ML18354A736

Company - Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan

ML18354A736
Person / Time
Site:	Maine Yankee
Issue date:	12/10/2018
From:	Pizzella C Maine Yankee Atomic Power Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
OMY-18-030
Download: ML18354A736 (19)

Text

Maine Yankee 321 Old Ferry Road, Wiscasset, Maine 04578 December 10, 2018, OMY-18-030 Re: 10 CFR 72.4 and 10 CFR 72.30 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Maine Yankee Atomic Power Company Maine Yankee Independent Spent Fuel Storage Installation NRC License No. DPR-36 (NRC Docket No. 50-309) 7Z-3D

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, Maine Yankee Atomic Power Company (Maine Yankee) is providing the three-year update to the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Maine Yankee ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous Maine Yankee ISFSI DFP on December 16, 2015 (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 Maine Yankee ISFSI remains unchanged.

10 CFR 72.30( c) defines specific events that must be considered in the subsequent updates.

Since the submittal of the updated Decommissioning Funding Plan for the ISFSI in December 2015:

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, Maine Yankee complies with the requirements of 10 CFR 72.30(b )(1) through (b )( 6), as follows.

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." Maine Yankee has

Maine Yankee Atomic Power Company OMY-18-030/December 10, 2018/Page 2 established accounts within its Nuclear Decommissioning Trust {NDT) entitled, "ISFSI Rad Coho" and "ISFSI Rad Mellon," that segregate the funds for decommissioning of the ISFSI 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 DCB for the Maine Yankee ISFSI.

10 CFR 72.30(b )(2) requires the licensee to provide a detailed cost estimate for decommissioning. Enclosure 1 provides a revised DCB for the Maine Yankee ISFSI that:

1) Utilizes an independent contractor to perform the decommissioning activities in accordance with 10 CFR 72.30(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 72.30(b )(2)(iii). In addition, the revised Maine Yankee ISFSI DCB 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 Maine Yankee ISFSI DCB estimates the total cost to decommission the Maine Yankee ISFSI to be $25.14 million and

$25.77 million (in 2018 and 2019 dollars, respectively), inclusive ofradiological and non-radiological removal.

10 CFR 72.30(b )(3) requires the licensee to identify and justify the key assumptions contained in the DCB. Enclosure 1 provides the revised DCB for the Maine Yankee 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. Maine Yankee will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30(c).

On a periodic basis, Maine Yankee 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.

Maine Yankee has successfully litigated several breaches 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. Another breach of contract damages claim for the period 2013-2016 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, Maine Yankee 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.

Maine Yankee Atomic Power Company OMY-18-030/December 10, 2018/Page 3 This 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 <;;ontaminants 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 activatio:µ 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. In addition, the site will meet the remediation standards established by the State of Maine.

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 Maine Yankee ISFSI for the management of irradiated fuel and GTCC waste at the Maine Yankee ISFSI through 2036. A revised budget is planned to be submitted to FERC upon receipt of proceeds from the DOE associated with the Company's Phase IV litigation scheduled for trial in January of 2019. This revised budget is expected to address a lengthier period of storage and result in an increase in the overall costs of the management of irradiated fuel and GTCC waste.

A summary of the revised DCE and the cost estimate for the management of irradiated fuel and GTCC waste at the Maine Yankee ISFSI will be incorporated into the Post-Shutdown Decommissioning Activities Report (PSDAR) and the License Termination Plan (LTP) following the FERC approval of a revised budget some time in calendar year 2019.

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

Respectfully,

~~l~

Vice President, Chief Financial Officer, and Treasurer

Enclosures:

1. Decommissioning Study of the Maine Yankee Independent Spent Fuel Storage Installation

2. Certification of Financial Assurance _

3. Total Costs Associated with the Maine Yankee-ISFSI, including Cost Estimate for Managing Irradiated Fuel and GTCC Waste

Maine Yankee Atomic Power Company OMY-18-030/December 10, 2018/Page 4

Reference:

1. Letter from C. Pizzella (Maine Yankee) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 16, 2015 (OMY-15-053) cc:

D. Lew, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region 1 J. Nguyen, NRC Project Manager P. J. Dostie, SNSI, State ofMaine J. Hyland, State of Maine

\\

ENCLOSURE 1 TO OMY-18-030 DECOMMISSIONING STUDY OF THE MAINE YANKEE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Maine Yankee Atomic Power Company Maine Yankee ISFSI

• Page 1 of 10 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1.

Background and Intr.oduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[lJ with the rule becoming effective on December 17, 2012. Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the Maine Yankee (MY) Independent Spent Fuel Storage Installation (ISFSI) in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402

• This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy Maine Yankee (MY) was successfully decommissioned between 1997 and 2005.

During deco.mmissioning all 1,434 spent fuel assemblies were transferred from the spent fuel pool to 60 spent fuel storage casks. In addition, 4 GTCC casks containing segmented sections of the reactor internals are stored on the spent fuel storage pad. The ISFSI is operated under a Part 50 General License.

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 TLG Services, Inc.

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page2of 10 Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[21

3.

ISFSI Decommissioning Strategy At the conclusion of the DOE spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC and state of Maine release criteria.

4.

ISFSI Description The MY ISFSI is located on approximately 11 acres of the site. The ISFSI consists of 60 dry storage casks containing 1,434 spent nuclear fuel assemblies used during operations. The NAC-MPC fuel storage and transport canister system was chosen by MY and is licensed by the NRC for both storage and transportation. The NAC-MPC system consists of a multi-purpose spent fuel storage canister and a vertical concrete and steel overpack. Each vertical concrete cask has a three-and-a-half inch steel liner surrounded by 21 inches of reinforced concrete. Construction of the concrete storage pad and vertical concrete and steel storage was completed during decommissioning.

Transferring the spent fuel from the spent fuel pool to the storage casks was completed in March of 2004.

In addition to the 60 spent fuel storage casks there are 4 casks containing segmented sections of the reactor internals classified as Greater than Class C waste. The multi-purpose canisters will be transferred directly to the DOE.

After removal of the MPC canisters, the remaining overpacks are assumed to have residual radioactivity due to some

• minor level of neutron-induced activation as* a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and 2

U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a)... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as... "

TLG Services, Inc.

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page 3o/ 10 surrounding environs. meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

Table 1 provides the significant quantities and physical dimension~ used as the basis in developing the ISFSI decommissioning estimate.

5.

Key Assumptions/ Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the assumptions associated with DOE's spent fuel acceptance, as previously described.

The decommissioning estimate is based on the premise that the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. At the request of Maine Yankee Atomic Power Company (MYAPCo) all 60 overpacks and liners which contained spent fuel canisters are assumed to be affected, i.e., contain residual radioactivity. The remaining four GTCC overpacks are conservatively assumed to be treated in the same manner.

It is assumed for this analysis that the ISFSI pads will be contaminated. As such, the pads will be removed and disposed of as low-level waste.

The subsurface material of the ISFSI site is not expected to contain any significant residual radioactivity that will require remediation to meet the criteria for license termination.

Decommissioning is assumed to be performed by an independent contractor.

As such, essentially all labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as RSMeans Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. MY, as licensee, will oversee the site activities.

The Utility oversight staff is assumed to be similar in size and configuration as it is currently.

The following buildings are disposed of as* clean wa_ste in a local landfill.

Fencing TLG Services, Inc.

Maine Yankee Atomic Power Company Maine Yankee ISFSI ISFSI support systems Security operations building (SOB)

• Miscellaneous pads

• Miscellaneous structures Nuisance fence Buried utilities

• Road in licensed area SOB electrical service

• Vehicle barriers Costs are reported in 2018 dollars.

Page4of 10 NUREG-1757.[3] specifies that a contingency of 25% is to be included in the estimate. This estimate takes exception to this contingency level, at the request of MYAPCo, 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 MY site has recently been successfully decommissioned, and the land released from the operating license, with the exception of land associated with the ISFSI and a laydown area.

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

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(l)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-1757, Volume 3, Revision 1, February 2012 TLG Services, Inc.

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page 5of 10 (4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into four phases, including:

• An initial planning phase - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The license termination phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

Site restoration - While not required by the NRC this estimate includes the cost to remove and dispose of all non-contaminated structures. A list of all structures included in this estimate is provided in Table 3.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate.also contains costs for the NRC (and NRC contractor), MY's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year following all spent fuel removal.

TLG Services, Inc.

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 1 Page 60/ 10 Significant Quantities and Physical Dimensions ISFSIPad Residual Item Length (ft)

Width (ft)

Radioactivity ISFSI Pads - 16 Total (dimensions are for each pad) 31 31 Yes ISFSI Overpack Item Value Notes (all dimensions are nominal)

MY-MPC Overall Height (inches) 225.9 Dimensions are nominal Overall Diameter (inches) 136.0 Dimensions are nominal Inside Diameter (inches) 74.5 Dimensions are nominal Inner Liner Thickness (inches) 2.50 Dimensions are nominal Quantity (total) 64 60 spent fuel + 4 GTCC Quantity (with residual radioactivity) 64 Total Surface Area of overpack interior with Residual 269 Radioactivity (square feet)

Low-Level Radioactive Waste (cubic feet) 319,111 Low-Level Radioactive Waste (packaged density) 49 Other Potentially Impacted Items Item Value Notes Number of MPCs used for GTCC storage 4

Residual radioactivity TLG Services, Inc.

, Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 2 ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Costs Activitv Descriution Decommissioning Contractor Planning (characterization, 142 142 specs and procedures)

Decontamination (activated 353 2,003 5,641 7,997 liner and concrete removal)

License Termination 397 397 (radiological survevs)

Subtotal 353 2,003 5,641 538 8,535 Supporting Costs NRC and NRC Contractor Fees 273 273 and Costs Insurance 629 629 Property taxes 1,266 1,266 NRCFees 939 939 Site O&M Cost 3,316 3,316 Security Staff Cost 664 664 TLG Services, Inc.

Burial Volume Class A (cubic feet) 376,771 376,771 Page 7of 10 Oversight Craft and Manhours Contractor Manhours 880 4,354 2,392 6,746 880 1,153 46,985

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposa!

Other Total Costs Costs Costs Costs Costs Activity Description Costs DOC Staff Cost 1,964 1,964 Utility Staff Cost 2,486 2,486 Subtotal 11,535 11,535 ISFSI Decontamination 353 2,003 5,641 12,074 20,070 Total (w/o contine:ency)

ISFSI Decontamination 388 2,204 6,205 13,281 22,078 Total (with 10%

contine:ency)

ISFSI Site Restoration Building removal - Inside fence Fencing (linear foot) 5 5

ISFSI support systems 113 113 Building removal - Outside fence Miscellaneous pads 18 18 Miscellaneous structures 98 98 Nuisance fence 18 18 Removal of buried utilities 3

3 Removal of road in licensed area 33 33 SOB electrical service 0

0 Security operations building (SOB) 284 284 Vehicle barriers 1

1 TLG Services, Inc.

Burial Volume Class A (cubic feet) 376,771 Page 8of 10 Oversight Craft and Manhours Contractor Manhours 19,347 28,606 96,091 6,746 96,971 67 1,552 94 706 196 16 326 2

2,584 4

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Activitv Description Costs

'Construction debris 152 152 Site restoration 7

7 Subtotal 579 152 730 Supporting Costs Insurance 78 78 Property taxes 157 157 Heavy equipment rental 115 115 NRCFees 116 116 Site O&M Cost 410 410 Security Staff Cost 82 82 DOC Staff Cost 243 243 Utility Staff Cost 308 308 Severance 547 547 Subtotal 115 1,941 2,056 ISFSI Site Restoration 694 2,092 2,786 Total (w/o contine:encv)

ISFSI Site Restoration 763 2,302 3,064 Total (with 10%

contingency)

Total (w/o contingency) 1,046 2,003 5,641 14,166 22,856 Total (w/10% contingency) 1,151 2,204 6,205 15,583 25,142 TLG Services, Inc.

Burial Volume Class A (cubic feet) 376,771 Page 9of 10 Oversight Craft and Manhours Contractor Manhours 32 5,579 5,813 2,393 3,539 11,745 5,579 11,745 12,325 108,716

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 3 ISFSI Decommissioning - Structures Included Contaminated Removal Cask inner liner Cask lid Cask base & misc. Internal fixtures VCC concrete ISFSI concrete pad Clean Removal Remove fencing ilinear foot)

ISFSI support systems Miscellaneous pads Miscellaneous structures Nuisance fence Removal of buried utilities Removal of road in licensed area Security operations building (SOB)

SOB electrical service Vehicle barriers TLG Services, Inc.

Page JO of 10

ENCLOSURE 2 TO OMY-18-030 CERTIFICATION OF FINANCIAL ASSURANCE

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licensee:

Maine Yankee Atomic Power Company Maine Yankee Independent Spent Fuel Storage Installation NRC License No. DPR-36 (NRC Docket No. 72-30) 321 Old Ferry Road Wiscasset, ME 04578-4922 Issued to: U.S. Nuclear Regulatory Commission Certification:

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

During the operation of this ISFSI, spent nuclear fuel and Greater than Class C waste *will be stored at the Maine Yankee 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 Maine Yankee will dispose of other radiological waste in accordance with NRC regulations, at which time the Maine Yankee ISFSI will be decommissioned in accordance with NRC regulations.

I further certify that financial assurance in an amount sufficient to fund Maine Yankee ISFSI radiological decommissioning at the time of such decommissioning has been provided, pursuant to 10 CFR 72.30, as described in Enclosure 1 to 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:

Maine Yankee ISFSI

$22.08 million (in 2018 dollars, inclusive of contingency) c~~~

Maine Yankee Atomic Power Company Vice President, Chief Financial Officer, and Treasurer Phone (860) 267-6426 x304 Date

\\ ).. J \\ t) I \\ ~

Corporate Seal

.ENCLOSURE 3 TO OMY-18-030 TOTAL COSTS ASSOCIATED WITH THE HNP ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

Mlllna Yankee Atomic Power Comp.ny Spant Fual Management 11nd ISFSI Dacom Estimate Represented In 2019 Dollars FERC

SUMMARY

Su!11Df2019 Sumof2020 Sum of2021 Contingency 556,164 599,118 565,400 Insurance 538,678 538,678 538,678 Labor* Non-Manual 2,478,965 2,478,965 2,325,861 Labor* Security 3,122,983

.3,122,983 3,122,983 Materials & Supplles 104,509 131,431 158,303 Miscellaneous 147,534 147,534 147,534 Outside Services* A&G 702,574 700,151 641,999 Outside Services. Fuel Loading Outside Services* ISFSI OP's 1,911,839 2,746,430

.1,879,533 Outside Services* legal 215,378 215,378 592,290 Outside Services* NON*RAD D&D of ISFSI Outside Services* RAD D&O of ISFSI Property Taxes 1,026,384 1,026,384 1,026,384 Regulatory Fees 745,208 745,208 745,208 Utilities 129,227 129,227 129,227 GrandTotaJ 11,679,444 12,581,488 U.,873,400 Note 1: The cost of management of irradiated fuel and GTCC waste Is calculated as follows:

201,781,563 Grand Total from Above (3,140,600) Non*Rad D&D ISFSI (22,629,950) Rad D&O ISFSI Sumof2022 Sumof2023 553,018 484,636 538,678 538,678 2,325,861 2,325,861 3,122,983 3,122,983 104,509 115,278 147,534 147,534 641,999 641,999 1,712,615 684,184 565,368 215,378 1,026,384 1,026,384 745,208 745,208 129,227 129,227 11,613,384 10,177,350 176,011,013 Management of Irradiated Fueland GTCC Waste Sumof2D24 Sumof2025 sumof2026 Sumof2027 1Sumof2028 Sumof2029 Sumof2030 487,126 505,097 497,365 481,968 477,445 505,780 500,598 538,678 538,678 538,678 538,678 538,678 538,678 538,678 2,325,861 2,325,861 2,235,886 2,235,886 2,235,886 2,235,886 2,235,886 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 131,431 104,509 158,303 104,509 131,431 104,509 115,278 147,534 147,534 147,534 147,534 147,534 147,534 147,534 702,574 641,999 641,999 700,151 641,999 702,574 641,999 657,262 727,260 635,724 673,415 614,186 770,335 743,413 215,378 592,290 565,368 215,378 215,378 592,290 565,368 1,026,384 1,026,384 1,026,384 1,026,384 1,026,384 1,026,384 1,026,384 745,208 745,208 745,208 745,208 745,208 745,208 745,208 129,227 129,227 129,227 129,227 129,227 129,227 129,227 10,229,647 10,607,030 10,444,659 10,121,3211 10,026,340' 10,621,389 10,512,556 Note 2:The cost of RAO and NON-RAD O&D of the ISFSI in 2019 dollars as provided In the columns labeled 'Sum of2034' and 'Sum of 2035' is derived by escalating the value of the cost estimates provided In Enclosure 1 by 2.5%

Note 3:Thls Summary combines MY's 2016 approved FERC Rate Case with th~ nG Services 2018 RAD and NON*Rad lSFSI Decom Cost Estimate.

Sumof2031 Sumof2032 Sumof2033 Sumof2034 Sumof2035 Sumof2036 Sum ofTotllls 2019-2036 490,365 487,918 498,471 1,488,776 9,179,244 538,678 538,678 538,678 538,678 8,618,847 2,235,886 2,235,886 2,235,886 2,235,886 36,710,207 3,122,983 3,122,983 3,122,983 3,122,983 49,967,725 158,303 142,739 115,816 115,816 1,996,675 147,534 147,534 147,534 125,996 2,339,006 641,999 700,151 641,999 641,999 10,628,167 3,101,445 3,101,445 705,722 614,186 673,415 248,043 15,997,563 215,378 215,378 592,290 565,368 6,353,655 3,140,600 3,140,600 7,467,884 15,162,067 22,629,950 1,026,384 1,026,384 1,026,384 1,026,384 16,422,151 885,204 885,204 745,208 1,138,273 12,596,390 129,227 129,227 129,227 161,534 2,099,937 10,297,663 10,246,268 10,467,892 14,511,182 7,467,884 18,302,667 201,781.563 Check Sum 201,781,563