NL-19-1125, Independent Spent Fuel Storage Installation - Decommissioning Funding Plan Triennial Update

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Independent Spent Fuel Storage Installation - Decommissioning Funding Plan Triennial Update
ML20091K821
Person / Time
Site: 07200042, 07200036, 07201039
Issue date: 03/31/2020
From: Gayheart C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
NL-19-1125
Download: ML20091K821 (32)


Text

SNC Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205.992.5000 tel 205.992.7795 fax March 31, 2020 NL-19-1125 Docket Nos.: 72-36 72-42 72-1039 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Ladies and Gentlemen:

In accordance with 10 CFR 72.30(b) and (c), Southern Nuclear Operating Company (SNC) hereby submits the enclosed Independent Spent Fuel Storage Installation (ISFSI) decommissioning funding plans for Joseph M. Farley Nuclear Plant (Farley) Units 1 and 2 (Docket 72-42), Edwin I.

Hatch Nuclear Plant (Hatch) Units 1 and 2 (Docket 72-36), and Vogtle Electric Generating Plant (Vogtle) Units 1 and 2 (Docket 72-1039).

This letter contains no NRC commitments. If you have any questions or if additional information is needed, please contact Jamie Coleman at 205.992.6611.

Respectfully submitted, Cheryl Gayheart Regulatory Affairs Director efb/scm

Enclosures:

1. Farley ISFSI Decommissioning Funding Plan Triennial Update
2. Hatch ISFSI Decommissioning Funding Plan Triennial Update
3. Vogtle ISFSI Decommissioning Funding Plan Triennial Update

U. S. Nuclear Regulatory Commission NL-19-1125 Page 2 cc:

NRC Director - Division of Spent Fuel Management NRC Region II Regional Administrator NRC NRR Project Manager - Farley, Hatch, and Vogtle NRC Senior Resident Inspector - Farley, Hatch, and Vogtle Alabama Power Company Georgia Power Company Oglethorpe Power Corporation Municipal Electric Authority of Georgia Dalton Utilities SNC Document Control R-Type: PP1.006

Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Farley ISFSI Decommissioning Funding Plan Triennial Update to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 1 Joseph M. Farley Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, with the rule becoming effective on December 17, 2012. Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that Southern Nuclear Operating Company (SNC) submit for NRC review and approval a decommissioning funding plan that demonstrates reasonable assurance that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update, including a detailed cost estimate, with adjustments as necessary to account for changes in costs and site conditions. This enclosure also provides the key assumptions contained in the cost estimate, and the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Spent Fuel and ISFSI Management Strategy The operating licenses for the Farley Nuclear Plant (Farley) Units 1 & 2 are currently set to expire on June 25, 2037 and March 31, 2041 respectively. Approximately 5,520 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The Farley ISFSI currently has 59 loaded casks on the pad and is licensed and operated in accordance with the general license provisions of 10 CFR 72.210.

Assuming that the plant operates to the end of its currently licensed life, the spent fuel pools are expected to contain a total of approximately 1,340 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and allow termination of the Part 50 license using the DECON method described in NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. The SNC spent fuel management plan for Farley assumes: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and 2) completion of spent fuel receipt by year 2075. The completion date is based on DOEs allocation/receipt schedules with the oldest fuel receiving the highest priority.

The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/year.

At the conclusion of the spent fuel transfer process, the ISFSI will be promptly decommissioned (consistent with the DECON option) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 2 ISFSI Description The Farley ISFSI uses a Holtec International (Holtec) HI-STORM 100 dry storage system. The HI-STORM 100 is comprised of a multi-purpose canister (MPC) and storage overpack. The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining overpacks are assumed to have residual radioactivity due to neutron-induced activation resulting from long-term storage of the spent fuel.

SNCs current spent fuel management plan for Farley spent fuel would result in 122 spent fuel storage casks (32 assemblies per cask) being placed on a storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents approximately 71% of the total spent fuel projected to be generated during the currently licensed operating period. The balance of the fuel assemblies is assumed to have been transferred directly to the DOE from the Farley spent fuel pools.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 8) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

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 unit operating until the end of its current license, (Unit 1 - June 25, 2037; Unit 2 - March 31, 2041), and the assumptions associated with DOEs spent fuel acceptance, as previously described.

The size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is assumed to be 43,000 square feet in surface area.

Some of the inner steel-liners of the HI-STORM concrete overpacks, 10 of the 122 total, are assumed to contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. The estimate is based upon the number of casks required for the final core off-load (i.e., 157 offloaded assemblies, 32 assemblies per cask) which results in 5 overpacks per unit. It is assumed that these are the final overpacks to be emptied of their spent fuel casks because the DOE plans to dispose of the oldest fuel first. These final 10 overpacks are assumed to be disposed of before sufficient time has elapsed for radioactive decay of the neutron activation products.

This analysis assumes that good radiological practices are employed, and there will be no residual contamination left on the concrete ISFSI pad or other facilities at the Farley ISFSI. Consequently, only verification surveys are assumed in the decommissioning estimate.

There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 3 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. The estimate includes labor and overhead for SNC oversight of the contractor, SNC security, and other site operating costs.

Low-level radioactive waste disposal costs are based on SNCs current cost of disposal at the EnergySolutions Clive, Utah disposal site.

Costs are reported in 2018 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.

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

In accordance with 10 CFR 72.30(c)(1)-(4), the following 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 Farley 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; therefore, no actual remediation costs exceed the previous cost estimate.

All expenditures are conservatively assumed to be incurred in the year 2076, the year following all spent fuel removal.

Cost Estimate and Financial Assurance Certification The estimated cost to decommission the Farley ISFSI and release the facility for unrestricted use is provided in Table 2.

Adequate funds for decommissioning of the Farley ISFSI are assured by the same external sinking fund method used for the nuclear decommissioning trust (NDT) fund established for each unit in accordance with 10 CFR 50.75. The Farley NDTs are maintained and adjusted as necessary to ensure that the total amount of funds is sufficient to pay the ISFSI decommissioning costs.

to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 4 The Farley ISFSI decommissioning cost estimate is derived from a comprehensive site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following removal of the spent fuel. The estimated costs are adjusted to reflect current assumptions regarding the cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the ISFSI into the scope of the Farley decommissioning cost study, and its use for cost-of-service ratemaking, provide assurance that adequate funding will be available as required by 10 CFR 72.30.

Financial assurance that adequate funds are available to decommission the ISFSI may be summarized as follows:

  • Site specific cost studies have historically included the cost to decommission the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
  • An external sinking fund was established in accordance with 10 CFR 50.75 for the original 40-year operating license period. Under the renewed license, these funds continue to accumulate interest for an additional 20 years.
  • The most recent Farley decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $11,156,000 (2018$) shared by both operating units. The estimates are included in Table 3.
  • The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. However, in accordance with 10 CFR 72.30(b), funds for decommissioning the ISFSI are provided and accounted for separate from the requirements of 10 CFR 50.75(b). As shown in Table 3, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Farley Units 1 and 2.

to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 6 Table 1 Significant Quantities and Physical Dimensions Item Area (ft2)

Notes ISFSI Pad 43,000 No residual radioactivity ISFSI Overpack (HI-STORM 100S Version B)

Item Value Notes Overall Height (inches) 218.0 Outside Diameter (inches) 132.0 Main cylindrical body of overpack Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.25 Quantity (total) 130 Spent Fuel 122 + GTCC 8 Quantity (with residual radioactivity) 10 The number of overpacks used to store the last complete core offloads Total Surface Area of Overpack Inner Liner with Residual Radioactivity (square feet) 3,167 Low-Level Radioactive Waste (cubic feet) 50,626 Low-Level Radioactive Waste (packaged density-lbs./cu.ft.)

53 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 8

No residual radioactivity Transfer Cask 1

No residual radioactivity to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 7 Table 2 ISFSI Decommissioning Costs1 and Waste Volumes (thousands, 2018 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee NRC Decommissioning Contractor Planning (characterization, specs and procedures) 400 400 1,216 Remediation (activated liner removal) 268 203 1,196 2,738 25 4,430 50,626 2,965 License Termination (radiological surveys) 1,995 1,995 16,586 Subtotal 268 203 1,196 2,738 2,421 6,825 50,626 19,551 1,216 Supporting Costs NRC and NRC Contractor Fees and Costs 380 380 776 Insurance 179 179 Property Tax 2

2 Site Overheads 35 35 ISFSI Operating Costs 53 53 Corporate Overheads 174 174 Security (Industrial) 977 977 17,780 Farley Oversight Staff 298 298 3,761 Subtotal 2,098 2,098 21,541 Total (w/o contingency) 268 203 1,196 2,738 4,519 8,923 50,626 19,551 22,757 776 Total (with 25% contingency) 11,156 Note 1: Costs are assumed to be incurred in year 2076.

to NL-19-1125 Farley ISFSI Decommissioning Funding Plan Triennial Update E1 - 8 Table 3 - Financial Assurance - Alabama Power Company 1 Calculated using NUREG-1307, Rev. 17, for the burial factor, the Dec. 2019 BLS data for labor, and the Sept. 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75(b) and (c) (Dec 2019$)

$485,355,5091

$485,355,5091 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$518,777,489

$501,976,830 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 4.5%

7.0%

2.5%

4.5%

7.0%

2.5%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75(b) and (c) (U1 - year 2037, U2 - year 2041)

$1,071,897,336

$1,278,257,511 5

Projected ending fund balance (U1 - year 2037, U2 year 2041)

$1,709,296,479

$2,132,688,561 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb))

and site restoration for U1 in 2037 and Unit 2 in 2041. Row 5 minus Row 4.

$637,399,143

$854,431,050 7

ISFSI decommissioning cost study estimate (2018$)

$5,578,000

$5,578,000 8

Projected ISFSI decommissioning cost estimate (U1 - year 2037, U2 - year 2041)

$12,873,245

$15,351,584

Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Hatch ISFSI Decommissioning Funding Plan Triennial Update to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 1 Edwin I. Hatch Nuclear Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, with the rule becoming effective on December 17, 2012. Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that Southern Nuclear Operating Company (SNC) submit for NRC review and approval a decommissioning funding plan that demonstrates reasonable assurance that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update, including a detailed cost estimate, with adjustments as necessary to account for changes in costs and site conditions. This enclosure also provides the key assumptions contained in the cost estimate, and the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Spent Fuel and ISFSI Management Strategy The operating licenses for the Hatch Nuclear Plant (Hatch) Units 1 & 2 are currently set to expire on August 6, 2034 and June 13, 2038 respectively. Approximately 14,823 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The Hatch ISFSI currently has 84 loaded casks on the pad and is licensed and operated in accordance with the general license provisions of 10 CFR 72.210.

Assuming that the plant operates to the end of its currently licensed life, the spent fuel pools are expected to contain a total of approximately 4,156 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and allow termination of the Part 50 license using the DECON method described in NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. The SNC spent fuel management plan for Hatch assumes: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and 2) completion of spent fuel receipt by year 2074. The completion date is based on DOEs allocation/receipt schedules with the oldest fuel receiving the highest priority.

The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/year.

At the conclusion of the spent fuel transfer process, the ISFSI will be promptly decommissioned (consistent with the DECON option) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 2 ISFSI Description The Hatch ISFSI uses a Holtec International (Holtec) HI-STORM 100 dry storage system. The HI-STORM 100 is comprised of a multi-purpose canister (MPC) and storage overpack. The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining overpacks are assumed to have residual radioactivity due to neutron-induced activation resulting from long-term storage of the spent fuel.

SNCs current spent fuel management plan for Hatch spent fuel would result in 138 spent fuel storage casks (68 assemblies per cask) and 39 spent fuel storage casks (52 assemblies per cask) being placed on a storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents approximately 77% of the total spent fuel projected to be generated during the currently licensed operating period. The balance of the fuel assemblies is assumed to have been transferred directly to the DOE from the Hatch spent fuel pools.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 6) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

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 unit operating until the end of its current license, (Unit 1 -August 6, 2034; Unit 2 - June 13, 2038), and the assumptions associated with DOEs spent fuel acceptance, as previously described.

The size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is assumed to be 48,500 square feet in surface area.

Some of the inner steel-liners of the HI-STORM concrete overpacks, 22 of the 177 total, are assumed to contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. The estimate is based upon the number of casks required for the final core off-load (i.e., 560 offloaded assemblies, 52 assemblies per cask) which results in 11 overpacks per unit. It is assumed that these are the final overpacks to be emptied of their spent fuel casks because the DOE plans to dispose of the oldest fuel first. These final 22 overpacks are assumed to be disposed of before sufficient time has elapsed for radioactive decay of the neutron activation products.

This analysis assumes that good radiological practices are employed, and there will be no residual contamination left on the concrete ISFSI pad or other facilities at the Hatch ISFSI. Consequently, only verification surveys are assumed in the decommissioning estimate.

There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 3 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. The estimate includes labor and overhead for SNC oversight of the contractor, SNC security, and other site operating costs.

Low-level radioactive waste disposal costs are based on SNCs current cost of disposal at the EnergySolutions Clive, Utah disposal site.

Costs are reported in 2018 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.

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

In accordance with 10 CFR 72.30(c)(1)-(4), the following 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 Hatch 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; therefore, no actual remediation costs exceed the previous cost estimate.

All expenditures are conservatively assumed to be incurred in the year 2076, the year following all spent fuel removal.

Cost Estimate and Financial Assurance Certification The estimated cost to decommission the Hatch ISFSI and release the facility for unrestricted use is provided in Table 2.

Adequate funds for decommissioning of the Hatch ISFSI are assured by the same external sinking fund method used for the nuclear decommissioning trust (NDT) fund established for each unit in accordance with 10 CFR 50.75. The Hatch NDTs are maintained and adjusted as necessary to ensure that the total amount of funds is sufficient to pay the ISFSI decommissioning costs.

The Hatch ISFSI decommissioning cost estimate is derived from a comprehensive site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 4 removal of the spent fuel. The estimated costs are adjusted to reflect current assumptions regarding the cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the ISFSI into the scope of the Hatch decommissioning cost study and its use for cost-of-service ratemaking, provides assurance that adequate funding will be available as required by 10 CFR 72.30.

Financial assurance that adequate funds are available to decommission the ISFSI may be summarized as follows:

  • Site specific cost studies have historically included the cost to decommission the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
  • An external sinking fund was established in accordance with 10 CFR 50.75 for the original 40-year operating license period. Under the renewed license, these funds continue to accumulate interest for an additional 20 years.
  • The most recent Hatch decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $17,191,000 (2018$) shared by both operating units. The estimates are included in Tables 3-6.
  • The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. However, in accordance with 10 CFR 72.30(b), funds for decommissioning the ISFSI are provided and accounted for separate from the requirements of 10 CFR 50.75(b). As shown in Tables 3-6, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Hatch Units 1 and 2.

to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 6 Table 1 Significant Quantities and Physical Dimensions Item Area (ft2)

Residual Radioactivity ISFSI Pad 48,500 No residual radioactivity ISFSI Overpack (HI-STORM 100S Version B)

Item Value Notes (all dimensions are nominal)

Overall Height (inches) 229.0 Outside Diameter (inches) 132.0 Main cylindrical body of overpack Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.25 Quantity (total) 183 Spent Fuel 177 + GTCC 6 Quantity (with residual radioactivity) 22 The number of overpacks used to store the last complete core offloads Total Surface Area of Overpack Inner Liner with Residual Radioactivity (square feet) 7,368 Low-Level Radioactive Waste (cubic feet) 111,265 Low-Level Radioactive Waste (packaged density-lbs./cu.ft.)

53 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 6

No residual radioactivity Transfer Cask 1

No residual radioactivity Cask Transfer Facility 1

No residual radioactivity to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 7 Table 2 ISFSI Decommissioning Costs1 and Waste Volumes (thousands, 2018 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee NRC/ NRC Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 471 471 1,312 Remediation (activated liner removal) 542 493 3,295 5,641 35 10,008 111,265 6,684 License Termination (radiological surveys) 2,043 2,043 16,522 Subtotal 542 493 3,295 5,641 2,549 12,522 111,265 23,206 1,312 Supporting Costs NRC and NRC Contractor Fees and Costs 499 499 1,153 Insurance 87 87 Property Tax 0

0 Security (Industrial) 306 306 2,500 Hatch Oversight Staff 339 339 1,896 Subtotal 1,231 1,231 4,396 1,153 Total (w/o contingency) 542 493 3,295 5,641 3,780 13,753 111,265 23,206 5,708 1,153 Total (with 25% contingency) 17,191 Note 1: Costs are assumed to be incurred in year 2075.

to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 8 Table 3 - Financial Assurance - Georgia Power Company (50.1% Ownership) 1Calculated using NUREG-1307, Rev. 17, for the burial factor, the Dec. 2019 BLS data for labor, and the Sept. 2019 BLS data for energy.

2In addition to the main decommissioning trust fund, which provides a surplus of funds to use for decommissioning the ISFSI, spent fuel management, and site restoration, Georgia Power holds supplemental trust fund accounts, funded through rates in accordance with Georgia PSC Orders, specifically for spent fuel management and decommissioning the ISFSI in the amount of $9,782,660 for Unit 1 and $20,364,360 for Unit 2.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$324,296,6511

$324,296,6511 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$314,119,0002

$289,828,0002 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.79%

4.79%

2.00%

2.80%

4.80%

2.00%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2034, U2 - year 2038)

$490,010,577

$548,039,223 5

Projected ending fund balance (U1 - year 2034, U2 year 2038)

$633,620,000

$706,838,000 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2034 and Unit 2 in 2038. Row 5 minus Row 4.

$143,609,4232

$158,798,7772 7

ISFSI decommissioning cost study estimate (2018$)

$4,306,095

$4,306,095 8

Projected ISFSI decommissioning cost estimate (U1 - year 2034, U2 - year 2038)

$6,688,018

$7,480,763 to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 9 Table 4 - Financial Assurance - Oglethorpe Power Corporation (30% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$194,189,6111

$194,189,6111 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$176,882,446

$139,060,932 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.80%

5.00%

2.20%

2.80%

5.00%

2.20%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2034, U2 - year 2038)

$293,847,982

$328,167,200 5

Projected ending fund balance (U1 - year 2034, U2 year 2038)

$367,725,901

$351,400,049 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2034 and Unit 2 in 2038. Row 5 minus Row 4.

$73,877,919

$23,232,849 7

ISFSI decommissioning cost study estimate (2018$)

$2,578,500

$2,578,500 8

Projected ISFSI decommissioning cost estimate (U1 - year 2034, U2

- year 2038)

$4,011,040

$4,479,499 to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 10 Table 5 - Financial Assurance - Municipal Electric Authority of Georgia (17.7% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$114,571,8711

$114,571,8711 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$135,723,000

$135,421,000 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.25%

4.15%

1.90%

2.25%

4.15%

1.90%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75(b) and (c) (U1 - year 2034, U2 - year 2038)

$165,934,230

$183,160,342 5

Projected ending fund balance (U1 - year 2034, U2 year 2038)

$241,099,000

$279,953,000 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2034 and Unit 2 in 2038. Row 5 minus Row 4.

$75,164,770

$96,792,658 7

ISFSI decommissioning cost study estimate (2018$)

$1,521,315

$1,521,315 8

Projected ISFSI decommissioning cost estimate (U1 - year 2034, U2

- year 2038)

$2,258,401

$2,492,852 to NL-19-1125 Hatch ISFSI Decommissioning Funding Plan Triennial Update E2 - 11 Table 6 - Financial Assurance - Dalton Utilities (2.2% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$14,240,5711

$14,240,5711 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$20,624,312

$20,779,540 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.80%

2.02%

(0.78%)

2.80%

2.02%

(0.78%)

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75(b) and (c) (U1 - year 2034, U2 - year 2038)

$21,548,852

$24,065,595 5

Projected ending fund balance (U1 - year 2034, U2 year 2038)

$27,839,361

$30,384,843 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2034 and Unit 2 in 2038. Row 5 minus Row 4.

$6,290,509

$6,319,248 7

ISFSI decommissioning cost study estimate (2018$)

$189,090

$189,090 8

Projected ISFSI decommissioning cost estimate (U1 - year 2034, U2

- year 2038)

$294,143

$328,497

Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Independent Spent Fuel Storage Installation ISFSI Decommissioning Funding Plan Triennial Update Vogtle ISFSI Decommissioning Funding Plan Triennial Update to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 1 Vogtle Electric Generating Plant - Units 1 and 2 ISFSI Decommissioning Funding Plan Triennial Update Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, with the rule becoming effective on December 17, 2012. Subpart 72.30, Financial assurance and recordkeeping for decommissioning, requires that Southern Nuclear Operating Company (SNC) submit for NRC review and approval a decommissioning funding plan that demonstrates reasonable assurance that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with Subpart 72.30(b) and (c) of the rule, this enclosure provides the required triennial update, including a detailed cost estimate, with adjustments as necessary to account for changes in costs and site conditions. This enclosure also provides the key assumptions contained in the cost estimate, and the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Spent Fuel and ISFSI Management Strategy The operating licenses for the Vogtle Electric Generating Plant (Vogtle) Units 1 & 2 are currently set to expire on January 16, 2047 and February 9, 2049 respectively. Approximately 7,156 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date. The Vogtle ISFSI currently has 34 loaded casks on the pad and is licensed and operated in accordance with the general license provisions of 10 CFR 72.210.

Assuming that the plant operates to the end of its currently licensed life, the spent fuel pools are expected to contain a total of approximately 2,409 spent fuel assemblies after the final core offloads. To facilitate immediate dismantling or safe-storage operations, the spent fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and allow termination of the Part 50 license using the DECON method described in NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. The SNC spent fuel management plan for Hatch assumes: 1) a 2032 start date for DOE initiating transfer of commercial spent fuel to a federal facility, and 2) completion of spent fuel receipt by year 2078. The completion date is based on DOEs allocation/receipt schedules with the oldest fuel receiving the highest priority.

The end date assumes a maximum rate of transfer of 3,000 metric tons of uranium/year.

At the conclusion of the spent fuel transfer process, the ISFSI will be promptly decommissioned (consistent with the DECON option) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 2 ISFSI Description The Vogtle ISFSI uses a Holtec International (Holtec) HI-STORM 100 dry storage system. The HI-STORM 100 is comprised of a multi-purpose canister (MPC) and storage overpack. The MPCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining overpacks are assumed to have residual radioactivity due to neutron-induced activation resulting from long-term storage of the spent fuel.

SNCs current spent fuel management plan for Vogtle spent fuel would result in 93 spent fuel storage casks (32 assemblies per cask) and 78 spent fuel storage casks (24 assemblies per cask) being placed on a storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents approximately 67% of the total spent fuel projected to be generated during the currently licensed operating period. The balance of the fuel assemblies is assumed to have been transferred directly to the DOE from the Vogtle spent fuel pools.

In addition to the spent fuel casks located on the ISFSI pad after shutdown there are projected to be additional casks used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

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 unit operating until the end of its current license, (Unit 1 - January 16, 2047; Unit 2 -

February 9, 2049), and the assumptions associated with DOEs spent fuel acceptance, as previously described.

The size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is assumed to be 57,000 square feet in surface area.

Some of the inner steel-liners of the HI-STORM concrete overpacks, 18 of the 171 total, are assumed to contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. The estimate is based upon the number of casks required for the final core off-load (i.e., 193 offloaded assemblies, 24 assemblies per cask) which results in 9 overpacks per unit. It is assumed that these are the final overpacks to be emptied of their spent fuel casks because the DOE plans to dispose of the oldest fuel first. These final 18 overpacks are assumed to be disposed of before sufficient time has elapsed for radioactive decay of the neutron activation products.

This analysis assumes that good radiological practices are employed, and there will be no residual contamination left on the concrete ISFSI pad or other facilities at the Hatch ISFSI. Consequently, only verification surveys are assumed in the decommissioning estimate.

There is no expected subsurface material in the proximity of the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 3 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. The estimate includes labor and overhead for SNC oversight of the contractor, SNC security, and other site operating costs.

Low-level radioactive waste disposal costs are based on SNCs current cost of disposal at the EnergySolutions Clive, Utah disposal site.

Costs are reported in 2018 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.

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

In accordance with 10 CFR 72.30(c)(1)-(4), the following 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 Vogtle 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; therefore, no actual remediation costs exceed the previous cost estimate.

All expenditures are conservatively assumed to be incurred in the year 2079, the year following all spent fuel removal.

Cost Estimate and Financial Assurance Certification The estimated cost to decommission the Vogtle ISFSI and release the facility for unrestricted use is provided in Table 2.

Adequate funds for decommissioning of the Vogtle ISFSI are assured by the same external sinking fund method used for the nuclear decommissioning trust (NDT) fund established for each unit in accordance with 10 CFR 50.75. The Vogtle NDTs are maintained and adjusted as necessary to ensure that the total amount of funds is sufficient to pay the ISFSI decommissioning costs.

The Vogtle ISFSI decommissioning cost estimate is derived from a comprehensive site-specific decommissioning cost study prepared every three years. The scope of the decommissioning cost to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 4 study includes decommissioning of the reactor facility to permit license termination, management of the spent fuel in accordance with 10 CFR 50.54(bb), and decommissioning the ISFSI following removal of the spent fuel. The estimated costs are adjusted to reflect current assumptions regarding the cost of energy, labor, burial cost, projected capacity, and schedule for removal of fuel from the site. Incorporation of the cost to decommission the ISFSI into the scope of the Vogtle decommissioning cost study and its use for cost-of-service ratemaking, provides assurance that adequate funding will be available as required by 10 CFR 72.30.

Financial assurance that adequate funds are available to decommission the ISFSI may be summarized as follows:

  • Site specific cost studies have historically included the cost to decommission the ISFSI as part of the scope of activities necessary to decommission the Part 50 facility and terminate the Part 50 specific license in accordance with 10 CFR 50.82, Termination of License.
  • An external sinking fund was established in accordance with 10 CFR 50.75 for the original 40-year operating license period. Under the renewed license, these funds continue to accumulate interest for an additional 20 years.
  • The most recent Vogtle decommissioning cost study update estimates the amount necessary for ISFSI decommissioning to be $14,948,000 (2018$) shared by both operating units. The estimates are included in Tables 3-6.
  • The amount allocated for ISFSI decommissioning is held in the same financial instrument as the reactor decommissioning funds required by 10 CFR 50.75. However, in accordance with 10 CFR 72.30(b), funds for decommissioning the ISFSI are provided and accounted for separate from the requirements of 10 CFR 50.75(b). As shown in Tables 3-6, these funds are in excess of the amount required for decommissioning the Part 50 facility and provide adequate assurance that funding for decommissioning the ISFSI will be available upon expiration of the Part 50 operating licenses for Vogtle Units 1 and 2.

to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 6 Table 1 Significant Quantities and Physical Dimensions Item Area (ft2)

Residual Radioactivity ISFSI Pad 57,000 No residual radioactivity ISFSI Overpack (HI-STORM 100S Version B)

Item Value Notes Overall Height (inches) 218 Outside Diameter (inches) 132 Main cylindrical body of overpack Inside Diameter (inches) 73.5 Inner Liner Thickness (inches) 1.25 Quantity (total) 181 Spent Fuel 171 + GTCC 10 Quantity (with residual radioactivity) 18 The number of overpacks used to store the last complete core offloads Total Surface Area of Overpack Inner Liner with Residual Radioactivity (square feet) 5,700 Low-Level Radioactive Waste (cubic feet) 90,527 Low-Level Radioactive Waste (packaged density-lbs./cu.ft.)

54 Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 10 No residual radioactivity Transfer Cask 1

No residual radioactivity Cask Transfer Facility 1

No residual radioactivity to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 7 Table 2 ISFSI Decommissioning Costs1 and Waste Volumes (thousands, 2015 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee NRC/ NRC Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 473 473 1,312 Remediation (activated liner removal) 487 370 2,632 4,557 25 8,071 90,527 5,333 License Termination (radiological surveys) 2,157 2,157 17,580 Subtotal 487 370 2,632 4,557 2,655 10,701 90,527 22,913 1,312 Supporting Costs NRC and NRC Contractor Fees and Costs 494 494 1,153 Insurance 87 87 NRC ISFSI Fees 38 38 Security (Industrial) 469 469 9,733 Vogtle Oversight Staff 170 170 1,912 Subtotal 1,257 1,257 3,824 1,153 Total (w/o contingency) 487 370 2,632 4,557 3,912 4,890 90,527 22,913 12,957 1,153 Total (with 25% contingency) 14,948 Note 1: Costs are assumed to be incurred in year 2079.

to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 8 Table 3 - Financial Assurance - Georgia Power Company (45.7% Ownership) 1Calculated using NUREG-1307, Rev. 17, for the burial factor, the Dec. 2019 BLS data for labor, and the Sept. 2019 BLS data for energy.

2In addition to the main decommissioning trust fund, which provides a surplus of funds to use for decommissioning the ISFSI, spent fuel management, and site restoration, Georgia Power holds supplemental trust fund accounts, funded through rates in accordance with Georgia PSC Orders, specifically for spent fuel management and decommissioning the ISFSI in the amount of $19,864,492 for Unit 1 and $29,509,689 for Unit 2.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$234,256,5291

$234,256,5291 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$157,182,0002

$173,052,0002 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.69%

4.69%

2.00%

2.70%

4.70%

2.00%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2047, U2 - year 2049)

$492,583,672

$520,960,759 5

Projected ending fund balance (U1 - year 2047, U2 year 2049)

$569,441,000

$686,202,000 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2047 and Unit 2 in 2049. Row 5 minus Row 4.

$76,857,3282

$165,241,2412 7

ISFSI decommissioning cost study estimate (2018$)

$3,415,618

$3,415,618 8

Projected ISFSI decommissioning cost estimate (U1 - year 2047, U2

- year 2049)

$7,375,403

$7,801,050 to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 9 Table 4 - Financial Assurance - Oglethorpe Power Corporation (30% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$153,778,9031

$153,778,9031 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$103,192,374

$93,474,746 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.70%

5.00%

2.30%

2.70%

5.00%

2.30%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2047, U2 - year 2049)

$324,241,932

$341,987,369 5

Projected ending fund balance (U1 - year 2047, U2 year 2049)

$404,527,430

$403,992,467 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2047 and Unit 2 in 2049. Row 5 minus Row 4.

$80,285,498

$62,005,098 7

ISFSI decommissioning cost study estimate (2018$)

$2,242,200

$2,242,200 8

Projected ISFSI decommissioning cost estimate (U1 - year 2047, U2

- year 2049)

$4,855,313

$5,121,039 to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 10 Table 5 - Financial Assurance - Municipal Electric Authority of Georgia (22.7% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$116,359,3701

$116,359,3701 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$135,953,000

$130,969,000 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.25%

4.15%

1.90%

2.25%

4.15%

1.90%

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2047, U2 - year 2049)

$232,310,902

$244,071,642 5

Projected ending fund balance (U1 - year 2047, U2 year 2049)

$397,640,000

$434,215,000 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2047 and Unit 2 in 2049. Row 5 minus Row 4.

$165,329,098

$190,143,358 7

ISFSI decommissioning cost study estimate (2018$)

$1,696,598

$1,696,598 8

Projected ISFSI decommissioning cost estimate (U1 - year 2047, U2

- year 2049)

$3,471,931

$3,647,697 to NL-19-1125 Vogtle ISFSI Decommissioning Funding Plan Triennial Update E3 - 11 Table 6 - Financial Assurance - Dalton Utilities (1.6% Ownership) 1This amount is based on NUREG-1307, Rev. 17, for the burial factor, the December 2019 BLS data for labor, and the September 2019 BLS data for energy.

Unit 1 Unit 2 1

The NRC minimum decommissioning estimate, pursuant to 10 CFR 50.75 (b) and (c) (Dec 2019$)

$8,201,5411

$8,201,5411 2

Total amount accumulated in the trust fund at the end of 2019 (2019$)

$11,147,831

$10,665,124 3

Assumptions regarding:

(a) Rates of escalation in decommissioning costs (b) Rates of earnings on decommissioning funds (c) Real rate of return 2.70%

2.02%

(0.68%)

2.70%

2.02%

(0.68%)

4 Projected NRC minimum requirements pursuant to 10 CFR 50.75 (b) and (c) (U1 - year 2047, U2 - year 2049)

$17,292,903

$18,239,326 5

Projected ending fund balance (U1 - year 2047, U2 year 2049)

$19,515,483

$19,432,357 6

Surplus funds available for decommissioning the ISFSI (10 CFR 72.30), spent fuel management (10 CFR 50.54 (bb)) and site restoration for U1 in 2047 and Unit 2 in 2049. Row 5 minus Row 4.

$2,222,580

$1,193,031 7

ISFSI decommissioning cost study estimate (2018$)

$119,584

$119,584 8

Projected ISFSI decommissioning cost estimate (U1 - year 2047, U2

- year 2049)

$258,950

$273,122