ML21362A159

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

ML21362A159
Person / Time
Site:	Maine Yankee (DPR-036)
Issue date:	12/10/2021
From:	Conry T Maine Yankee Atomic Power Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
OMY-21-013
Download: ML21362A159 (19)

Text

Maine Yankee 321 Old Ferry Road, Wiscasset, Maine 04578 December 10, 2021 OMY-21-013 Re: 10 CFR 72.4 and 10 CFR 72.30 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Maine Yankee Atomic Power Company Maine Yankee Independent Spent Fuel Storage Installation NRC License No. DPR-36 {NRC Docket No. 50-309)

72. -3D

Subject:

Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan Pursuant to the requirements of 10 CFR 72.30( c) and 10 CFR 70.4, Maine Yankee Atomic Power Company (Maine Yankee) is providing the three-year update to the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Maine Yankee ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous Maine Yankee ISFSI DFP on December 10, 2018 (Reference 1). It includes adjustments to account for changes in costs, a modified assumption regarding the amount of material that would be shipped offsite as low-level radioactive waste (modified to align with other industry precedent), and a modified contingency factor (increased from 10% to 25%). The update does not include any adjustments for additional radiological contamination, because the extent of radioactive contamination at the Maine Yankee ISFSI remains unchanged.

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

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

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

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

3. There were no changes in authorized possession limits.

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

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

10 CFR 72.30(b)(l) requires the licensee to provide "information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI." Maine Yankee has

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Maine Yankee Atomic Power Company OMY-21-013/December 10, 2021/Page 2 established accounts within its Nuclear Decommissioning Trust (NDT) entitled, "ISFSI Rad Coho" and "ISFSI Rad Mellon," that segregate the funds for decommissioning of the ISFSI from the larger balance of funds for ongoing management of irradiated fuel and GTCC waste held in the NDT. Currently, the trust has sufficient funds to meet the revised DCE for the Maine Yankee ISFSI.

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

1. Utilizes an independent contractor to perform the decommissioning activities in accordance with 10 CFR 72.30(b )(2)(i);

2. Includes an adequate contingency factor in accordance with 10 CFR 72.30(b )(2)(ii); and

3. Includes the cost of meeting the criteria for unrestricted release in accordance with 10 CFR 72.30(b )(2)(iii).

In addition, the revised Maine Yankee ISFSI 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 Maine Yankee ISFSI DCE estimates the total cost to decommission the Maine Yankee ISFSI to be $7.3 million in 2021 dollars for radiological decommissioning and

$12.5 million in 2021 dollars for ISFSI site restoration that includes the additional costs for non-radiological decommissioning and site restoration costs.

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 Maine Yankee ISFSI, including the key assumptions and the justification for their use.

10 CFR 72.30(b )( 4) requires the licensee to provide a description of the method of assuring funds for decommissioning from 10 CFR 72.30(e), including means for adjusting cost estimates and associated funding levels periodically over the life of the facility. Maine Yankee will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30(c).

On a periodic basis, Maine Yankee will submit rate cases to Federal Energy Regulatory Commission (FERC) that will include revised cost estimates for decommissioning and the.

management of irradiated fuel and GTCC waste. If necessary, additional funds may be recovered from the purchasers.

Maine Yankee has successfully litigated several breaches of contract damages claims against the Department of Energy (DOE) for failure to begin the removal of spent nuclear fuel (SNF) and GTCC waste from the site in 1998. Additional damages claims against the DOE relating to the government's breach of contract are expected to continue as long as the irradiated fuel and GTCC waste remain on site.

Annually, Maine Yankee submits the reports required by 10 CFR 50.75(f)(2),

10 CFR 50.82(a)(8)(v) and 10 CFR 50.82(a)(8)(vii) to establish how it satisfies the obligations defined in those regulations regarding the assurance of decommissioning funding and the status of funding for the management of irradiated fuel.

Maine Yankee Atomic Power Company OMY-21-013/December 10, 2021/Page 3 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 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 a limited number of Vertical Concrete Casks (VCCs) and VCCs liners 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 Maine.

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

In addition, Enclosure 3 provides an estimate of the total costs associated with the Maine Yankee ISFSI for the management of irradiated fuel and GTCC waste at the Maine Yankee ISFSI through 2036.

A summary of the revised DCE and the cost estimate for the management of irradiated fuel and GTCC waste at the Maine Yankee ISFSI will be incorporated into the Post-Shutdown Decommissioning Activities Report (PSDAR) and the License Termination Plan (LTP) in calendar year 2022.

If you have any questions, please do not hesitate to contact me at (508) 612-3322.

Maine Yankee Atomic Power Company OMY-21-013/December 10, 2021/Page 4

Enclosures:

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

2. Certification of Financial Assurance

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

Reference:

1. Letter from C. Pizzella (Maine Yankee) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 10, 2018 (OMY-18-030) cc:

D. Lew, NRC Region I Administrator T. Dimitriadis, Chief, Decommissioning Branch, NRC, Region 1 J. McKirgan, Chief, Storage and Transportation Licensing Branch, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards J. Hyland, State of Maine

ENCLOSURE 1 TO OMY-21-013 DECOMMISSIONING STUDY OF THE MAINE YANKEE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page 1 of 10 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[11 with the rule becoming effective on December 17, 2012. Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

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

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

2.

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

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

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

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page2of 10 Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactorJ2l

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 Maine release criteria.

4.

ISFSI Description The MY ISFSI is located on approximately 11 acres of the site. The ISFSI consists of 60 dry storage casks containing 1,434 spent nuclear fuel assemblies used during operations. The NAC-UMS fuel storage and transport canister system was chosen by MY and is licensed by the NRC for both storage and transportation. The NAC-UMS system consists of a multi-purpose spent fuel storage canister and a vertical concrete and steel overpack. Each vertical concrete cask has a two-and-a-half-inch steel liner surrounded by approximately 28 inches of reinforced concrete. Construction of the concrete storage pad and vertical concrete and steel storage was completed during decommissioning. Transferring the spent fuel from the spent fuel pool to the storage casks was completed in March of 2004.

In addition to the 60 spent fuel storage casks there are 4 casks containing segmented sections of the reactor internals classified as Greater than Class C waste. The storage overpacks used for the GTCC canisters 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. The multi-purpose canisters will be transferred directly to the DOE. After removal of the UMS canisters, the overpacks will be surveyed and any found 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 will be removed as activated. 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 ranlµng 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, LLC

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

Table 1 provides the significant quantities and physical 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.

TLG does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. This assumption is adopted for this analysis.

The decommissioning estimate is based on the premise that the inner steel liners of some of the concrete and steel overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 10 of the 60 overpacks are assumed to be affected, i.e., contain residual radioactivity. This is conservative, because the fuel had decayed in the spent fuel pool for a few years prior to being placed into dry storage. The overpacks will be segmented and packaged.

for disposal as low-level radioactive waste.

It is not expected that there will be any residual contamination to be left on the concrete ISFSI pad. It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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 TLG Services, LLC

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page 4of 10 positions are expected to be provided locally. MY, as licensee, will oversee the site activities.

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

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

ISFSI Pad Remaining Overpacks Fencing

• ISFSI support systems Security operations building (SOB)

Miscellaneous pads Miscellaneous structures Nuisance fence Buried utilities Road in licensed area SOB electrical service Vehicle barriers Costs are reported in 2021 dollars. Costs do not include Maine sales tax.

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.(31 Contingency has been added to the Site Restoration costs at a rate of 25%.

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

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

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

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

3 "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, LLC

Maine Yankee Atomic Power Company Maine Yankee ISFSI Page 5 of 10 (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 (liner removal) developed.

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

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

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

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), lVlY'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, LLC

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 1 Page 6of 10 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity ISFSI Pads -16 Total (dimensions are for each pad) 31 31 No ISFSI Overpack Item Value Notes (all dimensions are nominal)

MY-UMS Overall Height (inches) 225.9 Dimensions are nominal Overall Diameter (inches) 136.0 Dimensions are nominal Inside Diameter (inches) 74.5 Dimensions are nominal Inner Liner Thickness (inches) 2.50 Dimensions are nominal Quantity (total) 64 60 spent fuel + 4 GTCC Quantity (with residual radioactivity) 10 Total Surface Area of overpack interior with Residual 3,918 Radioactivity (sauare feet)

Low-Level Radioactive Waste (cubic feet) 50,817 Low-Level Radioactive Waste foackaged density) 50 TLG Services, LLC

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 2 ISFSI Decommissioning Costs and Waste Volumes (Thousands of 2021 Dollars)

• LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Costs Activity Description Decommissioning Contractor Planning (characterization, 285 285 specs and procedures)

Decontamination (activated 122 261 612 994 liner and concrete removal)

License Termination 1,285 1,285 (radiological surveys)

Subtotal 122 261 612 1,570 2,565 Supporting Costs NRC and NRC Contractor 298 298 Fees and Costs Insurance 161 161 Property taxes 322 322 NRCFees 247 247 Site O&M Cost 558 558 Security Staff Cost 164 164 TLG Services, LLC Burial Volume Class A (cubic feet) 50,817 50,817 Page 7of 10 Oversight Craft and Manhours Contractor Manhours 1,048 1,645 8,196 9,841 1,048 1,153 11,625

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

ISFSI Decommissioning Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Activity Description Costs DOC Staff Cost 522 522 Utility Staff Cost 966 966 Subtotal 3,239 3,239 ISFSI Decontamination 122 261 612 4,809 5,804 Total (w/o contine;ency)

ISFSI Decontamination 153 326 765 6,012 7,255 Total (with 25%

continl!'ency)

ISFSI Site Restoration Building removal - Inside fence Fencing (linear foot) 6 6

ISFSI Cask & Pad 1,189 325 1,514 Demolition and Removal ISFSI Support sytems 122 122 Building removal - Outside fence Miscellaneous Pads 19 19 Miscellaneous structures 104 104 Nuisance Fence 19 19 Removal of buried utilities 3

3 Removal of road in licensed 35 35 area TLG Services, LLC Burial Volume Class A (cubic feet) 50,817 Page 8of 10 Oversight Craft and Manhours Contractor Manhours 4,787 4,787 12,778 9,841 13,826 67 1,552 94 706 196 16 326

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 2 (~ontinued)

ISFSI Decommissioning Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Removal Packaging Transport Disposal Other Total Costs Costs Costs Costs Costs Activity Descriution Costs SOB Electrical service 0.3 0.3 Security Operations 303 303 Building Vehicle Barriers 1

1 Construction Debris 204 204 Site Restoration 7

7 Subtotal 1,809 529 2,338 Supporting Costs NRC and NRC Contractor 26 26 Fees and Costs Property taxes 161 161 Site O&M Cost 279 279 Security Staff Cost 82 82 DOC Staff Cost 261 261 Utility Staff Cost 483 483 Severance 545 545 Subtotal 1,837 1,837 ISFSI Site Restoration Total 1,809 2,367 4,176 (w/o contingency)

ISFSI Site Restoration Total 2,261 2,958 5,219 (with 25% contingency)

Total (w/o contingency) 1,931 261 612 7,176 9,979 Total (with contingency) 2,414 326 765 8,970 12,474 TLG Services, LLC Burial Volume Class A (cubic feet) 50,817 50,817 Page 9 of 10 Oversight Craft and Manhours Contractor Manhours 2

2,584 4

32 5,579 160 5,813 2,393 2,393 5,813 16,572 5,579 16,572 15,420 30,398 15,420 30,398

Maine Yankee Atomic Power Company Maine Yankee ISFSI Table 3 ISFSI Decommissioning - Structures Included Contaminated Removal Cask inner liner Cask lid Cask base & misc. Internal fixtures VCC concrete Clean Removal Non-activated overpacks ISFSI Concrete Pad Remove fencing Ginear foot)

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

SOB electrical service Vehicle barriers TLG Services, LLC Page JO of 10

ENCLOSURE 2 TO OMY-21-013 CERTIFICATION OF FINANCIAL ASSURANCE

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licensee:

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

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

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

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

That radiological decommissioning funding assurance is premised on a site-specific decommissioning cost estimate and funding methodology described therein, in the amount of:

Maine Yankee ISFSI

$7.3 million (in 2021 dollars, inclusive of contingency) ee Atomic Power Company reasurer Phone (508) 612-3322

• <corporate Seal ~,

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ENCLOSURE 3 TO OMY-21-013 TOTAL COSTS ASSOCIATED WITH THE HNP ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

Maine Yankee Atomic Power company Irradiated Fuel & GTCC Waste Management and ISFSI Decom Estimate Represented In 2022 DoUars FERC Summary Sum of 2022 Sum of 2023 Sum of 2024 Sum of 2025 Sum of 2026 contingency

~.118 531,670 516,402 516,606 Insurance 506,359 506,359 506,359 508,359 Labor - Non-Manual 2,896,851 2,871,056 2,814,347 2,806,606 Labor - Non-Manual Succession Plannln 90,942 16,966 Labor - Security 3,287,122 3,287,122 3,287,122 3,287,122 Materials & Supplies 166,430 124,970 134,770 307,934 Miscellaneous 144,303 144,303 165,841 144,303 Outside Sen,lces

• A&G 840,906 840,906 701,481 840,906 Outside Services - Fuel Loading Outside Services - IAGE 75,382 75,382 75,382 75,382 OU1slde Services

• ISFSI OP's 1,080,480 375,117 556,034 385,885 Outside services - Legal 430,756 699,979 161,534 269,223 OU1slde Services

• NON-RAO O&O of IS Outside Services

• RAO O&O of ISFSI Property Taxes 999,462 999,462 999,462 999,462 Regulatory Fees 772,131 777,515 777,515 777,515 utilities 12~227 129 227 129J227 129,227 Grand Total 11,783,471 11,185,069 10,144,443 10,Ul,732 Source 2019 FERC, Escalated In 2022 S Note 1: The cost of management of Irradiated fuel and GTCC waste is calculated as follows:

213,319,293 Grand Total from AbOve (4,680,406) Non-Rad O&O ISFSI

---

c,>;cs.,,Sc;,74~71;;9*) Rad O&O ISFSI 203,084,188 Management of Irradiated Fueland GTCC Waste 628,109 508,359 2,802,258 131,007 3,287,122 187,753 144,303 840,906 775,381 1,748,152 430,756 999,462 777,515 129,227 13,190,292 Sum of 2027 Sum of 2028 579,922 5

21,o<<

506,359 508,359 2,758,677 2,758,677 252,538 3,287,122 3,287,122 123,355 176,122 165,841 144,303 699,058 840,906 183,071 75,382 1,455,238 509,728 511,523 161,534 999,462 999,462 777,515 777,515 129227 129,227 12,178,372 10,941,918 Maine Yankee 2022

• 2039 Summary Sum of202t Sum of 2030 Sum of 2031 Sum of 2032 Sum of 2033 507,298 528,284 59~

511,~

506,202 506,359 506,359 508,359 506,359 506,359 2,689,811 2,689,611 2,689,811 2,689,611 2,689,611 50,392 3,287,122 3,287,122 3,287,122 3,287,122 3,287,122 113,770 197,768 219,952 142,200 203,o<<

144,303 165,841 144,303 144,303 165,841 701,481 840,906 840,906 699,058 840,906 75,382 75,382 775,381 129,227 75,382 450,499 663,723 1,193,553 509,728 378,347 269,223 430,756 511,523 161,534 269,223 999,462 999,462 999,462 999,462 999,462 m,s1s m

,s1s 777,515 777,515 777,515 129,227 129,227 129,227 129~7 ___

129,227 10,853,263 11,093,957 12,470,740 10,739,125 10,630,243 Sumof 2034 522,741 506,359 2,853,607 3,287,122 158,461 144,303 840,906 75,382 509,728 430,756 999,462 917,511

_129.rrL_

10,977,617 Note 2: The cost of RAD and NON-RAD D&O of the ISFSI In 2022 dollars as provided In the columns labeled 'Sum of 2037' and 'Sum of 2038' Is derived by escalating the value of the cost estimates provkied In Enclosure 1 by 2.5%

Note 3: This Summary combfnes MY's 2019 approved FERC Rate Case with the TLG services 2021 RAD and NON-Rad ISFSI Decom Cost Estimate.

Summary Sum of 2035 Sum of 2031 Sum of 2037 Sum of 2031 Sum of 2039 2022-2039

~

07 581,550 1,622,073 1,946,13_1 __ 703,638 12,599,125 508,359 508,359 508,359 506,359 829,723 9,471,834 2,653,607 2,845,530 2,845,530 2,687,529 2,668,953 49,111,482 541,842 3,287,122 3,287,122 3,287,122 538,445 538,445 53,670,850 193,460 208,752 292,426 33,434 29,722 3,014,323 144,303 165,841 122,766 122,766 97,997 2,615,767 840,906 840,906 840,906 840,906 589,215 11,722,073 3,101,445 3,101,445 75,382 775,381 75,382 129,227 75,382 3,872,197 321,272 1,331,395 224,352 181,276 80,767 11,955,275 511,523 161,534 161,534 161,534 1,238,424 6,972,667 4,610,406 4,680,406 1,139,657 3,738,062 5,574,719 999,462 999,462 999,462 501,400 252,389 16,745,165 917,511 m

,s1s 1,1 70,580 1,811,330 608,443 15,527,666 129"227

_____m221 181 ~

2.!hlI!_ 2!,~22 2,342,237 10,901,243 12,212,556 17,053,130 17,895,183 7,740,000 213,319,293