ML14269A032

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Irradiated Fuel Management Plan
ML14269A032
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 09/23/2014
From: Thomas J. Palmisano
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14269A032 (14)


Text

SOUIHERN CALIFORNIA Thomas 1. Palmisano FDISO*.Vice President & Chief Nuclear Officer

~JEDISON' An EDISON INTERNATONA01 Company 10 CFR 50.82(a)(4)(i)

September 23, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3 Irradiated Fuel Management Plan Reference Letter from P.T. Dietrich (SCE) to the U.S. Nuclear Regulatory Commission, dated June 12, 2013;

Subject:

Certification of Permanent Cessation of Power Operations, San Onofre Nuclear Generating Station, Units 2 and 3

Dear Sir or Madam:

On June 12, 2013, SCE submitted the referenced letter to the U.S. Nuclear Regulatory Commission (NRC) certifying the permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, in accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), Southern California Edison (SCE) is required to submit an Irradiated Fuel Management Plan (IFMP), Site Specific Decommissioning Cost Estimate (DCE) and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.

The SONGS, Units 2 and 3 IFMP is attached. The DCE and PSDAR are being concurrently submitted under separate cover letters. The IFMP represents SCE's current plans and is subject to change as the project progresses. In particular, the Independent Spent Fuel Storage Installation location, and storage equipment and vendor(s) have not been selected. The decision making and procurement activities are underway but have not been finalized.

Changes to significant details will be included in subsequent revisions to the IFMP as required by 10 CFR 50.54(bb). Financial assurance information will be provided on an annual basis as required by 10 CFR 50.75(f)(1).

This letter does not contain any new commitments.

If there are any questions or if additional information is needed, please contact me or Ms. Andrea Sterdis at (949) 368-9985.

Sincerely, P.O. Box 128 San Clemente. CA 92672 0 D (949) 368-6575 PAX 86575 Fax: (949) 368-6183 Toni.Palmisano@sce.comn

Enclosure:

San Onofre Nuclear Generating Station Units 2 and 3 Irradiated Fuel Management Plan cc:

M. L. Dapas, Regional Administrator, NRC Region IV T. J. Wengert, NRC Project Manager, SONGS, Units 2 and 3 T. J, Warnick, NRC Project Manager, San Onofre Units 2 and 3 Decommissioning R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Health Services, Radiologic Health Branch 2

SONGS Units 2 and 3 Irradiated Fuel Management Plan I.

Background and Introduction On June 12, 2013, Southern California Edison (SCE) submitted a letter to the U.S.

Nuclear Regulatory Commission (NRC) (Reference 1) certifying the permanent cessation of operations at San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 effective June 7, 2013, in accordance with 10 CFR 50.82(a)(1)(i). All fuel was removed from the SONGS Units 2 and 3 reactor vessels and placed in their respective spent fuel pools as certified in accordance with 10 CFR 50.82(a)(1)(ii) (References 2 and 3).

Pursuant to 10 CFR 50.54(bb), licensees are required to submit a plan for the management of irradiated fuel until title and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. The Irradiated Fuel Management Plan (IFMP) is required to be submitted to the Commission either five years before expiration of the Operating License or within two years following permanent cessation of operations, whichever occurs first. Therefore, the SONGS Units 2 and 3 plans are required to be submitted prior to June 7, 2015, two years following the cessation of operations. This submittal constitutes SCE's IFMP for SONGS Units 2 and 3, submitted on behalf of itself and the other SONGS Participants responsible for the funding of the SONGS decommissioning. The other SONGS Participants are the City of Anaheim, the City of Riverside, and San Diego Gas &

Electric Company (SDG&E).

EnergySolutions, LLC has prepared a site-specific decommissioning cost estimate (DCE) for SONGS Units 2 and 3 (Reference 15). The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the IFMP, along with license termination and site restoration activities and costs. This DCE is being submitted concurrent with the Post-Shutdown Decommissioning Activities Report (PSDAR, Reference 4) and this plan. The assumptions regarding the United States Department of Energy (US DOE) acceptance of irradiated fuel is consistent with the EnergySolutions DCE and is based on testimony filed with the California Public Utility Commission (Reference 13). The SONGS Units 2 and 3 DCE and this IFMP are based on commencement of industry-wide acceptance of spent fuel by US DOE in 2024.

Page 1 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan II.

Irradiated Fuel Management Strategy The safe initial interim storage of SONGS Units 2 and 3 irradiated fuel will be "wet storage" in each unit's respective spent fuel pool. The spent fuel pools will be isolated from their normal support systems and those systems replaced by stand-alone cooling and filtration units (also termed a "spent fuel pool island"). Doing so facilitates earlier system abandonment and parallel decommissioning activities.

Subsequently, all irradiated fuel in the SONGS Units 2 and 3 spent fuel pools will be safely transferred to "dry storage" at the common Independent Spent Fuel Storage Installation (ISFSI) located on the SONGS site. Dry storage is also considered interim storage pending transfer to the US DOE.

A total of 1,726 irradiated fuel assemblies have been generated in SONGS Unit 2 and 1,734 irradiated fuel assemblies have been generated in SONGS Unit 3, for a total of 3,460 irradiated fuel assemblies. At present, 792 SONGS Units 2 and 3 irradiated fuel assemblies have already been transferred to the common ISFSI. The remaining 2,668 irradiated fuel assembles will be loaded into Dry Shielded Canisters (DSCs) and transferred to the ISFSI.

The current ISFSI is located inside the Owner Controlled Area. It was constructed to accommodate SONGS Unit 1 irradiated fuel and provides additional capacity for a limited amount of SONGS Units 2 and 3 irradiated fuel.

The ISFSI currently contains 18 DSCs storing Unit 1 fuel and Greater than Class C (GTCC) waste. The ISFSI also contains 33 DSCs which store Units 2 and 3 fuel. All of the fuel on the ISFSI is stored in Transnuclear NUHOMS Model Number-24PT1 or PT4 DSCs.

The major IFMP activity phases, including start and end dates and associated costs for each period are identified in Table 1. The identified Spent Nuclear Fuel (SNF) Periods are developed in and align with the site-specific DCE (Reference 15).

The current plans are to obtain necessary permits for the ISFSI to be expanded to accommodate the remaining inventory of the SONGS Units 2 and 3 spent fuel pools.

SONGS plans to commence the movement of irradiated fuel from the Unit 2 and Unit 3 pools to the ISFSI in 2017. SONGS expects to complete the transfer in 2019. Additional DSCs will be procured from one or more of the available dry storage system suppliers beginning in 2014. An additional 47 DSCs will be required for the SONGS Unit 2 irradiated fuel and an additional 44 DSCs will be required for the SONGS Unit 3 Page 2 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan irradiated fuel (depending on the capacity of the selected system and the number of DSCs needed to store GTCC waste and other materials). The spent fuel pool inventory is forecast to be transferred to the ISFSI no later than the end of 2019.

The US DOE Standard Contracts for acceptance and disposal of spent nuclear fuel and high level waste contain the basis for the initial ranking of industry-wide spent fuel acceptance obligations based upon the date of permanent removal of the spent nuclear fuel from service ("oldest fuel first" allocation). Those Standard Contracts also contain provisions allowing for "exchanges" of acceptance obligations, and priority for retired units. Given the US DOE's lack of performance, a common assumption for purposes of this fuel management plan is to base acceptance projections upon application of an "oldest fuel first" allocation scheme to a projected start date for repository operations.

This plan is based upon a 2024 start date (Reference 13) for US DOE acceptance of spent fuel from the industry and the SONGS Units 2 and 3 positions in the queue. As indicated in Table 3, SCE is therefore assuming all fuel will be removed from the SONGS site as of 2049. Based on this assumption, the ISFSI will be subsequently decommissioned by the 2051 final license termination date.

Ill.

Financial Assurance The regulations (10 CFR 50.54(bb)) also require that funding adequacy be demonstrated to support the irradiated fuel management plan.

The cost of twelve (12) additional DSCs to be stored on the current ISFSI was funded from sources other than the Nuclear Decommissioning Trusts (NDT) (Reference 5), as are the costs associated with ongoing storage of Unit 1 spent fuel at the GE-Hitachi Nuclear America LLC's Morris Operation ISFSI located in Morris, Illinois. Table 1 includes the costs of procurement and construction of the expanded ISFSI capacity and all loading costs. Operation of the spent fuel pools is modeled as being discontinued in 2019 after all of the fuel has been transferred to dry storage. ISFSI operations continue until the US DOE is able to complete the transfer of the SONGS fuel to a repository or interim storage facility, which is currently assumed to occur by 2049.

SONGS management is committed to providing consistent and up-to-date information to all of its stakeholders and regulators. Aspects of the SONGS Nuclear Decommissioning Trust Fund are regulated by both the California Public Utilities Commission (CPUC) and the NRC. Previous Decommissioning Cost Estimates (DCEs) were updated and submitted to the CPUC as part of the Nuclear Decommissioning Cost Triennial Proceedings (Reference 5). Financial assurance reports including the balances and expenditures for SONGS Unit 1 were supplied to the NRC (as required by 10 CFR Page 3 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan 50.82(a)(8)(v)) annually (most recently in Reference 6) and balances for SONGS Units 2 and 3 were submitted on a biennial basis (as required by 10 CFR 50.75(f)(1)) (most recently in Reference 7). Reports regarding ISFSI costs and decommissioning funding assurance for these costs were summarized triennially as required by 10 CFR 72.30(c)

(most recently in Reference 8). Going forward, balances and expenditures will be supplied annually to the NRC for all three units and the ISFSI.

An updated site-specific DCE will be concurrently submitted to the NRC. As summarized in Table 1, this plan is based on decommissioning and the termination of the license by 2051, approximately 38 years following the permanent cessation of operations. The summary in Table 1 includes the funds for dry storage through 2049 and final release of the ISFSI in 2051.

Tables 4A and 4B summarize the estimated annual spending for all decommissioning activities (License Termination, Spent Fuel Management, and Site Restoration), and combined NDT current balances in 2014 dollars. Table 2 reflects key tasks addressed by the NRC staff in a recent safety evaluation.

The total of all Nuclear Decommissioning Trust funds balances for SONGS Units 2 and 3 was $3,926 million as of December 31, 2013 (Reference 9). Evaluation of the projected cash flows assuming earnings on existing balances as permitted by NRC regulations demonstrates the adequacy of the existing funds to cover all aspects of decommissioning, including the costs of irradiated fuel management. This demonstrates that the balance in the decommissioning trust is adequate to fund all aspects of decommissioning as well as the costs of irradiated fuel management. As decommissioning proceeds the DCE will be updated as appropriate and annual updates of spending and trust fund balances will be docketed as required.

IV.

Regulatory Activities The IFMP assumes that the SONGS Participants will make withdrawals from their nuclear decommissioning trusts for spent fuel management purposes. The SONGS Participants have collected funds from ratepayers and accumulated funds in the nuclear decommissioning trusts for the purpose of funding three primary categories of costs: (1)

License Termination; (2) Spent Fuel Management; and (3) Site Restoration. On November 18, 2013, SCE filed a Tier 3 Advice Letter (Reference 10) with the CPUC to obtain authorization for the use of funds in the near term and to establish processes for further CPUC oversight of withdrawals from the nuclear decommissioning trusts. On February 21, 2014, SDG&E filed a similar letter (Reference 14) with the CPUC. In addition to authorizing and overseeing the withdrawals, the CPUC is expected to Page 4 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan designate the specific amounts from the existing fund balances that are available for License Termination and therefore subject to 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(2). The fund balances would then be allocated to separate subaccounts within each trust fund and, as such, available for spent fuel management and site restoration, consistent with the requirements of 10 CFR 50.75, 10 CFR 50.82, and 10 CFR 72.30.

To confirm such access, SCE requested (Reference 11) an exemption from 10 CFR 50.75 and 50.82 to authorize the use of trust funds to pay for spent fuel management and site restoration including other transitional costs. The regulations limit the use of the nuclear trust fund to decommissioning costs. This exemption was granted on September 5, 2014 (Reference 12).

The SONGS Participants responsible for decommissioning will periodically review the amount of cash contributions required for the decommissioning fund to ensure that withdrawals do not inhibit the ability of the licensee to complete NRC License Termination, Spent Fuel Management, and Site Restoration. The SONGS Participants will obtain authorization as necessary through the ratemaking processes to provide for further contributions if required.

In accordance with 10 CFR 50.82(a)(8)(vii), SONGS will annually submit to the NRC by March 3 1st a report on the status of the funding for managing spent fuel. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing the spent fuel, the projected cost of managing spent fuel until title to the fuel and possession of the fuel is transferred to the Secretary of Energy, and if the funds accumulated do not cover the projected cost, a plan to provide additional funding assurance using one of the methods allowed by NRC regulations.

Page 5 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan V.

References

1. Letter from P. Dietrich, Southern California Edison, to U.S. Nuclear Regulatory Commission,

Subject:

Dockets 50-361 and 50,362, Certification of Permanent Cessation of Power Operations, San Onofre Nuclear Generating Station Units 2 and 3, dated June 12, 2013

2. Letter from P. Dietrich, Southern California Edison, to U.S. Nuclear Regulatory Commission,

Subject:

Dockets 50-361 Permanent Removal of Fuel from Reactor Vessel, San Onofre Nuclear Generating Station, Unit 2, dated July 22, 2013

3. Letter from P. Dietrich, Southern California Edison, to U.S. Nuclear Regulatory Commission,

Subject:

Dockets 50-362 Permanent Removal of Fuel from Reactor Vessel, San Onofre Nuclear Generating Station, Unit 3, dated June 28, 2013

4. SONGS Units 2 and 3 Post-Shutdown Decommissioning Activities Report, San Onofre Nuclear Generating Station
5. Decommissioning Cost Estimate, 2013 Scenario, dated July 11, 2013, ABZ, Incorporated.

Used in support of Nuclear Decommissioning Cost Triennial Proceeding, Exhibit SCE-12

6. Letter from Richard C. Brabec, Southern California Edison to U. S. Nuclear Regulatory Commission,

Subject:

10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v-vii) Decommissioning Funding Status Report San Onofre Nuclear Generating Station Unit 1 dated March 31, 2014

7. Letter from Richard C. Brabec, Southern California Edison to U. S. Nuclear Regulatory Commission,

Subject:

10 CFR 50.75(f)(1) Decommissioning Funding Status Report, San Onofre Nuclear Generating Station Units 2 and 3 dated March 31, 2014

8. Letter from Douglas R. Bauder, Southern California Edison U. S. Nuclear Regulatory Commission,

Subject:

10 CFR 72.30 ISFSI Decommissioning Funding Plan, San Onofre Nuclear Generating Station Units 1, 2 & 3 dated December 14, 2012

9. Letter from Richard C. Brabec, Southern California Edison to U.S. Nuclear Regulatory Commission,

Subject:

San Onofre Nuclear Generating Station, Units 2 and 3 Access to Nuclear Decommissioning Trust Funds, Supplemental Information, Dated March 12, 2014

10. Letter from Megan Scott-Kakures, Southern California Edison, to Public Utilities Commission of the State of California Energy Division Submitting a Tier 3 Advice Letter Requesting (1)

Authorization of Disbursements from the Master Trusts for San Onofre Nuclear Generating Station; (2) Approval of Tier 2 Advice Letter to Process for Future Disbursements; (3)

Designation of Trust Amounts Set Aside for License Termination; and (4) Approval of Balancing Account, dated November 18, 2013 Page 6 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan

11. Letter from Tom J. Palmisano, Southern California Edison, to U. S. Nuclear Regulatory Commission,

Subject:

San Onofre Nuclear Generating Station Units 2 and 3, Access to Nuclear Decommissioning Trust Funds, dated February 13, 2014

12. Letter from Thomas Wengert, Nuclear Regulatory Commission to Tom J. Palmisano, Southern California Edison, Granting Exemptions from the Requirements of 10 CFR 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(2) (TAC Nos. MF3544 an MF 3545) dated September 5, 2014
13. Testimony on Nuclear Decommissioning of SONGS 2 & 3 and Palo Verde, exhibit No. SCE-2, dated December 21, 2012
14. Letter from Clay Faber, San Diego Gas & Electric, to Public Utilities Commission of the State of California submitting a Tier 3 Advice Letter Requesting (1) Designation of SONGS 2&3 Costs Incurred During and After June 2013 As Decommissioning Costs Eligible for Payment with Trust Funds; (2) Authorization of Disbursements from the Master Trusts for San Onofre Nuclear Generating Station; (3) Approval of Tier 2 Advice Letter Process for Future Trust Disbursements; (4) Acknowledgement That Funds Have Been Collected From Ratepayers and Have Been Accumulating In The Trusts To Be Used for NRC and Non-NRC Jurisdictional Decommissioning Cost Categories; and (5) Designation of an Allocation of the SDG&E SONGS 2&3 Trusts Among the Major Decommissioning Cost Categories, dated February 21, 2014
15. EnergySolutions Document No. 164001, "2014 Decommissioning Cost Analysis of the San Onofre Nuclear Generating Station Units 2 and 3" Page 7 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan Table 1 Irradiated Fuel Management Plan - Summary Schedule Cost and Schedule Summary (2014 Dollars in thousands)

Spent Fuel 10 CFR 50.54(bb)

Period No.

Period Description Start End Years Unit 2 Unit 3 Total Cost Cost Cost SNF Pd 1 Spent Fuel Management Transition 6/7/2013 12/31/2013 0.56

$63,891

$66,105

$129,997 SNF Pd 2 Spent Fuel Transfer to Dry Storage 1/1/2014 6/1/2019 5.41

$344,629

$372,193

$716,822 SNF Pd 3 Dry Storage During Decommissioning -

6/1/2019 12/5/2031 12.51

$61,425

$61,425

$122,849 Units 1, 2 and 3 SNF Pd 4 Dry Storage Only - Units 1, 2 and 3 12/5/2031 12/31/2035 4.07

$29,383

$29,383

$58,765 SNF Pd 5 Dry Storage Only - Units 2 and 3 12/31/2035 12/31/2049 14.00

$107,326

$107,326

$214,653 SNF D&D Pd 1 ISFS1 License Termination 12/31/2049 5/6/2050 0.34

$1,260

$1,260

$2,520 SNF D&D Pd 2 ISFS1 Demolition 5/6/2050 9/8/2051 1.34

$15,295

$15,295

$30,590

_ Category Total 1

138.23 1$623,209 [$652,987 1$1,276,196 Page 8 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan Table 2 Major Fuel Management Tasks Major Fuel Management Task Direct Explanatory or Additional Details Estimate Schedule Costs in DCE in DCE (Note 1)

(in Thousands)

Estimated cost for Islanding

$ 22,183 Estimated Costs to isolate spent fuel e No additional costs are required 6/2015 pools and fuel handling systems for fuel handling systems. Cranes (Note 2) are single-failure proof ISFSI in operation; so, current costs are for wet/dry combination.

$ 396,391 Estimated cost to construct an ISFSl 0

Costs are associated with capacity 6/2019 or a combination of wet/dry storage expansion (pad and associated (Note 3) facility costs, DSCs and HSMs).

Operational and maintenance costs are NOT readily separable Estimated annual cost for the (fuel storage support vice other operation of the selected option demands); but, are included in Table 4 cash flows.

Estimated cost for preparation, Off-site transportation costs are

$ 6,742 Thru packaging and shipping of fuel to part of contract with US DOE.

DOE (Note 4) 12/2049 Estimated cost to decommission the Funded from both Unit 1 and

$ 33,110 2049-ISFSI Units 2&3 Decommissioning Trust 2051 Funds.

(Note 5)

See Section II for selected Brief discussion of selected storage method N/

N/A method or methods and estimated methods.

N/A N/A time frame for these activities See Table 1 for time frames.

Notes:

1. Tasks from NRC Safety Evaluation (SE) on Kewaunee Integrated Fuel Management Plan dated, September 28, 2009, publically available under ADAMS Accession No. ML092321079
2.

Cost based on DCE, DECON Pd 2, Items 2.23 through 2.30

3.

Cost based on DCE, SNF Pd 2, Items 8.05 through 8.13

4.

Cost based on SNF Pd 4 and SNF Pd 5, Item 2.03

5.

Cost based on DCE, total of SNF D&D Pd 1 and SNF Pd 2 Page 9 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan Table 3 SONGS Unit 2 & Unit 3 Spent Fuel Shipping Schedule 2024 DOE Acceptance On-Site Inventory (Beginning of the Year)

On-Site Transfers (During Off-Site Transfers (During Year)

Year)______

Unit 2& 3 Units 2 &3 Units 2& 3 Units 2 Unit 2& 3 Fuel Fuel Fuel

&3 Fuel Unit 2 & 3 Unit 2 Unit 3 Unit 2 & 3 Unit 2 & 3 Assemblies Assemblies Assemblies Canisters Assemblies Canisters Assemblies Assemblies Assemblies Canisters in Wet in Dry in On-Site in Transferred Transferred Transferred Transferred Transferred Transferred Year Storage Storage Storage ISF51 to SF51 to SFS1 to DOE to DOE to DOE to DOE 2014 2668 792 3460 33 0

0 0

0 0

0 2015 2668 792 3460 33 0

0 0

0 0

0 2016 2668 792 3460 33 0

0 0

0 0

0 2017 2668 792 3460 33 768 24 0

0 0

0 2018 1900 1560 3460 57 1536 48 0

0 0

0 2019 364 3096 3460 105 364 13 0

0 0

0 2020 0

3460 3460 118 0

0 0

0 0

0 2021 0

3460 3460 118 0

0 0

0 0

0 2022 0

3460 3460 118 0

0 0

0 0

0 2023 0

3460 3460 118 0

0 0

0 0

0 2024 0

3460 3460 118 0

0 0

0 0

0 2025 0

3460 3460 118 0

0 0

0 0

0 2026 0

3460 3460 118 0

0 0

0 0

0 2027 0

3460 3460 118 0

0 0

0 0

0 2028 0

3460 3460 118 0

0 0

0 0

0 2029 0

3460 3460 118 0

0 0

0 0

0 2030 0

3460 3460 118 0

0 48 48 96 4

2031 0

3364 3364 114 0

0 192 96 288 12 2032 0

3076 3076 102 0

0 120 120 240 10 2033 0

2836 2836 92 0

0 0

96 96 4

2034 0

2740 2740 88 0

0 112 120 232 8

2035 0

2508 2508 80 0

0 96 96 192 6

2036 0

2316 2316 74 0

0 128 96 224 7

2037 0

2092 2092 67 0

0 0

0 0

0 2038 0

2092 2092 67 0

0 96 128 224 7

2039 0

1868 1868 60 0

0 96 96 192 6

2040 0

1676 1676 54 0

0 96 96 192 6

2041 0

1484 1484 48 0

0 0

0 0

0 2042 0

1484 1484 48 0

0 96 96 192 6

2043 0

1292 1292 42 0

0 96 96 192 6

2044 0

1100 1100 36 0

0 96 96 192 6

2045 0

908 908 30 0

0 128 96 224 7

2046 0

684 684 23 0

0 96 128 224 7

2047 0

460 460 16 0

0 96 230 326 11 2048 0

134 134 5

0 0

0 0

0 0

2049 0

134 134 5

0 0

134 0

134 5

20S0 1 0

1 0

1 0

1 0

1 0

1 0

1 0

1 0

1 0

1 0

Note: The number of canisters listed are for storage of irradiated fuel not GTCC waste.

Page 10 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan Table 4A SONGS Unit 2 Decommissioning Funding Plan Total Radiological Spent Fuel Site Total Available Year Decontamination Management Restoration Decommissioning Funds Decotamnatin MnageentCosts 2013

$25,749

$63,891

$49,067

$138,706

$1,847,000 2014

$79,799

$35,719

$15,089

$130,607 2015

$69,196

$106,308

$7,439

$182,943 2016

$54,541

$59,308

$3,730

$117,579 2017

$111,903

$59,308

$1,957

$173,168 2018

$47,520

$59,308

$0

$106,828 2019

$108,328

$27,554

$13,539

$149,420 2020

$185,482

$4,908

$36

$190,426 2021.

$79,081

$4,908

$36

$84,026 2022

$54,785

$4,908

$1,927

$61,621 2023

$158,207

$4,908

$36

$163,151 2024

$37,930

$4,908

$16,848

$59.687 2025

$2,922

$4,908

$44,621

$52,451 2026

$2,922

$4,908

$19,412

$27,243 2027

$2,922

$4,908

$22,469

$30,299 2028

$2,922

$4,908

$31,688

$39,518 2029

$2,922

$4,908

$66,873

$74,704 2030

$2,922

$4,908

$71,867

$79,697 2031

$2,055

$5,089

$23,181

$30.325 2032

$2,122

$7,214

$0

$9,336 2033

$0

$7,214

$0

$7,214 2034

$0

$7,214

$0

$7,214 2035

$0

$7,228

$0

$7,228 2036

$0

$7,665

$0

$7,665 2037

$0

$7,665

$0

$7,665 2038

$0

$7,665

$0

$7,665 2039

$0

$7,665

$0

$7,665 2040

$0

$7,665

$0

$7,665 2041

$0

$7,665

$0

$7,665 2042

$0

$7,665

$0

$7,665 2043

$0

$7,665

$0

$7,665 2044

$0

$7,665

$0

$7,665 2045

$0

$7,665

$0

$7,665 2046

$0

$7,665

$0

$7,665 2047

$0

$7,665

$0

$7,665 2048

$0

$7,665

$0

$7,665 2049

$0

$7,667

$0

$7,667 2050

$0

$9,974

$20,177

$30,151 2051

$0

$6,573

$11,928

$18,500 2052

$0

$0

$1,377

$1,377 Notes: Costs are in 2014 dollars (in thousands) and are not escalated from the base year SONGS Unit 2 Trust fund balances at end of 2013 were $1,847,000 Page 11 of 12 Revision 0

SONGS Units 2 and 3 Irradiated Fuel Management Plan Table 4B SONGS Unit 3 Decommissioning Funding Plan Yer Radiological Spent Fuel Site Deommssonn Fundsbl Yer Decontamination Management Restoration D commstsing Fud 2013

$26,566

$66,105

$49,067

$141,739

$2,079,400 2014

$78,964

$40,156

$15,969

$135,089 2015

$74,096

$112,024

$9,390

$195,509 2016

$61,451

$64,405

$25,227

$151,083 2017

$40,631

$64,405

$3,799

$108,835 2018

$86,348

$64,405

$0

$150,753 2019

$96,521

$29,675

$13,908

$140.014 2020

$120,873

$4,908

$2,135

$127,916 2021

$194,090

$4,908

$575

$199,574 2022

$135,313

$4,908

$2,467

$142,688 2023

$114,581

$4,908

$1,511

$121,000 2024

$26,874

$4,908

$36,778

$68,560 2025

$2,922

$4,908

$40,655

$48,485 2026

$2,922

$4,908

$21,676

$29,507 2027

$2,922

$4,908

$25,848

$33,678 2028

$2,922

$4,908

$20,945

$28,776 2029 1

$2,922

$4,908

$117,321

$125,151 2030

$2,922

$4,908

$116,672

$124,503 2031

$2,055

$5,089

$25,501

$32,645 2032

$2,122

$7,214

$0

$9,336 2033

$0

$7,214

$0

$7,214 2034

$0

$7,214

$0

$7,214 2035

$0

$7,228

$0

$7,228 2036

$0

$7,665

$0

$7,665 2037

$0

$7,665

$0

$7,665 2038

$0

$7,665

$0

$7,665 2039

$0

$7,665

$0

$7,665 2040

$0

$7,665

$0

$7,665 2041

$0

$7,665

$0

$7,665 2042

$0

$7,665

$0

$7,665 2043

$0

$7,665

$0

$7,665 2044

$0

$7,665

$0

$7,665 2045

$0

$7,665

$0

$7,665 2046

$0

$7,665

$0

$7,665 2047

$0

$7,665

$0

$7,665 2048

$0

$7,665

$0

$7,665 2049

$0

$7,667

$0

$7,667 2050

$0

$9,974

$23,120

$33,094 2051

$0 1

$6,573

$45,566

$52,139 2052

$0

$0

$1,377 1

$1,377 Notes: Costs are in 2014 dollars (in thiousands) and are not escalated from thle base year SONGS Unit 3 Trust Fund balances at end of 2013 were $2,079,400 Page 12 of 12 Revision 0