Text

Yankee ISFSI - Three-Year Update to the Decommissioning Funding Plan
	ML16020A016
Person / Time
Site:	Yankee Rowe
Issue date:	12/14/2015
From:	Pizzella C; Yankee Atomic Electric Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	BYR 2015-036
	Download: ML16020A016 (29)
	v • d • e

YANKEE ATOMIC ELECTRIC COMPANY

" ANKEI 49 Yankee Road, Rowe, Massachusetts 01367 December 14, 2015 BYR 20 15-036 Re: 10 CFR 72.4 and 10 CFR 72.30 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 Yankee Atomic Electric Company Yankee Nuclear Power Station Independent Spent Fuel Storage Installation NRC License No. DPR-3 (NRC Docket No.50-029)

Subject:

Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan Pursuant to the requirements of 10 CFR 72.30(c) and 10 CFR 70.4, Yankee Atomic Electric Company (YAEC) is providing the three-year update to the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Yankee Nuclear Power Station (YNPS) ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the original YNPS ISFSI DFP on December 17, 2012 (Reference 1). It includes adjustments to account for changes in costs. The update does not include any adjustments for additional radiological contamination, because the extent of radioactive contamination at the YNPS ISFSI remains unchanged.

10 CFR 72.3 0(c) defines specific events that must be considered in the subsequent updates.

Since the submittal of the original Decommissioning Funding Plan for the ISFSI in December 2012:

1. No spills of radioactive material producing additional residual radioactivity in onsite subsurface material have occurred.

2. Facility modifications that affected the ISFSI, including those that were implemented within the licensed area, were assessed for impact.

3. There were no changes in authorized possession limits.

4. No active decommissioning has occurred, thus, there have not been any actual remediation costs that exceed the previous cost estimate.

In addition, YAEC complies with the requirements of 10 CFR 72.30(b)(1) through (b)(6), as follows.

Yankee Atomic Electric Company BYR 2015-036/December 14, 2015/Page 2 10 CFR 72.30(b)( 1) requires the licensee to provide "information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI." YAEC has established an account within its Nuclear Decommissioning Trust (NDT) entitled, "ISFSI Radiological Decom," that segregates the funds for decommissioning of the 1SF SI from the larger balance of funds for ongoing management of irradiated fuel and GTCC waste held in the NDT. Currently, the trust has sufficient funds to meet the revised DCE for the YNIPS ISFSI.

10 CFR 72.30(b)(2) requires the licensee to provide a detailed cost estimate for decommissioning. Enclosure 1 provides a revised DCE for the YNPS ISFSI that: 1) Utilizes an independent contractor to perform the decommissioning activities in accordance with 10 CFR 72.3 0(b)(2)(i); 2) Includes an adequate contingency factor in accordance with 10 CFR 72.30(b)(2)(ii); and 3) Includes the cost of meeting the criteria for unrestricted release in accordance with 10 CFR 72.3 0(b)(2)(iii). In addition, the revised YNPS ISFSI DCE specifically considered the effects of the events described in 10 CFR 72.30(c) on the costs of decommissioning and the extent of contamination. The revised YNIPS ISFSI DCE estimates the total cost to decommission the YNPS ISFSI to be $10.1 million and $10.4 million (in 2015 and 2016 dollars, respectively), inclusive of both radiological and non-radiological removal.

10 CFR 72.3 0(b)(3) requires the licensee to identify and justify the key assumptions contained in the DCE. Enclosure 1 provides the revised DCE for the YNPS ISFSI, including the key assumptions and the justification for their use.

10 CFR 72.30(b)(4) requires the licensee to provide a description of the method of assuring funds for decommissioning from 10 CFR 72.30(e), including means for adjusting cost estimates and associated funding levels periodically over the life of the facility. YAEC will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30(c). On a periodic basis, YAEC will submit rate cases to Federal Energy Regulatory Commission (FERC) that will include revised cost estimates for decommissioning and the management of irradiated fuel and GTCC waste. If necessary, additional funds may be recovered from the purchasers.

YAEC has successfully litigated a couple of breach of contract damages claims against the Department of Energy (DOE) for failure to begin the removal of spent nuclear fuel (SNF) and GTCC waste from the site in 1998. A third breach of contract damages claim for the period 2008

- 2012 is with the federal court for decision and additional damages claims against the DOE relating to the government's breach of contract are expected to continue as long as the irradiated fuel and GTCC waste remain' on site.

Annually, YAEC submits the reports required by 10 CFR 50.75(f)(2), 10 CFR 50.82(a)(8)(v) and 10 CFR 50.82(a)(8)(vii) to establish how it satisfies the obligations defined in those regulations regarding the assurance of decommissioning funding and the status of funding for the management of irradiated fuel.

10 CFR 72.30(b)(5) requires the licensee to define the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination. No subsurface material is assumed to require remediation regarding radionuclides.

This is justified because: 1) the ISFSI area was confirmed to be clean of radiological

Yankee Atomic Electric Company BYR 2015-036/December 14, 2015/Page 3 contaminants prior to the construction of the ISFSI; 2) the ISFSI area will be maintained clean of loose radiological contaminants during the storage period; 3) the irradiated fuel and GTCC waste are stored in sealed canisters; 4) nuclear activation of the Vertical Concrete Casks (VCCs),

VCCs liners, and ISFSI are anticipated; the activation products will remain fixed during the storage period; and 5) if contamination of subsurface occurs during decommissioning activities, the contamination is expected to remain below the decommissioning criteria of 25 millirem per year Total Effective Dose Equivalent.

10 CFR 72.30(b)(6) requires a certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning. Enclosure 2 provides the certification of financial assurance.

In addition, Enclosure 3 provides an estimate of the total costs associated with the YNPS 1SF SI for the management of irradiated fuel and GTCC waste at the YNPS ISFSI through 2033.

A summary of the revised DCE and the cost estimate for the management of irradiated fuel and GTCC waste at the YNPS ISFSI will be incorporated into the Post-Shutdown Decommissioning Activities Report (PSDAR) and the License Termination Plan (LTP).

If you have any questions, please do not hesitate to contact me at (860) 267-6426 x304.

Respectfully, Carla M. Pizzella Vice President, Chief Financial Officer, and Treasurer

Enclosures:

1.

Decommissioning Study of the Yankee Rowe Independent Spent Fuel Storage Installation

2.

Certification of Financial Assurance

3.

Total Costs Associated with the YNPS ISFSI, including Cost Estimate for Managing Irradiated Fuel and GTCC Waste

Reference:

1.

Letter from C. Pizzella (YAEC) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 17, 2012 (BYR 20 12-043)

Yankee Atomic Electric Company BYR 2015-036/December 14, 2015/Page 4 cc:

D. Dorman, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region 1 J. Goshen, NRC Project Manager J. Giarrusso, Planning, Preparedness & Nuclear Section Chief, MEMA J. Cope-Flanagan, Assistant General Counsel, MDPUJ J. Reyes, State of Massachusetts Office of the Attorney General

a I'

ENCLOSURE 1 TO BYR 2015-036 DECOMMISSIONING STUDY OF THE YANKEE ROWE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Decommissioning Study of the Yankee Rowe Independent Spent Fuel Storage Installation Prepared for Yankee Atomic, Power Company Knight Cost Engineering Services, ULC November, 2015

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2015, 2015-200 Rev° 0 Table of Contents

1.0 INTRODUCTION

.............................................................................. 3 2.0

SUMMARY

...................................................................................... 4 3.0 DECOMMISSIONING COST ESTIMATING APPROACR............................ 7 4.°0 ASSUMPTIONS................................................................................. 8 5.0 SCHEDULE.................................................................................... 10 6.0 PROJECT MANAGEMENT................................................................ 12 6.1 OVERSIGHT STAFF............................................................................... 12 6.2 DECOMMISSIONING GENERAL CONTRACTOR............................................13 6.3 SECURITY.......................................................................................... 13

7.0 REFERENCES

................................................................................. 14 APPENDIX A.......................................................................................... 15 Page 2 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv

1.0 INTRODUCTION

The purpose of this study is to identify the costs associated with the decommissioning of the Yankee Rowe (YR) Independent Spent Fuel Storage Installation (ISFSI). This estimate includes only the structures, systems and land within the NRC licensed area. The YR. ISESI is located in the South East portion of the former reactor site. The NAC-MPC fuel storage and transport canister system chosen by YR is licensed by the NRC for both storage and transportation.

There are 16 dry storage casks on the 50 by 180-foot, three-foot-thick concrete pad at the YR ISFSI. Fifteen of the casks contain the 533 spent fuel assemblies and one cask stores sections of the reactor vessel internals that are classified as Greater Than Class C (GTCC) waste. Each vertical concrete cask has a three and a half-inch steel liner surrounded by 21 inches of reinforced concrete.

Page 3 of 15

I-Knight Cost Engineering Services, LLC KCES 2015, 2015-200 Rev. 0 2.0

SUMMARY

Decommissioning is the safe removal of a facility or site from service and the reduction of radioactivity to a level that permits either the release of the property for unrestricted use and NRC license termination; or a restricted release of the property and NRC license termination. This estimate includes all costs incurred to release the property for unrestricted use.

On June 17, 2011, the NRC published a final rule amending its regulations to improve decommissioning planning. The rule became effective on December 17, 2012. This rule requires licensees to report additional details in their decommissioning cost estimate. To assist in the implementation of the new rule, the NRC issued NUREG-1757, "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping and Timeliness."

NUREG-1757 does not apply to licensees under 1 OCFR Part 50 nor does it eliminate the need to follow Regulatory Guide 1.202 or NUJREG-1713.

It does provide additional information to support the development of the cost estimate. This cost estimate was prepared in accordance with the guidelines provided in RG 1.202 and NUREG-1713. In addition, it does take into account the guidelines identified in NUREG-1757.

NIJREG-1757 specifies that a contingency of 25% is to be included in the estimate. This estimate takes exception to this contingency level for two reasons. First, the estimate is conservative in that the entire storage pad, concrete overpacks and overpack liners are assumed to be disposed of as potentially contaminated. Second, the YR site has recently been successfully decolmmissioned, and the land released from the operating license, with the exception of land associated with the ISESI.

The lessons learned from that project will be incorporated in the YR ISFSI decommissioning. For this reason it is felt that a 10% contingency is adequate to cover unknown and unplanned occurrences.

The original Decommissioning Funding Plan for the Yankee Nuclear Power Station (YNPS)

Independent Spent Fuel Storage Installation (ISFSI) to comply with 10 CFR 72.30(b) was submitted on December 17, 2012. 10 CFR 72.30(c) defines specific events that must be considered in the subsequent updates. Since the submittal of the original Decommissioning 3Funding Plan for the YNPS ISFSI in December 2012:

1. No spills of radioactive material producing additional residual radioactivity in onsite subsurface material have occurred.

2. Facility modifications that affected the ISFSI, including those that were implemented within the licensed area, were assessed for impact.

3. There were no changes in authorized possession limits.

4. No active decommrrissioninig has occurred, thus, there have not been any actual remediation costs that exceed the previous oost estimate.

Page 4 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2015,2015-200 Rev. O The total cost including contingency is $10.1 m~illion, $8.6 million for radiological removal and

$1.5 million for non-radiological removal. Table 2-1 provides a summary of costs. Cost details are provided in Appendix A TABLE 2-4 SUMMAMIY OF COSTS Non-Radiological radiological Total Cost Removal $

Removal $

Grand Total Building Tax on General Contractor

$10,136,945

$8,625,080

$1,511,866

$0 S0

$0 General Contractor with contingency Site Costs with contingency General Contractor

$6,029,787

$5,130,480

$899,307

$4,107,158

$3,494,600

$612,558

$5,481,625

$4,664,073

$817,552

$3,733,780

$3,176,909

$556,871

$9,215,405

$7,840,982

$1,374,423

$6,127,717

$5,213,804

$913,913 Site Costs YR ISFSI PERIOD DEPENDENT COSTS 1.1 1.1.1 1.1.2 1.1.3 1.1.4 1.1.5 1.1.6 1.2.1 1.2.2 1.2.3 YR Site Costs Proj ect Management Security Staff Fees Insurance Legal Property Taxes General Contractor Decommissioning General Contractor Waste Packaging Crew Equipment & Materials

$3,733,780

$1,452,876

$873,828

$404,491

$510,760

$200,000

$291,825

$2,393,937

$1,212,768

$564,137

$617,033

$3,176,909

$344,163

$434,583

$170,171

$248,301

$2,036,895

$556,871

$60,327

$76,177

$29,829

$43,524

$357,042 1.2 ACTIVITIES 1.3 1.3.1

.1.3.2

$3,087,688

$2,627,177

$460,510 1.4 1.5 Project Engineering

'Procedure Development and Review - Offsite Preparation of QA and Safety Documents -

Offsite (in parallel with 1.2.1)

Site Mob'lization and General Employee Training (GET)

Site Metrilization Genera! Eniphyee Training i[

,7*.ratioa

- Performed by Staff

$9,538

$4,769

$4j769

$122,240 832,388

$80,389

$9,463

$16,4&3

$8,116

$1,423

$104,009

$18,231 1.4.1 1.4.2 1.4.3

$14,029

$2,459 Page 5 ofi5

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2025, 20!5-200 Rev. O

SUMMARY

OF COSTS, continued 1.5.1 1.5.2 1.5.3 1.6 1.7 1.6.1 1.6.2 1.6.3 1.7.1 1.7.2 1.7.3 1.7.3.1 1.7.3.2 1.7.4 1.7.5 1.7.6 1.8 1.8.1 1.8.2 1.8.3 1.8;4 1,8.5 1.8.10 Initial Site Survey Setup work areas Decontamination Readiness Review Disconnect all utilities to work areas.

Electrical Ventilation Piping Removal inside security feaice Remove Guard Posts Instrument Enclosure Remove VCCs Exterior Concrete Steel liner Remove Concrete Pad Remove Fence and Towers Remove Light Towers Removal outside security fence Remove Nuisance Fence Retaining Wall Conduit and wire - Instrument Enclosure to Utility Pole Remove road inside licensed area Remove vehicle barriers Miscellaneous Final Site Survey Structure gone - By DGC Staff Prepare Final Stats Sur-vey Plan Soil Sampling Direct Survey Sampling Analysis Prepare Final Status Survey Report Orise Site Release Confirmation Outside areas Backfill, grade and seed Demolition Crew Demobilization Final Project Report - Offsite

$8,244

$4,122

$2,061

$2.5 16,294

$3,561

$8,913

$1,186,886

$582,304

$604,581

$1,262,287

$43,481

$11,166

$359,284

$83,691

$49,010

$7,015

$2,449,173

$0

$1,186,886

$0

$1,262,287

$1,230

$67,121

$3,561

$8,913

$0

$43,481

$11,166

$359,284

$83,691

$49,010

$26,561

$196,300

$3,722

$3,729

$2,904

$3,419

$711

$26,561

$196,300

$3,722

$25,000

$21,271 1.9 1.9.1 1.9.2 1.9.3 1.9.4 1.9.5 1.10 1.11 1.11.1 1.12 1.13

$2,904

$22,926

$4,769

$19,506

$4,058 Page 6 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2015, 2015-200 Rev. 0 3.0 DECOMMISSIONING COST ESTIMATING APPROACH Two types of costs were determined in this estimate: activity costs and level of effort costs. The activity costs were developed utilizing a unit cost factor approach. Site material quantities for concrete, steel and equipment where developed from site specific drawings. Productivity factors were applied to these quantities to determine ac~tivity durations. Labor crews were developed and applied to the material quantities to determine labor costs and person-hours. The activity durations were used to develop a project schedule.

The level of effort costs such as equipment rental and the General Contractor (GC) staff were developed based on the project schedule duration. A rental equipment file was developed for the construction effort. The GC staff is assumed to be on-site for the duration of the project. The Oversight staff cost is another level of effort cost that is included in the cost estimate.

Bulk removal of the storage pad and concrete storage casks is assumed to be performed using an excavator with a hydraulic hammer attachment. The steel liner will be segmented utilizing torch cutters. All of this waste will be trucked off-site for processing. This leads to a large disposal volume; however, at a lower rate for bulk processing than for direct burial. In addition, there will be far less characterization and iterative decontamination. Clean structures will be demolished using mechanical means and disposed of at a local landfill.

In addition to the removal labor there is a dedicated waste packaging crew included in this estimate.

This crew will consolidate, package and prepare containers for transportation.

The waste packaging crew is estimated to remain on site for the duration of the project. This crew consists of.

2 laborers; 1 Health Physics Technician; 1 Equipment Operator and 1 Foreman.

Page 7 of 15

Knight Cost Engineering Services, LLC CS21 p0-0 R.0 KCES 2015, 2015-200 Rev. 0 4.0 ASSUMPTIONS Following is a list of assumptions developed by KCES in completing this study.

These assumptions are based on the most current decommissioning methodologies and site-specific considerations.

1. Component quantities were developed from actual plant listings.

2. Concrete volumes were developed from plant drawings.

3. The oversight staff is assumed to be sinilar in size and configuration as it is currently.

4. The oversight staff positions and costs were supplied by the Company and represent September 2015 salary and benefit data.

5. Subcontractor base labor rates and fringe benefits were taken directly from the 2015 R. S. Means Heavy Construction Cost Data and adjusted to Massachusetts based on thle City Cost Indexes for Pittsfield, MA.

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

7. All skilled laborers will be supplied locally and hired by the Decommissioning General Contractor (DGC).

8. The cost for Utility personnel assisting the DGC to develop decommissioning activity specifications is included in the Utility Staff costs.

9. The separate DGC staff salaries, including overhead and profit, were determined by KCES.

10. Transportation costs for LLW are included in the bulk disposal rate.

11. The ISFSI Concrete Pad, VCC exterior concrete and VCC liner steel are assumed to be low-level radioactive wastes that will be disposed of at the Waste Control Specialists facility in Texas (a licensed facility) at $0.25 per pound.

12. The following buildings are disposed of as Clean waste in local landfill. A disposal rate of $91.80 per ton has been used in this estimate and is based on information provided in the 2015 R. S. Means Building Construction Cost Data.

Guard Posts Instrument Enclosure Security Fence.

Light Towers Nuisance Fence Page 5 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 20!5, 2015-200 Rev. 0 Retaining Wall Conduit and wire - Instrument Enclosure to Utility Pole Road inside licensed area Vehicle barrier

13. All costs used in these calculations were current on September, 2015.

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

15. It is assumed that all MPCs containing both spent fuel and GTCC will have been removed from site prior to the start of decommissioning.

16. Property taxes are included in the estimate at the current cost of $291,825 per year.

17. Fees are included in the estimate at the current cost of $404,491 per year.

18. Insurance costs are included in the estimate at the current cost of $510,760 per year.

19. Legal costs arc included in the estimate at the current cost of $200,000 per year.

20. The decommissioning will be performed under the current regulations.

21. Removal of the pad and concrete overpacks will be performed in Tyvek coveralls.

Productivity rates have been adjusted to account for this.

22. No subsurface material is assumed to require remediation regarding radionuclides. This asstumption is justified because: 1) the ISFSI area was confirmed to be clean of radiological contaminants prior to the construction of the ISFSI; 2) the ISFSI area will be maintained clean of loose radiological contaminants during the storage period; 3) the irradiated fuel and GTCC waste are stored in sealed canisters; 4) nuclear activation of the VCCs, YCCs liners, and ISFSI pad are anticipated; the activation products will remain fixed during the storage period; and 5) if contamination of subsurface material occurs during decommissioning activities, the contamination is expected to remain below the decommissioning criteria of 25 millirem per year Total Effective Dose Equivalent.

Page 9 o*15

Knight Cost Engineering Services, [IC KE 05 0520Rv KCES 2015,2015-200 Rev. O 5.0 SCHEDULE A scenario-specific schedule has been developed for estimate.

Activity durations were determined based On the unit cost factor approach.

Plant material inventory quantities were developed from site specific material. Unit rates for cost, man hours and schedule hours were applied to the material quantities.

From this calculation the removal or decontamination cost, total man hours and total schedule hours were determined for an activity.

The schedule hours are then entered into the schedule to determine project duration. Two work crews are assumed for the concrete pad and concrete overpacks. All other work was assumed to be performed by one crew. Work outside of the security fence will be performed in parallel with the work inside the fence. The total project duration is 6.96 months.

Figure 5-1 provides the detailed decommissioning schedule.

Page 10 of 15

Knight Cost Erlnnertng Services, Lit KCES 2015, 2015-200 Rev. 0 Figure 5-1 N--

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Knight Cost Engineering Services, LLC KE 05 0320Rv KCES 2015,2015-200 Rev. O 6.0 PROJECT MANAGEMENT There are three components to project management during decommi~ssioning, Oversight Staff" (staff), Decommissioning General Contractor Staff (DGC) and Security. The person levels for each are identified below.

6.1 OVERSIGHT STAFF The staff size is assumed to be maintained at the current level and at a similar configuration during the decommissioning. In addition, the staff is augmented with one final status survey resource and one licensing person to assist in the decommissioning.

The staff will provide DGC oversight as well as maintain license compliance. Table 6-1 provides a summary of this staff.

TABLE 6-1 OVERSIGHT STA~f Staff Number President1 Cask Relicensing Project Manager 1

Workers Concerns Manager1 Director of Operations 1

ISFSI Manager1 ISFSI QA Manager 1

ISFSI RPM 1

ISFSI Operations Specialist 1

ISFSI Administrator 1

Licensing Specialist 1

FSS Manager 1

ISFSI Technical Specialist 1

Assistant Director of Operations 1

Program Manager I

Program Manager 1

Program Manager1 Public/Government Regulatory Affairs 1

General Counsel1 Licensing Engineer 1

VP CFO & Treasurer1 Business Administrator1 Accounting Manager 1

Sr. Accountant1 Sr. Accountant1 Benefits 1

IT Services1 Security Manager 27 Page 12 of 15

Knight Cost Engineering Services, LIC KE 05 0520Rv KCES 2015,2015-200 Rev. O 6.2 DECOMMISSIONING GENERAL CONTRACTOR The DGC will be responsible for all of the physical work. The staff will oversee the work crews, schedule work and supply [-IP support. The DGC will be responsible for finishing the project on time and on budget. Table 6-2 provides a summary of the DGC staff.

TABLE 6-2 DGC STAFF 2015 Base Man Position Salary Lever Project Superintendent

$200,000 1.00 QA Auditor/Inspector

$64,000 1.00 Health & Safety Supervisor

$89,205 1.00 Packaging/Shipping Specialist

$66,522 1.00 Cost Control Accountant

$65,071 1.00 Scheduler Il

$65,000 1.00 Demolition Specialist

$56,000 1.00 Industrial Safety

$67,000 1.00 Engineering Supervisor

$113,000 1.00 Project Supervisor

$81,000 1.00 Decontamination Tech

$35,000 2.00 Instrumentation Tech

$42,248 1.00 Tool Crib Atenan

$33,976 1.00 14.00 6.3 SECURITY Once spent fuel and GTCC waste are removed from the site the security force will be significantly reduced. This estimate assumes a force of 13 guards, four supervisors and one manager. This will allow a security person level of 5 guards during work time and two guards all other times. While this staff level may be high for industrial standards, we have decided to maintain the security staff at conservatively high level. The guard force was assumed to consist of various levels of guards and the rate used has been adjusted accordingly.

Page 13 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2015, 2015-200 Rev. 0 7°0 REFERENCES

1. R.S. Means, rInc, Building Construction Cost Data, Kingston, Massachusetts, 2015.

2. Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors"

3. NUJREG-17 13, "Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors"

4. NUREG-1757, "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping and Timeliness"

5. 10CFR 72.30, Financial Assurance and Recordkeeping for Decommissioning

6. Letter form Carla Pizella (YAEC) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 17, 2012.

Page 14 of 15

Knight Cost Engineering Services, LLC KE 05 0520Rv KCES 2015, 2015-200 Rev. 0 APPENDIX A Page 15 of 15

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ENCLOSURE 2 TO BYR 2015-036 CERTIFICATION OF FINANCIAL ASSURANCE

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licensee:

Yankee Atomic Electric Company Yankee Rowe Independent Spent Fuel Storage Installation NRC License No. DPR-3 (NRC Docket No.50-029) 49 Yankee Road Rowe, MA 01367 Issued to: U.S. Nuclear Regulatory Commission Certification:

I hereby certify that Yankee Atomic Electric Company (YAEC) is the licensee for the Yankee Nuclear Power Station Independent Spent Fuel Storage Installation (YNPS ISFSI) and that I, the undersigned, am authorized to provide this Certification of Financial Assurance with respect to the radiological decommissioning of the YNPS ISFSI.

During the operation of this ISFSI, spent nuclear fuel and Greater than Class C waste will be stored at the YNPS ISFSI in storage casks licensed under 10 CFR 72. Pursuant to contracts with the Department of Energy the spent fuel and associated casks will ultimately be removed from the ISFSI location, and YAEC will dispose of other radiological waste in accordance with NRC regulations, at which time the YNPS ISFSI will be decommissioned in accordance with NRC regulations.

I further certify that financial assurance in an amount sufficient to fund YNPS ISFSI radiological decommissioning at the time of such decommissioning has been provided, pursuant to 10 CFR 72.30, as described in the letter to which this Certification is attached. That radiological decommissioning funding assurance is premised on a site-specific decommissioning cost estimate and funding methodology described therein, in the amount of:

YNPS ISFSI

$8.6 million (in 2015 dollars, inclusive of contingency)

Carla M. Pizzella Yankee Atomic Electric Company Vice President, Chief Financial Officer, and Treasurer Phone (860) 267-6426 x304 Date

\\*,\\'-4/\\ %

ENCLOSURE 3 TO BYR 2015-036 TOTAL COSTS ASSOCIATED WITH TILE YNPS ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

2013-2033 Summary (UNESCALATED)

Yankee Atomic Eteofdo Company treodlated Fuel & GTCC Waste Managemenet and ]SF31 Deconr Estimate Represueted In 2016 Dollars FERCSoummaro Sumnf2D16 Somof2017 Soumof2018 Suof2o019 Sumot~o2O Somot2O2l Suorfl2022 Somof 2023 Sumof2024 Sumsf2S2S5oSmof2026 Suornf2027 50umof2028 5omet2029 5omof2800 Sumof203l Sunmof2SS2 Somnf2O33 SuofnTota~o2013-2023 zontthigency Inororan*

Lobort-Non-Manual Lotbor

-Security Moterials

& Supplies lsceelaneocs Outside Sera.tes -ASS astside Servtens - Fuel Leading Outside Ser.stue-18F5101PS Ouraide Serviceas-Legol Ortsidn Serutues-N0ON-PAD D&D otio5FSI Srtsde Seticens-PAD D&6SefISFSI Property Taens Regrdoloy Fsen UtiSines 0539,178

$854.200 0382.748 419,669

$,06.307

$3392746

$392.740

$232,746

$3392,746

$8311.130

$392,746

$392.746 3392.746 2392.746 3860,144

$889,951

$3554,381

$8.1ss0,u 3464.140

$464,140

$464,140 464,140

$464,140

$464.140

$464,140 3464,140 0464,140 3466.140 3464.140 3464.140 0464.140 3464.140 3464,140 3464.140

$1,135,043

$83561,380

$1,723.8393$1,722.833

$1,7236833 1,723,623 31.723.833 31,723.633

$1,723,833

$1,723,823

$1.723,833 31.723,833 31,723,833 01.723.833 51,723,833 31.723.633 31,723,833 31,745.370 31,103.544 039,706,404 3,.101.230 $3,4t1,353 53,411,353 3,411,353

$3,411,353 33,411.353 33,411.303 03,411.353

$3,411,333 03,411.353

$8,411,353 33,411,353

$3.411,353 33,411.353 03,411.283 33.411.353 30 354,271.510 083.767

$83,767

$80,767 00,767 000,767 500,767

$80,767 300.767

$000767

$80.767 300.767 300,767 900,767

$0,0767 380.767 580.767 521.538 31,313.607 367.174

$07.174 007.174 87,174

$87,174 367.174

$87,174 587,174 007.174 007.174

$67,174 357,174 367,174 387.174

$87,174 307.174 341,676

$1,436.464

$1.59t,752

$1.083,670

$056,765 004,785 3506,785

$506.705 3006,705

$006.785

$056.785 0500,780 3906.785 3$56,785 3506.760 9506.765 3514.561 3006.785

$821.837 510,900,423 SO 30 30 5

00 00

$0

$0 00

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$0 0279.,902 9753.833 50

$1,033.815 32,743.917 $2.743,517

$580,136 550.136 0550.130 3050,136 3050.136 3530,136 3530.136 0590.130 3$50,136

$350,.136

$890.136

$550,13

$8 3590.136 0595.136

$38,767

$13,835.500 0215.378 3215.378

$210.378 703.833

$484.601

$215,378 0215.378 0215,378 0215.378

$1.023.046 3215.378

$355,378 3215.378 3215,376 9753,823 5464.651

$1,733.025

$7.0921071¢

$0

$0 0

$05 00 00 00 00 00 00

$0

$0 00 00 00 31,545,683

$0

$1.54,5.640

$0 00 30 0

$0 30 30 00 00 05 30 00 90 30 00 00 38,840,707

$00

$8,80,70i 3279.,93 0279.502 0278,932 279.993 3279.952 3279,892

$279.992 3270,952 33795902 3278.992

$279,552

$379.,52 5379,993 5379.992

$379,992 5379,993

$107,989 34,567,50' 3415.587 3419,507 0419,507 419.907

$415.987 3419,507 3419,987 3413.387 3419.507 3419.007 3419.507 3419.987

$419.567 3419.987 5419.987 3419.567

$843,981

$7,383,277 378.982 075,352 375,382 78,362 670.352

$78.362

$78,383 375.302 375.382 375.383

$70.382 570.382 075.382 375.362

$75,352

$75.382

$84,613

$1,278,721 Cheek Sum

$0159,458,390 Nate 1 : The cost ot managemeet sf irrodiated tuo ni GT45CC wrasta is csteuloted oslfo~ons:

3159.458.350 Grand Total fram.Aboce (01,549,883) Nan-Rad 5&D ISF51 (3333lRed D&D S8F51 0140.060.020 Managemennt at Irradiated Foe nt G38rCC Waole Naot 2" The cost of 86D and 00N-RAD D&D of thre SF581 In 3916 do~lars no provided in rhoealuant tblaeed "0um oft2032" is darived by esooaoi0g the cean luofthe cost estintetes proaided in Costosren 1 by 2.5%.

Note 3: "his Summary CeotBines YR85 2913 Approved FERC Rate Costerwith the Knigst Cost Engineerinrg Senrciec 3915 P8D end NON-Rod ISF51 Decent Cool Estimate