ML24150A003

Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) and Proposed Amendment to the Decommissioning Trust Agreement

ML24150A003
Person / Time
Site:	Salem, Hope Creek, Peach Bottom
Issue date:	05/28/2024
From:	Mannai D Public Service Enterprise Group
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24150A002	List: LR-N24-0040, Attachment 3: Decommissioning Cost Analysis for Peach Bottom Atomic Power Station, Units 2 and 3 ML24150A003 ML24150A004 ML24150A005
References
LR-N24-0040
Download: ML24150A003 (1)

Text

David J. Mannai Executive Director - Regulatory Affairs and Nuclear Oversight, PSEG Nuclear

PO Box 236 o PSEG I NUCLEAR Hancocks Bridge, New Jersey 08038-0221 856-339-2061 David.Mannai@pseg.com

10 CFR 50.12 10 CFR 50.82(a)(8)(i)(A) 10 CFR 50.75(h)(1)(iv) 10 CFR 50.75(h)(1)(iii)

LR-N24-0040 May 28, 2024

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272, 50-311 and 72-48 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket Nos. 50-354 and 72-48 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277, 50-278 and 72-29

Subject:

Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) and Proposed Amendment to the Decommissioning Trust Agreement

References:

1. Letter from David J. Mannai (PSEG Nuclear LLC) to U.S. Nuclear Regulatory Commission, Notice of Proposed Amendment to Decommissioning Trust Agreement, dated September 8, 2023 (ADAMS Accession No. ML23252A001)

2. Letter from U.S. Nuclear Regulatory Commission to Charles V. McFeaters (PSEG Nuclear LLC), Hope Creek Generating Station, Salem Nuclear Generating Station, Unit Nos. 1 and 2, and Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 - Notice of Objection to Proposed Amendment to Decommissioning Trust Agreement (EPID-L-2023-LRO-0063), dated November 29, 2023 (ADAMS Accession No. ML23270C007)

Pursuant to 10 CFR 50.12, Specific exemptions, PSEG Nuclear LLC (PSEG) requests exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for the facilities listed above. The exemptions would allow PSEG to per iodically transfer earnings from funds dedicated for activities consistent with the definition of decommission in 10 CFR 50.2 (radiological decommissioning) into separately maintained subaccounts within the Nuclear Decommissioning Trust (NDT). Funds accumulated in the subaccounts would be used to pay for activities that are part of the larger decommissioning process and not exclusively dedicated for radiological decommissioning. PSEG also requests, pursuant to 10 CFR 50.12, an exemption from 10 CFR 50.75(h)(1)(iv) to allow the periodic transfers to be made without prior notification to the NRC.

LR-N24-0040 Page 2

In Reference 1, pursuant to 10 CFR 50.75(h)(1)(iii), PSEG initially notified the NRC of a proposed amendment to the Master Decommissioning Trust Agreement (Trust Agreement) to exclude NRC requirements from applying to separately maintained subaccounts that had been established in the NDT as of the end of 2022. The subaccounts are intended to pay for decommissioning costs as defined by the Treasury Department regulations implementing Section 468A of the Internal Revenue Code. Specifically, 26 CFR 1.468A-1, Nuclear decommissioning costs; general rules, paragraph (b)(6) defines decommissioning costs to include costs for radiological and non-radiological activities and certain spent fuel management activities whether the plant is operating or has permanently ceased operations. The practice of commingling funds in the NDT is generally permitted under NRC guidance as long as the licensee is able to identify and account for the funds dedicated to radiological decommissioning separately from funds set aside for other purposes. Reference 1 also described that certain earnings from NDT funds would be used as a source of funds for the subaccounts.

In Reference 2, the NRC provided notice of objection to Reference 1. The NRC affirmed that subaccounts may be established within the NDT and that their withdrawals are not necessarily restricted to radiological decommissioning expenses. However, the NRC stated that earnings from funds originally dedicated for radiological decommissioning in an NDT fund are restricted by 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) to being withdrawn only for radiological decommissioning expenses. For such funds in the subaccounts to be used for expenses other than radiological decommissioning, PSEG would need to request and have approved an exemption, under 10 CFR 50.12, from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) in addition to amending the Trust Agreement.

Consistent with Reference 2, Enclosure 1 provides the request for exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv). The requested exemptions would allow PSEG to periodically transfer earnings from f unds dedicated for radiological decommissioning in the NDT into the subaccounts without prior notice to the NRC in accordance with the following proposed conditions:

• Transfers are limited to earnings from funds dedicated for radiological decommissioning as determined by an increase in the amount of funds accumulated in the NDT since the last decommissioning funding status (DFS) report submitted under 10 CFR 50.75(f)(1).

• At the time of the transfer, the amount of decommissioning funding assurance (DFA) provided by NDT funds, excluding funds held in the subaccounts, using the prepayment method in 10 CFR 50.75(e)(1)(i) must exceed the amount of DFA required by 10 CFR 50.75(b) and (c) for the associated station by at least $100 million (nominal dollars).

• DFS reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into the subaccounts since the last submitted report.

The exemption request relies on earnings during operations therefore the exemptions would remain effective only while the reactors are operating. The exemptions would cease to be effective on an individual reactor basis once the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1)(i) and (ii) have been submitted. During decommissioning, funds held in the subaccounts would be available, but not exclusively dedicated, for radiological decommissioning.

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provides analyses that demonstrate the funds accumulated in the NDT as of December 31, 2023, excluding funds held in the subaccounts, provide reasonable assurance of adequate funding for radiological decommissioning while allowing for periodic transfers of earnings in accordance with the exemption request. Decommissioning cash flow analyses are based on the site-specific decommissioning cost estimates provided in Attachments 1, 2, and 3 to this letter.

The requested exemptions are permissible under 10 CFR 50.12(a)(1) because they are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. As described in the exemption request, special circumstances are present pursuant to 10 CFR 50.12(a)(2).

Consistent with Reference 2 and contingent upon the NRC granting the exemptions, provides notification pursuant to 10 CFR 50.75(h)(1)(iii) and Section 10.06 of the Trust Agreement of a proposed amendment to t he Trust Agreement. The amendment involves a change to the provisions related to withdrawals from the NDT and would establish that funds held in the subaccounts are not subject to the NRCs restrictions and reporting requirements for funds dedicated for radiological decommissioning, similar to the amendment proposed in Reference 1. Thus, funds transferred into the subaccounts would be reallocated to pay for activities that are part of the larger decommissioning process and not restricted to radiological decommissioning. The amendment to the Trust Agreement is proposed to be effective following NRC approval of the requested exemptions, furthermore provided that no written notice of objection is received from the NRC.

Approval of the requested exemptions is requested by December 6, 2024, so they may be used prior to the end of 2024 and the next DFS report required to be submitted by March 31, 2025.

This letter contains no new regulatory commitments.

If there are any questions concerning this submittal, please contact Mr. Michael Wiwel at michael.wiwel@pseg.com.

Sincerely,

David J. Mannai Executive Director - Regulatory Affairs and Nuclear Oversight PSEG Nuclear LLC

Enclosures:

1. Request for Exemptions

2. Proposed Amendment to the Decommissioning Trust Agreement Attachments:

1. Salem Generating Station, Units 1 and 2 Site-Specific Decommissioning Cost Estimate

2. Hope Creek Generating Station Site-Specific Decommissioning Cost Estimate

3. Peach Bottom Atomic Power Station, Units 2 and 3 Site-Specific Decommissioning Cost Estimate LR-N24-0040 Page 4

cc: Administrator, Region I, NRC Mr. J. Kim, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Ms. Ann Pfaff, Manager, NJBNE PSEG Commitment Tracking Coordinator

LR-N24-0040

Enclosure 1

Salem Generating Station, Units 1 and 2

Hope Creek Generating Station

Peach Bottom Atomic Power Station, Units 2 and 3

Request for Exemptions

LR-N24-0040

1. SPECIFIC EXEMPTION REQUEST

Pursuant to 10 CFR 50.12, Specific exemptions, PSEG requests exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Salem Generating Station (Salem) Units 1 and 2, Hope Creek Generating Station (Hope Creek), Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and the associated gen eral licensed Independent Spent Fuel Storage Installations (ISFSIs), to allow PSEG to periodically transfer earnings from funds dedicated for activities consistent with the definition of decommission in 10 CFR 50.2 (radiological decommissioning) in the Nuclear Decommissioning Trust (NDT) into separately maintained subaccounts (Non-50.75 Subaccounts) in the NDT, and to allow periodic transfers to be made without prior notification to the NRC. The N on-50.75 Subaccounts would be used to separately account for funds to pay for activities that are part of the larger decommissioning process and not restricted to radiological decommissioning, subject to other applicable requirements including the Trust Agreement.

As of the end of 2022, PSEG has established the Non-50.75 Subaccounts within the NDT to separately account for funds to pay for decommissioning costs as defined by the Treasury Department regulations implementing Section 468A of the Internal Revenue Code. Specifically, 26 CFR 1.468A-1, Nuclear decommissioning costs; general rules, paragraph (b)(6), defines decommissioning costs to include costs for radiological and non-radiological activities and certain spent fuel management activities whet her the plant is operating or has permanently ceased operations. The practice of commingling funds in the NDT is generally permitted by the NRC as long as the licensee is able to ident ify and account for the funds dedicated for radiological decommissioning separately from funds set aside for other purposes.

In Reference 1, PSEG initially notified the NRC, pursuant to 10 CFR 50.75(h)(1)(iii), of a proposed amendment to PSEGs Master Decommissi oning Trust Agreement (Trust Agreement) that is relied upon to provide reasonable assurance that adequate funds will be available to decommission the facilities. The proposed amendment was intended to exclude funds held in the separately maintained Non-50.75 Subaccounts in the NDT from the requirements in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) that restrict the use of NDT funds to radiological decommissioning expenses. Reference 1 described that certain earnings from NDT funds would be used as a source of funds for the Non-50.75 Subaccounts.

In Reference 2, the NRC provided notice of objection to Reference 1. The NRC affirmed that subaccounts may be established within the NDT and that their withdrawals are not necessarily restricted to radiological decommissioning expenses. However, the NRC stated that earnings from funds originally dedicated for radiological decommissioning in an NDT fund are restricted by 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) to being withdrawn only for radiological decommissioning expenses. For such funds in the subaccounts to be used for expenses other than radiological decommissioning, PSEG would need to request and have approved an exemption, under 10 CFR 50.12, from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) in addition to amending the Trust Agreement.

10 CFR 50.82(a)(8)(i)(A) restricts the use of NDT funds to withdrawals for expenses for activities consistent with the definition of decommission in 10 CFR 50.2 (radiological decommissioning). As defined in 10 CFR 50.2, decommission means to remove a facility or site safely from service and reduce residual radioactivity to a level that permits (1) release of the

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property for unrestricted use and termination of the license or (2) release of the property under restricted conditions and termination of the license. Thus, funds in Non-50.75 Subaccounts would not be exclusively dedicated for radiological decommissioning.

10 CFR 50.75(h)(1)(iv) restricts disbursements or payments from the NDT, other than for payment of ordinary administrative costs and other incidental expenses of the fund, to radiological decommissioning expenses or transfer to another acceptable financial assurance method until final radiological decommissioning has been completed.

When funds are commingled in the NDT and not distinctly identified or are derived from earnings from funds originally dedicated for radiological decommissioning in the NDT (Reference 2), 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) do not allow their withdrawals to pay for activities other than radiological decommissioning until final radiological decommissioning has been completed.

The analyses provided in support of the exemption request demonstrate that the funds accumulated in the NDT as of December 31, 2023, excluding funds accounted for in Non-50.75 Subaccounts, provide reasonable assurance of sufficient funding for radiological decommissioning. Funds accounted for in Non-50.75 Subaccounts consist entirely of earnings from NDT funds during calendar year 2023. Thus, the exemption request includes reallocating funds that have been accounted for in the Non-50.75 Subaccounts as of December 31, 2023, for purposes not restricted to radiological decommissioning. The proposed conditions of the exemption request would restrict periodic transfers to actual earnings from funds dedicated for radiological decommissioning in the NDT and require the amount of funding assurance provided by funds in the NDT, excluding funds in the Non-50.75 Subaccounts, to exceed the amount required by 10 CFR 50.75(b) and (c) at the time of the transfer.

10 CFR 50.75(h)(1)(iv) further requires that, except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs and other incidental expenses of the fund in connection with the operation of the fund, no disbursement or payment may be made from the NDT without written notice to the NRC at least 30 working days before the date of the intended disbursement or payment. Pursuant to 10 CFR 50.12, PSEG also requests an exemption from 10 CFR 50.75(h)(1)(iv) to allow periodic transfers to be made in accordance with the exemption request without prior NRC noti fication in the same manner as withdrawals made under 10 CFR 50.82(a)(8).

The exemption request relies on earnings from NDT funds during operations. Accordingly, the exemptions would remain effective only while the reactors are operating. The exemptions would cease to be effective on an individual reactor basis once the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1)(i) and (ii) have been submitted. Thereafter, no further transfers would be allowed for that unit. During decommissioning, funds in Non-50.75 Subaccounts would be available, but not exclusively dedicated, for radiological decommissioning.

This exemption request is informed by draft NRC Interim Staff Guidance, Use of the Decommissioning Trust Fund During Operations for Major Radioactive Components (Reference 3). The draft guidance addresses establishing subaccounts to pay for decommissioning activities other than radiological decommissioning in existing NDTs and

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requesting exemptions under the 10 CFR 50.12 specific exemption process to fund the subaccounts using funds dedicated for radiological decommissioning.

2. BACKGROUND

PSEG provides funding assurance for radiological decommissioning for its ownership share of each of the reactors using the prepayment method in 10 CFR 50.75(e)(1)(i). The amount of funding assurance required is adjusted annually in accordance with 10 CFR 50.75(b) and (c).

Funding assurance for radiological decommissioning of the on-site general licensed ISFSIs for the reactors is also provided under 10 CFR 50.75, in accordance with 10 CFR 72.30(e)(5).

Since PSEG is not an electric utility as defined in 10 CFR 50.2, the Trust Agreement that is relied upon to provide reasonable assurance that funds held in the NDT will be available to decommission the facilities is subject to the provisions in 10 CFR 50.75(h)(1).

Salem is a dual unit pressurized water reactor located in Salem County, New Jersey along the eastern shore of the Delaware River. The NRC issued the Unit 1 operating license on December 1, 1976, the Unit 2 operating license on May 20, 1981. The renewed licenses were issued on June 30, 2011, with expiration dates of August 13, 2036, for Unit 1 and April 18, 2040, for Unit 2. The licensed rated thermal power of each unit is 3459 MWt. PSEG holds 57.41%

ownership share in Salem Units 1 and 2 and is the licensed operator. Constellation Energy Generation, LLC (CEG) holds the remaining ownership share.

Hope Creek is a single unit boiling water reactor, co-located with Salem. The NRC issued the operating license on July 25, 1986. The renewed license was issued on July 20, 2011, with an expiration date of April 11, 2046. The licensed rated thermal power is 3902 MWt. PSEG holds 100% of the ownership interest in Hope Creek and is the licensed operator.

The on-site ISFSI, licensed under the general license provisions of 10 CFR Part 72, is shared by Salem and Hope Creek and has been in operation since 2006.

PBAPS Units 2 and 3 are boiling water reactors located in southeastern Pennsylvania on the westerly shore of Conowingo Pond at the mouth of Rock Run Creek. The NRC issued the Unit 2 operating license on October 25, 1973, and the Unit 3 operating license on July 2, 1974. The renewed licenses were issued on May 7, 2003. Subsequent renewed licenses were issued on March 5, 2020, with expiration dates of August 8, 2053, for Unit 2 and July 2, 2054, for Unit 3. 1 The licensed rated thermal power of each unit is 4016 MWt. PSEG holds 50% ownership share in PBAPS Units 2 and 3. CEG holds the remaining ownership share and is the licensed operator. The on-site ISFSI has been in operation since 2000.

PSEG Nuclear is a wholly owned subsidiary of PSEG Power LLC (PSEG Power), a Delaware limited liability company formed in 1999 as a result of deregulation and restructuring of the electric power industry in New Jersey. Ownership in the nuclear facilities was acquired in 2000 and 2001. Asset transfers included funds held in irrevocable external trusts that were created when the nuclear units were placed into service. Initially, funds for decommissioning continued

1 In 2022, the expiration dates for PBAPS Units 2 and 3 subsequent renewed licenses as issued on March 5, 2020, were reverted to the renewed license expiration dates while the environmental analysis is updated, as directed by NRC Memorandum and Order CLI-22-04 dated February 24, 2022 (ADAMS Accession No. ML22055A557).

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to be collected from ratepayers through a non-bypassable charge component and PSEG relied on the external sinking fund method in 10 CFR 50.75(e)(1)(ii) to provide funding assurance.

On July 31, 2003, at the conclusion of a 4-year deregulation and restructuring transition period, the non-bypassable charge for decommissioning was eliminated under the terms of a settlement agreement approved by the New Jersey Board of Public Utilities. Customers no longer had responsibility for decommissioning costs nor any right to funds in the NDT. Accordingly, PSEG changed its funding assurance method from an external sinking fund to prepayment. Since 2003 there have been no additional contributions (i.e., cash injections) to the NDT and no other methods in 10 CFR 50.75(e)(1) have been used to provide financial assurance. Prepayment has relied on credit for earnings as allowed by 10 CFR 50.75(e)(1)(i) to provide reasonable assurance that sufficient funds will be available to pay for radiological decommissioning costs when permanent cessation of operations is expected.

2.1 Decommissioning Funding Assurance (DFA) History

Consistent with Reference 3, the following is a historical perspective of DFA provided by PSEG for radiological decommissioning of the facilities.

Tables 1-S, 1-HC, and 1-PB, provided at the end of this Enclosure, include information from decommissioning funding status (DFS) reports submitted by PSEG under 10 CFR 50.75(f)(1) covering the timeframe from 2004 to 2022 during which PSEG has used the prepayment method to provide DFA. The tables show the amount of funds accumulated in the NDT as of the end of the calendar year, the projected value of the funds taking credit for projected earnings, and the amount of funds required by the formulas in 10 CFR 50.75(c), pro-rated for PSEGs ownership share, at the time of the report. DFS reports for years 2008 to 2016 were based on site-specific decommissioning cost estimates (SSDCEs) under 10 CFR 50.75(b)(1) and took credit for earnings through the projected decommissioning periods as allowed by 10 CFR 50.75(e)(1)(i). However, in order to show trends using a consistent set of data, the information provided in the tables is based only on the minimum formula amounts in 10 CFR 50.75(c).

Estimated costs to decommission the ISFSIs are not included. Historical information provided in the tables is considered reasonably accurate for trending purposes.

Credit for earnings is taken using a 2% annual real rate of return (RROR) up to the license expiration date in effect at the time of the DFS report, i.e., expected permanent cessation of operations, as allowed by 10 CFR 50.75(e)(1)(i). Additional DFA taking pro-rata credit for earnings during the immediate dismantlement period is not reflected in the projected values.

Observations based on Tables 1-S, 1-HC, and 1-PB:

2008 Fund values significantly decreased due to a historic economic downturn affecting the financial markets. PSEG continued to demonstrate adequate DFA by taking credit for decommissioning period earnings and the funds recovered by the end of 2010.

2012 The projected values of the Salem and Hope Creek funds significantly increased when the renewed licenses were issued in 2011 due to the additional earnings credit for 20 additional years of operations.

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2014 Near the end of their initial 40-year operating terms, Salem units were fully funded -

meaning the amount of funds accumulated in the NDT exceeded the formula amount at that time.

2020 Funds rebounded from early losses due to the effect of the COVID-19 pandemic on the markets, again showing the robustness of the funds against a historic economic downturn. The projected values of the PBAPS Units 2 and 3 funds significantly increased when the subsequent renewed licenses were issued in 2020 due to the earnings credit for 20 additional years of operations. All of the units were fully funded at that time.

2022 Following interim gains in 2021, fund values significantly decreased due to market losses driven by rising consumer-price inflation and interest rates. Despite the losses, adequate DFA was maintained for all of the facilities at years end, once again showing the robustness of the NDT to weather economic downturns and cost increases.

Figures 1-S, 1-HC, and 1-PB are provided at the end of this Enclosure and illustrate the DFA trends from information provided in the tables. The trends clearly show that PSEG has provided significant excess DFA over many years.

The trends further show that if all future earnings from funds in the NDT continue to be dedicated for radiological decommissioning, the projected amount of funds accumulated in the NDT at the start of decommissioning would be significantly greater than the amount needed to provide reasonable assurance that sufficient funds will be available.

Two primary contributing factors to this circumstance are (1) more funds in the NDT have been dedicated for radiological decommissioning than originally intended through the rate-setting process, and (2) actual earnings from funds in the NDT have been accumulated for longer periods than the initial 40-year operating terms assumed when funds for decommissioning were collected.

Amounts originally collected through the rate-setting process for nuclear decommissioning were awarded based on site-specific studies that included the removal of high-level and low-level radioactive waste, as well as the removal of all facilities, and returning the property to a green field condition. The non-bypassable charge component for nuclear decommissioning that was already in effect when ownership of the facilities was acquired had been assessed to assure the required level of funding for decommissioning, including for State obligations (non-radiological),

would be obtained by the end of the initial 40-year operating terms.

However, the distinction between funds collected for radiological decommissioning and funds collected for other decommissioning purposes was not preserved. When funds are commingled in the NDT and not distinctly identified, the NRC considers all funds to be dedicated for radiological decommissioning. This resulted in a greater amount of funds being dedicated for radiological decommissioning than originally intended through the rate-setting process in place prior to acquiring ownership of the facilities.

Since 2003, PSEG has provided DFA consistent with the requirement for merchant plant licensees to meet up-front funding assurance that was established, in part, to mitigate concerns of premature shutdowns (Reference 4). However, the premature shutdown concern

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has not materialized for PSEGs facilities and the NRC has issued renewed licenses for all of the units. Renewed licenses have authorized additional decades of operations to accumulate earnings from NDT funds before the start of decommissioning is expected. With the exception of Hope Creek, actual earnings have already been accumulated over longer periods than the initial 40-year operating terms assumed when funds for decommissioning were collected.

In summary, greater amounts of funds have been dedicated for radiological decommissioning than were originally intended through the rate-setting process because funds for different purposes have been commingled and not distinctly identified in the NDT. Renewed licenses for the facilities have authorized longer times for earnings from funds to grow than the initial 40-year operating terms upon which the collections of funds for decommissioning were based. As a result, PSEG has provided significant excess DFA over many years, which the trends show has increased over time.

2.2 Financial Health

Consistent with Reference 3, the following is a brief discussion on PSEGs financial health.

PSEG Nuclear is a wholly owned subsidiary of PSEG Power LLC (PSEG Power), a Delaware limited liability company formed in 1999 as a result of the deregulation and restructuring of the electric power industry in New Jersey. PSEG Power earns revenues from its nuclear generation and marketing of power and natural gas to hedge business risks and the value of its portfolio of nuclear power plants, other contractual arrangements, and gas storage facilities. PSEG Power has 3761 MW of nuclear generation capacity from its ownership share of Salem, Hope Creek, and PBAPS.

PSEG Power and Public Service Electric and Gas Company (PSE&G) are the two principal direct operating subsidiaries of Public Service Enterprise Group Incorporated, a public utility holding company consisting primarily of a regulated electric and gas utility and a nuclear generation business. Annual, quarterly, and current reports and other information are filed with the U.S. Securities and Exchange Commission (SEC) and are available on the internet at https://www.sec.gov and https://investor.pseg.com.

In August 2022, the Inflation Reduction Act (IRA) was signed into law and established a production tax credit (PTC) for existing nuclear facilities generating electricity to be available from the federal government through at least 2032. For Salem and Hope Creek, revenue from zero emission certificates (ZECs) awarded by the New Jersey Board of Public Utilities (BPU) through May 2025 is expected to be reduced corresponding to the value of the PTC received.

The PTC is expected to provide downside price protection as its value is directly linked to a nuclear facilitys gross receipts. Revenues at the PTC threshold level offer stability that supports long-term growth outlook.

2.3 Structure of the NDT

Consistent with Reference 3, the following is a description of the structure of the NDT.

Under the prepayment method in 10 CFR 50.75(e)(1)(i), PSEG maintains a single NDT to provide funding assurance for radiological decommissioning of the nuclear facilities. The

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overarching requirement in the Trust Agreement is that the trust must be used for the exclusive purpose of providing funds for decommissioning the plants, to pay the administrative costs and other incidental expenses of the trust funds, and to make certain investments. As required by 10 CFR 50.75(h)(1)(iv), the Trust Agreement further limits the use of NDT assets to expenses related to decommissioning of the plants as defined by the NRC in its regulations and issuances, and as provided in the licenses, until completion of decommissioning.

The NDT is segregated into qualified and nonqualified funds, or accounts, for each reactor (unit). The terms qualified and nonqualified are as defined in Section 468A of the Internal Revenue Code. The Trust Agreement requires each account to be separately maintained from other accounts.

Non-50.75 Subaccounts associated with each units qualified and nonqualified accounts have been established within the NDT. The Non-50.75 Subaccounts are intended to accumulate and distinctly identify funds to pay for decommissioning costs as defined in 26 CFR 1.468A-1(b)(6) and not exclusively dedicated for radiologica l decommissioning. Therefore, an amendment to the Trust Agreement, pursuant to 10 CFR 50.75(h)(1)(iii), would be necessary to exclude funds in Non-50.75 Subaccounts from being subject to the NRCs restrictions for funds dedicated for radiological decommissioning in the NDT.

3. BASIS FOR EXEMPTION REQUEST

PSEGs last submitted DFS report under 10 CFR 50.75(f)(1) identified that Non-50.75 Subaccounts had been established within the NDT as of the end of 2022 (Reference 5). The Non-50.75 Subaccounts were not used to account for any NDT funds prior to that date.

The balance of funds in the NDT as of December 31, 2022, was:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Total NDT funds $461,632,945 $389,222,654 $626,864,653 $382,017,447 $377,883,610

The amount of funds in the NDT as of the end of 2022 is analogous to the principal amounts invested. Earnings from funds in 2023 increased the total amount of funds accumulated, and part of the earnings was accounted for in the Non-50.75 Subaccounts for internal accounting purposes. The balance of funds in the NDT as of December 31, 2023, was:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Total NDT funds $530,398,159 $439,014,015 $700,364,565 $437,236,495 $430,254,610 Subaccount funds $35,228,162 $25,410,791 $37,418,173 $28,268,664 $26,782,996 Remaining funds $495,169,997 $413,603,224 $662,946,392 $408,967,831 $403,471,614

Funds accounted for in the Non-50.75 Subaccounts consist entirely of earnings from NDT funds in 2023 and do not include any of the principal amounts invested at the beginning of the year.

The accrual process included transfers of funds between NDT accounts and their associated Non-50.75 Subaccounts shortly after the close of the investment period at the end of the

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calendar year. The purpose of the year-end transfers was to finalize the percentage of earnings accounted for in the subaccounts based on the amount of DFA required and overall fund performance for the year. Transfers made in accordance with the exemption request would be similar. Since the year-end transfers involve only those funds that exist in the NDT as of the end of the calendar year, whether in an account or its associated Non-50.75 Subaccount, the amount of radiological decommissioning funds reported under 10 CFR 50.75(f)(1) would appropriately reflect any year-end transfers.

Earnings from funds, including the portion of earnings accounted for in the Non-50.75 Subaccounts, can be distinctly identified in NDT. With respect to the decommissioning trust provisions in 10 CFR 50.75(h)(1), the NRC has stated it does not object to commingling funds for radiological decommissioning with funds for other purposes in the NDT as long as licensees are able to provide a separate accounting of the amounts dedicated for radiological decommissioning (Reference 6). NRC guidance in Regulatory Issue Summary (RIS) 2001-07, Revision 1 (Reference 7) and Regulatory Guide 1.159, Revision 2 (Reference 8) generally allows the commingling of funds in the NDT provided that the licensee identifies and accounts for the funds dedicated to radiological decommissioning separately from funds set aside for other purposes. However, based on Reference 2 all earnings from NDT funds dedicated for radiological decommissioning are restricted by 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) to being withdrawn only for radiological decommissioning expenses.

The following sections demonstrate that NDT funds accumulated as of December 31, 2023, excluding funds accounted for in Non-50.75 Subaccounts, provided reasonable assurance that sufficient funds for radiological decommissioning will be available when needed.

3.1 DFA using the Formula Amounts in 10 CFR 50.75(c)

Table 2, provided at the end of this Enclosure, shows the amount of DFA provided by funds accumulated in the NDT as of December 31, 2023, excluding funds held in Non-50.75 Subaccounts, plus credit for earnings up to the license expiration dates using a 2% annual RROR and pro-rata credit for earnings during the immediate dismantlement period, as allowed by 10 CFR 50.75(e)(1)(i). The amount of DFA required is based on the formulas in 10 CFR 50.75(c) as of December 31, 2023, pro-rated for PSEGs ownership share.

From Table 2, the amount of DFA provided and the amount of DFA required based on the formulas in 10 CFR 50.75(c) as of December 31, 2023, are approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 DFA provided $704,593,000 $630,407,000 $1,122,993,000 $541,340,000 $543,762,000 DFA required $349,181,000 $349,181,000 $826,987,000 $365,172,000 $365,172,000

The amount of excess DFA provided by NDT funds, excluding credit for funds held in Non-50.75 Subaccounts, based on the formulas in 10 CFR 50.75(c) was approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Excess DFA $355,412,000 $281,226,000 $296,006,000 $176,168,000 $178,590,000 provided

8 LR-N24-0040 Enclosure 1

If the expiration dates for the PBAPS Units 2 and 3 subsequent renewed licenses as issued on March 5, 2020, are used (80-year operating terms), the excess DFA provided for Units 2 and 3 as of December 31, 2023, increases to approximately $452.3 million and $455.9 million, respectively, due to earnings credit for 20 additional years of operations (refer to Table 2).

The results demonstrate that the funds accumulated in the NDT as of December 31, 2023, excluding funds in the Non-50.75 Subaccounts, provided reasonable assurance at that time that sufficient funds will be available to decommission the facilities based on the formula amounts in 10 CFR 50.75(c). The surplus in DFA provided is more than sufficient to provide reasonable assurance of funding for the estimated costs to decommission the ISFSIs.

3.2 DFA using SSDCEs

PSEG anticipates using the SAFSTOR method to decommission the facilities. Under SAFSTOR, a facility is placed in a safe storage condition for an extended period. Radioactive decay occurs during the safe storage period, reducing the quantity of contaminated and radioactive material that must be disposed of during subsequent decontamination and dismantlement of the facility after the end of the storage period.

Tables 3-S1, 3-S2, 3-HC, 3-PB2, and 3-PB3, provided at the end of this Enclosure, show the annual decommissioning cash flow analyses based on the SAFSTOR SSDCEs for each facility, prepared in 2021. The SSDCEs, provided in Attachments 1, 2, and 3 to the letter, include information relevant to the SAFSTOR method that has been extracted from the full reports.

The cash flow analyses include only the radiological decommissioning expenses that are allowed to be withdrawn under 10 CFR 50.82(a)(8). Costs are pro-rated for PSEGs ownership share and escalated to December 2023 dollars. An escalation factor of 1.128 was calculated using Consumer Price Index (CPI) data for services in U.S. city average, all urban consumers, not seasonally adjusted (Series ID CUUR0000SAS), consistent with Regulatory Guide 1.159 (Reference 8). Thereafter, a 0% cost escalation factor was used. The total escalated cost for radiological decommissioning of each facility is greater than the amount based on the generic formulas in 10 CFR 50.75(c), as required by 10 CFR 50.75(b)(1). Radiological decommissioning is projected to be completed within 60 years of expected permanent cessation of operations in accordance with 10 CFR 50.82(a)(3).

As previously discussed, the balance of funds in the NDT, excluding funds held in Non-50.75 Subaccounts, as of December 31, 2023, was:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Fund balances $495,169,997 $413,603,224 $662,946,392 $408,967,831 $403,471,614

Starting fund balances in the cash flow analyses exclude any credit for funds held in Non-50.75 Subaccounts as of December 31, 2023. Credit is taken for projected earnings on funds using a 2% annual RROR up to the license expiration date and through the decommissioning period, as allowed by 10 CFR 50.75(e)(1)(i). Earnings on funds conservatively assumes all costs for the year are incurred at the beginning of the year. The analyses assume no future contributions to the NDT.

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The results of the decommissioning cash flow analysis for each unit are summarized in the following table.

Table 3-Summary Summary of Annual SAFSTOR Decommissioning Cash Flow Analyses (2023 dollars)

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Reference Table Table 3-S1 Table 3-S2 Table 3-HC Table 3-PB2 Table 3-PB3 Permanent cessation August 13, 2036 April 18, 2040 April 11, 2046 August 8, 2033 July 2, 2034 of operations Projected funds at $603,609,000 $567,789,000 $985,103,000 $469,775,000 $472,731,000 start of analysis using a 2% annual RROR Radiological $518,809,000 $511,616,000 $1,223,436,000 $474,282,000 $501,614,000 decommissioning cost (SSDCE)

Decommissioning $1,146,189,000 $905,700,000 $1,732,987,000 $836,219,000 $804,678,000 period earnings using a 2% annual RROR Projected surplus of $1,230,989,000 $961,873,000 $1,494,654,000 $831,712,000 $775,795,000 funds at completion of decommissioning

Tables 3-PB2-SLR and 3-PB3-SLR, provided at the end of this Enclosure, show the annual decommissioning cash flow analyses if the expiration dates for the PBAPS Units 2 and 3 subsequent renewed licenses as issued on March 5, 2020, are used (80-year operating terms),

excluding funds in Non.50.75 Subaccounts as of December 31, 2023. Due to credit for earnings for 20 additional years of operations, the projected funds at the start of the analyses for Units 2 and 3 increase to approximately $698.1 million and $702.5 million, respectively. Consequently, the projected surpluses at the completion of radiological decommissioning increase to approximately $1.627 billion and $1.560 billion, respectively.

The cash flow analyses demonstrate the funds accumulated in the NDT, excluding funds in Non-50.75 Subaccounts, as of December 13, 2023, provided reasonable assurance at that time that sufficient funds for radiological decommissioning will be available when needed.

3.3 Sensitivity Analyses Assuming 0% Annual RROR During Operations

Sensitivity analyses were performed using the same SAFSTOR decommissioning cash flow analyses as described in the previous section with the exception of taking credit for earnings on NDT funds during operations using a 0% annual RROR.

When the NRC proposed to allow licensees to take credit for earnings on NDT funds, it considered the 2% RROR default earnings rate in the regulations to be as close to a risk free return as possible that can be consistently achieved with confidence (Reference 9). The NRC

10 LR-N24-0040 Enclosure 1

also stated that an assumption of a zero rate of return is too conservative and not supported by the data.

Tables 3-S1-0, 3-S2-0, 3-HC-0, 3-PB2-0, and 3-PB3-0, provided at the end of this Enclosure, present the sensitivity analysis for each unit.

Expected dates for permanent cessation of operations are the same as in the previous section.

However, due to the assumption of 0% earnings on funds during operations, the projected starting balances of funds for the sensitivity cash flow analyses are the same as the balances of funds, excluding funds in Non-50.75 Subaccounts, as of December 31, 2023.

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Projected funds at $495,169,997 $413,603,224 $662,946,392 $408,967,831 $403,471,614 start of analysis using a 0% annual RROR

Radiological decommissioning costs for the facilities used for the sensitivity analyses are the same as those used for the cash flow analyses described in the previous section and are approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Radiological $518,809,000 $511,616,000 $1,223,436,000 $474,282,000 $501,614,000 decommissioning cost (SSDCE)

Same as the cash flow analyses discussed in the previous section, credit for earnings during the decommissioning periods is calculated using a 2% annual RROR and all costs for the year are conservatively assumed to be incurred at the beginning of the year. Earnings during the decommissioning periods and the projected surpluses of funds at completion of radiological decommissioning in 2023 dollars are approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Reference Table Table 3-S1-0 Table 3-S2-0 Table 3-HC-0 Table 3-PB2-0 Table 3-PB3-0 Decommissioning $810,514,000 $583,177,000 $844,788,000 $630,200,000 $584,241,000 period earnings using a 2% annual RROR Projected surplus of $786,875,000 $485,164,000 $284,299,000 $564,885,000 $486,098,000 funds at completion of decommissioning

For PBAPS Units 2 and 3, if the expiration dates for the subsequent renewed licenses as issued on March 5, 2020, are used (80-year operating terms), the projected starting balances for the sensitivity analyses would be the same as for the 60-year terms only shifted by 20 years. Thus, the projected surpluses at completion of radiological decommissioning would be the same.

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The sensitivity cash flow analyses project large surpluses in NDT funds at the completion of radiological decommissioning, excluding credit for funds held in Non-50.75 Subaccounts as of December 31, 2023. By assuming an overly conservative 0% annual RROR on the remaining funds in the NDT during operations, the results indicate that a substantial part of the projected earnings from NDT funds during operations can be transferred into Non-50.75 Subaccounts while the remaining NDT funds provide reasonable assurance that sufficient funds will be available for radiological decommissioning when needed. This remains valid whether actual earnings on NDT funds are greater or less than the 2% annual RROR default rate used in the regulations.

3.4 Exemption Request Considerations

Funds accumulated in Non-50.75 Subaccounts would be used to pay for activities that are not restricted to radiological decommissioning. The requested exemptions would allow PSEG to periodically transfer earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts without prior NRC notification in accordance with the following proposed conditions. Funds dedicated for radiological decommissioning in the NDT are herein referred to as RD funds and exclude funds held in the Non-50.75 Subaccounts.

1. Transfers are limited to earnings from RD funds as determined by an increase in the amount of RD funds accumulated since the last decommissioning funding status (DFS) report submitted under 10 CFR 50.75(f)(1).

2. At the time of the transfer, the amount of DFA provided by the remaining RD funds using the prepayment method in 10 CFR 50.75(e)(1)(i) must exceed the amount of DFA required by 10 CFR 50.75(b) and (c) for the associated station by at least $100 million (nominal dollars).

3. DFS reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into Non-50.75 Subaccounts since the last submitted report.

4. The exemptions would cease to be effective on an individual reactor basis once the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1)(i) and (ii) have been submitted.

The following provides additional explanation regarding the proposed conditions.

The first condition restricts transfers to actual earnings from RD funds. No transfers can be made if the value of the RD funds has decreased since the last submitted DFS report. The amount of RD funds reported is expected to generally increase over time unless affected by market conditions. Investment losses are expected to reduce the value of all funds in the NDT, so the percentages of losses for an RD funds account and its associated Non-50.75 Subaccount would be approximately the same, accounting for allowed expenses. Funds held in a Non-50.75 Subaccount would not be transferred to its associated RD funds account to make up for investment losses unless necessary to provide adequate DFA. Subsequent earnings from funds held in Non-50.75 Subaccounts are distinct from earnings from RD funds and would be accumulated within the segregated subaccounts.

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The second condition restricts the amount of earnings from RD funds that can be transferred into Non-50.75 Subaccounts to ensure that funds transferred are not necessary to meet the amount of DFA required at that time. Transfers are only allowed if, at the time of the transfer, DFA provided by the remaining RD funds plus credit for earnings on those funds as allowed by 10 CFR 50.75(e)(1)(i) exceeds the amount of DFA required for the associated station.

Maintaining excess DFA at the time of the transfer will reduce vulnerability to volatile market conditions and other factors that are not within the ability of PSEG to control.

The minimum excess DFA required at the time of the transfer is $100 million for the associated station, i.e., Salem Units 1 and 2 (total), Hope Creek, or PBAPS Units 2 and 3 (total). However, if a Salem or PBAPS unit has permanently ceased operations then the minimum excess DFA required for the remaining operating unit is reduced to $50 million. The amount is specified in nominal dollars to simplify the process for verify ing the condition is satisfied. Earnings from RD funds that are not needed to meet the minimum excess DFA requirement at the time of the transfer are considered excess earnings.

During operations, if the DFA provided is based on a SSDCE under 10 CFR 50.75(b)(1), then the amount of DFA required may be more, but not less, than the formulas in 10 CFR 50.75(c).

The generic formulas provide amounts such that when the preliminary SSDCE is required by 10 CFR 50.75(f) about 5 years prior to the projected end of operations, most of the funds necessary to cover the estimated cost for radiological decommissioning should have been accumulated and there is sufficient time to adjust funding levels, if needed, before decommissioning starts.

The exemption request does not involve any changes to the 10 CFR 50.75(e)(1) provisions allowing credit for earnings on NDT funds using up to a 2% annual RROR and to use actual earnings on existing funds to calculate future fund needs. Financial assurance methods other than prepayment, for example a parent company guarantee, are excluded when calculating the amount of DFA provided for this condition.

The third condition will allow periodic transfers made in accordance with the exemption request to be monitored by the NRC. The reporting requirements in 10 CFR 50.75(f)(1) allow the status of funding for radiological decommissioning to be continually monitored by the NRC.

The fourth condition clarifies the exemptions will cease to be effective for each reactor upon transitioning from operations to decommissioning status. Thereafter, no further transfers would be allowed for that unit.

3.5 Use of Funds in Non-50.75 Subaccounts

Non-50.75 Subaccounts funds would be used to pay for decommissioning costs as defined in 26 CFR 1.468A-1(b)(6), subject to other applicable requirements including the Trust Agreement.

The definition of decommissioning costs in 26 CFR 1.468A-1(b)(6) forms the basis for a large portion of the Treasury Departments rulemaking regarding Section 468A of the Internal Revenue Code and forms the bulk of the basis for its regulations (Reference 10). As decommissioning activity increases and technologies change, the Treasury Department determined that additional guidance was needed to address withdrawals from the NDT to cover

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new costs and cost categories that may arise for the purposes of decommissioning. For example, the accumulating amounts of spent nuclear fuel and the ongoing lack of a federal repository for that fuel have resulted in the need for plant owners to store spent fuel in ISFSIs that was not anticipated when previous Treasury Department regulations were issued.

Funds accumulated in Non-50.75 Subaccounts are not intended to be subject to the restrictions in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for the use of RD funds. Funds accumulated in Non-50.75 Subaccounts would be used to pay for activities that are part of the larger decommissioning process at any time during operations or decommissioning. Such activities include transferring and safely storing spent fuel at the ISFSIs and decontamination, removal, and disposal of radioactive components, which are under the regulatory authority of the NRC. Allowing funds to be used for these expenses would more accurately reflect the current environment in which a permanent federal repository for spent fuel does not exist and PSEG is required to provide long-term storage for spent fuel in the ISFSIs. The need to remove and dispose of radioactive components during the extended terms of the renewed operating licenses is reasonably expected.

During decommissioning, funds in Non-50.75 Subaccounts would be available, but not dedicated, for radiological decommissioning. Non-50.75 Subaccount funds could also be used to show funding for managing irradiated fuel during decommissioning, for which licensees for decommissioning reactor facilities have requested exemptions from the same regulations (see Section 6 below).

4. ADJUSTING REQUIRED DFA AND FUNDING LEVELS

During operations, the amount of DFA required will be determined annually in accordance with 10 CFR 50.75(b) and (c). While the reactors are operating, using the formula amounts adequately provides early indication of a potentia l or actual funding deficiency. PSEG does not intend to rely on SSDCEs in lieu of the generic formula amounts. However, if a SSDCE is relied upon to provide DFA or is required to be submitted by the regulations, then the amount of DFA required is determined by the SSDCE and must be at least equal to the generic formula amount in 10 CFR 50.75(c). Any SSDCE relied upon will be adjusted consistent with the guidance in Regulatory Guide 1.159 (Reference 8).

The amount of DFA required must be covered by one or more of the financial assurance methods described in 10 CFR 50.75(e)(1). The amount of DFA provided using the prepayment method will include the amount of RD funds and credit for earnings on RD funds using a 2%

annual RROR and credit for earnings during decommissioning as allowed by 10 CFR 50.75(e)(1)(i), excluding any credit for funds held in Non-50.75 Subaccounts. The requested exemptions would not invalidate the underlying assumptions that support using the 2% annual RROR default earnings rate in the regulations. If the exemptions are granted, taking credit for earnings on RD funds using a 2% annual RROR and using actual earnings on existing RD funds to determine future fund needs as allowed by 10 CFR 50.75(e)(1)(i) will continue to be appropriate. PSEG will continue to rely on part of the earnings from RD funds to increase the amount of RD funds accumulated to account for expected inflation in decommissioning costs.

Consistent with guidance in RIS 2001-07 Revision 1 (Reference 7), funds held in Non-50.75 Subaccounts will not be included with the amount of funds dedicated for radiological decommissioning reported under 10 CFR 50.75(f)(1).

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As clarified in Regulatory Guide 1.159 (Reference 8), Regulatory Position 2.1.5, the NRC interprets the requirements in 10 CFR 50.75 to mean that, for licensees who are no longer rate-regulated or do not have access to a non-bypassable charge, a shortfall in DFA identified in a DFS report submitted pursuant to 10 CFR 50.75(f)(1) must be corrected by the time the next report is due. PSEG is obligated to comply with applicable regulations.

About 5 years prior to the projected end of operations, 10 CFR 50.75(f) requires the submittal of a preliminary SSDCE which includes an up-to-date assessment of the major factors that could affect the cost to decommission. The generic formula in 10 CFR 50.75(c) provides an amount such that when the preliminary SSDCE is required, most of the funds necessary to cover the estimated cost to decommission the facilities should have been accumulated and there is sufficient time for funding levels to be adjusted if needed before decommissioning starts. Prior to or within 2 years following permanent cessation of operations, 10 CFR 50.82(a)(4)(i) requires the submittal of a post-shutdown decommissioning activities report (PSDAR) that includes a SSDCE. Submittals of SSDCEs when required by the regulations will ensure that the amount of DFA provided will be appropriately adjusted.

Consistent with Reference 3, the following is a brief discussion on additional funding methods that could be made available to cover potential future shortfalls in the NDT.

In accordance with 10 CFR 50.75, if the NDT is not sufficiently funded, as identified in a DFS report submitted under 10 CFR 50.75(f)(1), then additional funding assurance will be provided to make up the shortfall by the time the next report is due. Additional funding assurance will be provided using one or more of the methods described in 10 CFR 50.75(e)(1) and the guidance in Regulatory Guide 1.159 (Reference 8). Additional funding methods that could be made available include:

• Funds held in Non-50.75 Subaccounts would be readily available to be transferred to their associated RD funds account without prior approval (or subject to disapproval) by a State regulatory authority, thereby dedicated for radiological decommissioning as prepaid funds under 10 CFR 50.75(e)(1)(i).

• Generation of electric energy from PSEGs operating nuclear plants provides a source of revenue for cash injections to the NDT as prepaid funds under 10 CFR 50.75(e)(1)(i).

• PSEGs parent company meets Financial Test A.2 in Appendix A to 10 CFR Part 30 for providing a guarantee in an amount that would be a significant part of the required amount of funding, pursuant to 10 CFR 50.75(e)(1)(iii).

5. JUSTIFICATION FOR EXEMPTIONS AND SPECIAL CIRCUMSTANCES

Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of 10 CFR Part 50 which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The Commission will not consider granting an exemption unless special circumstances are present.

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5.1 Exemptions

Pursuant to 10 CFR 50.12(a)(1), the exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security, as discussed below.

A. The exemptions are authorized by law

The requested exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would allow PSEG to periodically transfer earnings from funds dedicated for radiological decommissioning in the NDT into Non-50.75 Subaccounts to pay for activities that are part of the larger decommissioning process and not restricted to radiological decommissioning without prior notification to the NRC, in the same manner that withdrawals are made under 10 CFR 50.82(a)(8). 10 CFR 50.12 allows the NRC to grant exemptions from the requirements of 10 CFR Part 50. The proposed exemptions would not result in a violation of the Atomic Energy Act of 1954, as amended, or the NRCs regulations. The NRC has granted exemptions to other 10 CFR Part 50 licensees to use funds in the NDT for purposes other than radiological decommissioning (see Section 6). The NRC has issued draft interim staff guidance that addresses establishing subaccounts in existing NDTs to pay for decommissioning activities other than radiological decommissioning and requesting exemptions under 10 CFR 50.12 to fund the subaccounts using NDT funds dedicated for radiological decommissioning (Reference 3). Therefore, the exemptions are authorized by law.

B. The exemptions will not present an undue risk to public health and safety

The underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) is to provide reasonable assurance that adequate funds will be available for radiological decommissioning of power reactors. Supported by analyses based on the formulas in 10 CFR 50.75(c) and cash flow analyses based on SSDCEs under 10 CFR 50.75(b)(1), the transfer of a portion of the funds accumulated in the NDT as of December 31, 2023, into the Non-50.75 Subaccounts, as identified in the exem ption request, to be used for activities that are part of the larger decommissioning process and not dedicated for radiological decommissioning will not adversely impact PSEGs ability to complete decommissioning within 60 years of permanent cessation of operations and terminate the licenses.

PSEG has proposed conditions for periodic trans fers of earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts in accordance with the exemption request. These conditions limit periodic transfers to earnings from funds dedicated for radiological decommissioning and ensure that the amount of those funds remaining in the NDT exceed the amount required by 10 CFR 50.75(b) and (c) at the time of the transfer. The amount of excess DFA required to be provided at the time of the transfer is at least $100 million (nominal dollars) for the associated station. Thus, at the time of the transfer, reasonable assurance will be provided that sufficient funds will be available for radiological decommissioning when needed at permanent cessation of operations.

As part of rulemaking for Financial Assurance Requirements for Decommissioning Nuclear Power Reactors (Reference 9), the proposed action to allow licensees to take credit for

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earnings on NDT funds from the time of collection through the decommissioning period along with the reporting requirements in 10 CFR 50.75(f)(1) was determined to provide licensees relief from the existing requirements with no adverse impact on public health and safety. The requested exemptions would not change the basis for this determination since periodic transfers made in accordance with the exemption request would not involve any funds needed at the time of the transfer to demonstrate reasonable assurance of funding.

Part of the earnings will remain dedicated for radiological decommissioning as necessary to ensure that RD funds will continue to be accumulated as needed to meet reasonable assurance of funding and to account for expected inflation in decommissioning costs.

Furthermore, an exemption from 10 CFR 50.75(h)(1)(iv) to allow periodic transfers to be made without prior written notification to the NRC will not affect the sufficiency of funds remaining in the NDT to accomplish radiological decommissioning because such transfers are constrained by the proposed conditions for the exemption request. If the exemptions are granted, reasonable assurance of funding would be provided by compliance with the regulations, as exempted. PSEG has proposed an additional condition for the exemption request that DFS reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into the Non-50.75 Subaccounts since the last submitted report. This condition will allow periodic transfers made in accordance the exemptions to be monitored by the NRC. The requested exemptions would not affect the existing reporting requirements in 10 CFR 50.75(f)(1) that allow the status of funding for radiological decommissioning to be continually monitored by the NRC and provide the NRC with awareness of, and the ability to act on, any actual or potential funding deficiencies.

The exemptions would no longer be in effect on an individual reactor basis once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1)(i) and (ii) have been submitted.

Thereafter, no further transfers would be allowed for that unit. During decommissioning, funds in the Non-50.75 Subaccounts would be available, but not exclusively dedicated, for radiological decommissioning.

For the reasons above, the proposed exemptions will not present an undue risk to the public health and safety due to insufficient funds for radiological decommissioning.

The requested exemptions do not involve any physical changes to the facilities or changes to any procedures governing operation of the facilities, therefore the exemptions do not involve a significant increase in the probability or consequences of radiological accidents, and do not create the possibility of a new or different kind of accident. The requested exemptions do not alter the design basis or any safety limits for the facilities, or any structures, systems, and components relied upon for accident mitigation or physical security, and therefore do not involve a significant reduction in a margin of safety. The requested exemptions have no direct radiological impacts and do not result in any changes in the types or amounts of effluents released offsite resultin g from the exemptions, and therefore will not result in a significant increase to occupational or public doses.

Therefore, for all these reasons, the proposed exemptions will not present an undue risk to the public health and safety.

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C. The exemptions are consistent with the common defense and security

The requested exemptions would allow PSEG to periodically transfer part of the earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts. Funds accumulated in the Non-50.75 Subaccounts would not be dedicated for radiological decommissioning and would be used for activities that are part of the larger decommissioning process at any time during operations or decommissioning. Such activities include transferring and safely storing spent fuel at the general licensed ISFSIs and decontamination, removal, and disposal of radioactive components, which are under the regulatory authority of the NRC. The proposed exemptions will not adversely affect PSEGs ability to physically secure the sites and facilities and to protect special nuclear material.

Periodic transfers under the requested exemptions have no relation to security issues and will not alter the scope or availability of sufficient funding for the security programs for the sites. Therefore, the exemptions are consistent with the common defense and security.

5.2 Special Circumstances

Pursuant to 10 CFR 50.12(a)(2), the Commission will not consider granting an exemption unless special circumstances are present. PSEG has determined that special circumstances are present as discussed below.

A. Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule (10 CFR 50.12(a)(2)(ii))

The requirements in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) restrict withdrawals from NDTs to expenses for radiological decommissioning activities until final radiological decommissioning has been completed. The underlying purpose of the regulations is to provide reasonable assurance that adequate funds will be available for radiological decommissioning of the facilities and termination of the licenses. Strict application of these requirements would prohibit the use of funds from PSEGs NDT for activities other than radiological decommissioning, such as for spent fuel management and decontamination and disposal of radioacti ve components during operations, until final radiological decommissioning at the facilities has been completed.

The requested exemption would allow PSEG to periodically transfer earnings from funds dedicated for radiological decommissioning in the NDT into Non-50.75 Subaccounts established within the NDT. Funds held in the separately maintained Non-50.75 Subaccounts are intended to pay for activities that are part of the larger decommissioning process and not exclusively dedicated for radiological decommissioning. Such activities include transferring and safely storing spent fuel at the general licensed ISFSIs and decontamination, removal, and disposal of radioactive components during operations, which are under the regulatory authority of the NRC.

As described in Section 3, the balance of funds in the NDT as of December 31, 2023, for each reactor was:

18 LR-N24-0040 Enclosure 1

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Total balance $530,398,159 $439,014,015 $700,364,565 $437,236,495 $430,254,610 Balance of Non-50.75 $35,228,162 $25,410,791 $37,418,173 $28,268,664 $26,782,996 Subaccounts Excluding Non-50.75 $495,169,997 $413,603,224 $662,946,392 $408,967,831 $403,471,614 Subaccounts

The internal accounting for funds in the Non-50.75 Subaccounts was consistent with the exemption request. Funds accounted for in Non-50.75 Subaccounts are comprised entirely of earnings from NDT funds in 2023. Analyses based on the generic formulas in 10 CFR 50.75(c) and annual decommissioning cash flow analyses based on SSDCEs under 10 CFR 50.75(b)(1) for each reactor demonstrate that the amount of funds accumulated in the NDT as of December 31, 2023, excluding funds accounted for in the Non-50.75 Subaccounts, provided reasonable assurance at that time of sufficient funding for radiological decommissioning. Completion of radiological decommissioning for each reactor is projected within 60 years of permanently ceasing operations in accordance with 10 CFR 50.82(a)(3).

Based on the formulas in 10 CFR 50.75(c), pr o-rated for PSEGs ownership share, the amount of DFA provided by funds in the NDT as of December 31, 2023, excluding funds in Non-50.75 Subaccounts, taking credit for earnings as allowed by 10 CFR 50.75(e)(1)(i), was approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 DFA provided $704,593,000 $630,407,000 $1,122,993,000 $541,340,000 $543,762,000 Formula amount in $349,181,000 $349,181,000 $826,987,000 $365,172,000 $365,172,000 10 CFR 50.75(c)

The decommissioning cash flow analyses based on SSDCEs for each of the facilities (escalated to 2023 dollars), with the license expiration date as the expected date of permanent cessation of operations, assume a 2% annual RROR on the NDT balance, excluding funds held in Non-50.75 Subaccounts, as allowed by 10 CFR 50.75(e)(1)(i), and conservatively assuming all costs for the year are incurred at the beginning of the year. The cash flow analyses project the amount of funds remaining in the NDT at completion of radiological decommissioning are approximately:

Salem 1 Salem 2 Hope Creek PBAPS 2 PBAPS 3 Projected surplus of $1,230,989,000 $961,873,000 $1,494,654,000 $831,712,000 $775,795,000 funds at completion of decommissioning

PSEG has proposed conditions for periodic trans fers of earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts to be made in accordance with the exemption request. The conditions will limit periodic transfers to earnings from funds and ensure that funds in the NDT, excluding funds in Non-50.75 Subaccounts, provide DFA using the prepayment method in 10 CFR 50.75(e)(1)(i) in an amount that exceeds the amount required by 10 CFR 50.75(b) and (c) by at least $100

19 LR-N24-0040

million (nominal dollars) for the associated station at the time of the transfer. Thus, the periodic transfers will not adversely affect reasonable assurance that sufficient funds will be available for radiological decommissioning at permanent cessation of operations.

In addition, the requested exemptions will not in hibit PSEGs ability to correct any shortfalls in the NDT identified in a DFS report by the time the next report is due, as required by 10 CFR 50.75. Options to provide additional funding assurance include transferring funds held in the Non-50.75 Subaccounts into the associated RD funds accounts thereby dedicating the funds for radiological decommissioning, cash injections to the NDT available from revenue from the generation of electric energy from PSEGs operating nuclear plants, and the ability of PSEGs parent company to provide a guarantee under Appendix A to 10 CFR Part 30 pursuant to 10 CFR 50.75(e)(1)(iii).

Based on the analyses provided and the proposed conditions for the exemption request, PSEG concludes that strict application of the requirements in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) restricting the use of NDT funds to radiological decommissioning expenses is not necessary to achieve the underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) to restrict withdraw als from NDTs to expenses for radiological decommissioning activities.

PSEG also requests exemption from the requirement in 10 CFR 50.75(h)(1)(iv) to provide prior notification to the NRC for periodic transfers made in accordance with the exemption request. The underlying purpose of notifying the NRC prior to the use of funds from the NDT is to provide opportunity for NRC intervention, when deemed necessary, if their use is for expenses other than those authorized by 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) that could result in there being insufficient funds in the NDT to complete radiological decommissioning of the facilities.

As a condition of the exemption request, PSEG proposes that decommissioning funds status reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into the Non-50.75 Subaccounts since the last submitted report. If the exemptions are granted, then NRC approval of the exemption request serves as advance notice to the NRC of periodic transfers made in accordance with the exemptions. Applying the prior notification requirement in 10 CFR 50.75(h)(1)(iv) to each periodic transfer would duplicate the proposed condition and is not necessary to achieve the underlying purpose of the regulation. The requested exemptions, if granted, would not allow NDT funds to be used for any other purpose that is not currently authorized in the regulations without prior notification to the NRC. In addition, the existing reporting requirements in 10 CFR 50.75(f)(1) allow the status of funding for radiological decommissioning to be continually monitored by the NRC and provide the opportunity for the NRC to take appropriate actions. The requested exemption does not change the 10 CFR 50.75 requirement that any shortfall in funding assurance identified in a report submitted pursuant to 10 CFR 50.75(f)(1) must be corrected by the time the next report is due.

Therefore, since the underlying purpose of the rule would be achieved while allowing periodic transfers to be made without prior notification to the NRC in accordance with the exemption request, the special circumstances of 10 CFR 50.12(a)(2)(ii) are present.

20 LR-N24-0040

B. Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated (10 CFR 50.12(a)(2)(ii))

The NRC did not intend to prevent the use of NDT funds for purposes other than radiological decommissioning solely because the funds are commingled. To do so would create an unnecessary financial burden without any corresponding safety benefit. The NRC does not preclude use of funds from the NDT in excess of those needed for radiological decommissioning for purposes other than radiological decommissioning.

Funds in Non-50.75 Subaccounts would not be dedicated for radiological decommissioning and would be used to pay for decommissioning costs as defined at 26 CFR 1.468A-1(b)(6) in the Treasury Department regulations for Section 468A of the Internal Revenue Code. This definition includes costs for radiological and non-radiological activities and certain spent fuel management activities whether the plant is operating or has permanently ceased operations. Thus, the funds would be used to pay for activities that are part of the larger decommissioning process that include transferring and safely storing spent fuel at the ISFSIs and decontamination, removal, and disposal of radioactive components, which are under the regulatory authority of the NRC.

With respect to the decommissioning trust provisions in 10 CFR 50.75(h), the NRC has stated it does not object to commingling funds for radiological decommissioning with funds in the NDT for other purposes as long as licensees are able to provide a separate accounting of the amounts dedicated for radiological decommissioning (Reference 6). NRC guidance in RIS 2001-07, Revision 1 (Reference 7) and Regulatory Guide 1.159, Revision 2 (Reference 8) generally allows the commingling of funds in the NDT provided that the licensee identifies and accounts for the funds dedicated to radiological decommissioning separately from funds set aside for other purposes.

In response to comments received during the rulemaking for the Decommissioning Trust Provisions in 10 CFR 50.75(h) that the restrictions should not apply to funds held in the NDT for purposes other than radiological decommissioning, the Commission stated it does not object to commingling of funds and that withdrawals for purposes that do not affect the amount of radiological decommissioning funds remaining in the NDT are not covered by the rule, as long as licensees can provide an accounting showing the amount of funds dedicated to radiological decommissioning in the NDT separate from funds for other purposes (Reference 6). The Commission further stated that it appreciates the benefits that some licensees may derive from using their NDT funds for all of their decommissioning costs but must be able to identify the individual amounts contained within the NDT.

The analyses based on the formulas in 10 CFR 50.75 and the decommissioning cash flow analyses based on site-specific decommissioning cost estimates demonstrate the ability of the funds accumulated in the NDT as of December 31, 2023, excluding funds accounted for in the Non-50.75 Subaccounts, to provide reasonable assurance that sufficient funds will be available to pay for radiological decommissioning costs at expected permanent cessation of operations. For future periodic transfers, PSEG has proposed conditions for the exemption request that would restrict periodic transfers to earnings from NDT funds, require funding

21 LR-N24-0040

assurance at the time of the transfer greater than required by the regulations, and require reports submitted under 10 CFR 50.75(f)(1) to include the amount of funds transferred into Non-50.75 Subaccounts. The proposed conditions ensure the periodic transfers will not adversely affect the ability of the NDT to provide the required funding assurance.

Additionally, the use of Non-50.75 Subaccounts provides a means to distinctly identify and account for funds dedicated for radiological decommissioning, i.e., NDT funds excluding the Non-50.75 Subaccounts.

If PSEG cannot use funds accumulated in the Non-50.75 Subaccounts for their intended purpose, it would need to obtain additional funds to pay for activities that would not be recoverable from the NDT or modify operations at the facilities to avoid or delay such costs until final radiological decommissioning has been completed. The current environment in which a permanent federal repository for spent fuel does not exist requires PSEG to provide long-term storage for spent fuel in the on-site independent spent fuel storage installations.

Not granting the requested exemptions to PSEG would impose costs in excess of those incurred by other 10 CFR Part 50 licensees that have requested and been granted exemptions from these regulations for similar purposes (see Section 6). The need to remove and dispose of radioactive components during the extended terms of the renewed operating licenses is reasonably expected. The analyses demonstrate there are sufficient funds in the NDT to pay for decommissioning activities other than radiological decommissioning and to provide reasonable assurance that sufficient funds for radiological decommissioning will be available. Therefore, preventing the use of these funds in the NDT would impose an unnecessary and undue burden in excess of that contemplated when the regulation was adopted without any corresponding safety benefit.

Therefore, strict compliance with the rule would result in an undue hardship or other costs that are significantly in excess of those contemplated when the regulations were adopted, or that are significantly in excess of those incurred by others similarly situated, and the special circumstances of 10 CFR 50.12(a)(2)(iii) are present.

6. PRECEDENT

The proposed exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are in many respects similar to exemptions the NRC ha s recently granted for 10 CFR Part 50 power reactor facilities transitioning to or in decommissioning to allow funds in their NDTs to be used for spent fuel management and site restoration activities. Exemptions have been granted under the provisions of 10 CFR 50.12 and based on a determination of reasonable assurance that, even after the proposed withdrawals of funds, sufficient funding will remain available to complete radiological decommissioning. This determination has typically been based on a decommissioning cash flow analysis based on a SSDCE that includes a safe storage period up to 60 years after permanent cessation of operations.

Specifically, the NRC has granted exemptions al lowing funds in an NDT to be used for purposes other than radiological decommissioning for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Reference 11), Duane Arnold Energy Center (Reference 12), Indian Point Nuclear Generating Station, Unit Nos. 1, 2 and 3 (Reference 13), Palisades Nuclear Plant (Reference 14), Three Mile Island Station, Unit 1 (Reference 15), and Kewaunee Power Station (Reference 16). The NRC also recently granted exemptions for Maine Yankee Atomic Power Station (Reference 17)

22 LR-N24-0040

to allow the transfer of excess funds from a segregated account for ISFSI radiological decommissioning into its overall NDT to pay for activities including spent fuel management and site restoration, and for transfers to be made on an annual basis without prior NRC notification.

This exemption request is informed by draft NRC Interim Staff Guidance on the use of NDT funds during operations (Reference 3). The draft guidance addresses requesting exemptions from the NRCs regulations for the purpose of funding subaccounts in the NDT to pay for decommissioning activities other than radiological decommissioning.

7. ENVIRONMENTAL ASSESSMENT

Pursuant to 10 CFR 51.21, the following environmental considerations are provided.

1. Description of the Proposed Action

The proposed action would partially exempt PSEG from meeting the requirements in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Salem Generating Station (Salem)

Units 1 and 2, Hope Creek Generating Station (Hope Creek), Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and the associated general licensed Independent Spent Fuel Storage Installations (ISFSIs). Specifically, the proposed action would allow PSEG to periodically transfer earnings from funds dedicated for activities that fall within the definition of decommission in 10 CFR 50.2 (radiological decommissioning) in the Nuclear Decommissioning Trust (NDT) into subaccounts established in the NDT (Non-50.75 Subaccounts) to pay for activities that are part of the larger decommissioning process and not restricted to radiological decommissioning. Funds in the Non-50.75 Subaccounts would be excluded from the NRCs requirements for funds dedicated for radiological decommissioning in the NDT. The proposed action would also exempt PSEG from the requirements in 10 CFR 50.75(h)(1)(iv) for prior notification to the NRC for periodic transfers made in accordance with the exemption request.

2. Need for the Proposed Action

The purpose of the Non-50.75 Subaccounts is to separately account for funds accumulated in the NDT to pay for decommissioning costs as by the Treasury Department regulations implementing Section 468A of the Internal Revenue Code. Specifically, 26 CFR 1.468A-1, Nuclear decommissioning costs; general rules, paragraph (b)(6), defines decommissioning costs to include costs for radiological and non-radiological activities and certain spent fuel management activities whet her the plant is operating or has permanently ceased operations.

10 CFR 50.82(a)(8)(i)(A) states that NDT funds may be used if the withdrawals are for expenses for activities consistent with the definition of decommission in 10 CFR 50.2. As defined in 10 CFR 50.2, decommission means to remove a facility or site safely from service and reduce residual radioactivity to a level that permits (1) release of the property for unrestricted use and termination of the license or (2) release of the property under restricted conditions and termination of the license. Funds in the Non-50.75 Subaccounts would be used to pay for activities that do not fall under this definition. During decommissioning, funds

23 LR-N24-0040

in Non-50.75 Subaccounts would be available, but not dedicated, for radiological decommissioning.

10 CFR 50.75(h)(1)(iv) requirements restrict the use of NDT funds, other than for payment of ordinary administrative costs and other incidental expenses of the fund in connection with the operation of the fund, to withdrawals being made under 10 CFR 50.82(a)(8) for radiological decommissioning expenses or transfer to another financial assurance method acceptable under 10 CFR 50.75(e) until final radiological decommissioning has been completed.

When funds are commingled in the NDT and are not distinctly identified or are derived from earnings from funds originally dedicated for radiological decommissioning in the NDT (Reference 2), 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) do not allow their withdrawals to pay for activities other than radiological decommissioning until final radiological decommissioning has been completed. Therefore, exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are needed to allow PSEG to transfer earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts to be used for purposes not restricted to radiological decommissioning. If the exemptions are granted, funds in Non-50.75 Subaccounts would remain subject to other applicable requirements including the Decommissioning Trust Agreement.

The exemption request is supported by funding assurance determinations consistent with the requirements in 10 CFR 50.75(b) and (c) and decommissioning cash flow analyses based on site-specific decommissioning cost estimates (SSDCEs) for each of the facilities.

These demonstrate that funds accumulated in the NDT as of December 31, 2023, excluding comingled funds accounted for in the Non-50.75 Subaccounts, provide reasonable assurance that adequate funding for radiological decommissioning of the facilities will be available when needed. Therefore, funds accounted for in the Non-50.75 Subaccounts as of that date are in excess of the amount of funds needed to provide reasonable assurance.

PSEG has proposed conditions for future periodic transfers of earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts to ensure that such transfers, at the time of the transfer, do not involve any funds needed for reasonable assurance of adequate funding for radiological decommissioning when permanent cessation of operations is expected.

If PSEG cannot use excess funds in the NDT to pay for activities other than radiological decommissioning until after final completion of radiological decommissioning, it would be forced to provide additional funds to pay for those activities that would not be recoverable from the NDT until after final completion of radiological decommissioning. Such activities include transferring and safely storing spent fuel at the ISFSIs and decontamination, removal, and disposal of radioactive co mponents during operations, which are under the regulatory authority of the NRC. Allowing funds to be used for these expenses would reflect the current environment in which a permanent federal repository for spent fuel does not exist and PSEG is required to provide long-term storage for spent fuel in the independent spent fuel storage installations associated with the reactors. The need to remove and dispose of radioactive components during the extended terms of the renewed operating licenses is reasonably expected.

24 LR-N24-0040

10 CFR 50.75(h)(1)(iv) further provides that, except for withdrawals for decommissioning being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative costs and other incidental expenses of the fund in connection with the operation of the fund, no disbursement or payment from the NDT may be made until written notice of the intention to make a disbursement or payment has been given to the NRC as least 30 working days in advance. Therefore, an exemption from 10 CF R 50.75(h)(1)(iv) is needed to allow PSEG to make periodic transfers in accordance with the exemption request without prior NRC notification, in the same manner as withdrawals made under 10 CFR 50.82(a)(8).

3. Environmental Impacts of the Proposed Action

The proposed action involves exemptions from regulatory requirements that relate only to sources or means of funding or verifying that adequate funding is available for radiological decommissioning of the facilities and are of a financial or administrative nature which do not have an impact on the environment.

Decommissioning cash flow analyses based on site-specific decommissioning cost estimates for each of the facilities demonstrate that the funds accumulated in the NDT as of December 31, 2023, excluding funds accounted for in the Non-50.75 Subaccounts, provide reasonable assurance that sufficient funding will be available to complete radiological decommissioning of the facilities and to allow reallocating funds accounted for in the Non-50.75 Subaccounts for purposes not restricted to radiological decommissioning. Large surpluses in NDT reserves are projected at the completion of radiological decommissioning within 60 years of expected permanent cessation of operations.

For periodic transfers of funds into the Non-50.75 Subaccounts, proposed conditions for the exemptions would only allow funds from earnings from NDT funds to be transferred into the Non-50.75 Subaccounts. Transfers will only be allowed if the amount of funding assurance provided by the funds dedicated for radiological decommissioning remaining in the NDT exceed the amount of funding required by 10 CFR 50.75 by at least $100 million (nominal dollars) for the associated station at the time of the transfer.

In accordance with the proposed exemptions, PSEGs decommissioning funding status reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into Non-50.75 Subaccounts since the last submitted report. This will allow periodic transfers being made in accordance with the exemptions to be monitored by the NRC. During operations, the reporting requirements in 10 CFR 50.75(f)(1) allow the status of funding for radiological decommissioning to be continually monitored by the NRC and will provide ample opportunity for the NRC to take actions as appropriate.

The proposed exemptions would no longer be effective on an individual reactor basis once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1)(i) and (ii) have been submitted.

Thereafter, no further transfers would be allowed for that unit. During decommissioning, funds in Non-50.75 Subaccounts would be available, but not dedicated, for radiological decommissioning.

25 LR-N24-0040

For these reasons, there is reasonable assurance that there will be no environmental impact due to lack of adequate funding for radiological decommissioning.

The proposed action does not involve any physical change in the facilities or in the procedures governing facility operations, therefore the exemptions do not involve a significant increase in the probability or consequences of radiological accidents, and do not create the possibility of a new or different kind of accident. The proposed action does not alter the design basis or any safety limits for the facilities, or any structures, systems, and components relied upon for accident mitigation or physical security, therefore the proposed action does not involve a significant reduction in a margin of safety. The proposed action has no direct radiological impacts and there are no changes in the types or amounts of effluents released offsite resulting from the exemptions, therefore the proposed action will not result in a significant increase to occupational or public doses. No changes would be made to buildings or property at the site from the proposed changes. Therefore, there are no significant radiological environmental impac ts associated with the proposed action.

With regard to potential non-radiological impacts, the proposed action involves no new construction of modifications of plant operational systems and therefore has no foreseeable impacts to land, air, or water resources, including terrestrial and aquatic biota, as it involves no new construction of modifications of plant operational systems. There would be no changes to the quality or quantity of non-radiological effluents. No changes to the discharge permits would be needed as a result of the proposed action. In addition, there would be no noticeable effect on socioeconomic conditions in the region, no environmental justice impacts, no air quality impacts, and no impacts to historic and cultural resources from the exemptions. Therefore, there are no significant non-radiological environmental impacts associated with the proposed action.

Accordingly, it can be concluded that there are no significant environmental impacts associated with the proposed action.

4. Environmental Impacts of the Alternatives to the Proposed Action

As an alternative to the proposed action, the no action alternative was considered which would result in no change in current environmental impacts. Therefore, the environmental impacts of the proposed action and the alternative action are similar.

5. Alternative Use of Resources

The proposed action does not involve the use of any different resources than previously authorized for the licensed facilities. There are no unresolved conflicts concerning alternative uses of available resources under the proposed action.

In conclusion with regard to environmental impacts, based on the information provided above the proposed action will not have a significant effect on the quality of the human environment and does not involve any significant environmental impacts.

The proposed exemptions do not require any additional Federal permits, licenses, or approvals.

26 LR-N24-0040

8. CONCLUSION

The requested exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would allow PSEG to periodically transfer earnings from funds dedicated for radiological decommissioning in the NDT into the Non-50.75 Subaccounts without prior notification to the NRC. Funds accumulated in Non-50.75 Subaccounts would be used to pay for activities that are part of the larger decommissioning process and not restricted to radiological decommissioning, at any time during operations or decommissioning.

Under the proposed conditions for the exemptions, periodic transfers are restricted to actual earnings from NDT funds and funds dedicated for radiological decommissioning remaining in the NDT, excluding funds in Non-50.75 Subaccounts, must provide funding assurance that exceeds the amount required by 10 CFR 50.75(b) and (c) at the time of the transfer. Therefore, approval of the requested exemptions will not undermine PSEGs ability to maintain the minimum amounts of NDT funds required for radiological decommissioning by the regulations to provide reasonable assurance that sufficient funds for radiological decommissioning will be available at expected permanent cessation of operations. Furthermore, DFS reports submitted under 10 CFR 50.75(f)(1) will include the amount of funds transferred into the Non-50.75 Subaccounts since the last submitted report to allow the periodic transfers to be monitored by the NRC. The existing reporting requirements in 10 CFR 50.75(f)(1) will continue to allow the status of funding for radiological decommissioning to be continually monitored by the NRC and provide the NRC with awareness of, and the ability to act on, any actual or potential funding deficiencies.

Pursuant to 10 CFR 50.12, PSEG is requesting the exemptions would cease to be effective on an individual reactor basis once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel required under 10 CFR 50.82(a)(1) have been submitted.

Based on the considerations discussed above, th e requested exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. Special circumstances are present as set forth in 10 CFR 50.12(a)(2)(ii) and (iii).

9. REFERENCES

1. Letter from David J. Mannai (PSEG Nuclear LLC) to NRC, Notice of Proposed Amendment to Decommissioning Trust Agreement, dated September 8, 2023 (ML23252A001)

2. Letter from NRC to Charles V. McFeaters (PSEG Nuclear LLC), Hope Creek Generating Station, Salem Nuclear Generating Station, Unit Nos. 1 and 2, and Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 - Notice of Objection to Proposed Amendment to Decommissioning Trust Agreement (EPID-L-2023-LRO-0063), dated November 29, 2023 (ML23270C007)

3. NRC Draft Interim Staff Guidance - Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal, dated June 21, 2023 (ML23150A051)

27 LR-N24-0040

4. Federal Register Notice - U.S. Nuclear Regulatory Commission Final Rule, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors, dated September 22, 1998 (63 FR 50465)

5. PSEG letter to NRC, Report of Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 24, 2023 (ML23083A089)

6. Federal Register Notice - U.S. Nuclear Regulatory Commission Final Rule, Decommissioning Trust Provisions, dated December 24, 2002 (67 FR 78332)

7. NRC Regulatory Issue Summary 2001-07, Revision 1, "10 CFR 50.75 Reporting and Recordkeeping for Decommissioning Planning," dated January 8, 2009 (ML083440158)

8. NRC Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Revision 2, dated October 2011 (ML112160012)

9. Federal Register Notice - U.S. Nuclear Regulatory Commission Proposed Rule, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors, dated September 10, 1997 (62 FR 47588)

10. Federal Register Notice - U.S. Department of the Treasury, Internal Revenue Service, Final Regulations, Nuclear Decommissioning Funds, dated September 4, 2020 (85 FR 55185)

11. Letter from NRC to James M. Welsch (Pacific Gas and Electric Company), "Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.82(a)(8)(ii)) (EPID L-2018-LLE-0023),"

dated September 10, 2019 (ML19163A104)

12. Letter from NRC to NextEra Energy Duane Arnold, "Duane Arnold Energy Center -

Exemption from 10 CFR 50.82(a)(8)(i)(A) and Section 75(h)(1)(iv) to Allow Use of Funds from Decommissioning Trust Fund for Spent Fuel Management and Site Restoration Activities (EPID L-2020-LLE-0011)," dated August 12, 2020 (ML20171A626).

13. Letter from NRC to Andrea L. Sterdis (Holtec Decommissioning International, LLC),

Indian Point Nuclear Generating Station, Unit Nos. 1, 2 and 3 Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv), dated November 23, 2020 (ML20309A577)

14. Letter from NRC to Jean A. Fleming (Holtec Decommissioning International, LLC),

Palisades Nuclear Plant - Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Holtec Decommissioning International, LLC (EPIC L-2020-LLE-0240), dated December 13, 2021 (ML21286A294)

15. Letter from NRC to David P. Rhoades (Constellation Energy Generation, LLC), Three Mile Island Station, Unit 1 - Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Constellation Energy Generation, LLC (EPID: L-2021-LLE-0030), dated June 8, 2022 (ML22126A143)

16. Letter from NRC to Amy C. Hazelhoff (EnergySolutions, LLC), Kewaunee Power Station

- Exemption to Allow Use of Funds from the Nuclear Decommissioning Trust for Site Restoration and to Remove a Notification Requirement for the Disbursal of Funds from

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the Decommissioning Trust (EPID No. L-2023-LLE-0008), dated January 26, 2024 (ML23339A133); Exemption (ML23339A134) and Safety Evaluation (ML23339A136)

17. Letter from U.S. Nuclear Regulatory Commission to D. Laing (Maine Yankee Atomic Power Company), Issuance of Exemption for Maine Yankee Atomic Power Company Regarding Maine Yankee Independent Spent Fuel Storage Installation, dated February 29, 2024 (ML23286A326); Exemption (89 FR 22462, dated April 1, 2024)

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Table 1-S Salem Units 1 and 2 DFA vs. NRC Minimum for Years Reported from 2004 to 2022 (Thousands of dollars in year reported)

Salem Unit 1 Salem Unit 2

Projected Value Projected Value Year NDT Funds 1 of NDT Funds 2 NDT Funds 1 of NDT Funds 2 NRC Minimum 3 2004 $ 212,158 $ 267,033 $ 195,349 $ 264,462 $ 215,314 2005 221,154 272,902 203,848 270,560 201,636 2006 246,113 297,750 224,841 292,576 204,368 2008 187,371 217,875 175,853 219,938 243,734 2010 251,954 281,603 230,825 277,489 276,730 2012 288,471 460,479 262,897 451,377 304,545 2014 356,575 547,104 315,279 520,307 305,823 2016 374,602 552,430 327,104 518,846 269,076 2018 377,660 535,327 332,811 507,413 287,989 2020 510,046 694,889 437,012 640,391 294,439 2022 461,633 604,525 389,223 548,229 346,411

1 Amount accumulated as of the end of the calendar year as reported in the DFS reports and supplements.

2 2% annual RROR up to the license expiration date in effect at the time of the report as allowed by 10 CFR 50.75(e)(1)(i). Units 1 and 2 renewed licenses issued in 2011 extended the expiration dates to August 13, 2036, and April 18, 2040, respectively.

3 Amount of funding assurance estimated to be required for each unit as of the end of the calendar year indicated, using the generic formula in 10 CFR 50.75(c), and pro-rated for PSEGs ownership share of 57.41%.

Figure 1-S Salem Units 1 and 2 DFA Trends from Table 1-S (Thousands of dollars in year reported)

$800,000 -- NRG Minimum (57.41 % share)

-- Sa lem 1 NOT Funds

$700,000 - salem 1 NOT Funds Projected Val u e

-- Salem 2 NOT Funds

- sa lem 2 NOT Funds Projected Value

$600,000

$500,000

$400,000

$300,000

$200,000

$100,000 2004 2006 2008 2010 2012 2014 2016 20 18 2020 2022

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Table 1-HC Hope Creek DFA vs. NRC Minimum for Years Reported from 2004 to 2022 (Thousands of dollars in year reported)

Hope Creek

Projected Value Year NDT Funds 1 of NDT Funds 2 NRC Minimum 3 2004 $ 324,441 $ 494,438 $ 459,964 2005 338,920 506,383 465,476 2006 375,461 549,987 472,414 2008 301,865 424,999 587,108 2010 390,030 527,819 628,252 2012 437,528 845,637 691,487 2014 519,996 966,027 693,640 2016 536,295 957,593 636,441 2018 548,048 940,605 682,967 2020 709,710 1,170,732 697,459 2022 626,865 993,944 821,502

1 Amount accumulated as of the end of the calendar year as reported in the DFS reports and supplements.

2 2% annual RROR up to the license expiration date in effect at the time of the report as allowed by 10 CFR 50.75(e)(1)(i). Hope Creek renewed license issued in 2011 extended the expiration date to April 11, 2046.

3 Amount of funding assurance estimated to be required using the generic formula in 10 CFR 50.75(c).

Figure 1-HC Hope Creek DFA Trend from Table 1-HC (Thousands of dollars in year reported)

$1,400,000 -NRC Minimum (1 00%share)

- NOT Funds

$1,200,000 -o-NDT Funds Projected Value

$1,000,000

$800,000

$600,000

$400,000

$200,000 2004 2006 2008 2010 2012 2014 2016 2018 2020 2022

31 LR-N24-0040

Table 1-PB PBAPS Units 2 and 3 DFA vs. NRC Minimum for Years Reported from 2004 to 2022 (Thousands of dollars in year reported)

PBAPS Unit 2 PBAPS Unit 3

Projected Value Projected Value Year NDT Funds 1 of NDT Funds 2 NDT Funds 1 of NDT Funds 2 NRC Minimum 3 2004 $ 178,108 $ 313,811 $ 180,641 $ 323,985 $ 235,085 2005 185,808 320,963 188,421 331,316 242,049 2006 206,965 350,504 209,467 361,106 265,486 2008 159,382 259,432 162,546 269,329 293,554 2010 212,694 332,775 215,347 342,971 314,225 2012 242,056 363,998 244,769 374,682 345,744 2014 297,767 430,399 298,542 439,262 346,820 2016 311,970 433,407 311,663 440,749 333,382 2018 315,179 420,873 315,709 429,145 349,651 2020 423,253 807,208 420,575 816,492 347,081 2022 382,017 700,294 377,884 705,145 362,429

1 Amount accumulated as of the end of the calendar year as reported in the DFS reports and supplements.

2 2% annual RROR up to the license expiration date in effect at the time of the report as allowed by 10 CFR 50.75(e)(1)(i). Units 2 and 3 renewed licenses issued in 2003 extended the expiration dates to August 8, 2033, and July 2, 2034, respectively. Subsequent renewed licenses issued in 2020 extended the expiration dates by 20 additional years. In 2022, NRC Memorandum and Order CLI-22-04 directed the expiration dates be reverted while the environmental analysis is updated and the change was reflected in the DFS report; however, this table uses 80-year operating terms for trending purposes.

3 Amount of funding assurance estimated to be required for each unit using the generic formula in 10 CFR 50.75(c),

pro-rated for PSEGs ownership share of 50%.

Figure 1-PB PBAPS Units 2 and 3 DFA Trends from Table 1-PB (Thousands of dollars in year reported)

$900,000 -NRC Minimum (50% share)

$800,000 - Unit 2 NOT Funds

--<>- Unit 2 NOT Funds Projec ted Value

- Unit 3 NOT Funds

$700,000 --<>- Unit 3 NOT Funds Projected Value

$600,000

$500,000

$400,000

$3 00,000

$200,000

$100,000 2004 2006 2008 2010 2012 2014 2016 2018 2020 2022

32 LR-N24-0040 Enclosure 1

Table 2 DFA Using NRC Minimum Formula Amounts as of December 31, 2023 -

Excluding Funds in Non-50.75 Subaccounts (2023 dollars, thousands)

Salem Unit 1 Salem Unit 2 Hope Creek PBAPS Unit 2 PBAPS Unit 3

Minimum DFA required using $ 349,181 $ 349,181 $ 826,987 $ 365,172 $ 365,172 10 CFR 50.75(c) formula, pro-rated for ownership share 1 NDT Funds as of $ 495,170 $ 413,603 $ 662,946 $ 408,968 $ 403,472 December 31, 2023, excluding Non-50.75 Subaccounts

Projected NDT funds using a $ 635,737 $ 571,154 $ 1,030,557 $ 494,639 $ 496,747 2% annual RROR up to license expiration date August 13, 2036 April 18, 2040 April 11, 2046 August 8, 2033 July 2, 2034

Total DFA taking pro-rata credit $ 704,593 $ 630,407 $ 1,122,993 $ 541,340 $ 543,762 during decommissioning 2

80-year Operating Terms 3

Projected NDT funds using a $ 735,008 $ 738,140 2% annual RROR up to license expiration date August 8, 2053 July 2, 2054 Total DFA taking pro-rata credit $ 817,448 $ 821,046 during decommissioning 2

1 Minimum funding assurance determined using the table of minimum amounts and adjustment factor in 10 CFR 50.75(c),

guidance in NUREG-1307, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities Revision 19, February 2023 (ML23044A207), and data published by the U.S.

Department of Labor, Bureau of Labor Statistics (BLS):

• Labor cost escalation factor (Lx) is 3.52, calculated using the formula in NUREG-1307, Section 3.2, where Base Lx is 2.16 for Northeast Region from Table 3-2 and the Employment Cost Index (ECI) for total compensation for private industry workers in the Northeast region (BLS Series ID CIU2010000000210I) estimate value is 163.0 for 2023-Qtr4.

• Energy cost escalation factor (Ex) is 3.172 (PWR) or 3.224 (BWR), calculated using the formulas in NUREG-1307, Section 3.3, where (Px) cost escalation factor for industrial electric power is the producer price index (PPI) commodity (BLS Series ID WPU0543) value of 295.340 for December 2023 (preliminary as of May 2024) divided by 114.2 (January 1986 value), and (Fx) cost escalation factor for diesel and other fuels for transportation and other heavy equipment operation is the PPI commodity (BLS Series ID WPU0573) value of 321.916 for December 2023 (preliminary as of May 2024) divided by 82.0 (January 1986 value).

• Low-level waste burial cost escalation factor (Bx) is taken from NUREG-1307, Table 2-1 and is consistent with current waste disposal practices and decommissioning planning. Salem (Bx) is 14.067, PWR value for South Carolina site (combination). Hope Creek (Bx) is 15.550, BWR value for South Carolina site (combination). PBAPS (Bx) is 12.296, BWR value for generators located in unaffiliated states/compact-affiliated states with no disposal facility.

• $105 million (PWR) or $135 million (BWR) from the table of minimum amounts multiplied by the adjustment factor and pro-rated for PSEGs ownership share: 57.41% for Salem, 100% for Hope Creek, and 50% for PBAPS.

2 Pro-rata credit during the 7-year immediate dismantlement period in accordance with 10 CFR 50.75(e)(1)(i). Calculated using a monthly cash flow analysis with the projected funds at license expiration as the starting fund balance, uniform monthly expenses based on the minimum formula amount, and a monthly earnings rate equivalent to a 2% annual RROR, consistent with Nuclear Reactor Regulation (NRR) Office Instruction LIC-205, Revision 6, "Procedures for NRCs Independent Analysis of Decommissioning Funding Assurance for Operating Nuclear Power Reactors and Power Reactors in Decommissioning," effective date April 10, 2017 (ML17075A095).

3 Results if the expiration dates for the PBAPS Units 2 and 3 subsequent renewed licenses as issued on March 5, 2020, are used. Refer to NRC Memorandum and Order CLI-22-04.

33 LR-N24-0040

Table 3-S1 Salem Unit 1 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2034 $ 603,609 $ 1,310 $ - $ 602,299 $ 12,046 $ 614,345 2035 614,345 3,416 - 610,929 12,219 623,148 2036 623,148 17,451 - 605,696 12,114 617,810 2037 617,810 48,429 - 569,381 11,388 580,769 2038 580,769 10,359 - 570,410 11,408 581,818 2039 581,818 5,752 - 576,066 11,521 587,588 2040 587,588 4,352 - 583,235 11,665 594,900 2041 594,900 4,164 - 590,736 11,815 602,551 2042 602,551 2,242 - 600,309 12,006 612,315 2043 612,315 2,242 - 610,073 12,201 622,275 2044 622,275 2,248 - 620,027 12,401 632,427 2045 632,427 2,242 - 630,185 12,604 642,789 2046 642,789 2,388 - 640,401 12,808 653,209 2047 653,209 2,388 - 650,821 13,016 663,837 2048 663,837 2,346 - 661,491 13,230 674,721 2049 674,721 2,308 - 672,414 13,448 685,862 2050 685,862 2,249 - 683,613 13,672 697,285 2051 697,285 2,249 - 695,035 13,901 708,936 2052 708,936 2,256 - 706,681 14,134 720,814 2053 720,814 2,249 - 718,565 14,371 732,936 2054 732,936 2,249 - 730,687 14,614 745,300 2055 745,300 2,249 - 743,051 14,861 757,912 2056 757,912 2,256 - 755,656 15,113 770,770 2057 770,770 2,249 - 768,520 15,370 783,891 2058 783,891 2,249 - 781,641 15,633 797,274 2059 797,274 2,249 - 795,025 15,900 810,925 2060 810,925 2,256 - 808,669 16,173 824,843 2061 824,843 2,249 - 822,593 16,452 839,045 2062 839,045 2,249 - 836,796 16,736 853,532 2063 853,532 2,249 - 851,282 17,026 868,308 2064 868,308 2,256 - 866,052 17,321 883,373 2065 883,373 2,249 - 881,124 17,622 898,747 2066 898,747 2,249 - 896,497 17,930 914,427 2067 914,427 2,249 - 912,178 18,244 930,421 2068 930,421 2,256 - 928,166 18,563 946,729 2069 946,729 2,249 - 944,480 18,890 963,369 2070 963,369 2,249 - 961,120 19,222 980,342 2071 980,342 2,249 - 978,093 19,562 997,655 2072 997,655 2,256 - 995,399 19,908 1,015,307 2073 1,015,307 2,249 - 1,013,058 20,261 1,033,319 2074 1,033,319 2,249 - 1,031,069 20,621 1,051,691 2075 1,051,691 2,249 - 1,049,441 20,989 1,070,430 2076 1,070,430 2,256 - 1,068,175 21,363 1,089,538 2077 1,089,538 2,249 - 1,087,289 21,746 1,109,034 2078 1,109,034 2,249 - 1,106,785 22,136 1,128,921 2079 1,128,921 2,249 - 1,126,671 22,533 1,149,205 2080 1,149,205 2,256 - 1,146,949 22,939 1,169,888 2081 1,169,888 2,249 - 1,167,639 23,353 1,190,991

34 LR-N24-0040 Enclosure 1

Table 3-S1 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2082 1,190,991 2,249 - 1,188,742 23,775 1,212,517 2083 1,212,517 2,249 - 1,210,267 24,205 1,234,473 2084 1,234,473 2,256 - 1,232,217 24,644 1,256,862 2085 1,256,862 2,249 - 1,254,612 25,092 1,279,704 2086 1,279,704 2,249 - 1,277,455 25,549 1,303,004 2087 1,303,004 2,249 - 1,300,755 26,015 1,326,770 2088 1,326,770 2,256 - 1,324,514 26,490 1,351,004 2089 1,351,004 20,976 - 1,330,029 26,601 1,356,629 2090 1,356,629 47,216 - 1,309,414 26,188 1,335,602 2091 1,335,602 93,364 - 1,242,238 24,845 1,267,083 2092 1,267,083 56,659 1,008 1,209,416 24,188 1,233,604 2093 1,233,604 40,460 1,443 1,191,701 23,834 1,215,535 2094 1,215,535 34,214 1,209 1,180,112 23,602 1,203,714 2095 1,203,714 5,067 - 1,198,647 23,973 1,222,620 2096 1,222,620 15,768 - 1,206,852 24,137 1,230,989 Total $ 515,149 $ 3,660 $ 1,146,189

1 Beginning of Year Trust Fund Balance in 2034 is based only on the amount of Salem Unit 1 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($495.2M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 1, Table 3.3a, Unit 1, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 1, Table 3.3b, Unit 1, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2036 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after th e projected completion of decommissioning in 2096 are administrative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 57.41%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

35 LR-N24-0040

Table 3-S1-0 Salem Unit 1 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 -

Sensitivity Analysis Using 0% RROR during Operations 1 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2034 $ 495,170 $ 1,310 $ - $ 493,860 $ - $ 493,860 2035 493,860 3,416 - 490,444 - 490,444 2036 490,444 17,451 - 472,992 9,460 482,452 2037 482,452 48,429 - 434,023 8,680 442,703 2038 442,703 10,359 - 432,344 8,647 440,991 2039 440,991 5,752 - 435,240 8,705 443,944 2040 443,944 4,352 - 439,592 8,792 448,384 2041 448,384 4,164 - 444,220 8,884 453,105 2042 453,105 2,242 - 450,863 9,017 459,880 2043 459,880 2,242 - 457,638 9,153 466,791 2044 466,791 2,248 - 464,543 9,291 473,833 2045 473,833 2,242 - 471,591 9,432 481,023 2046 481,023 2,388 - 478,635 9,573 488,208 2047 488,208 2,388 - 485,820 9,716 495,537 2048 495,537 2,346 - 493,191 9,864 503,054 2049 503,054 2,308 - 500,747 10,015 510,762 2050 510,762 2,249 - 508,512 10,170 518,683 2051 518,683 2,249 - 516,433 10,329 526,762 2052 526,762 2,256 - 524,506 10,490 534,997 2053 534,997 2,249 - 532,747 10,655 543,402 2054 543,402 2,249 - 541,153 10,823 551,976 2055 551,976 2,249 - 549,726 10,995 560,721 2056 560,721 2,256 - 558,465 11,169 569,635 2057 569,635 2,249 - 567,385 11,348 578,733 2058 578,733 2,249 - 576,483 11,530 588,013 2059 588,013 2,249 - 585,764 11,715 597,479 2060 597,479 2,256 - 595,223 11,904 607,128 2061 607,128 2,249 - 604,878 12,098 616,976 2062 616,976 2,249 - 614,727 12,295 627,021 2063 627,021 2,249 - 624,772 12,495 637,267 2064 637,267 2,256 - 635,012 12,700 647,712 2065 647,712 2,249 - 645,462 12,909 658,372 2066 658,372 2,249 - 656,122 13,122 669,245 2067 669,245 2,249 - 666,995 13,340 680,335 2068 680,335 2,256 - 678,080 13,562 691,641 2069 691,641 2,249 - 689,392 13,788 703,180 2070 703,180 2,249 - 700,930 14,019 714,949 2071 714,949 2,249 - 712,699 14,254 726,953 2072 726,953 2,256 - 724,698 14,494 739,192 2073 739,192 2,249 - 736,942 14,739 751,681 2074 751,681 2,249 - 749,432 14,989 764,420 2075 764,420 2,249 - 762,171 15,243 777,414 2076 777,414 2,256 - 775,159 15,503 790,662 2077 790,662 2,249 - 788,412 15,768 804,181 2078 804,181 2,249 - 801,931 16,039 817,970 2079 817,970 2,249 - 815,721 16,314 832,035

36 LR-N24-0040 Enclosure 1

Table 3-S1-0 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2080 832,035 2,256 - 829,779 16,596 846,375 2081 846,375 2,249 - 844,126 16,883 861,008 2082 861,008 2,249 - 858,759 17,175 875,934 2083 875,934 2,249 - 873,684 17,474 891,158 2084 891,158 2,256 - 888,903 17,778 906,681 2085 906,681 2,249 - 904,431 18,089 922,520 2086 922,520 2,249 - 920,270 18,405 938,676 2087 938,676 2,249 - 936,426 18,729 955,155 2088 955,155 2,256 - 952,899 19,058 971,957 2089 971,957 20,976 - 950,982 19,020 970,001 2090 970,001 47,216 - 922,785 18,456 941,241 2091 941,241 93,364 - 847,878 16,958 864,835 2092 864,835 56,659 1,008 807,168 16,143 823,311 2093 823,311 40,460 1,443 781,408 15,628 797,037 2094 797,037 34,214 1,209 761,613 15,232 776,845 2095 776,845 5,067 - 771,778 15,436 787,214 2096 787,214 15,768 - 771,446 15,429 786,875 Total $ 515,149 $ 3,660 $ 810,514

1 Beginning of Year Trust Fund Balance in 2034 is based only on the amount of Salem Unit 1 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($495.2M), taking credit for a 0% annual RROR up to the license expiration date.

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 1, Table 3.3a, Unit 1, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 1, Table 3.3b, Unit 1, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2036 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after th e projected completion of decommissioning in 2096 are administrative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 57.41%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

37 LR-N24-0040

Table 3-S2 Salem Unit 2 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2040 $ 567,789 $ 26,306 $ - $ 541,483 $ 10,830 $ 552,312 2041 552,312 39,621 - 512,691 10,254 522,945 2042 522,945 4,570 - 518,375 10,368 528,743 2043 528,743 4,487 - 524,256 10,485 534,741 2044 534,741 4,175 - 530,566 10,611 541,177 2045 541,177 4,168 - 537,009 10,740 547,749 2046 547,749 2,409 - 545,340 10,907 556,247 2047 556,247 2,409 - 553,838 11,077 564,915 2048 564,915 2,362 - 562,553 11,251 573,804 2049 573,804 2,320 - 571,485 11,430 582,914 2050 582,914 2,255 - 580,659 11,613 592,272 2051 592,272 2,255 - 590,017 11,800 601,818 2052 601,818 2,261 - 599,556 11,991 611,547 2053 611,547 2,255 - 609,292 12,186 621,478 2054 621,478 2,255 - 619,223 12,384 631,607 2055 631,607 2,255 - 629,352 12,587 641,939 2056 641,939 2,261 - 639,678 12,794 652,472 2057 652,472 2,255 - 650,216 13,004 663,221 2058 663,221 2,255 - 660,966 13,219 674,185 2059 674,185 2,255 - 671,930 13,439 685,368 2060 685,368 2,261 - 683,107 13,662 696,769 2061 696,769 2,255 - 694,514 13,890 708,404 2062 708,404 2,255 - 706,149 14,123 720,272 2063 720,272 2,255 - 718,017 14,360 732,377 2064 732,377 2,261 - 730,116 14,602 744,718 2065 744,718 2,255 - 742,463 14,849 757,312 2066 757,312 2,255 - 755,057 15,101 770,158 2067 770,158 2,255 - 767,903 15,358 783,261 2068 783,261 2,261 - 781,000 15,620 796,620 2069 796,620 2,255 - 794,365 15,887 810,252 2070 810,252 2,255 - 807,997 16,160 824,157 2071 824,157 2,255 - 821,902 16,438 838,340 2072 838,340 2,261 - 836,078 16,722 852,800 2073 852,800 2,255 - 850,545 17,011 867,556 2074 867,556 2,255 - 865,301 17,306 882,607 2075 882,607 2,255 - 880,352 17,607 897,959 2076 897,959 2,261 - 895,697 17,914 913,611 2077 913,611 2,255 - 911,356 18,227 929,583 2078 929,583 2,255 - 927,328 18,547 945,875 2079 945,875 2,255 - 943,619 18,872 962,492 2080 962,492 2,261 - 960,231 19,205 979,435 2081 979,435 2,255 - 977,180 19,544 996,724 2082 996,724 2,255 - 994,468 19,889 1,014,358 2083 1,014,358 2,255 - 1,012,103 20,242 1,032,345 2084 1,032,345 2,261 - 1,030,083 20,602 1,050,685 2085 1,050,685 2,255 - 1,048,430 20,969 1,069,398 2086 1,069,398 2,255 - 1,067,143 21,343 1,088,486

38 LR-N24-0040 Enclosure 1

Table 3-S2 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2087 1,088,486 2,255 - 1,086,231 21,725 1,107,956 2088 1,107,956 2,261 - 1,105,694 22,114 1,127,808 2089 1,127,808 2,068 - 1,125,740 22,515 1,148,255 2090 1,148,255 18,624 - 1,129,631 22,593 1,152,224 2091 1,152,224 46,535 - 1,105,689 22,114 1,127,803 2092 1,127,803 94,209 - 1,033,594 20,672 1,054,265 2093 1,054,265 55,786 1,141 997,339 19,947 1,017,286 2094 1,017,286 48,722 1,352 967,211 19,344 986,556 2095 986,556 45,523 1,167 939,866 18,797 958,663 2096 958,663 15,651 - 943,012 18,860 961,873 Total $ 507,956 $ 3,660 $ 905,700

1 Beginning of Year Trust Fund Balance in 2040 is based only on the amount of Salem Unit 2 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($413.6M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 1, Table 3.4a, Unit 2, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 1, Table 3.4b, Unit 2, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs after the projected completion of decommissioning in 2096 are admini strative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 57.41%. Costs are escalated from December 2021 dollars to Decem ber 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

39 LR-N24-0040

Table 3-S2-0 Salem Unit 2 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 -

Sensitivity Analysis Using 0% RROR during Operations 1 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2040 $ 413,603 $ 26,306 $ - $ 387,297 $ 7,746 $ 395,043 2041 395,043 39,621 - 355,422 7,108 362,531 2042 362,531 4,570 - 357,961 7,159 365,120 2043 365,120 4,487 - 360,633 7,213 367,846 2044 367,846 4,175 - 363,671 7,273 370,944 2045 370,944 4,168 - 366,776 7,336 374,111 2046 374,111 2,409 - 371,702 7,434 379,137 2047 379,137 2,409 - 376,728 7,535 384,262 2048 384,262 2,362 - 381,900 7,638 389,538 2049 389,538 2,320 - 387,219 7,744 394,963 2050 394,963 2,255 - 392,708 7,854 400,562 2051 400,562 2,255 - 398,307 7,966 406,273 2052 406,273 2,261 - 404,012 8,080 412,092 2053 412,092 2,255 - 409,837 8,197 418,034 2054 418,034 2,255 - 415,779 8,316 424,094 2055 424,094 2,255 - 421,839 8,437 430,276 2056 430,276 2,261 - 428,014 8,560 436,575 2057 436,575 2,255 - 434,320 8,686 443,006 2058 443,006 2,255 - 440,751 8,815 449,566 2059 449,566 2,255 - 447,311 8,946 456,257 2060 456,257 2,261 - 453,996 9,080 463,076 2061 463,076 2,255 - 460,820 9,216 470,037 2062 470,037 2,255 - 467,782 9,356 477,137 2063 477,137 2,255 - 474,882 9,498 484,380 2064 484,380 2,261 - 482,118 9,642 491,761 2065 491,761 2,255 - 489,506 9,790 499,296 2066 499,296 2,255 - 497,041 9,941 506,981 2067 506,981 2,255 - 504,726 10,095 514,821 2068 514,821 2,261 - 512,560 10,251 522,811 2069 522,811 2,255 - 520,556 10,411 530,967 2070 530,967 2,255 - 528,712 10,574 539,286 2071 539,286 2,255 - 537,031 10,741 547,771 2072 547,771 2,261 - 545,510 10,910 556,420 2073 556,420 2,255 - 554,165 11,083 565,248 2074 565,248 2,255 - 562,993 11,260 574,253 2075 574,253 2,255 - 571,998 11,440 583,438 2076 583,438 2,261 - 581,176 11,624 592,800 2077 592,800 2,255 - 590,545 11,811 602,356 2078 602,356 2,255 - 600,101 12,002 612,103 2079 612,103 2,255 - 609,847 12,197 622,044 2080 622,044 2,261 - 619,783 12,396 632,179 2081 632,179 2,255 - 629,924 12,598 642,522 2082 642,522 2,255 - 640,267 12,805 653,072 2083 653,072 2,255 - 650,817 13,016 663,833 2084 663,833 2,261 - 661,572 13,231 674,804 2085 674,804 2,255 - 672,548 13,451 685,999 2086 685,999 2,255 - 683,744 13,675 697,419

40 LR-N24-0040 Enclosure 1

Table 3-S2-0 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2087 697,419 2,255 - 695,164 13,903 709,067 2088 709,067 2,261 - 706,806 14,136 720,942 2089 720,942 2,068 - 718,874 14,377 733,251 2090 733,251 18,624 - 714,628 14,293 728,920 2091 728,920 46,535 - 682,386 13,648 696,033 2092 696,033 94,209 - 601,824 12,036 613,860 2093 613,860 55,786 1,141 556,934 11,139 568,073 2094 568,073 48,722 1,352 517,998 10,360 528,358 2095 528,358 45,523 1,167 481,669 9,633 491,302 2096 491,302 15,651 - 475,651 9,513 485,164 Total $ 507,956 $ 3,660 $ 583,177

1 Beginning of Year Trust Fund Balance in 2040 is based only on the amount of Salem Unit 2 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($413.6M), taking credit for a 0% annual RROR up to the license expiration date.

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 1, Table 3.4a, Unit 2, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 1, Table 3.4b, Unit 2, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs after the projected completion of decommissioning in 2096 are admini strative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 57.41%. Costs are escalated from December 2021 dollars to Decem ber 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

41 LR-N24-0040

Table 3-HC Hope Creek Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2044 $ 985,103 $ 4,320 $ - $ 980,783 $ 19,616 $ 1,000,399 2045 1,000,399 5,950 - 994,449 19,889 1,014,338 2046 1,014,338 56,944 - 957,393 19,148 976,541 2047 976,541 96,155 - 880,386 17,608 897,994 2048 897,994 9,785 - 888,209 17,764 905,973 2049 905,973 8,552 - 897,421 17,948 915,369 2050 915,369 4,455 - 910,915 18,218 929,133 2051 929,133 4,455 - 924,678 18,494 943,172 2052 943,172 4,467 - 938,705 18,774 957,479 2053 957,479 4,455 - 953,024 19,060 972,085 2054 972,085 4,455 - 967,630 19,353 986,983 2055 986,983 4,455 - 982,528 19,651 1,002,178 2056 1,002,178 4,467 - 997,712 19,954 1,017,666 2057 1,017,666 4,455 - 1,013,211 20,264 1,033,475 2058 1,033,475 4,455 - 1,029,021 20,580 1,049,601 2059 1,049,601 4,455 - 1,045,146 20,903 1,066,049 2060 1,066,049 4,467 - 1,061,582 21,232 1,082,814 2061 1,082,814 4,455 - 1,078,359 21,567 1,099,926 2062 1,099,926 4,455 - 1,095,472 21,909 1,117,381 2063 1,117,381 4,455 - 1,112,926 22,259 1,135,185 2064 1,135,185 4,467 - 1,130,718 22,614 1,153,332 2065 1,153,332 4,455 - 1,148,878 22,978 1,171,855 2066 1,171,855 4,455 - 1,167,400 23,348 1,190,748 2067 1,190,748 4,455 - 1,186,294 23,726 1,210,020 2068 1,210,020 4,467 - 1,205,553 24,111 1,229,664 2069 1,229,664 4,455 - 1,225,209 24,504 1,249,713 2070 1,249,713 4,455 - 1,245,258 24,905 1,270,164 2071 1,270,164 4,455 - 1,265,709 25,314 1,291,023 2072 1,291,023 4,467 - 1,286,556 25,731 1,312,287 2073 1,312,287 4,455 - 1,307,833 26,157 1,333,989 2074 1,333,989 4,455 - 1,329,534 26,591 1,356,125 2075 1,356,125 4,455 - 1,351,670 27,033 1,378,704 2076 1,378,704 4,467 - 1,374,237 27,485 1,401,722 2077 1,401,722 4,455 - 1,397,267 27,945 1,425,212 2078 1,425,212 4,455 - 1,420,758 28,415 1,449,173 2079 1,449,173 4,455 - 1,444,718 28,894 1,473,612 2080 1,473,612 4,467 - 1,469,145 29,383 1,498,528 2081 1,498,528 4,455 - 1,494,074 29,881 1,523,955 2082 1,523,955 4,455 - 1,519,500 30,390 1,549,890 2083 1,549,890 4,455 - 1,545,436 30,909 1,576,344 2084 1,576,344 4,467 - 1,571,877 31,438 1,603,315 2085 1,603,315 4,455 - 1,598,860 31,977 1,630,838 2086 1,630,838 4,455 - 1,626,383 32,528 1,658,910 2087 1,658,910 4,455 - 1,654,456 33,089 1,687,545 2088 1,687,545 4,467 - 1,683,078 33,662 1,716,739 2089 1,716,739 6,341 - 1,710,398 34,208 1,744,606 2090 1,744,606 6,341 - 1,738,265 34,765 1,773,030 2091 1,773,030 6,341 - 1,766,688 35,334 1,802,022

42 LR-N24-0040 Enclosure 1

Table 3-HC (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2092 1,802,022 6,359 - 1,795,663 35,913 1,831,577 2093 1,831,577 6,341 - 1,825,235 36,505 1,861,740 2094 1,861,740 6,341 - 1,855,399 37,108 1,892,507 2095 1,892,507 6,341 - 1,886,165 37,723 1,923,888 2096 1,923,888 6,359 - 1,917,530 38,351 1,955,880 2097 1,955,880 6,341 - 1,949,539 38,991 1,988,530 2098 1,988,530 6,341 - 1,982,188 39,644 2,021,832 2099 2,021,832 6,341 - 2,015,491 40,310 2,055,800 2100 2,055,800 42,452 - 2,013,349 40,267 2,053,616 2101 2,053,616 100,371 - 1,953,244 39,065 1,992,309 2102 1,992,309 215,711 - 1,776,598 35,532 1,812,130 2103 1,812,130 162,247 3,319 1,646,564 32,931 1,679,496 2104 1,679,496 139,263 4,783 1,535,450 30,709 1,566,160 2105 1,566,160 107,390 2,496 1,456,274 29,125 1,485,399 2106 1,485,399 20,052 - 1,465,347 29,307 1,494,654 Total $ 1,212,838 $ 10,597 $ 1,732,987

1 Beginning of Year Trust Fund Balance in 2044 is based only on the amount of Hope Creek NDT funds accumulated as of December 31, 2023, and intended to be dedicated to radiologi cal decommissioning ($662.9M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reac tor costs are from Attachment 2, Table 3.2a, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 2, Table 3.2b, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2046 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2106 are administrative expenses for fi nal reports to NRC under site closeout activities and therefore not included. Costs reflect PSEGs ownership share of 100%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

43 LR-N24-0040

Table 3-HC-0 Hope Creek Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 -

Sensitivity Analysis Using 0% RROR during Operations 1 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2044 $ 662,946 $ 4,320 $ - $ 658,626 $ - $ 658,626 2045 658,626 5,950 - 652,676 - 652,676 2046 652,676 56,944 - 595,732 11,915 607,646 2047 607,646 96,155 - 511,491 10,230 521,721 2048 521,721 9,785 - 511,936 10,239 522,175 2049 522,175 8,552 - 513,623 10,272 523,895 2050 523,895 4,455 - 519,440 10,389 529,829 2051 529,829 4,455 - 525,374 10,507 535,882 2052 535,882 4,467 - 531,415 10,628 542,043 2053 542,043 4,455 - 537,589 10,752 548,340 2054 548,340 4,455 - 543,886 10,878 554,763 2055 554,763 4,455 - 550,309 11,006 561,315 2056 561,315 4,467 - 556,848 11,137 567,985 2057 567,985 4,455 - 563,530 11,271 574,801 2058 574,801 4,455 - 570,346 11,407 581,753 2059 581,753 4,455 - 577,298 11,546 588,844 2060 588,844 4,467 - 584,377 11,688 596,065 2061 596,065 4,455 - 591,610 11,832 603,442 2062 603,442 4,455 - 598,988 11,980 610,967 2063 610,967 4,455 - 606,513 12,130 618,643 2064 618,643 4,467 - 614,176 12,284 626,459 2065 626,459 4,455 - 622,005 12,440 634,445 2066 634,445 4,455 - 629,990 12,600 642,590 2067 642,590 4,455 - 638,135 12,763 650,898 2068 650,898 4,467 - 646,431 12,929 659,360 2069 659,360 4,455 - 654,905 13,098 668,003 2070 668,003 4,455 - 663,548 13,271 676,819 2071 676,819 4,455 - 672,365 13,447 685,812 2072 685,812 4,467 - 681,345 13,627 694,972 2073 694,972 4,455 - 690,517 13,810 704,327 2074 704,327 4,455 - 699,873 13,997 713,870 2075 713,870 4,455 - 709,415 14,188 723,604 2076 723,604 4,467 - 719,137 14,383 733,520 2077 733,520 4,455 - 729,065 14,581 743,646 2078 743,646 4,455 - 739,191 14,784 753,975 2079 753,975 4,455 - 749,521 14,990 764,511 2080 764,511 4,467 - 760,044 15,201 775,245 2081 775,245 4,455 - 770,790 15,416 786,206 2082 786,206 4,455 - 781,751 15,635 797,386 2083 797,386 4,455 - 792,932 15,859 808,790 2084 808,790 4,467 - 804,323 16,086 820,410 2085 820,410 4,455 - 815,955 16,319 832,274 2086 832,274 4,455 - 827,819 16,556 844,376 2087 844,376 4,455 - 839,921 16,798 856,719 2088 856,719 4,467 - 852,253 17,045 869,298 2089 869,298 6,341 - 862,956 17,259 880,215

44 LR-N24-0040 Enclosure 1

Table 3-HC-0 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2090 880,215 6,341 - 873,874 17,477 891,351 2091 891,351 6,341 - 885,010 17,700 902,710 2092 902,710 6,359 - 896,351 17,927 914,278 2093 914,278 6,341 - 907,937 18,159 926,096 2094 926,096 6,341 - 919,754 18,395 938,149 2095 938,149 6,341 - 931,808 18,636 950,444 2096 950,444 6,359 - 944,085 18,882 962,967 2097 962,967 6,341 - 956,626 19,133 975,758 2098 975,758 6,341 - 969,417 19,388 988,805 2099 988,805 6,341 - 982,464 19,649 1,002,113 2100 1,002,113 42,452 - 959,661 19,193 978,854 2101 978,854 100,371 - 878,483 17,570 896,053 2102 896,053 215,711 - 680,342 13,607 693,949 2103 693,949 162,247 3,319 528,383 10,568 538,951 2104 538,951 139,263 4,783 394,905 7,898 402,803 2105 402,803 107,390 2,496 292,918 5,858 298,776 2106 298,776 20,052 - 278,724 5,574 284,299 Total $ 1,212,838 $ 10,597 $ 844,788

1 Beginning of Year Trust Fund Balance in 2044 is based only on the amount of Hope Creek NDT funds accumulated as of December 31, 2023, and intended to be dedicated to radiologi cal decommissioning ($662.9M), taking credit for a 0% annual RROR up to the license expiration date.

2 Radiological decommissioning costs only. Reac tor costs are from Attachment 2, Table 3.2a, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 2, Table 3.2b, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2046 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2106 are administrative expenses for fi nal reports to NRC under site closeout activities and therefore not included. Costs reflect PSEGs ownership share of 100%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

45 LR-N24-0040

Table 3-PB2 PBAPS Unit 2 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2031 $ 469,775 $ 627 $ - $ 469,148 $ 9,383 $ 478,531 2032 478,531 1,583 - 476,949 9,539 486,488 2033 486,488 16,374 - 470,114 9,402 479,516 2034 479,516 45,591 - 433,925 8,678 442,603 2035 442,603 10,488 - 432,115 8,642 440,758 2036 440,758 8,522 - 432,236 8,645 440,880 2037 440,880 7,011 - 433,869 8,677 442,547 2038 442,547 7,011 - 435,535 8,711 444,246 2039 444,246 2,105 - 442,141 8,843 450,984 2040 450,984 2,269 - 448,715 8,974 457,689 2041 457,689 1,552 - 456,137 9,123 465,260 2042 465,260 1,552 - 463,709 9,274 472,983 2043 472,983 1,552 - 471,431 9,429 480,860 2044 480,860 1,556 - 479,304 9,586 488,890 2045 488,890 1,552 - 487,339 9,747 497,086 2046 497,086 1,552 - 495,534 9,911 505,445 2047 505,445 1,552 - 503,893 10,078 513,971 2048 513,971 1,556 - 512,415 10,248 522,664 2049 522,664 1,552 - 521,112 10,422 531,534 2050 531,534 1,552 - 529,983 10,600 540,582 2051 540,582 1,552 - 539,031 10,781 549,811 2052 549,811 1,556 - 548,256 10,965 559,221 2053 559,221 1,552 - 557,669 11,153 568,823 2054 568,823 1,552 - 567,271 11,345 578,617 2055 578,617 1,552 - 577,065 11,541 588,606 2056 588,606 1,556 - 587,050 11,741 598,792 2057 598,792 1,552 - 597,240 11,945 609,185 2058 609,185 1,552 - 607,633 12,153 619,786 2059 619,786 1,552 - 618,234 12,365 630,599 2060 630,599 1,556 - 629,043 12,581 641,624 2061 641,624 1,552 - 640,073 12,801 652,874 2062 652,874 1,552 - 651,323 13,026 664,349 2063 664,349 1,552 - 662,797 13,256 676,053 2064 676,053 1,556 - 674,498 13,490 687,988 2065 687,988 1,552 - 686,436 13,729 700,165 2066 700,165 2,079 - 698,086 13,962 712,048 2067 712,048 2,079 - 709,969 14,199 724,168 2068 724,168 2,085 - 722,084 14,442 736,525 2069 736,525 2,079 - 734,446 14,689 749,135 2070 749,135 2,079 - 747,057 14,941 761,998 2071 761,998 2,079 - 759,919 15,198 775,117 2072 775,117 2,085 - 773,033 15,461 788,493 2073 788,493 2,079 - 786,414 15,728 802,143 2074 802,143 2,079 - 800,064 16,001 816,065 2075 816,065 2,079 - 813,986 16,280 830,266 2076 830,266 2,085 - 828,182 16,564 844,745 2077 844,745 2,079 - 842,666 16,853 859,520 2078 859,520 2,079 - 857,441 17,149 874,590

46 LR-N24-0040 Enclosure 1

Table 3-PB2 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2079 874,590 2,079 - 872,511 17,450 889,961 2080 889,961 2,079 - 887,882 17,758 905,640 2081 905,640 2,079 - 903,561 18,071 921,632 2082 921,632 2,079 - 919,553 18,391 937,944 2083 937,944 2,079 - 935,865 18,717 954,583 2084 954,583 2,085 - 952,498 19,050 971,548 2085 971,548 7,246 - 964,302 19,286 983,589 2086 983,589 30,102 - 953,486 19,070 972,556 2087 972,556 70,241 - 902,316 18,046 920,362 2088 920,362 73,868 188 846,306 16,926 863,232 2089 863,232 35,259 1,023 826,950 16,539 843,489 2090 843,489 35,259 1,023 807,207 16,144 823,351 2091 823,351 23,359 664 799,328 15,987 815,314 2092 815,314 4,095 - 811,219 16,224 827,443 2093 827,443 12,039 - 815,404 16,308 831,712 Total $ 471,385 $ 2,897 $ 836,219

1 Beginning of Year Trust Fund Balance in 2031 is based only on the amount of PBAPS Unit 2 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($409.0M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.3a, Unit 2, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.3b, Unit 2, SAFSTOR Alternative Spent Fuel Management Expenditures, adjusted by 20 years to account for shut down in 2033 vice 2053. Costs prior to shut down in 2033 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2093 are administrative expenses for final reports to NRC under site closeout activities and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are e scalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

47 LR-N24-0040

Table 3-PB2-0 PBAPS Unit 2 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 -

Sensitivity Analysis Using 0% RROR during Operations 1 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2031 $ 408,968 $ 627 $ - $ 408,341 $ - $ 408,341 2032 408,341 1,583 - 406,758 - 406,758 2033 406,758 16,374 - 390,384 7,808 398,192 2034 398,192 45,591 - 352,601 7,052 359,653 2035 359,653 10,488 - 349,165 6,983 356,148 2036 356,148 8,522 - 347,626 6,953 354,578 2037 354,578 7,011 - 347,567 6,951 354,519 2038 354,519 7,011 - 347,507 6,950 354,458 2039 354,458 2,105 - 352,353 7,047 359,400 2040 359,400 2,269 - 357,130 7,143 364,273 2041 364,273 1,552 - 362,722 7,254 369,976 2042 369,976 1,552 - 368,424 7,368 375,793 2043 375,793 1,552 - 374,241 7,485 381,726 2044 381,726 1,556 - 380,170 7,603 387,774 2045 387,774 1,552 - 386,222 7,724 393,947 2046 393,947 1,552 - 392,395 7,848 400,243 2047 400,243 1,552 - 398,692 7,974 406,665 2048 406,665 1,556 - 405,110 8,102 413,212 2049 413,212 1,552 - 411,660 8,233 419,894 2050 419,894 1,552 - 418,342 8,367 426,709 2051 426,709 1,552 - 425,157 8,503 433,660 2052 433,660 1,556 - 432,105 8,642 440,747 2053 440,747 1,552 - 439,195 8,784 447,979 2054 447,979 1,552 - 446,428 8,929 455,356 2055 455,356 1,552 - 453,805 9,076 462,881 2056 462,881 1,556 - 461,325 9,226 470,551 2057 470,551 1,552 - 469,000 9,380 478,380 2058 478,380 1,552 - 476,828 9,537 486,365 2059 486,365 1,552 - 484,813 9,696 494,510 2060 494,510 1,556 - 492,954 9,859 502,813 2061 502,813 1,552 - 501,261 10,025 511,287 2062 511,287 1,552 - 509,735 10,195 519,930 2063 519,930 1,552 - 518,378 10,368 528,746 2064 528,746 1,556 - 527,190 10,544 537,734 2065 537,734 1,552 - 536,182 10,724 546,906 2066 546,906 2,079 - 544,827 10,897 555,724 2067 555,724 2,079 - 553,645 11,073 564,718 2068 564,718 2,085 - 562,633 11,253 573,886 2069 573,886 2,079 - 571,807 11,436 583,243 2070 583,243 2,079 - 581,164 11,623 592,788 2071 592,788 2,079 - 590,709 11,814 602,523 2072 602,523 2,085 - 600,438 12,009 612,447 2073 612,447 2,079 - 610,368 12,207 622,576 2074 622,576 2,079 - 620,497 12,410 632,907 2075 632,907 2,079 - 630,828 12,617 643,445 2076 643,445 2,085 - 641,360 12,827 654,187

48 LR-N24-0040 Enclosure 1

Table 3-PB2-0 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2077 654,187 2,079 - 652,108 13,042 665,150 2078 665,150 2,079 - 663,072 13,261 676,333 2079 676,333 2,079 - 674,254 13,485 687,739 2080 687,739 2,079 - 685,660 13,713 699,374 2081 699,374 2,079 - 697,295 13,946 711,241 2082 711,241 2,079 - 709,162 14,183 723,345 2083 723,345 2,079 - 721,266 14,425 735,692 2084 735,692 2,085 - 733,607 14,672 748,279 2085 748,279 7,246 - 741,033 14,821 755,854 2086 755,854 30,102 - 725,752 14,515 740,267 2087 740,267 70,241 - 670,026 13,401 683,427 2088 683,427 73,868 188 609,371 12,187 621,558 2089 621,558 35,259 1,023 585,276 11,706 596,982 2090 596,982 35,259 1,023 560,700 11,214 571,914 2091 571,914 23,359 664 547,890 10,958 558,848 2092 558,848 4,095 - 554,753 11,095 565,848 2093 565,848 12,039 - 553,809 11,076 564,885 Total $ 471,385 $ 2,897 $ 630,200

1 Beginning of Year Trust Fund Balance in 2031 is based only on the amount of PBAPS Unit 2 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($409.0M), taking credit for a 0% annual RROR up to the license expiration date.

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.3a, Unit 2, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.3b, Unit 2, SAFSTOR Alternative Spent Fuel Management Expenditures, adjusted by 20 years to account for shut down in 2033 vice 2053. Costs prior to shut down in 2033 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2093 are administrative expenses for final reports to NRC under site closeout activities and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are e scalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

49 LR-N24-0040

Table 3-PB2-SLR PBAPS Unit 2 Annual SAFSTOR Decommissioning Cash Flow - License Expiration 2053

- Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2051 $ 698,062 $ 627 $ - $ 697,435 $ 13,949 $ 711,383 2052 711,383 1,583 - 709,801 14,196 723,997 2053 723,997 16,374 - 707,622 14,152 721,775 2054 721,775 45,591 - 676,184 13,524 689,708 2055 689,708 10,488 - 679,220 13,584 692,804 2056 692,804 8,522 - 684,282 13,686 697,968 2057 697,968 7,011 - 690,956 13,819 704,776 2058 704,776 7,011 - 697,764 13,955 711,720 2059 711,720 2,105 - 709,615 14,192 723,807 2060 723,807 2,269 - 721,538 14,431 735,969 2061 735,969 1,552 - 734,417 14,688 749,105 2062 749,105 1,552 - 747,554 14,951 762,505 2063 762,505 1,552 - 760,953 15,219 776,172 2064 776,172 1,556 - 774,617 15,492 790,109 2065 790,109 1,552 - 788,557 15,771 804,329 2066 804,329 1,552 - 802,777 16,056 818,833 2067 818,833 1,552 - 817,281 16,346 833,627 2068 833,627 1,556 - 832,071 16,641 848,712 2069 848,712 1,552 - 847,161 16,943 864,104 2070 864,104 1,552 - 862,553 17,251 879,804 2071 879,804 1,552 - 878,252 17,565 895,817 2072 895,817 1,556 - 894,261 17,885 912,147 2073 912,147 1,552 - 910,595 18,212 928,807 2074 928,807 1,552 - 927,255 18,545 945,800 2075 945,800 1,552 - 944,249 18,885 963,134 2076 963,134 1,556 - 961,578 19,232 980,810 2077 980,810 1,552 - 979,258 19,585 998,843 2078 998,843 1,552 - 997,292 19,946 1,017,238 2079 1,017,238 1,552 - 1,015,686 20,314 1,036,000 2080 1,036,000 1,556 - 1,034,444 20,689 1,055,133 2081 1,055,133 1,552 - 1,053,581 21,072 1,074,653 2082 1,074,653 1,552 - 1,073,102 21,462 1,094,564 2083 1,094,564 1,552 - 1,093,012 21,860 1,114,872 2084 1,114,872 1,556 - 1,113,316 22,266 1,135,583 2085 1,135,583 1,552 - 1,134,031 22,681 1,156,712 2086 1,156,712 2,079 - 1,154,633 23,093 1,177,726 2087 1,177,726 2,079 - 1,175,647 23,513 1,199,160 2088 1,199,160 2,085 - 1,197,075 23,942 1,221,017 2089 1,221,017 2,079 - 1,218,938 24,379 1,243,317 2090 1,243,317 2,079 - 1,241,238 24,825 1,266,063 2091 1,266,063 2,079 - 1,263,984 25,280 1,289,263 2092 1,289,263 2,085 - 1,287,179 25,744 1,312,922 2093 1,312,922 2,079 - 1,310,844 26,217 1,337,060 2094 1,337,060 2,079 - 1,334,982 26,700 1,361,681 2095 1,361,681 2,079 - 1,359,602 27,192 1,386,794 2096 1,386,794 2,085 - 1,384,710 27,694 1,412,404 2097 1,412,404 2,079 - 1,410,325 28,207 1,438,532 2098 1,438,532 2,079 - 1,436,453 28,729 1,465,182

50 LR-N24-0040 Enclosure 1

Table 3-PB2-SLR (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2099 1,465,182 2,079 - 1,463,103 29,262 1,492,365 2100 1,492,365 2,079 - 1,490,286 29,806 1,520,092 2101 1,520,092 2,079 - 1,518,013 30,360 1,548,374 2102 1,548,374 2,079 - 1,546,295 30,926 1,577,221 2103 1,577,221 2,079 - 1,575,142 31,503 1,606,645 2104 1,606,645 2,085 - 1,604,560 32,091 1,636,651 2105 1,636,651 7,246 - 1,629,405 32,588 1,661,994 2106 1,661,994 30,102 - 1,631,891 32,638 1,664,529 2107 1,664,529 70,241 - 1,594,289 31,886 1,626,174 2108 1,626,174 73,868 188 1,552,119 31,042 1,583,161 2109 1,583,161 35,259 1,023 1,546,879 30,938 1,577,816 2110 1,577,816 35,259 1,023 1,541,534 30,831 1,572,365 2111 1,572,365 23,359 664 1,548,342 30,967 1,579,308 2112 1,579,308 4,095 - 1,575,213 31,504 1,606,717 2113 1,606,717 12,039 - 1,594,678 31,894 1,626,572 Total $ 471,385 $ 2,897 $ 1,402,793

1 Beginning of Year Trust Fund Balance in 2051 is based only on the amount of PBAPS Unit 2 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($409.0M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.3a, Unit 2, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.3b, Unit 2, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2053 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after th e projected completion of decommissioning in 2113 are administrative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

51 LR-N24-0040

Table 3-PB3 PBAPS Unit 3 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2032 $ 472,731 $ 791 $ - $ 471,940 $ 9,439 $ 481,379 2033 481,379 1,578 - 479,800 9,596 489,396 2034 489,396 19,269 - 470,127 9,403 479,529 2035 479,529 47,114 - 432,415 8,648 441,063 2036 441,063 10,925 - 430,138 8,603 438,741 2037 438,741 8,955 - 429,787 8,596 438,382 2038 438,382 8,955 - 429,428 8,589 438,016 2039 438,016 8,955 - 429,062 8,581 437,643 2040 437,643 2,609 - 435,034 8,701 443,735 2041 443,735 1,632 - 442,103 8,842 450,945 2042 450,945 1,632 - 449,314 8,986 458,300 2043 458,300 1,632 - 456,668 9,133 465,802 2044 465,802 1,636 - 464,166 9,283 473,449 2045 473,449 1,632 - 471,818 9,436 481,254 2046 481,254 1,632 - 479,622 9,592 489,215 2047 489,215 1,632 - 487,583 9,752 497,335 2048 497,335 1,636 - 495,699 9,914 505,613 2049 505,613 1,632 - 503,981 10,080 514,061 2050 514,061 1,632 - 512,429 10,249 522,678 2051 522,678 1,632 - 521,046 10,421 531,467 2052 531,467 1,636 - 529,831 10,597 540,428 2053 540,428 1,632 - 538,796 10,776 549,572 2054 549,572 1,632 - 547,941 10,959 558,900 2055 558,900 1,632 - 557,268 11,145 568,413 2056 568,413 1,636 - 566,777 11,336 578,113 2057 578,113 1,632 - 576,481 11,530 588,011 2058 588,011 1,632 - 586,379 11,728 598,107 2059 598,107 1,632 - 596,476 11,930 608,405 2060 608,405 1,636 - 606,769 12,135 618,904 2061 618,904 1,632 - 617,273 12,345 629,618 2062 629,618 1,632 - 627,987 12,560 640,546 2063 640,546 1,632 - 638,915 12,778 651,693 2064 651,693 1,636 - 650,057 13,001 663,058 2065 663,058 1,632 - 661,427 13,229 674,655 2066 674,655 2,142 - 672,513 13,450 685,963 2067 685,963 2,142 - 683,821 13,676 697,498 2068 697,498 2,148 - 695,349 13,907 709,256 2069 709,256 2,142 - 707,114 14,142 721,256 2070 721,256 2,142 - 719,114 14,382 733,497 2071 733,497 2,142 - 731,354 14,627 745,981 2072 745,981 2,148 - 743,833 14,877 758,710 2073 758,710 2,142 - 756,568 15,131 771,699 2074 771,699 2,142 - 769,557 15,391 784,948 2075 784,948 2,142 - 782,806 15,656 798,462 2076 798,462 2,148 - 796,314 15,926 812,240 2077 812,240 2,142 - 810,098 16,202 826,300 2078 826,300 2,142 - 824,157 16,483 840,641 2079 840,641 2,142 - 838,498 16,770 855,268

52 LR-N24-0040 Enclosure 1

Table 3-PB3 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2080 855,268 2,142 - 853,126 17,063 870,189 2081 870,189 2,142 - 868,046 17,361 885,407 2082 885,407 2,142 - 883,265 17,665 900,930 2083 900,930 2,142 - 898,788 17,976 916,764 2084 916,764 2,148 - 914,616 18,292 932,908 2085 932,908 2,142 - 930,766 18,615 949,381 2086 949,381 2,688 - 946,693 18,934 965,627 2087 965,627 20,516 - 945,111 18,902 964,013 2088 964,013 57,306 - 906,707 18,134 924,841 2089 924,841 82,019 - 842,822 16,856 859,678 2090 859,678 44,568 1,011 814,099 16,282 830,381 2091 830,381 44,362 1,017 785,003 15,700 800,703 2092 800,703 41,182 869 758,651 15,173 773,824 2093 773,824 13,241 - 760,584 15,212 775,795 Total $ 498,717 $ 2,897 $ 804,678

1 Beginning of Year Trust Fund Balance in 2032 is based only on the amount of PBAPS Unit 3 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($403.5M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.4a, Unit 3, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.4b, Unit 3, SAFSTOR Alternative Spent Fuel Management Expenditures, adjusted by 20 years to account for shut down in 2034 vice 2054. Costs prior to shut down in 2034 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2093 are administrative expenses for final reports to NRC under site closeout activities and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are e scalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

53 LR-N24-0040

Table 3-PB3-0 PBAPS Unit 3 Annual SAFSTOR Decommissioning Cash Flow -

Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 -

Sensitivity Analysis Using 0% RROR during Operations 1 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2032 $ 403,472 $ 791 $ - $ 402,680 $ - $ 402,680 2033 402,680 1,578 - 401,102 - 401,102 2034 401,102 19,269 - 381,832 7,637 389,469 2035 389,469 47,114 - 342,355 6,847 349,202 2036 349,202 10,925 - 338,277 6,766 345,042 2037 345,042 8,955 - 336,088 6,722 342,810 2038 342,810 8,955 - 333,855 6,677 340,532 2039 340,532 8,955 - 331,577 6,632 338,209 2040 338,209 2,609 - 335,600 6,712 342,312 2041 342,312 1,632 - 340,681 6,814 347,494 2042 347,494 1,632 - 345,863 6,917 352,780 2043 352,780 1,632 - 351,148 7,023 358,171 2044 358,171 1,636 - 356,535 7,131 363,666 2045 363,666 1,632 - 362,034 7,241 369,275 2046 369,275 1,632 - 367,644 7,353 374,996 2047 374,996 1,632 - 373,365 7,467 380,832 2048 380,832 1,636 - 379,196 7,584 386,780 2049 386,780 1,632 - 385,149 7,703 392,852 2050 392,852 1,632 - 391,220 7,824 399,044 2051 399,044 1,632 - 397,413 7,948 405,361 2052 405,361 1,636 - 403,725 8,075 411,800 2053 411,800 1,632 - 410,168 8,203 418,371 2054 418,371 1,632 - 416,740 8,335 425,075 2055 425,075 1,632 - 423,443 8,469 431,912 2056 431,912 1,636 - 430,276 8,606 438,881 2057 438,881 1,632 - 437,250 8,745 445,995 2058 445,995 1,632 - 444,363 8,887 453,251 2059 453,251 1,632 - 451,619 9,032 460,651 2060 460,651 1,636 - 459,015 9,180 468,196 2061 468,196 1,632 - 466,564 9,331 475,895 2062 475,895 1,632 - 474,264 9,485 483,749 2063 483,749 1,632 - 482,118 9,642 491,760 2064 491,760 1,636 - 490,124 9,802 499,926 2065 499,926 1,632 - 498,295 9,966 508,261 2066 508,261 2,142 - 506,119 10,122 516,241 2067 516,241 2,142 - 514,099 10,282 524,381 2068 524,381 2,148 - 522,233 10,445 532,677 2069 532,677 2,142 - 530,535 10,611 541,146 2070 541,146 2,142 - 539,003 10,780 549,783 2071 549,783 2,142 - 547,641 10,953 558,594 2072 558,594 2,148 - 556,446 11,129 567,575 2073 567,575 2,142 - 565,433 11,309 576,741 2074 576,741 2,142 - 574,599 11,492 586,091 2075 586,091 2,142 - 583,949 11,679 595,628 2076 595,628 2,148 - 593,480 11,870 605,349 2077 605,349 2,142 - 603,207 12,064 615,271

54 LR-N24-0040 Enclosure 1

Table 3-PB3-0 (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2078 615,271 2,142 - 613,129 12,263 625,391 2079 625,391 2,142 - 623,249 12,465 635,714 2080 635,714 2,142 - 633,572 12,671 646,243 2081 646,243 2,142 - 644,101 12,882 656,983 2082 656,983 2,142 - 654,841 13,097 667,938 2083 667,938 2,142 - 665,795 13,316 679,111 2084 679,111 2,148 - 676,963 13,539 690,503 2085 690,503 2,142 - 688,360 13,767 702,127 2086 702,127 2,688 - 699,439 13,989 713,428 2087 713,428 20,516 - 692,912 13,858 706,770 2088 706,770 57,306 - 649,464 12,989 662,453 2089 662,453 82,019 - 580,434 11,609 592,043 2090 592,043 44,568 1,011 546,464 10,929 557,393 2091 557,393 44,362 1,017 512,015 10,240 522,255 2092 522,255 41,182 869 480,204 9,604 489,808 2093 489,808 13,241 - 476,567 9,531 486,098 Total $ 498,717 $ 2,897 $ 584,241

1 Beginning of Year Trust Fund Balance in 2032 is based only on the amount of PBAPS Unit 3 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($403.5M), taking credit for a 0% annual RROR up to the license expiration date.

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.4a, Unit 3, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.4b, Unit 3, SAFSTOR Alternative Spent Fuel Management Expenditures, adjusted by 20 years to account for shut down in 2034 vice 2054. Costs prior to shut down in 2034 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after the projected completion of decommissioning in 2093 are administrative expenses for final reports to NRC under site closeout activities and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are e scalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

55 LR-N24-0040

Table 3-PB3-SLR PBAPS Unit 3 Annual SAFSTOR Decommissioning Cash Flow - License Expiration 2054

- Excluding Funds in Non-50.75 Subaccounts as of December 31, 2023 (2023 dollars, thousands)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2052 $ 702,454 $ 791 $ - $ 701,662 $ 14,033 $ 715,696 2053 715,696 1,578 - 714,117 14,282 728,400 2054 728,400 19,269 - 709,130 14,183 723,313 2055 723,313 47,114 - 676,198 13,524 689,722 2056 689,722 10,925 - 678,797 13,576 692,373 2057 692,373 8,955 - 683,419 13,668 697,087 2058 697,087 8,955 - 688,133 13,763 701,895 2059 701,895 8,955 - 692,941 13,859 706,800 2060 706,800 2,609 - 704,191 14,084 718,274 2061 718,274 1,632 - 716,643 14,333 730,976 2062 730,976 1,632 - 729,344 14,587 743,931 2063 743,931 1,632 - 742,300 14,846 757,146 2064 757,146 1,636 - 755,510 15,110 770,620 2065 770,620 1,632 - 768,988 15,380 784,368 2066 784,368 1,632 - 782,736 15,655 798,391 2067 798,391 1,632 - 796,760 15,935 812,695 2068 812,695 1,636 - 811,059 16,221 827,280 2069 827,280 1,632 - 825,648 16,513 842,161 2070 842,161 1,632 - 840,530 16,811 857,340 2071 857,340 1,632 - 855,709 17,114 872,823 2072 872,823 1,636 - 871,187 17,424 888,611 2073 888,611 1,632 - 886,979 17,740 904,719 2074 904,719 1,632 - 903,087 18,062 921,149 2075 921,149 1,632 - 919,517 18,390 937,908 2076 937,908 1,636 - 936,272 18,725 954,997 2077 954,997 1,632 - 953,366 19,067 972,433 2078 972,433 1,632 - 970,801 19,416 990,217 2079 990,217 1,632 - 988,586 19,772 1,008,358 2080 1,008,358 1,636 - 1,006,722 20,134 1,026,856 2081 1,026,856 1,632 - 1,025,224 20,504 1,045,729 2082 1,045,729 1,632 - 1,044,097 20,882 1,064,979 2083 1,064,979 1,632 - 1,063,348 21,267 1,084,615 2084 1,084,615 1,636 - 1,082,979 21,660 1,104,638 2085 1,104,638 1,632 - 1,103,007 22,060 1,125,067 2086 1,125,067 2,142 - 1,122,925 22,458 1,145,383 2087 1,145,383 2,142 - 1,143,241 22,865 1,166,106 2088 1,166,106 2,148 - 1,163,958 23,279 1,187,237 2089 1,187,237 2,142 - 1,185,094 23,702 1,208,796 2090 1,208,796 2,142 - 1,206,654 24,133 1,230,787 2091 1,230,787 2,142 - 1,228,645 24,573 1,253,218 2092 1,253,218 2,148 - 1,251,070 25,021 1,276,091 2093 1,276,091 2,142 - 1,273,949 25,479 1,299,428 2094 1,299,428 2,142 - 1,297,286 25,946 1,323,231 2095 1,323,231 2,142 - 1,321,089 26,422 1,347,511 2096 1,347,511 2,148 - 1,345,363 26,907 1,372,270 2097 1,372,270 2,142 - 1,370,128 27,403 1,397,530 2098 1,397,530 2,142 - 1,395,388 27,908 1,423,296 2099 1,423,296 2,142 - 1,421,154 28,423 1,449,577

56 LR-N24-0040 Enclosure 1

Table 3-PB3-SLR (Continued)

Beginning of Year End of Year Beginning of Year Reactor ISFSI Trust Fund Balance Trust Fund Trust Fund Year Trust Fund Balance 1 Cost 2 Cost 2 Less Costs Earnings 3 Balance 2100 1,449,577 2,142 - 1,447,434 28,949 1,476,383 2101 1,476,383 2,142 - 1,474,241 29,485 1,503,726 2102 1,503,726 2,142 - 1,501,583 30,032 1,531,615 2103 1,531,615 2,142 - 1,529,473 30,589 1,560,062 2104 1,560,062 2,148 - 1,557,914 31,158 1,589,072 2105 1,589,072 2,142 - 1,586,930 31,739 1,618,669 2106 1,618,669 2,688 - 1,615,981 32,320 1,648,300 2107 1,648,300 20,516 - 1,627,784 32,556 1,660,340 2108 1,660,340 57,306 - 1,603,034 32,061 1,635,094 2109 1,635,094 82,019 - 1,553,075 31,062 1,584,137 2110 1,584,137 44,568 1,011 1,538,558 30,771 1,569,329 2111 1,569,329 44,362 1,017 1,523,950 30,479 1,554,429 2112 1,554,429 41,182 869 1,512,378 30,248 1,542,626 2113 1,542,626 13,241 - 1,529,385 30,588 1,559,973 Total $ 498,717 $ 2,897 $ 1,359,133

1 Beginning of Year Trust Fund Balance in 2052 is based only on the amount of PBAPS Unit 3 NDT funds accumulated as of December 31, 2023, and intended to be dedicated for radiological decommissioning ($403.5M), taking credit for a 2% annual RROR allowed by 10 CFR 50.75(e)(1)(i).

2 Radiological decommissioning costs only. Reacto r costs are from Attachment 3, Table 3.4a, Unit 3, SAFSTOR Alternative License Termination Expenditures, and ISFSI costs are from Attachment 3, Table 3.4b, Unit 3, SAFSTOR Alternative Spent Fuel Management Expenditures. Costs prior to shut down in 2054 are planning costs allowed by 10 CFR 50.82(a)(8)(ii). Costs after th e projected completion of decommissioning in 2113 are administrative expenses for final reports to NRC under site closeout activi ties and therefore not included. Costs are pro-rated for PSEGs ownership share of 50%. Costs are escalated from December 2021 dollars to December 2023 dollars by applying a factor of 1.128, thereafter using a 0% escalation rate. Columns may not add due to rounding.

3 Credit for a 2% annual RROR on Beginning of Year Trust Fund Balance Less Costs.

57 LR-N24-0040

Enclosure 2

Salem Generating Station, Units 1 and 2

Hope Creek Generating Station

Peach Bottom Atomic Power Station, Units 2 and 3

Proposed Amendment to the Decommissioning Trust Agreement

LR-N24-0040

Proposed Amendment to the PSEG Nuclear LLC Master Decommissioning Trust Agreement for Salem Generating Station, Units 1 and 2 Hope Creek Generation Station, and Peach Bottom Atomic Power Station, Units 2 and 3

Contingent upon the NRC granting exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) as requested in Enclosure 1, PSEG provides notification pursuant to 10 CFR 50.75(h)(1)(iii) and Section 10.06 of the Trust Agreement of a proposed amendment to the Trust Agreement. The amendment involves a change to the provisions related to withdrawals from the NDT and would establish that funds in Non-50.75 Subaccounts in the NDT are not subject to the NRCs restrictions and reporting requirements for NDT funds dedicated for activities that fall under the NRCs definition of decommission in 10 CFR 50.2 (radiological decommissioning). Thus, funds transferred into a Non-50.75 Subaccount would be reallocated to pay for activities that are part of the larger decommissioning process and not exclusively restricted to radiological decommissioning.

The requested exemptions in Enclosure 1 would exclude the requirements of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) from applying to funds transferred into Non-50.75 Subaccounts as described in the exemption request. However, funds in Non-50.75 Subaccounts remain subject to other applicable requirements including the Trust Agreement. The overarching requirement in the Trust Agreement is that the trust must be used for the exclusive purpose of providing funds for the decommissioning of the plants, to pay the administrative costs and other incidental expenses of the trust funds, and to make certain investments.

The purpose of a Non-50.75 Subaccount is to separately account for NDT funds to pay for decommissioning costs as defined in the Treasury Department regulations for Section 468A of the Internal Revenue Code. Specifically, 26 CFR 1.468A-1, Nuclear decommissioning costs; general rules, paragraph (b)(6) defines decommissioning costs to include costs for radiological and non-radiological activities and ce rtain spent fuel management activities whether the plant is operating or has permanently ceased operations. The proposed change to Section 1.01, Definitions, defines the term Non-50.75 Subaccount to reflect this purpose.

In the proposed Section 1.01 definition, the phrase having once been dedicated refers to funds dedicated for radiological decommissioning in the NDT as reported in the last submitted decommissioning funding status report under 10 CFR 50.75(f)(1). Thus, the definition serves to reinforce that funds in a Non-50.75 Subaccount are not expected to be involved in the transfer or reallocation of such funds. Rather, earnings from NDT funds dedicated for radiological decommissioning will be periodically transferred into the Non-50.75 Subaccounts under the conditions specified in the exemption request. Subsequent earnings from funds held in a Non-50.75 Subaccount will be accumulated within that same segregated subaccount, distinct from earnings from other funds in the NDT. During decommissioning, funds in Non-50.75 Subaccounts would be available, but not exclusively dedicated for, radiological decommissioning.

Section 2.02, Use of Assets, restricts disbur sements or payments from the NDT, other than for payment of ordinary administrative costs and other incidental expenses of the fund, to

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withdrawals for radiological decommissioning expenses under 10 CFR 50.82(a)(8) or transfer to another acceptable financial assurance method until final radiological decommissioning has been completed. Therefore, the proposed change to Section 2.02 is needed to allow funds accumulated in the Non-50.75 Subaccounts to be used for their intended purpose.

Funds in the Non-50.75 Subaccounts would not be exclusively dedicated for radiological decommissioning and are separately maintained in the NDT from funds dedicated to radiological decommissioning, therefore their withdrawals cannot affect the amount of funds dedicated to radiological decommissioning remaining in the NDT. Accordingly, the proposed change to Section 4.01, Payment of Decommissioning Costs, would exclude their withdrawals from the requirements for prior notice to the NRC.

The proposed amendment to the Trust Agreement consists of the following changes:

1. The following definition shall be added to Section 1.0.1, Definitions:

(54) Non-50.75 Subaccount shall mean a subaccount established within a Fund, which is intended to accumulate funds for decommissioning costs other than those amounts having once been dedicated pursuant to 10 CFR 50.75 for decommissioning of the Plants as defined by the NRC in its regulations and issuances. Funds in a Non-50.75 Subaccount are not subject to the requirements of 10 CFR 50.75(h)(1)(iv) and are not subject to the restrictions on the use of funds in 10 CFR 50.82(a)(8).

2. The first sentence of Section 2.02, Use of Assets, shall be restated and a new sentence added to read as follows:

The use of assets in both the Qualified Funds and Nonqualified Funds, excluding assets in a Non-50.75 Subaccount, shall be limited to expenses related to decommissioning of the Plants as defined by the NRC in its regulations and issuances, and as provided in the units' licenses and any amendments thereto. The use of assets in a Non-50.75 Subaccount shall be limited to expenses related to decommissioning costs as defined by the Treasury Department in its regulations and issuances.

3. The first sentence of Section 4.01, Payment of Decommissioning Costs, shall be restated to read as follows:

Except for withdrawals being made under 10 CFR 50.82(a)(8) as exempted, as applicable, by NRC approved site-specific exemptions, withdrawals being made from a Non-50.75 Subaccount, or for payments of expenses of administration pursuant to Section 4.02, no disbursements or payments from the trust shall be made by the Trustee until the Trustee has first given the NRC Director, Office of Nuclear Reactor Regulation, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days notice of payment.

The above changes are the same as previously proposed in PSEG Nuclear letter to NRC, Notice of Proposed Amendment to Decommissioning Trust Agreement, dated September 8, 2023 (ML23252A001), which included a mark-up of the Trust Agreement in Attachment 3.

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Attachment 1

Salem Generating Station, Units 1 and 2

Site-Specific Decommissioning Cost Estimate

(124 pages including this cover page)

LR-N24-0040

Attachment 2

Hope Creek Generating Station

Site-Specific Decommissioning Cost Estimate

(100 pages including this cover page)

LR-N24-0040

Attachment 3

Peach Bottom Atomic Power Station, Units 2 and 3

Site-Specific Decommissioning Cost Estimate

(129 pages including this cover page)