Text

Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan
	ML24353A260
Person / Time
Site:	Dresden
Issue date:	12/18/2024
From:	Lueshen K; Constellation Energy Generation
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24353A260	List: RS-24-135, Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan;
References
	RS-24-135
	Download: ML24353A260 (1)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-24-135 10 CFR 50.54(bb) 10 CFR 50.75(f)(3)

December 18, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Unit 2 Renewed Facility Operating License No. DPR-19 NRC Docket Nos. 50-237 and 72-37

Subject:

Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan

Reference:

Letter from P. R. Simpson (Constellation Energy Generation, LLC) to U.S.

Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations,"

dated March 23, 2023 (ML23082A312)

In accordance with 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning,"

paragraph (f)(3), "Each power reactor licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission." Constellation Energy Generation, LLC (CEG) is submitting this letter to provide a preliminary decommissioning cost estimate in accordance with 10 CFR 50.75(f)(3) and irradiated fuel management plan in accordance with 10 CFR 50.54(bb) for Dresden Nuclear Power Station, Unit 2 (DNPS), as the Facility Operating License (FOL) expires on December 22, 2029.

CEG has not made a final determination of the decommissioning approach for DNPS Unit 2. For purposes of this submittal, the SAFSTOR option has been selected. CEG reserves the right to choose an alternative decommissioning option at the actual time of decommissioning in accordance with its business needs, recognizing the need to assure the chosen option meets NRC requirements for decommissioning funding.

of this submittal contains a preliminary decommissioning cost estimate (DCE) for DNPS Unit 2. The cost estimate is a preliminary estimate of anticipated costs and will be updated at various times as deemed appropriate by CEG and/or in compliance with regulatory requirements. The attached preliminary decommissioning cost estimate assumes that DNPS Unit 2 permanently ceases operations on December 22, 2029, in accordance with the DNPS Unit 2 FOL.

December 18, 2024 U.S. Nuclear Regulatory Commission Page 2 The latest Decommissioning Funding Report for DNPS Unit 2 was submitted as Attachment 10 of the referenced letter. The minimum formula cost amount using the formula in 10 CFR 50.75(c) was calculated assuming the labor, energy, and burial factors described in Attachment 1 of the referenced letter. The site-specific cost amount reported in the DCE is greater than the minimum formula cost amount, as required by 10 CFR 50.75(b)(1).

The major factors that could affect the cost estimate as well as contingencies to allow for unknown or unplanned occurrences during decommissioning are included in the attached preliminary DCE.

Additionally, soil and groundwater remediation costs are included in the cost estimate. The required soil remediation is based on evaluation of 10 CFR 50.75(g)(1) reports.

As discussed in 10 CFR 50.54(bb), "Conditions of licenses," paragraph (bb), a licensee shall "5 years before expiration of the reactor operating license,. submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."

Accordingly, Attachment 2 of this submittal includes the DNPS Unit 2 Irradiated Fuel Management Plan for NRC review and preliminary approval.

contains the projected annual cash flow from the DNPS Unit 2 decommissioning trust fund for decommissioning the site based on the Attachment 1 DCE. The Attachment 1, Table 6-2 costs have been escalated from January 2023 dollars to the January 2024 dollars shown in using an escalation rate of 3.33%. The costs for radiological decommissioning (i.e.,

license termination costs) and Independent Spent Fuel Storage Installation (ISFSI) decommissioning are reflected in Attachment 3 consistent with the definition of decommission in 10 CFR 50.2. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period.

contains the projected annual cash flow from the DNPS Unit 2 decommissioning trust fund for decommissioning (i.e., including radiological decommissioning and ISFSI decommissioning) and spent fuel management based on the Attachment 1 DCE. The Attachment 1, Table 6-2 costs have been escalated from January 2023 dollars to the January 2024 dollars shown in Attachment 4 using an escalation rate of 3.33%. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period. CEG recognizes that an exemption from 10 CFR 50.82(a)(8)(i)(A) is required to use decommissioning trust funds for expenses other than decommissioning activities as the term "decommission" is defined in 10 CFR 50.2.

December 18, 2024 U.S. Nuclear Regulatory Commission Page 3 As of December 31, 2023, DNPS Unit 2 decommissioning trust fund balances totaled $937.6 million which exceeds the amount required for decommissioning of the site and spent fuel management.

In accordance with 10 CFR 50.75(f)(1) and 10 CFR 50.82(8)(v) the financial assurance summary report will be updated and submitted to the NRC annually starting in 2025. The cost estimates and financial levels will be adjusted in accordance with Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors" and will be used to demonstrate funding assurance. If the funding assurance demonstration shows the decommissioning trust fund is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in the Regulatory Guide will be put in place at an appropriate time.

In accordance with 10 CFR 50.54(bb), a copy of this notification will be maintained until the expiration of the DNPS Unit 2 operating license. Additionally, CEG will notify the NRC of any significant changes in the proposed Irradiated Fuel Management Plan described in.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Jeff Dunlap at (779) 231-5216.

Respectfully, Kevin Lueshen Director, Licensing and Regulatory Affairs Constellation Energy Generation, LLC Attachments: 1.

Preliminary Decommissioning Cost Estimate for Dresden Nuclear Power Station, Unit 2

2.

Irradiated Fuel Management Plan for Dresden Nuclear Power Station, Unit 2

3.

Decommissioning Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2

4.

Decommissioning and Spent Fuel Management Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2 CC:

Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC NRR Project Manager - Dresden Nuclear Power Station Lueshen, Kevin Digitally signed by Lueshen, Kevin Date: 2024.12.18 12:46:51

-06'00'

Preliminary Decommissioning Cost Estimate for Dresden Nuclear Power Station, Unit 2

DECOM-2023-DCE-DRE Rev. 0 2023 DECOMMISSIONING COST ANALYSIS REPORT Dresden Nuclear Power Station Unit 2 November 2024

DECOM-2023-DCE-DRE Rev. 0 Page i of vi APPROVALS PREPARER:

James Escarrilla___________________________________________________________

PREPARER SIGNATURE DATE REVIEWER:

Jill Fisher___________________________________________________________________

REVIEWER SIGNATURE DATE APPROVER:

Jeffrey Dunlap_______________________________________________________________

APPROVER SIGNATURE DATE Escarrilla, James Digitally signed by Escarrilla, James Date: 2024.11.08 11:03:22 -05'00' Fisher, Jill T.

Digitally signed by Fisher, Jill T.

Date: 2024.11.18 13:25:27 -06'00' Dunlap, Jeffrey A.

Digitally signed by Dunlap, Jeffrey A.

Date: 2024.11.18 14:35:31 -06'00'

DECOM-2023-DCE-DRE Rev. 0 Page ii of vi EXECUTIVE

SUMMARY

This report presents the cost to decontaminate and dismantle Dresden Nuclear Power Station Unit 2. The primary objectives of the decommissioning project are to remove the unit from service, and reduce residual radioactivity to levels permitting unrestricted release, so that the plants operating licenses can be terminated within 60-years after permanent cessation of operations.

Although Constellation is not obligated to restore the site to a greenfield condition, the costs to do so are conservatively included in the DCE.

The selection of a preferred decommissioning alternative is influenced by numerous factors including the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns. The alternative and/or plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.

This report presents the SAFSTOR (license termination occurs 60 years after permanent shutdown) method for Dresden Unit 2.

The cost elements are assigned to one of five subcategories: Radiological Decommissioning (radiological remediation), Spent Fuel Management, Site Restoration, ISFSI Radiological Decommissioning, Radiological Decommissioning Planning. The Radiological Decommissioning and Radiological Decommissioning Planning subcategories are used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR 50.75). The cost reported for this subcategory is generally sufficient to terminate a units operating license, recognizing that there may be some additional cost impact from spent fuel management.

Section 2 of this report, Decommissioning Scenario and Schedule, discusses the three available decommissioning scenarios, and provides the schedule for SAFSTOR. The methodology used to develop the estimated costs, including financial aspects, is discussed in Section 3, Cost Estimate Methodology. Section 4, Assumptions, provides a discussion of the assumptions used in developing the various costs elements and considerations; including the cost associated with decontamination and component removal, waste disposal, and labor. These assumptions serve as the foundation in the development of the anticipated cost to decommission Dresden Generating Station Unit 2.

The major milestones associated with the decommissioning time periods for the SAFSTOR scenario are discussed in Section 5, Schedule Assumptions.

The following tables summarize the estimated costs for the SAFSTOR scenario reflecting the various cost elements. Additional detail regarding the estimated costs is provided in Section 6 of this report.

DECOM-2023-DCE-DRE Rev. 0 Page iii of vi Dresden SAFSTOR Scenario Cost (thousands, January 2023 dollars)

Cost Element Unit 2 Decontamination 18,331 Removal 174,138 Packaging 26,897 Transportation 14,458 Waste Disposal 78,026 Waste Processing 12,725 Program Management1 370,538 Security 127,724 Spent Fuel Storage 185,406 Insurance and Regulatory Fees 53,598 Energy 27,774 Characterization and Licensing Surveys 8,697 Property Taxes 51,476 Miscellaneous Equipment and Supplies 52,123 Total2 1,201,911 Cost Element Unit 2 Radiological Decommissioning 909,795 Spent Fuel Management 220,871 Site Restoration 57,368 ISFSI Radiological Decommissioning 7,153 Radiological Decommissioning Planning 6,724 Total2 1,201,911 1 Includes engineering costs.

2 Columns may not add up due to rounding.

DECOM-2023-DCE-DRE Rev. 0 Page iv of vi ACRONYMS AE Architect Engineer AIF/NESP Atomic Industrial Forum/National Environmental Studies Project ALARA As Low as Reasonably Achievable BWR Boiling Water Reactor CEA Control Element Assembly CFR Code of Federal Regulations D.C.

District of Columbia DCE Decommissioning Cost Estimate DOC Decommissioning Operations Contractor DOE Department of Energy DSAR Defueled Safety Analysis Report Constellation Constellation Energy Generation FEMA Federal Emergency Management Agency FLEX Diverse and Flexible Coping Strategies FOL Facility Operating License GAO Government Accountability Office GTCC Greater than Class C [Waste]

HTGR High Temperature Gas-Cooled Reactor IP Industrial Package ISFSI Independent Spent Fuel Storage Installation LLW Low Level Waste LSA Low Specific Activity LTP License Termination Plan MPC Multi-Purpose Canister MTHM Metric Tons Heavy Metal NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Report (NRC)

NWPA Nuclear Waste Policy Act (1982)

PSDAR Post Shutdown Decommissioning Activities Report RCS Reactor Coolant System RPV Reactor Pressure Vessel SCO Surface Contaminated Object SFP Spent Fuel Pool U.S.

United States WDF Work Difficulty [Adjustment] Factor

DECOM-2023-DCE-DRE Rev. 0 Page v of vi TABLE OF CONTENTS EXECUTIVE

SUMMARY

........................................................................................................... ii ACRONYMS............................................................................................................................iv

1.

OVERVIEW........................................................................................................................ 1

2.

DECOMMISSIONING SCENARIO AND SCHEDULE........................................................ 3 2.1.

Decommissioning Methods......................................................................................... 3 2.2.

Decommissioning Schedule........................................................................................ 3

3.

COST ESTIMATE METHODOLOGY................................................................................. 6 3.1.

Methodology Bases..................................................................................................... 6 3.2.

Financial Components of the Cost Model.................................................................... 6

4.

ASSUMPTIONS................................................................................................................. 8 4.1.

General....................................................................................................................... 8 4.2.

Labor Costs................................................................................................................. 9 4.3.

Transition Activities..................................................................................................... 9 4.4.

Non-Radioactive Waste............................................................................................... 9 4.5.

Radioactive Waste.................................................................................................... 10 4.6.

Component Removal................................................................................................. 11 4.7.

Spent Fuel Management........................................................................................... 12 4.8.

Independent Spent Fuel Storage Installation............................................................. 12 4.9.

Site Restoration......................................................................................................... 12 4.10. Site Conditions Following Decommissioning............................................................. 13

5.

SCHEDULE..................................................................................................................... 16 5.1.

Schedule Assumptions.............................................................................................. 16

6.

COST ESTIMATE............................................................................................................ 18

7.

REFERENCES................................................................................................................. 27

DECOM-2023-DCE-DRE Rev. 0 Page vi of vi Tables and Figures Figure 4-1: Unit 2 Total Labor Hours - SAFSTOR Scenario.................................................... 14 Table 4-1: Radioactive Waste - SAFSTOR Scenario.............................................................. 15 Table 5-1: Decommissioning Timeline - SAFSTOR Scenario................................................. 17 Table 6-1: SAFSTOR Scenario Cost....................................................................................... 19 Table 6-2: Unit 2 Total Annual Expenditures - SAFSTOR Scenario........................................ 20 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario.................................................... 22

DECOM-2023-DCE-DRE Rev. 0 Page 1 of 27

1. OVERVIEW This report presents decommissioning cost estimates for Dresden Nuclear Power Station Unit 2 (DRE 2). DRE 2 is approximately 8 miles east of Morris, Illinois, and 50 miles southwest of downtown Chicago. The Dresden site consists of approximately 2,500 acres owned by Constellation with an additional 17 acres of river frontage leased from the State of Illinois. The site includes the reactors and supporting structures on the north end (approximately 953 acres) and a large cooling pond (approximately 1,275 acres of the total 2,500 acres) on the south end.

The Dresden site includes two operating units, Units 2 and 3 as well as one permanently shut down unit, Unit 1. This report includes costs for the decommissioning of Unit 2 only. However, it is assumed that demolition and dismantlement of Units 1, 2, and 3 occurs on the same time line.

DRE 2 is a General Electric Boiling Water Reactor (BWR) licensed to generate 2957 megawatts-thermal (MWt). DRE 2 was originally analyzed for a "reference design" thermal output of 2255 MWt and designed to permit ultimate operation at power levels of about 2600 MWt. Analyses and modifications performed as part of the extended power uprate (EPU) support operation of the unit at 2957 MWt. The reactors and supporting infrastructure are located at the north end of the site adjacent to the Kankakee River. Other structures associated with the site include two independent spent fuel storage installation (ISFSI) pads, a radwaste storage mausoleum, two switchyards, training building, parking lots, sewage treatment plant, mechanical draft cooling towers, and site roads.

The primary objectives of the decommissioning project are to remove Unit 2 from service and reduce residual radioactivity to levels permitting unrestricted release, so that the facilitys operating license can be terminated within 60-years after permanent cessation of operations.

Although Constellation is not obligated to restore the site to a greenfield condition, the costs to do so are conservatively included in the DCE.

This analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering processes required to carry out the decommissioning of the nuclear unit. It also may not reflect the actual plan to decommission once DRE 2 is shutdown; the plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.

The cost elements are assigned to one of five subcategories:

(1) Radiological Decommissioning - this subcategory is used to accumulate costs that are consistent with decommissioning as defined by the Nuclear Regulatory Commission (NRC) in its financial assurance regulations (i.e., 10 CFR 50.75) and separately address the cost of radiological decommissioning as defined by 10 CFR 50.2. The cost reported for this subcategory along with the Radiological Decommissioning Planning subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from managing the spent fuel.

(2) Spent Fuel Management - this subcategory contains costs associated with the containerization and transfer of spent fuel from the wet storage pool to a Department of Energy (DOE) transport cask or to the ISFSI for interim storage, as well as the transfer of

DECOM-2023-DCE-DRE Rev. 0 Page 2 of 27 the spent fuel in storage at the ISFSI to the DOE. Costs are included for management of the ISFSI until such time that the transfer is complete. It does not include any costs related to the final storage of the spent fuel at a national repository.

(3) Site Restoration - this subcategory is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet below grade and backfilled to conform to local surface elevation.

(4) ISFSI Radiological Decommissioning - this subcategory is used to capture costs associated with activities directly related to radiological decontamination or dismantlement of the spent fuel dry storage facility as required by 10 CFR 72.30.

(5) Radiological Decommissioning Planning - this subcategory is used to accumulate costs associated with planning for radiological decommissioning that are incurred prior to the cessation of plant operations.

It should be noted that the costs assigned to these subcategories are allocations. Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the five subcategories. For example, Constellation may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to a Radiological Decommissioning support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.

The estimates were developed, and costs are presented in 2023 dollars. As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the station or during the decommissioning period.

DECOM-2023-DCE-DRE Rev. 0 Page 3 of 27

2. DECOMMISSIONING SCENARIO AND SCHEDULE 2.1.

DECOMMISSIONING METHODS The following decommissioning scenarios were evaluated:

(1) DECON - spent fuel is transferred to the ISFSI shortly after shutdown and decommissioning and dismantlement is performed concurrently with the spent fuel transfer campaign.

(2) Shortened SAFSTOR (SHORTSTOR) - spent fuel is transferred to the ISFSI and decommissioning starts after all fuel is transferred to the DOE.

(3) SAFSTOR - spent fuel is transferred to the ISFSI and the plant facility is left intact until the decommissioning starts sometime in the future (dormancy phase), with structures maintained in a sound condition. Decommissioning commences such that license termination is completed within the required 60-years.

The scenarios also recognize that spent fuel will be stored at the site in the spent fuel storage pool(s) and/or in an ISFSI until such time that it can be transferred to a DOE facility. The estimates also include the cost to operate and eventually decommission the ISFSI.

The selection of a preferred decommissioning scenario is influenced by numerous factors at the time of plant shutdown. These factors include the cost of each decommissioning scenario, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns. This report will describe the costs for the SAFSTOR method only.

2.2.

DECOMMISSIONING SCHEDULE The conceptual approach that the NRC has described in its regulations divides decommissioning into three phases; 1) the initial phase begins with the permanent shutdown and through the transition to storage or decommissioning activities, 2) the next phase encompasses activities during the storage period or during major decommissioning activities, or a combination of the two; and 3) the final phase pertains to the activities involved in radiological decommissioning and license termination. The decommissioning estimates developed herein are also divided into phases or periods; however, demarcation of the phases is based upon major milestones within the project or significant changes in the projected expenditures and differs from those presented by the NRC.

The major phases are:

Decommissioning Planning - Begins 2 years prior to shut down when a small utility staff, the Decommissioning Transition Organization (DTO), is established to perform planning and licensing activities and ends at plant shutdown.

Shutdown through Permanent Defuel - This is a short period (< 1 month) where the plant staff defuels the reactor. The only decommissioning activity during this period is continued planning by the DTO.

Permanent Defuel through Zirconium Fire Window - This period runs from permanent defuel until the end of the Zirconium fire (Zirc fire) window when the fuel no longer has enough heat to generate Zirc fire conditions in less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. A Decommissioning

DECOM-2023-DCE-DRE Rev. 0 Page 4 of 27 Organization (DO) is established during this period to meet all security, emergency planning, and fire protection requirements, but also performs activities to deenergize and deactivate plant systems and initiate the pool to pad activities required to move all the spent fuel from the SFP to the ISFSI.

End of Zirc Fire Window through All Fuel on Pad - Fuel is moved from the pool to the pad, and emergency planning and insurance requirements are reduced due to the end of the Zirc fire window.

All Fuel on the Pad through License Termination - Further reduction in emergency planning and security requirements due to the fact that all fuel is in dry storage at the ISFSI. This period ends when the NRC license has been terminated (SAFSTOR scenarios).

Site Restoration - Final demolition of any non-radiological structures, site grading and preparation for reuse of the land.

ISFSI Operations and Decommissioning (DECON scenario only) - The ISFSI continues to operate until the fuel is transferred to the Department of Energy. Following fuel transfer, the ISFSI is decommissioned, restored to a greenfield state, and the NRC license is terminated.

2.2.1.

SAFSTOR Schedule 2.2.1.1.

Pre-shutdown and Period 1 (Shutdown through Transition) - Preparations Prior to the permanent shutdown and defueling, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, characterization of the facility and major components, and the development of the Post Shutdown Decommissioning Activities Report (PSDAR).

Following the final shutdown and defueling, the site will be prepared to minimize operation and maintenance to those systems/components/areas that are required to support the safe handling and management of spent fuel. Those systems/components that will not be required will be isolated and removed from service. Radiation controls will be put in place to reduce radiation and contamination in areas that will need to be accessed to support decommissioning. Areas not needed will have access restricted to minimize radiation/contamination exposure and potential safety hazards. ISFSI expansion will occur and spent fuel in the spent fuel storage pool will be transferred to the ISFSI. The security area will be adjusted to reflect protection of equipment and areas necessary to support the safe handling and management of spent fuel.

2.2.1.2.

Period 2 - Dormancy Phase The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phase of the SAFSTOR scenario. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, maintenance of necessary area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel will perform maintenance and inspection activities to maintain safe conditions. The transfer of the spent fuel from the spent fuel pool to the ISFSI continues during this period until

DECOM-2023-DCE-DRE Rev. 0 Page 5 of 27 complete. Additionally, the transfer of the spent fuel from the ISFSI to the DOE occurs during this period.

2.2.1.3.

Period 3 - Site Reactivation and Decommissioning Preparations Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for decommissioning activities and the writing of work packages, activity specifications and decommissioning procedures are initiated. The environmental impact associated with the planned decommissioning activities is also considered. If the consequences of a planned decommissioning activity are predicted to be greater than what is bounded by previously evaluated environmental assessments or impact statements, a license amendment would have to be submitted to the NRC for the specific activity and the environmental report would have to be updated.

2.2.1.4.

Period 4 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and non-contaminated components and structures. Existing facilities will be modified, and/or temporary facilities will be constructed to support decommissioning, decontamination, and dismantling activities. Components and piping systems will be decontaminated as necessary to control (minimize) worker exposure and facilitate packaging and transportation. Piping and components no longer essential to support decommissioning operations will be removed. The reactor internal and external components will be removed. Some larger Nuclear Steam Supply System (NSSS) components may be decontaminated and sealed in such a manner as to serve as their own shipping/burial containers. The reactor will be segmented, removed, and placed in shielded casks. Activated portions of the reactor and other biological shield walls will be demolished by controlled processes.

The License Termination Plan (LTP), which includes the Final Survey Plan, is developed and submitted to the NRC during this period. Once the survey is complete, the results are provided to the NRC for their review and evaluation. Once the NRC approves the LTP, the final remediation of site facilities and services may start. Subsequently, the NRC independently confirms the radiological site conditions and approves a license amendment that releases the property, inclusive of the ISFSI, for unrestricted use.

2.2.1.5.

Period 5 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin.

Remaining structures are removed, exterior walls and foundations are removed to a nominal depth of three feet below grade, and non-contaminated concrete rubble produced by demolition activities is processed and then used to backfill foundation voids. The site area is graded and vegetation is established to inhibit erosion.

DECOM-2023-DCE-DRE Rev. 0 Page 6 of 27

3. COST ESTIMATE METHODOLOGY 3.1.

METHODOLOGY BASES The systematic approach used herein for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs. The costs and schedules follow the general guidance and sequence in Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors (Reference 7.1). The format and content of the estimates is consistent with the recommendations of Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Reference 7.2). The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates" (Reference 7.3) and the DOE "Decommissioning Handbook" (Reference 7.4).

The unit cost factors used in this analysis incorporate site-specific costs and the latest available information about worker productivity in decommissioning. The detail provided in the unit cost factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. The activity-dependent costs were estimated with the item quantities based on plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures are based on cost data from RSMeans (Reference 7.5).

Critical path was used to determine the total decommissioning program schedule and establish carrying costs, which include program management, administration, field engineering, equipment rental, quality assurance, and security.

3.2.

FINANCIAL COMPONENTS OF THE COST MODEL The cost model used provides distinct cost elements, however these distinct cost elements do not comprise the total estimated cost to accomplish the project goal. Additional factors as described below are also taken into consideration.

3.2.1.

Contingency Contingencies are necessary to provide assurance that sufficient funding will be available since the cost elements are based on ideal conditions and maximum efficiency. They are an integral part of the total cost to complete the decommissioning process and are expected to be fully expended. A contingency is applied on a line-item basis. Contingency, in this analysis, is not intended to address changes in price escalation and inflation in the cost of decommissioning over the remaining operating life of the station, or duration of the decommissioning program and dry fuel storage period.

Major activities (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency were examined. Individual activity contingencies ranged from 10% to 75%, depending on the degree of difficulty judged to be appropriate. The contingency values used in this study are as follows:

DECOM-2023-DCE-DRE Rev. 0 Page 7 of 27 Engineering 15%

Staffing - Utility and DOC Staff 15%

Decontamination 50%

Contaminated Removal (includes contaminated component removal and contaminated concrete removal) 25%

NSSS Component Removal 25%

Reactor Segmentation 75%

Reactor Waste Packaging 25%

Reactor Waste Transport 25%

Reactor Vessel Component Disposal 50%

Contaminated Component Packaging 10%

Contaminated Component Transport 15%

Low-Level Radioactive Waste Disposal 25%

Non-Radioactive Component Removal 15%

Supplies 25%

GTCC Disposal 25%

Other - includes: Operations and Maintenance Expense, Heavy Equipment and Tooling, and Construction 15%

Energy 15%

Characterization, Licensing and Termination Surveys 30%

Taxes, Fees, and Insurance 10%

Spent Fuel Transfer Costs 15%

ISFSI Decommissioning 25%

Low-Level Radioactive Waste Processing 15%

3.2.2.

Financial Risk This cost study does not include any specific costs for financial risk since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.

3.2.3.

Work Difficulty Factors Work difficulty factor (WDF) adjustments are used to account for the inefficiencies in working in the confined and/or hazardous environments within the power plant. WDFs are applied against the inventory of materials removed in the radiologically controlled areas. The cost model applies WDFs to account for access limitations, work breaks, respiratory protection, ALARA practices, and protective clothing.

The factors and their associated range of values were developed in conjunction with the process described in AIF/NESP-036 (Reference 7.3).

Because the use of radiation dose minimization practices is considered in the WDFs, changes to worker exposure limits may also impact the decommissioning cost and project schedule.

DECOM-2023-DCE-DRE Rev. 0 Page 8 of 27

4. ASSUMPTIONS The cost estimates herein assume Unit 2 ceases operation in 2029 and that the shutdown is pre-planned (i.e., there is no delay in transitioning the plant and workforce from operations or in obtaining regulatory relief from operating requirements, etc.). The estimates include additional resources to support the engineering, planning, and licensing efforts. The ISFSI is assumed to remain operational until the DOE transfers the spent fuel offsite. The estimate also includes the dismantling of non-essential structures and restoration of the site.

4.1.

GENERAL 4.1.1.

Energy The physical plant is assumed to be de-energized, except for those facilities associated with spent fuel storage. Minimal energy usage is assumed to support remaining plant staffing. Additional energy is required during active decommissioning.

4.1.2.

Emergency Planning Federal Emergency Management Agency (FEMA) and state and local fees associated with emergency planning are assumed to continue through the end of the Zirc fire window following the cessation of operations.

4.1.3.

Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums, and subsequent reductions based on regulatory requirements.

4.1.4.

Taxes All property taxes are assumed to be allocated to the operating unit at the site until such time that all units are permanently defueled. Once all units are defueled, property taxes are allocated to each unit starting at the operating rate. Tax payments decrease during decommissioning until reaching a minimum property tax payment for the site; this level is maintained for the balance of the decommissioning program.

4.1.5.

NRC Fees NRC charges are included to support the decommissioning program. The license fee is reduced based on the NRC fees for a reactor in decommissioning (Spent Fuel Storage/Reactor Decommissioning). The charges associated with NRC professional services for inspections and reviews are based on the NRC hourly rate and the anticipated level of participation commensurate with the decommissioning scenario and schedule.

4.1.6.

Contaminated Soil The estimate includes an allowance for the remediation of contaminated soil at the site as documented in the 10 CFR 50.75(g) file. This portion of the estimate may be affected by continued plant operations and/or future regulatory actions.

4.1.7.

Impact of Decommissioning Multi-Unit Sites For sites that have more than one unit on a site, there can be opportunities to achieve economies of scale by sharing costs between units and coordinating the sequence of work

DECOM-2023-DCE-DRE Rev. 0 Page 9 of 27 activities. This is true for DRE 2. The work associated with developing activity specifications and procedures are essentially identical between units 2 and 3, therefore costs associated with additional units are less than the first.

There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitation on when final status surveys can take place. There may also be common systems that reduce the overall site scope and cost. All of these aspects of a multi-unit site are factored into the work planning and associated costs for DRE 2.

4.2.

LABOR COSTS For purposes of this analysis, it is assumed that a Decommissioning Operations Contractor (DOC) will manage the decommissioning. Constellation will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases. Constellation provides the total site scope during planning, transition periods, and dormancy periods. Contract personnel will provide engineering services under the direction of Constellation.

Average labor costs are based on industry wide average salaries. Craft labor rates are based on the current craft labor contract. DOC labor costs were based on industry wide average salaries.

All costs include adders for pension and benefits, payroll taxes, corporate overhead, per diems, and profit where applicable. All labor costs are adjusted to account for regional differences between the sites. A profile of the projected staffing level for decommissioning for SAFSTOR is provided in Figure 4-1.

4.3.

TRANSITION ACTIVITIES Those systems and components that are not needed for the safe storage and handling of spent fuel will be removed from service and deactivated. Hazardous fluids will be drained and removed from retired plant equipment. Operating waste inventories will be processed by plant staff during the transition period.

Operation and maintenance costs for the spent fuel pool are included within the estimate until the spent fuel has been transferred to the ISFSI.

The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.

4.4.

NON-RADIOACTIVE WASTE 4.4.1.

Processed Water It is assumed that all water released will meet the state and federal release limits. This estimate assumes that processed water which meets state and federal release limits is disposed of without additional cost.

4.4.2.

Asbestos Abatement An allowance for the removal of asbestos has been added to the estimate to account for the removal and disposal costs.

DECOM-2023-DCE-DRE Rev. 0 Page 10 of 27 4.4.3.

Scrap and Salvage Metallic material generated is processed to the greatest extent possible to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration.

The existing plant equipment is considered obsolete and suitable for scrap as deadweight quantities only. No credit is taken for salvage value since it would be speculative, and any recovered value would be small in comparison to the overall decommissioning expenses.

4.5.

RADIOACTIVE WASTE The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities of radioactive material.

The waste material generated in the decontamination and dismantling of the site is primarily generated during Period 4 in the SAFSTOR scenario. Material that is considered potentially contaminated is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal.

The volumes of radioactive waste generated during the various decommissioning activities are calculated based on the container size and are summarized consistent with 10 CFR 61 classifications. Table 4-1 provides the radwaste volumes by class expected to be generated during decommissioning.

4.5.1.

Low-Level Radioactive Waste Disposal A significant portion of the waste material may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. The estimates reflect the savings from waste recovery/volume reduction when feasible.

All options and services currently available were taken into consideration regarding the disposition of the various waste streams produced by the decommissioning process. Disposal fees are calculated using representative costs. The disposal costs for Class A, B, and C waste were based upon a representative fleet cost. Class A processed and oil waste are assumed to be disposed of at a facility in Tennessee. All other Class A waste is assumed to be disposed of at a facility in Utah. Class B and C waste is assumed to be disposed of at a facility in Texas.

The waste volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.

4.5.2.

Greater Than Class C Radioactive Waste The dismantling of the components residing closest to the reactor core generally generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level waste with concentrations greater than the NRC limits for Class C waste (i.e., GTCC)). A small quantity of material generated during decommissioning will be GTCC waste; GTCC waste is expected to be a small percentage of the total waste volume. GTCC waste is assumed to be placed in spent fuel storage canisters and disposed of in a similar manner to that envisioned for spent fuel disposal.

DECOM-2023-DCE-DRE Rev. 0 Page 11 of 27 The federal government has the responsibility for the disposal of this material. However, the federal government has not identified a cost for disposing of GTCC, a schedule for acceptance, nor acceptance criteria for this material. For purposes of this analysis, the GTCC radioactive waste is assumed to be packaged and disposed of in a similar manner as high-level waste and at a cost equivalent to that envisioned for the spent fuel. 7 GTCC containers are assumed to be collected from unit 2 GTCC canisters will remain in storage until such time the DOE is ready to accept GTCC waste; it is assumed that the DOE would not accept this waste prior to completing the transfer of spent fuel.

4.5.3.

Transportation Methods The transport of all waste material and components will primarily be by a combination of truck and/or multi-wheeled transporter. Transportation costs for material requiring controlled disposal or processing are based upon the mileage to the respective disposal or processing site.

4.6.

COMPONENT REMOVAL 4.6.1.

Reactor Vessel and Internal Components The curie contents of the reactor vessel and internals are derived from those listed in NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," (Reference 7.6) and are based on a generic model for the reactor design. Additional short-lived isotopes were derived from NUREG/CR-0672, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," (Reference 7.7) and benchmarked to the long-lived values from NUREG/CR-3474 (Reference 7.6).

The reactor pressure vessel and internal components are assumed to be segmented for disposal in shielded, reusable transportation casks. Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology. Due to the uncertainty in the viability of disposing of the reactor vessel and internals as a self-contained package, segmentation is assumed as a bounding condition.

The disposal cost for the control blades removed from the vessel with the final core load are included within the estimates. Control blades are not Greater than Class C (GTCC) material.

4.6.2.

System Components Reactor piping and other NSSS components will be removed. Specialized equipment will be brought in as necessary. With proper closure of all openings, access ways, and penetrations, some larger components may be used as their own shipping and burial containers.

Radioactive piping and components will be removed using methods appropriate with their potential contamination level. Non-contaminated piping and components will be removed using conventional dismantlement and removal processes.

Components will be packaged and readied for transport in accordance with the intended disposition.

4.6.3.

Retired Components Any components that have been replaced and where the original components are stored on site at the time of shutdown are included in the cost of decommissioning. Since the components have

DECOM-2023-DCE-DRE Rev. 0 Page 12 of 27 already been removed from the plant, only packaging, disposal, and transportation costs are included for the components.

4.7.

SPENT FUEL MANAGEMENT Since the DOE is ultimately responsible for spent fuel disposal, the cost to dispose of spent fuel is not reflected within the estimate. However, the costs for spent fuel management while the fuel remains onsite are included and identified separately as "Spent Fuel Management.

For the purposes of this estimate, it is assumed the spent fuel will be packaged into multi-purpose containers (MPCs) over the first 5 years after shutdown. It is assumed that this period provides the necessary cooling for the spent fuel from the final core to meet the transport and/or storage requirements for decay heat. The estimate includes the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel containers from the ISFSI onto the transport vehicle.

Given the status of the DOE spent fuel program, Constellation estimates that 2035 will be the most likely year when the DOE begins spent fuel removal from the industry. Constellation assumed that the DOEs repository will have a maximum annual capacity of receiving 3,000 metric tons of uranium from the industry (Reference 7.8) and that the repository will accept spent fuel in the order in which it was removed (oldest fuel first). Additionally, Constellation assumes that it is able to re-assign its DOE spent fuel allocations between its large fleet of units to minimize on-site storage costs.

Based on the above, the spent fuel is projected to remain onsite until the end of 2050. Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer.

4.8.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION 4.8.1.

Construction, Operation and Maintenance An ISFSI has been constructed on site to support storage of all spent fuel. Expansion of the ISFSI is modeled to support the transfer of all the fuel in the SFP to the ISFSI. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. Operation and maintenance costs for the ISFSI are included as "Spent Fuel Management" expenditures in the estimate.

4.8.2.

ISFSI Decommissioning The ISFSI site and associated facilities also must have a proposed decommissioning plan. The cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities, 2) an adequate contingency factor (see Section 3.2.1),

and 3) the cost of meeting the criteria for unrestricted use.

4.9.

SITE RESTORATION The cost for the site restoration of non-contaminated structures has been calculated and is separately presented as "Site Restoration expenditures in this report.

While some structures may be dismantled, and the costs included in the decontamination process, the dismantlement of the remaining site structures are included in the site restoration

DECOM-2023-DCE-DRE Rev. 0 Page 13 of 27 costs. All structures are assumed to be removed to a nominal depth of three feet below grade and the voids backfilled with clean debris then topped with soil. Bulk excavation of soil and material in the immediate vicinity of the reactor building is included to remove various duct banks, catch basins, and underground utilities that may exist. The site will then be graded to conform to the adjacent landscape and vegetation is established to inhibit erosion.

Site utility and service piping are abandoned in place and manholes are backfilled. Asphalt surfaces and facility roads, except for the site access road, will be broken up and the material used as backfill on site.

The existing electrical switchyard is assumed to remain functional in support of the regional electrical distribution system.

Site restoration costs are included in all estimates for completeness but may not be a required activity at all sites. Although Constellation is not obligated to restore the site to a greenfield condition, the costs to do so are conservatively included in the DCE.

4.10. SITE CONDITIONS FOLLOWING DECOMMISSIONING Once the NRC determines that site radiological remediation has been performed in accordance with the LTP and the final radiation survey demonstrates that the facility is suitable for release, the NRC will terminate the facility license(s) (or amend the license(s) if an ISFSI is still present).

Building codes and environmental regulations will dictate the remaining actions in the decommissioning process.

DECOM-2023-DCE-DRE Rev. 0 Page 14 of 27 Figure 4-1: Unit 2 Total Labor Hours - SAFSTOR Scenario

DECOM-2023-DCE-DRE Rev. 0 Page 15 of 27 Table 4-1: Radioactive Waste - SAFSTOR Scenario Unit 2 Class / Type Volume (cf)

Mass (lb)

A / Bulk 134,623 10,614,821 A /

Containerized 164,251 8,339,158 A / DAW 26,497 529,947 A / Lead 353 250,000 A/ Oil 2,005 125,175 A / Processed 400,145 16,554,705 B

2,224 342,699 B / Resin 3,210 211,865 C

840 129,346 GTCC 2,534 518,021 Total /

Disposal 736,682 37,615,736

DECOM-2023-DCE-DRE Rev. 0 Page 16 of 27

5. SCHEDULE 5.1.

SCHEDULE ASSUMPTIONS The schedules for the decommissioning scenarios follow the sequence presented in the AIF/NESP-036 study, with changes to reflect recent experience, site-specific constraints, site restoration activities occurring after the license has been terminated, and spent fuel management plans.

The work activity durations are based on adjusted actual person-hour estimates. Durations are established between several milestones in each decommissioning period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs (program management, administration, field engineering, equipment rental, contracted services, etc.). A second critical path is used for the spent fuel. Dismantling of the fuel handing systems and decontamination of the spent fuel pools is dependent upon the timing of the transfer of the spent fuel assemblies to the ISFSI. The project schedule is included in Table 5-1 for the SAFSTOR decommissioning scenario.

DECOM-2023-DCE-DRE Rev. 0 Page 17 of 27 Table 5-1: Decommissioning Timeline - SAFSTOR Scenario Plant Status / Decommissioning Activities Start End Approximate Duration (years)

Pre-Shutdown Pre-Shutdown Planning Dec 2027 Dec 2029 2.0 Preparations for Dormancy Plant Shutdown / Defueling Outage Dec 2029 Dec 2029 0.1 System Abandonments and Fuel Transfer to ISFSI Dec 2029 Jan 2036 6.1 Final System Abandonments Feb 2036 Feb 2037 1.0 Dormancy Dormancy w/Dry Fuel Storage Feb 2037 Jan 2045 7.9 Fuel Shipping Jan 2045 Dec 2050 6.0 Dormancy w/o Fuel On-site Jan 2051 Aug 2082 31.6 Site Reactivation Preparations for D&D Aug 2082 Aug 2083 1

Decommissioning Operations Large Component Removal Aug 2083 Mar 2087 3.6 Plant Systems Removal and Building Decontamination1 Mar 2087 Mar 2089 2

License Termination Mar 2089 Dec 2089 0.8 Total from Shutdown to Completion of License Termination 60 Site Restoration Dec 2089 Jun 2092 2.5 1 ISFSI D&D occurs during this period along with plant D&D.

DECOM-2023-DCE-DRE Rev. 0 Page 18 of 27

6. COST ESTIMATE The estimate presented in this document reflects the total cost to decontaminate the nuclear unit, manage the spent fuel until the DOE transfers it to a federal facility, dismantle the plant, and restore the site for alternative use. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant).

Table 6-1 summarizes the estimated cost by cost element. Table 6-2 provides yearly expenditures broken down by cost contributor. The detailed cost estimate for SAFSTOR is provided in Table 6-3.

DECOM-2023-DCE-DRE Rev. 0 Page 19 of 27 Table 6-1: SAFSTOR Scenario Cost (thousands, January 2023 dollars)

Cost Element Unit 2 Decontamination 18,331 Removal 174,138 Packaging 26,897 Transportation 14,458 Waste Disposal 78,026 Waste Processing 12,725 Program Management1 370,538 Security 127,724 Spent Fuel Storage 185,406 Insurance and Regulatory Fees 53,598 Energy 27,774 Characterization and Licensing Surveys 8,697 Property Taxes 51,476 Miscellaneous Equipment and Supplies 52,123 Total5 1,201,911 Cost Element Unit 2 Radiological Decommissioning 909,795 Spent Fuel Management 220,871 Site Restoration 57,368 ISFSI Radiological Decommissioning 7,153 Radiological Decommissioning Planning 6,724 Total2 1,201,911 1 Includes engineering costs.

2 Columns may not add up due to rounding.

DECOM-2023-DCE-DRE Rev. 0 Page 20 of 27 Table 6-2: Unit 2 Total Annual Expenditures - SAFSTOR Scenario (thousands, January 2023 dollars)

Year Radiological Decommissioning Spent Fuel Management Site Restoration ISFSI Radiological Decommissioning Radiological Decommissioning Planning Total1 2027 0

0 0

0 97 97 2028 0

0 0

0 3,228 3,228 2029 0

0 0

0 3,399 3,399 2030 41,557 116,030 92 0

0 157,679 2031 36,860 1,823 17 0

0 38,701 2032 37,723 1,828 17 0

0 39,568 2033 34,679 1,823 17 0

0 36,519 2034 32,436 26,135 17 0

0 58,588 2035 28,589 28,312 17 0

0 56,918 2036 15,217 4,078 83 0

0 19,378 2037 4,387 1,823 8

0 0

6,218 2038 3,467 1,823 0

0 0

5,290 2039 3,467 1,823 0

0 0

5,290 2040 3,476 1,828 0

0 0

5,304 2041 3,467 1,823 0

0 0

5,290 2042 3,467 1,823 0

0 0

5,290 2043 3,467 1,823 0

0 0

5,290 2044 3,476 1,828 0

0 0

5,304 2045 3,384 4,373 0

0 0

7,757 2046 3,384 4,373 0

0 0

7,757 2047 3,384 4,373 0

0 0

7,757 2048 3,394 4,385 0

0 0

7,778 2049 3,384 4,373 0

0 0

7,757 2050 3,384 4,373 0

0 0

7,757 2051 3,754 0

0 0

0 3,754 2052 3,764 0

0 0

0 3,764 2053 3,754 0

0 0

0 3,754 2054 3,754 0

0 0

0 3,754 2055 3,754 0

0 0

0 3,754 2056 3,764 0

0 0

0 3,764 2057 3,754 0

0 0

0 3,754 2058 3,754 0

0 0

0 3,754 2059 3,754 0

0 0

0 3,754 2060 3,764 0

0 0

0 3,764

DECOM-2023-DCE-DRE Rev. 0 Page 21 of 27 Table 6-2: Unit 2 Total Annual Expenditures - SAFSTOR Scenario (continued)

(thousands, January 2023 dollars)

Year Radiological Decommissioning Spent Fuel Management Site Restoration ISFSI Radiological Decommissioning Radiological Decommissioning Planning Total1 2061 3,754 0

0 0

0 3,754 2062 3,754 0

0 0

0 3,754 2063 3,754 0

0 0

0 3,754 2064 3,764 0

0 0

0 3,764 2065 3,754 0

0 0

0 3,754 2066 3,754 0

0 0

0 3,754 2067 3,754 0

0 0

0 3,754 2068 3,764 0

0 0

0 3,764 2069 3,754 0

0 0

0 3,754 2070 3,754 0

0 0

0 3,754 2071 3,754 0

0 0

0 3,754 2072 3,764 0

0 0

0 3,764 2073 3,754 0

0 0

0 3,754 2074 3,754 0

0 0

0 3,754 2075 3,754 0

0 0

0 3,754 2076 3,764 0

0 0

0 3,764 2077 3,754 0

0 0

0 3,754 2078 3,754 0

0 0

0 3,754 2079 3,754 0

0 0

0 3,754 2080 3,764 0

0 0

0 3,764 2081 3,754 0

0 0

0 3,754 2082 20,889 0

36 0

0 20,925 2083 60,022 0

110 0

0 60,132 2084 80,629 0

141 0

0 80,770 2085 80,409 0

140 0

0 80,549 2086 80,409 0

140 0

0 80,549 2087 81,412 0

865 0

0 82,277 2088 81,006 0

1,068 5,042 0

87,117 2089 32,507 0

737 2,110 0

35,354 2090 0

0 20,415 0

0 20,415 2091 0

0 20,415 0

0 20,415 2092 0

0 13,034 0

0 13,034 Total1 909,795 220,871 57,368 7,153 6,724 1,201,911 1Rows and columns may not add up due to rounding

DECOM-2023-DCE-DRE Rev. 0 Page 22 of 27 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario (thousands, January 2023 dollars)

Total cost Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security Spent Fuel Storage Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment and Supplies Grand total 01 - Planning &

Preparation Costs 01.0101 - Utility Staff 0

0 0

0 5,377 0

0 0

5,377 01.0801 - NRC Fees 0

0 0

1,123 0

0 0

0 1,123 01.3201 - Contracted Engineering Analyses 0

0 0

0 225 0

0 0

225 02 - Plant Deactivation Costs 02.0101 - Utility Staff 0

0 0

0 85,773 0

0 0

85,773 02.0102 - Security Staff 0

0 0

44,504 0

0 0

0 44,504 02.0301 - Insurance 0

0 0

3,817 0

0 0

0 3,817 02.0501 - Heavy Equipment 0

6,096 0

0 0

0 6,096 02.0503 - Health Physics Supplies 0

446 0

0 0

0 446 02.0504 - Maintenance Supplies 0

0 0

2,494 2,494 02.0508 - Spent Fuel Pool O&M Supplies 0

0 0

7,353 7,353 02.0601 - Plant Energy 0

0 0

0 14,196 0

0 0

14,196 02.0702 - Hazardous Liquid Remediation 0

0 80 61 275 0

0 0

416 02.0801 - NRC Fees 0

0 0

3,875 0

0 0

0 3,875 02.1001 - Emergency Planning Fees 0

0 0

1,955 0

0 0

0 1,955 02.1101 -

Modifications 0

0 0

6,126 6,126 02.1801 - Process Decommissioning Water Waste 0

0 35 429 4,070 0

0 0

0 9

0 0

0 3,840 8,382 02.1901 - Site Upkeep 0

0 0

2,434 2,434 02.2301 - Disposal of Dry Active Waste 0

0 3

6 74 0

0 0

83 02.3701 - Severance 0

0 0

0 9,477 0

0 0

9,477 03 - Safe Storage Operations Costs 03.0101 - Utility Staff 0

0 0

0 48,183 0

0 0

48,183

DECOM-2023-DCE-DRE Rev. 0 Page 23 of 27 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario (continued)

(thousands, January 2023 dollars)

Total cost Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security Spent Fuel Storage Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment and Supplies Grand total 03.0102 - Security Staff 0

0 0

34,092 0

0 0

0 34,092 03.0301 - Insurance 0

0 0

20,942 0

0 0

0 20,942 03.0503 - Health Physics Supplies 0

2,863 0

0 0

0 2,863 03.0504 - Maintenance Supplies 0

0 0

2,435 2,435 03.0601 - Plant Energy 0

0 0

0 4,092 0

0 0

4,092 03.0801 - NRC Fees 0

0 0

14,899 0

0 0

0 14,899 03.1801 - Process Decommissioning Water Waste 0

0 16 190 1,800 0

0 0

0 2,448 4,453 03.1901 - Site Upkeep 0

0 0

17,300 17,300 03.2301 - Disposal of Dry Active Waste 0

0 16 40 476 0

0 0

532 04 - Dismantlement Costs 04.0101 - Utility Staff 0

0 0

0 22,832 0

0 0

22,832 04.0102 - Security Staff 0

0 0

14,218 0

0 0

0 14,218 04.0103 - DOC Staff 0

0 0

0 193,579 0

0 0

193,579 04.0201 - Structure Removal 16,285 20,345 281 905 2,255 1,775 0

0 0

0 41,846 04.0202 - System Removal 383 48,850 1,222 1,618 2,770 9,558 0

0 0

0 64,401 04.0301 - Insurance 0

0 0

3,053 0

0 0

0 3,053 04.0401 - Reactor Pressure Vessel 0

10,219 6,282 1,711 7,272 0

0 0

25,484 04.0402 - Reactor Pressure Vessel Internals 0

9,908 16,629 3,432 28,410 0

0 0

58,380 04.0403 - GTCC Disposal 0

0 0

0 15,580 0

0 0

15,580 04.0501 - Heavy Equipment 0

31,511 0

0 0

0 31,511 04.0503 - Health Physics Supplies 0

7,634 0

0 0

0 7,634

DECOM-2023-DCE-DRE Rev. 0 Page 24 of 27 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario (continued)

(thousands, January 2023 dollars)

Total cost Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security Spent Fuel Storage Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment and Supplies Grand total 04.0504 - Maintenance Supplies 0

0 0

506 506 04.0507 - Plant Preparation and Temporary Services 0

6,480 3

8 100 0

0 0

6,592 04.0601 - Plant Energy 0

0 0

0 9,015 0

0 0

9,015 04.0702 - Hazardous Liquid Remediation 0

0 27 20 92 0

0 0

139 04.0703 - Lead Remediation 0

0 16 83 0

112 0

0 0

0 210 04.0801 - NRC Fees 0

0 0

3,374 0

0 0

0 3,374 04.0901 - Asbestos 0

9,375 0

0 0

0 9,375 04.1303 - Condenser 0

484 674 454 555 0

0 0

2,166 04.1304 - Turbine Generator 0

475 489 601 1,222 0

0 0

2,787 04.1306 - Recirc Pumps/Reactor Coolant Pumps 0

478 354 301 320 0

0 0

1,452 04.1401 - Site Excavation 0

1,344 292 3,295 6,654 0

0 0

0 5

0 0

11,589 04.1701 - Scaffolding 0

9,691 37 11 56 0

0 0

9,796 04.1801 - Process Decommissioning Water Waste 0

0 31 380 3,610 0

0 0

0 3,134 7,156 04.1901 - Site Upkeep 0

0 0

2,923 2,923 04.2101 - Spent Fuel Rack Removal 1,663 1,268 201 400 1,126 0

0 0

4,657 04.2301 - Disposal of Dry Active Waste 0

0 20 51 606 0

0 0

677 04.2601 - DOC Relocation 0

0 0

0 776 0

0 0

776 04.2700 - Misc Decommissioning Waste 0

0 60 107 56 686 0

0 0

0 908

DECOM-2023-DCE-DRE Rev. 0 Page 25 of 27 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario (continued)

(thousands, January 2023 dollars)

Total cost Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security Spent Fuel Storage Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment and Supplies Grand total 04.2901 - Site Grading and Landscaping 0

2,253 0

0 0

0 2,253 04.3103 - Remove Rubble / Backfill Site 0

642 0

0 0

0 642 04.3300 - Radiation Surveys 0

0 0

8,650 0

0 8,650 04.3701 - Severance 0

0 0

0 1,374 0

0 0

1,374 05 - ISFSI Costs 05.0101 - Utility Staff 0

0 0

0 2,235 0

0 0

2,235 05.0102 - Security Staff 0

0 0

34,910 0

0 0

0 34,910 05.0301 - Insurance 0

0 0

388 0

0 0

0 388 05.0501 - Heavy Equipment 0

217 0

0 0

0 217 05.0504 - Maintenance Supplies 0

0 0

22 22 05.0601 - Plant Energy 0

0 0

0 471 0

0 0

471 05.0801 - NRC Fees 0

0 0

165 0

0 0

0 165 05.1201 - Fuel from Pool to Pad 0

0 0

0 167,257 0

0 0

167,257 05.1202 - Fuel from Pad to DOE 0

0 0

0 14,810 0

0 0

14,810 05.1601 - ISFSI License Termination Planning 0

0 0

0 135 0

0 0

135 05.1602 - ISFSI License Termination Radiological D&D 0

329 132 356 631 594 0

0 0

0 2,041 05.1603 - ISFSI License Termination Surveys 0

0 0

0 3,205 0

0 0

3,205 05.1604 - ISFSI Site Restoration 0

3,232 0

0 17 0

0 0

3,249 05.1901 - Site Upkeep 0

0 0

1,110 1,110 05.3202 - Contracted Engineering Analyses -

ISFSI 0

0 0

0 213 0

0 0

213

DECOM-2023-DCE-DRE Rev. 0 Page 26 of 27 Table 6-3: Unit 2 Total Cost by WBS - SAFSTOR Scenario (continued)

(thousands, January 2023 dollars)

Total cost Decontamination Removal Packaging Transportation Waste Disposal Waste Processing Program Management Security Spent Fuel Storage Insurance and Regulatory Fees Energy Characterization and Licensing Surveys Property Taxes Miscellaneous Equipment and Supplies Grand total 05.3300 - Radiation Surveys 0

0 0

42 0

0 42 05.3701 - Severance 0

0 0

0 495 0

0 0

495 06 - Property Tax Costs 06.0302 - Property Taxes 0

0 0

0 51,476 0

51,476 Grand total1 18,332 174,138 26,897 14,458 78,026 12,725 370,538 127,724 185,406 53,599 27,774 8,697 51,476 52,124 1,201,911 1 Rows and columns may not add up due to rounding.

DECOM-2023-DCE-DRE Rev. 0 Page 27 of 27

7. REFERENCES 7.1.

Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors, Revision 1, Nuclear Regulatory Commission, October 2013 7.2.

Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Nuclear Regulatory Commission, February 2005 7.3.

"Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986, T.S. LaGuardia et al.

7.4.

"Decommissioning Handbook," U.S. Department of Energy, DOE/EV/10128-1, November 1980, W.J. Manion and T.S. LaGuardia 7.5.

Construction Cost Information, RSMeansonline.com, Gordian Company 7.6.

NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, August 1984, J.C. Evans et al.

7.7.

NUREG/CR-0672 and addenda, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1980, H.D. Oak, et al.

7.8.

Civilian Radioactive Waste Management System Requirements Document, DOE/RW-0406, Revision 8, September 2007

Irradiated Fuel Management Plan for Dresden Nuclear Power Station, Unit 2

Page1of2

Irradiated Fuel Management Plan for Dresden Nuclear Power Station, Unit 2

1. Background

The Dresden Nuclear Power Station, Unit 2 (DNPS) operating license expires on December 22, 2029.

Constellation Energy Generation, LLC (CEG) has not made a final determination of the decommissioning approach for DNPS Unit 2. For purposes of this Irradiated Fuel Management Plan (IFMP), the SAFSTOR option has been selected. In this SAFSTOR scenario, active decommissioning is deferred as long as possible before ultimately terminating the Unit 2 License 60 years after shutdown. CEG reserves the right to choose an alternative decommissioning option at the actual time of decommissioning in accordance with its business needs, recognizing the need to assure the chosen option meets NRC requirements for decommissioning funding.

In order to estimate the costs associated with maintenance of the DNPS Unit 2 site in SAFSTOR and the eventual decommissioning of the site, at the time of the estimate, CEG assumed 2035 as the first year that the U.S. Department of Energy (DOE) will begin removing spent nuclear fuel from nuclear power reactor sites. Pursuant to the Nuclear Waste Policy Act (Reference 2), the Federal government has the responsibility to remove all spent fuel from DNPS Unit 2 and other commercial nuclear power reactor sites. However, the DOE spent fuel and high-level waste management program is currently stalled. Given the status of the DOE program, CEG considered information made publicly available by DOE in 2023, the Government Accountability Office (GAO), the Blue Ribbon Commission on America's Nuclear Future, and the political environment surrounding this issue, and concluded that 2035 was the most likely timeframe for DOE to initiate removal of commercial nuclear fuel from reactor sites. This date does change over time as new information becomes available and any changes would be incorporated into the cost estimate the next time it is updated.

2. Spent Fuel Management Strategy The NRC requires, as discussed in 10 CFR 50.54(bb), that licensees establish a program "to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." Pending transfer of the fuel to the DOE [Secretary of Energy], CEG will store fuel on an interim basis in the spent fuel pool and/or the Independent Spent Fuel Storage Installation (ISFSI) located at the DNPS site.

A licensed ISFSI is currently operational at DNPS. The ISFSI facility will be expanded to accommodate the inventory of spent fuel in the spent fuel pool following the final reactor defueling. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. Once the spent fuel pool is emptied of fuel, the facility will be placed in a SAFSTOR condition. The ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete. Active decommissioning will begin about 53 years after shutdown so that DNPS Unit 2 will be fully decommissioned to support license termination 60 years after shut down.

Assuming the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2035 with an annual capacity of 3,000 metric tons of uranium, spent fuel is projected to remain at the DNPS site for approximately 21 years after the termination of operation (i.e.,

spent fuel is projected to be removed from the DNPS site by the end of 2050). Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in spent fuel remaining at the site longer than anticipated.

Page2of2

Operation and maintenance costs for the storage facilities (i.e., ISFSI and spent fuel pool) are reflected in the DNPS Unit 2 Decommissioning Cost Estimate (DCE) (Reference 1) and include the costs for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the ISFSI and to decommission the ISFSI. A discussion of site-specific considerations for the management of spent fuel at DNPS Unit 2 is included in the DCE report.

When DNPS Unit 2 ceases operations in 2029, DNPS Unit 2 will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the DNPS Unit 2 spent fuel pool and ISFSI, as necessary, under the decommissioning scenario ultimately selected. In addition, DNPS Unit 2 will also comply with applicable license termination requirements in accordance with 10 CFR 50.82, "Termination of license," with respect to plant shutdown and post-shutdown activities, including seeking NRC approvals as appropriate for the continued storage of irradiated fuel until transfer of the fuel to the DOE is complete.

3. Cost Estimate and Funding for Spent Fuel Management Total costs for spent fuel management under the SAFSTOR scenario will be approximately

$220.8 million (2023 dollars). Further breakdown is included in the DCE (Reference 1).

As of December 31, 2023, the DNPS Unit 2 decommissioning trust fund balance was $937.6 million. At this time, there are no annual contributions to the fund and none are anticipated through the decommissioning period. To the extent that the trust fund balance exceeds costs required for radiological decommissioning, trust fund monies, subject to receipt of NRC approval of an exemption as discussed in Section 4, in conjunction with CEG operating revenues, will be used to pay for spent fuel management costs.

An additional potential source of funding for DNPS Unit 2 spent fuel management costs is the Settlement Agreement between CEG and the DOE, under which the United States Government has agreed to reimburse CEG for costs incurred attributable to DOEs failure to meet its contractual obligations for the transfer of spent fuel from DNPS (Reference 3).

4. NRC Approvals This IFMP contemplates potential withdrawals from the decommissioning trust for spent fuel management purposes. Prior to any such withdrawals, in accordance with 10 CFR 50.12, Specific exemptions, CEG will make appropriate submittals seeking an exemption from the requirements of 10 CFR 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for spent fuel management expenses. CEG will monitor the funding level of the decommissioning fund to ensure that spent fuel management withdrawals will not inhibit the ability of CEG to complete radiological decommissioning.

5. References

1. Report DECOM-2023-DCE-DRE, Revision 0, "2023 Decommissioning Cost Analysis Report Dresden Nuclear Power Station - Unit 2," November 2024

2. United States of America Public Law 97-425, "Nuclear Waste Policy Act of 1982," dated January 7, 1983

3. Settlement Agreement between the U.S. Department of Energy and Exelon Generation Company, LLC (including Commonwealth Edison Company and AmerGen Energy Company), signed and executed August 5, 2004, as amended by the First Addendum to the Settlement Agreement signed May 4, 2009, as amended by the Second Addendum to the Settlement Agreement signed August 18, 2019

Decommissioning Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2

Page1of2

Decommissioning Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2 (thousands of January 2024 dollars)

Page2of2

Decommissioning Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2 (thousands of January 2024 dollars)

(continued)

(a) Cash flows may not add due to rounding (b) A 2% real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)

Decommissioning and Spent Fuel Management Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2

Page1of2

Decommissioning and Spent Fuel Management Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2 (thousands of January 2024 dollars)

Page2of2

Decommissioning and Spent Fuel Management Cash Flow Analysis for Dresden Nuclear Power Station, Unit 2 (thousands of January 2024 dollars)

(continued)

(a) Cash flows may not add due to rounding (b) A 2% real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)

v t e Letter Sequence Request
EPID:L-2024-LLL-0025, Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan (Open)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other: ML25013A259
MONTHYEAR2025-01-13 [Table View]

RS-24-135, Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan

Text

Subject:

Reference:

SUMMARY

SUMMARY

1. Background

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