ML22010A012

Yankee Atomic Electric Company - Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan

ML22010A012
Person / Time
Site:	Yankee Rowe
Issue date:	01/10/2022
From:	Conry T Yankee Atomic Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
BYR 2021-019
Download: ML22010A012 (20)

Text

YANKEE ATOMIC ELECTRIC COMPANY 49 Yankee Road, Rowe, Massachusetts 01367

December 10, 2021 BYR 2021-019 Re: 10 CPR 72.4 and 10 CPR 72.30

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission

. Washington, DC 20555 - 0001

Yankee Atomic Electric Company Yankee Nuclear Power Station Independent Spent Fuel Storage Installation NRC License No. DPR-3 (NRC Docket No.50-029)

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 72.4, Yankee Atomic Electric Company (Y AEC) is providing the three-year update to the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Yankee Nuclear Power Station (YNPS) ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous YNPS 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 YNPS 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 2018:

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

10 CFR 72.30(b)(l) requires the licensee to provide "information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI." Y AEC has established Yankee Atomic Electric Company BYR 2021-019/December 10, 2021/Page 2 an account within its Nuclear Decommissioning Trust (NDT) entitled, "ISFSI Radiological Decom," that segregates the funds for decommissioning of the ISFSI from the larger balance of funds for ongoing management of irradiated fuel and GTCC waste held in the NDT. Currently, the trust has sufficient funds to meet the revised DCE for the YNPS 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 YNPS 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 IO CFR 72.30(b )(2)(iii).

In addition, the revised YNPS 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 YNPS ISFSI DCE estimates the total cost to decommission the YNPS ISFSI to be $5.9 million in 2021 dollars for radiological decommissioning and $8.5 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 YNPS 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 (unds 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. Y AEC will periodically reassess the decommissioning cost estimate in accordance with 10 CFR 72.30( c ). On a periodic basis, Y AEC 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.

Y AEC 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, Y AEC submits the reports required by 10 CFR 50.75(f)(2), 10 CFR 50.82(a)(8)(v) and 10 CFR 50.82(a)(8)(vii) to establish how it satisfies the obligations defined in those regulations regarding the assurance of decommissioning funding and the status of funding for the management of irradiated fuel.

10 CFR 72.30(b )(5) requires the licensee to define the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license Yankee Atomic Electric Company BYR 2021-019/December 10, 2021/Page 3 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 the Vertical Concrete Casks (VCCs) and VCCs liners is 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 Commonwealth of Massachusetts.

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 YNPS ISFSI for the management of irradiated fuel and GTCC waste at the YNPS ISFSI through 2037.

A summary of the revised DCE and the cost estimate for the management of irradiated fuel and GTCC waste at the YNPS 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.

Respectfully, Yankee Atomic Electric Company BYR 2021-019/December 10, 2021/Page 4

Enclosures:

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

2. Certification of Financial Assurance

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

Reference:

1. Letter from C. Pizzella (Y AEC) to Document Control Desk (NRC), Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 10, 2018 (BYR2018-025)

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. Viveiros, Senior Nuclear Planner, MEMA J. Cope-Flanagan, Assistant General Counsel, MDPU J. Rogers, State of Massachusetts Office of the Attorney General ENCLOSURE 1 TO BYR 2021-019

DECOMMISSIONING STUDY OF THE YANKEE ROWE INDEPENDENT SPENT FUEL STORAGE INSTALLATION Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 1 of 11

10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction

The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,( 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 Yankee Rowe (YR) 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

Yankee Rowe (YR) was successfully decommissioned between 1992 and 2007.

During decommissioning all 533 spent fuel assemblies were transferred from the spent fuel pool to 15 spent fuel storage casks. In addition, 1 GTCC cask 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 Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 2of 11

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 reactorJ 2J

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 Commonwealth of Massachusetts release criteria.

4. ISFSI Description

The YR ISFSI is located on approximately 2 acres of the 1800-acre site. The ISFSI consists of 15 dry storage casks containing 533 spent nuclear fuel assemblies used during operations. The NAC-MPC fuel storage and transport canister system was chosen by YR and is licensed by the NRC for both storage and transportation. The NAC-MPC system consists of a multi-purpose spent fuel storage canister and a vertical concrete and steel overpack. Each vertical concrete cask has a three-and-a-half-inch steel liner surrounded by 21 inches of reinforced concrete. Construction of the concrete storage pad and vertical concrete and steel storage was completed during decommissioning.

Transferring the spent fuel from the spent fuel pool to the storage casks was completed in March of 2003.

In addition to the 15 spent fuel storage casks there is one cask 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 MPC canisters, the overpacks will be surveyed and any found to have residual

2 U.S. Code of Federal Regulations, Title 10, Part 961.11, Article N - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a)... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as... "

TLG Services, LLC Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 3of 11

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 surrounding environs meet the NRC's radiological limits established for unrestricted use, forms 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, 3 of the 15 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.

TLG Services, LLC Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 4 of 11

Decommissioning is assumed to be performed by an independent contractor.

As such, essentially all labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as RSMeans Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Those craft labor positions are expected to be provided locally. Yankee Atomic Electric Company, 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

• Diesel generator and building

• Gatehouse

• ISFSI support building

• Instrument enclosure -conduit and wire

• Nuisance fence

• Remove road inside licensed area

• Remove vehicle barriers

• Retaining wall

• Septic system and utilities

Costs are reported in 2021 dollars. Costs do not include Massachusetts sales tax.

Contingency has been added to the ISFSI Decontamination costs 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.

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

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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) 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 as 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), YR's oversight staff, site security (industrial), and other site operating costs.

TLG Services, LLC Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 6of 11

For estimating purposes, it should be conservatively assumed that all expenditures will be incurred in the year following all spent fuel removal.

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Table 1 Significant Quantities and Physical Dimensions

ISFSI Pad

Item Length (ft) Width (ft) Radioactivity Residual

ISFSI Pad (dimensions are for current pad) 180 48 No

ISFSI Overpack

Item Value Notes (all dimensions are nominal)

NAC-MPC Overall Height (inches) 160.0 Dimensions are nominal Overall Diameter (inches) 128.0 Dimensions are nominal Inside Diameter (inches) 79.0 Dimensions are nominal Inner Liner Thickness (inches) 3.50 Dimensions are nominal Quantity (total) 16 15 spent fuel+ 1 GTCC Quantity (with residual radioactivity) 3 Total Surface Area of overpack interior with Residual 827 Radioactivity (square feet)

Low-Level Radioactive Waste (cubic feet) 8,692 Low-Level Radioactive Waste foackaged density) 52

TLG Services, LLC Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI

• Page 80{ 11

Table 2 ISFSI Decommissioning Costs and Waste Volumes (Thousands of 2021 Dollars)

Removal Packaging Transport Disposal Other Total LLRW Burial Oversight Costs Costs Costs Costs Costs Costs Volume Craft and Class A Manhours Contractor Activity Descriution (cubic feet) Manhours

Decommissionine: Contractor Planning ( characterization, specs and procedures) - - - - 185 185 -- 952 Decontamination ( activated liner and concrete removal) 22 62 - 118 - 202 8,692 238 -

License Termination (radiological surveys) - - - - 818 818 -5,068 -

Subtotal 22 62 - 118 1,003 1,204 8,692 5;306 952

Sunnortine: Costs NRC and NRC Contractor - - - - 289 289 - - 1,153 Fees and Costs Insurance - - - - 168 168 -- -

Property taxes - - - - 123 123 -- -

NRCFees - - - - 138 138 -- -

Site O&M Cost - - - - 1,135 1,135 -- -

Security Staff Cost - - - - 164 164 -- 11,625 DOC Staff Cost - - - - 522 522 -- 4,787 Utility Staff Cost - - - - 1,007 1,007 -- 5,471 Subtotal - - - - 3,546 3,546 -- 23,036,

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Table 2 (continued)

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

Removal Packaging Transport Disposal Other Total LLRW Burial Oversight Costs Costs Costs Costs Costs Volume Craft and Activitv Description Costs Class A Manhours Contractor (cubic feet) Manhours

ISFSI Decontamination Total 22 62 - 118 4,549 4,751 8,692 5,306 23,988 (w/o contin2ency)

ISFSI Decontamination Total 28 77 - 147 5,687 5,939 8,692 5,306 23,988 (with 25% contin2ency)

ISFSI Site Restoration Remove Fencing (linear foot) 3 - - - - 3 - 33 -

ISFSI Cask & Pad Demolition 295 - - - 75 369 - 1,789 -

and Removal ISFSI Support systems 48 - - - - 48 -614 -

Demolition of Remaining Site Buildin2s Diesel Generator and Building 0 - - - - 0 - 1 -

Gatehouse 17 - - - - 17 -166 -

ISFSI Suooort Building 36 - - - - 36 -252 -

Instrument Enclosure -conduit 0 - - - - 0 - 0 -

and wire Nuisance Fence 146 - - - - 146 -1,571 -

Remove road inside licensed 47 - - - - 47 -430 -

area Remove vehicle barriers 1 - - - - 1 -8 -

Retaining Wall 11 - - - - 11 -51 -

Septic System and Utilities 3 - - - - 3 -17 -

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Table 2 (continued)

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

Removal Packaging Transport Disposal Other Total LLRW Burial Oversight Costs Costs Costs Costs Costs Volume Craft and Activity Description Costs Class A Manhours Contractor (cubic feet) Manhours Construction Debris - - - - 28 28 -- -

Grade and Landscape 3 - - - - 3 -12 -

Subtotal 608 - - - 103 711 -4,945 -

Suooortin2 Costs NRC and NRC Contractor - - - - 26 26 - - 160 Fees and Costs Property taxes - - - - 31 31 -- -

Site O&M Cost - - - - 284 284 -- -

Security Staff Cost - - - - 41 41 -- 2,906 DOC Staff Cost - - - - - 130 130 -- 1,197 Utility Staff Cost - - - - 252 252 -- 1,368 Severance - - - - 604 604 -- -

Subtotal - - - - 1,368 1.368 -- 5,631

ISFSI Site Restoration Total 608 - - - 1,471 2,079 - 4,945 5,631 (w/o contin2ency)

ISFSI Site Restoration Total 761 - - - 1,838 2,599 - - -

(with 25% contin2ency)

Total (w/o contin2ency) 631 62 - 118 6,020 6,830 8,692 10,251 29,618

Total (with contin2ency) 788 77 - 147 7,525 8,538 8,692 10,251 29,618

TLG Services, LLC Yankee Atomic Electric Company Attachment 1 Yankee Rowe ISFSI Page 11 of 11

Table 3 ISFSI Decommissioning - Structures Included

Contaminated Removal Cask inner liner Cask lid Cask base & misc. Internal fixtures VCC concrete Clean Removal ISFSI concrete pad Non-activated overpacks Remove fencing (linear foot)

ISFSI suooort systems Diesel generator and building Gatehouse ISFSI support building Instrument enclosure -conduit and wire Nuisance Fence Remove road inside licensed area Remove vehicle barriers Retaining wall Septic system and utilities

TLG Services, LLC ENCLOSURE 2 TO BYR 2021-019

CERTIFICATION OF FINANCIAL ASSURANCE CERTIFICATION OF FINANCIAL ASSURANCE

NRC Licensee:

Yankee Atomic Electric Company Yankee Rowe Independent Spent Fuel Storage Installation NRC License No. DPR-3 {NRC Docket No.50-029) 49 Yankee Road Rowe, MA 0 1367

Issued to: U.S. Nuclear Regulatory Commission

Certification:

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

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

I further certify that financial assurance in an amount sufficient to fund YNPS ISFSI radiological decommissioning at the time of such decommissioning has been provided, pursuant to 10 CFR 72.30, as described in the letter to which this Certification is attached. That radiological decommissioning funding assurance is premised on a site-speci_fic decommissioning cost estimate and funding methodology described therein, in the amount of:

$5.9 million (in 2021 dollars, inclusive of contingency)

T yConry Yankee Atomic Electric Company Treasurer Phone (508) 612-3322

Date D ecc-" \\o,,.- I 0 J q) 0 0.. I Corporate Seal I I ENCLOSURE 3 TO BYR 2021-019

TOTAL COSTS ASSOCIATED WITH THE YNPS ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE YANKEE ATOMIC ELECTRIC COMPANY 2022 -2039 Summary

Yankee Atomic El<<:tric Company Irradiated Fuel & GTCC Waste Management and ISFSI Decom Estimate Represented in 2022 Dollars FERn -tCl _.; _eun-~-m - - --:::_- __ ~ Sum of2022 Sum of2023 Sum of 2024 Sum of 2025 Sum of 2020 Sum of 2027 Sum of202S Sum of2029 Sum of 2030 Sum of2031 Sum of 2032 Sum of 2033 Sum of2034 Sum of 2035 Sum Summary I Co..,. -~ s10,441 494,4n 74, 621 466,880 es, s21 593,788 482,709 463,448 475,633 11, se1 537,931 481,095 78, 769 469,481 967,-41Qi 1.065.447 1,367, osa 795,3 2 of203& Sum of 2037 Sum of 2038 Sum of 2039 2022-2039 Insurance 523,947 523,947 623,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 523,947 1,101,QOO 11,121,940 Labor-No n-Manua l 2,954,963 2,929,167 2,872,458 2,914,706 2,838,508 2,823,894 2,838,009 2,751.125 2,726,843 2,726,643 2,726,843 2,726,843 2,726,843 2.726.843 2,718,767 2,733,843 2,733,843 2,702,845 10,008,999 Materials & Supp lies 170,149 93,689 97, 997 94,766 93,689 177,687 93,689 93,689 93,689 93,689 115, 50,171,187 MlsceU aneous 166,757 188,294 166,757 166,757 188,294 166,757 166,757 188,29-4 166,757 166,757 188.294 166,757 166,757 168, 757 188,29-1 166,757 170,956 Hil1,148 227 93,689 93,68fil 93,689 212, 147 93,689 34,-161 34,-161 1,873,790 Outside SeMces

• A&G 732,526 710,988 754,064 678,681 740,602 739,256 700,219 732,526 700,219 719,065 700,219 678,681 814,639 657,143 719,065 657, 143 786,372 866,471 3,137,898 Outside Services. Fuel Loading 279,992 753,823 13,087,879 Outside Services* ISFSI OP's 626,750 481,370 662,288 48 1, 370 626,750 1,163,042 626,750 481,370 662,288 481,370 626,750 516,908 626,750 481,370 662,288 389,834 181,995 136,227 1,033,815 Outs ide Servlcel

• Legal 430,756 699,979 161,534 269,223 430,756 511,523 161,534 269,223 430,756 511,523 161,534 269,223 430,756 511,523 161,534 269,223 269,223 1,238,424 9,915,470 OutskH Services

• NON.RAO D&0 of 7,188,245 ISFSI 2,207,SN 2,207,694

'Outalde Servk:M - RAD D&0 of ISFSI 3,871,938 3,871,938 Property Taxes 382,298 382,296 382,296 382,296 382,296 382,296 382,298 382,296 382,296 382,298 382,296 382,296 382,296 382,296 382,296 382,296 382,296 382,298 6,881,331 Regulatory Fees 430,756 430,756 430,756 430,756 430,756 430,756 430,756 430,756 430,756 430,756 430.756 414,603 414,603 414,603 430,756 430,756 603,058 606,289 8,052,988 utilities 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 75,382 1,356,882 Federal Ex cise Tax 3,974 3,974 3,974 3,974 3,974 3,974 3, 974 3,974 3,974 3,974 3,974 3,974 3,974 3, 974 3,974 3,974 3,974 3, 97 71,527 Labor

• Non--Manua i. Success ion Plann ing 87,173 45,212 65,831 283,275 20,640 36,345 50,392 568,889 Labor

• Security Contractor 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3,240,364 3, 240,364 3,240,364 3, 2 0, 364 3,240,364 538,445 538,445 52,922,713 Outside Sefvlces

• IAGE 775,361 129,227 75,382 75,382 75,382 829,206 129,227 75,382 75.38~ I 75,382 775,361 129,227 75,382 75,382 75,382 75,382 129,227 75,382 3,726,042

~:;~ *U=FT~-----~ =~ ~: 807 668 807 668 B0~668 8~ 3,230,672 11 079 10_,38!t_906 9 087 031 980Ua5 10,202,381 12, e9,539 10 13& 888 9732, 17 9,988,287 9,902918 11 296,S. 7 9,882,988 10,05,C 152 9 859100 10~1,608 11,719,022 13,879,798 a 148 568 190,44e,ne I Source 2019 FERC, Eac:afated In 2022 S

Note 1: The cost of management of irradiated fuel and GTCC waste is calculated as follows:

$ 190,449,776 Grand Total from Above

$ (2,207,594) Non-Rad D&D ISFSI (per 2021 Knight Cost Study)

$ (3,871,938) Rad D&D ISFSI (per 2021 Knight Cost Study )

$184,370,245 Management of Irradiated Fuel and GTCC Waste

Note 2 : The cost of RAD and NON-RAD D&D of the ISFSI in 2022 dollars as provided in the column labeled "Sum of 2038" is derived by escalating the value of the cost estimates prov ided In Enclosure 1 by 2.5%.

Note 3: This Summary Combines YR's 2019 Approved FERC Rate Case with the TLG Services 2021 RAD and NON-Rad ISFSI Decom Cost Estimate