NG-09-0860, Response to Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate

Response to Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate

ML093440059
Person / Time
Site:	Duane Arnold
Issue date:	12/01/2009
From:	Costanzo C NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-09-0860
Download: ML093440059 (21)

Text

NEXTera ENERGYP DUANE ARNOLD December 1, 2009 NG-09-0860 10 CFR 50.75 10 CFR 50.54 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Response to Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate

Reference:

Request from NRC to NextEra Energy Duane Arnold, dated November 9, 2009, "Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate" (ADAMS Accession No. ML093140630)

By the reference above the Nuclear Regulatory Commission Staff (NRC) issued a Request for Additional Information (RAI) related to the Irradiated Fuel Management Program, and the Preliminary Decommissioning Cost Estimate provided by NextEra Energy Duane Arnold. NextEra Energy's responses to the Staff's RAI are provided in the Enclosures to this letter.

Should you have questions regarding NextEra Energy's responses to the Staff's RAI, please contact Licensing Manager, Steve Catron at (319) 851-7234.

Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC ,/,40cI NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

NG-09-0860 December 1, 2009 Page 2 of 2 Enclosures (4) cc: Administrator, Region III, USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC

NG-09-0860 December 1, 2009 Page 1 of 8 ENCLOSURE 1 Response to Request for Additional Information to Support the Review of the Duane Arnold Energy Center Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate Irradiated Fuel Management Program RAI No. 1: Financial Assurance In order for a licensee to assume an earnings credit on its decommissioning funds over a DECON or SAFESTOR period that is greater than a 2 percent real rate of return, the licensee must be able to recover total decommissioning costs through rates set by itself or a regulatory authority, 10 CFR 50.75(e)(ii)(A). Such rates must be subject to adjustment upwards during the SAFESTOR period following the permanent shutdown of the plant if the actual rate of growth of the decommissioning funds does not meet or exceed the approved higher real earnings rate. Please provide a statement and supporting references or documents that demonstrate DAEC will be able to receive upward adjustments from ratepayers to its decommissioning funds, if necessary, following permanent shutdown. FPL stated that the Corn Belt Power Cooperative (CBPC) is a 10% owner and Central Iowa Cooperative (CIPCO) is a 20% owner and both have an exempt status under IRS ruling. CIPCO and CBPC both claim a higher rate of return although both CIPCO and CBPC rates are not authorized by any state or federal agency but are adjusted annually by their Board of Directors. DAEC needs to provide the documented basis, as identified above, to claim a higher real rate of return (RRR) greater than 2 percent as well as recognizing that the remaining 70 percent ownership would be subject to the 2 percent RRR.

NextEra's Response to RAI No. 1 CIPCO is a public corporation incorporated under Chapter 499 Iowa Code (2009).

CIPCO has the authority and is required to fix, establish, and collect adequate rates and other charges for electrical energy or services sold or furnished by it. CIPCO is accordingly authorized to establish its own rates and other charges through which it can recover its cost of service. CIPCO is governed by a 13 member Board of Directors that are elected by the CIPCO members. The Board of Directors is the rate making authority for CIPCO. CIPCO rates are not regulated by any state or federal authority. In a Board Resolution dated October 27, 2009, the CIPCO Board of Directors resolved that the rates and other charges for electrical energy services and the decommissioning fund be established assuming a real rate of return on the decommissioning fund of four percent. A copy of the CIPCO Board resolution is attached as Enclosure 2.

Corn Belt Power Cooperative is a public corporation incorporated under Chapter 499 Iowa Code (2009). The Cooperative has the authority and is required to fix, establish, and collect adequate rates and other charges for electrical energy or

NG-09-0860 December 1, 2009 Page 2 of 8 services sold or furnished by it. Corn Belt is governed by an 11 member Board of Directors who are elected by its members. The Corn Belt Board of Directors is accordingly authorized to establish its own-rates and other charges through which it can recover its cost of service and is the rate making authority for the Cooperative.

The Cooperative's rates are not regulated by any state or federal authority. In a Board Resolution dated October 30, 2009, the Corn Belt Board of Directors resolved that the rates and other charges for electrical energy services and the decommissioning fund be established assuming a real rate of return on the decommissioning fund of three percent. A copy of the Corn Belt Board Resolution is attached as Enclosure 3.

NextEra Energy recognizes that the remaining 70 percent ownership share would be subject to the two percent RRR.

RAI No. 2: Duane Arnold Energy Center Annual Costs The Staff requests that DAEC provide a break down of the estimated $4.1 million annual cost and identify the supporting activities that support spent fuel management for DECON option identified for the period 2026-2052, and the $5.3 million annual cost for a similar period for SAFESTOR.

NextEra's Response to RAI No. 2 In the case of Scenario 1 (DECON), the maintenance and operation of the ISFSI continues well past the completion of decommissioning and site restoration. The costs during 2026-2052 are in such a period, EnergySolutions' Dry Period (Pd) 4 -

Dry Storage Only, so that the costs correspond to the total spent fuel management costs during that period. The Scenario 1 Annual Cash Flow Table, on page 1 of 6 in Appendix E, shows an annual cost of $4.103M in the Spent Fuel category from 2026 to 2052 for Scenario 1 (DECON). Costs for Dry Pd 4 are also shown in the Appendix D Detailed Cost Tables, on page 13 of 82. A breakdown of cost components is listed on this page, with the total equal to $113.846M. When annualized over the 27.74 year duration of this period, this equates to $4.103M per year.

In the case of Scenario 2 (SAFSTOR), the maintenance and operation of the ISFSI occurs in combination with the SAFSTOR dormancy surveillance and maintenance of the power block structures. Therefore, the annual cost of $5.3 M is a combined total of license termination (10 CFR 50.75(c)) and spent fuel management (10 CFR 50.54(bb)) costs. The Scenario 2 Annual Cash Flow Table, on page 2 of 6 in Appendix E, shows an annual cost of $1.448M per year in the License Termination category and an annual cost of $3.949M in the Spent Fuel category, which total to

$5.397M in combined costs. These costs also span the years from 2026 to 2052, and correspond to both EnergySolutions' SAFSTOR Pd 6 - Dormancy With Dry Storage (License Termination) and Dry Pd 3, Dry Storage During Dormancy (Spent Fuel).

NG-09-0860 December 1, 2009 Page 3 of 8 The license termination costs of SAFSTOR Pd 6 are also shown in the Appendix D Detailed Cost Tables, on page 25 of 82. A breakdown of cost components is listed on this page, with the total equal to $41.845M. When annualized over the 28.89 year duration of this period, this equates td $1.448M per year. The concurrent spent fuel management costs of Dry Pd 3 are also shown in the Appendix D Detailed Cost Tables, on page 37 of 82. A breakdown of cost components is listed on this page, with the total equal to $135.952M. When annualized over the 34.42 year duration of this period, this cost equates to $3.949M per year.

As apparent from the Appendix D Detailed Cost Tables referenced above, staff costs represent a significant portion of costs incurred during any of these periods. Tables 6-2 and 6-6 in the report show the Scenario 1 (DECON) and Scenario 2 (SAFSTOR)

Utility staff levels, respectively. Bases for property tax, NRC 171.15 fees, insurance, and supplies and services costs are given in Section 5.0 of the report, items 26 - 30.

The basis for Utility staff salaries is given in Section 5.0, item 33.

RAI No. 3: Section 3. Cost Considerations This submittal indicated that DAEC has an existing independent spent fuel storage installation (ISFSI) with sufficient capacity to accommodate the spent fuel in the reactor building pool at shutdown. What is storage capacity of the ISFSI? At the time of shutdown, how many modules will be stored on the ISFSI? How many additional multipurpose canisters will be loaded with fuel from the pool at the time of shutdown?

NextEra's Response to RAI No. 3 The DAEC ISFSI is designed to be constructed in three phases with a combined total storage capacity of 80 NUHOMS-61 BT dry storage canisters. Each NUHOMs 61 BT has the capacity for 61 Boiling Water Reactor (BWR) spent fuel assemblies.

The reinforced concrete pad (basemat) is designed to be installed in three phases; Phase 1 is for 30 storage systems, Phase 2 is for an additional 30 storage systems, and Phase 3 is for a final 20 systems. The Phase 1 basemat was operational in 2003. The Phase 2 and 3 basemats are planned for future installation.

Appendix B of the report contains the spent fuel schedule for Scenario 1 (DECON) and 2 (SAFSTOR). Looking at the column "No Dry Modules," it can be seen that 20 modules will be stored in the ISFSI by shutdown (2014). 33 additional modules will be required after shutdown, during the years 2017 - 2019. This corresponds to 1,972 fuel assemblies transferred from the pool to dry storage during these years.

RAI No. 4: Cost Estimate and Funding for Spent Fuel Management based on DECON Methodology In the submittal, FPL estimated the cost for Spent Fuel Cooling and transfer of the fuel to dry storage is approximately $129.7 million over approximately 5 years, and

NG-09-0860 December 1, 2009 Page 4 of 8 identified several supporting activities. For each identified activity, provide a cost breakout associated with each activity.

NextEra's Response to RAI No. 4:

Table 6-1 of the report, on page 36 of 58, includes Scenario 1 (DECON) Dry Pd 2 -

Spent Fuel Cooling and Transfer to Dry Storage, with a duration of 4.99 years and a total cost of $129.7M. The costs for Dry Pd 2 are also shown in the Appendix D Detailed Cost Tables, on page 11 of 82. A breakdown of cost components is listed on this page, each of which is further broken out into Labor, Equipment, Disposal, Other, and Contingency costs. A discussion of contingency costs and their assignment is included in the report on pages 16 and 17 of 58.

Table 6-5 of the report, on page 42 of 58, includes Scenario 2 (SAFSTOR) Dry Pd 2

- Spent Fuel Cooling and Transfer to Dry Storage, with a duration of 4.99 years and a total cost of $129.7M. The costs for Dry Pd 2 are also shown in the Appendix D Detailed Cost Tables, on page 36 of 82. A breakdown of cost components is listed on this page, each of which is further broken out into Labor, Equipment, Disposal, Other, and Contingency costs.

Costs for Purchase of Dry Storage Modules are related to both the costs per module and the number of modules required. The cost bases for dry storage canisters and Horizontal Storage Modules (HSMs) are given in Section 5.0 of the report, item 23.

Appendix B contains the spent fuel schedule for Scenarios 1 and 2, which gives the number of dry storage modules purchased following shutdown (33) for either scenario.

Staff costs are related to both staffing levels and salaries. Table 6-2 in the report shows Scenario 1 (DECON) staff levels. Table 6-6 in the report shows Scenario 2 (SAFSTOR) staff levels. The basis for utility staff salaries is given in Section 5.0, item 33. Bases for property tax, NRC 171.15 fees, insurance, and supplies and services costs are given in Section 5.0 of the report, items 26 - 30.

Preliminary Decommissioning Cost Estimate RAI No. 5: Section 1.0 Executive Summary In the submittal, FPL identified 4 possible decommissioning scenarios for DAEC, and provided the total cost for each option, including spent fuel costs and greenfield costs. Later in the cost study, FPL identified its annual costs associated with each option. However, FPL did not provide an analysis using the decommissioning funds to demonstrate that adequate funds are available to address these options. FPL needs to provide the supporting analysis for each of the identified alternatives or, at a minimum, for the selected option based on the trust fund balance as of December 31,2008.

NG-09-0860 December 1, 2009 Page 5 of 8 NextEra's Response to RAI No. 5 As stated in NextEra Energy's November 5, 2009 "Response to Requests for Additional Information," concerning decommissioning funding assurance (Reference 1), NextEra Energy has chosen to rely upon its preliminary site-specific estimate of the cost to decommission the DAEC using the SAFSTOR method, which complies with 10 CFR 50.75. NextEra Energy has not made a final determination of the actual decommissioning approach for DAEC, but the SAFSTOR option has been selected for the purpose of demonstrating the adequacy of DAEC's decommissioning funding. NextEra Energy may choose a different decommissioning option in the future, recognizing that the chosen option must meet NRC requirements for decommissioning funding. Specifically, renewal of the DAEC operating license may lead NextEra Energy to change its planned decommissioning methods for funding assurance purposes. NextEra Energy filed a license renewal application for DAEC on September 30, 2008 (Reference 2).

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site specific estimate under § 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." Thus, a site-specific cost estimate may be used for demonstrating decommissioning funding assurance, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2)." (Section 1.1.1 in References 4 and 5.)

Scenario 2 of the DAEC preliminary decommissioning cost estimate considers the costs to decommission the facility assuming (1) no renewal of the facility operating license, and (2) the use of a SAFSTOR period. NextEra Energy's revised plan for demonstrating decommissioning funding assurance is based upon this scenario - a period of safe storage until 2068, at which time decommissioning activities will commence.

The decommissioning trust funds for DAEC have increased since December 31, 2008. As of September 30, 2009, the total decommissioning trust fund balance including the shares of all three joint owners is approximately $232,709,000, compared to the December 31, 2008 balance of $203,073,403. Table 1 of utilizes the September 30, 2009 DAEC decommissioning trust fund balance in lieu of the December 31, 2008 balance. Additional information about Table 1 of Enclosure 4 can be found in NextEra Energy's November 5, 2009 "Response to Requests for Additional Information," concerning decommissioning funding assurance (Reference 1). Because this particular RAI requests an analysis based on the balance as of December 31, 2008, NextEra Energy provides that additional analysis in Table 2 of Enclosure 4.

NG-09-0860 December 1, 2009 Page 6 of 8 In each Table, the decommissioning trust fund ending balance is escalated each year by the 2% real rate of return allowed pursuant to 10 CFR 50.75(e)(1 )(i) for NextEra's share, and by the 3% and 4% real rates of return authorized by Corn Belt's and CIPCO's rate-setting authorities, respectively, as allowed under 10 CFR 50.75(e)(i) and discussed in the answer to RAI No. 1. After the annual escalation, the estimated annual costs are subtracted from the annual total decommissioning fund balance and the planned contributions of CIPCO and Corn Belt are added. The tables include only license termination costs and do not include spent fuel management or non-radiological greenfield costs.

As can be seen from the information provided in Table 1 and 2, the required funding for a SAFSTOR decommissioning, approximately $579 million, is greater than the current (September 30, 2009) NRC formula amount per 10 CFR 50.75(b) and (c) of

$507,291,842. It is also greater than the December 31, 2008 NRC formula amount of $503,764,690, which was stated in NextEra Energy's March 27, 2009 Decommissioning Funding Status Report (Reference 3). Therefore, the site-specific SAFSTOR analysis complies with the NRC's position outlined in Section 1.1.1 of Reference 4 that a site-specific cost estimate may only be used if it is equal to or greater than the NRC formula amount.

As explained in Reference 1, this SAFSTOR analysis demonstrates that when the September 30, 2009 decommissioning trust fund balance is escalated at the allowable rates and compared against the annual figures for the SAFSTOR period studied in the DAEC preliminary decommissioning cost estimate, a significant surplus would remain at the end of the decommissioning project. Accordingly, NextEra Energy concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning DAEC.

However, as shown in Table 2 of Enclosure 4, when using the fund balance as of December 31, 2008, NextEra Energy's 70% share would project to be under-funded during the last two years of decommissioning by approximately $24 million. Several points are important to consider with respect to that projected under-funding. First, while NextEra Energy's share would be projected to be under-funded, the total fund including the shares of all three joint owners would be fully funded. This is demonstrated by the total surplus at the end of the decommissioning period in Table

2. Second, NextEra maintains a $93 million parent guaranty (which was in place on December 31, 2008) to provide additional decommissioning funding assurance of its decommissioning obligations. Finally, as discussed above, gains in the fund during 2009 have eliminated the under-funding that would be projected for NextEra Energy's share based upon its year-end 2008 balance.

As stated in Reference 1, while the $93 million parent guaranty is no longer necessary to provide partial decommissioning funding assurance, NextEra Energy will maintain the parent guaranty in place until after it receives NRC approval of the revised decommissioning funding plan.

NG-09-0860 December 1, 2009 Page 7 of 8 RAI No. 6: Section 2.1 Study Objective The submittal focuses on DECON as the preferred option for decommissioning, and Section 2.1 provided detailed discussions on the preferred DECON option as well as 3 other options. The Irradiated Fuel Management Program submittal uses the DECON option as the mechanism for addressing the radiological and spent fuel management costs. FPL needs to confirm which option is the preferred decommissioning option.

NextEra's Response to RAI No. 6 NextEra has not made a final determination of the actual decommissioning approach for DAEC, but the SAFSTOR option has been selected for the purpose of demonstrating the adequacy of DAEC's decommissioning funding.

RAI No. 7: Section 3.4 Site Specific Considerations The submittal did not address why the site specific cost estimate was lower than the minimum amount established by 10 CFR 50.75(a)(1) and since it was lower, the analysis must be based on the higher amount. Since the site specific cost estimate is lower than the formula amount, FPL needs to address, in detail, why the site specific cost is less than the formula amount.

NextEra's Response to RAI No. 7 As can be seen from the information provided in Tables 1 and 2 of Enclosure 4, the required funding for a SAFSTOR decommissioning, approximately $579 million, is greater than the current (September 30, 2009) NRC formula amount per 10 CFR 50.75(b) and (c) of $507,291,842. It is also greater than the December 31, 2008 NRC formula amount of $503,764,690, which was stated in NextEra Energy's March 27, 2009 Decommissioning Funding Status Report (Reference 3). Therefore, the site-specific SAFSTOR analysis complies with the NRC's position outlined in Section 1.1.1 of Reference 4 that a site-specific cost estimate may only be used if it is equal to or greater than the NRC formula amount.

References

1. Letter from M. Nazar to NRC, "Response to Requests for Additional Information,"

dated November 5, 2009. (ML093130065)

2. Letter from R. Anderson to NRC, "Duane Arnold Energy Center Application for Renewed Operating License TSCR-109," dated September 30, 2008.

(ML082980480)

3. Letter from R. Hughes to NRC, "Decommissioning Funding Status Reports,"

dated March 27, 2009. (ML090900306)

NG-09-0860 December 1, 2009 Page 8 of 8

4. Regulatory Guide 1.159 Revision 1, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," dated October 2003.

5. Draft Regulatory Guide-1229, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," dated June 2009.

ENCLOSURE2 CIPCO Board Resolution 1 Page Follows

IOWA 83 CEDAR RAPIDS CERTIFICATE I, Dale Walkup, do hereby certify:

That I am the duly elected, qualified and acting Secretary-Treasurer of CENTRAL IOWA POWER COOPERATIVE (hereinafter called the "Cooperative") and the keeper of its records; that at aregular meeting of the Board of.Directors of the Cooperative with a quorum of directors present in person held October 27, 2009, the following resolution was unanimously adopted:

WHEREAS the Board of Directors of CIPCO is required to fix, establish, and collect adequate rates and other charges for electrical energy or services sold or furnished by it, and WHEREAS for the purpose of establishing rates and charges necessary to recover its cost of service, including the DAEC decommissioning fund, the Board of Directors of CIPCO has assumed a Real Rate of Return on the decommissioning fund of four per cent, and BE IT RESOLVED BY THE BOARD OF DIRECTORS OF CIPCO that the rates and other charges for electrical energy services and the decommissioning fund be established assuming a Real Rate of Return on the decommissioning fund of four percent.

That said resolution has, not been amended, altered, rescinded or modified and is presently in full force and effect.

IN WITNESS WHEREOF, I have executed this certificate and attached a corporate seal of the Cooperative this 27 day of October 2009.

S ecrie--Wiqreasurer ....

ENCLOSURE3 Corn Belt Board Resolution 1 Page Follows

CORN BELT POWER COOPERATIVE Humboldt, Iowa CERTIFICATE I, Scott Stecher, do hereby certify that I am the duly appointed, elected, qualified and acting Secretary of Corn Belt Power Cooperative and that the following is a true and correct extract of minutes duly.adopted by the Board of Directors of Corn Belt Power Cooperative at its meeting held October 30, 2009 WHEREAS, the Board of Directors is required to fix, establish, and collect adequate rates and other charges for electrical energy or services sold or furnished by it; and WHEREAS, for the purpose of establishing rates and charges necessary

• torecover its cost of service, including the cost of decommissioning the Duane Arnold Energy Center (DAEC), the Board of Directors has assumed a Real Rate of Return on the DAEC decommissioning trust fund of three percent; IT IS, THEREFORE, RESOLVED that the rates and other charges for electrical energy services and the DAEC decommissioning trust fund be, and they are hereby, established assuming a Real Rate of Return on the DAEC decommissioning trust fund of three percent.

and that the action taken and/or resolutions adopted as above set out have never been rescinded, altered, amended, M`odified, or repealed, and are of the date hereof in full force and effect.

IN WITNESS WHEREOF, I have hereunto set my hand and attached the seal of the Cooperative this 30ýth day of October A.D., 2009 I(Se Secretary j 00 134757!OXk i

ENCLOSURE 4 Tables 1 and 2 6 Pages Follow

TABLE 1 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 9/30/09: (Thousands of Dollars)

Next Era 184,620 70% ownership CIPCO 31,985 20% ownership Corn Belt 16,104 10% ownership Total Trust Fund Balance 232,709 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D F F H I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost 0% of expenses Contributions Contributions expenses Contributions Contributions 2009 T184,620 32,485 16,604 233,709 500 500 2010 188,312 34,784 17,602 240,699 1,000 500 2011 - 192,079 37,176 18,880 248,135 1,000 750 2012 7,908 7,908 190,385 38,081 19,656 248,122 1,000 1,000 2013 9,100 9,100 187,822 38,784 20,585 247,192 1,000 1,250 2014 42,672 42,672 161,708 32,801 18,436 212,946 1,000 1,500 2015 1,789 1,789 163,690 33,756 18,810 216,256 2016 1,789 1,789 165,712 34,748 19,195 219,655 2017 1,789 1,789 167,774 35,780 19,592 223,146 2018 1,789 1,789 169,877 36,854 20,001 226,732 2019 13,308 13,308 163,959 35,666 19,270 218,895 2020 3,794 3,794 164,582 36,334 19,469 220,385 2021 3,794 3,794 165,218 37,029 19,674 221,920 2022 3,794 3,794 165,867 37,751 19,885 223,502 2023 3,794 3,794 166,528 38,502 20,102 225,132 2024 3,794 3,794 167,203 39,283 20,325 226,812 2025 2,036 2,036 169,122 40,448 20,732 230,301 2026 1,448 1,448 171,491 41,776 21,209 234,475 2027 1,448 1,448 173,907 43,157 21,700 238,764 2028 1,448 1,448 176,371 44,594 22,206 243,172 2029 1,448 1,448 178,885 46,088 22,728 247,701 2030 1,448 1,448 181,449 47,642 23,265 252,356 2031 1,448 1,448 184,065 49,258 23,818 257,141 2032 1,448 1,448 186,732 50,939 24,388 262,059 2033 1,448 1,448 189,453 52,687 24,975 267,115 2034 1,448 1,448 192,229 54,505 25,579 272,313 2035 1,448 1,448 195,060 56,395 26,202 277,657

TABLE 1 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 9/30/09: (Thousands of Dollars)

Next Era 184,620 70% ownership CIPCO 31,985 20% ownership Corn Belt 16,104 10% ownership Total Trust Fund Balance 232,709 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D E F G H I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost -. 0% of expenses Contributions Contributions expenses Contributions Contributions 2036 1,448 1,448 197,947 58,362 26,843 283,152 2037 1,448 1,448 200,893 60,406 27,503 288,803 2038 1,448 1,448 203,897 62,533 28,184 294,614 2039 1,448 1,448 206,961 64,745 28,884 300,591 2040 1,448 1,448 210,087 67,045 29,606 306,738 2041 1,448 1,448 213,275 69,437 30,349 313,062 2042 1,448 1,448 216,527 71,925 31,115 319,567 2043 1,448 1,448 219,844 74,513 31,904 326,260 2044 1,448 1,448 223,227 77,203 32,716 333,147 2045 1,448 1,448 226,678 80,002 33,553 340,233 2046 1,448 1,448 230,198 82,912 34,415 347,525 2047 1,448 1,448 233,788 85,939 35,302 355,030 2048 1,448 1,448 237,451 89,087 36,216 362,754 2049 1,448 1,448 241,186 92,361 37,158 370,705 2050 1,448 1,448 244,996 95,766 38,128 378,890 2051 1,448 1,448 248,882 99,307 39,127 387,317 2052 1,448 1,448 252,847 102,990 40,156 395,993 2053 1,448 1,448 256,890 106,820 41,216 404,926 2054 2,184 2,184 260,499 110,656 42,234 413,389 2055 2,303 2,303 264,097 114,621 43,271 421,989 2056 2,303 2,303 267,767 118,746 44,339 430,851 2057 2,303 2,303 271,510 123,035 45,439 439,983 2058 2,303 2,303 275,328 127,496 46,571 449,395 2059 2,303 2,303 279,222 132,135 47,738 459,096 2060 2,303 2,303 283,195 136,960 48,940 469,095 2061 2,303 2,303 287,247 141,978 50,178 479,402 2062 2,303 2,303 291,379 147,196 51,453 490,028

TABLE 1 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 9/30/09: (Thousands of Dollars)

Next Era 184,620 70% ownership CIPCO 31,985 20% ownership Corn Belt 16,104 10% ownership Total Trust Fund Balance 232,709 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D E F G H I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost 0% of expenses Contributions Contributions expenses Contributions Contributions 2063 2,303 2,303 295,595 152,623 52,766 500,984 2064 2,303 2,303 299,895 158,268 54,119 512,281 2065 2,303 2,303 304,280 164,138 55,512 523,930 2066 9,354 9,354 303,818 168,832 56,242 528,893 2067 14,366 14,366 299,838 172,712 56,493 529,044 2068 63,862 63,862 261,132 166,849 51,802 479,782 2069 79,225 79,225 210,897 157,678 45,433 414,008 2070 96,091 96,091 147,851 144,766 37,187 329,805 2071 80,953 80,953 94,141 134,366 30,207 258,715 2072 47,681 47,681 62,647 130,205 26,345 219,198 2073 18,654 18,654 50,842 131,682 25,270 207,795 Total 579,397 579,397 Calculations:

Column C = (B)*(l +.00)^(current year - 2008) or Column C = Column B Column D = (Column D (Previous year's fund balance)* (1+.02)) - (Column C* 0.70) (70% of current year's decommissioning expenditures)

Column E = (Column E (Previous year's fund balance)* (1+.04)) - (Column C* 0.20) (20% of current year's decommissioning expenditures) + Column H (current year's contributions)

Column F = (Column F (Previous year's fund balance)* (1+.03)) - (Column C* 0.10) (10% of current year's decommissioning expenditures) + Column I (current year's contributions)

Column G = Column D + Column E + Column F

Table 2 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 12/31/08: (Thousands of Dollars)

Next Era 163,576 70% ownership CIPCO 26,112 20% ownership Corn Belt 13,386 10% ownership Total Trust Fund Balance 203,074 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D E F G H I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost 0% of expenses Contributions Contributions expenses Contributions Contributions 2009 163,576 26,612 13,886 204,074 500 500 2010 166,848 28,676 14,803 210,327 1,000 500 2011 - - 170,184 30,824 15,997 217,005 1,000 750 2012 7,908 7,908 168,053 31,475 16,686 216,213 1,000 1,000 2013 9,100 9,100 165,044 31,914 17,526 214,484 1,000 1,250 2014 42,672 42,672 138,474 25,656 15,285 179,415 1,000 1,500 2015 1,789 1,789 139,991 26,324 15,565 181,880 2016 1,789 1,789 141,539 27,020 15,853 184,411 2017 1,789 1,789 143,117 27,743 16,149 187,009 2018 1,789 1,789 144,727 28,495 16,455 189,677 2019 13,308 13,308 138,306 26,973 15,618 180,897 2020 3,794 3,794 138,417 27,293 15,707 181,416 2021 3,794 3,794 138,529 27,626 15,799 181,954 2022 3,794 3,794 138,644 27,972 15,893 182,509 2023 3,794 3,794 138,761 28,332 15,991 183,084 2024 3,794 3,794 138,880 28,707 16,091 183,678 2025 2,036 2,036 140,233 29,448 16,370 186,050 2026 1,448 1,448 142,024 30,336 16,716 189,076 2027 1,448 1,448 143,851 31,260 17,073 192,184 2028 1,448 1,448 145,714 32,221 17,440 195,375 2029 1,448 1,448 147,615 33,220 17,819 198,653 2030 1,448 1,448 149,554 34,259 18,209 202,021 2031 1,448 1,448 151,531 35,340 18,610 205,481 2032 1,448 1,448 153,548 36,464 19,024 209,035 2033 1,448 1,448 155,605 37,633 19,449 212,687 2034 1,448 1,448 157,704 38,848 19,888 216,440 2035 1,448 1,448 159,844 40,113 20,340 220,297

Table 2 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 12/31/08: (Thousands of Dollars)

Next Era 163,576 70% ownership CIPCO 26,112 20% ownership Corn Belt 13,386 10% ownership Total Trust Fund Balance 203,074 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D F F G H _ I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost 0% of expenses Contributions Contributions expenses Contributions Contributions 2036 1,448 1,448 162,028 41,428 20,805 224,261 2037 1,448 1,448 164,255 42,795 21,285 228,334 2038 1,448 1,448 166,526 44,217 21,779 232,522 2039 1,448 1,448 168,843 45,696 22,287 236,826 2040 1,448 1,448 171,206 47,235 22,811 241,252 2041 1,448 1,448 173,617 48,834 23,350 245,802 2042 1,448 1,448 176,076 50,498 23,906 250,480 2043 1,448 1,448 178,583 52,229 24,478 255,290 2044 1,448 1,448 181,142 54,028 25,068 260,238 2045 1,448 1,448 183,751 55,900 25,675 265,326 2046 1,448 1,448 186,412 57,846 26,301 270,559 2047 1,448 1,448 189,127 59,870 26,945 275,942 2048 1,448 1,448 191,896 61,975 27,609 281,480 2049 1,448 1,448 194,720 64,165 28,292 287,177 2050 1,448 1,448 197,601 66,442 28,996 293,039 2051 1,448 1,448 200,539 68,810 29,721 299,070 2052 1,448 1,448 203,536 71,273 30,468 305,277 2053 1,448 1,448 206,594 73,834 31,237 311,665 2054 2,184 2,184 209,197 76,351 31,956 317,503 2055 2,303 2,303 211,769 78,944 32,684 323,397 2056 2,303 2,303 214,392 81,641 33,434 329,467 2057 2,303 2,303 217,068 84,446 34,207 335,721 2058 2,303 2,303 219,797 87,363 35,003 342,163 2059 2,303 2,303 222,581 90,397 35,823 348,801 2060 2,303 2,303 225,420 93,553 36,667 355,640 2061 2,303 2,303 228,316 96,834 37,537 362,688 2062 2,303 2,303 231,271 100,247 38,433 369,950

Table 2 Duane Arnold Energy Center Decommissioning Funding Plan Scenario 2: 2014 Shutdown, SAFSTOR Alternative (Thousands of Dollars)

Basis Year 2008 Fund Balance as of 12/31/08: (Thousands of Dollars)

Next Era 163,576 70% ownership CIPCO 26,112 20% ownership Corn Belt 13,386 10% ownership Total Trust Fund Balance 203,074 Annual Escalation 0%

Annual Earnings - Next Era 2%

Annual Earnings - CIPCO 4%

Annual Earnings - Corn Belt 3%

A B C D F F C H I CIPCO Corn Belt Next Era Decommissioning Decommissioning Decommissioning Trust Fund Trust Fund Balance Trust Fund Balance escalated escalated at 3% Total CIPCO Corn Belt Total Cost Balance escalated at 4% minus 20% minus 10% of Decommisioning Decommissioning Decommissioning Escalated at at 2% minus 70% of expenses + expenses + Trust Fund minus Trust Fund Trust Fund Year 50.75 Cost - 0% of expenses Contributions Contributions expenses Contributions Contributions 2063 2,303 2,303 234,284 103,796 39,355 377,436 2064 2,303 2,303 237,358 107,487 40,306 385,151 2065 2,303 2,303 240,493 111,326 41,285 393,104 2066 9,354 9,354 238,755 113,909 41,588 394,251 2067 14,366 14,366 233,474 115,592 41,399 390,464 2068 63,862 63,862 193,440 107,443 36,255 337,137 2069 79,225 79,225 141,851 95,896 29,420 267,166 2070 96,091 96,091 77,424 80,513 20,693 178,631 2071 80,953 80,953 22,306 67,543 13,219 103,068 2072 47,681 47,681 (10,625) 60,709 8,847 58,931 2073 18,654 18,654 (23,895) 59,406 7,247 42,758 Total 579,397 579,397 Calculations:

Column D = (Column D (Previous year's fund balance)* (1+.02)) - (Column C* 0.70) (70% of current year's decommissioning expenditures)

Column E = (Column E (Previous year's fund balance)* (1+.04)) - (Column C* 0.20) (20% of current year's decommissioning expenditures) + Column H (current year's contributions)

Column F = (Column F (Previous year's fund balance)* (1+.03)) - (Column C* 0.10) (10% of current year's decommissioning expenditures) +Column I (current year's contributions)

Column G = Column D + Column E + Column F