L-PI-08-062, Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates

Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates

ML082260425
Person / Time
Site:	Prairie Island
Issue date:	08/08/2008
From:	Wadley M Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-08-062
Download: ML082260425 (124)

Text

NMC Prairie Island Nuclear Generating Plant Committed to Nuclear Excellen Operated by Nuclear Management Company, LLC SAUG 0 8 2008 L-PI-08-062 10 CFR 50.54 10 CFR 50.75 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimates for Prairie Island Nuclear Generating Plant (PINGP)

References:

1) Nuclear Management Company, LLC (NMC) letter to US Nuclear Regulatory Commission (NRC), "Application for Renewed Operating Licenses," dated April 11, 2008, Accession No. ML081130673.

2) NMC letter to NRC, "Decommissioning Funding Status Reports," dated March 30, 2007, Accession No. ML070890622.

The enclosed Irradiated Fuel Management Plan (Enclosure 1) and Preliminary Decommissioning Cost Estimate (Enclosure 2) are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.54(bb) "Conditions of Licenses," and 10 CFR 50.75(f)(3), "Reporting and Recordkeeping for Decommissioning Planning," respectively, for PINGP. As holder of the plant operating license, NMC is submitting these reports on behalf of the plant owner, Xcel Energy.

The financial information provided in the enclosures reflects information provided to NMC by Xcel Energy.

Pursuant to 10 CFR 50.54(bb), a licensee shall "submit written notification to the Commission 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 following permanent cessation of operation of the reactor 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 Irradiated Fuel Management Plan (Enclosure 1) is provided for NRC review and preliminary approval.

Additionally, 10 CFR 50.75(f)(3), "Reporting and Recordkeeping for Decommissioning Planning" states, "each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to 1717 Wakonade Drive East

• Welch, Minnesota 55089-9642 Telephone: 651.388.1121

Document Control Desk Page 2 decommission." Accordingly, the Preliminary Decommissioning Cost Estimate (Enclosure 2) is provided for NRC review and approval.

NMC submitted a sufficient application for renewal of the PINGP operating licenses (Reference 1) and therefore, in accordance with 10 CFR 2.109, "Effect of Timely Renewal Application," "the existing license will not be deemed to have expired until the application has been finally determined." Although NMC is seeking license renewal, the Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate are submitted based on the current operating license expiration date of August 9, 2013 for PINGP Unit 1. If PINGP's licenses are renewed, the current Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate would no longer be applicable, and a new plan and cost estimate will be submitted in accordance with 10 CFR 50.54(bb) and 10 CFR 50.75(f)(3), respectively.

If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

Michael D. Wadley Site Vice President, Prairie Island Nuclear Generating Plant, Units 1 and 2 Nuclear Management Company, LLC

Enclosures:

(2) cc:

Administrator, Region III, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC Irradiated Fuel Management Plan For Prairie Island Nuclear Generating Plant

1.

Background

The Preliminary Decommissioning Cost Estimate (Enclosure 2) in accordance with 10 CFR 50.75(f)(3) for Prairie Island Nuclear Generating Plant (PINGP) Unit 1 and Unit 2 evaluates the DECON strategy with operating licenses expiration of August 9, 2013 for Unit 1 and October 29, 2014 for Unit 2. The Irradiated Fuel Management Plan is also based on the DECON analysis and current operating license expiration dates. There is one independent spent fuel storage installation (ISFSI) on the PINGP site operating under a Site Specific Nuclear Regulatory Commission (NRC) license. Xcel Energy reserves the right to choose the ultimate decommissioning option in accordance with its business needs, recognizing the need to ensure the chosen option meets NRC requirements for decommissioning funding. Inclusion of costs in this submittal is not in-tended to acknowledge that these costs will ultimately be borne by Xcel Energy or Nuclear Management Company, LLC (NMC), as some (or all) are expected to be the responsibility of the U.S. Department of Energy as a result of the breach of the Standard Contract of Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste.

I1.

Spent Fuel Management Strategy The NRC requires (10 CFR 50.54(bb)) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the U. S. Department of Energy (DOE).

Interim storage of the irradiated fuel will be either in the spent fuel storage pool or the ISFSI located on the PINGP site until the DOE has completed the transfer to a repository. The ISFSI operates under an independent site specific license from the Nuclear Regulatory Commission. The design of the ISFSI provides room for expansion that will accommodate the inventory of spent fuel residing in PINGP's storage pool at the conclusion of the required cooling period. The ISFSI if expanded would store all spent nuclear fuel on-site.

The spent fuel pool will remain operational for a minimum of 15 years following the cessation of operations. This period provides the necessary cooling for the final irradiated fuel removed from the reactor core to meet dry storage canister requirements for decay heat. The spent fuel pool will be isolated and a spent fuel island created. Over the fifteen year cool-down period, the irradiated fuel would be packaged into TN-40 casks for transfer to DOE from the ISFSI. Transfer of irradiated fuel from the spent fuel pool to dry storage in the ISFS1 allows for early decontamination and dismantlement of plant structures. The ISFSI will remain operational and provide interim storage of spent fuel until such time that the DOE.

Page 1 of 4

Enclosure I completes fuel acceptance. Consequently, costs are included within the estimate below for the long-term caretaking of the irradiated fuel at PINGP through the year 2053.

The shipping of spent nuclear fuel assemblies to DOE during decommissioning is based upon several assumptions. First DOE would begin accepting irradiated fuel from PINGP in 2028. Second, based on DOE generator allocation/receipt schedules, the oldest irradiated fuel receives the highest acceptance priority.

Third, the maximum rate at which irradiated fuel is removed from commercial sites like PINGP is based upon 3,000 metric tons of uranium (MTU) national ac6eptance rate. However, any delay in the startup of the repository or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in the fuel remaining at the site longer. In the DECON scenario, the ISFSI will continue to operate until such time that the transfer of irradiated fuel to the DOE is complete. Finally, assuming that the DOE commences repository operation in 2025, irradiated fuel is projected to be removed from the PINGP site by the end of 2053. Consequently, costs are included within this analysis for the continued operation of the storage pool and ISFSI, as required, and for the long-term caretaking of the spent fuel until the year 2053. At the conclusion of the spent fuel transfer process the ISFSI will be decommissioned.

Operation and maintenance costs for the storage facilities (ISFSI and the spent fuel pool) are included within the estimate below and address the cost for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to an ISFSI. A cost-estimate for irradiated fuel management at PINGP under the DECON scenario may be found in Table 1.

In the event that PINGP ceases operation in 2013 and 2014 for Unit 1 and Unit 2 respectively, PINGP will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and each ISFSI, as necessary, under the decommissioning scenario ultimately selected. In addition, PINGP will also comply with applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued safe storage of irradiated fuel.

Page 2 of 4 III.

Funding for Spent Fuel Management Based on the DECON Decommissioning Option The NRC minimum decommissioning financial assurance requirement as reported in Reference 2 and set forth in 10 CFR 50.75(c) for PINGP is approximately $324.9 million for Unit1 and $324.9 million for Unit 2.

As of December 31, 2007, the PINGP decommissioning trust funds balance were

$402.4 million for Unit 1 and $430.2 for Unit 2. These funds are being supplemented with annual total Company contributions of approximately $15 million for Unit 1 and $19 million for Unit 2 based on a prescribed schedule per Minnesota Public Utility Commission direction. Adjustments to the annual contribution require approval of multiple state public utilities commissions. The trust fund monies will be used for radiological decommissioning and to pay for irradiated fuel management. However, inclusion of irradiated fuel costs in this submittal is not intended to acknowledge that these costs will ultimately be borne by Xcel Energy or NMC, as some (or all) are expected to be the responsibility of the U.S. Department of Energy as a result of the breach of the Standard Contract of Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste.

IV.

Cost Estimate For Spent Fuel Management Based on the DECON Decommissioning Option The "Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant," included cost estimates of $404 million for spent fuel management,

$1,026 million for decommissioning and $83.7 million for site restoration using a DECON scenario (Table 1). The following items are key costs estimates:

(1) The estimated cost to isolate the spent fuel pool and fuel handling systems is

$11.8 million. This cost is based on spent fuel pool isolation costs at other decommissioned facilities and engineering judgment. This cost is part of the activities necessary to maintain the spent fuel in a safe and controlled state both during the initial decommissioning activities and during the irradiated fuel cool-down period to meet dry storage canister requirement for decay heat.

(2) The estimated annual cost for the dry storage ISFSI at PINGP is approximately $6.6 million. This cost is based on actual costs at decommissioned facilities, estimated costs for facilities similar to PINGP and engineering judgment. These are annual costs incurred during the storage period, beginning in 2031 and continuing through removal of all fuel and "Greater Than Class C" radioactive material in 2053.

3) The estimated cost for preparation, packaging, and shipping of irradiated fuel to the Department of Energy (DOE) is $220 million. This cost includes the unit cost of approximately $4.1 million for each TN-40 cask. This cost is based on Page 3 of 4

Enclosure I actual costs at decommissioned facilities, estimated costs for facilities similar to PINGP, and engineering judgment.

(4) An average cost of $100,000 is used for labor and equipment to load each TN-40 onto a DOE-provided railcar for transport of the irradiated fuel to a DOE repository.

(5) The estimated ISFSI Decontamination & Dismantling cost is $12.9 million.

This cost includes disposal of the TN-40 casks.

The decommissioning schedule includes the following program period and durations for a DECON with dry storage scenario:

Period #

Activity Unit 1 & 2 Irradiated Fuel Duration (a)

(thousands, 2008 dollars)

(Months) 1 Transition and Preparation 37,582 20 2

Decommissioning 196,051 194 3b Site Restoration 20,288 28 3c & 3d ISFSI Operations 135,682 244 ISFSI Decommissioning 14,452 7

3e & 3f Dismantlement & Restoration TOTALS(b) 404,056 493 (a) Figure 4.2, Decommissioning Timeline, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant. August 2008.

(b) Columns may not add due to rounding.

Page 4 of 4 Prairie Island Nuclear Generating Plant Preliminary Decommissioning Cost Estimate I.

Introduction This report presents a summary of the preliminary decommissioning cost estimate to decommission Prairie Island Nuclear Generating Plant (PINGP) Unit 1 and Unit 2, as required by 10CFR50.75(f)(3). This cost estimate is based on the "Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant" and premised on the assumption that PINGP Unit 1 and Unit 2 permanently cease to operate in August 2013 and October 2014, respectively. The estimate assumes the eventual removal of all contaminated and activated plant components and structural materials, such that the PINGP operating licenses may be terminated to permit unrestricted use of the site. Although Nuclear Management Company, LLC (NMC) is currently seeking license renewal for PINGP, this cost estimate is based on the current operating licenses expiration dates for PINGP. If license renewal for PINGP is granted, this Preliminary Decommissioning Cost Estimate would no longer be applicable and a new estimate will be submitted in accordance with 10CFR50.75(f)(3).

I1.

Comparison of the Preliminary Cost Estimate to the Minimum Required Decommissioning Fund The minimum decommissioning financial assurance requirement for PINGP, as reported in Reference 2 and set forth in 10CFR50.75(c), is approximately $324.9 million for each unit. The total preliminary decommissioning cost estimate based on the "Decommissioning Cost Analysis" is approximately $1,513.7 million. This estimate includes approximately $1,026 million for decommissioning costs, $404 million for spent fuel management and $83.7 million for site restoration (Table 1).

II1.

Assessment of Maoor Factors That Could Affect Preliminary Cost Estimate A.

Decommissioningq Option/Method This Preliminary Decommissioning Cost Estimate assumes a DECON decommissioning option with dry storage of spent nuclear fuel. This estimate assumes cessation of operation for Unit 1 in August 2013 and Unit 2 in October 2014 and a Department of Energy (DOE) spent fuel repository open in 2025 with the first irradiated fuel leaving the plant in 2028. Interim safe storage of the irradiated fuel will be in the spent nuclear fuel storage pool and/or the ISFSI located on the PINGP site until the DOE assumes title to the spent fuel. The Page 1 of 8 ISFSI which operates under an independent Site Specific NRC license, will accommodate the inventory of spent fuel residing in the spent nuclear fuel storage pool at the conclusion of the required irradiated fuel cooling period. This cost estimate scenario includes the decontamination and dismantlement of the facility, irradiated fuel management, and restoration of the site.

B.

Potential for Known or Suspected Contamination The Preliminary Decommissioning Cost Estimate does not assume the remediation of any significant volume of contaminated soil. This assumption may be affected by continued plant operations and/or future regulatory actions, such as the development of site-specific release criteria.

C.

LLW Disposition Plan Low Level (Radioactive) Waste (LLW) disposal costs include processing, packaging, shipping, and burial/vendor costs. This Preliminary Decommissioning Cost Estimate assumes that additional disposal capacity will be available to support reactor decommissioning, particularly for the isolation of the more highly radioactive material. Therefore, for estimating purposes, Class B and C waste disposal costs were generated using the last available published pricing schedule for Barnwell in South Carolina for non-Atlantic members. Costs related to Class A waste uses the Energy Solutions rates for their open facility in Utah. Due to the high cost per cubic foot of LLW disposal, decontamination, recycling, conditioning and metal processing were incorporated into the decommissioning cost calculations in order to reduce the overall LLW disposal. costs.

D.

Preliminary Schedule of Decommissioninq Activities A schedule of the decommissioning scenario is illustrated in Table 3. Activity and period-dependent costs are estimated for each of the 5 decommissioning time periods, post-decommissioning ISFSI operation, and ISFSI decontamination and decommissioning. These time periods are briefly described in Section IV, below.

E.

Other Factors That Could Significantly Affect the Cost to Decommission NMC is currently unaware of any major site-specific factors that could have a significant effect on the cost of decommissioning. In order to anticipate unknown or unplanned occurrences during decommissioning, e.g., tool breakage, accidents, illnesses, weather delays, and labor stoppages, contingencies are applied to the cost estimates. Contingencies are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook" as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and Page 2 of 8 actual costs has shown that unforeseeable events which will increase costs are likely to occur." The amount of contingency depends on the status of design, procurement and construction; and the complexity and uncertainties within the defined project scope. The "Decommissioning Cost Analysis for PINGP" conducted by TLG Services, Inc, examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. The composite contingency value calculated for the PINGP DECON alternative is 17.07%.for Unit 1 and 17.23% for Unit 2. Individual activity contingencies range from 10% to 75%

depending on the degree of difficulty judged to be appropriate from actual decommissioning experience. Examples include: 15% for staffing and engineering; 25% for low level waste disposal; 50% for decontamination and 75% for reactor segmentation. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the remaining operating life of the station.

IV.

Preliminary Cost Estimate Considerations The Preliminary Decommissioning Cost Estimate is based on costs associated with the entire decommissioning work scope, including those activities related to the following periods of the decommissioning project: (1) Transition and Preparations, (2) Decommissioning (3) Site Restoration (4) ISFSl Operations and (5) ISFSI Decommissioning and Site Restoration. The cost estimate also includes ISFSI operating and decommissioning costs. The scope of each of those activities is described below. Disposition of LLW is also accounted for in the Preliminary Decommissioning Cost Estimate, as described in Section Ill.C, above.

A summary of activities and time duration for each DECON period follows (see Table 2 for summary of cost elements and Table 3 for cost estimates for each period):

(1) Transition and Preparations: Includes preliminary engineering and planning to permanently de-fuel the reactor, revision of Technical Specifications applicable to operating conditions and requirements, a characterization of the facility and major components, and the development of the Post-Shutdown Decommissioning Activities Report (PSDAR). This period includes activities including, but not limited to, transfer of the spent fuel to the ISFSI, draining and de-energizing of non-contaminated systems, disposal of contaminated filter elements and resin beds, decontamination of the reactor coolant system, draining of the reactor vessel, preparing lighting, alarm, and security systems, and performing radiation surveys. Period duration is estimated at 20 months.

Page 3 of 8 (2) Decommissioning: Includes continuation of spent fuel transfer from spent fuel pool to the ISFSI, commencement of shipments of irradiated fuel from the ISFSI to the DOE, removal of reactor internals and vessel, non-essential systems removal, structure decontamination, removal of spent fuel racks, and final site survey of reactor plant. Also included are physical decommissioning activities associated with the removal and disposal of contaminated components and structures. This period also includes surveys leading to the successful termination of the 10CFR50 operating license. Period duration estimated at 194 months.

(3b) Site Restoration: Includes activities required to remove contaminated materials and verify that residual radionuclide concentrations are below NRC limits. This will include prompt removal of site structures, removal of foundations and exterior walls to a nominal depth of three feet below grade, and fill and grading of the site. Period duration estimated at 28 months.

(3cl3d) ISFSI Operations: Includes continued on-site dry storage of spent fuel, completion of spent fuel shipment from pool to ISFSI. Period duration estimated at 244 months.

(3e/3f) ISFSI D&D: Includes completion of irradiated fuel shipments from dry storage to DOE, and a final survey of ISFSI and removal. Period duration estimated at 7 months.

V.

Plans for Adiusting Levels of Funding NMC submitted a sufficient application for renewal of an operating license (Reference 1) and therefore, in accordance with 10 CFR 2.109, "Effect of Timely Renewal Application," "the existing license will not be deemed to have expired until the application has been finally determined." Although NMC is seeking license renewal, the Preliminary Decommissioning Cost Estimate is submitted based on the current operating license expiration dates of August 9, 2013 for PINGP Unit 1 and October 29, 2014 for Unit 2. If license renewal for PINGP is granted, the Preliminary Decommissioning Cost Estimate would no longer be applicable and a new plan and cost estimate will be submitted in accordance with 10 CFR 50.75(f)(3).

The cost to decommission PINGP is estimated to be $1,513.7 million in 2008 dollars. The "Decommissioning Cost Analysis for PINGP" included cost estimates of approximately $1,026 million for decommissioning costs, $404 million for spent fuel management and $83.7 million for site restoration using a DECON scenario. The total estimated decommissioning costs by period and decommissioning activity are provided in Tables 1 and 2.

Page 4 of 8 The NRC minimum decommissioning financial assurance requirement for PINGP as reported in Reference 2 and set forth in1OCFR50.75(c) is approximately

$324.9 million for each unit at PINGP. As of December 31, 2007, the PINGP decommissioning trust fund balance was $402.4 million for Unit 1 and $430.2 million for Unit 2.

Xcel Energy applies reasonable earnings rates to the decommissioning funds throughout the decommissioning periods described above. In addition, the Preliminary Decommissioning Cost Estimate includes reasonable escalation factors for the decommissioning activities. Based on a cash flow analysis for the decommissioning activities to be performed for the periods described above, Xcel Energy believes that there is reasonable assurance that adequate decommissioning funds will be available to decommission PINGP Unit 1 and Unit 2 as described herein (assuming an August 2013 and October 2014 cessation of operations dates for each respective unit). Xcel Energy plans to review the decommissioning fund status on a regular basis as described above.

Page 5 of 8

Table 1 Summary of Annual D&D, Irradiated Fuel, and Site Restoration Costs (thousands, 2008 dollars)

Year Site D&D IFM Site Restore Total 2013 22,964 4,639 224 27,827 2014 82,929 14,691 997 98,617 2015 163,925 25,478 1,882 191,285 2016 169,706 23,604 2,785 196,095 2017 139,661 18,776 2,752 161,189 2018 88,448 13,724 1,524 103,696 2019 53,248 12,696 696 66,640 2020 19,457 12,098 0

31,555 2021 19,404 12,065 0

31,469 2022 19,404 12,065 0

31,469 2023 19,404 12,065 0

31,469 2024 19,457 12,098 0

31,555 2025 19,404 12,065 0

31,469 2026 19,404 12,065 0

31,469 2027 19,404 12,065 0

31,469 2028 19,457 12,098 0

31,555 2029 29,444 10,122 0

39,566 2030 65,192 979 0

66,171 2031 14,444 6,627 22,918 43,989 2032 120 8,788 31,533 40,441 2033 70 7,880 18,352 26,302 2034 0

6,644 0

6,644 2035 0

6,644 0

6,644 2036 0

6,662 0

6,662 2037 0

6,644 0

6,644 2038 0

6,644 0

6,644 2039 0

6,644 0

6,644 2040 0

6,662 0

6,662 2041 0

6,644 0

6,644 2042 0

6,644 0

6,644 2043 0

6,644 0

6,644 2044 0

6,662 0

6,662 2045 0

6,644 0

6,644 2046 0

6,644 0

6,644 2047 0

6,644 0

6,644 2048 0

6,662 0

6,662 2049 0

6,644 0

6,644 2050 0

6,644 0

6,644 2051 0

6,644 0

6,644 2052 0

6,662 0

6,662 2053 21,028 6,710 0

27,738 2054 14,346 0

14,346 Total 1,025,971 404,056 83,662 1,513,689 "I Section 3, TLG Services, Inc. Decomm August 2008.

(b) Columns may not add due to rounding.

issioning Cost Analysis for Prairie Island Nuclear Generating Plant.

Page 6 of 8

Table 2 (a)

Unit I & 2 Cost Summary of Decommissioning Cost Elements (thousands, 2008 dollars)

Cost Element Unit I Unit 2 Total Percentage Decontamination 8,873 14,101 22,974 1.5%

Removal 71,116 91,943 163,059 10.8%

Packaging 18,148 18,447 36,595 2.4%

Transportation 6,828 7,411 14,239 0.9%

Waste Disposal 48,983 50,257 99,240 6.6%

Off-site Waste Processing 13,211 15,534 28,745 1.9%

Program Management (1) 334,149 381,084 715,233 47.3%

Spent Fuel Pool Isolation 5,911 5,911 11,822 0.8%

Spent Fuel Management (direct costs) (2) 128,061 127,342 255,403 16.9%

Insurance and Regulatory Fees 24,638 22,277 46,915 3.1%

Energy 24,306 23,721 48,027 3.2%

Characterization and Licensing Surveys 8,276 9,713 17,989 1.2%

Property Taxes 21,069 19,904 40,973 2.7%

Miscellaneous Equipment 6,228 6,250 12,478 0.8%

Total (3) 719,795 793,894 1,513j689 100.0%

(1) Includes engineering and security costs (2) Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees (3) Column may not add due to rounding (a) Section 3, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant.

August 2008.

Page 7 of 8

Table 3 (a)

PINGP Unit I & Unit 2 Summary of DECON Cost Estimate by Period Cost and Activity Cost (thousands, 2008 dollars)

NRC Irradiated Fuel Total License Management Site Restoration Unit I Contingency Total Costs Term Costs Costs Costs Period 1: Transition &

Preparations 17,282 127,053 106,917 18,791 1,345 Period 2: Decontamination 72,434 472,934 370,363 98,385 4187 Period 3b: Site Restoration 4,398 34,228 195 7,851 26181 Period 3c: Fuel Storage Operation/Shipping 8,231' 67,570 0

67,570 0

Period 3d: GTCC Shipping 1,396 10,785 10,514 271 0

Period 3e: ISFSI Decon 1,108 6,474 0

6,474 0

Period 3f: ISFSI Site Restoration 98 752 0

752 0

(b) 104,947 719,795 487,988 200,095 31,712 NRC Irradiated Fuel Total License Management Site Restoration.

Unit 2 Contingency Total Costs Term Costs Costs Costs Period 1: Transition &

Preparations 15,188 112,796 93,430 18,791 576 Period 2: Decontamination 82,997 536,375 433,957 97,666 4753 Period 3b: Site Restoration 7,647 59,142 83 12,437 46621 Period 3c: Fuel Storage Operation/Shipping 8,231 67,570 0

67,570 0

Period 3d: GTCC Shipping 1,396 10,785 10,514 271 0

Period 3e: ISFSI Decon 1,108 6,474 0

6,474 0

Period 3f: ISFSI Site Restoration 98 752 0

752 0

(b) 116,665 793,894 537,983 203,961 51,950 (a) Section 3, TLG Services, Inc. Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant. August 2008.

(b) Columns may not add due to rounding.

Page 8 of 8 to Enclosures I and 2 Decommissioning Cost Analysis for Prairie Island Nuclear Generating Plant August 2008 by TLG Services, Inc.

109 pages follow

Document X01-1586-002, Rev. 0 DECOMMISSIONING COST ANALYSIS for the PRAIRIE ISLAND NUCLEAR GENERATING PLANT prepared for Xcel Energy Services, Inc.

prepared by TLG Services, Inc.

Bridgewater, Connecticut August 2008 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Page ii of xv APPROVALS Project Manager Project Engineer Technical Manager Quality Assurance Manager (acting)

Date Date Date ok/0S/0 Date Dat-e William A. Cloutier, Jr.

/JophJ Adle 4

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page iii of xv TABLE OF CONTENTS SECTION PAGE EXECUTIVE SUM M ARY....................................................................................................

vii-xv

1.

INTRODUCTION.......................................................................................................................

1-1 1.1 Objectives of Study..................................................................

1........................................ 1-1 1.2 Site Description.................................................................................................................

1-1 1.3 Regulatory Guidance..........................................................................................................

1-2 1.3.1 Nuclear W aste Policy Act................................................................................

1-4 1.3.2 Low-Level Radioactive W aste Acts.....................................................................

1-5 1.3.3 Radiological Criteria for License Term ination.....................................................

1-6

2.

'DECOMMISSIONING ALTERNATIVE DESCRIPTION...........................

2-1 2.1 Period 1 - Preparations......................................................................................................

2-1 2.1.1 Engineering and Planning................................................................................

2-1 2.1.2 Site Preparations....................... :............................................................................. 2-2 2.2 Period 2 - Decomm issioning Operations...........................................................................

2-3 2.3 Period 3 - Site Restoration.................................................................................................

2-6 2.4 ISFSI Operations and Decomm issioning..........................................................................

2-6

3.

COST ESTIM ATE......................................................................................................................

3-1 3.1 Basis of Cost Estimate.......................................................................................................

3-1 3.2 M ethodology..................................................................................................................

• ....3-1 3.3 Impact of D ecomm issioning M ultiple Reactor Units.......................................................

3-3 3.4 Financial Components of the Cost M odel........................................................................

3-4 3.4.1 Contingency....................................................................................................

3-4 3.4.2 Financial Risk........................................................................................................

3-6 3.5 Site-Specific Considerations..............................................................................................

3-7 3.5.1 Spent Fuel M anagement.......................................................................................

3-7 3.5.2 Reactor Vessel and Internal Components............................................................

3-9 3.5.3 Primary System Large Components..................................................................

3-11 3.5.4 M ain Turbine and Condenser.............................................................................

3-12 3.5.5 Transportation M ethods.....................................................................................

3-12 3.5.6 Low-Level Radioactive W aste Disposal...........................................................

3-13 3.5.7 Site Conditions Follow ing Decomm issioning...................................................

3-14 3.6 Assumptions.....................................................................................................................

3-14 3.6.1 Estimating Basis 3-14 3.6.2 Labor Costs.........................................................................................................

3-15 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Page iv of xv TABLE OF CONTENTS (continued)

SECTION PAGE 3.6.3 Design Conditions..................................................................

3-15 3.6.4 General...............................................................................

3-16 3.7 Cost Estimate Summary....................................................................

3-18

4.

SCHEDULE ESTIMATE..........................................................................

4-1 4.1 Schedule Estimate Assumptions..............................................................

4-1 4.2 Project Schedule................................................................................

4-2

5.

RADIOACTIVE WASTES..........................................................................

5-1

6.

RESULTS............................................................................................

6-I

7.

REFERENCES.......................................................................................

7-1 TABLES Cost Summary, Decommissioning Cost Elements...........................................

xv 3.1 Schedule of Total Annual Expenditures, Unit I...........................................

3-19 3.1a Schedule of License Termination Expenditures, Unit 1.........................

3-21 3.1lb Schedule of Spent Fuel Management Expenditures, Unit 1.....................

3-23 3.1c Schedule of Site Restoration Expenditures, Unit 1...............................

3-25 3.2 Schedule of Total Annual Expenditures, Unit 2...........................................

3-27 3.2a Schedule of License Termination Expenditures, Unit 2..........................

3-29 3.2b Schedule of Spent Fuel Management Expenditures, Unit 2...................... 3-31 3.2c Schedule of Site Restoration Expenditures, Unit 2...............................

3-33 5.1 Decommissioning Waste Summary..........................................................

5-3 6.1 Cost Summary, Decommissioning Cost Elements..........................................

6-3 FIGURES 4.1 Activity Schedule..............................................................................

4-3 4.2 Decommissioning Timeline..................................................................

4-5 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Page v of xv SECTI TABLE OF CONTENTS (continued)

ION PAGE APPENDICES Unit Cost Factor Development......................................

A-I Unit Cost Factor Listing..................................................................................................

B-1 D etailed C ost T ables...............................................................................................................

C -1 A.

B.

C.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Page vi of xv REVISION LOG No.

CRA No.

Date Item Revised Reason for Revision 0

08-05-08 Original Issue TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Page vii of xv

'EXECUTIVE

SUMMARY

This report presents an estimate of the cost to promptly decommission the Prairie Island Nuclear Generating Plant (Prairie Island) following the scheduled cessation of plant operations. The prompt decommissioning, or DECON method, as described below, was selected as it is the most cost-effective of the alternatives (in current dollars) to achieve the objectives of decommissioning. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,11] updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects.

The current estimate is designed to provide the plant's owners, with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear units.

The primary goal of decommissioning is the removal and disposal of the contaminated systems and structures so that the plant's operating licenses can be terminated. This analysis recognizes that spent fuel will be stored at the site in the plant's storage pool and/or in an independent spent

-fuel storage installation (ISFSI) until such time that it can be transferred to a U.S. Department of Energy (DOE) facility. Consequently, the estimate also includes those costs to manage and subsequently decommission these storage facilities.

The Prairie Island site currently consists of two operating pressurized water reactors, and Units I and 2 are each nominally rated to produce approximately 529 megawatts of electricity (MW).

The currently projected cost to decommission the station is estimated at $1,514 million, as reported in 2008 dollars. The estimate is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. *The estimate incorporates a minimum cooling period for the spent fuel that resides in the storage pool when operations cease. Any residual fuel remaining in the pool after the cooling period is relocated to the ISFSI to await transfer to a DOE facility. The estimate also includes the dismantling of site structures and non-essential facilities and the limited restoration of the site.

An ISFSI is currently operating on the Prairie Island site. The facility will contain 29 Transnuclear dry storage casks after 40 years of operation. The casks are single-purpose and the stored assemblies will be relicensed to meet transport regulations in support of final transferfto a DOE repository. An additional 39 Transnuclear casks will be purchased to accommodate all residual fuel remaining in the pool after final shutdown. Transfer of all spent fuel post-shutdown will require 15 years to allow for radioactive decay to decrease heat loading. Spent fuel is expected to be completely removed from the site by 2053.

"Decommissioning Cost Analysis for the Prairie Island Nuclear Generating Plant," Document No.

X01-1526-002, TLG Services, Inc., October 2005.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Page viii of xv Alternatives and Regulations The ultimate objective of the decommissioning process is to reduce the inventory of contaminated and activated material so that the license(s) can be terminated. The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule adopted on June 27, 1988.[21 In this rule, the NRC set forth financial criteria for decommissioning licensed nuclear power facilities. The regulations addressed planning needs, timing, funding methods, and environmental review requirements for decommissioning.

The rule also defined three decommissioning alternatives as being acceptable to the NRC: DECON, SAFSTOR, and ENTOMB.

DECON is defined as "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations." [3]

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

ENTOMB is defined as "the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete; the entombed structure is appropriately maintained and continued surveillance is carried out until the radioactive material decays to a level permitting unrestricted release of the property."'51 As with the SAFSTOR alternative, decommissioning is currently required to be completed within 60 years.

The 60-year restriction has limited the practicality for the ENTOMB alternative at commercial reactors that generate significant amounts of long-lived radioactive material.

In 1997, the Commission directed its staff to re-evaluate this alternative and identify the technical requirements and regulatory actions that would be necessary for entombment to become a viable option. The resulting evaluation provided several recommendations; however, rulemaking has been deferred pending the completion of additional research studies, for example, on engineered barriers.

2 U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72 "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988 Ibid. Page FR24022, Column 3 4

Ibid.

5 Ibid. Page FR24023, Column 2 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page ix of xv In 1996, the NRC published revisions to the general requirements.for decommissioning nuclear power plants to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process.161 The amendments allow for greater public participation and better define the transition process from operations to decommissioning.

Regulatory Guide 1.184, issued in July 2000, further described the methods and procedures acceptable to the NRC staff for implementing the requirements of the 1996 revised rule relating to the initial activities and major phases of the decommissioning process. The costs and schedules presented in this analysis follow the general guidance and processes described in the amended regulations. The format and content of the estimate is also consistent with the recommendations of Regulatory Guide 1.202, issued in February 2005.71' Methodology The methodology used to develop the estimate described within this document follows the basic approach originally presented in the cost estimating guidelines181 developed by the Atomic Industrial Forum (now Nuclear Energy Institute). This reference describes a unit factor method for determining decommissioning activity costs. The unit factors used in this analysis incorporate site-specific costs and the latest available information on worker productivity in decommissioning.

The estimate also reflects lessons learned from TLG's involvement in the Shippingport Station

,decommissioning, completed in 1989, and the decommissioning of the Cintichem reactor, hot cells and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big. Rock Point, Maine Yankee, Humboldt Bay-3, Connecticut Yankee and San Onofre-1 nuclear units have provided additional insight into the process, the regulatory aspects, and technical challenges of decommissioning commercial nuclear units.

An activity duration critical path is used to determine the total decommissioning program schedule.

The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment-rental, and support services, such as quality control and security.

Contingency Consistent with cost estimating practice, contingencies are applied to the decontamination and dismantling costs developed as "specific provision for unforeseeable elements of cost within the defined project scope, particularly important where previous experience relating estimates and actual 6

U.S. Code of Federal Regulations, Title 10, Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors,"

Nuclear Regulatory Commission, Federal Register Volume 61, (p 39 2 7 8 et seq.), July 29, 1996 7

"Standard Format and Content of Decommissioning Cost Estimates of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide 1.202, U.S. Nuclear Regulatory Commission, February 2005 8

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

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Page x of xv costs has shown that unforeseeable events which will increase costs are likely to occur."19' The cost elements in this estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line-item basis. This contingency factor is a nearly universal element in all large-scale construction and demolition projects. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the projected operating life of the station.

Contingency funds are expected to be fully expended throughout the program. As such, inclusion of contingency is necessary to provide assurance that sufficient funding will be available to accomplish the intended tasks.

Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,110] the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation.

After little progress, the "Low-Level Radioactive Waste Policy Amendments Act of 1985,"1'"'1 extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. Subsequent court rulings have substantially diluted those sanctions and, to date, no new compact facilities have been successfully sited, licensed and constructed.

In the interim, and as a proxy, the EnergySolutions' disposal facility in Clive, Utah is used as the destination for the lowest level, Class A,1 121 radioactive waste. EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C) generated in the dismantling of the reactor. The rates are comparable with those offered by the Barnwell facility in South Carolina which currently does accept Class B and C material, but which in the future would not be available to Xcel Energy under current South Carolina law. Despite the closing of one of the two currently accessible commercial disposal sites, it is reasonable to assume that additional disposal capacity will be available to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere. For estimating purposes, and as a 9

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

'0 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980 11 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986 12 U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste" TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page xi of xv proxy for future disposal facilities, waste disposal costs are estimated using available pricing schedules for the currently operating facilities, i.e., Barnwell and. EnergySolutions.

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery.

Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for Prairie Island reflects the savings from waste recovery/volume reduction.

High-Level Radioactive Waste Management Congress passed the "Nuclear Waste Policy Act""] (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high-level radioactive waste and utilities would,pay the cost of -the disposition services for that material.

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

Since the. original legislation, the DOE has announced several delays in-the program schedule. By January 1998, the DOE had failed to accept any spent fuel or high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOE's breach of contract.

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE submitted its license application in June 2008. Assuming a timely review, DOE expects that receipt of fuel could begin as early as 2017,1143 although 2020 may be more likely according to the director of the DOE's waste program.[15]

It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).1 161 This funding 13 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian Radioactive Management, 1982.

14 "DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's Office of Public Affairs, Press Release July 19, 2006.

'5 Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006.

16 U.S. Code of Federal Regulations, Title 10, Part 50, "Domestic Licensing of Production and Utilization Facilities,"

Subpart 54 (bb), "Conditions of Licenses."

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page xii of xv requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the following fifteen years the assemblies are packaged into casks and transferred to dry storage at the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet the storage canister requirements for decay heat.

DOE's contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. For purposes of this analysis, acceptance of commercial spent fuel by the DOE is expected to begin in 2025. The first assemblies removed from the Prairie Island site are assumed to be in 2028. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year, completion of the removal of fuel from the site is projected to be in the year 2053.

The existing ISFSI, which operates under the Station's general license, is expanded to support decommissioning. As such, the facility will be modified to accommodate the additional dry storage casks needed to off-load the wet storage pool so that dismantling activities can proceed.

Xcel Energy's position is that the DOE has a contractual obligation to accept Prairie Island' fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds at the end of the station's' life if, contrary to its contractual obligation, the DOE has not performed earlier.

Site Restoration Prompt dismantling of site structures (once the facilities are decontaminated) is clearly the most appropriate and cost-effective option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process is deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public and the demolition work force. Consequently, this study assumes that site structures are removed to a nominal depth of three feet below the local grade level wherever possible. The site is then to be graded and stabilized.

Summary The cost to promptly decommission the Prairie Island units assumes the removal of all contaminated and activated plant components and structural materials such that the owner(s) may then have unrestricted use of the site with no further requirements for an operating license. Low-level TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page xiii of xv radioactive

waste, other than GTCC waste, is sent to a commercial processor for treatment/conditioning or a controlled disposal facility.

Decommissioning is accomplished within the 60-year period required by current NRC regulations.

In the interim, the spent fuel remains in storage at the site until such time that the transfer to a DOE facility is complete. Once emptied, the storage facilities are also decommissioned.

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

The cost elements in this estimate are assigned to one of three subcategories: NRC License Termination, Spent Fuel Management, and Site Restoration. The subcategory "NRC License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in its financial assurance regulations (i.e., 10 CFR Part 50.75). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.

The "Spent Fuel Management" subcategory contains costs associated with the construction of an ISFSI, the containerization and transfer of spent fuel to the ISFSI that is not transferred directly to the DOE over the five and one-half years of post-shutdown pool operations, and the management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g.,

geologic repository) is complete. The estimate also includes spent fuel management expenses incurred prior to the cessation of plant operations.

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

It should be noted that the costs assigned to these subcategories are allocations. Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., ARO determinations). In reality, there can be considerable interaction between the activities in the three subcategories. For example, an owner may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to an NRC License Termination support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Page xiv of xv The estimate presented in this document reflects the total cost (100%) to decontaminate the nuclear units, manage the spent fuel until the DOE is able to complete the transfer to a federal facility, dismantle the plant and restore the site for alternative use.

As noted within this document, the estimate was developed and costs are presented in 2008 dollars.

As such, the estimate does not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the reactors or during the decommissioning period.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Page xv of xv COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)

Cost Element Unit I Unit 2 Decontamination 8,873 14,101 Removal 71,116 91,943 Packaging 18,148 18,447 Transportation 6,828 7,411 Radioactive Waste Disposal 48,983 50,257 Off-site Waste Processing 13,211 15,534 Program Management ['

334,149 381,084 Spent Fuel Pool Isolation 5,911 5,911 Spent Fuel Management (direct costs) [2]

128,061 127,342 Insurance and Regulatory Fees 24,638 22,277 Energy 24,306 23,721 Characterization and Licensing Surveys 8,276 9,713 Property Taxes 21,069 19,904 Miscellaneous Equipment 6,228 6,250 Total [3]

719,795 793,894 Cost Element Unit 1 Unit 2 License Termination 487,988 537,983 Spent Fuel Management 200,095 203,961 Site Restoration 31,713 51,950 Total [3]

719,795 793,894 t'

Includes engineering and security costs

[2]

Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging/spent fuel pool O&M and EP fees 131 Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page I of 7

1. INTRODUCTION This report presents an estimate of the cost to promptly decommission the Prairie Island Nuclear Generating Plant (Prairie Island) following the scheduled cessation of plant operations. The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,ý11 updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects. The current estimate -is designed to provide the plant's owners, with sufficient information to assess their financial obligations, as they pertain to the eventual decommissioning of the nuclear units. It is not a detailed engineering document, but a financial analysis prepared in advance of the detailed engineering that will be required to carry out the decommissioning.

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

For the purposes of this study, final shutdown dates (license expiration) for Unit 1 and Unit 2 are August 2013 and October 2014, respectively. Assuming a scheduled cessation of operations, these dates approximate a forty-year operating life.

1.2 SITE DESCRIPTION Prairie Island is located on the west bank of the Mississippi River, approximately 26 miles southeast of the Twin City Metropolitan Area and within the city limits of Red Wing. The site is in Goodhue County, Minnesota.

The Nuclear Steam Supply System (NSSS) consists of a pressurized water reactor and a two-loop reactor coolant system. The system is comprised of the reactor vessel and two closed reactor coolant loops connected in parallel to the reactor vessel, each containing a reactor coolant pump and a steam generator.

An electrically heated pressurizer is connected to one of the loops. The components were supplied by the Westinghouse Electric Corporation, with the reactor rated at a net core power output of 1650 MW(t). The steam and power conversion equipment, including the turbine-generator, has the capability to generate a gross unit output is 592 MW(e).

The system is housed within the reactor containment vessel, a free-standing cylindrical steel shell with a hemispherical dome and ellipsoidal bottom designed to withstand the internal pressure accompanying a loss-of-coolant accident., The reactor containment vessel TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. O Decommissioning Cost Analysis Section 1, Page 2 of 7 is surrounded by a cylindrical shield building constructed of reinforced concrete, -which serves as a radiation shielding for normal operations and for the loss-of-coolant condition.

Heat produced in the reactor is converted to electrical energy by the plant's power conversion system. A turbine-generator converts the thermal energy of steam produced in the steam generators into mechanical shaft power and then into electrical energy. The turbine-generator consists of one high-pressure, double-flow and two low-pressure, double-flow elements driving a direct-coupled generator at 1800 rpm. The turbines are operated in a closed feedwater cycle in which the steam is condensed and returned to the steam generators by the feedwater system.

Heat rejected in the main condensers is removed by the circulating water system, which provides the heat sink for the removal of the waste heat in the power plant's thermal cycle.

The majority of the heat is removed through dilution with river water in the discharge canal. Forced draft cooling towers provided supplemental heat removal.

1.3 REGULATORY GUIDANCE The Nuclear Regulatory Commission (NRC or Commission) provided initial decommissioning requirements in its rule "General Requirements for Decommissioning Nuclear Facilities," issued in June 1988.[2] This rule set forth financial criteria for decommissioning licensed nuclear power facilities.

The regulation addressed decommissioning planning needs, timing, funding methods, and environmental review requirements. The intent of the rule was to ensure that decommissioning would be accomplished in a safe and timely manner and that adequate funds would be available for this purpose. Subsequent to the rule, the NRC issued Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors,"'[3 which provided additional guidance to the licensees of nuclear facilities on the financial methods acceptable to the NRC staff for complying with the requirements of the rule. The regulatory guide addressed the funding requirements and provided guidance on the content and form of the financial assurance mechanisms indicated in the rule.

The rule defined three decommissioning alternatives as being acceptable to -the NRC:

DECON, SAFSTOR, and ENTOMB. The DECON alternative assumes that any contaminated 'or activated portion of the plant's systems, structures and facilities are removed or decontaminated to levels that permit the site to be released for unrestricted use shortly after the cessation of plant operations. The rule also placed limits on the time allowed to complete the decommissioning process. For SAFSTOR, the process is restricted in overall duration to 60 years, unless it can be shown that a longer duration is necessary to protect public health and safety. The guidelines for ENTOMB are similar, providing the NRC with both sufficient leverage and flexibility to ensure that this deferred option is only used in situations where it is reasonable and consistent with the definition of decommissioning. At the conclusion of a 60-year dormancy period (or longer for TLG Services, Inc;

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 3 of 7 ENTOMB if the NRC approves such a, case), the site would still require significant remediation to meet the unrestricted release limits for license termination.

The ENTOMB alternative has not been viewed as a viable option for power reactors due to the significant time required to isolate the long-lived radionuclides for decay to permissible levels. With rulemaking permitting the controlled release of a site,[4] the NRC has re-evaluated this alternative. The resulting feasibility study, based upon an assessment by Pacific Northwest National Laboratory, concluded that the method did have conditional merit for some, if not most reactors. However, the staff also found that additional rulemaking would be needed before this option could be treated as a generic alternative.

The NRC considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineered barriers for reactor entombmentsJ51 At this time, however, the NRC's staff has recommended that rulemaking be deferred, based upon several factors including that no licensee has committed to pursuing the entombment option, the unresolved issues associated with the disposition of greater-than-Class C material (GTCC), and the NRC's current priorities, at least until after the additional research studies are complete.

The Commission concurred with the staff's recommendation.

In 1996, the NRC published revisions to the general requirements for decommissioning nuclear power plants.16] When the decommissioning regulations were adopted in 1988, it was assumed that the majority of licensees would decommission at the end of the facility's operating licensed life. Since that time, several licensees permanently and prematurely ceased operations. Exemptions from certain operating requirements were required once the reactor was defueled to facilitate the decommissioning. Each case was handled individually, without clearly defined generic requirements. The NRC amended the decommissioning regulations in 1996 to clarify ambiguities and codify procedures and terminology as a means of enhancing efficiency and uniformity in the decommissioning process. The amendments allow for greater public participation and better define the transition process'from operations to decommissioning.

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

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 4 of 7 1.3.1 Nuclear Waste Policy Act Congress passed the "Nuclear Waste Policy Act"I71 (NWPA) in 1982, assigning the federal government's long-standing responsibility for disposal of the spent nuclear fuel created by the commercial nuclear generating plants to the DOE. The NWPA provided that DOE would enter into contracts with utilities in which DOE would promise to take the utilities' spent fuel and high level waste, and utilities would pay the cost of the disposition services for that material. NWPA, along with the individual disposal contracts with the utilities, specified that the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the program schedule. By January 1998, the DOE had failed to accept spent nuclear fuel and high level waste, as required by the NWPA and utility contracts. Delays continue and, as a result,, generators have initiated legal action against the DOE in an attempt to obtain compensation for DOE's breach of contract.

Operation of DOE's yet-to-be constructed repository is contingent upon the review and approval of the facility's license application by the NRC and the successful resolution of pending litigation. The DOE filed the license application in June 2008. Assuming a timely review, DOE expects that receipt of -fuel could begin as early as 2017,[8]

although 2020 may be more likely according to the director of the DOE's waste program.[9]

It is generally necessary that spent fuel be actively cooled and stored for a minimum period at the generating site prior to transfer. As such, the NRC requires that licensees establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy, pursuant to 10 CFR Part 50.54(bb).t'°' This funding requirement is fulfilled through inclusion of certain cost elements in the decommissioning estimate, for example, associated with the isolation and continued operation of the spent fuel pool and ISFSI.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles) as well as the final reactor core. Over the next fifteen years the assemblies are packaged into multipurpose canisters for transfer to DOE from the ISFSI. It is assumed that this period provides the necessary cooling for the final core to meet storage canister requirements for decay heat.

DOE's contracts with utilities generally order the acceptance of spent fuel from utilities based upon the oldest fuel receiving the highest priority. The contracts also provide for exchanges of acceptance allocations among utilities, priority acceptance of spent fuel from permanently shutdown reactors and emergency acceptance of spent TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 5 of 7 fuel. In addition, DOE has discussed the development of new contracts that would address acceptance of spent fuel from new plants. For purposes of this analysis, the acceptance of commercial spent fuel by the DOE is expected to begin in 2025. The first assemblies removed from the Prairie Island site are assumed to be in 2028. With an estimated rate of transfer of 3,000 metric tons of uranium (MTU)/year, completion of the removal of fuel from the site is projected to be in the year 2053.

An ISFSI, which Xcel Energy operates under a site-specific license, is currently in operation to support plant operations and decommissioning. As such, the facility will be modified to accommodate the dry storage casks needed to off-load the wet storage pool so that dismantling activities can proceed.

Xcel Energy's position is that the DOE has a contractual obligation to accept Prairie Island' fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. However, at this time, including the cost of storing spent fuel in this study is the most reasonable approach because it insures the availability of sufficient decommissioning funds if, contrary to its contractual obligations, the DOE has not performed.

1.3.2 Low-Level Radioactive Waste Acts The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste, although not all of the material is suitable for "shallow-land" disposal. With the passage of the "Low-Level Radioactive Waste Policy Act" in 1980,1"1 the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders.

The federal law encouraged the formation of regional groups or compacts to implement this objective safely, efficiently, and economically, and set a target date of 1986 for implementation. After little progress, the "Low-Level Radioactive Waste Policy Amendments Act of 1985,'[12] extended the implementation schedule, with specific milestones and stiff sanctions for non-compliance. Subsequent court rulings have substantially diluted those sanctions and, to date, no new compact facilities have been successfully sited, licensed and constructed.

In June 2000, South Carolina formally joined with Connecticut and New Jersey to form the Atlantic Compact. The legislation allowed South Carolina to gradually limit access to. the Barnwell facility, with only Atlantic Compact members having access to the facility after mid-year 2008. Therefore, Prairie Island is no longer able to access the disposal facility in Barnwell, South Carolina. Prairie Island still has access to the EnergySolutions facility in Clive Utah (for 10 CFR 61 Class A waste only). It is TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 1, Page 6 of 7 reasonable to assume that additional disposal capacity will be developed to support reactor decommissioning, particularly for the isolation of the more highly radioactive material that is not suitable for disposal elsewhere.

In the interim, and as a proxy, the EnergySolutions' disposal facility in Clive, Utah is used as the destination for the lowest level, Class A,[131 radioactive waste.

EnergySolutions does not have a license to dispose of the more highly radioactive waste (Class B and C) generated in the dismantling of the reactor. As such, the disposal costs for this material are based upon the last published rate schedule for non-compact waste.for the Barnwell facility.

A significant portion of the waste material generated during decommissioning may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including analyses and surveys or decontamination to eliminate the portion of waste that does not require disposal as radioactive waste, compaction, incineration or metal melt. The estimate for the Prairie Island units reflects the savings from waste recovery/volume reduction.

1.3.3 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination,"['14] amending 10 CFR Part-20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year, and provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA).

The decommissioning estimate for the Prairie Island site assumed that it will be remediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental Protection Agency (EPA) differ on the amount of residual radioactivity 'considered acceptable in site remediation. The EPA has two limits that apply to radioactive materials. An EPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).1 151 An additional and separate limit of 4 millirem per year, as defined in 40 CFR Part 141.16, is applied to drinking water.[1 6]

On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 1, Page 7 of 7 Memorandum of Understanding (MOU)1171 provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority. The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU.

The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning.

Most sites are expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees.

The present study does not include any costs for this occurrence.

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I Prairie Island Nudcear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Sedion Z Page I of 7

2. DECOMMISSIONING ALTERNATIVE DESCRIPTION A detailed cost estimate was developed to promptly decommission the Prairie Island nuclear units, (i.e., the DECON decommissioning alternative). The DECON alternative, as defined by the NRC, is "the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after cessation of operations."

The following sections describe the basic activities associated with the DECON alternative.

Although detailed procedures for each activity identified are not provided, and the actual sequence of work may vary, the activity descriptions provide a basis not only for estimating but also for the expected scope of work (i.e., engineering and planning at the time of decommissioning).

The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases. The initial phase commences with the effective date of permanent cessation of operations and involves the transition of both plant and licensee from reactor operations (i.e.,

power production) to facility de-activation and closure. During the first phase, notification is provided to the NRC certifying the permanent cessation of operations and the removal of fuel from the reactor vessel. The licensee is then prohibited from reactor operation.

The second phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two. The third phase pertains to the activities involved in license termination. The decommissioning estimate developed for Prairie Island is also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected rate of expenditure.

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

2.1.1 Engineering and Planning The PSDAR, required within two years of the notice to cease operations, provides a description of the licensee's planned decommissioning activities, a timetable, and TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 2 of 7 the associated financial requirements of the intended decommissioning program.

Upon receipt of the PSDAR, the NRC will make the document available to the public for comment in a local hearing to be held in the vicinity of the reactor site.

Ninety days following submittal and NRC receipt of the PSDAR, the licensee may begin to perform major decommissioning activities under a modified 10 CFR Part 50.59 procedure (i.e., without specific NRC approval). Major activities are defined as any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components (for shipment) containing GTCC, as defined by 10 CFR Part 61. Major components are further defined as comprising the reactor vessel and internals, steam generators, large bore reactor coolant system piping, and other large components that are radioactive. The NRC includes the following additional criteria for use of the Part 50.59 process in decommissioning. The proposed activity must not:

o foreclose release of the site for possible unrestricted use, o significantly increase decommissioning costs, o cause any significant environmental impact, or o violate the terms of the licensee's existing license.

Existing operational technical specifications are reviewed and modified to reflect plant conditions and the safety concerns associated with permanent cessation of operations.

The environmental impact associated with the planned decommissioning activities is also considered. Typically, a licensee is not allowed to proceed if the consequences of a particular decommissioning activity are greater than that bounded by previously evaluated environmental assessments or impact statements. In this instance, the licensee must submit a license amendment for the specific activity and update the environmental report.

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

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

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• Characterize the site and surrounding environs. This includes radiation surveys and sampling of the work areas, major components (including the reactor vessel and its internals), internal piping, and biological shield.

• Isolate the spent fuel storage pool and fuel 'handling systems, such that decommissioning operations can commence on the balance of the plant.

Decommissioning operations are scheduled around the fuel handling area to optimize the overall project schedule. The fuel is transferred -from the pool once it decays to the point that it meets the heat load criteria of the storage/transport containers. Consequently, it is assumed that the fuel pool will remain operational for approximately fifteen years following the cessation of plant operations while the residual inventory is transferred to the ISFSI.

• Specify of transport and disposal requirements.for activated materials and/or hazardous materials, including shielding and waste stabilization.

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

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

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

• Reconfigure and modify site structures and facilities as needed to support decommissioning operations. This may include the upgrading of roads (on-and off-site) to facilitate hauling and transport. Modifications may be required to the containment structure to facilitate access of large/heavy equipment. Modifications may also be required to the refueling area of the building to support the segmentation of the reactor vessel internals and component extraction.

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

• Procure (lease or purchase) of shipping canisters, cask liners, and industrial packages.

" Decontaminate components and piping systems as required to control (minimize) worker exposure.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XO I-1586-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 4 of 7 o Remove piping and components no longer essential to support decommissioning operations.

• Remove control rod drive housings and the head service structure from reactor vessel head. Segment the vessel closure head.

" Remove and segment the upper internals assemblies. 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.

o Disassemble and segment the remaining reactor internals, including the core former and lower core support assembly. Some material is expected to exceed Class C disposal requirements. That material will be packaged in a modified spent fuel storage canister for geologic disposal.

o Segment the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in air using remotely operated equipment within a contamination control envelope. The water level is maintained just below the cut to minimize the working area dose rates. Segments are transferred in-air to containers that are stored under water, for example, in an isolated area of the refueling canal.

o Remove activated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated cubicles necessary for access and component extraction are removed.

o Remove the steam generators and pressurizer for controlled disposal. The steam domes are removed for off-site processing. The lower shell is sealed and the nozzles and other openings welded closed. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized. Steel shielding is added, as necessary, to those external areas of the steam generators to meet transportation limits and regulations.

o Transfer any remaining spent fuel from the storage pool to the ISFSI.

At least two years prior to the anticipated date of license termination, a LTP is required.

Submitted as a supplement to the FSAR, or equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the.

site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will notice the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the Commission. The licensee may then commence with the final remediation of site facilities and services, including:

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Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 5 of 7

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

" Remove steel liners from refueling canal, disposing of the activated and contaminated sections as radioactive waste. Remove any remaining activated/ contaminated concrete.

• Survey decontaminated areas of the containment structure.

• Remediate and remove the contaminated equipment and material from the mechanical and electrical auxiliary and fuel handling buildings and any other contaminated facility.

Radiation and contamination controls are utilized until residual levels indicate that the structures and equipment can be released for unrestricted access and conventional demolition. This activity may necessitate the dismantling and disposition of most of the systems and components (both clean and contaminated) located within these buildings.

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

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

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

Incorporated into the LTP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)."I'181 This document incorporates the statistical approaches to survey design and data interpretation used by the EPA. 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 survey is complete, the results are provided to the NRC in a format that can be verified.

The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on final termination of the license.

The NRC will terminate the operating license(s) if it determines that site remediation has been performed in accordance with the LTP, and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 2, Page 6 of 7 2.3 PERIOD 3 - SITE RESTORATION Following completion of decommissioning operations, site restoration activities will begin.

Efficient removal of the contaminated materials and verification that residual radionuclide concentrations are below the NRC limits may result in substantial damage to many of the structures.

Although performed in a controlled, safe manner, blasting, coring, drilling, scarification (surface removal), and the other decontamination activities will substantially degrade power block structures including the reactor, fuel handling and mechanical and electrical auxiliary buildings. Verifying that subsurface radionuclide concentrations meet NRC site release requirements may require removal of grade slabs and lower floors, potentially weakening footings and structural supports. This removal activity is necessary for those facilities and plant areas where historical records, when available, indicate the potential for radionuclides having been present in the soil, where system failures have been recorded, or where it is required to confirm that subsurface process and drain lines were not breached over the operating life of the station.

Prompt dismantling of site structures is clearly the most appropriate option. It is unreasonable to anticipate that these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a work force already mobilized on site is more efficient than if the process were deferred. Site facilities quickly degrade without maintenance, adding additional expense and creating potential hazards to the public as well as to future workers. Abandonment creates a breeding ground for vermin infestation as well as other biological hazards.

This cost study presumes that non-essential structures and site facilities are dismantled as a continuation of the decommissioning activity. Foundations and exterior walls are removed to a nominal depth of three feet below grade. The three-foot depth allows for the placement of gravel for drainage, as well as topsoil, so that vegetation can be established for erosion control. Site areas affected by the dismantling activities are restored and the plant area graded as required to prevent ponding and inhibit the refloating of subsurface materials.

Concrete rubble produced by demolition activities is processed to remove rebar and miscellaneous embedments. The processed material is then used on site to backfill voids.

Excess materials are trucked to an off-site area for disposal as construction debris.

2.4 ISFSI OPERATIONS AND DECOMMISSIONING The ISFSI will continue to operate under a site-specific license as authorized by 10 CFR Part 72. Assuming the DOE begins to remove fuel from the Prairie Island site in 2028, the process is not expected to be completed until 2053. Any delay in the transfer process, for example, due to a delay in the scheduled opening of the geologic repository, a slower acceptance rate, or a combination of a delayed start date and lower transfer rate, can result TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 2, Page 7 of 7 in a longer on-site residence time for the fuel discharge from the reactors, as well as additional caretaking expenses.

At the conclusion of the spent fuel transferprocess, the ISFSI will be decommissioned. The Commission will terminate the license, when it determines that the remediation of the ISFSI has been performed in accordance with an ISFSI license termination plan and that the final radiation survey and associated documentation demonstrate that the facility is suitable for release.

The assumed design for the ISFSI is based upon the use of the TN-40 cask from Transnuclear. The Prairie Island ISFSI already contains twenty-four TN-40 casks, and Xcel Energy has indicated that the remainder of the Prairie Island spent fuel will be loaded into TN-40 casks as well. Therefore the TN-40 is used as a basis for this cost analysis. For purposes of this cost analysis, it is assumed that the spent fuel is shipped to DOE within the TN-40 casks. The concrete storage pad will then be removed, and the area graded and landscaped to conform to the surrounding environment. Once the spent fuel has been removed from the casks by DOE at the geologic repository, the TN-40 casks will be disposed of as low-level waste.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page I of 34

3. COST ESTIMATE The cost estimate prepared for decommissioning the Prairie Island units considers the unique features of the plant, including the nuclear steam supply system, power generation systems, support services, plant structures, and ancillary facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

3.1 BASIS OF COST ESTIMATE The analysis relies upon site-specific, technical information from an earlier evaluation prepared in 2005,E11 updated to reflect current assumptions pertaining to the disposition of the nuclear units and relevant industry experience in undertaking such projects. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluations were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

3.2 METHODOLOGY The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates,"[ 19]

and the DOE "Decommissioning Handbook.",1201 These documents present a unit factor method for estimating decommissioning activity costs, which simplifies the estimating calculations.

Unit factors for concrete removal ($/cubic yard), steel removal ($/ton), and cutting costs

($/inch) are developed using local labor rates. The activity-dependent costs are estimated with the item quantities (cubic yards and tons), developed from plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures rely upon information available in the industry publication, "Building Construction Cost Data," published by R.S. Means. [21]

The unit factor method provides a demonstrable basis for establishing a reliable cost estimate. The detail provided in the unit factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. Appendix A presents the detailed development of a typical unit factor. Appendix B provides the values contained within one set of factors developed for this analysis.

This analysis reflects lessons learned from TLG's involvement in the Shippingport Station Decommissioning Project, completed in 1989, as well as the decommissioning of the Cintichem reactor, hot cells, and associated facilities, completed in 1997. In addition, the planning and engineering for the Pathfinder, Shoreham, Rancho Seco, Trojan, Yankee TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 2 of 34 Rowe, Big Rock Point, Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and San Onofre-I nuclear units have provided additional insight into the process, the regulatory aspects, and the technical challenges of decommissioning commercial nuclear units.

Work Difficulty Factors The estimate follows the principles of ALARA through the use of work duration adjustment factors. These factors address the impact of activities such as radiological protection instruction, mock-up training, and the use of respiratory protection and protective clothing. The factors lengthen a task's duration, increasing costs and lengthening the overall schedule. ALARA planning is considered in the costs for engineering and planning, and in the development of activity specifications and detailed procedures.

Changes to worker exposure limits may impact the decommissioning cost and project schedule.

Work difficulty adjustment factors (WDFs) account for the inefficiencies in working in a power plant environment. The factors are assigned to each unique set of unit cost factors, commensurate with the inefficiencies associated with working in confined, hazardous environments. The ranges used for the WDFs are as follows:

• Access Factor 10% to 20%

Respiratory Protection Factor 10% to 50%

• Radiation/ALARA Factor 10% to 37%

• Protective Clothing Factor 0% to 30%

• Work Break Factor 8.33%

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

Scheduling Program Durations The unit factors, adjusted by the WDFs as described above, are applied against the inventory of materials to be removed in the radiological controlled areas. The resulting man-hours, or crew-hours, are used in the development of the decommissioning program schedule, using resource loading and event sequencing considerations. The scheduling of conventional removal and dismantling activities is based upon productivity information available from the "Building Construction Cost Data" publication.

An activity duration critical path is used to determine the total decommissioning program schedule. The schedule is relied upon in calculating the carrying costs, which include TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 3 of 34 program management, administration, field engineering, equipment rental, and support services such as quality control and security. This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the result.

3.3 IMPACT OF DECOMMISSIONING MULTIPLE REACTOR UNITS In estimating the near simultaneous decommissioning of two co-located reactor units there can be opportunities to achieve economies of scale, by sharing costs between units, and coordinating the sequence of work activities. There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitations on when final status surveys can take place. For purposes of the estimate, Units 1 and 2 are assumed to be essentially identical. Common facilities have been assigned to Unit 2. A summary of the principal impacts are listed below.

The sequence of work generally follows the principal that the work is done at Unit 1 first, followed by similar work at Unit 2. This permits the experience gained at Unit 1 to be applied by the workforce at the second,unit. It should be noted however, that the estimate does not consider productivity improvements at the second unit, since there is little documented experience with decommissioning two units simultaneously. The work associated with developing activity specifications and procedures can be considered essentially identical between the two units, therefore the second unit costs are assumed to be a fraction of the first unit (- 40%).

o Segmenting the reactor vessel and internals will require the use of special equipment.

The cost of procuring that equipment is assumed to be shared on an equal basis between the two units. In addition, the decommissioning project will be scheduled such that Unit 2's reactor internals and vessel are segmented immediately after the activities at Unit I have been completed.

o Some program management and support costs, particularly costs associated with the more senior positions, can be avoided with two reactors undergoing decommissioning simultaneously. As a result, the estimate is based on a "lead" unit that includes these senior positions, and a "second" unit that excludes these positions. The designation as lead is based on the unit undertaking the most complex tasks (for instance vessel segmentation) or performing tasks for the first time.

The final radiological survey schedule is also affected by a two-unit decommissioning schedule. It would be considered impractical to try to complete the final status survey of Unit 1, while Unit 2 still has ongoing radiological remediation work and waste handling in process. As a result, Unit I is assumed to enter a delay period after completion of radiological remediation, such that the final status survey can be completed for the station. During this delay, program management costs are reduced accordingly.

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• The final demolition of buildings at Units 1 and 2 are considered to take place concurrently. This is considered a reasonable assumption since. access to the buildings is considered good at the station.

• Unit 1, as the first unit to enter decommissioning, incurs the majority of site characterization costs.

" Shared systems and structures are generally assigned to Unit 2.

• Station costs such as ISFS1 operations, emergency response fees, regulatory agency fees, and insurance are generally allocated on an equal basis between the two units.

3.4,FINANCIAL COMPONENTS OF THE COST MODEL TLG's proprietary decommissioning cost model, DECCER, produces a number of distinct cost elements. These direct expenditures, however, do not comprise the total cost to accomplish the project goal (license termination and site restoration).

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

3.4.1 Contingency

'The activity-and period-dependent costs are combined to develop the total decommissioning cost. A contingency is then applied on a line-item basis, using one or more of the contingency types listed in the AIF/NESP-036 study.

"Contingencies" are defined in the American Association of Cost Engineers "Project and Cost Engineers' Handbook"' 221 as "specific provision for unforeseeable elements of cost within the defined project scope; particularly important where previous experience relating estimates and actual costs has shown that unforeseeable events which will increase costs are likely to occur." The cost elements in this analysis are based upon ideal conditions and maximum efficiency; therefore, consistent with industry practice, contingency is included. In the AIF/NESP-036 study, the types of unforeseeable events that are likely to occur in decommissioning are discussed and guidelines are provided for percentage contingency in each category. It should be noted that contingency, as used in this analysis, does not account for price escalation and inflation in the cost of decommissioning over the anticipated operating life of the station.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 5 of 34 Contingency funds are an integral part of the totalý cost to complete the decommissioning process. Exclusion of this component puts at risk a successful completion of the intended tasks and, potentially, subsequent related activities. For this study, TLG examined the major activity-related problems (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 0% to 75%, depending on the degree of difficulty judged to be appropriate from TLG's actual decommissioning experience. The contingency values used in this study are consistent with those developed in the AIF/NESP-036 study and are as follows:

• Decontamination 50%

Contaminated Component Removal 25%

" Contaminated Component Packaging 10%

• Contaminated Component Transport 15%

" Low-Level Radioactive Waste Disposal 25%

• Reactor Segmentation 75%

• Nuclear Steam Supply System Component Removal 25%

Reactor Waste Packaging 25%

• Reactor Waste Transport 25%

• Reactor Vessel Component Disposal 50%

• Greater-than-Class C Disposal 15%

" Non-Radioactive Component Removal 15%

Heavy Equipment and Tooling 15%

Supplies 25%

• Engineering 15%

" Energy 15%

• Characterization and Termination Surveys 30%

• Construction 15%

Property Taxes 0%

Fees 10%

Insurance 10%

• Staffing 15%

The contingency values are applied to the appropriate components of the estimate on a line item basis. A composite value is then reported at the end of each detailed estimate as provided in Appendix C.

TLG Services, Inc.

-Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 6 of 34 3.4.2 Financial Risk In addition to the routine uncertainties addressed by contingency, another cost element that is sometimes necessary to consider when bounding decommissioning costs relates to uncertainty, or risk. Examples can include changes in work scope, pricing, job performance, and other variations that could conceivably, but not necessarily, occur. Consideration is sometimes necessary to generate a level of-confidence in the estimate, within a range of probabilities. TLG considers these types of costs under the broad term "financial risk." Included within the category of financial risk are:

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

• Changes in the project work scope from the baseline estimate, involving the discovery of unexpected levels of contaminants, contamination in places not previously expected, contaminated soil previously undiscovered (either radioactive or hazardous material contamination), variations in plant inventory or configuration not indicated by the plant drawings.

• Regulatory changes, for example, affecting worker health and safety, site release criteria, waste transportation, and disposal.

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

• Pricing changes for basic inputs such as labor, energy, -materials, and disposal.

Items subject to widespread price competition (such as materials) may not show significant variation; however, others such as waste disposal could exhibit large pricing uncertainties, particularly in markets where limited access to services is available.

It has been TLG's experience that the results of a risk analysis, when compared with the base case estimate for decommissioning, indicate that the chances of the base decommissioning estimate's being too high is a low probability, and the chances that the estimate is too low is a higher probability. This is mostly due to the pricing uncertainty for low-level radioactive waste disposal, and to a lesser extent due to schedule increases from changes in plant conditions and to pricing variations in the cost of labor (both craft and staff). This cost study, however, does not add any additional costs to the estimate for financial risk, since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk should be revisited periodically and addressed through repeated revisions or updates of the base estimate.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 7 of 34 3.5 SITE-SPECIFIC CONSIDERATIONS There are a number of site-specific considerations that affect the method for dismantling and removal of equipment from the site and the degree of restoration required. The cost impact of the considerations identified below is included in this cost study.

3.5.1 Spent Fuel Management The cost to dispose the spent fuel generated from plant operations is not reflected within the estimate to decommission the Prairielsland units. Ultimate disposition of the spent fuel is within the province of the DOE's Waste Management System, as defined by the Nuclear Waste Policy Act (the disposal cost is financed by a 1 millikWhr surcharge paid into the DOE's waste fund during operations). However, the NRC requires licensees to establish a program to manage and provide funding for the management of all irradiated fuel at the reactor until title of the fuel is transferred to the Secretary of Energy. This funding requirement is fulfilled through inclusion of certain high-level waste cost elements within the estimate, as described below.

Operation of the DOE's yet-to-be constructed geologic repository is contingent upon the review and approval of the facility's license application by the NRC, the successful resolution of pending litigation, and the development of a national transportation system. The timetable issued by the DOE in 2006 is based upon submittal of the license application in mid-2008 (The application was submitted to the NRC in June 2008). Assuming a timely review (the application for the Private Fuel Storage's facility on the Goshute reservation took 8'/2 years), the DOE expects that receipt of fuel could begin as early as 2017. However, for purposes of this estimate, full scale operations at the repository are not expected to commence before 2025.

Spent Fuel Management Model Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site. The timing for removal of spent fuel from the site is based upon the DOE's most recently published annual acceptance rates of 400 MTU/year for year 1, 3,800 MTU total for years 2 through 4 and 3,000 MTU/year for year 5 and beyond.[231 The DOE contracts provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst utilities and the option of providing priority acceptance from permanently shutdown nuclear reactors. Because it is unclear how these mechanisms may operate once DOE begins accepting spent fuel from commercial reactors, this study assumes that DOE will accept spent fuel in an oldest fuel first order.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 8 of 34 ISFSI This analysis assumes that the existing ISFSI is modified at the cessation of plant operations to facilitate the decommissioning of the two nuclear units. The storage facility is sized to accommodate the fuel present in the storage pool at shutdown that cannot be transferred directly to the DOE.

Construction, operation and maintenance costs for the 1SFSI are included within the estimate and address the costs for staffing the facility, as well as security, insurance, and licensing fees. The estimate also includes the costs to purchase, load, and transfer the Transnuclear TN-40 metal cask storage system spent fuel storage canisters from the pool to the 1SFSI. Costs are also provided for 'the final disposition of the facilities once the transfer is complete.

Storage Canister Design The design and capacity of the ISFSI is based upon the TN-40 dry cask storage system. A capacity of 40 fuel assemblies is used, at a unit cost of approximately

$4,095,000 per cask.

Canister Loading and Transfer A cost of $100,000 is used for the labor and equipment to load each TN-40 onto a DOE-provided railcar for transport of the spent fuel to the DOE.

Operations and Maintenance An annual cost (excluding labor) of approximately $746,000 and $87,000 are used for operation and maintenance of the spent fuel pool and the ISFSI, respectively.

At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies (from the most recent refueling cycles). Over the next fifteen years the assemblies are packaged into TN-40s -for transfer to the ISFSI for transfer to the DOE. It is assumed that the fifteen years also provides the necessary cooling period for -the final core to meet transport system requirements for decay heat and/or the dry cask storage vendor's system. Once the pool is emptied, the spent fuel storage and handling facilities are available for decommissioning.

ISFSI Design Considerations The TN-40° is an ultra-high capacity vertical storage system with self-contained steel and borated resin shielding. Borated aluminum plates and stainless steel tubes form the basket assembly. The Prairie Island ISFSI already contains twenty-four TN-40 casks, and Xcel Energy has indicated that the remainder of the Prairie Island TLG Services, Inc.

2 Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 9 of 34 spent fuel will be loaded into TN-40 casks as well. Therefore the TN-40 is used as a basis for this cost analysis. While it is expected that surface contamination within the TN-40 casks could be removed to levels that meet the site release criteria, it is also expected that the casks will have some level of neutron-ihduced activation as a result of the long-term storage of the fuel (i.e., to levels exceeding free-release limits). The cost of the disposal of this material, as well as the demolition of the ISFSI, is reflected within the estimate.

GTCC The dismantling of the reactor internals generates radioactive waste considered unsuitable for shallow land disposal (i.e., low-level radioactive waste with concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste (GTCC)). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the Federal Government the responsibility for the disposal of this material. The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs of disposing of such waste. Although there are strong arguments that GTCC waste is covered by the spent fuel contact with DOE and the fees being paid pursuant to that contract, DOE has taken the position that GTCC waste is not covered by that contract or its fees and that utilities, including Xcel Energy, will have to pay an additional fee for the disposal of their GTCC waste. However, to date, the Federal Government has not identified a cost for disposing of GTCC or a schedule for acceptance. As such, the estimate to decommission the Prairie Island units includes an allowance for the disposition of GTCC material.

For purposes of this study, GTCC is packaged in the same canisters used to store spent fuel. It is not anticipated that the DOE would accept this waste prior to completing the transfer of spent fuel. Therefore, until such time the DOE is ready to accept GTCC waste, it is reasonable to assume that this material remains in storage with the spent fuel at the ISFSI.

3.5.2 Reactor Vessel and Internal Components The reactor vessel internal components are segmented for disposal in shielded, reusable transportation casks. Segmentation is performed underwater when practical where a remote cutter is installed. Transportation cask specifications and transportation regulations will dictate segmentation and packaging methodology.

The control elements are disposed of along with the spent fuel and, there is no additional cost provided for their disposal.

As stated previously, the dismantling of reactor internals will generate radioactive waste considered unsuitable for shallow land disposal (i.e., GTCC). Although the material is not classified as high-level waste by the NRC, DOE at one time TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XO)-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 10 of 34 indicated it would accept title to this waste for disposal at the future high-level waste repository. [24] However, the current DOE position is unclear, and DOE Ihas not been forthcoming with an acceptance. criteria or disposition schedule for this material, and numerous questions remain as to the ultimate disposal cost and waste form requirements. As such, for purposes of this study, the GTCC radioactive waste has been packaged and disposed of as high-level waste, at a cost equivalent to that envisioned for the spent fuel.

Intact disposal of reactor vessel shells has been successfully demonstrated at several of the sites recently decommissioned. Access to navigable waterways has allowed these large packages to be transported to the Barnwell disposal site with minimal overland travel. Intact disposal of the reactor vessel and internal components can provide savings in cost and worker exposure by eliminating the complex segmentation requirements, isolation of the GTCC material, and transport/storage of the resulting waste packages. Portland General Electric (PGE) was able to dispose of the Trojan reactor as an intact package (including the internals).

However, its location on.the Columbia River simplified the transportation analysis since:

• the reactor package could be secured to the transport vehicle for the entire journey, i.e., the package was not lifted during transport,

• there were no man-made or natural terrain features between the plant site and the disposal location that could produce a large drop, and transport speeds were very low, limited by the overland transport vehicle and the river barge.

As a member of the Northwest Compact, PGE had a site available for disposal of the package - the US Ecology facility in Washington State. The characteristics of this arid site proved favorable in demonstrating compliance with land disposal regulations.

,It is not known whether this option will be available when the Prairie 'Island units cease operation. Future viability of this option will depend upon the ultimate location of the disposal site, as well as the disposal site licensee's ability to accept highly radioactive packages and effectively isolate them from the environment. As such, the estimate assumes segmentation of the reactor vessel, as a bounding condition. With lower levels of activation, the vessel shell can be packaged more efficiently than the curie-limited internal components. This will allow the use of more conventional waste packages rather than shielded casks for transport.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page)) of 34 3.5.3 Primary System Large Components The reactor coolant system components are assumed to be decontaminated using chemical agents prior to the start of cutting operations.

This type of decontamination can be expected to have a significant ALARA impact in the DECON scenario, since in this scenario the removal work is done within the first few years of shutdown. It should be noted that if the decommissioning work is significantly delayed, chemical decontamination might not be necessary. A decontamination factor (average reduction) of 10 is assumed for the process.

Disposal of the decontamination solution effluent is included within the estimate as a "process liquid waste" charge.

The following discussion deals with the removal and disposition of the steam generators, but the techniques involved are also applicable to other large radioactively-contaminated components, such as heat exchangers and the pressurizer. The steam generators' size and weight, their location within the reactor building, as well as the disposal facility waste acceptance criteria, and access to transportation will ultimately determine the removal, transportation, and disposal strategy.

A crane is set up for the removal of the generators. It can also be used to move portions of the steam generator cubicle walls and floor slabs from the reactor building to a location where they can be decontaminated and transported to the material handling area. Interferences within the work area, such as grating, piping, and other components are removed to create sufficient lay-down space for processing these large components.

The generators are rigged for removal, disconnected from the surrounding piping and supports, and maneuvered into the open area where they are lowered onto a down-ending cradle. Each generator is rotated into the horizontal position for extraction from the containment and placed onto a multi-wheeled vehicle for transport to an on-site preparation area.

Disposal costs are based upon the displaced volume and weight of the primary side portions of the steam generators. Each component is then loaded onto a rail car for transport to the disposal facility. The secondary side is assumed to be sent to an off-site waste processor.

Reactor coolant piping is cut from the reactor once the water level (used for personnel shielding during dismantling and cutting operations in and around the reactor) is dropped below the elevation of associated nozzle(s). The piping is boxed and transported by shielded van. The reactor coolant pumps and motors are lifted out intact, packaged, and transported for disposal.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 12 of 34 3.5.4 Main Turbine and Condenser The main turbine and condenser are assumed to have only minor levels of contamination. As such, the components are dismantled using conventional maintenance procedures. The turbine rotors and shafts are removed to a laydown area. The lower turbine casings are removed from their anchors by controlled--

demolition. The main condensers are also disassembled and moved to a laydown area. Material is then surveyed and designated for either decontamination or volume reduction, conventional disposal, or controlled disposal. Components are packaged and readied for transport in accordance with the intended disposition.

This estimate assumes that the components can meet free-release limits and ultimately dispositioned as scrap metal.

3.5.5 Transportation Methods Contaminated piping, components, and structural material other than the highly activated reactor vessel and internal components will qualify as LSA-I,.11 or III or Surface Contaminated Object, SCO-I or 1I, as described in Title 49.[251 The contaminated material will be packaged in Industrial Packages (IP-1,.IP-2, or IP-3, as defined in subpart 173.411) for transport unless demonstrated to qualify as their own shipping containers. The reactor vessel and internal components are expected to be transported in accordance with Part 71, as Type B. It is conceivable that the reactor, due to its limited specific activity, could qualify as LSA II or III. However, the high radiation levels on the outer surface would require that additional shielding be incorporated within the packaging so as to attenuate the dose to levels acceptable for transport.

Any fuel cladding failure that occurred during the lifetime of the plant is assumed to have released fission products at sufficiently low levels that the buildup of quantities of long-lived isotopes (e.g., 137Cs, 90Sr, or transuranics) has been prevented from reaching levels exceeding those that permit the major reactor components to be shipped under current transportation regulations and disposal requirements.

Transport of the highly activated metal, produced in the segmentation of the reactor vessel and internal components, will be by shielded truck cask. Cask shipments may exceed 95,000 pounds, including vessel segment(s), supplementary shielding, cask tie-downs, and tractor-trailer. The maximum level of activity per shipment assumed permissible was based upon the license limits of the available shielded transport casks. The segmentation scheme for the vessel and internal segments is designed to meet these limits.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 13 of 34 The transport of large intact components (e.g., large heat exchangers and other oversized components) will be by a combination of truck, rail, and/or multi-wheeled transporter.

Transportation costs for Classes A, B and C material requiring controlled disposal are based upon the mileage to the EnergySolutions facility in Clive, Utah. The existing Barnwell facility rate schedule for non-Atlantic Compact members is used as the cost estimating basis for disposal of the Class B and C material.

Transportation costs for off-site waste processing are based upon the mileage to Memphis, Tennessee. Truck transport costs are estimated using published tariffs from Tri-State Motor Transit.[26]

3.5.6 Low-Level Radioactive Waste Disposal To the greatest extent practical, metallic material generated in the decontamination and dismantling processes is processed to reduce the total cost of controlled disposal. Material meeting the'regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration. Conditioning (preparing the material to meet the waste acceptance criteria of the disposal site) and recovery of the waste stream is performed off site at a licensed processing center. Any material leaving the site is subject to a survey and release charge, at a minimum. Based on TLG's experience, rates were assumed for off-site processing as well as survey and release.

The mass of radioactive waste generated during the various decommissioning activities at the site is shown on a line-item basis in the detailed Appendix C, and summarized in Table 5.1. The quantified waste summaries shown in these tables are consistent with 10 CFR Part 61 classifications. Commercially available steel containers are presumed to be used for the disposal of piping, small components, and concrete. Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations. The volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

The more highly activated reactor components will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

Disposal fees are based upon estimated charges, with surcharges added for the highly activated components, for example, generated in the segmentation of the reactor vessel. The cost to dispose of the majority of the material generated from TLG Services, Inc.

(

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 14 of 34 the decontamination and dismantling activities is based upon Xcel Energy's current cost for disposal at EnergySolutions facility in Clive, Utah. Disposal costs for the higher activity waste (Class B and C) were estimated using the last available Barnwell rate structure for non-Atlantic Compact members.

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

There are varying degrees to which the Prairie Island site can be restored following the decommissioning of the two nuclear units.

The estimate presented herein includes the dismantling of the major structures to just below ground level, backfilling and the collapsing of below grade voids, and general terra-forming such that the site upon which the power block and supplemental structures are located is transformed into a "grassy plain." Certain facilities, which have continued use or value (e.g., the switchyard) are left intact.

3.6 ASSUMPTIONS The following are the major assumptions made in the development of the estimate for decommissioning Prairie Island.

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

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 3, Page 15 of 34 3.6.2 Labor Costs The craft labor required to decontaminate and dismantle the Prairie Island units will be acquired through standard site contracting practices. Craft labor costs were based upon information from Xcel Energy. Craft labor costs include applicable overheads and profit.

Xcel Energy, as the operator, will continue.to provide site operations support, including decommissioning program management, licensing, radiological protection, and site security. A Decommissioning Operations Contractor (DOC) will provide the supervisory staff needed to oversee the labor subcontractors, consultants, and specialty contractors needed to perform the work required for the decontamination and dismantling effort. The DOC will also provide the engineering services needed to develop activity specifications, detailed procedures, detailed activation analyses, and support field activities such as structural modifications.

Utility labor costs were provided by Xcel Energy. Average costs were provided by department or' work group and included payroll overheads. Decommissioning Operations Contractor (DOC) labor costs were based on utility labor costs with modified markups to account for employee benefits, DOC overhead and profit.

Severance costs were included as a separate expenditure within the estimate.

Based upon site overhead costs provided by Xcel Energy, an administrative and general cost (A&G) is included. This cost is based on the average annual A&G per person applied to each of the utility staffing positions (number of utility personnel assigned to the project). The A&G cost includes: site overhead costs directly required to support the site decommissioning staff.

Security, while reduced from operating levels, is maintained throughout the decommissioning for access control, material control, and to safeguard the spent fuel.

3.6.3 Design Conditions Activation levels in the vessel and internal components are modeled using NUREG/CR-3474.[27 I Estimates are derived from the curie/gram values contained therein and adjusted for the different mass of the Prairie Island components, projected operating life(s), and different periods of decay. Additional short-lived isotopes were derived from CR-0130 [28] and CR-0672 [29j and benchmarked to the long-lived values from CR-3474.

The control elements are disposed of along with the spent fuel (i.e., there is no additional cost provided for their disposal). Disposition of any control elements TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 16 of 34 stored in the pool from operations is considered an operating expense and therefore not accounted for in the decommissioning estimate.

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

3.6.4 General Transition Activities Existing warehouses are cleared of non-essential material and remain for use by the plant operator and its subcontractors. The plant's operating staff performs the following activities at no additional cost or credit to the project during the transition period.

• Drain and collect fuel oils, lubricating oils, and transformer oils for recycle and/or sale.

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

• Process operating waste inventories. This estimate does not address the disposition of any legacy wastes and the disposal of operating wastes during this initial period is not considered a decommissioning expense.

Scrap and Salvage The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. Xcel Energy will make economically reasonable efforts

!to salvage equipment following final plant shutdown. However, dismantling techniques assumed for equipment in this analysis are not consistent with removal techniques required for salvage (resale) of equipment. Experience has indicated that some buyers wanted equipment stripped down to very specific requirements before they would consider purchase. This required expensive rework after the equipment had been removed from its installed location. Since placing a salvage value on this machinery and equipment would be speculative, and the value would be small in comparison to the overall decommissioning expenses, this analysis does not attempt to quantify the value that an owner may realize based upon those efforts.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Secion 3, Page 17 of 34 It is assumed, for purposes of this analysis, that any value received from the sale of scrap generated in the dismantling process would be more than offset by the on-site processing costs. The dismantling techniques assumed in the decommissioning estimate do not include the additional cost for size reduction and preparation to meet "furnace ready" conditions. With a volatile market, the potential profit margin in scrap recovery is highly speculative, regardless of the ability to free release this material. An allowance has been included for the survey and release of all metallic material released from the site.

Furniture, tools, mobile equipment such as forklifts, trucks, bulldozers, and other property is removed at no cost or credit to the decommissioning project. Disposition may include relocation to other facilities. Spare parts are also made available for alternative use.

The concrete debris resulting from building demolition activities is crushed on site to reduce the size of the debris. The resulting crushed concrete is used to backfill below grade voids, with the excess assumed to be removed from the site as recycled material at no cost or credit to the decommissioning program. The rebar removed from the concrete crushing process is disposed of as scrap steel in a similar fashion as other scrap metal as discussed previously.

Energ.

For estimating purposes, the plant is assumed to be de-energized, with the exception of those facilities associated with spent fuel storage (temporary power is run throughout the plant, as needed).

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

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance and the limits for coverage defined in the NRC's proposed rulemaking "Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors."' 30° The NRC's financial protection requirements are based on various reactor (and spent fuel) configurations.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning'Cost Analysis Section 3, Page 18 of 34 Site Modifications The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the site security plan in force during the various stages of the project.

3.7 COST ESTIMATE

SUMMARY

Schedules of expenditures are provided in Tables 3.1 and 3.2. The tables delineatethe cost contributors by year of expenditures as well as cost contributor (e.g., labor, materials, and waste disposal).

The cost elements are also assigned to one of three subcategories: "License Termination,"

"Spent Fuel Management,"

and "Site Restoration."

The subcategory "License Termination" is used to accumulate costs that are consistent with "decommissioning" as defined by the NRC in :its financial assurance regulations (i.e., 10 CFR §50.75). In situations where the long-term management of spent fuel is not an issue, the cost reported for this subcategory is generally sufficient to terminate the unit's operating license.

The "Spent Fuel Management" subcategory contains costs associated with the containerization and transfer of spent fuel to the ISFSI, and ýthe management of the ISFSI until such time that the transfer of all fuel from this facility to an off-site location (e.g.,

geologic repository) is complete. It also includes spent fuel management expenses incurred prioruto the cessation of plant operations.

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

As discussed in Section 3.5.1, it is not anticipated that the DOE will accept 'the GTCC waste prior to completing the transfer of spent fuel. Therefore, the cost of GTCC disposal is shown in the final year of ISFSI operation. While designated for disposal at the geologic repository along with the spent fuel, GTCC waste is still classified as low-level radioactive waste and, as such, included as a "License Termination" expense.

Decommissioning costs are reported in 2008 dollars. Costs are not inflated, escalated, or discounted over the period of expenditure (or' projected lifetime of the plant). The schedules are based upon the detailed activity costs reported in Appendix C, along with the timeline presented in Section 4.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 19 of 34 TABLE 3.1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 18,730 54,479 57,610 42,606 33,917 15,258 8,692 8,716 8,692 8,692 8,692 8,716 8,692 8,692 8,692 8,716 10,302 13,819 9,409 9,393 6,451 2,363 2,363 2,369 2,363 2,363 2,363 2,369 3,838 13,925 29,919 18,193 10,326 5,605 3,944 3,955 3,944 3,944 3,944 3,955 3,944 3,944 3,944 3,955 3,968 2,577 3,420 4,359 2,577 96 96 96 96 96 96 96 1,168 4,108 3,123 2,433 2,205 1,009 588 590 588 588 588 590 588 588 588 590 692 893 374 295 208 88 88 88 88 88 88 88 21 3,012 22,490 12,694 5,624 1,472 11 11 11 11 11 11 11 11 11 11 607 1,775 10 0

0 0

0 0

0 0

0 0

4,071 11,618 7,706 4,973 3,731 2,584 2,181 2,187 2,181 2,181 2,181 2,187 2,181 2,181 2,181 2,187 2,377 5,234 2,566 778 776 775 775 777 775 775 775 777 27,827 87,143 120,848 80,899 55,802 25,928 15,416 15,459 15,416 15,416 15,416 15,459 15,416 15,416 15,416 15,459 17,947 24,299 i5,779 14,825 10,011 3,322 3,322 3,331 3,322 3,322 3,322 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis

.DocunentX01-1586-002, Rev. 0 Section 3, Page 20 of 34 TABLE 3.1 (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy Burial Other Year Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,356 527 96 96 96 96 96 96 96 96 96 96 96 96 313 1,070 88 88 88 88 88 88 88

'88 88 88 88 88 89 146 0

0 0

0 0

0 0

0 0

0 0

0 34 4,054 775 775 775 777 775 775 775 777 775 775 775 777 11,078 1,375 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 13,869 7,173 406,770 141,387 24,306 51,900 95,432 719,795 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 21 of 34 TABLE 3.1a PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy Burial Other Year Total 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 17,424 50,558 53,047 39,046 30,956 13,540 7,413 7,433 7,413 7,413 7,413 7,433 7,413 7,413 7,413 7,433 9,234 13,737 2,625 84 49 0

0 0

0 0

0 0

591 5,028 20,321 11,179 4,878 1,348 106 106 106 106 106 106 106 106 166 106 763 2,330 195 0

0 0

0 0

0 0

0 0

1,168 4,108 3,123 2,433 2,205 1,009 588 590 588 588 588 590 588 588 588 590 692 893 159 0

0 0

0 0

0 0

0 0

21 3,012 22,490 12,694 5,624 1,472 11 11 11 11 11 11 11 11 11 11 607 1,775 10 0

0 0

0 0

0 0

0 0

3,760 10,838 6,926 4,310 3,142 1,996 1,592 1,597 1,592 1,592 1,592 1,597 1,592 1,592 1,592 1,597 1,865 5,074 1,957 0

0 0

0 0

0 0

0 0

22,964 73,544 105,907 69,663 46,805 19,365 9,710 9,736 9,710 9,710 9,710 9,736 9,710 9,710 9,710 9,736 13,162 23,810 4,945 84 49 0

0 0

0 0

0 0

Note: Columns may not add dueto rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 22 of 34 TABLE 3.1a (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT,, UNIT 1

,SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 220 0

0 0

0 0

0 0

0 0

01 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

10,294 0

0 0

0 0

0 0

• 0 0

0 0

0 0

10,514 0

304,487 47,913 21,677 47,812 66,098 487,988 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 23 of 34 TABLE 3.1b PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 1,082 2,966 3,191 2,332 1,811 1,418 1,279 1,283 1,279 1,279 1,279 1,283 1,279 1,279 1,279 1,283 1,068 82 1,754 2,387 2,373 2,363 2,363 2,369 2,363 2,363 2,363 2,369 3,246 8,897 9,574 6,995 5,434 4,254 3,838 3,849 3,838 3,838 3,838 3,849 3,838 3,838 3,838 3,849 3,205 247 165 148 126 96 96 96 96 96 96 96 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 64 88 88 88 88 88 88 88 88 88 310 781 609 590 589 589 589 590 589 589 589 590 589 589 589 590 512 160 608 777 775 775 775 777 775 775 775 777 4,639 12,644 13,374 9,917 7,834 6,260 5,707 5,722 5,707 5,707 5,707 5,722 5,707 5,707 5,707 5,722 4,785 489 2,592 3,401 3,362 3,322 3,322 3,331 3,322 3,322 3,322 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

.Prairie Island Nudear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Secion 3, Page 24 of 34 TABLE 3.1b (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy Burial Other Year Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,356 527 96 96 96 96 96 96 96 96 96 96 96 96 93 1,070 88 88 88 88 88 88 88 88

'88 88 88 88 89 146 0

0 0

0 0

0 0

0 0

0 0

0 34 4,054 775 775 775 777 775 775 775 777 775 775 775 777 784 1,375 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,355 7,173 81,073 83,694 2,152 4,088 29,087 200,094 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 i

Section 3, Page 25 of 34 TABLE 3.1c PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 224 955 1,371 1,229 1,150 299 0

0 0

0 0

0 0

0 0

0 0

0 5,031 6,922 4,028 0

0 0

0 0

0 0

0 0

24 18 13 3

0 0

0 0

0 0

0 0

0 0

0 0

3,060 4,210 2,450 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

150 206 120 0

0 0

0 0

0 0

0 0

171 73 0

0 0

0 0

0 0

0 0

0 0

0 0

0 1

1 1

0 0

0 0

0 0

0 224 955 1,567 1,320 1,163 303 0

0 0

0 0

0 0

0 0

0 0

0 8,242 11,340 6,600 0

0 0

0 0

0 0

Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XOl-1586-002, Rev. 0 Section 3, Page 26 of 34 TABLE 3.1c (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy

'Burial Other Year Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0' 0

0 0

0 00 0

0 0

0 0

0 0

0 0

0 0

0 0

0 21,210 9,780 476 0

247 31,713 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 27 of 34 TABLE 3.2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 7,510 44,360 56,365 56,382 53,429 34,256 8,877 8,853 8,853 8,853 8,877 8,853 8,853 8,853 8,877 13,330 28,047 19,269 18,641 11,832 2,363 2,363 2,369 2,363 2,363 2,363 2,369 1,689 11,510 28,466 23,703 11,639 8,540 4,445 4,433 4,433 4,433 4,445 4,433 4,433 4,433 4,445 4,526 3,233.

4,650 5,901 3,474 96 96 96 96 96 96 96 516 3,456 3,816 2,548 2,205 1,509 590 588 588 588 590 588 588 588 590 691 896 374 295 208 88 88 88 88 88 88 88 8

1,370 19,135 17,218 6,749 3,851 11 11 11 11 11 11 11 11 11 747 2,223 11 0

0 0

0 0

0 0

0 0

1,751 9,742 7,414 5,536 3,746 3,067 2,173 2,168 2,168 2,168 2,173 2,168 2,168 20168 2,173 2,325 7,473 3,906 779 776 775 775 777 775 775 775 777 11,474

,70,437 115,195 105,387 77,769 51,222 16,096 16,052 16,052 16,052 16,096 16,052 16,052 16,052 16,096 21,619 41,872 28,210 25,617 16,291 3,322 3,322 3,331 3,322 3,322 3,322 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nudear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 28 of 34 TABLE 3.2 (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF TOTAL ANNUAL EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy Burial Other Year Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,356 527 96 96 96 96 96 96 96 96 96 96 96 96 313 1,070 88 88 88 88 88 88 88 88 88 88 88 88 89 146 0

0 0

0 0

0 0

0 0

0 0

0 34 4,054 775 775 775 777 775 775 775 777 775 775 775 777 11,078 1,375 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 13,869 7,173 470,976 150,471 23,721 55,497 93,229 793,894 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XO)-1586-002, Rev. 0 Section 3, Page 29 of 34 TABLE 3.2a PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 6,990 41,214 51,793 52,342 50,503 31,967 7,431 7,411 7,411 7,411 7,431 7,411 7,411 7,411 7,431 12,124 27,964 5,728 36 21 0

0 0

0 0

00 256 3,018 18,669 15,913 6,469 3,732 106 106 106 106 106 106 106 106 106 908 2,986 304 0

0 0

0 0

0 0

0 0

516 3,456 3,816 2,548 2,205 1,509 590 588 588 588 590 588 588 588 590 691 896 159 0

0 0

0 0

0 0

0 0

8 1,370 19,135 17,218 6,749 3,851 11 11 11 11 11 11 11 11 11 747 2,223 11 0

0 0

0 0

0 0

0 0

1,614 8,961 6,631 4,835 3,157 2,478 1,583 1,579 1,579 1,579 1,583 1,579 1,579 1,579 1,583 1,811 7,313 3,296 0

0 0

0 0

0 0

0 0

9,385 58,018 100,043 92,856 69,083 43,538 9,721 9,694 9,694 9,694 9,721 9,694 9,694 9,694 9,721 16,282 41,382 9,499 36 21 0

0 0

0 0

0 0

Note:, Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant

-Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 30 of 34 TABLE 3.2a (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF LICENSE TERMINATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

.0 0

"0 0

0 0

0 0

0 0

0 220 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

10,294 0

0 0

0 0

0 0

0 0

0 0

0 0

10,514 0

347,441 53,427 21,092 51,409 64,614 537,983 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XOI-1586-002, Rev. 0 Section 3, Page 31 of 34 TABLE 3.2b PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES (thousands, 2008 dollars) '

Equipment &

Materials Year Labor Energy Burial Other Total 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 478 2,831 3,258 2,588 1,719 1,600 1,446 1,442 1,442 1,442 1,446 1,442 1,442 1,442 1,446 1,206 83 3,198 4,373 3,529 2,363 2,363 2,369 2,363 2,363 2,363 2,369 1,433 8,492 9,775 7,765 5,157 4,800 4,339 4,327 4,327 4,327 4,339 4,327 4,327 4,327 4,339 3,618 248 165 148 126 96 96 96 96 96 96 96 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

64 88 88 88 88 88 88 88 88 88 137 781 653 589 589 589 590 589 589 589 590 589 589 589 590 513 160 608 777 775 775 775 777 775 775 775 777 2,047 12,104 13,687 10,942 7,464 6,989 6,376 6,358 6,358 6,358 6,376 6,358 6,358 6,358 6,376 5,337 490 4,035 5,387 4,518 3,322 3,322 3,331

, 3,322 3,322 3,322 3,331 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XOl-1586-002, Rev. 0 Secion 3, Page 32 of 34 TABLE 3.2b (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SPENT FUEL MANAGEMENT EXPENDITURES

,(thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2,363 2,363' 2,363 2,369 2,363 2,363 2,363 2,369 2,363 2,363 2,363 2,369 2,356 527 96 96 96 96 96 96 96 96 96 96 96 96 93 1,070 88 88 88 88 88 88 88 88 88 88 88 88 89 146 0

0 0

0 0

0 0

0 0

0 0

0 34 4,054 775 775 775 777 775 775 775 777 775 775 775 777 784 1,375 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,322 3,322 3,322 3,331 3,355 7,173 85,659 83Y694 2,152 4,088 28,368 203,961 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XO)-1586-002, Rev. 0 Section 3, Page 33 of 34 TABLE 3.2c PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Materials Year Labor Energy Burial Other Total 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 42 315 1,314 1,452 1,208 688 0

0 0

0 0

0 0

0 0

'0 0

10,343 14,232 8,283 0

0 0

0

.0 0

0 0

0 22 25 14 8

0 0

0 0

0 0

0 0

0 0

0 4,181 5,753 3,348 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 150 206 120 0

0

.0 0

0 0

0 0

0 129 112 0

0 0

0 0

0 0

0 0

0 0

0 0

2 2

1 0

0 0

0 0

0 0

42 315 1,465 1,589 1,221 696 0

0 0

0 0

0 0

0 0

0 0

14,676 20,193 11,752 0

0 0

0 0

0 0

Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 3, Page 34 of 34 TABLE 3.2c (continued)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 SCHEDULE OF SITE RESTORATION EXPENDITURES (thousands, 2008 dollars)

Equipment &

Labor Materials Energy Burial

Other, Year Total 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 37,877 13,350 476 0

247 51,950 Note: Columns may not add due to rounding TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page I of 5

4. SCHEDULE ESTIMATE The schedule for the decommissioning scenario considered in this study follows the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect the spent fuel management plan described in Section 3.5.1.

A schedule or sequence of activities for the DECON alternative is presented in Figure 4.1. The scheduling sequence assumes that fuel is removed from the spent fuel pool approximately five and one-half years following the permanent cessation of plant operations. The key activities listed in the schedule do not reflect a one-to-one correspondence with those activities in the cost table, but reflect dividing some activities for clarity and combining others for convenience. The schedule was prepared using the "Microsoft Project Professional 2003" computer software.[31]

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

Software Package. The work activity durations used in the precedence network reflect the actual man-hour estimates from the cost table, adjusted by stretching certain activities over their slack range and shifting the start and end dates of others. The following assumptions were made in the development of the decommissioning schedule:

o The fuel handling area of the Auxiliary Building is isolated until such time that all spent fuel has been discharged from the spent fuel pool to the ISFSI. Decontamination and dismantling of the storage pool is initiated once the transfer of spent fuel is complete.

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

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

o Multiple crews work parallel activities to the maximum extent possible, consistent with optimum efficiency, adequate access for cutting, removal and laydown space, and with the stringent safety measures necessary during demolition of heavy components and structures.

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

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 4, Page 2 of 5 4.2 PROJECT SCHEDULE The period-dependent costs presented in Appendix C are based upon the durations developed -in the schedules for decommissioning. Durations are established between several milestones in each project period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is shown for the spent fuel storage period, which determines the release of the auxiliary building for final decontamination. A project timeline is provided in Figure 4.2.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document Xfl-1586-002, Rep. 0 Sedion 4, Page 3of 5 FIGURE 4.1 ACTIVITY SCHEDULE Task Name 4

Pmrb Wahid Unit 1 & 2 *lardk Shutdown ni I Period Isa Uit I -Shisin timpgh lruaniton Certificate of permanent ressatron of ope.rtions submitted Fuel storae pool operations peconfisour plant Po actwiviy epecifarstino Perform soe charaltenrimon ttritien certificate of pernonent removal of fuel submitted Site siecific decomiuounisionmop rust estoulate submilted lofr'rt mobi 2i Perd lb Unil I -Ieoommisseio g preparations Fuel storage pool operainos Reeonio Pw plant oimuedi Prepare setaied work procedures Decon NSSS LIoate spnt fuelpool Period 2a Utni -Imp component removal Fuel storaste poolopprotious Preparatson for reacor ceslol rinoral Re oar vessel&

mitrnul Remainino l]rme NSSS toonpuinent diposainot Non-esoential systems Main tarlinetenerator Main oondenser hLene terrmatouu plan submitted Pernod Unit - Ncontaimmanuon (wet fuel)

Fuel storsge pool opsratioi.a Remuve si"eite not supporting wet fuel eore Decon bsooliage not suppoDrfi w*t fuel storage leo nee i rrouoatuon plan approved ehrd f. I-Dlay before pool DWJON Delay pernd por to poolDECONX Period Zi Unit I-Demotaminamon of pool Remove remmiorna systems Derun wet fuel storage area Ulo 2 'peratonE Shutiwn u Unit 2 Period la Urnit 2 -*Shutdown Iluol tr-asition Certifate of peom ent resoqtin of operations oubmiirfd 2 013 214 9015 2016 2017 1201 Wi 7L UL 7I E

8 1 2 0.90 12021 1 2021 4 1.5 12 7 2 0 120, 2912030 2031 2032 2033 11~i o+UII+F+III++

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TLG Services, Inc.

Prarie Isiad Nudear Gemewng Plant Documeuu XE1-1586-002, Rev. 0 De Cost Andysis Seclk 4, Poe 4 of5 FIGURE 4.1 ACTIVITY SCHEDULE (continued)

Task Name 2013 Fuel garage Pool o eaueuý Reconiuarep p Ir Wuue scsi mit. ofprMauetiremoa ffuel 4binitted Site 5pes ur "~meioa Ccsteetiatesubmited3 Period bUnd 2 -Nxawsoi prepmaonat Fuel gaurage pol up ratioos Rtofmas Plntfei one At Dyfuel straie topranon Prew ptaka d work prcs~

e rita DIt mNzlrSSS orcun~

i W*Spent fuetil Poolm Per~Uiod21 d -Lacotmpone~n~t remoa Fuel q rsrgr pool opeaiucs Pireaaion fr rem sot k psl emo aul Ltsp conitwriars*&

slterup -aý tFe.s~

No"eou Sytemaopa s e Mai cndg.Iehiefrnpo~

Remuve vqmo!nost upoan;les ue>org NiDMODu bwa.DI Suppotingt a tnfueal 5ra Foron ite rauneeo pnapri

\\1(reoa&-Dly bfre o O

Litiesa terminartapedlP r377 Perid PUnit I A&2

-Phdhomtergtant.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 4, Page 5 of 5 FIGURE 4.2 DECOMMISSIONING TIMELINE (not to scale)

Unit 1 Shutdown Period 1 Transition and Preparations Period 2 Decommissioning Period 3 Site Restoration ISFSI Operations ISFSI D&D I.......................................................................................................................................................................................

I...........................................

.....................I 1

12/2053 4

07/2054 08/2013 08/2013 02/2015 04/2031 08/2033 ISFSI expansion Cask installation Spent fuel campaigns Storage Pool Empty 10/2029 Unit 2 Shutdown Period 1 Transition and Period 2 Preparations Decommissio Period 3 Site ISFSI' ISFSI Restoration Operations I D&D 10/2014 10/2014 04/2016 04/2031 08/2033 12/2053 07/2054 TLG Services, Inc.

Prairie island Nuclear Generating Plant Document X01-)1586-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page I of 3

5. RADIOACTIVE WASTES The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination ofthe NRC license. This currently requires the-remediation of all radioactive material at the site in excess of applicable legal limits.

Under the Atomic Energy Act,[321 the NRC is responsible for :protecting the public from sources of ionizing radiation. Title 10 of the Code of Federal Regulations delineates the production, utilization, and disposal of radioactive materials and processes. In particular, Part 71 defines radioactive material as it pertains to transportation and Part 61 specifies its disposition.

Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities, as defined in 49 CFR Parts 173-178. Shipping containers are required to be Industrial Packages (IP-1, IP-2 or IP-3, as defined in 10 CFR § 173.411). For this study, commercially available steel' containers are presumed to be used for the disposal of piping, small components, and concrete.

Larger components can serve as their own containers, with proper closure of all openings, access ways, and penetrations.

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

The reactor vessel and internals are categorized as large quantity shipments and, accordingly, will be shipped in reusable, shielded truck casks with disposable liners. In calculating disposal costs, the burial fees are applied against the liner volume, as well as the special handling requirements of the payload. Packaging efficiencies are lower for the highly activated materials (greater than Type A quantity waste), where high concentrations of gamma-emitting radionuclides limit the capacity of the shipping canisters.

No process system containing/handling radioactive substances at shutdown is presumed to meet material release criteria by decay alone (i.e., systems radioactive at shutdown will still be radioactive over the time period during which the decommissioning is accomplished, due to the presence of long-lived radionuclides). While the dose rates decrease with time, radionuclides such as 137Cs will still control the disposition requirements.

The waste material produced in the decontamination and dismantling of the nuclear units is primarily generated during Period 2. Material that is considered potentially contaminated when removed from the radiological controlled area is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 5, Page 2 of 3 for controlled disposal. The disposal volumes reported in the tables reflect the savings resulting from reprocessing and recycling.

For purposes of constructing the estimate, the cost for disposal at the EnergySolutions facility was used as a proxy for future disposal facilities. Separate rates were used for containerized waste and large components, including the steam generators and reactor coolant pump motors.

Demolition debris including miscellaneous steel, scaffolding, and concrete was disposed of at a bulk rate. The decommissioning waste stream also included resins and dry active waste.

Since EnergySolutions is not currently able to receive the more highly radioactive components generated in the decontamination and dismantling of the reactor, disposal costs for the Class B and C material were based upon the last available published disposal rates for Barnwell for non-Atlantic Compact members. Additional surcharges were included for activity, dose rate, and/or handling added as appropriate for the particular package.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis DocumentXO)-1586-002, Rev. 0 Setion 5, Page 3 of 3 TABLE 5.1 DECOMMISSIONING WASTE

SUMMARY

Waste Volume Mass Waste Cost Basis Class P]

(cubic feet)

(pounds)

Low-Level Radioactive Waste EnergySolutions A

47,143 4,696,459 (near-surface disposal)

EnergySolutions B

4,938 608,324 EnergySolutions C

1 ;837 224,252 Greater than Class C Spent Fuel GTCC 1,024 211,190 (geologic repository)

Equivalent Processed/Conditioned Recycling A

1-1,646,327 (off-site recycling center)

Vendors Low-Level Radioactive Waste EnergySolutions Containerized 104,031 16,103,225 Low-Level Radioactive Waste EnergySolutions Bulk/ DAW 61,298 2,000,870 Total [2]

220,271 35,490,647

[P]

[2]

Waste is classified according to the requirements as delineated in Title 10 CFR, Part 61.55

'Columns may not add due to rounding.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page I of 3

6. RESULTS The cost projected to promptly decommission the two Prairie Island nuclear units is estimated to be $1,514 million. The estimate is based on numerous fundamental assumptions, including regulatory requirements, project contingencies, and low-level radioactive waste disposal practices and high-level waste management considerations.

The primary cost contributors, identified in Table 6.1, are either labor-related or associated with the management and disposition of the radioactive waste. Program management is the largest single contributor to the overall cost. The magnitude of the expense is a function of both the size of the organization required to manage the decommissioning, as well as the duration of the program. It is assumed, for purposes of this -analysis, that Xcel Energy will oversee the decommissioning program, using a DOC to manage the decommissioning labor force and the associated subcontractors: The size and composition of the management organization varies with the decommissioning phase and associated site activities.

As described in this report, the spent fuel pool will remain operational for fifteen years following the cessation of operations. The pool will be isolated to allow decommissioning operations to proceed in and around the pool area. Over the fifteen year period, the spent fuel will be packaged for transfer to the ISFSI.

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

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

Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program. Decontamination and packaging costs also have a large labor component that is based upon prevailing wages. Non-radiological demolition is a natural extension of the decommissioning process. The methods employed in decontamination and dismantling are generally destructive and indiscriminate in inflicting collateral damage. With a work force mobilized to support decommissioning TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 6, Page 2 of 3 operations, non-radiological demolition can be an integrated activity and a logical expansion of the work being performed in the process of terminating the operating license. Prompt demolition reduces future liabilities and can 'be more cost effective than deferral, due to the deterioration of

-the facilities (and therefore the working conditions) with time.

The reported cost for transport includes the tariffs and surcharges associated with moving large components and/or overweight shielded casks overland, as well as the general expense (labor and fuel) of transporting material to the destinations identified in this report. For purposes of this analysis, material is primarily moved overland by truck.

Decontamination is used to reduce the plant's radiation fields and minimize worker exposure.

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

License termination survey costs are associated with the labor intensive and complex activity of verifying that contamination has been removed from the site to the levels specified by the regulating agency. This process involves a systematic survey of all remaining plant surface areas and surrounding environs, sampling, isotopic analysis, and documentation of the findings.

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

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Section 6, Page 3 of 3 TABLE 6.1 COST

SUMMARY

DECOMMISSIONING COST ELEMENTS (thousands of 2008 dollars)

Cost Element Unit 1 Unit 2 Total Percentage Decontamination 8,873 14,101 22,974 1.5 Removal 71,116 91,943 163,059 10.8 Packaging 18,148 18,447 36,595 2.4 Transportation 6,828 7,411 14,238 0.9 Waste Disposal 48,983 50,257 99,240 6.6 Off-site Waste Processing 13,211 15,534 28,745 1.9 Program Management Il 334,149 381,084 715,233 47.3 Spent Fuel Pool Isolation 5,911 5,911 11,822 0.8 Spent Fuel Management (direct costs) [2]

128,061 127,342 255,402 16.9 Insurance and Regulatory Fees 24,638 22,277 46,914 3.1 Energy 24,306 23,721 48,027 3.2 Characterization and Licensing Surveys 8,276 9,713 17,989 1.2 Property Taxes 21,069 19,904 40,973 2.7 Miscellaneous Equipment 6,228 6,250 12,478 0.8 Total [3]

719,795 793,894 1,513,689 100.0 Cost Element Unit 1 Unit 2 Total Percentage License Termination 487,988 537,983 1,025,971 67.8 Spent Fuel Management 200,095 203,961 404,056 26.7 Site Restoration 31,713 51,950 83,662 5.5 Total [3]

719,795 793,894 1,513,689 100.0

[I]

Includes engineering and security costs

[2]

Excludes program management costs (staffing) but includes capital expenditures for ISFSI construction, costs for spent fuel loading/packaging costs/spent fuel pool O&M and EP fees

[3]

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

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page I of 3

7. REFERENCES I.

"Decommissioning Cost Analysis for the Prairie Island Nuclear Generating Plant," TLG Services Document No. XO I-1526-002, Rev. 0, October 2005

2.

U.S. Code of Federal Regulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirements for Decommissioning Nuclear Facilities," Nuclear Regulatory Commission, Federal Register Volume 53, Number 123 (p 24018 et seq.), June 27, 1988

3.

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

4.

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

5.

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

6.

U.S. Code of Federal Regulations, Title 10, Parts 2, 50 and 51, "Decommissioning of Nuclear Power Reactors," Nuclear Regulatory Commission, Federal Register Volume 61 (p 39278 et seq.), July 29, 1996

7.

"Nuclear Waste Policy Act of 1982 and Amendments," U.S. Department of Energy's Office of Civilian Radioactive Management, 1982

8.

"DOE Announces Yucca Mountain License Application Schedule", U.S. Department of Energy's Office of Public Affairs, Press Release July 19, 2006

9.

Remarks of OCRWM Director Ward Sproat to the National Academy of Science, November 2006

10.

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

11.

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

12.

"Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 2 of 3

7. REFERENCES (continued)

13.

U.S. Code of Federal Regulations, Title 10, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste"

14.

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

15.

"Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination,"

EPA Memorandum OSWER No. 9200.4-18, August 22, 1997

16.

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

17.

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

18.

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

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

19.

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

20.

W.J. Manion and T.S. LaGuardia, "Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980

21.

"Building Construction Cost Data 2008," Robert Snow Means Company, Inc., Kingston, Massachusetts

22.

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

Prairie Island Nudear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Section 7, Page 3 of 3

7. REFERENCES (continued)

23.

Civilian Radioactive Waste Management System Waste Acceptance System Requirements Document, Revision 5" (DOE/RW-035 1) issued May 31, 2007

24.

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

25.

U.S. Department of Transportation, Section 49 of the Code of Federal Regulations, "Transportation," Parts 173 through 178, 2006

26.

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

27.

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

28.

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

29.

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

30.

"Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors,"

10 CFR Parts 50 and 140, Federal Register Notice, Vol. 62, No. 210, October 30, 1997

31.

"Microsoft Project Professional 2003," Microsoft Corporation, Redmond, WA.

32.

"Atomic Energy Act of 1954," 42 U.S.C 2001 et seq.

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XOI-1586-O02, Rev. 0 Appendic A, Page I of 4 APPENDIX A UNIT COST FACTOR DEVELOPMENT TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 AppendixA, Page 2of4 APPENDIX A UNIT COST FACTOR DEVELOPMENT Example:

Unit Factor for Removal of Contaminated Heat Exchanger < 3,000 lbs.

1.

SCOPE Heat exchangers weighing < 3,000 lbs. will be removed in one piece using a crane or small hoist.

They will be disconnected from the inlet and outlet piping. The heat exchanger will be sent to the waste processing area.

2.

CALCULATIONS Act Activity ID Description Activity Duration (minutes)

Critical Duration (minutes) a b

c d

e f

g h

i Remove insulation Mount pipe cutters Install contamination controls Disconnect inlet and outlet lines Cap openings Rig for removal Unbolt from mounts Remove contamination controls Remove, wrap :in plastic, send to the waste processing area 60 (b) 60 60 20 (b) 60 60 20 (d) 30 30 30 30 15 15 60 60 Totals (Activity/Critical)

Duration adjustment(s):

+ Respiratory protection adjustment (50% of critical duration)

+ Radiation/ALARA adjustment (37.08% of critical duration)

Adjusted work duration

+ Protective clothing adjustment (30% of adjusted duration)

Productive work duration

+ Work break adjustment (8.33 % of productive duration)

Total work duration (minutes) 355 255 128 95 478 143 621 52 673 Total duration = 11.217 hours0.00251 days <br />0.0603 hours <br />3.587963e-4 weeks <br />8.25685e-5 months <br /> TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 3 of 4 APPENDIX A (continued)

3.

LABOR REQUIRED Duration Rate Crew Number (hr)

($/hr)

Cost Laborers 3.00 11.217

$42.06

$1415.36 Craftsmen 2.00 11.217

$58.49

$1312.16 Foreman 1.00 11.217

$58.53

$656.53 General Foreman 0.25 11.217

$60.53

$169.74 Fire Watch 0.05 11.217

$42.06

$23.59 Health Physics Technician 1.00 11.217

$46.21

$518.34 Total labor cost

$4095.72

4.

EQUIPMENT & CONSUMABLES COSTS Equipment Costs none Consumables/Materials Costs Gas torch consumables 1 @ $8.36/hour x 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> il

$8.36 Blotting paper 50 @ $0.46 square foot [2]

$23.00 Plastic sheets/bags 50 @ $0.14/square foot [3]

$7.00 Subtotal cost of equipment and materials

$38.36 Overhead & sales tax on equipment and materials @ 16.50 %

$6.33 Total costs, equipment & material

$44.69 TOTAL COST: Removal of contaminated heat exchanger <3000 pounds:

$4,140.41 Total labor cost:

$4,095.72 Total equipment/material costs:

$44.69 Total craft labor man-hours required per unit:

81.88 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix A, Page 4. of 4 APPENDIX A (continued)

5.

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

References for equipment & consumables costs:

1.

R.S. Means (2008) Division 01 54 33, Section 40-6360, Reference-10.

2.

McMaster-Carr, Item 7193T88, Spill Control.

3.

R.S. Means (2008) Division 01 56 13.6-0200, page 20.

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

TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document X01-1586-002, Rev. 0 Appendix B, Page ) of 7 APPENDIX B UNIT COST FACTOR LISTING TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 2 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.46 Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 4.92 Removal of clean pipe >2 to 4 inches diameter, $/linear foot 7.03 Removal of clean pipe >4 to 8 inches diameter, $/linear foot 13.99 Removal of clean pipe >8 to 14 inches diameter, $/linear foot 26.91 Removal of clean pipe >14 to 20 inches diameter, $/linear foot 34.90 Removal of clean pipe >20 to 36 inches diameter, $/linear foot 51.37 Removal of clean pipe >36 inches diameter, $/linear foot 61.08 Removal of clean valve >2 to 4 inches 91.15 Removal of clean valve >4 to 8 inches 139.89 Removal of clean valve >8 to 14 inches 269.13 Removal of clean valve >14-to 20 inches 349;02 Removal of clean valve >20 to 36 inches 513.72 Removal of clean valve >36 inches 610.77 Removal of clean pipe hanger for small bore piping 29.53 Removal of clean pipe hanger for large bore piping 107.73 Removal of clean pump, <300 pound 234.09 Removal of clean pump, 300-1000 pound 658.66 Removal of clean pump, 1000-10,000 pound 2,603.35 Removal of clean pump, > 10,000 pound 5,028.11 Removal of clean pump motor, 300-1000 pound 277.67 Removal of clean pump motor, 1000-10,000 pound 1,085.16 Removal of clean pump motor, >10,000 pound 2,441.63 Removal of clean heat exchanger <3000 pound 1,391.64 Removal of clean heat exchanger >3000 pound 3,493.88 Removal of clean feedwater heater/deaerator 9,893.65 Removal of clean moisture separator/reheater 20,397.87 Removal of clean tank, <300 gallons 301.33 Removal of clean tank, 300-3000 gallon 953.77 Removal of clean tank, >3000 gallons, $/square foot surface area 8.05 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XO)-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 3 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of clean electrical equipment, <300 pound 128.66 Removal of clean electrical equipment, 300-1000 pound 452.07 Removal of clean electrical equipment, 1000-10,000 pound 904.14 Removal of clean electrical equipment, >10,000 pound 2,143.14 Removal of clean electrical transformer < 30 tons 1,488.39 Removal of clean electrical transformer > 30 tons 4,286.30 Removal of clean standby diesel generator, <100 kW 1,520.27 Removal of clean standby diesel generator, 100 kW to 1 MW 3,393.32 Removal of clean standby diesel generator, >1 MW 7,024.86 Removal of clean electrical cable tray, $/linear foot 11.96 Removal of clean electrical conduit, $/linear foot 5.22 Removal of clean mechanical equipment, <300 pound 128.66 Removal of clean mechanical equipment, 300-1000 pound 452.07 Removal of clean mechanical equipment, 1000-10,000 pound 904.14 Removal of clean mechanical equipment, >10,000 pound 2,143.14 Removal of clean HVAC equipment, <300 pound 128.66 Removal of clean HVAC equipment, 300-1000 pound 452.07 Removal of clean HVAC equipment, 1000-10,000 pound 904.14 Removal of clean HVAC equipment, >1I0,000 pound 2,143.14 Removal of clean HVAC ductwork, $/pound 0.49 Removal of contaminated instrument and sampling tubing, $/linear foot 1.44 Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 18.86, Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 33.26 Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 53.69 Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 106.01 Removal of contaminated pipe >14 to 20 inches diameter, $/Iinear foot 127.76 Removal of contaminated pipe >20 to 36 inches diameter, $/Iinear foot 177.76 Removal of contaminated pipe >36 inches diameter, $/linear foot 210.56 Removal of contaminated valve >2 to 4 inches 409.55 Removal of contaminated valve >4 to 8 inches 500.28 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 4 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated valve >8 to 14 inches 1 025.15 Removal of contaminated valve >14 to 20 inches 1,305.51 Removal of contaminated valve >20 to 36 inches 1,742.61 Removal of contaminated valve >36 inches 2,070.70 Removal of contaminated pipe hanger for small bore piping 99.30 Removal of contaminated pipe hanger for large bore piping 327.77 Removal of contaminated pump, <300 pound 889.22 Removal of contaminated pump, 300-1000 pound 2,084.98 Removal of contaminated pump, 1000-10,000 pound 6,863.28 Removal of contaminated pump, >10,000 pound 16,718.32 Removal of contaminated pump motor, 300-1000 pound 874.87 Removal of contaminated pump motor, 1000-1 0,000 pound 2,781.86 Removal of contaminated pump motor, >10,000 pound 6,245.52 Removal of contaminated heat exchanger <3000 pound 4,140.41 Removal of contaminated heat exchanger >3000 pound 11,957.46 Removal of contaminated tank, <300 gallons 1,475.45 Removal of contaminated tank, >300 gallons, $/square foot 29.47 Removal of contaminated electrical equipment, <300 pound 696.17 Removal of contaminated electrical equipment, 300-1000 pound 1,702.11 Removal of contaminated electrical equipment, 1000-10,000 pound 3,276.66 Removal of contaminated electrical equipment, >10,000 pound 6,394.12 Removal of contaminated electrical cable tray, $/linear foot 33.58 Removal of contaminated electrical conduit, $/linear foot 15.31 Removal of contaminated mechanical equipment, <300 pound 775.13 Removal of contaminated mechanical equipment, 300-1000 pound 1,882.27 Removal of contaminated mechanical equipment, 1000-10,000 pound 3,617.63 Removal of contaminated mechanical equipment, >10,000 pound 6,394.12 Removal of contaminated HVAC equipment, <300 pound 775.13 Removal of contaminated HVAC equipment, 300-1000 pound 1,882.27 Removal of contaminated HVAC equipment, 1000-10,000 pound 3,617.63 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document XOI-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 5 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Removal of contaminated HVAC equipment, >10,000 pound 6,394.12 Removal of contaminated HVAC ductwork, $/pound 1.97 Removal/plasma arc cut of contaminated thin metal components, $/linear in.

3.73 Additional decontamination of surface by washing, $/square foot 7.49 Additional decontamination of surfaces by hydrolasing, $/square foot 34.48 Decontamination rig hook up and flush, $/ 250 foot length 6,585.18 Chemical flush of components/systems, $/gallon 13.23 Removal of clean standard reinforced concrete, $/cubic yard 128.23 Removal of grade slab concrete, $/cubic yard 172.13 Removal of clean concrete floors, $/cubic yard 329.05 Removal of sections of clean concrete floors, $/cubic yard 993.82 Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 217.92 Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 1,986.01 Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 275.54 Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 2,629.56 Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 428.01 Removal of below-grade suspended floors, $/cubic yard 329.05 Removal of clean monolithic concrete structures, $/cubic yard 845.27 Removal of contaminated monolithic concrete structures, $/cubic yard 1,985.44 Removal of clean foundation concrete, $/cubic yard 662.49 Removal of contaminated foundation concrete, $/cubic yard 1,849.43 Explosive demolition of bulk concrete, $/cubic yard 28.88 Removal of clean hollow masonry block wall, $/cubic yard 90.72 Removal of contaminated hollow masonry block wall, $/cubic yard 301.40 Removal of clean solid masonry block wall, $/cubic yard 90.72 Removal of contaminated solid masonry block wall, $/cubic yard 301.40 Backfill of below-grade voids, $/cubic yard 23.09 Removal of subterranean tunnels/voids, $/linear foot 106.43 Placement of concrete for below-grade voids, $/cubic yard 123.82 Excavation of clean material, $/cubic yard 2.63 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Document X01-1586-002, Rev. 0 Decommissioning Cost Analysis Appendix B, Page 6 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Excavation of contaminated material, $/cubic yard 38.21 Removal of clean concrete rubble (tipping fee included), $/cubic yard 20.56 Removal of contaminated concrete rubble, $/cubic yard 23.37 Removal of building by volume, $/cubic foot 0.28 Removal of clean building metal siding, $/square foot 1.08 Removal of contaminated building metal siding, $/square foot 3.74 Removal of standard asphalt roofing, $/square foot 2.17 Removal of transite panels, $/square foot 2.05 Scarifying contaminated concrete surfaces (drill.& spall), $/square foot 12.82 Scabbling contaminated concrete floors, $/square foot 7.48 Scabbling contaminated concrete walls, $/square foot 19.52 Scabbling contaminated ceilings, $/square foot 66.76 Scabbling structural steel, $/square foot 6.32 Removal of clean overhead crane/monorail < 10 ton capacity 636.59 Removal of contaminated overhead crane/monorail < 10 ton capacity 1,767.18 Removal of clean overhead crane/monorail >10-50 ton capacity 1,527.80 Removal of contaminated overhead crane/monorail > 10-50 ton capacity 4,240.55 Removal of polar crane > 50 ton capacity 6,352.78 Removal of gantry crane > 50 ton capacity 26,789.34 Removal of structural steel, $/pound 0.20 Removal of clean steel floor grating, $/square foot 4.50 Removal of contaminated steel floor grating, $/square foot 12.90 Removal of clean free standing steel liner, $/square foot 12.07 Removal of contaminated free standing steel liner, $/square foot 34.53 Removal of clean concrete-anchored steel liner, $/square foot 6.04 Removal of contaminated concrete-anchored steel liner, $/square foot 40.23 Placement of scaffolding in clean areas, $/square foot 14.41 Placement of scaffolding in contaminated areas, $/square foot 24.36 Landscaping with topsoil, $/acre 21,043.22 Cost of CPC B-88 LSA box & preparation for use 1,537.33 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XO1-1586-002, Rev. 0 Appendix B, Page 7 of 7 APPENDIX B UNIT COST FACTOR LISTING (Power Block Structures Only)

Unit Cost Factor Cost/Unit($)

Cost of CPC B-25 LSA box & preparation for use Cost of CPC B-12V 12 gauge LSA box & preparation for use Cost of CPC B-144 LSA box & preparation for use Cost of LSA drum & preparation for use Cost of cask liner for CNSI 14 195 cask Cost of cask liner for CNSI 8 120A cask (resins)

Cost of cask liner for CNSI 8 120A cask (filters)

Decontamination of surfaces with vacuuming, $/square foot 1,356.59 1,328.96 8,033.36 134.03 165.72 6,461.28 1,078.13 0.65 TLG Services, Inc.

Prairie Island Nuclear Generating Plant Decommissioning Cost Analysis Document XO)-1586-002, Rev. 0 Appendix C, Page.] of 21 APPENDIX C DETAILED COST TABLES Table Paae C-1 Unit 1 DECON Decommissioning Cost Estimate..........................................................

2 C-2 Unit 2 DECON Decommissioning Cost Estimate............................................................

11 TLG Services, Inc.

Pre.1rk Island Nootoo Gooostiag Ptooti Doeooosinialioto Cost A.oo~ai..

Dorooooot XD1 -1 086-002. NRv. 0 Appenodix C, Pagr 2 sf21 Table C-i Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

OW-Sbft 1100 NMC Speot FusM sit PusoOroist Vole-.

Belief540 Acvity D.00e Rioool Packaging Transport Processing Disposed Other Total To:t Us. Term. Uonogeslat Restoration Votum Class A CUSS B C"Is. C GTCC P0o0.50se CroS CoorMI.

Ind..

A80t0 0.5 p5d0 Cost Cost costs Costs Costs Costs Costs Csnency costs Costs Costs Costs Cs. Feet Cu. Foat Cu. Foot Cu. Faot Cu. Feet W., Lbs.

Monhtt-Maoollhrs PERIOD Is -S8hunoos, Seough Transtion Pedod Is Direct Doeonnsoroning Act00es

'a.1.1 prepare pindmavy d 1cormin0sioning cost 1I.1.2 Nob0ficaton of Cessaton of Operators 10.A.3 Renno. 1.5 sofull t-rihal 1:.1.4 No f-tion o f penlannt Dfloling 10.1.5 DOs=lvn plant sylones & process wast 10.1.6 Prepar, and Wa1n P6DAR 1.1.7 Roow plato dwgs & qiecs 1:.1.8 Parlor. detailed red l

-ey I.1.9 Estoina by-produ0 inoonry 1E.1.1604nd podict descripton 1.1.11 on04sad bylodit i-nO1 ory 1.1.12 D.:: r01*01 or wqu0ro0 1:.1.13 P01foor SER "nd EA 1I,1.14 Perform s01 -Specsc Cost S"udy 1:.1.15 Prnparl/subrit Licerse Ternination Plan 1.1.16 Raer,.0 NRC ppr100o of bernsnsot plan Acbvdy Specifictions, l:.1.17.1 Plant & tanporary foies 1 J.17P2 Plant sypnms 10,1,17,3 Ne6ss 0.oslanlat n Flosh 10.1.17.4 Reactor L'rna0 s la.1.17.5 Reactor 0e1 el lo.A.17.6 BiotogiIl shield Ia.1.17.7 Stam P ert-or la.1.17.8 R00fonfed co0co're ta.1.17.9 Main Tsttso 1.1.17.10 Main Condensers 1.1.17.11 Plaint ar nuadiS&

ngs 10.1.17.12 V.A0 mnglenment 1.1.17.13 Facility & adostoo 1a.1.17 Tota P

nIn--g

& Sh Preparaorknt 10.1.18 Props. d atilg s*oqoorn 1

P.1.10 Plan tpop.&lolop1,s os 1,.A..

Design -fatr ckaw-systmn 1:1..21 RigginWCont colEn1ftos

.oofotgfo 1I.122 Pro-iica salrme rs&confisne 10.1 04Subeo Perod Is A801101 Costs Perod Is Addnonal Cosks 1:.2.1 Spent Fuel Pool isolato*

10.2 Suboll Period 1.0 Additional Costs Period 11 Collaorol Costs 1:.3.1 Spnlt Fuol Capital and Transt-I1.3 Subtta1 Period I. Coliateo l Costs Period 1. Piriod--D penden Costs 1:.4.1 1--ran 1.4.2 Property 0U.0 Ia.4.3 He.h phyo sopplos Is.4.4

.eW qivaen en 1.4.5 Dispos of DAW generaed 1.4.6 Plaino -nWly budget 1I.4,7 NRC Fm 1.4.0 onenrgency Planning Fees 141 21 162 162 217 33 250 250 499 75 574 574 1,300 106 I09 141 814 337 543 445 534 452 54 771 700 54 339 174 43 43 339 499 98 4.108 16 12 125 10 125 125 21 162 162 122 930 930 50 387 387 01 624 624 67 511 511 00 614 503 68 520 468 a

62 62 116 886 886 106 e11 011 0

62 62 51 390 390 26 200 100 7

50 7

50 51 390 195 75 574 574 15 112 56 616 4,722 4,158 52 100 50 50-195 56 564 2,000 4,600 1.000 1,300 7.500 3.100 5.000 4.096 4.920 4,167 7.100 6.500 5w2 3,120 1.6O0 40D) 400 3,120 4,620 900 37,827 1,400 1.230 73,753 261 39 362 362 2.700 405 3,162 3,106 3152 2

175 175 2

2.100 315 2,415 2.415 134 25 154 154 12.807 1.921 14,725 14.163 9,140 771 5.911 5,911 5,140 771 5.911 5.911 564 9,475 1,421 10.896 10.806 9,475 1,421 10,896 10,809 386 387 9

6 775 1,745 41 2,557 706 275 77 852 852 174 1,919 1,919 97 483 483 58 445 445 12 69 69 383 2,940 2,940 71 776 770 27 302 302 610 12.190 22 TLG S-krtoso, 10-.

P-boill. Wood AN..4our Gasdesutisg P0.04 D.coomed-icaulag Cost Adjyori.

Da~ooe4 XOJI.1586-002, Reo. 0 Appjoll.t C, Pam. 2 fj'l Table C-1 Prairie Island Nuclear Generating Plant, UnitI DECON Deconms asioning Cost Estimnate (MFousaudo of 2098Dollars)

I Asboffty 0.60.

Revemsid Posbaglaig Tomsoport Pro0005mg Disposal Other Total Total UsG. I-.

Maramiled-It R..ketist Volum.

Class A Ci.. B Class C GTCC Processed Craft Cosivedoar col costs Costs Come Cns 010 C~o..

CoCos ts C

CO.

costs Co. Fast Co. Fes o.Fst C

o. FeelC~ho Co. Fent WVE.

Lbs.

2b.1000Ws MmnhOOW Period 1. Paricod.O.pao4.nlCosts

(-nobud) 1:.4.9 Sp~ot Foel Pool 051M 1 4.10 ISF01 Operating co

1. 4.11 Samm~ystaff o10 l..4 12 UtsO1Staffcost 1.4 Subtsotal Period 1. P-oo1-Dpdeo,dm Coost 1.0o TOTAL PERIOD Is COST PERIO It lb.Datuarithselooao1 Re~pulsed-Period1 lb Direc Datosoo04ooOiche A*.bot.

0.01.M4 WkI P-da.s lb.1.1.l Pliall Yetsol 1.1..2 NSSS DnoosrtsmlkationFlush 1011.3 Reactorifllellols lb1.1 14 Re "Its' buidt".

lb10110 CRSIIO-so

&OICItubn.

lb.1.18 Reactlor aas.I 11,11'0 M140000145 lb.i1. IlBiological "d 1111.111 OlO= g.1.m11 b1 1 114 M6in1oTrbin lb.1IllS Mos Ca04001 lb101.11 A.04ooylsbdo ibi 1.17 Racmturuidog Ibi I1 Toad lb102 D.-0 p10109 loop lb.I Subtotal Period lb, A.6,*~ Comss Period1 ItAdditc0l~o Costs

ý1,.2.1 Si.0 Chimson1loboln 1b.22 Mixed hM I b.2,3 RCRAV82O.

Ib.2. 4 Aab.IWnAbt.

M00 lb.2 Subbalol Period lb, Add.60,1 Co.-

Period lb, Collateral Costs lb.31 D-60 S63t10011 lb 3 2 D0C staf relocaboo exoesses~

1 3.3 Pln ssiqd -see l03.4 S0004110W0al 15 b3.5 P 0.Oftv0g-qPo82 lb 3.6 0.60rig lb.3.7 Spare Fool Capoita and Trsoolbr lb.3 Subtota Period lbI0II Colltra dts Period It Parod-O.Pel.M14nts Co 11,41.1 no0- -*Pbol I b a.2 1-150 lb.4.3 Propay ou0.5 I1b4 4 Health Physicssupplies I1,4.5 H~avy.qupniwd Ioo lb. 4.6 DisposaoI D AWgennlsbd We.7 Paidl51lnlW budget 773 373 44 2,276 24.026 9

6 41 32.17*5 56 429 429 7

5o 56 341 2.618 2,018 3,604 27,630 27.630 4,906 38,513 37,732 781 46,678 423.400 610 12.190 22 470.078 773 9

6 41 60.196 9.021 70,047 57.106 11,677 564 610 12J190 22 543.831 514 77 591 532 S19 16 125 125 271 41 312 312 147 22 169 42 109 16 125 125 109 16 125 125 109 10 125 125 394 59 453 453 130 20 150 75 49 7

56 56 130 29 150 150 499 75 574 574 109 16 125 62

.16 25 198 169 25 195 296 44 341 307 296 44 341 307 3S6A 541 4.150 3.370 59 75 62 195 195 34 34 780 4,733 1,000 2,50) 1,350 1,000 1,000 1,000 3,630 1,2D0 450 1,200 1,000 1,560 1,560 2,730 33,243 190 570 570 3,609 731 4.720 3,940 782 380 1.067 33.243 1.50 1820*

11 6

1 17 3.290 987 4,277 4.277 53 946 151 1.161 1.161 4

21 4

35 35 103 88 437 2.227 2,227 159 968 82 3.290 1,5I6 7,701 7.701 12.043 12.543 166,959 18,667 16.,959 18.667 743 27 40 225 21 1.666

-O 1.4

.00 2.170 1,021 40 225 912 22.023 2,023 0.756 111 085 859 137 1.04 9 1.949 557 2,872 2.872 3

25 25 10 1.150 1.150 210 1 '610 1.610 877 6.720.

6.720 2,045 14.280 7,560 6.720 6

29 29 39 430 430 88 966 968 71 356 356 29 224 224 7

41 41 387 2,964 2,824 174 565 73.114 144 174 565 73.114 144 360 7,197 13 23 285 195 5

391 800 4

24 2,578 nlo sanmi-,

Im.

Prairie Island Nucear Generating plant Deco-soeftoting Ced Anoodtin" Document X01-158-002, t*e. 0 Appendix C, Page 4 afR2 Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands af 2008 Dollars)

I IActiy Off-11,6 LLRW NRC Spent Fuod sit.

Processed Burdal olumes lB I UlftMy osd Decon Removal Packaging Transport Processing Disposal D tto Toni Toee Us. Ton.

Muoagoo*ol Restoaoton Volume Class A Class B Class C GTCC Processed Craft Cosoossor Cost Cost Cost Costs Costs Costs Costs Co0osnon Costs COSTS Costs Coosp Cu. Faot Ca. Fust Cu. Fust Cu. Feos Cu. Fast WL, Lbs.

Moohosro MolhorssI lodex Period lb Period-"Opendent Costs (Wonbesd)

Wb,4.R NRC Foes lb.4.9 Emergency Planing Foos lb.4.10 Spe*d Fuoo Pool O&M 1b,4,11 ISFSI Opeatng Costs lb.4.12 Seourity StaffCost lb,4.13 DOC SffCos lb.4.14 U

atsyStoffCost lb.4 Sb!t5 Pust lb Ponod-DOplndet Coos 1b.0 TOTAL PERIOD 1t COST PERIOD I TOTALS PERIOD 2a -Large Component Removal Period 2a Dreco D nnriodong Actrooes NUdoan Shoan Supply System Removal 2a.1.1.1 Reactor Coolant Pip'ig 2a.112 Prsuner Reulief Tank 2.1.13 Resctor Coolant Pumps & Motos 2o.1.1.4 Prssurizerr 2..1.115 Stam Generators 2.1.1.6 CRDMstChuSoese-St-t-nr R-romol 2a1.1.7 R eo Ves eal lnlorala 2a.1.1.5 RetoronVososl 2.,1.1 Totals Remonvl of Major Equipment 2a.1.2 Main TuitsnGenoaien 2%.1.3 Main Condenses Ca.s-*dns Cost from Cloan Building D foinono 2.1.41 RIector 2..1.4 Toads Disposal of Ptant Systems 2.1,51 Air Rrnnodl 2a..52 Auxilaryo Feesitfr 2.1.53 Audloary Feedwaler - RCA 2.1.54 Eled Stearn 2a. 5.5 Caussc Addon -RCA 2.1.50 Chnol Foed 2a,1.5,7 Chuncal Fe.d - RCA 2..1.508 Ciondsng oWater 2a.1.5.9 Condensate 2.1.510 Conde"sa" Poshing 2.1.511 Condernslo Poialsngi-RCA 2..1.5.12 "I.nJyora-lko 2a.1,5,13 Fuodnoato 2a.1.5.14 Fen-doss-FRCA 2.,15 1

-Glad Sea 2..1516 Heaetr Drain 2..1.5.17 Intenal Ciu Water & CDSR 2..1,518 Most GOurdoran/ Tnand.onmn 2.15..19 Man Slan 2..1.5,20 Main Seam -RCA 2.1.5.21 Staeorn bondewn 2a.l,22 S:m

-ereoforstro 20.1.5.23 Turbine & Mosntes Separatons 2.1 5,24 Turbine Oi Prficatbon 23 480 2.573 3.10D 2,573 3,873 5-4 63 388 72 394 350 36 391 391 139 14.

152 188 28 216 22 3

25 4,083 612 4.695 4.695 5.055 758 5,813 5.813 12.173 1.020 13.999 13.099 24 25,803 3.9D5 30.304 29.910 968 2.136 39,518 8,260 57.005 49.111 968 2.177 90,714 17,282 127.053 108.917 152 216 25 394 7,114 10,791 780 1.345 360 13.377 565 13,988 505 79.313 64,137 214.491 7.197 13 358.011 247,270 19,891 391.254 259.460 19.913 935.015 41 34 4

7 18 15 3

5 41 46 20 84 36 58 492 306 181 Z513 1.739 1.330 128 55 110 34 00 1.777 9,.77 908 58 3.450 1.022 459 599 7.949 13.375 3,223 55 34 40 909 671 1.149 3.088 84 9.331 174 4.410 174 1.190 18.673 349 357 100 253 120 45 187 187 22 97 97 303 1.539 1.539 309 1,903 1.063 2,037 12.038 12.036 115 531 531 8,795 31,061 31.001 5,217 14.790 14.790 16,843 62.205 62.205 288 192 132 1,701 2.450 18.M72 11.318 2.404 501 527 4.319 1,377 18.804 23.180 1,904 918 918 34,807 1,414 21.280 625 325,380 1,785 202.122 2,282 1.68.341 11,617 53,072 3.225 219,145 21,733 619.525 21.733 3.143.000 64.414 2,875 1,001 1,001 4,878 245 130 51 2.045 56 35 170 1.12D 1.1250 2.131 1.107 287,637 4,667 590 3.099 3.099 2.851 941 203,723 39.151 862 882 22 3`1

-30 0

3 25 0

14 1

0 29 336 165 125 2

6 108 133 4

24 282 19 0

Of 251 6

314 12 4

275 50 1

17 1

19 0

0 12 166 19 257 30 404 21 162 69 12M 992 992 129 992 992 3

25 5

36 10 59 59 9

73 9

55 55 2

16 0

1 1

4 34 S0 307 25 190 50 364 364 1

7 16 124 75 488 488 4

27 42 324 3

21 0

0 12 93 125 819 019 124 703 703 1

4 41 3106 7

57 25 36 215 73 233 16 34 387 190 2,078 7

124 3,208 27 324 21 0

93 5,044 2.031 40 4

316 57 452 70

-,722 575 1,335 9,453 443 304 243 12 619 8,837 3,419 04,395 2,299 127 2,215 130.294 2,604 505 5.1181 S389 5

1 30 204.R25 4,871 125.865 6.152 75 1.003 11.415 11.415 M1G Servieso, Inc.

Prairde Lidd ANuclear Generatnsg Plant D..onounia.olmit. CostAa.LyoI.

Doooxeral XD1-1586-00, ft.Rn. 0 APinnaL. C, Page 5 of*1 Table C-I Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (Thousands of 2008 Doilars) i I Asfiotri Dessn, Renewal P.s.kglo Teospod P~os...15g 19.Po4 Oth.,

Total Total UsTos, Manaoqnownt Rioddratis SoiW-,

C616A Cl.

B CI...C GTCC P--.5.0 ClaS ContractorI C-2 ~ ~ ~ ~

~

~

~

~

~

~

~

~

~

s Coa Cod Coot..O col at ot ah iedC.FdC Fa ie I

Inda.

2.1.5 ToBIO 2a.1. 5 Scffoking, in Reppoe of doeumewasmnog 2.1 Subtotal P.004 2. Ach*l Coee Period 2. Cottoned Coate

2. 31-P-0.

liquid osoBe

2. 32

-010 love ---, on, 2.3.3 Some0 Fuel Cao ar6 Traoneo 2..3 Suttee0 Perid a 4 4awra08.

Co Period 2. P. d-epandeent 0010.

2..4.1 Deon tuppIl.o 2..42 1-2..4.3 Property tooo 2.4.

51160185610 2..5 Henry quio~learental 2..4.a Disposal of DAWg.n10o0 2o4.7 Plant energy budge1 2..4.8 NRC F...

2..4.9 E-e..soy Plarunng F..

2.. 4, 10 Speo9 Fool Pool 051M

2. 4. 11 ISI'SI 0p068n9 Code.

2..4.12 eou" Staff Cast 2M.4.13 DOC StaffCoal 20.4.14 UOiftyStiff Coal 2..4 Soei pandod

2. Po.do4Opandanoo Cool.

2.0 TOTAL. PERIOD 2. COST PIERIOD th - 8160 D~so.nUM00OM P.erid 21, Drec Dooonerawwon~og ASOSO..a Diq.WofoioPlar, By-0 2.1.1.1. Am~ 8lq NooraI Veoation0 2b.1.1.2 Battery Ro Spacdo Ventlation 2b.1. 3 Buldingso 5100 2b 11.4 ChernacaI

& Volurn* Control 2b.1.1.5 Comlponent CooIhlg -FICA 2b.1.,.6 C'"'0io,6l Cooling 2b.1.1.7 Crn10.oo, Cooling -RICA 2b.1.1.8 Conounto.o Htydrogen Conal FICA 2b.1.1.9 CkoolooooonfSpray-5CRA 2b.1 110 ContaireeneV"'e.Snn 2b.1.1.11 Cocang VAl(

2.1, 1.;2 cooling VWW FI-CA 2b.I1113 DI Emergency Diool 2bI1 114 D2 EnorgancyO~

Deia 2b1.1115 DWW oRoon Verbatiom 2bI.116 Electricl -Clean 2b.1.1.17 Eloobrxidl Cor10o..olod 2b.I1I I Eletical s-Dooorearni.l 21,1 19 FueIl Heeling 21,1 1.20 Fue Od 2.,1 1.21 HVAC -Clean 21,1.122 HVAC - Coolooninat.4 2.,1 1.23 5100,. Inianarnooubor, 2b.I1124 Mi-Dr-

& V.nIs 2.1125 Rea=l,CooSlan 2.,1 1.28 Reo90r He Sarnplkog 2.38 25 a5 1,025 69 632 4,225 2.490 1.734 12.815 495 563,797 48,090 708 2

1 12 1

179 904 804 138 9

-" 6,982 6,073 599 14.197 13,589 3.395 2,842 19,023 349 18,590 72.544 70,809 1,734 36,739 25.711 1,904 918 4,205.820 173.810 4.878 57 21 114 142 57 142 21 114 108 74 374 374 21 164 147 14,038 2.105 16,141 108 14.036 2.201 16,679 521 16,141 1

16,141 16 58 1.125 2.363 56 3,488 713 17.827 I

0 3

832 926 574 51 209 21 63 184 113 442 35 26 6 8' 1,356 427 2.571 S

89 S

86 84 275 25 162 112 192 110 G4 44 29 44 29 13,654 3.539 0

0 51 65 15 74 4

20 o

1 1

5 13 39 9

46 4

16 25 140 3

8 5

21 1

1 a

9 12 13 7

5 B51 2,218 202 3.087 837 127 474 55 8,427 15,540 21,968 202 53.252 2.842 19.333 67,636 0

308 286 904 272 8

69 396 74 Ole 202 10

1. 884 73 22 251 12 5

6 31 52 28 78 5

34 14 72 72 52 570 570 222 2,440 2.196 281 1,406 1.406 355 2,718 2,718 59 334 334 463 3,551 3,551

• 4 920 920 13 140 71 545 8

64 1,264 9,691 9,691 2,331 17,871 17,871 3,295 25263 25,253 8.512 65,585 64,563 29,263 154,807 135,923 0

2 2

0 0

0 4

788 3.307 3,307 308 1.962 1,062 0

59 97 602 602 7

36 36 27 1G 108 131 838 838 17 130 211 1,327 1,327 5

41 4

29 1

7 204 1,563 142 801 601 949 5,572 5,572 40 235 235 13 99 13 97 115 688 one 8

40 40 60 322 322 131 566 568 08 344 344 140 545 64 748 16.889 244 244 1,995 387 387 2,90O 35,739 29.064 1,304 3

4,490 2,214 12,427 3,400 105 868 4,951 520 7,728 2,527 67 23,561 96m 154 3,261 87 60 40 390 363 344 548 Be 241 918 23.216 75 23,216 75 0

4 59 130 41 29 7

1,563 99 97 59,306 108 162,294 201,509 S -

374,673 59,308 10o 738,476 4268,343 173.93 743.354 140 22 65 363,748 33,361 504,675 10,93 1,0632 136,090 3,641 4,278 36O 35,249 1,195 247,736 3,661 2,398 313,832 8,397 730 522 113 26,081 108,671 8,376 959,401 49,378 A50677 1,782 1,697 1,861 140.234 5,031 6,015 424 48,363 3.008 63.108 5,963 24,259 3.940 30 S&rkoe. ln-.

Prairie Island Nuclear Generating Plant Deca*noelsatontng Coal Analysis Doattmsent X0.1586-002, Rev. 0 Appendix C, Page 6 oaf2 Table C-I Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) on-at.s uLtoW NRC Spiol Pool site Prosssd Bomst Vo.sta Bntal I 11111ty and AcStvlty Oecon flOaosal Packiglng Transport Processing Disposal Other Total Tom t

c. TaLr-Manageent Rastanson Volune Claus A Class a Class C GTCC Processed Crat Contractor Index Actvity Descripion Cast Cost Casts Costs Costs Casts Costs Contisnog*

Casts Ceats Costs Casts Cu. Fast Cu. Foot Cu. Feet Cu. Feet Cu. Feet WtL, Lbs.

Moalthors Manhours Sisposa at Plant Systems (on"rond) ab.1.1.27 Reactor Makeup 2at1120 Reactr Veassal 2a.1 2. Roiduoal Hast Reosoval 2b.t11.30 Safeguards Crtulde Wter 2b. 1.1.31 Safet Iniection 2b t.1a.

2 Sttyipcsl o

2b.1 1 33 Shield Bl5g Ventolabor t.1.1.34 Sut-snlsIruinrm Air 2b.1.1.3a Staaion I t

Intt ument Ai - RCA 2a.1.1.36 Tubine Bdg Trapi & Di 2a.1.1.37 Unit Coors 2b.1.1.38 Ui Coom-RCA 2a.1.1 Totals 2at1 2 Scaffolding in support of decatoranm.moog Deconasrnnaton of St. Builings 21t13.1 Rancor 2a..3 2 Bsk-usbh Wana R wivnlg Tank 2a.1.3 Totls 2at Subotol Period 2b Acdy Cost.

Period 2a Cosateal Coos 2b.3.1 Prs*60d ho s

2b.3.2 Soot too aIlnd a nI 2a,3.3 Spent Fuia Capital and! Tnsat-r 2a 3 Subtotal Period 2b Collaterl Costs Period 2b Peod-ODepindint Coos 21,.4.1 D-o

nuppins, 264.2 1-,ieain 2a.43 Property fares 2b44 H0 alh phycs supplies 2b,4.5 Heavy Wo*rnt nasnal 26.4.8 Disposal of DAWgrratsd 2a 4.7 Plantoerergy budget 2b 4.8 NRC Fees 2a.4.9 Emtrgescy Planning Fees 21,l10 Spent Fuel Paul OSM 2b.4.11 Liquid Radwants Proceosng EqoitprnntServicas 2b.4.12 ISFSI Operating Costs ba4.13 Seurity Staff Co 2b.4.14 DOC StaffCos 2bl4.15o uStytff Cost 2a 4 Subli Period 2P a Panod-Oependont Cons atb.

TOTAL PERIOD ab COST PERIOD Ze -Delay Bsdres End Of WM Fldd Sloarg Pernod 2c Direct os ig Activiti Period 2. Codlataal Costs 26.3.t Spent Fuel Capital and Trennd 26.3 Subtotal Period a6 Collast-al Costs Perod 2c Period-Dependnt Cots 2.4.1 Insurance 2aA.2 Propenty taxs 2e.4.3 Hoath phyics supplies 52 7

11 0

0 234 274 46 61 13 61-24 56 42 2

2 100 7

19 14 56 0

2 35 29 36 0

1 1,294 9,291 241 606 885 3

1 2

1 232 327 543 116 5

1, 172 49 27 18 8.206 1OOt IS 2

a 60 7

29 29 316 1.490 1,490 2

14 275 1,630 1,630 14 75 75 67 415 415 2

16 IS 104 104 5

40 4

33 12 68 68 4.095 22,813 20,621 224 1.130 1.130 60 1.D42 260 1

1,090 367 2.895 2.295 323,397 7.114 14 259 6,788 855 3480.07 12.044 59 76 9.163 809 2.102 346 118,482 2.015 1i 300 332 13,496 1.053 40 767 33 611 230 9,348 657 2.192 77,571 7.816 3.829.133 2D2.380 173 11 8.728 7.591 see 771 00 140 178 540 830 3,443 3.443 2,230 5,

6-7,193 30,a45 23 7

10 23 14 78 78 439 43.896 311 B0B 794 07 150 178 569 844 3,521 3,521 2.230 6,388 701,089 31,155 2.183 10.970 341 757 8,400 1,650 5,163 27.464 25,272 2.192 79,974 14,215 4,538,050 241,127 139 96 537 6-5 334 1,801 1,801 189 28 217 217 1-176 1,781 13,57 139 189 96 537 695 11.076 2.143 15,676 2.019 345 1.536 3,479 55 36 345 5,015 55 36 2,687 10.174 492 1,330 86 431 431 768 77 845 845 1,615 162 1,777 1,77 304 1,920 1,920 522 4,001 4,001 248 73 411 411 3,614 542 4,156 4,156 1,241 124 1,365 1,365 188 19 207 703 105 am 354 02 407 407 8 2 12 4

2,061 309 2,371 2,371 15,392 2.309 17.701 17,701 22,210 3,333 25,550 25,550 248 48,236 8,110 62,044 O0,934 6.400 2,593 60,112 15.416 105,184 88,*.5 13,w57 13,657 2W7 808 94 1,100 14.707 1.73 140.807 348 1.783 149,807 348 3,640 72.790 133 42263 212,297 395,109 3,640 72,796 133 649,609 2192 79,974 19,637 4.761,552 241,607 640,069 5-1,490 51,490 7,723 59,213 7,723 59.213 59,213 59,213 963 4,704 470 5,174 5,174 9,918 992 10,910 10,910 241 1,203 1,203 TLG S-r-r

, lve.

Prairie [Wn 4Nooc8or 2.ratiog PleadI

-dooooidunfeoolg Cbef Aay.1.oi Dwromeot XD1-1588-OO2 Reov. o Appendix C, PGV~ 7 orfl Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (rihousands of 2008 Dollars)

I I A."tir 0.000 8.0,0.01 Packaging Tiewsopr Proaoololln0,.on.oo lin T

TOWi U, Turn, Mangernwit R-oron.0 VOofIBM Clan A Cloan 8 CIM C GTCC Pr00.0009 Craft C008010.

t00 C~od Cuml Coeur Caiot Con Coeur C0.=oo~

Cooe.

Coon C.ot.

Costs Cu. Feet Cu. Foot CU. Ford CU. Fort Cu. Fewt WI.. 180.

Manourso Moithooto tonn.

"elf ve-o"Peore Peiod 2c Pernd0-opendeor Cows (nansued) 2.4.4 Depen of1DAW8 W100 2c,4.5 PFat energy budget 2c.4.6 NRC Feeo 20.4.7 Emergency Ptlnmoog F..

2v.4.8 Spent Fuel Pool O&M 2c.4.9 ISFS Opera Guin Cooe 204.10 Sonly Stlff Coid 2c,4.11 tialy Stun Codr 2.4 Sbtol Period 20 P.1reI0.pn.dent Covr 20.0 TOTAL PERIOD 20 COST PERIOD 2d - Dworauotin*dot F 011040g Wet Fuo St aobo Period 2d Dirct Deoornrynelaug So so 2d.1.1 R.n-o speet fuol rok.

DOtposidola P1a rSy0000 2.1.2.1 Electical -Codnoumnated

-Fuel Pool 2d.. 2.2 Eloomoal -D-noodnaotd - Ful Pool 2d.1.2.3 HVAC

- Comunewta d -Fuel Pool 2¢1.1.2.4 S.I Puird.ChWod otl-RCA 2d.1.2.5 Spalt Fuel Pool Cooing 2d.1.82.

Stalton & Inwomlov Aw". RCA Fuel Pool 2d.1.2 Tonle 2d.1.4 Scaffolding sop,,l of ¢oooosolboo.,

2d.1 Subtotal Period 2d Ac"0ty Coot, Perod 2d Codeotto Cons 2d.3.1 FP-o fiq id -noto 2d.3.2 0m,0 tooooonoo 2d.3.3 De-omnktog Eqo1 io t Ditpooono 2d.3A4 Sper Fuel Capiti and4 TTorevdet 2d.3 Sutol Pe.,0od 2d Collolotol Coon Period 2d Priod-O.epenent Cootn 2d.4.1 Don. oRppb.o 2d4.2 Insur-nc 2d.4.3 Prop" a01 0

2d.4.4 No.18 Phyolooon0o 2d,4.5 Hooy oinpnerot,

,t90l 2d.4.6 1lol of DAW gomo80d 24.4.7 PFirt 00,0 budget 24.4.8 NRC Fee.

2d.4.9 E-ooonvy PIWto,4 Fe 24.4.10 Liqui RadoooO P00noW EqxooWSot1km 2d4.4.11 ISFSI Ope01i0g Coot, 2d.4.12 0Se0ity Stff Cout 2d.4.13 DOC stn" Coot 2d.4.14 U01 Staff Cor0 2d.4 Su0t00 Period 2d Peo4-ODepeuent co00 2d4.

TOTAL PERIOD 2d COST PERIOD 2. - ULcene Trmiative Period 2. Died D-.ooono Aoo 2@1.1 ORIbSE confolulaory ue y

20.12 Tomitatt b-22 14 99 5,917 2,112 1.150 4,313 504 36,761 37,813 963 22 14 99 103,158 963 22 14 09 154,688 249 26 65 28 211 29 160 105 888 8.805

. 6.85 211 2,323 2.323 116 1,272 1,272 647 4.808 4,960 76 579 579 5.514 42.275 42,275 5.672 43,485 43.485 14,855 119.151 112,339 a.812 23,578 178,364 112,339 66,0235 194 773 773 1.460 29,205 53 706,011 1.460 29,205 53 1,405.959 1,460 29,205 53 1,405,911 1.477 132.519 576 102 1

4 49 2

35 197 197 15 16 26,444 2,077 642 7

35 471

-237 1.393 1.393 5,893 239,377 12.340 118 2

5 112 5

49 295 295 1.358 37 60.100 2.15-58 1

3 40 21 122 122 495 20,100 1.019 209 240 18 23 84 133 213 881 001 806 935 116.589 7,358 14 0

0 7

5 29 29 83 3,374 253 209 1.178 29 74 743 141 560 2,935 2,935 9,290 989 465.935 25212 177 1

0 3

0 45 228 229 35 2

1.746 1.518 458 1.381 00 103 746 352 799 3.934 3,934 9,325 2.468 6808.19 27.307 49 34 153 252 135 840 840 259 4

29 29 96 55 532 53 111 848 948 227 34 261 49 25 131 245 532 309 227 269 1.786 1.524 32

-285 599 323 1.288 1

a 52 714 460 70

.262 30 213 3,875 4.900 32 1.612 I1 6

52 11.408 538 3,018 237 35 1.278 709 11.635 8

40 40 29 313 313 08 659 659 81 403 403 153 1.483 1,483 15 99 88 107 822 822 46 508 5w6 7

77 39 301 301 5

35 32 245 245 S01 4.458 4.456 735 5.635 5,635 1.938 15.081 14.949 3,05 20.780 20.407 261 261 77 35 112 373 640 6,O0 373

.008 1014 785 765 15,325 4,240 54.310 125 303,.507 8s 357,817 213 15.294 28 4.371 53,186 88,157 15.294 20 145,714 973.310 27,540 145,714 148 44 193 193 3742 se-k.o, boa.

Pre~d~t. 1.1-d N-ledo, C20s,.tisg Moot4 Dooo.-de.doialig Cos A.,sl~wi.

Dovsssvoot XOI1586002, Rev. 0 A~pp.sdio C,,Pog 8of 21 Table C-i Prairie Island Nuclear Generating Plant, Unit I DECON Deconiissioning Cost Estimate (Thoosoadsof 2008 Dollars)

I Actlylty Off-Wito LLRW NRC 8lpent Fuel sit Pm

.s~l Burial Volurnes Burial I Utiliy aridl Decow Reibovt Packaging Transport Prtovsso Disposal Other

0.

To:I Totsl U*T Te Maa.lsemt R.st-ltkot Volume Class A Cie. B CUs. C GTCC P1.0.ssad Craft CooBaoto Cost Cost Como t

Cos" C

cot.

Coots coots Co.m Cost.

Cot.s Cost.

Costs Co. Feet Co. Foot CO. Feet Cu. Fast Cu. Feet WI, Lbs.

Mhobso ManhOrlsI too..

2e.1 Wartatd Period 2. A4c0ty Coost Period 20 Addr1oo Coast 20.2.1 L-oe.

T.rn*oore Stoosy 20.2 Subtotal Period 2. 44,50a1 Costs Period 2. Colateral Cots.

20.3.1 DOC stff rloca..one4oo 23.3.2 Speno Fuel Cap" arid Transfer 20.3 Subtoal Period 20 Collatera Costs Perod 2. Perod-D.p-nd M Coost 20.4.1 Inl[-r.o 204.2 Property Oarm 20.4.3 Healh Physics supplie 20.4.4 DlrodoflDAWINelvraed 20 4.5 Rontoenergy budget 20.4.0 NRC Fees 20.4.7 Eesrgency Planning Fm 20.4.0 ISFSI Operatg Cost.

2.4.9 S-onty Stff Coo 20.4.10 DOC Saff Cost 2..4.11 U0f1ty Staff Cost 20.4 Subtotal Period 2s period-Oepond.rt Costs 20.0 TOTAL PERIOD 2. COST PERIOD 2 TOTALS0 PERIOD 3b0-aSm BRst..owloo Period 30 Direct D0.omn-.osib Acsieso Dern0it0n of Re.m.ong Sit BOodoos 30.i.1.1 Reactor 3S.1.1.2 Contso ase Stompg. Tonk Foondtion 3,1.13 Turbine 3b.1.1.4 Turbinie Pedestal 201 I 4 Tobss 50.0 30.11 Totats Site CloCseovt ACtOs 310.1 2 Grade & landscape aft So.1.3 Findl report 0 NRC 30.1 Sbtoatal Period 31, Activty Cost.

Perlod 31 Addition Cost.

30,2.1 Cono'ate Cooruing 30.2 Sttothl Period 31 Addsorial Cos.

Period 30 Cokatied Coots 31.3.1 S0aU 0

oo aslosanlo 303.2 Spent Fuel Csp*WJ and Trasdw 303 Sub5,0 PFod 31 Col-tsad Coot.

Period 31, PsoOd-0pold.

Cost.

3b.4.1 tnsoo.0 30.4.2 Fropetly 0

3S.4.3 Heavy equiprent rrnaI 3b.4.4 Plantsenrgy b1.dget 3b.4.5 NRC ISFSI Fees 3b.4.0 Emo*.e-' Pltonig Fm 3b.4.7 ISFSI Operatin Coots 148 44 193 193 2.928 878 3,800 3.806 2.28 870 3,806 3.806 912 137 1.049 1.049 1.184 20 211 1.096 164 1.261 1.049 49.489 49.489 211 211 274 27 301 301 641 04 705 705 395

.99 403 493 5

3 22 6

36 6

316 6,325 12 382 57 440 440 528 53 581 581 75 7

82 82 33 5

37

-37 228 34 263 263 4000 2,591 389 2,979 2.979 35, 00 2,200 342 2.622 2.622 39:00

-0 395 5

3 22 7,032 1.014 8,540 8.420 120 316 6,325 12 79,560 205 5

3 22 11,204 2,171 13,799 13,4O8 331 316 6,325 49.501 79.560 3,919 38.377 14,410 5,245 10,520 22,755 305.275 72,434 472.934 370,363 98,385 4.187 132.037 54,724 1,904 918 10.058.730 492,701 3,024,285 4.001 Z65 Z235 685 7.948 749 5.740 1

7 340 2,605 103 788 1.192 9.140 5.740

-7 2,an 05 700.

S.14M 60.349 34.340 7,580 108,365 316 1.560 10.,680 1.560 126

- 0.74 210 210 92 92 10 145 169 25 195 105 109 1.236 9.480 195 2

32 244 2

32 244 9.2B5 244 244 1.126 1.128 397 397 14 105 00 450 73 562 100 458 40 105 5.726 847 as 932 153 15 168 000 6,585 592 0

6811 294 20 322 231 23 254 101 15 116 032 0.505 204 476 323 254 lie.-

TLG1 Sarvioi. Zoo.

Prairie Island Nuclear, Generating Plont Doooooauiooiooiog Cad Anaolysis D-nioeall XDI.1586-002, Ret.. 0 Appendix C, Page 9 of~i Table C-1 Prairie Island Nuclear Generating Plant, Unit 1 DECON Decommissioning Cost Estimate (TIhousands of 2008 Dollors)

Actoivty I

off-mt.

LLRW NIRC hoot Foo sit.

P-00000 Burial Voluesse s10011I Ulft. 00 00.0.

Raoiovdl Packaging Transport Proessing Disosaol Other Toni Toen Lin. Tern.

M08en0t Restoration Volur0 e Clasi A CUaSS B

Class C 0TCC 8000.4d craft Con0arto0r Cost Coa COsts Coot.

Coots Coost Costs Contingency Cols Coot.

Costs Costs Cu. Feet Cu. Foot Cou.Feel C. Feet Co. Foot Wt, Lee.

Ma04o0n, Mohtno kid.

Period 3b Poood-Oependerd Cons (corsnued) 35.4.

Securty Staf Cost 3b4.9 DOC S~tE Cost 3b,4.10 U"ty Staff Coa 3b.4 Subtotal Period 31 pariod-Dep nd.M Costs 3b.0 TOTAL PERIOD 31 COST PERIOD 3; - File$ 41t"o. Operoso.to ppig Period 3c Donot Doead ronog/ohoabs period 3c Collateral Coosts 30.3.1 Spent Fuol Capital and Transfer 30.3 Subtotal Period 3 ColIateral Costs Period o3 Penod-Dependnrd Costs 30.4.1 1ns-no.

30* 4.2 Property toes 30.4.3 Plant otoy bdgiet 30.4.4 NRC ISFSI Fees 3X.4.5 E

0Merency Plonnrog Fees 30.4.6 ISFS1 Operating Costs 3c.4.7 Sownty Staff Cost 30.4.8 Uiy Stnff Cost 3.4 Sublomtl Period 3c Penod-Oependent Costs 30.0 TOTAL PERIOD 3. COST PERIOD 3d -GTCC Slhpping Perio 3d Direct Deco rnmouioning Acivties Nuclebr St.-a Supply Systamn Remov, 35.1,1.1 V..et&sInt*.nolRGTCC Dioslal 3d.1.1 Totals 3d.1 Subtotal Perod5 3d Ac" Costs Period 3d Perio-D4epende COcT" 3S.4.1 1-34d4.2 Proper tyoxo WA4*.3 Plant ener0y budget 3d4.4 NRC ISFSI Fees WAS4.5 Emergency Pl0ann Fee.

3W.4.R ISFSI Operatng Coot.

344.7 Secury SDUIT Cost 34.48 Uility Saff Cost 34.4 Subtotal Peiod 3d Period0-epodent Cost 34.0 TOTAL PERIOD 3d COST PERIO0D13 -ISFt 8 o1 Deov o

Perod 3. Direct Debomrnieboning AOOides Period 3. Addihoeal Conts 3a.2.1 ISFSI License Ternwnaton (TN-40) 3..2 Subtotal Period 3. Addiional Cost.

Period 3o Pe.od-)SPandend Costs 3.4.1 W0 3.42 Propero tyooo 5.726 14.102 4.458 669 5.127 0

4,204 6,669 1,004 7,699 1,788 268 2.056 0

1,193 15.159 3,057 23,942 0

7.395 15.725 4,398 34,228 195 7,851 923 7,599 864 16,547 26,151 81.506 81.743 31.386 204,635 109,806 206,195 2,263 2,263 339 2,602 2,602 339 2.602 2,602 7,446 745 8,191 8.191 1,346 135 1,480 1,480 1,560 234 1,794 1,784 2,582 258 2,840 2.840 2,033 203 2,236 2,236 585 133 1.018 1,018 32,189 4,828 37.017 37,017 9.023 1,356 10,392 10,392 57,977 7.891 64,968 64.968 59.339 8.231 87.570 67,570 572,786 143,409 716,194 715.194 290 8,851 1.363 10,514 10,514 512 105.595 200 8,951 1,363 10,514 10,514 512 105.595 210 8,951 1,363 10,514 10,514 512 105,595 31 6

7 11 8

4 134 398 238 200 8.951 23B 3

34 1

8 1

7 1

12 1

9 1

4 20 155 6

43 33 271 1.396 10,785 10,514 34 6

7 12 9

4 105 43 271 271 5,598 5,580 512 105,500 2.391 599 2.990 2,800 5

317 177 5

317 177 3.271 827 1,001 5,599 3,271 827 1,01 5.59B 31.862 6,429.376 2,909 1.12D 31.862 6.42&.376 2.909 1.12D 121 12 133 133 22 2

24 24 T"/,0 ts-roo, la0.

Prairie Islaondo NooOdo-Generating P1000t Deeooooiooondiag Co.$ Analysis Dricapeen X01.1586-002, Rev. 0 App-ra.l C, Patge 10 of 21 Table C-I Prairie Island Nuclear Generating Plant, Unit I DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

O-U. LLRW NRC Spent Fuel sit.

Procraw 604a Rott1900u0 r44 as u

IUdfy aod Activity 04,00M Reovooal Packaging Trospoot Processing Disposa Other.

Total Tosts Uc. Tero.

Management Restoration Voluate Class A CiosS B Clas. C GTCC Processed Craft CodtoIt Index Activt 0escr0p1on Cost Coot Costs ts ots Cosot Coots Costs Coooa Costs Coot.

Cost.

Cosot Cu. Fet Cu. Foot Cu. Foot Cu. Foot Cu. Feet W, Lbs.

Machoors Manhours Period S3 Period-Depeodont Costns(cnrnued) 30.4.3 Heavy Wqiptnent l

3e.4.4 Ploteerrogy budget 3S.4.5 NRC ISFS1 Foeo 30.4.0 Secuity Staff Cost 3n4.7 UtUty Staff Cost 30.4 Subtotl Period 39 Period-Opendent Coas 30.0 TOTAL PERIOD 3. COST PERIOD 31f-tSSSit.a Restoration Period 3f Direct DecS mrssiooning Ac0v0es.

Period 3f Addi0ona0 Costs 3Y.2.1 ISFSI Demoliton & Sitn Restoraton (TN-40) 3f.2 Subt0ta Penod 3f AckOOiboal Costs Perid 3f Coatotarl Costs 31.3.1 S-lI tol W.1I00n 31.3 Subtotal Period 3f Collateral Cost.

Period 3f Perind-Depeodent Costs 3f.4.1 1oo--ano.

3f.4.2 Property tae 3f,4.3 Heavy Wqopment rental 31.44 Plant eny budget 3f.4.5 Security *unt Coot 3W.4.0 Si Sotr Cost 31.4 Subtt0 1 Period 3f P.id-Deperndnt Costs 31.0 TOTAL PERIOD 3f COST PERIM 3 TOTALS TOTAL COST TO DECOMMISSION 244 37 281 85 13 97 33 3

36 146 22 167 119 Is 137 244 525 107 876 249 317 177 3,271 1,353 1.10S 6,474 372 23 59 454 372 23 59 454 1

0 1

1 0

1 281 97 36 167 137 876 6.474 31,862 2,510 1,901 4,411 6,426,376 2,909 5.531 1.591 80 1,591 0

454 454 II 11 1

12 12 a,1 12 94 94 43 6

49 49 73 11 84 84 1,205 49 7

57 57 784 81 177 38 296 296 2.050 455

19.

98 752 752 1,591 2,130 14,806 517 177 12.222 76,858 15.230 119.80) 10,708 82,919 26.181 31,802 512 6,531,971 114,306 933,040 6,492 57,055 14.998 5,816 11,488 37,154 481.A47 104.946 710,795 487,988 200.095 31,713 132.037 100,572 2,469 B18 512 16,800.170 626,920 4.892.411 rOTAL COST TO DECOMMISSION WITH 1,07% CONTINGENCY:

$719,799 thousand of 208 dollars, rOTAL NRC UCENSE TERMINATION COST I 67.0% OR:

5437,988 thousandsof 28080 do0lar IPENT FUEL MANAGEMENT COST IS 27.8% OR:

$200,094 thousands of 2898 dollars ON-NUCLEAR DEMOUTION COST IS 4.41% OL

$31,713 thousonds of 2008 dooa00 rOTAL LOW4.EVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

103,959 cubic fedt tOTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED:

512 cubic teot tOTAL SCRAP METAL REMOVED.

27,00 tons rOTAL CRAFT LABOR REQUIREMENTS:

026,920.a0-Eons End 140t0s:

We0- inlals ha tisa0ivt 01.0 chage as.5001,..

deonrussionirig0 00p000.

a _ Indicates. trot 00001010 porkarnOd by stbooool atf.

o -Indicates 0011.

the:

8hsvau 1s0esta 0.5 butd isrin-,.o

. -0 consinrog" - indicates

.n -

valu 3LG sr*ico, Ino,.

Pnioki blond Noolear, Genratrinog Stoutioo Decouenodionioddg Cost Annilysis Doeonteng XOI.158.O-00, Rem. 0 Appendix C, Page II of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off-aSt, LLRW URC Spent Fuel Site Proceesed o-lal Volumel Burial UtIty Attty Icn Removed Packaging Transuport Processlng Disposal OUter Total Told Uc. Teem. Mauagemnent Restoraton Volume Class A Clases Class C GTCC ProCnssed Craft Corrautor dex Actviy Descipt Cost Cost Coats Costs Costs Coat.

Coot, ConS Cost.

Costs Cost.

Costs Cu. Feet Cu. Feel Cu. Feel Cu. Feet Cu. Feet Wt Lbs. Manors M0ort PEROD 1a - Shutdown through Transiton Period la Direct Decomrissioning Act-res 1:.1.1 Prepare prel*ssry d o

cost 10.1 2 Notification of Cessato

• O1perations 1a.013 Remove tuel & source mate1al 1a. 1.4 Notification of Permanenl Defeelg la.1.5 Deactvate plant systerms & process waste Ia.1.6 Prepare aod subst PSDAR la.1.7 Review plant dwgs & specs.

Ia.1.8 Perform detailed rod survey la.1.9 Estimate by-product invetory 1a.1.10 End prodc desiphor la.1.11 Detailed by-product inventory la.1.12 Definm maim work sequence la.1.13 Perform SER and EA 1a.1.14 Perform Sit~epecdc Cost Study la.1.15 Prepare/submtLi Ucense Termination Plan 1a.1.16 Receive NRC approval of termination plan Actvty Specifcations 10.1.1,721 Plant & temporary foerifiee 1011.72 Pluns systems la.1.17.3 NSSSDeontaminationFsh U..1174 Reactor intemals la.1.17.5 Reactor vessel a.01176 Biological shield 11.117.7 Steam generators la.1.178 ReMifonrced conreto la.1.179 MsnTurbine la.1017.10 Main Condenser la.1.17,11 Plant strsctures & buSldings la.1.17.12 Waste mnnagement la.1.17.13 Faciity & site closeot la.1.17 Total Plani0ng & Site Preparations la.1.18 Prepare dismatlming sequene la.1.19 Ptant prep. & temp. ovoes Ia.1.20 Design water dea-up systemn la.1.21 Riging/Cont. Cr01 Envlpsftooing/etc.

1a.1.22 Procure caskstliners & containers 1a.1 Subtotal Period 1a Activity Costs Period 1a Additional Costs la2.1 Spent Fuel Pool Isolation la.2 Sutotarl Period 1a Additional Costs Perod 1a Colaterl Costs 1a.3.1 Spent Fuel Capital and Transfer 1a.3 Suototal Period 1a Collateral Costs Period 1a Period-Dependent Costs 1a.4.1 Insurance 10.4.2 Property taes la.4.3 Healtr physics supplies 60 9

69 69.

tra 556 93 214 46 46 60 348 144 232 190 229 194 23 3.30 302 23 145 74 19 19 145 214 42 1,758 112 2.700 65 2,100 57 8,227 a

14 107 107 2

246 246 7

53 53 7

53 53 9

69 69 52 401 401 22 166 166 35 267 267 29 219 219 a

34 263 237 29 223 200 3

27 27 49 379 379 45 347 347 3

27 27 22 167 167 11 85 43 3

21 3

21 22 167 83 32 246 246 6

48 24 264 2,021 1.780 17 128 128 405 3,105 3,105 10 75 75 315 2,415 2,415 9

66 66 1,234 9,461 9,219 26 22 43 21 21 83 24 241 241 a56 1,969 428 428 556 3,210 1.327 2.140 1,753 2,106 1,783 214 3,039 2,782 214 1,335 685 171 171 1,335 1,969 385 16,190 1,027 599 31526 31.566 5.140 771 0,911 5,911 5,140 771 0,911 5,911 9,475 1.421 10,898 9,475 1,421 10,8986 10.89 363 775 77 852 852 1,745 174 1,919 1,919 91 454 454 TLG Servies, lne.

Prairie I0sland Nearteer Genear~ling Station Deeoeasd-i-ing Cost Analysis Docusenes XOI.1588d-OO Raev. 0 Appeadia' C, Page 12 or~l Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

IlActivity Off-Sit8 LLRW NRC Spent Fuea Star PrOCessed Buruta voitures B*urial i ullthin.

l Decon Removal Packaging Transport Processing Disposal Other Total Total Uc. Term.

Managernet ROestataon Volu-e Class A Class B Class C GTCC PressedP Craft ContractorI Cost Cost Costs Costs Costs Costs Costs Continsency Costs Costs Costs Costs Cu. Fast Cu. Fast Cu. Feet Cu. Feet Cu. Feet Wt, 1.6.

Manhours Manhours Period 1 a Peniod-Dependent Costs (continued) la.4.4 Heavy equipment rental la.4.5 Disposal of DAW generated la.4.6 Plant energy budget la.4.7 NRC Fees la.4.8 Emergency Planrnrg Fees la.4.9 Spent Fuel Pool O&M la.4 10 ISFSI Operating Costs la.4 11 Security Staff Cost la.4.12 LUUty Staff Cost la.4 Subtotal Period Ia Period.Oependent Costs la.0 TOTAL PERIOD la COST PERIOD lb - Oecommissioning Preparations Period lb Direct Deconnmissionong Actvities Detailed Work Procedures lb.1.1.1 Planlt systems lb.1.1.2 NSSS Decooitamirntion Rush lb 1.1.3 Reactor internals lb 1.1.4 Remianong buildings lb 1.1 5 CR0 cooing assembly lb.1.1.6 CRD hoimngs & ICI tubes lb.1.1.7 ncoe instrumentation lb.1.18 Reactor vessel lb 1.1.9 Facility closeout lb 11.10 Msosle shields lb,1.111 Biological slheld lb.1.112 Steam generatots lb.1113 Reilforced 0o0rete lb1114 Main Turbine lb.1.1.15 Main Conderriss lb.1.1.16 Aunxilary building lb.1.1.17 Reactor building lb,1.1 Total lb.1.2 Decon primary loop lb.1 Subtotal Period lb Activity Costs Period lb Additional Costs lb.21 Site Characteration 1b.22 Mixed Waste lb.2,3 Asbestas Abatement lb.2,4 RCRA Waste 1b.2 Subtotal Period lb Additional Costs Period lb Collateral Costs lb6.31 Decon equipment 16b.32 DOC staff relocation espenses lb.33 Process Liquid "ante lb.3.4 Smau tool allowance lb.3.5 Pipe cutting equipment lb.3.6 Decon ng lb.3.7 Spent Fuel Capital and Transfer 387 750 8

6 "38 2,557 471 275 373 44 8,099 19.030 8

6 38 33.368 58 445 445 11 64 64 383 2,940 2,940 47 518 518 27 302 56 429 7

50 1.215 9,314 9,314 2,855 21,885 21,885 5,002 39.172 38,391 302 429 50 78 2

11,677 241 565 11,299 11.299 21 157,471

- 346,229 21 503,700 750 8

6 38 56.209 8,428 65.440 53,522 11.299 21 535,266 220 46 116 63 46 46 46 169 56 21 56 214 46

• 72 72 127 127 1,545 33 253 228 7

53 53 17 134 134 9

72 18 7

53 53 7

53 53 7

53 53 25 194 194 8

64 32 3

24 24 8

64 64 32 246 246 7

53 27 11 63 11 63 19 146 131 19 146 131 232 1.776 1,442 190 570 570 25 54 32 27 83 83 15 15 334 2,026 428 1,070 578 428 428 428 1,554 514 193 514 1,969 428 668 668 1,168 1,168 14,228 1,067 1.067 14,228 380 380 1,545 422 2.346 2,012 334 1,598 1.598 21 1,000 S

1,407 11 53 989 1

103 as 2

4 19 13 159 1,008 88 1.407 912 40 225 2,023 5,a44 422 1.829 1,829 157 1.209 1.209 437 2,227 2.227 4

28 28 1,020 5,294 5.294 111 855 855 137 1,049 1,049 557 2,872 2,972 3

25 25 150 1,150 1,150 210 1,610 1,610 677 6.720 12,843 12.643 174 565 166,959 18.667 166,959 18,667 73,114 144 743 27 1,400 6.720 TLG Services, lna.

ftui~ sle Wod Nucelaar (Itnwrastlg Station Desrueiaadootg Cos" A.as.Ia Doncee-s XOI14586-002, RZe. 0 Appensdiv C, Page 13 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) 011-564 " LLRW NRC Spent Fuel Site Processed BMW Voluamts Bural Utility and Act6viy Damon Rormal Packaging Transport Processing Disposa Oth.

Total Total Lic. Tram.

Managerst Restoration

Vofeln, Class A Class B Clue. C GTCC Prosessed Craft ContractI Index Actlvity Desclption Cost Cost Costs Costa Costs Costs Costs Cotln Costa Costs Costs Costs Cu. Feet Cu. Feet Cu. Feel Cu. Feet Cu. Feet Wt, LIs.

Manhours Mahlours 1b.3 Subtotal Period lb Collateral Costs 2,170 1.021 40 225 2,023 6,756 2,045 14,280 7.560 6,720 174 565 73,114 144 Period Ilb PeW6-ependent Costs 1b.4.1 Decon supplies 15.4.2 Irsurance lb.4.3 Property tames 1b.4.4 Health physics supplies lb.4.5 Heavy equipment rental 1b.4.6 Disposal of DAW generated lb.4.7 Plait energy budget Ib.4.8 NRC Fees lb.4.9 Emergency Planning Fees lb.4.10 Spent Foot Pool O&M 1b.4.11 ISFSI Operating Costs 1b.4.12 Secuity Staff Cost 1b54.13 DOC StaffCost lb.4.14 Utifty Staff Cost 1b.4 Subtotal Period 1 b Pernod-ODpendert Costs 1b.0 TOTAL PERIOD lb COST PERIOD 1 TOTALS PERtOD 2o - Large Cosiponasi Reetoval Period 2a Direct Decorrnmjssiortng Activities Nuclear Steam Supply System Rernoval 2a.1,1 Reactor Coolant Piping 2a.1.1.2 Pressurizer Relief Tank 2a. 1.1.3 Reactor Coolant Pumps & Motors 2a.1.1.4 Pressurizer 2a.1 1.5 Steam Generators 2a.1.1.6 CRDMs IClsIService Structure Rerocal 2a.1.1.7 Reactor Vessel Internals 2a.1.1.8 Reactor Vessel 2a.1.1 Totals Reoanl of Major Equipment 2a.1.2 Main Turbine/Generator 2a.1.3 Main Conrdensers Cascading Costs fror Clean Building Derolition 2a.1.4.1 Reactor 2a,1.4.2 A 'xrlaoy 2a.1.4.3 Radwaste 2a.1.4 Totals Disposal of Plant Systte 2a.1.5.1 Admri Bldg Ventilatior 2a.1.5.2 Air Rerosal 2..1.5.3 Auxiiary Foe t r

2a.1.54 Aualiary Feedwate -RCA 2a.15.5 Bleed Stean 2a.1.56 CauOric Addition -RCA 2a.1.57 Chtrcal Feed 2a.1.5.8 Crerko Feed -RCA 23 268 195 23 463 5

3 5

3 391 880 223 2,578 237 139 188 22 4,0B3 3,536 9.593 22 21,645 2,573 3.083 56 388 1,008 2.134 31,353 2,573 3,833 66 393 1.008 2,172 87,562 6

29 29 39 430 430 88 968 968 67 335 335 29 224 224 7

37 37 387 2,964 2.964 24 261 261 14 152 28 216 3

25 612 4.695 4,695 530 4,066 4,065 1,439 11,032 11,032 3.273 25.435 25,G41 6,760 47,356 39.908 15,188 112.796 93,430 45 187 187

22.

97 97 303 1,539 1,539 309 1,963 1,963 2,037 12.036 12,036 115 531 531 8.756 31,065 31,065 5.216 14.793 14.793 16,845 62,212 62.212 176 1.120 1,120 590 3,099 3,099 129 992 992 54 411 411 2

15 15 15 1,417 1.417 152 216 25 394 7,114 334 18.791 576 327 327 13,344 565 13,909 565 6,541 6,541 246,614 19,889 315,462 257,913 19.910 850.728 12 79.383 47.314 174,537 12 301,234 41 34 18 15 41 46 36 58 181 2.513 126 55 98 1.777 58 3.450 599 7,949 4

7 55 3

5 34 20 84

.46 999 492 396 671 1.739 1.330 1.149 3.088 118 34 84 9,977 908 9.334 174 1,022 459 4.412 174 13,375 3,223 1,195 18,677 349 288 1-292 132 1,701 2,460 18,672 11,316 2,404 501 527 4,319 1.377 18.804 23,180 1.904 2,131 1,187 2,851 841 34,807 1,414 21,288 625 325,380 1,785 202,122 2.202 1,668,341 11,617 2,875 53,072 3.225 918 219,145 21.733 1.001 619,525 21.733 1.001 918 3,143,680 64.414 4.878 287.637 4.667 203,723 39.151 245 130 51 357 160 2,045 56 35 253 120 862 357 13 1,233 11.414 4,945 179 16.538 4

20 32 25 63 27 12 2

0 0

0 0

14 19 1

1 4

3 23 5

36 8

48 9

73 10 57 2

14 1

4 48 57 4

4 23 36 73 14 178 240 16 76 422 676 7,214 466 1,331 9.761 466 2m1 634 31 TL/ Sedicea, lie.

Prairie Islandi Nefear Genrooating Station D4aronuiaaiordng Cost Analysis Docasreoro XOI-ISS&.062, Bes. 0 ApPendixn C, Page 14 oral Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars) off-at.

LLRW NRC Spent Fuel Site Processed Burial Volumes BurialI Utility end Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Uc. Term.

Management Restoration Volme Class A Class B Class C GTCC Processed Craft Contractor loden Activity Description Cost Cost Costs Costs Costs Costs Cots ContCnen.C osts C Costs Costs Costs Cu. Feet Cu. Feet Cu. Foot Cu. Feet Cu. Feet Wt. Los.

Manhoure Mantomrs Disposal of Plant Systems (cotinued) 2a.1.5.9 Circulating Water 2a.1.5*10 Condt e

2a.1.5 11 Condensate Poiishing 2a.1.5.12 Condensate Polishing - RCA 2a.1.5.13 Eleeto-Hydraulic 2a.1.5.14 External Cirslating Water 2a.1.5.15 External Circulating Water - RCA 2a.1.5.16 Feedowter 2a.1.5 17 Feedwater - RCA 2a.1.5.18 Gland Seal 2a.1.5.19 Heater Drain 2a.1.5.20 Hypobromous Acid Feed 2a.1.5 21 Hypotoomoos Acid Feod - RCA 2a.1.5.22 Internal Ciro Water & CDSR 2a.1.5.23 Main GentExcter/Transformer 2a.1.5.24 Main Steam 2a.1.5.25 Main Steam - RCA 2a.1.5.25 Repairable Spare Snubbers 2a.1.5.27 Steam E2uesol 2a.1.5.28 Steam Exclusion - RCA 2a.1.5.29 Steam Generator Slowdowno 2,a.1.5.30 Steam Ge*n"Waon 2a.1.5.31 Turbine & Moisture Separatots 2a.1.5.32 Turbine Oil Puttcaton 2a.1.5.33 Water Treament 2a.1.5.34 Water Treatment -RCA 2a.1.5 Totals 2a.1.6 Scaffolding in support of decommissioning 2a.1 Subtotal Period 2a Activity Costs Period 2a Collateral Costs 2a.3.1 Process liquid waste 2a.3.2 Sinai tlol allowance 2a.3 3 Spent Fuel Capital and Transfer 2a.3 Subtotal Period 2a Collateral Costs Period 2a Period-Dependent Costs 2a.4.1 Decon supplies 2a.4.2 Insurance 2a.4.3 Property taxes 2a34.4 Health physics supples 2a.4.5 Heavy equipment rental 2a.4.6 Disposal of DAW generatod 34.4.7 Plant energy budget 2a.4.8 NRC Fees 2a,4.9 Emergency Planning Fees 2a.4.10 Spent Fuel Pool O&M 2e.4.11 JSFS1 Operating Costs 23.4.12 Security Staff Cost 2a.4.13 DOC Staff Cost 2a.4.14 Utility Staff Cost 23.4 Subtotal Period 2a Period-Dependent Costs 2a.0 TOTAL PERIOD 2a COST 19 373 146 26 7

S 19 50 90 170 23 270 4

1 0

`71 260 4

1 3

277 4

268 37 316 14 2,654 1

3 1

4

.5 25 0

o 6

31 0

0 0

0 11 20 0

1 25 86 39

-58 332 0

413 1

2 153 64 9

1.041 64 2,304 16 6

90 9

599 16,430 13,603 3,403 2,935 19,030 349 59 22 118 111 165 S

14,036 59 165 22 118 111 14.036 3

22 56 429 22 168 13 81 01 1

a 3

21 22 134 134 13 103 96 628 628 4

27 41 311 1

5 0

1 1

3 20 0

0 11 81 132 843 643 1

6 6

0 2

1 6

6 112 636 636 1

4 40 308 6

43 47 364 5

29 29 671 4,540 2,473 595 3,022 3,022 19,061 75,410 73.343 77 386 386 25 190 171 2,105 16.141 2,207 16,718 558 14 71 71 51 564 564 219 2,414 2,172 307 1,536 1,536 351 2,689 2,689 72 409 409 458 3,512 3,512 57 623 623 13 138 70 539 8

63 1,293 9,910 9,910 2,306 17,679 17,679 3.266 25,038 25,038 8.485 65,184 64,203 29.754 157,312 138,103 22 429 168 4483 21 721 103

- 4,147 27 311 2

20 0

81 5,166 12 2

24 1,906 457 4

308 43 364 115 2.067 13,010 457 1,012 63 2,067 37,809 25,727 1,904 400 19 19 400 401 7,537 2,987 19.616 486 143 385 29.264 927 1,840 168.414 3,319 504 5,638 6

100 11 366 5

1,482 209.799 5,061 490 75 32 966 47 117,369 5,408 S-75 5,472 757 6,676 4,652 250 568,299 53,692 51,199 25,908 918 4.254,538 204,371 4,878 23.991 78 23,991 78 72,430 132 165,896 199.337 371,134 72,430 132 736,367 918 4,350,959 204,580 741,245 57 1,.229 2,338 57 3.567 54 36 54 36 513 2.194 246 3,054 567 126 469 55 8,617 15,373 21,772 246 52.739 16,141 16,141 138 539 63 740 241 241 3,621 3.621 715 20,162 13,678 3,556 2,935 19,388 67.123 16,881 2,327 37,809 29,749 1,904 TLG Services, lac.

Prairie Istand Nwleloo Generating Sta.tion lleconnsasisoiaing Cost Analysis Documaent XOI.1586-00, Ram' 0 Appendio C, Page 15 of 21 Table'C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

I I Activity Otm-Sit LLRW NR; S:pent Fuel sit Processed mal Volume; mmlot Imp Utiit an Decon Removal Packaging Trans port Processing Disposal Other Total Total Lic. Term.

Managenenst Restowratll Volrm Clars A Class B Class C GTCC Processed Craft Contra Cat C,.st Cats C.,..

C,...

costs Cart.

Cano,,o-Cal.m Cal.t Cotl.

C.,.

Cu Fee C., Feel Cu Feel CU. F..t Cu Foo WI Ib Os rfi,, Man~hooos

'ry -

P-Cast Cast costs costs Costs Costs costs Cost.

Cu Feet Cu Feet Cu Feel Cu Feel Cu Feet WL Lbs.

Manhours PERIOD 2b-Site Decontminaton Period 2b Diect Decommissionng Acivates Disposal of Pant Systems 2b,1.1.1 ADT & Mist Ventilation 2b.1.1.2 Aux Bldg Normal Ventilation 2b.1.1.3 Aux Bldg Special Ventlation 2b.1.1.4 Battely RFl Special Ventilation 2b.1.1.5 Boron Recyde 2b 1.1.6 Chemical & Volume Control 2b 1.1.7 Cold Chemical Lab Vrrtiaon 2b 1.1.8 Component Cooling - RCA 2b 1.1.9 Containment Cooling 21.1.1.10 Containment Cooaing - RCA 2b.1.1.11 Conta fnent Hydrogen Control - RCA 2b,1.1.12 Conti;mre Spray - RCA 2b.1.1.13 Containmend Vesilation 2bI..114 Cor~trl/Relay/Cnqr Rem Vert 2b.1.I.15 Cooling Water 29.1.1.18 Cooling Water - RCA 2b..1.1.17 CranesHolatslevatoas - RCA 2b.1.1.18 D3 Emergency Diesel 2b.1.1.19 D4 Ernergency Diesel 2b1.1.20 D5 Emergency Diesel 2b.1.1.21 Electrical -Clean 2b.1.1.22 Electrical - Contaminated 2b.1.1.23 Electrical

- Decontaminated 2b.1.1.24 Filter Rm Ventilaton 2b.1.1.25 Fire Protection & Detection 2b.1.1.26 Fire Protection & Detection -RCA 2b.1.1.27 Fuel Handling 2b.1.1.28 Fuel Oil 2b9.1.1.29 HVAC - Clean 2b91.1 30 HVAC - Contamnated 2b 1.1.31 Healing 29..132 Heating - RCA 2b9.11.33 Hot Lab & Sample Rm Ventilaton 2b. 1 1.34 Incore Instumentagto 2b 1.1.35 Misc Drains & Vents 2b.1.1.36 Misc Lab & Serios Areas Vent 2b.1.1.37 Miscelianeoxs Gas 29.1.1.38 MisceLaneoxs Gas - RCA 2b 1,.39 Radiation Monftonng 2b.1,1.40 Radiaior" Morarorig - RCA 29.1.1.41 Reactor Coolant 2b.1.1.42 Reactor Hot Sampng 2b.1.1.43 Reactor Makeup 2b91.1.44 Reactor Makeup-RCA 2b9..1.45 Reactor Vessel 2b.1.1.46 Residual Heat Removal 2b91,.47 Safeguards Chilled Water 2b.1.1.48 Safety injection 2b.1.1.49 Sampling 2b.1.1.50 Seravce Bldg & New Cmpt" Vent 2b1 1 51 Shield Bldg Ventilation 2b.1.1 52 Station & Instrument Air 0

553 0

120 103 7

227 18 51 10 1

3 622 0

442 24 2D4 25 127 169 23 112 329 2

77 0

1,222 332 2,0033 142 164 54 0

106 905 224 224 14 22 157 90 49 88 5

44 152 87 29 3

10 260 3

605 36 0

85 112 0

1 1

5 0

0 0

0 35 41 14 71 3

16 0

1 2

9 13 38 1

2 10 50 0

1 3

13 22 111 0

0 2

11 1

16 69 2

11 0

1 1

1 7

8 5

5 1

4 0

2 11 11 6

5 0

0 o

0 46 61 24 55 2

1 7

19 12 1

55 4

6 1

0 1

.189 199 960 219 11 116 378 73 21 2

675 a

100 a

1,500 2

0 146 16 5

860 41 153 9

0 5

6 37 43 30 24 48 25 18 73 4

31 2

2 1

228 327 534 117 3

9 162 45 7

40 40 23 139 139 4

20 20 0

I 1

5 5

520 2.158 2,158 0

0 266 1.753 1,753 4

27 87 529 529 8

46 46 51 305 305 124 794 794 10 58 58 17 129 192 1.256 1,256 2

13 13 1

8 1

8 0

0 183 1,405, 111 620 626 745 4,382 4,382 1

7 7

21 163 65 388 388 18 96 96 0

1 16 122 377 2.268 2.268 34 257 81 471 471 5

29 29 8

43 43 57 309 309 34 189 189 7

57 30 170 170 1

6 15 87 87 122 507 507 83 319 319 4

33 1

6 6

7 27 27 308 1,457 1,457 1

4 271 1,606 1,606 12 64 64 0

0 61 383 383 17 129 153 7

692 27 70 4

3 6

2,356 1,485 0

11.996 27 2,743 141 1,453 4.721 509 260 14 129 S

.8442 103.

0 1.405 1,997 53 18,753 24 1

163 S

1,828 200 35 1

122 10,745 286 257 1.907 107 3

60 41 458 302 370 172 57 S

600 6

316 229 516 54 220 33 3

28 22 10 2.853 2,290 4

S 6.676 857 37 66 0

2,028 342 129 6,793 363 30,558 1,012 3,225 197 S -

20 680 50 220,756 22,365 8

487,169 8,420 477 111.390 3,872 5.742 487 59,019 Z507 237,445 3,366 11,856 454 Z344 342.822 6,243 4,184 48 140 140 5

24,276 85,872 6,502 761,569 38,423 1.017 69 3,009 74,245 3,057 11,259 1,101 9

2,373 462,026 16,575 4,804 77,458 4,028 4.621 285 6.097 457 45.599 3,050 30,430 1.709 1,073 24.378 1,593 111 12,826 782 55,497 5,247 21,920 3,680 583 1,148 47 1,781 337 321,222 6,693 75 344,588 11,818 7,398 712 S -

0-113,039 1,717 2,424 210 se-kie'%, La..

Praiie Is lood Nuclear Generidiiog Station Doooosesions~oig Cost Aoolyoi.

Docooooot XOI-1586002OZ Rev. 0 Appendix C, Page 16 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off'S".

1RW NRC Spent Foel alto Processed Burial Volomnes Burial I Utily and Activity Decon Reaoval Packaging Transport Proossing Dlsposal Other Total Total UL. Term.

Management Restoation Volumne Class A Class B Class C GTCC Pocessed Craft Contoract Indes Actvity Description Cost Cost Costs Costs Costs Cost Cofl Cos C*ts Costs Costs Cu. Foot Cu. Feet Cu. Feet CU. Feet Cu. Feot WL. Lbso Maohors Motro D0sposal of Plant Systems (continued) 2b.1.1.53 Station I Instrumert Air -RCA 2b.1.1.54 Turbine Bldg Taps It Dr s 2b.1.1.55 Turbine Bldg Traps & Drains - RCA 2b.1.1.56 Turbine Bldg Ventaton 2b.1.1.57 Unit Cooles 2b.1.1.58 UntCoo-le0RCA 2b.1.1.59 Waste oas Dposal 2b.1.1.60 Wste sLquid Disposal 2b.1.1.61 Waste Solid Disposal 2b.1.1 Total 2b.1.2 Scaffolding in support of decommissioning Decontamiation of Site Buldtngs 2b.1.3.1 Reactor 2b.1.3.2 Auxiliary 20.1 3.3 Bodrash Woase ReceivLng Tank 2b 1.34 Drum Transfer & Truck Loading Enclosure 2b.1.3.5 LLRW Storage Enclosure 2b.1.3*6 Radwoste 2b.1.3.7 Resin Disposal 2b.1.3 Total 2b. 1 Subtotal Period 2b Acivity Costs Period 2b Collateral Costs 2b.3.1 Process liquid vste 20.3.2 Small tool allowance 20.3.3 Spent Fuel Capital and Transfer 2b.3 Subtotal Period 2b Collateral Costs Period 2b PeriodDependent Costs 21,.4.1 Decon supplies 2b.4.2 Insurance 2b.4.3 Property taxes 2b.4.4 Health physics supplies 2b04.5 Heavy equipment rental 2b.4.6 Disposal of DAW generated 2b.4.7 Plant energy budget 2b.4.8 NRC Fees 20.4.9 Emergency Planrnig Fees 2b.4. 10 Spent Fuel Pool O&M 2b04.11 Liquid Rod te Processulg Equipment/Services 20.4.12 ISFS1 Operating Costs 20.4.13 Security Staff Cost 20.4.14 DOC Staff Coast 2b.4.15 USlty Staff Cost 2b.4 Subtotal Period 2b Perod-Dnpencent Costs 2b.0 TOTAL PERIOD 2b COST 203 21 20 28 16 36 414 340 1.061 1.167 84 100 2,569 11,339 2

10 0

1 0

1 25 33 65 70 6

8 335 749 130 14 19 196 292 31 7,277 137 361 40 1,552 2,880 20 10 112 11 72 416 416 3

24 7

43 43 4

32 2

1i 12 69 69 363 1.509 1.509 973 3,990 3.990 84 353 353 5.534 29.356 26.930 743 3,777 3,777 830 3,444 3,444 613 2,228 2,228 14 78 78 10 37 37 63 237 237 29 108 108 10 44 44 1'569 6,176 6.176 7,846 39,309 36.883 24 32 18 2,426 1,625 180 232 2,453 1,086 3,655 2,677 389 288 90,963 11,297 1.265 79 65.986 3,626 462 7,321 342 547 332 9,413 665 185,530 14,293 375.774 42,536 40.666 3,429 4,670,322 265,371 63,999 32,385 657.547 30,856 332,476 23,88W 43.896 311 7.118 370 44.969 2,436 21.136 1,087 9.271 384 1.116,412 59.330 5.850.732 357.087 888 772 929 326 23 13 7

89 42 39 19 12 9

1.970 1.198 90 140 45 73 7

10 1

2 7

10 3

5 1

2 154 242 178 85 1

7 278 546 156 23 3

23 10 3

766 2.230 5,953 1.060 2.911 439 19 64 38 435 42 196 83 60 3.471 10.058 2,426 95.7D0 21.434 4.539 15,417 510 1.801 7,667 2,329 213 137 768 276 213 276 137 768 973 479 2,570 2,570 41 318 318 11,876 1,781 13,657 973 11.876 2,302 16.545 2,888 2.552 13,657 13,657 2.552 209,631 498 209,631 498 777 2.054 3.667 777 5.720 81 53 81 53 810 1.702 369 3,809 895 198 740 373 86 13,611 23.389 33.023 369 78,636 194 971 971 81 891 891 170 1,873 1,873 513 2,567 2.567 550 4,217 4.217 108 612 612 571 4.380 4.380 90 985 985 20 218 111 851 56 428 428 13 99 2,042 15,653 15,653 3,508 26,897 26,897 4,953 37,976 37,976 12,981 98,618 97,449 218 851 99 1.169 5,422 5,422 108,444 198 26Z036 302429 561,357 108,444 198 1,125,821 6,168,807 357,782 1,125,821 5,529 21,414 728 1,822 7,667 3,670 90,512 23,129 154,472 137,220 14,827 2,426 95,700 29,408 TLO roie-., Ine.

Prairie Isln Nuclear Generating Stration Deoueeadario..ing Cost Analysis D-oe.-.$ XO1-15863-002, Bet. 0 Appendixs C, Page 17 ot~l Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

I Ac~t Off-Sits LLRW NRC Spent Fuel

" Site Prosassed Burial Vofums Burld I Utility and Decon Retoreval Packaging Transport Processing Disposal Other Total Total Uc. Terom M.Iagernt Restoatreon Volume Class A Class B Class C GTCC Processed Craft Contractor l Cost Cost Costs Costs Costs Costs Costs Continaencv Costs Casost s sts Costs Cu. Feet Cu: Feet Cu. Feet Cu. Feet Cu. Feet Wt. Lbs.

Manhours Manhours I PERIOD Z. - Delay Before End Of Wet Fuee Storage Period 2c Direct Dewornursioning Aobmfes Petiod 2c Collateral Costs 2c.3.1 Spent Fuel Capital and Transfer 2c.3 Subtotal Period 2c Collateral Costs Period 2c Period-Depndent Costs 2c.4.1 insurance 2c.4.2 Property taxes 2C.4.3 Health physios supplies 2c.4.4 Disposal of DAW generated 2c04.5 Plant energy budget 2c.4.6 NRC Fees 2c,4.7 Entergency Planning Fees 2C.48 Spent Fuel Pool O&M 2c.4.9 ISFSJ Operating Costs 2C.4.10 Seuity Staff Cost 2c.4.11 LJtity Staff Cost 2C4 Subtotal Period 2c Pernol-Oependent Costs 2c.0 TOTAL PERIOD 2c COST S

51,490 7,723 59,213 51.490 7,723 59,213 654 854 854 19 13 19 13 19 13 4,171 417 4,589 4,589 8,796 880 9,675 9,675 213 1.067 1,067 88 26 146 146 5,248 787 6,035 6,035 1,751 175 1,926 1,926 1,026 103 1.128 3,925 574 4,399 447 67 514 32,601 4,890 37.491 37,491 33,534 5,030 38,564 38,564 88 91,398 13.162 105,533 99.493 88 142.888 20,885 164,747 99,493 59,213 59,213 1,295 25,900 47 1,128 4,309 514 626,117 620,766 6,041 1.295 25,900 47 1.246.883 65,254 1,295 25,900 47 1,246,883 PERIOD 2d - Decontainnation Folowing Wet Fuel Storage Period 2d Direct Deconrrissaninog Activies 2d.1.1 Remove spent fuel racks Disposal of Plant System 2d 1.2.1 Electrical - Contaninated - Fuel Pool 2d 1.22 Elecbical - Deortan*iratod - Fuel Pool 24:1.2.3 Fire Protection & Detection - RCA Fuel Pool 2d 1.2.4 HVAC - Cofarinsatod - Fuel Pool 2d.1.25 Safeguards Chilled Water -RCA 2d.126 Spent Fuel Pool Cooling 2d.1.27 Spent Fuel Pool Normal Ventislstn 24.1.2 Totals Decontaminamon of S0 e Buildings 2d.1.3.1 Fuel Handling ofAur Building 2d.13 Totals 2d5.14 Scaffolding in support of deosrmmassioning 2d.1 Subtotal Period 24 Ac"ooly Costs Period 2d Collateral Costs 2d.3.1 Process Ipkid waste 24.3.2 Smars tool etlowa.',ro 2d.3.3 Deconnisssorarg Equopment Disposion 24.3.4 Spent Fuel Capital and Transfer 213 Subtotal Period 2d Collateral Costs 249 26 65 28 211 142 860 25 407 3

23 25 20 23 1,481 777 846 77-7 846 576 1,049 2,929 62 57 62 57 1

6 10 48 0

2 7

31 0

0 2

2 0

2 21 90 16 31 16 31 4

2 106 151 24 130 96 55 120 185 69 646 23 386 2

3 21 1.150 193 193 22 1,366 532 532 3

13 11 1

33 194 773 773 48 269 269 320 1,8w3 1,883 10 60 60 170 1,019 1,019 1

6 6

21 87 87 9

53 53 578 3,377 3.377 647 2,559 2,559 647 2,559 2.559 149 755 755 1,569 7,464 7,464 84 426 426 9

65 65 111 848 848 34 261 238 1,600 1,339 1.477 864 23 8,069 286 4,828 128 26 39 75 265 8

14,376 235 132519 576 37,160 2,783.

327,668 16,495 11,622 464 207,577 7,447 1,045 51 8,311 878 11,500 394 604,883 28,512 48 48 2

295 2,417 806 2,417 806 253 16 17,046 2,533 177.542 30,420 177,542 30,420 126800 6,477 927.744 65,985 125 53 227 179 227 440 27,040 86 6,000 373 303,507 88 261 261 6,000 813 330,547 174 TLG Seroi"e4, Ino.

Prairie Island Nuclear Generating Station Desoommissnnsing Cosl Analysis Docnument X01-158&-002, Rev. 0 Appendix AZ Page 1 ofs21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Off-tsts LLRW NRC Spent Fuel Site Processed Burial Volumes Burial I Utility and Activity Decon Removal Packaging Transport Processing Disposal Other Total Total Uc. Term.

Management Restoration Volume Class A Class B Clans C GTCC Processed Craft Contractor Index Activity Description Cast Cost Costs Costs Costs Costs Costs Conteninnca Costs Costs Costs Costs Cu. Feet Cu. Feet Cu. Feet Cu. Feet Cu. Feet WtL Lbs.

Manhours Manhours Period 2d Penod-Oependent Costs 2d.4.1 Decon supplies 139 35 173 173 2d.4.2 Insurance 285 28 313 313 2d.4.3 Property taxes 599 60 659 659 2d.4.4 Health physics supples 482 120 602 602 21.4.5 Heavy equipment rental 1,290 193 1,483 1,483 2d.4.6 Oispe1 of DAW generated 30 19 135 40 223 223 2d.4.7 Plant energy budget 714 107 822 822 2d,48 NRC Fees 315 31 346 346 2d.4.9 Emergency Planning Fees 70 7

77 2d.4. 10 Liquid Radwasta Processlng Equipment/Services 262 39 301 301 2d.4.11 ISFSI Operating Costs 30 5

35 2d.4.12 Security Staff Coot 2,655 398 3,053 3,053 2d.4.13 DOC Staff Coot 5.684 853 6,536 6,536 21.4 14 ULilty Staff Cost 8.439 1,266 9,706 9,705 2d.4 Subtotal Period 2d Period-Dependent Costs 139 1,772 30 19 135 19,053 3,183 24.329 24.218 21.0 TOTAL PERIOD 2d COST 1,250 4,757 255 356 1.898 608 19,280 4,989 33,393 33,020 PERIOD 2S - Licerme Termination Period 2e Direct Deoommissioning Activies 2e. 11 ORISE confirmatory survey 148 44 193 193 2e 1.2 Tenninate license a

2e. 1 Subtotal Period 2e Activiy Costs 148 44 193 193 Period 2e Additional Costs 2e 2.1 License Ternnnaton Survey 5,916 1,775 7.691 7.691 2e.2 Subtotal Period 2e Additional Costs 5,916 1,775 7,691 7.691 Period 2e Collateral Costs 2e.3 1 DOC staff relocaton expenses 912 137 1,049 1.049 2e.32 Spent Fuel Capital and Transfer 184 28 211 2e.3 Subtotal Period 2e Collateral Costs 1,096 164 1,261 1,049 Period 2e Period-Dependernt Costs 2e4 1 Insurance 274 27 301 301 2e.42 Properlty taxes 641 64 705 705 2e.4.3 Health physics supplies 636 159 795 795 2e.4.4 Disposal of DAW generated 5

3 24 7

40 40 2e.4.5 Plant energy budget 382 57 440 440 2e.4.6 NRC Fees 352 35 388 388 2e.4.7 Emergency Planning Fees 75 7

82 2e.4.8 ISFSI Operating Costs 33 5

37 2e.4.9 Security Staff Cost

-2786 418 3,203 3.203 2e.4.10 DOC Staff Cost 4,604 691 5,294 5,294 2e.4.11 irty Staff Cost 5,236 785 6,022 6,022 2e.4 Subtotal Period 2e Period-Dependrent Costs 636 5

3 24 14.382 2,256 17,307 17,188 2e.0 TOTAL PERIOD 2e COST 636 5

3 24 21.543 4,240 26.452 26,121 1.980 39,595 72 77 35 48,450 72,857 139,157 112 1.980 39.595 72 260,464 373 23.046 5.326 1,297,688 66,231 280,464 111.889 111.889 211 211 352 7,046 13 82 37 50,700 56,940 80,340 120 352 7,046 13 187,980 331 352 7,046 111,902 187,980 97.666 4.753 156.555 66.130 1.904 918 11.850,600 740,542 3.562.393 7.494 47.823 14,687 5.750 12,500 23.778 341,346

.82.997 536.375 433,957 PERIOD 2 TOTALS TLG Services, aIn.

Prairie Isanad Nuclear Generating Station Diecoesesasioning Cand Analyijsl Doeoosea XOI-1.586-OM, Be'. 0 Appendix 4i Page 19 ofj21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

Ont-Smte LLRW NRC Spent Fuel Site Procas Bural Volumes Burial I Utility and Activity Deon Removal Packaging Transpost Processing Disposal OUter Total Total Uc. Tem Management Restaration Volume Class A Class B Class C GTCC Processed Craft Contractor lnds Actlvit Desciption Cost Cost Costs Costs Costs Costs Costs Coatis Costs Costs Costs Costs Cu. Feet Cu. Fast Cu. Feet Cu. Feet Cs. Feet Wt.,Lbs Manhours Manhours PERIOD 3b - Site Restoration Period 3b Diect Decortmissuning Actmvres Demolition of Remaining Site Buildings 3b.1.1 1 Reactor 31b.1 12 AuWilary 3b 1 1.3 Condensate Storage Tank Foundation 31b 1.1.4 Construcion Warehouse & Fab Shop 31b1.1.5 D3lD4 Emergency Generator 3b.1.1.6 Drum Transfer & Truck Loading Endosure 3b.1.1.7 Hydrogen House 3b.1.1.8 LLRW Storage Enclosure 3b.1.1.9 Radaste 3b.11.10 Resi Disposal 3b.1.1.11 Soturic Acd Tank Enclo*ure 3b.1.1,12 Turbine 3b11.1.13 Turbine Pedestal 3b1,114 4Warehouse 02 3b, I1.15 Waste Neutralizing Tank House 3b.1.1.16 Waste O Storage 3b.1.1.17 Water Treat ment 3b,1.1.18 Fuel Handling of Am Building 3b.1.1 Totals Saie Closeout Actvites 3b.1.2 Remove Rubble 3b,1.3 Grade & landscape site 3b.1.4 Final report to NRC 3b.1 Subtotal Period 3b Ac-tiity Costs Period 3b Additina Costs 31,21 Concrete Crusnhin 3b.2 Subtotal Perod 3b Additional Costs Period 3b Colateral Costs 3b.3.1 Small ed aloweance 3b,.32 Spent Fuel Capital and Transfer 31b.3 Subtotal Period 35 Collateral Costs Period 3b Period-Dependent Costs 31b4.1 Insurance 3b.4.2 Property tbas 31b,4,3 Heavy equipment rental 3b.4.4 Plant energy budget 3b.4.5

. NRC ISFSI Fees 3b.4,6 Emergergcy Planrmg Fees 3b54,7 ISFS0 Operating Casts 3b.4.8 Secuity Stan Cost 3b.4.9 DOC Staff Cost 34.10 uSity Staff Cost 3b.4 Subtotal Period 3b Period-Depencent Costs 3b.0 TOTAL PERIOD 3b COST 4,992 3.223 13 141 24 20 10 188 253 24 3

2,266 6815 28 11 14 433 1,633 13.959 1,599 126 15.684 509 509 171 171 5736 5,726 22,090 749 5,740 483 3,706 2

14 21 162 4

27 3

24 2

12 28 216.

38 291 4

28

• 0 4

340 2.606 103 768 4

32 2

12 2

16 65 498 245 1,877 2.094 16,052 240 1,838 19 145 11 83 83 2.363 18.119 83 5,740 3.706 14 162 27 24 12 216 291 28 4

2,606 788 32 12 16 498 1,877 16,052 1,838 145 18,036 591 591 197 456 456 197 66,359 44.627 193 2,477 371 361

.153 2,776 3.555 383 54 34.352 7.580 457 165 225 6.498 21.027 191,613 10,653 316 668 202,582 668 2.731 Z731 72 72 5

76 591 5

76 591 397 397 847 153 592 294 231 101 4,458 13,590 8,664 28,930 26 197 so 456 85 653 85 932 15 168 859 6,585 89 681 0

29 323 23 254 15 116 669 5.127 0

2.039 15,629 1,300 9.963 0

5,122 39.779 0

932 168 2D4 323 254 116 4,204 5,779 11.981 476 923 15,629 27.798 81.506 164,171 131,579 377.256 205,313 377.924 29.405 7.647 59,142 83 12.437 46,621 T=03 Sen*re zoo.

Prairie ladnd Nues, Generating Sation Deemnan.niaoaning Coat A*ael-i.

Doiennae XO-1l5S0-0, Rev. 0 Appendi-C, Page 20 of21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

E IActivity ott-,ite LLRW NRC Spent Fuel SR.

P-rocessed Burial Volumes uorial I Utiliy and Decon Reroat Pakagilng Transport Processing Disposa Other Total Total Uic. Term.

Management RestoratIon Volume Class A Class B Class C GTCC Processed Crat5 ContractorI Cast rCsta costs Costs t

cos Ct fre cots costs e

cots cos.

Cu, Fast Cu Feet Cu Feel Cu Feet Co Feet Wt Lb.

Manhours Manhours I O I*v A*vJ*

• ln*

Activity M

Penn, PERIOD 3c - Fuea Storage OperafioesiShIpplng Period 3c Direct Deonnmissioning Actvites Period 3c Collateral Costs 3cX3.1 Spent Fuel Capital and Transfer 3c.3 Subtotal Period 3c Collateral Costs Period 3c Period-Dependern Costs 3c.4.1 Insurance 3c.4.2 Property taxes 3c.4.3 Plant energy budget 3c.4.4 NRC ISFSI Fees 3c.4.5 Emergency Planning Fees 3cW4S ISFS Operating Costs 3C.4.7 Security Staff Coast 3C.4,8 Utity Staff Cost 3&4 Subtotal Period 3c Period-Dependent Costs 3c.0 TOTAL PERIOD 3c COST PERIOD 3d -GTCC shipping Period 3d Direct Deosmmissioning AcvitSes Nuclear Steam Supply System Renroval 3d.1.1.1 Vessel & Internals GTCC Disposal 3d.1.1 Totals 3d.1 Sulbotal Period 3d Adctity Costs Period 3d Period Dependent Costs 3M.4.1 Insurnce 3d.4.2 Property taxes 3d.4.3 PMant energy biudget 3M.4.4 NRC ISFSI Fees 3d.4.5 Emergency Planning Fees 3d.4.6 ISFS Operating Costs 3d.4.7 Security Staff Cost 3d.4.8 Utility Staff Cost 3d.4 Subtotal Period 3d Period-Dependent Costs 3d.0 TOTAL PERIOD 3d COST PERIOD 3e - ISFSJ Decontandrulon Period 3e Direct Deosmrnssioning Actvites Period 3e Additional Costs 3e.2 1 ISFSI ULoense Terrinration (TN-40) 3e.2 Subtotal Period 3a Additional Costs Pesod 3e Period-Dependent Costs 3e.4,1 Insurance 3e.4.2 Property taxes 3e.4.3 Heavy eqwipmret rental 3e.4.4 Plant energy budget 3e.4.5 NRC ISFSI Fees 2,263 339 2,602 2,263 339 2,602 7,446 745 8.191 1,346 135 1,480 1,560 234 1,794 2,582 258 2.840 2,033 203 2,236 885 133 1.018 32,189 4,828 37,017 9,026 1,355 10,392 57,077 7,891 64.968 59,339 8,231 67,570 2,602 2,602 8,191 1,480 1,794 2,840 2,236 1,018 37,017 10,392 64,968 67.570 572,786 143,409 716,194 716,194 209 8,951 250 8,951 255 8,951 1.363 10,514 10,514 1,363 10,514 10,514 1,363 10,514 10.514 512 105,595 512 105,595 512 105,595 200 31 3

34 6

1 6

7 1

7 11 1

12 8

1 9

4 1

4 134 20 155 38 6

43 238 33 271 8,951 238 1,396 10,785 10,514 34 6

7 12 9

4 155 43 271 271 512 105,595 2,391 599 2,990 2,990 5

317 177 3,271 827 1,001 5,598 5

317 177 3,271 827 1,001 5,598 5,598 31,862 5,598 31,862 6,426,376 2,909 1.120 6,426,376 2,909 1,120 244 121 22 85 33 12 133 2

24 37 281 13 97 3

36 133 24 281 97 36 TLG Services, Ine.

Prairie Island Nodoor Generating Station Deceommissioning Codg Analeisi.

Daesmente X01-1586-002, Be.. 0 Appendiov Cý Page 21 of 21 Table C-2 Prairie Island Nuclear Generating Plant, Unit 2 DECON Decommissioning Cost Estimate (Thousands of 2008 Dollars)

I IActity Docon Removal Packaging Transport Processing Disposal Other Total Total UC. Term.

Management Restoratlon Volume Class A Clahn B Class C GTCC Processed Craft Contractor Ct CP1t C-.b C-*t Ct.

t,...

Coot.

C b,

C-oto ot.

Coot.

Cu Foot C,, Foo Cu Fot Cu-Fot Cu Fot Wet.b.

Maohor.

MnhS I

Period 3e Period-Dependent Costs (continued) 3e.4.6 Security Staff Cost 30.4.7 Utilty Staff Cost 3e.4 Suteotal Period 3e Period-Dependent Costs 3c0(

TOTAL PERIOD 3e COST PERIOD 3I.N ISFS Site Restoretln Period 3f Direct Decommissiosing Activities Period 3f Addtion'al Costs 31.211 ISFSI Demolition S Site Restoration (TN-40) 31.2 Subtotat Period 3/Addtiafnal Costs Period 3f Colsateal Costs 31.3.1 Smat tool allovance 31.3 Subtotal Period 3f Ctlateral Costs Period 3f Period-Dependent Costs 3f.4.1 Insurance 31.4.2 Property taxes 3t.4.3 Heavy equipment rental 31.4.4 Plant energy budget 374.5 Security Staff Cost 31.4.6 Utility Staff Cost 3t.4 Subtotal Period 3f Perod-Dependent Costs 3t.0 TOTAL PERIOD 3f COST PERIOD 3 TOTALS TOTAL COST TO DECOMMISSION 244 249 317 177 372 372 1

146 22 167 119 18 137 525 107 876 3.271 1,353 1,108 6,474 167 137 876 6,474 31.862 2,510 1,901 4,411 6,426.376 2,009 5,531 1,591 80 1,591 s0 23 23 59 454 59 454 0

1 0

1 454 454 454 454 11 1

12 12 81 12 94 94

-43 6

49 49 73 11 94 84 1,265 49 7

57 57 784 81 177 38 296 296 2,050 455 199 98 752 752 1.591 2,130 22.794 517 177 12,222 90,535 16.479 144,723 10,597 87.505 46,621 31,862 512 6.531,971 209,813 1,104.769 10,067 74.450 15.270 6,320 13,.08 38,172 519,443 116.,64 793,B94 537,983 203.961 51.950 156,555 111,901 2.469 819 512 18.640,480 970,260 5,517,691 TOTAL COST TO DECOMMISSION WITH 17.23% CONTINGENCY:

6793*94 thousands of 2008 dollars TOTAL NRC LICENSE TERMINATION COST IS 67.TT% OR:

$037,983 theosands of 2008 dollars SPENT FUEL MANAGEMENT COST IS 25.69% OR:

9203.961 ttlousands of 2008 dollar NON-NUCLEAR DEMOLITION COST IS 6.54% OR:

$51.950 thousands of 2068 dollars TOTAL LOW-LEVEL RADIOACTIVE WASTE VOLUME BURIED (EXCLUDING GTCC):

115= cubic fast OTAL GREATER THAN CLASS C RADWASTE VOLUME GENERATED 512 cubic faet OTAL SCRAP METAL REMOVED:

34,995 tons IOTAL CRAFT LABOR REQUIREMENTS:

970.35 man-hours End Notes:

n/a - indicates that Itis activity not charged as decomminssioning expense.

a - indicates Stat tims actrity performed by deosniansiosing staff.

0- indicates tat Otis value is less than 0.5 but is mn-ozes.

a cellocntaining -

intdicates a zero value ThG ts-&cea, rboo.