PACIFIC GAS & ELECTRIC COMPANYPACIFIC GAS & ELECTRIC COMPANY prepared by TLG Services, Inc....

Document P01-1604-002, Rev. 0

DECOMMISSIONING COST STUDY

for the

HUMBOLDT BAY POWER PLANT UNIT 3

2010 SAFSTOR

prepared for

PACIFIC GAS & ELECTRIC COMPANY

prepared by

TLG Services, Inc.Bridgewater, Connecticut

March 2009

Humboidt Bay Power Plaht U•it 3Decommissioning Cost Study 2010 SAFSTOR

APPROVALS

DocUment P01-1604-002, Rev. 0Page ii of xiii

Project EngineerWilliam J,

Project.Manager

Technical Manager

Quality Assurance Manager

Date- "

a

0.'v "iat e

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TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY ............................................................................. vii

1. INTRODUCTION ...................................................................................... 1-11.1 O bjective of Study ................................................................................. 1-11.2 Site D escription ..................................................................................... 1-11.3 R egulatory G uidance ............................................................................. 1-2

1.3.1 Nuclear Waste Policy Act ........................................................... 1-41.3.2 Low-Level Radioactive Waste Policy Amendments Act ............ 1-51.3.3 Radiological Criteria for License Termination .......................... 1-6

2. SAFSTOR DECOMMISSIONING ACTIVITIES ....................................... 2-12.1 Period 2 - Safe Storage and Decommissioning Preparations ............. 2-22.2 Period 3 - Preparations ....................................................................... 2-2

2.2.1 Engineering and Planning ......................................................... 2-32.2.2 Site Preparations ........................................................................ 2-3

2.3 Period 4 - Decommissioning Operations and License Termination ... 2-42.3.1 System R em oval ......................................................................... 2-42.3.2 Reactor Vessel Rem oval ............................................................. 2-52.3.3 Prepare Buildings for Demolition .............................................. 2-72.3.4 Building Demolition, Yard Work, Soil Remediation ................. 2-72.3.5 Final Site Survey - License Termination .................................. 2-8

2.4 Period 5 - Site Restoration ................................................................... 2-82.5 Post-Period 5 - ISFSI Operations and Demolition .............................. 2-9

3. COST ESTIMATE .......................................................................................... 3-13.1 B asis of E stim ate ................................................................................... 3-13.2 M ethodology ........................................................................................... 3-23.3 Financial Components of the Cost Model ............................................. 3-3

3.3.1 C ontingency ................................................................................ 3-43.3.2 Financial R isk ............................................................................. 3-6

3.4 Site Specific Considerations ............................... 3-73.4.1 Spent Fuel D isposition ............................................................... 3-73.4.2 Reactor Vessel and Internal Components ................................. 3-7

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TABLE OF CONTENTS(continued)

SECTION PAGE

3.4.3 Main Turbine and Condenser ................................................... 3-83.4.4 Plant System s ............................................................................. 3-93.4.5 Humboldt Bay Unit 3 Facilities ................................................. 3-93.4.6 Transportation M ethods ........................................................... 3-113.4.7 Coordination with. Units 1 and 2 ...................... 3-123.4.8 Site Conditions Following Decommissioning .......................... 3-13

3.5 A ssum ptions ........................................................................................ 3-133.5.1 E stim ating B asis ...................................................................... 3-133.5.2 L abor C osts ............................................................................... 3-143.5.3 G en eral .............. .......................................................................... 3-14

3.6 Cost Estim ate Sum m ary ..................................................................... 3-16

4. SCHEDULE ESTIMATE .............................................................................. 4-14.1 Schedule Estimate Assumptions ............................ 4-14.2 Project Schedule .................................................................................... 4-2

5. RADIOACTIVE WASTE .............................................................................. 5-1

6. R E SU L T S ....................................................................................................... 6-1

7. REFEREN CES .......................................................................... ................... ,7-1

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TABLE OF CONTENTS(continued)

SECTION PAGETABLES

Summary of Decommissioning Cost Contributors ..................... xiii3.1a Schedule of Expenditures .................................................................................... 3-173. lb Schedule of Expenditures, Excluding CPUC Disallowances ............................ 3-185.1 Decommissioning Waste Disposal Summary ...................................................... 5-36.1 Summary of Decommissioning Cost Contributors .............................................. 6-3

FIGURES

1.1 Layout of the Nuclear Plant Site and Surrounding Area ................................... 1-81.2 Schematic Diagram of the Vessel and Internals ................................................. 1-91.3 Sectional View Through the Caisson .................................................................. 1-104.1 D ecom m issioning Tim eline ................................................................................... 4-3

APPENDICES

A W ork Diffi culty Factor Adjustments ................................................................... A- 1B Unit Cost Factor Developm ent .......................................................................... B-1C Unit Cost Factor Listing (Representative) ..................................................... C-1D Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR

Decommissioning Cost Estimate ............................ I ..... D-1E Humboldt Bay Power Plant, Unit 3 2010 SAFSTOR

CPU C Cost Disallow ances ............................................................................... E-1F Humboldt Bay 2010 SAFSTOR Decommissioning Schedule ....................... F-1

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Document P01-1604-002, Rev. 0Page vi of xiii

REVISION LOG

Rev. No. CRA No. a ItemRevised Reason for Revisison

0 3/30/09 Original Issue

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EXECUTIVE SUMMARY

TLG Services, Inc. (TLG) has prepared a site-specific cost study fordecommissioning the Humboldt Bay Power Plant Unit 3 (HBPP3) for the PacificGas and Electric Company (PG&E); this will be referred to as the 2010 SAFSTORstudy. This estimate includes a comprehensive cost and schedule estimate forcompleting the decommissioning of HBPP3 based on outlined work areas of theplant. Manpower levels and activity durations were developed and are reflectedwithin the project schedule along with other associated site programs. This estimateincorporates the site specific decommissioning tasks and detailed plans which havebeen identified as a result of the ongoing detailed planning effort. The projected totalcost to decommission HBPP3, including costs spent to date and a 25% contingencyapplied to remaining work, is estimated to be approximately $499.8 million (2008dollars).

The California Public Utility Commission (CPUC) has previously ruled that certaincosts that were incurred after HBPP3 was permanently shutdown would not beincluded in rates for recovery of decommissioning costs. The costs associated withdecommissioning activities on systems and components which have been identified bythe CPUC as decommissioning disallowances is estimated at $385,520.

The major cost contributors to the overall decommissioning cost are labor, spent fuelstorage and the disposition of waste generated in the decontamination and demolitionof the unit. The estimate is based on several key assumptions, including regulatoryrequirements, estimating methodology, contingency requirements, low-levelradioactive waste (LLRW) disposal availability, high-level radioactive waste disposalschedule, and site restoration requirements. A summary of decommissioning costcontributors is provided at the end of this section and a complete discussion of the,assumptions used in this estimate is presented in Section 3.

Alternatives and Regulations

The Nuclear Regulatory Commission (NRC) provided general decommissioningguidance in the rule adopted on June 27, 1988.[11 In this rule the NRC sets f6rthtechnical and financial criteria for decommissioning licensed nuclear facilities. Theregulation addresses planning needs, timing, funding methods, and environmentalreview requirements for decommissioning. The rule also defined three

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

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decommissioning alternatives as being acceptable to the NRC - DECON, SAFSTORand ENTOMB.

DECON was defined as "the alternative in which the equipment,structures, and portions of a facility and site containing radioactivecontaminants are removed or decontaminated to a level that permits theproperty to be released for unrestricted use shortly after cessation ofoperations." [2]

SAFSTOR was defined as "the alternative in which the nuclear facility isplaced and maintained in a condition that allows the nuclear facility tobe safely stored and subsequently decontaminated (deferreddecontamination) to levels that permit release for unrestricted use." [3]

ENTOMB was defined as "the alternative in which radioactivecontaminants are encased in a structurally long-lived material, such asconcrete; the entombed structure is appropriately maintained andcontinued surveillance is carried out until the radioactive materialdecays to a level permitting unrestricted release of the property." [41

In 1996, the NRC published revisions to the general requirements fordecommissioning nuclear power plants to clarify ambiguities and codify proceduresand terminology as a means of enhancing efficiency and uniformity in thedecommissioning process. The amendments allow for greater public participation andbetter define 'the transition process from operations to decommissioning. The costs andschedules presented in this estimate follow the general guidance and sequence in theamended regulations.

Methodology

The methodology used to develop the decommissioning cost estimates for HBPP3follows the basic approach originally presented in the Guidelines.[5 ] This referencedescribes a unit factor method for determining decommissioning activity costs. Theunit factors used in this analysis incorporates site-specific costs and the latestavailable information on worker productivity in decommissioning.

An activity duration critical path is used to determine the total decommissioningprogram schedule. The schedule is relied upon in calculating the carrying costs, which

2 Ibid. Page FR24022, Column 3.3 Ibid.4 Ibid. Page FR24023, Column 2.5 T.S. LaGuardia et al., "Guidelines for Producing Commercial Nuclear Power Plant

Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

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include program management, administration, field engineering, equipment rental,and support services such as quality control and security. This systematic approachfor assembling decommissioning estimates ensures a high degree of confidence in thereliability of the resulting cost estimate.

This study assumes that utility and contractor personnel are already experienced inthe techniques and technology of nuclear power plant decommissioning, and thereforeperforms all work (both field activities and project management) in an efficientmanner.

Contingency

Consistent with industry practice, contingencies are applied to the decontaminationand dismantling costs developed as, "specific provision for unforeseeable elements ofcost within the defined project scope, particularly important where previousexperience relating estimates and actual costs has shown that unforeseeable eventswhich will increase costs are likely to occur."[61 The cost elements in this estimate arebased on ideal conditions; therefore, the types of unforeseeable events that are almostcertain to occur in decommissioning, based on industry experience, are addressedthrough a percentage contingency applied on a line-item basis. This contingency factoris a nearly ufiiversal element in all large-scale construction and demolition projects. Itshould be noted that contingency, as used in this analysis, is based on a preliminarytechnical position [71 to reflect the California Public Utilities Commission's desire forowners to conservatively establish an appropriate contingency factor for inclusion inthe decommissioning revenue requirements. It should also be noted that contingency,as used- in this estimate, does not account for price escalation and inflation in the costof decommissioning during the decommissioning period.

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

Low-Level Radioactive Waste Disposal

The contaminated and activated material generated in the decontamination anddismantling of a commercial nuclear reactor is classified as low-level (radioactive)

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

7 "Technical Position Paper for Establishing an Appropriate Contingency Factor for Inclusion in theDecommissioning Revenue Requirements", Study Number: DECON-POS-H002, Revision A, Status:Preliminary (provided by PG&E).

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waste, although not all of the material is suitable for "shallow-land" disposal. [8] Withthe passage of the "Low-Level Radioactive Waste Policy Act" in 1980, [9] and itsAmendments of 1985, [101 the states became ultimately responsible for the dispositionof low-level radioactive waste (LLRW) generated within their own borders.

Until recently, there were two facilities available to PG&E for the disposal of low-levelradioactive waste generated by HBPP3. As of July 1, 2008, however, the facility inBarnwell, South Carolina was closed to generators outside the Atlantic Compact(comprised of the states of Connecticut, New Jersey and South Carolina). This leavesthe facility in Clive, Utah, operated by EnergySolutions, as the only availabledestination for low-level radioactive waste requiring controlled disposal.

For the purpose of this analysis, the EnergySolutions' facility is used as the disposalsite (for purposes of determining the cost of transportation and the cost of disposal) forthe majority of the radioactive waste (Class A). There are no currently operatingdisposal facilities available to PG&E that have a license to dispose of the more highlyradioactive waste (Classes B and C), for example, generated in the dismantling of thereactor vessel. As such, waste disposal costs and waste transportation distances, andavailability must be estimated. The disposal cost and transportation distance for low-level radioactive waste is based on a study sponsored by PG&E and SouthernCalifornia Edison Company, "Establishing an Appropriate Disposal Rate for LowLevel Radioactive Waste During Decommissioning."["] The study was done to reflectthe California Public Utilities Commission's desire for these owners to conservativelyestimate their nuclear decommissioning LLRW disposal rates. It is assumed for thisestimate that Class B and C waste disposal facilities become available by 2016.

The dismantling of the components residing closest to the reactor core generatesradioactive waste considered unsuitable for shallow-land disposal (i.e., low-levelradioactive waste with concentrations of radionuclides that exceed the limitsestablished by the NRC for Class C radioactive waste (GTCC)). The Low-LevelRadioactive Waste Policy Amendments Act of 1985 assigned the federal governmentthe responsibility for the disposal of this material. The Act also stated that thebeneficiaries of the activities resulting in the generation of such radioactive wastebear all reasonable costs of disposing of such waste. However, to date, the federalgovernment has not identified a cost for disposing of GTCC or a schedule foracceptance. As such, the GTCC radioactive waste has been packaged and disposed ofas high-level waste, at a cost equivalent to that envisioned for the spent fuel.

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

9 "Low-Level Radioactive Waste Policy Act of 1980," Public Law 96-573, 1980.10 "Low-Level Radioactive Waste Policy Amendments Act of 1985," Public Law 99-240, 1986.11 "Establishing an Appropriate Disposal Rate for Low Level Radioactive Waste During

Decommissioning", Robert A Snyder NEWEX, Revision 0, July 2008 (provided by PG&E).

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For purposes of this study, GTCC is packaged in the same type of canister used forspent fuel. The GTCC material is either stored with the spent fuel at the ISFSI orshipped directly to a DOE facility as it is generated (depending upon the timing of thedecommissioning and whether the spent fuel has been removed from the site prior tothe start of decommissioning).

High-Level Waste

Congress passed the "Nuclear Waste Policy Act"[12] (NWPA) in 1982, assigning thefederal government's long-standing responsibility for disposal of the spent nuclear fuelcreated by the commercial nuclear generating plants to the DOE. The NWPA providedthat DOE would enter into contracts with utilities in which DOE would promise totake the utilities' spent fuel and high-level radioactive waste and utilities would paythe cost of the disposition services for that material. The NWPA, along with theindividual contracts with the utilities, specified that the DOE was to begin acceptingspent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays in the programschedule. By January 1998, the DOE had failed to accept any spent fuel or high levelwaste, as required by the NWPA and utility contracts. Delays continue and, as aresult, generators have initiated legal action against the DOE in an attempt to obtaincompensation for DOE's breach of contract.

Operation of DOE's yet-to-be constructed repository is contingent upon the review andapproval of the facility's license application by the NRC and the successful resolutionof pending litigation. The DOE submitted its license application to the NRC on June 3,2008, seeking authorization to construct the repository at Yucca Mountain, Nevada.Assuming a timely review and adequate funding, the DOE expects that receipt of fuelcould begin as early as 2020. [13]

The DOE's generator allocation/receipt schedules are based upon the oldest fuelreceiving the highest priority. For purposes of this analysis, acceptance ofcommercial spent fuel by the DOE is expected to begin in 2020. All assemblies areexpected to be removed from the Humboldt Bay site in 2020.

All fuel has been transferred to the ISFSI. The ISFSI will remain operational until2020.

12 "Nuclear Waste Policy Act of 1982 and Amendments," DOE's Office of Civilian RadioactiveManagement, 1982

13 DOE-RW-0604, "Project Decision Schedule", U.S. DOE Office of Civilian Radioactive WasteManagement, January 2009".

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Site Restoration

The efficient removal of the contaminated materials and verification that residualradionuclide concentrations are below the NRC guidelines will result in substantialdamage to many of the site structures. Blasting, coring, drilling, scarification(surface removal), and the other decontamination activities will substantiallydamage power block structures, potentially weakening the footings and structuralsupports. This study assumes that the majority of the site buildings are demolishedas part of the license termination activities, and any remaining buildings aredemolished immediately after license termination.

All demolition debris is assumed to be potentially radioactively contaminated, andtherefore transported and disposed of at a Low-Level Radiological Waste (LLRW)disposal facility. This study assumes that structures are removed to a nominaldepth of three feet below grade level. Below grade structures will bedecontaminated and left in place. Below grade voids are backfilled with clean fill.The site is assumed to be graded and landscaped.

Summary

The costs to decommission HBPP3 were evaluated for a SAFSTOR decommissioningalternative. The estimate includes costs spent-to-date. The estimate assumes theeventual removal of all the contaminated and activated plant components andstructural materials, such that the facility operator may then have use of the sitewith no further requirement for an NRC license. Decommissioning is initiated afterthe spent fuel has been removed from the spent fuel pool and is accomplishedwithin the 60-year period required by current NRC regulations. The estimateassumes that the spent fuel remains in storage at the site until such time that thetransfer to a DOE facility can be completed. Once the transfer is complete, thestorage facility is also decommissioned.

A detailed breakdown of these major cost contributors to the decommissioning costestimate is reported at the end of this section and in Section 6 of this document.Schedules of annual expenditures are provided in Section 3, and detailed cost, wastevolume, and man-hour schedules are provided in Appendix D and E. Costs arereported in 2008 dollars. Cash flows and expenditures to date are based on scheduleforecasts as of December 2008. The estimate includes the costs for storing theHBPP3 spent fuel until such time that the Department of Energy (DOE) cancomplete the transfer to an off-site facility.

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SUMMARY OF DECOMMISSIONING COST CONTRIBUTORS

Work Category Costs 08' $ Percent of Costs 04' $(thousands) Total (thousands)

Decontamination 978 0.2% 1,865

Removal 48,360 9.7% 23,899Packaging 9,258 1.9% 3,087

Shipping 11,722 2.3% 5,578Waste Processing & Recycling 675 0.1% 8,877

LLRW Burial 77,596 15.5% 17,446Demolition LLRW Burial 23,872 4.8% 38,528Staffing 132,760 26.6% 70,516

Security 45,687 9.1% 4,149License Termination Survey 1,958 0.4% 9,874Insurance 1,000 0.2% 786Energy 1,254 0.3% 827

NRC & EP Fees 5,386 1.1% 1,935NRC ISFSI Fees 1,023 0.2% 3,745ISFSI Capital, O&M, Fixed & Security 57,798 11.6% 66,391

Non-ISFSI Expenditures 28,015 5.6% 20,282Equipment & Supplies 28,797 5.8% 28,520Engineering 23,618 4.7% 11,121

Total 499,759 100.0% 317,424

CPUC Disallowances

Removal 193 50.1% 172

Packaging 21 5.5% 14Shipping 4 0.9% 5

Waste Processing & Recycling 0 0.0% 30"LLRW Burial 165 42.8% 135Equipment & Supplies 3 0.7% 2

Total 386 100.0% 357

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1. INTRODUCTION

TLG prepared this decommissioning cost estimate to provide Pacific Gas and ElectricCompany (PG&E) with sufficient information to prepare the financial planningdocuments for decommissioning, as required by the Nuclear Regulatory Commission(NRC). It is not a detailed engineering document, but a financial analysis prepared inadvance of the detailed engineering that will be required to carry out thedecommissioning.

1.1 OBJECTIVE OF STUDY

The objective of the study is to prepare a comprehensive estimate of the cost, aschedule of the associated activities, and an estimate of the volume of radioactivewaste generated during decommissioning of the Humboldt Bay Power Plant Unit3 (HBPP3).

1.2 SITE DESCRIPTION

HBPP3 is located approximately four miles southwest of Eureka, California. Thesite consists of approximately 143 acres located on the mainland shore ofHumboldt Bay. Figure 1.1 shows the layout of the site and the surrounding area.The adjacent generating units (Units 1 and 2) are fossil-fueled and are notconsidered in the scope of this study, except where noted.

The Nuclear Steam Supply System (NSSS) for HBPP3 consists of a single cycle,natural circulation, boiling water reactor and the associated control and supportsystems. Figure 1.2 shows a schematic diagram of the reactor pressure vesseland internal components. The generating unit had a rated core thermal power of220 MWth (thermal) with a corresponding net electrical output of 65 MWe(electric).

The NSSS is located within the "primary containment structure." The primarycontainment is located mostly below grade and consists of a drywell vessel and asuppression chamber. Both the drywell and the suppression. chamber area arelocated within a reinforced concrete caisson. The drywell vessel is centrallylocated in the caisson and serves as the primary containment vessel. Thesuppression chamber is constructed of reinforced concrete and lined with carbonsteel plate. Six vent pipes connect the drywell to a common ring header at thetop of the suppression chamber. Downcomers drop from the ring header andterminate below the normal water level of the suppression pool. As a system, thedrywell, suppression chamber, and interconnecting piping were designed toreduce the pressure increase in the event of a local process system piping failure.

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Figure 1.3, a sectional view through the caisson, depicts this generalarrangement and the associated concrete structure.

The turbine-generator system converts heat produced in the reactor to electricalenergy. This system converted the thermal energy of steam produced in thereactor vessel into mechanical shaft power and then into electrical energy. Theunit's turbine-generator consists of a tandem, compound, double flow, condensingturbine directly connected to a 13,800V, 3-phase, 60 cycle, hydrogen-cooled,synchronous generator. The turbine consists of a single flow high-pressuresection and a double flow, low-pressure section with a crossover pipe connectingthe two sections. The turbine was operated in a closed feedwater cycle wherebysteam was condensed and the condensate/feedwater was returned to the reactorvessel. Heat rejected in the main condenser was removed by the CirculatingWater System (CWS). The CWS delivers the water required to remove the heatload from the main condenser and other auxiliary equipment and returns it tothe bay through the discharge pipes and a canal.

Commercial operation began in August of 1963 and continued until July of 1976,at which time the unit was shut down after approximately 13 years of operationto conduct seismic modifications. In 1983 PG&E announced the decision todecommission Unit 3. The plant has been maintained in NRC SAFSTOR sincethat time. Fuel transfer to the ISFSI has been completed.

1.3 REGULATORY GUIDANCE

The Nuclear Regulatory Commission (NRC or Commission) provided initialdecommissioning requirements in its rule "General Requirements forDecommissioning Nuclear Facilities," issued in June 1988.[1]* This rule setforth financial criteria for decommissioning licensed nuclear power facilities.The regulation addressed decommissioning planning needs, timing, fundingmethods, and environmental review requirements. The intent of the rule wasto ensure that decommissioning would be accomplished in a safe and timelymanner and that adequate funds would be available for this purpose.Subsequent to the rule, the NRC issued Regulatory Guide 1.159, "Assuring theAvailability of Funds for Decommissioning Nuclear Reactors,"[21 whichprovided additional guidance to the licensees of nuclear facilities on thefinancial methods acceptable to the NRC staff for complying with therequirements of the rule. The regulatory guide addressed the fundingrequirements and provided guidance on the content and form of the financialassurance mechanisms indicated in the rule.

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

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The rule defined three decommissioning alternatives as being a cceptable to theNRC: DECON, SAFSTOR, and ENTOMB. The DECON alternative assumesthat any contaminated or activated portion of the plant's systems, structures,and facilities are removed or decontaminated to levels that permit the site tobe released for unrestricted use shortly after the cessation of plant operations.The rule also placed limits on the time allowed to complete thedecommissioning process. For SAFSTOR, the process is restricted in overallduration to 60 years, unless it can be shown that a longer duration isnecessary to protect public health and safety. The guidelines for ENTOMB aresimilar, providing the NRC with both sufficient leverage and flexibility toensure that these deferred options are only used in situations where it isreasonable and consistent with the definition of decommissioning. At theconclusion of a 60-year dormancy period (or longer for ENTOMB if the NRCapproves such a case), the site would still require significant remediation tomeet the unrestricted release limits for license termination.

The ENTOMB alternative has not been viewed as a viable option for powerreactors due to the significant time required to isolate the long-livedradionuclides for decay to permissible levels. However, with recent rulemakingpermitting the controlled release of a site, the NRC has re-evaluated thisalternative.[31 The resulting feasibility study, based upon an assessment byPacific Northwest National Laboratory, concluded that the method did haveconditional merit for some, if not most, reactors. However, the staff also foundthat additional rulemaking would be needed before this option could be treatedas a generic alternative. The NRC had considered rulemaking to alter the 60-year time for completing decommissioning and to clarify the use of engineeredbarriers for reactor entombments.[41 However, the NRC staff has recommendedthat rulemaking be deferred, based upon several factors, e.g., no licensee hascommitted to pursuing the entombment option, the disposition of greater-than-Class C material (GTCC) using this option, and the NRC's current priorities,at least until after the additional research studies are complete. TheCommission concurred with the staffs recommendation.

The NRC published revisions to the general requirements for decommissioningnuclear power plants in 1996.[5] When the regulations were originally adoptedin 1988, it was assumed that the majority of licensees would decommission atthe end of the facility's operating licensed life. Since that time, severallicensees permanently and prematurely ceased operations. Exemptions fromcertain operating requirements were required once the reactor was defueled tofacilitate the decommissioning. Each case was handled individually, withoutclearly defined generic requirements. The NRC amended the decommissioningregulations in 1996 to clarify ambiguities and codify procedures andterminology as a means of enhancing efficiency and uniformity in the

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decommissioning process. The new amendments allow for greater publicparticipation and better define the transition process from operations todecommissioning.

Under the revised regulations, licensees will submit written certification to theNRC within 30 days after the decision to cease operations. Certification willalso be required once the fuel is permanently removed from the reactor vessel.Submittal of these notices will entitle the licensee to a fee reduction andeliminate the obligation to follow certain requirements needed only duringoperation of the reactor. Within two years of submitting notice of permanentcessation of operations, the licensee is required to submit a Post-ShutdownDecommissioning Activities Report (PSDAR) to the NRC. The PSDARdescribes the planned decommissioning activities, the associated sequence andschedule, and an estimate of expected costs. Prior to completingdecommissioning, the licensee is required to submit an application to the NRCto terminate the license, which will include a License Termination Plan (LTP).

1.3.1 Nuclear Waste Policy Act

Congress passed the "Nuclear Waste Policy Act"[6] (NWPA) in 1982,assigning the federal government's long-standing responsibility fordisposal of the spent nuclear fuel created by the commercial nucleargenerating plants to the DOE. The NWPA provided that DOE wouldenter into contracts with utilities in which DOE would promise to takethe utilities' spent fuel and high-level radioactive waste and utilitieswould pay the cost of the disposition services for that material. TheNWPAI along with the individual contracts with the utilities, specifiedthat the DOE was to begin accepting spent fuel by January 31, 1998.

Since the original legislation, the DOE has announced several delays inthe program schedule. By January 1998, the DOE had failed to acceptany spent fuel or high level waste, as required by the NWPA and utilitycontracts. Delays continue and, as a result, generators have initiatedlegal action against the DOE in an attempt to obtain compensation forDOE's breach of contract.

Operation of DOE's yet-to-be constructed repository is contingent uponthe review andapproval of the facility's license application by the NRCand the successful resolution of pending litigation. The DOE submittedits license application to the NRC on June 3, 2008, seeking authorizationto construct the repository at Yucca Mountain, Nevada. Assuming atimely review and adequate funding, the DOE expects that receipt offuel could begin as early as 2020. [71

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It is generally necessary that spent fuel be actively cooled and stored fora minimum period at the generating site prior to transfer. As such, theNRC requires that licensees establish a program to manage and providefunding for the management of all irradiated fuel at the reactor siteuntil title of the fuel is transferred to the Secretary of Energy, pursuantto 10 CFR Part 50.54(bb). [8] This funding requirement is fulfilledthrough inclusion of certain cost elements in the decommissioningestimate, for example, associated with the continued operation of theISFSLI

DOE's contracts with utilities order the acceptance of spent fuel fromutilities based upon the oldest fuel receiving the highest priority. Forpurposes of this analysis, acceptance of commercial spent fuel by theDOE is expected to begin in 2020 (in accordance 'With DOE's latestpublished schedule). Since the estimate assumes that all spent fuel willbe transferred to the DOE during the first year, the estimate includesspent fuel caretaking costs through the year 2020.

1.3.2 Low-Level Radioactive Waste Policy Amendments Act

The contaminated and activated material generated in thedecontamination and dismantling of a commercial nuclear reactor isclassified as low-level (radioactive) waste, [9] although not all of thematerial is suitable for "shallow-land" disposal. With the passage of the"Low-Level Radioactive Waste Policy Act" in 1980, [10] and itsAmendments of 1985, [11] the states became ultimately responsible forthe disposition of low-level radioactive waste generated within their ownborders.

Until recently, there were two facilities available to PG&E for thedisposal of low-level radioactive waste generated by Humboldt. As ofJuly 1, 2008, however, the facility in Barnwell, South Carolina wasclosed to generators outside the Atlantic Compact (comprised of thestates of Connecticut, New Jersey and South Carolina). This leaves thefacility in Clive, Utah, operated by EnergySolutions, as the onlyavailable destination for low-level radioactive waste requiring controlleddisposal.

For the purpose of this analysis, the EnergySolutions' facility is used asthe disposal site for the majority of the radioactive waste (Class A).There are no currently operating disposal facilities available to PG&Ethat have a license to dispose of the more highly radioactive waste(Classes B and C), for example, generated in the dismantling of the

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reactor vessel. As such, waste disposal costs must be estimated. Thedisposal cost for low-level radioactive waste is based on a studysponsored by PG&E and Southern California Edison Company,"Establishing an Appropriate Disposal Rate for Low Level RadioactiveWaste During Decommissioning."[ 12] The study w'as done to reflect theCalifornia Public Utilities Commission's desire for these owners toconservatively estimate their nuclear decommissioning LLRW disposalrates. Although no current licensed facility exists for Class B and Cwaste, the study assumes that a facility will be available by 2016 tosupport decommissioning.

The dismantling of the components residing closest to the reactor coregenerates radioactive waste considered unsuitable for shallow-landdisposal (i.e., low-level radioactive waste with concentrations ofradionuclides that exceed the limits established by the NRC for Class Cradioactive waste (GTCC)). The Low-Level Radioactive Waste PolicyAmendments Act of 1985 assigned the federal government theresponsibility for the disposal of this material. The Act also stated thatthe beneficiaries of the activities resulting in the generation of suchradioactive waste bear all reasonable costs of disposing of such Waste.However, to date, the federal government has not identified a cost fordisposing of GTCC or a schedule for acceptance. As such, the GTCCradioactive waste has been packaged and disposed of as high-levelwaste, at a cost equivalent to that envisioned for the spent fuel.

For purposes of this study, GTCC is packaged in the same type ofcanister used for spent fuel. The GTCC material is either stored with thespent fuel or shipped directly to a DOE facility as it is generated(depending upon the timing of the decommissioning and whether thespent, fuel has been removed from the site prior to the start ofdecommissioning).

1.3.3 Radiological Criteria for License Termination

In 1997, the NRC published Subpart E, "Radiological Criteria forLicense Termination,"[131 amending 10 CFR §20. This subpart providesradiological criteria for releasing a facility for unrestricted use. Theregulation states that the site can be released for unrestricted use ifradioactivity levels are such that the average member of a critical groupwould not receive a Total Effective Dose Equivalent (TEDE) in excess of

* 25 millirem per year, and provided that residual radioactivity has beenreduced to levels that are As Low As Reasonably Achievable (ALARA).

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The decommissioning estimates for HBPP3 assume that the site will beremediated to a residual level consistent with the NRC-prescribed level.

It should be noted that the NRC and the Environmental ProtectionAgency (EPA) differ on the amount of residual radioactivity consideredacceptable in site remediation. The EPA has two limits that apply toradioactive materials. An EPA limit of 15 millirem per year is derivedfrom criteria established by the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA or Superfund).[141An additional limit of 4 millirem per year, as defined in 40 CFR §141.16,is applied to the drinking water exposure pathway.[151]

On October 9, 2002, the NRC signed an agreement with the EPA on theradiological decommissioning and decontamination of NRC-licensedsites. The Memorandum of Understanding (MOU) [16] provides that EPAwill defer exercise of authority under CERCLA for the majority offacilities decommissioned under NRC authority. The MOU also includesprovisions for NRC and EPA consultation for certain sites when, at thetime of license termination, (1) groundwater contamination exceedsEPA-permitted levels; (2) NRC contemplates restricted release of thesite; and/or (3) residual radioactive soil concentrations exceed levelsdefined in the MOU.

The MOU does not impose any new requirements on NRC licensees andshould reduce the involvement of the EPA with NRC licensees who aredecommissioning. Most sites are expected to meet the NRC criteria forunrestricted use, and the NRC believes that only a few sites will havegroundwater or soil contamination in excess of the levels specified in theMOU that trigger consultation with the EPA. However, if there areother hazardous materials on the site, the EPA may be involved in thecleanup. As such,, the possibility of dual regulation remains for certainlicensees. The present study does not include any costs for thisoccurrence.

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Document P01-1604-002, Rev. 0Section 1, Page 8 of 10

FIGURE 1.1

LAYOUT OF THE NUCLEAR PLANT SITE AND SURROUNDING AREA

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FIGURE 1.2

SCHEMATIC DIAGRAM OF THE VESSEL AND INTERNALS

• JWA DoY!R

sws

o LEVE pLm IRED WmGE

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FI

FIGURE 1.3


SECTIONAL VIEW THROUGH THE CAISSON

HEAT EXCHANGERS

-CORE SPRA:Y PUMPS NO. I & 2i6UCT. REACTOR CLEAN.-UPPUMP' OISCH.

-j

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2. SAFSTOR DECOMMISSIONING ACTIVITIES

This section describes the activities associated with the decontamination anddisassembly of the plant. Although detailed procedures for each activity identified arenot provided, and the actual sequence of work may vary, the activity descriptionsprovide a basis not only for estimating, but also for understanding the expected scopeof work, i.e., engineering and planning at the time of decommissioning.

The operation, shut down, and safe storage of the nuclear unit were described in detailin the decommissioning plan, "SAFSTOR Decommissioning Plan for the HumboldtBay Power Plant, Unit No. 3". [171 The activities and associated costs expended prior to1996, and routine operations and maintenance costs for dormancy, are not included inthe estimate. This study understanding specifically addresses those activities andcosts associated with the conclusion of the safe storage period and the subsequentdecommissioning process.

The NRC defines SAFSTOR as "the alternative in which the nuclear facility is placedand maintained in a condition that allows the nuclear facility to be safely stored andsubsequently decontaminated (deferred decontamination). to a level that permitsrelease for unrestricted use." The decommissioning scenario evaluated in this studypresumes that final decommissioning activities will start in 2010.

The SAFSTOR decommissioning plan prepared by PG&E primarily addressed theactivities and tasks related to preparing and maintaining the facility in safe storage.,The document was originally intended to be revised (updated) prior to initiatingdecommissioning activities in the year 2007. Under the current NRC decommissioningrequirements, the SAFSTOR Decommissioning Plan was considered to be both aPreliminary Shutdown Decommissioning Activities Report (PSDAR) and a DefueledSafety Analysis Report (DSAR). As a result, PG&E submitted a PSDAR in February1998 that describes planned decommissioning activities and associated schedule andcost.[18] The SAFSTOR Decommissioning Plan was renamed the DSAR, and itcontains system descriptions, administrative controls, and accident analysis. PG&Ewill submit a License Termination Plan at least two years prior to license termination.

The current NRC guidance (Reg. Guide 1.184 Decommissioning of Nuclear PowerReactors) defines decommissioning in three phases. The current plant status (safestorage) is addressed in Phase II. This phase is applicable to the dormancy phase ofthe deferred decommissioning alternatives. Phase III pertains to the activitiesinvolved in license termination.

The TLG cost estimating methodology subdivides the decommissioning project intoperiods, based upon major milestones in the project. Continuing Phase II expenses are

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included in Period 2 of this study, Phase III, includes the activities associated withlicense termination, is subdivided into Periods 3 and 4 in the cost estimate. Period .5includes those activities required for site restoration. Post-Period 5 covers ISFSIoperations, fuel transfer to the DOE, and ISFSI demolition..

2.1 PERIOD 2 - SAFE STORAGE AND DECOMMISSIONINGPREPARATIONS

With the recent completion of spent fuel transfer to the ISFSI, the emphasis hasshifted to activities associated with preparation for active decommissioningtasks. Site activities include: preventive and corrective maintenance on essentialsystems, general building maintenance, operation and maintenance of heatingand ventilation equipment, routine radiological inspections of contaminatedstructures, maintenance of structural integrity, and monitoring of environmentaland radiation conditions.

The estimate includes some specific decommissioning preparation line itemsbased upon the in depth planning activities which have occurred prior to andincluding 2008.

The following additional preparatory activities have occurred or are scheduled tooccur prior to the start of formal decommissioning: abatement of remainingasbestos, performance of a vessel and internals activation analysis, performanceof a radiological characterization survey of work areas, major components, andstructures (including the drywell), sampling of internal piping and primaryshield cores, development of cost and work control program, development ofdetailed work plans and schedules, development of a radioactive wasteprocessing and disposal plan, and the development of the engineeringdecommissioning licensing basis.

2.2 PERIOD 3 - PREPARATIONS

In anticipation of decommissioning, preparations are undertaken to provide asmooth transition from safe storage. The organization required to plan andmanage the intended decommissioning activities is-assumed to be assembledfrom available utility staff and outside resources, as required. For purposes ofthis study, a combination of utility and outside contracted resources is utilized tomanage the decommissioning and to manage and perform the physicaldecommissioning activities and associated management functions. Acombination of utility staff and outside contracted resources will be employed tomanage the processing and disposal of decommissioning waste, including thedisposition of equipment, components, and material and the disposal of all

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decommissioning waste, including concrete and steel structural debris,contaminated soil, and associated hazardous and mixed waste.

2.2.1 Engineering and Planning

Significant technical and engineering planning and evaluation must beperformed in preparation for physical decommissioning activities.Technical requirements documents are prepared for systems, components,and structures during each phase of the decommissioning (many of theserequirements documents are already complete). These engineeringrequirements are then transferred into specific documents for thepreparation of material and services contracts and for the preparation ofdetailed work plans and work authorization documents. Also, regulationsrequire the preparation of a license termination plan. The plan is requiredat least two years prior to the anticipated date of license termination. Theplan includes a site characterization, description of the remainingdismantling activities, plans for site remediation, procedures for the finalradiation survey, designation of any reuse of the site, an updated costestimate to complete the decommissioning, and resolution ofenvironmental concerns. The NRC will make the plan available for publiccomment. Plan approval will be subject to conditions and limitations asdeemed appropriate by the NRC. Much of the information needed inpreparing this submittal will have been used to develop the detailedengineering plans and procedures needed to support Period 4 activities.

Other engineering and planning work activities performed during Period3 include: evaluating alternatives for the removal of highly radioactivereactor vessel components, identifying specialty contractors, selecting themethodology and requirements for systems and structuresdecontamination, preparing procedures for radioactive material disposal,and designing and procuring specialty tooling.

2.2.2 Site Preparations

In preparation for the actual decommissioning, the following physicaltasks are performed and included in the cost estimate:

" The design and licensing of the ISFSI facility (completed).

" Constructing and modifying site support and storage facilities, asrequired (in progress).

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" Processing and disposal of residual liquid, solid, and mixed wasteinventories (in progress).

" Procuring waste containers, including specialty containers for thedisposition of highly activated and hazardous materials. The types ofcontainers needed to support decommissioning operations includestrong-tight steel boxes and drums, shielded transport casks, dry fuelstorage liners, high integrity containers, intermodal containers, andshipping transportation trailers. -J

" Developing procedures for occupational exposure control, control andrelease of liquid and gaseous effluent, processing of radwaste includingdry active waste (DAW), resins, filter media, metallic and non-metalliccomponents generated in decommissioning, site security and emergencyprograms, hazardous waste identification and processing, andindustrial safety.

2.3 PERIOD 4 - DECOMMISSIONING OPERATIONS AND LICENSETERMINATION

The decommissioning cost estimate has divided this period into sub-periods toassist in the development of cost elements and to better understand the worksequence and its impact on the overall duration of the work phase.

2.3.1 System Removal

This phase includes: construction of temporary facilities and shielding,modification of existing storage facilities to support the dismantlingactivities, decontamination of selected systems and components,procurement of specialty tooling, and modifications to systems andstructures to support handling of the waste from reactor vessel and spentfuel pool removal.

The following is the list of the system and component removal activitiesperformed during this sub-period.

" Removal of major turbine components, e.g. generator, turbine andcondenser.

" Removal of components and systems in the Turbine Building, includingpiping, pumps, heat exchangers and associated mechanical andelectrical components.

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* Removal of electrical control boards, distribution buses, andtransformers.

e Provide equipment handling capability and personnel access toequipment and components within the Refuel Building.

* Remove equipment and components in the Refuel Building..q

* Removal of Hot Machine Shop equipment and piping.

2.3.2 Reactor Vessel Removal

The following is a list of the system and component removal activitiesperformed during this sub-period:

" Removal of the reactor vessel closure head. The head is assumed to bedisposed of as low-level radioactive waste. Segmentation of the headmay be desirable to increase packaging efficiency and minimize itsdisposal volume.

" Removal and segmenting of the steam dryer, core spray piping,feedwater sparger and chimney, as required, for transport. Componentsegmentation may be performed in the reactor vessel; however,relocation to the spent fuel pool would allow greater control withrespect to water clarity and provide greater flexibility in packaging, i.e.,homogenization of the waste forms. Material meeting 10 CFR 61 ClassC criteria or less may be routed for off-site disposal at a commercialshallow-land waste disposal facility.

* Disassembly/segmentation of remaining reactor internals, including thecore shroud, core support assembly, control rod guide tube and othermiscellaneous components. These operations will probably be confinedto the reactor vessel due to the higher activation levels of thecomponents.

" Segmentation/sectioning of the reactor vessel, placing segments intoshielded containers. The operation is performed remotely, in-air, usinga shielded work platform and a contamination control envelope.Sections are placed in liners and stored in the spent fuel pool. Theliners are loaded into shielded transport casks for disposal at acommercial shallow-land waste disposal facility.

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Removal of control rod drive housings from reactor vessel bottom headand packaging for controlled disposal. The bottom head may be highlycontaminated from the swarf generated from in-vessel segmentationactivities. It may be advantageous to relocate the head to the spent fuelpool for additional processing and preparation for disposal. This willalso significantly lower the working radiation levels within the drywelland allow disassembly work to proceed.

Removal of systems and associated components as they become non-essential to the vessel removal operation, related decommissioningactivities, or worker health and safety (e.g., waste collection andprocessing systems, electrical and ventilation systems, etc.).

Removal of steel drywell liner and decontamination of the steel ventpipes connecting the drywell to the suppression chamber.Contaminated surfaces can be designated for decontamination whileactivated portions are packaged for direct disposal. This work wouldalso include the removal of activated concrete from behind the drywellsteel and the concrete floor slab at the bottom of caisson, and packagingthe material for direct disposal.

* Decontamination and removal of the suppression chamber steel,disposition of the waste as appropriate.

" Removal of contaminated equipment and material from the RadwasteTreatment and Refueling Buildings. Decontaminate the structures, e.g.,scarifying concrete surfaces until residual levels of contamination areacceptable for unrestricted release.

" Decontamination of remaining contaminated site buildings andfacilities. Package and dispose of all remaining low-level radioactivewaste, and any remaining hazardous and toxic materials.

" Removal of remaining components, equipment, and plant services insupport of the area release survey(s).

" Removal of contaminated soil and contaminated drain and catchbasins. Remediation of the intake and discharge canals.

Components removed in the decontamination and dismantling of HBPP3will be routed to an on-site central packaging and processing area.Contaminated material will be characterized and packaged for disposal atthe designated low-level radioactive waste disposal facility. Material that

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has been surveyed and found to be free of contamination will be releasedas scrap.

2.3.3 Prepare Buildings for Demolition

Buildings in the Restricted Area (RA) will be decontaminated as necessaryto allow conventional demolition. Structures will be removed down tothree feet below grade.

Remaining systems will be removed, surveyed and either released ordisposed of as radioactive waste.

Building decontamination debris and waste soil will be shipped usingintermodal containers via truck to a LLRW disposal facility.

The internally contaminated pipe tunnel between the Radwaste Buildingand Turbine Building is expected to be filled with concrete, the soilsurrounding the tunnel excavated, and the tunnel will be segmented intoblocks and shipped to and disposed of at a LLRW disposal facility.

The spent fuel pool walls (the 3 exterior walls) and tremie floor beneaththe pool will be removed and disposed of as radioactive waste. Removalof the walls and tremie requires special engineering controls due to thedepth of the structures and soil conditions. A combination of groundfreezing and sheet pile is expected to be utilized to provide access to thisarea.

2.3.4 Building Demolition, Yard Work, Soil Remediation

Buildings in the Restricted Area (RA) will be demolished usingconventional demolition. Most structures (including the Refuel Buildingand Turbine Building) will be removed down to three feet below grade.Buildings entirely at grade will be completely removed. The RadwasteBuilding will also be removed in its entirety.

Contaminated soil will be excavated, and processed as needed to removeexcess moisture.

Building demolition debris and contaminated soil will be packaged inintermodal containers and transferred via highway transport toEnergySolutions.

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2.3.5 Final Site Survey License Termination

At least two years prior to the anticipated date of license termination, anLTP is required. Submitted as a supplement to the Final Safety AnalysisReport (FSAR) or its equivalent, the plan must include: a sitecharacterization, 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 tocomplete the decommissioning, and any associated environmentalconcerns. The NRC will notice the receipt of the plan, make the planavailable for public comment, and schedule a local hearing. LTP approvalwill be subject to any conditions and limitations as deemed appropriate bythe Commission.

Incorporated into the LTP is the Final Survey Plan. This plan identifiesthe radiological surveys to be performed once the decontaminationactivities are completed and is developed using the guidance provided inthe "Multi-Agency Radiation Survey and Site Investigation Manual(MARSSIM)."[191 This document incorporates the statistical approachesto survey design and data interpretation used by the EPA. It alsoidentifies state-of-the-art, commercially available instrumentation andprocedures for conducting radiological surveys. Use of this guidanceensures that the surveys are conducted in a manner that provides ahigh degree of confidence that applicable NRC criteria are satisfied.Once the survey is complete, the results are provided to the NRC in aformat that can be verified. The NRC then reviews and evaluates theinformation, performs an independent confirmation of radiological siteconditions, and makes a determination on final termination of thelicense.

The NRC will terminate the operating license if it determines that siteremediation has been performed in accordance with the LTP, and thatthe terminal radiation survey and associated documentationdemonstrate that the facility is suitable for release.

.2.4 PERIOD 5 - SITE RESTORATION

Excavated areas will be backfilled to grade using clean fill. The existing intakeand discharge canals will also be backfilled.

Site areas affected by the dismantling activities are cleaned and the plant areagraded as required to prevent ponding and inhibit the refloating of subsurfacematerials.

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The remaining Class B & C 'radioactive waste will'be shipped and disposed of ata yet to be approved licensed Class B/C disposal facility (assumed for purposes ofthe estimate to be Andrews County, Texas).

2.5 POST-PERIOD 5 - ISFSI OPERATIONS AND DEMOLITION

The ISFSI will operate under a separate and independent license (10 CFR §72)following the termination of the §50 operating license. The ISFSI will continueto operate until all spent fuel and greater than Class C (GTCC) material hasbeen transferred to the DOE. This study assumes that the DOE will transferall spent fuel from HBPP3 in the year 2020.

At the conclusion of the transfer process, the ISFSI will be decommissioned. Thestorage modules are not assumed to be activated from the storage of fuel, due tothe age of the fuel when placed in the modules. and the relatively short residencetime. 'Consequently, this estimate does not include the cost of any significantdecontamination of the ISFSI facility. Confirmation of the radiological status willbe obtained through surveys and sampling of the modules.

The Commission will terminate the ISFSI 10 CFR 72 license when it determinesthat site remediation has been performed in accordance with a licensetermination plan and the terminal radiation survey and associateddocumentation demonstrate that the structure is suitable for release. Once therequirements are satisfied, the NRC can terminate the license for the ISFSI.

The assumed design for the ISFSI is based upon the use of a multi-purposecanister installed in a steel-lined below grade engineered concrete vault. Forpurposes of this cost analysis, it is assumed that once the inner canisterscontaining the spent fuel assemblies have been removed, requireddecontamination performed, and the license for the facility terminated, theconcrete vault can be dismantled using conventional techniques for thedemolition of reinforced concrete. After removal of the concrete vault and loadingramps the area will be graded and landscaped to conform to the surroundingenvironment.

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010,SAFSTOR Section 3, Page 1 of 18

3. COST ESTIMATE

A site-specific cost estimate was prepared for decommissioning HBPP3. Theestimate accounts for the unique features of the site, including the nuclear boiler,electric power generating systems, structures, and supporting facilities. Theestimate incorporates the site specific and special tasks that have been defined as aresult of the ongoing decommissioning planning. The basis of the estimate and thesources of information, methodology, site-specific considerations, assumptions, andtotal costs are described in this section.

3.1 BASIS OF ESTIMATE

The estimate was developed using work areas as the incremental unit. As partof the 1997 cost estimate, each accessible area was visually inspected and aphysical inventory of equipment, commodities and structural components ofeach area was documented. Specific consideration included materialaccessibility and egress, radiological conditions, and physical limitations forstaging work crews. The current estimate maintains these work areadesignations and incorporates changes in decontamination and dismantlingtechniques based on ongoing on-site planning. The current estimate reflectsthe changes in the inventory which have occurred since the original estimatewas performed.

Drawings and other documentation were used to plan and schedule activitiesin high radiation areas and areas currently inaccessible due to the plant'sconfiguration. The unit factors used in developing equipment and componentremoval costs were adjusted for the working conditions determined for eacharea. Adaptation of the unit factors was accomplished by the manipulation ofthe duration adjustment variables or "Work Difficulty Factors" (WDF's).

The waste stream is assumed to be transferred to an on-site radioactive wastehandling area for packaging and disposal preparation. Class A low-levelradioactive waste generated in the decontamination and dismantling ofHBPP3 is assumed to be buried at a LLRW disposal facility. Class B and Clow-level radioactive waste is assumed to be stored& onsite until a Class B/Cdisposal facility becomes available.

Spent fuel has been relocated to the ISFSI. This allows for decontaminationand dismantling activities to proceed on the refueling building without theconstraint to maintain active spent fuel storage pool systems and services, aswell as to eliminate any safety issues associated with dismantling activities inthe vicinity of the pool.

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HBPP3 above grade structures will be demolished using standard methodsand all demolition debris will be shipped off site to a LLRW disposal facility.Below grade portions of structures such as the Refuel and Turbine Buildingswill be decontaminated and left in place. The Radwaste Building will beremoved in its entirety.

As the licensee, PG&E will oversee the decommissioning operations. The plantstaff will be augmented with the resources necessary to ensure a safe andefficient operation. This organization will supervise the decontamination anddismantling of the nuclear unit. Oversight will continue in a reduced capacityduring site restoration and beyond, as dictated by the management of thespent fuel.

3.2 METHODOLOGY

The methodology used to develop the estimates follows the basic approachoriginally presented in the AIF/NESP-036 study report, "Guidelines forProducing Commercial Nuclear Power Plant Decommissioning CostEstimates,"[201 and the DOE "Decommissioning Handbook."[21] Thesedocuments present a unit factor method for estimating decommissioningactivity costs, which simplifies the estimating calculations. Unit factors forconcrete removal ($/cubic yard), steel removal ($/ton), and cutting costs ($/inch)were developed using local labor rates. The activity-dependent costs wereestimated with the item quantities (cubic yards and tons), developed fromplant drawings and inventory documents. Removal rates and material costs forthe conventional disposition of components and structures relied uponinformation available in the industry publication, "Building Construction CostData," published by R.S. Means.[22]

This analysis reflects lessons learned from TLG's involvement in theShippingport Station Decommissioning Project, completed in 1989, as well asthe decommissioning of the Cintichem reactor, hot cells, and associatedfacilities, completed in 1997. In addition, the planning and engineering for thePathfinder, Shoreham, Rancho Seco, Trojan, Yankee Rowe, Big Rock Point,Maine Yankee, Humboldt Bay-3, Oyster Creek, Connecticut Yankee, and SanOnofre-1 nuclear units have provided additional insight into the process, theregulatory aspects, and the technical challenges of decommissioningcommercial nuclear units.

The unit factor method provides a demonstrable basis for establishing reliablecost estimates. The detail available in the unit cost factors for activity time,labor (by craft), and equipment and consumable costs provide assurance thatcost elements has not been omitted. These detailed unit cost factors, coupled

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with the plant-specific inventory of piping, components, and structures provide.a high degree of confidence in the reliability of the cost estimates.

Work Difficulty Factors

WDF were assigned to each area, commensurate with the inefficienciesassociated with working in confined hazardous environments. The ranges usedfor the WDFs are as follows:

Access Factor 0% - 75%Respirator Protection Factor 0% - 100%

Radiation/ALARA Factor 0% - 100%Protective Clothing Factor 0% - 100%

Work Break Factor 8.33%

Alpha Adjustment Factor 0% - 200%

These factors and their associated range of values were developed in conjunction

with the Atomic Industrial Forum's guideline. The factors (and their suggestedapplication) are discussed in more detail in that publication. The WDF assignedto each work area is delineated in Appendix A.

Scheduling Program Durations

The unit factors, adjusted by the WDFs as described above, are applied againstthe inventory of materials to be removed in the radiologically controlled areas.The resulting man-hours, or crew-hours, are used in the development of thedecommissioning program schedule, using resource loading and eventsequencing considerations. The scheduling of conventional removal anddismantling activities are based upon productivity information available fromthe "Building Construction Cost Data" publication.

PG&E established the work sequence and duration based upon the length oftime and resources required to prepare for and remove the reactor vessel andinternals. The schedule is relied upon in calculating the carrying costs, whichinclude program management, administration, field engineering, equipmentrental, and support services such as quality control and security. This systematicapproach for assembling decommissioning estimates ensures a high degree ofconfidence in the reliability of the resulting cost estimate.

3.3 FINANCIAL COMPONENTS OF THE COST MODEL

TLG's proprietary decommissioning cost model, DECCER, produces a numberof distinct cost elements. These direct expenditures, however, do not comprise

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the total cost to accomplish the project goal, i.e., license termination and siterestoration.

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

3.3.1 Contingency

The activity- and period-dependent costs are combined to develop thetotal decommissioning cost. A contingency is then applied on a line-itembasis, using one or more of the contingency types listed in theAIF/NESP-036 study. "Contingencies" are defined in the AmericanAssociation of Cost Engineers "Project and Cost Engineers'Handbook"'[23] as "specific provision for unforeseeable elements of costwithin the defined project scope; particularly important where previousexperience relating estimates and actual costs has shown thatunforeseeable events which will increase costs are likely to occur." Thecost elements in this analysis are based upon ideal conditions andmaximum efficiency; therefore, consistent with industry practice,contingency is included. In the AIF/NESP-036 study, the types ofunforeseeable events that are likely to occur in decommissioning arediscussed and guidelines are provided for percentage contingency ineach category. It should be noted that contingency, as used in thisanalysis, includes contingency based on a preliminary technicalposition[241 to reflect the California Public Utilities Commission's desirefor owners to conservatively establish an appropriate contingency factorfor inclusion in the decommissioning revenue requirements.

Contingency Based on AIF Guidelines

As stated in the AIF study contingency funds are an integral part of thetotal cost to complete the decommissioning process. Exclusion of thiscomponent puts at risk a successful completion of the intended tasksand, potentially, subsequent related activities. For this study, TLGexamined the major activity-related problems (decontamination,segmentation, equipment handling, packaging, transport, and wastedisposal) that necessitate a contingency. Individual activity

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Section' 3, Page 5 of 18

contingencies ranged from 10% to 75%, depending on the degree ofdifficulty judged to be appropriate from TLG's actual decommissioningexperience. The contingency values used in this study are as follows:

o Decontamination 50%o Contaminated Component Removal 25%o Contaminated Component Packaging 10%* Contaminated Component Transport 15%* Low-Level Radioactive Waste Disposal 25%

o Reactor Segmentation 75%o NSSS Component Removal 25%o Reactor Waste Packaging 25%o Reactor Waste Transport 25%o Reactor Vessel Component Disposal 50%o GTCC Disposal 15%

" Non-Radioactive Component Removal 15%* Heavy Equipment and Tooling 15%o Supplies 25%* Engineering 15%* Energy 15%

o Characterization and Termination Surveys 30%* Construction 15%o Taxes and Fees 10%* Insurance 10%o Staffing 15%

The contingency values are applied to the appropriate components of theestimates on a line item basis. The composite contingency value(excluding additional contingency described in the PreliminaryTechnical Position) is 21.7%.

Contingency Based on Preliminary Technical Position

In addition to the contingency based on the AIF guidelines additionalcontingency was added to reflect the California Public UtilitiesCommission desire for owners to conservatively establish an appropriatecontingency factor for inclusion in the decommissioning revenuerequirements. Based on the previously referenced technical position,additional contingency was added to reflect an overall project

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contingency of 25%. This contingency was incorporated on a line itembasis, with each line item receiving a pro-rated share of the increase.

3.3.2 Financial Risk

In addition to the routine uncertainties 'addressed by contingency,another cost element that is sometimes necessary to consider whenbounding decom~missioning 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 inthe estimate, within a range of probabilities. TLG considers these typesof costs under the broad term "financial risk." Included within thecategory of financial risk are:

o Transition activities and costs: ancillary expenses associated witheliminating 50% to 80% of the site labor force shortly after thecessation of plant operations, added cost for worker separationpackages throughout the decommissioning program, national orcompany-mandated retraining, and retention incentives for keypersonnel.

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

o 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 soilpreviously undiscovered (either radioactive or hazardous materialcontamination), variations in plant inventory or configuration notindicated by the as-built drawings.

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

o Policy decisions altering national commitments (e.g., in the ability toaccommodate certain waste forms for disposition), or in the timetablefor such, for example, the start and rate of acceptance of spent fuel bythe DOE.

o Pricing changes for basic inputs such as labor, energy, materials, anddisposal. Items subject to widespread price competition (such as

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materials) may not show significant variation; however, others suchas 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, whencompared with the base case estimate for decommissioning, indicate thatthe chances of the base decommissioning estimate's being too high is alow probability, and the chances that the estimate is too low is a higherprobability. This is mostly due to the pricing uncertainty for low-levelradioactive waste burial, and to a lesser extent due to schedule increasesfrom changes in plant conditions and to pricing variations in the cost oflabor (both craft and staff. This cost study, however, does not add any

additional costs to the estimate for financial risk, since there isinsufficient historical data from which to project future liabilities.

Consequently, the areas of uncertainty or risk are revisited periodicallyand addressed through repeated revisions or updates of the baseestimates.

3.4 SITE SPECIFIC CONSIDERATIONS

3.4.1 Spent Fuel Disposition

The ISFSI design consists of a multi-purpose (storage and transport) dry

canister within a vertical multi-purpose steel cask. The ISFSI is alsodesigned and sized to handle one container of greater than Class C

(GTCC) waste that will be generated during the reactor vesseldismantling. The ISFSI will operate until 2020, the current projecteddate for the DOE to remove all spent fuel from the facility. Any delays inthe transfer date to the DOE will increase the overall operations andmaintenance cost.

The cost estimate includes the cost for the ISFSI canisters, the concretestorage facility, the road to the storage facility, and all engineering,construction, licensing, and cask handling (most of these costs have beenincurred, see cost table ISFSI Completed Projects). Thedecommissioning cost estimate includes costs for operation,maintenance, inspections, and security.

3.4.2 Reactor Vessel and Internal Components

The reactor vessel and internal components will be segmented in place

and transported for disposal in shielded transportation, casks.Segmentation of the less activated components is performed in the spent

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fuel storage pool to the extent practical. The highly activatedcomponents can be disassembled in the vessel as long as water clarity ismaintained. The vessel is segmented in place, using a mast-mountedcutter.

The dismantling of the reactor internals will generate radioactive wasteconsidered unsuitable for shallow land disposal, i.e., GTCC. Althoughthe material is not classified as high-level waste, the DOE has indicatedit will accept this waste for disposal at the future high-level wasterepository.[25] However, the DOE has not been forthcoming 'With anacceptance criteria or disposition schedule for this material, andnumerous questions remain as to the ultimate disposal cost and wasteform requirements. As such, for purposes of this study, the GTCC hasbeen packaged and disposed of as high-level waste, at a cost equivalentto that envisioned for the spent fuel. It is not anticipated that the DOEwould accept, this waste prior to completing the transfer of spent fuel.Therefore, until such time the DOE is ready to accept GTCC waste, it isreasonable to assume that this material would remain in storage at theHBPP3 site.

Feedwater piping is cut from the reactor vessel once the water level inthe vessel (used for personnel 'shielding during dismantling and cuttingoperations in and around the vessel) is dropped below the nozzles.

The estimate further assumes that the fuel failures that occurredreleased fission products at sufficiently low levels that the buildup ofquantities of long-lived isotopes has been prevented from reaching levelsexceeding those which permit the major NSSS components to be shippedunder current DOT regulations and to be buried within therequirements of 10 CFR 61.

The cost to remove and dispose of 48 control rod blades is included inthe estimate.

3.4.3 Main Turbine and Condenser

Due to the internal alpha particle contamination within the turbine,condenser and the associated components, PG&E plans to dismantle thecomponents intact (disassemble pack, and ship without disassembly asmuch as possible) thereby minimizing the potential spread ofradioactive contamination. The current estimate reflects these methods.Each component is surveyed, packaged and shipped a LLRW disposalfacility.

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3.4.4 Plant Systems

Due to the high levels of alpha contamination, mechanical cutting usingsaws and portable pipe cutters is the primary method of removingmechanical and electrical components. The cut areas for internallycontaminated components will be sealed prior to mechanical cutting tomitigate the spread of internal contamination. The work difficultyfactors and the unit cost factors for component removal and for selectivebuilding structural decontamination have been adjusted to account forthe impact of working in areas containing alpha contamination.Mechanical cutting using saws and portable pipe cutters is the primarymethod of component removal used in the estimate.

3.4.5 Humboldt Bay Unit 3 Facilities

Typically surface contamination can be removed by scarification wherethe contamination is limited to a thin surface layer. This technique ismost~effective on smooth, unbroken surfaces. The concrete surfaces wereoriginally uncoated and were subject to additional contaminationdeposits due to failed fuel in early cycles. As such, the contaminationhas likely migrated to depths greater than can be effectively removed bysurface scarification techniques. This condition was observed during theplant stack removal project where the vendor had difficulty in meetingthe free-release criteria for the stack material, even after extensivesurface decontamination. As a result of this expected plant conditionand for the purposes of this estimate, structural material removed aspart of the decommissioning project was assumed to be disposed of at aLLRW disposal facility. Although this same condition is expected toexist in below grade structures, due to the high water table andresulting cost to remove below grade structures, most of thesestructures will be decontaminated and surveyed in place.Decontaminating below-grade structures to free-release is expected to bemore cost-effective than complete removal.

The spent fuel pool walls and tremie concrete beneath the pool is notexpected to be cost effectively decontaminated to meet free-releaselimits. Consequently the estimate assumes an engineered approach toallow the excavation of the soil and, removal of the spent fuel pool wallsand floor. A combination of sheet pile and a freeze seal in the soilsurrounding the spent fuel pool will be installed to facilitate theexcavation and to prevent the in-leakage of groundwater into the arearequiring remediation. Contaminated concrete and soil will be disposedof as radioactive material.

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The concrete pipe tunnel (connecting the radwaste, refueling andturbine buildings) is not expected to be able to be cost effectivelydecontaminated to meet free-release limits. This structure will beremoved in its entirety by excavating the soil surrounding the tunnel,filling the free space with grout, removing, packaging and disposal ofthe material as radioactive material.

Significant alpha contamination exists within primary systems and asfixed contamination in the Refueling, Radwaste, and Turbine buildingsas a result of failed fuel. The presence of alpha contamination will resultin the need for additional radiological controls and will reduce overallworker productivity and the efficiency of component removal activities.The additional controls are designed to protect personnel from receivinginternal alpha dose. These controls will include: additional time for theset up of localized control of the contamination, additional respiratoryprotection requirements and controls, additional resources to performsurveys and establish contamination controls, additional time to obtain,dry, and prepare for counting alpha samples, and additionalnonproductive time for personnel involved in removal activities due tothe alpha contamination. Therefore, the WDF for buildingdecontamination activities in specified work areas has been increasedfrom 50 to 100% to account for these activities.

The caisson surrounding the reactor vessel, which constitutes thecontainment structure, will remain in place. The estimate assumes thatthe removal of the suppression pool liner and the decontamination of theconcrete surfaces beneath the liner should be adequate to precludewholesale removal of the entire caisson structure.

Additional facilities will be required in support of decommissioningactivities. This estimate provides for the following: personneldecontamination facility, protective clothing change-out facility, newradiological area access control point, relocation of the radiologicalcounting room, additional laydown areas (paved and unpaved) forstorage or radioactive material, storage area for waste shippingcontainers, radwaste shipment truck weighing & monitoring area, abulk material drying and storage area. An allowance has also beenprovided in the Period 3 costs for modification and upgrade of theRefueling Building crane. These upgrades are required prior to the startof decommissioning work in the buildings.

The HBPP site is physically small and the current restricted area iswithin 100 feet of the sites boundary. As such, the Radwaste Process

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Facility must be situated in a location to minimize the potentialradiation exposure to the public.

The estimate assumes perimeter fence and in-plant security barrierswill be moved as appropriate to maintain public exposures ALARA.

All buildings scheduled for demolition will be removed to a nominaldepth of three feet below grade, with the decontaminated or non-contaminated sub grade foundations remaining in place. Holes will bedrilled in each of the foundation basemats to allow for natural drainage.Building foundations will be backfilled with clean backfill, and the sitewill be graded and landscaped. All areas affected by dismantlingactivities will be cleaned up, covered with loam, and seeded.

A cost has been included for the survey of structures afterdecontamination and prior to the demolition and disposal of the debris.Decontamination and survey of the structures will allow more efficientstructures demolition with reduced radioactive materials monitoringand controls.

Yard drainage piping and surrounding soils are contaminated and willbe excavated and removed as radioactive material.

The existing circulating water discharge piping will be abandoned inplace.

The discharge canals and portions of the intake canal will beremediated. Contaminated material will be excavated and disposed of aslow-level radioactive waste. The existing intake and discharge canalswill be permanently backfilled with clean material. One third of theintake and discharge backfill cost is assigned to HBPP3.

A small volume of clean asphalt paving' will be shipped to a facility(Portland, Oregon) for disposal.

3.4.6 Transportation Methods

Class A waste (including waste from the reactor vessel segmentation)will be shipped by truck to the EnergySolutions disposal site. Class Band C low-level radioactive waste will be moved overland by truck orshielded van to a yet to be determined site but assumed to be AndrewsCounty, Texas. Building demolition debris and waste soil will be shippedusing intermodal containers via truck to EnergySolutions.

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Portions of the reactor vessel and internal components will betransported in accordance with 10 CFR 71, as Type B and C waste. It isconceivable that the reactor, due to its limited specific activity, couldqualify as Low Specific Activity (LSA) II or III. However, the highradiation levels on the outer surface would require that additionalshielding be incorporated with the packaging to attenuate the dose tolevels acceptable for transport under 49 CFR 173.[26] Contaminatedpiping, components, and structural steel other than the reactor vesseland internals, will qualify as LSA - I, II, or III or SCO-I, or II, asdescribed in 49 CFR Part 173. The contaminated material will bepackaged in Industrial Packages (IP I, II, or III) for transport unlessdemonstrated to qualify as their own shipping containers.

Shielded truck casks will be used to transport highly activated metalproduced in the segmentation of the reactor vessel and internalcomponents. Cask shipments may exceed 95,000 pounds due to theweight of the vessel segments(s), supplementary shielding, cask tie-downs and the tractor-trailer. The maximum curies per shipmentassumed permissible is based upon the license limits of availableshielded shipping casks. The number and curie content of vesselsegments are selected to meet these limits. The number of caskshipments out of the Refueling Building is expected to average one perweek. Non-cask shipments will be limited to five per week.

An allowance has been provided in the estimate for the purchase of 28special trailer beds. State law restricts the size of the trucks on localroads. Since shortened truck beds are not readily available for lease,PG&E has decided to purchase the equipment.

Transportation costs are estimated using published tariffs from Tri-

State Motor Transit.[271

3.4.7 Coordination with Units 1 and 2

Unit 1 and 2 are scheduled to be dismantled concurrent with thedecommissioning of Unit 3.

This estimate includes the cost of removal of the entire site drainagenetwork. A portion of the excavated soil will require remediation andwill be disposed of as radioactive waste. The estimate includes a costelement for the replacement of essential portions of the yard drainagesystem that may still be required for Units 1 or 2.

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I


Wherever shared process systems exist, between the fossil units andUnit 3, the Unit 3 systems will be isolated from the remainingoperational portions. Unit 1 and 2 portions of these systems that containresidual contamination will be remediated and decontaminated.

In accordance with NRC requirements, and based upon knownradioactive contamination, limited exterior radiological surveys of Units1 and 2 will be conducted as part of the Final Site Survey.

3.4.8 Site Conditions Following Decommissioning

It is assumed that the Unit 3 structures and site facilities will bedismantled following their decontamination. Most structures whichcontain below-grade areas (such as the Refuel and Turbine Buildings)will be removed to a nominal depth of 3 feet below grade. Due toexpected radiological conditions, the Radwaste Building will bedemolished in its entirety. The below-grade voids would be backfilledwith clean debris and capped with soil. The site would then be graded toconform to the adjacent landscape. Vegetation would be established toinhibit erosion.

The canals will be backfilled with clean material. The switchyard willremain in place, as well as the site access road.

3.5 ASSUMPTIONS

The following additional factors and conditions were used in developing thedecommissioning cost estimate for HBPP3. Radwaste estimating assumptionsare contained in Section 5.

3.5.1 Estimating Basis

The estimate is performed in accordance with the methodologydescribed in the AIF/NESP-036 study. Decommissioning costs arereported in the year of projected expenditures; however, the values arereported in 2008 dollars for the current estimate. Costs are not inflatedor escalated over the period of performance.

Plant drawings, equipment, and structural specifications, includingconstruction details, were provided by PG&E. TLG personnel preparedthe inventory of plant equipment.

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3.5.2 Labor Costs

Although PG&E will oversee the decommissioning operations, this studyassumes that PG&E augments its workforce with contractors to supportplanning, engineering, procurement, field supervision, and labor. Thisoutside contracted managerial and professional workforce is referred toas the "DOC Staff Cost" in the Period-Dependent Costs line items in theAppendix D detailed cost table.

Utility staffing requirements will vary with the level of effort associatedwith the various phases of the project. Once the decommissioningprogram. starts, only those staff positions necessary to support thedecommissioning program are included. There are no costs reflectedWithin the estimate for the transition of the maintenance organizationto decommissioning, e.g., separation packages, re-training, severance,incentives, etc.

The craft labor required to decontaminate and dismantle the nuclearunit will be acquired through standard contracting practices. Currentlocal craft labor rates were used in the estimate. Costs for siteadministrative, operations, construction and maintenance personnel arebased upon current PG&E salary information. Engineering services forsuch items as writing activity specifications, detailed procedures, andwork procedures are assumed to be provided by the DOC.

3.5.3 General

The existing plant equipment inventory is obsolete and only suitable forscrap as deadweight quantities. No equipment is salvageable. Scrapgenerated during decommissioning is not recognized as having anyvalue because (1) scrap value generally offsets scrap removal andprocessing costs and (2) scrap materials have a relatively low marketvalue. Scrap processing and site removal costs are not included in theestimate.

Clean asbestos will be disposed in an approved landfill. Contaminatedasbestos will be buried as radioactive waste.

PG&E will provide the electrical power for decommissioning.

PG&E will remove all items of furniture, tools, mobile equipment suchas forklifts, trucks, bulldozers, other similar mobile equipment, andother such items of personal property owned by PG&E that will be

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easily removed without the use of special equipment at no cost or creditto the project.

Existing 'warehouses will remain for use by PG&E and itssubcontractors.

The study follows the principles of ALARA through the use of workduration adjustment factors. These factors adjust. the time and cost forperforming tasks after consideration of factors such as use of protectiveclothing and respirators and the' effect of indoctrination and mock-uptraining. These items lengthen a task's duration, which increase thecosts and lengthen the overall schedule. ALARA planning is consideredin the costs for engineering and planning, and in the development of

activity specifications and detailed procedures.

Nuclear liability insurance provides coverage for off-site damage orinjuries due to radiation exposure from equipment and material.Nuclear property insurance provides protection against direct physicaldamage to on-site property by a broad range of causes including,radioactive contamination, fires, floods, etc. This estimate includes thepremium cost for both liability and property insurance. The premiumsare adjusted to reflect the relative changes in risk during the variousphases of decommissioning. Insurance is required until both the Part 50and Part 72 licenses are terminated.

The perimeter fence and in-plant security barriers will be moved asappropriate to conform with the Security Plan in force at the variousstages in the project. Additional survey equipment will be purchased tosupport the large radiological protection program and the Final StatusSurvey (FSS) effort.

The existing electrical switchyard will remain after decommissioning insupport of the remaining site generating units and the utility's electricaltransmission and distribution system.

Underground concrete pipe will be decontaminated and abandoned.Underground steel pipe will be removed, surveyed for contamination,removed from the site, and disposed of as clean scrap. Electricalmanholes will be backfilled with suitable earthen material andabandoned.

The caisson encapsulating the reactor vessel compartment will bedecontaminated and abandoned in place.

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Section 3,.Page 16 of 18

A series of groundwater monitoring wells will be installed to samplegroundwater for 90Sr and other mobile radionuclides. A nominal amount ofmixed waste will be disposed of and 169,000 cubic feet (packaged volume)of contaminated soil will require removal and disposal.

3.6 COST ESTIMATE SUMMARY

A summary of the decommissioning costs and annual expenditures is providedin the cash flow summary in Table 3.la. Table 3.lb is a similar table of annualexpenditures but omits those costs disallowed by the California Public UtilityCommission (CPUC). Table 6.1 provides a breakdown of those samedecommissioning costs into the components of decontamination, removal,packaging, etc. The costs were extracted from the detailed reports inAppendices D & E, which provide a detailed listing of activities and associatedcosts for the decommissioning scenario.

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TABLE 3.1a

SCHEDULE OF EXPENDITURES(thousands, 2008 dollars)1

PG&E Equipment & Contractor Process &Labor Materials Labor BurialYear Other Yearly Totals

1996 - 20082009

20102011

201220132014

20152016

20172018

20192020

7,023

7T,3507,689

7,8587,6056,594

6,127697

370370

370363

10,371

4,38310,291

11,2787,0593,271

2,4320

258

20,392

19,96619,872

21,96424,27413,084

14,0933,830

3,4713,471

3,4713,587

5,780

7,51411,224

19,91734,54912,515

8,3831,850

426

81,80114,860

6,2886,225

7,4009,6475,981

6,0792,006

525525

5252,506

81,80158,427

45,50155,301

68,41683,13341,446

37,1158,3824,3654,365

4,3657,139

52,417 49,345 151,474 102,157 144,367 499,759

1 Columns may not add due to rounding

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TABLE 3.1b

SCHEDULE OF EXPENDITURES,EXCLUDING CPUC DISALLOWANCES

(thousands, 2008 dollars)1

PG&E Equipment & Contractor Process &Labor Materials Labor BurialYear Other Yearly Totals

1996 - 20082009

20102011

201220132014

20152016

20172018

20192020

7,023

7,3507,689

7,8587,6056,594

6,127697

370370

370363

10,3714,352

10,291

11,2787,0593,253

2,432

0

258

20,392

19,84819,872

21,96424,27413,040

14,0933,8303,4713,471

3,4713,587

5,780

7,35411,224

19,917

34,54912,515

8,3831,850

426

81,80114,860

6,2766,225

7,4009,6475,980

6,0792,006

525525

5252,506

81,80158,427

45,17955,301

68,41683,13341,383

37,1158,382

4,3654,365

4,3657,139

52,417 49,295 151,312 101,997 144,353

1 Columns may not add due to rounding

499,373

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4. SCHEDULE ESTIMATE

The schedule for the decommissioning scenario considered in this study follows thesequence presented in the AIF/NESP-036 study, with minor changes to reflect currentplanning and site-specific constraints. In addition, the schedule reflects the spent fuelmanagement plan outlined for HBPP3.

Appendix F presents a GANTT chart schedule for the 2010 SAFSTORdecommissioning alternative. The key activities listed in the schedule do not reflect aone-to-one correspondence with those activities in the Appendix D cost table, butreflect sub-dividing some activities to facilitate understanding and combining othersfor clarity. The schedule was prepared using the "Microsoft Project for Windows"computer software. [28]

4.1 SCHEDULE ESTIMATE ASSUMPTIONS

The schedule estimate reflects the results of a precedence network developed forthe site decommissioning activities, i.e., a PERT (Program Evaluation andReview Technique) software package. The schedule forecast is current as ofDecember 2004. The following assumptions were made in the development of thedecommissioning schedule:

* Spent fuel transfer to the ISFSI was completed in 2008. Only limiteddecommissioning activities have occurred up until now.

* All work (except vessel and internals removal) is performed during an 10-hourworkday, 4 days per week, with no overtime.

e Vessel and internals removal activities are performed by using separate crewsfor different activities working on different shifts, with a correspondingbackshift charge for the second shift.

& Multiple crews work parallel activities to the maximum extent possible,consistent with: optimum efficiency; adequate access for cutting, removal andlaydown space; and the stringent safety measures necessary during demoli-tion of heavy components and structures.

* For removal of plant systems by area, the areas with the longest removaldurations on the critical path are considered to determine the duration.

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4.2 PROJECT SCHEDULE

The period-dependent costs presented in the cost table in Appendix D are basedupon the durations developed in the decommissioning project schedule.Durations are established between several milestones in each project period;these durations are used to establish a critical path for the entire project. Inturn, the critical path duration for each period is used as the basis fordetermining the total costs for these period-dependent items.

A project timeline for the decommissioning alternative is included in this sectionas Figure 4.1.

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FIGURE 4.1

DECOMMISSIONING TIMELINE(not to scale)

Period 3

Planning ActivitiesPlant preparations

Period 4

Systems RemovalPreparations for Reactor Vessel Removal

Dry Fuel Storage

-Period 5 Post-Period 5

" Remove RPV / fuel pool Final term. survey Site restoration DOE fuel shipmentsBuilding Decoa Bluikling tlemolition I Dry fuel storage Dry fuel storage

. Dry fuel storage Dry fuel storage

1/2009 4/2009 412011 10/2012 1/2016 1/2020 12P2020Dewemmiosin ning

Complete

Key Assumutions:1. Decommissioning commences on January of 2009.2. Use of a Decommissioning Operations Contractor (DOC) in later Period 3 planning activities.3. USDOE acceptance of spent fuel shipments occurs in 2020.4. GTCC wastes are removed from the plant site with the spent fuel.

Critical Path Discussion:Following removal of all spent fuel to long term dry storage, the decommissioning critical path is assumed to besequentially composed of preparations for and removing the reactor vessel and spent fuel pool, decontamination ofbuildings, performing final site termination surveys, site restoration, and final spent fuel acceptance and removal by theUSDOE.

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5. RADIOACTIVE WASTE

The objectives of the decommissioning process are the removal of all radioactivematerial from the site that would restrict its future use and the termination of theNRC license. This currently requires the remediation of all radioactive material atthe site in excess of applicable legal limits. Under the Atomic Energy Act,[291 theNRC is responsible for protecting the public from sources of ionizing radiation. Title10 of the Code of Federal Regulations delineates the production, utilization, anddisposal of radioactive materials and processes. In particular, Part 71 definesradioactive material as it pertains to transportation and Part 61 specifies itsdisposition.

Most of the materials being transported for controlled burial are categorized as LowSpecific Activity (LSA) or Surface Contaminated Object (SCO) materials containingType A quantities, as defined in 49 CFR Parts 173-178. Shipping containers arerequired 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 tobe used for the disposal of piping, and small components. Larger components canserve as their own containers, with proper closure of all openings, access ways, andpenetrations. Demolition debris (including concrete) and contaminated soil ispackaged and transported in reusable 25-yard steel intermodal containers.

The volumes of radioactive waste generated during the various decommissioningactivities at the site are shown on a line-item basis in Appendices D, andsummarized in Tables 5.1. The quantified waste volume summaries shown in thesetables are consistent with Part 61 classifications. The volumes are calculated basedon the exterior dimensions for containerized material and on the displaced volumeof 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, aswell as the special handling requirements of the payload. Packaging efficiencies arelower for the highly activated materials (greater than Type A quantity waste),where high concentrations of gamma-emitting radionuclides limit the capacity ofthe shipping canisters.

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

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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 thenuclear plants is primarily generated during Period 4 of SAFSTOR. Material that isremoved from the radiological controlled areas is routed for controlled disposal.Structural demolition debris and soil will be loaded onto intermodal containers andshipped by truck to a LLRW disposal facility. The estimate assumes that PG&E willpurchase 28 shipping trailers that are sized to meet the overland road shippinglimitations of local highways. The cost of the facility and the trailers are included inthe estimate.

For the purpose of this analysis, the EnergySolutions' facility is used as the disposalsite for the majority of the radioactive waste (Class A). This waste was disposed ofat a rate of $62 per cubic foot for "Bulk" waste, and a rate of $252 per cubic foot for"General" waste. These rates include State of Utah taxes and Southwest Compactfees. There are' no currently operating disposal facilities available to PG&E thathave a license to dispose of the more highly radioactive waste (Classes B and C), forexample, generated in the dismantling of the reactor vessel. As such, waste disposalcosts and waste transportation distances were estimated. For purposes ofestimating the Class B and C waste transportation cost it was assumed that thiswaste was shipped to Andrews County, Texas. The cost for disposal for Class B andC waste was $2,916 per cubic foot. This rate includes Southwest Compact fees.These disposal costs for low-level radioactive waste are based on a study sponsoredby PG&E and Southern California Edison Company. The study was done to reflectthe California Public Utilities Commission's desire for these owners toconservatively estimate their nuclear decommissioning LLRW disposal rates.

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Document P01-1604-002, Rev. 01 Section 5, Page 3 of 3

TABLE 5.1

DECOMMISSIONING WASTE DISPOSAL SUMMARY

Waste Volume3

(cubic feet)

Low-Level Radioactive Waste1

Class A2

Class BClass CGTCC

Subtotal

328,2013,083

56617

331,866

Miscellaneous Wastes

Demolition Debris 327,036

Notes: 1 Radioactive waste is classified according to the requirements as delineated in Title 10of the Code of Federal Regulations, Part 61.55.

2 Class A waste includes soil, discharge canal sediment and reactor caisson mixed waste.

3 Column may not add due to rounding.

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6. RESULTS

The analysis to estimate the costs to decommission HBPP3 relied upon the site-specific, technical information developed for previous analyses prepared in 1997,2001, and 2004. The estimate also incorporates additional activities andconsiderations which have been identified as a result of the ongoing planning. Whilenot an engineering study, the analysis provides PG&E with sufficient informationto assess its financial obligations, as they pertain to the eventual decommissioningof the nuclear station.

The estimates described in this report are based on numerous fundamentalassumptions, including regulatory requirements, project contingencies, low-levelradioactive waste disposal practices, high-level radioactive waste managementoptions, and site restoration requirements. The decommissioning scenario reflectsthe fact that all spent fuel has been transferred to the ISFSI and it will remain inthe ISFSI until such time that the DOE can complete the transfer of the assembliesto its repository.

The cost projected to decommission (SAFSTOR 2010) HBPP3 is $499.8 million(including 25% contingency) in 2008 dollars. This total includes $385,520 that hasbeen classified as CPUC's disallowances. The majority of this cost (84.3%) isassociated with the physical decontamination and dismantling of the nuclear unitsso that the licenses can be terminated. Another 15.3% is associated with themanagement, interim storage, and eventual transfer of the spent fuel. Theremaining 0.4% is for the demolition of the designated structures and limitedrestoration of the site.

The primary cost contributors, identified in Table 6.1 are either labor-related orassociated with the management and disposition of the radioactive waste. Programmanagement (staffing) is the largest single contributor to the overall cost. Themagnitude of the expense is a function of both the size of the organization requiredto manage the decommissioning, as well as the duration of the program. It isassumed, for purposes of this analysis, that PG&E will oversee thedecommissioning program, using a DOC to manage the decommissioning labor forceand the associated subcontractors. The size and composition of the managementorganization varies with the decommissioning phase and associated site activities.However, once the operating license is terminated, the staff is substantially reducedfor the conventional demolition and restoration of the site, and the long-term care ofthe spent fuel.

As described in this report, spent fuel has been transferred to the ISFSI and willremain there until the DOE is able to receive it. Dry storage of the fuel under a

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separate license provides additional flexibility in the event the DOE is not able tomeet the current timetable for completing the transfer of assemblies to an off-sitefacility and minimizes the associated caretaking expenses.

The cost for waste disposal includes only those costs associated with the controlleddisposition of the low-level radioactive waste generated from decontamination anddismantling activities, including plant equipment and components, structuralmaterial, filters, resins and dry-active waste. As described in Section 5, disposal ofthe radioactive material, including concrete and structural steel, as well as thehighly radioactive material, is sent to either a currently licensed LLRW facility(Class A waste) or the a yet to be licensed (Class B and C waste) burial site. Highlyactivated reactor vessel components (GTCC), requiring additional isolation from theenvironment, are packaged for geologic disposal. The cost of geologic disposal isbased upon a cost equivalent for spent fuel.

Removal costs reflect the labor-intensive nature of the decommissioning process, aswell as the management controls required to ensure a safe and successful program.Decontamination and packaging costs also have a large labor component that .isbased upon prevailing wages.

The reported cost for transport includes the tariffs and surcharges associated withmoving large components and/or overweight shielded casks overland, as well as thegeneral expense, e.g., labor and fuel, of transporting material to the destinationsidentified in this report. For purposes of this analysis, material is primarily movedoverland by truck.

License termination survey costs are associated with the labor intensive andcomplex activity of verifying that contamination has been removed from the site tothe levels specified by the regulating agency. This process involves a systematicsurvey of all remaining plant surface areas and surrounding environs, sampling,isotopic analysis, and documentation of the findings. The status of any plantcomponents and materials not removed in the decommissioning process will alsorequire confirmation and will add to the expense of surveying the facilities alone.

The remaining costs include allocations for heavy equipment and temporaryservices, 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 finalcessation of plant operations, certain administrative functions do need to bemaintained either at a basic functional or regulatory level. J

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TABLE 6.1

SUMMARY OF DECOMMISSIONING COST CONTRIBUTORS

Work Category Costs 08' $ -. Percent of Costs 04' $(thousands) Total (thousands)

Decontamination 978 0.2% 1,865

Removal 48,360 9.7% 23,899Packaging 9,258 1.9% 3,087

Shipping 11,722 2.3% 5,578Waste Processing & Recycling 675 0.1% 8,877

LLRW Burial 77,596 15.5% 17,446Demolition LLRW Burial 23,872 4.8% 38,528Staffing 132,760 26.6% 70,516Security 45,687 9.1% 4,149License Termination Survey 1,958 0.4% 9,874

Insurance 1,000 0.2% 786Energy 1,254 0.3% 827NRC & EP Fees 5,386 1.1% 1,935NRC ISFSI Fees 1,023 0.2% 3,745ISFSI Capital, O&M, Fixed & Security 57,798 11.6% 66,391

Non-ISFSI Expenditures 28,015 5.6% 20,282Equipment & Supplies 28,797 5.8% 28,520

Engineering 23,618 4.7% '11,121

Total 499,759 100.0% 317,424

CPUC Disallowances

Removal 193 50.1% 172

Packaging 21 5.5% 14Shipping 4 0.9% 5

Waste Processing & Recycling 0 0.0% 30LLRW Burial 165 42.8% 135Equipment & Supplies 3 0.7% 2

Total 386 100.0% 357

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7. REFERENCES

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

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

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

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

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

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

7. DOE/RW-0604, "Project Decision Schedule," U.S. Department of Energy's Officeof Civilian Radioactive Waste Management, January 2009

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

9. U.S. Code of Federal Regulations, Title 10, Part 61.55, "Waste classification"

10. "Low-LevelRadioactive Waste Policy," Public Law 96-573, 1980

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

12. "Establishing an Appropriate Disposal Rate for Low Level Radioactive WasteDuring Decommissioning", Robert A Snyder NEWEX, Revision 0, July 2008

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7. REFERENCES(continued)

13. U.S. Code of Federal Regulations, Title 10, Part 20, Subpart E, "RadiologicalCriteria for License Termination," Federal Register, Volume 62, Number 139 (p39058 et seq.), July 21, 1997

14. "Establishment of Cleanup Levels for CERCLA Sites with RadioactiveContamination," EPA Memorandum OSWER No. 9200.4-18, August 22, 1997

15. U.S. Code of Federal Regulations, Title 40, Part 141.16, "Maximumcontaminant levels for beta particle and photon radioactivity from man-maderadionuclides in community water systems"

16. "Memorandum of Understanding Between the Environmental ProtectionAgency and the Nuclear Regulatory Commission: Consultation and Finality onDecommissioning and Decontamination of Contaminated Sites," OSWER9295.8-06a, October 9, 2002

17. SAFSTOR Decommissioning Plan for the Humboldt Bay Power Plant, Unit No.3, July 1984

18. Preliminary Shutdown Decommissioning Activities Report, PG&E letter HBL-98-002 dated February 27, 1998

19. "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),"NUREG/CR-1575, Rev. 1, EPA 402-R-97-016, Rev. 1, August 2000

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

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

22. "Building Construction Cost Data 2004," Robert Snow Means Company, Inc.,Kingston, Massachusetts

23. Project and Cost Engineers' Handbook, Second Edition, p. 239, AmericanAssociation of Cost Engineers, Marcel Dekker, Inc., New York, New York, 1984

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7. REFERENCES(continued)

24. "Technical Position Paper for Establishing an Appropriate Contingency Factorfor Inclusion in the Decommissioning Revenue Requirements", Study Number:DECON-POS-H002, Revision A, Status: Preliminary (provided by PG&E)

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

26. U.S. Department of Transportation, Title 49 of the Code of Federal Regulations,"Transportation," Parts 173 through 178, 1996.U.S. Code of FederalRegulations, Title 10, Parts 30, 40, 50, 51, 70 and 72, "General Requirementsfor Decommissioning Nuclear Facilities," Nuclear Regulatory Commission,Federal Register Volume 53, Number 123 (p 24018+), June 27, 1988

27. Tri-State Motor Transit Company, published tariffs, Interstate CommerceCommission (ICC), Docket No. MC-427719 Rules Tariff, March 2004,Radioactive Materials Tariff, January 2008

28. "Microsoft Project 2003," Microsoft Corporation, Redmond, WA, 2002

29. "Atomic Energy Act of 1954." (68 Stat. 919)

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Document P01-1604-002, Rev. 0Appendix A, Page 1 of 4

1'

APPENDIX A

WORK DIFFICULTY FACTOR ADJUSTMENTS

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix A, Page 2 of 4

APPENDIX A

WORK DIFFICULTY FACTOR ADJUSTMENT

Respiratory Protective AlphaAREA AREA DESCRIPTION Access Protection ALARA clothing Adjust..

RB1-1 Emergency Condenser 20 25 10 30 200RB1-2 Spent Fuel Pool 20 25 10 30 200RB1-3 Cask Shipping Area 10 25 10 30 150RB1-4 SFP Pumps/Filters 0 25 10 30 150RB1-5 LaydowniCask Washdown General Area 10 25 10 30 150RB1-6 Reactor Vessel Cavity 30 50 40 50 150RB2-1 El -2 Suppression Pool Cooler 10 25 10 30 150RB2-2 Elev. -14, Manlift 10 25 10 30 150RB2-3 Elev. -24, CRD Hydraulic Filters 30 50 40 50 150RB2-4 Elev. -34, Suppression Pool Access Hatch 10 25 20 30 150RB2-5 Elev. -44, CRD Piping 10 50 20 30 150RB2-6 Elev. -54, CRD Trip Accumulators 10 25 20 30 150RB2-7 Elev. -66, Caisson Sump, REDT 10 25 20 30 150RB2-8 Suppression Pool - North 30 50 40 50 150RB2-9 Suppression Pool - South 30 50 40 50 150RB3-1 Cleanup Heat Exchangers 10 50 20 30 150RB3-2 New Fuel Storage/Fuel Pool Coolers 20 25 20 30 150

1RB4-1 Shutdown Heat Exchangers/Pumps 50 50 20 50 200RB4-2 TBDT/Floor Drain Pumps 20 50 20 50 200RB5-1 RFB Roof (HVAC only) 0 25 10 30 100RB5-1 RFB Roof 0-- 25 10 30 100TB 1-1' Main Turbine 75 75 20 50 200TB 1-2 Main Generator/Exciter House 0 0 0 0 100TB1-3 Hydrogen Yard 0 0 10 30 100TB2-1 Main Condenser 75 75 20 50 200TB2-2 Seal Oil Unit/Exciter Swgr 0 0 10 30 100TB3-1 Reactor Feed/Lube Oil/Air Sytems 10 25 10 30 150TB3-2 Propane Engine Generator 0 0 0 0 100TB3-3 2400/480V Transformers 0 0 10 0 100TB4-1 Laundry Drain Tank/Pipe Tunnel 10 25 20 30 150'TB4-2 Pipe Gallery 50 50 20 50 200TB5-1 Anion/Cation/Resin Tanks 10 25 20 30 150TB5-2 Condensate Demineralizers 10 25 20 30 150TB6-1 Air Ejector/Gland Seal Condenser 10 25 10 30 150TB6-2 Vacuum Pump/Condensate Pumps 0 25 10 30 150

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix A, Page 3 of 4

APPENDIX A

WORK DIFFICULTY FACTOR ADJUSTMENT(continued)

Respiratory Protective AlphaAREA AREA DESCRIPTION Access Protection ALARA clothing Adjust.

TB17-1 Main Control Room 0 25 10 30 100TB17-2 Instr Repair/Counting Room/Vent Equip 0 0 10 0 100TB17-3 Locker Room/Personnel Decon 0 0 10 0 100TB7-4 Hot Lab 10 25 10 30 150TB7-5 Demin Control Panel/RFB Access 0 0 10 0 100TB7-6 Hot Lab Attic 10 25 10 30 100TB7-7 RP Office/Count Room 0 0 0 0 100RWl-1 RWB - Concentrator/Pumps/Filters 10 25 20 30 150RW1-2 RWB - Waste Receiver/Hold Tanks 10 25 20 30 150RW1-3 Radwaste Demineralizer 30 50 40 50 150RW1-4 Concentrated Waste Tanks 50 50 20 50 200RW1-5 Resin Disposal Tank 50 50 40 50 200RW1-6 Upper Elevation - RWB 0 25 10 30 100RW1-7 Packaged Radwaste Storage Bldg 0 0 10 0, 100RWl-8 Low Level Waste Storage Bldg 0 0 10 0 100RW1-9 SolidWaste Vault 10 25 20 30 100YD1-1 Main Transformers 0 0 0 0 100YD1-2 CCW Heat Exchangers/Pumps 0 25 10 30 100YD1-5 Intake Structure 0 0 10 30 100YD2-1 Stack - Elev 0'0" .10 25 10 30 150YD2-2 Stack - Elev. 12'0" 10 25 10 30 100YD2-3 Stack - Elev. 26'0" 10 25 10 30 100YD2-4 Condensate/Demin Water Storage Tank 0 25 10 30 150YD2-5 Plant Exhaust Fans 25 50 20 30 150YD2-6 Gaseous Radwaste Holdup Tunnel 30 50 40 50 150HMS1-1 HMS Decon Area 0 25 10 30 100HMS1-2 Calibration Lab 10 25 20 30 100

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Document P01-1604.002, Rev. 0Appendix A, Page 4 of 4

APPENDIXA

WORK DIFFICULTY FACTOR ADJUSTMENT(continued)

AREA AREA DESCRIPTIONRespiratory

Access Protection ALARAProtective

clothingAlphaAdjust.

OTS-1OTS-2OTS-3OTS-4OTS-5OTS-6YARDRBPTBPYDPRWPHMSP

Hydrogen Analyzer/MCC #14Moisture Skid/Sump PumpJet Compressor/Recombiner/Carbon GuardCarbon AdsorbersPipe TunnelHEPA Filter (outside access only)General YardRefueling Building - Embedded PipingTurbine Building - Embedded PipingBuried Yard Piping/Catch Basins, Etc.Radwaste Building - Embedded PipingHot Machine Shop - Embedded Piping

0000

2500

1025201010

0000

5000

50500

5050

0000

2000

2020

02020

0000

3000

30300

3030

100100100100150100100150150100150150

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)

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix B, Page 1 of 4

APPENDIX B

UNIT COST FACTOR DEVELOPMENT

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APPENDIX B

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 orsmall hoist. They will be disconnected from the inlet and outlet piping. The heatexchanger will be sent to the waste processing area.

2. CALCULATIONS

Activity Description Critical Duration(minutes)

Install contamination controls, remove insulation, and mount pipe cutters 60Foam pipe 15Disconnect inlet and outlet lines, cap openings 60Rig for removal 30Unbolt from mounts 30Remove contamination controls 15Remove heat exchanger, wrap in plastic, and send to packing area 60

Critical Duration 270

Work Adjustments (Work Difficulty Factors)

+Duration adjustment(s)Area-specific alpha adjustment (50% of Critical Duration) 135

405+ Respiratory Protection (25% of Critical Duration) 101+ RadiationlALARA (10% of Critical Duration) 41

Adjusted Work Duration 547

+ Protective Clothing (30% of Adjusted Work Duration) 164Productive Work Duration 711

+ Work break adjustment (8.33 % of Productive Work Duration) 59Total Work Duration 770

* Total Work Duration = 770 minutes or 12.833 hours *

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APPENDIX B(continued)

Document P01-1604-002, Rev. 0Appendix B, Page 3 of 4

3. LABOR REQUIRED

Crew Number Duration(hours)

Rate($/hr)

Cost

Laborers 3.00 12.833 $51.54 $1,984.24Craftsmen 2.00 12.833 $62.62 $1,607.20Foreman 1.00 12.833 $65.45 $839.92General Foreman 0.25 12.833 $68.59 $220.05Fire Watch 0.05 12.833 $51.54 $33.07Health Physics Technician 1.00 12.833 $50.45 $647.42

Total Labor Cost

4. EQUIPMENT & CONSUMABLES COSTS

Equipment Costs-Portable electric band saw 1 @ $0.30/hr x 12.833 hrs {97}

Consumables/Materials Costs-Blotting paper 50 @ $0.60 sq ft {2}-Plastic sheets/bags 50 @ $0.18/sq ft {3}-Band Saw blades 1 @ $8.92/hr x .25/ hr {1}-Foam sealant .7 @ $31.92 ! cubic foot {99}

Subtotal Cost Of Equipment And MaterialsOverhead & Sales Tax On Equipment And Materials @ 17.25%

Total Costs, Equipment & Material

TOTAL COST: Removal of Contaminated Heat Exchanger <3000 Pounds:

Total Labor Cost:Total Equipment/Material Costs:Total Craft Labor Man-Hours Required Per Unit:

$5,331.90

$3.85

$30.00$9.00$2.2322.34

$67.42$11.63

$79.05

$5,410.95

$5,331.90$79.05

93.68

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APPENDIX B(continued)

5. NOTES AND REFERENCES

* Work difficulty factors were developed in conjunction with the AIF (nowNEI) program to standardize nuclear decommissioning cost estimates andare delineated in Volume 1, Chapter 5 of the "Guidelines for ProducingCommercial Nuclear Power Plant Decommissioning Cost Estimates,"AIF/NESP-036, May 1986.

* References for equipment & consumables costs:

1. The Wachs Companies, Quote dated 8/20082. McMaster-Carr website on-line catalog3. R.S. Means (2008) Division 015 Section 602-0200 pg 17

* Material and consumable costs were adjusted using the regional indices forEureka, California.

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix C, Page 1 of 7

APPENDIX C

UNIT COST FACTOR LISTING(Representative)

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APPENDIX C

UNIT COST FACTOR LISTING(Representative)

Unit Cost Factor Cost/Unit($)

Removal of clean instrument and sampling tubing, $/linear foot 0.55Removal of clean pipe 0.25 to 2 inches diameter, $/linear foot 5.94Removal of clean pipe >2 to 4 inches diameter, $/linear foot 8.40Removal of clean pipe >4 to 8 inches diameter, $/linear foot 16.16Removal of clean pipe >8 to 14 inches diameter, $/linear foot 22.74

Removal of clean pipe >14 to 20 inches diameter, $/linear foot 32.51Removal of clean pipe >20 to 36 inches diameter, $/linear foot 51.34Removal of clean pipe >36 inches diameter, $/linear foot 62.64Removal of clean valve >2 to 4 inches 107.37Removal of clean valve >4 to 8 inches 161.59

Removal of clean valve >8 to 14 inches 227.42Removal of clean valve >14 to 20 inches 325.10Removal of clean valve >20 to 36 inches 513.38Removal of clean valve >36 inches 626.43Removal of clean pipe hanger for small bore piping 35.52

Removal of clean pipe hanger for large bore piping 130.45Removal of clean pump, <300 pound' 270.78Removal of clean pump, 300-1000 pound 747.95

Removal of clean pump, 1000-10,000 pound 2,975.45Removal of clean pump, >10,000 pound 5,748.35

Removal of clean pump motor, 300-1000 pound 314.65Removal of clean pump motor, 1000-10,000 pound 1,239.21;Removal of clean pump motor, >10,000 pound 2,788.21Removal of clean heat exchanger <3000 pound 1,594.28Removal of clean heat exchanger >3000 pound 4,004.79

TLG Services, Inc.


APPENDIX C(continued)

Unit Cost Factor CostlUnit($)

Removal of clean feedwater heater/deaerator 10,067.99Removal of clean moisture separator/reheater 20,206.49Removal of clean tank, <300 gallons 348.54Removal of clean tank, 300-3000 gallon 1,102.38Removal of clean tank, >3000 gallons, $/square foot surface area 9.15

Removal of clean electrical equipment, <300 pound 148.42Removal of clean electrical equipment, 300-1000 pound 512.28Removal of clean electrical equipment, 1000-10,000 pound 1,024.54Removal of clean electrical equipment, >10,000 pound 2,425.15Removal of clean electrical transformer < 30 tons 1,684.24

Removal of clean electrical transformer > 30 tons 4,850.31Removal of clean standby diesel generator, <100 kW 1,720.30Removal of clean standby diesel generator, 100 kW to 1 MW 3,839.83Removal of clean standby diesel generator, >1 MW 7,949.23Removal of clean electrical cable tray, $/linear foot 13.83

Removal of clean electrical conduit, $/linear foot 6.04Removal of clean mechanical equipment, <300 pound 148.42Removal of clean mechanical equipment, 300-1000 pound 512.28Removal of clean mechanical equipment, 1000-10,000 pound 1,024.54Removal of clean mechanical equipment, >10,000 pound 2,425.15

Removal of clean HVAC equipment, <300 pound 148.42Removal of clean HVAC equipment, 300-1000 pound 512.28Removal of clean HVAC equipment, 1000-10,000 pound 1,024.54Removal of clean HVAC equipment, >10,000 pound 2,425.15Removal of clean HVAC ductwork, $/pound 0.58

Removal of contaminated instrument and sampling tubing, $/linear foot 1.74Removal of contaminated pipe 0.25 to 2 inches diameter, $/linear foot 35.75Removal of contaminated pipe >2 to 4 inches diameter, $/linear foot 46.84Removal of contaminated pipe >4 to 8 inches diameter, $/linear foot 99.14Removal of contaminated pipe >8 to 14 inches diameter, $/linear foot 164.71

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Unit Cost Factor Cost!Unit($)

Removal of contaminated pipe >14 to 20 inches diameter, $/linear foot 239.48Removal of contaminated pipe >20 to 36 inches diameter, $/linear foot 473.70Removal of contaminated pipe >36 inches diameter, $/linear foot 820.49Removal of contaminated valve >2 to 4 inches 566.35Removal of contaminated valve >4 to 8 inches 932.37

Removal of contaminated valve >8 to 14 inches 1,601.39Removal of contaminated valve >14 to 20 inches 2,441.90Removal of contaminated valve >20 to 36 inches 4,691.29Removal of contaminated valve >36 inches 8,310.16Removal of contaminated pipe hanger for small bore piping 136.43

Removal of contaminated pipe hanger for large bore piping 444.12Removal of contaminated pump, <300 pound 1,292.55Removal of contaminated pump, 300-1000 pound 2,817.30Removal of contaminated pump, 1000-10,000 pound 10,813.41Removal of contaminated pump, >10,000 pound 26,570.44

Removal of contaminated pump motor, 300-1000 pound 1,073.11Removal of contaminated pump motor, 1000-10,000 pound 3,315.52Removal of contaminated pump motor, >10,000 pound 7,479.31Removal of contaminated heat exchanger <3000 pound 5,410.95Removal of contaminated heat exchanger >3000 pound 17,054.39

Removal of contaminated feedwater heater/deaerator 40,490.70Removal of contaminated moisture separator/reheater 85,839.84Removal of contaminated tank, <300 gallons 1,892.52Removal of contaminated tank, >300 gallons, $/square foot 49.04Removal of contaminated electrical equipment, <300 pound 863.36

Removal of contaminated electrical equipment, 300-1000 pound 2,080.09Removal of contaminated electrical equipment, 1000-10,000 pound 4,000.50Removal of contaminated electrical equipment, >10,000 pound 7,573.91Removal of contaminated electrical cable tray, $/linear foot 41.74Removal of contaminated electrical conduit, $/linear foot 18.66

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Removal of contaminated mechanical equipment, <300 pound 932.10Removal of contaminated mechanical equipment, 300-1000 pound 2,229.58Removal of contaminated mechanical equipment, 1000-10,000 pound 4,293.69Removal of contaminated mechanical equipment, >10,000 pound 7,573.91Removal of contaminated HVAC equipment, <300 pound 932.10

Removal of contaminated HVAC equipment, 300-1000 pound 2,229.58Removal of contaminated HVAC equipment, 1000-10,000 pound J4,293.69Removal of contaminated HVAC equipment, >10,000 pound 7,573.91Removal of contaminated HVAC ductwork, $/pound 2.50Removal/plasma arc cut of contaminated thin metal components, $/linear in. 4.49

Additional decontamination of surface by washing, $/square foot 9.29Additional decontamination of surfaces by hydrolasing, $/square foot 39:31Decontamination rig hook up and flush, $/ 250 foot length. 7,886.42Chemical flush of components/systems, $/gallon 17.10Removal of clean standard reinforced concrete, $/cubic yard 79.69

Removal of grade slab concrete, $/cubic yard 90.60Removal of clean concrete floors, $/cubic yard 929.62Removal of sections of clean concrete floors, $/cubic yard 3,031.35Removal of clean heavily rein concrete w/#9 rebar, $/cubic yard 114.96Removal of contaminated heavily rein concrete w/#9 rebar, $/cubic yard 2,447.26

Removal of clean heavily rein concrete w/#18 rebar, $/cubic yard 155.74Removal of contaminated heavily rein concrete w/#18 rebar, $/cubic yard 3,237.70Removal heavily rein concrete w/#18 rebar & steel embedments, $/cubic yard 1,242.24Removal of below-grade suspended floors, $/cubic yard 218.31Removal of clean monolithic concrete structures, $/cubic yard 2,447.78

Removal of contaminated monolithic concrete structures, $/cubic yard 2,446.51Removal of clean foundation- concrete, $/cubic yard 2,125.41Removal of contaminated foundation concrete, $/cubic yard 2,276.31Explosive demolition of bulk concrete, $/cubic yard 89.89Removal of clean hollow masonry block wall, $/cubic yard 393.67

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Removal of contaminated hollow masonry block wall, $/cubic yard 393.67Removal of clean solid masonry block wall, $/cubic yard 393.67Removal of contaminated solid masonry block wall, $/cubic yard 393.67Backfill of below-grade voids, $/cubic yard 45.00Removal of subterranean tunnels/voids, $/linear foot 407.55

Placement of concrete for below-grade voids, $/cubic yard 201.08Excavation of clean material, $/cubic yard 8.94Excavation of contaminated material, $/cubic yard 47.52Removal of clean concrete rubble (tipping fee included), $/cubic yard 41.60Removal of containinated concrete rubble, $/cubic yard 33.26

Removal of building by volume, $/cubic foot 0.93Removal of clean building metal siding, $/square foot 4.84Removal of contaminated building metal siding, $/square foot 4.84Removal of standard asphalt roofing, $/square foot 8.03Removal of transite panels, $/square foot 7.51

Scarifying contaminated concrete surfaces (drill & spall), $/square foot 17.46Scabbling contaminated concrete floors, $/square foot 10.37Scabbling contaminated concrete walls, $/square foot 24.51Scabbling contaminated ceilings, $/square foot 83.77Scabbling structural steel, $/square foot .7.82

Removal of clean overhead crane/monorail < 10 ton capacity 2,058.81Removal of contaminated overhead crane/monorail < 10 ton capacity 2,058.81Removal of clean overhead crane/monorail >10-50 ton capacity 4,936.36Removal of contaminated overhead crane/monorail >10-50 ton capacity 4,936.36Removalof polar crane > 50 ton capacity 18,318.72

Removal of gantry crane > 50 ton capacity 77,245.55Removal of structural steel, $/pound 0.70Removal of clean steel floor grating, $/square foot 15.27Removal of contaminated steel floor grating, $/square foot 15.27Removal of clean free standing steel liner, $/square foot 37.73

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Document P01-1604-002, Rev. 0Appendix C, Page 7 of 7


Removal of contaminated free standing steel liner, $/square footRemoval of clean concrete-anchored steel liner, $/square footRemoval of contaminated concrete-anchored steel liner, $/square footPlacement of scaffolding in clean areas, $/square footPlacement of scaffolding in contaminated areas, $/square foot

Landscaping with topsoil, $/acreCost of CPC B-88 LSA box & preparation for useCost of CPC B-25 LSA box & preparation for useCost of CPC B- 12V 12 gauge LSA box & preparation for useCost of CPC B- 144 LSA box & preparation for use

Cost of LSA drum & preparation for useCost of cask liner for CNSI 14 195 caskCost 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

40.8019.1747.4329.8631.27

30,307.602,033.701,800.101,764.38

10,429.50

260.39593.81

10,974.894,017.47

2.15

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Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix D, Page 1 of 10

APPENDIX D

HUMBOLDT BAY POWER PLANT UNIT 32010 SAFSTOR

AREA-BY-AREA ESTIMATE

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0n4t0n444 a., Pn.na-P4nn that 4Nntstsssatnsasg Cast OOn4o2titOACSt02O 0-71= IDt-ttOO.O0 On10,

Appendix .Humboldt Buy Power Plant, Unit 3

2010 SAFSTOR Decommisoioning Cost Estimate('Thousand. of 2008 Dollart)

Antulo Roy o cts TrojM .nsea ts sT P t a noe T' tam L-T. iT . = =t R idn olan n A Oas B 0 a 000 P-a V.s an1non aon tsol a Cast Oont nats Onus Onto nto nto 000 s Onst anu Ona Onu O. .Fast Ca.- CmO.- Cast n se O..Ft.. s. tcos eot

'tool amoco Lktncnc 2003Q~Itool Dsign & LaWn 2000IoI D-tgc L& o I 000

to - Ic L& nwItotI anc a Luatn20Ito' SIac Lnt&Icrnta 2000t - ID n --catnntton 20(

I D-I[• & -1e~n 0

toO:S Oaetoignoa.2nsntauonsJc 2 000

Ca~nc Oanlu.•of Vespon lc

Oupptessioc Ottanosiroo ase Bai &lOOr aIns

0s'a(•oslohpns ChanceonRat1/

IOsdotudal Cltacr~ nleSentaFIPC Claysutansot OIttanusOt~u3Clt Oprto Cal 2 Csat toOpoa

Recol S Dspusal Oet atoi r ntat Ecag •~mcRw Ie& Diaponl eactor 0 Water Cl3o0 tp D OoopzeenTtana

Resoataatpnsal Clan 0 Raontoni Oats Cosa'Retonl0tosnal Con e0& C ltntterasil Osac

p3niOt 00.0000n nOg ndprepoCaration oneoan

3t2.n OAno~ auponti FaC t~etan. PoandFtatocn Lsytont ta

3625 RtplaoemntcatoRadO44note rnt,• n A c• otam• ystw

3b2-c PixtpWstyttet•petyintal~ ttt

Onbn O11~ •XeaLaty nlan g Cots

3bnt 212 -POotIlstltnvetogtto TlanEqiet

an '2 Pobotscal peraod o Ad onnl a~to os t

- 5,302 t3O2 5,303.4 . 34

1 tt2 1...2 te5.- 3527 0.547 2.547

0•00 20.00 20.00

1,31 Wcant

- - . .00

786

2.-'2

1.04

4.8=

5,7201,52

7322,67_

122

3;

4a22

5,7.t1.52

7,93

2-,

2,75

8230 82X30 .8,-1 , 54,286

- . -- tot- - - - 3.50

4.0'31

761 103

73

21.

4183

1218

1,.2

451

622

201126

13070

-b 1 De on eqpýt3b32 0O0 s2ta r eo3 p7n22 00 suctalnPrnu3 Claterotat od003 -1too-303b0t

P20 3b p-. sr-ios3b 4 1 - suppoi..

.4

14

1,4w6 277 173 ,12- t321 750 1,000

143 1,211 4t2t 4,.t2

T0, Co-oet 00-

-.. p.

flootet4O Oe0PemPt.eeit tlet 0

tteeoeo4..Oes,2e, Tot. SOot, OttO TOOIOOTitOA- -, t-ttid-24 em. oAppeo4$t. O Pogeeitef tt

Appendix D

Humboldt Boy Power Pious. Unit

2010 SAFSTOR Decommissioning Cost Estim.te(Thoousds of 20t8 Do.1ar.)

I tt R=W PiOti.S Tr-dor p..lng DlsoMa = C Tm T, 1-• -m- Vr• I C..",:: Cr"-C GlTICC PredC- f Mnh

00.s• LLRW NR0 Spe-t le t. o etrsssd e.itt vet.e Bol Utite _y0m es Stgt tC seit *tmet 015mM tis C eulC tot. Lie esto mog m Retot VeO. tlmC ttoV eetUI et 00l0F C 1U. 5554• 0,l tno ttst

I

-~o 3b - ,•epR-e O1 (1- 1=•W•42 Z0040 Prepe'oittes

0040 701ts401o otolWge e

10411 O tafftts~T

1,0414 U~tdy1, STtsl C

004 T0TALmPtERIO o eCOST

Re ! f Ma•E"'.~e~

55 12 MRR 2on11-813 Re~ 23~ ue al

*mlestetof ~=Sseemoe

l1,14 R2-4

its lit 2-551P~ ~li

V,5ý7 RB34

4151. TB1.2

41011 00511eo.3 llt~lostt

1,513 T s-4,3.514 T 31

M 151 T 1•.a1.5 1 T3-3.1e---re41,517 T4-1

411.1 TB-I1a 1 21 TB-

4a1522 T,- 2•1523 YARD

M -524 yDI-1 cd.- are

•1 5 T_•

4a6 s-dw--ol .gi u•oto o~ o.N[•

1 1.219

gg 1219

o

4

o

7o

7

4ý.125

21

2,1•1

40 123110 10.931

47 192 l9t24 20 00

27 107 1,07

4.,- 23..45 23845

.51 70 2 . 31!4. - 0 2,67t 2,1S 440 014 .i 1007 1,414 1702 1.7.2

- 11 23 21 51 . 0 2 01 43a

121

2o21

3

'424143.

117

21

41

1.3•

lw 410 410

7. 310 3;0

131 575 7

1 5

5 21 21-2 3. .•

3162 1, 1 1,31

3.2 1,815 ,1

.7 4 .64C280 2.0

8O 34 3"111 474 414

1 2 2

3,3.0 1440 14,4Q6

3 242. .25.

121

- 1.U41

$116

- .242

242.

202

- 1,014

- 1,514

Z- I 00

21 113

2,-10 61,000

20,713 1 1,22

241.00 1,.4

U0701 211750

41,259 2001

50,10 4001

110 1,. 66 -51,34 2,516

2.- . 4.1

3102 1,5 79887 ' 711

40522 101- -4343 2.166

- 31

- 781,02,100 10005.

1.1571110 01.,O0

117 20 167697 62 1, 5

1.3 12 3 141

92

4719 -5 1.2 5,.2

151 4 i1. 6

T7G -crelm, I-.

4-

llmo ýlBy Po~ .. n Ui 3A--~d, D, Pete, 4 of 10

Appendix D

Humboldt Boy Power Plont, Unit 32010 SAFSTOR Decommittioning Cost Estimate

(Thootod. of 2008 Doll.r1)

I ^111i,o".t" LLRW NRC t-t Foel F too Pro - Brio -lVol.•, 0urial Utyo1d

.0- t....... t 5ing o..... ..... 04opel t., Tol o, u'.T,. AMn .1•1, t.. .. .. .... .. .. ... .. .l C C.. C GTCc P.o c-l. C2.0..343II Ind0 44. 0444

VI41 4000 l9240813c005n 40A.- ..- I .. , C.. C- C.- c.l. C C_ C.- c. F.t C. F. C C. - C. 1,

P~ole 4• APJ~oeo-eodlCotsc

4l2.1 M44, tl1 Su14240 g t s b, Equr Re-a

4431 Pcpey.,watt4452 a-1-II.-oo0 alowan

41430 In21111t clell 1el1

40a 41 1 e1 1 C- 111 CO,

.4a47 lntney tgt

_ 0 I1 E•rn~t l / glni-n Suppot

414 ISFSI Serating•412 S-u* ataff t

,-• 13 0.. S.1f•s

4414 ,ubto4al1r24 o s

440 TOTAL PRIO4 4 C COST

117

26

26

a. 1.8 10

SO 1'23 1'311 22 232

. 7 54 1541l2 21 183 18

1046,25! 2

U6 1 27

42435• •44

4.- -1, 1,31

1.273

11324

117 31514 50,143

137 9,373 1434 3. 10 1 5 3t

7M6 3,152 3 152407 1,315 1315273 1,'128 1,128

1.c 1.205 1,45

4a2 S 675 8675

1,4 3,47 3341•40• 2:;77 5, 77ý3a6 11 a0 11,;70

11,05 65,515 34715

10034 41,011 410.3

11 4,

17S 3497

4b 1.1. RD.-s & - ti.Rva*N0 Re .-tor VsooIn04r l

1,312 R-oc.10--0

401.3 R34-1 l4012 45 .11ta62 3 R123

V627 Rr1412: RW1-:a•2 R1-6

662 11 -W1-S

SI S..ota -eio 4. Activty st

4 31 104 4 201 1 14 44 444 407 54t 144 1406 119 90.40 22,158 0..15420 5,404 4,09 536 4,.34 243 12,73 341.013 41,413

265

51127

1oaa~

,a27a4

111

1'45

277,

a

21a

716

4

41aSa

a3

171

23

13 7S

237 90 6

1S1 7.4 7.4

N8 4Z2 ,412

32 144 1441. 4=7 473 1; 171257 235 2.5

1 22a .. a0 500

6• 2a1 a81

1,S.X 2,6.9 470

514,27"

1 124

174

132.

21 72

217 125. 2. 7

133,43 2

251,78721S,61S

30974 2 53 392

1.931 414 87.103 348304

24,43 526 -30,504 12200 534

"'!31" 13,g 66

34.,9m4 27,043 14320

14415 50114123,326 .,3117,173 544 242,705 4 Ma0

.303 471 I

233242 2,124

4.28. 34,951

7.4.8 1,C31

2443 1,95 4,51 310 14 10948 42. 14434 43,1704 .. 0,10

TLG Srlýi-s, 1.,

OsotosOsO Os, bososs-btoso ttstaDoses ioskos Osg Coot 0osot~ 0024 SObObOx

--eeso s ,bl-0eOO o,. -A- -osstot, bogs lo 1t

Appendix D0Humboldt Bay Power Plont, Unit 3

2010 SAFSTOR Decoomissioning Cost Eotimote

(Thsoeooods of 2008 D.olls.)

o0""0t LLRW NRC Sptt Fool Wit. p.100. BP.l-tolul Buttlt t

sInd 00 AfltOs¢l~ons CsoStoOse• tests tegs Cotso tests Ctest totlsnOs sos ts ools toots tootsC. Foot to. boot Cu.Fbot 02. FosStoC. Foee Ot.,Lbs. Obshotnor Ohnhooss

bolos 40 AssOdonet0t Costs40421 Coosrsopprs

.b22 A-bt Ie -alIt 2 3 ~ ar-I Wate pakgngLy-nAe

40.44 ft 00 C.1 12o0 5

40.0 oaleioq.txxo

40.46 Ospoolateldoogotoo

4b 3 1 07 ots -ls11 0...s404 32 sto01oalolowane

no42 107140000 ot403 tsool rl00F llteoot t

It 413 Lean stpltCoIt4a H ls

4043 ~ooetoybseosotoax• osO~o

It 4a D_- -dl y uple

4004000-Pspeoo~llsogs 6W gestated

It1 EI t ~nngSpfb 4s12 ISFSI Ope,-atngttsts tIt Ila sa-w s., "oIt III DOC Cýf I$00 415 U1.1 L00 000= ootIt I S-bttal Per-> 4b eod3prreCss

It, TOT-AL RIO-4bCOST

p-•OD ft preFare Buildfings f•D-oItif

c1 116 HM81-

.:113 TMS4c: 1. 1 T-1

R1119 TS

Q 1.1 14 RB1-4

4Z 2.15 TB11

•1.1 T7 1B2

.•1.1.21 TT7.1

-c12a TB726

2 01 a .4 74 04 34. . . .. 28 - 4 3.

021 01 01 1 175 56 85

- 4 - 10 52 210 5l0

31 73 la 685 75 314 314

475 4 01, 514 012040 70 4 130 104

1,822 585a 2,4. 2- )- 2:26'1 -- 72 2,-7 2:'aa

a 3 65 - 211 .72 a72273 3 325 32

990 117 1, 117152 2O 11 171

.'122' a1 51'3 ',9

564 19 .73 173128 2 152 12

l l 835 ,89 11,731 11:731475 44-8 a a 52a 3a 316 8,5. .,1, .5,-2

.0a 12131 2a.8 7.2 1 11,N47 3697 - 29 88a. aa 3 88,01

21C

210

2 2587 - 0

211 2.,246 1... 470

70501 1112,581 55

1051 17

20100 1.40

1'77,4

26614,2,17

51732 17 002 4

1.112,768 07 0 47.4

1.271

1000 024

132

3217 4ý1

1 313723 1,•1417 4

231• 199(2a,14. 2,1734,2 4,2m

11.592 1 12

17,6• 1

.:,465 2 7'10

ý71

131 4.

- 7

I e

5 211a

127

1327

8 3 24 ... 1c3 1 15 24 24

1 0 2 12 1

'1 7 72 11 8

o 10 1]

3 1 21 152 1 7

11 4 50a 3 2.4

16 a 4 58 2. 21•20 a a2 17a 695 69

7 2 71 46 19 19.3 1 911 47 47

9 3 2•18 8

2 2 a . 8 315 315

. 13 1a

1 1 13 3I o 3 21 21a 2 1, 13 61

a41

341

.11

7o1

613

7141.07

32a

5146

00,0502241 Be3

Ponsrflnst 02403Owessss.,.osnr 00. 0ts4o8000 03001120 Ap-.- D, P-s 604lo

Appendix DHumboldt Boy Power Plant. UnitS

2010 SAFSTOR Decommissioning Cost Estimate(F0.ousnods of 20o8 Do.se.)

otofle D.oosonsRl Pock03Ing TI~seon P~wssi~ln tlspei 00,.R T.ol Tal l-..T. Sn r, P-1ge. CT:: R- Vol-. Cl1asA C- BOe ClssC TCfc Prsw-- c-0 tostrawm 03 sow ton tonto Cor 0 Cx Cn two Coo tl to. ts t. c-- - . FC t C t.. C.. t C.F.s C.. F1. 0, Lft. m.ot. shoen

0• .128 TolagI lwl I anolnl1.32 Y21

Ot

0110 YDllI

4I 1I Yll

022123 COss

3= 129 R•,n

4=313• TB7

021.3.17 T sr 2

04 1 0.0•19 CYt

0453 T-1. M0e1 1,10e

4c5 R=~a o1 3 -11f~ ol al

2 7 &o..t• Ol&Co meSog. Fac,l,ty

S32 llt al •

&43 &rp, x

4.4 4 Heýl phy..••plm4c4 ý H-a -- ý, et na

13

573

116

•53

%.7

57

3 .

2

2

1

111

18

1595

78

0

a 31

2,95

3 2

221 1,- 1,213 ,0 .

278 1.;17 1,17ý

1.- 7o 735" o

4 4~ 18 25 1 11

542 18.0 3 1 10.. 8.317 0.317200 0 1 .3 1542 W l.01 6'.01

7 35 51 214 214

7 3 T4• g 194 3 12 11 47 7

188 22 1,280 810 2,3 2.U402 1 02 15 10

11 705 57 270 22

711 91 .1 85

4 3 12 29 12 24

4o 179 7

3 2 11 47

1,12 1. 7315 48 .1

1,1 511 S'3 27-O v 00

114

133

- .30

- 12,387

43

,2,.

.93

.1

e. 313

43 47,-3

2.433

24,1•

=0 !16.

- 4,212 113S 3115 047

42502 1.034

- 31402 1,015

- 0 620 40,707

- 05201 0015

9•,5N -41

4 1700 1,02le1512 1,200

132S 2,.3

- 247,027 7,0301-5.411.4

2S,620 1210

1,54 47.33,97 3,014,628 1,2211369- 1, .

2. -024 150,02

11,0,787 2.024.87

170,254 2,11

2210,C 4:'~l1 - 47.

15,20.00 82034

S 11,354 08

.83

1441.

3.30

14035.

1,7

2,51 '44.220 125

2ý 17. Z 7 :4 31

,a•

8187 23 20833.

438 1,22 1,22191 1,100 1,100

140 0.101 0,10114,72 43.0 43.0

8,303 30,024 12,822

0 1,31 1,701

344 1,2 - ,73 2

1 24 '24

TOW Oeeoo, 102.

llumtold tay P u- plonA Unt4Jgoeeaasiesiasg class tudy 201t tAFSgOt

-.. eaa poaltt-aggd-., tac 0Appe-di lA Page 7Wo 10

Appendix DHumboldt Bay Power Plant, Unit 3

2010 SAFSTOR DecommissioningCtcEstimatefThoosands ol 2008 Dollars)

I ý -.1 oRgi TT-t'na isosa a cT analFt V A B CPt l C GTCC Ptoil C ntratrd-ot Cost Costs Cses Poste ts On., onnn sas Lts ots Costs c. tF..t Ct.- F Cu. 0 - M -t Wt.ss. O Manhotrs

N ý Aý .o- ý,A-et -o.t (--~d)4,46 Dt Idc - -AWeerated

_4 "NR -e 94c 4 E _t "Te"bncge

44410 Elirco-laEtg cEn S-gcSupport,•411 RaaSte gpR-n9 ER-IpJnUe

40 4 12 S F5 t "Cect fo C o ss44414 coccsost

4 s-1~a 4~i•,• e~cDed•Ct414 TOTAL PERIOD 44 COST

PERIOtD -- g40 aselte Osdnos.casrsdaa

A411' C'dastnatd EqStpat Stase•1 2 G.- S-ck

4-1.3 em canhs Soa Caliratioc4414 N- On I41 .. t

44415 RmeaalttstegTaceet

I4c21 Ocacel ft P OA t to T1

42 S -b rl ec 4, Add-I • Cost

4eod4143 Cllatel Costs

.42 P-opcr I ax0Aý 43 ý lý phycA •upW-

.4 44 HeIS equirl M.1e~a

_45 -P-1 .f -A-~re

Aý4 S PSar -ey uOt

4d 4 R E rgn Pln gFe

-44 E ý~~a P - 1 Engln nng uppo

441 ISFSI OPra.ir -otAý 41 Sýrt Stf I-,= -

4 414 utly SsITaco

A, 0 TOTAL RERID 44 COST

134 . 14 1 4 15 4.2 2 21 111 114

371 12 "17 -4

SS 1IS 0 101IS,1 62 28 4283

543 31.-7 2M,274 2 .2 7,1 97,181

iMl 3

- 1104428

ic o ~ rc 1415.7575 127 1 1

22 131.0 2,217 3,7t7 ..043 214444

7

4

1,181

1o 42S2 .3124 95

14. g97-1 1,247

141£ 4.03

3 1632 -0

',22

20,015

1 7444 44 ' t2347 145 10.1757. 4.41 43047

42 4.02 4.02

24 153 1531S65 10,375 10,376

5.26ý2 32,962 32,SS2

281 1 ý741

2 11 1

22560.441

51 687

84, 711,514

A571,1 ASA

2 847.575 1322t94S,511 3,112110,067 3

74c0 292 1.S74

2.,832.536 71.70

IlA1

1l4. 1,1. 4.3

1 18 1.154 1.14

7014 1 W 11 1587

14044 4,044 1431 1241

20,174 144051 IA 044 1446 1,1745

39

1,74142

110 52"17 .•0

7.7.c 410,244

44440314 7,-cc S.0241

TLG terce, aIe.

ThonOoOdO Oa, Po.aooPtoo,0 CoolSOlooonnmmong Pool 0004, 1010 0A000000 toenool'0.0t00-00Ow0

Appendix D

Humboldt Bay Power Plant, Unit 3

2010 SAFSTOR Decommissioning Coot Estimote(Thoostd, of 2008 Dollar.)

I = A-, -p-

Off-.•l LLRW *NRC 5gn Fe- ~ •gl~ t Pr.. I B.-rvI.olu Iu l! -fty -d

•n l~• cktn T~s P •• ~r T~alT= - l T= .U= • Vu Cý.sA C•rSB C-SC GTCC P.- C,• C •00411.g C400 to ce... olnroto BooC . - Co~o . - In..-l -:1. 1

081.1 tOItSm lorl•no00l12 Te= -"•ns

Oi su000.' P01d 0. ACo0y Coo.

0.21 L000 Te10rr010n totoy (oapeoO .00iltno & oqt.pmtoO

"031 tOO t 100000n 0p00ses

leoSwo.er Cot00-oooo0l c0oo1

4,41 1 o-842 -'qe t...

.44 D- dRC We

.A4 s9 IFS s-ran C

0. 10 S 0r110. s O m -

-11 m smbtta PI,• e••cpnetC

.oA 0ý -,t00.'1000. 000

Aeo TOTAL -•IOD Ae COsT

01.0 Fax re010t to 1

0-.. .0 R.0l.,-F~ot..

0.0 lOt Ao0-00.-

0.010 0..., shoe NCt

0ý.4s A.,O.0.101. I 00..00. Co.

5b01 S-bt1otl Per-ot 5b A-0 0r00npeo1 b 31 iina ot

3b2 P-F 5fb• ~y00b002 PSubtOtalPeriod 00A0,t0~ Ct

540 P10 ""`1 00000,40 N1.S11 e 5l lt •1Co Stoot 4 RSF01I0111

00.15b 4 5 EotlIy 00 n Coo

5b 46 Is'sI pftn ot

5b A 7 S.* Saf Cs

1b 4 8 $.ISaf Cs

151 2 1.0 18

151 29 1.. 10

125 200 0.004 1.0041003 010 1.004 1.0.0

1,430 077 1,713 1,7101,430 077 1,7101.110

1 0

192

As 40,119 7,731 0.010

23.

34

2s

2,1.21,457

76 7626

s. 74-4 1.,7.

3

230

4

74,0

273

A10528

340101.271

12"4

0.61

00. 0

152

3- 1

s'. I6 ss 714

3,0W• 1 ý714

•0.== s6,.s 1, - 21.141 0.00 05401 2- 470

41

41 I9 . 1 21172.

2.

155

75

75

105I. 1,560

• . 63 12 7140 1,0.0 - 010 0,o00015 100 1.107

148 14.00 103- 37s 32.4

-8 95 - 14 t.

384 Is6 14050

12 2 1Aa s 13 Ill

1,4. 274 1,6

1 27 24 152

0

1041;

27,0401 3C

TI.00 Ooeo4eoo, 0000.

tOoe.OoJOdOoeCatweCloaa CoOtOwaadmlm.Oo Coo Soal, aIde 0000000 A-- eAtoC Pag taflO

Appendix DHumboldt Bay Power Plant, Unit3

2010 SAFSTOR Decommiosioning Cost EstimateCflsoolaod. of 2008 Dollse.)

A nRmv P-ýlng Tn--~ P.-Nl DI-w -1 T I Io R-m•~ m fo V.-m C.s ýA Class Bt Cý;ý C GTCC P. - Cr- Cteal, -io- tnt seto " Falo ,aa, Rot C 0C oal lb

toll Lsdoy S•lCtn.b4 S-•mPf odeeO O504 TOTAL C-Rt00 d 5b COST

PFeOD ta-Foa st,•. optoa

twa4t Platorotoemt Coett

544 NRc ISF$1 F-

5ý47S SFu•S• C-.N.C4S DOC s.oSods4 tdlla tattt COtae

0tt

.4 St 1aloog Cana

od TOTAL P-O0 5, COST

pERIOD 5d Spnt Fatl aed GTCC shippina

N Sr•e m AS.. Ie R

o. 1 Cutaot rActrmrlCOaS

to-Il 5Otetal Cpae Cm

ColC Ce- Cato CoMttoot CTransfr petoFoItt ~N43 Rar enrg -udge

4 4 NRC ISFSI -~

5-05 EOrgerl -la- F..- 6 ISFSI Operting Costs

.47 s.uw .. , -t.041 OC SOtol

tl 4 S--tootalProPt

5(0 TOTAL -•ROD 5d COST

• 1 ISFSl I ora ttoll SCat tl al•t•

too Otoo Patio to Cot-ter tet Coa

a418 51i 5112_de5 41s 2.6St z

o 1,4Ot 3.Cl 1,1. 5,tt2 tote z.0 1384 g6

: 7,54

14.- 1. 37.0

251 32 284 28'

7m 91 SO1 S0

eat - 0 .00It-I.0S, 21. .1. 1,•

12tt 2,401 2 5,-07 15047

-14.0w 2,.-1 15t2d7 - 5,d7

0,827

14.617

-O,.7

:11 7a59 1

4. g 51 1

17 3• I

551

4ý

2S

I B41

7

137

27:1

57

51

1,705

21.7

57

2,.1

3- 2.30. 513 t ,.07 d,70d C 17 S,.S

5 2 1 16 231 1e4te7 1et4i tS : 1. 16,19 231 147 147 116 107S O d270 4.560

00

TOO Caalna la

00504445 On, No.0450' 04552Oeo.o...loose Os's 05043 0050 030510030 Apee-is, Pý -fs(O

Appendi. DHumboldt Boy Power Plant, Unit3

2010 SAFSTOR Decommissioning Cost Estimate

(Th.osad. of 3008 D.o.,s)

05-560t ILS.O NtC spset FueI so pr.5$45 Sut olo • Oso,.rSlO I Utleysdmia N"'s . ... - I a . - . t 0

RearR= P.=klig TTansf P~sn DisI Ie • l Tm n t -R -o V-.u ClassA C-ss C-vc GC C f s tzz'"C Crn C, • 1.Cnn, oss CSS CS Cu. F.t C.. -ee Cu. F.t Cu. F• CG..TFCtC LX.= Znhour

I A=......

.uny cn .......

Ns ow 5. Peod-0pe Coss

5s42 e•op.Iyas50043 Heasy e0ipeee1 100.

5044 P• •wrlo 0240015 45 u171 08500os

6027 0l1.1y51.500t

5.4 SubtIal -.ero 5. P-rio-.p8r515n

5e0 TOTAL PER-O 5, COST

0.620 SF NAs.00aor

5342 etopta •ely r Aos.. O•51 3 1ut57t0l e50d 5f trl

5425 Ipeoy Oaf Os

510 TOTAL 410.RI25 e5154-OST enl

p 51$•TL

TOA COS TOTA -100MISSCOSN

118 23 141

17 2157 15 114

- ,014 216 1007

10 2181 047 2,n4

26

141

21

114

2,764

l1e

124

270270

33

lie

17.M0170

- - - 10,210

10,370 1,270 21,7"0

- - 2003 10

1 3

12- 7ý-

11 1 1254 1.

See 19 3

.o

3

7ý

S.712

7:41.17..1

334 04 it I 110 1701 . 2.... 3 3 10.340

514 1,750 21,4 4r, 2.415 6,127 22,301 34 - 515 3 e 17 27e.50 20 2784009

Z214 41038 1 .8 3 0 714 50- 71407 271.402 83,50 .75 421.241 7e..7 1,871 0433 e6.23 7 3,0.3 50 17 44053532 -005 0243.02

TOTAL COST TO DECOM-•ONW N CONTIGN-Cy: -W,769 ua, dolar

OTAL NRC LICEN$•S5 TEMAION O$s a U&sOt 401 041 COST 0 0 O1 do,0

P n - 0NAG0T8 COST It 15.^ -t 507 O s a 2 sot.

NONINUCL0AR tEMO1T.ON COST 14 Q 5% OR: 1.871 4560 d01o1.

TOTAL C-s A 0AD0STS VOLUM BURR: M5,237 C-bt F5.8

TOTAL C-~s B & C RA-WST VOLUW• BUMISI: 3,W4 C-• F-

TOTAL GREATR THN CUM C RA- WILUM GERR 17 Cu.4© Feet

050TAL 50" mBOR R 01U0T0 200 ,6 040 LRom

08. 1104C1. 1710t 00= a800.5 0erl 0118 85 48011or 858a1n05 5075181.34 e. 1 T:8 8-4301s043 000500

.. X-. 01- T. 5015I,-

TOO Caes4saa, 'so.

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix E, Page 1 of 2

APPENDIX E

HUMBOLDT BAY POWER PLANT UNIT 32010 SAFSTOR

CPUC COST DISALLOWANCES

TLG Services, Inc.

t•o'ooooonog Cod Rebot.m 2010 00007TOR A0704.0 Pes-loft

Appendit E

Humboldt Bay Power Plant, Unit 3

2010 SAFSTOR CPUC COST DISALLOWANCES('llhousads of 2108 Doll.rs)

Io NRC ".tFo Si. Po . Bto l 00-0 ItUl-ItAoft ton, n vono P~okoaIg FrostoT Potoosg Ottpoog 070.t Cool toto Ut. Coit tonagor0 tReooooo 000,00 ¢OasA-to ¢lsS Coot 0700 Pooo... toO 00,00I odo Aooto.ooto oa. ot -o., too V0 ot 00 000Ot Co ot 00 to t.- Coo 0.Fn o Cot. t- Coo t C 4 0 O tooi too

Omo.1 at 000 Ooo UOOo

pulrtA A tol.0t.lO apn~iod-ton,,:n~ot ctoot

-AL -T o DAC-W O

TOTAltlo tOS TO 50C04008 O

178528.

2020

1 3 3

.21 1

43

43

17,.04 I 41t

17.-4 1,72

67'672

1884 24 512.

CPUC 07OlT.DI O OCt 0 000 0 C 00Cy 0750,

NRC UCEN0 -MN OT tO 0% 0 10,30

NOtN-UoLOARaDEOOOLTiO N OS0Io 220001 04014

TOTAL M-WA$T VOLUME BURIM• 5c- I..~~ Fe

-OAL -RW -AOR -1-5P•IqT 2O5Mho

Humboldt Bay Power Plant Unit 3 Document P01-1604-002, Rev. 0Decommissioning Cost Study 2010 SAFSTOR Appendix F, Page 1 of 2

APPENDIX F

HUMBOLDT BAY 2010 SAFSTORDECOMMISSIONING SCHEDULE

TLG Services, Inc.

If.hoidI By P-w Pkr.. U~it 3D-i..io..hg C~.4 Shtdy 2010 SAFSI'OR

DtP01-160402-ýY R... 0App.ndixF, AW.g 2 f2

HUMBOLDT BAY 2010 SAFSTOR DECOMMISSIONING SCHEDULE

MLG S,-I- 1-c

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