Text

Submittal of the Decommissioning Funding Status Reports
	ML23090A233
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	03/31/2023
From:	Benyak D; Energy Harbor Nuclear Corp
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23090A232	List: L-23-061, Submittal of the Decommissioning Funding Status Reports;
References
	L-23-061
	Download: ML23090A233 (1)
	v • d • e

Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 2 energy

,__ harbor Energy Harbor Nuclear Corp.

168 E. Market Street Akron, Ohio 44308 Darin M. Benyak 330-436-1380 Senior Vice President, Fleet Nuclear Operations March 31, 2023 L-23-061 10 CFR 50.75 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Submittal of the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant In accordance with 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning," paragraph (f)(1), Energy Harbor Nuclear Generation Corp., on behalf of Energy Harbor Nuclear Generation LLC, is submitting the decommissioning funding status reports for Beaver Valley Power Station, Unit Nos. 1 (BVPS-1) and 2 (BVPS-2);

Davis-Besse Nuclear Power Station (DBNPS); and Perry Nuclear Power Plant (PNPP) for the year ending December 31, 2022. The reports are contained in Attachments 1 through 4, respectively.

In accordance with 10 CFR 50.75(b), the estimated cost of decommissioning may be based on either the NRC minimum formula cost amount calculated in accordance with 10 CFR 50.75(c) or a site-specific decommissioning cost estimate (DCE) in accordance with 10 CFR 50.75(b)(4). The DBNPS and BVPS-2 decommissioning funding status reports meet the minimum funding criteria based on the NRC minimum formula cost calculation. The PNPP decommissioning funding status report meets the minimum funding criteria based on the use of the site-specific DCE. The BVPS-1 site-specific DCE identified a shortfall. Energy Harbor Nuclear Corp. has a surety bond in place worth $61 million that would be deposited in 2036 to cover the BVPS-1 shortfall. A copy Enclosure D of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure D, this letter is decontrolled.

Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-23-061 Page2 of the surety bond and associated riders that revised the value from $20 million to $61 million is provided in Enclosure D.

Certain confidential commercial and financial information is included in Enclosure D.

Energy Harbor Nuclear Generation LLC requests that Enclosure D be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4) and 10 CFR 9.17. A redacted version of Enclosure D is provided in the publicly available version of this submittal as Enclosure B. The redacted information is identified by brackets [ ]. A declaration supporting the request for withholding the proprietary confidential commercial and financial information from public disclosure is provided in Enclosure C.

The site-specific DCEs provided by letter dated March 23, 2021 (Accession No. ML21088A295) for BVPS-1, BVPS-2, and DBNPS remain as the current DCEs. They have been escalated to 2022 dollars and are based on a period of safe storage (SAFSTOR) that is described in the estimates. Annual cash flows based on the site-specific DCEs are included in the decommissioning funding analysis reports. An updated PNPP site-specific DCE is being submitted in accordance with 10 CFR 50.75(f)(3). The site-specific DCE for PNPP is provided as Enclosure A to this report.

An update to the period of safe storage (SAFSTOR) cash flows was made in August 2022 for BVPS-1. The update includes reducing the wet fuel storage time to three years in accordance with improved generic loading patterns and removing the Independent Spent Fuel Storage Installation (ISFSI) costs, which are part of a separate ISFSI decommissioning fund. The cash flows provided for BVPS-1 include this update.

Although a similar update was made to BVPS-2, there is no impact because cash flows are not required for BVPS-2.

Since a final determination on the decommissioning approach for each site has not been made and a different option ultimately may be chosen, Energy Harbor Nuclear Corp. recognizes that the chosen option must meet NRC requirements for decommissioning funding assurance.

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Phil H. Lashley, Manager- Fleet Licensing, at (330) 696-7208.

Sincerely, Digitally signed by Darin M.

Darin M. Benyak Date: Benyak 2023.03.3119:21:27-04'00' Darin M. Benyak Enclosure D of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure D, this letter is decontrolled.

Confidential Commercial and Financial Information Withhold from Public Disclosure Under 10 CFR 2.390 and 10 CFR 9.17 Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-23-061 Page 3 Attachments:

1. Energy Harbor Nuclear Generation LLC - Beaver Valley Power Station, Unit No. 1 Decommissioning Funding Status Report - December 31, 2022

2. Energy Harbor Nuclear Generation LLC - Beaver Valley Power Station, Unit No. 2 Decommissioning Funding Status Report - December 31, 2022

3. Energy Harbor Nuclear Generation LLC - Davis-Besse Nuclear Power Station Decommissioning Funding Status Report - December 31, 2022

4. Energy Harbor Nuclear Generation LLC - Perry Nuclear Power Plant Decommissioning Funding Status Report - December 31, 2022

Enclosure:

A. Perry Nuclear Power Plant Updated Decommissioning Cost Analysis, January 2023 B. Redacted Surety Bond with Associated Riders C. Declaration to Withhold from Public Disclosure D. Unredacted Surety Bond with Associated Riders cc: NRC Region I Administrator NRC Region III Administrator NRC Project Manager - Energy Harbor Nuclear Corp. Fleet NRC Resident Inspector (Beaver Valley)

NRC Resident Inspector (Davis-Besse)

NRC Resident Inspector (Perry)

Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board Enclosure D of this letter contains Confidential Commercial and Financial information to be withheld from public disclosure under 10 CFR 2.390 and 10 CFR 9.17.

Upon removal of Enclosure D, this letter is decontrolled.

Attachment 1 L-23-061 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION, UNIT NO. 1 Decommissioning Funding Status Report December 31, 2022 Page 1 of 6 The following notes and assumptions were used in developing the Decommissioning Funding Status Report:

1. Energy Harbor Nuclear Generation LLC has 100% ownership interest in BVPS-1.

2. Formal decommissioning has not started. No disbursement of decommissioning trust funds occurred in 2022 except for ordinary administrative costs.

3. Schedule 1 provides the minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(c).

4. The after-tax amount accumulated in the BVPS-1 external trust funds for radiological decommissioning as of December 31, 2022, is provided in Schedule 1.

5. There are no funds to be collected from the ratepayers.

6. There are no contracts upon which Energy Harbor Nuclear Generation LLC are relying pursuant to 10 CFR 50.75(e)(1)(v).

7. A $61 million dollar surety bond has been obtained since the last submitted report.

8. There have been no material changes to the applicable trust agreement(s) since the last submitted report.

9. Mathematical rounding was performed during the development of the supporting calculations.

10. The site-specific cost estimate is based on: Decommissioning Cost Analysis for the Beaver Valley Power Station, February 2021 performed in 2020 dollars and escalated to 2022 dollars.

11. Energy Harbor Nuclear Corp. recognizes that a shortfall exists for BVPS-1, when the existing trust balances and assumed earnings are compared to the NRC formula amount calculated in Schedule 1. To resolve the shortfall, the site-specific BVPS-1 DCE was evaluated in conjunction with a surety bond in the amount of $61 million.

The analysis assumes the surety bond will be deposited in 2036. Based on the site-specific DCE, surety bond, and associated assumed earnings, the shortfall is resolved.

12. Schedule 2 provides a BVPS-1 analysis that provides cash flows based on the site-specific decommissioning cost estimate that includes the use of SAFSTOR.

The analysis is associated with the costs for the radiological decommissioning of the facility in 2022 dollars. The cash flow analysis assumes the yearly expenses are incurred at mid-year. Schedule 3 provides the same methodology and assumptions as Schedule 2 but with updated cash flows utilizing updated price indices as of March 2023 and demonstrates additional margin.

13. A 2% annual real rate of return is used through dismantlement.

14. BVPS-1 is assumed to shut down in 2036, with license termination by 2096.

L-23-061 Page 2 of 6 Schedule 1 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION UNIT NO. 1 Calculation of Minimum Financial Assurance Amount 1 December 31, 2022 For BVPS-1 (PWR) Unit:

BVPS-1 Nuclear Decommissioning Trust Balance (After Tax) as of December 31, 2022

= $288,058,748 Pennsylvania Region Adjustment Ratio Escalation4 Factor Factor Labor (L); Northeast2 3.39 0.65 2.204 Energy (E): National2 3.446 0.13 0.448 Waste Burial (B): Generic3 13.711 0.22 3.016 PWR Escalation Factor 5.668 Base Amount for a PWR between 1200 MWt and 3400 MWt = $75 + 0.0088P (millions)

Where, P = power in megawatts thermal (MWt) = 2900 MWt Base Amount = $75 + 0.0088(2900) millions = $100,520,000 Escalated Amount for Unit = Base Amount x Escalation Factor

= $100,520,000 x 5.668 = $569,747,360 1Minimum financial assurance formula is based on 10 CFR 50.75(c).

2Labor and preliminary Energy factors were obtained from U.S Department of Labor, Bureau of Labor Statistics (4Q 2022 for Labor and December 2022 for Energy.)

3Waste burial factors were obtained from NRC report NUREG-1307, Rev. 19, "Report on Waste Burial Charges."

4Mathematical rounding was used in this calculation.

L-23-061 Page 3 of 6 Schedule 2 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION UNIT NO. 1 Calculation of a Site-Specific Cash Flow Analysis in 2022 Dollars December 31, 2022 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2022 - - - - 288,058,748 2023 288,058,748 - 5,761,175 - 293,819,923 2024 293,819,923 - 5,876,398 - 299,696,321 2025 299,696,321 - 5,993,926 - 305,690,248 2026 305,690,248 - 6,113,805 - 311,804,053 2027 311,804,053 - 6,236,081 - 318,040,134 2028 318,040,134 - 6,360,803 - 324,400,937 2029 324,400,937 - 6,488,019 - 330,888,955 2030 330,888,955 - 6,617,779 - 337,506,734 2031 337,506,734 - 6,750,135 - 344,256,869 2032 344,256,869 - 6,885,137 - 351,142,006 2033 351,142,006 - 7,022,840 - 358,164,847 2034 358,164,847 - 7,163,297 - 365,328,143 2035 365,328,143 - 7,306,563 - 372,634,706 2036 372,634,706 61,000,000 8,016,225 (55,586,451) 386,064,480 2037 386,064,480 - 7,063,721 (60,882,858) 332,245,343 2038 332,245,343 - 6,559,865 (7,873,831) 330,931,377 2039 330,931,377 - 6,565,636 (4,906,361) 332,590,652 2040 332,590,652 - 6,601,347 (4,672,570) 334,519,428 2041 334,519,428 - 6,640,060 (4,659,803) 336,499,686 2042 336,499,686 - 6,679,665 (4,659,803) 338,519,548 2043 338,519,548 - 6,720,062 (4,659,803) 340,579,808 2044 340,579,808 - 6,761,130 (4,672,570) 342,668,368 2045 342,668,368 - 6,803,039 (4,659,803) 344,811,604 2046 344,811,604 - 6,845,904 (4,659,803) 346,997,705 2047 346,997,705 - 6,889,626 (4,659,803) 349,227,528 2048 349,227,528 - 6,934,084 (4,672,570) 351,489,042 2049 351,489,042 - 6,979,452 (4,659,803) 353,808,692 2050 353,808,692 - 7,025,845 (4,659,803) 356,174,735 2051 356,174,735 - 7,073,166 (4,659,803) 358,588,098 2052 358,588,098 - 7,121,296 (4,672,570) 361,036,824 2053 361,036,824 - 7,170,408 (4,659,803) 363,547,429 2054 363,547,429 - 7,220,620 (4,659,803) 366,108,247 2055 366,108,247 - 7,271,836 (4,659,803) 368,720,281 2056 368,720,281 - 7,323,939 (4,672,570) 371,371,649 2057 371,371,649 - 7,377,105 (4,659,803) 374,088,951 2058 374,088,951 - 7,431,451 (4,659,803) 376,860,599 L-23-061 Page 4 of 6 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2059 376,860,599 - 7,486,884 (4,659,803) 379,687,680 2060 379,687,680 - 7,543,287 (4,672,570) 382,558,397 2061 382,558,397 - 7,600,839 (4,659,803) 385,499,434 2062 385,499,434 - 7,659,660 (4,659,803) 388,499,292 2063 388,499,292 - 7,719,657 (4,659,803) 391,559,147 2064 391,559,147 - 7,780,717 (4,672,570) 394,667,293 2065 394,667,293 - 7,843,017 (4,659,803) 397,850,508 2066 397,850,508 - 7,906,682 (4,659,803) 401,097,387 2067 401,097,387 - 7,971,619 (4,659,803) 404,409,204 2068 404,409,204 - 8,037,718 (4,672,570) 407,774,351 2069 407,774,351 - 8,105,159 (4,659,803) 411,219,707 2070 411,219,707 - 8,174,066 (4,659,803) 414,733,970 2071 414,733,970 - 8,244,351 (4,659,803) 418,318,518 2072 418,318,518 - 8,315,904 (4,672,570) 421,961,852 2073 421,961,852 - 8,388,909 (4,659,803) 425,690,958 2074 425,690,958 - 8,463,491 (4,659,803) 429,494,646 2075 429,494,646 - 8,539,564 (4,659,803) 433,374,408 2076 433,374,408 - 8,617,022 (4,672,570) 437,318,859 2077 437,318,859 - 8,696,049 (4,659,803) 441,355,106 2078 441,355,106 - 8,776,774 (4,659,803) 445,472,077 2079 445,472,077 - 8,859,113 (4,659,803) 449,671,387 2080 449,671,387 - 8,942,961 (4,672,570) 453,941,778 2081 453,941,778 - 9,028,507 (4,659,803) 458,310,483 2082 458,310,483 - 9,128,802 (3,463,513) 463,975,772 2083 463,975,772 - 9,242,108 (3,463,513) 469,754,367 2084 469,754,367 - 9,357,577 (3,473,000) 475,638,944 2085 475,638,944 - 9,475,371 (3,463,513) 481,650,802 2086 481,650,802 - 9,595,608 (3,463,513) 487,782,898 2087 487,782,898 - 9,718,250 (3,463,513) 494,037,636 2088 494,037,636 - 9,750,113 (12,095,682) 491,692,067 2089 491,692,067 - 9,189,097 (59,695,477) 441,185,686 2090 441,185,686 - 7,333,687 (137,958,346) 310,561,027 2091 310,561,027 - 4,671,476 (142,561,607) 172,670,896 2092 172,670,896 - 2,553,146 (83,354,186) 91,869,855 2093 91,869,855 - 1,238,415 (55,458,450) 37,649,820 2094 37,649,820 - 714,026 (3,608,195) 34,755,651 2095 34,755,651 - 385,800 (28,638,615) 6,502,836 2096 6,502,836 - 95,236 (3,224,021) 3,374,051 2097 3,374,051 - 66,067 (130,896) 3,309,222 2098 3,309,222 - 66,165 (1,793) 3,373,594 (872,619,485)

L-23-061 Page 5 of 6 Schedule 3 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION UNIT NO. 1 Calculation of a Site-Specific Cash Flow Analysis based on Q1 2023 Price Indices March 15, 2023 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2022 - - - - 288,058,748 2023 288,058,748 - 5,761,175 - 293,819,923 2024 293,819,923 - 5,876,398 - 299,696,321 2025 299,696,321 - 5,993,926 - 305,690,248 2026 305,690,248 - 6,113,805 - 311,804,053 2027 311,804,053 - 6,236,081 - 318,040,134 2028 318,040,134 - 6,360,803 - 324,400,937 2029 324,400,937 - 6,488,019 - 330,888,955 2030 330,888,955 - 6,617,779 - 337,506,734 2031 337,506,734 - 6,750,135 - 344,256,869 2032 344,256,869 - 6,885,137 - 351,142,006 2033 351,142,006 - 7,022,840 - 358,164,847 2034 358,164,847 - 7,163,297 - 365,328,143 2035 365,328,143 - 7,306,563 - 372,634,706 2036 372,634,706 61,000,000 8,017,832 (55,425,220) 386,227,318 2037 386,227,318 - 7,068,154 (60,773,885) 332,521,588 2038 332,521,588 - 6,565,759 (7,839,704) 331,247,642 2039 331,247,642 - 6,572,161 (4,887,915) 332,931,887 2040 332,931,887 - 6,608,357 (4,655,381) 334,884,864 2041 334,884,864 - 6,647,554 (4,642,660) 336,889,758 2042 336,889,758 - 6,687,652 (4,642,660) 338,934,750 2043 338,934,750 - 6,728,552 (4,642,660) 341,020,642 2044 341,020,642 - 6,770,132 (4,655,381) 343,135,393 2045 343,135,393 - 6,812,565 (4,642,660) 345,305,298 2046 345,305,298 - 6,855,963 (4,642,660) 347,518,601 2047 347,518,601 - 6,900,229 (4,642,660) 349,776,170 2048 349,776,170 - 6,945,243 (4,655,381) 352,066,032 2049 352,066,032 - 6,991,177 (4,642,660) 354,414,550 2050 354,414,550 - 7,038,148 (4,642,660) 356,810,037 2051 356,810,037 - 7,086,057 (4,642,660) 359,253,435 2052 359,253,435 - 7,134,788 (4,655,381) 361,732,842 2053 361,732,842 - 7,184,514 (4,642,660) 364,274,696 2054 364,274,696 - 7,235,351 (4,642,660) 366,867,387 2055 366,867,387 - 7,287,204 (4,642,660) 369,511,932 2056 369,511,932 - 7,339,958 (4,655,381) 372,196,509 2057 372,196,509 - 7,393,787 (4,642,660) 374,947,636 2058 374,947,636 - 7,448,809 (4,642,660) 377,753,786 L-23-061 Page 6 of 6 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2059 377,753,786 - 7,504,932 (4,642,660) 380,616,058 2060 380,616,058 - 7,562,040 (4,655,381) 383,522,718 2061 383,522,718 - 7,620,311 (4,642,660) 386,500,369 2062 386,500,369 - 7,679,864 (4,642,660) 389,537,574 2063 389,537,574 - 7,740,608 (4,642,660) 392,635,522 2064 392,635,522 - 7,802,430 (4,655,381) 395,782,571 2065 395,782,571 - 7,865,508 (4,642,660) 399,005,419 2066 399,005,419 - 7,929,965 (4,642,660) 402,292,725 2067 402,292,725 - 7,995,711 (4,642,660) 405,645,776 2068 405,645,776 - 8,062,635 (4,655,381) 409,053,030 2069 409,053,030 - 8,130,917 (4,642,660) 412,541,288 2070 412,541,288 - 8,200,682 (4,642,660) 416,099,311 2071 416,099,311 - 8,271,843 (4,642,660) 419,728,494 2072 419,728,494 - 8,344,289 (4,655,381) 423,417,402 2073 423,417,402 - 8,418,205 (4,642,660) 427,192,947 2074 427,192,947 - 8,493,716 (4,642,660) 431,044,003 2075 431,044,003 - 8,570,737 (4,642,660) 434,972,080 2076 434,972,080 - 8,649,161 (4,655,381) 438,965,860 2077 438,965,860 - 8,729,174 (4,642,660) 443,052,374 2078 443,052,374 - 8,810,904 (4,642,660) 447,220,619 2079 447,220,619 - 8,894,269 (4,642,660) 451,472,228 2080 451,472,228 - 8,979,164 (4,655,381) 455,796,011 2081 455,796,011 - 9,065,777 (4,642,660) 460,219,128 2082 460,219,128 - 9,167,159 (3,446,442) 465,939,845 2083 465,939,845 - 9,281,573 (3,446,442) 471,774,977 2084 471,774,977 - 9,398,174 (3,455,882) 477,717,268 2085 477,717,268 - 9,517,122 (3,446,442) 483,787,948 2086 483,787,948 - 9,638,535 (3,446,442) 489,980,042 2087 489,980,042 - 9,762,377 (3,446,442) 496,295,977 2088 496,295,977 - 9,795,749 (12,052,250) 494,039,476 2089 494,039,476 - 9,237,945 (59,519,549) 443,757,872 2090 443,757,872 - 7,386,779 (137,805,692) 313,338,959 2091 313,338,959 - 4,728,533 (142,422,837) 175,644,655 2092 175,644,655 - 2,613,978 (83,228,562) 95,030,071 2093 95,030,071 - 1,302,500 (55,376,913) 40,955,658 2094 40,955,658 - 780,138 (3,608,636) 38,127,160 2095 38,127,160 - 453,495 (28,614,136) 9,966,519 2096 9,966,519 - 164,539 (3,221,230) 6,909,828 2097 6,909,828 - 136,783 (130,884) 6,915,727 2098 6,915,727 - 138,295 (1,793) 7,052,229 (870,728,939)

Attachment 2 L-23-061 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION, UNIT NO. 2 Decommissioning Funding Status Report December 31, 2022 Page 1 of 2 The following notes and assumptions were used in developing the Decommissioning Funding Status Report:

1. Energy Harbor Nuclear Generation LLC has 100% ownership interest in BVPS-2.

2. Formal decommissioning has not started at BVPS-2. No disbursement of decommissioning trust funds occurred in 2022 except for ordinary administrative costs.

3. Schedule 1 provides the minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(c).

4. The after-tax amount accumulated in the BVPS-2 external trust funds for radiological decommissioning as of December 31, 2022, is provided in Schedule 1.

5. There are no funds to be collected from the ratepayers.

6. There are no contracts upon which Energy Harbor Nuclear Generation LLC are relying pursuant to 10 CFR 50.75(e)(1)(v).

7. There has been no modification to the current method of providing decommissioning funding assurance since the last submitted report.

8. There have been no material changes to the applicable trust agreement(s) since the last submitted report.

9. Mathematical rounding was performed during the development of the supporting calculations.

10. The site-specific cost estimate is based on: Decommissioning Cost Analysis for the Beaver Valley Power Station, February 2021 performed in 2020 dollars and escalated to 2022 dollars.

11. A 2% annual real rate of return is used through dismantlement.

12. BVPS-2 is assumed to shut down in 2047, with license termination by 2096.

L-23-061 Page 2 of 2 Schedule 1 ENERGY HARBOR NUCLEAR GENERATION LLC BEAVER VALLEY POWER STATION UNIT NO. 2 Calculation of Minimum Financial Assurance Amount 1 December 31, 2022 For BVPS-2 (PWR) Unit:

BVPS-2 Nuclear Decommissioning Trust Balance (After Tax) as of December 31, 2022,

= $388,611,909 Pennsylvania Region Adjustment Ratio Escalation4 Factor Factor Labor (L); Northeast2 3.39 0.65 2.204 Energy (E): National2 3.446 0.13 0.448 Waste Burial (B): Generic3 13.711 0.22 3.016 PWR Escalation Factor 5.668 Base Amount for a PWR between 1200 MWt and 3400 MWt = $75 + 0.0088P (millions)

Where, P = power in megawatts thermal (MWt) = 2900 MWt Base Amount = $75 + 0.0088(2900) millions = $100,520,000 Escalated Amount for Unit = Base Amount x Escalation Factor

= $100,520,000 x 5.668 = $569,747,360 1Minimum financial assurance formula is based on 10 CFR 50.75(c).

2Labor and preliminary Energy factors were obtained from U.S Department of Labor, Bureau of Labor Statistics (4Q 2022 for Labor and December 2022 for Energy.)

3Waste burial factors were obtained from NRC report NUREG-1307, Rev. 19, "Report on Waste Burial Charges."

4Mathematical rounding was used in this calculation.

Attachment 3 L-23-061 ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION Decommissioning Funding Status Report December 31, 2022 Page 1 of 2 The following notes and assumptions were used in developing the Decommissioning Funding Status Report:

1. Energy Harbor Nuclear Generation LLC has 100% ownership interest in DBNPS.

2. Formal decommissioning has not started at DBNPS. No disbursement of decommissioning trust funds occurred in 2020 except for ordinary administrative costs.

3. Schedule 1 provides the minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(c).

4. The after-tax amount accumulated in the DBNPS external trust funds for radiological decommissioning as of December 31, 2022, is provided in Schedule 1.

5. There are no funds to be collected from the ratepayers.

6. There are no contracts upon which Energy Harbor Nuclear Generation LLC are relying pursuant to 10 CFR 50.75(e)(1)(v).

7. There has been no modification to the current method of providing decommissioning funding assurance since the last submitted report.

8. There have been no material changes to the applicable trust agreement(s) since the last submitted report.

9. Mathematical rounding was performed during the development of the supporting calculations.

10. The site-specific cost estimate is based on: Decommissioning Cost Analysis for the Davis-Besse Nuclear Power Station, February 2021 performed in 2020 dollars and escalated to 2022 dollars.

11. A 2% annual real rate of return is used through dismantlement.

12. DBNPS is assumed to shut down in 2037, with license termination by 2097.

L-23-061 Page 2 of 2 Schedule 1 ENERGY HARBOR NUCLEAR GENERATION LLC DAVIS-BESSE NUCLEAR POWER STATION Calculation of Minimum Financial Assurance Amount 1 December 31, 2022 For DBNPS (PWR) Unit:

DBNPS Nuclear Decommissioning Trust Balance (After Tax) as of December 31, 2022

= $563,595,446 Ohio Region Adjustment Ratio Escalation4 Factor Factor Labor (L); Midwest2 3.18 0.65 2.067 Energy (E): National2 3.446 0.13 0.448 Waste Burial (B): Generic3 13.711 0.22 3.016 PWR Escalation Factor 5.531 Base Amount for a PWR between 1200 MWt and 3400 MWt = $75 + 0.0088P (millions)

Where, P = power in megawatts thermal (MWt) = 2817 MWt Base Amount = $75 + 0.0088(2817) millions = $99,789,600 Escalated Amount for Unit = Base Amount x Escalation Factor

= $99,789,600 x 5.531 = $551,936,278 1Minimum financial assurance formula is based on 10 CFR 50.75(c).

2Labor and preliminary Energy factors were obtained from U.S Department of Labor, Bureau of Labor Statistics (4Q 2022 for Labor and December 2022 for Energy.)

3Waste burial factors were obtained from NRC report NUREG-1307, Rev. 19, "Report on Waste Burial Charges."

4Mathematical rounding was used in this calculation.

Attachment 4 L-23-061 ENERGY HARBOR NUCLEAR GENERATION LLC PERRY NUCLEAR POWER PLANT Decommissioning Funding Status Report December 31, 2022 Page 1 of 4 The following notes and assumptions were used in developing the Decommissioning Funding Status Report:

1. Energy Harbor Nuclear Generation LLC has 100% ownership interest in PNPP.

2. Formal decommissioning has not started at PNPP. No disbursement of decommissioning trust funds occurred in 2022 except for ordinary administrative costs.

3. Schedule 1 provides the minimum decommissioning fund estimate, pursuant to 10 CFR 50.75(c).

4. The after-tax amount accumulated in the PNPP external trust funds for radiological decommissioning as of December 31, 2022, is provided in Schedule 1.

5. There are no funds to be collected from the ratepayers.

6. There are no contracts upon which Energy Harbor Nuclear Generation LLC. are relying pursuant to 10 CFR 50.75(e)(1)(v).

7. There has been no modification to the current method of providing decommissioning funding assurance since the last submitted report.

8. There have been no material changes to the applicable trust agreement(s) since the last submitted report.

9. Mathematical rounding was performed during the development of the supporting calculations.

10. The site-specific cost estimate is based on: Perry Nuclear Power Plant Updated Decommissioning Cost Analysis, January 2023 performed in 2022 dollars.

11. A site-specific cost estimate for the radiological decommissioning of PNPP utilizing SAFSTOR was performed using the guidance of the Regulatory Guide (RG) 1.159, Revision 2. The facility specific analysis demonstrated the adequacy of decommissioning funding since the results of the SAFSTOR analysis are greater than the estimate calculated pursuant to 10 CFR 50.75(c).

12. A 2% annual real rate of return is used through dismantlement.

13. PNPP is assumed to shut down in 2026, with license termination by 2086.

14. Schedule 2 provides a PNPP analysis that provides cash flows based on the site-specific decommissioning cost estimate that includes the use of SAFSTOR.

The analysis is associated with the costs for the radiological decommissioning of the facility in 2022 dollars. The cash flow analysis assumes the yearly expenses are incurred at mid-year.

L-23-061 Page 2 of 4 Schedule 1 ENERGY HARBOR NUCLEAR GENERATION LLC PERRY NUCLEAR POWER PLANT Calculation of Minimum Financial Assurance Amount 1 December 31, 2022 For PNPP (BWR) Unit:

PNPP Nuclear Decommissioning Trust Balance (After Tax) as of December 31, 2022,

= $514,936,901 Ohio Region Adjustment Ratio Escalation4 Factor Factor Labor (L); Midwest2 3.18 0.65 2.067 Energy (E): National2 3.540 0.13 0.460 Waste Burial (B): Generic3 12.296 0.22 2.705 BWR Escalation Factor 5.232 Base Amount for a BWR greater than 3400 MWt = $135,000,000 Where, P = power in megawatts thermal (MWt) = 3758 MWt Escalated Amount for Unit = Base Amount x Escalation Factor

= $135,000,000 x 5.232 = $706,320,000 1Minimum financial assurance formula is based on 10 CFR 50.75(c).

2Labor and preliminary Energy factors were obtained from U.S Department of Labor, Bureau of Labor Statistics (4Q 2022 for Labor and December 2022 for Energy.)

3Waste burial factors were obtained from NRC report NUREG-1307, Rev. 19, "Report on Waste Burial Charges."

4Mathematical rounding was used in this calculation.

L-23-061 Page 3 of 4 Schedule 2 ENERGY HARBOR NUCLEAR GENERATION LLC PERRY NUCLEAR POWER PLANT Calculation of a Site-Specific Cash Flow Analysis in 2022 Dollars December 31, 2022 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2022 - - - - 514,936,901 2023 514,936,901 - 10,298,738 - 525,235,639 2024 525,235,639 - 10,504,713 - 535,740,352 2025 535,740,352 - 10,714,807 - 546,455,159 2026 546,455,159 - 10,923,090 (8,776,000) 548,602,249 2027 548,602,249 - 10,378,129 (58,056,000) 500,924,378 2028 500,924,378 - 9,557,557 (44,863,000) 465,618,935 2029 465,618,935 - 8,878,872 (42,208,000) 432,289,807 2030 432,289,807 - 8,561,887 (7,289,000) 433,562,695 2031 433,562,695 - 8,587,033 (7,317,000) 434,832,728 2032 434,832,728 - 8,612,401 (7,317,000) 436,128,128 2033 436,128,128 - 8,638,275 (7,317,000) 437,449,404 2034 437,449,404 - 8,664,667 (7,317,000) 438,797,071 2035 438,797,071 - 8,691,586 (7,317,000) 440,171,657 2036 440,171,657 - 8,719,042 (7,317,000) 441,573,699 2037 441,573,699 - 8,747,047 (7,317,000) 443,003,746 2038 443,003,746 - 8,776,740 (7,204,000) 444,576,485 2039 444,576,485 - 8,808,154 (7,204,000) 446,180,639 2040 446,180,639 - 8,840,196 (7,204,000) 447,816,835 2041 447,816,835 - 8,872,878 (7,204,000) 449,485,713 2042 449,485,713 - 8,906,212 (7,204,000) 451,187,925 2043 451,187,925 - 8,940,213 (7,204,000) 452,924,138 2044 452,924,138 - 8,974,892 (7,204,000) 454,695,031 2045 454,695,031 - 9,010,265 (7,204,000) 456,501,295 2046 456,501,295 - 9,046,344 (7,204,000) 458,343,639 2047 458,343,639 - 9,083,143 (7,204,000) 460,222,782 2048 460,222,782 - 9,120,678 (7,204,000) 462,139,460 2049 462,139,460 - 9,158,962 (7,204,000) 464,094,422 2050 464,094,422 - 9,198,011 (7,204,000) 466,088,433 2051 466,088,433 - 9,237,840 (7,204,000) 468,122,273 2052 468,122,273 - 9,278,464 (7,204,000) 470,196,738 2053 470,196,738 - 9,319,900 (7,204,000) 472,312,638 2054 472,312,638 - 9,362,164 (7,204,000) 474,470,802 2055 474,470,802 - 9,405,272 (7,204,000) 476,672,074 2056 476,672,074 - 9,449,241 (7,204,000) 478,917,315 2057 478,917,315 - 9,494,088 (7,204,000) 481,207,403 2058 481,207,403 - 9,539,831 (7,204,000) 483,543,233 2059 483,543,233 - 9,586,487 (7,204,000) 485,925,721 2060 485,925,721 - 9,634,076 (7,204,000) 488,355,796 2061 488,355,796 - 9,682,615 (7,204,000) 490,834,411 2062 490,834,411 - 9,732,123 (7,204,000) 493,362,535 L-23-061 Page 4 of 4 Beginning Ending Year Balance Deposits Earnings Withdrawal Balance 2063 493,362,535 - 9,782,621 (7,204,000) 495,941,155 2064 495,941,155 - 9,834,127 (7,204,000) 498,571,283 2065 498,571,283 - 9,886,662 (7,204,000) 501,253,944 2066 501,253,944 - 9,940,246 (7,204,000) 503,990,191 2067 503,990,191 - 10,011,569 (5,535,000) 508,466,760 2068 508,466,760 - 10,093,056 (6,329,000) 512,230,816 2069 512,230,816 - 10,168,240 (6,329,000) 516,070,056 2070 516,070,056 - 10,244,926 (6,329,000) 519,985,983 2071 519,985,983 - 10,323,144 (6,329,000) 523,980,127 2072 523,980,127 - 10,402,924 (6,329,000) 528,054,051 2073 528,054,051 - 10,484,298 (6,329,000) 532,209,350 2074 532,209,350 - 10,567,297 (6,329,000) 536,447,647 2075 536,447,647 - 10,651,954 (6,329,000) 540,770,601 2076 540,770,601 - 10,738,302 (6,329,000) 545,179,904 2077 545,179,904 - 10,826,375 (6,329,000) 549,677,279 2078 549,677,279 - 10,871,494 (10,806,000) 549,742,773 2079 549,742,773 - 10,577,433 (40,381,000) 519,939,206 2080 519,939,206 - 9,912,098 (47,393,000) 482,458,304 2081 482,458,304 - 8,805,494 (83,234,000) 408,029,797 2082 408,029,797 - 7,597,558 (55,326,000) 360,301,356 2083 360,301,356 - 6,642,209 (55,527,000) 311,416,564 2084 311,416,564 - 5,001,365 (122,053,000) 194,364,929 2085 194,364,929 - 3,040,256 (84,313,000) 113,092,185 2086 113,092,185 - 2,151,984 (10,709,000) 104,535,169 2087 104,535,169 - 2,067,443 (2,060,000) 104,542,612 (1,001,954,000)

Enclosure A L-23-061 Perry Nuclear Power Plant Updated Decommissioning Cost Analysis January 2023 (51 pages follow)

HOLTEC I NTERNAT I ONAL Perry Nuclear Power Plant Updated Decommissioning Cost Analysis Prepared for Energy Harbor Nuclear Corporation Prepared by Holtec International, LLC March 29, 2023

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL TABLE OF CONTENTS Executive Summary ........................................................................................................................ 1 1.0 Introduction............................................................................................................................ 3 1.1 Objectives.......................................................................................................................... 3 1.2 Site Description ................................................................................................................. 3 1.3 Radiological Criteria for License Termination ................................................................. 4 2.0 Perry Decommissioning Strategy ......................................................................................... 4 2.1 Decommissioning Strategy ............................................................................................... 4 2.1.1 DCE Development to Support the Decommissioning Strategy................................. 5 2.2 Period 1 Pre-Decommissioning Planning and Preperation ............................................... 5 2.3 Period 2 Plant Deactivation............................................................................................... 5 2.4 Period 3 SAFSTOR Operations ........................................................................................ 6 2.5 Period 4 Dismantlement .................................................................................................... 7 2.6 Period 5 Ongoing ISFSI Operations.................................................................................. 8 2.7 Period 6 Program Management......................................................................................... 9 3.0 Perry DCE Cost Estimate Approach..................................................................................... 9 3.1 Perry DCE Basis of Estimate ............................................................................................ 9 3.2 Perry DCE Methodology................................................................................................. 10 3.3 Waste Management Considerations for the DCE ........................................................... 11 3.3.1 Low-Level Radioactive Waste ............................................................................... 12 3.3.2 Intermediate and High-Level Radioactive Waste................................................... 12 3.3.3 Greater than Class C Radioactive Waste ................................................................ 12 3.3.4 Spent Fuel Management ......................................................................................... 12 3.4 Updated Perry DCE Financial Assumptions.................................................................. 13 3.4.1 Contingency............................................................................................................ 13 3.4.2 Work Difficulty Factors.......................................................................................... 14 3.4.3 Period 3 Security Costs.......................................................................................... 14 3.4.4 Labor Staffing........................................................................................................ 14 3.4.5 Asbestos Remediation ........................................................................................... 14 3.4.6 Energy.................................................................................................................... 14 3.4.7 Insurance................................................................................................................ 14 3.4.8 EHNC Corporate Overhead.................................................................................... 15 3.4.9 Site Non-Labor Overhead....................................................................................... 15 i PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant

HOL TEC Updated Decommissioning Cost Analysis I NTERNAT I ONAL 3.4.10 Property Taxes ........................................................................................................ 15 3.4.11 NRC Fees................................................................................................................ 15 3.4.12 Emergency Planning Fees ...................................................................................... 15 3.4.13 Miscellaneous Cost Allocation ............................................................................... 15 4.0 Perry Cost Estimate Summary ........................................................................................... 16 Tables Table 1. Perry Decommissioning SAFSTOR Cost Summary Table 2. Decommissioning Periods and WBS Elements with Start/Finish Dates Attachments Perry Decommissioning SAFSTOR Cost Summary Perry Decommissioning Study Waterfall Chart Work Breakdown Structure Code and Name Summary of Perry Decommissioning Waste Volume and Weight by Disposal Category Estimated Decommissioning Cost by Major Category Decommissioning Activities and Cost by Period Labor Cost and Requirements by Year Labor Staffing Curve by Year Program Management Cost Detail 0 ISFSI Decommissioning Cost Estimate ii PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL ABBREVIATIONS and ACRONYMS ALARA As Low As Reasonably Achievable DCE Decommissioning Cost Estimate DFP Decommissioning Funding Plan DOE Department of Energy EHNC Energy Harbor Nuclear Corporation FEMA Federal Emergency Management Agency GTCC Greater than Class C HDI Holtec Decommissioning International, LLC IAEA International Atomic Energy Agency ISDC International Structure for Decommissioning Costing ISFSI Independent Spent Fuel Storage Installation LTP License Termination Plan MPCs Multi-Purpose Dry Shielded Storage Canisters NSSS Nuclear Steam Supply System NRC Nuclear Regulatory Commission OECD Organization for Economic Co-operation and Development Perry Perry Nuclear Power Plant SAFSTOR Safe Storage TEDE Total Effective Dose Equivalent USEPA U.S. Environmental Protection Agency WBS Work Breakdown Structure WDF Work Difficulty Factors iii PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis INTERNATIONAL EXECUTIVE

SUMMARY

This report presents an updated decommissioning cost estimate (DCE) of the Perry Nuclear Power Plant (Perry) following the scheduled shutdown of plant operations. This DCE evaluation has been prepared on behalf of Energy Harbor Nuclear Corp. (EHNC) to support an updated 2023 Decommissioning Funding Plan (DFP) submittal to the Nuclear Regulatory Commission (NRC).

Perry is owned by Energy Harbor Nuclear Generation LLC and is operated by Energy Harbor Nuclear Corp. (EHNC). The analysis relies on a combination of site-specific, technical information obtained from prior cost study evaluations prepared for Perry as well as relevant industry decommissioning experience acquired by Holtec Decommissioning Inc. (Holtec) in currently undertaking five similar projects, and this experience has been incorporated into the preparation of this DCE.

The DCE is based on assumptions in areas of regulation, component characterization, high-level radioactive waste management, low-level radioactive waste disposal, demolition, site restoration requirements, labor staffing, security staffing, fuel management, administrative costs, SAFSTOR costs, and contingency.

The analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering required to carry out the decommissioning of Perry. The assumptions and approach described in this DCE may not reflect the actual plan to decommission Perry as the selected approach may differ from the assumptions made in this evaluation over the course of time.

The primary goal of decommissioning is the removal and disposal of the radiologically contaminated systems and structures required to terminate the Part 50 NRC license. This analysis recognizes that spent fuel will be stored onsite in an independent spent fuel storage installation (ISFSI) until such time that it can be transferred to the Department of Energy (DOE) or to an offsite storage facility.

The DCE recognizes and includes costs to manage and decommission this ISFSI. Costs are reported in 2022 dollars and include monies anticipated to be spent for decommissioning, operating license termination, spent fuel management, and site restoration activities. Attachment 1, also shown below as Table 1, provides the updated cost by category for decommissioning.

Table 1 Peri Decommissioning S STOR Co t Summar (thousands of 2023 dollars)

License Cost Category Spent Fuel Site Restoration Total Termination Decont amination 7,704 7,704 Rem oval 224,409 24,124 248,533 Packagi ng 28,555 720 29,275 Transpo rtation 33,168 2,616 35,784 Di.sposal 112,760 7,024 119,785 Off-site Waste Processing 23,541 23,541 Program Manage ment 249,923 6,071 205 256,199 Corpor ate A&G 50,097 22,358 1,861 74,316 Spent Fuel (Direct Expend it ures) 364,880 364,880 Insurance and Regulatory Fees 44,221 26,889 195 71,306 Energy 21,489 21,489 Characterization and Licensing Surveys 37,462 37,462 Property Taxes 77,404 77,404 Misce llaneous Equipment / Site Services 91,207 26,958 472 118,637 Spent Fuel Pool Isolat ion Grand Tot al 1,001,940 447,155 37,217 1,486,312 1 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL The Perry DCE has been developed using EHNCs planned shutdown date of November 7, 2026.

The estimate includes continued operation of the spent fuel pool as interim wet fuel storage facility for approximately three years after cessation of operations. During this period, it is assumed that the spent fuel residing in the pool, following a sufficient cooling period, will be transferred to an ISFSI located on the site. The ISFSI will remain operational until the spent fuel is transferred to DOE or an appropriate offsite storage facility. The current ISFSI is sufficiently sized to accommodate all fuel in dry storage assuming the shutdown in 2026.

Decommissioning scenarios were evaluated for removal of the reactor internals before and after the safe storage (SAFSTOR) dormancy. The decommissioning scenario to remove and segment the reactor internals was selected as the optimum approach. Benefits of this approach include the following:

Radioactive decay of the internal components will result in lower waste management costs and lower overall dose to site decommissioning workers.

Total decommissioning costs are reduced because of the added growth of the decommissioning fund in lieu of incurring the cost of this effort shortly after plant shutdown. provides a high-level summary schedule of the selected decommissioning approach evaluated in this DCE.

The estimate to decommission Perry assumes the removal of all contaminated and activated plant components and structural materials for unrestricted use of the site with no further requirements for an operating license. Low-level radioactive waste, other than greater than Class C (GTCC) waste, is sent to a commercial processor for treatment/conditioning or to a controlled disposal facility. GTCC waste will be stored on the ISFSI pad on site for eventual transfer to DOE with the spent fuel.

Decommissioning is accomplished within the 60-year period required by current NRC regulations.

In the interim, the spent fuel remains in storage at the site until such time that the transfer to an appropriate disposal facility is complete. After the ISFSI facility is closed, it is also decommissioned.

Cost categories are provided and discussed in Section 3. Detailed cost breakdown information is summarized in Section 4, with supporting tables attached to this DCE.

The DCE was developed with costs in 2022 dollars. The DCE does not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the plant or during the decommissioning period.

2 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL

1.0 INTRODUCTION

This report presents an updated decommissioning cost estimate (DCE) of the Perry Nuclear Power Plant (Perry) following the scheduled shutdown of plant operations. Perry is owned by Energy Harbor Nuclear Generation LLC. The plant is operated by Energy Harbor Nuclear Corporation (EHNC). The analysis relies upon site-specific, technical information from an evaluation prepared in 2020. This report reflects changes and updated costs along with EHNCs current assumptions for disposition of the nuclear unit. Relevant industry experience by Holtec Decommissioning Inc.

(Holtec) in undertaking such projects is incorporated into this DCE.

1.1 Objectives The objective of this evaluation is to prepare a DCE to decommission Perry, provide a sequence or schedule for the associated activities, address waste stream projections, and outline the overall decommissioning process. The operating license for the nuclear Unit 1 was issued on March 18, 1986. For purposes of this analysis, Perry is assumed to cease operations on November 7, 2026, after 40 years of operations.

1.2 Site Description The site description provided in this section is consistent with prior DCE estimates and Decommissioning Funding Plans (DFPs) prepared for Perry. No changes in the sites condition have been identified in this evaluation.

The Perry site is located approximately 35 miles northeast of Cleveland, Ohio, on the southern shore of Lake Erie. Although the station is comprised of two nuclear units, only Unit 1 is currently in operation and considered within the scope of this cost estimate.

The nuclear steam supply system (NSSS) includes a single cycle, forced circulation, General Electric boiling water reactor producing steam for direct use in the steam turbine.

The rated core thermal output was increased in the year 2000 from 3,579 megawatts (thermal) to 3,758 megawatts, corresponding to a net design electrical rating of 1,268 megawatts (electric) with the reactor at rated power.

The NSSS is within a pressure-suppression containment which houses the reactor vessel, the recirculation loops, and branch connections of the reactor primary system. The containment system consists of a drywell that encloses the reactor pressure vessel, the reactor recirculation loops and pumps, and other branch connections of the reactor primary system. The drywell is a cylindrical reinforced concrete structure with a removable steel head. Part of the containment system is the suppression pool, containing a large amount of water used to rapidly condense steam from a reactor vessel blowdown or from a break in a major pipe. The third part of the containment system is the leak-tight containment vessel surrounding the drywell and the suppression pool. The containment vessel is a cylindrical steel structure with a dome top and flat bottom supported by a reinforced concrete foundation mat. The shield building is a cylindrical concrete structure enclosing the containment vessel, providing shielding from direct radiation under normal and accident conditions, and providing missile protection for the containment vessel.

The unit utilizes a power conversion system, including a turbine-generator, a main condenser, air ejector and turbine steam packing exhausting condensers, condensate filter-demineralizers, and a feedwater system. The power conversion system produces electrical 3 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL power from the energy of the steam coming from the reactor, condenses the steam into water, and returns the feedwater to the reactor. The heat rejected to the main condenser is removed by the circulating water system.

The turbine is a General Electric tandem compound, six-flow, reheat, 1800 rpm unit, consisting of one double-flow high pressure turbine and three double-flow low pressure turbines. Exhaust steam from the high-pressure turbine passes through moisture separator/reheaters before entering the three low-pressure turbines. Reheated steam is also supplied to two reactor feed pump drive turbines. Turbine steam is also extracted for six stages of feedwater heating.

1.3 Radiological Criteria for License Termination 10 CFR Part 20 Subpart E specifies the radiological criteria for license termination. The radiological criteria for releasing a facility for unrestricted use specify that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem per year provided that residual radioactivity has been reduced to levels that are As Low As Reasonably Achievable (ALARA). This DCE assumes that the Perry site will be remediated to this Nuclear Regulatory Commission (NRC) prescribed level.

NRC and the U.S. Environmental Protection Agency (USEPA) differ on the amount of residual radioactivity considered acceptable in site remediation. The USEPA has two limits that apply to radioactive materials. A USEPA limit of 15 millirem per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act. An additional and separate limit of 4 millirem per year, as defined in 40 CFR Part 141.16, is applied to drinking water. A memorandum of understanding between the NRC and USEPA does not impose any new requirements on NRC licensees and should reduce the involvement of the USEPA with NRC licensees who are decommissioning. If there are hazardous materials on the site, the USEPA may be involved in the cleanup. If these circumstances occur, dual regulation by both agencies is possible. However, the DCE does not anticipate this occurrence and thus does not include any cost for this remote possibility.

2.0 PERRY DECOMMISSIONING STRATEGY 2.1 Decommissioning Strategy The decommissioning alternative chosen in this study for Perry Unit 1 is SAFSTOR.

Following shutdown, the spent fuel will be relocated to the independent spent fuel storage installation (ISFSI) for interim onsite storage. All fuel is projected to be moved to dry storage within 3 years of shutdown. Dry fuel storage operations will continue at the site until the transfer of the fuel to the Department of Energy (DOE) for disposal, or to an offsite interim storage facility is completed. This transfer is assumed to begin in 2038 and will be complete in 2066 based upon current DOE fuel acceptance schedules. Unit 1 will remain in protective storage following the removal of all spent fuel from the site, with decommissioning deferred to 2078. Decommissioning operations will commence in 2078 and will last approximately eight years with license termination in 2086. Attachment 2 4 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL provides a high-level summary schedule of the selected decommissioning approach evaluated in this DCE.

2.1.1 DCE Development to Support the Decommissioning Strategy The DCE to decommission Perry is based upon the NRC approved decommissioning alternative of SAFSTOR followed by eventual decommissioning. As outlined in Regulatory Guide 1.202, the six periods of Perrys decommissioning and an outline of the supporting tasks are provided below in Table 2.

2.2 Period 1 Pre-Decommissioning Planning and Preparations Preparations for long-term storage include the planning for permanent defueling of the reactor, revision of technical specifications appropriate to the operating conditions and requirements, and characterization of the facility. The process of pre-planning decommissioning tasks will be limited to a six-month duration identified as Period 1 prior to shutdown of plant operations. Pre-planning tasks initiated prior to plant deactivation are limited to the following activities:

Development of licensing submittals to support shutdown and plant post shutdown configuration.

General characterization of the site and surrounding environs. This includes radiation surveys of work areas, major components (including the reactor vessel and its internals), internal piping, and primary shield cores. This task is expected to be initiated in November 2026.

Engineering tasks related to the procurement of casks for dry storage Period 1 is planned to be completed near the end of 2026.

2.3 Period 2 Plant Deactivation Plant deactivation tasks allow for completing the work to prepare for the sites dormancy period of the deferred decommissioning. The process of plant deactivation is expected to be approximately three years. The process of placing the plant in SAFSTOR includes tasks such as but not limited to the following activities:

Isolating the spent fuel storage services and fuel handling systems so that SAFSTOR operations may commence. These activities will be carried out by plant personnel in accordance with existing operating technical specifications.

Transferring the spent fuel from the storage pool to the ISFSI for interim storage, following the minimum required cooling period in the spent fuel pool.

Draining and deenergizing of the noncontaminated systems not required to support continued site operations or maintenance.

Draining of the reactor vessel, with the internals and the reactor vessel remaining in place.

Draining and deenergizing nonessential systems, decontaminating as required for future maintenance and inspection.

Preparing lighting and alarm systems whose continued use is required; deenergizing portions of fire protection, electric power, and HVAC systems 5 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL whose continued use is not required.

Cleaning of the loose surface contamination from building access pathways.

Performing an interim radiation survey of plant and posting warning signs where appropriate.

Erecting physical barriers and/or securing all access to radioactive or contaminated areas, except as required for inspection and maintenance.

Installing security and surveillance monitoring equipment and relocating security fence around secured structures, as required.

Developing of procedures for occupational exposure control, control and release of liquid and gaseous effluent, processing of radwaste (including dry-active waste, resins, filter media, metallic and nonmetallic components generated in decommissioning), site security and emergency programs, and industrial safety.

Period 1 is expected to be complete near the end of 2029.

2.4 Period 3 SAFSTOR Operations SAFSTOR operations are expected to the longest portion of the decommissioning process.

SAFSTOR operations are planned to be initiated in November 2029 and continue until November 2078 (39 years). The process of SAFSTOR dormancy efforts will include managing a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel perform equipment maintenance, inspection activities, routine services to maintain safe conditions, adequate lighting, heating and ventilation, and periodic preventive maintenance on essential site services.

Security during the dormancy period is conducted primarily to prevent unauthorized entry and to protect the public from the consequences of its own actions. The security fence, sensors, alarms, and other surveillance equipment are maintained throughout the dormancy period. Fire and radiation alarms are also functional.

An environmental surveillance program will be carried out during the dormancy period to ensure that releases of radioactive material to the environment are prevented or detected and controlled. Appropriate emergency procedures are established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program constitutes an abbreviated version of the program in effect during normal plant operations.

The SAFSTOR operations are planned to start in November 2029, or three years after the plant shutdown. During the SAFSTOR period, fuel cask pickups are planned to occur between January 2038 and December 2066. SAFSTOR is planned to continue after the final fuel cask pickups until the year 2078, when the plant is expected to initiate decommissioning. The anticipated start of decommissioning work is targeted for 2078 to allow eight years to complete the Period 4 dismantling before the required decommissioning completion date of 2086.

6 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL 2.5 Period 4 Dismantlement Plant dismantlement is expected to start in November 2078. At the start of the Period 4 dismantlement work, preparations will be initiated to plan for the start of the period decommissioning operations to reactivate site services and prepare for decommissioning.

Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning and the assembly of activity specifications and detailed work procedures are also initiated at this time.

Dismantlement will require engineering plans and procedures. Variation in the length of the dormancy period is expected to have some effect upon the quantities of radioactive waste generated from system and structure removal operations. Given the levels of radioactivity and spectrum of radionuclides expected from 40 years of plant operation, no plant process system identified as being contaminated upon final shutdown is assumed to become releasable due to the decay period alone. However, due to the lower activity levels, a greater percentage of the waste volume can be designated for off-site processing and recovery.

Eventually, site restoration will be required. Site restoration captures costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures not exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels.

This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures, including the successful release of the site from the 10 CFR Part 50 operating license, exclusive of the ISFSI. Significant decommissioning activities in this phase include:

Construction of temporary facilities and/or modification of existing facilities to support dismantling activities.

Reconfiguration and modification of site structures and facilities as needed to support decommissioning operations. This will likely include the upgrading of roads to facilitate hauling and transport. Modifications will likely be required to the containment structure to facilitate access of large/heavy equipment.

Modifications will also likely be required to the refueling area of the reactor building to support the segmentation of the reactor vessel internals and component extraction.

Design and fabrication of temporary and permanent shielding to support removal and transportation activities, and construction of contamination control envelopes.

Procurement (lease or purchase) of shipping canisters, cask liners, and industrial packages for the transportation and disposal of low-level radioactive wastes generated during decommissioning.

Decontamination of components and piping systems as required to control (minimize) worker exposure.

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Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL

Segmentation by weight and activity maximizes the loading of the shielded transport casks. The operations are conducted underwater using remotely operated tooling and contamination controls.

Disconnection of the control blades from the drives on the vessel lower head.

Blades are transferred to the dryer-separator pool for packaging.

Disassembly, segmentation, and packaging of the core shroud and in-core guide tubes. Some of the material is expected to exceed Class C disposal requirements.

Removal and segmentation of the remaining internals including the jet pump assemblies, orifice fuel supports, and core plate assembly.

Draining and decontamination of the reactor well and the permanent sealing of the spent fuel transfer gate. Install a shielded platform for segmentation of the reactor vessel. Cutting operations are performed in air using remotely operated equipment within a contamination control envelope, with the water level maintained just below the cut to minimize the working area dose rates. Sections are transferred to the dryer-separator pool for packaging and interim storage.

Disconnection of the control rod drives and instrumentation tubes from reactor vessel lower head. The lower reactor head and vessel supporting structure are then segmented.

Removal of the reactor recirculation pumps. Exterior surfaces are decontaminated, and openings covered. Components can serve as their own burial containers provided that all penetrations are properly sealed.

Demolition of the primary shield activated concrete.

At least two years prior to the anticipated date of license termination, a license termination plan (LTP) is required. Submitted as a supplement to the final safety analysis report, the plan must include: a site characterization, description of the remaining dismantling activities, plans for site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns. The NRC will acknowledge the receipt of the plan, make the plan available for public comment, and schedule a local hearing. LTP approval will be subject to any conditions and limitations as deemed appropriate by the NRC.

2.6 Period 5 Ongoing ISFSI Operations EHNC currently has an operational ISFSI on site. After the plant shutdown, the remainder of the spent fuel will be loaded into casks and moved to the ISFSI. Greater than Class C (GTCC) waste will be handled in a similar manner. The DCE estimates assume that the shutdown date of the nuclear unit is scheduled for 2026, and there is no delay in transitioning the plant and workforce from operations or in obtaining regulatory relief from operating requirements. The DCE includes the continued operation of the spent fuel pool as interim wet fuel storage facility for approximately three years after cessation of operations. During this period, it is assumed that the spent fuel residing in the pool will be transferred to an ISFSI located on the site. The ISFSI will remain operational until the spent fuel is transferred to an appropriate disposal facility. The ISFSI is planned to remain operational until the end of 2066.

2.7 Period 6 Program Management 8 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL Program management costs are incurred during the decommissioning period. These costs include detailed project management activities and support services. These activities and services include the following:

Project implementation planning

Scheduling and cost control

Safety and environmental analysis, and ongoing operational activities

Quality assurance

Plant surveillance

Public relations and stakeholder involvement

Information systems and computer support

Personnel management and training

Project documentation and records control

Procurement, warehousing, and materials handling

Industrial health and safety management Site restoration is also included in program management. Removal of the contaminated materials at the site may result in damage to many of the site structures. Decontamination activities can impact the power block structures, potentially weakening the footings and structural supports. It is not reasonable to expect these structures would be repaired and preserved after the radiological contamination is removed. The cost to dismantle site structures with a workforce already mobilized is expected to be less due to the more efficient planning and implementation of the work. The DCE assumes that some site features will remain following the decommissioning project. These include the existing electrical switchyard, which is assumed to remain functional in support of the regional electrical distribution system. The existing shoreline and other water features will be left intact.

3.0 PERRY DCE COST ESTIMATE APPROACH The DCE estimate prepared for decommissioning Perry considers features of the site, including the NSSS, electric power generating systems, structures, and supporting facilities. The basis of the estimate, including the sources of information relied upon, the estimating methodology employed, site-specific considerations, and other pertinent assumptions, is described in this section.

This estimate has been developed assuming that Energy Harbor selects to self-perform and manage the decommissioning operations utilizing industry vendors as necessary.

3.1 Perry DCE Basis of Estimate The basis of estimate relies upon site-specific, technical information from earlier evaluations prepared in 2014 and 2020. Data has been updated to reflect current assumptions pertaining to the disposition of nuclear power plants.

Regulatory Guide 1.184 describes the methods and procedures that are acceptable to the NRC staff for implementing the requirements that relate to the initial activities and the major phases of the decommissioning process. The costs and schedules follow the general guidance and sequence in the regulations. The format and content of the estimates is also consistent with the recommendations of Regulatory Guide 1.202.

9 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL Relevant industry experience of current HDI decommissioning projects is the basis for a significant portion of the current update. This information was reviewed for the current analysis and updated as deemed appropriate. The site-specific considerations and assumptions used in the previous evaluations were also revisited. Modifications were incorporated where new information was available or experience from ongoing decommissioning programs provided viable alternatives or improved processes.

3.2 Perry DCE Methodology The methodology used to develop the estimates follows the basic approach presented in the Nuclear Energy Agency Report "International Structure for Decommissioning Costing (ISDC) of Nuclear Installations. This report was published in 2012 as a cooperative effort between the Organization for Economic Co-operation and Developments (OECD)

Nuclear Energy Agency, the European Commission, and the International Atomic Energy Agency (IAEA).

The ISDC uses a two-digit numbering system with eleven primary activities. These primary activities are as follows:

01 - Pre-Decommissioning Activities

02 - Facility Shutdown Activities

03 - Additional Activities for Safe Enclosure and Entombment

04 - Dismantling Activities within the Controlled Area

05 - Waste Processing, Storage, and Disposal

06 - Site Infrastructure and Operations

07 - Conventional Dismantling, Demolition, and Site Restoration

08 - Project Management, Engineering, and Support

09 - Research and Development

10 - Fuel and Nuclear Material

11 - Miscellaneous Expenditures The work breakdown structure (WBS) for the current DCE is based on and numbered according to this numbering system. Costs were allocated within each WBS activity except for 09 - Research and development. The Perry site has no research and development activities or costs, therefore, this numbering sequence was not used. The estimate was developed by assigning work tasks and their associated costs to specific WBS tasks.

Attachment 3 provides a summary of the assigned WBS code and name for each task.

Within the DCE, costs within each of the ten numbering systems were then allocated to six specific periods during the overall decommissioning process. These 6 specific periods are as follows:

Period 1 - Pre-Decommissioning Planning and Preparation

Period 2 - Plant Deactivation

Period 3 - SAFSTOR Operations

Period 4 - Dismantlement

Period 5 - Ongoing ISFSI Operations

Period 6 - Program Management 10 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTERNAT I ONAL Table 2 provides a summary of the WBS elements mapped to each period, including the projected start and end date for each period.

Decommi ioning Periods and '\VB Element 3.3 Waste Management Considerations for the DCE Attachment 4 provides a summary of the Perry waste volumes by regulatory disposal classification. The estimated volume and weight for each waste classification category has been updated from the prior DCE estimate submitted by EHNC. Detailed waste management considerations are as follows:

Class A waste volume has been increased by approximately 103,000 cubic feet.

This increase assumes that an increased volume of waste will be directly disposed rather than processed.

Core hardware and spent resins (Class B/C) volume has been increased overall when compared to the prior estimate.

Greater than Class C volume has remained unchanged from the previous estimate.

LLRW waste disposal costs have been estimated based upon current 2022 markets conditions (excluding GTCC which used existing basis of estimate) rather than adopting the NUREG 1307 Rev 1 Report on Waste Burial Charges.

The reactor pressure vessel is assumed to be Class A waste. SAFSTOR decay of short half-life radionuclides was assumed to reduce the activity by an estimated thirty percent.

Class B and C wastes were assumed to be ninety percent Class B and ten percent Class C. These waste volumes represent an increase and shift in waste class from the prior SAFSTOR estimate based on decay, and the benefit of removing those wastes after the SAFSTOR period.

Exempt waste volume assumption is that these low activity wastes comprise 11 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL seventy-five percent of Class A waste volume estimate. It is assumed that spot decontamination or segregation by a waste processor can further reduce certain exempt wastes volumes to allow for metal recovery or free release. Wastes that are borderline impacted by alpha contamination will be shipped to and disposed at a licensed disposal facility.

3.3.1 Low-Level Radioactive Waste The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is generally classified as low-level radioactive waste. Most of the low-level radioactive waste designated for direct disposal (Class A) will be assumed to be sent to a licensed radioactive waste disposal site. Disposal costs for Class A waste were based upon information available to HDI from similar projects.

A significant portion of the metallic waste material generated during decommissioning may only be potentially contaminated by radioactive materials.

This waste can be surveyed on site or shipped off site to licensed facilities for further survey, for processing, and/or for conditioning/recovery. Reduction in the volume of low-level radioactive waste requiring disposal in a licensed low-level radioactive waste disposal facility can be accomplished through a variety of methods, including assay and surveys or decontamination to isolate the portion of waste that does not require disposal as radioactive waste, compaction, incineration, or metal melt. The estimate allows $20,000,000 for waste recovery and volume reduction of low-level radioactive materials. This would be accomplished at a licensed waste processor and would represent approximately 15,000,000lbs of processed/ conditioned wastes.

3.3.2 High Activity Low Level Radioactive Waste (Class B and C)

The contaminated and activated materials with concentrations of radionuclides that exceed the limits established by the NRC for Class A waste and meet the definition of Class B&C waste are assumed to be removed, packaged, and disposed at a facility licensed for Class B&C waste disposal. The Waste Control Specialists facility in Andrews, Texas is licensed for Class B&C disposal and is the assumed disposal site for these wastes generated at Perry.

3.3.3 Greater than Class C Radioactive Waste GTCC radioactive waste does not currently have an approved disposal pathway.

For purposes of this evaluation, GTCC radioactive waste is assumed to be packaged and stored in a similar manner and at a cost equivalent to that for spent fuel. GTCC will be packaged in Non-Fuel Waste Canisters similar to canisters used for spent fuel. This approach is consistent with the planned approach as other similar sites planning or performing decommissioning. GTCC will be shipped directly to a Department of Energy (DOE) facility as it is generated.

3.3.4 Spent Fuel Management EHNCs spent fuel management plan for the Perry spent fuel is based upon the following:

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Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL

Spent fuel will be transferred from the pool to the ISFSI during the three-year period after final shutdown.

Spent fuel will be shipped in the Holtec International multi-purpose dry shielded storage canisters (MPCs).

First shipment of spent fuel from the Perry site occurs in 2038. Final shipment of spent fuel from the Perry site occurs in 2066.

A maximum rate of transfer for spent fuel to DOE is 3,000 metric tons of uranium per year. DOE acceptance schedules may result in different completion dates.

The spent fuel pool will contain both assemblies from the most recent refueling cycles as well as the final reactor core at shutdown. Over the following three years, the assemblies will be packaged into MPCs for transfer to the ISFSI for interim storage.

This period provides the necessary cooling for the freshly discharged fuel to meet the storage requirements for decay heat.

The Perry ISFSI, operated under a Part 50 General License in accordance with 10 CFR 72, Subpart K, has been constructed to support continued plant operations. The facility will not need to be expanded to support decommissioning based upon 2026 date of shutdown.

EHNC's position is that the DOE has a contractual obligation to accept Perrys fuel earlier than the projections set out above consistent with its contract commitments.

No assumption made in this study should be interpreted to be inconsistent with this claim. However, including the cost of storing spent fuel in this study is appropriate to ensure the availability of sufficient decommissioning funds at the end of the stations life if the DOE has not met its obligation.

3.4 Updated Perry DCE Financial Assumptions As a key process in developing this DCE, some underlying assumptions from prior DCEs were altered or eliminated. Each of these updated assumptions is listed below along with the justification for the change.

3.4.1 Contingency Inherent in any cost estimate for a significant future project is the inability to specify the precise source of costs since that may be changed by factors such as tool breakage, accidents, illnesses, weather delays, labor stoppages, regulatory changes, or other unknowns. Contingencies are the financial provision for unforeseeable elements of cost within a project scope where previous experience relating estimates and actual costs has shown that unforeseeable events can increase costs.

The prior DCE utilized varying contingencies ranging from 10 to 75 percent depending on the task. The overall calculated contingency for the estimate was 17.97 percent. Given the maturity of decommissioning programs which have generated predictability in decommissioning costs at HDI managed sites, HDI applies a standard contingency to all decommissioning cost items in its cost estimates. For this DCE estimate, a conservative contingency of 18 percent, consistent with contingency applied to HDI decommissioning site estimates, has been applied to each cost item. The change does not impact the acceptability of the DCE.

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Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL 3.4.2 Work Difficulty Factors The prior DCE included work difficulty adjustment factors (WDFs) assigned to specific work tasks to account for the inefficiencies in working in a decommissioning environment. Factors ranged from 8.33 to 37 percent depending on the presumed inefficiency. Since the current DCE has been developed using the current industry experience of HDI, WDFs have been removed from the current estimate. Work task durations are based on HDIs direct experience in performing decommissioning activities at multiple sites. The change does not impact the acceptability of the DCE.

3.4.3 Period 3 Security Costs A significant portion of the planned cost in Period 3 SAFSTOR is the labor cost of security. Based on HDIs experience in providing security at decommissioning sites, all the allocated security labor costs between the initiation of SAFSTOR in 2029 and the final removal of spent fuel from the site in 2066 are considered a reimbursable cost from the DOE.

After final transfer of the spent fuel canisters from the ISFSI to DOE in 2066, the security labor costs are subsequently captured as a line-item cost as part of license termination for the duration of the estimate timeline.

3.4.4 Labor Staffing This DCE utilizes a fully burdened cost for labor. Hourly labor costs include wages and benefits at rates comparable to HDIs experience at ongoing decommissioning projects and the Bureau of Labor Statistics for wage rates in that region. A limited amount of overtime cost is included for tasks and activities that would expect to require additional labor effort to meet the schedule milestones.

3.4.5 Asbestos Remediation The prior DCE did not include any cost for asbestos removal. Based on the plant type, and Holtecs experience at other sites currently performing decommissioning,

$7,000,000 has been allocated to this line item in this DCE. While not a radiological decommissioning expense, asbestos removal in radiological contaminated areas must be performed to complete radiological decommissioning activities.

3.4.6 Energy For estimating purposes, the plant is assumed to be deenergized, except for those facilities associated with spent fuel storage. Replacement power costs are used to calculate the cost of energy consumed during decommissioning for tooling, lighting, ventilation, and essential services.

3.4.7 Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums. Reductions in premiums, throughout the decommissioning process, are based upon the guidance provided in SECY 0145, Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning.

14 PROJECT ID - 3299-01 REV 1

Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL The NRCs financial protection requirements are based on various reactor and spent fuel configurations.

3.4.8 EHNC Corporate Overhead A corporate support overhead cost has been included at a level commensurate with the existing Perry corporate support costs.

3.4.9 Site Non-Labor Overhead These estimates include costs for site non-labor overhead charges. These costs include telephones, copy machines, computers, IT infrastructure, office supplies, janitorial supplies, training expenses, and other similar costs. EHNC provided a site non-labor overhead allowance to address these costs.

3.4.10 Property Taxes Property taxes are included in the DCE estimate. EHNC provided their 2021 property tax payments which were escalated to 2022 dollars. This rate per month is assumed to continue until zirconium fire elimination. Property taxes were reduced to be estimated to be 60% of operational value based on experience from other plants that have been managed by HDI having closed and transitioned from operating to non-operating plants. Further reductions were taken after fuel on pad through SAFSTOR and decommissioning complete phases.

3.4.11 NRC Fees These estimates include charges from the NRC to support the Perry decommissioning program. Charges are included for the yearly licenses held by EHNC for the Part 50 license, as well as engineering support charges by the NRC to review activities at the site. The Part 50 license fee for a reactor in a decommissioning or possession-only status and which has spent fuel onsite is

$188,000 per year. The hourly rate for NRC review is $290 per hour. The level of effort of NRC participation is commensurate with the decommissioning alternative and schedule.

3.4.12 Emergency Planning Fees This estimate includes costs for emergency planning support activities. There are three separate civil emergency planning entities assumed to be supporting EHNC during the decommissioning program including FEMA, local Fire department fees and training, and State and local fees, rentals, and maintenance. The Federal Emergency Management Agency (FEMA) yearly fees are estimated for the site from shutdown until approximately 12 months after unit shutdown, after which the FEMA fees are assumed to be eliminated.

3.4.13 Miscellaneous Cost Allocation The prior DCE did not allocate any cost for taxes, insurance, NRC fees, energy, health physics staff supplies, or disposal of dry activated waste as part of the spent fuel management cost during the Period 3 SAFSTOR. These miscellaneous costs have been added and assigned as DOE reimbursable costs.

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Perry Nuclear Power Plant HOL TEC Updated Decommissioning Cost Analysis I NTE R NAT I ONAL 4.0 PERRY COST ESTIMATE

SUMMARY

The DCE to decommission Perry relies on site-specific, technical information. While not an engineering study, the estimate provides sufficient information to assess the financial obligations to the eventual decommissioning of the nuclear station.

The DCE is based on fundamental assumptions, including regulatory requirements, project contingencies, low-level radioactive waste disposal practices, high-level radioactive waste management options, and site restoration requirements. The decommissioning scenario assumes continued operation of the spent fuel pool for a minimum of three years following the cessation of operations for continued cooling of the assemblies.

Various supporting detailed summaries are included with this DCE. Each of these detailed attachments and the data provided is listed below.

Attachment 1 provides the decommissioning cost estimate summary by cost category. The summary of the costs estimated are a breakdown of License Termination, Spent Fuel and Site Restoration.

Attachment 2 provides a project timeline that presents the schedule major scope of work and milestones for decommissioning and spent fuel management. The timeline also depicts key licensing milestones.

Attachment 3 provides the list of ISDC (International Structure for Decommissioning Costing) WBS codes considered into the cost estimate.

Attachment 4 provides a summary of the waste volumes and weights by regulatory disposal classification.

Attachment 5 provides the decommissioning cost by cost element assigned to each major cost category. The major cost categories are license termination, spent fuel management, and site restoration. These categories are provided to support an understanding of the adjustments and updates from the prior DCE.

Attachment 6 provides the decommissioning activities and cost by period. This breakdown is provided to show the assignment of cost to planned decommissioning periods. This detailed information has been added since it was not included in the prior DCE.

Attachment 7 provides the labor cost and labor requirements by calendar year. This breakdown is provided to update the DCE from the prior DCE.

Attachment 8 provides the labor staff curve by calendar year.

Attachment 9 provides the program management cost detail by calendar year. This breakdown is provided to update the DCE from the prior DCE.

Attachment 10 provides the DCE for the eventual closure of the ISFSI. This breakdown is provided to update the DCE from the prior DCE.

16 PROJECT ID - 3299-01 REV 1

HOLTEC I NT ERNATIONAL ATTACHMENT 1 Perry Decommissioning SAFSTOR Cost Summary

HOLTEC I NT ERNATIONAL Perry Decommissioning SAFSTOR COST

SUMMARY

(thousands of 2022 dollars)

HOLTEC I NT ERNATIONAL ATTACHMENT 2 Perry Decommissioning Study Waterfall Chart

HOLTEC PERRY DECOMMISSIONING STUDY WATERFALL CHART DECOMMISSIO ING FUEL I TER ATIO AL DORMANCY REMOVAL PERIOD END PHASE 1 START COMPLETE DORMANCY BUILDING 12/04/2026 ZIRCONIUM FIRE 11/08/2029 FUEL PERIOD DEMOLITION FINAL LICENSE ELIMINATED

~

SHUTDOWN END PHASE 2 FUEL ON PAD DOE SITE SHIPMENT FINISH COMPLETE FINAL SITE TERMINATION 11/07/2026 03/05/2028 END PHASE 3 AVAILABLE END PHASE 4 END PHASE 5 END PHASE 6 SURVEY END PHASE 7 11/07/2029 01/01/2038 12/31/2066 11/07/2078 12/21/2085 05/06/2086 07/08/2087 Overall Schedule YEAR 2026 I I

2027 ,., 2028 I I

I 2029 l DORMANCY l ~ I 2078 2079 2080 2081 2082 2083 2084 2085 2086 2087 MILESTONE MONTH J F M A M J J A SO N D J F M A M J J ASO N DJ F M A M J J ASO N D J F M A M J A SO N 08-NOV-2029 TO 07-NOV-2078 I N D J F M A M J J ASON D J F M A M J J ASON D J F M A M J J ASON D J F M A M J J ASON D J F M A M J J ASO N D J F M A M J J ASO N D J F M A M J J ASO N DJ F M A M J J ASO N D J F M A M J J ASON D I

I I 11 I 111 111 11 I 111111 I I 1111 I I I 111 111111 I 11111 11 11 111111 111 111 11 I I 1111 I I 111111 I I 111 I 11 11 I 11 11111 11 SITE MODIFICATIONS SITE MODIFICATIONS SITE MODIFICATIONS MODIFICAllONS LICENSE NRC TERMINATION LTP PLAN APPROVAL

~ -

DEVELOP CHARACTE NRC REVIEW / APPROVE

~

CHARACTERIZATION - SCOPING / LICENSE CHARACTERIZATION RIZATION -

SAMPLING / REPORT / REMEDIATION TERMINATIO LICENSE TERMINATION PLAN HSA N PLAN ISFSI FUEL POOL TO PAD L FUEL CASKS PICKUP ENG. / DESIGN / REACTOR PRE- REACTOR SEGMENTATION FAB. / INSTALL TOOLING WORK WORK INTERNALS PRESSURE VESSEL PRE-DEMOLITION OF SSCS / DISMANTLING (SELECTED) DISMANTLING RELEASE (RAD AND NON RAD)

DEMOLITION OF DEMOLITION (SELECTED) DEMOLITION STRUCTURES WASTE WASTE MANAGEMENT WASTE MANAGEMENT MANAGEMENT SITE RESTORA EARTHWORK RESTORATION i TION i

NRC APPROVAL FINAL STATUS SURVEY I NRC SITE FSS REPORT SUBMITTAL FSS REPORT SURVEY I REVIEW NRC CONFIRMATORY SURVEY I I

HOLTEC INTERNA T I ONAL ATTACHMENT 3

'Wo1*k Breakdown Sh*ucture Code and Name

Work Breakdown Structure Code and Name WBS CODE WBS Name 01.02.01.02.01 Detailed facility characterization.

01.02.01.03.03 Safety, security and emergency planning for site operations.

01.02.01.05.01 License applications and license approvals.

01.02.01.06.01 Management team activities.

01.02.02.01.03 Cooling down of spent fuel.

01.02.03.01.01 Preparation for SAFSTOR 01.02.03.02.01 SAFSTOR Operations & Maintenance 01.02.04.01.03 Procurement of special tools for dismantling the reactor systems.

01.02.04.04.02 Removal of asbestos.

01.02.04.05.01 Dismantling of reactor internals.

01.02.04.05.02 Dismantling of reactor vessel and core components.

01.02.04.05.03 Dismantling of other primary loop components.

01.02.04.06.02 Dismantling of remaining components.

01.02.05.01.04 Maintenance, surveillance and operational support for waste management system.

01.02.05.08.07 Containers.

01.02.05.09.02 Processing.

01.02.05.09.05 Transport.

01.02.05.09.06 Disposal.

01.02.05.09.07 Containers.

01.02.05.12.01 Treatment and packaging.

01.02.05.12.03 Transport of hazardous waste.

01.02.05.12.04 Disposal of hazardous waste at dedicated waste dumps.

01.02.05.13.02 Treatment and packaging of hazardous waste.

01.02.06.01.01 Procurement of general security equipment.

01.02.06.01.04 Deployment of guards/security forces.

01.02.06.02.01 Inspection and maintenance of buildings and systems.

01.02.06.02.02 Site upkeep activities.

01.02.06.03.01 Electricity supply systems.

01.02.06.03.02 Ventilation systems.

01.02.06.03.07 Other systems.

01.02.06.04.01 Procurement and maintenance of equipment for radiation protection and environmental monitoring.

01.02.06.04.02 Radiation protection and monitoring.

01.02.07.03.01 Demolition of buildings and structures from the formerly controlled area.

01.02.07.03.02 Demolition of buildings and structures outside the controlled area.

01.02.07.05.01 Final survey.

01.02.08.02.01 Core management group.

01.02.08.02.02 Project implementation planning, detailed ongoing planning.

01.02.08.02.03 Scheduling and cost control.

01.02.08.02.04 Safety and environmental analysis, ongoing studies.

01.02.08.02.05 Quality assurance and quality surveillance.

01.02.08.02.06 General administration and accounting.

01.02.08.02.07 Public relations and stakeholders involvement.

01.02.08.03.01 Engineering support.

01.02.08.03.02 Information system and computer support.

01.02.08.03.03 Waste management support.

01.02.08.03.04 Decommissioning support including chemistry, decontamination.

01.02.08.03.05 Personnel management and training.

01.02.08.03.06 Documentation and records control.

01.02.08.03.07 Procurement, warehousing, and materials handling.

01.02.08.03.08 Housing, office equipment, support services.

01.02.08.04.01 Health physics.

01.02.08.04.02 Industrial safety.

01.02.08.08.02 Information system and computer support.

01.02.10.01.02 Transfer of fuel or nuclear material to dedicated ISFSI.

01.02.10.02.02 Operation of ISFSI.

01.02.10.02.03 Transfer of fuel and/or nuclear material away from the ISFSI.

01.02.10.03.01 Decommissioning of ISFSI.

01.02.10.03.02 Management of waste.

01.02.11.01.01 Implementation of transition plans.

01.02.11.01.03 Payments (fees) to authorities.

01.02.11.02.02 Local, community, federal taxes.

01.02.11.03.01 Nuclear related insurances.

1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 20 of 27

HOLTEC I NT ER NATIONAL ATTACHMENT 4 Summary of Perry Decommissioning Waste Volume and Weight by Disposal Category

H OLTEC l'ITER A T IONAL Perry Decommissioning Waste Volume and Weight by Disposal Category Perry Waste Volumes Pen,* Pen,*

"*aste Class (cubic feet) (lbs)

A 1,027,537 67,574,155 Low-LeYel B 2,98 1 275,507 RadioactiYe Waste C 331 51,278 Greater than Class C Waste GTCC 1,868 365,766 Total 1,032,717 68,266,706

HOL T EC INTERNATIONAL ATTACHMENT 5 Estimated Decommissioning Cost by Major Category

Estimated Decommissioning Cost by Major Category (thousands of 2022 dollars)

Cost By Cost Element By WBS License Spent Fuel Site Restoration Total Termination WBS Activities 01.02 Decommissioning Unit 1,001,940 447,155 37,217 1,486,312 01.02.01 Pre-decommissioning actions 12,343 4,045 0 16,388 01.02.01.02 Facility characterization. 8,921 0 0 8,921 01.02.01.02.01 Detailed facility characterization. 8,921 0 0 8,921 01.02.01.03 Safety, security and environmental studies. 0 4,045 0 4,045 01.02.01.03.03 Safety, security and emergency planning for site operations. 0 4,045 0 4,045 01.02.01.05 Authorisation. 3,410 0 0 3,410 01.02.01.05.01 License applications and license approvals. 3,410 0 0 3,410 01.02.01.06 Preparing management group and contracting. 12 0 0 12 01.02.01.06.01 Management team activities. 12 0 0 12 01.02.02 Facility shutdown activities 7,888 6,699 40 14,627 01.02.02.01 Plant shutdown and inspection. 7,888 6,699 40 14,627 01.02.02.01.03 Cooling down of spent fuel. 7,888 6,699 40 14,627 01.02.03 Additional activities for safe enclosure or entombment 343,966 241,393 451 585,809 01.02.03.01 Preparation for safe enclosure. 4,186 0 0 4,186 01.02.03.01.01 Preparation for SAFSTOR 4,186 0 0 4,186 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 339,780 241,393 451 581,623 01.02.03.02.01 SAFSTOR Operations & Maintenance 339,780 241,393 451 581,623 01.02.04 Dismantling activities within the controlled area 108,493 0 0 108,493 01.02.04.01 Procurement of equipment for decontamination and dismantling. 7,806 0 0 7,806 01.02.04.01.03 Procurement of special tools for dismantling the reactor systems. 7,806 0 0 7,806 01.02.04.04 Removal of materials requiring specific procedures. 8,110 0 0 8,110 01.02.04.04.02 Removal of asbestos. 8,110 0 0 8,110 01.02.04.05 Dismantling of main process systems, structures and components. 90,148 0 0 90,148 01.02.04.05.01 Dismantling of reactor internals. 56,375 0 0 56,375 01.02.04.05.02 Dismantling of reactor vessel and core components. 3,491 0 0 3,491 01.02.04.05.03 Dismantling of other primary loop components. 30,283 0 0 30,283 01.02.04.06 Dismantling of other systems and components. 2,430 0 0 2,430 01.02.04.06.02 Dismantling of remaining components. 2,430 0 0 2,430 01.02.05 Waste processing, storage and disposal 224,373 0 10,905 235,278 01.02.05.01 Waste management system. 8,492 0 0 8,492 01.02.05.01.04 Maintenance, surveillance and operational support for waste management system. 8,492 0 0 8,492 01.02.05.08 Management of decommissioning intermediate-level waste. 11,151 0 0 11,151 01.02.05.08.07 Containers. 11,151 0 0 11,151 01.02.05.09 Management of decommissioning low-level waste. 129,027 0 2,262 131,289 01.02.05.09.02 Processing. 24,780 0 0 24,780 01.02.05.09.05 Transport. 6,985 0 325 7,309 01.02.05.09.06 Disposal. 81,449 0 1,581 83,030 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 24 of 27

Cost By Cost Element By WBS License Spent Fuel Site Restoration Total Termination WBS Activities 01.02.05.09.07 Containers. 15,813 0 356 16,169 01.02.05.12 Management of decommissioning exempt waste and materials. 68,268 0 8,644 76,912 01.02.05.12.01 Treatment and packaging. 3,094 0 402 3,496 01.02.05.12.03 Transport of hazardous waste. 27,929 0 2,429 30,358 01.02.05.12.04 Disposal of hazardous waste at dedicated waste dumps. 37,246 0 5,813 43,059 01.02.05.13 Management of decommissioning waste and materials generated outside controlled areas. 7,434 0 0 7,434 01.02.05.13.02 Treatment and packaging of hazardous waste. 7,434 0 0 7,434 01.02.06 Site infrastructure and operation 55,615 2,444 13 58,072 01.02.06.01 Site security and surveillance. 34,881 0 0 34,881 01.02.06.01.01 Procurement of general security equipment. 4,847 0 0 4,847 01.02.06.01.04 Deployment of guards/security forces. 30,034 0 0 30,034 01.02.06.02 Site operation and maintenance. 4,235 2,444 13 6,693 01.02.06.02.01 Inspection and maintenance of buildings and systems. 3,320 2,444 13 5,778 01.02.06.02.02 Site upkeep activities. 915 0 0 915 01.02.06.03 Operation of support systems. 14,171 0 0 14,171 01.02.06.03.01 Electricity supply systems. 9,992 0 0 9,992 01.02.06.03.02 Ventilation systems. 2,821 0 0 2,821 01.02.06.03.07 Other systems. 1,358 0 0 1,358 01.02.06.04 Radiation and environmental safety monitoring. 2,328 0 0 2,328 01.02.06.04.01 Procurement and maintenance of equipment for radiation protection and environmental monitoring. 1,394 0 0 1,394 01.02.06.04.02 Radiation protection and monitoring. 934 0 0 934 01.02.07 Conventional dismantling, demolition and site restoration 95,677 0 22,709 118,386 01.02.07.03 Demolition of buildings and structures. 73,748 0 22,709 96,456 01.02.07.03.01 Demolition of buildings and structures from the formerly controlled area. 73,748 0 17,753 91,500 01.02.07.03.02 Demolition of buildings and structures outside the controlled area. 0 0 4,956 4,956 01.02.07.05 Final radioactivity survey of site. 21,930 0 0 21,930 01.02.07.05.01 Final survey. 21,930 0 0 21,930 01.02.08 Project management, engineering and support 105,593 3,271 2 108,866 01.02.08.02 Project management. 41,185 3,271 2 44,458 01.02.08.02.01 Core management group. 26,383 3,271 2 29,656 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 1,457 0 0 1,457 01.02.08.02.03 Scheduling and cost control. 1,551 0 0 1,551 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 5,969 0 0 5,969 01.02.08.02.05 Quality assurance and quality surveillance. 2,408 0 0 2,408 01.02.08.02.06 General administration and accounting. 2,110 0 0 2,110 01.02.08.02.07 Public relations and stakeholders involvement. 1,308 0 0 1,308 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 25 of 27

Cost By Cost Element By WBS License Spent Fuel Site Restoration Total Termination WBS Activities 01.02.08.03 Support services. 51,480 0 0 51,480 01.02.08.03.01 Engineering support. 19,907 0 0 19,907 01.02.08.03.02 Information system and computer support. 4,438 0 0 4,438 01.02.08.03.03 Waste management support. 4,847 0 0 4,847 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 824 0 0 824 01.02.08.03.05 Personnel management and training. 2,085 0 0 2,085 01.02.08.03.06 Documentation and records control. 10 0 0 10 01.02.08.03.07 Procurement, warehousing, and materials handling. 4,068 0 0 4,068 01.02.08.03.08 Housing, office equipment, support services. 15,302 0 0 15,302 01.02.08.04 Health and safety. 10,942 0 0 10,942 01.02.08.04.01 Health physics. 7,759 0 0 7,759 01.02.08.04.02 Industrial safety. 3,182 0 0 3,182 01.02.08.08 Support services by contractors (if needed). 1,986 0 0 1,986 01.02.08.08.02 Information system and computer support. 1,986 0 0 1,986 01.02.10 Fuel and nuclear material 8,443 181,904 2,685 193,032 01.02.10.01 Removal of fuel or nuclear material from facility to be decommissioned. 0 108,542 0 108,542 01.02.10.01.02 Transfer of fuel or nuclear material to dedicated ISFSI. 0 108,542 0 108,542 01.02.10.02 Dedicated ISFSI for fuel and/or nuclear material. 4,030 73,361 0 77,391 01.02.10.02.02 Operation of ISFSI. 0 25,869 0 25,869 01.02.10.02.03 Transfer of fuel and/or nuclear material away from the ISFSI. 4,030 47,492 0 51,522 01.02.10.03 Decommissioning of ISFSI. 4,413 0 2,685 7,098 01.02.10.03.01 Decommissioning of ISFSI. 4,413 0 0 4,413 01.02.10.03.02 Management of waste. 0 0 2,685 2,685 01.02.11 Miscellaneous expenditures 39,550 7,400 411 47,362 01.02.11.01 Owner costs. 8,797 2,384 213 11,394 01.02.11.01.01 Implementation of transition plans. 5,647 2,384 213 8,243 01.02.11.01.03 Payments (fees) to authorities. 3,151 0 0 3,151 01.02.11.02 Taxes. 22,656 0 0 22,656 01.02.11.02.02 Local, community, federal taxes. 22,656 0 0 22,656 01.02.11.03 Insurances. 8,097 5,017 198 13,312 01.02.11.03.01 Nuclear related insurances. 8,097 5,017 198 13,312 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 26 of 27

HOLTEC I NTERNATIONAL ATTACHMENT 6 Decommissioning Activities and Cost by Period

Table 3-1 Decommissioning Activities and Costs by Period Period: Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Pre- decommissioning Program Plant Safe Storage Ongoing ISFSI Activities Planning & Dismantlement Management Total Deactivation Operations Operations Preparation Costs License Termination 12,342,710 7,888,168 343,965,569 428,543,173 8,442,802 200,757,630 1,001,940,052 Pre-decommissioning actions 12,342,710 0 0 0 0 0 12,342,710 Facility characterization. 8,920,800 0 0 0 0 0 8,920,800 Detailed facility characterization. 8,920,800 0 0 0 0 0 8,920,800 Authorisation. 3,409,558 0 0 0 0 0 3,409,558 License applications and license approvals. 3,409,558 0 0 0 0 0 3,409,558 Preparing management group and contracting. 12,352 0 0 0 0 0 12,352 Management team activities. 12,352 0 0 0 0 0 12,352 Facility shutdown activities 0 7,888,168 0 0 0 0 7,888,168 Plant shutdown and inspection. 0 7,888,168 0 0 0 0 7,888,168 Cooling down of spent fuel. 0 7,888,168 0 0 0 0 7,888,168 Additional activities for safe enclosure or entombment 0 0 343,965,569 0 0 0 343,965,569 Preparation for safe enclosure. 0 0 4,185,870 0 0 0 4,185,870 Preparation for SAFSTOR 0 0 4,185,870 0 0 0 4,185,870 Site boundary reconfiguration, isolating and securing structures. 0 0 339,779,699 0 0 0 339,779,699 SAFSTOR Operations & Maintenance 0 0 339,779,699 0 0 0 339,779,699 Dismantling activities within the controlled area 0 0 0 108,493,247 0 0 108,493,247 Procurement of equipment for decontamination and dismantling. 0 0 0 7,805,700 0 0 7,805,700 Procurement of special tools for dismantling the reactor systems. 0 0 0 7,805,700 0 0 7,805,700 Removal of materials requiring specific procedures. 0 0 0 8,109,818 0 0 8,109,818 Removal of asbestos. 0 0 0 8,109,818 0 0 8,109,818 Dismantling of main process systems, structures and components. 0 0 0 90,147,855 0 0 90,147,855 Dismantling of reactor internals. 0 0 0 56,374,500 0 0 56,374,500 Dismantling of reactor vessel and core components. 0 0 0 3,490,739 0 0 3,490,739 Dismantling of other primary loop components. 0 0 0 30,282,616 0 0 30,282,616 Dismantling of other systems and components. 0 0 0 2,429,873 0 0 2,429,873 Dismantling of remaining components. 0 0 0 2,429,873 0 0 2,429,873 Waste processing, storage and disposal 0 0 0 224,372,791 0 0 224,372,791 Waste management system. 0 0 0 8,492,402 0 0 8,492,402 Maintenance, surveillance and operational support for waste management system. 0 0 0 8,492,402 0 0 8,492,402 Management of decommissioning intermediate-level waste. 0 0 0 11,151,000 0 0 11,151,000 Containers. 0 0 0 11,151,000 0 0 11,151,000 Management of decommissioning low-level waste. 0 0 0 129,026,919 0 0 129,026,919 Processing. 0 0 0 24,780,000 0 0 24,780,000 Transport. 0 0 0 6,984,784 0 0 6,984,784 Disposal. 0 0 0 81,449,397 0 0 81,449,397 Containers. 0 0 0 15,812,738 0 0 15,812,738 Management of decommissioning exempt waste and materials. 0 0 0 68,268,469 0 0 68,268,469 Treatment and packaging. 0 0 0 3,093,812 0 0 3,093,812 Transport of hazardous waste. 0 0 0 27,928,901 0 0 27,928,901 Disposal of hazardous waste at dedicated waste dumps. 0 0 0 37,245,757 0 0 37,245,757 Management of decommissioning waste and materials generated outside controlled areas. 0 0 0 7,434,000 0 0 7,434,000 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 6 of 27

Period: Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Pre- decommissioning Program Plant Safe Storage Ongoing ISFSI Activities Planning & Dismantlement Management Total Deactivation Operations Operations Preparation Costs Treatment and packaging of hazardous waste. 0 0 0 7,434,000 0 0 7,434,000 Site infrastructure and operation 0 0 0 0 0 55,614,825 55,614,825 Site security and surveillance. 0 0 0 0 0 34,881,429 34,881,429 Procurement of general security equipment. 0 0 0 0 0 4,847,395 4,847,395 Deployment of guards/security forces. 0 0 0 0 0 30,034,034 30,034,034 Site operation and maintenance. 0 0 0 0 0 4,235,279 4,235,279 Inspection and maintenance of buildings and systems. 0 0 0 0 0 3,320,118 3,320,118 Site upkeep activities. 0 0 0 0 0 915,160 915,160 Operation of support systems. 0 0 0 0 0 14,170,540 14,170,540 Electricity supply systems. 0 0 0 0 0 9,992,010 9,992,010 Ventilation systems. 0 0 0 0 0 2,820,585 2,820,585 Other systems. 0 0 0 0 0 1,357,946 1,357,946 Radiation and environmental safety monitoring. 0 0 0 0 0 2,327,577 2,327,577 Procurement and maintenance of equipment for radiation protection and environmental monitoring. 0 0 0 0 0 1,394,046 1,394,046 Radiation protection and monitoring. 0 0 0 0 0 933,531 933,531 Conventional dismantling, demolition and site restoration 0 0 0 95,677,136 0 0 95,677,136 Demolition of buildings and structures. 0 0 0 73,747,531 0 0 73,747,531 Demolition of buildings and structures from the formerly controlled area. 0 0 0 73,747,531 0 0 73,747,531 Final radioactivity survey of site. 0 0 0 21,929,605 0 0 21,929,605 Final survey. 0 0 0 21,929,605 0 0 21,929,605 Project management, engineering and support 0 0 0 0 0 105,592,581 105,592,581 Project management. 0 0 0 0 0 41,184,750 41,184,750 Core management group. 0 0 0 0 0 26,382,888 26,382,888 Project implementation planning, detailed ongoing planning. 0 0 0 0 0 1,456,806 1,456,806 Scheduling and cost control. 0 0 0 0 0 1,550,800 1,550,800 Safety and environmental analysis, ongoing studies. 0 0 0 0 0 5,968,511 5,968,511 Quality assurance and quality surveillance. 0 0 0 0 0 2,407,952 2,407,952 General administration and accounting. 0 0 0 0 0 2,109,640 2,109,640 Public relations and stakeholders involvement. 0 0 0 0 0 1,308,151 1,308,151 Support services. 0 0 0 0 0 51,479,943 51,479,943 Engineering support. 0 0 0 0 0 19,906,775 19,906,775 Information system and computer support. 0 0 0 0 0 4,438,039 4,438,039 Waste management support. 0 0 0 0 0 4,847,030 4,847,030 Decommissioning support including chemistry, decontamination. 0 0 0 0 0 823,616 823,616 Personnel management and training. 0 0 0 0 0 2,084,501 2,084,501 Documentation and records control. 0 0 0 0 0 9,845 9,845 Procurement, warehousing, and materials handling. 0 0 0 0 0 4,068,481 4,068,481 Housing, office equipment, support services. 0 0 0 0 0 15,301,654 15,301,654 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 7 of 27

Period: Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Pre- decommissioning Program Plant Safe Storage Ongoing ISFSI Activities Planning & Dismantlement Management Total Deactivation Operations Operations Preparation Costs Health and safety. 0 0 0 0 0 10,941,807 10,941,807 Health physics. 0 0 0 0 0 7,759,413 7,759,413 Industrial safety. 0 0 0 0 0 3,182,394 3,182,394 Support services by contractors (if needed). 0 0 0 0 0 1,986,080 1,986,080 Information system and computer support. 0 0 0 0 0 1,986,080 1,986,080 Fuel and nuclear material 0 0 0 0 8,442,802 0 8,442,802 Dedicated ISFSI for fuel and/or nuclear material. 0 0 0 0 4,029,724 0 4,029,724 Transfer of fuel and/or nuclear material away from the ISFSI. 0 0 0 0 4,029,724 0 4,029,724 Decommissioning of ISFSI. 0 0 0 0 4,413,078 0 4,413,078 Decommissioning of ISFSI. 0 0 0 0 4,413,078 0 4,413,078 Miscellaneous expenditures 0 0 0 0 0 39,550,224 39,550,224 Owner costs. 0 0 0 0 0 8,797,347 8,797,347 Implementation of transition plans. 0 0 0 0 0 5,646,699 5,646,699 Payments (fees) to authorities. 0 0 0 0 0 3,150,648 3,150,648 Taxes. 0 0 0 0 0 22,656,000 22,656,000 Local, community, federal taxes. 0 0 0 0 0 22,656,000 22,656,000 Insurances. 0 0 0 0 0 8,096,877 8,096,877 Nuclear related insurances. 0 0 0 0 0 8,096,877 8,096,877 Spent Fuel 4,044,898 6,698,838 349,935,015 0 73,361,366 13,115,354 447,155,471 Pre-decommissioning actions 4,044,898 0 0 0 0 0 4,044,898 Safety, security and environmental studies. 4,044,898 0 0 0 0 0 4,044,898 Safety, security and emergency planning for site operations. 4,044,898 0 0 0 0 0 4,044,898 Facility shutdown activities 0 6,698,838 0 0 0 0 6,698,838 Plant shutdown and inspection. 0 6,698,838 0 0 0 0 6,698,838 Cooling down of spent fuel. 0 6,698,838 0 0 0 0 6,698,838 Additional activities for safe enclosure or entombment 0 0 241,392,527 0 0 0 241,392,527 Site boundary reconfiguration, isolating and securing structures. 0 0 241,392,527 0 0 0 241,392,527 SAFSTOR Operations & Maintenance 0 0 241,392,527 0 0 0 241,392,527 Site infrastructure and operation 0 0 0 0 0 2,444,245 2,444,245 Site operation and maintenance. 0 0 0 0 0 2,444,245 2,444,245 Inspection and maintenance of buildings and systems. 0 0 0 0 0 2,444,245 2,444,245 Project management, engineering and support 0 0 0 0 0 3,270,680 3,270,680 Project management. 0 0 0 0 0 3,270,680 3,270,680 Core management group. 0 0 0 0 0 3,270,680 3,270,680 Fuel and nuclear material 0 0 108,542,488 0 73,361,366 0 181,903,854 Removal of fuel or nuclear material from facility to be decommissioned. 0 0 108,542,488 0 0 0 108,542,488 Transfer of fuel or nuclear material to dedicated ISFSI. 0 0 108,542,488 0 0 0 108,542,488 Dedicated ISFSI for fuel and/or nuclear material. 0 0 0 0 73,361,366 0 73,361,366 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 8 of 27

Period: Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Pre- decommissioning Program Plant Safe Storage Ongoing ISFSI Activities Planning & Dismantlement Management Total Deactivation Operations Operations Preparation Costs Operation of ISFSI. 0 0 0 0 25,869,498 0 25,869,498 Transfer of fuel and/or nuclear material away from the ISFSI. 0 0 0 0 47,491,868 0 47,491,868 Miscellaneous expenditures 0 0 0 0 0 7,400,429 7,400,429 Owner costs. 0 0 0 0 0 2,383,608 2,383,608 Implementation of transition plans. 0 0 0 0 0 2,383,608 2,383,608 Insurances. 0 0 0 0 0 5,016,820 5,016,820 Nuclear related insurances. 0 0 0 0 0 5,016,820 5,016,820 Site Restoration 0 39,662 451,258 33,614,112 2,685,388 426,542 37,216,961 Facility shutdown activities 0 39,662 0 0 0 0 39,662 Plant shutdown and inspection. 0 39,662 0 0 0 0 39,662 Cooling down of spent fuel. 0 39,662 0 0 0 0 39,662 Additional activities for safe enclosure or entombment 0 0 451,258 0 0 0 451,258 Site boundary reconfiguration, isolating and securing structures. 0 0 451,258 0 0 0 451,258 Modification of auxiliary systems. 0 0 451,258 0 0 0 451,258 Waste processing, storage and disposal 0 0 0 10,905,492 0 0 10,905,492 Management of decommissioning low-level waste. 0 0 0 2,261,950 0 0 2,261,950 Transport. 0 0 0 324,665 0 0 324,665 Disposal. 0 0 0 1,581,072 0 0 1,581,072 Containers. 0 0 0 356,213 0 0 356,213 Management of decommissioning exempt waste and materials. 0 0 0 8,643,542 0 0 8,643,542 Treatment and packaging. 0 0 0 402,021 0 0 402,021 Transport of hazardous waste. 0 0 0 2,428,600 0 0 2,428,600 Disposal of hazardous waste at dedicated waste dumps. 0 0 0 5,812,922 0 0 5,812,922 Site infrastructure and operation 0 0 0 0 0 13,273 13,273 Site operation and maintenance. 0 0 0 0 0 13,273 13,273 Inspection and maintenance of buildings and systems. 0 0 0 0 0 13,273 13,273 Conventional dismantling, demolition and site restoration 0 0 0 22,708,619 0 0 22,708,619 Demolition of buildings and structures. 0 0 0 22,708,619 0 0 22,708,619 Demolition of buildings and structures from the formerly controlled area. 0 0 0 17,752,619 0 0 17,752,619 Demolition of buildings and structures outside the controlled area. 0 0 0 4,956,000 0 0 4,956,000 Project management, engineering and support 0 0 0 0 0 2,251 2,251 Project management. 0 0 0 0 0 2,251 2,251 Core management group. 0 0 0 0 0 2,251 2,251 Fuel and nuclear material 0 0 0 0 2,685,388 0 2,685,388 Decommissioning of ISFSI. 0 0 0 0 2,685,388 0 2,685,388 Management of waste. 0 0 0 0 2,685,388 0 2,685,388 Miscellaneous expenditures 0 0 0 0 0 411,018 411,018 Owner costs. 0 0 0 0 0 212,936 212,936 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 9 of 27

Period: Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Pre- decommissioning Program Plant Safe Storage Ongoing ISFSI Activities Planning & Dismantlement Management Total Deactivation Operations Operations Preparation Costs Implementation of transition plans. 0 0 0 0 0 212,936 212,936 Insurances. 0 0 0 0 0 198,082 198,082 Nuclear related insurances. 0 0 0 0 0 198,082 198,082 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 10 of 27

HOLTEC INTE RN A T I O N AL ATTACHMENT 7 Labor Cost and Requirements by Year

Labor Costs and Requirements by Year (thousands of 2022 dollars)

Labor (FTEs) and Labor Costs Labor Category 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 Management Labor Cost 1,237 6,213 6,128 5,636 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 Management Labor FTEs 4 23 23 21 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 Professional Labor Cost 5,147 26,434 22,175 19,594 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 Professional Labor FTEs 26 144 123 110 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 Craft Labor Cost 1,939 11,866 9,920 8,672 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 Craft Labor FTEs 9 55 47 41 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Total Labor Cost 8,323 44,514 38,223 33,902 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 Total Labor FTEs 39 222 192 172 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 Labor (FTEs) and Labor Costs Labor Category 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 2068 2069 Management Labor Cost 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 544 249 249 249 Management Labor FTEs 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1 1 1 Professional Labor Cost 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 6,819 1,816 1,816 1,816 Professional Labor FTEs 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 10 10 10 Craft Labor Cost 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 Craft Labor FTEs 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Total Labor Cost 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 9,437 4,139 4,139 4,139 Total Labor FTEs 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 51 21 21 21 Labor (FTEs) and Labor Costs Labor Category 2070 2071 2072 2073 2074 2075 2076 2077 2078 2079 2080 2081 2082 2083 2084 2085 2086 2087 2088 Total Management Labor Cost 249 249 249 249 249 249 249 249 540 4,032 4,089 4,089 4,089 4,089 4,089 3,563 874 510 72,034 Management Labor FTEs 1 1 1 1 1 1 1 1 2 15 16 16 16 16 16 14 3 2 277 Professional Labor Cost 1,816 1,816 1,816 1,816 1,816 1,816 1,816 1,816 2,035 4,435 4,435 4,435 4,435 4,435 4,435 4,790 0 0 379,089 Professional Labor FTEs 10 10 10 10 10 10 10 10 11 22 22 22 22 22 22 24 0 0 2,129 Craft Labor Cost 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,074 2,155 3,047 3,047 3,047 3,047 3,047 3,047 2,726 184 107 155,393 Craft Labor FTEs 10 10 10 10 10 10 10 10 10 15 15 15 15 15 15 13 1 1 748 Total Labor Cost 4,139 4,139 4,139 4,139 4,139 4,139 4,139 4,139 4,730 11,514 11,572 11,572 11,572 11,572 11,572 11,079 1,057 617 0 0 0 606,516 Total Labor FTEs 21 21 21 21 21 21 21 21 24 52 52 52 52 52 52 51 4 3 0 0 0 3,154 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 17 of 27

Labor Costs and Requirements by Year (thousands of 2022 dollars)

Labor (FTEs) and Labor Costs Period 1 Period 2 Period 3 Period 4 Period 5 Program Management Total Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost PWR DECON Decommissioning Crews 0 0 61 14,627 511 106,699 129 24,678 0 0 46 9,390 748 155,393 Management / Support Staff 13 2,892 0 0 1,676 299,530 3 937 173 26,396 541 121,367 2,406 451,123 Total 13 2,892 61 14,627 2,187 406,229 132 25,615 173 26,396 588 130,758 3,154 606,516 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 18 of 27

HOLTEC INTERNATIONA L ATTACHMENT 8 Labor Staffing Curve by Y ea1*

HOLTEC INTER A T IO AL Labor Staffing Curve by Year 420 400 380 360 340 320 300 280 260 240 220 Total Labor FTEs Management Labor FTEs 200 Professional Labor FTEs 180 Craft Labor FTEs 160 Security Labor FTEs 140 120 100 80 60 40 20 0

HOLTEC I NT ER NA T l ON A L ATTACHMENT 9 Program Management Cost Detail

Table 3-2 Program Management Cost Detail WBS_Code Activities 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 01.02.03 Additional activities for safe enclosure or entombment 0 0 0 2,355,717 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 0 0 0 2,355,717 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.03.02.01 SAFSTOR Operations & Maintenance 0 0 0 2,355,717 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.06 Site infrastructure and operation 4,006,564 14,899,617 12,505,938 10,732,375 0 0 0 0 0 0 0 0 0 0 01.02.06.01 Site security and surveillance. 1,755,866 9,642,545 7,684,789 6,446,186 0 0 0 0 0 0 0 0 0 0 01.02.06.01.01 Procurement of general security equipment. 94,876 1,138,517 913,091 768,120 0 0 0 0 0 0 0 0 0 0 01.02.06.01.04 Deployment of guards/security forces. 1,660,989 8,504,028 6,771,698 5,678,067 0 0 0 0 0 0 0 0 0 0 01.02.06.02 Site operation and maintenance. 1,353,756 1,909,700 1,596,177 1,367,364 0 0 0 0 0 0 0 0 0 0 01.02.06.02.01 Inspection and maintenance of buildings and systems. 1,342,796 1,822,020 1,426,297 1,186,524 0 0 0 0 0 0 0 0 0 0 01.02.06.02.02 Site upkeep activities. 10,960 87,680 169,880 180,840 0 0 0 0 0 0 0 0 0 0 01.02.06.03 Operation of support systems. 507,033 2,683,029 2,560,629 2,309,844 0 0 0 0 0 0 0 0 0 0 01.02.06.03.01 Electricity supply systems. 221,426 1,231,975 1,262,268 1,166,335 0 0 0 0 0 0 0 0 0 0 01.02.06.03.02 Ventilation systems. 190,867 1,017,955 865,262 746,501 0 0 0 0 0 0 0 0 0 0 01.02.06.03.07 Other systems. 94,740 433,099 433,099 397,007 0 0 0 0 0 0 0 0 0 0 01.02.06.04 Radiation and environmental safety monitoring. 389,909 664,343 664,343 608,981 0 0 0 0 0 0 0 0 0 0 Procurement and maintenance of equipment for radiation protection and environmental 01.02.06.04.01 38,723 464,682 464,682 425,958 0 0 0 0 0 0 0 0 0 0 monitoring.

01.02.06.04.02 Radiation protection and monitoring. 351,186 199,661 199,661 183,023 0 0 0 0 0 0 0 0 0 0 01.02.08 Project management, engineering and support 2,932,215 18,343,264 16,400,241 14,439,853 0 0 0 0 0 0 0 0 0 0 01.02.08.02 Project management. 1,191,188 6,383,468 6,159,776 5,578,111 0 0 0 0 0 0 0 0 0 0 01.02.08.02.01 Core management group. 796,403 3,461,443 3,461,443 3,172,989 0 0 0 0 0 0 0 0 0 0 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 149,909 553,509 415,132 338,256 0 0 0 0 0 0 0 0 0 0 01.02.08.02.03 Scheduling and cost control. 14,864 237,822 237,822 218,004 0 0 0 0 0 0 0 0 0 0 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 112,327 1,347,928 1,347,928 1,235,601 0 0 0 0 0 0 0 0 0 0 01.02.08.02.05 Quality assurance and quality surveillance. 29,728 237,822 237,822 218,004 0 0 0 0 0 0 0 0 0 0 01.02.08.02.06 General administration and accounting. 59,520 317,438 317,438 290,985 0 0 0 0 0 0 0 0 0 0 01.02.08.02.07 Public relations and stakeholders involvement. 28,438 227,505 142,190 104,273 0 0 0 0 0 0 0 0 0 0 01.02.08.03 Support services. 1,368,628 9,927,661 8,720,663 7,625,136 0 0 0 0 0 0 0 0 0 0 01.02.08.03.01 Engineering support. 542,461 3,232,995 2,618,833 2,212,937 0 0 0 0 0 0 0 0 0 0 01.02.08.03.02 Information system and computer support. 74,105 988,061 395,224 181,144 0 0 0 0 0 0 0 0 0 0 01.02.08.03.03 Waste management support. 43,499 439,788 439,788 403,139 0 0 0 0 0 0 0 0 0 0 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 79,705 255,055 255,055 233,801 0 0 0 0 0 0 0 0 0 0 01.02.08.03.05 Personnel management and training. 237,475 633,266 633,266 580,494 0 0 0 0 0 0 0 0 0 0 01.02.08.03.06 Documentation and records control. 9,845 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.07 Procurement, warehousing, and materials handling. 60,381 524,600 524,600 480,883 0 0 0 0 0 0 0 0 0 0 01.02.08.03.08 Housing, office equipment, support services. 321,158 3,853,896 3,853,896 3,532,738 0 0 0 0 0 0 0 0 0 0 01.02.08.04 Health and safety. 315,473 1,349,025 1,349,025 1,236,606 0 0 0 0 0 0 0 0 0 0 01.02.08.04.01 Health physics. 130,748 789,172 789,172 723,408 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety. 184,725 559,853 559,853 513,198 0 0 0 0 0 0 0 0 0 0 01.02.08.08 Support services by contractors (if needed). 56,926 683,110 170,778 0 0 0 0 0 0 0 0 0 0 0 01.02.08.08.02 Information system and computer support. 56,926 683,110 170,778 0 0 0 0 0 0 0 0 0 0 0 01.02.11 Miscellaneous expenditures 1,408,528 16,902,336 11,585,994 8,996,056 0 0 0 0 0 0 0 0 0 0 01.02.11.01 Owner costs. 246,025 2,952,299 2,627,821 2,309,690 0 0 0 0 0 0 0 0 0 0 01.02.11.01.01 Implementation of transition plans. 158,507 1,902,083 1,577,605 1,346,992 0 0 0 0 0 0 0 0 0 0 01.02.11.01.03 Payments (fees) to authorities. 87,518 1,050,216 1,050,216 962,698 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes. 836,633 10,039,590 5,585,024 3,758,488 0 0 0 0 0 0 0 0 0 0 01.02.11.02.02 Local, community, federal taxes. 836,633 10,039,590 5,585,024 3,758,488 0 0 0 0 0 0 0 0 0 0 01.02.11.03 Insurances. 325,871 3,910,448 3,373,149 2,927,878 0 0 0 0 0 0 0 0 0 0 01.02.11.03.01 Nuclear related insurances. 325,871 3,910,448 3,373,149 2,927,878 0 0 0 0 0 0 0 0 0 0 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 11 of 27

Table 3-2 Program Management Cost Detail WBS_Code Activities 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 01.02.03 Additional activities for safe enclosure or entombment 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.03.02.01 SAFSTOR Operations & Maintenance 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 01.02.06 Site infrastructure and operation 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01 Site security and surveillance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01.01 Procurement of general security equipment. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01.04 Deployment of guards/security forces. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02 Site operation and maintenance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02.01 Inspection and maintenance of buildings and systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02.02 Site upkeep activities. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03 Operation of support systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.01 Electricity supply systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.02 Ventilation systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.07 Other systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.04 Radiation and environmental safety monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Procurement and maintenance of equipment for radiation protection and environmental 01.02.06.04.01 0 0 0 0 0 0 0 0 0 0 0 0 0 0 monitoring.

01.02.06.04.02 Radiation protection and monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08 Project management, engineering and support 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02 Project management. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.01 Core management group. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.03 Scheduling and cost control. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.05 Quality assurance and quality surveillance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.06 General administration and accounting. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.07 Public relations and stakeholders involvement. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03 Support services. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.01 Engineering support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.03 Waste management support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.05 Personnel management and training. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.06 Documentation and records control. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.07 Procurement, warehousing, and materials handling. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.08 Housing, office equipment, support services. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04 Health and safety. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.01 Health physics. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.08 Support services by contractors (if needed). 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.08.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11 Miscellaneous expenditures 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01 Owner costs. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01.01 Implementation of transition plans. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01.03 Payments (fees) to authorities. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02.02 Local, community, federal taxes. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.03 Insurances. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.03.01 Nuclear related insurances. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 12 of 27

Table 3-2 Program Management Cost Detail WBS_Code Activities 2054 2055 2056 2057 2058 2059 2060 2061 2062 2063 2064 2065 2066 2067 01.02.03 Additional activities for safe enclosure or entombment 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 6,139,586 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 6,139,586 01.02.03.02.01 SAFSTOR Operations & Maintenance 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 13,490,654 6,139,586 01.02.06 Site infrastructure and operation 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01 Site security and surveillance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01.01 Procurement of general security equipment. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.01.04 Deployment of guards/security forces. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02 Site operation and maintenance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02.01 Inspection and maintenance of buildings and systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02.02 Site upkeep activities. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03 Operation of support systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.01 Electricity supply systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.02 Ventilation systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.07 Other systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.04 Radiation and environmental safety monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Procurement and maintenance of equipment for radiation protection and environmental 01.02.06.04.01 0 0 0 0 0 0 0 0 0 0 0 0 0 0 monitoring.

01.02.06.04.02 Radiation protection and monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08 Project management, engineering and support 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02 Project management. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.01 Core management group. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.03 Scheduling and cost control. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.05 Quality assurance and quality surveillance. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.06 General administration and accounting. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.07 Public relations and stakeholders involvement. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03 Support services. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.01 Engineering support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.03 Waste management support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.05 Personnel management and training. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.06 Documentation and records control. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.07 Procurement, warehousing, and materials handling. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.08 Housing, office equipment, support services. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04 Health and safety. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.01 Health physics. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.08 Support services by contractors (if needed). 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.08.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11 Miscellaneous expenditures 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01 Owner costs. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01.01 Implementation of transition plans. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.01.03 Payments (fees) to authorities. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02.02 Local, community, federal taxes. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.03 Insurances. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.03.01 Nuclear related insurances. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 13 of 27

Table 3-2 Program Management Cost Detail WBS_Code Activities 2068 2069 2070 2071 2072 2073 2074 2075 2076 2077 2078 2079 2080 2081 01.02.03 Additional activities for safe enclosure or entombment 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 5,709,720 981,200 981,200 981,200 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 5,709,720 981,200 981,200 981,200 01.02.03.02.01 SAFSTOR Operations & Maintenance 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 6,139,586 5,709,720 981,200 981,200 981,200 01.02.06 Site infrastructure and operation 0 0 0 0 0 0 0 0 0 0 187,386 2,248,637 2,248,637 2,248,637 01.02.06.01 Site security and surveillance. 0 0 0 0 0 0 0 0 0 0 110,024 1,320,288 1,320,288 1,320,288 01.02.06.01.01 Procurement of general security equipment. 0 0 0 0 0 0 0 0 0 0 22,739 272,865 272,865 272,865 01.02.06.01.04 Deployment of guards/security forces. 0 0 0 0 0 0 0 0 0 0 87,285 1,047,424 1,047,424 1,047,424 01.02.06.02 Site operation and maintenance. 0 0 0 0 0 0 0 0 0 0 5,480 65,760 65,760 65,760 01.02.06.02.01 Inspection and maintenance of buildings and systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.02.02 Site upkeep activities. 0 0 0 0 0 0 0 0 0 0 5,480 65,760 65,760 65,760 01.02.06.03 Operation of support systems. 0 0 0 0 0 0 0 0 0 0 71,882 862,589 862,589 862,589 01.02.06.03.01 Electricity supply systems. 0 0 0 0 0 0 0 0 0 0 71,882 862,589 862,589 862,589 01.02.06.03.02 Ventilation systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.03.07 Other systems. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.06.04 Radiation and environmental safety monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Procurement and maintenance of equipment for radiation protection and environmental 01.02.06.04.01 0 0 0 0 0 0 0 0 0 0 0 0 0 0 monitoring.

01.02.06.04.02 Radiation protection and monitoring. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08 Project management, engineering and support 0 0 0 0 0 0 0 0 0 0 590,796 7,379,211 7,437,142 7,437,142 01.02.08.02 Project management. 0 0 0 0 0 0 0 0 0 0 262,171 3,435,710 3,493,641 3,493,641 01.02.08.02.01 Core management group. 0 0 0 0 0 0 0 0 0 0 187,094 2,534,779 2,592,710 2,592,710 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.03 Scheduling and cost control. 0 0 0 0 0 0 0 0 0 0 9,909 118,911 118,911 118,911 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 0 0 0 0 0 0 0 0 0 0 22,644 271,726 271,726 271,726 01.02.08.02.05 Quality assurance and quality surveillance. 0 0 0 0 0 0 0 0 0 0 19,819 237,822 237,822 237,822 01.02.08.02.06 General administration and accounting. 0 0 0 0 0 0 0 0 0 0 13,227 158,719 158,719 158,719 01.02.08.02.07 Public relations and stakeholders involvement. 0 0 0 0 0 0 0 0 0 0 9,479 113,752 113,752 113,752 01.02.08.03 Support services. 0 0 0 0 0 0 0 0 0 0 234,154 2,809,853 2,809,853 2,809,853 01.02.08.03.01 Engineering support. 0 0 0 0 0 0 0 0 0 0 132,936 1,595,231 1,595,231 1,595,231 01.02.08.03.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 32,935 395,224 395,224 395,224 01.02.08.03.03 Waste management support. 0 0 0 0 0 0 0 0 0 0 36,649 439,788 439,788 439,788 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.05 Personnel management and training. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.06 Documentation and records control. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.07 Procurement, warehousing, and materials handling. 0 0 0 0 0 0 0 0 0 0 28,472 341,659 341,659 341,659 01.02.08.03.08 Housing, office equipment, support services. 0 0 0 0 0 0 0 0 0 0 3,163 37,951 37,951 37,951 01.02.08.04 Health and safety. 0 0 0 0 0 0 0 0 0 0 81,820 981,845 981,845 981,845 01.02.08.04.01 Health physics. 0 0 0 0 0 0 0 0 0 0 65,764 789,172 789,172 789,172 01.02.08.04.02 Industrial safety. 0 0 0 0 0 0 0 0 0 0 16,056 192,673 192,673 192,673 01.02.08.08 Support services by contractors (if needed). 0 0 0 0 0 0 0 0 0 0 12,650 151,802 151,802 151,802 01.02.08.08.02 Information system and computer support. 0 0 0 0 0 0 0 0 0 0 12,650 151,802 151,802 151,802 01.02.11 Miscellaneous expenditures 0 0 0 0 0 0 0 0 0 0 94,396 1,132,753 1,132,753 1,132,753 01.02.11.01 Owner costs. 0 0 0 0 0 0 0 0 0 0 38,330 459,961 459,961 459,961 01.02.11.01.01 Implementation of transition plans. 0 0 0 0 0 0 0 0 0 0 38,330 459,961 459,961 459,961 01.02.11.01.03 Payments (fees) to authorities. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes. 0 0 0 0 0 0 0 0 0 0 23,426 281,107 281,107 281,107 01.02.11.02.02 Local, community, federal taxes. 0 0 0 0 0 0 0 0 0 0 23,426 281,107 281,107 281,107 01.02.11.03 Insurances. 0 0 0 0 0 0 0 0 0 0 32,640 391,685 391,685 391,685 01.02.11.03.01 Nuclear related insurances. 0 0 0 0 0 0 0 0 0 0 32,640 391,685 391,685 391,685 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 14 of 27

Table 3-2 Program Management Cost Detail WBS_Code Activities 2082 2083 2084 2085 2086 2087 Total 01.02.03 Additional activities for safe enclosure or entombment 981,200 981,200 981,200 981,200 0 0 581,623,484 01.02.03.02 Site boundary reconfiguration, isolating and securing structures. 981,200 981,200 981,200 981,200 0 0 581,623,484 01.02.03.02.01 SAFSTOR Operations & Maintenance 981,200 981,200 981,200 981,200 0 0 581,623,484 01.02.06 Site infrastructure and operation 2,248,637 2,248,637 2,248,637 2,248,637 0 0 58,072,343 01.02.06.01 Site security and surveillance. 1,320,288 1,320,288 1,320,288 1,320,288 0 0 34,881,429 01.02.06.01.01 Procurement of general security equipment. 272,865 272,865 272,865 272,865 0 0 4,847,395 01.02.06.01.04 Deployment of guards/security forces. 1,047,424 1,047,424 1,047,424 1,047,424 0 0 30,034,034 01.02.06.02 Site operation and maintenance. 65,760 65,760 65,760 65,760 0 0 6,692,797 01.02.06.02.01 Inspection and maintenance of buildings and systems. 0 0 0 0 0 0 5,777,637 01.02.06.02.02 Site upkeep activities. 65,760 65,760 65,760 65,760 0 0 915,160 01.02.06.03 Operation of support systems. 862,589 862,589 862,589 862,589 0 0 14,170,540 01.02.06.03.01 Electricity supply systems. 862,589 862,589 862,589 862,589 0 0 9,992,010 01.02.06.03.02 Ventilation systems. 0 0 0 0 0 0 2,820,585 01.02.06.03.07 Other systems. 0 0 0 0 0 0 1,357,946 01.02.06.04 Radiation and environmental safety monitoring. 0 0 0 0 0 0 2,327,577 Procurement and maintenance of equipment for radiation protection and environmental 01.02.06.04.01 0 0 0 0 0 0 1,394,046 monitoring.

01.02.06.04.02 Radiation protection and monitoring. 0 0 0 0 0 0 933,531 01.02.08 Project management, engineering and support 7,437,142 7,437,142 7,437,142 6,739,601 3,066,076 1,788,544 108,865,511 01.02.08.02 Project management. 3,493,641 3,493,641 3,493,641 3,059,158 580,983 338,907 44,457,681 01.02.08.02.01 Core management group. 2,592,710 2,592,710 2,592,710 2,158,227 580,983 338,907 29,655,819 01.02.08.02.02 Project implementation planning, detailed ongoing planning. 0 0 0 0 0 0 1,456,806 01.02.08.02.03 Scheduling and cost control. 118,911 118,911 118,911 118,911 0 0 1,550,800 01.02.08.02.04 Safety and environmental analysis, ongoing studies. 271,726 271,726 271,726 271,726 0 0 5,968,511 01.02.08.02.05 Quality assurance and quality surveillance. 237,822 237,822 237,822 237,822 0 0 2,407,952 01.02.08.02.06 General administration and accounting. 158,719 158,719 158,719 158,719 0 0 2,109,640 01.02.08.02.07 Public relations and stakeholders involvement. 113,752 113,752 113,752 113,752 0 0 1,308,151 01.02.08.03 Support services. 2,809,853 2,809,853 2,809,853 2,809,853 2,485,092 1,449,637 51,479,943 01.02.08.03.01 Engineering support. 1,595,231 1,595,231 1,595,231 1,595,231 0 0 19,906,775 01.02.08.03.02 Information system and computer support. 395,224 395,224 395,224 395,224 0 0 4,438,039 01.02.08.03.03 Waste management support. 439,788 439,788 439,788 439,788 256,198 149,449 4,847,030 01.02.08.03.04 Decommissioning support including chemistry, decontamination. 0 0 0 0 0 0 823,616 01.02.08.03.05 Personnel management and training. 0 0 0 0 0 0 2,084,501 01.02.08.03.06 Documentation and records control. 0 0 0 0 0 0 9,845 01.02.08.03.07 Procurement, warehousing, and materials handling. 341,659 341,659 341,659 341,659 36,588 21,343 4,068,481 01.02.08.03.08 Housing, office equipment, support services. 37,951 37,951 37,951 37,951 2,192,306 1,278,845 15,301,654 01.02.08.04 Health and safety. 981,845 981,845 981,845 718,788 0 0 10,941,807 01.02.08.04.01 Health physics. 789,172 789,172 789,172 526,115 0 0 7,759,413 01.02.08.04.02 Industrial safety. 192,673 192,673 192,673 192,673 0 0 3,182,394 01.02.08.08 Support services by contractors (if needed). 151,802 151,802 151,802 151,802 0 0 1,986,080 01.02.08.08.02 Information system and computer support. 151,802 151,802 151,802 151,802 0 0 1,986,080 01.02.11 Miscellaneous expenditures 1,132,753 1,132,753 1,132,753 1,132,753 281,107 163,979 47,361,671 01.02.11.01 Owner costs. 459,961 459,961 459,961 459,961 0 0 11,393,891 01.02.11.01.01 Implementation of transition plans. 459,961 459,961 459,961 459,961 0 0 8,243,243 01.02.11.01.03 Payments (fees) to authorities. 0 0 0 0 0 0 3,150,648 01.02.11.02 Taxes. 281,107 281,107 281,107 281,107 281,107 163,979 22,656,000 01.02.11.02.02 Local, community, federal taxes. 281,107 281,107 281,107 281,107 281,107 163,979 22,656,000 01.02.11.03 Insurances. 391,685 391,685 391,685 391,685 0 0 13,311,780 01.02.11.03.01 Nuclear related insurances. 391,685 391,685 391,685 391,685 0 0 13,311,780 1/12/2023 10:47 AM PER_DCE Cost Model Tables_Seg_after_SAFSTOR-20230110-rev00 Page 15 of 27

HOLTEC I NT ER NA T l ON A L ATTACHMENT 10 ISFSI Decommissioning Cost Estimate

HO LT EC I N TER N AT IONA L ISFSI Decommissioning Cost Estimate (thousands of 2022 dollars)

Reruoml Disposal Other

.-\cthities Transport Costs Total Costs Costs Costs Costs ISFSI Demolition Non-Radiological 3,281 3,281 ISFSI Clean Waste 526 394 920 ISFSI Final Site Suryey 191 191 ISFSI NRC Confinnato,y SurYey 21 21 ISFSI Demolition Radiological 394 394 ISFSI Radiological Was1e 166 1,708 417 2,292 Total 4,367 1,708 417 606 7,098

Enclosure B L-23-061 Redacted Surety Bond with Associated Riders (9 pages follow)

APPENDIXA A standby trust fund must be established to receive funds from the surety bond. The standby trust fund should satisfy the criteria described in Section A.12 and in Checklist 12-A of this appendix.

A.5.4 Model Surety Bond PAYMENT SURETY BOND Date bond executed: December 21, 2022 Effective date: December 21, 2022 Principal: Energy Harbor Nuclear Generation LLC 168 E. Market Street Akron, OH 44308 Type of organization: LLC State of incorporation: DE (if applicable)

NRC license number, docket number, name and address of facility, and amount for decommissioning activities guaranteed by this bond:

License: DPR-66 Docket: 50-334 Name: Beaver Valley Power Station Unit 1 Amount: $20,000,000.00 Surety: Federal Insurance Company 202B Hall's Mill Road, Whitehouse Station NJ 08889 Type of organization: Corporation State of incorporation: IN (if applicable)

Surety's qualification in jurisdiction where licensed facility is located. Yes Surety's bond number: K41651738 Total penal sum of bond: $20,000,000.00 Know all persons by these presents, that we, the Principal and Surety hereto, are firmly bound to the U.S. Nuclear Regulatory Commission (hereinafter called NRC) in the above penal sum for the payment of which we bind ourselves, our heirs, executors, administrators, successors, and assigns jointly and severally; provided that, where the Sureties are corporations acting as co- sureties, we, the Sureties, bind ourselves in such sum jointly and severally" only for the purpose of allowing a joint action or actions against any or all ofus, and for all other purposes each Surety binds itself, jointly and severally with the Principal, for the payment of such sum only as is set forth opposite the name of such Surety; but if no limit of liability is indicated, the limit of liability shall be the full amount of the penal swn.

WHEREAS, the U.S. Nuclear Regulatory Commission, an agency of the U.S. Government, pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, A-61 NUREG-1757, Vol. 3, Rev. l

APPENDIX A Part 50, applicable to the Principal, which require that a license holder or an applicant for a facility license provide financial assurance that funds will be available when needed for facility decommissioning; NOW, THEREFO RE, the conditions of the obligation are such that if the Principal shall faithfully, before the beginning of decommiss ioning of each facility identified above, fund the standby trust fund in the amount(s) identified above for the facility; Or, if the Principal shall fund the standby trust fund in such amount(s) after an order to begin facility decommiss ioning is issued by NRC or a U.S. District Court or other court of competent jurisdiction; Or, if the Principal shall provide alternative financial assurance, and obtain NRC's written approval of such assurance, within 30 days after the date a notice of cancellation from the Surety is received by both the Principal and NRC, then this obligation shall be null and void; otherwise it is to remain in full force and effect.

The Surety shall become liable on this bond obligation only when the Principal has failed to fulfill the conditions described above. Upon notification by NRC that the Principal has failed to perform as guaranteed by this bond, the Surety shall place funds in the amount guaranteed for the facility into the standby trust fund.

The liability of the Surety shall not be discharged by any payment or succession of payments hereunder, unless and until such payment or payments shall amount in the aggregate to the penal sum of the bond, but in no event shall the obligation of the Surety hereunder exceed the amount of said penal sum.

The Surety may cancel the bond by sending notice of cancellation by certified mail to the Principal and to NRC provided, however, that cancellation shall not occur during the 90 days beginning on the date ofreceipt of the notice of cancellation by both the Principal and N RC. as evidenced by the return receipts.

The Principal may terminate this bond by sending written notice to NRC and to the Surety 90 days prior to the proposed date of termination, provided, however, that no such notice shall become effective until the Surety receives written authorization for termination of the bond from NRC.

The Principal and Surety hereby agree to adjust the penal sum of the bond yearly so that it guarantees a new amount, provided that the penal sum does not increase by more than 20 percent in any one year.

If any part of this agreement is invalid, it shall not affect the remaining provisions that will remain valid and enforceable.

NUREG-1757, Vol. 3, Rev. 1 A-62

APPENDIX A In Witness Whereof, the Principal and Surety have executed this financial guarantee bond and have affixed their seals on the date set forth above.

The persons whose signatures appear below hereby certify that they are authorized to execute this surety bond on behalf of the Principal and Surety.

Principal: Energy Harbor Nuclear Generation LLC Whitehouse Station NJ 08889 State of incorporation: IN Liability limit: $20,000,000.00

. ;, c. G. McVaugh, Attomey-i

. ,. [C,81p6i61te seal]

)

,* ')

[For'eve,y co-surety, provide signatures, names and titles, corporate seal, and other information in the same manner as for the Sureties above.]

Bond Premium: [ ]

CHUBB Power of Attorney Federal Insurance Company IVigilant Insurance Company I Pacific Indemnity Company Westchester Fire Insurance Company I ACE American Insurance Company Know All by These Presents, that FEDERAL INSURANCE COMPANY, an Indiana corporation, VIGILANT INSURANCE COMPANY, a New York corporation, PACIFIC INDEMNITY COMPANY, a Wisconsin corporation, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY corporations of the Commonwealth or Pennsylvania, do each hereby constitute and appoint Kimberly G. Sherrod and Babette Ward of Columbus, Ohio; Dana Donahue, Patricia Dorsaneo, George Gionis, Wayne G. McVaugh, Sara Owens, Patricia A. Rambo and Lori S. Shelton of Philadelphia, Pennsylvania; Cathy H. Ho and Justin Johnson of Pittsburgh, Pennsylvania; Annmarie Breene, Vicki Johnston and Joanne C. Wagner of Radnor, Pennsylvania ---***********************************-*-********

each as their true and lawful Attorney-in-Fact to execute under such designation in their names and to affix their corporate seals to and deliver [or and on their behalfas surety thereon or otherwise, bonds and undertakings and other writings obligatory in the nature thereof (other than bail bonds) given or executed in the course of business, and any instruments amending or altering the same, and consents to the modification or alteration of any instrument referred to in said bonds or obligations.

In Witness Whereof, said FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY have each executed and attested these presents and affixed their corporate seals on this 12th day of December, 2022.

-Dtu..1.n,....,"'f\. ~~ ~ M. ~

STATE OF NEW JERSEY County of Hunterdon ss.

On this 12th day of December, 20 22 berore me, a Notary Public of New Jersey, personally came Dawn M. Chloros and Stephen M. Haney, to me known to be Assistant Secretary and Vice President, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY, the companies which executed the foregoing Power or Attorney, and the said Dawn M. Chlorosand Stephen M. Haney, being by me duly sworn, severally and each for herself and himself did depose and say that they are Assistant Secretary and Vice President, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY and know the corporate seals thereof, that the seals affixed to the foregoing Power of Attorney are such corporate seals and were thereto affixed by authority of said Companies; and that their signatures as such officers were duly affixed and subscribed by like authority.

Notarial Seal Albon Contunl NOTARY PU9UC OF NEW JERSEY No502023&9 Commluion E,q,;;e, /wcust U.2027 CERTIFJCATION Resolutions adopted by the Boards of Directors of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, and PACIFIC INDEMNITY COMPANY on August 30, 201 6; WESTCHESTER FIRE INSURANCE COMPANY on December 11, 2006; and ACE AMERICAN INSURANCE COMPANY on March 20. 2009:

"RESOLVED, that the fotJowing authorizatJons relate to the execution. for and on behalf of the Company, of bonds, undertakings, recognl2.anres. rontracts and other wr~tten commitments of the Com}lany entered intoln the ordinary r::ourse of business (each a "Wrinen Commltment1:

(1) Each of the Chairman, the President and the Vice Pre,i,ldehts of the Company Is hereby authorized to execute any Written Commitment ror and on behalf or the Company, under the seal afthe Company or ntherwlse.

(2) Each duly appointEd attorncy-ln-fact of the Company is hereby authorized to execute any Written Commitment for and on behaU oftllc Company, un der the seal of the Company or otherwl.se, to tile extent that such action is ;;iuthorlzcd by lhe grant of powers provided for In such person's written appointme nt as su cll attorney-In-fact (3) Each of the Cllilirman, the President and the Vice Presidents of the Campany is hereby authorlzi?d, for and on behalf ofthe Co mpany, to appoint in writing any person the attarney-1n-fact of the Company wlth full power and authority to execute, for and on behalf of the Company. under the seal of the Company or otherwise, such Written Commitments of the Company as may be spedfied In such written appointmen4 which specification may be by general type or class of Written Commibnents or by specification of one or more partirular Written Commitrnent.s.

(4) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized, for and on behalf of the Company, to delegate tn writing to any otl,er officer of the Company the authority to execute, for and on behalf of the Company, under the Company's sea l o r othe rwise. such Written Cornmionencs of the Company as are s pecified In such written delegation, which speciRcation may be by general type or class of Written Commlunent:s or by specification of one or more particular Written Commitments.

(5) The signanu-e or any officer or other person executing any Written Commtonent or appointment or delegation pursuant to this Resolution, and the sea\ of the Company. may be affixed by racsimHe on such Written Commitment or written appointme11t or delegation.

FURTHER RESOLVED, that the foregoing Resolution shall not be deemed lo be an exclusive statement of the powers and authority arofficcr5, employees: and other persons to act for and on behalr ofthc Company, .ind such Reso lution shalt not limit or otherwise affect the exercise of any such power or a uthority oth erwise validly granlcd or vested."

I, Dawn M. Chloros, Assistant Secretary of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY (the "Companies'1 do hereby certify that

[i) the foregoing Resolutions adopted by the Board of Directors of the Companies are true, correct and in full force and effect,

{ii) the foregoing Power of Attorney is true, correct and in full force and effect Given under my hand and seals of said Companies at Whitehouse Station, Nj, this 21st day of December, 2022 IN TIIE EVENT YOU IVISII TO VF.RIFY THE AUTllf.NTICITY Of THIS BO NDOR NOTIFY US OF Nff OTHER MATTER. PLEASE CONTACT US AT, Trle hone 908 903- 3*-13 f.1x qoa ~03-3656 t-*m,111 surtl ~c:huhbcmn Combined. FED-VIG*Pl*WFIC-AAIC (rev 11 -19)

BOND NO. --'-->...!--'-='--'--'--'

K41651738 "--"-- - - - --

RIDER To be attached to and form a part of Bond No. K41651738 executed by _ _ __ _ _ __ _ _ __ _ E_N_E_RG _ Y_H_A_R_B_O_R_C _O _R _P ____________ __c* as Principal and by __ __ _ _ __ __ ____F_E_D_E_R_A_L _IN_S_U_R_A_N_C_E_C_O_M_PA_N_Y _ _ __ _ __ _ __ _ _ _ as Surety, in favor of ------------=E'-'-N=E'-'-R'-=G'-'Y-'H--"A--"R..:.:B:::.;O:::.;R__:_:_:N=U=C-=L=EA'--"RC.:....:::G:.:::E:.:..:N:.:::E;.:..;R::..;Ac:..T!.:::1O'-!.N.:..;L=.,L::.::C:...__ _ _ _ _ _ _ _ __

and effective as of December 21 , 2022 1n consideration of the mutual agreements herein contained the Principal and the Surety hereby consent to changing Bond Amount FROM : Twenty Million and no/100~------($20,000,000.00)

TO: Fifty Million and no/100---------- -----(-$50,000,000.00)

Nothing herein contained shall vary, alter or extend any provision or condition of this bond except as herein expressly stated. This rider is effective on the 24th day of February 2023

- - - - - -----=------ - -

ENERGY HARBOR CORP.

FEDERAL INSURANCE COMPANY

CHU E3 B '

Power of Attorney Federal Insurance Company I Vigilant Insurance Company I Pacific Indemnity Company Westchester Fire Insurance Company I ACE American Insurance Company Know All by These Presents, that FEDERAL INSURANCE COMPANY, an Indiana corporation, VIGILANT INSURANCE COMPANY, a New York corporation, PACIFIC INDEMNITY COMPANY, a Wisconsin corporation, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY corporations of the Commonwealth of Pennsylvania, do each hereby constitute and appoint Kimberly G. Sherrod and Babette Ward of Columbus, Ohio; Dana Donahue, Patricia Dorsaneo, George Gionis, Wayne G. McVaugh, Sara Owens, Patricia A. Rambo and Lori S. Shelton of Philadelphia, Pennsylvania; Cathy H. Ho and Justin Johnson of Pittsburgh, Pennsylvania; Annmarie Breene and Joanne C. Wagner of Radnor, Pennsylvania---------------------------------------------------------------------

each as theirtrue and lawful Attorney-in-Fact to execute under such designation in their names and to affix their corporate seals to and deliver for and on their behalf as surety thereon or otherwise, bonds and undertakings and other writings obligatory in the nature thereof (other than bail bonds) given or executed in the course of business, and any instruments amending or altering the same, and consents to the modification or alteration of any instrument referred to in said bonds or obligations.

In Witness Whereof, said FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY have each executed and attested these presents and affixed their corporate seals on this 19th day of January, 2023 .

~tepllcn ~I. I bnc") . \ ice l'rcsitfc-nr STATE OF NEW JERSEY County of Hunterdon ss.

On this 19 th day of January 2023 before me, a Notary Public of New Jersey, personally came Dawn M. Chloros and Stephen M. Haney, to me known to be Assistant Secretary and Vice President, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC IND EMN ITY COMPANY, WESTC HESTER FIRE IN SURANCE COMPANY and ACE AMERICAN IN SURANCE COMPANY, the companies which executed the foregoing Power of Attorney, and the said Dawn M. Chloros and Stephen M. Haney, being by me duly sworn, severa lly and each for herself and himself did depose and say that they are Assistant Secretary and Vice Pres ident, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDE MNITY COMPANY, WESTC HESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY and know the corporate seals thereof, that the seals affixed to the foregoing Power of Attorney are such corporate seals and were thereto affixed by authority of said Companies; and that their signatures as su ch officers were duly affixed and subscribed by like authority.

Notarial Seal Albert Co.ntursi NOTARY PUBLIC OF N.EW JERSEY No 50202369 Commisston Expires Au gust 22,2027

~ - Notary Public CERTIFICATION Resolutions adopted by the Boards of Directors of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, and PACIFIC INDEMNITY COMPANY on August 30, 2016; WESTCHESTER FIRE INSURANCE COMPANY on December 11, 2006; and ACE AMERICAN INSURANCE COMPANY on March 20, 2009:

"RESOLVED, that the following authorizations relate to the execution, for and on behalf of the Company, of bonds, undertakings, recognizances, contracts and other written commitments of the Company entered into in the ordinary course of business (each a "Written Commitment"):

(1) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized to execute any Written Committnent for and on behalf of the Company, under the seal of the Company or otherwise.

(2) Each duly appo inted attorney-in-fact of the Company is hereby authorized to execute any Written Commitment for and on behalf of the Company, under the seal of th e Company or otherwise, to the extent that such action is authorized by the grant of powers provided for in such person's written appointment as such attorney-in-fact.

(3) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized, for and on behalf of the Company, to appoint in writing any person the attorney-in-fact of th e Company with full power and authority to execute, for and on behalf of the Company, under the seal of the Company or otherwise, such Written Commitments of the Company as may be specified in such written appointment, which specification may be by general type or class of Written Commitments or by specification of one or more particular Written Commitments.

(4) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized, for and on behalf of th e Company, to delegate in writing to any other officer of the Company th e authority to execute, for and on behalf of the Company, under the Company's seal or otherwise, such Written Commitments of the Company as are specified in s uch written delegation, which specification may be by general type or class of Written Commitments or by specification of one or more particular Written Commibnents.

(5) The signature of any officer or other person executing any Written Commitment or appointment or delegation pursuant to this Resolution, and the seal of the Company, may be affixed by facsimile on such Written Commitment or written appointment or delegation.

FURTHER RESOLVED, that the foregoing Resolution shall not be deemed to be an exclusive statement of the powers and authority of officers, employees and other persons to act for and on behalf of the Company, and such Resolution shall not limit or otherwise affect the exercise of any such power or authority otherwise validly granted or vested."

I, Dawn M. Chloros, Ass istant Secretary of FEDERAL IN SURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMN ITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY (the "Companies") do hereby certify that (i) the foregoin g Reso lutions adopted by the Board of Directors of the Companies are true, correct and in full force and effect, (ii) the foregoing Power of Attorney is true, correct and in full force and effect.

Given under my hand and seals of said Companies at Whitehouse Station, NJ, this February 24, 2023 IN THE EVENT YOU WISH TO VERll'Y THE AUTHENTICITY OF THIS BOND OR NOTll'Y US OF ANY OTHER MATTER, PLEASE CONTACT US AT:

Tele hone 908 903- 3493 Fax 908 903- 3656 e-mail: sure @chubb.com Combined: FED-VIG-PI-WFIC-AAIC (rev. 11-19)

BOND NO. -'-'-'--'-="--'--'--"-"'-------

K41651738 RIDER To be attached to and form a part of Bond No. -'--K'-'-4--'-'16:. :5. :. 17.c. .:3:. :8_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

executed by _ _ _ _ _ _ _ _ _ _ _ _ _E_N_E_R_G_Y_H_A_R_B_O_R_C_O_R_P_ _ _ _ _ _ _ _ _ _ _ _ _. as Principal and bv .___________ __ FE_D_E_RA_L_I_N_S_U_RA_N_C_E_C_O_M_P_A_N_Y_ _ _ _ _ _ _ _ _ _ _ _ _ as Surety, in favor of ------------=E:..:.N:.E:..:.RG.::::.Y..:....:..H:,_A::..;R,::Bc,::Oc,_;R:.,.:.N.,_,U::,.:C::..::L::.:::E::..A::..;R....,G"-'E:.!.N.,_,E:.:.R.,._A....T.,_,1O::..!N.!...!:all::..:C~ ---------~

and effective as of _ _ _ _ _ _ _ _ _ _ _ _ _ _--=D..: .ec.: . :e: .:.;mc:.:b: .: ec:. r.=.2. :. i1,-=2:.;:0=22=----- -----------

ln consideration of the mutual agreements herein contained the Principal and the Surety hereby consent to changing Bond Amount FROM: Fifty Million and 00/100-------(-$50,000,000.00)

TO: Sixty One Million and 00/10*1-------(-$61 ,000,000.00)

Nothing herein contained shall vary, alter or extend any provision or condition of this bond except as herein expressly stated. This rider is effective on the_--=-3.;..;:1s=t~ day of _ _ _ _ _M_a_rc_h_ _ _ __ 2023

Signed and sealed this 30th . day of _________M_a:.;;.r..:..:ch..:.__ _ _ _ _ _ __ 2023 FEDERAL INSURANCE COMPANY Surety A::-~~:y-'. ~-~ac~

C H UBB.

- Power of Attorney Federal Insurance Company I Vigilant Insurance Company I Pacific Indemnity Company Westchester Fire Insurance Company I ACE American Insurance Company Know All by These Presents, that FEDERAL INSURANCE COMPANY, an Indiana corporation, VIGILANT INSURANCE COMPANY, a New York corporation, PACIFIC INDEMNITY COMPANY, a Wisconsin corporation, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY corporations of the Commonwealth of Pennsylvania, do each hereby constitute and appoint Kimberly G. Sherrod and Babette Ward of Columbus, Ohio; Dana Donahue, Patricia Dorsaneo, George Gionis, Wayne G. McVaugh, Sara Owens, Patricia A. Rambo and Lori S. Shelton of Philadelphia, Pennsylvania; Cathy H. Ho and Justin Johnson of Pittsburgh, Pennsylvania; Annmarie Breene and Joanne C. Wagner of Radnor, Pennsylvania -- -----------------------------------

each as their true and lawful Attorney-in-Fact to execute under such designation in their names and to affix their corporate seals to and deliver for and on their behalf as surety thereon or otherwise, bonds and undertakings and other writings obligatory in the nature thereof (other than bail bonds) given or executed in the co urse of business, and any instruments amending or altering the same, and consents to the modification or alteration of any instrument referred to in said bonds or obligations.

In Witness Whereof, said FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY have each executed and attested these presents and affixed their corporate s eals on this 19th day of January, 2023.

Davm M. Chloros. Assisc::mtSecretary Stephen M. Haney, Vice Presiden t STATE OF NEW JERSEY County of Hunterdon 55.

On this 19th day of January 2023 before me, a Notary Public of New Jersey, personally came Dawn M. Chloros and Stephen M. Haney, to me known to be Assistant Secretary and Vice President, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY, the companies wh ich executed the foregoing Power of Attorney, and the said Dawn M. Chloros and Stephen M. Haney, being by me duly sworn, severally and each for herself and himself did depose and say that they are Assistant Secretary and Vice President, respectively, of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY and know the corporate seals thereof, that the seals affixed to the foregoing Power of Attorney are such corporate seals and were thereto affixed by authority of said Companies; and that their signatures as s uch officers were duly affixed and subscribed by like authority.

Notarial Seal Albert Contursi NOTARY PWLIC OF NEW JERSEY No,5020236!1 Commfssi.cin Expires: August 22.,,2027

~ - Natary Publlc CERTIFICATION Resolutions adopted by the Boards of Directors of FEDERAL INSURANCE COMPANY, VIG ILANT INSURANCE COMPANY, and PACIFIC INDEMN ITY COMPANY on August 30, 2016; WESTCHESTER FIRE INSURANCE COMPANY on December 11, 2006; and ACE AMERICAN INSURANCE COMPANY on March 20, 2009:

"RESOLVED, that the following authorizations relate to the execution, for and on behalf of the Company, of bonds, undertakings, recognizances, contracts and other written commitments of the Compa ny entered into in the ordinary course of business (each a "Written Commitment"):

(1) Each of the Chairman, th e President and the Vice Presidents of the Company is hereby authorized to execute any Written Commitment for and on behalf of the Company, under the seal of the Company or otherwise.

(2) Each duly appointed attorney-in-fact of the Company is hereby authorized to execute any Written Commitment for and on behalf of the Company, under the seal of the Company or otherwise, to the extent that such action is authorized by the grant of powers provided for in such person's written appointment as such attorney-in-fact (3) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized, for and on behalf of the Company, to appoint in writing any person the attorney-in-fact of the Company with full power and authority to execute, for and on behalf of the Company, under the seal of the Company or otherwise, such Written Commitments of the Company as may be specified in such written appointment, which specification may be by general type or class of Written Commitments or by specification of one or more particular Written Commitments.

(4) Each of the Chairman, the President and the Vice Presidents of the Company is hereby authorized, for and on behalf of the Company, to delegate in writing to any other officer of the Company the authority to execute, for and on behalf of the Company, under the Company's seal or otherwise, such Written Commitments of the Company as are specified in such written delegation, which specification may be by general type or class of Written Commitments or by specification of one or more particular Written Commitments.

(5) The signature of any officer or other person executing any Written Commitment or appo intment or delegation pursuant to this Resolution, and the seal of the Company, may be affixed by facsimile on such Written Commitment or written appointment or delegation.

FURTHER RESOLVED, that the foregoing Resolution shall not be deemed to be an exclusive statement of the powers and authority of officers, emp loyees and other persons to act for and on behalf of the Company, and such Resolution shall not limit or otherwise affect the exercise of any such power or authority otherwise validly granted or vested."

I, Dawn M. Chloros, Assistant Secretary of FEDERAL INSURANCE COMPANY, VIGILANT IN SURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTC HESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY (the "Companies'1 do hereby certify that (i) the foregoing Resolutions adopted by the Board of Directors of the Companies are true, correct and in full force and effect, (ii) the foregoing Power of Attorney is true, correct and in full force and effect.

Given under my hand and seals of said Companies at Whitehouse Station, NJ, this 30th day of March, 2023 Dawn M. Ch loros. Assistant Secretary' IN THE EVENT YOU W ISH TO -VERIFY Tll !;__A_!!THENTICITY~ F T)-ll~ BOND OR NOTIFY US OF ANY OTHER MATTER, PLEASE CONTACT US AT:

Tele hone 903 9_03'"3*493 Fax 908 903- 3656 e-mail : sure @chubb.com Combined: FED-VIG-PI-WFIC-MIC (rev. 11-19)

Enclosure C L-23-061 Declaration (2 pages follow)

10 CFR 2.390 DECLARATION OF DARIN M. BENYAK SUPPORTING ENERGY HARBOR NUCLEAR CORP.S APPLICATION TO WITHHOLD CERTAIN INFORMATION FROM PUBLIC DISCLOSURE Page 1 of 2 I, Darin M. Benyak, Senior Vice President, Fleet Nuclear Operations, for Energy Harbor Nuclear Corp., declare the following under penalty of perjury:

1. I am authorized to execute this declaration on behalf of Energy Harbor Nuclear Corp., on behalf of itself and Energy Harbor Nuclear Generation LLC (collectively referred to as Energy Harbor).

2. Energy Harbor is providing information to the U.S. Nuclear Regulatory Commission (NRC) in support of its Submittal of the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant (the Submittal). Enclosure D to the Submittal contains a surety bond that Energy Harbor is relying upon, in part, to provide decommissioning financial assurance. Certain information in these surety bonds constitutes proprietary commercial and financial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4) and 10 CFR 9.17(a)(4) because:

a. The bonds contain information that is held in confidence by Applicants and their affiliates.

b. This information is of a type that is customarily held in confidence by Applicants and their affiliates and there is a rational basis for doing so because the information contains sensitive financial information concerning the Applicants purchase of the bonds.

c. This information is being transmitted to the NRC in confidence.

d. This information is not available in public sources and could not be gathered readily from publicly available information.

e. Public disclosure of this information would create substantial financial harm to the competitive position of Energy Harbor by disclosing their costs of purchasing bonds to other parties whose commercial interests may be adverse to those of Energy Harbor.

10 CFR 2.390 DECLARATION OF DARIN M. BENYAK SUPPORTING ENERGY HARBOR NUCLEAR CORP.'S APPLICATION TO WITHHOLD CERTAIN INFORMATION FROM PUBLIC DISCLOSURE Page 2 of2

3. Accordingly, Energy Harbor requests that the proprietary version of Enclosure B to the "Submittal of the Decommissioning Funding Status Reports for Beaver Valley Power Station, Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station, and Perry Nuclear Power Plant" be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4) and 9.l 7(a)(4).

I declare under penalty of perjury of the laws of the United States that the foregoing is true and correct.

Executed on March 31, 2023.

Energy Harbor Nuclear Corp.

Digitally signed by Darin M.

Darin M. Benyak Benyak Date: 2023.03.31 19:22:54 -04'00' Darin M. Benyak Senior Vice President, Fleet Nuclear Operations

L-23-061, Submittal of the Decommissioning Funding Status Reports

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L-23-061, Submittal of the Decommissioning Funding Status Reports

Text

SUBJECT:

Enclosure:

SUMMARY

1.0 INTRODUCTION

SUMMARY

SUMMARY

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