NG-10-0067, Submittal of Response to Supplemental Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate

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Submittal of Response to Supplemental Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate
ML100540024
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 02/15/2010
From: Costanzo C R
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-10-0067
Download: ML100540024 (13)
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Text

NExTeraM ENERGY1LO DUAN ARNOLD February 15, 2010 NG-1 0-0067 10 CFR 50.75 10 CFR 50.54 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Response to Supplemental Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate

Reference:

Request from NRC to NextEra Energy Duane Arnold, dated January 19, 2010, "ME1148 (DAEC) RAI No. 5 Supplement 1," (ML100220514)

By the Reference above NRC issued a Supplemental Request for Additional Information (RAI) related to the Irradiated Fuel Management Program, and the Preliminary Decommissioning Cost Estimate provided by NextEra Energy Duane Arnold. This supplemental RAI question is identified as RAI No. 5 Supplement 1.NextEra Energy's responses to the Staff's RAI are provided in the Enclosures to this letter.Enclosure 5 of this letter contains a proprietary version of the "Settlement Agreement" with the United Stated Department of Energy. NextEra Energy requests this proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4).

An affidavit supporting this request is provided in Enclosure

4. A redacted version of this proprietary document is included in Enclosure 6.Aoo/NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 NG-10-0067 February 15, 2010 Page 2 of 2 This letter makes the following new commitment:

In the event license renewal is not granted, Duane Arnold Energy Center (DAEC) joint owners commit to provide $52 million initial funding for spent fuel management.

Should you have questions regarding NextEra Energy's responses to the Staff's RAI, please contact Licensing Manager, Steve Catron at (319) 851-7234.Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosures (6)cc: Administrator, Region Ill, USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC NG-10-0067 February 15, 2010 Page 1 of 7 ENCLOSURE 1 Response to Supplemental Request for Additional Information RAI No. 5, Supplement 1 to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate RAI No. 5: Section 1.0 Executive Summary (NRC's November 9, 2009 letter)In the submittal, FPL identified 4 possible decommissioning scenarios for DAEC, and provided the total cost for each option, including spent fuel costs and Greenfield costs. Later in the cost study, FPL identified its annual costs associated with each option. However, FPL did not provide an analysis using the decommissioning funds to demonstrate that adequate funds are available to address these options. FPL needs to provide the supporting analysis for each of the identified alternatives or, at a minimum, for the selected option based on the trust fund balance as of December 31, 2008. NextEra's Response to NRC's RAI No. 5 was inadequate.

Supplemental RAI Part 1 [January 19, 2009 e-mail]In NextEra Energy's December 1, 2009 (NG-09-0860) response to NRC's RAI No. 5 (above), NextEra did not address the staff concerns.

In their RAI response, NextEra refers to Table 1 and Table 2 as part of their response.

For both Table 1 and Table 2, NextEra appears to be deducting more than the 3 percent for decommissioning planning.

The regulation, 10 CFR 50.82(8)(i)(C)(ii), limits the withdrawal to 3 percent of the generic amount specified in 10 CFR 50.75 which would limit the amount to$15.1 million based on December 31, 2008 formula amount of $503.7 million, and$15.2 million based on September 30, 2009 formula amount of $507.3 million. The amount deducted:

$7.9 million in 2012, $9.1 million in 2013, and part or all of $42.6 million depending on what is deducted prior to February 21, 2014, exceeds the 3 percent allowed ($17.0 to $59.6 million).

NextEra needs to revise its submittal to reflect the regulatory limit allowed for decommissioning planning.NextEra Energy Response to Supplemental RAI Part 1: A revised Decommissioning Cost Estimate Study for the Duane Arnold Energy Center (DAEC) is provided as Enclosure

3. It provides revised cost estimates for the decommissioning planning period (pre-shutdown) in order to comply with the 10 CFR 50.82(8)(ii) limitation.

The following adjustments were made to the estimate.1. The duration of the pre-shutdown planning period was reduced by ten months.

NG-10-0067 February 15, 2010 Page 2 of 7 2. The following activities initially scheduled to be performed during the pre-shutdown planning period were delayed until after shutdown and are now included in the post-shutdown site modifications and preparation period: a. Administrative Activities

b. Planning for asbestos abatement c. Design of interim storage facility for Greater than Class A Waste d. Planning and design of site characterization.
3. Security guard costs during the pre-shutdown planning period were eliminated.

These costs are now assumed to be an operational expense.4. The duration that the Decommissioning General Contractor (DGC) staff is on-site during the pre-shutdown planning period was reduced from twelve months to six months.5. The size of the DAEC and DGC staffs during the pre-shutdown planning period were reduced commensurate with the reduction in activities performed in that period.6. The duration of the post-shutdown site modifications and preparation period was increased by about three months to account for the additional activities required during this period.7. The amount of Dry Active Waste generated during the post-shutdown site modifications and preparation period increased slightly due to the additional person-hours occurring in this period. Therefore, waste disposal costs increased slightly during this period.Revisions to Tables 1 and 2 are provided in Enclosure

2. These revised tables demonstrate sufficient funding, based upon the September 30, 2009 and December 31, 2008 trust balances, respectively, taking into account the cost flow revisions necessary to meet the 3% limitation in 10 CFR 50.82(8)(ii) that are provided in the revised Decommissioning Cost Estimate Study in Enclosure
3. While the revised Tables 1 and 2 reflect almost $56 million being spent by the end of 2014, the period of currently licensed operations would end on February 21, 2014. A significant majority of the $56 million would be spent in 2014 following plant shutdown.

Table 6-5 of the revised Decommissioning Cost Estimate Study shows the license termination costs for the selected decommissioning option, Scenario 2 (SAFSTOR and no license renewal).

Period 1, "SAFSTOR Planning Prior to Shutdown" lasts from December 29, 2012 to February 21, 2014 with a total cost of $12,571,000, which is less than 3 percent of the generic amount specified in 10 CFR 50.75.As discussed in NextEra's December 1, 2009 response (Reference

1) and shown in the revised Table 2, when using the fund balance as of December 31, 2008, NextEra's 70% share would be projected to be under funded during the last two years of decommissioning, while the overall decommissioning obligation, including NG-10-0067 February 15, 2010 Page 3 of 7 that of the joint owners, is projected as fully funded. However, as discussed in Enclosure 1 of Reference 1, and shown in the revised Table 1, gains in the fund during 2009 eliminated the under funding that is projected for NextEra -Energy's share based upon its year-end 2008 balance, such that both NextEra's share and the overall decommissioning obligation for DAEC are fully met.On November 5, 2009, NextEra submitted a "Response to Requests for Additional Information" (Reference
2) related to the Biennial Decommissioning Funding Report that was submitted on March 27, 2009. In the November 5, 2009 submittal, NextEra relied upon the same SAFSTOR cash flow table provided in the original Decommissioning Cost Estimate Study that has now been revised to comply with the 3 percent regulatory limitation.

NextEra intends for both submittals to consistently reflect the selection of the SAFSTOR option and comply with the 3 percent limitation.

For this reason, the attached Table 1, which utilizes the balances as of September 30, 2009 is also intended to update the Table 1 from NextEra's November 5, 2009 biennial funding RAI response (Reference 2), which also utilized the September 30, 2009 balances.Supplemental RAI Part 2: In addition, the NRC's RAI requested that both the spent fuel and decommissioning costs be addressed as NextEra submittal was in response to the 10 CFR 50.75 and 10 CFR 50.54(bb) requirements.

The NextEra's December 1, 2009 response only addressed decommissioning costs for the SAFSTOR option. Based on the current balances shown in both Table 1 and Table 2, DAEC does not have sufficient funds to address both the spent fuel management and decommissioning costs for either option. The remaining balances shown in Table 1 and Table 2 are significantly less than the $274.0 million, in 2008 dollars, that DAEC has estimated for spent fuel expenditures.

NextEra needs to show how the spent fuel management costs will be addressed.

NextEra Energy Answer to Supplemental RAI Part 2: NextEra's February 19, 2009 Irradiated Fuel Management Plan (Reference 3)explained that NextEra's 70% share of the post-shutdown spent fuel management funding would be assured by the issuance of a new parent company guarantee in the event the operating license for DAEC is not renewed. Also in that submittal, Corn Belt Power Cooperative (Corn Belt) and Central Iowa Power Cooperative (CIPCO) stated their plans to use operating revenue and investments outside of funds designated for decommissioning to fund their respective portions of spent fuel management.

The NRC's November 9, 2009 RAI did not question the adequacy of this spent fuel management funding plan. Based upon the NRC's prior preliminary approvals of a plan involving the future issuance of a parent guarantee for spent fuel management (Reference

5) and of a plan involving future contributions (Reference 6), NextEra considers its February 19, 2009 plan to be adequate for preliminary NRC approval.

NG-10-0067 February 15, 2010 Page 4 of 7 However, since the submittal of the February 19, 2009 Irradiated Fuel Management Plan, NextEra has entered into a Settlement Agreement

("the Agreement")

with the U.S. Department of Energy (DOE), under which the United States Government has agreed to reimburse FPL and NextEra for costs incurred attributable to its failure to meet its contractual obligations to dispose of spent fuel at DAEC and at other FPL and NextEra plants. A copy of the Agreement is included as Enclosure 5 (to be withheld from public disclosure under 10 CFR 2.390 as requested by the Affidavit provided in Enclosure

4. A redacted version of the Agreement is provided in Enclosure 6). The Agreement provides substantial further assurance of the funding for spent fuel management at DAEC and NextEra relies on the Agreement in its modification of the February 19, 2009 plan, as is discussed below.The Settlement Agreement The Agreement provides for reimbursement to NextEra of all "allowable costs." Allowable costs are "those costs incurred by NextEra for managing and storing[Spent Nuclear Fuel/High Level Waste] SNF/HLW which were foreseeable in the event of DOE's Delay, and that NextEra would not have incurred but for, and which are directly related to, DOE's Delay in performance of its acceptance obligations under the Contracts." 1 Costs must also be "reasonable," meaning they do not exceed those that would be incurred by a prudent person or entity in the context of NextEra's line of business.As part of the Agreement, DOE and NextEra reached agreement as to the total damages for DAEC due to DOE's breach of contract from 1998, when DOE's obligation began, through the end of 2007. NextEra received payment for this amount as part of the settlement.

The Agreement also provides a framework for obtaining future damages due to DOE's continuing failure to pick up spent fuel. Under the terms of the Agreement, NextEra will make regular filings with the DOE Contracting Officer on or around April 30 of each year identifying allowable costs expended during the preceding 12 months. While the Agreement provides a dispute resolution process, NextEra does not anticipate significant disputes during the period following the permanent cessation of operations.

Any costs necessary to comply with NRC regulations for the safe storage of spent fuel onsite and therefore relevant for the purpose of the Irradiated Fuel Management Plan and 10 CFR 50.54(bb) would necessarily be reasonable costs under the Agreement, because a prudent entity in NextEra's line of business would incur costs necessary to comply with NRC regulations.

The Agreement provides significant benefits in providing spent fuel management funding assurance.

While a Spent Fuel Management Plan can only provide estimates of potential spent fuel management costs, under the terms of the 1 NextEra is the sole Plaintiff party to the Agreement with respect to DAEC. Under the terms of the DAEC joint ownership agreement, NextEra will pay ongoing expenses such as spent fuel management and bill CIPCO and Corn Belt in accordance with their ownership shares in DAEC. NextEra will be reimbursed directly through the Agreement and pass a pro rata share of funds recovered from DOE to CIPCO and Corn Belt in accordance with their ownership shares in DAEC.

NG-10-0067 February 15, 2010 Page 5 of 7 Agreement, DOE is responsible for 100% of the actual and reasonable spent fuel management costs attributable to its failure to dispose of DAEC's spent fuel.Whether the cash flows provided in the Decommissioning Cost Estimate Study turn out to be significantly lower or higher than the actual amount incurred becomes irrelevant because DOE must pay the actually incurred spent fuel management cost rather than the cost estimated for the purpose of 10 CFR 50.54(bb).

Spent Fuel Management Funding Assurance DAEC's spent fuel management funding obligations can be met in part by reliance upon the reimbursement proceeds from the Agreement, an obligation of the United States Government.

Accordingly, NextEra is modifying its February 19, 2009 funding plan as described below.As can be seen in Table 6-5 of the revised Decommissioning Cost Estimate Study and Appendix E "Annual Cash Flow Tables," the total cost of spent fuel management after the February 21, 2014 permanent cessation of operations is approximately

$273 million. (The Cost Estimate includes costs for 2013 that are excluded from this discussion because they would be incurred prior to the permanent cessation of operation.)

The Appendix E Cash Flow Table for Scenario 2 shows the greatest costs incurred in the first five years following shutdown, followed by additional years with a significantly reduced cost. For this reason, the plan to rely upon proceeds from the Agreement must also provide a mechanism to provide initial funding for the first several years following shutdown.

Table 3 in Enclosure 2 of this submittal demonstrates a spent fuel management funding cash flow initially funded with $52 million. Table 3 demonstrates that this amount is adequate to cover spent fuel management funding until sufficient reimbursement proceeds are provided by the federal government to cover future costs. Table 3 does not represent a commitment to the creation of a separate trust fund and, in turn, does not take credit for any rate of return. Instead, the purpose of the plan is to demonstrate that, with an initial commitment of $52 million, the proceeds from the Agreement would be sufficient to fund ongoing spent fuel management.

In the event license renewal is not granted, all of the DAEC joint owners commit to provide the $52 million initial funding necessary for spent fuel management.

NextEra would obtain parental assurance for its 70% share ($36.4 million) consistent with its February 19, 2009 plan (Reference 3).2 Similarly, CIPCO and Corn Belt would provide their 20% ($10.4 million) and 10% ($5.2 million) ownership shares, 2 NextEra's commitment to provide future parental assurances is similar to the plan provided by Dominion Energy Kewaunee, Inc. and approved by the NRC. See Safety Evaluation by the Office of Nuclear Reactor Regulation Related to the Irradiated Fuel Management Program and Preliminary Decommissioning Cost Estimate for Kewaunee Power Station, Docket No. 50-305, September 28, 2009 (Reference 5). The commitment of CIPCO and Corn Belt to provide a future contribution is similar to the plan provided by Entergy Nuclear Operations, Inc. and approved by the NRC. See Safety Evaluation by the Office of Nuclear Reactor Regulation Related to the Spent Fuel Management Program, Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station, Docket No. 50-271, October 8, 2009 (Reference 6).

NG-1 0-0067 February 15, 2010 Page 6 of 7 respectively, through operating revenue and investments outside of funds designated for decommissioning.

CIPCO and Corn Belt are electric cooperatives and are able to recover their cost of service. Subsequent reimbursements from the federal government would be directed to future spent fuel management costs in an amount sufficient to ensure adequate funding.Supplemental RAI Part 3: The NextEra December 1, 2009 response to RAI No. 5 refers to a $93 million dollar parent company guarantee (PCG) issued by [FPL Group Capital Inc.] on behalf of DAEC. The staffs review of FPL's annual report for 2008 did not locate any reference to the $93 million PCG mentioned in the response to RAI. No. 5. Provide a citation to the page in the annual report that discusses the PCG, or verify that the annual report does not include such a discussion.

If there is no discussion of the PCG in the annual report, explain why the discussion was not included.

In addition, the DAEC License Condition 2, Appendix B, page 2 of the Duane Arnold License, as amended in Amendment 275 (ML093030113 dated November 13, 2009) references a PCG of $75 million (in 2005 dollars).

Explain the reference to the $93.0 million PCG in the December 1, 2009, NextEra's RAI response compared to the November 13, 2009 Amendment 275 that identifies a PCG in the amount of $75 million in 2005 dollars.NextEra Energy Answer to Supplemental RAI Part 3: The license condition to which the RAI refers states that upon the closing of the sale FPL Energy Duane Arnold, LLC (now NextEra Energy Duane Arnold, LLC) was required to obtain a $75 million parent guarantee to provide additional decommissioning funding assurance.

Further, the license condition requires the licensee to obtain appropriate adjustments to that guarantee in order to meet decommissioning obligations.

A $75 million parent guarantee was provided at the time of the closing of the sale, as required by the license condition.

However, in compliance with the license condition and with 10 CFR 50.75, the DAEC parent guarantee was increased to $93 million in 2007. This was reported to the NRC in FPL Energy's June 28, 2007 Revised Decommissioning Funding Status Report (Reference 7). It is unnecessary to amend this license condition each time the parent guarantee must be increased, as the condition was historical in nature and already requires appropriate future adjustments.

The FPL Group 2008 Annual Report identifies the DAEC parent guarantee on page 66, but does not state its amount. The current amount is stated on page 38 of FPL Group's 3rd Quarter 2009 Form 1 0-Q, dated October 30, 2009.3 3 FPL Group's 2008 Annual Report is available at: http://www.fplgroup.con/reports/pdf/2008 annual.pdf.

FPL Group's 3rd Quarter 2009 Form 10-Q is available at: htlp://www.investor.fplgroup.com/phoenix.zhtml?c=88486&p=irol-sec.

NG-10-0067 February 15, 2010 Page 7 of 7

References:

1. Letter NG-09-0860 from C. Costanzo, NextEra Energy Duane Arnold, to NRC,"Response to Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate," dated December 1, 2009. (ML093440059)
2. Letter L-2009-256 from M. Nazar, Florida Power & Light Company, to NRC,"Response to Requests for Additional Information," dated November 5, 2009.(ML093130065)
3. Letter NG-09-0038 from R. Anderson, FPL Energy Duane Arnold, to NRC,"Irradiated Fuel Management Plan and Preliminary Decommissioning Cost Estimate for Duane Arnold Energy Center," dated February 19, 2009.(ML090550968)
4. Request from NRC to NextEra Energy Duane Arnold, "Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate," dated November 9, 2009. (ML093140630)
5. Letter from NRC to D. Heacock, "Kewaunee Power Station -Irradiated Fuel Management Program and Preliminary Decommissioning Cost Estimate," dated September 28, 2009. (ML092321079)
6. Letter from NRC to Vermont Yankee Site Vice President, "Vermont Yankee Nuclear Power Station -Safety Evaluation RE: Update to Spent Fuel Management Program," dated October 8, 2009. (ML092740238)
7. Letter NG-07-0481 from G. Van Middlesworth, FPL Energy Duane Arnold, to NRC, "Revised Decommissioning Funding Status Report for the Duane Arnold Energy Center," dated June 28, 2007. (ML071860229)

ENCLOSURE2 Tables 1, 2 and 3 3 Pages Follow Table I Duane Arnold Energy Center License Termination Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)Basis Year 2008 Fund Balance as of 9130109: (Thousands of Dollars)Next Era 184,620 70% ownership CIPCO 31,985 20% ownership Corn Belt 168104 10% ownership Total Trust Fund Balance 232,709 Annual Escalation 0%Annual Earnings -Next Era 2%Annual Earnings -CIPCO 4%Annual Earnings -Corn Belt 3%A R C.n2 F F to Next Era Decommissioning Trust Fund Balance escalated at 2% minus 70%of expenses +CIPCO Decommissioning Trust Fund Balance escalated at 4% minus 20%of expenses.Corn Belt Decommissioning Trust Fund Balance escalated at 3%minus 10% of expenses+50.75 Ucense Total Cost Termination Escalated Total ClPCO Cor Belt Decommisioning Decommissioning Decommissioning Trust Fund minus Trust Fund Trust Fund near .usost at 0%. 1 onnutulns E onnulons Eunnolons expenses , onmow 2009 184 620 32485 16604 233.709 2010 188,312 34 784 17,602 240,699 2011 -192,079 37:1766 18880 248,135 I ... ý.-Hh.M-2012 1 90 I 90 195,8571 39,6451 20,4381 255,940 2025 1 2,035 2,035 1 166,7551 39,7411 20,3851 226,881 2044 1,448 1,4481 219,7801 75,7141 32,1081 327,602 2060 1 2,305 2,3051 278,898 134,3101 48,0301 461,238 2066 8,156 8,156 299,811 165,717 55,2741 520,802 Calculations:

Column D = (Column D (Previous year's fund balance)*

(1+.02)) -(Column C* 0.70) (70% of current year's decommissioning expenditures)

Column E = (Column E(Previous year's fund balance)*

(1+.04)) -(Column C* 0.20) (20% of current years decommissioning expenditures)

+ Column H (current years contributions)

Column F = (Column F (Previous years fund balance)*

(1+.03)) -(Column C* 0.10) (10% of current year's decommissioning expenditures)

+ Column I (current years contrbutions)

Column G = Column D + Column E + Column F Table 2 Duane Arnold Energy Center License Termination Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)Basis Year 2008 Fund Balance as of 12/31108: (Thousands of Dollars)Next Era 163,576 70% ownership CIPCO 26,112 20% ownership Corn Belt _,386 10% ownership Total Trust Fund Balance 203,074 Annual Escalation 0%Annual Earnings -Next Era 2%Annual Earnings -CIPCO. 4%Annual Earnings -Corn Belt 3%A 0 C fl F P A R C D E 50.75 License Termination Cost Total Cost Escalated at 0%Next Era Decommissioning Trust Fund Balance escalated at 2% minus 70%of expenses+Contributions 163,576 166,846 170,184 173,525 169,348 141,494 CIPCO Decommissioning Trust Fund Balance escalated at 4% minus 20%of expenses +Corn Belt Decommissioning Trust Fund Balance escalated at 3%minus 10% of expenses +Total Decommisioning Trust Fund minus expenses CIPCO Decommissioning Trust Fund Contributions Corn Belt Decommissioning Trust Fund Contributions Year 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 204.074;00 210.327 000 00 217,005 1,0001 750 1.790 142,6851 27,962 0 B 33,399 185,570 188,589 191,690 194,874 198,146 201,507 204,960 208,508 212:153 215,0OO 219,750 223,707 227,774 231,955 236,253 240,672 245,210 240,888 254,692 259,634 264,716 269,943 275,321 2800853 286,545 292,402 298,429 304,631 310,842 316,551 322,432 328,489 334,730 341,159 347,783 354,610 361,645 1,448 1 180,23!2059 2,30ý 2,355 2050 2,305 2,305 2060 2,305 2061 2,305 2062 1 2,305 1 5,742 108,1011 Calculations:

Column D = (Column 0 (Previous years fund balance)*

(1+.02)) -(Column C* 0.70) (70% of current years decommissioning expenditures)

Column E = (Column E(Previous year's fund balance)*

(1+.04)) -(Column C* 0.20) (20% of current year's decommissioning expenditures)+

Column H (current year's contributions)

Column F =(Column F (Previous years fund balance)*

(1+.03))- (Column C* 0.10) (10% of current years decommissioning expenditures)

+Column I (current year's contributions)

Column G = Column D + Column E + Column F Table 3 Duane Arnold Energy Center Spent Fuel Management Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)2008 0%Basis Year: Annual Escalation:

50.54(bb)

Prior Year Balance -Spent Fuel Total Cost Current Year Management Escalated Expense + DOE Initial Funding DOE Year Cost (2) at 0% Reimbursement Commitment Reimbursement 2013 2014 (1) 22,299 22,299 29,701 52,000 2015 25,939 25,939 3,762 2016 25,939 25,939 122 22,299 2017 25,939 25,939 122 25,939 2018 25,939 25,939 122 25,939 2019 7,027 7,027 19,034 25,939 2020 3,949 3,949 41,024 25,939 2021 3,949 3,949 44,102 7,027 2022 3,949 3,949 44,102 3,949 2023 3,949 3,949 44,102 3,949 2024 3,949 3,949 44,102 3,949 2025 3,949 3,949 44,102 3,949 2026 3,949 3,949 44,102 3,949 2027 3,949 3,949 44,102 3,949 2028 3,949 3,949 44,102 3,949 2029 3,949 3,949 44,102 3,949 2030 3,949 3,949 44,102 3,949 2031 3,949 3,949 44,102 3,949 2032 3,949 3,949 44,102 3,949 2033 3,949 3,949 44,102 3,949 2034 3,949 3,949 44,102 3,949 2035 3,949 3,949 44,102 3,949'2036 3,949 3,949 44,102 3,949 2037 3,949 3,949 44,102 3,949 2038 3,949 3,949 44,102 3,949 2039 3,949 3,949 44,102 3,949 2040 3,949 3,949 44,102 3,949 2041 3,949 3,949 44,102 3,949 2042 3,949 3,949 44,102 3,949 2043 31949 3,949 44,102 3,949 2044 3,949 3,949 44,102 3,949 2045 '3,949 3,949 44,102 3,949 2046 3,949 3,949 44,102 3,949 2047 3,949 3,949 44,102 3,949 2048 3,949 3,949 44,102 3,949 2049. 3,949 3,949 44,102 3,949 2050 3,949 3,949 44,102 3,949 2051 3,949 3,949 44,102 3,949 2052 3,949 3,949 44,102 3,949 2053 4,749 4,749 43,302 3,949 2054 4,644 4,644 42,607 3,949 2055 -47,356 4,749 2056 52,000 4,644 Total 272,792 272,792 52,000 272,792 (1)Assumes

$52 million initial contribution amount in 2014 to fund years prior to receiving DOE, reimbursement.

(2) Excludes costs occuring in 2013, which is during the period of licensed operations.

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