CY-18-021, Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan

Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan

ML18354A741
Person / Time
Site:	Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/10/2018
From:	Pizzella C Connecticut Yankee Atomic Power Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CY-18-021
Download: ML18354A741 (20)

Text

CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT PLANT 362 'INJUN HOLLOW ROAD

• EAST HAMPTON, CT 06424-3099 December 10, 2018 CY-18-021 Re: 10 CFR 72.4 and 10 CFR 72.30 ATTN: Document Control Desk, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 rZ-039 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License No. DPR-61 (NRC Docket No. 50-213)

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, Connecticut Yankee Atomic Power Company (CYAPCO) is providing the three-year update to the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Haddam Neck Plant (HNP) ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous HNP 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 HNP 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 preyious cost estimate.

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

10 CFR 72.30(b)(l) requires the licensee to provide "information on how reasonable assurance will be provided that funds will be available to decommission the ISFSL" CYAPCO has * *

• _.* * *_ _ . . - *. . * ;JfV/552?,

JV /J/ 5 5

Connecticut Yankee Atomic Power Company CY-18-021/December 10, 2018/Page 2 established an account within its Nuclear Decommissioning Trust (NOT) 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 HNP 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 HNP 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 HNP 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 HNP ISFSI DCB estimates the total cost to decommission the HNP ISFSI to be $19.41 million and $19.9 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 DCE. Enclosure 1 provides the revised DCE for the HNP ISFSI, including the key assumptions and the justification for their use.

10 CFR 72.3 O(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. CYAPCO will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30(c).

On a periodic basis, CYAPCO 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.

CYAPCO 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 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, CYAPCO 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 th~t 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 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

Connecticut Yankee Atomic Power Company CY-18-021/December 10, 2018/Page 3 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 State of Connecticut.

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 HNP ISFSI for the management of irradiated fuel and GTCC waste at the HNP 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 HNP 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 cc:mtact me at (860) 267-6426 x304.

Respectfully,

~""

Vice President, Chief Financial Officer, and Treasurer

Connecticut Yankee Atomic Power Company CY-18-021/December 10, 2018/Page 4

Enclosures:

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

2. Certification of Financial Assurance

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

Reference:

1. Letter from C. Pizzella (CYAPCO) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 14, 2015 (CY-15-042) cc: D. Lew, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region 1 J. Nguyen, NRC Project Manager J. Semancik, Director, CT DEEP, Radiation Division M. Firsick, CT DEEP, Radiation Division

ENCLOSURE 1 TO CY-18-021 DECOMMISSIONING STUDY OF THE CONNECTICUT YANKEE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI - Page 1 of 11 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,[ll 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 Connecticut Yankee (CY) Independent Sperit 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 Connecticut Yankee (CY) was successfully decommissioned between 1998 and 2007. During decommissioning all 1,019 spent fuel assemblies were transferred from the spent fuel pool to 40 spent fuel storage casks. In addition, 3 GTCC casks containing segmented sections of the reactor internals are stored on the spent fuel storage pad. There are also two spent fuel transfer casks stored on the pad. The fuel transfer casks are assumed to remain on-site until 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.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page2o/ 11 decommissioning and the disposition of which is included in this estimate. The ISFSI is operated under a Part 50 General License.

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 reactorJ2J

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 the State of Connecticut release criteria.

4. ' ISFSI Description The CY ISFSI is located on approximately 5 acres of the 525 acre site. The ISFSI consists .of 40 dry storage casks containing 1,019 spent nuclear fuel assemblies used during operations. The NAC-MPC fuel storage and transport canister system was chosen by CY 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 in 2002. Transferring the spent fuel from the spent fuel pool to the storage casks was completed in March of 2005.

In addition to the 40 spent fuel storage casks there are 3 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 remainil).g 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.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 3of 11 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 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 Connecticut Yankee Atomic Power Company (CYAPCo) all 40 overpacks and liners which contained spent fuel canisters are assumed to be affected, i.e., contain residual radioactivity. The remaining three GTCC overpacks are conservatively assumed to be treated in the same manner.

The decommissioning estimate assumes that some residual contamination may be present within the NAC transfer casks. For purposes of this estimate, the transfer casks are shipped for controlled disposal as low-level radioactive waste.

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. CY, as licensee, will oversee the site activities.

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

TLG Services, Inc.

Connecticut Yankee Atomic Power Co1J1,pany Attachment 1 Connecticut Yankee ISFSI Page 4of 11 The following buildings are disposed of as clean waste in local landfill.

• Fencing

• Asphalt paving

• Emergency electrical enclosure

• ISFSI support systems

• Conduit and wire from the SAS to pad

• Diesel generator

• Emergency operations facility

• Power supply (buried) to security alarm station

• Remove security fence, light towers, access road

• Remove road inside licensed area

• Remove vehicle barriers

• Security alarm station (SAS)

• Septic system I

• ISFSI support building

• Vehicle barrier 1 (steel)

• Vehicle barrier 2 (steel)

Costs are reported in 2018 dollars. Costs do not includ~d Connecticut sales tax.

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 CYAPCo, 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 CY 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 CY 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:

a "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.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 5of 11 (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.

(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 Oiner 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), CY'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.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 6of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity ISFSI Pads (dimensions are for current pad) 228 70 Yes Concrete Paved Road 284 18 No ISFSI Overpack Item Value Notes (all dimensions are nominal)

CY-MPC Overall Height (inches) 190.6 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) 43 40 spent fuel + 3 GTCC Quantity (with residual radioactivity) 43 Total Surface Area of overpack interior with Residual 15,377 Radioactivity (square feet)

Low-Level Radioactive Waste (cubic feet) 153,121 Low-Level Radioactive Waste (packaged densitv) 54 Other Potentially Impacted Items Item Value Notes Transfer Cask 2 Residual radioactivity Number of MPCs used for GTCC storage 3 Residual radioactivity TLG Services, Inc.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 7of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes Burial Oversight LLRW Removal Packaging Transport Other Total Volume Craft and Disposal Costs Costs Costs Costs Costs Class A Manhours Contractor Costs Activity Description (cubic feet) Manhours Decommissioning Contractor Planning (characterization, - - - - 142 142 - - 880 snecs and nrocedures)

Decontamination (activated 312 1,617 65 4,038 - 6,032 215,264 2,545 -

liner and concrete removal)

License Termination - - - - 474 474 - 2,938 -

(radiological surveys)

Subtotal 312 1,617 65 4,038 616 6,648 215,264 5,483 880 Supporting Costs NRC and NRC Contractor Fees - - - - 273 273 - - 1,153 and Costs -

Insurance - - - - 517 517 - - -

Pronertv taxes - - - - 1,201 1,201 - - -

Plant energy budget - - - - - - - - -

NRCFees - - - - 732 732 - - -

Site O&M Cost - - - - 1,745 1,745 - - -

Security Staff Cost - - - - 418 418 - - 29,547 TLG Services, Inc.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 8 of 11 Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes Burial Oversight LLRW Removal Packaging Transport Other Total Volume Craft and Disposal Contractor Costs Costs Costs Costs Costs Class A Manhours Costs (cubic feet) Manhours Activity Description DOC Staff Cost - - - - 1,235 1,235 - - 12,167 Utility Staff Cost - - - - 1,978 1,978 - - 17,989 Subtotal - - - - 8,098 8,098 - - 60,856 ISFSI Decontamination 312 1,617 65 4,038 8,714 14,746 215,264 5,483 61,736 Total (w/o contingency)

ISFSI Decontamination 343 1,778 72 4,442 9,586 16,221 - - -

Total (with 10%

contingency)

ISFSI Site Restoration Asbestos removal 167 0 - 4 - 171 474 1,196 -

Building removal - Inside fence Fencing (linear foot) 8 - - - - 8 - 96 -

Remove asphalt paving 22 - - - - 22 - 216 -

Emergency electrical 4 - - - - 4 - 50 -

enclosure ISFSI support systems 68 - - - - 68 - 908 -

Building removal - Outside fence Conduit and wire from the 1 - - - - 1 - 5 -

SAS to pad TLG Services, Inc.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 9of 11 Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes Burial Oversight LLRW Removal Packaging Transport Other Total Volume Craft and Disposal Costs Costs Costs Costs Costs Class A Manhours Contractor Activity Description Costs (cubic feet) Manhours Diesel Generator 0 - - - - 0 - 1 -

Emergency operations 343 - - - - 343 - 2,357 -

facility Power to the Security alarm 0 - - - - 0 - 2 -

station Security fence, light towers, 14 - - - - 14 - 71 -

access road Remove road inside licensed 15 - - - - 15 - 141 -

area Remove vehicle barriers 1 - - - - 1 - 4 -

Security alarm station 16 - - - - 16 - 166 -

Septic system 0 - - - - 0 - 2 -

ISFSI support building 35 - - - - 35 - 252 -

Vehicle barrier 1 (steel) 8 - - - - 8 - 90 -

Vehicle barrier 2 (steel) 5 - - - - 5 - 54 -

Construction debris - - - - 23 23 - - -

Site restoration 6 - - - - 6 - 25 -

Subtotal 713 0 - 4 23 741 - 5,635 -

Supporting Costs Insurance - - - - 102 102 - - -

TLG Services, Inc.

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 10 of 11 Table 2 (continued)

ISFSI Decommissioning Costs and Waste Volumes Burial Oversight LLRW Removal Packaging Transport Other Total Volume Craft and Disposal Costs Costs Costs Costs Costs Class A Manhours Contractor Costs Activity Description (cubic feet) Manhours Property taxes - - - - 236 236 - - -

Heavy equipment rental 115 - - - - 115 - - -

Plant energy budget - - - - - - - - -

NRCFees - - - - 144 144 - - -

Site O&M Cost - - - - 343 343 - - -

Security Staff Cost - - - - 82 82 - - 5,813 DOC Staff Cost - - - - 243 243 - - 2,393 Utility Staff Cost - - - - 389 389 - - 3,539 Severance - - - - 505 505 - - -

Subtotal 115 - - - 2,045 2,160 - - 11,745 ISFSI Site Restoration 828 0 - 4 2,068 2,901 - 5,635 11,745 Total (w/o contine:ency)

ISFSI Site Restoration 911 0 - 5 2,275 3,191 - - -

Total (with 10%

contine:ency)

Total (w/o contingency) 1,140 1,617 65 4,043 10,782 17,647 215,264 11,119 73,481 Total (w/10% 1,254 1,778 72 4,447 11,861 19,411 - - -

contine:ency)

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Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI

• Page 11 of 11 Table 3 ISFSI Decommissioning - Structures Contaminated Removal Transfer Cask Assembly Cask inner liner Cask lid Cask base & misc. Internal fixtures VCC Concrete ISFSI Concrete Pad Clean Removal Remove Fencing Oinear foot)

Remove Asphalt Paving Emergency Electrical Enclosure ISFSI Support systems Conduit and Wire SAS to pad Diesel Generator EOF Power to SAS Remove Security Fence, towers, access road Remove road inside licensed area Remove vehicle barriers SAS Building Septic System Support Building ISFSI Vehicle barrier 1 (steel)

Vehicle barrier 2 (steel)

TLG Services, Jnc.

ENCLOSURE 2 TO CY-18-021 CERTIFICATION OF FINANCIAL ASSURANCE

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licensee:

Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC No. DPR-61 (NRC Docket No. 50-213) 362 Injun Hollow Road East Hampton, CT 06424-3099 Issued to: U.S. Nuclear Regulatory Commission Certification:

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

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

• I further certify that financial assurance in an amount sufficient to fund HNP 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:

HNP ISFSI $16.22 million (in 2018 dollars, inclusive of contingency)

Uv---~e:

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

ENCLOSURE 3 TO CY-18-021 TOTAL COSTS ASSOCIATED WITH THE HNP ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

2013-2033 Summary (UNESCALATEO)

ConneGUcut Yankee Atomlc Po\Ner Company lrradlted Fuel & GTCC Waste Management and ISFSI Decom EsUmate Represented In 2019 Dollars FERCSummary Sumof2019 Sumof2020 Sum of2021 Sumof2022 sumof2023 Sumof202' Sumof2025 Sumof2026 Sumof2027 Sumof2028 Sum of2029 Sumof2030 Sumof2031 sumof2032 Sumof2033 Sumof2034 Sumof2035 Sumof2036 SumofTotal2019-2036 Contingency 676,971 729,860 689,040 677,073 608,691 611,141 625,921 618,336 606,653 602,182 625,012 619,439 603,259 744,870 635,859 1,437,402 2,570,326 $13,682,235 GE Morris 1,971,518 1,971,518 1,971,518 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 1,938,403 $33,052,196 lnsurance 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 647,194 $11,002,298 Labor-No~anuaJ 2,469,705 2,469,705 2,261,480 2,261,480 2,261,480 2,261,480 2,261,480 2,185,150 2,185,150 2,185,150 2,185,150 2,185,150 2,185,150 2,185,150 2,185,150 2,200,226 2,226,072 $38,154,308 Lmor-Seeurity 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 3,122,983 $53,090,711 Materia!s & Suppies 113,074 139,996 113,074 113,074 123,842 139,996 113,074 113,074 113,074 139,996 113,074 123,842 113,074 2,993,756 113,074 113,074 91,536 $4,883,704 Miscellaneous 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 141,073 $2,398,241 Outside Services-A&G 650,227 652,650 592,074 592,074 592,074 650,227 592,074 592,074 652,650 592,074 650,227 592,074 592,074 592,074 592,074 592,074 538,230 $10,307,025 Outside Se~- Fuel Loading Outside Services- lSFSJ OP's 1,ns,so2 2,753,932 1,856,344 1,677,042 648,611 623,304 627,073

- 578,613 638,381 578,613 627,073

- 589,921 627,073 578,613 902,158 2,315,315 255,546 2,055,784 186,625

$4,371,099

$15,474,424 Outside Semces-Lega 289,145 289,145 666,057 639,135 289,145 289,145 666,057 639,135 289,145 289,145 666,057 639,135 289,145 289,145 666,057 639,135 289,145 $7,823,073 Outside Services- NON-RAD D&D oflSFSI - - - - 3,210,ns $3,270,775 Outside Services-RAD D&DoflSFSI Property Taxes 1,399,958 1,399,958 1,399,958 1,399,958

- 1,399,958 1,399,958 1,399,958 1,399,958 1,399,958 1,399,958 1,399,958

- 1,399,958 1,399,958 1,399,958 1,399,958 1,399,958 2,189,277 16,626,525 $16,626,525

$24,588,605 Regulatory Fees 912,126 912,126 912,126 912,126 912,126 912,126 912.126 912,126 912,126 912,126 912,126 912,126 912,126 912,126 912,126 912,126 879,820 $15,473,836 Utities $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $96,920 $98,920 $96,920 $96,920 $96,920 $96,920 $96,920 $1,647,640 Grand Total $14,216,396 $15,327,060 $14,469,841 $14,218,535 $12,782,500 $12,833,950 $13,14',336 $12,985,039 $12.743,910 $12,645,817 $13,125,250 $13,008,218 $12,668,432 $15,642,265 $13,353,029 $15,811,429 $16,973,388 $19,897,300 $255,846,695 Check Sum Note 1: The cost of management of Irradiated fuel and GTCC waste is calculated as folows:

$ 255,846,695 GrandTotalfromAbove

$ (3,270,775) Non-Rad D&D ISFSI

$ (16,626,525) Rad D&D ISFSI

$ 235,949,395 Management of lrracfiated Fuel and GTCC Waste Note 2: The cost of RAD and NON-RAD D&D of the ISFSI ii 2019 dollars as provided In the cokJmn labeled nsum of2036" ls derilled by escalating the v.iue of the cost estimates provided in Enclosure 1 by 2.5%.

Note 3: This Summary Combines CY's 2016 Approved FERC Rate case with the TLG Ser\'lces 2018 RAD and NO~ad ISFSI Oecom Ccst EQimate