Free Motion for Summary Judgment - District Court of Federal Claims - federal

Case 1:02-cv-01894-EJD

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(Chief Judge Damich) No. 02-1 894C

IN

THE UNITED STATES COURT OF FEDERAL CLAIMS

CONSUMERS ENERGY Plaintiff,
V,

COMPANY,

THE UNITED STATES, Defendant.

APPENDIX TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT UPON COUNTS I AND il OF PLAINTIFF'S COMPLAINT AND, IN THE ALTERNATIVE, FOR PARTIAL SUMMARY JUDGMENT UPON DEFENDANT'S RIGHT TO RECOVER UNPAID FEES

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director HAROLD D. LESTER, JR. Assistant Director Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D. C. 20530 Tele: (202) 305-7562 Fax: (202) 307-2503 Attorneys July 9, 2004 for Defendant

OF COUNSEL: JANE K. TAYLOR Office of General Counsel Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585

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INDEX TO APPENDIX

DOCUMENT Letter from Eugene R. VanHoof,ConsumersPower Company, Mr. Claristopher to Jedrey, Department of Energy, dated May31, 1985 ............................. Internal memorandum from ConsumersPower Company entitled "Responses to R J AnconaLetter of May1, 1984 Regarding Spent Nuclear Fuel Costs And The Nuclear Fuel Waste Disposal Act .................................... Internal Correspondence from T.C. Bordine, ConsumersPower Company, dated May7, 1992, regarding "Spent Nuclear Fuel Shipments To DOE"............. Memorandum from T.C. Bordine, Consumers Power Company,dated January 21, 1993, regarding "DOE Allocations - SNFShipments" . ....................... Letter from Thomas Bordine, ConsumersPower, to Linda Stroud, Contracting C. Officer, Department of Energy, dated April 13, 1993 ............................ Internal Correspondencefrom K.J. Slaields, Consumers PowerCompany, T.C. to Bordine regarding "Correcting DCSforms," dated June 18, 1993 ................. Internal Correspondence from K.J. Shields, ConsumersPowerCompany, R.W. to Sindemaanregarding "SNM Inventory to 2007 based on DCS's," dated August 16, 1993 ................................................... Letter from Thomas Bordine, ConsumersPower, to Beth Tomasoni, Contracting C. Officer, Department of Energy, dated August 19, 1993 ......................... Unsigned Delivery Commitment Schedule for 1999 with handwritten notes ............... Approved Delivery CommitmentSchedules for 1999 ................................. Approved Delivery CommitmentSchedules for 2000 ................................. Approved Delivery CommitmentSchedules for 2001 and 2002 ......................... Pages from Consolidated Accounting and Investment System, Nuclear Waste Fund, Quarterly Statement of Payments, dated April 2, 2004 .....................

PAGE

1

2

5

6

8

10

12

15 17 18 22 26

29

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Consumers power company
1945 West Parna[IRoad, Jackson, 49201 (517)788-1545 MI ¯

EugeneR VanHoof

May 31, 1985 ERV-85-74

Mr Christophlr T Jedrey US Department of Energy Procurement and Assistance Management Directorate Office of Procurement Operations Washlngton, DC 20585 Dea~ Mr Jedrey Pursuant to Article Nuclear Fuel and/or (DE-CR01-83NE44374), Option 2, the single Respectfully VIII.Bo2 of our Contract for Disposal of Spent High-Level Radioactive Waste dated June 3, 1983, Consumers Power Company selects as its fee payment, payment prior to delivery of the spent nuclear fuel.

CC

RJOdlevak SNSpring JLBacon ABBass TCCampbell GLSchwass

OC0585-0038A-FS02

I

COF00913.12

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CONSUMERS POWER COMPANY P~sponses to R J Ancona Letter of May i, 1984 Regarding Spent Nuclear Fuel Costs and The Nuclear Fuel Waste Disposal Act Does your Company have a contract wSth the DOE for disposing of spen~ nuclear fuel? Response: Consumers Power executed with DOE the Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (SNF/HLW) on June 3. 1983. A copy of the Contract has been furnished to your Mr R C Callen. For fuel burned prier to April 7, 1983, how much is there and how many dollars are owed to the DOE? Response: For fuel burned priur to April 7, 1983, there is approximately 238,000 kSU for which $44,280,78~.21is owed DOE. 3. ~or fuel burned prior to April 7, 1983, how many dollars have been collected from your ratepayers for spent fuel disposal (by year of collection)? Response: Through 1974 $1,690.199 1975 2,067,118 1976 4,332,968 1977 4,006,031 1978 2,152,836 2,602,268 1979 1980 2,070,961 1981 2,889,407 1982 2,661,047 1983 1,275,006 Total $25,747,841

4.

Is the money referred to in question 3 in a special account? Response: No. Has your Company decided on how it will make the payment for fuel burned prior to April 7, 19837 If so, which option? Response: Consumers Power has not elected an option on payment for spent fuel burned prior to April 7, 1983. A decision is scheduled to be made by approximatelyApril 1985. If the money collected from the ratepayers is not in a special account, where would the cash come from to meet a 1985 lump-sum payment (please answer regardless of.whlch option has been chosen by your Company)? Response: Should Consumers Power elect the 1985 lump-sum payment option, the cash will be provided from internally generated funds and

=~ern=lfisancleg.

01010488

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For fuel burned after April 7, 1983, trace the dollars between the time it Is collected through Account 518 to the time it is paid to the DOE. Response: Amounts payable to the DOE are charged monthly to Account 518 and credited to Account 232 based on 1 mill per kilowatthour (kWh) of gross nuclear generation. Quarterly payments these amounts are payable to the DOE on the last day of the month following each quarter. Collectlen of these costs from our customers is dependent Upon estimated power supply cost recovery (PSCR) factors and sales levels; therefore, the timing of collection is not kno%rn until the annual PSCR reconciliation.

8.

H~w loug after it is collected is it paid to the DOE? Response: As stated in the response to question 7, payment to the DOE is based on a monthly charge of 1 mill per kWh and not on the amount actually collected from customers. To the extent that the PSCR factor accurately estimates fuel costs, including the 1 mill per kWh, and sales levels, customers are billed currently for the DOE assessment and the bills are due 21 days after billing.

9.

Please provide Act. Response:

your Company's

evaluation

of the Nuclear

Waste Disposal

The Nuclear Waste Policy Act (N~TA) sf 1982 establlshes the method, the means, the responsibility, the schedule and the institutional process by which SNF/HLW will ultimately be disposed of. Consumers Power supports the NWPA of 1982.

10.

Please prov-lde your Company's evaluation of the DOE thus far in administering the Act. Response: DOE has accepted the responsibility under the ~PA of 1982 to carry out the Act by establishing management organizations iu all appropriate areas to carry out the provisions of the Act. Contracts have been executed with all generators and holders of SNF/~IW providing revenues to support the SNF/HLW program budget. Efforts are underway to develo~ the SNF/HLW containment technology and to carry out the institutional process of site selection. Schedules have been developed to meet the January 31, 1998 date for receiving SNF/HLW. Progress to date in meeting key dates established in t.he Act appears to be satisfactory.

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3

11. Please provide your Company's evaluation of what will happen ~n the near
future with the Act and the DOE. Response: In the near future it is expected that DOE will continue to hold workshops with the individual states that have land areas under consideration for SNF/HLW disposal site selection. Some members of the Michigan Governors Task Force were scheduled to attend their third workshop this past winter 1984. The final version of the l~/ssion Plan Volume I (DOE report to Congress) should be published in August 1984. A draft of the Mission Plan Volume II should be published for comment by August 1984. The Site Selection Guidelines should be finalized by September 1984. A recommendation to the President on uhe three sites to he characterized in the selection process for the first disposal facility should be made'by January 1985. A reduction of approximately 220 areas ~own to about 20 areas under consideration for characterization in the selection process for the second disposal site should be made by June 1985. The 1 mill/kWh fee should remain the same through 1985. Finally, it is expected that the permanent .Director of the Office of Civilian Radioactive Waste Management, recently nominated by the President, should be confirmed by the Senate in the near future.

12. Please provide your Company's estimated timing of a permanent storage
s~te. Response: It is expected that DOE will begin accepting SNF/HLW by January 31, 1998 unless the NWPA-1982 is amended. DOE will store ~the SNF/HLW accepted in the operational storage site or a backup monitored retrlevable storage (M~S) facility until the storage site is complete.

01010490

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GRBoss, RockPoint Big RJGerltng, Palisades HGHlynarek, Palisades TCBordine, P-24-602 y~/~ Hay 7, 1992 CONSUHERS POWER COHPANY Internal Correspondence TCB 92-47 3SRang,P-24-614A RWStnderman, P-24-401 GBSIade,Palisades ERVanHoof, P-24-113B GCWithrow, RockPoint Big

From

~ate

Subject SPENT NUCLEAR FUEL SHIPHENTS DOE TO CC DPHoffman, P-26-117A WLBeckman, Rock Point . Big DEEngle,Palisades MAFerens, Palisades DRHughes, P-24-420A RDOrosz, Palisades

Attached is a copy of DOE'sAnnual Capacity Report (ACR) published December 199] and received March 1992. The report stipulates the annual allocation of Spent Nuclear Fuel that maybe shipped to a disposal facility for each utility for a ten-year period, the first year beginning in 1998. Our first allocation begins in the second year, 1999, and is for 2.5 MTU spent fuel which is of equivalent to ]8 Big Rock Point fuel assemblies. Our secondallocation begins in the third year, 2000, and is for 87.3 MTU spent fuel which is equivalent of to 22 Big Rock Point fuel assemblies and 205 Palisades fuel assemblies. Although it is questionable whether or not DOE will have a facility ready to receive our spent nuclear fuel beginning in the year 1999, since we are paying I mill/KWh DOE to dispose our spentfuelassemblies, is appropriate for of it that we complete all contractual requirements in order that we do not lose our shipment allocations. The contract requires that beginning January ], 1992, and at least 63 monthsprior to any allocated shipment, we must complete a form identified as the Delivery CoganttmentSchedule(DCS). The form should, therefore, be submitted sometimebetweennowand August, 1993 to facilitate our first shipment. Since each DCSreceived by DOE date-stamped and is approved(or disapproved), within 3 monthsof receipt, it is in our best interest submit to the formearlyin order takeadvantage the "first to of come, firstserve" contractual obligation thatthe DOE mustfollow. The decision thatneeds be madeprior submitting firstDCS is how to to to out splitup our allocations between RockPointand Palisades. Big Eachallocationcan be divided between plants assigned to Palisades Big Rock or all or P~int. Eventhough the firstyearallocation 2.5 HT~ was established IB of by fuelassemblies discharged fromBig RockPoint, may choose have we to Palisades utilize allocation Big RockPointutilize of the 87.3 the and all ~TTOallocation following the year, viceversa. or Sinceit is morelikely thatBig RockPointwillhavereached end of its' the operating license the timethe DOE has an operating facility, may be by MRS it appropriate use all allocations to assigned Big RockPointfirst, to untilall fuelhas beentransferred offsite DOE,and thenbeginshipping to Palisades spent fuel. A meeting suggested establish is to appropriate disposal strategy our for spentfuelshipments DOE.Please to contact withyourpreferences a me for meeting location, timeand thoseindividuals should involved the who be in decisions regarding spentfuelshipments. persons, copyof this our Any by memo,who have input,pleasefeel free to call me on 80665. 0,i00~.~

CPTO01 0035

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To:

GRBoss, Big Rock Point RJGerling, Palisades PJKluskowski, Palisades TCBordine, P24-602J~

CONSUMERS POWER COMPANY TCB-93-09

Date: subJect: CC:

January

21, 1993 - SNF Shipments JSRang, P24-614 SRMaclean, Palisades KFKrueger, Palisades JJFremeau, P24-414A RAHarrington, P24-606

DOE Allocations

MAFerens, Palisades GHGoralski, Palisades HAReyner, Palisades WEKessler, P24-616 DEEngle, Palisades

Last July 14, 1992 we held a meeting to discuss the DOE Disposal Contract allocations for spent nuclear fuel shipments, currently scheduled to begin, for CPCo, in the year 1999. In attendance were those addressees and recipients by copy of this memo. In that meeting, we concluded that decisions regarding DOE allocations between BRP and PAL should await completion of an economic study conducted by JSRang to look at various costs and identify the minimum costs for BRP decommissioning. I have been briefed by WEKessler and JSRang concerning the results of the decommissioning study as applicable to BRP spent nuclear fuel shipments. The least cost alternative for BRP is to maximize BRP's use of our DOE allocations , however, BRP cannot utilize all the authorized shipments, therefore the following scenario is offered for your approval. DOE has authorized CPCo 2.5 MTU worth of SNF shipments in the second year (1999), 87.3 MTU~ in the third year (2000), 2.7 MTU the fourth year (2001) and 27.3 MTU in the fifth year (2002). Fuel must decay five years in the spent fuel pool before it can be shipped via dry cask storage. Hence the fuel shipped in the year 2000 must be discharged into the spent fuel pool during the year 1995. BRP's spent fuel inventory is as follows: Present 1993 end of cycle 26 1994 end of cycle 27 1995 end of cycle 28 # of assemblies discharge (+22) discharge (+20) discharge (+20) allocation = 294 316 336 356 for

BRP gets the first the year 1999.

of 2.5 MTU = 18 assemblies

BRP remaining assemblies for possible 2000 = 356 - 18 = 338 assemblies. 3. 338 BRP assemblies = 46.9 MTU worth

shipment

in year

of allocation.

0100195S

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Palisades gets the remaining 87.3 allocation for the year 2000.

- 46.9

= 40.4

MTU worth

of

40.4 MTU of Palisades spent fuel assemblies assemblies depending on which ones we ship.

= from 94 to 100 for

BRP gets the third allocation of 2.7 MTU = 22 assemblies fuel discharged in 1996 and shipment in the year 2001.
7o

BRP/Palisades similar split in the year 2002 for the 27.3 MTU allocation as was done in 2000, (ie, 20 assemblies for BRP = 2.7 MTU and balance of 24.6 MTU = 61 Palisades assemblies.

A meeting is requested in order to roach consensus regarding the split of our authorized DOE allocations between BRP and PAL. I recommend Thursday, February 4, 1993 after lunch, ie, 1:00-3:00. Paul Kluskcwski/Bud Gerling is requested to obtain a meeting room location and finalize the meeting date and time. It is my intent that following the meeting, GRBoss commit to filling out two (2) Delivery Commitment Schedule (DCS) forms (attached), one for the year 1999 and one for the year 2000 and PJKluskowski complete one form for the agreed balance shipment in the year 2000. Our DOE contract requires at least a 63 month notification, however, it is in our best interest to submit our notification as early as possible in order not to lose it to a "squeekier wheel" that would cause re-allocation of priorities (eg, Trojan, Rancho Seco,--~m~ Yankee, LaCrosse, etc).

~0!001956

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COIISUmors Powor April 1993 13,
US Department Energy of Contracting Officer Office Placement Admin of and PR-322.1 1000 IndependenceAvenue, SW Washington, OC 20585 DearMs Linda Stroud: Our contract for Disposal SpentNuclear of Fuel and/orHigh LevelRadioactive Wastespecifies underArticle V.B, the requirement submitDelivery to Co~l~itment Schedules sixty-three (63) months advance our intended in of shipment date. DOE letterdatedMarch4, 1992 specifies that "the allocations the 1991 in Annual Capacity Report (ACR) should be the basis for the OCSsubmittals." The ACR established Consumers PowerCompany's firstyear allocation 0 MTU, at secondyearallocation 2.5 MTU and thirdyear allocation 87.3 MTU. The at at March4, 1992 letterfurther requests to submitas many allocations us as possible assistthe DOE in planning the Federal to of WasteManagement System (FWMS). Attached are Consumers PowerCompany's completed DCS formsfor our firsttwo allocations. services The underour contract, per Article are required II to begin"not laterthan January 31, 199B".Sinceour firstyear allocation is zero,the attached DCS formsreflect our allocations the years1999 and for 2000. The instructions permitdivision the allocations of between our Big Rock Point and Palisades Plantsas we deem appropriate. Sinceby ]998,Big Rock Point will no longerhave full core discharge capability, is our intentto it maximize use of our a]locations Big Rock Pointdeliveries. ba]ance for The remaining afterassignment from Big Rock Pointhas been designated for Palisades. Big Rock Pointwill actually lose full core discharge capability 1996.If in additional allocations shouldbecomeavailable the firstyear,1998, for Consumers Power Company requests the opportunity to utilize someof those additional allocations for our Big Rock Point discharged fuel. Weunderstand that Prtic]e V.E. of our standard contract permits the exchange approved of DCS'sbetweenpurchasers. you shouldbecomeawareof any approved If DCS's that are available for exchange from 1998 for a latertime,pleasefeel free to informthe partyof our request for exchange ,otlfyus of any party or desiring such exchange. Our 1999 allocation 2.5 MTU is divided of into four (4) DCS's,all assigned Big Rock PointPlant.They are divided follows: as

01001996

m.

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2

DCS # 99-1201-02 99-1201-03 99-1201-04

Description 5 Assemblies 14 Assemblies Non fuel components

HTU 0.59 ~ 1.647 0.10~

Specific pin and assembly identification information attached each DCS. is to Our 2000 allocation of 87.3 HTUis divided such that Big Rock Point Plant is designated 44.32 MTUtotal and the balance of 42.98 ~ is designated to Palisades Plant. The Big Rock Point Plant allocations follows: DCS # 00-1201-01 00-1201-02 00-1201-03 are divided into three (3) DCS's, Description 30 Assemblies 287 Assemblies - ~6 ~ ~20_JLcsegdrTt~ MTU 3.84 ~'~ 37.84 ~-,L-( 2.64 "----- ..... :

Specific assembly identification information included is for the Big Rock Point DCS's.

The Palisades Plantallocations divided are into two (2) DCS's,as follows: DCS # 00-1204-01 00-1204-02 Description 60 Assemblies ~ 47 Assemblies MTU 24.0 ~ 18.98 L~.t~'~

Specific assembly identification information not included is with the Palisades DC$ forms. If you have any questions require or more information concerning attached the nine (9) DCS forms,pleasefeel free to contact the respective plantcontact personidentified the DCS formsor me at (517)788-0665. on Yoursverytruly,

ThomasC Bordtne NuclearFuel SupplyDirector TCB-93-34 CC: USDOE ChiefLogistics and Utility Interface Branch Officeof Nuclear Radioactive WasteManagement RW-432 1000 Independence Avenue, SW ¯ Washington, DC20585 JCDodge,M-645A DEBarth, M-1033 JJFremeau, P24-414A PJKluskowski, PAL GRBoss, BRP KMFarr, M-877

01001997

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From: ~JShields Date: 06/18/93 subject= CC: Correcting DOS forms

CONSUMEP~ PO~/ER COMPANY Internal Correspondence KJS-93-015

TCMort, Big Rook Point RJKluskowski, Palisades

References:

1) 2)

To Thomas

07/23/93.

C. Bordine

(OPec)

From Beth Tomasoni

(DOE),

TCB-93-12, To GRBoes (CPCO}, TCBordine (CPCo} 02/01/93. To Linda Stroud (DOE),

RJKluskowski

(CPCo),

From

3)

From TCBordins

(CPCo},

04/13/93f (DCS's)

P~ference 1 ask for corrections to the Delivery commitment Schedule's sent in Reference 3. This letter will address those corrections.

PC$ ~O, 99-~01-4374-°I The DOE rejected the DOS because the earliest discharge date 2.6, 03/23/74 corrse~x~nded to Cycle iI fuel which was reported to be all shipped off mite. The data for these fuel pins was reported incorrectly. The range of dates should be 06/02/74 to 09/26/93 which corresponds to Cyelea 12 and 26. The Cycle 26 RW-659 is assumed to be submitted this year, and the piece list has been updated to reflect the cycle discharge date of each item. Corrected DCS attached. pCS No. 99v1201-4374-02 DOE Accepted. Copy with actual pCS Nor 99-~201-4374-03 DOE Accepted. Copy with actual

cycle base discharged

dates attached.

cycle base discharged

dates attached.

DOS NO. 99-1201-4374-04 The DOE rejected the DCS because the present process does not handle non-fuel material. This DCS is resubmitted as a single BWR fuel assembly with the full range of acceptable delivery dates. The intention is to change the DOS later as the DOE expands its process. pcs No. 00-~01-4374-o1 DOE Accepted. copy with actual cycle base discharged dates attached.

pCS No. q0-~20~-4374-0~ The DOE rejected the DCS because the discharge dates 2.6, do not correspond to the end of Big Rock Point Cycles. Big Rock Point predicted discharge dates into the future and the DOE does not want this. The DOS has been revised to reflect only assemblies discharged as of the latest cycle, Cycle 26 06/26/93. corrected DCS attached. pcs ~or 00-~01-4374-03 The DOE rejected the DCS because the discharge dates 2.6, do not correspond the end of Big Rock Point Cycles. Big Rock Point predloted discharge dates into the future and the DOE does not want this. The DCS has.been deleted since it deals only with future discharge assemblies. to

01001966

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pcs NO. 00-1204-4374-01 The DOE rejected the DCS because the Identification number was unacceptable. Palisadea assumed that the 12 digit number had to be unique, however the DOE requests that the purchaser or contract number be sequenced per year. Given this and the above DOS being deleted the ~CS number should be 00-1204-4374-03. pC~ No. 00-1204-4374-02 The DOE rejectsd the DCS bacause the Identification number was unacceptable. Palisades assumed that the 12 digit number had to be unlqu~, howaver the DOE requests that the purchaser or contract number be sequenced per year. Given this and the above DOS being deleted the DOS number should be 00-1204-4374-04. Biq Rock Point cask The Rig Rock Point crane is rated for 75 tons, howaver it is limited to only 25 tons over tha spent fuel paul. The p~ssible loading of shipping caska will hal Usa the 24 ton transfer cask from SFP to the 60 ton Shipping Cask I) on the reactor deck. Move the 60 ton shipping cask to the floor of ccntainmant from the 2} reactor deck. Truck the 60 ton shipping cask off site. 3) Palisades Cask To ba address in a later letter.

010O1967

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To= From: Date: Subject: CO:

"~ RWSinderman, P24-401 KJShlelds, Big Rock Point~~ % t ~t''~ 08/16/93 SNM Inventory to 2007 based on DCS's TCMoct, Big R~ck Point RJKluskowskl, Rx Eng-Palisades RHHarrington, P24-606 TCBordine, P24-602

CONSDM~RS POWER COMPANY Internal Correspondence KJS-93-014

References: I)

KJS-93-006 "SNM Shipping DCS forms and draft schedule", To TCBordine (CPCo), From KJShields(cPco), 02/24/93. TCB-93-12 TO GRBosS (CPCO), RJKluskowski (CPCO), TCBordine {CPCo}, 02/01/93 To Thomas Eordlne (CPCo), From M. Detmer Contracting Officer, office of Placement and Administration (DOE), 03/04/92 "F~LISADES Fuel Schedule to End of Plant Life", RJKluskowski (CPCo} 04/02/93. GRB 93-15 "FSDD For 18 Fuel", To TCBordine (CPCo}, From GRBoas (CPCO), 05/18/93.

2) 3) 4) s)

In response to our discussion 08/16/93 the following pages provide an estimate of the fuel ship,ants as per our planned 10CFR961 Delivery commitment Schedule's (DOS's). The following assumptions are made in the development of the table. BRP ASSUMPTIONS Last core will off loaded on 05/01/2000. 2. There will be four more reloads at BRP i8, I9, IA, and ID 3. Reloads IS, I9, IA, end IB will average 131704 gms/aaaembly BRP will have priority over Palisades in the DOE allocations. 4. BRP will ship the smaller items first. 5. HTU - Initlal Pu + initial U 6. 7. The fuel that has decayed 5 years in November of the year 2000 will get shipped out ~n the year 2000. 1. 2. There will be Mine more reloads between 1994 and 2007. Each reload will be 60 ass~lies. Each Fuel Assembly ks 0.4 MTU.

01001992

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DOE ALLOCATION MTU Reference 3 0.0 1999" 2.5

BRP ALLOCATION Reference 1 O. 0 MTU 2.40 MTU 19 Assemblies 188 pins 44.32 HT~ 337 Assemblies " 0.0 MTU 2.63 MTU 20 Assemblies 2.63 MTU 20 Assemblies 0.00 MTU

POSSIBLE PALISADES ALLOCATION

0.O ,MTU 0.i0 MTU Assemblies pine 42.98 107 Aee~mbllme 2.70 MTU 6 Asee,,mbliee 24.66 ~U 61 Aes,e~blies 0.87 MTU 2 ASs,e~.b, lies 26.50 MTU 66 Ass..e~blies 0.0 MTU

2000* 2001 2002 2003 2004 2005 2006 2007 Total

87.3 2.7 27.3

3.5
26.5 0.0 2.8

0.00 MTU 2.80 MTU 21 kssembllee 8.30 MTU 63 Assemblies 63.06 MTU 480 Assemblies 188 pins

0.0 MTU 22.50 MTU 56 Assemblies 120.34 MTU ? pins

30.8
183.4

*

DCS's submitted to DOE, must be submitted 63 month~ prior to shipment.

BRP SUmmARY i. 441 locations in BRP SFP 2. 84 locations in ~ R~sctor

1993 1994 1995 1996 1997 1996 - 1999 2000 2001 2002 2003 2004 2005 2006 2007 ¯ NO Full

0 0 0 0 0 O t9 337 0 20 20 0 0 21 63 Core Off

22 20 20 20 0 20 0 0 0 0 0 0 0 0 0 Load

316 336 356 376 376 396 377 124 124 104 84 84 84 63 0

* ~ ~ ~

84 84 84 84 84 84 84 0 0 O 0 0 0 0 0

400 420 440 460 460 480 461 124 124 104 B4 84 84 63 0

01001993

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pALISADES SUMM~RY TO END-OF INITIAL LICENSE i. 857 locations in pALISADES SFP 204 locations in pALISADES Reactor 2. Assemblies Shim~d 0 0 0 0 0 0 0 107 6 61 2 66 0 0 56 ? Assemblies ~ 60 60 0 60 60 0 60 60 60 0 60 60 0 60 0 ? Assemblies ~ ~ 733 793 * 793 * ~ 853 887 * 887 * " 887 887 * 857 * 887 * ~ 887 887 * 887 * 887 " ~ 887 " ? Assemblies In Reactor 204 204 204 204 204 204 204 204 204 204 204 204 204 204 204 ? Assembliee ~ 937 997 997 1057 1117 ** 1117 ** 1177 "* 1130 ** 1184 ** 1123 ** 1181 ~* 1175 ** 1175 ** 1235 ** 1179 ** ?

~ 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008+

+ 26 + 26 + 86 + 39 + 93 + 32 + 90 + 84 + B4 +144 + 88

No Pull core off load No Room i~ the Pool or Reactor, storage ~T~ CASES PALISADES I. 887 locations 2. 204 locations 3. 24 Assemblies Assemblies 1993 1994 1995 1996 1997 1958 1999 2000 2001 2002 2003 2004 2005 2006 2007 ~008+ 0 0 0 0 0 0 0 107 6 6~ 2 66 0 0 56 ?

nnn

have to 90 to alternate

SUMMARY TO END-OF INITIAL in PALISADES SFP in PALISADES Reactor per Cask ~ssemblles 685 481 355 445 481 457 517 423 427 367 401 371 347 407 303 ?

LICENSE

Assemblies 60 60 0 60 60 0 60 60 60 0 60 60 0 60 0 ?

Assemblies 48 312 408 408 432 456 456 504 552 552 576 600 624 624 672 ?

~ssemblles 204 204 204 204 204 204 204 204 204 204 204 204 204 204 204 ?

Aeaamblles 937 997 997 1057 1117 1117 1177 1130 1184 1123 I181 1175 1175 1235 1179 ?

01001994

14
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