ML18183A220

Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar

ML18183A220
Person / Time
Site:	Vermont Yankee  File:NorthStar Vermont Yankee icon.png
Issue date:	06/28/2018
From:	State S NorthStar Group Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLM-0002
Download: ML18183A220 (14)

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North Star Scott E. State CEO Northstar Group Services, Inc.

370 7th Avenue, Suite 1803 New York, NY 10001 Phone (212) 951-3660 Fax (212) 951-8923 www.northstar.com 10 CFR 50.80 10 CFR 50.90 10 CFR 72.50 June 28, 2018 A TIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar (EPID No. L-2017-LLM-0002)

Vermont Yankee Nuclear Power Station License No. DPR-28 Docket Nos. 50-271 and 72-59

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement," BVY 17-005, dated February 9, 2017 (ML17045A140)

2. Letter, Entergy Nuclear Operations, Inc. to USN RC, "Supplemental Information Regarding Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment and Notification of Amendment to Decommissioning Trust Agreement," BVY 17-027, dated August 22, 2017 (ML17234A141)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar," BVY 17-043, dated December 4, 2017 (ML17339A896) *

4. Letter, NorthStar Group Services, Inc. to USNRC, "Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar,"

dated December 22, 2017 (ML18009A459)

5. March 2, 2018 Vermont Yankee Settlement Agreement {ML18066A044)

6. Letter, USNRC to Entergy Nuclear Operations, Inc.," Vermont Yankee Nuclear Power Station - Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to

Page 2 of 3 Northstar (EPID No. L-2017-LLM-0002)," dated April 5, 2018 (ML18045A817)

7. Letter, Northstar Group Services, Inc. to USNRC, "Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers from Entergy to Northstar," BVY 18-016, dated May 21, 2018 (IY1L181428193)

8. Letter, Northstar Group Services, Inc. to USN RC, "Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) (EPID No. L-2017-LLM-0002),"

BVY 18-023, dated May 25, 2018 (ML18150A315)

Dear Sir or Madam:

This "Supplemental Response to Request for Additional Information Regarding the Request for Direct and Indirect License Transfers" is submitted by Northstar Group Services, Inc.

(Northstar), on behalf of itself, Entergy Nuclear Vermont Yankee, LLC (ENVY), which is to be renamed Northstar Vermont Yankee, LLC (Northstar VY), Northstar Nuclear Decommissioning Company, LLC (Northstar NOC) and Entergy Nuclear Operations, Inc. (ENOI).

By letter dated February 9, 2017, ENOI, ENVY, and Northstar NOC (together, Applicants) submitted an application for consent to the direct and indirect license transfers 'of Renewed Facility Operating License No. DPR-28 for Vermont Yankee Nuclear Power Station (VY) and the general license for the VY Independent Spent Fuel Storage Installation (ISFSI) from ENOI and ENVY to Northstar NOC and Northstar VY (Reference 1, as supplemented by Reference 2).

Specifically, the Applicants requested the U.S. Nuclear Regulatory Commission's (NRC) written consent to the direct transfer of ENO l's licensed authority to Northstar NOC, and to the indirect transfer of control of ENVY's licenses to Northstar Decommissioning Holdings, LLC, and its parents, in accordance with Section 184 of the Atomic Energy Act, and Title 1O of the Code of Federal Regulations (CFR), sections 10 CFR 50.80 and 10 CFR 72.50.

In Reference 7, Applicants responded to NRC's Requests for Additional Information dated April 5, 2018 (ML18045A817). Northstar provided a revised Form of Financial Support Agreement in the amount of $140 million as Enclosure 6 to Attachment 2.

Northstar has further revised the language in Section 3 of the Form of Financial Support Agreement, and it therefore is providing a revised Form of Financial Support Agreement as Attachment 1 to this letter.

In Reference 7 as Enclosures 1-3 of Attachment 2, Applicants provided annual cash flow analyses in response to RAl-1. Northstar now anticipates the possibility of alternative tax treatment that might impact the assumed opening trust balances reflected in these analyses. to this letter provides further information regarding NorthStar's revised assumptions, and it also. includes updates to Enclosures 1-3 to reflect the revised assumptions.

Reference 8 included a cash flow analysis to support the exemption request that was identical to Enclosure 1 of Attachment 2 in the Reference 7. The updated Enclosure 1 to Attachment 2 to this letter should be substituted for the analysis provide in Reference 8.

This letter contains no new regulatory commitments.

In the event that the NRC has any questions about the transactions described in this letter or wishes to obtain any additional information, please contact Coley Chappell of ENOI at

Page 3 of 3 802-451-3374, or contact Gregory G. Dicarlo of Northstar Group Services, Inc. at 203-222-0584 x3051 or GDiCarlo@NorthStar.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 28, 2018.

Sincerely,

~1\:te~

CEO

Attachment:

1. Form of Financial Support Agreement cc:

2. Supplemental Response to RAl-1 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-5A10 Washington, DC 20555 Ms. June Tierney, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601

Docket No. 50-271 and 72-59 Attachment 1 Vermont Yankee Nuclear Power Station Form of Financial Support Agreement

/ Page 1 of 3 SUPPORT AGREEMENT BETWEEN NORTHSTAR GROUP SERVICES, INC. AND NORTHSTAR VERMONT YANKEE, LLC THIS SUPPORT AGREEMENT (this "Agreement"), dated as of June 28 , 2018, is made by and between NorthStar Group Services, Inc., a Delaware corporation ("Parent"), and NorthStar Vermont Yankee, LLC a Delaware limited liability company f/k/a Entergy Nuclear Vermont Yankee, LLC (the "Subsidiary").

WITNESSETH:

WHEREAS, Parent is the indirect owner of 100% of the outstanding interests in the Subsidiary; WHEREAS, the Subsidiary owns the Vermont Yankee Nuclear Power Station, located in Vernon, Vermont ("VYNPS"), Renewed Facility Operating License No. DPR-28 on the basis of which the Subsidiary and Northstar Nuclear Decommissioning Company, LLC, a Delaware limited liability company, under the ownership of Parent, are authorized to own, possess maintain and decommission the VYNPS facilities and nuclear material (the "NRC License"); and WHEREAS, Parent and the Subsidiary desire to take certain actions to assure the Subsidiary's ability to pay the expenses of maintaining and decommissioning VYNPS safely and protecting the public health and safety and to meet Nuclear Regulatory Commission ("NRC")

and State of Vermont requirements until the NRC License is terminated and site restoration under state-law requirements is complete ( collectively, the "Decommissioning Costs").

Now, THEREFORE, in consideration of the mutual promises herein contained and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto agree as follows:

1. Availability of Funding; Use of Proceeds. From time to time, upon request of the Subsidiary, Parent shall provide or cause to be provided to the Subsidiary such funds as the Subsidiary determines to be necessary to pay the Decommissioning Costs; provided, however, in any event the aggregate amount which Parent is obligated to provide under this Agreement shall not exceed $140 million.

2. No Guarantee to Third Parties. Without limiting the obligation set forth in paragraph 1, this Support Agreement is not, and nothing herein contained, and no action taken pursuant hereto by Parent shall be construed as, or deemed to constitute, a direct or indirect guarantee by Parent to any third party (other than the NRC and the Vermont Public Utility Commission) of the payment of the Decommissioning Costs or of any liability or obligation of any kind or character whatsoever of the Subsidiary. This Agreement may, however, be relied upon by

/ Page 2 of 3 the NRC as a parental guarantee in determining the financial qualifications of the Subsidiary to hold the NRC License, including funding the costs associated with the spent fuel management program, and by the Vermont Public Utility Commission as a parental guarantee in determining financial assurance for the completion of decommissioning and site.restoration.

3. Waivers. Parent hereby waives any failure or delay on the part of the Subsidiary in asserting or enforcing any of its rights or in making any claims or demands hereunder.

4. Amendments and Termination. This Agreement may not be amended or modified at any time without 30 days' prior written notice to the NRC, the Vermont Department of Public Service, the Vermont Agency of Natural Resources, and the Vermont Attorney General's Office. This Agreement shall terminate at such time as Parent or any affiliate is no longer the direct or indirect owner of any of the shares or other ownership interests in the Subsidiary. This Agreement shall also terminate with respect to the Decommissioning Costs at such time as the NRC License is terminated for all areas *of the VYNPS site and the Vermont Agency of Natural Resources has determined that site restoration is complete.

5. Successors. This Agreement shall be binding upon the parties hereto and their respective successors and assigns.

6. Third Parties. Except as expressly provided in Sections 2 and 4 with respect to the NRC, the Vermont Public Utility Commission, the Vermont Department of Public Service, the Vermont Agency of Natural Resources, and the Vermont Attorney General's Office, this Agreement is not intended for the benefit of any person other than the parties hereto, and shall not confer or be deemed to confer upon any other such person any benefits, rights, or remedies hereunder.

7. Governing Law. This Agreement shall be governed by the laws of the State of Delaware.

8. Subsidiary Covenants. The Subsidiary shall take no action to (a) cause Parent, or its successors and assigns, to void, cancel or otherwise modify its $140 million support commitment hereunder; (b) cause Parent to fail to perform its commitments hereunder or (c) impair Parent's performance hereunder, or remove or interfere with the Subsidiary's ability to draw upon Parent's commitment, in each case, without the prior written consent of the NRC's Director of the Office of Nuclear Reactor Regulation. Further, the Subsidiary shall inform the NRC in writing any time that it draws upon the $140 million commitment.

[SIGNATURE PAGE FOLLOWS]

/ Page 3 of 3 IN WI1NESS WHEREOF, the parties hereto have caused this Agreement to be executed and delivered by their respective officers thereunto duly authorized as of the day and year first above written.

NorthStar Group Services, Inc.

By:

Name:

Title:

NorthStar Vermont Yankee, LLC By:

Name: Scott E. State

Title:

/ Enclosures Attachment 2 Vermont Yankee Nuclear Power Station Supplemental Response to RAl-1

Attachment 1 / Page 1 of 3 Supplemental Response:

The cash flow analyses previously provided as Enclosures 1-3 of Attachment 2 to Reference 7 are consistent with the expected opening balance of the trust fund,

_beginning with a transfer completed at the end of 2018 and with work commencing January 1, 2019. However, Northstar is providing revised cash flow analyses that reflect a more conservative potential scenario, where trust fund income taxes would be paid prior to closing the transaction, as opposed to after the transaction closing, as currently contemplated. Under this more conservative scenario, the opening trust fund balance would be reduced from $513.35 million to $487.89 million.

As Northstar previously indicated in its Responses to RAls (Reference 7), Entergy and Northstar have agreed to contribute $30 million collectively to an escrow account at the time of the transaction closing. Consistent with requirements for the prepayment method of financial assurance pursuant to 10 CFR 50. 75(e)(i), the escrow account will be segregated from the licensee assets and outside the administrative control of the licensee and its*subsidiaries or affiliates and will contain cash or liquid assets that will produce earnings. Alternatively, the escrow account may be considered an equivalent form of financial assurance pursuant to 10 CFR 50. 75(e)(vi).

Accordingly, Northstar is providing revised cash flow analyses that reflect the availability of the $30 million escrow account funds (subject to the restrictions on the use of those funds in paragraphs 2(c) and 4 of the Vermont Settlement Agreement (Reference 5)), at the time the Licenses are transferred, so that the assumed combined opening balance of available funds in the trust fund and the escrow account under the more conservative scenario would be $517.89 million (i.e., $487.89 million+ $30 million). Updates to Enclosures 1-3 of Attachment 2 to Reference 7 are provided as Enclosures 1-3 to this letter.

In addition, Northstar notes that further sources of funding will be available to Northstar VY that have not been incorporated into the cash flow analyses. For example, Northstar has committed to make further contributions to the escrow account of an additional $25 million, which are expected to be completed by 2024, consistent with paragraph 2(c) of the Vermont Settlement Agreement (Reference 5).

Also, pursuant to paragraph 3(a) of the Vermont Settlement Agreement (Reference 5),

North Star will have a $60 million trust account for site restoration costs prior to the transfer of the Licenses, which is more than double NorthStar's estimated site restoration costs (approximately $25 million). Once partial site release and partial site restoration are complete in 2027, Northstar would seek the required approvals and consents necessary to obtain release of the projected excess funds in the site restoration subaccount. Even if site restoration costs are $10 million (40%) higher than estimated, and assuming all necessary approvals and consents are obtained, Northstar conservatively projects that it would be able to access at least $25 million in funds released from the site restoration subaccount in 2027.

/ Page 2 of 3 Finally, it should be noted that the projected license termination (radiological decommissioning) costs in column 1 of Enclosures 1 through 3 include $50 million of contingency. Along with the absence of any credit given to DOE recoveries, these analyses are therefore very conservative.

/ Page 3 of 3 Enclosures to Attachment 2 - Cash Flow Analysis (License Termination Plus $20 million for Spent Fuel) - Cash Flow Analysis (2019-2052 With Expected DOE Recoveries) - Cash Flow Analysis (2019-2030 Without Expected DOE Recoveries)

ENCLOSURE 1-Supplemental RAI Northstar Nuclear Power Station - Prompt D&D Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs

{In Thousand s of Period of Perfo rm ance Dollars)

Base Case NDT Model - $20M Spent Fuel Management Withdrawals Column 4 Column 2 Column 3 Column 1 Beginning of Column 7 Column 8 50.54 (bb) Total Column 5 Column 6 50.75 Year Trust+ Trust Fund Year Ending Year Spent Fuel Withdrawals Total DOE License Escrow Fund Earnings Trust Fund Management Cost (Sum of Withdraws Recovery Termination Cost Balance (4) Balance (1) (2) Columns 1-2)

(3) 2019 66,672 9,241 75,913 517,890 (75,913) 0 8,840 450,817 2020 65,612 6,141 71,753 450,817 (71,753) 0 7,581 386,645 2021 69,745 4,241 73,986 386,645 {73,986) 0 6,253 318,912 2022 78,438 377 78,815 318,912 {78,815) 0 4,802 244,899 2023 87,519 - 87,519 244,899 {87,519} 0 3,148 160,528 2024 76,253 - 76,253 . 160,528 {76,253) 0 1,685 85,960 2025 41,369 - 41,369 85,960 {41,369) 0 892 45,483 2026 9,390 - 9,390 45,483 (9,390) 0 722 36,815 2027 0 - 0 36,815 0 0 736 37,551 2028 0 - 0 37,551 0 0 751 38,302 2029 0 - 0 38,302 0 0 766 39,068 2030 0 - 0 39,068 0 0 781 39,849 2031 0 - 0 39,849 0 0 797 40,646 2032 0 - 0 40,646 0 0 813 41,459 2033 0 - 0 41,459 0 0 829 42,289 2034 0 - 0 42,289 0 0 846 43,134 2035 0 - 0 43,134 0 0 863 43,997 2036 0 - 0 43,997 0 0 880 44,877 2037 0 - 0 44,877 0 0 898 45,774 2038 0 - 0 45,774 0 0 915 46,690 2039 0 - 0 46,690 0 0 934 47,624 2040 0 - 0 47,624 0 0 952 48,576 2041 0 - 0 48,576 0 0 972 49,548 2042 0 - 0 49,548 0 0 991 50,539 2043 0 - 0 50,539 0 0 1,011 51,549 2044 0 - 0 51,549 0 0 1,031 52,580 2045 0 - 0 52,580 0 0 1,052 53,632 2046 0 - 0 53,632 0 0 1,073 54,705 2047 0 - 0 54,705 0 0 1,094 55,799 2048 0 - 0 55,799 0 0 1,116 56,915 2049 0 - 0 56,915 0 0 1,138 58,053 2050 0 - 0 58,053 0 0 1,161 59,214 2051 0 - 0 59,214 0 0 1,184 60,398 2052 3,454 - 3,454 60,398 (3,454) 0 1,139 58,083 2053 498,452 20,000 518,452 517,890 {518,452) 0 58,645 58,083 518,4S2 Footnotes: (1) Annual Spent ISFSI Operations Costs

{2) ISFSI Costs Paid from NDT limited to $20 million (3 ) Beginning NDT + Escrow Accou nt Balance of $517.890 mil lion calculated as follows:

Minim um NDT pre-tax balance required pursua nt to MIPA/DCAA 538,3 50 Less: Site Restoration Trust {25,000)

Less: Est. Tax on Unrea li zed Gains Pa id @ Closing {25,460)

- - - - - - - --'P_lu'""s_: E _s_cr_o_w_A_cc_o_u_nt_a_t_Cl_os_in~g~p_u_rs_u_an_t_to_VT_M_O_U_ _ _ _30~,_0 0_0_ ($20,000 Entergy; $10,000 Northsta r)

Beginning Balance at Closing 517,890 (4) 2% annual earnings rate

ENCLOSURE 2-Supplemental RAI Northstar Nuclear Power Station - Prompt D&D Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands of Period of Performance Dollars)

Base Case NOT Model - with DOE Standard Contract Spent Fuel Management Cost Recoveries Column 2 Column 3 Column 4 Column 1 Column 7 Column 8 50.54 (bb) Total Beginning of Year Column 5 Column 6 50.75 Trust Fund Year Ending Year Spent Fuel Withdrawals Trust + Escrow Total DOE Recovery license Earnings Trust Fund Management Cost (Sum of Fund Balance Withdraws (3) (4) (5)

Termination Cost (6) Balance (1) Columns 1-2) (2) 2019 66,672 9,241 75,913 517 890 (75,913) 0 8,840 450,817 2020 65,612 6,141 71,753 450,817 (71,753) 0 7,581 386,645 2021 69,745 4,241 73,986 386,645 (73,986) 0 6,253 318,912 2022 78,438 4,241 82,679 318,912 (82,679) 0 4,725 240,958 2023 87,519 4,241 91,760 240,958 (91,760) 10,000 3,184 162,382 2024 76,253 4,241 80,494 162,382 (80,494) 21,205 2,062 105,154 2025 41,369 8,657 50,026 105,154 (50,026) 4,241 1,187 60,557 2026 9,390 5,104 14,494 60,557 (14,494) 8,657 1,094 55,814 2027 0 9,276 9,276 55,814 (9,276) 5,104 1,033 52,676 2028 0 9,276 9,276 52,676 (9,276) 9,276 1,054 53,729 2029 0 9,276 9,276 53,729 (9,276) 9,276 1,075 54,804 2030 0 9,276 9,276 54,804 (9,276) 9,276 1,096 55,900 2031 0 9,276 9,276 55,900 (9,276) 9,276 1,118 57,018 2032 0 9,276 9,276 57,018 (9,276) 9,276 1,140 58,158 2033 0 9,276 9,276 58,158 (9,276) 9,276 1,163 59,321 2034 0 9,276 9,276 59,321 (9,276) 9,276 1,186 60,508 2035 0 9,276 9,276 60,508 (9,276) 9,276 1,210 61,718 2036 0 9,276 9,276 61,718 (9,276) 9,276 1,234 62,952 2037 0 9,276 9,276 62,952 (9,276) 9,276 1,259 64,211 2038 0 9,276 9,276 64,211 (9,276) 9,276 1,284 65,495 2039 0 9,276 9,276 65,495 (9,276) 9,276 1,310 66,805 2040 0 9,276 9,276 66,805 (9,276) 9,276 1,336 68,141 2041 0 9,276 9,276 68,141 (9,276) 9,276 1,363 69, 504 2042 0 9,276 9,276 69,504 (9,276) 9,276 1,390 70,894 2043 0 9,276 9,276 70,894 (9,276) 9,276 1,418 72,312 2044 0 9,276 9,276 72,312 (9,276) 9,276 1,446 73,759 2045 0 9,276 9,276 73,759 (9,276) 9,276 1,475 75,234 2046 0 9,276 9,276 75,234 (9,276) 9,276 1,505 76,738 2047 0 9,276 9,276 76,738 (9,276) 9,276 1,535 78,273 2048 0 9,276 9,276 78,273 (9,276) 9,276 1,565 79,839 2049 0 9,276 9,276 79,839 (9,276) 9,276 1,597 81,435 2050 0 9,276 9,276 81,435 (9,276) 9,276 1,629 83,064 2051 0 9,276 9,276 83,064 (9,276) 9,276 1,661 84,725 2052 3,454 9,807 13,261 84,725 (13,261) 9,276 1,615 82,355 2053 82,355 0 9,807 1,843 94,005 498,452 287,802 786,254 517,890 (786,254) 290,902 71,467 94,005 Footnotes: (1) Annual Spe nt ISFSI Operations Costs (2) Beginning NOT+ Escrow Account Balance of $517.890 million calculated as follows:

Minimum NOT pre-tax balance required pursuant to MIPA/DCAA 538,350 Less: Site Restoration Trust (25,000)

Less: Est. Tax on Unrealized Gains Paid@ Closing (25,460)

Plus: Escrow Account at Closing pursuant to VT MOU 30,000 ($20,000 Entergy; $10,000 NorthStar)

Beginning Balance at Closing 517,890 (3) $10 million DOE Round 3 Claim Recovery in 2023 (4) $21.205 million DOE Recovery in 2024 is for Round 4 claim (2019 thru 2023 @$4.241 million/year)

(5) 2025 thru 2031 DOE Recoveries based on annual claims paid by DOE pursuant to post litigation Settlement Agreement (6) 2% annual earnings rate

ENCLOSURE 3-Supplemental RAI NorthStar Nuclear Power Station - Prompt D&D Methodology Annual Cash Flow Analysis

• Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands of Period of Performance Dollars)

Base Case NDT Model* $20M Spent Fuel Management Withdrawals* 2030 Fuel Pick-up Column2 ~ Columns Column 6

!:Qlumn u Column 1 Spent Fuel Colum n 9 Column 10 $140M Support 50.54 (bb) Total Beginning of Yea r Column7 Column 8 50.75 Management Tru st Fund Yea r End ing Alfeement Year Spent Fuel Withdrawals Trust + Escrow Total DOE License Paid by Support Earnings Trust Fund Funding by Management Cost (Sum of Fund Balance Withdraws Recovery Termination Cost Alfeement (4) Balance Northstar (1) Columns 1-3) (3)

(2) (S) 2019 66,672 9,241 75,913 517,890 (75,913) 0 8,840 450,817 0 2020 65,612 6,141 71,753 450,817 (71,753) 0 7,581 386,645 0 2021 69,745 4,241 73,986 386,645 (73,986) 0 6,253 318,912 0 2022 78, 438 4,241 (3,864) 78,815 318,912 (78,815) 0 4,802 244,899 3,864 2023 87,519 4,241 (4,241) 87,519 244,899 (87,519) 0 3,148 160,528 4,241 2024 76, 253 4,241 (4,241) 76,253 160,528 (76,253) 0 1,685 85,960 4,241 2025 41,369 8,657 (8,657) 41,369 85,960 (41,369) 0 892 45,483 8,657 2026 9,390 5,104 (5,104) 9,390 45,483 (9,390) 0 722 36,815 5,104 2027 0 9,276 (9,276) 0 36,815 0 0 736 37,551 9,276 2028 0 9,276 (9,276) 0 37,551 0 0 751 38,302 9,276 2029 0 9,276 (9,276) 0 38,302 0 0 766 39,068 9,276 2030 3,454 9,276 (12,730) 0 39,068 0 0 781 39,849 12,730 2031 0 498,452 83,211 (66,665) 514,998 517,890 (514,998) 0 36,957 39,849 66,665 Total Spent Fuel Management Costs 83,211 514,998 Paid by Support Northstar Agreement (66,665) Ending NDT Balance 39,849

_ _ _s_p_en_t_F_ue_1_c_osts_P_a_id_fr_o_m_N_DT_ _ _ _ _1_6_ ,54_6_ (Proposed Agreement w/NRC) Su pport Agreement Availa bility 73,335 73,335 TOTAL FUNDING SURPLUS 113,184 l 140,000 Footnotes: (1) Annual Spent ISFSI Operations Costs (2) ISFSI Costs Paid by Northstar via Support Agreement (All SFM Costs > $20 million)

(3) Beginning NDT + Escrow Account Balance of $517.890 million calculated as follows :

Minimum NOT pre-tax balance required pursuant to MIPA/DCAA 538,350 Less: Site Restoration Trust (25,000)

Less: Est. Tax on Unrealized Gains Paid@ Closing (25,460)

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Beginning Balance at Closing 517,890 (4) 2% annual earnings rate (5) Funding provided by $140 million Northstar Support Agreement