RS-24-033, Request for Exemption from 10 CFR 50.82(a)(8)

Request for Exemption from 10 CFR 50.82(a)(8)

ML25031A350
Person / Time
Site:	Dresden
Issue date:	01/31/2025
From:	Humphrey M Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-24-033
Download: ML25031A350 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-24-033 10 CFR 50.12 10 CFR 50.82(a)(8)(i) and (ii)

January 31, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Request for Exemption from 10 CFR 50.82(a)(8)

Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 In accordance with 10 CFR 50.12, Constellation Energy Generation, LLC (CEG) is requesting NRC approval of an exemption from 10 CFR 50.82(a)(8)(i) and (ii) for Dresden Nuclear Power Station, Units 2 and 3 (Dresden) to allow use of decommissioning trust (NDT) funds.

Specifically, CEG requests an exemption from provisions that restrict the withdrawal of funds from the NDT until after permanent plant shutdown.

The NDT funds will be used for prompt disposal of Major Radioactive Components (MRCs) at Dresden and will not exceed $20 million per unit. CEG requests this exemption to provide for disposal of the Steam Dryers that were removed from Dresden in 2006 and 2007, and for the demolition and disposal of the concrete mausoleum currently used to store these components.

The cost of disposal of MRCs and mausoleum is included in the site-specific decommissioning cost estimates for Dresden. If approved, this exemption will facilitate the prompt removal of radiologically contaminated material from Dresden, reduce overall decommissioning costs, and reduce an unnecessary regulatory burden on CEG for costs associated with maintaining the MRCs on site.

As described more fully in the attachments, the funds CEG proposes to withdraw were originally collected from ratepayers for the defined purpose of decommissioning Dresden; however, NRC regulations restrict the use of such commingled funds prior to permanent shutdown of the plant.

Because the Dresden trusts currently contain funds substantially in excess of those required for radiological decommissioning, the transfer would have no adverse impact on those decommissioning activities.

U.S. Nuclear Regulatory Commission January 31, 2025 Page 2 2

CEG requests that the NRC grant the exemption because:

(1) The exemption, "will not present an undue risk to the public health and safety, and [is]

consistent with the common defense and security," in accordance with 10 CFR 50.12(a)(1), and (2) Special circumstances are present that satisfy 10 CFR 50.12(a)(2).

CEG demonstrates in the attachments that the request satisfies these provisions.

Granting this exemption is consistent with the NRC decommissioning regulations (see 10 CFR 50.82(a)(6)) as it would not:

(1) eliminate the potential for unrestricted site release (in fact, it would have the opposite effect).

(2) have a significant environmental impact not previously considered in Environmental Impact Statements (EISs); or (3) decrease reasonable assurance that adequate funds will be available for decommissioning.

The exemption would support efforts to ultimately achieve unrestricted release of Dresden, thus improving environmental conditions. In addition, prompt disposal when cost effective disposal alternatives are available eliminates future price uncertainty and potential risks associated with the future availability of disposal capacity. It is prudent and consistent with the underlying purpose of the Commissions decommissioning regulations to remove MRC source terms that otherwise would remain on site until much later in time.

The NRC prepared a supplemental environmental impact statement (SEIS) in 2004 as part of its environmental review of the Exelon Generation Company, LLC (Exelon) initial license renewal application, to renew the operating licenses for Dresden, Units 2 and 3 for an additional 20 years (NUREG-1437 Supplement 17, NRC 2004). This final SEIS includes the NRC staffs evaluation of the environmental impacts of the initial license renewal as well as alternatives to initial license renewal.

CEG submitted an application for Subsequent License Renewal (SLRA) to the NRC for review on April 17, 2024. This application includes a site-specific Environmental Report the NRC will use to develop a new SEIS. The lack of environmental or resource changes at the site since the 2004 SEIS support the conclusion that the existing SEIS and the SEIS which will be prepared from the SLRA will remain bounding for Dresden, Units 2 and 3 steam dryer disposal.

U.S. Nuclear Regulatory Commission January 31, 2025 Page 3 3

Granting this request will facilitate the decommissioning process by removing the specified components from the site so that (1) inventory of radioactive waste and the associated source term at the site will be reduced; (2) an unnecessary regulatory burden can be eliminated as the costs associated with maintaining the MRCs on site and providing protection to the workers as a result of those MRCs can be avoided; (3) the overall cost to decommission the site will be reduced; (4) any uncertainty regarding future disposal cost and capacity for these MRCs is eliminated; and (5) adequate funds will be available to decommission the reactors at the time the reactors cease operation. Finally, the adequacy of the available funds for Dresden decommissioning is supported by the site-specific decommissioning cost estimate and the associated funding program.

CEG recognizes that on February 22, 2019, EnergySolutions submitted a rulemaking petition to the NRC (PRM-50-119) seeking to amend the Commissions regulations to provide a process for the NRC to allow licensees to use decommissioning trust funds for the disposal of MRCs and that the Commission has denied this petition. In denying the petition, the Commission noted that the NRC has a process in place for requesting exemptions that is well suited to the purpose of the petition.

CEG also notes that the Commission directed the NRC to notify stakeholders "what information would assist the staff in assessing an exemption request." In response to this direction, the NRC has issued "Interim Staff Guidance on the Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal." This exemption request addresses the applicable items discussed in this guidance.

All of the data and calculations in the attachments are based on December 31, 2023, since this was the date of the last decommissioning funding report to the NRC. The trust fund values as of December 31, 2024 were $1,006M and $1,028M, for Dresden Unit 2 and Dresden Unit 3 respectively. This represents a return of over 7% on both funds in 2024. Since the 7% is well in excess of the 2% credited in the evaluations contained in the attachments, the conclusions remain valid and the margin available over the required funding assurance has increased.

CEG is submitting this exemption request to provide timely resolution of this issue and support planning activities for Steam Dryer removal and disposal. Accordingly, CEG requests approval of this request by January 31, 2026, to avoid the resource allocation and other expenses associated with storing the MRCs, which would be avoided if NDT funds can be used for the prompt disposal.

U.S. Nuclear Regulatory Commission January 31, 2025 Page 4 4

This letter and attachment contain no new regulatory commitments.

Should you have any questions concerning this request, please contact Mr. Jeff Dunlap at (779) 231-5216.

Respectfully, Mark D. Humphrey Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments: 1. Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii)

2. Decommissioning Cash Flow Analysis for Dresden, Unit 2 SAFSTOR Radiological

3. Decommissioning Cash Flow Analysis for Dresden, Unit 3 SAFSTOR Radiological

4. Decommissioning Cash Flow Analysis for Dresden, Unit 2 SAFSTOR Total

5. Decommissioning Cash Flow Analysis for Dresden, Unit 3 SAFSTOR Total

6. Parent Guarantee Qualification cc: NRC Regional Administrator, Region III Illinois Emergency Management Agency and Office of Homeland Security - Division of Nuclear Safety NRC Sr. Resident Inspector - Dresden Nuclear Power Station

Humphrey, Mark D.

Digitally signed by Humphrey, Mark D.

Date: 2025.01.31 11:36:40 -06'00' Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 1 I.

Exemption Request In accordance with the provisions of 10 CFR 50.12, "Specific Exemptions," Constellation Energy Generation, LLC (CEG) requests that the U.S. Nuclear Regulatory Commission (NRC) grant an exemption from provisions of 10 CFR 50.82, "Termination of License." Specifically, CEG requests an exemption from the requirements in 10 CFR 50.82(a)(8)(i) and (ii) in order to permit the immediate withdrawal of funds from the nuclear decommissioning trust funds (NDTs) to cover the cost of disposal of certain major radioactive components (MRCs) prior to the permanent cessation of operations. In addition, this request follows the interim staff guidance (ISG) issued by NRC staff that defines the information that would assist the NRC in evaluating an exemption request.1 The purpose of this exemption request is to permit the use of NDT funds, up to $20 million per unit, to promptly dispose of steam dryers that were removed from Dresden Nuclear Power Station, Units 2 and 3 (Dresden), and to demolish and dispose of the mausoleum currently used to store the steam dryers. Prompt disposal will result in several benefits, as follows: (1) the inventory of radioactive waste and associated source term at the site will be reduced; (2) the costs associated with maintaining the MRCs on site and providing protection to workers from MRCs can be avoided; (3) the overall cost to decommission the site will be reduced; (4) any uncertainty regarding future disposal cost and capacity for these MRCs is eliminated; and (5) assurance of adequate funds will be available to decommission the reactor at the time the reactors cease operation will be maintained. Finally, the adequacy of the availability of funds for Dresden decommissioning is supported by the site-specific decommissioning cost estimate (DCE) and the associated funding program.

Authorization of the use of NDT funds for prompt disposal of the MRCs is in the public interest because it would immediately reduce on-site waste inventories, eliminate risks associated with future disposal, and reduce the eventual cost and complexity of decommissioning Dresden.

Consequently, authorization to expend decommissioning trust funds for prompt disposal of the MRCs would further the purpose of 10 CFR 50.82(a)(8), which is to provide reasonable assurance that the decommissioning trust funds will be adequate to accomplish their intended purpose.

1 "Interim Staff Guidance on the Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal," August 5, 2024.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 2 II.

Requirements The NRC regulations in 10 CFR 50.82(a)(8)(i) provide that decommissioning trust funds may be used by CEG if:

(A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2; (B) The expenditure would not reduce the value of the NDT below an amount necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise; (C) The expenditure would not inhibit the ability of CEG to complete funding of any shortfalls in the NDT needed to ensure the availability of funds to ultimately release the site and terminate the license.

10 CFR 50.82(a)(8)(i)(A) refers to the definition of "decommissioning" in 10 CFR 50.2, which defines the term "decommission" rather than "decommissioning." By that definition, the term "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.

(emphasis added).

The NRC has further conditioned the withdrawal of decommissioning trust funds by limiting the withdrawal rate from the trust. 10 CFR 50.82(a)(8)(ii) provides:

Initially, 3 percent of the generic amount specified in § 50.75 may be used for decommissioning planning. For licensees that have submitted the certifications required under § 50.82(a)(1) and commencing 90 days after the NRC has received the [post-shutdown decommissioning activities report]

PSDAR, an additional 20 percent may be used. A site-specific decommissioning cost estimate must be submitted to the NRC prior to the licensee using any funding in excess of these amounts.

In the absence of an exemption by the NRC, these provisions would restrict the ability of CEG to use NDT for the disposal of MRCs prior to permanent cessation of operations at Dresden, even though removal of the MRCs would reduce the level of radioactivity at Dresden and would not adversely impact the ability to fund future decommissioning.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 3 A request for an exemption from these requirements must satisfy the requirements of 10 CFR 50.12. As demonstrated below, this exemption request satisfies the provisions of 10 CFR 50.12. Moreover, in addition to providing the information requested by the NRC in the ISG, CEG has considered and addressed the concerns expressed by the Commission2 in denying the EnergySolutions petition for rulemaking, in particular:

x There will be a large projected excess in the NDT after the removal of the MRCs x

The removal of the MRCs is included in the site-specific decommissioning cost estimate (DCE)

III.

Background

In the Statements of Consideration for the 1996 amendments to 10 CFR 50.82, the NRC stated in response to a comment as follows:

The NRC has concluded that allowing decommissioning trust funds withdrawals for disposals by nuclear power plants that continue to operate is not warranted.

These activities are more appropriately considered operating activities and should be financed that way.3 This position is reflected in the NRCs regulations quoted above. Consequently, licensees, have been precluded from using decommissioning trust funds for prompt disposal of MRCs. The cost of disposal can be very substantial, and such costs are planned for as part of the eventual decommissioning of a plant. Thus, many licensees have elected to store MRCs onsite until permanent shutdown, rather than to expend limited operating funds to pay for prompt MRC disposal.4 The Dresden dryers were replaced after an Extended Power Uprate (EPU) with a more robust design to support long term operation under EPU operating conditions. The Unit 3 steam dryer was removed and replaced during Refuel Outage D3R19 in 2006 and the Unit 2 steam dryer replacement occurred during Refuel Outage D2R20 in 2007. The replaced steam dryers were moved as a single piece into a common storage building constructed specifically for the purpose of long-term storage within the Dresden Owner Controlled Area. The storage building is a reinforced concrete structure which provides shielding to minimize radioactive dose outside of the building. The original plan was to store the steam dryers in this structure until they were dispositioned during decommissioning. The storage structure is currently monitored for water intrusion bi-annually.

2 SECY-20-0095, "Denial of Petition for Rulemaking to Access the Decommissioning Trust Fund for the Disposal of Large Components," U.S. Nuclear Regulatory Commission, p. 2, October 19, 2020.

3 61 FR 39278, 39293; July 29, 1996.

4 See, e.g., Letter from G. Van Noordennen (EnergySolutions) to A.L. Vietti-Cook (NRC), "Rulemaking Petition to Amend 10 C.F.R. 50.82 and 50.2" (June 3, 2021) ("Currently, 15 reactor heads and 127 steam generators, as well as other numerous components, are stored on nuclear power plant sites across the country. These MRCs equate to approximately 631,000 cubic feet of radioactive waste.")

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 4 IV.

Basis The NRC definition of "decommission" states that the entire reactor facility must be removed from service before related activities fall within NRC-sanctioned decommissioning (10 CFR 50.2). Further, when the NRC promulgated the decommissioning rule in 1988, it noted in the Statements of Consideration to the final rule that "[d]ecommissioning activities are initiated when a licensee decides to terminate licensed activities."5 Nevertheless, the permanent disposal of MRCs is closely related to decommissioning activity because it involves the removal of a large piece of radioactive capital equipment from the site, which would ultimately be necessary to complete decommissioning. If this exemption were granted, CEG will dispose of the MRCs during plant operation rather than waiting until the entire site is decommissioned. This is proposed to be accomplished using funds from the NDTs that were placed there for the purpose of removing such components.

The MRCs at issue have already been removed from service well in advance of the rest of Dresden. Absent this exemption, the MRCs would remain on site until both Dresden units cease operation. Accordingly, an exemption with respect to 10 CFR 50.82(a)(8)(i)(A) is needed because Constellation has no immediate plans to remove these units from service and therefore, payment for MRC disposal falls outside the definition "decommissioning activity" as the NRC has interpreted 10 CFR 50.82(a)(8)(i)(A).

Nonetheless, 10 CFR 50.2 also provides both that the permanent removal of "major radioactive components" is a "major decommissioning activity" and that steam dryers are "major radioactive components" because they are considered to be "large components that are radioactive to a comparable degree" as other components identified in the definition. As such, CEG concluded that the use of the fund for the disposal or MRCs prior to shutdown is a judicious use of the funds.

An exemption from 10 CFR 50.82 (a)(8)(ii) is also necessary because that paragraph allows only planning costs to be paid from the NDT in advance of submittal of a Post Shutdown Decommissioning Activities Report (PSDAR). The expenditures for which the exemption is being requested are not planning activities. Rather, they are necessary to remove the MRCs from the plant site and dispose of them, and demolish the mausoleum currently used to store the components, and the exemption request will allow the withdrawal of the funds necessary for that purpose from the NDTs notwithstanding the 10 CFR 50.82 (a)(8)(ii) restrictions.

5 53 FR 24,018, 24,019; June 27, 1988.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 5 A.

Dresden Decommissioning Trust Fund

1.

There is a Large Projected Surplus in the Decommissioning Trust Fund Compared with the Site-Specific Decommissioning Cost Estimate NDT balances for Dresden reported for the end of calendar year 2023 for radiological decommissioning were approximately $938 and $958 million, respectively. The NDTs at Dresden were originally established through ratepayer collections, which included amounts for spent fuel management, however, this money was commingled in the overall NDTs and not separately accounted. Collections ended in 2006, but the historical collection amounts in conjunction with the license renewal to 60 years has resulted in a robust funding level for Dresden.

The projected value of the NDTs at the time of decommissioning is estimated to be $995 and

$1,058 million. This compares favorably with the amount estimated to be required for radiological decommissioning in the site-specific DCE which is $955 and $983 million. This assumes the current license expiration dates of 2029 and 2031 for Units 2 and 3. CEG submitted an application to renew the licenses for an additional 20 years on April 17, 2024, which would allow an additional 20 years of fund growth, and further improve the funding situation.

Based on the NDT fund values as of December 31, 2023, less the amount required to remove and dispose of the Steam Dryers and demolish and dispose of the mausoleum, using the site specific DCE, each unit still has more than adequate funding for the remaining radiological decommissioning after shutdown assuming the SAFSTOR scenario6. Attachments 2 and 3 show the decommissioning funding analysis for Unit 2 and Unit 3, respectively, using the site specific DCE. In each case, a large surplus exists at the end of decommissioning, and adequate decommissioning funding assurance is maintained. In fact, the anticipated fund value at the start of decommissioning exceeds the total estimated cost required for license termination. For both Units, the $20 million expenditure is conservatively modeled to be in 2024, although it is likely to be later than that in reality. This is conservative since it allows the least time for the fund to grow prior to the expenditure. In any case, the timing of the cash flow will not change the overall result that a large surplus is projected to exist at the end of decommissioning.

Even though funding assurance is only required to be provided for radiological decommissioning, as a further demonstration of the amount of margin, Attachments 4 and 5 show the same analysis, but use total costs after shutdown (i.e., radiological decommissioning, spent fuel management, and site restoration7). Even with these additional costs being considered, there is still a large projected surplus in the 6 Note that the SAFSTOR scenario is chosen here for demonstration of funding assurance purposes.

CEG has not made a final determination of the decommissioning option and may choose a different option in the future recognizing that the chosen option must meet NRC requirements for decommissioning funding.

7 CEG is not required to perform site restoration to a Greenfield state at Dresden, this demonstration is included to help show the amount of overall margin for all potential decommissioning related activities.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 6 decommissioning funds. In addition, if an additional 20 years of fund growth allowed by subsequent license renewal were credited, the anticipated fund value at the time of decommissioning would exceed the estimated total cost for license termination, spent fuel management, and site restoration. As previously stated, the $20 million expenditure is conservatively modeled to be in 2024, although it is likely to be later than that in reality.

2.

Time Period Before Commencement of Major Radiological Decommissioning Activities The license expiration date for Unit 2 is December 22, 2029, and for Unit 3 is January 12, 2031, so there are more than five and six years remaining to accumulate earnings before the shutdown and commencement of major decommissioning activities for Units 2 and 3, respectively.

As described above, the time period prior to commencement of decommissioning activities is sufficient to provide for the accumulation of funds to support license termination. Further time allowed by approval of subsequent license renewal will further increase the margin in the trust fund.

3.

Status and Structure of the Decommissioning Trust Fund The funds for Dresden were originally collected from ratepayers through 2006. The original collections were based on radiological decommissioning and spent fuel management costs, but the funds were not segregated or accounted for separately in the NDT. Hence, they have historically been commingled and not reported separately to the NRC and are considered funds for radiological decommissioning.

4.

Decommissioning Funding Assurance History As noted previously, the amounts previously collected and the additional time for funds to grow due to the extension of the licenses to 60 years has resulted in a robust funding level for Dresden Units 2 and 3. This has been the case for many years, as shown in the table below which demonstrates that the funds have exceeded the minimum formula amounts from 10 CFR 50.75(b) and (c), without any credit for future earning, and that the current surplus is in excess of $180M per unit.

Date Unit 2 Unit 3 Fund Value

($M)

Minimum Formula Amount ($M)

Fund Value

($M)

Minimum Formula Amount ($M) 12/31/2022

$869

$683

$891

$683 12/31/2020

$876

$653

$895

$653 12/31/2018

$696

$660

$712

$660 12/31/2016

$651

$631

$666

$631 Furthermore, since the initiation of annual reporting in 1999, there has not ever been a shortfall reported for Dresden Units 2 and 3.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 7

5.

Funding mechanisms to cover future shortfalls in the Decommissioning Trust Fund (for a merchant plant owner)

NRC regulations in 10 CFR 50.75(e) specify funding mechanisms that are acceptable for demonstrating financial assurance. Due to the current funding level of the Dresden NDTs, and the minimal amount of expenditures expected under this exemption request, it is unlikely that any additional financial assurance would be required. In the unlikely event of a shortfall for Dresden, CEG would use one of these authorized methods to make up any shortfall that may occur, including but not limited to a parent company guarantee. CEG meets the financial test in 10 CFR 30 Appendix A for providing a parent company guarantee (see Attachment 6) and could also provide additional assurances using a letter of credit or surety bond if required.

6.

Cost-Benefit Analysis The main reason for removal of the steam dryers at this time is to reduce the environmental liability on the site, and reduce the risk associated with disposal cost and availability in the future. These benefits cannot be explicitly quantified. Furthermore, since the steam dryers at Dresden are already in a dedicated storage facility on site, there is not additional cost being incurred for construction, and normal maintenance and surveillance costs are minimal. For these reasons, a cost benefit analysis is not applicable. However, it should be noted that the costs for removal and disposal of the steam dryers will be incurred at some point, either during operation, or during decommissioning of the plant after shutdown, so there are no incremental costs associated with this action.

7.

Current Financial Health of CEG Pursuant to longstanding NRC financial qualification guidance under NUREG-1577, Revision 1, if an applicant "has an investment grade rating or equivalent from at least two of these sources

[Moodys Standard and Poors, and Value Line],the reviewer will find such applicant financially qualified". CEG maintains an investment grade credit rating with the S&P of BBB+ and Moody's of Baa1. It would require a three-notch downgrade from their current levels to BB+ and Ba1 to drop below an investment grade credit rating.

Historical financial information regarding CEG and its parent company is provided in its February 27, 2024 Form 10-K Annual Report filed with the Securities and Exchange Commission and available on the Internet at:

https://www.sec.gov/Archives/edgar/data/1168165/000186827524000014/ceg-20231231.htm See pages 86-95.

B.

The Site-Specific Decommissioning Cost Estimate

1.

The Site-Specific Decommissioning Cost Estimate Is Comprehensive Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 8 The NRC requires in 10 CFR 50.75(f)(2) that each licensee prepare and submit a DCE at least five years prior to the projected end of operations. CEG already has in place a detailed, site-specific DCE even though operations are not expected to cease for at least five years. The most recent DCE is comprehensive; it resulted in a total estimated cost, including spent fuel management and site restoration of $1,243M for Unit 2 and $1,293M for Unit 3 in 2024 dollars based on the SAFSTOR scenario. Of this total cost, $955M for Unit 2 and $983M for Unit 3 is attributed to license termination (i.e., 2024 dollars, plant and Independent Spent Fuel Storage Installation (ISFSI) license termination).

The site-specific estimate considers the lessons learned and industry experience gained from the decommissioning of several nuclear power plants in recent years. These plants include the completed projects at Maine Yankee, Connecticut Yankee, Yankee Rowe, Trojan, and Big Rock Point. Although some of those projects exceeded projected costs, the experience has led to improvements in the ability to prepare DCEs that address all costs. For example, the Zion Nuclear Power Station, where all physical decommissioning work has been completed, will be decommissioned for significantly less than the DCE that was prepared and submitted to the NRC. In addition, decommissioning projects that are underway at Vermont Yankee, Oyster Creek, and Pilgrim also are projected to be completed for less than estimated.

In particular, contemporary DCEs, including the one for Dresden, account for the significant lessons learned in the segmentation and disposal of reactor pressure vessels.

The uncertainty with these projects has historically been very high, both in terms of the cost to complete the work and the estimate of the volume and class of low-level radioactive waste (LLW) generated. Significant progress has been made in the ability to reduce the generation of Greater than Class C Waste (GTCC), which must be stored onsite in the ISFSI.

In addition, the DCEs include detailed staffing models based on recent experience and include activity-based contingency based on the complexity and uncertainty of each activity. The DCEs are consistent with industry standards as described in AIF/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," and NRC Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," February 2005.

2.

The Site-Specific Decommissioning Cost Estimate includes the expense for which the exemption is requested The current site-specific estimate includes a cost to remove, package, transport, and dispose of the steam dryers. It also includes the cost of demolition and disposal of the mausoleum in which the steam dryers are stored. These costs are assumed to be incurred during the major decommissioning activities portion of the schedule. For the purposes of the financial evaluations in Attachments 2 through 5, the estimated cost to dispose of the steam dryers during operations is explicitly added to the evaluation, but the original costs in the site-specific cost estimate are conservatively left in the overall costs during the decommissioning period.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 9 The DCE includes not only the radiological cleanup required by the NRC, but also includes dismantling the facilities and restoring the site as closely as possible to its natural state8. The estimate also includes funds intended for ultimate storage and monitoring of spent nuclear fuel remaining on site following shutdown in the event the U.S. Department of Energy has not fulfilled its obligation to take custody of the spent fuel.

3.

The Site-Specific Decommissioning Cost Estimate Is Reliable As discussed above, the DCE contains a thorough and comprehensive analysis of the anticipated costs of decommissioning. In addition to reflecting updated rates for such items as labor and waste disposal, the DCE also reflects the lessons learned in the decommissioning of other power reactors. As an example, it was assumed that an outside contractor would be used for vessel and internals removal as opposed to in house personnel. An improved GTCC segmentation analysis also was assumed, reducing the volume of this waste. The Utility staff size has been modified in the most recent version to reflect experience from ongoing projects.

This consideration of past industry experience provides additional assurance that the DCE is a reliable indicator of the future costs of decommissioning.

In addition, previous decommissioning projects provide ample evidence that it is reasonable to rely on the DCE. Data for the three large PWRs that have been fully demolished (i.e., Connecticut Yankee, Maine Yankee, and Trojan) show that final decommissioning costs were less than projected in the DCE for two (Maine Yankee and Trojan) and 24% higher for Connecticut Yankee. These data indicate that the DCEs are reliable planning tools.

Furthermore, the difference in the case of Connecticut Yankee is now well understood.

Additional completed reactor decommissioning projects have continued to prove the reasonableness of DCEs.

One key reason that Connecticut Yankee stands out as an exception is that it entered the decommissioning process following an unplanned shutdown. The lack of planning was a key factor in the challenges that the project faced. Decommissioning planning is another area that has proven to show significant benefits in recent years. The Decommissioning Planning costs are also included in the most recent DCE. These lessons are useful even in the event of an unplanned shutdown and have been applied at the current generation of nuclear power plants undergoing decommissioning.

C.

Withdrawal of Funds Now From the NDT Will Not Jeopardize CEGs Ability to Fully Decommission Dresden

1.

There Will Be Sufficient Funds Available To Decommission Dresden The NDT provides adequate assurance that funds will be available throughout the decommissioning period.

8 CEG is not required to perform site restoration to a Greenfield state at Dresden, but those costs are in the cost estimate to ensure all decommissioning related costs are included.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 10 As noted above, NDT balances for Units 2 and 3 reported for the end of calendar year 2023 were approximately $938 and $958 million, respectively. If these balances were reduced by not more than $20 million for each unit in order to fund MRC disposal activities, the remaining Unit 2 balance of $918 million and the remaining Unit 3 balance of $938 would continue to exceed the NRC minimum "formula" amount of $688 million for each unit at the end of calendar year 2023, without taking credit for any earnings. As such, even after the withdrawal of funds to pay for MRC disposal, the NDT balances are sufficient to be considered fully prepaid for purposes of meeting NRCs requirements to provide financial assurance for decommissioning, in accordance with 10 CFR 50.75(e)(1)(i) (prepayment method).

2.

The Withdrawal Will Not Reduce The Value Of The Decommissioning Trust Below An Amount Necessary To Place And Maintain The Reactor In A Safe Storage Condition If Unforeseen Conditions Or Expenses Arise (10 CFR 50.82(a)(8)(i)(B))

The use of NDT for the requested purpose will not reduce its value below an amount necessary to place and maintain the reactor in a safe storage condition. The NDT balances will continue to exceed the NRC minimum requirements for financial assurance for decommissioning and be considered fully funded for purposes of compliance with NRCs rules.

Even with the requested withdrawal, CEG not only has sufficient funds to place and maintain the reactor in a safe storage condition, but CEG expects to have more than sufficient funds to complete the NRC-required radiological decommissioning based on the site-specific DCE as shown in Attachments 2 and 3.

3.

The Withdrawal Will Not Inhibit The Ability Of CEG To Complete Funding Of Any Shortfalls In The Decommissioning Trust Needed To Ensure The Availability Of Funds To Ultimately Release The Site And Terminate The License (10 CFR 50.82(a)(8)(i)(C))

The expenditure of NDT funds would not inhibit the ability of CEG to complete funding of any shortfalls in the NDTs needed to ensure the availability of funds to ultimately release the site and terminate the license. Even though CEG proposes reducing the principal to cover the disposal costs of the MRCs, the remaining funds already in the trusts exceed the NRCs minimum funding requirements pursuant to 10 CFR 50.75.

V.

Justification of Exemption and Special Circumstances 10 CFR 50.12, "Specific Exemptions," states that the NRC may grant exemptions from the requirements of the regulations in 10 CFR Part 50 if three conditions are met. The three conditions are: 1) the exemption is authorized by law, 2) the exemption will not present an undue risk to the public health and safety, and 3) the exemption is consistent with the common defense and security. In addition, section 50.12 provides that the NRC will not consider granting an exemption unless special circumstances are present.

A.

The Requested Exemption is Authorized by Law This exemption is authorized by law as required by 10 CFR 50.12(a)(1). No law exists that precludes the activities covered by this exemption request. The provisions of 10 CFR 50.82 as Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 11 well as the definition of "decommission" at 10 CFR 50.2 were adopted at the discretion of the NRC consistent with its statutory authority. No statute required the NRC to adopt the specific regulations from which CEG now seeks an exemption. Rather, it is entirely within the NRCs discretion to determine that alternative means are adequate to provide reasonable assurance of adequate protection of safety.

B.

The Requested Exemption Does Not Present an Undue Risk to the Public Health and Safety This exemption will not present an undue risk to the public health and safety. To the contrary, granting this exemption will result in increasing the protection to the public health and safety as a significant source term will be removed from the site and properly disposed of decades in advance of the time the MRCs would be removed if CEG waited until the reactors cease operation. This will reduce the potential for exposures from this source.

C.

The Requested Exemption Will Not Endanger the Common Defense and Security This exemption is consistent with the common defense and security because it removes a source term from the site sooner than would otherwise be the case without the exemption.

Furthermore, because the MRCs are currently stored outside the protected area, their removal will have the added advantage of removing an MRC that requires additional security protections to comply with 10 CFR Part 37 from the site. Use of the NDT funds during operation to dispose of the MRCs will not reduce the physical security of the site or the protection of remaining special nuclear material from theft.

D.

Special Circumstances NRC regulations require that special circumstances be present in order to grant an exemption.

This exemption is justified based on four of the six special circumstances cited in the regulations. The following special circumstances from 10 CFR 50.12(a)(2) are present that warrant the granting of this exemption request:

1.

The Regulation In The Particular Circumstances Conflicts With Other Rules Or Requirements Of The Commission (10 CFR 50.12(a)(2)(i))

In this particular circumstance, application of the regulations in 10 CFR 50.82(a) is in conflict with the philosophy underlying the approach the Commission has taken for expeditiously decontaminating contamination. It is inconsistent with the timeliness requirements set up for materials licensees as it may provide an unnecessary economic barrier for the removal of source terms from reactor sites. Material licensees of the NRC are subject to the 1994 Decommissioning Timeliness Rule, 10 CFR 30.36, 40.42, 70.38, and 72.54, which requires licensees to decontaminate and decommission certain unused portions of operating nuclear materials facilities.

Allowing contaminated land, buildings, or equipment to remain on site was seen as a possible public and environmental liability and the Commission looked for ways to achieve early decommissioning of unused portions of materials facilities, absent any other operational or safety concerns that would increase the risk to the site. For valid and sound reasons, reactor Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 12 licensees are not subject to this rule and, in fact, are allowed the SAFSTOR option under 10 CFR 50.82. Nevertheless, in this case, absent the requested exemption, the requirement creates an economic barrier for the Licensee, who seeks to make a prudent decision to remove a source term from the site.

In addition, granting an exemption to the regulations in 10 CFR 50.82(a) would be consistent with the philosophy underlying the approach the Commission took for the license termination rule in modifications to its regulations in 1997. NRC added 10 CFR 20.1406 which reads:

Applicants for licenses, other than renewals, after August 20, 1997, shall describe in the application how facility design and procedures for operation will minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize to the extent practicable, the generation of radioactive waste.

The intent of 10 CFR 20.1406 is to diminish the occurrence and severity of site contamination by taking measures that will control contamination and facilitate eventual decommissioning.

Consistent with this philosophy, early removal of large components would comply with the Commissions intent under 10 CFR 20.1406.

In contrast, the storage of the steam dryers at Dresden until permanent cessation of operations will increase the complexity of decommissioning and volume of waste to be disposed at the end of plant life. Due to the location of the storage facility, there would be little to no impact on the operating units onsite. Moreover, this complexity will be exacerbated by the inventory of MRCs stored onsite at other plants. Thus, permitting the phased disposal of large components over time will reduce the inventory of waste material and eliminate this future decommissioning activity, consistent with the philosophy underlying 10 CFR 20.1406.

2.

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 underlying purpose of the rule is to provide adequate funds for ultimate decommissioning of the site. The application of the regulation restricts the expenditure of NDTs in this circumstance, which is unnecessary to achieve the underlying purpose of the rule. The purpose of the restrictions on fund withdrawal is to protect the health and safety of the public by assuring that there will be adequate funds available to complete NRC-required decommissioning activities following termination of the operating license. The above analysis of the site-specific DCE and the NDT demonstrates that funding will be adequate to complete decommissioning even if funds are withdrawn for early disposal of the Component. It is noteworthy that a licensee can exceed the three (3) and 20 percent limitations of 10 CFR 50.82(a)(8)(ii) if a site-specific DCE is submitted to the NRC. Once this cost estimate is provided to the NRC, the licensee, according to the 1996 Statements of Consideration, may withdraw funds without obtaining additional approvals from the NRC.9 Since the cash flow analysis from CEGs site-specific DCE is being 9 61 FR 39278, 39285; July 29, 1996.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 13 submitted with this exemption request, NRC has the information that is needed to assess the requirements of 10 CFR 50.82(a)(8)(ii) before CEG exceeds the limitations.

As noted above, it is prudent from both the safety and economic sense to use funds from the NDT to dispose of these MRCs. If the exemption is not granted, MRCs will be stored on site until permanent cessation of operations, increasing the complexity and cost of decommissioning, as discussed further below. For example, many plants have stored large components similar to those of CEG and are planning to decommission within the same window of time. Onsite storage of MRCs until that time could complicate the logistics of final decommissioning of all plants. In contrast, permitting the phased disposal of large components over time will reduce the inventory of waste material and eliminate this from the decommissioning activities at the end of plant life.

The underlying purpose is also to protect the environment; delaying removal would be counterproductive for this underlying purpose.

3.

The Exemption Would Result In Benefit To The Public Health And Safety That Compensates For Any Decrease In Safety That May Result From The Grant Of The Exemption (10 CFR 50.12(a)(2)(iv))

While CEG clearly is capable of maintaining protection of the public health and safety if the MRCs are stored on-site, the exemption would result in benefit to the public health and safety, because removal of the MRCs would provide a permanent disposal solution. This eliminates any potential future risk associated with on-site storage, even if such risk is low.

Furthermore, there is no associated decrease in safety. Allowing the exemption will result in a net benefit to the public health and safety. Prompt disposal by removing the source term from the site created by these MRCs furthers the objective of maintaining radiation exposures as low as reasonably achievable pursuant to 10 CFR 20.1101(b) by minimizing the potential for long-term exposure. This is a clear safety benefit that can be implemented now as there is disposal capacity for these MRCs. In addition, disposing of waste prior to the permanent cessation of operations is consistent with NRC policy to minimize the costs and complexity of decommissioning, which can only improve safety at the site.

4.

There Is Present Any Other Material Circumstance Not Considered When The Regulation Was Adopted For Which It Would Be In The Public Interest To Grant An Exemption. (10 CFR 50.12(a)(2)(vi))

As promulgated, the rule has never required that site-specific decommissioning cost estimates be developed prior to the last five years of the operating life of the plant, but instead assumed that such estimates would be developed around the time a plant ceases operation. See 10 CFR 50.75(f)(2). In the absence of site-specific information, there is an understandable preference for preserving funds in the NDTs, because it would be difficult to make informed decisions regarding detailed activities and costs. However, where detailed site-specific information is available, NRC and CEG have the ability to evaluate the cost and benefits of prompt disposal versus deferring expenditures. A site-specific DCE provides NRC with the ability to determine if there is reasonable assurance that sufficient funds will be available at the Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 14 time of decommissioning if this exemption is granted to allow funds to be withdrawn to cover the disposal costs for these MRCs.

The exemption request also satisfies the special circumstance criterion of 10 CFR 50.12(a)(2)(vi) in that this particular circumstance was not considered when the regulation was adopted. Specifically, it was not contemplated when this rule was adopted that these MRCs would be removed from Dresden and stored onsite long before the permanent cessation of operation and therefore NDTs did not include sub-accounts to address disposal of MRCs.

NRCs rulemaking history makes clear that licensees may maintain sub-accounts in NDTs that might be used for purposes unrestricted by NRC, such as covering the disposal costs for MRCs.

For example, American Electric Power Company had funds set aside that were dedicated for disposal of steam generators from DC Cook. However, some state utility commissions do not favor the use of sub-accounts. The regulation did not contemplate that funds collected for all purposes of decommissioning would be commingled with the NRC-required decommissioning funds, because the NRC anticipated that sub-accounts would be used to separate the funds collected for NRC-jurisdiction decommissioning from other decommissioning uses.10 In this case, the funds for NRC-jurisdictional decommissioning and non-NRC jurisdictional decommissioning are commingled in the NDT. Preventing the use of those funds solely because they are commingled creates an unnecessary regulatory burden as it does not have a corresponding safety benefit. This is especially true in the current situation where the NRC can examine a site-specific DCE that sets out the costs for the different elements of decommissioning (including the disposal of the subject MRCs) to determine whether there are adequate funds to fulfill NRC decommissioning requirements. It is not apparent that this situation was considered at the time the regulation was adopted and - because of the benefits, financial, environmental, and safety, associated with the early removal from the site of contaminated material - it is in the public interest to grant the exemption. Thus, this exemption is further warranted under the special circumstances set forth in 10 CFR 50.12(a)(2)(vi).

Another material circumstance not considered at the time the restrictions on NDT use were established in 1988 is the impact of license renewal and subsequent license renewal. It was not considered at the time that capital projects of this scope would be undertaken to extend Dresdens operation, resulting in on-site storage of MRCs until Dresden permanently ceases operation and that permanent cessation of operations would be twenty (or possibly 40) additional years in the future. Specifically, the NRC considered that licensees would not evaluate waste disposal options until five years prior to the projected end of operations.11 License renewal has completely altered the landscape for how long MRCs will be stored on site without regulatory relief. As of March 28, 2024, 94 commercial nuclear reactors have received license renewal, renewing their operating licenses from 40 to 60 years. In recent years, it has become evident that there will be another wave of subsequent license renewals. The NRC granted the first application for subsequent license renewal out to 80 years in 2019. Six 10 61 FR 39,278, 39,285; 1996.

11 53 FR 24,018, 24,041; 1988.

Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 15 reactors have now received approval to operate up to 80 years.12 The Nuclear Energy Institute estimates that over 70 reactors will seek subsequent license renewal13. The regulation did not account for either the amount of time available for the appreciation of nuclear decommissioning trust funds, or the duration of time for on-site storage of MRCs that results from renewals.

12 CEG acknowledges, however, that the Commission took action in 2022 that affecting the previously approved subsequent license renewals and recently completed a rulemaking to revise 10 CFR Part 51 and the Generic Environmental Impact Statement for License Renewal. See generally SECY-24-0017 (Feb. 21, 2024).

13 NEI Publication, "The Future of Nuclear Power - 2023 Baseline Survey" Request for Exemption from 10 CFR 50.82(a)(8)(i) AND (ii) 16 VI.

Conclusion Granting this exemption will be consistent with the NRC decommissioning regulations as it: (1) would not eliminate the potential for unrestricted site release; (2) would not have a significant environmental impact not previously considered in Environmental Impact Statements, and (3) would not decrease reasonable assurance that adequate funds will be available for decommissioning. Conversely, the exemption would support efforts to achieve unrestricted release, improve environmental conditions as a result, and increase the effectiveness of the decommissioning fund for unrestricted release of the site.

It is prudent and consistent with the NRCs philosophy regarding the timely remediation of source terms to remove large component source terms that otherwise would remain on site until much later in time. In sum, it will facilitate the decommissioning process by removing the specified components from the site so that: (1) the inventory of radioactive waste and the associated source term at Dresden will be reduced; (2) the costs associated with maintaining the Steam Dryers on site and providing protection to workers can be avoided; (3) the overall cost to decommission the site will be reduced; (4) any uncertainty regarding future disposal cost and capacity for these MRCs is eliminated; and (5) adequate funds will be available to decommission Dresden at the time the reactor ceases operation. Finally, the adequacy of the availability of funds for Dresden decommissioning is supported by a site-specific Decommissioning Cost Estimate and the associated funding program.

Decommissioning Cash Flow Analysis for Dresden, Unit 2 SAFSTOR Radiological

Page 1 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 2 - SAFSTOR Radiological (thousands of 2024 dollars)

Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2024(c)(d) 20,000 0

20,000 937,625 917,625 18,352 935,977 2025 0

0 0

935,977 935,977 18,720 954,697 2026 0

0 0

954,697 954,697 19,094 973,791 2027(e) 100 0

100 973,791 973,691 19,474 993,164 2028(e) 3,327 0

3,327 993,164 989,837 19,797 1,009,634 2029 3,513 0

3,513 1,009,634 1,006,121 20,122 1,026,243 2030 43,032 0

43,032 1,026,243 983,211 19,664 1,002,875 2031 38,087 0

38,087 1,002,875 964,788 19,296 984,084 2032 38,872 0

38,872 984,084 945,212 18,904 964,117 2033 35,833 0

35,833 964,117 928,283 18,566 946,849 2034 33,607 0

33,607 946,849 913,242 18,265 931,507 2035 29,541 0

29,541 931,507 901,966 18,039 920,005 2036 15,691 0

15,691 920,005 904,314 18,086 922,400 2037 4,536 0

4,536 922,400 917,864 18,357 936,221 2038 3,595 0

3,595 936,221 932,626 18,653 951,279 2039 3,585 0

3,585 951,279 947,694 18,954 966,648 2040 3,585 0

3,585 966,648 963,063 19,261 982,324 2041 3,585 0

3,585 982,324 978,739 19,575 998,314 2042 3,595 0

3,595 998,314 994,719 19,894 1,014,613 2043 3,528 0

3,528 1,014,613 1,011,085 20,222 1,031,307 2044 3,509 0

3,509 1,031,307 1,027,798 20,556 1,048,354 2045 3,509 0

3,509 1,048,354 1,044,844 20,897 1,065,741 2046 3,519 0

3,519 1,065,741 1,062,222 21,244 1,083,467 2047 3,509 0

3,509 1,083,467 1,079,957 21,599 1,101,557 2048 3,509 0

3,509 1,101,557 1,098,047 21,961 1,120,008 2049 3,509 0

3,509 1,120,008 1,116,499 22,330 1,138,829 2050 3,890 0

3,890 1,138,829 1,134,939 22,699 1,157,638 2051 3,879 0

3,879 1,157,638 1,153,759 23,075 1,176,834 2052 3,879 0

3,879 1,176,834 1,172,955 23,459 1,196,414 2053 3,879 0

3,879 1,196,414 1,192,535 23,851 1,216,386 2054 3,890 0

3,890 1,216,386 1,212,496 24,250 1,236,746 2055 3,879 0

3,879 1,236,746 1,232,867 24,657 1,257,524 2056 3,879 0

3,879 1,257,524 1,253,645 25,073 1,278,718 2057 3,879 0

3,879 1,278,718 1,274,839 25,497 1,300,336 2058 3,890 0

3,890 1,300,336 1,296,446 25,929 1,322,375 2059 3,879 0

3,879 1,322,375 1,318,496 26,370 1,344,866

Page 2 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 2 - SAFSTOR Radiological (thousands of 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)

(c) 2024 costs are for steam dryer disposal and mausoleum demolition and disposal (d) The 2024 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2024 dryer and mausoleum expenses (e) 2027 and 2028 costs are for decommissioning planning Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2060 3,879 0

3,879 1,344,866 1,340,987 26,820 1,367,806 2061 3,879 0

3,879 1,367,806 1,363,927 27,279 1,391,206 2062 3,890 0

3,890 1,391,206 1,387,316 27,746 1,415,062 2063 3,879 0

3,879 1,415,062 1,411,183 28,224 1,439,407 2064 3,879 0

3,879 1,439,407 1,435,528 28,711 1,464,238 2065 3,879 0

3,879 1,464,238 1,460,359 29,207 1,489,567 2066 3,890 0

3,890 1,489,567 1,485,677 29,714 1,515,390 2067 3,879 0

3,879 1,515,390 1,511,511 30,230 1,541,742 2068 3,879 0

3,879 1,541,742 1,537,862 30,757 1,568,620 2069 3,879 0

3,879 1,568,620 1,564,741 31,295 1,596,035 2070 3,890 0

3,890 1,596,035 1,592,146 31,843 1,623,989 2071 3,879 0

3,879 1,623,989 1,620,110 32,402 1,652,512 2072 3,879 0

3,879 1,652,512 1,648,633 32,973 1,681,605 2073 3,879 0

3,879 1,681,605 1,677,726 33,555 1,711,281 2074 3,890 0

3,890 1,711,281 1,707,391 34,148 1,741,539 2075 3,879 0

3,879 1,741,539 1,737,660 34,753 1,772,413 2076 3,879 0

3,879 1,772,413 1,768,534 35,371 1,803,905 2077 3,879 0

3,879 1,803,905 1,800,025 36,001 1,836,026 2078 3,890 0

3,890 1,836,026 1,832,136 36,643 1,868,779 2079 3,879 0

3,879 1,868,779 1,864,900 37,298 1,902,198 2080 3,879 0

3,879 1,902,198 1,898,319 37,966 1,936,285 2081 3,879 0

3,879 1,936,285 1,932,406 38,648 1,971,054 2082 21,716 0

21,716 1,971,054 1,949,338 38,987 1,988,325 2083 62,116 0

62,116 1,988,325 1,926,209 38,524 1,964,733 2084 83,085 0

83,085 1,964,733 1,881,649 37,633 1,919,282 2085 83,085 0

83,085 1,919,282 1,836,197 36,724 1,872,921 2086 83,085 0

83,085 1,872,921 1,789,836 35,797 1,825,633 2087 84,183 0

84,183 1,825,633 1,741,450 34,829 1,776,279 2088 83,549 5,468 89,017 1,776,279 1,687,263 33,745 1,721,008 2089 33,606 2,288 35,894 1,721,008 1,685,114 33,702 1,718,816 Totals(a) 967,317 7,756 975,074

Decommissioning Cash Flow Analysis for Dresden, Unit 3 SAFSTOR Radiological

Page 1 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 3 - SAFSTOR Radiological (thousands of 2024 dollars)

Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2024(c)(d) 20,000 0

20,000 958,464 938,464 18,769 957,233 2025 0

0 0

957,233 957,233 19,145 976,378 2026 0

0 0

976,378 976,378 19,528 995,905 2027 0

0 0

995,905 995,905 19,918 1,015,823 2028 0

0 0

1,015,823 1,015,823 20,316 1,036,140 2029(e) 3,201 0

3,201 1,036,140 1,032,939 20,659 1,053,598 2030(e) 3,300 0

3,300 1,053,598 1,050,298 21,006 1,071,304 2031 61,392 0

61,392 1,071,304 1,009,912 20,198 1,030,110 2032 39,658 0

39,658 1,030,110 990,452 19,809 1,010,261 2033 36,620 0

36,620 1,010,261 973,641 19,473 993,114 2034 34,396 0

34,396 993,114 958,718 19,174 977,892 2035 30,327 0

30,327 977,892 947,565 18,951 966,516 2036 16,348 0

16,348 966,516 950,167 19,003 969,171 2037 4,702 0

4,702 969,171 964,469 19,289 983,759 2038 3,714 0

3,714 983,759 980,044 19,601 999,645 2039 3,704 0

3,704 999,645 995,941 19,919 1,015,860 2040 3,704 0

3,704 1,015,860 1,012,156 20,243 1,032,399 2041 3,704 0

3,704 1,032,399 1,028,695 20,574 1,049,269 2042 3,714 0

3,714 1,049,269 1,045,555 20,911 1,066,466 2043 3,647 0

3,647 1,066,466 1,062,819 21,256 1,084,076 2044 3,628 0

3,628 1,084,076 1,080,447 21,609 1,102,056 2045 3,628 0

3,628 1,102,056 1,098,428 21,969 1,120,397 2046 3,638 0

3,638 1,120,397 1,116,758 22,335 1,139,094 2047 3,628 0

3,628 1,139,094 1,135,465 22,709 1,158,174 2048 3,628 0

3,628 1,158,174 1,154,546 23,091 1,177,637 2049 3,628 0

3,628 1,177,637 1,174,009 23,480 1,197,489 2050 4,009 0

4,009 1,197,489 1,193,480 23,870 1,217,349 2051 3,998 0

3,998 1,217,349 1,213,351 24,267 1,237,618 2052 3,998 0

3,998 1,237,618 1,233,620 24,672 1,258,293 2053 3,998 0

3,998 1,258,293 1,254,295 25,086 1,279,380 2054 4,009 0

4,009 1,279,380 1,275,371 25,507 1,300,879 2055 3,998 0

3,998 1,300,879 1,296,881 25,938 1,322,818 2056 3,998 0

3,998 1,322,818 1,318,820 26,376 1,345,197 2057 3,998 0

3,998 1,345,197 1,341,199 26,824 1,368,023 2058 4,009 0

4,009 1,368,023 1,364,014 27,280 1,391,294

Page 2 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 3 - SAFSTOR Radiological (thousands of 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)

(c) 2024 costs are for steam dryer disposal and mausoleum demolition and disposal (d) The 2024 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2024 dryer and mausoleum expenses (e) 2029 and 2030 costs are for decommissioning planning Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2059 3,998 0

3,998 1,391,294 1,387,296 27,746 1,415,042 2060 3,998 0

3,998 1,415,042 1,411,044 28,221 1,439,264 2061 3,998 0

3,998 1,439,264 1,435,266 28,705 1,463,972 2062 4,009 0

4,009 1,463,972 1,459,963 29,199 1,489,162 2063 3,998 0

3,998 1,489,162 1,485,164 29,703 1,514,867 2064 3,998 0

3,998 1,514,867 1,510,869 30,217 1,541,086 2065 3,998 0

3,998 1,541,086 1,537,088 30,742 1,567,830 2066 4,009 0

4,009 1,567,830 1,563,821 31,276 1,595,097 2067 3,998 0

3,998 1,595,097 1,591,099 31,822 1,622,921 2068 3,998 0

3,998 1,622,921 1,618,923 32,378 1,651,302 2069 3,998 0

3,998 1,651,302 1,647,303 32,946 1,680,250 2070 4,009 0

4,009 1,680,250 1,676,240 33,525 1,709,765 2071 3,998 0

3,998 1,709,765 1,705,767 34,115 1,739,883 2072 3,998 0

3,998 1,739,883 1,735,884 34,718 1,770,602 2073 3,998 0

3,998 1,770,602 1,766,604 35,332 1,801,936 2074 4,009 0

4,009 1,801,936 1,797,927 35,959 1,833,886 2075 3,998 0

3,998 1,833,886 1,829,888 36,598 1,866,485 2076 3,998 0

3,998 1,866,485 1,862,487 37,250 1,899,737 2077 3,998 0

3,998 1,899,737 1,895,739 37,915 1,933,654 2078 4,009 0

4,009 1,933,654 1,929,645 38,593 1,968,237 2079 3,998 0

3,998 1,968,237 1,964,239 39,285 2,003,524 2080 3,998 0

3,998 2,003,524 1,999,526 39,991 2,039,517 2081 3,998 0

3,998 2,039,517 2,035,518 40,710 2,076,229 2082 21,835 0

21,835 2,076,229 2,054,393 41,088 2,095,481 2083 62,591 0

62,591 2,095,481 2,032,890 40,658 2,073,548 2084 84,095 0

84,095 2,073,548 1,989,453 39,789 2,029,242 2085 84,095 0

84,095 2,029,242 1,945,147 38,903 1,984,049 2086 84,095 0

84,095 1,984,049 1,899,954 37,999 1,937,953 2087 98,199 0

98,199 1,937,953 1,839,754 36,795 1,876,549 2088 101,156 5,468 106,624 1,876,549 1,769,925 35,398 1,805,323 2089 37,561 2,288 39,849 1,805,323 1,765,474 35,309 1,800,784 Totals(a) 995,567 7,756 1,003,323

Decommissioning Cash Flow Analysis for Dresden Unit 2 SAFSTOR Total

Page 1 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 2 - SAFSTOR Total (thousands of 2024 dollars)

Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Spent Fuel Management Cost Site Restoration Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2024(c)(d) 20,000 0

0 0

20,000 937,625 917,625 18,352 935,977 2025 0

0 0

0 0

935,977 935,977 18,720 954,697 2026 0

0 0

0 0

954,697 954,697 19,094 973,791 2027(e) 100 0

0 0

100 973,791 973,691 19,474 993,164 2028(e) 3,327 0

0 0

3,327 993,164 989,837 19,797 1,009,634 2029 3,513 0

0 0

3,513 1,009,634 1,006,121 20,122 1,026,243 2030 43,032 0

119,896 96 163,024 1,026,243 863,219 17,264 880,484 2031 38,087 0

1,884 18 39,989 880,484 840,495 16,810 857,305 2032 38,872 0

1,884 18 40,773 857,305 816,532 16,331 832,863 2033 35,833 0

1,884 18 37,735 832,863 795,128 15,903 811,031 2034 33,607 0

27,050 18 60,675 811,031 750,356 15,007 765,363 2035 29,541 0

29,217 18 58,775 765,363 706,588 14,132 720,719 2036 15,691 0

4,205 86 19,982 720,719 700,737 14,015 714,752 2037 4,536 0

1,884 8

6,428 714,752 708,323 14,166 722,490 2038 3,595 0

1,889 0

5,484 722,490 717,006 14,340 731,346 2039 3,585 0

1,884 0

5,469 731,346 725,878 14,518 740,395 2040 3,585 0

1,884 0

5,469 740,395 734,926 14,699 749,625 2041 3,585 0

1,884 0

5,469 749,625 744,156 14,883 759,039 2042 3,595 0

1,889 0

5,484 759,039 753,556 15,071 768,627 2043 3,528 0

3,822 0

7,350 768,627 761,277 15,226 776,503 2044 3,509 0

4,456 0

7,965 776,503 768,538 15,371 783,909 2045 3,509 0

4,456 0

7,965 783,909 775,944 15,519 791,463 2046 3,519 0

4,468 0

7,987 791,463 783,476 15,670 799,146 2047 3,509 0

4,456 0

7,965 799,146 791,181 15,824 807,004 2048 3,509 0

4,456 0

7,965 807,004 799,040 15,981 815,020 2049 3,509 0

4,456 0

7,965 815,020 807,055 16,141 823,197 2050 3,890 0

0 0

3,890 823,197 819,307 16,386 835,693 2051 3,879 0

0 0

3,879 835,693 831,814 16,636 848,450 2052 3,879 0

0 0

3,879 848,450 844,571 16,891 861,463 2053 3,879 0

0 0

3,879 861,463 857,583 17,152 874,735 2054 3,890 0

0 0

3,890 874,735 870,845 17,417 888,262 2055 3,879 0

0 0

3,879 888,262 884,383 17,688 902,071 2056 3,879 0

0 0

3,879 902,071 898,192 17,964 916,156 2057 3,879 0

0 0

3,879 916,156 912,277 18,246 930,522 2058 3,890 0

0 0

3,890 930,522 926,632 18,533 945,165 2059 3,879 0

0 0

3,879 945,165 941,286 18,826 960,112

Page 2 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 2 - SAFSTOR Total (thousands of 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)

(c) 2024 costs are for steam dryer disposal and mausoleum demolition and disposal (d) The 2024 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2024 dryer and mausoleum expenses (e) 2027 and 2028 costs are for decommissioning planning Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Spent Fuel Management Cost Site Restoration Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2060 3,879 0

0 0

3,879 960,112 956,233 19,125 975,357 2061 3,879 0

0 0

3,879 975,357 971,478 19,430 990,908 2062 3,890 0

0 0

3,890 990,908 987,018 19,740 1,006,758 2063 3,879 0

0 0

3,879 1,006,758 1,002,879 20,058 1,022,937 2064 3,879 0

0 0

3,879 1,022,937 1,019,058 20,381 1,039,439 2065 3,879 0

0 0

3,879 1,039,439 1,035,560 20,711 1,056,271 2066 3,890 0

0 0

3,890 1,056,271 1,052,381 21,048 1,073,429 2067 3,879 0

0 0

3,879 1,073,429 1,069,550 21,391 1,090,941 2068 3,879 0

0 0

3,879 1,090,941 1,087,062 21,741 1,108,803 2069 3,879 0

0 0

3,879 1,108,803 1,104,924 22,098 1,127,022 2070 3,890 0

0 0

3,890 1,127,022 1,123,133 22,463 1,145,595 2071 3,879 0

0 0

3,879 1,145,595 1,141,716 22,834 1,164,551 2072 3,879 0

0 0

3,879 1,164,551 1,160,672 23,213 1,183,885 2073 3,879 0

0 0

3,879 1,183,885 1,180,006 23,600 1,203,606 2074 3,890 0

0 0

3,890 1,203,606 1,199,716 23,994 1,223,711 2075 3,879 0

0 0

3,879 1,223,711 1,219,832 24,397 1,244,228 2076 3,879 0

0 0

3,879 1,244,228 1,240,349 24,807 1,265,156 2077 3,879 0

0 0

3,879 1,265,156 1,261,277 25,226 1,286,503 2078 3,890 0

0 0

3,890 1,286,503 1,282,613 25,652 1,308,265 2079 3,879 0

0 0

3,879 1,308,265 1,304,386 26,088 1,330,474 2080 3,879 0

0 0

3,879 1,330,474 1,326,595 26,532 1,353,127 2081 3,879 0

0 0

3,879 1,353,127 1,349,248 26,985 1,376,232 2082 21,716 0

0 37 21,753 1,376,232 1,354,479 27,090 1,381,569 2083 62,116 0

0 113 62,229 1,381,569 1,319,340 26,387 1,345,727 2084 83,085 0

0 145 83,230 1,345,727 1,262,497 25,250 1,287,747 2085 83,085 0

0 145 83,230 1,287,747 1,204,517 24,090 1,228,607 2086 83,085 0

0 145 83,230 1,228,607 1,145,378 22,908 1,168,285 2087 84,183 0

0 895 85,077 1,168,285 1,083,208 21,664 1,104,872 2088 83,549 5,468 0

1,102 90,119 1,104,872 1,014,753 20,295 1,035,048 2089 33,606 2,288 0

762 36,656 1,035,048 998,392 19,968 1,018,360 2090 0

0 0

21,152 21,152 1,018,360 997,209 19,944 1,017,153 2091 0

0 0

21,094 21,094 1,017,153 996,059 19,921 1,015,980 2092 0

0 0

13,813 13,813 1,015,980 1,002,167 20,043 1,022,210 Totals(a) 967,317 7,756 227,899 59,680 1,262,653

Decommissioning Cash Flow Analysis for Dresden, Unit 3 SAFSTOR Total

Page 1 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 3 - SAFSTOR Total (thousands of 2024 dollars)

Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Spent Fuel Management Cost Site Restoration Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2024(c)(d) 20,000 0

0 0

20,000 958,464 938,464 18,769 957,233 2025 0

0 0

0 0

957,233 957,233 19,145 976,378 2026 0

0 0

0 0

976,378 976,378 19,528 995,905 2027 0

0 0

0 0

995,905 995,905 19,918 1,015,823 2028 0

0 0

0 0

1,015,823 1,015,823 20,316 1,036,140 2029(e) 3,201 0

0 0

3,201 1,036,140 1,032,939 20,659 1,053,598 2030(e) 3,300 0

0 0

3,300 1,053,598 1,050,298 21,006 1,071,304 2031 61,392 0

119,731 94 181,218 1,071,304 890,086 17,802 907,888 2032 39,658 0

1,884 22 41,564 907,888 866,324 17,326 883,650 2033 36,620 0

1,884 22 38,526 883,650 845,124 16,902 862,027 2034 34,396 0

27,010 22 61,428 862,027 800,599 16,012 816,611 2035 30,327 0

29,254 22 59,604 816,611 757,007 15,140 772,147 2036 16,348 0

4,208 86 20,643 772,147 751,504 15,030 766,534 2037 4,702 0

1,884 8

6,593 766,534 759,941 15,199 775,140 2038 3,714 0

1,889 0

5,603 775,140 769,537 15,391 784,927 2039 3,704 0

1,884 0

5,588 784,927 779,340 15,587 794,927 2040 3,704 0

1,884 0

5,588 794,927 789,339 15,787 805,126 2041 3,704 0

1,884 0

5,588 805,126 799,538 15,991 815,529 2042 3,714 0

1,889 0

5,603 815,529 809,926 16,199 826,124 2043 3,647 0

3,797 0

7,444 826,124 818,680 16,374 835,054 2044 3,628 0

4,422 0

8,051 835,054 827,003 16,540 843,543 2045 3,628 0

4,422 0

8,051 843,543 835,492 16,710 852,202 2046 3,638 0

4,435 0

8,073 852,202 844,129 16,883 861,012 2047 3,628 0

4,422 0

8,051 861,012 852,961 17,059 870,020 2048 3,628 0

4,422 0

8,051 870,020 861,970 17,239 879,209 2049 3,628 0

4,422 0

8,051 879,209 871,158 17,423 888,581 2050 4,009 0

0 0

4,009 888,581 884,572 17,691 902,264 2051 3,998 0

0 0

3,998 902,264 898,266 17,965 916,231 2052 3,998 0

0 0

3,998 916,231 912,233 18,245 930,478 2053 3,998 0

0 0

3,998 930,478 926,479 18,530 945,009 2054 4,009 0

0 0

4,009 945,009 941,000 18,820 959,820 2055 3,998 0

0 0

3,998 959,820 955,822 19,116 974,938 2056 3,998 0

0 0

3,998 974,938 970,940 19,419 990,359 2057 3,998 0

0 0

3,998 990,359 986,361 19,727 1,006,088 2058 4,009 0

0 0

4,009 1,006,088 1,002,079 20,042 1,022,121

Page 2 of 2 Decommissioning Cash Flow Analysis for Dresden Unit 3 - SAFSTOR Total (thousands of 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)

(c) 2024 costs are for steam dryer disposal and mausoleum demolition and disposal (d) The 2024 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2024 dryer and mausoleum expenses (e) 2029 and 2030 costs are for decommissioning planning Year Radiological Decommissioning Cost ISFSI Decommissioning Cost Spent Fuel Management Cost Site Restoration Cost Total Cost(a)

BOY Trust Fund Value BOY Trust Fund Less Cost Trust Fund Earnings(b)

EOY Trust Fund Value(a) 2059 3,998 0

0 0

3,998 1,022,121 1,018,123 20,362 1,038,485 2060 3,998 0

0 0

3,998 1,038,485 1,034,487 20,690 1,055,177 2061 3,998 0

0 0

3,998 1,055,177 1,051,179 21,024 1,072,202 2062 4,009 0

0 0

4,009 1,072,202 1,068,193 21,364 1,089,557 2063 3,998 0

0 0

3,998 1,089,557 1,085,559 21,711 1,107,270 2064 3,998 0

0 0

3,998 1,107,270 1,103,272 22,065 1,125,337 2065 3,998 0

0 0

3,998 1,125,337 1,121,339 22,427 1,143,766 2066 4,009 0

0 0

4,009 1,143,766 1,139,757 22,795 1,162,552 2067 3,998 0

0 0

3,998 1,162,552 1,158,554 23,171 1,181,725 2068 3,998 0

0 0

3,998 1,181,725 1,177,727 23,555 1,201,282 2069 3,998 0

0 0

3,998 1,201,282 1,197,284 23,946 1,221,229 2070 4,009 0

0 0

4,009 1,221,229 1,217,220 24,344 1,241,565 2071 3,998 0

0 0

3,998 1,241,565 1,237,566 24,751 1,262,318 2072 3,998 0

0 0

3,998 1,262,318 1,258,320 25,166 1,283,486 2073 3,998 0

0 0

3,998 1,283,486 1,279,488 25,590 1,305,078 2074 4,009 0

0 0

4,009 1,305,078 1,301,069 26,021 1,327,090 2075 3,998 0

0 0

3,998 1,327,090 1,323,092 26,462 1,349,554 2076 3,998 0

0 0

3,998 1,349,554 1,345,556 26,911 1,372,467 2077 3,998 0

0 0

3,998 1,372,467 1,368,469 27,369 1,395,838 2078 4,009 0

0 0

4,009 1,395,838 1,391,829 27,837 1,419,666 2079 3,998 0

0 0

3,998 1,419,666 1,415,668 28,313 1,443,981 2080 3,998 0

0 0

3,998 1,443,981 1,439,983 28,800 1,468,782 2081 3,998 0

0 0

3,998 1,468,782 1,464,784 29,296 1,494,080 2082 21,835 0

0 37 21,873 1,494,080 1,472,207 29,444 1,501,652 2083 62,591 0

0 167 62,758 1,501,652 1,438,894 28,778 1,467,672 2084 84,095 0

0 278 84,373 1,467,672 1,383,299 27,666 1,410,964 2085 84,095 0

0 278 84,373 1,410,964 1,326,591 26,532 1,353,123 2086 84,095 0

0 278 84,373 1,353,123 1,268,750 25,375 1,294,125 2087 98,199 0

0 2,771 100,971 1,294,125 1,193,155 23,863 1,217,018 2088 101,156 5,468 0

3,459 110,083 1,217,018 1,106,934 22,139 1,129,073 2089 37,561 2,288 0

1,470 41,319 1,129,073 1,087,753 21,755 1,109,509 2090 0

0 0

28,980 28,980 1,109,509 1,080,529 21,611 1,102,139 2091 0

0 0

28,901 28,901 1,102,139 1,073,238 21,465 1,094,703 2092 0

0 0

17,534 17,534 1,094,703 1,077,169 21,543 1,098,713 Totals(a) 995,567 7,756 225,627 84,431 1,313,381

Parent Guarantee Qualification

Page 1 of 1 Parent Guarantee Qualification As of December 31, 2023 Draft Interim Staff Guidance Parent Guarantee Financial Test II Parameter Value All decommissioning amounts covered by an NRC or Agreement State parent company guarantees or self-guarantee.

$0 All amounts covered by parent guarantees, self-guarantees, or financial tests of other Federal or State agencies (e.g. EPA)

$0 Creditworthiness criteria provided to NRC?

Tangible Net Worth

$10,525 million Total Net Worth

$11,286 million Total Assets in the United States

$49,899 million Criteria Met?

Tangible net worth of at least $21M?

Yes Total net worth at least six times the amount of decommissioning funds being assured by a parent guarantee for the total of all nuclear facilities or parts thereof (or prescribed amount, if certification is used)?

Yes Are at least 90 percent of the firm's assets located in the United States?

Or Assets located in the United States amount to at least six times the current decommissioning cost estimates?

Yes N/A