RS-25-2025, Constellation Energy Generation, LLC - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
| ML25085A363 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Salem, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, Zion, FitzPatrick, LaSalle, Crane |
| Issue date: | 03/26/2025 |
| From: | Steinman R Constellation Energy Generation |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-25-2025 | |
| Download: ML25085A363 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 RS-25-046 10 CFR 50.75(f) 10 CFR 72.30(b) 10 CFR 50.82(a)
March 26, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. STN 50-317 and STN 50-318 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Independent Spent Fuel Storage Installation Materials License No. SNM-2505 NRC Docket No. 72-08 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 and 72-1046 Dresden Nuclear Power Station, Units 1, 2 and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-10, 50-237, 50-249, and 72-37 James. A FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket Nos. 50-333 and 72-012 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65
March 26, 2025 U.S. Nuclear Regulatory Commission Page 2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and DPR-69 NRC Docket Nos. 50-220, 50-410, and 72-1036 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278, and 72-29 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244 and 72-67 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272, 50-311, and 72-48 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289, and 72-77 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295, 50-304 and 72-1037
Subject:
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations In accordance with 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning," paragraph (f), Constellation Energy Generation, LLC (CEG) is submitting a report on the status of decommissioning funding for the reactors owned or co-owned by CEG.
Additionally, in accordance with 10 CFR 72.30, "Financial assurance and recordkeeping for decommissioning," CEG is submitting updates to the decommissioning funding plans for the independent spent fuel storage installations (ISFSIs) owned or co-owned by CEG.1 Updated decommissioning cost estimates for ISFSI decommissioning are provided in the attached report in Attachment 30 and 31. With respect to the other information required by 10 CFR 72.30(b) and (c), unless otherwise noted in Attachment 31, there have been no changes from the information provided in the initial ISFSI decommissioning funding plans (see 1, References 1, 2, 3, 5, 8, and 10).
In accordance with 10 CFR 50.75(b)(4), 50.75(c), and 50.75(f), the estimated cost of decommissioning for financial assurance is based on either the NRC formula cost amount 1 CEG currently has ISFSIs at each of its sites.
March 26, 2025 U.S. Nuclear Regulatory Commission Page 3 calculated in accordance with 10 CFR 50.75(c) or site-specific decommissioning cost estimates.
If used in this report, the site-specific decommissioning cost estimates are based on a period of safe storage that is specifically described in the estimates. Site-specific cash flows from the site-specific cost estimates are included, as applicable. Unless otherwise noted, the specific cash flow analysis for the site-specific decommissioning cost estimates conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period. The cash flow analysis for Peach Bottom Atomic Power Station (PBAPS), Unit 1 assumes that half of the current year contributions are included in the current year earnings to estimate payment of contributions throughout the year (i.e., a mid-year convention). CEG uses a mid-year convention in this instance because the contributions are made monthly at a constant rate throughout the year.
Nine Mile Point Nuclear Station (NMP), Unit 2 is co-owned by Nine Mile Point Nuclear Station, LLC (82%), an indirect CEG co-owned subsidiary, and Long Island Power Authority (LIPA)
(18%). The information provided in this letter for NMP, Unit 2 includes summary statements provided and verified by LIPA.
For shutdown units the reporting requirements of 10 CFR 50.82(a)(8)(v) and (vii) are also included in this report.
For units whose license will expire within five years the following reporting was completed. For Clinton Power Station (CPS) preliminary site-specific SAFSTOR scenario estimate was provided in a letter dated April 18, 2022 (ML22108A263). CPS is currently reporting formula cost amount using the formula in 10 CFR 50.75(c). For Dresden Nuclear Power Station (DNP),
Unit 2, preliminary site-specific SAFSTOR scenario estimate was provided in a letter dated December 18, 2024 (ML24353A260). DNPS is currently reporting formula cost amount using the formula in 10 CFR 50.75(c). For NMP, Unit 1, preliminary site-specific SAFSTOR scenario estimate was provided in a letter dated August 20, 2024 (ML24233A234). NMP Unit 1 is currently reporting formula cost amount using the formula in 10 CFR 50.75(c). For R.E.Ginna Nuclear Power Plant, preliminary site-specific SAFSTOR scenario estimate was provided in a letter dated September 10, 2024 (ML24254A292). Ginna is currently reporting formula cost amount using the formula in 10 CFR 50.75(c).
CEG has not made a final determination of the decommissioning option for any of its operating nuclear units. CEG uses the formula cost amount or the site-specific decommissioning cost estimates to demonstrate adequacy of funding to meet regulatory requirements. To the extent the site-specific cost estimates assume a decommissioning option, CEG may select a different decommissioning option in the future for any of its nuclear units, recognizing that the chosen option must meet NRC requirements for decommissioning funding.
Financial assurance for decommissioning has been provided for all units except for PBAPS, Unit 1. PBAPS, Unit 1, did not meet the minimum funding assurance criteria under 10 CFR 50.75 and 10 CFR 50.82 as of December 31, 2024, based solely on the trust fund balance.
Financial assurance for decommissioning this reactor is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii). The source of revenue for the external sinking fund is a "non-bypassable charge" approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. The amount to be collected will be adjusted, as necessary, in accordance with the applicable tariff in the next submission to the PaPUC of the Nuclear Decommissioning Cost Adjustment (NDCA) to cover any funding shortfall
March 26, 2025 U.S. Nuclear Regulatory Commission Page 4 that exists at that time. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The most recent rate adjustment was effective January 1, 2023. CEG's ability to adjust the amount collected for PBAPS, Unit 1, is consistent with the guidance in Regulatory Guide 1.159, "Assuring Availability of Funds for Decommissioning Nuclear Reactors," Revision 2, page 13, which provides that, "Adjustments to the annual amount of funds being set aside may be made to coincide with rate cases considered by a licensee's public utility commission (PUC)."
Disbursements made through December 31, 2024 from the decommissioning trust funds since the last report, other than those for allowed administrative costs and other incidental expenses of the fund in connection with the operation of the fund per 10 CFR 50.75(h)(1)(iv), were in support of decommissioning planning. DNPS Unit 1, PBAPS Unit 1, Three Mile Island (TMI)
Unit 1, and Zion disbursements contained additional costs in support of decommissioning activities as outlined in their respective attachments.
There are no regulatory commitments contained within this letter.
If you have any questions concerning this letter, please contact Danii Gantt at (779) 231-6227.
Respectfully, Rebecca L. Steinman Sr. Manager - Licensing Constellation Energy Generation, LLC cc:
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Salem Generating Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station NRC Senior Resident Inspector - Zion Nuclear Power Station
- Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2025.03.26 13:47:06 -05'00'
March 26, 2025 U.S. Nuclear Regulatory Commission Page 5 Attachments:
- 1.
Labor, Energy, and Burial Factors Used in Calculations (All Facilities)
- 2.
Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 1
- 3.
Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 2
- 4.
Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 1
- 5.
Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 2
- 6.
Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 1
- 7.
Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 2
- 8.
Annual Radiological Decommissioning Funding Assurance Report for Clinton Power Station, Unit 1
- 9.
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1
- 10. Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 2
- 11. Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 3
- 12. Annual Radiological Decommissioning Funding Assurance Report for James A. FitzPatrick Nuclear Power Station
- 13. Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 1
- 14. Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 2
- 15. Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 1
- 16. Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 2
- 17. Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 1
- 18. Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2 CEG Portion
- 19. Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2 LIPA Portion
- 20. Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1
- 21. Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 2
- 22. Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 3
- 23. Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 1
- 24. Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 2
- 25. Annual Radiological Decommissioning Funding Assurance Report for R.E. Ginna Nuclear Power Plant
- 26. Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 1
March 26, 2025 U.S. Nuclear Regulatory Commission Page 6
- 27. Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 2
- 28. Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1
- 29. Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Zion Nuclear Power Station
- 30. ISFSI Decommissioning Funding Estimates
- 31. Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates
ATTACHMENT 1 Labor, Energy, and Burial Factors Used in Calculations (All Facilities)
Page 1 of 2 ATTACHMENT 1 Labor, Energy, and Burial Factors Used in Calculations (All Facilities)
The labor, energy, and burial indexes used are consistent with those described in NUREG-1307, Revision 20, issued December 27, 2024.
The current labor cost indexes used are obtained from the Employment Cost Index, published by the U.S. Department of Labor, Bureau of Labor Statistics (BLS).
Specifically, Constellation Energy Generation, LLC (CEG) used the Employment Cost Index for total compensation for private industry workers by region. The labor adjustment factors were calculated according to Section 3.2 of NUREG-1307, Revision 20, using fourth quarter 2024 data. Table 1 shows the data used for this calculation.
Table 1: Labor Adjustment Factors Region Applicable Sites Series ID 4Q2024 Index Number Base Lx Labor Adjustment Factor (Lx)
Northeast James A.
FitzPatrick Limerick Nine Mile Point Peach Bottom R.E. Ginna Salem TMI CIU2010000000210I 168.4 2.16 3.637 South Calvert Cliffs CIU2010000000220I 165.0 1.98 3.267 Midwest Braidwood Byron Clinton Dresden LaSalle Quad Cities CIU2010000000230I 163.7 2.08 3.405 The current energy cost indexes used are obtained from Producer Price Indexes (PPI) -
Commodities, published by the U.S. Department of Labor, BLS. Specifically, CEG used the PPI for industrial electric power (WPU0543) and light fuel oils (WPU0573). The energy adjustment factors were calculated according to Section 3.3 of NUREG-1307, Revision 20, using December 2024 data. Table 2 shows the data used for this calculation.
Table 2: Energy Adjustment Factors WPU0543 - January 1986 (base value) 114.2 WPU0573 - January 1986 (base value) 82.0 WPU0543 - December 2024 (preliminary value) 296.8 WPU0573 - December 2024 (preliminary value) 277.5 Industrial electric power adjustment factor - Px 2.599 Light fuel oil adjustment factor - Fx 3.384 Energy Adjustment Factor (PWR) - Ex(PWR) 2.929 Energy Adjustment Factor (BWR) - Ex(BWR) 2.960
Page 2 of 2 ATTACHMENT 1 (Continued)
Labor, Energy, and Burial Factors Used in Calculations (All Facilities)
The waste burial adjustment factors used are taken from Table 2-1 of NUREG-1307, Revision 20, based on 2024 data. The adjustment factors CEG used assume a combination of compact-affiliated and non-compact facilities for sites affiliated with a compact. This is consistent with current waste disposal practices at CEG and consistent with typical waste disposal practices during decommissioning. For sites not affiliated with a compact, the values for generators located in unaffiliated states were used.
Table 3 summarizes the data used for the calculation of the waste adjustment factors.
Table 3: Waste Adjustment Factors LLW Burial Site Reactor Type Applicable Site Combination of Compact-Affiliated and Non-Compact Disposal Facilities Waste Adjustment Factor (Bx)
Generators Located in the Unaffiliated States and those Located in Compact-Affiliated States having no Disposal Facility Waste Adjustment Factor (Bx)
South Carolina site Atlantic Compact PWR Salem 12.813 N/A Generic LLW Disposal Site BWR Clinton Dresden James A. FitzPatrick LaSalle Limerick Nine Mile Point Peach Bottom Quad Cities N/A 11.658 Generic LLW Disposal Site PWR Braidwood Byron Calvert Cliffs R.E. Ginna TMI N/A 12.405 The calculation methodology used for all adjustment factors is consistent with NUREG-1307, Revision 20.
ATTACHMENT 2 Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 1
Page 1 of 1 ATTACHMENT 2 Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$ 558,920 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,429 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$ 497,556 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on October 17, 2046.
ATTACHMENT 3 Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 2
Page 1 of 1 ATTACHMENT 3 Annual Radiological Decommissioning Funding Assurance Report for Braidwood Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$558,920 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,429 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$538,151 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on December 18, 2047.
ATTACHMENT 4 Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 1
Page 1 of 1 ATTACHMENT 4 Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$558,920 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$7,706 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$545,002 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on October 31, 2044.
ATTACHMENT 5 Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 2
Page 1 of 1 ATTACHMENT 5 Annual Radiological Decommissioning Funding Assurance Report for Byron Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$558,920 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$7,706 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$524,647 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on November 6, 2046.
ATTACHMENT 6 Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 1
Page 1 of 1 ATTACHMENT 6 Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$518,552 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$6,825 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$561,193 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on July 31, 2034.
ATTACHMENT 7 Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 2
Page 1 of 1 ATTACHMENT 7 Annual Radiological Decommissioning Funding Assurance Report for Calvert Cliffs Nuclear Power Plant, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$518,552 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$6,825 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$728,416 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on August 13, 2036.
ATTACHMENT 8 Annual Radiological Decommissioning Funding Assurance Report for Clinton Power Station, Unit 1
Page 1 of 1 ATTACHMENT 8 Annual Radiological Decommissioning Funding Assurance Report for Clinton Power Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$696,976 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$11,472 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$748,161 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on April 17, 2027.
ATTACHMENT 9 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1
Page 1 of 5 ATTACHMENT 9 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
N/A (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4) and 50.75(f)
$348,693 (a) 3 Site-specific cost amount per 10 CFR 72.30(b)
$4,553 (b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$480,865 (c) 5 Schedule of the annual amounts remaining to be collected
$0 6
Assumptions used regarding rates of escalation for decommissioning costs, earnings on funds, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v) 8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) 9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
10 2024 annual amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$4,992 (e) 11 Cumulative amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$143,159 (f)
Reimbursed from the decommissioning trust fund
$132,136 (f)
Not yet reimbursed from the decommissioning trust fund
$11,023 12 Amount of funds accumulated to cover the cost of managing irradiated fuel pursuant to 10 CFR 50.82(a)(8)(vii)(A) as of December 31, 2024
$48,664 (g) 13 Projected cost of managing irradiated fuel based on site-specific estimate per 10 CFR 50.82(a)(8)(vii)(B)
$32,705(a)
Page 2 of 5 ATTACHMENT 9 (Continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands)
(a) A formula cost amount using the formula in 10 CFR 50.75(c) is not applicable because Dresden, Unit 1, has been shutdown since October 31, 1978, and some decommissioning activities have already occurred on this unit. However, the amount to decommission Dresden, Unit 1, was calculated pursuant to 10 CFR 50.75(c) to be $592.7 million (as of December 31, 2024). Dresden, Unit 1, was a BWR reactor that operated at a maximum power level of 700 MWt (< 1200 MWt as specified in 10 CFR 50.75(c)). This amount assumes Dresden, Unit 1, was a BWR reactor type rated at a power capacity of 1200 MWt as required by the formula in 10 CFR 50.75(c). The calculation of this value assumes the labor, energy, and burial factors described in Attachment 1 and does not account for decommissioning activities that have occurred for Dresden, Unit 1.
In accordance with the regulatory requirements, the site-specific amount is reported per 10 CFR 50.75(b)(4), 50.75(f), 50.82(a)(8)(iii), and 50.82(a)(8)(v)(B) and assumes a DECON scenario as described in the site-specific cost estimate (SSCE) (DECOM-2023-EST-DRE, Revision 0, "Dresden Decommissioning Cost Estimate - 2023). The decommissioning cost estimate has been adjusted consistent with the description of planned decommissioning activities in the Dresden Nuclear Power Station, Unit 1, Post-Shutdown Decommissioning Activities Report (PSDAR), as most recently updated in a letter from Michael P. Gallagher to U.S. Nuclear Regulatory Commission dated March 19, 2018. The costs have been escalated from the 2023 dollars reflected in the 2023 decommissioning cost estimate to estimated costs as of December 31, 2024.
Decommissioning expenditures prior to the year the SSCE updates were prepared (historical expenditures) are not included in the estimated total cost of decommissioning in the final SSCE reports. Also, the amount reported does not include cash flows from the SSCE estimate for the 2023 through 2024 annual radiological costs because CEG considers the SSCE estimated costs for 2023 through 2024 decommissioning activities to be historical expenditures at the time the 2025 decommissioning funding assurance report is generated.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
Page 3 of 5 ATTACHMENT 9 (Continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands)
(c) The trust fund amount is the amount allocated for radiological decommissioning only.
The allocation of funds for radiological decommissioning is based on the fraction of radiological decommissioning costs to radiological decommissioning costs plus spent fuel management costs identified in the DECON scenario as described in the site-specific cost estimate (SSCE) (DECOM-2023-EST-DRE, Revision 0, "Dresden Decommissioning Cost Estimate - 2023.) This allocation is for purposes of demonstrating adequate decommissioning funding assurance only and is adjusted, as necessary, to provide adequate funding assurance for radiological decommissioning and spent fuel management. No spent fuel management costs are planned to be incurred until 2028.
There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) The amount spent on decommissioning in 2024 is consistent with the projected 2024 expense total of $3,245 (December 31, 2024 thousands of dollars) from the site-specific cost estimate. The delta of $1,747 can be attributed to additional projects that were undertaken in 2024 to reduce long term maintenance costs during the remaining dormancy period. In addition, activities to support early decommissioning planning were conducted.
The amount spent on decommissioning in 2024 represents the 2024 charges to the Dresden, Unit 1, project. Prior to reimbursement from the decommissioning trust fund, these charges will be validated to confirm they are legitimate decommissioning expenses. Consequently, the amount reimbursed may differ from the value provided.
(f) Not all historical data is available, and therefore, the cumulative amount spent on decommissioning and the amount reimbursed are estimates based on the best information obtainable at this time.
(g) The allocation of funds accumulated for managing irradiated fuel is based on the fraction of spent fuel management costs to radiological decommissioning costs plus spent fuel management costs identified in the DECON scenario as described in the site-specific cost estimate (SSCE) (DECOM-2023-EST-DRE, Revision 0, "Dresden Decommissioning Cost Estimate - 2023). This allocation is for purposes of demonstrating adequate decommissioning funding assurance only and is adjusted, as necessary, to provide adequate funding assurance for radiological decommissioning and spent fuel management. No spent fuel management costs are planned to be incurred until 2028.
Page 4 of 5 ATTACHMENT 9 (Continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands)
BOY BOY EOY Radiological Trust Trust Fund Trust Trust Decommissioning Fund Value Fund Fund Year Cost Value Less Cost Earnings Value 2025
$3,245
$480,865
$477,620
$9,552
$487,173 2026
$3,245
$487,173
$483,927
$9,679
$493,606 2027
$3,245
$493,606
$490,361
$9,807
$500,168 2028
$3,254
$500,168
$496,914
$9,938
$506,852 2029
$42,630
$506,852
$464,222
$9,284
$473,506 2030
$57,367
$473,506
$416,139
$8,323
$424,461 2031
$54,203
$424,461
$370,258
$7,405
$377,664 2032
$51,931
$377,664
$325,733
$6,515
$332,248 2033
$48,170
$332,248
$284,078
$5,682
$289,759 2034
$48,072
$289,759
$241,687
$4,834
$246,521 2035
$22,216
$246,521
$224,305
$4,486
$228,791 2036
$888
$228,791
$227,903
$4,558
$232,461 2037
$0
$232,461
$232,461
$4,649
$237,110 2038
$0
$237,110
$237,110
$4,742
$241,853 2039
$0
$241,853
$241,853
$4,837
$246,690 2040
$0
$246,690
$246,690
$4,934
$251,624 2041
$1,140
$251,624
$250,483
$5,010
$255,493 2042
$1,513
$255,493
$253,979
$5,080
$259,059 2043
$1,513
$259,059
$257,545
$5,151
$262,696 2044
$1,518
$262,696
$261,179
$5,224
$266,402 2045
$1,513
$266,402
$264,889
$5,298
$270,186 2046
$1,513
$270,186
$268,673
$5,373
$274,046 2047
$1,513
$274,046
$272,533
$5,451
$277,984 2048
$4,553
$277,984
$273,431
$5,469
$278,899 Total*
$353,246
- Column may not add due to rounding
Page 5 of 5 ATTACHMENT 9 (Continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Dresden Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands)
BOY BOY EOY Irradiated Irradiated Fuel Irradiated Fuel Irradiated Fuel Irradiated Fuel Fuel Trust Fund Trust Fund Trust Fund Trust Fund Year Cost Value Less Cost Earnings Value 2025
$0
$48,664
$48,664
$973
$49,637 2026
$0
$49,637
$49,637
$993
$50,630 2027
$0
$50,630
$50,630
$1,013
$51,642 2028
$1,014
$51,642
$50,629
$1,013
$51,641 2029
$1,011
$51,641
$50,631
$1,013
$51,643 2030
$1,011
$51,643
$50,632
$1,013
$51,645 2031
$1,011
$51,645
$50,634
$1,013
$51,647 2032
$1,014
$51,647
$50,633
$1,013
$51,646 2033
$1,011
$51,646
$50,635
$1,013
$51,648 2034
$1,011
$51,648
$50,637
$1,013
$51,650 2035
$1,011
$51,650
$50,639
$1,013
$51,652 2036
$1,708
$51,652
$49,944
$999
$50,942 2037
$1,782
$50,942
$49,161
$983
$50,144 2038
$1,788
$50,144
$48,356
$967
$49,323 2039
$1,798
$49,323
$47,525
$951
$48,476 2040
$1,803
$48,476
$46,673
$933
$47,607 2041
$2,149
$47,607
$45,458
$909
$46,367 2042
$2,263
$46,367
$44,104
$882
$44,986 2043
$2,263
$44,986
$42,723
$854
$43,577 2044
$2,270
$43,577
$41,307
$826
$42,134 2045
$2,263
$42,134
$39,870
$797
$40,668 2046
$2,263
$40,668
$38,404
$768
$39,172 2047
$2,263
$39,172
$36,909
$738
$37,647 2048
$0
$37,647
$37,647
$753
$38,400 Total*
$32,705
- Column may not add due to rounding
ATTACHMENT 10 Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 2
Page 1 of 1 ATTACHMENT 10 Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$674,327 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,078 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$1,005,737(b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on December 22, 2029.
ATTACHMENT 11 Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 3
Page 1 of 1 ATTACHMENT 11 Annual Radiological Decommissioning Funding Assurance Report for Dresden Nuclear Power Station, Unit 3 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$674,327 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,078 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$1,028,059(b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on January 12, 2031.
ATTACHMENT 12 Annual Radiological Decommissioning Funding Assurance Report for James A. FitzPatrick Nuclear Power Station
Page 1 of 1 ATTACHMENT 12 Annual Radiological Decommissioning Funding Assurance Report for James A. FitzPatrick Nuclear Power Station (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$673,930 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$13,154 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$1,048,546(b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on October 17, 2034.
ATTACHMENT 13 Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 1
Page 1 of 1 ATTACHMENT 13 Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$696,976 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$9,830 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$737,051 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on April 17, 2042.
ATTACHMENT 14 Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 2
Page 1 of 1 ATTACHMENT 14 Annual Radiological Decommissioning Funding Assurance Report for LaSalle County Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$696,976 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$9,830 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$738,543 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on December 16, 2043.
ATTACHMENT 15 Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 1
Page 1 of 2 ATTACHMENT 15 Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$717,376 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,410 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$644,271 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 (c) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
Page 2 of 2 ATTACHMENT 15 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 1 (December 31, 2024 dollars, thousands)
(c) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2043.
(d) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953," dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on October 26, 2044.
ATTACHMENT 16 Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 2
Page 1 of 2 ATTACHMENT 16 Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$717,376 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,410 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$688,423 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 (c) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
Page 2 of 2 ATTACHMENT 16 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Limerick Generating Station, Unit 2 (December 31, 2024 dollars, thousands)
(c) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2048.
(d) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953," dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on June 22, 2049.
ATTACHMENT 17 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 1
Page 1 of 1 ATTACHMENT 17 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$641,122 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$8,351 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$892,132 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on August 22, 2029.
ATTACHMENT 18 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2 CEG Portion
Page 1 of 1 ATTACHMENT 18 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2, CEG Portion (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$588,249 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$6,848 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$582,304 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Nine Mile Point Nuclear Station, Unit 2 of 82%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on October 31, 2046.
ATTACHMENT 19 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2 LIPA Portion
Page 1 of 1 ATTACHMENT 19 Annual Radiological Decommissioning Funding Assurance Report for Nine Mile Point Nuclear Station, Unit 2, LIPA Portion (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$129,128 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$1,503 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$155,110 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 There are no material changes to the trust fund agreements.
(a) Value is based on the Long Island Power Authority (LIPA) ownership share of Nine Mile Point Nuclear Station, Unit 2 of 18%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The total trust fund amount is $196,241 with a portion allocated to contaminated (radiological) decommissioning and a portion allocated to non-contaminated decommissioning. The amount allocated to contaminated decommissioning is $155,110. These amounts were provided by the Nine Mile Point Nuclear Station, Unit 2 co-owner LIPA. LIPA has no past-due tax payments related to decommissioning trust fund activities as of December 31, 2024. The trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024. CEG has not independently verified or assessed the trust fund amount.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on October 31, 2046.
ATTACHMENT 20 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1
Page 1 of 4 ATTACHMENT 20 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
N/A (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4) and 50.75(f)
$258,751 (a) 3 Site-specific cost amount per 10 CFR 72.30(b)
N/A (g) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$178,707 (b) 5 Schedule of the annual amounts remaining to be collected.
$4,213 (c) 6 Assumptions used regarding rates of escalation for decommissioning costs, earnings on funds, and other factors used in funding projections 3% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
10 2024 annual amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A).
$980 (e) 11 Cumulative amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A).
$18,359 (f)
Reimbursed from the decommissioning trust fund
$13,590 (f)
Not yet reimbursed from the decommissioning trust fund
$4,769 12 Amount of funds accumulated to cover the cost of managing irradiated fuel pursuant to 10 CFR 50.82(a)(8)(vii)(A) as of December 31, 2024.
N/A (g) 13 Projected cost of managing irradiated fuel based on site-specific estimate per 10 CFR 50.82(a)(8)(vii)(B).
N/A (g)
Page 2 of 4 ATTACHMENT 20 (Continued)
Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1 (December 31, 2024 dollars, thousands)
(a) A formula cost amount using the formula in 10 CFR 50.75(c) is not applicable because Peach Bottom, Unit 1, has been shutdown since October 31, 1974, and some decommissioning activities have already occurred on this unit. Furthermore, Peach Bottom, Unit 1, was a High Temperature Gas Cooled Reactor (HTGR), which does not translate to a BWR or PWR as specified in the formula for calculating the formula cost amount, and hence a formula cost amount per 10 CFR 50.75(c) cannot be calculated for Peach Bottom, Unit 1.
In accordance with the regulatory requirements, the site-specific amount is reported per 10 CFR 50.75(b)(4), 50.75(f), 50.82(a)(8)(iii), and 50.82(a)(8)(v)(B) and assumes a DECON scenario as described in the site-specific cost estimate (SSCE) (DECOM-2023-EST-PEA-1, Revision 0, "2023 Decommissioning Cost Estimate Peach Bottom 1 2034 License Termination"). The decommissioning cost estimate has been adjusted consistent with the description of planned decommissioning activities in the Peach Bottom, Unit 1, Decommissioning Plan. The costs have been escalated from the January 2023 dollars reflected in the SSCE to estimated costs as of December 31, 2024.
Decommissioning expenditures prior to the year the SSCE updates were prepared (historical expenditures) are not included in the estimated total cost of decommissioning in the final SSCE reports. Also, the amount reported does not include cash flows from the SSCE for the annual radiological decommissioning costs for 2023 through 2024. CEG considers the SSCE estimated costs for 2023 through 2024 decommissioning activities to be historical expenditures at the time the 2025 decommissioning funding assurance report is generated.
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments related to decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Adjustments to the amount collection was made in the March 31, 2022 filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of $4,213k through 2032.
Page 3 of 4 ATTACHMENT 20 (Continued)
Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1 (December 31, 2024 dollars, thousands)
(d) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953,"
dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(e) The amount spent on decommissioning in 2024 is consistent with the projected 2024 expense of $1,274 (December 31, 2024 thousands of dollars) from the site-specific cost estimate. The delta of $294 (thousands of dollars) can be attributed to less decommissioning work performed in 2024 than what was estimated.
The amount spent on decommissioning in 2024 represents the 2024 charges to the Peach Bottom, Unit 1, project. Prior to reimbursement from the decommissioning trust fund, these charges will be validated to confirm they are legitimate decommissioning expenses. Consequently, the amount reimbursed may differ from the value provided.
(f) Not all historical data is available, and therefore, the cumulative amount spent on decommissioning and the amount reimbursed are estimates based on the best information obtainable at this time.
(g) Peach Bottom, Unit 1, was shut down in October of 1974, with defueling of the core completed by the following June. Starting in 1975, the spent fuel was shipped by truck to Idaho. The final of 44 shipments was completed in February of 1977.
Consequently, no irradiated fuel for Peach Bottom, Unit 1, remains on-site; therefore, 10 CFR 50.82(a)(8)(vii) and 10 CFR 72.30(b) do not apply.
Page 4 of 4 ATTACHMENT 20 (Continued)
Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 1 (December 31, 2024 dollars, thousands)
BOY BOY EOY Radiological Trust Trust Fund First Trust Second Trust Decommissioning Fund Value Half Fund Half Fund Year Cost Value Less Cost**
Contributions Earnings Contributions Value 2025
$1,274
$178,707
$177,433
$2,107
$5,386
$2,107
$187,032 2026
$1,274
$187,032
$185,759
$2,107
$5,636
$2,107
$195,607 2027
$1,274
$195,607
$194,334
$2,107
$5,893
$2,107
$204,440 2028
$4,949
$204,440
$199,491
$2,107
$6,048
$2,107
$209,752 2029
$23,413
$209,752
$186,339
$2,107
$5,653
$2,107
$196,205 2030
$46,888
$196,205
$149,318
$2,107
$4,543
$2,107
$158,073 2031
$46,888
$158,073
$111,186
$2,107
$3,399
$2,107
$118,797 2032
$55,713
$118,797
$63,085
$2,107
$1,956
$2,107
$69,253 2033
$67,361
$69,253
$1,892
$0
$57
$0
$1,949 2034
$9,718
$1,949
($7,769)
$0
$0
$0
($7,769)
Total*
$258,751
- Columns may not add due to rounding
- Annual contributions added to individual years - Earnings of half of contributions are included in current year to estimate payment of contributions throughout the year
ATTACHMENT 21 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 2
Page 1 of 2 ATTACHMENT 21 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$358,688 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$3,540(a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$391,248 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 (d) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (e) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Peach Bottom Atomic Power Station, Unit 2 of 50%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
Page 2 of 2 ATTACHMENT 21 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 2 (December 31, 2024 dollars, thousands)
(d) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2032.
(e) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953,"
dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(f) For purposes of this report, permanent termination of operations (shutdown) is expected on August 8, 2033.
ATTACHMENT 22 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 3
Page 1 of 2 ATTACHMENT 22 Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 3 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$358,688 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$3,540 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$424,103 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 (d) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (e) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Peach Bottom Atomic Power Station, Unit 3 of 50%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2033.
Page 2 of 2 ATTACHMENT 22 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Peach Bottom Atomic Power Station, Unit 3 (December 31, 2024 dollars, thousands)
(e) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953,"
dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(f) For purposes of this report, permanent termination of operations (shutdown) is expected on July 2, 2034.
ATTACHMENT 23 Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 1
Page 1 of 1 ATTACHMENT 23 Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$505,745 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$6,405 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$634,496 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Quad Cities Nuclear Power Station, Unit 1 of 75%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on December 14, 2032.
ATTACHMENT 24 Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 2
Page 1 of 1 ATTACHMENT 24 Annual Radiological Decommissioning Funding Assurance Report for Quad Cities Nuclear Power Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$505,745(a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$6,405 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$719,959 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Quad Cities Nuclear Power Station, Unit 2 of 75%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) For purposes of this report, permanent termination of operations (shutdown) is expected on December 14, 2032.
ATTACHMENT 25 Annual Radiological Decommissioning Funding Assurance Report for R.E. Ginna Nuclear Power Plant
Page 1 of 1 ATTACHMENT 25 Annual Radiological Decommissioning Funding Assurance Report for R.E. Ginna Nuclear Power Plant (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$496,068 2
Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$9,272 (a) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$670,274 (b) 5 Schedule of the annual amounts remaining to be collected.
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (c) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(b) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(c) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(d) For purposes of this report, permanent termination of operations (shutdown) is expected on September 18, 2029.
ATTACHMENT 26 Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 1
Page 1 of 2 ATTACHMENT 26 Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$248,816 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$4,150 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$361,687 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 (d) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (e) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) Value is based on the Constellation Energy Generation, LLC (CEG) ownership share of Salem Generating Station, Unit 1 of 42.59%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2035.
Page 2 of 2 ATTACHMENT 26 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 1 (December 31, 2024 dollars, thousands)
(e) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953,"
dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(f) For purposes of this report, permanent termination of operations (shutdown) is expected on August 13, 2036.
ATTACHMENT 27 Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 2
Page 1 of 2 ATTACHMENT 27 Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 2 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
$248,816 (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4)
N/A 3
Site-specific cost amount per 10 CFR 72.30(b)
$4,150 (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$299,989 (c) 5 Schedule of the annual amounts remaining to be collected.
$0 (d) 6 Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 3% (e) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v).
8 Financial assurance for decommissioning is provided by the external sinking fund method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(ii) and 10 CFR 72.30(e)(3).
9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
(a) All values are based on the Constellation Energy Generation, LLC (CEG) ownership share of Salem Generating Station, Unit 2 of 42.59%.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning only. There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) The funding mechanism being used as the source of revenues for the external sinking funds is a non-bypassable charge approved by the Pennsylvania Public Utilities Commission (PaPUC) authorizing PECO Energy Company to continue to collect decommissioning funds for CEG. Any needed adjustments to the amount collected will be made in the next filing of the Nuclear Decommissioning Cost Adjustment (NDCA) to the PaPUC. This cost adjustment is made every five years pursuant to PaPUC Electric Tariff No. 4. The last adjustment was effective January 1, 2023, and allows for the collection of annual payments from ratepayers of
$0 through 2039.
Page 2 of 2 ATTACHMENT 27 (continued)
Annual Radiological Decommissioning Funding Assurance Report for Salem Generating Station, Unit 2 (December 31, 2024 dollars, thousands)
(e) 10 CFR 50.75(e)(1)(ii) allows licensees to use a rate of return higher than 2% if the applicable rate-setting authority has specifically authorized a higher rate. The PaPUC approved a 3% real rate of return as part of the approval of the restructuring plan for PECO Energy Company (Letter from J. J. McNulty (PaPUC) to B. D. Crowe (PECO Energy Company), "Approval of Restructuring Plan for PECO Energy Company under Section 2806 of the Public Utility Code; Docket No. R-00973953,"
dated May 3, 2001). Accordingly, CEG uses a 3% real rate of return. The 3% is applicable through the decommissioning period as described in RAI #1 response provided in the Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Response to Request for Additional Information Related to 2013 Report on Status of Decommissioning Funding for Reactors," dated August 15, 2013.
(f) For purposes of this report, permanent termination of operations (shutdown) is expected on April 18, 2040.
ATTACHMENT 28 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1
Page 1 of 6 ATTACHMENT 28 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
N/A (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4) and 50.75(f)
$892,176 (a) 3 Site-specific cost amount per 10 CFR 72.30(b)
$8,431 (b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$633,083 (c) 5 Schedule of the annual amounts remaining to be collected
$0 6
Assumptions used regarding rates of escalation, earnings, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v) 8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) 9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
10 2024 annual amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$9,789(e) 11 Cumulative amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$197,352 Reimbursed from the decommissioning trust fund
$196,892 Not yet reimbursed from the decommissioning trust fund
$459 12 Amount of funds accumulated to cover the cost of managing irradiated fuel pursuant to 10 CFR 50.82(a)(8)(vii)(A) as of December 31, 2024 (c) 13 Projected cost of managing irradiated fuel based on site-specific estimate per 10 CFR 50.82(a)(8)(vii)(B)
$93,489 (a) 14 2024 annual amount spent on irradiated fuel management
$1,712 (e) 15 Cumulative amount spent on irradiated fuel management
$115,238 Reimbursed
$112,343 (f)
Not yet reimbursed
$2,896
Page 2 of 6 ATTACHMENT 28 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands) 16 Projected cost of Site restoration based on site-specific estimate per 10 CFR 50.82(a)(8)(vii)(B)
$115,252 17 2024 annual amount spent on site restoration
$0 (e) 18 Cumulative amount spent on site restoration
$100 Reimbursed
$100 Not yet reimbursed
$0
Page 3 of 6 ATTACHMENT 28 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands)
(a) A formula cost amount using the formula in 10 CFR 50.75(c) is not applicable because Three Mile Island, Unit 1, has been shutdown since September 2019, and some decommissioning activities have already occurred on this unit. However, the amount to decommission Three Mile Island, Unit 1, was calculated pursuant to 10 CFR 50.75(c) to be $534.3 million (as of December 31, 2024). The calculation of this value assumes the labor, energy, and burial factors described in Attachment 1 and does not account for decommissioning activities that have occurred for Three Mile Island, Unit 1.
In accordance with the regulatory requirements, the site-specific amount is reported per 10 CFR 50.75(b)(4), 50.75(f), 50.82(a)(8)(iii), and 50.82(a)(8)(v)(B) and assumes a SAFSTOR scenario as described in the site-specific cost estimate (SSCE) ("Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1," March 21, 2023 (ML23080A210)). The costs have been escalated from the June 2022 dollars reflected in the decommissioning cost estimate to estimated costs as of December 31, 2024.
The amount reported does not include cash flows from the SSCE estimate for the 2022 - 2024 annual radiological and spent fuel costs because CEG considers the SSCE estimated cost for 2022 - 2024 decommissioning activities to be historical expenditures at the time the 2025 decommissioning funding assurance report is generated.
This site specific estimate assumes the site remains shutdown in accordance with the current license. Starting in 2025, the site does not anticipate any radiological decommissioning or site restoration expenses based on the current plan to restart TMI Unit 1, until needed to support the licensed shutdown date of 2034.
(b) The costs from the current detailed site-specific ISFSI decommissioning cost estimate have been escalated to December 31, 2024 dollars using published escalation indices. Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for Radiological Decommissioning, Spent Fuel Management and Site Restoration. The Spent Fuel Management exemption allowing use of the trust fund for Spent Fuel Management was approved on October 16, 2019 (letter from U.S. Nuclear Regulatory Commission (J. Poole) to Exelon Generation Company, LLC (B. Hanson), Three Mile Island Nuclear Station, Unit 1 - Exemption from the Requirements of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (EPID L-2019-LLE-0009), ML192549A179. The Site Restoration exemption allowing use of the trust fund for Site restoration was approved on June 8,
Page 4 of 6 ATTACHMENT 28 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands) 2022 (letter from U.S. Nuclear Regulatory Commission (Amy M. Snyder) to Constellation Energy Generation, LLC (David P. Rhoades), Three Mile Island Nuclear Station, Unit 1 - Exemption from the Requirements of 10 CFR 50.82(a)(8)(i)(A) AND 10 CFR 50.75(h)(1)(iv) (EPID: L2021LLE0030), ML21140A311.
There are no past-due tax payments related to decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursements from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) The amount spent on decommissioning in 2024 is consistent with the projected 2024 expense of $6,830 (December 31, 2024 thousands of dollars) from the site-specific cost estimate. The increase of $2,959 can be attributed to a delay in the decommissioning schedule shifting costs.
The amount spent on irradiated fuel management in 2024 is consistent with the projected 2024 expense total of $4,323 (December 31, 2024 thousands of dollars) from the site-specific cost estimate (SSCE). The decrease of $2,611 can be attributed to variance in labor distribution between Radiological Decommissioning and Spent Fuel management due to a delay in the decommissioning schedule.
The amount spent on site restoration in 2024 is consistent with the projected 2024 expense 2024 total of $0 (December 31, 2024 thousands of dollars) from the site-specific cost estimate (SSCE).
The amount spent on radiological decommissioning and irradiated fuel management in 2024 represents the 2024 charges to the TMI, Unit 1, project. Prior to reimbursement from the decommissioning trust fund, these charges will be validated to confirm they are legitimate decommissioning expenses. Consequently, the amount reimbursed may differ from the value provided.
(f) The amount of irradiated fuel management reimbursed is the total amount reimbursed from the decommissioning trust fund and the Department of Energy.
Page 5 of 6 ATTACHMENT 28 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands)
Radiological BOY BOY EOY Decommissioning Trust Trust Fund Trust Trust Spent Fuel, & Site Fund Value Fund Fund Year Restoration Cost Value Less Cost Earnings Value 2025
$10,998
$633,083
$622,085
$12,442
$634,527 2026
$11,000
$634,527
$623,527
$12,471
$635,998 2027
$11,003
$635,998
$624,995
$12,500
$637,495 2028
$11,784
$637,495
$625,711
$12,514
$638,225 2029
$11,752
$638,225
$626,473
$12,529
$639,002 2030
$11,752
$639,002
$627,250
$12,545
$639,795 2031
$11,752
$639,795
$628,043
$12,561
$640,604 2032
$11,784
$640,604
$628,820
$12,576
$641,396 2033
$11,752
$641,396
$629,644
$12,593
$642,237 2034
$11,752
$642,237
$630,485
$12,610
$643,095 2035
$11,752
$643,095
$631,343
$12,627
$643,970 2036
$11,784
$643,970
$632,186
$12,644
$644,829 2037
$11,752
$644,829
$633,077
$12,662
$645,739 2038
$11,752
$645,739
$633,987
$12,680
$646,667 2039
$11,752
$646,667
$634,915
$12,698
$647,613 2040
$15,577
$647,613
$632,036
$12,641
$644,677 2041
$23,094
$644,677
$621,583
$12,432
$634,015 2042
$7,354
$634,015
$626,660
$12,533
$639,193 2043
$7,354
$639,193
$631,839
$12,637
$644,476 2044
$7,375
$644,476
$637,101
$12,742
$649,843 2045
$7,354
$649,843
$642,489
$12,850
$655,339 2046
$7,354
$655,339
$647,984
$12,960
$660,944 2047
$7,354
$660,944
$653,590
$13,072
$666,661 2048
$7,375
$666,661
$659,287
$13,186
$672,473 2049
$7,354
$672,473
$665,118
$13,302
$678,420 2050
$7,354
$678,420
$671,066
$13,421
$684,487 2051
$7,354
$684,487
$677,133
$13,543
$690,676 2052
$7,375
$690,676
$683,301
$13,666
$696,967 2053
$7,354
$696,967
$689,613
$13,792
$703,405 2054
$7,354
$703,405
$696,051
$13,921
$709,972
Page 6 of 6 ATTACHMENT 28 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Three Mile Island Nuclear Station, Unit 1 (December 31, 2024 dollars, thousands)
Radiological BOY BOY EOY Decommissioning Trust Trust Fund Trust Trust Spent Fuel, & Site Fund Value Fund Fund Year Restoration Cost Value Less Cost Earnings Value 2055
$7,354
$709,972
$702,617
$14,052
$716,670 2056
$7,375
$716,670
$709,295
$14,186
$723,481 2057
$7,354
$723,481
$716,126
$14,323
$730,449 2058
$7,354
$730,449
$723,095
$14,462
$737,556 2059
$7,354
$737,556
$730,202
$14,604
$744,806 2060
$7,375
$744,806
$737,432
$14,749
$752,180 2061
$7,354
$752,180
$744,826
$14,897
$759,722 2062
$7,354
$759,722
$752,368
$15,047
$767,415 2063
$7,354
$767,415
$760,061
$15,201
$775,262 2064
$7,375
$775,262
$767,888
$15,358
$783,245 2065
$7,354
$783,245
$775,891
$15,518
$791,409 2066
$7,354
$791,409
$784,054
$15,681
$799,735 2067
$7,354
$799,735
$792,381
$15,848
$808,229 2068
$7,375
$808,229
$800,854
$16,017
$816,871 2069
$7,354
$816,871
$809,517
$16,190
$825,707 2070
$7,354
$825,707
$818,353
$16,367
$834,720 2071
$7,354
$834,720
$827,365
$16,547
$843,913 2072
$7,375
$843,913
$836,538
$16,731
$853,269 2073
$29,308
$853,269
$823,961
$16,479
$840,440 2074
$81,882
$840,440
$758,558
$15,171
$773,729 2075
$108,058
$773,729
$665,671
$13,313
$678,985 2076
$108,354
$678,985
$570,631
$11,413
$582,043 2077
$103,179
$582,043
$478,865
$9,577
$488,442 2078
$103,606
$488,442
$384,836
$7,697
$392,533 2079
$39,272
$392,533
$353,260
$7,065
$360,326 2080
$53,685
$360,326
$306,641
$6,133
$312,774 2081
$41,066
$312,774
$271,707
$5,434
$277,142 Total*
$1,109,349
- Column may not add due to rounding
ATTACHMENT 29 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Zion Nuclear Power Station
Page 1 of 2 ATTACHMENT 29 Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Zion Nuclear Power Station (December 31, 2024 dollars, thousands) 1 Formula cost amount per 10 CFR 50.75(c)
N/A (a) 2 Site-specific cost amount per 10 CFR 50.75(b)(4) and 50.75(f)
$12,156 (a) 3 Site-specific cost amount per 10 CFR 72.30(b)
N/A (a)(b) 4 The amount of decommissioning trust funds accumulated as of December 31, 2024
$13,381 (c) 5 Schedule of the annual amounts remaining to be collected
$0 6
Assumptions used regarding rates of escalation for decommissioning costs, earnings on funds, and other factors used in funding projections 2% (d) 7 There are no contracts relied upon pursuant to 10 CFR 50.75(e)(1)(v) 8 Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) 9 The trust fund Master Terms for trust agreements was amended effective March 1, 2024, to reflect a change in responsibility for preparing and filing required trust fund tax returns from the Trustee to the Owner of the trust.
10 2024 annual amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$0 (e) 11 Cumulative amount spent on decommissioning in accordance with 10 CFR 50.82(a)(8)(v)(A)
$0 (e)
Reimbursed from the decommissioning trust fund
$0 (e)
Not yet reimbursed from the decommissioning trust fund
$0 (e) 12 Amount of funds accumulated to cover the cost of managing irradiated fuel pursuant to 10 CFR 50.82(a)(8)(vii)(A) as of December 31, 2024
$49,383 (f) 13 Projected cost of managing irradiated fuel based on site-specific estimate per 10 CFR 50.82(a)(8)(vii)(B)
$169,133 (g)
Page 2 of 2 ATTACHMENT 29 (continued)
Annual Radiological Decommissioning Funding Assurance and Spent Fuel Management Report for Zion Nuclear Power Station (December 31, 2024 dollars, thousands)
(a) A formula cost amount using the formula in 10 CFR 50.75(c) is not applicable because the Zion Units, have been shut down since February 13, 1998, and the Zion licenses have been amended, releasing most of the formerly licensed land for unrestricted use, shrinking the licensed land to that utilized to support the Independent Spent Fuel Storage Installation (ISFSI). Thus, the only decommissioning activities and decommissioning funding requirements that remain are those associated with the decommissioning of the Zion ISFSI, which is currently scheduled to occur after the Department of Energy (DOE) removes the irradiated fuel and Greater than Class C (GTCC) waste. In accordance with the regulatory requirements, the site-specific amount is reported per 10 CFR 50.75(b)(4), 50.75(f),
50.82(a)(8)(iii), 50.82(a)(8)(v)(B), and 72.30(b) and assumes a Spent Fuel scenario as described in the site-specific cost estimate (SSCE).
(b) Attachment 31 provides information on the detailed decommissioning funding plan, detailed site-specific ISFSI decommissioning cost estimate, and the occurrence and the effect on the ISFSI decommissioning costs of the events listed in 10 CFR 72.30 (c)(1)-(4).
(c) The trust fund amount is the amount allocated for radiological decommissioning only.
The allocation of funds for radiological decommissioning is based on Spent Fuel scenario as described in the site-specific cost estimate (SSCE).
There are no past-due tax payments owed on the decommissioning trust fund activities as of December 31, 2024. Periodic payments of estimated income taxes are made by CEG during the year on a quarterly basis. CEG then obtains reimbursement from the trust funds. The reported trust fund amounts comply with the reporting requirements of 10 CFR 50.75(f) in that the amount of funds reported are those that were accumulated as of December 31, 2024.
(d) A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i).
(e) The only decommissioning activities that remain are those associated with the decommissioning of the Zion ISFSI, which is currently scheduled to occur after the DOE removes the irradiated fuel and GTCC waste. The cumulative cost spent on decommissioning the Zion ISFSI is $0, and the amount spent in calendar year 2024 is $0.
(f) The allocation of funds accumulated for managing irradiated fuel is based on the Spent Fuel scenario as described in the site-specific cost estimate (SSCE).
(g) Current projected cost estimate for management of irradiated fuel. Zion is anticipating that some of the cost will be recovered from DOE.
ATTACHMENT 30 ISFSI Decommissioning Funding Estimates
Page 1 of 4 ATTACHMENT 30 ISFSI Decommissioning Funding Estimates Dresden Nuclear Power Station (December 31, 2024 dollars, thousands)
Activity Description Removal Costs Packaging Costs Transportation Costs LLRW Disposal Costs Other Costs Total Costs Burial Volume Class A (ft3)
Decommissioning Contractor Decontamination (activated disposition)
$1,315
$283
$766
$2,637
$5,001 74,114 Characterization and Licensing Surveys
$8,058
$8,058 Subtotal
$1,315
$283
$766
$2,637
$8,058
$13,058 74,114 Supporting Costs Utility Staff Cost
$636
$636 Security Staff Cost
$793
$793 Insurance and NRC Fees
$1,196
$1,196 Property Taxes
$798
$798 Plant Energy Budget
$37
$37 Equipment and Supplies
$48
$48 Subtotal
$48
$0
$0
$0
$3,461
$3,509 Total w/o contingency
$1,363
$283
$766
$2,637
$11,519
$16,568 74,114 Total with 25% contingency
$1,704
$354
$958
$3,296
$14,398
$20,710 Note: Values may not add due to rounding.
Costs for ISFSI decommissioning are split as following: Unit 1 - 22%, Unit 2 - 39%, Unit 3 - 39%.
Page 2 of 4 ATTACHMENT 30 (Continued)
ISFSI Decommissioning Funding Estimates Peach Bottom Nuclear Power Station (December 31, 2024 dollars, thousands)
Activity Description Removal Costs Packaging Costs Transportation Costs LLRW Disposal Costs Other Costs Total Costs Burial Volume Class A (ft3)
Decommissioning Contractor Decontamination (activated disposition)
$837
$204
$925
$2,157
$4,123 60,639 Characterization and Licensing Surveys
$4,569
$4,569 Subtotal
$837
$204
$925
$2,157
$4,569
$8,692 60,639 Supporting Costs Utility Staff Cost
$640
$640 Security Staff Cost
$811
$811 Insurance and NRC Fees
$1,024
$1,024 Property Taxes
$80
$80 Plant Energy Budget
$35
$35 Equipment and Supplies
$45
$45 Subtotal
$45
$0
$0
$0
$2,589
$2,634 Total w/o contingency
$881
$204
$925
$2,157
$7,158
$11,326 60,639 Total with 25% contingency
$1,102
$255
$1,156
$2,697
$8,948
$14,158 Note: Values may not add due to rounding.
Costs for ISFSI decommissioning are split as following: Unit 1 - 0% (U1 has no fuel), Unit 2 - 50%, Unit 3 - 50%.
Constellation is responsible for 50.00% of this cost and PSEG is responsible for 50.00% of this cost
Page 3 of 4 ATTACHMENT 30 (Continued)
ISFSI Decommissioning Funding Estimates Limerick Nuclear Power Station (December 31, 2024 dollars, thousands)
Activity Description Removal Costs Packaging Costs Transportation Costs LLRW Disposal Costs Other Costs Total Costs Burial Volume Class A (ft3)
Decommissioning Contractor Decontamination (activated disposition)
$1,042
$245
$899
$2,157
$4,343 60,639 Characterization and Licensing Surveys
$6,203
$6,203 Subtotal
$1,042
$245
$899
$2,157
$6,203
$10,546 60,639 Supporting Costs Utility Staff Cost
$662
$662 Security Staff Cost
$909
$909 Insurance and NRC Fees
$1,130
$1,130 Property Taxes
$120
$120 Plant Energy Budget
$35
$35 Equipment and Supplies
$53
$53 Subtotal
$53
$0
$0
$0
$2,856
$2,909 Total w/o contingency
$1,095
$245
$899
$2,157
$9,059
$13,455 60,639 Total with 25% contingency
$1,369
$306
$1,124
$2,697
$11,324
$16,819 Note: Values may not add due to rounding.
Costs for ISFSI decommissioning are split equally between the units
Page 4 of 4 ATTACHMENT 30 (Continued)
ISFSI Decommissioning Funding Estimates Salem Generating Station (December 31, 2024 dollars, thousands)
Activity Description Removal Costs Packaging Costs Transportation Costs LLRW Disposal Costs Other Costs Total Costs Burial Volume Class A (ft3)
Decommissioning Contractor Planning (Characterization, Specs and
$0
$0
$0
$0
$575
$575 40,657 Decontamination (activated disposition)
$1,028
$750
$3,350
$5,628
$0
$10,756 License Termination (radiological surveys)
$0
$0
$0
$0
$2,897
$2,897 Subtotal
$1,028
$750
$3,350
$5,628
$3,472
$14,228 40,657 Supporting Costs NRC and NRC Contractor Fees
$553
$553 Insurance
$63
$63 Property taxes
$20
$20 Plant energy budget
$11
$11 Barnwell Annual Access Fee
$341
$341 Security Staff Cost
$153
$153 Utility Staff Cost
$221
$221 Subtotal
$0
$0
$0
$0
$1,361
$1,361 Total w/o contingency
$1,028
$750
$3,350
$5,628
$4,833
$15,589 40,657 Total with 25% contingency
$1,285
$937
$4,187
$7,036
$6,042
$19,486 Note: Values may not add due to rounding.
Salem data provided by outside source. Formatting may be different that other Attachment 30 tables. Salem values escalated from original data provided.
Costs for ISFSI decommissioning are split equally between the units. Constellation is responsible for 42.59% of this cost and PSEG is responsible for 57.41% of this cost.
ATTACHMENT 31 Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates
Page 1 of 6 ATTACHMENT 31 Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates Pursuant to 10 CFR 72.30(b), decommissioning funding plans (DFPs) are required for all independent spent fuel storage installations (ISFSls). One piece of the DFP is a detailed ISFSI decommissioning estimate. The detailed cost estimate is periodically revised based on the schedule for refreshing the full decommissioning cost estimate for the site.
In accordance with 10 CFR 72.30(c), "At the time of license renewal and at intervals not to exceed 3 years, the decommissioning funding plan must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination." To update its DFPs, CEG either makes a full update to the DFP, updates the detailed ISFSI decommissioning cost estimate and affirms that the remainder of the DFP has not changed, or escalates the ISFSI decommissioning cost estimate and affirms that the remainder of the DFP has not changed.
Along with each DFP update for each ISFSI, information on the occurrence, and the effect on decommissioning costs, of each of the events listed in 10 CFR 72.30(c)(1)-(4):
(1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate must be included.
The table below specifies the current detailed DFP and current detailed decommissioning cost estimate for each Constellation Energy Generation, LLC (CEG) ISFSI. At the time Reference 10 was issued Zion Solutions still maintained the Zion license. Subsequently, Zion license was transferred to CEG November 2023. The license transfer does not affect any of the information provided in Reference 10 and is therefore, still the current detailed DFP for Zion station. The current detailed DFP is unchanged as of December 31, 2024 for all CEG ISFSIs. For Braidwood, Byron, Calvert Cliffs, Clinton, Ginna, FitzPatrick, LaSalle, Nine Mile Point, Quad Cities, TMI, and Zion the cost estimate is unchanged as of December 31, 2024. The ISFSI decommissioning cost escalated to December 31, 2024 dollars is contained in the attachment to this letter indicated in the table below. For Limerick, Peach Bottom, Dresden, and Salem ISFSIs, a new detailed ISFSI decommissioning cost estimate is provided in Attachment 30 of this letter.
Page 2 of 6 ATTACHMENT 31 (Continued)
Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates ISFSI Facility Current Detailed DFP Current Detailed Cost Estimate Current Dollar Cost Estimate Braidwood Station Reference 1 Reference 9 /3 Byron Station Reference 1 Reference 9 /5 Calvert Cliffs Nuclear Power Plant Reference 2 Reference 9 /7 Clinton Power Station References 3 and 4 Reference 9 Dresden Nuclear Power Station Reference 1 0 /10/11 James A. Fitzpatrick Nuclear Power Station Reference 5 Reference 9 2 LaSalle County Station Reference 1 Reference 9 3/14 Limerick Generating Station Reference 1 0 5/16 Nine Mile Point Nuclear Station Reference 2 Reference 9 7/18/19 Peach Bottom Atomic Power Station Reference 1 0 0/21/22 Quad Cities Nuclear Power Station Reference 1 Reference 9 3/24 R.E. Ginna Nuclear Power Plant Reference 2 Reference 9 5 Salem Generating Station Reference 1 0 6/27 Three Mile Island Nuclear Station, Unit 1 Reference 8 Reference 9 8 Zion Station Reference 10 Reference 10 9
Page 3 of 6 ATTACHMENT 31 (Continued)
Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates The effect of each of the events listed in 10 CFR 72.30(c)(1) through (4) on the detailed cost estimates provided in Reference 9 for the ISFSIs at Braidwood, Byron, Calvert Cliffs, Clinton, Ginna, FitzPatrick, LaSalle, Nine Mile Point, Quad Cities and TMI is listed below.
For these ISFSIs, the most recent DFP update prior to the one contained herein is contained in Reference 9. Reference 9 provides the effect of the events listed in 10 CFR 72.30(c)(1) through (4) as of December 31, 2022. Consequently, the effect of the events from December 31, 2022 through December 31, 2024 is provided below.
(1)
Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material in 2023 or 2024 at any of the ISFSls at the facilities listed above.
(2)
Facility modifications:
No impact. There have not been any modifications to the ISFSls at the facilities listed above in 2023 or 2024 that would materially change the latest decommissioning cost estimate.
The ISFSI facility design at the time the cost estimate was prepared was incorporated in the estimate for the facilities listed above. Also, any ISFSI modifications (i.e., ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the cost estimate.
(3)
Changes in authorized possession limits:
No impact. There have not been any changes in authorized possession limits at the ISFSls at the facilities listed above during 2023 or 2024 that would materially change the decommissioning cost estimate.
The capacity of the cask used at the ISFSI at the time the cost estimate was performed was incorporated in the estimate for the facilities listed above.
(4)
Actual remediation costs that exceed the previous cost estimate:
No impact. As of December 31, 2024, decommissioning had not begun at any of the ISFSls listed above. Consequently, there have been no actual remediation costs that exceed the latest cost estimate.
Page 4 of 6 ATTACHMENT 31 (Continued)
Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates In Attachment 30 of this letter, decommissioning cost estimates are provided for the ISFSls at Limerick, Peach Bottom, Dresden, and Salem. The detailed cost estimates for Limerick, Peach Bottom, and Dresden were prepared in 2023. The detailed cost estimate for Salem was prepared in 2024. Each of the items listed in 10 CFR 72.30(c)(1) through (4) was considered in preparation of the updated cost estimate. Additionally, the effect of the items in 10 CFR72.30(c) from cost estimate completion to December 31, 2024, were reviewed. A discussion of each item is included below.
(1)
Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
No impact. There were no spills of radioactive material producing additional residual radioactivity in onsite subsurface material at any of the ISFSls at the facilities listed above through December 31, 2024.
(2)
Facility modifications:
No impact. Although there was an expansion to the Dresden ISFSI pad this was already accounted for in the latest detailed cost estimate. There have not been any other modifications to the ISFSls at the facilities listed above during 2023 and 2024 that would materially change the latest decommissioning cost estimate.
The ISFSI facility design at the time the updated cost estimate was prepared was incorporated in the estimate for the facilities listed above.
Also, any ISFSI modifications (i.e., ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the updated cost estimate.
(3)
Changes in authorized possession limits:
No impact. There have not been any changes in authorized possession limits at the ISFSls at the facilities listed above during 2023 through 2024 that would materially change the latest decommissioning cost estimate.
The capacity of the cask used at the ISFSI at the time the updated cost estimate was performed was incorporated in the estimate for the facilities listed above. In anticipation of a change in cask size at Dresden, a larger cask size was incorporated in the updated estimate for this ISFSI. The cask size did not change in the updated estimate relative to the previous estimate for the other ISFSIs.
(4)
Actual remediation costs that exceed the previous cost estimate:
No impact. As of December 31, 2024, decommissioning had not begun at any of the ISFSls listed above. Consequently, there have been no actual remediation costs that exceed the costs included in the latest cost estimate.
Page 5 of 6 ATTACHMENT 31 (Continued)
Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates The effect of each of the events listed in 10 CFR 72.30(c)(1) through (4) on the detailed cost estimates provided in Reference 10 for the ISFSI at Zion is listed below. For this ISFSI, the most recent DFP update prior to the one contained herein is contained in Reference 10. Reference 10 provides the effect of the events listed in 10 CFR 72.30(c)(1) through (4) as of August 31, 2022. Consequently, the effect of the events from August 31, 2022, through December 31, 2024, is provided below.
(1)
Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material in 2022, 2023, or 2024 at the ISFSl of the facility listed above.
(2)
Facility modifications:
No impact. There have not been any modifications to the ISFSl at the facility listed above in 2022, 2023, or 2024 that would materially change the latest decommissioning cost estimate.
The ISFSI facility design at the time the cost estimate was prepared was incorporated in the estimate for the facility listed above.
(3)
Changes in authorized possession limits:
No impact. There have not been any changes in authorized possession limits at the ISFSl at the facility listed above during 2022, 2023 or 2024 that would materially change the decommissioning cost estimate.
The capacity of the cask used at the ISFSI at the time the cost estimate was performed was incorporated in the estimate for the facilities listed above.
(4)
Actual remediation costs that exceed the previous cost estimate:
No impact. Decommissioning had not begun at the ISFSl listed above. Consequently, there have been no actual remediation costs that exceed the latest cost estimate.
Page 6 of 6 ATTACHMENT 31 (Continued)
Independent Spent Fuel Storage Installation Decommissioning Funding Plan Updates References
- 1. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plans for Braidwood, Byron, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Quad Cities, and Salem," dated December 17, 2012
- 2. Letter from Stephen A. Mormann (Constellation Energy Nuclear Group, LLC) to U.S. Nuclear Regulatory Commission, "ISFSI Decommissioning Funding Plans,"
dated December 17, 2012
- 3. Letter from David M. Gullett (CEG) to U.S. Nuclear Regulatory Commission, "Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plans for Clinton Power Station," dated September 6, 2016
- 4. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated March 30, 2017
- 5. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Report on the Status of Decommissioning Funding for James A. Fitzpatrick Nuclear Power Plant Independent Spent Fuel Storage Installation," dated December 10, 2018
- 6. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (ISFSIs)," dated May 2, 2018
- 7. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installation," dated February 24, 2021
- 8. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Proposed Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plans for Three Mile Island, Unit 1 dated July 15, 2021
- 9. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations dated March 23, 2023
- 10. Letter from Patrick R. Simpson (CEG) to U.S. Nuclear Regulatory Commission, "Updated ISFSI Decommissioning Funding Plan for Zion Nuclear Power Station dated October 26, 2022