Text

Decommissioning Funding Status Reports/Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update
	ML17093A722
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold, 07200061, 07200062
Issue date:	03/30/2017
From:	Larry Nicholson; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	L-2017-040
	Download: ML17093A722 (63)
	v • d • e

March 30, 2017 L-2017-040 10 CFR 50.75(f)(1) 10 CFR 72.30(c)

Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Docket No. 72-61 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Docket No. 72-62 NextEra Energy Seabrook, LLC Seabrook Station Docket No. 50-443 Docket No. 72-63 NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center Docket No. 50-331 Docket No. 72-32 NextEra Energy Point Beach, LLC Point Beach Units 1 and 2 Docket Nos. 50-266, 50-301 Docket No. 72-05 Decommissioning Funding Status Reports I Independent Spent Fuel Storage Installation (ISFSI)

Financial Assurance Update Pursuant to 10 CFR 50.75(f)(1) and 10 CFR 72.30(c), enclosed are the Decommissioning Funding Status (DFS)

Reports and Independent Spent Fuel Storage Installation Financial Assurance Update for the following units:

1. St. Lucie Units 1 and 2

2. Turkey Point Units 3 and 4

3. Seabrook Station

4. Duane Arnold Energy Center

5. Point Beach Units 1 and 2 Florida Power and Light Company (FPL) is the sole owner of Turkey Point Units 3 and 4 and St. Lucie Unit 1. FPL, Florida Municipal Power Agency, and Orlando Utilities Commission own St. Lucie Unit 2. The report for St. Lucie Unit 2 provides the status of decommissioning funding for all three owners of that unit.

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_Fl_or_id_a_Po_w_e_r&~Ug_h_t_co_m_p_a_ny~~~~~~~~~~~~~~~~~~~~~~~~~~~~. Jy....-{~7 700 Universe Boulevard, Juno Beach, FL 33408 /V

L-2017-040 Page 2 of2 NextEra Energy Seabrook, LLC (Seabrook), Hudson Light and Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Lighting Plant own Seabrook Station. The report for Seabrook Station provides the status of decommissioning funding for all four owners of that unit.

NextEra Energy Duane Arnold, LLC (Duane Arnold), Central Iowa Power Cooperative, and Corn Belt Power Cooperative own Duane Arnold Energy Center. The report for Duane Arnold Energy Center provides the status of decommissioning funding for all three owners of that unit.

NextEra Energy Point Beach, LLC is the sole owner of Point Beach Units 1 and 2.

This letter contains no new commitments and no revisions to existing commitments.

Should there be any questions, please contact Pam Metz at (561) 904-5189.

~ ~JA___

Larry Nicholson Nuclear Licensing and Regulatory Compliance Director Enclosures (2)

Enclosure 1 Decommissioning Funding Status Reports 10 CFR 50.75(f)(1)

St. Lucie Units 1 and 2 Turkey Point Units 3 and 4 Seabrook Station Duane Arnold Energy Center Point Beach Units 1 and 2

St. Lucie Nuclear Plant- Unit 1 Florida Power and Light Company (FPL),

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75(b) and (c).

Plant Owner(% Ownership) NRC Minimum (a)

FPL (100%) 468,366,936 (a) Refer to St. Lucie Unit 1 for calculation assumptions

2. The amount accumulated at the end of the calendar year preceding the date of the re ort. Trust fund balance is net of taxes Total FPL 100% 1,014, 177,909

3. Projected Funds at Shutdown 2% real rate of return).

Total FPL 100% see note b 1,482,685, 182 (b) Pursuant to Florida Public Service Commission (FPSC) Order No. PSC-16-0250-PAA-EI, customer contributions to the decommissioning trust remain at zero effective June 29, 2016.

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements.

None 1

NRC letter dated November 26, 2008, St. Lucie Plant, Unit Nos. 1 and 2 - Biennial Decommissioning Funding Report (TAC Nos.

MD9354 and MD9355), directed FPL to report all funds within the trust as designated for radiological decommissioning purposes since FPL does not earmark each cost component of decommissioning within the trust. However, the trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRC guidance, either an order of the FPSC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, St. Lucie Unit 1 allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in December 2015 with the FPSC.

Page 11

ST. LUCIE NUCLEAR PLANT - UNIT 1 NRC Minimum Decommissioning Cost Determination NRG Minimum = $101.58 million X (0.65L + 0.13E + 0.228)

Where:

$101.58 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year3 E = Energy escalation factor to current year4 B = LLRW escalation factor to current year5

Item Description Value 1 Labor escalation factor for Quarter 4, 2016 3 126.2 2 Base adjustment factor from NU REG-1307 2 1.98 3 Escalation factor from NU REG-1307 100 4 L =#1 times #2 divided by #3 2.50 5 Electric power escalation factor, 2016 6 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 7 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P =#5 divided by #6 1.88 10 F =#7 divided by #8 1.85 11 E =0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 5 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.61 14 1986 minimum-millions of dollars for PWR 101.58 15 2016 minimum-millions of dollars: #13 times #14 468.4 2

NUREG 1307, Rev 16, Table 3.2 3

NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002201 (South Region).

4 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

5 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S.,

the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

6 December 2016 value is 215.0 (See note #4) Information was preliminary as of 01/13/17.

7 December 2016 value is 152.0 (See note #4) Information was preliminary as of 01/13/17.

Page 12

ST. LUCIE NUCLEAR PLANT - UNIT 1 The St. Lucie Unit 1 trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRG guidance, either an order of the FPSC or an NRG exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, the data summarized below allocates the NRG license termination portion of the trust fund balance based upon percentages in FPL's most recent FPSC decommissioning cost study. St. Lucie Unit 1 is utilizing the formula method to demonstrate financial assurance pursuant to 10CFR 50.75(b).

,., .. ,.. ,. ****-****************-- . . ..... ,............ *-* **1

~;~~-!i~::~~n::;;i~~t~~~~a~i~~~~;; Te~minat~;;FOOds----t------------j I ------

1As of December 31, 2016

-~---~---------------**---: --*--~-----**--~-1 1************* *--**-* .. .. ............. **~*** ... -* *************----*- .............,...., ***-*-- -- ...... " --~ ........,...........'"'"**------*- .. .. .. *--**-

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.... **-*--***- .. ***-***. *r**********-***-****-* ..... *-----

i

w*~****-*******1

~ c"mrt-Stud;*,th~usa~ds of s2o1si~----*---------~_l____~_j lucense Tennination I i St Lucie Unit 1 589, 149 Ii 1~ftf~~~1::i:~~g~~~~!=~:=:-=-~:----**-*-**--*--~=:~-=r---------:i~-=-=:=- ~ffi~l

~!()~~---~--------~~~-

I .... ---------------------t-----

r------*--.. -*-----*-*--*"****---- *-*-**--***************--*---- -----*********-*"*--------****--*. *,--*------****. --- *------------*--*------*-**---**.--,

I 934,648 i I

ICategory% l ! l ILic~~~~'T~~i*~-~!i~~--:-::** ___ .-------~~------ _--------- - - - _-:_ _- --* . -__ . -_: . __ 63_:~3%!

!Spent Fuel Management r:-:--------: **-*-*-------*****-**---------*-* ----*----------*--*-** *r*--** I .. *-------*--**********r*

. I..**---****-*-***-***-****---*---i 31.69% J iSite Restoration i I 5.28% !

1-r~t;;i- ----- --- . --*---** --*: - i 100%!

...... -**-* ..................-....---**-----*-*---*-----***-*------***--*-- *******--------*******..--*-----*--_j__, ............,..,.........,............ ======

II .-.................. ..-. . . . . . . . .**-- * *--*--** --** * * * * * * * ------* . ..-------** * *--** * * *---*--*--- . .- *-* * * * : * * ----* ----** * -* *- -* * ---..******t****- . ... ----** -*-- * -----*-* * * * * -- 1\

~--"*--********~-"'"'****"'~"" .."""--""""'""--****-*-*-*---*--**--M'"-'"""" ... ,.~-*-**-**~-*--""'""'"-**-**i---*'"**--"-"""--~~*-*:---**~ *****----~'""-'"'"'"""~1

Projected Trust Fund Balance at Shutdown l: 1,482,685, 182 I

[Pro}e-:~;~=;t~~;td-0~;~~;;;~-r:~~i;atfo~:=;;;;:=--*1==---:=--::.=~-=~1 -- -:-~-=::=.*::~~=-~-:1 l(Allocatio~ based on TLG S!udy) __ ... . ... _ j _ _ --~34,60~ 1_5~--5j Page 13

St. Lucie Nuclear Plant - Unit 2 Florida Power and Light Company (FPL),

Florida Municipal Power Agency (FMPA),

Orlando Utilities Commission (OUC)

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75(b) and (c).

Plant Owner(% Ownership) NRC Minimum (a)

FPL (85.10449%) 398,601,292 FMPA (8.806%) 41,244,392 ouc (6.08951 %) 28,521,251 Total 468,366,936 (a) Refer to St. Lucie Unit 2 for calculation assumptions

2. The amount accumulated at the end of the calendar year preceding the date of the report. (Trust fund balances are net of taxes)

Total 8 FPL (85.10449%) 859,683,907 FMPA (8.806%) 73,909,113 ouc (6.08951 %) 41,044,267 Total 974,637 ,286

3. Projected Funds at Shutdown (2% real rate of return).

Total FPL (85.10449%) (see note (b)) 1,446,593,796 FMPA (8.806%) (see note (c)) 124,367,181 OUC (6.08951%) (see note (c)) 69,065,364 Total 1,640,026,341 (b) Pursuant to Florida Public Service Commission (FPSC) Order No. PSC-16-0250-PAA-EI, customer contributions to the decommissioning trust remain at zero effective June 29, 2016.

(c) Assumes no contributions to the fund.

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements.

None 8

NRC letter dated November 26, 2008, St. Lucie Plant, Unit Nos. 1 and 2 - Biennial Decommissioning Funding Report (TAC Nos.

MD9354 and MD9355), directed FPL to report all funds within the trust as designated for radiological decommissioning purposes since FPL does not earmark each cost component of decommissioning within the trust. However, the trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRC guidance, either an order of the FPSC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, St. Lucie Unit 2, allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in December 2015 with the FPSC ..

Page 14

ST. LUCIE NUCLEAR PLANT - UNIT 2 NRC Minimum Decommissioning Cost Determination NRC Minimum = $101.58 million X (0.65L + 0.13E + 0.228)

Where:

$101.58 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year 10 E =Energy escalation factor to current year 11 B = LLRW escalation factor to current year12

Item Description Value 10 1 Labor escalation factor for Quarter 4, 2016 126.2 2 Base adjustment factor from NUREG-1307 9 1.98 3 Escalation factor from NUREG-1307 100 4 L = #1 times #2 divided by #3 2.50 5 Electric power escalation factor, 2016 13 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 14 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P = #5 divided by #6 1.88 10 F = #7 divided by #8 1.85 11 E = 0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 12 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.61 14 1986 minimum-millions of dollars for PWR 101.58 15 2016 minimum-millions of dollars: #13 times #14 468.4 9

NUREG 1307, Rev 16, Table 3.2 10 NUREG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002201 (South Region).

11 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

12 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

13 December 2016 value is 215.0. (See note #12) Information was preliminary as of 01/13/17.

14 December 2016 value is 152.0 (See note #12) Information was preliminary as of 01/13/17.

Page 15

ST. LUCIE NUCLEAR PLANT - UNIT 2 The St. Lucie Unit 2 trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRG guidance, either an order of the FPSC or an NRG exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, the data summarized below allocates the NRG license termination portion of the trust fund balance based upon percentages in FPL's most recent FPSC decommissioning cost study. St. Lucie Unit 2 is utilizing the formula method to demonstrate financial assurance pursuant to 10CFR 50.75(b).

--------;***--** - -*-*****-**-*-**-*****---=-------***---*--********-*---*-*---- ----***---*--*-***-,--*--*-----*--*-r-----------****-*-*--*-** ***--, . *1- -** *--------****--i*-*-*------**;

Florida Power and Light Company 1 '

1

-oeco~rili~~i~~ii19rru~Ti=llilci -: _Cicenserermir1cii~~il-i=~~-~-r---*-----

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- ----- - ----i-- -------r-------1 I

!As of December 31 2016 i !

1*** **--****** ............... i jTLG Cost Study (thousands of $20151______ --*-*-----****---**-* -*-*--*---*--*-*--- . . ~j _s_t_L_uc_ie_u_n_it_2_l!--i_ _F_P_L -~'!---!_F_M_P_A_~_o_u_c_~

!License Termination 619,0BB I I

\sp~nt Fu~IM-;~;g-;~-~~! *t- -**------------- -----190-.s-1sf- -------

Site Restoration 62,22a 871,831 I

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. .. l ******!

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--****"*-------*-**----*--------- * - - *--*-**-* - - - ----1~**--*-*---*-~-*-*----***-*-----r- -***--*-*---**-

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License Termination

--*--1--* -I---- *****-71-~c).;;;;i----------*+--- II - -,:

..;I. - - 21. .:. .aso/oi T:_-----F-~--1 jsp1:mt ~u~I Management _ --t

@it~~estoration -*---- .. - - * * - - -********--** --*-* *--**----*-**--------***L---***--******-**---*-*---'_ _ _ _7_.1_4o/c_oi JTotal 100%i l--------***---------*****--------*-*--------}---------**-**-:*-*-*----****- I ._ ----- --}- -****--***~-+---***----**---~

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[Projected T~ust Fund Balance at_Shutdov.t~ .. -!

.. I

. " !,640,~-2_~.~~1-I .1A4~!59~,796 r l

124,367,181 I

I ... 69,065,36~1 fPro)ection at-Shutdown~License-Tennination-Portion -----i--***---'---------- ------1 . -- --1-- --------r- . ----- -

J!J\ll()E:_<l~on base_cl_()~ T~~-~~u_dy) .. . i. _ --~ 16~_84,22_~_1 __ ~~2_!!2.E*.~~~-L- .1111*?!~*2_5~.L. *-~¥1~~!_3~_]

1 Page 16

Turkey Point Nuclear Plant - Unit 3 Florida Power and Light Company (FPL),

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75(b) and (c).

Plant Owner(% Ownership) NRC Minimum (a)

FPL (100%) 453, 110,059 (a) Refer to Turkey Point Unit 3 for calculation assumptions

2. The amount accumulated at the end of the calendar year preceding the date of the report. Trust fund balance is net of taxes Total 15 FPL 100% 839,232,304

3. Projected Funds at Shutdown (2% real rate of return .

Total FPL 100% see note b ) 1, 142,066,625 (b) Pursuant to Florida Public Service Commission (FPSC) Order No. PSC-16-0250-PAA-EI, customer contributions to the decommissioning trust remain at zero effective June 29, 2016.

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements.

None 15 NRC letter dated November 26, 2008, St. Lucie Plant, Unit Nos. 1 and 2 - Biennial Decommissioning Funding Report (TAC Nos.

MD9354 and MD9355), directed FPL to report all funds within the trust as designated for radiological decommissioning purposes since FPL does not earmark each cost component of decommissioning within the trust. However, the trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRC guidance, either an order of the FPSC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, Turkey Point Unit 3, allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in December 2015 with the FPSC Page 17

TURKEY POINT NUCLEAR PLANT - UNIT 3 NRC Minimum Decommissioning Cost Determination NRG Minimum= $98.27 million X (0.65L + 0.13E + 0.228)

Where:

$98.27 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year17 E = Energy escalation factor to current year18 B = LLRW escalation factor to current year19

Item Description Value 1 Labor escalation factor for Quarter 4, 2016 17 126.2 2 Base adjustment factor from NUREG-1307 16 1.98 3 Escalation factor from NUREG-1307 100 4 L = #1 times #2 divided by #3 2.50 5 Electric power escalation factor, 2016 20 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 21 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P = #5 divided by #6 1.88 10 F = #7 divided by #8 1.85 11 E = 0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 19 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.61 14 1986 minimum-millions of dollars for PWR 98.27 15 2016 minimum-millions of dollars: #13 times #14 453.1 16 NUREG 1307, Rev 16, Table 3.2 17 NUREG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002201 (South Region).

18 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

19 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A,B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

20 December 2016 value is 215.0. (See note #19) Information was preliminary as of 01/13/17.

21 December 2016 value is 152.0 (See note #19) Information was preliminary as of 01/13/17.

Page 18

TURKEY POINT NUCLEAR PLANT - UNIT 3 The Turkey Point Unit 3 trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRG guidance, either an order of the FPSC or an NRG exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, the data summarized below allocates the NRG license termination portion of the trust fund balance based upon percentages in FPL's most recent FPSC decommissioning cost study. Turkey Point Unit 3 is utilizing the formula method to demonstrate financial assurance pursuant to 10CFR 50.75(b).

Florida Power and Light C9mpany . _

i Decommissio11ing Trust Fund - License Termination Funds

[:As ~i Dec~~ber 31~ -2o16- -- -------!---***- -----*-***--r-*-----*--*--------

r*-- -----*-*------*-*--*----** ------ ---------j Turkey Point ITLG Cost Study (thousands of $2015)

I

.*j..

Unit 3 i

l1-License Tennination jSpent Fuel Management i

--rl 580,783 224.586 j LSite~~~~CI!~~-- ______ _ l 40,665 I i 846,034 [

1-T_?_!<ll l-**

!Category%

J 1 1-~i~~~~~!~r:ri:i~C11.i~~-- -- ll: . . . . ***** . . ...J!~:~~~-i

~pe~!-~uel MCl~Cl£le_me~! 26.55%[

1

- *, - ---*----*-- - -**---*+-****.

isite Restoration l 4.81%i l1Total l *-**------** --*-----*-***---*------*****--*----*****-*-

------**-- * * ------r--*--*---

i -*--***-****-**** '

1 1Projected Trust Fund Balance at Shutdown I ** ~~-~*~*****--'-*"""---'***---********'-'-*- **-****l-~!1~!0~~~~~*~***!

~-*--- -*** -* ****- --*-

Projection at Shutdown - License

!Termination Portion (Allocation based on

[TL~ 8-.!~~~)___ * * --- __ _

Page 19

Turkey Point Nuclear Plant - Unit 4 Florida Power and Light Company (FPL),

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75(b) and (c).

Plant Owner(% Ownership} NRC Minimum (a}

FPL (100%) 453, 110,059 (a} Refer to Turkey Point Unit 4 for calculation assumptions

2. The amount accumulated at the end of the calendar year preceding the date of the re ort. Trust fund balance is net of taxes Total 22 FPL 100% 948, 100,859

3. Projected Funds at Shutdown 2% real rate of return .

Total FPL 100% see note b 1,308,903,859 (b} Pursuant to Florida Public Service Commission (FPSC} Order No. PSC-16-0250-PAA-EI, customer contributions to the decommissioning trust remain at zero effective June 29, 2016.

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements.

None 22 NRC letter dated November 26, 2008, St. Lucie Plant, Unit Nos. 1 and 2 - Biennial Decommissioning Funding Report (TAC Nos.

MD9354 and MD9355), directed FPL to report all funds within the trust as designated for radiological decommissioning purposes since FPL does not earmark each cost component of decommissioning within the trust. However, the trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRC guidance, either an order of the FPSC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, Turkey Point Unit 4, allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in December 2015 with the FPSC.

Page 110

TURKEY POINT NUCLEAR PLANT - UNIT 4 NRC Minimum Decommissioning Cost Determination NRC Minimum = $98.27 million X (0.65L + 0.13E + 0.228)

Where:

$98.27 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year24

=

E Energy escalation factor to current year2 5 B = LLRW escalation factor to current year2 6

Item Description Value 1 Labor escalation factor for Quarter 4, 2016 24 126.2 2 Base adjustment factor from NUREG-1307 23 1.98 3 Escalation factor from NUREG-1307 100 4 L =#1 times #2 divided by #3 2.50 5 Electric power escalation factor, 2016 27 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 28 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P =#5 divided by #6 1.88 10 F =#7 divided by #8 1.85 11 E =0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 26 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.61 14 1986 minimum-millions of dollars for PWR 98.27 15 2016 minimum-millions of dollars: #13 times #14 453.1 23 NUREG 1307, Rev 16, Table 3.2 24 NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002201 (South Region).

25 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

26 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

27 December 2016 value is 215.0 (See note #26) Information was preliminary as of 01/13/17.

28 December 2016 value is 152.0 (See note #26) Information was preliminary as of 01/13/17.

Page 111

TURKEY POINT NUCLEAR PLANT - UNIT 4 The Turkey Point Unit 4 trust includes non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the Florida Public Service Commission (FPSC). FPL understands that under NRC guidance, either an order of the FPSC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, the data summarized below allocates the NRC license termination portion of the trust fund balance based upon percentages in FPL's most recent FPSC decommissioning cost study. Turkey Point Unit 4 is utilizing the formula method to demonstrate financial assurance pursuant to 10CFR 50.75(b).

IFlorida Power and Light Coinpany ,

iii-;~~~~~~i~~i~g i" ***-*. " __. __.__..-'".....,. *-****- ****-~*****

Tru;t*f:~~d : Lice~s~-Termination Funds

. . .. ******-**-********************* ............ ****-*-*********************w***r*** ..............*..........,.....................f"' . .., ...... *-***

!As

,__ --**** of December - - 31, ... 2016 - ------------ --- -i-' i

............~-~-..

Turkey Point 1

TLG Cost Study (thousands of $2015) Unit4 l ""'"""-" * -***-*-"""" -'""""" *"'**

!License Termination 624,798

. I I

!spe:~~~~_Man~9.~m~~ ___ _ ______ _ 255,084 :

-*** ----- *1

site Restoration 53,633 i

Total 933,5151

category% _______ _

License Termination

>spent Fuel Management

<Site Restoration J I

66.93°1ol 27.33~/ol 5.75%1 iTotal ------------ ______ J __ -------- ......... I 1 100%:

I

' ---------------T-------------1----------- --------- -j

!Projected Trust Fund Balance at Shutdown 1- --- ----- * ---- - -- -

1 ri 1,308,903,859

- ---1 i

l. --- -'-- - -------------- -** -----------

l I

!Projection at Shutdown - License 1 I

!Termination Portion (Allocation based on I

!TLG Study) _______________________ ----------"**-********- l -~~~~~.320 J Page 112

Seabrook Station NextEra Energy Seabrook, LLC, Hudson Light and Power Department, Massachusetts Municipal Wholesale Electric Company, Taunton Municipal Lighting Plant Decommissioning Funding Status Report29

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75t b) and {c).

Plant Owner(% Ownership) NRC Minimum (a)

NextEra Enerav Seabrook, LLC. (88.22889%) 444,089,971 Hudson Light and Power Department (.07737%) 389,433 Massachusetts Municipal Wholesale Electric Company (11.5934%) 58,354,046 Taunton Municipal Lighting Plant (.10034%) 505,050 Total 503,338,500 (a) Refer to Seabrook for calculation assumptions

2. The amount accumulated at the end of the calendar year preceding the date of the report. (Trust fund balances are net of taxes)

Total 30 NextEra Enerav Seabrook, LLC. (88.22889%) 593,287,528 Hudson Light and Power Department (.07737%) 516,197 Massachusetts Municipal Wholesale Electric Company (11.5934%) 56,192,055 Taunton Municipal Lighting Plant (.10034%) 676,011 Total 650,671,790

3. Projected Funds at Shutdown (2% real rate of return).

Total NextEra Energy Seabrook, LLC. (88.22889%) 827,989, 111 Hudson Light and Power Department (.07737%) 720,401 Massachusetts Municipal Wholesale Electric Company (11.5934%) 78,421,351 Taunton Municipal Lighting Plant (.10034%) 943,437 Total 908,074,301 29 The New Hampshire Nuclear Decommissioning Financing Committee (NDFC) was established under New Hampshire law to provide assurance of adequate funding for decommissioning of nu.clear generating facilities. This was intended "to ensure proper and safe decommissioning and subsequent surveillance of nuclear reactor sites to the extent necessary to prevent such sites from constituting a hazard to future generations." RSA 162-F: 1. The NDFC is responsible for determining the appropriate amount of money that needs to be set aside and maintained in a trust fund, for the purpose of decommissioning any nuclear facilities located in the state of New Hampshire.

30 NRC letter dated November 26, 2008, St. Lucie Plant, Unit Nos. 1 and 2 - Biennial Decommissioning Funding Report (TAC Nos.

MD9354 and MD9355), directed FPL to report all funds within the trust as designated for radiological decommissioning purposes since FPL does not earmark each cost component of decommissioning within the trust. The Seabrook trusts contain non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the NDFC. NextEra understands that under NRC guidance, either an order of the NDFC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, Seabrook allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in 2015 with the NDFC.

Page 113

Seabrook Station NextEra Energy Seabrook, LLC, Hudson Light and Power Department, Massachusetts Municipal Wholesale Electric Company, Taunton Municipal Lighting Plant Decommissioning Funding Status Report

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements.

None Page 114

SEABROOK STATION NRC Minimum Decommissioning Cost Determination NRC Minimum =$105 million X (0.65L + 0.13E + 0.228)

Where:

$105 million is value for reference PWR in 1986 dollars L =Labor escalation factor to current year32 E = Energy escalation factor to current year33 B = LLRW escalation factor to current year34

Item Description Value 32 1 Labor escalation factor for Quarter 4, 2016 128.7 2 Base adjustment factor from NUREG-1307 31 2.16 3 Escalation factor from NUREG-1307 100 4 L =#1 times #2 divided by #3 2.78 5 Electric power escalation factor, 2016 35 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 36 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P =#5 divided by #6 1.88 10 F =#7 divided by #8 1.85 11 E =0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 34 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.79 14 1986 minimum-millions of dollars for PWR 105 15 2016 minimum-millions of dollars: #13 times #14 503.3 31 NUREG 1307, Rev 16, Table 3.2 32 NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, and Series CIU20100000002101 (Northeast Region).

33 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

34 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

35 December 2016 value is 215.0 (See note #34) Information was preliminary as of 01/13/17.

36 December 2016 value is 152.0 (See note #34) Information was preliminary as of 01/13/17.

Page 115

SEABROOK STATION The Seabrook trusts contain non-earmarked funds for spent fuel management and site restoration purposes collected at the direction of the New Hampshire Decommissioning Financing Committee (NDFC). NextEra understands that under NRC guidance, either an order of the NDFC or an NRC exemption would be necessary to utilize the funds for these non-radiological purposes. For informational purposes only, the data summarized below allocates the trust account amounts by license termination, spent fuel management and site restoration costs based on assumptions from the decommissioning cost study filed in 2015 with the NDFC. Seabrook is utilizing the formula method to demonstrate financial assurance pursuant to 10CFR 50.75(b).

NextEra Energy Seabrook, LLC Decommissioning Trust Fund - License Termination Funds As of December 31, 2016 TLG Cost Studll Scenario 1 {thousands of ~20151 Seabrook NextEra I Hudson I MMWEC I Taunton I License Termination 647,542 Spent Fuel Management 232,292 Site Restoration 51,564 Total 931,398 Component%

License Termination 69.52%

Spent Fuel Management 24.94%

Site Restoration 5.54%

Total 100%

Projected Trust Fund Balance at Shutdown 908,074,301 827,989, 111 720,401 78,421,351 943,437 Projection at Shutdown - License Termination Portion

{Allocation based on TLG Study) 631,326,510 575,648,353 500,850 54,521,395 655,912 Page 116

Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC (NextEra),

Central Iowa Power Cooperative (CIPCO),

Corn Belt Power Cooperative (Corn Belt)

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50. 751 b) and (c).

Plant Owner(% Ownership) NRC Minimum (a)

NextEra (70%) 409,931,516 CIPCO (20%) 117, 123,290 Corn Belt (10%) 58,561,645 Total 585,616,452 (a) Refer to Duane Arnold for calculation assumptions.

2. The amount accumulated at the end of the calendar year preceding the date of the report. (Trust fund balances are net of taxes)

Plant Owner(% Ownership) Total NextEra (70%) 354,653,394 CIPCO (20%) 60,672,615 Corn Belt (10%) 28,819,363 Total 444, 145,372 Projected Funds at Shutdown 3.

Plant Owner(% Ownership) Total NextEra (70%) (a) 535, 142,459 CIPCO (20%) (a) 137,679,279 Corn Belt (10%) (a) 65,397,365 Total 738,219, 102 (a) Projection includes a pro-rata credit during the dismantlement period pursuant to 10CFR 50.75(e)(1)(ii).

4. Assumptions used regarding escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors used in funding

. f ions.

pro1ec Plant Owner(% Ownership) Real Rate of Return NextEra (see note (c)) (70%) 2%

CIPCO (see note (d)) (20%) 4%

Corn Belt (see note (e)) (10%) 4%

Basis for Allowance:

(c) 10 CFR 50.75 allows licensees to assume up to a 2% real rate of return unless the licensee's rate-setting authority has specifically authorized a higher rate.

Page 117

Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC (NextEra),

Central Iowa Power Cooperative (CIPCO),

Corn Belt Power Cooperative (Corn Belt)

Decommissioning Funding Status Report (d) Central Iowa Power Cooperative (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.

(e) Corn Belt Power Cooperative is a public corporation incorporated under Chapter 499 Iowa Code (2009). Corn Belt 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. 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 May 2, 2014, 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 four percent.

5. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

6. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

7. Any material changes to trust agreements.

None Page 118

DUANE ARNOLD ENERGY CENTER NRC Minimum Decommissioning Cost Determination NRG Minimum= $121.2 million X (0.65L + 0.13E + 0.228)

Where:

$121.2 million is value for reference BWR in 1986 dollars L = Labor escalation factor to current year38 E = Energy escalation factor to current year39 B = LLRW escalation factor to current year40

Item Description Value 1 Labor escalation factor for Quarter 4, 2016 38 125.7 2 Base adjustment factor from NUREG-1307 37 2.08 3 Escalation factor from NUREG-1307 100 4 L = #1 times #2 divided by #3 2.61 5 Electric power escalation factor, 2016 41 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 42 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P = #5 divided by #6 1.88 10 F = #7 divided by #8 1.85 11 E = 0.54P(#9) + 0.46F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 40 13.132 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.83 14 1986 minimum-millions of dollars for BWR 121.2 15 2016 minimum-millions of dollars: #13 times #14 585.6 37 NUREG 1307, Rev 16, Table 3.2 38 NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002301 (Midwest Region).

39 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

40 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16 of the CWF in Andrews County, Texas is also available as a full-service (i.e. Class A, B and C) LLW disposal facility for waste generators located in States not affiliate with the Texas Compact Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposal at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S.,

41 December 2016 value is 215.0. (See note #40) Information was preliminary as of 01/11/17.

42 December 2016 value 152.0 (See note #40) Information was preliminary as of 01/13/17.

Page 119

Point Beach Nuclear Plant - Unit 1 NextEra Energy Point Beach, LLC (NextEra),

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuantto 10 CFR 50.75(b) and (c).

NRC Minimum (a)

NextEra (100%) 425,694,408 (a) Refer to Point Beach Unit 1 for calculation assumptions.

2. The amount accumulated at the end of the calendar year preceding the date of the re ort. Trust fund balance is net of taxes Total NextEra 100% 410,419,939

3. Projected Funds at Shutdown 2% real rate of return .

Total NextEra 100% see note b 579, 154,627 (b) Projection includes a pro-rata credit during the dismantlement period pursuant to 10CFR 50.75(e)(1)(ii).

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements. None Page 120

POINT BEACH NUCLEAR PLANT - UNIT 1 NRC Minimum Decommissioning Cost Determination NRG Minimum = $90.84 million X (0.65L + 0.13E + 0.228)

Where:

$90.84 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year44 E =Energy escalation factor to current year45 B = LLRW escalation factor to current year46

Item Description Value 44 1 Labor escalation factor for Quarter 4, 2016 125.7 2 Base adjustment factor from NUREG-1307 43 2.08 3 Escalation factor from NUREG-1307 100 4 L =#1 times #2 divided by #3 2.61 5 Electric power escalation factor, 2016 47 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 48 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P =#5 divided by #6 1.88 10 F =#7 divided by #8 1.85 11 E =0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 46 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.69 14 1986 minimum-millions of dollars for PWR 90.84 15 2016 minimum-millions of dollars: #13 times #14 425.7 43 NUREG 1307, Rev 16, Table 3.2 44 NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002301 (Midwest Region).

45 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

46 NUREG 1307 provides a value for B in Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

47 December 2016 value is 215.0 (See note #46) Information was preliminary as of 01/13/17.

48 December 2016 value is 152.0 (See note #46) Information was preliminary as of 01/13/17.

Page 121

Point Beach Nuclear Plant - Unit 2 NextEra Energy Point Beach, LLC (NextEra),

Decommissioning Funding Status Report

1. The minimum decommissioning fund estimate pursuant to 10 CFR 50.75(b) and (c).

NRC Minimum (a)

NextEra (100%) 425,694,408 (a) Refer to Point Beach Unit 2 for calculation assumptions.

2. The amount accumulated at the end of the calendar year preceding the date of the re ort. Trust fund balance is net of taxes Total NextEra 100% 386,710,421

3. Projected Funds at Shutdown 2% real rate of return .

Total NextEra 100% see note b 572,382,852 (b) Projection includes a pro-rata credit during the dismantlement period pursuant to 10CFR 50.75(e)(1)(ii).

4. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v). None

5. Any modifications to a licensee's method of providing financial assurance occurring since the last submitted report. None

6. Any material changes to trust agreements. None Page 122

POINT BEACH NUCLEAR PLANT - UNIT 2 NRC Minimum Decommissioning Cost Determination NRC Minimum= $90.84 million X (0.65L + 0.13E + 0.228)

Where:

$90.84 million is value for reference PWR in 1986 dollars L = Labor escalation factor to current year50 E = Energy escalation factor to current year51 B = LLRW escalation factor to current year52

Item Description Value 1 Labor escalation factor for Quarter 4, 2016 50 125.7 2 Base adjustment factor from NUREG-1307 49 2.08 3 Escalation factor from NUREG-1307 100 4 L = #1 times #2 divided by #3 2.61 5 Electric power escalation factor, 2016 53 215.0 6 Electric power escalation factor for Jan., 1986 from NUREG-1307 114.2 7 Fuel escalation factor for 2016 54 152.0 8 Fuel escalation factor for Jan., 1986 from NUREG-1307 82 9 P = #5 divided by #6 1.88 10 F = #7 divided by #8 1.85 11 E = 0.58P(#9) + 0.42F(#10) per NUREG-1307 1.87 12 Value of B from Table 2.1 of NUREG-1307 52 12.471 13 0.65L(#4) + 0.13E(#11) + 0.228(#12) 4.69 14 1986 minimum-millions of dollars for PWR 90.84 15 2016 minimum-millions of dollars: #13 times #14 425.7 49 NUREG 1307, Rev 16, Table 3.2 50 NU REG 1307 specified that source is Bureau of Labor Statistics Data, Employment Cost Index, Series CIU20100000002301 (Midwest Region).

51 NUREG 1307 specifies that source is a weighted calculation using Bureau of Labor Statistics Data, Producer Price Index-Commodities, Series wpu0573 (light fuel oils) and wpu0543 (industrial electric power).

52 NUREG 1307 provides a value for Bin Table 2.1. In the March 2017 Revision 16, the CWF in Andrews County, Texas, is also available as a full-service (i.e., Class A, B, and C) LLW disposal facility for waste generators located in States not affiliated with the Texas Compact. Out-of-compact generators, however, must submit an import petition to the Texas Compact Commission for approval prior to shipping. The State of Texas also limits total non-compact waste disposed at the CWF to 30-percent of licensed capacity and imposes additional fees on LLW disposed of from out-of-compact generators. With the availability of this full-service disposal facility to out-of-compact waste generators and the Clive, Utah disposal facility for any Class A LLW generated in the U.S., the Generic LLW Disposal Site option used in previous versions of NUREG-1307 is replaced with this option, which provides Bx values representing a composite of the disposal rates for these two disposal facilities.

53 December 2016 value is 215.0 (See note #52) Information was preliminary as of 01/13/17.

54 December 2016 value is 152.0 (See note #52) Information was preliminary as of 01/13/17.

Page I 23

Enclosure 2 Independent Spent Fuel Storage Installation (ISFSI)

Decommissioning Financial Assurance Update 10 CFR 72.30(c)

Cost Estimates Prepared by TLG Services, Inc.

ISFSI Decommissioning Financial Assurance Update 10 CFR 72.30(c)

The following table adjusts the ISFSI Decommissioning Funding Plans to 2016 dollars. The reports are provided in the following pages.

Projected 10 CFR 50.75 NRC Minimum Decommissioning ISFSI Trust Balance Decommissioning Amount per Trust Fund Value Decommissioning as of 12/31/16 Trust Fund Value 10 CFR 50.75(b) Surplus Cost Estimate Site ($Thousands) ($Thousands) ($Thousands) ($Thousands) ($Thousands)

St. Lucie Unit 1 1,014,178 1,482,685 468,367 1,014,318 4,754 St. Lucie Unit 2- FPL 859,684 1,446,594 398,601 1,047,993 4,045 St. Lucie Unit2- FMPA 73,909 124,367 41,244 83,123 419 St. Lucie Unit 2 - OUC 41,044 69,065 28,521 40,544 289 Turkey Point Unit 3 839,232 1, 142,067 453,110 688,957 3,887 Turkey Point Unit 4 948,101 1,308,904 453, 110 855,794 3,887 Seabrook - NextEra 593,288 827,989 444,090 383,899 4,947 Seabrook - MMWEC 56,192 78,421 58,354 20,067 650 Seabrook - Tauten 676 943 505 438 6 Seabrook - Hudson 516 720 389 331 4 Duane Arnold - NextEra 354,653 535,142 409,932 125,211 4,657 Duane Arnold - Corn Belt 28,819 65,397 58,562 6,836 665 Duane Arnold - Cl PCO 60,673 137,679 117,123 20,556 1,331 Point Beach Unit 1 410,420 579,155 425,694 153,460 4,053 Point Beach Unit 2 386,710 572,383 425,694 146,688 4,053 Page 11

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011, [IJ with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at St. Lucie in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating licenses for Units 1 and 2 at St. Lucie are currently set to expire on March 1, 2036 and April 6, 2043, respectively. Approximately 6,710 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration dates.

Under the current spent fuel management plan, and assuming that the units operate to the end of their currently licensed lives, approximately 2,528 spent fuel assemblies in 79 modules will have b~en relocated to the ISFSI during plant operations. Another 1,558 spent fuel assemblies are expected to be transferred to the ISFSI once operations cease (fuel that cannot be directly transferred from the pools to the DOE within the first 5 years of pool operations).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page j 2

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040 To facilitate immediate dismantling or safe-storage operations, the spent fuel is assumed to be packaged in dry storage containers (DSCs) for interim storage at the ISFSI.

Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or resulting in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.[2] For purposes of this analysis, Florida Power & Light Company's (FPL) current spent fuel management plan for the St. Lucie spent fuel l3l is based upon the first assemblies being removed from the site in 2032. Assuming a maximum rate of transfer of 3,000 metric tons ofuranium/year,l4l the spent fuel is projected to be completely removed from the St. Lucie site in 2073.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The St. Lucie ISFSI is based upon a NUHOMS-32PTH dry storage system and is operated under a general license (10 CFR Part 50). The NUHOMS system is comprised of a DSC and a horizontal storage module (HSM). The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-2 U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HL W as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

"Decommissioning Cost Analysis for the St. Lucie Nuclear Plant, Units I and 2," prepared for Florida Power &

Light Company by TLG Services, Inc., Document No. F02-1714-001, Rev. 0, November 2015 4

"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 Page [ 3

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040 induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

FPL's current spent fuel management plan for the St. Lucie spent fuel would result in 129 HSMs (nominal 32 assemblies per DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pools. This represents approximately 61 % of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of 14) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the two units at St. Lucie operating until the end of their current licenses, March 1, 2036 and April 6, 2043, respectively, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is expected to be approximately 288 feet in width, and 456 feet in length.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for characterization of 10% of the HSMs; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate is based on the premise that some of the DSC support structure and surrounding concrete within the HSMs will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 14 of the 129 HSMs are assumed to be affected, i.e.,

contain residual radioactivity. The allowance quantity is based upon the number ofDSCs Pagel4

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040 required for the final core off-load (i.e., 217 offloaded assemblies per unit for 434 total, 32 assemblies per DSC) which results in a total of approximately 14 HSMs that contain residual radioactivity.

It is not expected that there will be any residual contamination left oh the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

FPL has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the ISFSI pad and the immediate area surrounding the pad, and a significant fraction of the HS Ms surfaces.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. FPL, as licensee, will oversee the site activities; the estimate includes FPL's labor and overhead costs. The licensee's costs are based upon current, average, fleet salaries and associated expenses, for selected positions.

Low-level radioactive waste transport and disposal costs are based on rates consistent with the most recently developed decommissioning cost estimate.

Costs are reported in 2015 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[S]

The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 Page[5

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (DSC support structure removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), FPL's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2074, the year following all spent fuel removal.

Page I 6

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L.:.2017-040 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity ISFSIPad 456 288 No ISFSI Horizontal Storage Module Item Value N ates (all dimensions are nominal)

Outside Height (inches) 222 without vent cover Outside Length (inches) 248 without shield walls Outside Width (inches) 116 without shield walls Quantity (total) 143 Spent Fuel (129) GTCC (14)

Equivalent to the number ofHSMs used to store Quantity (with residual radioactivity) 14 last complete core offload HS Ms with Residual Radioactivity (pounds) 4,300,800 includes concrete and steel Dry Active Waste and Filters (pounds) 70,440 secondary waste from surveys and demolition Low-Level Radioactive Waste (cubic feet) 29,908 Low-Level Radioactive Waste (packaged density) 146 average weight density Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 14 no residual radioactivity Pagel?

Florida Power & Light Company St. Lucie Nuclear Plant ISFSI L-2017-040 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste (thousands, 2015 dollars) Volume Person-Hours Oversight and Removal Packa2in1?: Transport Disposal Other Total (ft3) Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 289 289 - - 1,264 Remediation (RSM disposition) 678 6 1,297 2,030 - 4,011 29,908 6,914 -

License Termination (radiological surveys) - - - - 1,915 1,915 - 18,155 -

Subtotal 678 6 1,297 2,030 2,204 6,215 29,908 25,068 1,264 Supporting: Costs NRC and NRC Contractor Fees and Costs - - - - 411 411 - - 776 Florida LLRW Inspection Fee - - - - 58 58 - - -

Insurance - - - - 136 136 - - -

Property taxes - - - - 24 24 - - -

Plant energy budget - - - - 199 199 - - -

Security (industrial) - - - - 147 147 - - 3,457 Licensee Oversight Staff - - - - 318 318 - - 3,803 Subtotal - - - - 1,293 1,293 - - 8,036 Total (w/o contingency) 678 6 1,297 2,030 3,497 7,508 29,908 25,068 9,300 Total (w/25% contingency) 848 7 1,621 2,537 4,372 9,385 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2074 Page\8

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,Pl with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Turkey Point in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating licenses for Units 3 and 4 at Turkey Point are currently set to expire on July 19, 2032 and April 10, 2033, respectively. Approximately 4,653 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration dates.

Under the current spent fuel management plan, and assuming that the units operate to the end of their currently licensed lives, approximately 1,920 spent fuel assemblies in 60 modules will have been relocated to the. ISFSI during plant operations. Another 1,869 spent fuel assemblies are expected to be transferred to the ISFSI once operations cease (fuel that cannot be directly transferred from the pools to the DOE within the first 5 years of pool operations).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 19

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 To facilitate immediate dismantling or safe-storage operations, the spent fuel is assumed to be packaged in dry storage containers (DSCs) for interim storage at the ISFSI.

Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or resulting in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactorY1 For purposes of this analysis, Florida Power & Light Company's (FPL) current spent fuel management plan for the Turkey Point spent fuel [3J is based upon the first assemblies being removed from the site in 2031. Assuming a maximum rate of transfer of 3,000 metric tons ofuranium/year,[4J the spent fuel is projected to be completely removed from the Turkey Point site in 2072.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The Turkey Point ISFSI is based upon a NUHOMS-32PT dry storage system and is operated under a general license (10 CFR Part 50). The NUHOMS system is comprised of a DSC and a horizontal storage module (HSM). The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HL W at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

"Decommissioning Cost Analysis for the Turkey Point Nuclear Plant, Units 3 and 4," prepared for Florida Power & Light Company by TLG Services, Inc., Document No. F02-l 714-002, Rev. 0, November 2015 4

"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 Page 110

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 induced activation as a result of the long-term storage of the spent fuel. The cost to dispose* of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

FPL's current spent fuel management plan for the Turkey Point spent fuel would result in 120 HSMs (nominal 32 assemblies per DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pools. This represents approximately 82% of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the two units at Turkey Point operating until the end of their current licenses, July 19, 2032 and April 10, 2033, respectively, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is expected to be approximately 128 feet in width, and 780 feet in length.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for characterization of 10% of the HSMs; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate is based on the premise that some of the DSC support structure and surrounding concrete within the HSMs will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 10 of the 120 HSMs are assumed to be affected, i.e.,

contain residual radioactivity. The allowance quantity is based upon the number ofDSCs Page 111

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 required for the final core off-load (i.e., 157 offloaded assemblies per unit for 314 total, 32 assemblies per DSC) which results in a total of approximately 10 HSMs that contain residual radioactivity.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is as~umed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

FPL has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the ISFSI pad and the immediate area surrounding the pad, and a significant fraction of the HSMs surfaces.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. FPL, as licensee, will oversee the site activities; the estimate includes FPL's labor and overhead costs. The licensee's costs are based upon current, average, fleet salaries and associated expenses, for selected positions.

Low-level radioactive waste transport and disposal costs are based on rates consistent with the most recently developed decommissioning cost estimate.

Costs are reported in 2015 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[S]

The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.

Nuclear Regulatory Commission's Office ofNuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision I, February 2012 Page 112

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (DSC support structure removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), FPL's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2073, the year following all spent fuel removal.

Page 113

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity ISFSIPad 780 128 No ISFSI Horizontal Storage Module Item Value Notes (all dimensions are nominal)

Outside Height (inches) 222 without vent cover Outside Length (inches) 248 without shield walls Outside Width (inches) 116 without shield walls Quantity (total) 130 Spent Fuel (120) GTCC (10)

Equivalent to the number of HS Ms used to Quantity (with residual radioactivity) 10 store last complete core offloads HSMs with Residual Radioactivity (pounds) 3,072,000 includes concrete and steel Dry Active Waste and Filters (pounds) 50,772 secondary waste from surveys and demolition Low-Level Radioactive Waste (cubic feet) 21,386 Low-Level Radioactive Waste (packaged density) 146 average weight density Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 10 no residual radioactivity Page 114

Florida Power & Light Company Turkey Point Nuclear Plant ISFSI L-2017-040 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste (thousands, 2015 dollars) Volume Person-Hours Oversight and Removal Packa!!in!! Transport Disposal Other Total (ft3) Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 269 269 - - 1,216 Remediation (RSM disposition) 635 5 983 1,452 - 3,074 21,386 6,285 -

License Termination (radiological surveys) - - - - 1,594 1,594 - 14,738 -

Subtotal 635 5 983 1,452 1,863 4,937 21,386 21,023 1,216 Supportin!! Costs NRC and NRC Contractor Fees and Costs - - - - 411 411 - - 776 Florida LLRW Inspection Fee - - - - 42 42 - - -

Insurance - - - - 68 68 - - -

Property taxes - - - - 10 10 - - -

Plant energy budget - - - - 194 194 - - -

Security (industrial) - - - - 153 153 - - 3,457 Licensee Oversight Staff - - - - 326 326 - - 3,803 Subtotal - - - - 1,203 1,203 - - 8,036 Total (w/o contingency) 635 5 983 1,452 3,066 6,140 21,386 21,023 9,252 Total (w/25% contingency) 794 6 1,229 1,814 3,832 7,675 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2073 Page 115

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,Pl with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

FPL/NextEra filed its initial ISFSI Decommissioning Funding Plan for Seabrook Station on December 17, 2012,l2l along with the other units in the fleet. Supplemental information was provided on August 12, 2014 in response to a request by the NRC for additional information. l3l In accordance with the rule that states "at intervals not to exceed 3 years, the decommissioning funding plan must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination," this letter provides an updated, detailed cost estimate for decommissioning the ISFSI at Seabrook Station in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

FPL Letter L-2012-442, ISFSI Decommissioning Funding Plans, NRC ADAMS Accession No. ML12354Al34, dated December 17, 2012 FPL Letter L-2014-214, Reply to Request for Additional Information for Review of the Decommissioning Funding Plans Regarding the Independent Spent Fuel Storage Installations, NRC ADAMS Accession No. ML14225A655, dated August 12, 2014 Page 116

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040

2. Spent Fuel Management Strategy The operating license for Seabrook Station is currently set to expire on March 15, 2030.

Approximately 2,295 spent fuel assemblies are projected to be generated as a result of plant operations through the license expiration date.

Assuming that the unit operates to the end of its currently licensed life, and no spent fuel is transferred to the DOE during this time period, approximately 1,120 spent fuel assemblies in 35 modules will have been relocated to the ISFSI during plant operations.

The remaining 1, 17 5 spent fuel assemblies are expected to be transferred to the ISFSI once operations cease.

To facilitate immediate dismantling or safe-storage operations, the spent fuel is assumed to be packaged in dry storage containers (DSCs) for interim storage at the ISFSI.

Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel.

allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor.l4l However, for purposes of this analysis, NextEra Energy Seabrook, LLC's (NextEra) current spent fuel management plan for the Seabrook Station spent fuel is based on the New Hampshire Nuclear Decommissioning Finance Committee's directive in its 2014 Order. In that Order, fuel is assumed to remain on site until 2100.[SJ

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4 U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV -Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HLW at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

5 New Hampshire Nuclear Decommissioning Financing Committee's December 12, 2014 Final Report and Order in Docket NDFC 2014-1 Page 117

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040

4. ISFSI Description The Seabrook Station ISFSI is based upon a NUHOMS-HD-32PTH dry storage system and operated under a general license (10 CFR Part 50). The NUHOMS system is comprised of a DSC and a horizontal storage module (HSM). The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

NextEra's current spent fuel management plan for the Seabrook Station spent fuel would result in 72 HSMs (nominal 32 assemblies per DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents 100% of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of 5) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on Seabrook Station operating until the end of its current license,

March 15, 2030, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad, approximately 123 feet in width, and 462 feet in length, is sufficient to store the projected amount of spent fuel.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for characterization of 10% of the HSMs; it is likely that some of this characterization will take place well before the Page 118

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040 last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate is based on the premise that some of the DSC support structure within the HS Ms and surrounding concrete will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 72 HSMs are assumed to be affected, i.e.,

contain residual radioactivity. The allowance quantity is based upon the number ofDSCs required for the final core off-load (i.e., 193 offloaded assemblies, 32 assemblies per DSC) which results in a total of approximately 7 HSMs that contain residual radioactivity.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

The Seabrook ISFSI pad is placed on a bedrock foundation. NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the I SF SI pad and the immediate area surrounding the pad, and a significant fraction of the HSMs surfaces.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. NextEra, as licensee, will oversee the site activities; the estimate includes NextEra's labor and overhead costs. The licensee's costs are based upon current, average, fleet salaries and associated expenses, for selected positions.

Low-level radioactive waste transportation and disposal costs are based on rates consistent with the most recently developed decommissioning cost estimate, completed in May 2015J6l Costs are reported in 2014 dollars.

6 "Decommissioning Cost Analysis for the Seabrook Station," TLG Document No. N35-1705-001, Rev. 0, dated May2015 Page 119

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040 Contingency has been added at an overall rate of25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.Pl The estimate is limited to costs necessary to terminate the ISFSl's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (DSC support structure removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), ~extEra's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2101, the year following all spent fuel removal.

7 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 Page I 20

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft) Width (ft) Residual Radioactivity ISFSI Pad 462 123 No ISFSI Horizontal Storage Module Item Value Notes (all dimensions are nominal)

Outside Height (inches) 222 without vent cover Outside Length (inches) 248 without shield walls Outside Width (inches) 116 without shield walls Quantity (total) 77 spent fuel (72) GTCC (5) equivalent to the number ofHSMs used to Quantity (with residual radioactivity) 7 store last complete core offload HSM Concrete with Potential Activation (pounds) 1,261,568 HSM Internal Steel with Residual Radioactivity (pounds) 33,075 Low-Level Radioactive Waste (cubic feet) includes disposition of transfer cask and any 15,728 dry active waste (DAW) average packaged weight density, excluding Low-Level Radioactive Waste (packaged density) 87 transfer cask which is shipped intact Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 5 no residual radioactivity Page 121

NextEra Energy Seabrook, LLC Seabrook Station ISFSI L-2017-040 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste (thousands, 2014 dollars Volume Person-Hours Oversight and Removal Packaging Transport Disposal Other Total (cubic feet) Craft Contractor Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 217 217 - - 1,096 Remediation (activated metal removal) 23 53 608 1,198 - 1,881 15,728 169 -

License Termination (radiological surveys) - - - - 1,085 1,085 - 8,700 -

Subtotal 23 53 608 1,198 1,302 3,183 15,728 8,869 1,096 Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 397 397 - - 776 Insurance - - - - 67 67 - - -

NH Disposal Tax - - - - 236 236 - - -

Plant energy budget - - - - 87 87 - - -

Security (industrial) - - - - 183 183 - - 5,096 Licensee Oversight Staff - - - - 271 271 - - 3,866 Subtotal - - - - 1,240 1,240 - - 9,737 Total (w/o contingency) 23 53 608 1,198 2,542 4,423 15,728 8,869 10,833 Total (w/25% contingency) 29 66 759 1,497 3,177 5,529 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2101 Page 122

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,lll with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

The rules also requires re submittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Florida Power & Light Company (FPL) in August 2014. [ZJ In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Duane Arnold in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating license for Duane Arnold is currently set to expire on February 21, 2034.

Approximately 4,712 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date.

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

FPL Letter No. L-2014-214 to the NRC, Reply to Request for Additional Information for Review of the Decommissioning Funding Plans Regarding the Independent Spent Fuel Storage Installations, dated August 12, 2014 (NRC Accession No. ML14225A655)

Page J 23

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 Under the current spent fuel management plan and assuming that the unit operates to the end of its currently licensed life, approximately 2,318 spent fuel assemblies in 3 8 modules will have been relocated to the ISFSI during plant operations. Another 1,403 spent fuel assemblies are expected to be transferred to the ISFSI once operations cease (fuel that cannot be directly transferred from the pools to the DOE within the first 5 years of pool operations).

To facilitate immediate dismantling or safe-storage operations, the spent fuel is assumed to be packaged in dry storage containers (DSCs) for interim storage at the ISFSI.

Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or resulting in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactorY1 For purposes of this analysis, NextEra Energy Duane Arnold, LLC's (NextEra) current spent fuel management plan for the Duane Arnold spent fuel[4J is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Duane Arnold fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of3,000 metric tons ofuranium/year,E51the spent fuel is projected to be removed from the Duane Arnold site in 2072.

3. ISFSI Decommissioning Strategy This analysis assumes that, at the conclusion of the spent fuel transfer process, the ISFSI will be promptly decommissioned by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt ofSNF and/or HLW at the DOE repository. This priority ranking shall be based on the age ofSNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

4 "2015 Decommissioning Cost Update of the Duane Arnold Energy Center," prepared for FPL Energy Duane Arnold, LLC by EnergySolutions, Document No 164024-DCE-016, Rev. 0, September I, 2015 5

"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 Page 124

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The Duane Arnold ISFSI is based upon a NUHOMS-61BT dry storage system and is operated under a general license (10 CFR Part 50). The NUHOMS system is comprised of a DSC and a horizontal storage module (RSM). The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

NextEra's current spent fuel management plan for the Duane Arnold spent fuel would result in 61 HSMs (nominal 61 assemblies per DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pool. This represents 78% of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on Duane Arnold operating until the end of its current license, February 21, 2034, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The nominal size of the ISFSI pad is sufficient to store the projected amount of spent fuel and is expected to be approximately 122 feet in width, and 502 feet in length.

It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely Page I 25

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 small. To validate this assumption, the estimate accounts for characterization of 10% of the HSMs; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate is based on the premise that some of the DSC support structure within the HSMs will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 61 HSMs are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number ofDSCs required for the final core off-load (i.e., 368 offloaded assemblies, 61 assemblies per DSC) which results in a total of approximately 7 HSMs that contain residual radioactivity.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the ISFSI pad and the immediate area surrounding the pad, and a significant fraction of the HSMs surfaces.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. NextEra, as licensee, will oversee the site activities; the estimate includes NextEra's labor and overhead costs. The licensee's costs are based upon current, average, fleet salaries and associated expenses, for selected positions.

Low-level radioactive waste disposal costs are based on rates consistent with the most recently developed decommissioning FPL cost estimates (year 2015 dollars), escalated to 2016 dollars. Transport costs are based on current trucking tariffs.

Costs are reported in 2016 dollars.

Page I 26

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[6]

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (DSC support structure removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), NextEra's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2073, the year following all spent fuel removal.

6 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 Page 127

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity ISFSI Pad 502 122 No ISFSI Horizontal Storage Module Item Value Notes (all dimensions are nominal)

Outside Height (inches) 180 without vent cover Outside Length (inches) 238 without shield walls Outside Width (inches) 116 without shield walls Quantity (total) 65 Spent Fuel (61) GTCC (4)

Equivalent to the number of HSMs used Quantity (with residual radioactivity) 7 to store last complete core offload)

HSM Internal Steel with Residual Radioactivity (pounds) 22,400 Low-Level Radioactive Waste (cubic feet) 20,729 Low-Level Radioactive Waste (packaged density) 119 Average weight density Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 4 no residual radioactivity Page I 28

NextEra Energy Duane Arnold, LLC Duane Arnold Energy Center ISFSI L-2017-040 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste (thousands, 2016 dollars) Volume Person-Hours Class A Oversight and (cubic Craft Contractor Removal Packaging Transport Disposal Other Total feet) Hours Hours Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 235 235 - - 1,072 Remediation (activated metal removal) 52 3 569 2,405 14 3,043 20,729 314 -

License Termination (radiological surveys) - - - - 1,021 1,021 - 8,046 -

Subtotal 52 3 569 2,405 1,271 4,299 20,729 8,360 1,072 Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 366 366 - - 776 Insurance - - - - 81 81 - - -

Security (industrial) - - - - 266 266 - - 5,949 Licensee Oversight Staff - - - - 311 311 - - 4,171 Subtotal - - - - 1,023 1,023 - - 10,897 Total (w/o contin2ency) 52 3 569 2,405 2,294 5,322 20,729 8,360 11,969 Total (w/25% contin2ency) 64 4 711 3,006 2,868 6,653 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2073 Page 129

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 10 CFR 72.30 ISFSI Decommissioning Cost Estimate

1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,Pl with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

The rules also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Florida Power & Light Company (FPL) in August 2014_l2l In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Point Beach in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of the key assumptions contained in the cost estimate; and

2. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2. Spent Fuel Management Strategy The operating licenses for Units 1 and 2 at Point Beach are currently set to expire on October 5, 2030 and March 8, 2033, respectively. Approximately 3,616 spent fuel assemblies are currently projected to be generated as a result of plant operations through the license expiration date.

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

FPL Letter No. L-2014-214 to the NRC, Reply to Request for Additional Information for Review of the Decommissioning Funding Plans Regarding the Independent Spent Fuel Storage Installations, dated August 12, 2014 (NRC Accession No. ML14225A655)

Page I 30

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 Under the current spent fuel management plan and assuming that the units operate to the end of their currently licensed lives, approximately 2,048 spent fuel assemblies in 68 modules (16 VS Cs and 52 HSMs) will have been relocated to the ISFSI during plant operations. Another 544 spent fuel assemblies (17 HSMs) are expected to be transferred to the ISFSI once operations cease (fuel that cannot be directly transferred from the pools to the DOE within the first 5 years of pool operations).

To facilitate immediate dismantling or safe-storage operations, the spent fuel is assumed to be packaged in dry storage containers (DSCs) for interim storage at the ISFSI.

Transferring the spent fuel from the pool to the ISFSI will permit decontamination and dismantling of the spent fuel pool systems and fuel pool areas or result in reduced operating expenses should the station be placed into a SAFSTOR dormancy configuration.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactorYl For purposes of this analysis, NextEra Energy Point Beach, LLC's (NextEra) current spent fuel management plan for the Point Beach spent fuel [4l is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Point Beach fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of3,000 metric tons ofuranium/year,l5l the spent fuel is projected to be removed from the Point Beach site in 2074.

3. ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative) by removing and disposing of residual radioactivity and verifying that remaining materials satisfy NRC release criteria.

U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV - Responsibilities of the Parties, B. DOE Responsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNF and/or HL W at the DOE repository. This priority ranking shall be based on the age of SNF and/or HLW as calculated from the date of discharge of such materials from the civilian nuclear power reactor. The oldest fuel or waste will have the highest priority for acceptance, except as ... "

4 "2015 Decommissioning Cost Update of the Point Beach Nuclear Plant," prepared for NextEra Energy Point Beach, LLC by EnergySolutions, Document No. 164023-DCE-015, Rev O,September 15, 2015 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 Page I 31

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 For purposes of providing an estimate for a funding plan, financial assurance is expected to be provided on the basis of a prompt ISFSI decommissioning scenario. In this estimate the ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4. ISFSI Description The Point Beach ISFSI is currently using a NUHOMS-32PT dry storage system (there are also an additional 16 VSC-24 casks on site, storing 384 total assemblies). The ISFSI is operated under a general license (10 CFR Part 50).The NUHOMS system is comprised of a DSC and a horizontal storage module (HSM). The DSCs are assumed to be transferred directly to the DOE and not returned to the station. Some of the remaining HSMs are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the spent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established for unrestricted use, form the basis of the ISFSI decommissioning estimate.

NextEra's current spent fuel management plan for the Point Beach spent fuel would result in 69 HSMs (nominal 32 assemblies per NUHOMS DSC) being in position on the storage pad at the site after all spent fuel has been removed from the spent fuel pool (in addition to the 16 VSCs). The irradiated fuel in the 85 dry storage systems (69 HSMs and 16 VSCs) represents 72% of the total spent fuel projected to be generated during the currently licensed operating period.

In addition to the spent fuel HSMs located on the ISFSI pad after shutdown there are projected to be additional HSMs that are expected to be used for Greater-than-Class-C (GTCC) storage. The HSMs used for the GTCC canisters (estimated quantity of2) are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5. Key Assumptions I Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the Point Beach units operating until the end of their current licenses, October 5, 2030 and March 8, 2033, respectively, and the assumptions associated with DOE's spent fuel acceptance, as previously described.

The current size of the ISFSI pads (2 each at 195 feet long by 35 feet wide) is not sufficient to store the projected amount of spent fuel to support decommissioning. For purposes of this estimate an expansion of the current ISFSI area is assumed.

Page j 32

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 It is not expected that the HSMs will have any interior or exterior radioactive surface contamination. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Any neutron activation of the steel and concrete is expected to be extremely small. To validate this assumption, the estimate accounts for characterization of 10% of the HS Ms; it is likely that some of this characterization will take place well before the last of the fuel is removed from the ISFSI in order to establish a more definitive decommissioning scope.

The decommissioning estimate is based on the premise that some of the DSC support structure within the HSMs will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 8 of the 69 HSMs are assumed to be affected, i.e., contain residual

,J radioactivity. The allowance quantity is based upon the number ofDSCs required for the final core off-load (i.e., 121 offloaded assemblies per unit for 242 total, 32 assemblies per DSC) which results in a total of approximately 8 HSMs that contain residual radioactivity.

It is not expected that there will be any residual contamination left on the concrete ISFSI pad. It is expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. Therefore, it is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate.

NextEra has no record of onsite subsurface material associated with the ISFSI containing residual radioactivity that will require remediation to meet the criteria for license termination.

To support an application for License Termination, the estimate assumes that a Final Status Survey will be performed; this will include a 100% survey of the ISFSI pad and the immediate area surrounding the pad, and a significant fraction of the HS Ms surfaces.

Decommissioning is assumed to be performed by an independent contractor. As such, essentially all labor, equipment, and material costs are based on national averages, i.e.,

costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. NextEra, as licensee, will oversee the site activities; the estimate includes NextEra's labor .and overhead costs. The licensee's costs are based upon current, average, fleet salaries and associated expenses, for selected positions.

Low-level radioactive waste transportation and disposal costs are based on rates consistent with the most recently developed decommissioning FPL cost estimates (year 2015 dollars), escalated to 2016 dollars.

Page 133

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 Costs are reported in 2016 dollars.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[6]

The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meet the §20.1402 criteria for umestricted use. Disposition of released material and structures is outside the scope of the estimate.

6. Cost Estimate The estimated cost to decommission the ISFSI and release the facility for umestricted use is provided in Table 2. The cost has been organized into three phases, including:

An initial planning phase - empty HSMs are characterized and the specifications and work procedures for the decontamination (DSC support structure removal) developed.

The remediation phase - residual radioactivity is removed, packaged in certified waste containers, transported to the low-level waste site, and disposed of at low-level waste.

The final phase - license termination surveys, independent surveys are completed, and an application for license termination submitted.

In addition to the direct costs associated with a contractor providing the decommissioning services, the estimate also contains costs for the NRC (and NRC contractor), NextEra's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it should be conservatively assumed that all expenditures will be incurred in the year 2075, the year following all spent fuel removal.

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012 Page I 34

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft) Width (ft) Radioactivity VSC ISFSI Pad 195 35 No HSM ISFSI Pads 195 35 No HSM ISFSI Pads (future pad) 160 35 No ISFSI Horizontal Storage Module Item Value Notes (all dimensions are nominal)

Outside HSM Height (inches) 180 without vent cover Outside HSM Length (inches) 228 without shield walls Outside HSM Width (inches) 116 without shield walls Quantity (total dry fuel storage systems) 87 HSMs (69), VS Cs (16) GTCC (2)

Equivalent to the number of HSMs used Quantity (HSMs with residual radioactivity) 8 to store last complete core offload HSM Internal Steel with Residual Radioactivity (pounds) 24,800 Low-Level Radioactive Waste (cubic feet) 24,128 Low-Level Radioactive Waste (packaged density) 119 Average weight density Other Potentially Impacted Items Item Value Notes Number ofHSMs used for GTCC storage 2 no residual radioactivity Page I 35

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant ISFSI L-2017-040 Table 2 ISFSI Decommissioning Costs 1 and Waste Volumes Waste (thousands, 2016 dollars) Volume Person-Hours Class A Oversight and (cubic Craft Contractor Removal Packaging Transport Disposal Other Total feet) Hours Hours Decommissioning Contractor Planning (characterization, specs and procedures) - - - - 429 429 - - 2,048 Remediation (activated metal removal) 61 3 664 2,798 14 3,540 24,128 361 -

License Termination (radiological surveys) - - - - 1,442 1,442 - 10,842 -

Subtotal 61 3 664 2,798 1,886 5,411 24,128 11,203 2,048 Supporting Costs NRC and NRC Contractor Fees and Costs - - - - 373 373 - - 776 Insurance - - - - 137 137 - - -

Security (industrial) - - - - 261 261 - - 5,825 Licensee Oversight Staff - - - - 303 303 - - 4,072 Subtotal - - - - 1,073 1,073 - - 10,673 Total (w/o contingency) 61 3 664 2,798 2,959 6,484 24,128 11,203 12,721 Total (w/25% contine:ency) 76 4 830 3,497 3,699 8,105 Note 1: for funding planning purposes decommissioning costs can be assumed to be incurred in year 2075 Page j 36

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