ML20236T911

Testimony of Js Robinson Re Licensing of Facility

ML20236T911
Person / Time
Site:	Seabrook
Issue date:	07/20/1998
From:	NEW ENGLAND POWER CO.
To:
Shared Package
ML20236T231	List: ML20236T229 ML20236T911
References
NUDOCS 9807290155
Download: ML20236T911 (20)

Text

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i NEW ENGLAND POWER COMPANY

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i N.H.N.D.F.C. Docket No. 98-01 l Witness: Robinson DIRECT TESTIMONY r

t OF JAMES S. ROBINSON I

i Table of Contents -

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l L In trod u ction ........ .......

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II. Pu rpose of Testimony... .... ........ .. ........ ... . .. ..... ............. ..... 3 III. Expected Service Life .. . ... ....... ...... ... .... .................. ............. 3 l IV. Intergenerational Ineq uity ........ .... .... .... . ...... .. . .............. 11 i

V. Fu nding Meth od ology........... ...... ..... . .. . ... . ........ ..... ............ 13 l VI. Summary..................................................................................... 13 1

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NEW ENGLAND POWER COMPANY

[ N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson 1 Testimony of James S. Robinson 2 1. Introduction 3 Q. Please state your name, business address and occupation.

4 A. My name is James S. Robinson. My business address is 25 Research Drive, Westborough, N 5 MA 01582. I am Vice President and Director of Generation Investments for New England 6

Power Company ("NEP"), a subsidiary of the New England Electric System (NEES). In 7 that capacity, I am responsible for oversight of NEP's investments in six nuclear units -

[ 8 Seabrook, Millstone 3, Connecticut Yankee, Maine Yankee, Vermont Yankee and the 9 Yankee plant in Rowe, Massachusetts. I serve as a member of the Board ofDirectors of the 10 four " Yankee" companies: Yankee Atomic Electric Company, Connecticut Yankee Atomic 11 Power Company, Ve ment Yankee Nuclear Power Corporation and Maine Yankee Atomic 12 Power Company.

13 14 Q.

- Please describe your educational background and training.

15 A.

In 1975, I received a Bachelor of Arts degree in Business Economics from the College of 16 Wooster in Ohio and, in 1982, received a degree ofMaster of Business Administration 17 from the University of New Haven in Connecticut.

18 19 Q. Please describe your professional experience with the NEES Companies.

h 20 A.

Ijoined the NEES Companies as Coordinator of Nuclear Projects in 1988. In 1990, I

NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson 1

became Manager ofJoint Owned Projects / Contract Administration. In 1993, I became L 2 Manager, Wholesale Business Administration. In 1997, I became Director of Nuclear 3 Investments and was promoted to my current position in June 1998.  !

4 5' Q. Please describe your professional experience prior tojoining the NEES Companies.

6 A. Immediately prior tojoining the NEES Companies, I was employed by The United 7 Illuminating Company (UI), in New Haven, Connecticut, as Manager of Nuclear 8 Entitlement. I was employed by UI for 8 years, during which time I filled positions in 9 Operations, Engineering, Budgeting, Financial Planning and Rates. Prior to joining UI, I 10 was employed by The Toledo Edison Company in its Rate Department.

11 12 Q. Do you have any other professional experience which is relevant to your testimony?

{

13 A. Yes. From 1987 through 1996,I was a member of the Steering Committee of the Nuclear  ;

1 14 Nonoperating Owners' Group ("NNOG") and have served as its Chairman. NNOG is made 15 up ofindividuals whose purpose is to serve the interests of nonoperating owners, and/or 16 agencies which have financial interests in nuclear power plants comparable to an owner.

17- NNOG provides a forum for nonoperating owners to exchange information on managing 18 their interests and aseociated costs from such plants.

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NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 l Witness: Robinson 1 II. . Purpose of Testimony 2 Q. Wh it is the purpose of your testimony?

3 A. The purpose of my testimony is to present NEP's position regarding the appropriate 4

decommissioning funding period for Seabrook Unit 1 ("Seabrook Station" or "the unit"). It 5 is NEP's position that it is appropriate to collect the necessary funds for the eventual 6 decommissioning obligation for Seabrook Station over a period of time that matches the 7

expected service life of the unit. I explain that recent experience in the nuclear industry 8 makes it unlikely that the unit will operate for the maximum term of the operating license 9 issued by the Nuclear Regulatory Commission (NRC), contrary to the direct testimony filed 10 on behalf of North Atlantic. Rather, a more reasonable estimate of the service life of the 11 unit, based upon industry experience, is 25 years from the date of commercial operation, 12 ending in mid-2015. In addition to a shorter funding period, I also propose that funding of 13 decommissioning should be sufficient to ensure the necessary funds are available to 14 decommission the unit commuscing in mid-2015.

q 15 16 III. Expected Service Life

17. Q.- What is NEP's ownership interest in Seabrook Station.

18 A. NEP owns 9.95766% of the unit.

i 19 20 Q. Does the current period for collecting necessary funds for the eventual decommissioning l

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NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson 1 obligation for the unit match the expected service life of the unit?

l l 2 A. . No. Until now, utilities have typically used the full term of the NRC operating license as 1

3 the basis for nuclear plant depreciation and decommissioning. While this period represents 4 a maximum period that a nuclear plant is authorized to operate, industry experience and, in 5 particular, recent events, make it clear that it is no longer reasonable to expect the 6 Seabrook Station will operate for its maximum license term.

7

.8 Q. . Why is that?

9 A. In light of rccent retirements of many commercial nuclear power plants, it is no longer 10 reasonable to assume that the anticipated energy-producing life of a nuclear plant is equal 11 to the maximum period that plant is legally licensed to operate. It is important to recognize 12 that no commercial nuclear plant has operated for the full term ofits NRC operating 13 license. Moreover, over the past 9 years, eleven commercial operating U.S. nuclear power

.14 plants have shutdown prior to the' expiration of their operating licenses . Those plants are 15 Rancho Seco, Fort St. Vrain, Yankee Atomic (Rowe), San Onofre Unit 1, Trojan, 16 Connecticut Yankee (Haddam Neck), Maine 1 ankee, Big Rock Point, Zion 1, Zion 2 and 17 Millstone Unit 1. (NEP is a 30% stockholder and power purchaser of Yankee Atomic, a 18 15% stockholder and power purchaser of Connecticut Yankee and a 20% stockholder and 19 17.%% power purchaser of Maine Ya6kee).

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NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson

! l Q. How do these shutdowns support your argument of a shorter expected service life for 2 Seabrook Station?

l j 3 A. All of these units were shut down ultimately for economic reasons which indicates that 4

economic value, rather than technical ability to operate, has now become the predominant 5 force in determining an expected service life of an op_erating nuclear plant.

6 l

7 Q. How long did these units operate?

8 A. On average, the eleven commercial units which have been permanently retired operated for 9 23.4 years. (See Exhibit JSR-1) From the date ofcommercial operation to the date of l 10 permanent retirement, the plants operated for the following durations:

11 Unit Xnats l

12 Rancho Seco 12.1 13 Fort St Vrain 10.6 14 Yankee 30.6 1

15 San Onofre 1 24.8 16' Trojan 16.5

17. Connecticut Yankee 28.9 l

18 Maine Yankee 24.6 l

! 19 Big Rock Point 34.7 20 Zion 1 24.0 l  !

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NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson i

i 1' Zion 2 23.3 2- Millstone 1 27.4 l

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. 4 Q. Why does the fact that other nuclear plants have shut down before the expiration of their '

S NRC operating licenses lead you to conclude that it ipot reasonable to expect Seabrook 6 Station to avoid a similar outcome?

7 A. In each of the recent shutdowns, the principal reason for the shutdown was economic -

8 while it appeared to be technically feasible to keep the plants in service, their continued 9 operation was detennined to be too costly. When it became necessary to spend significant 10 amounts of money to upgrade systems to comply with new regulatory requirements or to i 11 replace major plant components, the plants' owners determined that it was not economic to

-12 do so in light of the value of the plants' capacities, the cost of altemative power at that time i

13 and the finite remaining term of the operating licensees. Similarly, while we have no reason

! 14 to question the technical reliability of the facilitics at Seabrook Station or to expect that the 15 -!

unit will not be operated safely, it is reasonable to expect that similar economic factors will ,

16 affect the unit later in its life. Increased competition and the addition ofnew and more 17 efficient generation capacity in the region will increase the economic pressures on

.I8 Seabrook Station, suggesting a shorter economic service life for the unit than that proposed I 19 by North Atlantic. ,

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I NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson 1 Q. Whyis that?

2 A. The experience of many nuclear plants, to date, has been that they require potentially 3 significant expenditures either to fulfill normal operational requirements or to upgrade (or l

4 replace) major plant systems later in their lives. As recent experience has shown, more 5 frequently a plant's continued operation is costly relative to alternative sources of power, 6 and shutdown is the prudent course of action. There is no reason to expect Seabrook Station 7

will be immune from the same economic pressures as other plants. It is also worth noting 8 that of the nine nuclear units which have operated in New England, four have now been 9 retired early.

10 11 Q. Of the eleven units which have been prematurely shutdown, does any one situation stand l

12 out as being of greater significance?

13 A. Yes. I believe that the announcement earlier this year of the retirement of the two Zion 14 units is very significant for two reasons: 1) it is the first multi-unit station to be retired; and 15

2) it is operated by Commonwealth Edison Company, a subsidiary of Unicom, the largest 16 nuclear power plant operating company in the country. The fact that both units were 17- shutdown indicate that even with the potential economies of scale that result from operating ,

18 two units at the same site, supported by an organization that operates 12 units overall, these  !

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! 19 units were not seen to be economic over the long tenn.

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4 NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson 1 Q. Other than the recent shutdown of the eleven units, are there other factors which suppon 2 your position that economic pressures will continue to be significant and will have a major

'3 impact on shortening a nuclear plant's expected service life?

4 A. Yes, there are several.

5 1) Because nuclear plants operate with finite operating licenses, they suffer from a 6 phenomenon which can be called " finite life syndrome". This simply means that each 7 incremental capital expenditure needed to continue to operate the plant must be cost-

'8 effective over the remaining license life. As a plant gets older, the remaining life gets 9 shoner and the cost-benefit threshold grows. In the event that an older plant is faced 10 with major incremental capital expenditures (as is often the case), its owners may fmd 11 that the additional expenditures are not cost justified over the remaining license life, t

.12 when compared to alternative sources ofpower.

I 13 2) As the nuclear industry matures and fewer plants are operating as the result of 14 premature shutdown or expiration of their operating licenses, the reduction in the 15 number of operating plants will impact the level of costs allocated to the units by the 4

16 operating company's nuclear services organization and corporate support functions.

l l '17 Seabrook Station falls into this category, as it is currently operated by a subsidiary of ,

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,. Northeast Utilities which also operates the three Millstone units, and to a lesser degree, i

19 Connecticut Yankee.

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j. NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 l Witness: Robinson L 1 Q. Is the shorter expected service life based on actual operating performance of the unit?

2 A. No. In fact, as the shutdown of Yankee Rowe, Connecticut Yankee and Maine Yankee 3 plants make clear, even an excellent operating record may not be enough to prevent a l

4 premature plant shutdown when economic conditions warrant it.

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6 Q. Is there any evidence that more nuclear plants may be prematurely shutdown?

7 A. Yes. While there has been considerable speculation that additional early nuclear plant i

8 retirements will be forthcoming as the electric generation business becomes more 1

l 9 competitive, there is a specific instance worth mentioning. On several occasions, most 10 recently this month, GPU Nuclear indicated that its Oyster Creek unit will likely be retired j i

11 ifit cannot be sold. Oyster Creek began commercial operation about 29 years ago.  !

12 13 Q. Are there other reasons that support your belief that Seabrook Station's expected service 14 life will be shorter than its license life?

15. A. Yes. Although the unit is among the most recent units to enter commercial service, as the 16 industry matures and other operating plants retire, Seabrook Station will be among the 17 shrinking number of units still operating. For example, today there are 104 nuclear units 18: with operating licenses. (See Exhibit JSR-2) By the year 2026, when Seabrook Station's 19 operating license is set to expire, there will be, at most, about 20 units in operation in the 20 U.S. (See Exhibit JSR-3) In my opinion, this decline in the number of operating units will l .__ -

NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson I result in increased costs from outside vendors to operate and maintain each unit. At the 2 present time, the nuclear service vendors have a relatively large base of operating plants 3 over which to spread their fixed costs. As the number of operating units diminishes, the 4 fixed costs that must be assigned to each unit will increase. In addition, a reduced market 5 for nuclear services will likely reduce the population of viable nuclear services vendors.

6 7 Q In summary, what is the basis for your estimate of a 25 year expected service life?

1 8 A. While, of course, one caanot predict the precise date that a specific unit will be retired, the 9 history of other commercial nuclear plants and the economic factors discussed warrant 10 using an expected service life shorter than the NRC operating license. There are a munber 11 of facts that support a 25 year expected service life for Seabrook Station:

12 .

As I mentioned, no commercial nuclear power plant has operated for the full duration 13 ofits NRC operating license.

14 .

The average operating lives for the eleven plants permanently retired thus far was 15 about 23 years.

16 .

There are other plants that appear to be candidates for early retirement.

17 .

Four of New England's nine nuclear units have been retired early. j 18 .

Based upon operating license expiration dates, the number of operating nuclear plants j 19 will continue to decline throughout the early part of the next century, which will likely 20 increase the cost ofdoing business.

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NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 l Witness: Robinson l

1 l-l l 2 IV. IntergenerationalInequity 3 Q. Does a shortened decommissioning funding period as you propose result in the imposition  :

4 ofintergenerational inequity on customers?

5 A. No. Intergenerational inequity is an issue when a generation of customers pays a l

l 6 disproportionate share of a plant's decommissioning; such as when the decommissioning i

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funding period does not coincide with the service life of the unit. Here, I am suggesting l 8 that the funding period match the expected service life of the plant. Therefore, a 25-year i 9 funding period, based upon a 25-year estimated service life, does not result in i

10 intergenerational inequity. Indeed, in light of the evidence in the industry, failure to adopt 11 a shorter service life estimate and corresponding funding period could significantly l 1

12 increase the risk of significant intergenerational inequity.  !

l 13 4

14 Q. How could using a 36-year funding period result in Intergenerational inequity?

15 A. If the unit were to shutdown before 2015, use of a 25-year service life would assure a 16 greater level of funding in the decommissioning account and reduce any potential

17. decommissioning shortfall that would result from a longer funding period. The risk that 18 future customers that do not benefit from the unit's output would have to meet such a i 19' shortfallis thus reduced.

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20 Furthermore, even if Seabrook Station continued to operate beyond 2015, the NDFC's

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l NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson I ability adjust the funding amount any time during the energy-producing life of the unit i 2

further reduces the risk ofintergenerational inequity. For example, if the NDFC determines l 3 in 2010 that the unit will likely operate beyond 2015, but the decommissioning fund is on I i

4

. track to fund a complete decommissioning beginning in 2015, the Committee could adjust 1

5 the amount to be recovered in subsequent years so as_not to over collect the fund. While it 6

is true that the NDFC could also decide to increase the amount to be collected ifit 7 determined down the line that there was going to be a shortfall in the fund, I believe a more 8

pmdent course would be to plan conservatively and run the risk of a potential 9 overcollection (which would be subject to refund), than it would be to continue the status 10 quo only to discover too late that the original assumptions were overly optimistic and the 11 fund is dramatically under collected at a time when funds are needed to decommission the 12 plant.

13 14 Q. You have stated that, in light of the evidence in the industry, failure to adopt a shorter 15 service life estimate and corresponding funding period could significantly increase the risk l 16 of significant intergenerational inequity. Are there any examples of this having happened?

17 - A. Yes. In the cases of Yankee Atomic, Connecticut Yankee and Maine Yankee, when the 18' units were prematurely shut down, the amounts of money set aside in trust funds were far 19 less than the amounts necessary to decommission the units. On a composite basis,

'20 including all three plants, approximately 39% of the estimated cost to decommission the 7

1 NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson

! I units was funded at the time of shutdown. (See Exhibit JSR-4) This has resulted in - i l

l 2 collecting from customers very significant amounts for decommissioning during a period 3 when the plants produce no electricity.-

4 l 1

1 5 V. Funding Methodology  ;

6 Q. In light of your 25 year expected service life expectation, does NEP have a position as to 7 the appropriate annual funding methodology?  !

8 A. Yes. NEP believes that the appropriate funding methodology would be to collect the 9 necessary funds for the eventual decommissioning obligation for Seabrook Station over the 10 remainder of the period ending in mid-2015 at an annual level sufficient to ensure the i 11 necessary funds are available to decommission the unit commencing in mid-2015.

12 13 VI. Summary 14 Q. Could you please summarize your testimony.

15 A. NEP believes that it is appropriate to use a 25 year expected service life for purposes of 16 collecting the funds necessary to decommission Seabrook Station. Given recent experience 17 in the nuclear industry, it is no longer reasonable to expect that Seabrook Station will be 18 able to operate its full NRC license life. The recent shutdown of the three " Yankee" plants 19 has indicated that even plants which have a long history of being run safely and reliably are 20 not immune from economic pressures as the electric generation markets evolve. There are j l

NEW ENGLAND POWER COMPANY N.H.N.D.F.C. Docket No. 98-01 Witness: Robinson l 1

.many factors which indicate that cost pressures on nuclear units will increase, rather than l

2 decrease. While many costs can and will be controlled, many are outside the control of the 3

plant operators. Given the uncertainty of costs, which will influence a plant's economic 4

viability, which, in turn, will determine how icng a plant will mn, it is no longer reasonable 5

to assume that Seabrook Station will operate the full _ duration ofits current operating 6 license. By using a funding period more in line with the expected service life, there is a 7

better match between costs incurred and the benefits received.

8 9 Q. Does this conclude your prefiled testimony?

10 A. Yes.

Exhibit JSR-1 U.S. NucleIr Power Plants age 1 of1 I Years of Service Prior to Shutdown i

)

MWe Commercial License Shutdown Years of No ' ' Unit (MDC) Operation Expiration Date Service 1 Rancho Seco 916 Apr-77 Oct-2008 Jun 89 12.1 2 Fort St Vrain 330 Jan 79 Sep-2008 Aug-89 10.6 3 Yankee Atomic 167 Jul41 Jul 2000 Feb-92 30.6 4 San Onofre 1 430 Jan48 Mar-2004 Nov-92 5 Trojan 24.8 1,130 May-76 Feb-2011 Dec-92 16.5 6 Connecticut Yankee 560 Jan48 Jun 2007 Dec-96 7 Maine Yankee 28.9 860 Dec-72 Oct 2008 Aug-97 8 Big Rock Point 24.6 67 Dec42 May-2000 Aug-97 34.7 i 9 Zion 1 1,040 Dec-73 Apr-2013 Jan-98 10 Zion 2 24.0 1,040 Sep.74 Nov-2013 Jan 98 11 Millstone " 23.3 641 Mar-71 Oct-2010 Jul-98 i

27.4 i

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Total Years of Service 257.7 Average Years of Service 23.4 l

l 07/20/98

. , Exhibit .1SR-2 U.S. Nucle:r Pawer Plants Years of Service To Date Page1Of3 MWe Commercial 1.icense Shutdown i. Years of Operation No Unit ' (MDC) Operation Expiration Date Operating Shutdown 1 Yankee Atomic 167 Jul41 Jul-2000 Feb-92 2 Big Rock Point 30.6 67 Dec42 May-2000 Aug 97 3 Connecticut Yankee 34.7 560 Jan48 Jun 2007 Dec-96 4 San Onofre 1 28.9 430 Jan48 Mar-2004 Nov-92 5 Oyster Creek 24.8 619 Dec-69 Dec-2009 28.7 I 6 Nine Mile Point 1 565 Dec-69 Aug-2009 28.7 7 Dresden 2 772 Jun-70 Jan-2006 28.1 8 Ginna 470 Jul-70 Sep-2009 28.1 9 Point Beach 1 485 Dec-70 Oct-2010 27.6 i

10 Millstone 1 641 Mar-71 Oct 2010 Jul-98 11 Robinson 2 27.4 683 Mar-71 Jul-2010

! 27.4 12 Monticello 544 Jun-71 Sep 2010 ._ 27.1 13 Dresden 3 773 Nov-71 Jan-2011 26.7 14 Palisades 730 Dec.71 Mar-2007 26.6 15 Point Beach 2 485 Oct-72 Mar-2013 25.8 l 16 VermontYankee 510 Nov-72 Mar-2012 l 17 Pilgrim 25.7 670 Dec-72 Jun-2012 18 Turkey Point 3 25.7 l

693 Dec-72 Jul-2012 19 Surry1 25.6 801 Dec-72 May-2012 25.6 20 Maine Yankee 860 Dec 72 Oct-2008 Aug-97 21 Qusd Cities 1 24.6 769 Feb-73 Dec-2012 25.4 22 Quad Cities 2 769 Mar-73 Dec-2012 25.4 23 Surry2 801 May-73 Jan-2013 25.3 24 Oconee 1 846 Jul-73 Feb-2013 25 Turkey Point 4 25.0 693 Sep.73 Apr-2013 24.9 26 FortCalhoun 478 Sep 73 Aug-2013 24.8 27 Prairie Island 1 513 Dec-73 Aug-2013 24.6 28 Zion 1 1,040 Dec-73 Apr-2013 Jan-98 29 Kewaunee 24.0 511 Jun-74 Dec-2013 i

30 Cooper 24.1 764 Jul-74 Jan-2014 24.1 31 Poach Bottom 2 1,093 Jul-74 Aug-2013 24.1 32 Indian Point 2 951 Aug-74 Sep-2013 24.0 33 Browns Feny 1 1,065 Aug-74 Dec-2013 24.0 34 Three Mila Island 1 786 Sep-74 Apr-2014 23.9 l 35 Oconee 2 846 Sep-74 Oct-2013 23.9 36 Zion 2 1,040 Sep-74 Nov-2013 Jan-98 37 Oconee 3 23.3 846 Dec-74 Jul-2014 23.6 38 Arkansas 1 836 Dec-74 May-2014 23.6 39 Prairie Island 2 512 Dec-74 Oct-2014 23.6 40 Peach Bottom 3 1,093 Dec-74 Jul-2014 23.6 41 Duane Arnold 520 Feb-75 Feb 2014 23.5 42 Browns Feny2 1,065 Mar-75 Jun-2014 23.4 43 Calvert Cliffs 1 835 May-75 Jul-2014 44 Fitzpatrick 23.2 762 Jul-75 Oct-2014 23.0 45 DC Cook 1 1,000 Aug-75 Oct 2014 22.9 46 Brunswick 2 754 Nov-75 Dec-2014 22.7 47 Millstone 2 871 Dec-75 Jul-2015 22.6 48 Hatch 1 805 Dec-75 Aug-2014 22.6 l 49 Trojan 1,130 May-76 Feb-2011 Dec-92 16.5 50 indian Point 3 965 Aug-76 Dec-2015 21.9 51 BeaverValley1 810 Oct-76 Jan-2016 21.8 l

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- Exhibit JSR-2 U.S. Nuclerr Pcwor Plants Page 2 of 3 Years of Service To Date MWe Commercial License Shutdown l Years of Operation No Unit' (MDC) Operation Expiration Date Operating Shutdown 52 StLucie 1 839 Dec-76 Mar-2016

! 53 Browns Ferry 3 21.6 1,065 Mar-77 Jul-2016 54 CrystalRiver3 21.4 818 Mar-77 Dec-2016 21.4 55 Brunswick 1 767 Mar-77 Sep-2016 .

21.4  !

! 56 Calvert Cliffs 2 840 Apr-77 Aug-2016 57 Rancho Seco 21.3 918 Apr 77 Oct-2008 Jun-89 i 58 Salem i 1,106 12.1 Jun-77 Aug-2016 21.1 59 Farley1 812 Dec-77 Jun-2017 20.7

60 North Anna 1 893 Jun-78 Apr-2018 i 61 DC Cook 2 1,060 202 Jul-78 Dec-2017 20.1 l- 62 Davis Besse 873 Jul-78 Apr-2017 20.0 63 Fort St Vrain 330 Jan-79 Sep 2008 - Aug49 64 Hatch 2 10.6 809 Sep.79 Jun-2018 18.9 65 Arkansas 2 858 Mar 40 Jul-2018 18.3 66 North Anna 2 897 Dec40 Aug-2020 67 Sequoyah 1 17.6 1,117 Jul-41 Sep 2020 17.1 68 Farley2 822 Jul41 Mar-2021 17.0 69 Salem 2 1,106 Oct41 Apr-2020 16.8 70 McGuire 1 1,129 Dec41 Jun-2021 16.7 71 Sequoyah 2 1,117 Jun42 Sep-2021 72 San Onofre 3 162 1,080 Apr43 Oct-2013 73 Susquehanna 1 15.3 1,090 Jun43 Jul-2022 15.1 74 St Lucie 2 839 Aug43 Apr-2023 15.0 75 San Onofre 2 1,070 Aug43 Oct-2013 15.0 76 LaSalle 1 1,036 Jan44 May-2022 77 Summer 14.6 945 Jan-84 Aug-2022 14.6 78 McGuire 2 1,129 Mar 44 Mar-2023 14.4 79 LaSalle 2 1,036 Oct44 Dec-2023 80 Washington Nuclear 2 13.8 1,107 Dec44 Dec-2023 13.6 81 Callaway 1,125 Dec44 Oct-2024 82 Susquehanna 2 13.6 1.094 Feb-85 Mar 2024 83 Diablo Canyon 1 13.5 1,073 Mg 85 Sep 2021 84 Catawba 1 132 1,129 Jun45 Dec-2024 13.1 85' Grand Gulf 1 1,179 Jul45 Jun-2022 13.1 86 Wolf Creek 1,163 Sep45 Mar-2025 87 Byron 1 12.9 1,105 Sep45 Oct-2024 12.9 88 Waterford 3 1,104 Sep45 Dec-2024 12.9 89 PaloVerde 1 1,227 Jan46 Dec 2024 12.5 90 Umerick1 1,105 Feb.86 Oct-2024 12.5

, 91 Diablo Canyon 2 1,087 Mar 46 Apr-2025 12.4 92 Millstone 3 1,137 Apr46 Nov-2025 12.3 93 RiverBend 936 Jun46 Aug-2025 12.1 94 Catawba 2 1,129 Aug46 Feb-2026 12.0 95 Palo Verde 2 1,227 Sep46 Dec-2025 96 Hope Creek 11.9 1,031 Dec46 Apr-2026 11.6 97 Harris 1 860 May47 Oct-2026 98 Vogtle 1 11 2 1,162 Jun47 Jan-2027 99 Byron 2 11 2 1,105 Aug-87 Nov-2026 10.9 100 BeaverValley2 836 Nov47 May-2027 101 Perry 1 10.7 1,160 Nov47 Mar-2026 10.7 102 Clinton 930 Nov47 Sep-2026 10.7 07/20/98

l** Exhibit JSR-2 f

U.S. Nucle:r P:wer Plants Page 3 of 3 Years of Service To Date l

MWe Commercial License Shutdown l Years of Operation Nm Unit ' (MDC) Operation Expiration  !

Date Operating Shutdown l 103 Palo Verde 3 1,230 Jan-88 Mar-2027 10.6 104 Fermi 2 876 Jan48 Mar-2025 10.5 105 Nine Mile Point 2 1,105 Mar 48 Oct 2026 10.4 106 Braidwood1 1,120 Jul48 Oct-2026 10.0 j 107 South Texas 1 1,251 Au948 Au9-2027 9,9 108 Braidwood2 1,120 Oct48 Dec-2027 9.8 109 Vogtle2 1,162 May49 Feb2029 9.2 110 South Texas 2 1,251 Jun49 Dec-2028 9.1 111 Umerick2 1,115 Jarw90 Jun-2029 8.6 112 ComanchePeaki 1,150 Au9-90 Feb-2030 8.0 113 Seabrook 1,158 Jun-90 Oct-2026 8.1 114 Comanche Peak 2 1,150 Aug-93 Feb-2033 _.- 5.0 115 Watts Bar 1 1,117 May-96 Nov-2035 2.2 j l

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.. Exhibit JSR-4 U.S. Nucle r Power Plints Page1 of1 Years of Service Prior to shutdown l Decommissioning Commercial License Shutdown 5000 in No Unit - Operation Estimate  % funded as Expiration Date Trust Funds $000 of Shutdown l 1 Yankee Atomic Jul41 Jul-2000 Feb-92 $72,100 5247,000 29.2%

) 2 Connecticut Yankee Jan48 Jun 2007 Dec46 $197,900 l $426,700 46.4 %

3 Maine Yankee Dec-72 Oct-2008 Aug47 $194,400 $508,600 38.2 %

l 8464,400 $1,1821 300 39.3%

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07/20/98

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