ML123550040

ISFSI Decommissioning Funding Plan

ML123550040
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	12/17/2012
From:	Mormann S Constellation Energy Nuclear Group, EDF Group
To:	Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards
References
Download: ML123550040 (37)

Text

Stephen A. Mormann VP - Financial Services & Treasurer Constellation Energy Nuclear Group, LLC 100 Constellation Way Suite 200C Baltimore, MD 21202 (410) 470-4809 CENG a joint venture of

]E December 17, 2012 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

SUBJECT:

Document Control Desk Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Specific License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-4 10 Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation General License Docket No. 72-1036 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 R.E. Ginna Independent Spent Fuel Storage Installation General License Docket No. 72-67 ISFSI Decommissioning Funding Plans (a) Letter from S. A. Mormann (CENG) to Document Control Desk (NRC), dated March 8, 2012, Status of Decommissioning Funding (ML12072A058)

(b) Letter from G. C. Creel (CCNPP) to Director, Office of Nuclear Material Safety and Safeguards (NRC), dated August 18, 1992, Revision to the ISFSI Decommissioning Plan (ML920820002)

(c) Letter from Mr. S. L. Miller (CENG) to Document Control Desk (NRC), dated November 10, 2011, Response to NRCs Request for Additional Information on License Transfer Application (ML11335A024) (Proprietary)

REFERENCES:

v-5 ý

Document Control Desk December 17, 2012 Page 2 (d) Letter from D. E. Lauver (CCNPP) to Document Control Desk (NRC), dated March 22, 2011, Submittal of Site-Specific SAFSTOR Decommissioning Cost Estimates (ML110830680)

(e) Letter from H. B. Barron (CENG) to Document Control Desk (NRC), dated November 20, 2009, Submittal of Site-Specific SAFSTOR Decommissioning Cost Estimates (ML093340088)

(f) Letter from G. H. Gellrich (CCNPP) to Document Control Desk (NRC), dated September 17, 2010, Site-Specific Independent Spent Fuel Storage Installation (ISFSI) License Renewal Application (ML102650247)

Title 10 of the Code of Federal Regulations (CFR) Section 72.30(b) requires that each holder of a license under 10 CFR Part 72 for an Independent Spent Fuel Storage Installation (ISFSI) must submit to the U.S.

Nuclear Regulatory Commission (NRC) for review and approval a decommissioning funding plan (DFP) with respect to the ISFSI. Pursuant to the requirements of 10 CFR 72.30(b), this letter forwards the 2012 DFP for the ISFSIs of Calvert Cliffs Nuclear Power Plant (CCNPP), R.E. Ginna Nuclear Power Plant (Ginna), and Nine Mile Point Nuclear Station (NMPNS). CCNPP, Ginna, and NMPNS Unit 1 (NMPI) are owned by wholly owned subsidiaries of Constellation Energy Nuclear Group, LLC (CENG). Nine Mile Point Unit 2 (NMP2) is co-owned 82% by a wholly owned subsidiary of CENG and 18% by Long Island Power Authority (LIPA).

The information provided for NMP2 includes summary statements provided by LIPA. CENG has not independently verified the information provided by LIPA.

The approach CENG has taken in preparing this DFP, and a summary of the results from the reviews and analyses performed, demonstrating decommissioning funding assurance in accordance with 10 CFR 72.30, is as follows:

Decommissioning Cost Estimate [10 CFR 72.30(b)(2), (3), and (5)]

1. CENG expects that the canisters containing the spent fuel within the ISFSIs will contain the radioactivity without leakage, and that the operation of the ISFSIs will therefore not result in radioactive contamination of the ISFSls. CENG does not expect that any onsite subsurface material associated with any of the ISFSIs will require remediation to meet the radiological criteria for license termination for unrestricted use. This assumption is discussed in greater detail in the section below under "Updated Assumption Related to ISFSI Decommissioning."

2. Because CENG does not expect the ISFSIs to be contaminated, CENG expects that the primary radiological decommissioning activities for the ISFSIs will be planning and reporting activities and a survey (as discussed in 3 below) to confirm the absence of contamination.

3. Because the CCNPP ISFSI is outside the protected area of the plant and operates under a separate license, CENG expects to perform a separate survey for the CCNPP ISFSI independent of any surveys performed for the remainder of the CCNPP site. Because the NMPNS and Ginna ISFSIs are within the protected areas of those plants and operate under the general licenses pursuant to Subpart K of 10 CFR Part 72, CENG does not expect to perform separate or additional surveys for those ISFSIs beyond the surveys performed for the sites as a whole. Nonetheless, for purposes of this submittal, CENG has assumed that we will perform separate surveys for all three of the ISFSIs.

4. The site-specific decommissioning cost studies in References (d) and (e), supporting Reference (a),

described all costs necessary for the decommissioning of the entire sites, including the ISFSIs.

Accordingly, the decommissioning cost estimates that are the basis for this DFP are consistent With and are derived from the decommissioning cost studies supporting Reference (a).

The

Document Control Desk December 17, 2012 Page 3 decommissioning cost estimates from these site-specific cost studies exceed the NRC minimum certification amount described in 10 CFR 50.75(c), in accordance with 10 CFR 50.75(b)(1).

5. Because there are so few radiological decommissioning activities for the ISFSIs as discussed in I and 2 above, the costs of those activities are expected to be relatively minimal (approximately $2 million for each ISFSI in 2012 dollars).

Decommissioning Funding Assurance [10 CFR 72.30(b)(1), (4) and (6)]

6. CENG is providing the financial assurance for the decommissioning of its ISFSIs through its existing trust funds as set forth in 7 and 8 below. No additional financial assurance is currently required.

7. For CCNPP, in accordance with 10 CFR 72.30(e)(1), trust funds have been set aside for the decommissioning of the ISFSI. These funds are held in a combination of a separate nonqualified trust fund and an allocation of a portion of the general plant qualified trust funds. The CCNPP ISFSI is licensed under a specific license. Neither the nonqualified fund nor the allocated portion of the qualified funds has been included in any of CCNPP's prior financial assurance submittals to the NRC under 10 CFR 50.75.

8. For both NMPNS and Ginna, the decommissioning of the site's ISFSI is subject to the requirements of the respective general license. Prior to the Decommissioning Planning Rule, 76 Fed. Reg. 35512 (June 17, 2011), there was no requirement for a general ISFSI licensee to submit an ISFSI decommissioning funding plan. For Ginna and NMPNS, the costs of decommissioning the ISFSIs were included in the site-specific cost estimates previously submitted in Reference (e), and the funds to decommission the ISFSI and the funds to decommission the remainder of the site are included in the same trust for each site. We include in this submission the cost of the radiological license termination decommissioning activities for the entire site, including the ISFSI.

We also provide the current total balance of trust funds, separately identify the amount of funds (on a present value basis) necessary to provide for ISFSI decommissioning, and demonstrate that the trust funds are sufficient to pay the radiological decommissioning costs of the ISFSI and the balance of the site. Refer to Attachment (2) for an accounting schedule of the separate allocation of costs and funds between the ISFSI and the balance of the site needed to conduct ISFSI decommissioning for each site. CENG will continue to assess the overall decommissioning funding status for NMPNS and Ginna in accordance with NRC requirements [e.g., 10 CFR 50.75(b)(2), 10 CFR 50.75(f)(1),

and 10 CFR 72.30(c)] and account for adequate ISFSI funding assurance, consistent with the levels described in this letter, above the level of funding necessary to provide overall plant decommissioning funding assurance.

Updated Assumption Related to ISFSI Decommissioning

9. The 1992 Calvert Cliffs ISFSI decommissioning plan assumed certain activation levels (Reference b). However, that assumption has been updated for this submittal. The Decommissioning Cost Estimate (DCE) provided in Attachment (3) sets forth the current expectations related to the absence of activation products in the ISFSI Pad, the Horizontal Storage Modules (HSMs), or subsurface material around the ISFSI that might result from neutron activation from the stored spent fuel. Current evaluations indicate that such activation products are not expected. Similarly, with the zero-leakage canisters in use, no residual contamination is expected to be left behind on the ISFSI storage pads.

10. The results of the periodic monitoring and comprehensive dose rate surveys that have been performed at all of the areas at CCNPP, NMPNS, and Ginna that can be surveyed around the ISFSI

Document Control Desk December 17, 2012 Page 4 pad, HSMs, and the ISFSI subsurface in accordance with the respective NRC licenses are consistent with the above change in assumption. To date, no external contamination or elevated dose rates have been found in the ISFSI areas. In addition, in the summer of 2012, several of the HSMs were inspected using remote cameras to satisfy NRC inquiries, and no anomalies were found.

11. Information concerning the updated assumption discussed in 9 above has previously been provided to the NRC. In November 2011, CENG submitted Reference (c) to the NRC in connection with its request that the NRC consent to certain indirect license transfers.

The specific assumption regarding activation, and its general impact on ISFSI decommissioning costs (reduction thereof),

was also specifically noted therein (Attachment 1, Response to Request for Additional Information No. 1). This change had also been reflected (but was not highlighted because it was not significant for the purposes of those reports) in the November 2009 site-specific Decommissioning Cost Estimates submitted to the NRC in March 2011 (Reference d).

12. Consistent with the above, this DFP also serves as an update to References (b), (c), (d), and (e) to reflect the current analysis of ISFSI radiological DCEs.

13. CENG also intends to incorporate this updated assumption in the pending license renewal for the specific license for the Calvert Cliffs ISFSI (Reference f).

The information supporting this DFP, as required by 10 CFR 72.30(b), is provided in Attachments (1) -

(4).

The amounts provided in these attachments are as of September 30, 2012 (unless otherwise indicated), because that is the latest date for which complete trust fund information is available. The contents of this submittal are as follows:

Attachment (1) summarizes the status of decommissioning funding for the ISFSI with respect to each facility. The content of Attachment (I) differs for CCNPP as compared to NMPNS and Ginna because of differences in the funding as described in 7 and 8 above.

Attachment (2) contains a table with summary and annual calculations of radiological license termination decommissioning cash flows and fund balances demonstrating financial assurance for each unit and ISFSI. These calculations are the basis for the summary amounts in Attachment (1),

and include the escalation of the site-specific DCEs from 2009 dollars in Attachment (3) to September 2012 dollars summarized in Attachment (1).

Attachment (3) provides the site-specific DCEs for the radiological license termination decommissioning of the ISFSIs. These DCEs are the basis for the calculations in Attachment (2),

and they are presented solely to demonstrate the adequacy of radiological decommissioning financial assurance for each ISFSI; actual decommissioning costs and schedules may vary from these DCEs.

Attachment (4) contains a separate certification page, as required under 10 CFR 72.30(b)(6),

certifying that financial assurance for decommissioning has been provided in the amount of the cost estimate for ISFSI decommissioning.

There are no new regulatory commitments contained in this letter.

Document Control Desk December 17, 2012 Page 5 Should you have questions regarding the information in this submittal, please contact Bruce Montgomery at (410) 470-3777 or bruce.montgomery@cengllc.com.

A. Mormann SAM/EMT/bjd Attachments:

(1) September 2012 ISFSI Decommissioning Funding Plan (2)

September 2012 Radiological License Termination Decommissioning Financial Assurance Summary and Supporting Annual Decommissioning Cost Estimates (3)

Site-specific ISFSI Decommissioning Cost Studies (4) Certification of Financial Assurance cc:

B. K. Vaidya, NRC M. C. Thadani, NRC N. S. Morgan., NRC J. A. Simpson, NRC T. Frederichs, NRC C. M. Regan, NRC W. M. Dean, NRC Resident Inspector, Calvert Cliffs Resident Inspector, Ginna Resident Inspector, Nine Mile Point S. Gray, DNR M. D. Hervey, LIPA

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Constellation Energy Nuclear Group, LLC December 17, 2012

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Calvert Cliffs Nuclear Power Plant Independent Spent Fuel Storage Installation 10 CFR Part 72 Material License Number: SNM-2505 Table 1 - Calvert Cliffs Nuclear Power Plant Independent Spent Fuel Storage Installation Information Required by 10 CFR 72.30(b)

ISFSI Only

($000's)

Radiological ISFSI decommissioning cost estimate derived from the I

Scenario 3 spent fuel category of decommissioning costs included in the

$2,059' 2009 site-specific study (Reference d), in September 2012 dollars Assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds 2

Annual decommissioning cost escalation 4%2 Annual after-tax rate of earnings on decommissioning funds 6%'

Real rate of return on decommissioning funds 2%3 Present value of funds imputed as of September 30, 2012 that would be 3

sufficient to pay the amount in row I above at the start of the ISFSI

$7354,6 decommissioning The amount accumulated as of September 30, 2012 in the external decommissioning qualified trust pursuant to current 10 CFR 72.30(b) and 4a 10 CFR 50.75(b) and (c), net of income taxes payable/receivable, allocated

$22'3175 to the ISFSI The amount accumulated as of September 30, 2012 in the external 4b decommissioning nonqualified trust pursuant to current 10 CFR 72.30(b),

$9,122' net of income taxes payable/receivable, specifically for the ISFSI 4c Combined amounts from row 4a and 4b above

$31,43956 I

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Table 1 Notes - Calvert Cliffs Nuclear Power Plant Independent Spent Fuel Storagye Installation General notes: Each dollar amount in Table 1 is supported by the corresponding amount set forth in Attachment (2), which contains the summary and annual calculations of radiological license termination decommissioning cash flows and fund balances based on the DCEs presented in Attachment (3) and the Table I assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds. A final determination of the decommissioning approach has not been made.

For the purpose of this financial assurance submittal, each of the projected trust fund balances (net of income taxes payable/receivable) is based on Scenario 3 (50-year SAFSTOR) of the supporting site-specific study, which is within the guidelines set forth in 10 C.F.R. 50.75.

Different decommissioning options that also meet the NRC financial assurance requirements may be chosen in the future. Any funds remaining after the completion of radiological decommissioning could be available for nonradiological decommissioning.

This amount is the total cost, including an adequate contingency factor, anticipated to be incurred by an independent contractor to perform all radiological ISFSI decommissioning activities required under 10 CFR 72.30 to meet the criteria under 10 CFR 20.1402 for unrestricted use.

The decommissioning activities primarily consist of planning and reporting activities and a survey to confirm the absence of contamination, which costs are calculated in Attachment (3). The costs of dismantling nonradioactive ISFSI systems and structures are not included in this estimate.

2 4% is the annualized weighted average cost escalation value for all decommissioning costs based on recent site-specific decommissioning studies performed on a CENG fleet-wide basis.

3 6.5% is the long-term target rate of return for the funds. However, since 10 CFR 50.75(e) limits the real rate of return to 2% and the cost escalation is 4%, the annual after-tax rate of earnings on decommissioning funds is assumed to be 6%.

4 The ISFSI amount is the present value of funds as of September 30, 2012 that would be sufficient to pay the cost amount in row I of Table 1 at the start of the ISFSI decommissioning, assuming the above escalation and earnings rates.

5 As of September 30, 2012, the amounts in the CCNPP ISFSI decommissioning trust accounts were separately identified and not included as part of the facility radiological trust fund balances reported earlier this year in CENG's report on decommissioning funding (Reference a).

6 Financial assurance is demonstrated as of September 30, 2012, since the sum of the combined amounts from the qualified and nonqualified trust funds in row 4c of Table I is greater than the amount sufficient to pay for the ISFSI radiological decommissioning in row 1 of Table 1.

2

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation Table 2 - Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation (Constellation Energy Nuclear Group (CENG) Ownership Interest),

Unit 1 Unit 2 ISFSI Total Information Required by 10 CFR 72.30(b)

($000's)

($000's)

($000's)

($000's)

Decommissioning cost estimate based on the same Scenario 3 license termination costs for Unit I and Unit 2 and the radiological ISFSI

$8068212

$767,3912

$1,8212

$1,576,033 spent fuel costs included in the 2009 site-specific study (Reference e), in September 2012 dollars Assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds Annual decommissioning cost escalation 4%3 2

Annual after-tax rate of earnings on 6%4 decommissioning funds Real rate of return on decommissioning funds 2%4 Trust fund balance as of September 30, 2012,

$434,006'

$273,985'

$577'

$708,568' net of income taxes payable/receivable

$434'006_

$273'9855

$57_$7_'68 Trust fund balance at the end of the decommissioning period, net of income taxes payable/receivable, after the accumulation of earnings in the trust account and the payment of all facility and ISFSI radiological

$693,525

$372,825

$0

$1,066,350 decommissioning costs (financial assurance is demonstrated because each ending balance is greater than or equal to zero) 3

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Table 2 Notes - Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation (Constellation Energy Nuclear Group Ownership Interest)

General notes: Each dollar amount in Table 2 is supported by the corresponding amount set forth in Attachment (2), which contains the summary and annual calculations of radiological license termination decommissioning cash flows and fund balances based on the DCEs presented in Attachment (3) and the Table 2 assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds. A final determination of the decommissioning approach has not been made.

For the purpose of this financial assurance submittal, each of the projected trust fund balances (net of income taxes payable/receivable) is based on Scenario 3 (50-year SAFSTOR) of the supporting site-specific study, which is within the guidelines set forth in 10 C.F.R. 50.75. Different decommissioning options that also meet the NRC financial assurance requirements may be chosen in the future. Any funds remaining after the completion of radiological decommissioning could be available for nonradiological decommissioning.

Constellation Energy Nuclear Group is the ultimate owner of 100% of NMP1 and 82% of NMP2.

The NMPI amounts provided in this table represent the 100% CENG share of decommissioning responsibilities.

The NMP2 amounts provided in this table represent the 82% CENG share of decommissioning responsibilities.

Table 3 contains information regarding the 18% share of the NMP2 liability assumed by the Long Island Power Authority (LIPA).

2 This amount is the total cost, including an adequate contingency factor, anticipated to be incurred by an independent contractor to perform all radiological license termination decommissioning activities required under 10 CFR 50.75 and 10 CFR 72.30 for Units I and 2 and the ISFSI, respectively, to meet the criteria under 10 CFR 20.1402 for unrestricted use. The ISFSI decommissioning activities primarily consist of planning and reporting activities and a survey to confirm the absence of contamination, which costs are calculated in Attachment (3). The cost of dismantling nonradioactive systems and structures is not included in this estimate.

3 4% is the annualized weighted average cost escalation value for all decommissioning costs based on recent site-specific decommissioning studies performed on a CENG fleet-wide basis.

4 6.5% is the long-term target rate of return for the funds. However, since 10 CFR 50.75(e) limits the real rate of return to 2% and the cost escalation is 4%, the annual after-tax rate of earnings on decommissioning funds is assumed to be 6%.

The amount in the Total column is the balance of funds accumulated as of September 30, 2012 in the external decommissioning trust pursuant to 10 CFR 72.30 and 10 CFR 50.75(b) and (c), net of income taxes payable/receivable. The amount in the ISFSI column is the present value of funds as of September 30, 2012 that would be sufficient to pay the ISFSI cost amount in row 1 of Table 2 at the start of the ISFSI decommissioning, assuming the above escalation and earnings rates. The amounts in the Unit I and Unit 2 columns reflect the allocations of the Total column amount between Unit I and Unit 2, net of the amount allocated to the ISFSI.

4

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation Table 3 - Nine Mile Point Nuclear Station (Long Island Power Authority 18% NMP2 Ownership Interest)'

Note: Information in this table for rows 2-4 was provided by the NMP2 minority owner, Long Island Power Authority.

CENG has not independently verified or assessed the information provided by this co-owner.

Unit 2 ISFSI Total Information Required by 10 CFR 72.30(b)

($000's)

($000's)

($000's)

Decommissioning cost estimate based on the same Scenario 3 license termination costs for Unit 2 and the radiological

$168,4522

$3422

$168,794 ISFSI spent fuel costs included in the 2009 site-specific study (Reference e), in September 2012 dollars Assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds 2

Annual decommissioning cost escalation 4%3 Annual after-tax rate of earnings on decommissioning funds 6%4 Real rate of return on decommissioning funds 2%4 Trust fund balance as of September 30, 2012, net of income

$76,144'

$108'

$76,253' taxes payable/receivable

$614

$08

$725 Trust fund balance at the end of the decommissioning period, net of income taxes payable/receivable, after the accumulation of earnings in the trust account and the 4

payment of all facility and ISFSI radiological

$166,283 0

$166,283 decommissioning costs (financial assurance is demonstrated because each ending balance is greater than or equal to zero) 5

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Table 3 Notes - Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation (Long Island Power Authority 18% NMP2 Ownership Interest)

General notes: Each dollar amount in Table 3 is supported by the corresponding amount set forth in Attachment (2), which contains the summary and annual calculations of radiological license termination decommissioning cash flows and fund balances based on the DCEs presented in Attachment (3) and the Table 3 assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds. A final determination of the decommissioning approach has not been made. For the purpose of this financial assurance submittal, each of the projected trust fund balances (net of income taxes payable/receivable) is based on Scenario 3 (50-year SAFSTOR) of the supporting site-specific study, which is within the guidelines set forth in 10 C.F.R. 50.75. Different decommissioning options that also meet the NRC financial assurance requirements may be chosen in the future. Any funds remaining after the completion of radiological decommissioning could be available for nonradiological decommissioning.

Constellation Energy Nuclear Group is the ultimate owner of 82% of NMP2. The NMP2 amounts provided in this table represent the remaining 18% LIPA share of decommissioning responsibilities.

Constellation Energy Nuclear Group has not independently verified this information provided by LIPA.

2 This amount is the total cost, including an adequate contingency factor, anticipated to be incurred by an independent contractor to perform all radiological license termination decommissioning activities required under 10 CFR 50.75 and 10 CFR 72.30 for Unit 2, and the ISFSI, respectively, to meet the criteria under 10 CFR 20.1402 for unrestricted use. The ISFSI decommissioning activities primarily consist of planning and reporting activities and a survey to confirm the absence of contamination, which costs are calculated in Attachment (3). The cost of dismantling nonradioactive systems and structures is not included in this estimate.

Constellation Energy Nuclear Group has not independently verified this information as provided by LIPA.

3 4% is the annualized weighted average cost escalation value for all decommissioning costs based on recent site-specific decommissioning studies performed on a CENG fleet-wide basis.

4 6.5% is the long-term target rate of return for the funds. However, since 10 CFR 50.75(e) limits the real rate of return to 2% and the cost escalation is 4%, the annual after-tax rate of earnings on decommissioning funds is assumed to be 6%.

5 The amount in the Total column is the balance of funds accumulated as of September 30, 2012 in the external decommissioning trust pursuant to 10 CFR 72.30 and 10 CFR 50.75(b) and (c), net of income taxes payable/receivable. The amount in the ISFSI column is the present value of funds as of September 30, 2012 that would be sufficient to pay the ISFSI cost amount in row I of Table 3 at the start of the ISFSI decommissioning, assuming the above escalation and earnings rates. The amount in the Unit 2 column reflects the allocation of the Total column amount between Unit 2 and the amount allocated to the ISFSI.

6

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN R.E. Ginna Nuclear Power Plant Independent Spent Fuel Storage Installation Table 4 - R.E. Ginna Nuclear Power Plant Independent Spent Fuel Storage Installation Unit ISFSI Total Information Required by 10 CFR 72.30(b)

($000's)

($000's)

($000's)

Decommissioning cost estimate based on the same Scenario 1

3 license termination costs for the unit and the radiological

$655,421'

$2,232'

$657,653 ISFSI spent fuel costs included in the 2009 site-specific I study (Reference e), in September 2012 dollars Assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds 2

Annual decommissioning cost escalation 4%2 Annual after-tax rate of earnings on decommissioning funds 6%_

Real rate of return on decommissioning funds 2%3 Trust fund balance as of September 30, 2012, net of income

$304,3154

$1,1854

$305,5004 taxes payable/receivable Trust fund balance at the end of the decommissioning period, net of income taxes payable/receivable, after the accumulation of earnings in the trust account and the 4

payment of all facility and ISFSI radiological

$208,295

$0

$208,295 decommissioning costs (financial assurance is demonstrated because each ending balance is greater than or equal to zero) 7

ATTACHMENT (1)

SEPTEMBER 2012 ISFSI DECOMMISSIONING FUNDING PLAN Table 4 Notes - R.E. Ginna Nuclear Power Plant Independent Spent Fuel Storage Installation General notes: Each dollar amount in Table 4 is supported by the corresponding amount set forth in Attachment (2), which contains the summary and annual calculations of radiological license termination decommissioning cash flows and fund balances based on the DCEs presented in Attachment (3) and the Table 3 assumptions used in funding projections regarding escalation in decommissioning cost and rates of earnings on decommissioning funds. A final determination of the decommissioning approach has not been made.

For the purpose of this financial assurance submittal, each of the projected trust fund balances (net of income taxes payable/receivable) is based on Scenario 3 (50-year SAFSTOR) of the supporting site-specific study, which is within the guidelines set forth in 10 C.F.R. 50.75. Different decommissioning options that also meet the NRC financial assurance requirements may be chosen in the future. Any funds remaining after the completion of radiological decommissioning could be available for nonradiological decommissioning.

This amount is the total cost, including an adequate contingency factor, anticipated to be incurred by an independent contractor to perform all radiological license termination decommissioning activities required under 10 CFR 50.75 and 10 CFR 72.30 for the facility and the ISFSI, respectively, to meet the criteria under 10 CFR 20.1402 for unrestricted use.

The ISFSI decommissioning activities primarily consist of planning and reporting activities and a survey to confirm the absence of contamination, which costs are calculated in Attachment (3). The cost of dismantling nonradioactive systems and structures is not included in this estimate.

2 4% is the annualized weighted average cost escalation value for all decommissioning costs based on recent site-specific decommissioning studies performed on a CENG fleet-wide basis.

3 6.5% is the long-term target rate of return for the funds. However, since 10 CFR 50.75(e) limits the real rate of return to 2% and the cost escalation is 4%, the annual after-tax rate of earnings on decommissioning funds is assumed to be 6%.

4 The amount in the Total column is the balance of funds accumulated as of September 30, 2012 in the external decommissioning trust pursuant to 10 CFR 70.30(c) and 10 CFR 50.75(b) and (c), net of income taxes payable/receivable. The amount in the ISFSI column is the present value of funds as of September 30, 2012 that would be sufficient to pay the ISFSI cost amount in row 1 of Table 4 at the start of the ISFSI decommissioning, assuming the above escalation and earnings rates. The amount in the Unit column reflects the allocations of the Total column amount between the Unit and the amount allocated to the ISFSI.

8

ATTACHMENT (2)

SEPTEMBER 2012 RADIOLOGICAL LICENSE TERMINATION DECOMMISSIONING FINANCIAL ASSURANCE

SUMMARY

AND SUPPORTING ANNUAL DECOMMISSIONING COST ESTIMATES Note: The schedules in this Attachment (2) are presented plant by plant, beginning with a summary and followed by detailed annual calculations for each plant.

Constellation Energy Nuclear Group, LLC December 17, 2012

Calvert Cliffs Nuclear Power Plant ISFSI NRC Radiological License Termination Decommissioning Financial Assurance Summary As of September 30, 2012 Dollars in Thousands CCNPP ISFSI License Information 10 CFR license part Final year of decommissioning period ISFSI Radiological Decommissioning Trust Fund Activity Balance of ISFSI trust funds as of 9/30/2012 A

Trust fund market value balance as of 9/30/2012, net of income taxes payable/receivable [ISFSI amount imputed to cover future ISFSI decommissioning costs]

License termination disbursements through period of decommissioning B

Disbursements of decommissioning cash flows per excerpt from 2009 site-specific study (Scenario 3) in Attachment (3) (in 2009 dollars) 72.30 2064 Imputed Actual 735

$ 31,439 (1,686)

Cost escalation factors:

C 2009 dollars to December 2011 dollars [equal to NRC Minimum increase % per Reference (a)]

18.57%

D December 2011 dollars to September 2012 dollars [equal to 9/12 x 4.00% weighted average annual cost escalation per Attachment (1)]

3.00%

E Compounded escalation factor from 2009 dollars to September 2012 dollars [equal to (1+C) x (1 +D)]

1.2213 F

Disbursements of decommissioning cash flows in September 2012 dollars [equal to B x E]

(2,059)

Earnings through period of decommissioning G

Trust fund earnings through decommissioning period based on 2% real rate of return per Attachment (1) 1,324 Financial assurance H

Balance of trust funds upon completion of decommissioning, net of income taxes payable/receivable [equal to A + B + G]

0 Page 1 of 13

Calvert Cliffs Nuclear Power Plant ISFSI Detailed Annual Trust Fund Activity Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Assumptions from Attachment (2) Summary Period 12/2008-12/2011 12/2011-09/2012 Completion 2064 Year 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 Escalation Compound Factor Real Return 18.57%

12 3.00%

J 1.2213 2.00%

ISFSI Radiological Decommissioning Expenditures In 9/30/2012

$000s ISFSI Radiological Trust Funds Earnings Imputed balance as of 9/30/2012 to cover costs:

15 15 15 16 16 16 17 17 17 18 18 18 19 19 19 20 20 21 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 Balance 735 750 765 780 796 812 828 845 862 879 896 914 933 951 970 990 1,009 1,030 1,050 1,071 1,093 1,114 1,137 1,159 1,183 1,206 1,230 1,255 1,280 1,306 1,332 1,359 1,386 1,413 Page 2 of 13

Calvert Cliffs Nuclear Power Plant ISFSI Detailed Annual Trust Fund Activity Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Assumptions from Attachment (2) Summary Period 12/2008-12/2011 12/2011-09/2012 Completion 2064 Year 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 Totals Escalation Compound Factor Real Return 18.57%

.10 3.00%0/

1.2213 2.00%

ISFSI Radiological Decommissioning Expenditures In 9/30/2012

$000s ISFSI Radiological Trust Funds Earnings 28 29 29 30 31 31 32 32 33 34 34 35 36 37 37 38 39 40 40 2,059 2,059 1,324 Balance 1,442 1,471 1,500 1,530 1,561 1,592 1,624 1,656 1,689 1,723 1,757 1,793 1,828 1,865 1,902 1,940 1,979 2,019 2,059 Page 3 of 13

Nine Mile Point Nuclear Station and ISFSI NRC Radiological License Termination Decommissioning Financial Assurance Summary As of September 30, 2012 Dollars in Thousands NMP CENG 100% of Unit I and 82% of Unit 2 LIPA 18% of Unit 2 Unit t Unit 2 ISFSI Total Unit 2 ISFSI Total License Information 10 CFR license part Final year of decommissioning period General License 2095 50.75 General License 2095 2071 50.75 2077 2071 Radiolopical Decommissioning Trust Fund Activity Balance of trust funds as of 9/30/2012 A

Trust fund market value balance as of9/30/2012, net of income taxes payable/receivable [ISFSI amount imputed to cover future ISFSI decommissioning costs]

License termination disbursements through period of decommissioning B

Disbursements of decommissioning cash flows per excerpt from 2009 site-specific study (Scenario 3) in Attachment (3) (in 2009 dollars)

Cost escalation factors:

C 2009 dollars to December 2011 dollars [equal to NRC Minimum increase % per Reference (a)]

D December 2011 dollars to September 2012 dollars [equal to 9/12 x 4.00% weighted average annual cost escalation per Attachment (1)]

E Compounded escalation factor from 2009 dollars to September 2012 dollars [equal to (1+C) x ( 1+D)]

F Disbursements of decommissioning cash flows in September 2012 dollars [equal to B x E]

Earnings through period of decommissioning G

Trust fund eamings through decommissioning period based on 2%

real rate of return per Attachment (1)

Financial assurance H

Balance of trust funds upon completion of decommissioning, net of income taxes payable/receivable [equal to A + B + G]

$ 434,006

$ 273,985 577 708,568

$ (700,583)

$ (666,344)

S (1,581)

$(1,368,508) 11.81%

11.81%

11.81%

3.00%

3.00%

3.00%

1.1516 1.1516 1.1516 76,144 S

108 76,253

$(146,271)

S (297)

$(146,568) 11.81%

11.81%

3.00%

3.00%

1.1516 1.1516

$ (806,821)

$ (767,391)

$ (1,821)

$(1,576,033) 1 $(168,452)

$ (342)

$(168,794)

$1,066,340 866,231 1,243

$ 1,933,815 1 S 234

$ 258,824

$ 693,525

$ 372,825 S

0

$ 1,066,350

$ 166,283 0

$ 166,283 Page 4 of 13

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - CENG's 82% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2) Summary 12/2008-12/2011-Compound Real Return 12/2011 09/2012 Factor Unit I Unit 2 ISFSI 11.81%

3.00%

1.15164 2.00%

2.00%

2.00%

Radiological Decommissioning Expenditures Completion 2095 Year 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

.2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 Radiological Trust Funds In 9/30/2012 $000s 100%

CENG's Portion Unit I Unit 2 ISFSI 6,710 56,902 35,902 4,065 4,065 4,065 19,891 15,768 2,040 2,040 2,040 2,040 2,040 2,040 2,040 2,040 2,040 Unit 1 Earnings Balance

$ 434,006 8,680 442,686 8,854 451,540 9,031 460,571 9,211 469,782 9,396 479,178 9,584 488,761 9,775 498,537 9,971 508,507 10,170 518,678 10,374 529,051 10,581 539,632 10,793 550,425 11,008 561,433 11,229 572,662 11,453 584,115 11,682 595,797 11,782 600,869 10,879 554,846 10,379 529,323 10,505 535,762 10,634 542,331 10,765 549,031 10,583 539,722 10,479 534,434 10,648 543,041 10,820 551,821 10,996 560,776 11,175 569,911 11,357 579,228 11,544 588,731 11,734 598,425 11,928 608,312 12,125 618,397 Unit 2 Earnings Balance

$ 273,985

$ 5,480 279,464 5,589 285,054 5,701 290,755 5,815 296,570 5,931 302,501 6,050 308,551 6,171 314,722 6,294 321,017 6,420 327,437 6,549 333,986 6,680 340,665 6,813 347,479 6,950 354,428 7,089 361,517 7,230 368,747 7,375 376,122 7,522 383,645 7,673 391,318 7,826 399,144 7,983 407,127 8,143 415,269 8,305 423,575 8,471 432,046 8,641 440,687 8,814 449,501 8,990 458,491 9,170 467,661 9,353 477,014 9,540 486,554 9,731 496,285 9,926 506,211 10,124 516,335 10,327 526,662 ISFSI Earnings Balance 577 12 589 12 601 12 613 12 625 12 637 13 650 13 663 13 676 14 690 14 704 14 718 14 732 15 747 15 762 15 777 16 793 16 808 16 825 16 841 17 858 17 875 18 893 18 910 18 929 19 947 19 966 19 985 20 1,005 20 1,025 21 1,046 21 1,067 21 1,088 22 1,110 Page 5 of 13

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - CENG's 82% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2) Summary 12/2008-12/2011-Compound Real Return 12/2011 09/2012 Factor Unit I Unit 2 ISFSI 11.81%

3.00%

1.15164 2.00%

2.00%

2.00%

Radiological Decommissioning Expenditures Completion 2095 Year 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 2068 2069 2070 2071 2072 2073 2074 2075 2076 2077 2078 Radiological Trust Funds In 9/30/2012 $000s Unit I Unit 2 ISFSI 100%

Unit 1 2,043 2,051 2,087 2,039 2,939 2,039 2,039 2,084 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,051 2,055 2,051 2,951 2,051 2,124 2,466 22,203 82,521 268,510 158,206 49,917 CENG's Portion Unit 2 ISFSI 2,664 25,454 51,665 4,989 4,989 4,989 18,505 19,389 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,122 2,126 2,121 3,128 2,121 1,821 2,182 2,461 2,332 2,282 2,313 2,325 2,736 3,135 Earnings 12,327 12,533 12,742 12,956 13,156 13,378 13,605 13,835 14,071 14,312 14,557 14,807 15,062 15,322 15,588 15,858 16,135 16,416 16,704 16,997 17,295 17,600 17,911 18,228 18,534 18,864 19,198 19,533 19,480 18,219 13,213 10,313 9,521 9,712 Balance 628,681 639,163 649,817 660,734 670,951 682,290 693,857 705,608 717,629 729,889 742,395 755,151 768,162 781,433 794,970 808,777 822,861 837,226 851,879 866,824 882,069 897,618 913,474 929,652 945,235 962,048 979,122 996,190 993,466 929,164 673,866 525,974 485,578 495,290 Earnings 10,480 10,180 9,351 9,438 9,527 9,618 9,440 9,241 9,383 9,529 9,677 9,828 9,982 10,139 10,300 10,463 10,630 10,800 10,974 11,151 11,331 11,516 11,703 11,895 12,070 12,269 12,471 12,671 12,878 13,090 13,306 13,525 13,741 13,953 Balance 534,478 519,205 476,891 481,341 485,879 490,509 481,443 471,296 478,558 485,965 493,520 501,227 509,087 517,105 525,283 533,625 542,133 550,812 559,664 568,694 577,903 587,298 596,875 606,649 615,591 625,739 636,029 646,239 656,784 667,593 678,585 689,785 700,790 711,609 Earnings 22 23 23 24 24 25 25 25 26 27 27 28 28 29 29 30 30 31 32 32 33 34 34 35 36 Balance 1,132 1,155 1,178 1,201 1,225 1,250 1,275 1,300 1,326 1,353 1,380 1,407 1,436 1,464 1,494 1,524 1,554 1,585 1,617 1,649 1,682 1,716 1,750 1,785 1,821 Page 6 of 13

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - CENG's 82% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2) Summary 12/2008-12/2011-Compound Real Return 12/2011 09/2012 Factor Unit 1 Unit 2 ISFSI 11.81%

3.00%

1.15164 2.00%

2.00%

2.00%

Radiological Decommissioning Expenditures Completion 2095 Year 2079 2080 2081 2082 2083 2084 2085 2086 2087 2088 2089 2090 2091 2092 2093 2094 2095 Totals Radiological Trust Funds In 9/30/2012 $000s Unit I Unit 2 ISFSI 100%

Unit I CENG's Portion Unit 2 ISFSI 3,135 3,135 3,135 3,135 3,135 3,135 3,135 3,135 3,135 3,135 4,141 16,173 65,186 177,066 169,558 111,955 359 Earnings 9,906 10,104 10,306 10,512 10,722 10,937 11,156 11,379 11,606 11,838 12,075 12,317 12,563 12,814 13,070 13,332 13,599 Balance 505,196 515,299 525,605 536,118 546,840 557,777 568,932 580,311 591,917 603,755 615,831 628,147 640,710 653,524 666,595 679,927 693,525 Earnings 14,169 14,390 14,615 14,845 15,079 15,318 15,562 15,810 16,064 16,322 16,566 16,574 15,602 12,372 9,229 7,174 7,310 Balance 722,643 733,899 745,380 757,090 769,034 781,218 793,645 806,320 819,249 832,437 844,862 845,262 795,678 630,984 470,654 365,874 372,825 Earnings Balance 806,821 767,391 1,821 1,066,340 866,231 1,243 Page 7 of 13

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - LIPA's 18% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2):

Compound Summary 12/2008-12/2011 12/2011-09/2012 Factor Real Return 11.81%

3.00%

1.15164 2.00%

2.00%

Completion 2095 Year 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 Radiological Decommissioning Expenditures In 9/30/2012 $000s Unit 2 ISFSI LIPA's Portion Unit 2 ISFSI Earnings 1,523 1,553 1,584 1,616 1,648 1,681 1,715 1,749 1,784 1,820 1,856 1,894 1,931 1,970 2,009 2,050 2,091 2,132 2,175 2,219 2,263 2,308 2,354 2,401 2,449 2,498 2,548 2,599 2,651 2,704 2,758 2,814 2,870 2,916 2,862 Balance 76,144 77,667 79,220 80,805 82,421 84,069 85,751 87,466 89,215 90,999 92,819 94,676 96,569 98,500 100,470 102,480 104,529 106,620 108,752 110,928 113,146 115,409 117,717 120,072 122,473 124,922 127,421 129,969 132,569 135,220 137,924 140,683 143,497 146,367 148,697 145,972 Earnings 2

2 2

2 2

2 2

2 3

3 3

3 3

3 3

3 3

3 3

3 3

3 3

3 3

4 4

4 4

4 4

4 4

4 4

Balance 108 111 113 115 117 120 122 125 127 130 132 135 138 140 143 146 149 152 155 158 161 164 168 171 174 178 181 185 189 193 196 200 204 208 213 217 Page 8 of 13 585 5,587

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - LIPA's 18% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2):

Compound Summary 12/2008-12/2011 12/2011-09/2012 Factor Real Return 11.81%

3.00%

1.15164 2.00%

2.00%

Completion 2095 Year 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 2068 2069 2070 2071 2072 2073 2074 2075 2076 2077 2078 2079 2080 2081 2082 Radiological Decommissioning Expenditures In 9/30/2012 $000s Unit 2 ISFSI LIPA's Portion Unit 2 11,341 1,095 1,095 1,095 4,062 4,256 466 466 466 466 466 466 466 466 466 466 466 466 466 466 467 466 687 466 479 540 512 501 508 510 601 688 688 688 688 688 ISFSI 342 Earnings 2,693 2,725 2,757 2,790 2,765 2,735 2,781 2,827 2,874 2,922 2,971 3,021 3,073 3,125 3,178 3,232 3,287 3,344 3,401 3,460 3,520 3,581 3,639 3,703" 3,767 3,832 3,898 3,966 4,035 4,106 4,176 4,245 4,316 4,389 4,463 4,539 Balance 137,324 138,953 140,616 142,311 141,014 139,493 141,808 144,169 146,577 149,034 151,539 154,095 156,702 159,361 162,073 164,840 167,661 170,540 173,475 176,470 179,523 182,639 185,591 188,828 192,116 195,407 198,793 202,258 205,785 209,381 212,956 216,513 220,141 223,842 227,617 231,468 Earnings 4

4 5

5 5

5 5

5 5

5 5

5 6

6 6

6 6

6 6

6 6

7 7

Balance 221 226 230 235 239 244 249 254 259 264 270 275 281 286 292 298 304 310 316 322 329 335 342 Page 9 of 13

Nine Mile Point Nuclear Station and ISFSI Detailed Annual Trust Fund Activity - LIPA's 18% Portion Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2):

Compound Summary 12/2008-12/2011 12/2011-09/2012 Factor Real Return 11.81%

3.00%

1.15164 2.00%

2.00%

Completion 2095 Year 2083 2084 2085 2086 2087 2088 2089 2090 2091 2092 2093 2094 2095 Totals Radiological Decommissioning Expenditures In 9/30/2012 $000s LIPA's Portion Unit 2 ISFSI Earnings Balance Unit 2 688 688 688 688 688 688 909 3,550 14,309 38,868 37,220 24,575 79 168,452 ISFSI Earnings 4,616 4,694 4,774 4,856 4,939 5,024 5,107 5,138 4,954 4,276 3,617 3,198 3,260 342 258,590 Balance 235,395 239,401 243,487 247,655 251,907 256,243 260,440 262,028 252,673 218,081 184,478 163,101 166,283 234 234 Page 10 of 13

R.E. Ginna Nuclear Power Plant and ISFSI NRC Radiological License Termination Decommissioning Financial Assurance Summary As of September 30, 2012 Dollars in Thousands Ginna Plant ISFSI Total License Information 10 CFR license part Final year of decommissioning period General License 2078 2045 50.75 Radiological Decommissioning Trust Fund Activity Balance of trust funds as of 9/30/2012 A

Trust fund market value balance as of 9/30/2012, net of income taxes payable/receivable [ISFSI amount imputed to cover future ISFSI decommissioning costs]

$ 304,315 1,185

$ 305,500 B

License termination disbursements through period of decommissioning Disbursements of decommissioning cash flows per excerpt from 2009 site-specific study (Scenario 3) in Attachment (3) (in 2009 dollars)

$ (537,306)

$ (1,830)

$ (539,136)

Cost escalation factors:

C 2009 dollars to December 2011 dollars [equal to NRC Minimum increase % per Reference (a)]

18.43%

18.43%

D December 2011 dollars to September 2012 dollars [equal to 9/12 x 4.00% weighted average annual cost escalation per Attachment (1)]

3.00%

3.00%

E Compounded escalation factor from 2009 dollars to September 2012 dollars [equal to (I+C) x (I+D)]

1.2198 1.2198 F

Disbursements of decommissioning cash flows in September 2012 dollars [equal to B xE]

$ (655,421)

$ (2,232)

$ (657,653)

Earnings through period of decommissioning G

Trust fund earnings through decommissioning period based on 2% real rate of return per Attachment (1)

$ 559,401 1,048

$ 560,448 Financial assurance H

Balance of trust funds upon completion of decommissioning, net of income taxes payable/receivable [equal to A + B + G]

$ 208,295 0

$ 208,295 Page II of 13

R.E. Ginna Nuclear Power Plant and ISFSI Detailed Annual Trust Fund Activity Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2) Summary.

12/2011-Compound Real Return 12/2008-12/2011 09/2012 Factor Unit I ISFSI 18.43%

3.00%

1.21983 2.00%

2.00%

Radiological Decommissioning Expenditures Completion 2078 Year 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 Radiological Trust Funds In 9/30/2012 $000s Unit ISFSI Unit 1 Earnings Balance

$304,315 6,086 310,402 6,208 316,610 6,332 322,942 6,459 329,401 6,588 335,989 6,720 342,708 6,854 349,563 6,991 356,554 7,131 363,685 7,274 370,959 7,419 378,378 7,568 385,945 7,719 393,664 7,873 401,537 8,031 409,568 8,191 417,760 8,196 418,008 7,601 387,635 7,250 369,725 7,299 372,251 7,350 374,828 7,401 377,457 7,430 378,955 7,142 364,266 7,230 368,710 7,318 373,243 7,409 377,867 7,502 382,584 7,596 387,394 7,692 392,301 7,790 397,306 7,890 402,412 2

7,993 407,619 8,097 412,930 ISFSI Earnings Balance 1,185 24 1,208 24 1,232 25 1,257 25 1,282 26 1,308 26 1,334 27 1,361 27 1,388 28 1,416 28 1,444 29 1,473 29 1,502 30 1,532 31 1,563 31 1,594 32 1,626 33 1,659 33 1,692 34 1,726 35 1,760 35 1,795 36 1,831 37 1,868 37 1,905 38 1,943 39 1,982 40 2,022 40 2,062 41 2,104 42 2,146 43 2,189 44 2,232 7,948 37,973 25,160 4,773 4,773 4,773 5,932 21,832 2,785 2,785 2,785 2,785 2,785 2,785 2,785 2,785 2,785 2,785 2,23 Page 12 of 13

R.E. Ginna Nuclear Power Plant and ISFSI Detailed Annual Trust Fund Activity Trust Fund Balances (Net of Income Taxes Payable/Receivable)

Based on Site-Specific Study Scenario 3 Cash Flows and 2% Real Rate of Return In Thousands of Dollars Escalation Period Assumptions from Attachment (2) Summary:

12/2011-Compound Real Return 12/2008-12/2011 09/2012 Factor Unit 1 ISFSI 18.43%

3.00%

1.21983 2.00%

2.00%

Radiological Decommissioning Expenditures Completion 2078 Year 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 2068 2069 2070 2071 2072 2073 2074 2075 2076 2077 2078 Radiological Trust Funds In 9/30/2012 $000s Unit 3,594 3,711 3,711 4,141 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 3,711 4,141 3,711 3,711 3,711 3,711 9,090 28,591 139,645 160,814 71,623 ISFSI Unit 1 Earnings Balance 8,187 417,523 8,276 422,089 8,368 426,745 8,452 431,056 8,547 435,893 8,644 440,825 8,742 445,857 8,843 450,989 8,946 456,224 9,050 461,564 9,157 467,010 9,266 472,566 9,377 478,232 9,490 484,012 9,606 489,907 9,724 495,920 9,844 502,054 9,967 508,310 10,092 514,691 10,220 521,200 10,350 527,839 10,483 534,611 10,618 541,519 10,748 548,125 10,888 555,303 11,032 562,624 11,178 570,091 11,328 577,708 11,372 579,991 11,028 562,428 8,456 431,239 5,408 275,833 4,084 208,295 ISFSI Earnings Balance 655,421 2,232

$ 559,401 1,048 Page 13 of 13

ATTACHMENT (3)

SITE-SPECIFIC ISFSI DECOMMISSIONING COST STUDIES Constellation Energy Nuclear Group, LLC December 17, 2012

ENERGYSOLUTIONS December 10, 2012 Mr. Stephen A. Mormann VP - Financial Services & Treasurer Constellation Energy Nuclear Group 100 Constellation Way Suite 200C Baltimore, MD 21202

Subject:

SITE-SPECIFIC ISFSI DECOMMISSIONING COST STUDIES

Dear Mr. Mormann:

EnergySolutions prepared for Constellation Energy Nuclear Group (CENG) the 2009 Decommissioning Cost Updates (the 2009 Cost Studies) containing site-specific decommissioning cost estimates (the 2009 DCEs) for the Calvert Cliffs Nuclear Power Plant' (CCNPP), Nine Mile Point Nuclear Station 2 (NMP), and R.E. Ginna Nuclear Power Plant3 (Ginna) (collectively, the Sites), each of which is ultimately owned by CENG. This summary and the following schedules (collectively, the ISFSI DCEs) present the results of those previously prepared 2009 Cost Studies with respect to the portions of those 2009 DCEs dealing with the radiological decommissioning of the independent spent fuel storage installations (ISFSIs) at the Sites. The 2009 DCEs and the ISFSI DCEs are in 2009 dollars. The ISFSI DCEs are for the activities required to terminate the 10 CFR 72.30 license for each Site's ISFSI, and they assume that decommissioning the ISFSIs will be performed by an independent contractor, will be performed to the extent required to meet the 10 CFR 20.1402 release criteria for unrestricted use, and will be performed to permit termination of the ISFSI licenses (the ISFSI License Termination).

The assumptions and other information contained in the ISFSI DCEs are included in the Spent Fuel category of Scenario 3 cost assumptions and supporting information contained in the 2009 Cost Studies, which also include the License Termination costs to decommission the nuclear power plant site. Accordingly, the ISFSI DCEs in Schedule 1 for CCNPP, Schedule 2 for NMP, and Schedule 3 for Ginna refer to, and consist of presenting the same, or allocations of the same, Spent Fuel Scenario 3 cost assumptions from the 2009 Cost Studies with respect to activities required for the ISFSI License Termination.

100 MIIl Plain Road, Mail Box No. 106

• Danbury, Connecticut 06811 860.355.8194 ° Fax 860.355.3295

• www.energysolutions.com

ENERGYSOLUTIONS With the current zero-leakage design of the dry shielded canisters used in storing spent fuel at the ISFSIs, no residual activated concrete or surface contamination is expected to be left behind on the ISFSI concrete storage pads or the horizontal storage modules at the time of their decommissioning. It is estimated that no decontamination will be required in connection with decommissioning the ISFSIs because of the relatively low neutron flux emanating from the spent fuel. Since no equipment is expected to be contaminated, and consistent with NRC regulations, the decommissioning cost estimates do not take credit for any salvage value of decontaminated equipment. There have been no facility modifications, leaks, spills, increased waste inventory, increased disposal costs, authorized possession limits, or onsite remediation that would impact these assumptions. No ISFSI activities or events have created any subsurface contamination that would require remediation as part of the ISFSI decommissioning and ultimate license termination of the ISFSIs.

The spent fuel shipping schedule for Scenario 3, provided in Appendix B to the 2009 Cost Studies, is based on information from CENG and also based, in part, on the DOE's "Acceptance Priority Ranking & Annual Capacity Report," dated July 2004 (Ref. No. 11). Spent fuel shipments to the DOE repository from the spent fuel pool are assumed to begin in 2020.

Should you have any questions, please contact me at (801) 303-1098 or by e-mail at jmartin(aenergysolutions.com.

Sincerely, Jeffrey J. Martin Project Manager Attachments - Schedules 1, 2, and 3 REFERENCES

1.

2009 Decommissioning Cost Update of the Calvert Cliffs Nuclear Power Plant, Prepared by EnergySolutions, LLC, December 9, 2009

2.

2009 Decommissioning Cost Update of the Nine Mile Point Nuclear Power Plant, Prepared by EnergySolutions, LLC, December 5, 2009

3.

2009 Decommissioning Cost Update of the R.E. Ginna Nuclear Power Plant, Prepared by EnergySolutions, LLC, December 5, 2009 100 Mill Plain Road, Mail Box No. 106 ° Danbury, Connecticut 06811 860.355.8194

• Fax 860.355.3295 - www.energysolutions.com

SCHEDULE 1 2012 ISFSI DECOMMISSIONING COST ESTIMATE SITE-SPECIFIC DECOMMISSIONING COST STUDIES Calvert Cliffs ISFSI License Termination Costs - Scenario 3 (50-Year SAFSTOR)

Assumption Sources: 2009 Cost Studies Table 6-6A A dix C. and AppeAdit D Table 3 Period, Cost

[IaDa:lfl/2064 ]

Costs in Thousands, 2009$

Type, & No.

Item Description Duration Labor Mater. And Equip.

Disposal Other Contingency Total SNF Pd 4 Spent Nuclear Fuel (SNF) Dry Storage During Dormancy Distributed (costs identied with specific activity) 14.01 Preparation and NRC Review of License Termination Plan 14.02 Verification Survey of Horizontal Storage Modules (includes pad) 14.03 Preparation of Final Report on Decommissioning and NRC Review*

Total distributed 147 days

$80 20 days

$170 13 days

$40 180 days

$290

$0

$0

$121

$44

$0

$0

$0

$0

$71

$44

$0

$192

$26

$227

$29

$243

$14

$125

$69

$595

• Excludes uaiting period for NRC review duration Cost 6f/25/2042 - 3/21/2065 Allocation Total SNF Pd 4 Cost Undistributed (period costs) 2.01 Utility Spent Fuel Staff 2.02 Utility Staff HP Supplies 2.05 Security Guard Force 2.06 Insurance 2.08 Energy Total undistributed Total Costs in Thousands, 2009 Dollars Method' 8 305 das Co in Costs for S80-day duration ofISFSI License Termination Activities F Z

$64,734

$8,415

$510

$0

$0

$0

$66

$576 StaffCosts

$3,121

$468

$0

$17

$0

$0

$3

$20

$71,967

$10,795

$312

$0

$0

$0

$47

$359 Proration

$4,581

$687

$0

$0

$0

$99

$15

$114 Proration

$855

$128

$0

$0

$0

$19

$3

$22

$822

$17

$0

$118

$134

$1,091

$1,112

$61 s0

$310

$203

$1,686 Staff FTEs &

hicluded in Line Nos. 2.01, 2.02, and 2.05 above HP Supplies Department Utility Staff HP 1SO days Labor Supplies Health Physics Fuel Pool Maintenance and Operation Staff Total FTEs Requiring Health Physics Supplies Administration (Accountant 1.0, Fitness For Duty Administrator 0. 1, Occupational Health Nurse 0. 1)

Security Admin Engineering Management Total Utility Spent Fuel Staff FTEs 0.5

$6 1.0

$11 1.5

$17 1.2 1.0 1.0 Average Annual 0.3 Burdened Cost/FrE 5.0

$510

$209 5.0

$312

$127 Security Guards Note:

Insurance and energy costs are calculated by prorating their entire Spent Nuclear Fuel Dry Storage Dormancy Period 4 (SNF Pd 4) costs for only that portion of that period in which the distributed cost activities are performed. ISFSI decommissioning staff, supplies, and security guard costs are calculated by specifically identifying the applicable number or fraction of full-time employees (FTE) at their fully-burdened labor and overhead rate for the associated distributed cost activity period. ISFSI decommissioning contingency costs assume the same contingency percentage for each of the corresponding costs as they appear in the 2009 Cost Studies.

SCHEDULE 2 2012 ISFSI DECOMMISSIONING COST ESTIMATE SITE-SPECIFIC DECOMMISSIONING COST STUDIES Nine Mile Point ISFSI License Termination Costs - Scenario 3 (50-Year SAFSTOR)

Assumption Sources: 2009 Cost Studies Table 6-9, A edi, C, and Appendi. D Table 3 Period, Cost

/St

.te:

9/9/2070J Costs in Thousands, 2009$

Type, & No.

Item Description Duration Labor Mater. And Equip.

Disposal Other Contingency Total SNF Pd 8 Spent Nuclear Fuel (SNF) Dry Storage During Dormancy Distributed (costs identied with specific activity) 29.01 Preparation and NRC Review of License Termination Plan 29.02 Verification Survey of Horizontal Storage Modules (includes pad) 29.03 Preparation of Final Report on Decommissioning and NRC Reviem*

Total distributed

• Excludes isailing period for NRC review duration 180 days

$80 30 days

$64 13 days

$40 223 days

$184

$0

$26

$0

$26

$0

$122

$0

$0

$0

$72

$0

$194

$26

$228

$12

$102

$14

$126

$52

$456 Cost Allocation Undistributed (period costs)

Method' 2.01 Utility Spent Fuel Staff Table for 2.02 Utility Staff HP Supplies Staff Costa 2.05 Security Guard Force 2.06 Insurance Proration 2.08 Energy Proration Total undisaibuted - 100% allocated to Unit 2 Total Costs in Thousands, 2009 Dollars Staff FTEs &

Included in Line Nos. 2.01, 2.02, and 2.05 above HP Supplies Department Health Physics Fuel Pool Maintenance and Operation Staff Total FTEs Requiring Health Physics Supplies Administration (Accountant 1.0, Fitness For Duty Administrator 0.1, Occupational Health Nurse 0. 1)

Security Admin Engineering Management Total Utility Spent Fuel Staff FTEs Security Guards 8/22/2067 - 10/31/2071 Total SNF Pd 8 Cost 1,531Lday Contingency Costs for 223-day duration of ISFSI License Termination Activities

$12,039

$1,565

$639

$0

$0

$0

$83

$1,404

$211

$0

$21

$0 s0

$3

$12,048

$1,807

$351

$0

$0

$0

$53

$844

$127

$0

$0

$0

$123

$18

$780

$117

$0

$0

$0

$114

$17

$990

$21

$0

$237

$174 St 722

$24 404

$141

$131

,422

$1,174

$47

$0

$431

$226

$1,878 Utility StaffHP 223 days Labor Supplies 0.5

$7 1.0

$14 1.5

$21 1.2 1.0 1.0 Average Annual 0.3 Burdened Cost/FTE 5.0

$639

$211 5.0

$351

$115 Cost Allocation ISFSI CENG-LIPA Unit I Unit 2 Distributed:

$456 50%

50%

Amount

$228

$228 Undistributed:

$1,422 0%

100%

Amount

$0

$1,422 Total Amount

$228

$1,650 Unit 2 82%

$228

$1,353 CENG Total 84.2%1"$1,581 Unit 2 18%

$0

$297 LIPA Total 15.8%

$297 CENG and LIPA Total

$1,878 Note:

Insurance and energy costs are calculated by prorating their entire Spent Nuclear Fuel Dry Storage Dormancy Period 8 (SNF Pd 8) costs for only that portion of that period in which the distributed cost activities are performed. ISFSI decommissioning staff, supplies, and security guard costs are calculated by specifically identifying the applicable number or fraction of full-time employees (FTE) at their fully-burdened labor and overhead rate for the associated distributed cost activity period.

ISFSI decommissioning contingency costs assume the same contingency percentage for each of the corresponding costs as they appear in the 2009 Cost Studies.

SCHEDULE 3 2012 ISFSI DECOMMISSIONING COST ESTIMATE SITE-SPECIFIC DECOMMISSIONING COST STUDIES R.E. Ginna ISFSI License Termination Costs - Scenario 3 (50-Year SAFSTOR)

Assumption Sources: 2009 Cost Studies Table 6-6, A ndix C and Appendix D Table 3 ost I Star..tDa:

7/24304j Costs in Thousands, 2009$

o Item Descriotion Duration Labor Mater. And Eoaui.

Disnosal Other Continaencv Total Period, Co Type. & N SNF Pd 4 Spent Nuclear Fuel (SNF) Dry Storage During Dormancy Distributed (costs identied with specific activity) 14.01 Preparation and NRC Review of License Termination Plan 14.02 Verification Survey of Horizontal Storage Modules (includes pad) 14.03 Preparation of Final Report on Decommissioning and NRC Review*

Total distributed

. Excludes waiting period for NRC review duration 180 days

$80 30 days

$48 13 days

$40 223 days

$168

$0

$0

$121

$23

$0

$0

$0

$0

$71

$23

$0

$192

$26

$227

$10

$81

$14

$125

$50

$433 Undistributed (period costs) 2.01 Utility Spent Fuel Staff 2.02 Utility Staff HP Supplies 2.05 Security Guard Force 2.06 Insurance 2.08 Energy Total undistributed Total Costs in Thousands. 2009 Dollars Cost 6/25/2035 - 9/17/2045 Allocation Total SNF Pd 4 Cost Methodi 3737 days Continaency Costs for 223-day duration of ISFSI License Termination Activities FTE Table for

$29,128

$3,787

$632

$0

$0

$0

$82

$714 fT

$1,404

$211

$0

$21

$0

$0

$3

$24

$32,383

$4,857

$386

$0

$0

$0

$58

$444 Proration

$2,061

$309

$0

$0

$0

$123

$18

$141 Proration

$1,078

$162

$0

$0

$0

$64

$10

$74

$1,018

$21

$0

$187

$171

$1,397

$1,186

$44

$0

$379

$221

$1,830 Staff FTrEs &

Included in Line Nos. 2.01. 2.02, and 2O5 above HP Supplies Department Health Physics Fuel Pool Maintenance and Operation Staff Total FTEs Requiring Health Physics Supplies Administration (Accountant 1.0, Fitness For Duty Administrator 0. 1, Occupational Health Nurse 0. 1)

Security Admin Engineering Management Total Utility Spent Fuel Staff FTEs Utility Staff HtP 223 days Labor Supplies 0.5 1.0 15

$7

$14

$21 1.2 1.0 1.0 Average Annual 0.3 Burdened Cost/FTE 5.0

$632

$209 5.0

$386T

$126 Security Guards Note:

Insurance and energy costs are calculated by prorating their entire Spent Nuclear Fuel Dry Storage Dormancy Period 4 (SNF Pd 4) costs for only that portion of that period in which the distributed cost activities are performed. ISFSI decommissioning staff, supplies, and security guard costs are calculated by specifically identifying the applicable number or fraction of full-time employees (FIE) at their fully-burdened labor and overhead rate for the associated distributed cost activity period. ISFSI decommissioning contingency costs assume the same contingency percentage for each of the corresponding costs us they appear in the 2009 Cost Studies.

ATTACHMENT (4)

CERTIFICATION OF FINANCIAL ASSURANCE Constellation Energy Nuclear Group, LLC December 17, 2012

CERTIFICATION OF FINANCIAL ASSURANCE NRC Licenses and Licensees:

Calvert Cliffs Nuclear Power Plant Independent Spent Fuel Storage Installation, License No. SNM-2505 Docket No. 72-8 Calvert Cliffs Nuclear Power Plant, LLC 1650 Calvert Cliffs Parkway Lusby, MD 20657 Nine Mile Point Nuclear Station Independent Spent Fuel Storage Installation, General License, Docket No. 72-1036 Nine Mile Point Nuclear Station, LLC P. 0. Box 63 Lycoming, NY 13093 R.E. Ginna Nuclear Power Plant Independent Spent Fuel Storage Installation, General License, Docket No. 72-67 R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519 Issued to: U.S. Nuclear Regulatory Commission I certify that Constellation Energy Nuclear Group, LLC (CENG) as parent to its subsidiaries, Calvert Cliffs Nuclear Power Plant, LLC, Nine Mile Point Nuclear Station, LLC, and R.E. Ginna Nuclear Power Plant, LLC, which are NRC licensees owning and operating their respective ISFSIs, is authorized to provide this Certification of Financial Assurance with respect to the decommissioning of the ISFSIs.

During the operation of those ISFSIs, spent nuclear fuel will be stored in storage casks licensed under 10 CFR Part 72.

Pursuant to contracts with the Department of Energy those radioactive materials will ultimately be removed from each ISFSI location, at which time the respective ISFSI will be decommissioned in accordance with NRC regulations.

I further certify that financial assurance in amounts sufficient to fund ISFSI decommissioning at the time of such decommissioning has been obtained, as described in the letter to which this Certification of Financial Assurance is attached.

I of 2

These amounts are premised on principal and earnings sufficient to provide funds to meet the site-specific decommissioning cost estimates in the following amounts (September 2012 Dollars) at the time of ISFSI decommissioning, in accordance with 10 CFR Part 72.

Calvert Cliffs Nuclear Power Plant Nine Mile Point Nuclear Station R.E. Ginna Nuclear Power Plant

$ 2,059,000

$ 2,163,000 (Inclusive of Long Island Power Authority 18% Interest in NMP2)

$ 2,232,000 Stephen A. Mormann VP - Financial Services & Treasurer Subscribed and sworn before me, a Notary Public, in and for the State of Maryland and

/-Tv Baltimore, this 17th day of December, 2012.

of WITNESS my hand and Notarial Seal:

My Commission Expires:

5h/i 11--olo rJ 1) A' Nota6[PublýJ_ 0) PoHw Date 2 of 2