ML18354A738

Yankee Nuclear Power Station Independent Spent Fuel Storage Installation - Three-Year Update to the Decommissioning Funding Plan

ML18354A738
Person / Time
Site:	Yankee Rowe
Issue date:	12/10/2018
From:	Pizzella C Yankee Atomic Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
BYR 2018-025
Download: ML18354A738 (19)

Text

YANKEE ATOMIC ELECTRIC COMPANY 49 Yankee Road, Rowe, Massachusetts 01367 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 December 10, 2018 BYR 2018-025 Re: 10 CFR 72.4 and 10 CFR 72.30

12-Ci~ I Yankee Atomic Electric Company Yankee Nuclear Power Station fudependent Spent Fuel Storage fustallation NRC License No. DPR-3 (NRC Docket No.50-029)

Subject:

Three-Year Update to the fudependent Spent fuel Storage fustallation Decommissioning Funding Plan Pursuant to the requirements of 10 CFR 72.30(c) and 10 CFR 70.4, Yankee Atomic Electric Company (Y AEC) 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 decomniissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous YNPS ISFSI DFP on December 14, 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 YNPS 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, Y AEC complies with the requirements of 10 CFR 72.30(b )( 1) through (b )( 6), as follows.

Yankee Atomic Electric Company BYR2018-025/December 10, 2018/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." Y AEC has established an account within its Nuclear Decommissioning Trust (NDT) entitled, "ISFSI Radiological Decom," that segregates 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 DCE for the YNPS 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 72.30(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 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 YNPS ISFSI DCE estimates the total cost to decommission the YNPS ISFSI to be $9.76 million and$ 10.00 million (in 2018 and 2019 dollars, respectively), inclusive of both radiological and non-radiological removal.

10 CFR 72.30(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. Y AEC will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30(c). On a periodic basis, Y AEC 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.

Y AEC 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. An additional breach of contract damages claim for the period 2013 - 2016 is with tlte 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 GTC:::C waste remain on site.

Annually, YAEC submits the reports required by 10 CFR 50.75(t)(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 2018-025/December 10, 2018/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. In addition, the site will meet the remediation standards established by the Commonwealth of Massachusetts.

IO 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 ISFSI for the management of irradiated fuel and GTCC waste at the YNPS ISFSI through 2036. A revised budget is planned to be submitted to FERC upon receipt of proceeds from the DOE assodated with the Company's Phase N 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 YNPS 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, Carla M. Pizzella Vice President, Chief Financial Officer, and Treasurer

Enclosures:

I.

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

Yankee Atomic Electric Company BYR2018-025/December 10, 2018/Page 4

Reference:

1.

• Letter from C. Pizzella (Y AEC) to Document Control Desk (NRC), Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 14, 2015 (BYR 2015-036) cc:

D. Lew, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region I J. Nguyen, NRC Project Manager J. Giarrusso, Planning, Preparedness & Nuclear Section Chief, MEMA J. Cope-Flanagan, Assistant General Counsel, MDPU R. Tepper, State of Massachusetts Office of the Attorney General

ENCLOSURE 1 TO BYR 2018-025 DECOMMISSIONING STUDY OF THE YANKEE ROWE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Yankee Atomic Electric Company Yankee Rowe ISFSI Page 1 of 10 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012. Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requir~s 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 d_ecommissioning the Yankee* Rowe (YR) 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 Yankee Rowe (YR) was successfully decommissioned. between 1992 and 2007.

During decommissioning all 533 spent fuel assemblies were transferred from the spent fuel pool.to 15 spent fuel storage casks. In addition, 1 GTCC cask 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.

Yankee Atomic Electric Company Yankee Rowe ISFSI Page 2of 10 Completion of the ISFSI decommissioning process is dependent upon the _

DOE's ab_ility to remove spent fuel from the site. DOE's repository program assumes that spent fu~l 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.£2]

3.

ISFSI Decommissioning Strategy At the condusion 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 the Commonwealth of Massachusetts release criteria.

4.

ISFSI Description The YR ISFSI is located on approximately 2 acres of the 1800-acre site. The ISFSI consists of 15 dry storage casks containing 533 spent nuclear fuel assemblies used during operations. The NAC-MPC fuel storage and transport canister system was chosen by YR 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 2003.

In addition to the 15 spent fuel storage casks there is one cask 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 9f 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.

Yankee Atomic Electric Company Yankee Rowe ISFSI Page 3of 10 surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decopimissioning estimate.

Table 1 provides the significant quantities and physical dimensions 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 Yankee Atomic Electric Company (YAEC) all 15 overpacks.and liners which contained spent fuel canisters are assumed to be affected, i.e., contain residual radioactivity. The remaining GTCC overpack is conservatively assumed to be treated in the same manner.

It is assumed for this analysis that the ISFSI pad will be contaminated. As such, the pad 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. YR, 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 waste in a local landfill.

Fencing ISFSI support systems TLG Services, Inc.

Yankee Atomic Electric Company Yankee Rowe ISFSI

• Diesel generator and building Gatehouse ISFSI support building

• Instrument enclosure -conduit and wire Nuisance fence

• Remove road inside licensed area

• Remove vehicle barriers

• Retaining wall Septic system and utilities Costs are reported in 2018 dollars.

Page 4of 10 NUREG-1757.[31 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 YAEC, 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 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 YR 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 rel~ased 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.

a "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and*

Timeliness," U.S. Nucle~r Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-!757, Volume 3, Revision 1, February 2012 TLG Services, Inc.

Yankee Atomic Electric Company Yankee Rowe 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 1are 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), YR'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.

Yankee Atomic Electric Company Yankee Rowe ISFSI Table 1 Page 6of 10 Significant Quantities and Physical_ Dimensions ISFSIPad Residual Item Length (ft)

Width (ft)

Radioactivity ISFSI Pad (dimensions are for current pad) 180 48 Yes ISFSI Overpack Item Value.

Notes (all dimensions are nominal)

NAC:.MPC Overall Height (inches) 160,0 Dimensions are nominal Overall Diameter (inches) 128.0 Dimensions are nominal Inside Diameter (inches) 79.0 Dimensions are nominal Inner Liner Thickness (inches) 3.50 Dimensions are nominal Quantity (total) 16 15 spent fuel + 1 GTCC Quantity (with residual radioactivity) 16 Total Surface Area of overpack interior with Residual 101 Radioactivity (square feet)

Low-Level Radioactive Waste (cubic feet) 47,651 Low-Level Radioactive Waste (packaged density) 51 Other Potentially Impacted Item:s Item Value Notes Number of MPCs used for GTCC storage 1

Residual radioactivity TLG Services, Inc.

Yankee Atomic Electric Company Yankee Rowe ISFSI Table 2 ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Costs Activity Description Decommissioning Contractor Planning (characterization, 142 142 specs and procedures).

Decontamination (activated 127 585 1,646 2,359 liner and concrete removal)

License Termination 505 505 (radiololrical.survevs)

Subtotal 127 585 1,646 647 3,006 Supporting Costs NRC and NRC Contractor Fees 273 273 and Costs Insurance 231 231 Property taxes 173 173 NRCFees 244 244 Site O&M Cost 1,092 1,092 Security Staff Cost 248 248 DOC Staff Cost 733 733 Utility Staff Cost 1,283 1,283 Subtotal 4,276 4,276 TLG Services, Inc.

Burial Volume Class A (cubic feet) 83,135 83,135 Page 7of 10 Oversight Craft and Manhours Contractor Manhours 880 777 3,250 4,027 880 1,153 17,535 7,220 10,676 36,583

Yankee Atomic Electric Company Yankee Rowe ISFSI Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposal

• Other Total Costs Costs Costs Costs Costs Activity Descriution Costs ISFSI Decontamination 127 585 1,646 4,923 7,282 Total (w/o contine:ency)

ISFSI Decontamination 140 644 1,811 5,415 8,010 Total (with 10%

contingency)

ISFSI Site Restoration Building removal - Inside fence Fencing (linear foot) 3 3

ISFSI support systems 46 46 Building removal - Outside fence Diesel Generator and 0

0 Building Gatehouse 16 16 ISFSI Support Building 34 34 Instrument Enclosure -

0 0

conduit and wire Nuisance Fence 141 141 Remove road inside licensed 45 45 area Remove vehicle barriers 1

1 Retaining Wall 10 10 Septic System and Utilities 3

3 TLG Services, Inc.

Burial Volume Class.A (cubic feet) 83,135 Page 8 of 10 Oversight Craft and Manhours Contractor Manhours 4,027 37,463 33 614 1

166 252 0

1;571 430 8

51 17

Yankee Atomic Electric Company Yankee Roive ISFSI Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Activity Description Costs Construction debris 22 22 Site restoration 3

3 Subtotal 301 22 323 Supporting Costs Insurance 38 38 Property taxes 29 29 Heavy equipment rental 57 57 NRCFees 40 40 Site O&M Cost 181 181' Security Staff Cost 41 41 DOCStaffCost 121 121 Utility Staff Cost 213 213 Severance 548 548 Subtotal 57 1,211 1,269 ISFSI Site Restoration 359 1,233 1;591 Total (w/o continl?encv)

ISFSI Site Restoration 395 1,356 1,751 Total (with 10%

contingency)

Total (w/o contingency) 486 585 1,646 6,156 8,873 Total (w/10% contingency) 535 644 1,811 6,771 9,760 TLG Services, Inc.

Burial Volume Class A (cubic feet)

I 83,135 Page 9of 10 Oversight Craft and Manhours Contractor Manhours 12 3,156 2,906 1,197 1,769 5,872 3,156 5,872

• 7,182 43,336

Yankee Atomic Electric Company Yankee Rowe 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 suooort systems Diesel generator and building Gatehouse ISFSI suooort building Instrument enclosure. -conduit and wire Nuisance Fence Remove road inside licensed area Remove vehicle barriers Retaining wall Septic system and utilities TLG Services:, Inc.

Page lOof 10

ENCLOSURE 2 TO lJYR 2018-025 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 (Y ABC) 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 IO 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 Y ABC 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 IO CFR 72.30, as described in the letter to whfoh 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:

$ 8.01 million (in 2018 dollars, inclusive of contingency)

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

ENCLOSURE 3 TO BYR 2018-025 TOTAL COSTS ASSOCIATED WITH THE YNPS ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

Yankee Atomic Electric Company Irradiated Fuel & GTCC Waste Management and ISFSI Decom Estimate Represented in 2019 Dollars FERC Summary Contingenc)

Insurance Labor* Non-Manual Labor-Soo.zrily Materials & Suppliei Miscellanoout Outside Services-MG outsldo SeMoos-Fuel loacfinc:

Outstdo Servlces-lSFSI OP'l!

Outalde Servloo11-Logal Out&.!de Services - NON-RAO D&D of JSFS Out&kfe Services-RAD D&O of JSFS Property Tax.ii:

RegulatDryFeea

Ulilitie, sumot2019 sumof2020 sumof2021 Sumof2022 Sumot2023 Sumof2024 Sumof2025 Sumof202B Sumot2027 Sumof2021 Sumof2029 Sumof2030 Sumof2031 Sumof2032 Sumof2033 sumot20J.4 sumof2035 493,604 $

556,319 510,810 S 499,045 $

430,124 $

,985 $

448,969 $

442,327 $

428,852 $

422,808 $

446,769 $

440,900 $

427,251 422,808 $

910,338 $

925,199 499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,628 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 $

499,828 2.B76,ZT7 $

2,665,508 $ 2.415,185 $ 2,415,185 $ 2,415,185 $ 2,415,185 $ 2,415,185 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,338,875 $ 2,353,852 3,015,294 $

3,015,294 $ 3,015,294 S 3,015,294 $ 3,015,294 $ 3,015,294 $ 3,015,294 S 3,015,294 $ 3,015,294 $ 3,015,294

$ 3,015,294 $ 3,015,294 $ 3,015,294 $ 3,015,294 $ 3,015,294 $ 3,015,294 93,689 $

93,689 $

93,689 $

93,689 $

93,689 $

93,689 $

93,689 S 93,689 S 93,689 S 93,689 $

93,689 $

83,689 $

93,689 $

93,689 $

93,689 $

93,689 130,681 $

130,681 130,681 130,681 130,681 130,681 $

130,681 130,681 $

130,681 130,681 130,681 $

130,681 130,681 130,681 130,681 130,681 604,163 $

632,431 590,701 571,856 $

550,318 $

625,700 $

550,318 $

612,239 $

610,893 $

571,856 $

604,163 $

571,856 $

590,701 571,856 $

550,318 $

571,856 S

S S

S S

S S

S S

$279,992$753,823 1,692,334 $

2,929,143 $ 1,934,096 $ 1,744,563 S 737,ff!O $

679,518 $

737,fflO S 848,134 S 7Zl,ffl8 $

846,134 $

718,132 $

657,980 $

718,132 $

646,134 $

657,980 $

323,067 215,378 $

215,378 $

592,290 $

565,368 $

215,378 $

215.378 $

592,290 $

565,368 $

215,378 $

215,378 S 592,290 $

565,368 $

215,378 $

215,378 $

592,290 $

565,368 s

s s

s s

s s

s s

s s

$ 1,794,ns S

S S

S S

S S

S S

S S

S

$8,210,250 376,912 $

376,912 $

376,912 $

378,912 $

376,912 S 376,912 $

378,912 $

376,912 S 378,912 $

376,912 S 378,912 $

378,912 S 376,912 $

378,912 $

378,912 $

376,912 492,139 S 492,139 $

492,139 $

492,139 S 492.139 $

492.139 $

492,139 $

492,139 $

492,139 $

492,139 $

492.139 $

492,139 $

492,139 $

492,139 $

492,139 $

492,139 75,382 $

75,382 S 75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 $

75,382 Sum of 2038 Sum ofTotab 20184038

780, 9,017,815

$ 1,222,317 $

9,219,583

$ 2,336,232 $

40,818,892 538,445 S 48.783,145 93,689 $

1,592,721 130,304 $

2,221,195

$

• 939,910 S 10,321,135 1,033,815 S

308,375 S 16,499,041

$ 1,453,802 $

7,8lJT,457 1.794,ns S

8,210,250 107,689 $

6,138,277 600,905 $

8,475,129 75,382 S 1,281,500 Grand Total 10.365,680 s 11.682,103 s10.121,ooo s10,479,940 s 9,032,599 s 9,050,691 s a,428,357 s s,288,868 s s,005,902 s e.a1s,en s 9,382.154 s s.258.904 s as12.262 s e.s78,977 s,0,013.717 s10,1n,1ss s,o.oos.025 s e,585,557 s 173,214,509 (Sourcs

• LT /SFS/ Bus Ops\\3 Company Budgels\\Fina/ FERC 2016 Budgets\\YA-2016 FERC Budget /2036) F/NAl._0719)

Note 1: The cost of management of Irradiated fuel and GTCC waste Is calculated as foUows:

$ 173,214,509 Grand Total from Above (1,794,nSJ Non-Rad D&D JSFSJ (per 2018 Knight Cost Study)

{8,210 250) Rad D&D ISFSI (per2018 Knight Cost Study)

$163,209,484 Management of Irradiated Fuel and GTCC Wasta Note 2: The cost of RAD and NO~RAD D&D ofthe lSFSI in 2019 doUars as provided Ill the column labeled *sum of203S" Is derived by escalating the value of the cost estimates provided In Enclosure 1 by2.5%.

Note 3: This Summary Combines YR's 2016 Approved FERC Rate Case with the TLG SeNices 2018 RAD and NON-Rad ISFSI Decom Cost Estimate Check Sum 173,214.509