L-19-059, Stations - Irradiated Fuel Management Plans

Stations - Irradiated Fuel Management Plans

ML19074A244
Person / Time
Site:	Beaver Valley, Davis Besse, Perry, 07201043, 07200040, 07200069
Issue date:	03/15/2019
From:	Benyak D FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
L-19-059
Download: ML19074A244 (56)

Text

FENOG 341 Vfhite Pond Dr.

Akron, Ohio 44320 HEt E reg/ rtrclar @dilng futnprry March 15, 2019 L-19-059 10 cFR 50.54(bb) 10 cFR 72.218 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Beaver Valley Power Station, Unit Nos. 1 and 2, ISFSI Docket No. 72-1043 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI Docket No. 72-14 Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant, Unit No. 1 ISFSI Docket No. 72-69 lrradiated Fuel Manaoement Plans By letter dated April 25, 2018 (Accession No. ML181154007) FirstEnergy Solutions Corp. (FES), the parent of FirstEnergy Nuclear Generation, LLC (FENGen), notified the Nuclear Regulatory Commission (NRC) of the intention to permanently cease operation of the four FENGen reactors over the next three years. The first unit scheduled for shutdown is Davis-Besse Nuclear Power Station (DBNPS) by May 31,2020, followed by Perry Nuclear Power Plant (PNPP) and Beaver Valley Power Station, Unit No. 1 (BVPS-1) by May 31,2421, and BeaverValley PowerStation, Unit No.2 (BVPS-2) by October 31,2021.

Therefore, pursuant to 10 CFR 50.54(bb), FirstEnergy Nuclear Operating Company (FENOC) hereby submits the attached lrradiated Fuel Management Plans for the FENGen facilities listed above for review and preliminary approval.

Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station lndependent Spent Fuel Storage Installation Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station lndependent Spent Fuel Storage lnstallation Perry Nuclear Power PIant, Unit No. 1 Perry Nuclear Power Plant lndependent Spent Fuel Storage lnstallation L-19-059 Page 2 The lrradiated Fuel Management Plans are based, in part, on decommissioning cost estimates (DCEs), which include elements associated with spent fuel management. The DCEs for the four FENGen facilities were prepared in 2018.

By letter dated March 15, 2019, FENOC submitted to the NRC the decommissioning trust fund financial status report for the four FENGen facilities in accordance with 10 CFR 50.75(0(1). Enclosures in that letter included the DCEs for BVPS 1 and 2, DBNPS, and PNPP.

The DCEs assume that each nuclear unit is placed and maintained in a condition that allows it to be safely stored and subsequently decontaminated. This approach for decommissioning is known as SAFSTOR. FENOC has not made a final determination on the decommissioning approach for any of the listed nuclear units. FENOC may select a different decommissioning option in the future for any of the listed nuclear units, recognizing that the chosen option must meet NRC requirements for decommissioning funding.

There are no regulatory commitments contained in this letter. lf there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager, Nuclear Licensing and Regulatory Affairs, at (330) 315-6810.

Sincerely,

\a/^/nlt4B*1 Darin M. Benyak Vice President, Nuclear Support and Regulatory Affairs Attachments:

1. Beaver Valley Power Station, Unit No. 1 Irradiated Fuel Management Plan

2. Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management PIan

3. Davis-Besse Nuclear Power Station, Unit No. 1 lrradiated Fuel Management Plan

4. Perry Nuclear Power Plant, Unit No. 1 lrradiated Fuel Management Plan

Beaver Valley Power Station, Unit Nos. 1 and 2 Beaver Valley Power Station lndependent Spent Fuel Storage Installation Davis-Besse Nuclear Power Station, Unit No. 1 Davis-Besse Nuclear Power Station lndependent Spent Fuel Storage Installation Perry Nuclear Power Plant, Unit No. 1 Perry Nuclear Power Plant lndependent Spent Fuel Storage lnstallation L-19-059 Page 3 cc: NRC Region I Administrator NRC Region lll Administrator NRC Project Manager - FENOC FIeet NRC Resident lnspector - Beaver Valley Power Station NRC Resident lnspector - Davis-Besse Nuclear Power Station NRC Resident lnspector - Perry Nuclear Power Plant Director BRP/DEP Site Representative BRP/DEP Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

Attachment 1 L-19-059 Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan (Eleven pages follow)

Attachment 1 L-19-059 Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan Page1of11 Backqround 10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Beaver Valley Power Station, Unit No. 1 lrradiated Fuel Management Plan (IFMP), described herein, is based, in part, on a decommissioning cost estimate (DCE) that was prepared in 2018 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 , BVPS-2, or collectively, BVPS), which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the BVPS-1 IFMP, along with license termination and site restoration activities and costs.

Pursuant to 10 CFR 50.75(f)(1) on March 15,2019, FENOC submitted its decommissioning trust financial status report for the four FENOc-operated nuclear facilities. Enclosure A of that report is a copy of the BVPS DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from BVPS.

As stated in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), this IFMP is based on the assumption that BVPS-1 shuts down by May 31,2021. This IFMP presumes the DOE will commence acceptance of BVPS-1's spent fuel in 2029 and completes removal of spent fuel from the site by 2060 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.

1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.

However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2029 from BVPS-1 and in accordance with spent fuel shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purposes other than for this submission. Such other purposes would include, but are not limited to, disputes regarding DOE's legal or contractual acceptance obligations, or damages claims for recovery of incurred costs.

L-19-059 Page 2 of 11 Soent Fuel Man aqement Strateov FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercial nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that starts operation in 2025. The DCE assumes that BVPS-1 will shutdown and cease operations in 2021 and that BVPS-1 spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, BVPS-1 fuel would be accepted at the DOE storage facility starting in 2029.

The spent fuel pool will contain discharged fuel from the previous refueling cycles, as well as the final reactor core at shutdown. lmmediately after shutdown, spent fuel will be located in the spent fuel pool and in canisters located on an independent spent fuel storage installation (lSFSl). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFSI for interim storage. This period provides the necessary cooling time for the spent fuel to meet the decay heat requirements for placement in dry storage.

The current BVPS dry fuel storage system consists of a Transnuclear Standardized NUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). There are ten modules currently on the ISFSI pad with 37-assembly capacifi DSCs. A Holtec HI-STORM FW system, with a 37-fuel assembly capacity Multi-Purpose Canister (MPC) and concrete shield overpack is expected to be used following shutdown.

The DSCs and MPCs are assumed to be transferred directly to the DOE.

FENOC has constructed an ISFSI at BVPS to support BVPS-1 and BVPS-2 operations. The ISFSI operates under a general license pursuant to 10 CFR 72.210. The current size of the ISFSI pad is approximately 300 feet by 90 feet. The ISFSI will require expansion once plant operations cease in order to support spent fuel management activities. The pad expansion will be 120 feet by 90 feet. Total capacity of the consolidated pad is expected to be 88 DSCs and MPCs holding spent fuel and 6 MPCs holding greater than Class C waste. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. The DCE assumes that the BVPS spent fuel will be transferred to the DOE by 2060.

Table 1 provides a listing of the location of the spent fuel from 2019 until the spent fuel has been accepted by the DOE.

L-19-059 Page 3 of 11 Table 1 - Spent Fuel Management Schedule (BVPS-1 Fuel Assembly Location)l Year BVPS-1 BVPS-1 DOE Acceptance Pool lnventory ISFSI lnventory of BVPS-1 Fuel 201 g 1,252 370 0 2020 1,252 370 0 2021 1,409 370 0 2022 1,409 370 0 2023 1,409 370 0 2024 1,409 370 0 2025 706 1,073 0 2426 0 1,779 0 2027 0 1,779 0 2028 0 1,779 0 202s 0 1,763 16 2030 0 1,710 53 2031 0 1,657 53 2032 0 1,512 145 2033 0 1,439 73 2034 0 1,369 70 2035 0 1,369 0 2036 0 1,324 45 2437 0 1,263 61 2038 0 1 ,190 73 2039 0 1,117 73 2040 0 1,054 63 2041 0 1,054 0 2042 0 985 69 2043 0 924 61 2044 0 846 78 2045 0 789 57 2046 0 728 61 2047 0 659 69 2048 0 659 0 2049 0 554 105 2050 0 534 20 205 1 0 469 65

?052 0 412 57 2053 0 355 57 2054 0 298 57 2055 0 241 57 L-19-059 Page4of11 Table 1 (continued)

Year BVPS.1 BVPS.1 DOE Acceptance Pool lnventory !SFSI !nventory of BVPS-1 Fuel 2056 0 184 57 2057 0 127 57 2058 0 70 57 2059 0 13 57 2060 0 0 13 Total 1,779 Note:

1 . Fuel location is as of the date of the submittal. It is assumed that no fuel is transferred from the spent fuel pool to the ISFSI until 2025.

Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel management activity, its cost, and the approximate duration of the activity. The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.

Table 2 - Spent Fuel Management Activities Decommissioning Costs Start Date Stop Date Approximate Period (thousands, Duration 201 I (years) dollars)1 1 - Preparations 3,848 Mav 2021 December 2022 1.5 2a - Dormancy 125,892 December August 2026 3.7 with Wet Fuel 2022 Storage 2b - Dormancy 105,808 August 2026 January 2061 34.4 with Dry Fuel Storage Total 235,548 Note:

1. The values were obtained from the BVPS DCE, which were reported in 2014 dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differ from those in Table 3 due to the way the values in both tables were calculated.

L-19-059 Page5of11 Decommissioning Period 1 - Preparations During this period, the facility is placed in a condition that allows the spentfuel to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to levels that permit release for unrestricted use.

The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fuel storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage, Decommissioning Period 2a - Dormancy with Wet Fuel Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the remaining BVPS-1 spent fuel from the spent fuel poo! to dry storage in 2025 and to complete the transfer of fuel to the consolidated ISFSI in 2026.

Decommissioning Period 2b - Dormancy with Dry Fuel Storage During this period, spentfuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the BVPS DCE, the IFMP assumes that the DOE will begin removing fuel from BVPS-1 in 2029 and will complete the removal of spent fuel from the site in 2060, according to the schedule set forth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be performed as required. BVPS-1 will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the ISFS! and spent fuel.

Cost Estimate The BVPS DCE provides the basis for the costs associated with spent fuel management.

The DCE includes the cost of operating and maintaining the spent fue! pool and the lSFSl. Poo! operations are expected to continue approximately 5 years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 39-year period of operation following plant shutdown. The cost for L-19-059 Page6of11 the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the spent fuel poo! is also included. Costs for transferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete.

Table 3 provides an expenditure summary for the BVPS-1 IFMP in 2018 dollars.

Table 3 - IFMP Expenditure Summary Expenditure Year (thousands, 201 I dollars) 2021 1,838 2422 4,736 2023 32,844 2424 32,934 2425 32,844 2026 21,034 2027 2,487 2028 7,110 2029 2,799 2030 3,389 2031 3,389 2032 3,696 2033 3,088 2034 2,487 2036 3,095 2037 3,088 2038 3,088 2039 3,389 2040 2,794 2041 3,099 2042 3,098 2043 2,788 2044 2,794 L-19-059 Page 7 of 11 Table 3 (continued)

Expenditure Year (thousands, 2018 dollars) 2045 2,788 2046 2,788 2047 2,788 2048 2,794 2049 2,788 2050 2,788 2051 2,788 2052 2,794 2053 2,799 2054 2,788 2055 2,788 2056 2,794 2057 2,788 2058 3,088 2059 2,788 2060 2,794 Total 229,892 Funding FENGen is the owner of BVPS, Davis-Besse Nuclear Power Station (DBNPS),

and Perry Nuclear Power Plant (PNPP). As such, the BVPS-1 funding mechanisms take into account the need to fund spent fuel management for the other FENGen facilities.

The funding for BVPS-1 spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2021 to 2026. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Period 2b funding covers the period from 2027 to 2060. This correlates to long-term storage of spent fuel on the ISFSI pad until the fuel is transferred to the DOE.

L-19-059 Page8of11 Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and 2a funding, which includes ISFS!

activities and the transfer of spent fuel from the spent fuel pools to the ISFSI, for BVPS-1 , BVPS-2, DBNPS, and PNPP is approximately $620 million dollars.

FENGen intends to fund this obligation through a combination of a cash deposit of $475 million paid into a provisional trust coupled with funds in excess of those needed for license termination contained in the DBNPS and BVPS-2 nuclear decommissioning trusts (NDTs). To use the excess funds in the NDTs, exemptions from 10 CFR 50.82(aXBXIXA) for DBNPS and BVPS-2 will be required. These funds wil! be limited to use only for the management of spent fuel at DBNPS and BVPS-2, respectively. ln addition, FENGen expects to recover its costs by making claims for damages resulting from the DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) for BVPS-1 . lt also expects that by no later than January 1,2027, it will be able to obtain a settlement agreement to recover costs annually. Therefore, FENGen has focused on planning to fund the expected costs through 2026 (that is, Periods 1 and 2a).

As provided in Exhibit D, "Financial Projections," of the "Disclosure Statement for the First Amended Joint Plan of Reorganization of FirstEnergy Solutions, Corp., et al., Pursuantto Chapter 11 of the Bankruptcy Code," submitted to the United States Bankruptcy Court on March 9, 2019, the reorganized debtors are expected to have nearly $2 billion in assets upon emergence from bankruptcy, including approximately $1.56 billion in cash and cash equivalents. FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's four units by paying the approximately $2.1 million forthe 2020 DBNPS spent fuel expenditures and by placement of $475 million into a provisional trust by the end of 2021. The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a.

Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.

FENGen will withdraw money from the $475 million provisional trust to pay the BVPS-1 Periods 1 and 2a spent fuel expenditures. Table 4 provides a summary of the FENGen use of the $475 million provisional trust. The expenditures came from the respective site-specific DCEs that were developed in 2018.

L-19-059 Page9of11 Table 4 - Periods 1 and 2a Spent Fuel Expenditures (thousands, 2018 dollars)

Year BVPS.1 BVPS-2 DBNPS PNPP Total Trust Payments Payments Payments Payments FENGen Value Payments lnitial 475,000 Value 2021 1,838 530 5,567 2,151 10,096 464,914 2022 4,736 2,943 31,1721 7,059 45,810 419,104 2023 32,844 24,672 02 54,510 112,026 307,078 2024 32,934 36,556 02 54,659 124,149 182,929 2025 32,844 36,456 02 54,510 123,810 59,1 1 I 2026 21,034 1 ,4563 34,902 57,392 1,727 Totals 126,230 102,513 36,739 207,791 473,273 Notes:

1. For DBNPS, the listed partial payment is associated with the provisional trust. However, money from excess funds in the NDT will be used to make the full 2022 payment based upon the December 31, 2018 NDT values. An exemption from 10 CFR 50.82(aXBXlXA) will be made in orderto usefunds from the NDT.

2. For DBNPS these payments will be made from excess funds in the NDT by use of exemptions from 10 CFR 50.82(aXBXIXA)

3. For BVPS-2 the listed partial payment is associated with the provisional trust However, money from excess funds in the NDT will be used to make the full 2026 payment based upon the December 31, 2018 NDT values. An exemption from 10 CFR 50.82(aXBXIXA) will be made in order to use funds from the NDT.

The BVPS-1 Periods 1 and 2a costs will be fully paid for by funds withdrawn from ttre $475 million provisional trust, Period 2b Funding As described in the BVPS DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2A26. The spent fuel is assumed to remain on the ISFSI pad between 2427 and 2060, when the last of the spent fuel is transferred to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFS! pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partial breach of the DOE Standard Contract.

Atrachment 1 L-19-059 Page 10 of 1 1 FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017, FENGen has recovered more than $193 million from the DOE. However, this settlement expires December 31 ,2019, and FENGen may need to litigate with the DOE in order to obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with DOE to obtain recovery of dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the earlier expenses.

As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once adequate funds are set aside to fund the remaining annual spent fuel management expenses pending recovery from the DOE under a settlement, the purpose of the provisional trust will have been satisfied, and the provisional trust can be terminated. lnstead, FENGen will rely upon funds set aside in the segregated account.

The plan for BVPS-1 Period 2b funding process is to retain approximately $9.3 million in the segregated account for BVPS-1. The intent is to pay for the annual ISFSI activities, then apply for recovery of the expenses from the DOE, as needed.

lf FENGen is unable to obtain a settlement with DOE by the end of 2026, FENGen will obtain a performance bond for approximately $9.3 million (approximately 1.3 times the highest one-year value of ISFSI maintenance expenses). lf needed, the bond will be in place by the end of 2026. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.

ISFSI Decommissioning Fundinq Once the ISFSI pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2083. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17, 2018 (Accession No. ML183514161) states that sufficient funding is available for ISFSI decommissioning. At this time, no additional monies are required.

Adiustments to Fundins Pursuantto 10 CFR 50.75(0(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuant to 10 CFR 50.54(bb), FENOC is required to report to the NRC any L-19-059 Page11of11 significant changes to the IFMP. Since this IFMP includes funding mechanisms and values, significant changes to the funding mechanisms and values will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT or the FENGen provisional trust used to support the IFMP.

Attachment 2 L-19-059 Beaver Valley Power Station, Unit No. 2 Irradiated Fuel Management Plan (Thirteen pages follow)

Attachment 2 L-19-059 Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan Page 1 of 13

Background

10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Beaver Valley Power Station, Unit No. 2 lrradiated Fuel Management Plan (!FMP), described herein, is based, in part, on a decommissioning cost estimate (DCE) thatwas prepared in 2018 for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1, BVPS-2, or collectively, BVPS), which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the BVPS-2 IFMP, along with license termination and site restoration activities and costs.

Pursuant to 10 CFR 50.75(0(1) on March 15, 2019, FENOC submitted its decommissioning trust financial status report for the four FENOc-operated nuclear facilities. Enclosure A of that report is a copy of the BVPS DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from BVPS.

As stated in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the IFMP is based on the assumption that BVPS-2 shuts down by October 31 ,2021. This IFMP presumes the DOE will commence acceptance of BVPS-2's spent fuel in 2034 and completes removal of spent fuel from the site by 2060 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.

1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.

However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2034 from BVPS-Z and in accordance with spent fuel shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purposes other than for this submission. Such other purposes would include, but are not limited to, disputes regarding DOE's Iegal or contractual acceptance obligations, or damages claims for recovery of incurred costs.

L-19-059 Page 2 of 13 Spent Fuel Management Strategv FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercial nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that stafts operation in 2025. The DCE assumes that BVPS-2 will shutdown and cease operations tn 2021 and that BVPS-2 spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, BVPS-2 fuel would be accepted at the DOE storage facility starting in 2034.

The spent fuel pool will contain discharged fuel from the previous refueling cycles, as well as the fina! reactor core at shutdown. Immediately after shutdown, spent fuel will be located in the spent fuel pool and in canisters located on an independent spent fuel storage installation (!SFSI). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFSI for interim storage. This period provides the necessary cooling time for the spent fue! to meet the decay heat requirements for placement in dry storage.

The current BVPS dry fuel storage system consists of a Transnuclear Standardized NUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). There are ten modules currently on the ISFSI pad with 37-assembly capacity DSCs. A Holtec HI-STORM FW system, with a 37-fuel assembly capacity Multi-Purpose Canister (MPC) and concrete shield overpack, is expected to be used following shutdown.

The DSCs and MPCs are assumed to be transferred directly to the DOE.

FENOC has constructed an ISFSI at BVPS to support BVPS-1 and BVPS-2 operations. The ISFSI operates under a general license pursuant to 10 CFR 72.210. The current size of the ISFSI pad is approximately 300 feet by 90 feet. The ISFSI will require expansion once plant operations cease in order to support spentfuel management activities. The pad expansion will be 120 feet by 90 feet. Total capacity of the consolidated pad is expected to be 88 DSCs and MPCs holding spent fuel and 6 MPCs holding greater than CIass C waste. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. The DCE assumes that the BVPS spent fuel will be transferred to the DOE by 2060.

Table 1 provides a listing of the location of the spentfuel from 2019 until the spent fuel has been accepted by the DOE.

L-19-059 Page 3 of 13 Table 1 - Spent Fuel Management Schedule (BVPS-2 Fuel Assembly Location)1 Year BVPS.2 BVPS-2 DOE Acceptance Pool lnventory ISFSI lnventory of BVPS-2 Fuel 201 I 1,257 0 0 2020 1,317 0 0 2021 1,474 0 0 2A22 1,474 0 0 2023 1,474 0 0 2024 1,474 0 0 2025 1 ,104 370 0 2026 0 1,474 0 2027 0 1,474 0 2028 0 1,474 0 2029 0 1,474 0 2030 0 1,474 0 2031 0 1,474 0 2032 0 1,474 0 2033 0 1,474 0 2034 0 1,421 53 2035 0 1 ,352 69 2036 0 1,297 65 2037 0 1 ,216 71 2038 0 1,147 69 2039 0 1,085 62 2040 0 1,085 0 2041 0 1,021 64 2042 0 960 61 2043 0 895 65 2044 0 834 61 2045 0 834 0 2046 0 773 61 2047 0 713 60 2048 0 655 58 2049 0 594 61 2050 0 529 6s 2051 0 472 57 2052 0 415 57 2053 0 358 57 2054 0 301 57 2055 0 244 57 2056 0 187 57 L-19-059 Page 4 of 13 Table 1 (continued)

Year BVPS.2 BVPS-2 DOE Acceptance Pool lnventory !SFSI Inventory of BVPS- Fuel 2057 0 130 57 2058 0 73 57 2059 0 16 57 2060 0 0 16 Total 1,474 Note:

1 . Fuel location is as of the date of the submittal. lt is assumed that no fuel is transferred from the spent fuel pool to the ISFSI until 2025.

Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel program activity, its cost, and the approximate duration of the activity.

The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.

Table 2 - Spent Fuel Management Activities Decommissioning Costs Start Date Stop Date Approximate Period (thousands, Duration 201 I (years) dollars)1 1 - Preparations 3,846 October 2021 Mav 2023 1.5 2a - Dormancy 139,932 May 2023 January 2027 3.7 with Wet Fuel Storaqe 2b - Dormancy 1 00,1 57 January 2027 January 2061 34 with Dry Fuel Storage Total 243,935 Notes:

1. The values were obtained from the BVPS DCE, which were reported in zAM dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differ from those in Table 3 due to the way the values in both tables were calculated.

L-19-059 Page 5 of 13 Decommissioning Period 1 - Preparations During this period, the facility is placed in a condition that allows the spentfuel to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to levels that permit release for unrestricted use.

The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fue! storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage.

Decommissioning Period 2a - Dormancy with Wet Fue! Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the remaining BVPS-2 spent fuel from the spent fuel pool to dry storage in 2025 and to complete the transfer of fuel to the consolidated ISFSI in 2026.

Decommissioning Period 2b - Dormancy with Dry Fuel Storage During this period, spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the BVPS DCE, the IFMP assumes that the DOE will begin removing fuel from BVPS-2 in 2034 and will complete the removal of spent fuel from the site in 2060, according to the schedule set forth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be performed as required. BVPS-2 will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the ISFSI and spent fuel.

Cost Estimate The BVPS DCE provides the basis for the costs associated with spent fuel management.

The DCE includes the cost of operating and maintaining the spent fuel pool and the lSFSl. Pool operations are expected to continue approximately 5 years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 39-year period of operation following plant shutdown. The cost for L-19-059 Page 6 of 13 the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the spent fuel pool is also included. Costs for transferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete.

Table 3 provides an expenditure summaryforthe BVPS-2 IFMP in 2018 dollars.

Table 3 - IFMP Expenditure Summary Expenditure Year (thousands, 201 I dollars) 2021 530 2022 2,843 2023 24,672 2024 36,556 2025 36,456 2026 36,456 2027 3,592 2028 2,578 2029 2,571 2030 2,571 2031 2,571 2032 2,578 2033 2,571 2034 2,872 2036 3,1 79 2037 3,172 2038 3,172 2039 3,172 2040 2,578 2041 3,172 2042 3,172 2043 3,172 2044 3,1 79 L-19-059 Page 7 of 13 Table 3 (continued)

Expenditure Year (thousands, 2018 dollars) 2045 2,872 2046 2,872 2047 2,872 2048 2,879 2049 2,872 2050 2,872 2051 2,872 2052 3,1 79 2053 2,872 2054 3,172 2055 2,872 2056 3,1 79 2057 2,872 20s8 3,172 2059 2.872 2060 3,1 79 Total 238,037 Fundins FENGen is the owner of BVPS, Davis-Besse Nuclear Power Station (DBNPS),

and Perry Nuclear Power Plant (PNPP). As such, the BVPS-2 funding mechanisms take into account the need to fund spent fuel management for the other FENGen facilities.

The funding for BVPS-2 spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2021 to 2026. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Period 2b funding covers the period from 2027 to 2060. This correlates to long-term storage of spent fuel on the ISFSI pad until the fuel is transferred to the DOE.

L-19-059 Page I of 13 Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and 2a funding, which includes ISFSI activities and the transfer of spent fuel from the spent fuel pools to the lSFSl, for BVPS-1, BVPS-2, DBNPS, and PNPP is approximately $620 million dollars. FENGen intends to fund this obligation through a combination of a cash deposit of $475 million paid into a provisional trust coupled with funds in excess of those needed for license termination contained in the DBNPS and BVPS-2 nuclear decommissioning trusts (NDTs).

To use the excess funds in the NDTs, exemptions from 10 CFR 50.82(aXBXiXA) for DBNPS and BVPS-2 will be required. These funds will be limited to use only for the management of spent fuel at DBNPS and BVPS-2, respectively. !n addition, FENGen expects to recover its costs by making claims for damages resulting from the DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) for BVPS-2. lt also expects that by no later than January 1,2027, it will be able to obtain a settlement agreement to recover costs annually Therefore, FENGen has focused on planning to fund the expected costs through 2A26 (that is, Periods 1 and 2a).

As provided in Exhibit D, "Financial Projections," of the "Disclosure Statement for the FirstAmended Joint Plan of Reorganization of FirstEnergy Solutions, Corp., et al.,

Pursuant to Chapter 1 1 of the Bankruptcy Code," submitted to the United States Bankruptcy Court on March 9, 2019, the reorganized debtors are expected to have nearly $2 billion in assets upon emergence from bankruptcy, including approximately

$1.56 billion in cash and cash equivalents. FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's four units by paying the approximately $2.1 million for the 2020 DBNPS spent fuel expenditures and by placement of $475 million into a provisional trust by the end of 2021. The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a. Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.

FENGen will withdraw money from the $475 million provisional trust to pay the BVPS-2 Phase 1 and 2a spent fuel expenditures between 2021 and 2025. A withdrawa! from this trust will also be made to provide a partial payment in 2026.

To fully satisfy the 2026 spent fuel expenditure, FENGen intends to use excess funds in the BVPS-2 NDT.

L-19-059 Page I of 13 Table 4 provides a summary of the FENGen use of the $475 million provisional trust. The expenditures came from the respective facility DCEs that were developed in 2018. Table 5 provides a BVPS-2 NDTfunding analysis that includes the license termination expenditures and the partial 2026 spent fuel expenditure.

The analysis indicates that a positive balance remains in the NDT after the withdrawa! for the spent fuel expenditure.

ln order to withdraw funds from the NDT for use to pay for expenditures other than license termination activities, an exemption from 10 CFR 50.82(aXBXiXA) is required to be made and approved by the NRC prior to the withdrawal. The exemption request will be made in advance of when the withdrawal is needed in 2026.

rabre + - reriffiHffi:erlp:,H:r Expenditures Year BVPS-1 BVPS-2 DBNPS PNPP Total Trust Payments Payments Payments Payments FENGen Value Payments lnitial 475,000 Value 2021 1,838 530 5,567 2,151 10,086 464,914 2022 4,736 2,843 31,1721 7,059 45,810 419,104 2023 32,844 24,672 02 54,510 112,026 307,078 2024 32,934 36,556 02 54,659 124,149 182,929 2025 32,844 36,456 gz 54,510 123,810 59,1 1 I 2026 21,034 1 ,4563 34,902 57,392 1,727 Totals 126,230 102,513 36,739 207,791 473,273 Notes:

1. For DBNPS, the listed partial payment is associated with the provisional trust. However, money from excess funds in the NDT will be used to make the full 2022 payment based upon the December 31, 2018 NDT values. An exemption from 10 CFR 50.82(aXBXiXA) wil! be made in orderto usefunds from the NDT.

2. For DBNPS these payments will be made from excess funds in the NDT by use of exemptions from 10 CFR 50.82(aXBXIXA).

3. For BVPS-2 the listed partial payment is associated with the provisional trust.

However, money from excess funds in the NDT will be used to make the full 2026 payment based upon the December 31, 2018 NDT values. An exemption from 10 CFR 50.82(aXBXlXA) will be made in order to use funds from the NDT.

Attachment 2 L-19-059 Page 10 of 13 Table 5 - Nuclear Decommissioning Trust Funding Analysis1,2,3,4 Year Beginning Deposits Earnings License Spent Fuel Ending Balance Termination Withdrawal Balance Withdrawal 201 I 383,221 ,237 383,221,237 201 I 383,221,237 7,664,425 390,885,661 2020 390,885,661 7 ,817 ,713 398,703,375 2021 398,703,375 7,805,084 (8,449,180) 398,059,278 2022 398,059,278 6,861,401 (54,989,230) 349,931 ,449 2023 349,931 ,449 6,319,566 (33,953,155) 322,297,860 2024 322,297,860 6,359,823 (4,306,701) 324,350,982 2025 324,350,982 6,401 ,121 (4,294,934) 326,457,169 2026 326,457,169 5,743,245 (4,294,934) (35,000,000) 292,905,479 2027 292,905,479 5,776,903 (4,060,320) 294,622,063 2028 294,622,063 5,81 1 ,159 (4,064,1 33) 296,369,088 2029 296,369,088 5,846,321 (4,053,030) 298,162.379 2030 298, 1 62,379 5,882,187 (4,053,030) 299,991,536 2031 299,991,536 5,918,770 (4,053,030) 301,857,277 2032 301,857,277 5,955,863 (4,064,133) 303,749,006 2033 303,749,006 5,993,920 (4,053,030) 305,689,896 2034 305,689,896 6,A32,737 (4,053,030) 307,669,603 203s 307,669,603 6,072,331 (4,053,030) 309,688,905 2036 309,688,905 6,1 12,495 (4,064,133) 311,737,267 2037 311,737,267 6,153,685 (4,053,030) 313,837 ,922 2038 313,837 ,922 6,195,698 (4,053,030) 315,980,590 2039 315,980,590 6,238,551 (4,053,030) 31 8,1 66,1 1 1 2040 31 8,1 66,1 11 6,282,040 (4,064,133) 320,384,017 2041 320,384,017 6,326,620 (4,053,030) 322,657,607 2042 322,657,607 6,372,092 (4,053,030) 324,976,669 2043 324,976,669 6,418,473 (4,053,030) 327.342,112 2044 327,342,112 6,465,560 (4,064,133) 329,743,538 2045 329,743,538 6,513,810 (4,053,030) 332,204318 2046 332,204,318 6,563,026 (4,053,030) 334,71 4,314 2047 334,714,314 6,613,226 (4,053,030) 337 ,274,510 2048 337 ,274,510 6,664,209 (4,064,133) 339,874,584 2049 339,874,584 6,716.431 (4,053,030) 342,537,986 2050 342,537,986 6,769,699 (4,053,030) 345,254,655 205 1 345,254,655 6,824,032 (4,053,030) 348,025,657 2052 348,025,657 6,879,230 (4,064,133) 350,840.755 2053 350,840,755 6,935,754 (4,053,030) 353,723,479

Attachment 2 L-19-059 Page 11 of13 Table 5 (continued)

Year Beginning Deposits Earnings License Spent Fuel Ending Balance Termination Withdrawal Balance Withdrawal 2054 353,723,479 6,993,409 (4,053,030) 356,663,959 2055 356,663,858 7,052,217 (4,053,030) 359,663,045 2056 359,663,045 7 ,111,979 (4,064,133) 362,710,890 2057 362,710,890 7,173,157 (4,053,030) 365,831 ,017 2058 365,831 ,017 7,235,560 (4,053,030) 369,013,547 2059 369,01 3,547 7,299,214 (4,053,030) 372,259,728 2060 372,259,728 7,363,912 (4,064,133) 375,559,506 2061 375,559,506 7,428,725 (4,123,257\ 378,964,974 2062 378,864,974 7,494,834 (4j23,257\ 382,236,551 2063 382,236,551 7,562,266 (4,123,257\ 385,675,559 2064 385,675,559 7,630,820 (4,134,553) 389,171,827 2065 389, 171 ,827 7,700,971 (4,123,257) 392,749,541 2066 392,749,541 7,772,526 (4,123,257\ 396,398.809 2067 396,398,809 7,845,511 (4,123,257\ 400,1 21 ,063 2068 400,121,063 7,919,730 (4,134,553) 403,906,240 2069 403,906,240 7,995,660 (4,123,257) 407,778,642 2070 407,778,642 8,073,108 @j23,257\ 411,728,493 2071 411,728,493 8,1 52,1 05 (4,123,257) 415,757,340 2072 415,757,340 8,232,456 (4,134,553) 419,855 ,243 2073 419,855 ,243 8,314,640 (4,123,257\ 424,046,625 2074 424,046,625 8,398,467 (4,123,257\ 428,321,935 2075 428.321.835 7,922,730 (32,185,347) 404,059,219 2076 404,059,219 6,291 ,245 (89,496,954) 320,953,509 2077 320,853,509 4,122,035 (114,751,744\ 210,223,901 2078 210,223,801 2,793,786 (70,534,493) 142,493,095 2079 142,493,095 1,438,972 (70,534,493) 73,387,574 2080 73,387,574 299,832 (58,395,962) 15,291 .445 2081 15,291 ,445 19,666 (14,358,152) 951,959

?082 951,959 17,937 (55,104) 914,792 2083 914,792 17,912 (19,173) 913,531 2084 913,531 18,271 931,802 N otes 1 The analysis is based upon the SAFSTOR approach to decommissioning.

2 The analysis was performed for constant 2018 dollars.

3 A two percent after-tax real rate of return was used in the analysis.

4 Analysis is based upon the December 31, 2018 NDT balance.

L-19-059 Page 12 of 13 Period 2b Funding As described in the BVPS DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2026. The spent fuel is assumed to remain on the ISFSI pad between 2027 and 2060, when the last of the spent fuel is transferred to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFS! pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partial breach of the DOE Standard Contract.

FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017 , FENGen has recovered more than $193 million from the DOE. However, this settlement expires December31,2019, and FENGen may need to litigatewith the DOE in orderto obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with DOE to obtain recovery of dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the earlier expenses.

As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once adequate funds are set aside to fund the remaining annual spent fuel management expenses pending recovery from the DOE under a settlement, the purpose of the provisional trust will have been satisfied, and the provisional trust can be terminated. lnstead, FENGen will rely upon funds set aside in the segregated account.

The plan for BVPS-2 Period 2b funding process is to retain approximately $4.2 million in the segregated account for BVPS-2. The intent is to pay for the annual ISFSI activities, then apply for recovery of the expenses from the DOE, as needed. lf FENGen is unable to obtain a settlement with DOE by the end of 2026, FENGen will obtain a performance bond for approximately $+.2 million (approximately 1.3 times the highest one-year value of ISFSI maintenance expenses). lf needed, the bond will be in place by the end of 2026. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.

L-19-059 Page 13 of 13 ISFSI Decommissioninq Fundino Once the ISFSI pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2083. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17,2018 (Accession No. ML18351A161) states that sufficient funding is available for ISFSI decommissioning. At this time, no additional monies are required.

Adiustments to Fundinq Pursuantto 10 CFR 50.75(f)(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuantto 10 CFR 50.54(bb), FENOC is required to reporttothe NRC any significant changes to the IFMP. Since this IFMP includes a description funding mechanisms and costs, significant changes to the funding mechanisms and costs will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT or the FENGen provisional trust used to support the IFMP.

Attachment 3 L-19-059 Davis-Besse Nuclear Power Station, Unit No. 1 lrradiated Fuel Management Plan (Fourteen pages follow)

Attachment 3 L-19-059 Davis-Besse Nuclear Power Station, Unit No. 1 lrradiated Fuel Management Plan Page 1 of 14

Background

10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) lrradiated Fuel Management Plan (IFMP), described herein, is based, in part, on a decommissioning cost estimate (DCE) that was prepared in 2018 for DBNPS, which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the DBNPS IFMP, along with license termination and site restoration activities and costs.

Pursuantto 10 CFR 50.75(f)(1) on March 15,2019, FENOC submitted its decommissioning trust financial status report for the four FENOc-operated nuclear facilities. Enclosure B of that report is a copy of the DBNPS DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from DBNPS.

As stated in the DCE (and subject to the assumptions, quallfications, and reservations stated therein), the IFMP is based on the assumption that DBNPS shuts down by May 31, 2020. This IFMP presumes the DOE will commence acceptance of DBNPS's spent fuel in 2030 and completes removal of spent fuel from the site by 2059 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.

1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.

However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2030 from DBNPS and in accordance with spent fuel shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purposes other than for this submission. Such other purposes would include, but are not Iimited to, disputes regarding DOE's legal or contractual acceptance obligations, or damages claims for recovery of incurred costs.

L-19-059 Page 2 of 14 Spent Fuel Manasement Strategy FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercial nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that starts operation in 2025. The DCE assumes that DBNPS will shutdown and cease operations in 2020 and that DBNPS spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, DBNPS fuel would be accepted at the DOE storage facility starting in 2030.

The spent fuel pool will contain discharged fuel from the previous refueling cycles, as wel! as the final reactor core at shutdown. lmmediately after shutdown, spent fuel will be located in the spent fue! pool and in canisters located on an independent spent fuel storage installation (lSFSl). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFSI for interim storage. This period provides the necessary cooling time for the spent fuel to meet the decay heat requirements for placement in dry storage.

The current DBNPS dry fuel storage system consists of a Transnuclear Standardized NUHOMS multi-purpose (storage and transport) dry shielded storage canister (DSC) and a horizontal storage module (HSM). There are a total of eight HSMs on the ISFSI pad, consisting of three DSCs each storing 24-assemblies and four DSCs each storing 32-assemblies (the eighth HSM was never used to store fuel). A Holtec HI-STORM FW system, with a 37-fuel assembly capacity Multi-Purpose Canister (MPC) and concrete shield overpack is expected to be used following shutdown. The DSCs and MPCs are assumed to be transferred directly to the DOE.

FENOC has constructed an ISFSI at DBNPS to support facility operations. The ISFSI operates under a general license pursuantto 10 CFR 72.210. The size of the current pad is 229 feet by 88 feet. The ISFS! may require expansion once plant operations cease in order to support spent fuel management activities. The pad expansion would be 31 feet by 88 feet. Total capacity of the consolidated pad is expected to be 43 DSCs and MPCs holding spent fuel and 4 MPCs holding greater than Class C waste. The ISFSI will continue to operate until such time that the transfer of spent fuel and waste to the DOE can be completed. The DCE assumes that the DBNPS spent fuel has been transferred to the DOE by 2059.

L-19-059 Page 3 of 14 Table 1 provides a listing of the Iocation of the spent fuel from 2019 until the spent fuel has been accepted by the DOE.

Table 1 - Spent Fuel Management Schedule (Fuel Assembly Location)1 Year Pool lnventory ISFSI Inventory DOE Acceptance 201 I 856 496 0 2020 1,033 496 0 2021 1,033 496 0 2022 1 ,033 496 0 2023 1,033 496 0 2024 s15 1,014 0 2025 0 1,529 0 2026 0 1,529 0 2027 0 1,529 0 2428 0 1,529 0 2029 0 1,529 0 2030 0 1,477 52 2031 0 1,331 146 2032 0 1,331 0 2033 0 1,331 0 2034 0 1,268 63 2035 0 1,210 58 2036 0 1 ,153 57 2037 0 1,094 59 2038 0 1,033 61 2039 0 962 71 2040 0 962 0 2041 0 888 74 2042 0 812 76 2043 0 742 70 2044 0 742 0 2045 0 742 0 2046 0 668 74 2047 0 585 83 2048 0 585 0 2049 0 510 75 2050 0 510 0 2051 0 441 69 2052 0 386 55 2053 0 331 55 L-19-059 Page 4 of 14 Table 1 (continued)

Year Pool Inventory ISFSI lnventory DOE Acceptance 2054 0 276 55 2055 0 221 55 2056 0 166 55 2057 0 111 55 2058 0 56 55 2059 0 1 55 2060 0 0 1 Total 1,529 Note:

1. Fuel location is as of the date of the submittal. lt is assumed that no fuel is transferred from the spent fuel pool to the ISFSI until 2024.

Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel program activity, its cost, and the approximate duration of the activity.

The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.

Atachment 3 L-19-059 Page 5 of 14 Table 2 - Spent Fuel Management Activities Decommissioning Costs Start Date Stop Date Approximate Period (thousands, Duration 201 I (years) dollars)1 1 - Preparations 4,502 Mav 2020 December 2021 1.5 2a - Dormancy 147,686 December 2021 August 2025 3.7 with Wet Fuel Storaqe 2b - Dormancy 201 ,419 August 2025 January 2060 34.4 with Dry Fuel Storage Total 353,607 Notes:

1. The values were obtained from the DBNPS DCE, which were reported in 2014 dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differ from those in Table 3 due to the way the values in both tables were calculated.

Decommissioning Period 1 - Preparations During this period, the facility is placed in a condition that allows the spent fuel to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to Ievels that permit release for unrestricted use.

The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fuel storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage.

Decommissioning Period 2a - Dormancy with Wet Fuel Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the remaining DBNPS spent fuel from the spent fuel pool to dry storage in 2024 and to complete the transfer of fuel to the consolidated ISFSI in 2025.

L-19-059 Page 6 of 14 Decommissioning Period 2b - Dormancy with Dry Fuel Storage During this period, spent fuel will remain stored on the ISFSI until the DOE accepts the fuel and removes it from the site. As discussed above and in the DBNPS DCE, the IFMP assumes that the DOE will begin removing fuel from DBNPS in 2030 and will complete the removal of spent fuel from the site in 2059, according to the schedule set forth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be peformed as required. DBNPS will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the ISFSI and spent fuel.

Cost Estimate The DBNPS DCE provides the basis for the costs associated with spent fuel management.

The DCE includes the cost of operating and maintaining the spent fuel pool and the lSFSl. Pool operations are expected to continue approximately 5 years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 40-year period of operation following plant shutdown. The cost for the labor and equipment to load and transfer each spent fuel canister to the ISFS! from the spent fuel pool is also included. Costs fortransferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFS! is complete.

L-19-059 Page 7 of 14 Table 3 provides an expenditure summaryforthe DBNPS IFMP in 2018 dollars.

Table 3 - IFMP Expenditure Summary Expenditure Year (thousands, 201 I dollars) 2020 2,121 2021 5,567 2022 38,672 2023 38,672 2024 38,778 2025 25,582 2026 5,260 2027 5,260 2028 5,275 2029 10,394 2030 6,463 2031 5,861 2032 5,275 2033 5,861 2035 5,861 2036 5,876 2037 5,861 2038 5,861 2039 5,861 2A4A 5,275 2041 5,861 2042 5,861 2043 5,561 2044 5,575 2045 5,561 2046 5,561 2047 5,561 2048 5,575 2049 5,561 2050 5,561 2051 5,561 2052 5,575 2053 5,561 L-19-059 Page I of 14 Table 3 (continued)

Expenditure Year (thousands, 201 I dollars) 2054 5,561 2055 5,561 2056 5,575 2057 5,561 2058 5,861 2059 5,861 2060 0 Total 346,407 Funding FENGen is the owner of Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and BVPS-2, respectively), DBNPS, and Perry Nuclear Power Plant (PNPP). As such, the DBNPS funding mechanisms take into account the need to fund spent fuel management for the other FENGen facilities.

The funding for DBNPS spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2020 to 2025. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Period 2b funding covers the period from 2026 to 2059. This correlates to Iong-term storage of spent fuel on the ISFS! pad until the fuel is transferred to the DOE.

Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and funding, which includes ISFSI activities and the transfer of spent fuel from the spent fuel pools to the lSFSl, for BVPS-1, BVPS-2, DBNPS, and PNPP is approximately $620 million dollars.

FENGen intends to fund this obligation through a combination of a cash deposit of

$475 million paid into a provisional trust coupled with funds in excess of those needed for license termination contained in the DBNPS and BVPS-2 nuclear decommissioning trusts (NDTs). The exception to this is that the 2020 DBNPS spent fuel expenditures of approximately $2.t million will be paid by FENGen's parent. To use the excess funds in the NDTs, exemptions from 10 CFR 50.82(aXBXiXA) for DBNPS and BVPS-2 will be required. These funds will be limited to use only for the management of spent fuel at DBNPS and BVPS-2, respectively. ln addition, FENGen expects to recover its costs by making claims for damages resulting from DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or L-19-059 Page I of 14 High-Level Radioactive Waste (Standard Contract) for DBNPS. lt also expects that by no later than January 1,2026, it will be able to obtain a settlement agreement to recover costs annually. Therefore, FENGen has focused on planning to fund the expected costs through 2025 (that is, Periods 1 and 2a).

As provided in Exhibit D, "Financial Projections," of the "Disclosure Statement for the FirstAmended Joint Plan of Reorganization of FirstEnergy Solutions, Corp., et al.,

Pursuant to Chapter 1 1 of the Bankruptcy Code," submitted to the United States Bankruptcy Court on March 9, 2019, the reorganized debtors are expected to have nearly $2 billion in assets upon emergence from bankruptcy, including approximately

$1.56 billion in cash and cash equivalents. FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's four units by paying the approximately $2.1 million for the 2020 DBNPS spent fuel expenditures and by placement of $475 million into a provisional trust by the end of 2021. The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a. Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.

FENGen will withdraw money from the $475 million provisional trust to pay the DBNPS Periodsl and 2a spent fuel expenditures for 2021 and partially in 2022. To fully satisfy the 2022 spent fuel expenditure and the spent fuel expenditures between 2023 through 2025, FENGen intends to use excess funds in the DBNPS NDT.

Table 4 provides a summary of the FENGen use of the $475 million provisional trust. The expenditures came from the respective facility DCEs that were developed in 2018. Table 5 provides a DBNPS NDT funding analysis that includes the license termination expenditures and the partial 2022 spent fuel expenditure.

The analysis indicates that a positive balance remains in the NDT after the withdrawal for the spent fuel expenditure.

ln order to withdraw funds from the NDT for use to pay for expenditures other than license termination activities, an exemption from 10 CFR 50.82(aXBXiXA) is required to be made and approved by the NRC prior to the withdrawa!. The exemption request will be made in advance of when the withdrawal is needed in 2022.

L-19-059 Page 10 of 14 Table 4 - Periods 1 and 2a Spent Fuel Expenditures (thousands, 2018 dollars)

Year BVPS-1 BVPS.2 DBNPS PNPP Total Trust Payments Payments Payments Payments FENGen Value Payments lnitial 475,000 Value 2021 1 ,838 530 5,567 2,151 10,086 464,914 2022 4,736 2,843 31 ,1721 7,059 45,810 419,104 2023 3?.,844 24,672 02 54,510 112,026 307,078 2024 32,934 36,556 02 54,659 124,149 182,929 2025 32,844 36,456 02 54,510 123,810 59,1 1 I 2026 21,034 1,4563 34,902 57,392 1,727 Totals 126,230 102,513 36,739 207,791 473,273 Notes:

1. For DBNPS, the listed partial payment is associated with the provisional trust. However, money from excess funds in the NDT will be used to make the full 2022 payment based upon the December 31 , 2018 NDT values. An exemption from 10 CFR 50.82(aXBXIXA) will be made in order to use funds from the NDT.

2. For DBNPS these payments will be made from excess funds in the NDT by use of exemptions from 10 CFR 50.82(aXBXlXA).

3. For BVPS-2 the listed partial payment is associated with the provisional trust.

However, money from excess funds in the NDT will be used to make the full 2026 payment based upon the December 31,2018 NDT values. An exemption from 10 CFR 50.82(aXSXiXA) will be made in order to use funds from the NDT.

Attachment 3 L-19-059 Page11of14 Table 5 - Nuclear Decommissioning Trust Funding Analysis1,2,3,4 Year Beginning Deposits Earnings License Spent Fuel Ending Balance Termination Withdrawal Balance Withdrawal 201 I 562,958,730 562,958,730 201 I 562,958,730 11,259,175 574,217,905 2020 574,217,905 10,552,856 (46,575,099) 538,195,663 2021 538,195,663 8,983,464 (89,022,463) 458,156,664 2022 458,1 56,664 8, 888,8 1 3 (6,216,031) (7,500,000) 453,329,446 2023 453,329,446 8,168,828 (6,216,031) (38,672,000) 416,61 0,244 2024 416,61 0,244 7,431,994 (6,233,061) (38,778,000) 379,031 ,166 202s 379,031 ,166 6,947,909 (6,053,735) (25,582,000) 354,343,340 2026 354,343,340 0,970,831 (5,801,782) 355,512,390 2027 355,512,390 6,994,212 (5,801 ,782\ 356,704,820 2028 356,704,820 7,017,743 (5,817,675) 357,904,997 2029 357,904,887 7,042,062 (5,801,782) 359,1 45,1 6g 2030 359,145,1 6g 7,066,969 (5,801 ,782\ 360,410,254 2031 360,410,254 7,092,169 (5,801 ,782\ 361,700,641 2032 361,700 ,641 7,117,659 (5,817,675) 363,000,625 2033 363,000,625 7,143,977 (5,801 ,782\ 364,342,820 2034 364,342,920 7,170,821 (5,801 ,782\ 365,71 1,859 2035 365,71 1,859 7,198,202 (5,801 ,782\ 367,108,279 2036 367,108,279 7,225,912 (5,817,675) 368,516,415 2037 368,516,415 7,254,293 (5,801 ,782\ 369,968,926 2038 369,968,926 7,293,343 (5,801 ,7821 371,450,497 2039 371,450,487 7,312,974 (5,801 ,7821 372,961,679 2040 372,961,679 7,342,880 (5,817,675) 374,486,884 2041 374,486,994 7,373,702 (5,801 ,782\ 376,058,804 2042 376,058,804 7,405, 140 (5,801 ,782) 377 ,662,163 2043 377 ,662,163 7,437,208 (5,801 ,7821 379,297,589 2044 379,297,599 7,469,598 (5,817 .6751 380,949,511 2045 380,949,511 7,542,955 (5,801 ,7821 382,650,694 2046 382,650,684 7,536,979 (5,801 ,7821 384,385,990 2047 384,385,880 7,571,682 (5,801,782) 386,155,780 2048 386,1 55,790 7,606,762 (5,817,675) 387,944,867 2049 387,944,867 7,642,862 (5,801 ,782\ 389,795,947 2050 389,785,947 7,679,693 (5,801 ,782\ 391,663,949 2051 391,663,848 7 ,717 ,241 (5,801,782) 393,579,308 2052 393,579,308 7,755,233 (5,817 ,675\ 395,516,965 2053 395,516,865 7,794,302 (5,801 ,7821 397,509,385

Attachment 3 L-19-059 Page 12 at 14 Table 51,2' 3'a (continued)

Year Beginning Deposits Earnings License Spent Fuel End ing Balance Termination Withdrawal Balance Withdrawal 2054 397,509,385 7,834,152 (5,801 ,782J 399,541,755 2055 399,541,755 7,874,799 (5,801 ,782\ 401,61 4,773 2056 401,614.773 7,915,942 (5,817 ,675\ 403,713,039 2057 403,713,039 7,958.225 (5,801 ,782\ 405,869,482 20s8 405,869,482 8,001,354 (5,801,782) 408,069,055 2059 408,069,055 8,045,345 (5,801 ,7821 410,312,618 2060 410,312,618 8,085,363 (6,044,475) 412,353,506 2061 412,353,506 8,126,51 1 (6,027,959) 414,452,058 2062 414,452,058 8,168,482 (6,027,959) 416,592,582 2063 416,592,582 8,211,292 (6,027,959) 418,775,915 2064 418,775,915 8,254,629 (6,044,475) 420,996,069 2065 420,996,069 8,299,162 (6,027,959) 423,257,272 2066 423,257,272 8,344,586 (6,027,959) 425,573,900 2067 425,573,900 8,390,919 (6,027,959) 427,936,860 2068 427,936,860 8,437,949 (6,044,475) 430,330,233 2069 430,330,233 8,486,045 (6,027,959) 432,788,320 2070 432,788,320 8.535,207 (6,027,959) 435,295,568 2071 435,295,568 8,585,352 (6,027,959) 437,852,962 2472 437,852,962 8,636,170 (6,044,475) 440,444,656 2073 440,444,656 8,688,334 (6,027,959) 443,105,031 2074 443,105,031 8,378,589 (24,175,581) 427,309,040 2075 427,308,040 7,439,135 (55,351,290) 379,395,885 2076 379,395,885 4,836,350 (137,578,409) 246,653,825 2077 246,653,825 3, 1 39,393 (89,734,170) 160,058,048 2078 160,058,048 1,621,045 (79,005,780) 82,673,313 2079 82,673,313 335,904 (65,878,097) 17 ,131,121 2080 17 ,131 ,121 4,571 (16,902,552) 233j40 2081 233,1 40 2,547 (105,814) 129,872 2082 129,872 1,386 (60,589) 70,668 2083 70,668 1,413 72,082 N otes:

1 The analysis is based upon the SAFSTOR approach to decommissioning.

2 The analysis was performed for constant 2018 dollars.

3 A two percent after-tax real rate of return was used in the analysis.

4 Analysis is based upon the December 31 , 2018 NDT balance.

L-19-0s9 Page 13 of 14 Period 2b Funding As described in the DBNPS DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2025. The spent fuel is assumed to remain on the ISFSI pad between 2026 and 2059, when the last of the spent fuel is transferred to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFSI pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partial breach of the DOE Standard Contract.

FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017, FENGen has recovered more than $193 million from the DOE. However, this settlement expires December 31 ,2019, and FENGen may need to litigate with the DOE in order to obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with DOE to obtain recovery of dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the earlier expenses.

As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once adequate funds are set aside to fund the remaining annual spent fuel management expenses pending recovery from the DOE under a settlement, the purpose of the provisional trust will have been satisfied, and the provisional trust can be terminated. Instead, FENGen will rely upon funds set aside in the segregated account.

The plan for DBNPS Period 2b funding process is to retain approximately $13.5 million in the segregated account for DBNPS. The intent is to pay for the annual ISFSI activities, then apply for recovery of the expenses from the DOE, as needed. lf FENGen is unable to obtain a settlement with DOE by the end af 2A25, FENGen wil!

obtain a performance bond for approximately $t 3.5 million (approximately 1 .3 times the highest one-year value of ISFS! maintenance expenses). lf needed, the bond will be in place by the end of 2025. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.

L-19-059 Page 14 of 14 ISFSI Decommissionins Funding Once the ISFS! pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2082. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17,2018 (Accession No. ML18351A161) states that sufficient funding is available for ISFSI decommissioning. At this time, no additional monies are required.

Adiustments to Fundinq Pursuantto 10 CFR 50.75(f)(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuantto 10 CFR 50.54(bb), FENOC is required to reporttothe NRC any significant changes to the IFMP. Since this IFMP includes a description funding mechanisms and costs, significant changes to the funding mechanisms and costs will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT or the FENGen provisional trust used to support the IFMP.

Attachment 4 L-19-059 Perry Nuclear Power Plant, Unit No. 1 Irradiated Fuel Management Plan (Eleven pages follow)

Attachment 4 L-19-059 Perry Nuclear Power Plant, Unit No. 1 lrradiated Fuel Management Plan Page1of11

Background

10 CFR Part 50.54(bb) requires licensees to establish a program to manage and provide funding for the management of spent fuel at the reactor site until title and possession of the fuel is transferred to the United States Department of Energy (DOE) for ultimate disposal. The Perry Nuclear Power plant, Unit No. 1 (PNPP) lrradiated Fuel Management Plan (IFMP), described herein, is based, in part, on a decommissioning cost estimate (DCE) that was prepared in 2018 for PNPP, which includes elements associated with spent fuel management. The DCE identifies the details, schedules, and costs associated with spent fuel management activities described in the PNPP IFMP, along with license termination and site restoration activities and costs.

Pursuantto 10 CFR 50.75(f)(1) on March 15,2019, FENOC submitted its decommissioning trust financia! status report for the four FENOC-operated nuclear facilities. Enclosure C of that report is a copy of the PNPP DCE. The DCE describes the bases for the assumptions regarding DOE acceptance of spent fuel from the industry and from PNPP.

As stated in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), this IFMP is based on the assumption that PNPP shuts down by May 31 , 2021. This IFMP presumes the DOE will commence acceptance of PNPP's spent fuel in 2034 and completes removal of spent fuel from the site by 2060 consistent with the most recent DOE spent fuel management and acceptance strategyl described below.

1 DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.

However, for these purposes, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. Therefore, while DOE's Standard Contract governing the acceptance of spent fuel allows for alternative removal schedules, including priority for shutdown reactors and exchanges of allocations, for purposes of this estimate DOE acceptance is assumed to commence in 2034 from PNPP and in accordance with spent fuel shipment schedules that are based upon published historic acceptance priority rankings by DOE. Nothing herein should be interpreted as a concession or admission of any kind for purpo$es other than for this submission. Such other purposes would include, but are not limited to, disputes regarding DOE's legal or contractual acceptance obligations, or damages claims for recovery of incurred costs.

L-19-059 Page 2 of 11 Spent Fuel Manaqement Strateqv FENOC assumes that, as stated in the DOE's "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Waste," dated January 2013, the DOE will start accepting spent fuel for storage from the nation's commercia! nuclear plants beginning in 2025 for placement in a consolidated interim storage facility (CISF) that starts operation in 2025. The DCE assumes that PNPP will shutdown and cease operations in 2021 and that PNPP spent fuel will be accepted for placement in the CISF. Using the rankings for spent fuel receipt, as delineated in the Office of Civilian Radioactive Waste Management reports, "Annual Capacity Report," dated June 1987, and "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004, PNPP fuel would be accepted at the DOE storage facility starting in 2034.

The spent fuel pool will contain discharged fuel from the previous refueling cycles, as well as the final reactor core at shutdown. lmmediately after shutdown, spent fuel will be located in the spent fuel pool and in canisters located on an independent spent fuel storage installation (ISFSI). During the five-year period after the shutdown, the spent fuel from the spent fuel pool would be packaged into canisters and transferred to the ISFSI for interim storage. This period provides the necessary cooling time for the spent fuel to meet the decay heat requirements for placement in dry storage.

The current PNPP dry fuel storage system consists of a Holtec lnternational Hl-STORM 100S System (with a 68-fuel assembly capacity). The system consists of a Multi-Purpose Cannister (MPC) (storage and transport) and a concrete shield (overpack). The MPCs are assumed to be transferred directly to the DOE.

FENOC has constructed an ISFSI at PNPP to support plant operations. The ISFSI operates under a general license pursuant to 10 CFR 72.210. The current size of the ISFSI pad is 347 feet by 75 feet. The ISFSI may require expansion once plant operations cease in order to support spent fuel management activities. The pad expansion would be 40 feet by 75 feet. Total capacity of the consolidated pad is expected to be 80 MPCs holding spent fuel and 5 MPCs holding greater than Class C waste. The ISFS! will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. The DCE assumes that the PNPP spent fuel and has been transferred to the DOE by 2060.

Table 1 provides a listing of the location of the spent fuel from 2019 until the spent fuel has been accepted by the DOE.

L-19-059 Page3of11 Table 1 - Spent Fuel Management Schedule (Fuel Assembly Location)1 Year Pool lnventory ISFS! lnventory DOE Acceptance 201 I 3,285 1,360 0 2020 2,945 1,700 0 2021 3,693 1,700 0 2022 3,693 1,700 0 2023 3,693 1,700 0 20?4 3,693 1,700 0 2025 1,041 4,352 0 2026 0 5,393 0 2027 0 5,393 0 20?8 0 5,393 0 2029 0 5,393 0 2030 0 5,393 0 2031 0 5,393 0 2032 0 5,393 0 2033 0 5,393 0 2034 0 5,267 126 2035 0 4,839 428 2036 0 4,634 205 2037 0 4,404 230 2038 0 4,393 11 2039 0 4,106 287 2040 0 3,855 251 2041 0 3,582 273 2042 0 3,283 299 2043 0 3,283 0 2044 0 3,002 281 2045 0 2,714 288 2046 0 2,714 0 2047 0 2,430 284 2048 0 2,1 50 280 2049 0 2,1 50 0 2050 0 1,969 282 2051 0 1,969 0 2052 0 1,658 210 2053 0 1,448 210 2054 0 1,238 210 2055 0 1,028 210 2056 0 818 210 L-19-059 Page 4 of 11 Table 1 (continued)

Year Poo! lnventory ISFSI lnventory DOE Acceptance 2057 0 608 210 2058 0 398 210 2059 0 188 210 2060 0 0 188 Total 5,393 Note:

1 . Fue! location is as of the date of the submittal.

Schedule Table 2 provides a summary of the spent fuel management activities described in the DCE. The table provides the decommissioning period associated with the spent fuel program activity, its cost, and the approximate duration of the activity.

The table does not consider ISFSI decommissioning, as this is an activity undertaken after spent fuel has been accepted by the DOE and removed from the site.

Table 2 - Spent Fuel Management Activities Decommissioning Costs Start Date Stop Date Approximate Period (thousands, Duration 201 I (years) dollars)1 1 - Preparations 4,568 May 2021 December 2022 1.5 2a - Dormancy 208,007 December 2022 July 2026 3.7 with Wet Fuel Storage 2b - Dormancy 307,995 July 2026 January 2061 34.4 with Dry Fuel Storage Total 520,570 Note:

1. The values were obtained from the PNPP DCE, which were reported in 2014 dollars. A composite escalation factor was applied to convert the values into 2018 dollars. These values differfrom those in Table 3 due to the way the values in both tables were calculated.

L-19-059 Page5of11 Decommissioning Period 1 - Preparations During this period, the facility is placed in a condition that allows the spentfuel to be safely stored and the facility to be maintained in a condition to be subsequently decontaminated to levels that permit release for unrestricted use.

The facility is left essentially intact with structures maintained in a sound condition. The process of placing the plant in safe-storage includes, but is not limited to, isolating the spent fuel storage services and fuel handling systems so that the spent fuel can be safely transferred from the spent fuel storage pool to the ISFSI for interim storage.

Decommissioning Period 2a - Dormancy with Wet Fuel Storage During this period, the facility is in the dormancy period of SAFSTOR decommissioning. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. FENOC expects to construct an ISFSI pad expansion during this period. FENOC plans to begin transferring the remaining PNPP spent fuel from the spent fuel pool to dry storage in 2025 and to complete the transfer of fuel to the consolidated ISFSI in 2026.

Decommissioning Period 2b - Dormancy with Dry Fuel Storage During this period, spent fuel will remain stored on the ISFSI until the DOE accepts the fuel and removes it from the site. As discussed above and in the PNPP DCE, the IFMP assumes that the DOE will begin removing fuel from PNPP in 2034 and will complete the removal of spent fuel from the site in 2060, according to the schedule set forth in Table 1. During this period, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Maintenance, monitoring, and inspection of equipment, including fuel handling and shipping equipment, will be performed as required, PNPP will also maintain a security force, which will safeguard the spent fuel for as long as it remains on site. Security barriers, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the ISFSI and spent fuel.

Cost Estimate The PNPP DCE provides the basis for the costs associated with spent fuel management.

The DCE includes the cost of operating qnd maintaining the spent fuel pool and the ISFS!. Pool operations are expected to continue approximately 5 years after the cessation of plant operations. ISFSI operating costs are based upon an approximately 39-year period of operation following plant shutdown. The cost for L-19-059 Page6of11 the labor and equipment to load and transfer each spent fuel canister to the ISFSI from the spent fuel pool is also included. Costs for transferring the fuel from the ISFSI into the DOE transport cask are also included in the DCE.

Operation and maintenance costs for the spent fuel pool and the ISFSI are included within the DCE and address the cost for staffing the facility, as well as security, insurance, and licensing fees. Costs are also provided within the DCE for the decommissioning of the spent fuel pool, and the ISFSI after the fuel transfer to the DOE from the ISFSI is complete, Table 3 provides an expenditure summaryforthe PNPP IFMP in 2018 dollars.

Table 3 - IFMP Expenditure Summary Expenditure Year (thousands, 201 I dollars) 2021 2,151 2022 7,059 2023 54,510 2024 54,659 2025 54,510 2026 34,902 2027 8,036 2028 8,058 2029 8.036 2030 8,036 2031 8,036 2032 8,058 2033 12,652 2034 8,637 2035 9,839 2036 8,959 2037 8,937 2038 8,036 2039 9,239 2040 9,260 2041 9,238 2042 9,539 2043 8,637 2044 8,959 L-19-059 Page 7 of 11 Table 3 (continued)

Expenditure Year (thousands, 201 I dollars) 2045 8,637 2046 8,937 2047 8,637 2048 8,959 2049 8,637 2050 9,937 2051 8,637 2052 8,959 2053 8,937 2054 8,937 2055 8,937 2056 8,959 2057 8,937 2059 8,937 2060 8,959 Total 509,865 Funding FENGen is the owner of Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and BVPS-2, respectively), Davis-Besse Nuclear Power Station (DBNPS), and PNPP. As such, the PNPP funding mechanisms take into account the need to fund spent fuel management for the other FENGen facilities.

The funding for PNPP spent fuel management follows the schedule described above. Funding for Periods 1 and 2a extends from 2021 to 2026. This correlates with preparation activities and transferring the spent fuel to the ISFSI pad. Perlod 2b funding covers the period from 2027 to 2060. This correlates to long-term storage of spent fuel on the ISFSI pad until the fuel is transferred to the DOE.

Periods 1 and 2a Funding The total FENGen obligation for Periods 1 and 2a funding, which includes ISFSI activities and the transfer of spent fuel from the spent fuel pools to the ISFSI, for BVPS-1, BVPS-2, DBNPS, and PNPP is approximately $620 million dollars.

FENGen intends to fund this obligation through a combination of a cash deposit L-19-059 Page8of11 of $475 million paid into a provisional trust coupled with funds in excess of those needed for license termination contained in the DBNPS and BVPS-2 nuclear decommissioning trusts (NDTs). To use the excess funds in the NDTs, exemptions from 10 CFR 50.82(aXBXIXA) for DBNPS and BVPS-2 will be required. These funds will be Iimited to use only for the management of spent fuel at DBNPS and BVPS-2, respectively. ln addition, FENGen expects to recover its costs by making claims for damages resulting from the DOE's breach of the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) for PNPP. lt also expects that by no later than January 1,2027, it will be able to obtain a settlement agreement to recover costs annually. Therefore, FENGen has focused on planning to fund the expected costs through 2026 (that is, Periods 1 and 2a).

As provided in Exhibit D, "Financial Projections," of the "Disclosure Statement for the FirstAmended Joint Plan of Reorganization of FirstEnergy Solutions, Corp., et al.,

Pursuant to Chapter 1 1 of the Bankruptcy Code," submitted to the United States Bankruptcy Court on March 9,2019, the reorganized debtors are expected to have nearly $2 billion in assets upon emergence from bankruptcy, including approximately

$1.56 billion in cash and cash equivalents. FENGen anticipates that such assets would be able to fund Periods 1 and 2a spent fuel management activities for FENGen's four units by paying the approximately $2.1 million for the 2020 DBNPS spent fuel expenditures and by placement of $475 million into a provisional trust by the end of 2021 . The provisional trust will enable use of the funds for spent fuel management activities occurring during Periods 1 and 2a. Upon the completion of the spent fuel activities in Periods 1 and 2a, the terms of the provisional trust will provide that it can be terminated, and its balance released back to FENGen.

FENGen will withdraw money from the $475 million provisional trust to pay the PNPP Periods 1 and 2a spent fuel expenditures. Table 4 provides a summary of the FENGen use of the $475 million provisional trust. The expenditures came from the respective site-specific DCEs that were developed in 2018.

L-19-059 Page I of 11 Table 4 - Periods 1 and 2a Spent Fuel Expenditures (thousands, 201 I dollars)

Year BVPS-1 BVPS.2 DBNPS PNPP Total Trust Payments Payments Payments Payments FENGen Value Payments Initial 475,000 Value 2021 1,838 530 5,567 2,151 10,086 464,914 2022 4,736 2,943 31 ,1721 7,059 45,810 419,104 2023 32,844 24,672 02 54,510 112,026 307,078 2024 32,934 36,556 02 54,659 124,149 182,929 2025 32,844 36,456 02 54,510 123,910 59,1 1 g 2026 21,034 1,4563 34,902 57,392 1,727 Totals 126,230 102,513 36,739 207,791 473,273 Notes:

1. For DBNPS, the listed partial payment is associated with the provisional trust. However, money from excess funds in the NDT will be used to make the full 2022 payment. An exemption from 10 CFR 50.82(aXBXiXA) will be made in order to use funds from the NDT.

2. For DBNPS these payments will be made from excess funds in the NDT by use of exemptions from 10 CFR 50.82(aXBXlXA).

3. For BVPS-2 the listed partial payment is associated with the provisional trust.

However, money from excess funds in the NDT will be used to make the full 2026 payment. An exemption from 10 CFR 50.82(aXBXiXA) will be made in order to use funds from the NDT.

The PNPP Periods 1 and 2a costs will be fully paid for by funds withdrawn from the

$475 million provisional trust.

Period 2b Funding As described in the PNPP DCE, it is anticipated that the spent fuel will be entirely located on the ISFSI pad by 2026. The spent fuel is assumed to remain on the ISFSI pad between2027 and 2060, when the last of the spent fuel is transferred L-19-059 Page 10 of 1 1 to the DOE. There are annual costs associated with maintaining the spent fuel on the ISFSI pad during this period. FENGen generally expects to recover those costs for spent fuel management during Period 2b, through reimbursements from the DOE due to its partia! breach of the DOE Standard Contract.

FENGen has an existing settlement agreement with the DOE to recover spent fuel expenditures for its four facilities. Between 2012 and 2017, FENGen has recovered more than $193 million from the DOE. However, this settlement expires December 31,2019, and FENGen may need to litigate with the DOE in orderto obtain reimbursement of Period 1 and 2a spent fuel expenditures after that date if the current settlement agreement is not extended. Other licensees with plants in premature shutdown have litigated with the DOE to obtain recovery of dry fuel storage costs and then obtained a settlement agreement. Thus, FENGen expects to obtain a settlement agreement for the Period 2b expenses and potentially some of the earlier expenses.

As FENGen recovers its damages from the DOE, adequate funds will be retained in a segregated account to fund future annual expenses. Depending upon when litigation is resolved or a settlement is reached, this may include funding for parts of Periods 1 and 2a. Once adequate funds are set aside to fund the remaining annual spent fuel management expenses pending recovery from the DOE under a settlement, the purpose of the provisional trust will have been satisfied, and the provisional trust can be terminated. lnstead, FENGen will rely upon funds set aside in the segregated account.

The plan for PNPP Period 2b funding process is to retain approximately $16.5 million in the segregated account for PNPP. The intent is to pay for the annual ISFS! activities, then apply for recovery of the expenses from the DOE, as needed lf FENGen is unable to obtain a settlement with DOE by the end of 2026, FENGen will obtain a performance bond for approximately $16.5 million (approximately 1.3 times the highest one-year value of ISFSI maintenance expenses). lf needed, the bond will be in place by the end of 2026. The bond will be renewed annually and remain in-place until such time that a settlement with the DOE is obtained.

ISFSI Decommissioning Fundins Once the ISFSI pad is no longer needed, ISFSI decommissioning can occur. The ISFSI decommissioning is expected to be completed by 2083. ISFSI decommissioning costs will be paid from an existing provisional ISFSI trust that was established for that purpose. FENOC letter to the NRC dated December 17,2018 (Accession No. ML18351A161) states that sufficient funding is available for ISFSI decommissioning. At this time, no additional monies are required.

L-19-059 Page 11 of 11 Adiustme to Fundino Pursuantto 10 CFR 50.75(f)(1), and 10 CFR 50.82(aXBXv) and (vi), FENOC is currently required to annually report to the NRC the status of the FENGen facility NDTs. Pursuantto 10 CFR 50.54(bb), FENOC is required to reportto the NRC any significant changes to the IFMP. Since this IFMP includes a description funding mechanisms and costs, significant changes to the funding mechanisms and costs will be reported. FENOC will make any adjustments, as needed, to ensure the adequacy of the facility NDT or the FENGen provisional trust used to support the IFMP.