CY-21-015, Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan

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Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan
ML21362A132
Person / Time
Site: Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 12/10/2021
From: Conry T
Connecticut Yankee Atomic Power Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CY-21-015
Download: ML21362A132 (21)
v • d • e


Text

CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT PLANT 362 INJUN HOLLOW ROAD

  • EAST HAMPTON, CT 06424-3099 December 10, 2021 CY-21-015 Re: 10 CFR 72.4 and 10 CFR 72.30 ATTN: Document Control Desk, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License No. DPR-61 (NRC Docket No. 50-213) 1 z.- -3 9

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, Connecticut Yankee Atomic Power Company (CYAPCO) is providing the three-year update tci the Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan (DFP). Enclosure 1 updates the Haddam Neck Plant (HNP) ISFSI decommissioning cost estimate and the cost estimate for the management of irradiated fuel and Greater than Class C Waste submitted with the previous HNP 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 HNP 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 ofradioactive 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, CYAPCO 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." CYAPCO has

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Connecticut Yankee Atomic Power Company CY-21-015/December 10, 2021/Page 2 established 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 HNP 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 HNP ISFSI that:

1. Utilizes an independent contractor to perform the decommissioning activities in accordance with 10 CFR 72.30(b)(2)(i);
2. Includes an adequate contingency factor in accordance with 10 CFR 72.30(b)(2)(ii); and
3. Includes the cost of meeting the criteria for unrestricted release in accordance with 10 CFR 72.30(b)(2)(iii).

In addition, the revised HNP 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 HNP ISFSI DCE estimates the total cost to decommission the HNP ISFSI to be $6.9 million in 2021 dollars for radiological decommissioning and $11.5 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 HNP ISFSI, including the key assumptions and the justification for their use.

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

On a periodic basis, CYAPCO 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.

CYAPCO 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, CYAPCO 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.

IO 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

Connecticut Yankee Atomic Power Company CY-21-015/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 ofradiological 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 are anticipated; the activation products will remain fixed during the storage period; and
5. If contamination of subsurface occurs during decommissioning activities, the contamination is expected to remain below the decommissioning criteria of 25 millirem per year Total Effective Dose Equivalent.

In addition, the site will meet the remediation standards established by the State of Connecticut.

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 HNP ISFSI for the management of irradiated fuel and GTCC waste at the HNP ISFSI through 2036.

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

~

Treasurer

Connecticut Yankee Atomic Power Company CY-21-015/December 10, 2021/Page 4

Enclosures:

1. Decommissioning Study of the Connecticut Yankee Independent Spent Fuel Storage Installation
2. Certification of Financial Assurance
3. Total Costs Associated with the HNP ISFSI, including Cost Estimate for Managing Irradiated Fuel and GTCC Waste

Reference:

I. Letter from C. Pizzella (CYAPCO) to Document Control Desk (NRC), Independent Spent Fuel Storage Installation Decommissioning Funding Plan, dated December 10, 2018 (CY-18-021) 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. Semancik, Director, CT DEEP, Radiation Division M. Firsick, CT DEEP, Radiation Division

ENCLOSURE 1 TO CY-21-015 DECOMMISSIONING STUDY OF THE CONNECTICUT YANKEE

\ INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 1 of 12 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 record.keeping 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 Connecticut Yankee (CY) 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 Connecticut Yankee (CY) was successfully decommissioned between 1998 and 2007. During decommissioning all 1,019 spent fuel assemblies were transferred from the spent fuel pool to 40 spent fuel storage casks. In addition, 3 GTCC casks containing segmented sections of the reactor internals are stored on the spent fuel storage pad. There are also two spent fuel transfer casks stored on the pad. The fuel transfer casks are assumed to remain on-site until 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

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page2of 12 decommissioning and the disposition of which is included in this estimate. The ISFSI is operated under a Part 50 General License.

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

3. ISFSI Decommissioning Strategy At the conclusion of the DOE spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC and the State of Connecticut release criteria.
4. ISFSI Description The CY ISFSI is located on approximately 5 acres of the 525 acre site. The ISFSI consists of 40 dry storage casks containing 1,019 spent nuclear fuel assemblies used during operations. The NAC-MPC fuel storage and transport canister system was chosen by CY 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 in 2002. Transferring the spent fuel from the spent fuel pool to the storage casks was completed in March of 2005.

In addition to the 40 spent fuel storage casks there are 3 casks containing segmented sections of the reactor internals classified as Greater than Class C waste. The storage overpacks used for the GTCC canisters are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey. The multi-purpose canisters will be transferred directly to the DOE. After removal of the MPC canisters, the overpacks will be surveyed and any found to have residual radioactivity due to some minor level of neutron-induced activation as a result 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

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 8of 12 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, form the basis of the ISFSI decommissioning estimate.

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

5. Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the assumptions associated with DOE's spent fuel acceptance, as previously described.

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

The decommissioning estimate is based on the premise that the inner steel liners of some of the concrete and steel overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 40 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 decommissioning estimate assumes that some residual contamination may be present within the NAC transfer casks. For purposes of this estimate, the transfer casks are shipped for controlled disposal as low-level radioactive waste.

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

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 4of 12 Decommissionin g 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. CY, 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 local landfill.

  • Remaining Overpacks
  • Fencing
  • Asphalt paving
  • Emergency electrical enclosure
  • Conduit and wire from the SAS to pad
  • Diesel generator
  • Emergency operations facility
  • Power supply (buried) to security alarm station
  • Remove security fence, light towers, access road
  • Remove road inside licensed area
  • Remove vehicle barriers
  • Security alarm station (SAS)
  • Septic system
  • Vehicle barrier 1 (steel)
  • Vehicle barrier 2 (steel)

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

Contingency has been added to the ISFSI Decontaminatio n 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%.

3 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S. Nuclear Regulatory Commission's Office of Federal and State Materials and Environmental Management Programs, NUREG-1757, Volume 3, Revision 1, February 2012 TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment I Connecticut Yankee ISFSI Page 5of 12 The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

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

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

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

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into four phases, including:
  • An initial planning phase - empty overpacks are characterized and the specifications and work procedures for the decontamination (liner removal) developed.
  • The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.
  • The license termination phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.
  • Site restoration - While not required by the NRC this estimate includes the cost to remove and dispose of all non-contaminated structures. A list of all structures included in this estimate is provided in Table 3.

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

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 6of 12 NRC contractor), CY's oversight staff, site security (industrial), and other site operating costs.

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

TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 7of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity ISFSI Pad (dimensions are for current pad) 228 70 No Concrete Paved Road 284 18 No ISFSI Overpack Item Value Notes (all dimensions are nominal)

CY-MPC Overall Heie:ht (inches) 190.6 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) 43 40 spent fuel + 3 GTCC Quantity (with residual radioactivity) Equivalent to the number of DSCs 7

used to store last complete core offload Total Surface Area of overpack interior with Residual Radioactivity (square feet) 2,300 Low-Level Radioactive Waste (cubic feet) 26,372 Low-Level Radioactive Waste (packaged density) 54 Other Potentially Impacted Items Item Value Notes Transfer Casks 2 No residual radioactivity TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 8of 12 Table 2 ISFSI Decommission ing Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Burial Oversight Removal Packaging Transport Other Total Volume Craft and Costs Disposal Costs Costs Costs Costs Class A Manhours Contractor Costs Activity Description (cubic feet) Manhours Decommissioning Contractor Planning (characterization, - - - - 219 219 - - 1,000 specs and procedures)

Decontamination (activated 221 192 . 338 - 750 26,372 28,124 -

liner and concrete removal)

License Termination - - - - 1,117 1,117 - 7,245 .

(radiological surveys)

Subtotal 221 192 - 338 1,336 2,087 26,372 35,370 1,000 Supporting Costs NRC and NRC Contractor Fees . . - - 292 292 - . 1,153 and Costs Insurance - - . - 193 193 - . -

Property taxes - . . - 496 496 - . .

NRCFees . - . . 254 254 . . .

Site O&M Cost . - - - 553 553 . . -

Security Staff Cost - - . . 164 164 - . 11,625 TLG Services, LLC

Connecticu t Yankee Atomic Power Company Attachmen t 1 Connecticu t Yankee ISFSI Page 9of 12 Table 2 (continued )

ISFSI Decommiss ioning Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Burial Oversight Removal Packaging Transport Other Total Volume Craft and Costs Disposal Costs Costs Costs Costs Class A Manhours Contractor Activity Description Costs (cubic feet) Manhours DOC Staff Cost - - - - 522 522 - - 4,787 Utility Staff Cost - - - - 957 957 - - 5,471 Subtotal - - - - 3,431 3,431 - - 12,778 ISFSI Decontamina tion Total (w/o contim?encv) 221 192 - 338 4,768 5,518 26,372 35,370 13,778 ISFSI Decontamina tion 276 -

Total (with 25%

240 422 5,960 6,898 - - -

contingency)

ISFSI Site Restoration Asbestos removal 233 0.2 - 4 - 238 537 1,567 -

Building removal - Inside fence Fencing (linear foot) 8 - - - - 8 - 96 -

Remove asphalt paving 24 - - - - 24 - 216 -

ISFSI Cask & Pad 782 - - - 169 951 - - -

Demolition and Removal Emergency electrical 4 - - - - 4 - 50 enclosure ISFSI support systems 71 - - - - 71 - 908 Building removal - Outside fence Conduit and wire from the SAS to pad 1 - - - - 1 - 5 TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page JO of 12 Table 2 (continued)

ISFSI Decommission ing Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Burial Oversight Removal Packaging Transport Other Total Volume Craft and Costs Disposal Costs Costs Costs Costs Class A Manhours Contractor Activity Descriution Costs (cubic feet) Manhours Diesel Generator 0.3 - - - - 0.3 - 1 Emergency operations 363 - - - - 363 - 2,357 facility Power to the Security alarm 0 - - - - 0 - 2 station Security fence, light towers, 16 - - - - 16 - 141 access road Remove road inside licensed area 15 -* - - - 15 - 71 Remove vehicle barriers 1 - - - - 1 - 4 Security alarm station 17 - - - - 17 - 166 Septic system 0 - - - . 0 . 2 ISFSI support building 37 - . . - 37 - 252 Vehicle barrier 1 (steel) 8 . - - - 8 - 90 Vehicle barrier 2 (steel) 5 - . . . 5 . 54 -

Construction debris - - - - 32 32 - .

Site restoration 6 - . - . 6 - 25 Subtotal 1,593 0.2 - 4 201 1,798 537 6,006 -

Supporting Costs NRC and NRC Contractor - - - . 26 26 - . 160 Fees and Costs TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 11 of 12 Table 2 (continued)

ISFSI Decommission ing Costs and Waste Volumes (Thousands of 2021 Dollars)

LLRW Burial Oversight Removal Packaging Transport Other Total Volume Craft and Costs Costs Disposal Costs Costs Costs Class A Manhours Contractor Activitv Description Costs (cubic feet) Manhours Property taxes . . . . 248 248 . . .

Site O&M Cost . . . . 277 277 . . .

Security Staff Cost . . . . 82 82 . . 5,813 DOC Staff Cost . . . . 261 261 . . 2,393 Utility Staff Cost . . . . 478 478 . . 2,735 Severance . . . . 508 508 . . .

Subtotal - - - - 1,881 1,881 - - 11,101 ISFSI Site Restoration Total (w/o contine:encv) 1,593 0.2 - 4 2,081 3,678 537 6,006 11,101 ISFSI Site Restoration -

Total (with 25%

1,991 0.3 6 2,602 4,598 - - -

continl!'encv)

Total (w/o contingency) 1,813 192 - 342 6,849 9,197 26,909 41,376 24,880 Total (with continl!'encv) 2,266 240 - 428 8,561 11,496 26,909 41,376 24,880 TLG Services, LLC

Connecticut Yankee Atomic Power Company Attachment 1 Connecticut Yankee ISFSI Page 120/ 12 Table 3 ISFSI Decommission ing - Structures Contaminated Removal Transfer Cask Assembly Cask inner liner Cask lid Cask base & misc. Internal fixtures VCC Concrete Clean Removal Non-activated overoacks ISFSI Concrete Pad Remove Fencing Uinear foot)

Remove Asphalt Paving Emergency Electrical Enclosure ISFSI Support systems Conduit and Wire SAS to pad Diesel Generator EOF Power to SAS Remove Security Fence, towers, access road Remove road inside licensed area Remove vehicle barriers SAS Building Septic System Support Building ISFSI Vehicle barrier 1 (steel)

Vehicle barrier 2 (steel)

TLG Services, LLC

ENCLOSURE 2 TO CY-21-015 CERTIFICATION OF FINANCIAL ASSURANCE

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licensee:

Connectic°'t Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC No. DPR-61 (NRC Docket No. 50-213) 362 Injun Hollow Road East Hampton, CT 06424-3099 Issued to: U.S. Nuclear Regulatory Commission Certification:

I hereby certify that Connecticut Yankee Atomic Power Company is the licensee for the Haddam Neck Plant (HNP) Independent Spent Fuel Storage Installation (ISFSI) and that I, the

\ undersigned, am authorized to provide this Certification of Financial Assurance with respect to the radiological decommission1ng of the HNP ISFSI.

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

I further certify that financial assurance in an amount sufficient to fund HNP 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-specific decommissioning cost estimate and funding methodology described therein, in the amount of:

$6.9 million (in 2021 dollars, inclusive of contingency)

Ti C ee Atomic Power Company Treasurer Phone (508) 612-3322 Corporate Seal Date: December 10, 2021

ENCLOSURE 3 TO CY-21-015 TOTAL COSTS ASSOCIATED WITH THE HNP ISFSI, INCLUDING COST ESTIMATE FOR MANAGING IRRADIATED FUEL AND GTCC WASTE

Connecticut Yankee 2022 - 2039 Summary Connecticut YankH Atomk Power Company Spent Fuel Manaprntnt and ISfSI c>>c:om Estimate Represented ln 2022 Ootfars Rowlabtll Summary

~2022 Sum of 2023 Sum of 2024 Sum of 2025 Sum of 2026 Sum of 2027 Sum of 2028 Sum of 20211 Sum or 2030 Sum of 2031 Sum of 2032 Sum or 2033 Sum of 2034 Sum of 2036 Sum of Contln~ency 2038 Sum of 2037 Sum of 2038 Sum of 203Q 2022 - 2039 666,211 674,461 723,635 1191 ,056 655.064 654,136 660,370 710,663 763,645 645,449 778,938 643,242 724,062 647,606 GE Morris 650,542 1,488,994 2 ,605,007 811 ,2 ~ ,194,741 2,067,630 2,067,630 2 ,067,630 2 ,067,630 2,067,630 2 ,067,630 2 ,067,630 2,067,630 2,067,630 2,067,630 2,067,630 2 ,067,630 2.067 ,630 2,067,630 2,067,630 2,067,630 2,067,630 35,149,710 Insurance 602,848 604,937 602,648 602,648 604,937 602,648 602,648 604,837 602,648 602,648 604,937 602,648 602,648 602,648 604,937 602,648 602,648 1,115,690 11 ,372,158 labor - Non-Manual 2,864,520 2 ,693,587 2,653,844 2,800,ase 2 ,632,882 2 ,552,436 2,788,109 2,507,098 2,552,451 2,507,088 2,507,098 2,507,098 2.507,098 2,543,443 2,499,021 2,514,098 2 ,514,098 2,335,565 46,478,201 Labor- Securttv 3,257,594 3,257,594 3,257,594 3,257 , Sg 3,257,59<4 3,257 ,594 3,257,594 3,257,594 3,257,594 3,257,594 3,257,594 3,257,69-1 3,257,594 3,257,594 3,257,594 3,257,594 538,445 538,445 53,198,397 Materials & Supplln 121 ,689 277,838 148,811 123,735 121,689 121,689 285,376 132,458 121 ,689 121,689 2 ,993,756 267,069 121 ,689 121 ,689 121,889 121 ,689 3, 076 26,822 5,394,037 Miscellaneous 188,841 165,303 165,303 186,841 167,995 167,995 189,533 167,995 167,995 189,533 167,995 167,995 167,995 167,995 167,995 167,995 167,995 65,960 2,997,256 OUtside Services - A&G 731 ,006 769,774 756,852 698,700 698,700 698,700 737,468 756,852 698,700 698,700 898,700 737,468 698,700 877,182 677,162 6TT,162 677,162 677,162 12,766,125 Outside SeMCfl - Fuef loadinQ Outside Services - IAGE 2,315,315 2 ,055,784 4,371 ,099 94,704 152,669 852,648 208,513 152,669 206,513 152,669 852,648 206,513 152,669 152,669 152,869 852,648 206,513 152,669 152,669 n ,286 77,286 4,854,621 Outside Services - ISFSI OP's 492,139 325,221 527,676 1,132,889 492,139 360,758 492,139 325,221 2,681 ,458 325,221 492,139 360,758 492,139 325,221 825,914 253,069 147,534 45,768 10,097,404 Outside Services - Lei;al 430,756 699,979 161 ,534 268,223 430,756 572,098 161,534 269,223 430,756 511 ,523 181 ,534 269,223 430,756 511 ,523 161 ,534 268,223 430,756 1,238,424 7,410,354 Outside Sel'Vlcn - LIFT 807,668 607,668 807,668 807,668 3,230,672 Outside Services - NON-RAO O&O of ISFSI Outside Services - RAO O&O of 1SFSI 3,934,719 3,93-4,719 Property T:axn 4,943,003 4,943,063 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1,548,569 1.548,569 1,548,569 1,548,569 774,284 27,099,853 Regulatory Fees 791 ,515 791 ,515 791,515 791 ,515 791 ,515 791 ,515 791 ,515 791 ,515 791 ,515 791 ,515 781 ,515 791 ,515 791,515 791,515 791 ,515 607,668 721 ,517 274,607 13,878,511 Utilities 13 611 13 611 134,611 134,611 134611 134611 134,611 1J.4_.§_11_ _ 134L611 134 611 134611 134,..611~ 11 134~U 134l611~ 1 ~ 134,611 2 23 004 Grand Total 13,990,433 14,163,1187 15,200,536 14,512,179 13,75&,7159 13,736,894 13,867,764 14,923,911 16,036,5'13 13,554,448 18,357,1183 1uoa,osa 15.205,321 13,IS03,918

{B)

  • Source 2019 FERC, Eacalated In 2022 $ 13,861,380 18,378,933 23,200,000 8,923,832 264,502,021 Note 1: The cost of management of irradiated fuel and GTCC waste Is calculated as follows:

$ 264,592,021 Grand Total from Above

$ (3,934,719) Non-Rad D&D ISFSI

$ (4 943 063) Rad D&D ISFSI

$ 255,714,239 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 dertved by escalating the value of the 2021 cost estimates provided in Enclosure 1 by 2.5%.

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

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