172 U ndistribnted 2.01 Utility Staff $240 $0 $0 $0 $31 $271 2.13 Workers Comprehensive Insurance $0 $0 $0 $0 $0 $0 Undistributed Subtotal $240 $0 $0 $0 $31 $272 SNF Pd l Subtotal $391 $1 $0 $0 $51 $443 Page 15 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd2 Spent Fuel Cooling During Zirc Fire Window Distributed 13.01 Implement Spent Fuel Pool Security Modifications 550 $250 $0 $0 $45 $345 Distributed Subtotal $50 $250 $0 $0 $45 $345 Undistributed 2.01 Utility Staff $524 $0 $0 $0 $68 $592 2.02 Utility Staff HP Supplies $0 $171 $0 $0 $26 $197 2.03 Security $5,679 $0 $0 $0 $852 $6,531 2.04 Spent Fuel Pool Operations Staff $6,084 $0 $0 $0 $791 $6,875 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $812 $122 $934 2.09 Materials and Services $0 $576 $0 $0 $86 $662 2.10 Emergency Preparedness Fees $0 $0 $0 $961 $144 $1,105 2.11 EPlan On-Call Shift Pay $0 $76 $0 $0 $11 $88 2.13 Workers Comprehensive Insurance $0 $25 $0 $0 $4 $28 2.14 Spent Fuel Maintenance $0 $0 $0 $500 $75 $575 2.15 Energy $0 $0 $0 $431 $65 $495 2.17 DAW Disposal $0 $0 $4 $0 $1 $5 Undistributed Subtotal $12,287 $848 $4 $2,704 $2,244 $18,087 SNFPd2 Subtotal $12,337 $1,098 $4 $2,704 $2,289 $18,432 Page 16 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd3 Spent Fuel Transrcr to Dry Storage Distributed 14.01 Construct JSFSJ Phase 2 and 3 Pad Expansion $0 $0 $0 $2,250 $338 S2,588 14.02 Spent Fuel Pool to Pad Transfer $0 $49,208 $0 $16,948 $9,923 $76,079 14.03 Consuuct ISFSI Monitoring Building $0 $0 $0 $2,000 $300 S2,300 Distributed Subtotal $0 $49,208 $0 $21,198 $10,561 $80,967 Undistributed 2.01 Utility Staff $961 $0 $0 $0 $125 SI,086 2.02 Utility Staff HP Supplies $0 $315 $0 $0 $47 $362 2.03 Security $10,425 $0 $0 $0 $1,564 $11,989 2.04 Spent Fuel Pool Operations Staff $11,167 $0 $0 $0 $1,452 $12,619 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $509 $76 $585 2.09 Materials and Services $0 $1,057 $0 $0 $159 Sl,215 2.11 EPlan On-Call Shift Pay $0 $140 $0 $0 $21 $161 2.13 Workers Comprehensive Insurance $0 $45 $0 $0 $7 $52 2.14 Spent Fuel Maintenance $0 $0 $0 $917 $138 $1,055 2.15 Energy $0 $0 $0 $930 $139 $1,069 2.17 DAW Disposal $0 $0 $8 $0 $1 S9 Undistributed Subtotal $22,554 $1,557 $8 $2,356 $3,729 $30,203 SNFPd3 Subtotal $22,554 $50,765 $8 $23,554 $14,289 $111,169 Page 17 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: !0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd4 Dry Storage During Completion of SAFSTOR Preparations Undistributed 2.03 Secmity $2,031 $0 $0 $0 $305 $2,336 2.05 Nuclear Propetty and Liability Insurance $0 $0 $0 $219 $33 $252 2.08 NRC Annual Fees - SNF $0 $0 $0 $33 $5 $38 2.09 Materials and Setvices $0 $128 $0 $0 $19 $147 2.13 Workers Comprehensive Insurance $0 $5 $0 $0 $1 $6 2.14 Spent Fuel Maintenance $0 $0 $0 $115 $17 $132 2.15 Energy $0 $0 $0 $26 $4 $30 Undistributed Subtotal $2,031 $133 $0 $393 $384 $2,941 SNFPd4 Subtotal $2,031 $133 $0 $393 $384 $2,941 SNFPdS Dry Storage During Dormancy Distributed 16.0l Spent Fuel Transfer to DOE $0 $0 $0 $6,628 $994 $7,622 Disll'ibnted Subtotal $0 $0 $0 $6,628 $994 $7,622 Undistributed 2.03 Secmity $77,828 $0 $0 $0 $!!,674 $89,502 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $8,393 $1,259 $9,651 2.08 NRC Annual Fees - SNF $0 $0 $0 $1,265 $190 $1,455 2.09 Materials and Setvices $0 $4,885 $0 $0 $733 $5,618 2.13 Workers Comprehensive Insurance $0 $210 $0 $0 $31 $241 2.14 Spent Fuel Maintenance $0 $0 $0 $4,406 $661 S5,067 2.15 Energy $0 $0 $0 $2,109 $316 S2,426 Undistributed Subtotal $77,828 $5,095 $0 $16,172 $14,864 $113,959 SNFPd5 Subtotal $77,828 $5,095 $0 $22,801 $15,858 $121,582 Page 18 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit 1Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repositoty Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd 7 ISFSI and Support Structure Clean Demolition Distributed 18.01 Clean Demolition ofISFSJ $802 $990 $1,351 $0 $409 $3,551 18.02 Demolish ISFSI Support Structures $137 $!10 $115 $0 $47 $409 18.03 Backfill and Grade ISFSI Site $23 $18 $0 $0 $5 $46 Distributed Subtotal $962 $1,118 $1,466 $0 $461 $4,006 Undistributed 2.01 Utility Staff $173 $0 $0 $0 $23 $196 2.09 Materials and Services $0 $6 $0 $0 $1 $6 2.13 Workers Comprehensive Insurance $0 $0 $0 $0 $0 so 2.15 Energy $0 $0 $0 $45 $7 $52 2.16 Decommissioning General Contractor Staff $564 $0 $0 $0 $73 $637 Undistributed Subtotal $737 $6 $0 $45 $103 $892 SNFPd7 Subtotal $1,699 $1,124 $1,466 $45 $564 $4,898 B. Spent Fuel Subtotal $116,840 $58,216 $1,478 $49,496 $33,436 $259,466 Page 19 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total C. Greenfield Grn Pd 1 Clean Building Demolition During Decommissioning Distributed 19.0l Prepare Site Restoration Demolition Plan and Schedule $108 $15 $0 $0 $16 $140 19.02 Obtain Required Demolition Permits $28 $5 $0 $10 $6 $49 19.03 Clean Building Demolition Equipment $0 $1,086 $0 $0 $163 $1,249 19.04 Perform Pre-Demolition Asbestos Abatement $12 $145 $0 $55 $32 $244 19.05 Remove :md Dispose of Underground Storage Tm1ks $19 $27 $0 $0 $6 $53 19.06 Demolish Non-Essential Stmctures $972 $670 $682 $0 $302 $2,626 19.07 Demolish Training Center $91 $46 $47 $0 $24 $208 19.08 Demolish Plant Support Center and New Site Support Building $249 $159 $162 $0 $74 $644 19.09 Demolish Cooling Towers and Related Su*uctures $741 $450 $249 $0 $187 Sl,627 19.10 Demolish Existing Waste Water Treaunent Plant $27 $7 $4 $0 $5 $43

19. l l Demolish Intake and Discharge Stmctures $128 $187 $33 $0 $45 $393 19.12 Demolish Data Acquisition and Technical Support Building $212 $157 $147 $0 $67 $584 19.13 Demolish Guard Facility and Security Structures $545 $237 $184 $0 $126 Sl,092 19.14 Demolish Control and Adminisuative Buildings $470 $329 $284 $0 $141 Sl,223 19.15 Demolish Turbine Building $2,366 $1,162 $206 $0 $485 $4,219 19.16 Demolish Low-Level Radwaste Building $1,413 $1,360 $826 $0 $468 $4,068 19.17 Demolish HPCl and RCIC Building $179 $79 $9 $0 $35 $302 19.18 Demolish Reactor Building $3,078 $1,902 $401 $0 $699 $6,080 19.19 Demolish Off-Ga.s Stack $78 $96 $24 $0 $26 $224 19.20 Demolish Misc Foundations $61 $78 $126 $0 $34 $300 Distributed Subtotal $10,779 $8,198 $3,383 $65 $2,941 $25,367 Undistributed 3.01 Utility Staff $768 $0 $0 $0 $100 $868 3.03 Energy $0 $0 $0 $117 $17 $134 3.04 Decommissioning General Contractor Staff $6,837 $0 $0 $0 $1,026 $7,863 Page 20 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 3.06 Workers Comprehensive Insurance $0 $1 $0 $0 $0 $1 Undistributed Subtotal $7,606 $1 $0 $117 $1,143 $8,866 Grn Pd l Subtotal $18,384 $8,200 $3,383 $181 $4,084 $34,233 GrnPd2 Site Restoration Distributed 20.01 Site Restoration Equipment $0 $171 $0 $0 $22 $193 20.02 Remove Temporary Structures SI I $9 $0 $0 $3 $23 20.03 Finish Grading and Re-Vegetate Site $440 $354 $0 $0 $103 $898 Distributed Subtotal $452 $535 $0 $0 $128 $1,114 Undistributed 3.01 Utility Staff $147 $0 $0 $0 $19 $167 3.02 Security $129 $0 $0 $0 $19 $149 3.04 Decommissioning General Contractor Staff $681 $0 $0 $0 $102 $783 3.06 Workers Comprehensive Insurance $0 $1 $0 $0 $0 SI Undistributed Subtotal $958 $1 $0 $0 $141 $1,099 Gm Pd2 Subtotal $1,409 $535 $0 $0 $269 $2,214 C. Greenfield Subtotal $19,794 $8,735 $3,383 $181 $4,353 $36,447 Page 21 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down:

Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total D.ISFSID&D ISFSI D&D Pd 1 ISFSI D&D Planning Distributed 21.01 Preparation of!SFSI Portion ofLTP $185 $0 $0 $0 $24 $209 21.02 NRC Review of ISFSI Portion LTP $0 $0 $0 $44 $6 $50 Distl"ibuted Subtotal $185 $0 $0 $44 $30 $259 Undistributed 4.01 Utility Staff $556 $0 $0 $0 $72 $628 Undistributed Subtotal $556 $0 $0 $0 $72 $628 ISFSID&DPd Subtotal $741 $0 $0 $44 $102 $887 ISFSI D&D Pd 2 ISFSI Final Status Survey Distributed 22.01 Final Status Smvey of ISFSI $144 $50 $0 $0 $25 $220 22.02 Preparation of FSS Report and NRC Review $101 $0 $0 $33 $17 $151 Distributed Subtotal $245 $50 $0 $33 $43 $371 Undistributed 4.01 Utility Staff $338 $0 $0 $0 $44 $382 Undistributed Subtotal ISFSID&DPd Subtotal $584 $50 $0 $33 $87 $754 D.ISFSID&D Subtotal $1,324 $50 $0 $77 $189 $1,640 Total $450,444 $157,346 $133,138 $138,523 $142,789 $1,022,240 Page 22 of 22

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 AppendixE Annual Cost by Account Table

Duane Arnold Annual Cost By Account SAFSTOR, 2030 DOE Acceptance, Utility and DGC Unit No: Unit 1 2018 Dollars in Thousands Year License Spent Fuel Site Restoration ISFSI Total Termination Demolition 2019 $4,099 $233 $0 $0 $4,331 2020 $36,182 $3,324 $0 $0 $39,506 2021 $43,735 $19,105 $0 $0 $62,840 2022 $15,949 $57,546 $0 $0 $73,495 2023 $5,110 $50,910 $0 $0 $56,020 2024 $14,895 $3,222 $0 $0 $18, 117 2025 $5,604 $3,233 $0 $0 $8,837 2026 $2,201 $3,233 $0 $0 $5,434 2027 $1,827 $3,233 $0 $0 $5,060 2028 $1,827 $3,233 $0 $0 $5,060 2029 $1,827 $3,233 $0 $0 $5,060 2030 $1,884 $3,233 $0 $0 $5, 117 2031 $1,770 $3,233 $0 $0 $5,003 2032 $1,770 $3,504 $0 $0 $5,274 2033 $1,770 $3,507 $0 $0 $5,277 2034 $1,770 $3,507 $0 $0 $5,277 2035 $1,770 $3,507 $0 $0 $5,277 2036 $1,770 $3,507 $0 $0 $5,277 2037 $1,770 $3,507 $0 $0 $5,277 2038 $1,770 $3,507 $0 $0 $5,277 2039 $1,770 $3,507 $0 $0 $5,277 2040 $2,411 $3,507 $0 $0 $5,918 2041 $1,770 $3,507 $0 $0 $5,277 2042 $1,770 $3,507 $0 $0 $5,277 2043 $1,770 $3,507 $0 $0 $5,277 2044 $1,770 $3,507 $0 $0 $5,277 2045 $1,770 $3,507 $0 $0 $5,277 2046 $1,770 $3,507 $0 $0 $5,277 2047 $1,770 $3,507 $0 $0 $5,277 2048 $1,770 $3,507 $0 $0 $5,277 2049 $1,770 $3,507 $0 $0 $5,277 2050 $1,770 $3,507 $0 $0 $5,277 2051 $1,770 $3,507 $0 $0 $5,277 2052 $1,770 $3,507 $0 $0 $5,277 2053 $1,770 $3,507 $0 $0 $5,277 2054 $2,055 $3,507 $0 $0 $5,562 Page 1 of2

Duane Arnold Annual Cost By Account SAFSTOR, 2030 DOE Acceptance, Utility and DGC Unit No: Unit 1 2018 Dollars in Thousands Year License Spent Fuel Site Restoration ISFSI Total Termination Demolition 2055 $2,126 $3,507 $0 $0 $5,633 2056 $1,770 $3,507 $0 $0 $5,277 2057 $1,770 $3,507 $0 $0 $5,277 2058 $1,770 $3,507 $0 $0 $5,277 2059 $2,159 $2,909 $0 $0 $5,069 2060 $3,077 $0 $0 $0 $3,077 2061 $2,634 $0 $0 $0 $2,634 2062 $2,634 $0 $0 $0 $2,634 2063 $2,634 $0 $0 $0 $2,634 2064 $2,634 $0 $0 $0 $2,634 2065 $2,634 $0 $0 $0 $2,634 2066 $2,634 $0 $0 $0 $2,634 2067 $2,634 $0 $0 $0 $2,634 2068 $2,634 $0 $0 $0 $2,634 2069 $2,634 $0 $0 $0 $2,634 2070 $2,634 $0 $0 $0 $2,634 2071 $2,634 $0 $0 $0 $2,634 2072 $2,634 $0 $0 $0 $2,634 2073 $15,440 $0 $0 $0 $15,440 2074 $32,608 $0 $0 $0 $32,608 2075 $78,197 $0 $0 $184 $78,381 2076 $94,001 $0 $0 $403 $94,404 2077 $118,359 $25 $0 $303 $118,688 2078 $101,052 $4,873 $6,212 $731 $112,868 2079 $57,385 $0 $27,813 $19 $85,217 2080 $4,828 $0 $2,422 $0 $7,250 Total $724,688 $259,466 $36,447 $1,640 $1,022,240 Page 2 of2

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC

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Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 1 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Blue-spotted Ambystoma laterale AMPHIBIANS E Salamander Central Newt Notophthalmus AMPHIBIANS T viridescens Bald Eagle Haliaeetus BIRDS s leucocephalus Barn Owl Tyto alba BIRDS E Henslow's Sparrow Ammodramus BIRDS T henslowii American Brook Lampetra appendix FISH T Lamprey Black Redhorse Moxostoma FISH T duquesnei Blacknose Shiner Notropis heterolepis FISH T Grass Pickerel Esox americanus FISH T Lake Sturgeon Acipenser fulvescens FISH E Orangethroat Darter Etheostoma FISH T spectabile Weed Shiner Notropis texanus FISH E Western Sand Darter Ammocrypta clara FISH T Creek Heelsplitter Lasmigona FRESHWATER T compressa MUSSELS Creeper Strophitus undulatus FRESHWATER T MUSSELS Cylindrical Papershell Anodontoides FRESHWATER T ferussacianus MUSSELS Ellipse Venustaconcha FRESHWATER T ellipsiformis MUSSELS Higgin's-eye Pearly Lampsilis higginsii FRESHWATER E E Mussel MUSSELS

• E: Endangered, T: Threatened, S: Special concern

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 2 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Pistolgrip Tritogonia verrucosa FRESHWATER E MUSSELS Slippershell Mussel Alasmidonta viridis FRESHWATER E MUSSELS Yellow Sandshell Lampsilis teres FRESHWATER E MUSSELS Baltimore Euphydryas phaeton INSECTS T Byssus Skipper Problema byssus INSECTS T Pipevine Swallowtail Battus philenor INSECTS s Swamp Metalmark Calephelis mutica INSECTS s Wild Indigo Dusky Erynnis baptisiae INSECTS s Wing Zabulon Skipper Poanes zabulon INSECTS s Zebra Swallowtail Eurytides marcellus INSECTS s Northern Long-eared Myotis septentrionalis MAMMALS T Bat Plains Pocket Mouse Perognathus MAMMALS E flavescens Southern Flying Glaucomys volans MAMMALS s Squirrel Bent Milk-vetch Astragalus distortus PLANTS (DICOTS) s Black Huckleberry Gaylussacia baccata PLANTS (DICOTS) T Buckbean Menyanthes trifoliata PLANTS (DICOTS) T Cleft Phlox Phlox bifida PLANTS (DICOTS) s Flat Top White Aster Aster pubentior PLANTS (DICOTS) s Hill's Thistle Cirsium hillii PLANTS (DICOTS) s Kitten Tails Besseya bullii PLANTS (DICOTS) T Lance-leaved Violet Viola lanceolata PLANTS (DICOTS) s

• E: Endangered, T: Threatened, S: Special concern

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 3 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Large-leaf White Viola incognita PLANTS (DICOTS) E Violet Northern St. John's- Hypericum boreale PLANTS (DICOTS) E wort Pearly Everlasting Anaphalis PLANTS (DICOTS) s margaritacea Pink Milkwort Polygala incarnata PLANTS (DICOTS) T Prairie Bush Clover Lespedeza PLANTS (DICOTS) T T leptostachya Pretty Dodder Cuscuta indecora PLANTS (DICOTS) s Prince's Pine Chimaphila umbellata PLANTS (DICOTS) T Purple Cress Cardamine douglassii PLANTS (DICOTS) s Racemed Milkwort Polygala polygama PLANTS (DICOTS) E Sage Willow Salix candida PLANTS (DICOTS) s Scarlet Hawthorn Crataegus coccinea PLANTS (DICOTS) s Shrubby Cinquefoil Potentilla fruticosa PLANTS (DICOTS) T Small Sundrops Oenothera perennis PLANTS (DICOTS) T Smooth Black-haw Viburnum prunifolium PLANTS (DICOTS) s Spring Avens Geum vernum PLANTS (DICOTS) s Tunnel-formed Penstemon tubiflorus PLANTS (DICOTS) s Penstemon Veined Skullcap Scutellaria nervosa PLANTS (DICOTS) s Violet Viola macloskeyi PLANTS (DICOTS) s Water Shield Brasenia schreberi PLANTS (DICOTS) s Water Starwort Callitriche PLANTS (DICOTS) s heterophylla Winterberry llex verticillata PLANTS (DICOTS) E

• E: Endangered, T: Threatened, S: Special concern

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 4 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Yellow Monkey Mimulus glabratus PLANTS (DICOTS) T Flower Deep Green Sedge Carex tonsa PLANTS s (MONOCOTS)

Eastern Prairie Plata nth era PLANTS E T Fringed Orchid leucophaea (MONOCOTS)

Field Sedge Carex conoidea PLANTS s (MONOCOTS)

Fringed Sedge Carex crinita PLANTS s (MONOCOTS)

Glomerate Sedge Carex aggregata PLANTS s (MONOCOTS)

Grass Pink Calopogon tuberosus PLANTS s (MONOCOTS)

Great Plains Ladies'- Spiranthes PLANTS s tresses magnicamporum (MONOCOTS)

Green's Rush Juncus greenei PLANTS s (MONOCOTS)

Hidden Sedge Carex umbellata PLANTS s (MONOCOTS)

Northern Panic-grass Dichanthelium PLANTS E boreale (MONOCOTS)

Oval Ladies'-tresses Spiranthes ovalis PLANTS T (MONOCOTS)

Pale Green Orchid Platanthera flava PLANTS E (MONOCOTS)

Purple Fringed Orchid Platanthera psycodes PLANTS T (MONOCOTS)

Richardson Sedge Carex richardsonii PLANTS s (MONOCOTS)

• E: Endangered, T: Threatened, S: Special concern

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 5 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Showy Lady's Slipper Cypripedium reginae PLANTS T (MONOCOTS)

Slender Sedge Carex tenera PLANTS s (MONOCOTS)

Small Green Platanthera clavellata PLANTS s Woodland Orchid (MONOCOTS)

Small White Lady's Cypripedium PLANTS s Slipper candid um (MONOCOTS)

Soft Rush Juncus effusus PLANTS s (MONOCOTS)

Tall Cotton Grass Eriophorum PLANTS s angustifolium (MONOCOTS)

Vasey Pondweed Potamogeton vaseyi PLANTS s (MONOCOTS)

Western Prairie Platanthera praeclara PLANTS T T Fringed Orchid (MONOCOTS)

Yellow-eyed Grass Xyris torta PLANTS E (MONOCOTS)

Crowfoot Clubmoss Lycopodium digitatum PLANTS s (PTERIODOPHYTES)

Leathery Grape Fern Botrychium PLANTS T multifidum (PTERIODOPHYTES)

Ledge Spikemoss Selaginella rupestris PLANTS s (PTERIODOPHYTES)

Little Grape Fern Botrychium simplex PLANTS T (PTERIODOPHYTES)

Northern Adder's- Ophioglossum PLANTS s tongue pusillum (PTERIODOPHYTES)

Prairie Moonwort Botrychium PLANTS s campestre (PTERIODOPHYTES)

• E: Endangered, T: Threatened, S: Special concern

Duane Arnold Energy Center Post-Shutdown Decommissioning Activities Report Attachment 2 Page 6 of 6 Table 5.1 State and Federally Listed Species Potentially Occurring in the Vicinity of DAEC Common Name Scientific Name Class State Federal Status* Status Woodland Horsetail Equisetum sylvaticum PLANTS T (PTERIODOPHYTES)

Blanding's Turtle Emydoidea blandingii REPTILES T Bullsnake Pituophis catenifer REPTILES s sayi Ornate Box Turtle Terrapene ornata REPTILES T Smooth Green Snake Liochlorophis vernalis REPTILES s Bluff Vertigo Vertigo SNAILS E meramecensis

• E: Endangered, T: Threatened, S: Special concern