View source for BVY 07-007, Submittal of Report Pursuant to 10 CFR 50.54(bb), Titled, Vermont Yankee Nuclear Power Station - Program for Maintenance of Irradiated Fuel.

{{Adams
| number = ML070860696
| issue date = 03/21/2007
| title = Submittal of Report Pursuant to 10 CFR 50.54(bb), Titled, Vermont Yankee Nuclear Power Station - Program for Maintenance of Irradiated Fuel.
| author name = Sullivan T
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR/ADRO
| docket = 05000271
| license number = DPR-028
| contact person = 
| case reference number = BVY 07-007
| document type = Letter type:BVY
| page count = 15
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
E n tergy "P.O.
Vermont Yankee Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 March 21, 2007 BVY 07-007 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==Subject:==
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Report pursuant to 10 CFR 50.54(bb) 10 CFR 50.54(bb) requires Vermont Yankee (VY) submit, five years before expiration of the operating license, the program by which VY intends to manage and provide funding for the management of all irradiated fuel until title to the irradiated fuel is transferred to the Secretary of Energy. VY's operating license is scheduled to expire on March 21, 2012.
Attachment 1 includes the report pursuant to 10 CFR 50.54(bb) titled "Vermont Yankee Nuclear Power Station - Program for Maintenance of Irradiated Fuel."
It should be noted that VY has submitted an application for License Renewal pursuant to 10 CFR 54. Based on this, VY requests that the NRC schedule the review of this information following a final decision on the License Renewal application.
This letter contains no regulatory commitments.
We trust that the information provided is adequate; however should you have any question or require additional information, please contact Mr. David Mannai at (802) 258- 5422.
Sincerely, A.tullivan Site Vice President Vermont Yankee Nuclear Power Station Attachment 1 "Program for Maintenance of Irradiated Fuel" cc: next page ot(

BVY 07-007 / page 2 of 2 cc:     Mr. Samuel J. Collins, Regional Administrator (w/o Attachments)
U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08C2 Washington, DC 20555 David Pelton, USNRC Resident Inspector (w/o Attachments)
Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 07-007 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Program for Maintenance of Irradiated Fuel

BVY 07-007 /Attachment 1 March 13, 2007 Page 1 of 12 Attachment 1 Vermont Yankee Nuclear Power Station Program for Maintenance of Irradiated Fuel Background and Introduction As stated in the cover letter, Entergy Nuclear Vermont Yankee, LLC (Entergy VY or the Company) is seeking renewal of the operating license for the Vermont Yankee Nuclear Power Station (Vermont Yankee), currently set to expire on March 21, 2012. However, pursuant to 10 CFR 50.54(bb), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit written notification to the Nuclear Regulatory Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U.S. Department of Energy (DOE) for ultimate disposal.
A site-specific estimate of the cost to decommission the Vermont Yankee nuclear unit was recently prepared.'ll The analysis evaluated eight possible decommissioning scenarios, reflecting differences in the decommissioning alternative or approach selected, the expected operating license, as well as when the DOE could be expected to complete the transfer of spent fuel from the site. The analysis was prepared for the Vermont Public Service Board for financial plannin*
purposes and as evidence of Entergy VY's financial ability to store spent nuclear fuel the site.
It was based upon the assumptions stated within the referenced document, recognizing that additional and detailed planning and engineering will be required to refine the scenario(s) and execute the selected method of decommissioning at the time operations cease.
Entergy VY is submitting this plan to comply with the requirements of 10 CFR 50.54(bb).
Entergy VY has not determined or committed to a specific decommissioning approach for Vermont Yankee. However, for purposes of demonstrating the adequacy of funding to meet regulatory requirements, the SAFSTOR decommissioning option has been selected and evaluated based on the current license expiration date (Scenario 5 in the referenced decommissioning analysis). Entergy VY reserves the right to choose the ultimate decommissioning option in accordance with its business needs, recognizing that the chosen option will meet the NRC requirements for decommissioning funding.
     "Decommissioning Cost Analysis for the Vermont Yankee Nuclear Power Station," Document No. E 11-1559-002, Rev. 0, January 2007.
2   Docket No. 7082: Petition of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. for a certificate of public good to construct a dry-fuel-storage facility at the Vermont Yankee Nuclear Power Station, in Vernon, Vermont, January 10, 2007.

BVY 07-007/Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 2 of 12 Spent Fuel Management Strategv Completion of the decommissioning process is highly dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. 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 removed from service ("oldest fuel first allocation"). The Company's current spent fuel management plan for the Vermont Yankee spent fuel is based upon 1) a 2017 start date for repository operations, consistent with the DOE's License Application Schedule for Yucca Mountain released in 2006, and 2) the DOE's expectations for spent fuel receipt as delineated in the "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, last updated in July 2004. Optimally, the Company projects that fuel could be removed from the site as early as 2042, if the oldest fuel allocation receives the highest priority and the geologic repository is able to achieve the DOE's stated annual rate of transfer (3,000 metric tons of uranium/ year). 31 The NRC requires (in 10 CFR 50.54(bb)) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. Interim storage of the spent fuel, until the DOE has completed the transfer, will be in the reactor building storage pool and/or at an Independent Spent Fuel Storage Installation (ISFSI) located on the Vermont Yankee site.
An ISFSI is currently being constructed within the protected area (PA) to support continued plant operations. Depending upon the shutdown date and DOE's performance, this facility may not have sufficient capacity to support decommissioning operations. For example, in a scenario where the plant ceases operation in 2012, a second, supplemental ISFSI will likely be required to accommodate all the assemblies discharged over the operating period of the reactor. For financial planning purposes, the cost to construct this new facility is included within the decommissioning cost reported for the SAFSTOR scenario.
In the assumed scenario, 3,719 assemblies are generated through the end of currently licensed operations in 2012. To maintain core off-load capability, ten casks are loaded during operations (680 assemblies) and placed on the PA ISFSI pad. A new, larger pad is constructed at the north end of the site (within the owner controlled area) to permit post-shutdown dry fuel storage. The ten casks are relocated to this new pad in early 2015. The assemblies stored in the reactor building's spent fuel storage pool at the time of shutdown (3,039 assemblies) are loaded into multi-purpose canisters (MPCs) and moved into storage casks on the new pad by late 2017.
Under this scenario, the nuclear unit is placed in safe-storage until such time that all fuel is removed from the site. During the dormancy period, the MPCs are periodically off-loaded into a DOE transport cask such that all 55 canisters are removed from the site by the year 2042. A discussion of the site-specific considerations for the management of spent fuel at Vermont Yankee may be found in Section 3.4 of the referenced decommissioning analysis.
3    In addition to the satisfactory resolution of current and pending legal challenges and the elimination or amendment of the administrative limit on the repository's total capacity. The Company's analysis assumes, for purposes only of this report, that the Company does not employ DOE spent fuel disposal contract allowances for up to 20% additional fuel designation for shipment to DOE each year.

B VY 07-007 / Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 3 of 12 In the event that Vermont Yankee does cease operations in 2012, Entergy VY will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and ISFSI(s), as necessary, under the decommissioning scenario ultimately selected. In addition, Entergy VY will also comply with applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued storage of irradiated fuel.
Spent Fuel Management and the SAFSTOR Decommissioning Option The total cost to decommission Vermont Yankee, including placing the unit into safe-storage at the conclusion of its currently scheduled operating license (2012), storing and managing spent fuel until such time that the DOE can complete the transfer of spent fuel, and the Company can decommission the nuclear unit and restore the site, is estimated at $803.7 million (2006 nominal dollars), based upon the recent, site-specific analysis. The total cost comprises 1) costs associated with the termination of the reactor operating license, 2) costs assigned to the caretaking and transfer of the spent fuel, and 3) the restoration of the site following its release for unrestricted use. The individual estimates for these three activities are reported as $457.5 million, $304.8 million and $41.5 million, respectively, in 2006 dollars.
Table 1 provides a schedule of estimated expenditures (costs in 2006 nominal dollars, in the projected year of expenditure) for the license termination cost component. Table 2 provides a similar schedule for the estimated spent fuel management costs with Table 3; a combined total of the first two tables.
Cost Considerations The significant contributors to the cost of spent fuel management in the SAFSTOR scenario are identified in Table 4.[4] As shown, costs are included for the design and construction of the ISFSI, the relocation of the spent fuel from the pool to the ISFSI pad, and eventual transfer of the fuel to the DOE. Table 5 provides an annual schedule for the Table 4 expenditures. Note that the $94.2 million, shown in Tables 4 and 5, reflect the direct costs associated with constructing an ISFSI, procuring and loading dry storage canisters, and transferring fuel to the DOE. This cost is a subset of the $304.8 million (spent fuel costs) estimate identified in Table 2. The differential comprises the management, security and other administrative and site support costs assigned to the spent fuel management effort over the 30-year post-operations storage period (from 2012 to 2042). It must also be noted that these figures will vary based on actual DOE performance, including the actual cask provisions and requirements that DOE settles upon. At this time, DOE has not identified any transport casks or requirements. Therefore, there is considerable uncertainty as to the actual costs that will have to be incurred. Major scheduling milestones are identified in Table 6.
4   Direct costs only, excluding plant caretaking costs during the dormancy period.

BVY 07-007 /Attachmentl Programfor Maintenanceof IrradiatedFuel March 13, 2007 Page 4 of 12 Entergy VY is currently constructing an ISFSI to support continued plant operations. The cost to construct this ISFSI, located within the protected area and to the north of the Reactor Building, is not reflected within the decommissioning analysis since it will be in service prior to 2012.
However, the decommissioning analysis does address the disposition of the ten storage casks expected to be placed on the pad prior to current license expiration in 2012.
At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies from the most recent refueling cycles. Over the next five and one-half years the assemblies are packaged into MPCs for transfer to dry storage. It is assumed that the five and one-half years provides the necessary cooling period for the final core to meet the decay heat requirements for the dry cask storage system. During this period, the spent fuel storage and handling facilities are reconfigured so that the preparation for safe-storage can proceed on the remaining plant systems. The cost allocated to the isolation of the spent fuel pool is estimated at $9.2 million, based upon experience at Maine Yankee. Once the pool is emptied, the reactor building and the spent fuel storage and handling facilities are readied for long-term storage.
The evaluated SAFSTOR scenario includes the construction of a new ISFSI. Construction is assumed to occur such that the facility is available at the beginning of first quarter 2015.[5] The cost estimated for this activity is $28.4 million.[61 The estimate is based on the cost to build the current PA ISFSI and includes site improvements, the ISFSI pad, transporter path, and security systems and support facilities. The ten casks stored on the PA ISFSI are expected to be relocated to the new pad by the end of the first quarter 2015. Over the subsequent two and one-half years, Entergy VY anticipates loading 45 MPCs with the assemblies remaining in the reactor building's spent fuel pool. The MPCs will then be placed in storage casks on the new ISFSI.
In the absence of identifiable DOE cask requirements, the design and capacity of the new ISFSI is based upon a commercial dry cask storage system. The MPC has a capacity of 68 fuel assemblies at a unit cost of approximately $705,000. An additional cost of $292,000 is allocated for the concrete storage overpack.
An average cost of $274,500 was estimated for the labor and equipment to load, seal and transfer each MPC from the storage pool to the ISFSI. A cost of $76,000 was estimated for the final transfer of the MPC at the ISFSI into a DOE transport cask (50% of the cost incurred for transferring the spent fuel into a dry storage canister).
Operation of the spent fuel pool is discontinued in 2017 after the fuel has been transferred to dry storage. ISFSI operations continue throughout the dormancy period until such time that the DOE is able to complete the transfer of the Vermont Yankee fuel to a federal repository (currently anticipated to be in 2042).
5   A summary of significant milestones is shown in Table 6.
6    15% contingency is included in the spent fuel related costs, consistent with the site-specific decommissioning analysis.

BVY 07-007 / Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 5 of 12 Prior to transferring all fuel to dry storage, the annual cost to maintain the plant and the ISFSI in safe-storage, and packaging and transfer fuel to the ISFSI is approximately $31.5 million.
Dormancy activities include operations and maintenance of the spent fuel pool, procuring, loading and transferring MPCs, a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.
After all fuel has been transferred to dry storage, the annual cost to maintain the plant and the ISFSI in safe-storage, and transfer fuel to the DOE is estimated at approximately $6.4 million.
Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.
Decommissionin Once the spent fuel is removed from the site, decommissioning operations would commence.
The ISFSI is scheduled to be decommissioned along with the nuclear plant facilities. It is assumed that once the MPCs containing the spent fuel assemblies have been removed, any required decontamination performed on the storage modules (some minor activation is assumed) and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad can then be removed and the area regraded. The cost estimated to decontaminate the ISFSIs to the extent necessary to release the facilities for conventional demolition is estimated at $2.9 million.
Conventional demolition of the remaining overpacks and pads and restoration of the affected area of the site is estimated at $502,000.
Financial Assurance Assuming a 3% annual growth in the liability, an after-tax rate of return of 5.59% would be required to meet the distribution requirements identified in Table 3. At a 4% annual rate of growth in the liability, the required rate of return required increases to 6.62%.
The decommissioning trust fund balance for Vermont Yankee was reported at $416.5 million as of December 31, 2006. Since Entergy VY acquired Vermont Yankee on July 31, 2002, on an after-tax basis, funds in the decommissioning trust have grown at an annual rate of 6.73%. At this rate, assuming liability growth at 4% or less, sufficient funds would be available to decommission Vermont Yankee (including caretaking of the spent fuel) under the scenario described.
Additional Considerations As stated previously, Entergy VY is seeking renewal of the operating license for Vermont Yankee. With the potential for an additional 20 years of fund growth, there is a corresponding

BVY 07-007 /Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 6 of 12 and significant decrease in the earning requirements. For example, assuming the plant operates until 2032 and is then placed into SAFSTOR (Scenario 6 in the referenced analysis), the rate of return required is closer to 4%, assuming a 3% annual growth in the liability.

BVY 07-007 1/Attachment]
Program for Maintenance of Irradiated Fuel March 13, 2007 Page 7 of 12 Table 1 Estimated License Termination Costs (thousands of 2006 dollars)
Year     Labor      Equip & Matis    Energy         Burial        Other           Total 2012       27,572              545          688            40         2,809          31,654 2013       26,673            4,121          594         1,353         3,439          36,180 2014            36             240            0            33           252             560 2015            36             240            0            33           252             560 2016            36             241            0            33           253             562 2017            36             240            0            32           252             560 2018            36             240            0            31           251             558 2019            36             240            0            31           251             558 2020            36             240            0            31           252             559 2021            36             240            0            31           251             558 2022            36             240            0            31           251             558 2023            36             240            0            31           251             558 2024            36             240            0            31           252             559 2025            36             240            0            31           251             558 2026            36             240            0            31           251             558 2027            36             240            0            31           251             558 2028            36             240            0            31           252             559.
2029            36             240            0            31           251             558 2030            36              240           0            31           251             558 2031            36              240           0            31           251             558 2032            36              240           0            31           252             559 2033            36              240           0            31           251             558 2034            36              240           0            31           251             558 2035            36              240           0            31           251             558 2036            36              240           0            31           252             559 2037            36              240           0            31           251             558 2038            36-             240           0            31           251             558-2039            36              240           0            31           251             558 2040            36              240           0            31           252             559 2041            36              240           0            31           251             558 2042          113              242            2           31           258             647 2043       28,382            1,102         851            61         2,797          33,193 2044      48,097           14,114          832       29,333         11,531         103,907 2045       39,845           8,506          682       23,790          8,313          81,137 2046       35,175           3,784          638        13,963         4,986          58,547 2047       35,175           3,784          638        13,963         4,986          58,547 2048       19,826            1,671         278         3,356        12,782          37,913 2049           79                0            0             0             0              79 2050           37                0            0             0             0              37
______  261,970           44,591        5,204        86,767        58,949        457,480

BVY 07-007 /Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 8 of 12 Table 2 Estimated Spent Fuel Management Costs (thousands of 2006 dollars)
Year  Labor       Equip & Matls      Energy       Burial      Other            Total 2012       2,277            6,831             0          0        4,210           13,317 2013       5,756            9,263           51           0       12,107           27,177 2014      13,331          .13,432          170           0        3,981           30,914 2015      13,331          13,432           170           0        3,981           30,914 2016      13,368          13,469           171           0        3,992           30,999 2017      10,556            9,297          144           0        3,090           23,086 2018       4,470              353           85           0        1,103            6,011 2019       4,367                75          85           0        1,103            5,630 2020       4,441              242           85           0        1,106            5,874 2021       4,450              297           85           0        1,103            5,935 2022       4,450              297           85           0        1,103            5,935 2023       4,429              241           85           0         1,103           5,859 2024       4,420              186           85           0         1,106           5,798 2025       4,408              186           85           0         1,103           5,782 2026       4,408               186          85           0         1,103           5,782 2027       4,408               186          85           0         1,103           5,782 2028       4,420               186          85           0         1,106           5,798 2029       4,387               130          85           0         1,103           5,706 2030       4,408               186          85           0         1,103           5,782 2031       4,408               186          85           0         1,103           5,782 2032       4,379                75          85           0         1,106           5,645 2033       4,387               130          85           0         1,103           5,706 2034       4,387               130          85           0         1,103           5,706 2035       4,429              241           85           0         1,103           5,859 2036       4,399               131          85           0         1,106           5,722 2037       4,408               186          85           0         1,103           5,782 2038       4,408               186          85           0         1,103           5,782 2039       4,408               186           85          0         1,103           5,782 2040       4,420               186           85          0         1,106            5,798 2041       4,387               130           85          0         1,103            5,706 2042       4,479              408            85          0         1,100            6,072 2-043           0                 0           0          0             0                 0 2044            0                 0           0          0             0                 0 2045          99               82            0        95            438              714 2046         134              111            0       128            592              965 2047         134              111            0       128            592              965 2048          35                31           0         30           143              238 2049         105              172            0          0            57              335 2050          50                82           0          0            27              159 16,4               121          284          31         6,0              0,0 169,5431          71,241        2,834        381        60,806          304,804

BVY 07-007 /Attachmentl Program for Maintenance of Irradiated Fuel March 13, 2007 Page 9 of 12 Table 3 Estimated Combined License Termination and Spent Fuel Management Costs (thousands of 2006 dollars)
Year         Labor        EQuiv & Matls     Energy      Burial       Other     I    Total 2012             29,849            7,376          688         40        7,019          44,971 2013             32,429           13,384          646      1,353       15,546          63,358 2014             13,367           13,672          170         33        4,233          31,475 2015             13,367           13,672          170         33        4,233          31,475 2016             13,403           13,710          171         33        4,244          31,561 2017             10,591            9,537          144         32         3,342         23,646 2018               4,506             592           85         31         1,355          6,569 2019               4,402             315           85         31         1,355          6,188 2020               4,476             482           85         31         1,358          6,433 2021               4,485             537           85         31         1,355          6,493 2022               4,485             537           85         31         1,355          6,493 2023               4,464             481           85         31         1,355          6,417 2024               4,456             427           85         31         1,358          6,357 2025               4,444             426           85         31         1,355          6,340 2026               4,444             426           85         31         1,355          6,340 2027               4,444             426           85         31         1,355          6,340 2028              4,456              427           85         31         1,358          6,357 2029               4,423              370          85         31         1,355          6,264 2030               4,444             426           85         31         1,355          6,340 2031               4,444             426           85         31         1,355          6,340 2032               4,414              316          85         31         1,358          6,205 2033               4,423              370          85         31         1,355          6,264 2034               4,423              370          85         31         1,355          6,264 2035               4,464             481           85         31         1,355          6,417 2036               4,435              371          85         31         1,358          6,281 2037      4,    4,44                  426          85         31         1,355          6,340 2038              4,444              426          85         31         1,355          6,340 2039               4,444              426          85         31         1,355          6,340 2040               4,456              427          85         31         1,358          6,357 2041               4,423              370          85         31         1,355          6,264 2042               4,592              650          87         31         1,359          6,719 2043             28,382             1,102         851         61         2,797         33,193 2044             48,097            14,114         832     29,333       11,531         103,907 2045             39,944             8,589         682     23,884         8,751         81,851 2046            35,309             3,896         638     14,091         5,578         59,512 2047            35,309             3,896         638     14,091         5,578         59,512 2048             19,861            1,702         278      3,386        12,925         38,151 2049                 184             172            0         0            57            413 2050                  88              82            00                     27             197 431,513          115,832        8,038     87,147      119,755 1       762,2851

BVY 07-007 /Attachmentl Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 10 of 12 Table 4 Significant Cost Contributors Spent Fuel Management                                                                                   -        Direct Expenditures__                                                                                                                                                                                                                      (2006 dollars)*
New ISFSI Construction Cost                                                                                                                                                                                                                                                                                                                                                     28,365,814 Spent Fuel Transfer Facility                                                                                                                                                                                                                                                                                                                                                         3,660,105 Transfer of PA Casks to New ISFSI (10)                                                                                                                                                                                                                                                                                                                                                         762,522 Capital Costs of New ISFSI MPCs and Overacks (45)                                                                                                                                                                                                                                                                                                                               44,866,733 M        P .Loading MPC                   .....        a........ n.d _Costs    .............
(.s.[             .(45)4....) .......................                    ...............................
                                                                                                                                                                                                                                                                                                                                            ......................................... 5 .4 ._ ._!} .}..
5,490,158 MPC Transfer'Costs from Pool to New ISFSI (45)                                                                                                                                                                                                                                                                                                                                       6,862,697 MPC Transfer Costs from New ISFSI to DOE (55)                                                                                                                                                                                                                                                                                                                                        4,193,870
* Contingency has been added to all costs (15%)

BVY 07-007 / Attachment]
Programfor Maintenance of IrradiatedFuel March 13, 2007 Page 11 of 12
                                          -             Table 5 Estimated Expenditures for ISFSI Construction, Spent Fuel Packaging and Canister Transfer
* Transfer Fuel         PA**                         Pool to       Pool to     ISFSI to New ISFSI        Transfer     Casks to     ISFSI Cask         ISFSI        ISFSI         DOE            Total Year      Construction      Facility       ISFSI         Costs         Loading       Transfer     Transfer        ($2006)
        +                +         -   t            t                      -                I            I 2012         9,455,271               0           0              0                0            0            0      9,455,271 2013         9,455,271               0           0              0                0            0            0      9,455,271 2014         9,455,271               0           0      9,970,385                0            0            0     19,425,656 2015                  0              0    762,522      19,940,770      1,220,035     1,525,044             0     23,448,371 2016                  0              0           0     14,955,578      2,440,070     3,050,088             0     20,445,735 2017                  0     3,660,105            0              0      1,830,053     2,287,566             0      7,777,723 2018                  0              0           0              0                0            0     381,261         381,261 2019                  0              0           0              0                0            0            0               0 2020                  0              0           0              0                0            0     228,757         228,757 2021                  0              0           0              0                0            0     305,009         305,009 2022                  0              0           0               0               0            0     305,009         305,009 2023                  0              0           0               0               0            0     228,757         228,757 2024                  0              0           0               0               0            0     152,504          152,504 2025                  0              0           0               0               0            0     152,504          152,504 2026                   0             0           0               0               0            0     152,504          152,504 2027                   0             0           0               0               0            0     152,504          152,504 2028                   0             0           0               0               0            0     152,504          152,504 2029                   0             0           0               0               0            0      76,252           76,252 2030                   0             0           0               0               0            0     152,504          152,504 2031                   0             0           0               0               0            0     152,504          152,504 2032                   0             0           0               0               0            0            0               0 2033                   0             0           0               0               0            0      76,252           76,252 2034                   0             0            0              0               0            0      76,252           76,252 2035                   0             0            0              0               0            0     228,757         228,757 2036                   0             0            0              0               0            0      76,252           76,252 2037                   0             0            0              0               0            0     152,504          152,504 2038                   0             0            0              0               0            0     152,504          152,504 2039                   0             0            0              0               0            0     152,504          152,504 2040                   0             0            0              0               0            0     152,504          152,504 2041                   0             0            0              0               0            0      76,252           76,252 2042                   0             0            0              0               0            0     457,513         457,513 28,365,814 1 3,660,105 1 762,522           44,866,733      5,490,158   j_6,862,697    4,193,870    j 94,201,898
* A 15% contingency factor has been applied to all spent fuel related costs
      **  Transfer of the 10 casks located on the ISFSI constructed within the Protected Area (PA) to support plant operations to the new ISFSI constructed at the north end of the site property

BVY 07-007 / Attachmentl Programfor Maintenanceof IrradiatedFuel March 13, 2007 Page 12 of 12 Table 6 Projected Schedule and Milestones Major Milestones and Fuel-Related Events Currently scheduled cessation of plant operations                                   March 2012 New ISFSI available                                              2015 (beginning of 1st quarter) i Casks transferred from PA ISFSI to New ISFSI                        2015 (by end of 1st quarter)
First MPC transferred from.pool to New ISFSI                                 2015 (3 rd quarter)
Last MPwtransferred from pool to New
(     SFSt                                2017 (3rd quarter)
End of wet storage pool operations (66 months)                                 Se tember 2017 March 31, 2017 I DOE begins to receive commercial spent fuel Ist Vermont Yankee fuel assembly removed from site                           2018 ( 4 th quarter)
I Last Vermont Yankee fuel assembi leaves site                                   December 2042 Decommissioning Operations Commence                                            December 2042 ISFSI decommissioned (concurrent with other site facilities)       April 2045 thru March 2048 ISFSI demolition (concurrent with other site facilities)        December 2048 thru June 2050}}