ML25329A107

Safety Evaluation for Review of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan

ML25329A107
Person / Time
Site:	Dresden
Issue date:	11/28/2025
From:	Shilpa Arora Plant Licensing Branch III
To:	Mudrick C Constellation Energy Generation, Constellation Nuclear
Arora, S
References
EPID L-2024-LLL-0025
Download: ML25329A107 (0)

Text

November 28, 2025 Mr. Christopher H. Mudrick Sr.

Senior Vice President and Chief Nuclear Officer Constellation Energy Generation, LLC President Constellation Nuclear 200 Energy Way Kennett Square, PA 19348

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNIT 2 - SAFETY EVALUATION FOR REVIEW OF PRELIMINARY DECOMMISSIONING COST ESTIMATE AND IRRADIATED FUEL MANAGEMENT PLAN (EPID L-2024-LLL-0025)

Dear Mr. Mudrick:

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of Constellation Energy Generation, LLCs (CEG or the licensee) letter dated December 18, 2024 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML24353A260). In this letter, CEG submitted its preliminary decommissioning cost estimate (DCE) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.75(f)(3) and the irradiated fuel management plan (IFMP) in accordance with Section 50.54(bb) for its Dresden Nuclear Power Station (DNPS), Unit 2.

The NRC staff finds that CEGs costs for the long-term storage of the irradiated fuel and the preliminary cost estimate for radiological decommissioning of DNPS, Unit 2, are reasonable and provide sufficient details associated with the funding mechanisms. Therefore, the NRC staff concludes that the DNPS IFMP complies with 10 CFR 50.54(bb) and approves the costs on a preliminary basis. In addition, the NRC staff finds that the preliminary DCE for DNPS, Unit 2, complies with the requirements of 10 CFR 50.75(f)(3). The NRC staffs detailed technical review is provided in the enclosed safety valuation.

If you have any questions, please contact me at 301-415-1421 or Surinder.Arora@nrc.gov.

Sincerely,

/RA Scott P. Wall for/

Surinder S. Arora, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-237

Enclosure:

Safety Evaluation cc: Listserv

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE PRELIMINARY DECOMMISSIONING COST ESTIMATE AND IRRADIATED FUEL MANAGEMENT PLAN CONSTELLATION ENERGY GENERATION, LLC DRESDEN NUCLEAR POWER STATION, UNIT 2 DOCKET NO. 50-237

1.0 INTRODUCTION

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(bb), nuclear power plants that are within 5 years of expiration of their operating license must submit an irradiated fuel management and funding program to the U.S. Nuclear Regulatory Commission (NRC) for review and preliminary approval. The program should discuss the means by which the licensee intends to manage and provide funding for the management of spent fuel until the fuel is transferred to the U.S. Department of Energy (DOE) for permanent disposal. In the same time period, the licensee is also required by 10 CFR 50.75(f)(3) to submit a preliminary decommissioning cost estimate (DCE), which includes an up-to-date assessment of the major factors that could affect the cost to decommission the reactor.

By letter dated December 18, 2024 (Agencywide Documents Access and Management System Accession No. ML24353A260), Constellation Energy Generation, LLC (CEG or the licensee) submitted a preliminary DCE and irradiated fuel management plan (IFMP) for its Dresden Nuclear Power Station (DNPS), Unit 2 (DRE-2), in accordance with 10 CFR 50.75(f)(3) and 10 CFR 50.54(bb), respectively.

2.0 BACKGROUND

DNPS consists of one retired reactor and two operating boiling water reactors owned and operated by CEG. DRE-2 is one of the operating units and is licensed to generate 2957 megawatts thermal. The plant is located in Northern Illinois, approximately 23 miles southwest of Joliet, Illinois, at the confluence of the Des Plaines and Kankakee Rivers where they form the Illinois River.

CEG estimated the total decommissioning cost for DRE-2 to be approximately $1.2 billion (in 2023 dollars), including $923.7 million for license termination expenditures, $220.8 million for spent fuel management expenditures, and $57.4 million for the site restoration expenditures.

CEGs submittal also includes a decommissioning cash flow analysis (Attachment 3) and a decommissioning and spent fuel management cash flow analysis (Attachment 4) based on the preliminary DCE.

3.0 REGULATORY REQUIREMENTS Regulatory Requirements on Management of Spent Fuel The regulation under 10 CFR 50.54(bb) states, in part:

For nuclear power reactors licensed by the NRC, the licensee shall, within 2 years following permanent cessation of operation of the reactor or 5 years before expiration of the reactor operating license, whichever occurs first, submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository.

Regulatory Requirements on the Preliminary Decommissioning Cost Estimate The Regulation in 10 CFR 50.75(f)(3) requires that a licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission.

The Regulation in 10 CFR 50.75(f)(5) requires, if necessary, a licensee to include plans, with the preliminary cost estimate, to adjust decommissioning funding levels to demonstrate a reasonable level of assurance that funds will be available when needed to cover the cost of decommissioning.

The Regulation in 10 CFR 50.75(c)(1) provides a table of minimum amounts (in 1986 dollars, the base year) required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level.

Guidance The guidance in NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors, dated December 2004 (ML043510113), provides that the NRC staff should compare the preliminary cost estimate to the minimum decommissioning funding amount based on the formulas in 10 CFR 50.75(c), and perform an assessment of the major factors that could affect the preliminary cost estimate.

NUREG-1713, section C.1, provides additional guidance on the information that is to be addressed in the preliminary cost estimate. The major factors to be addressed are:

Decommissioning option/method anticipated; Potential for known or suspected contamination of the facility or site; Low-level radioactive waste (LLW) disposition plan; Preliminary schedule of decommissioning activities; and Any other factors that could significantly affect the cost to decommission.

The cost estimate should provide costs for each of the following, or similar, major decommissioning phases:

Pre-decommissioning engineering and planning - decommissioning engineering and planning prior to completion of reactor defueling; Reactor deactivation - deactivation and radiological decontamination of plant systems to place the reactor into a safe, permanent shutdown condition; Safe storage - safe storage monitoring of the facility until dismantlement begins (if storage or monitoring of spent fuel is included in the cost estimate, it should be shown separately);

Dismantlement - radiological decontamination and dismantlement of systems and structures required for license termination (if demolition of uncontaminated structures and site restoration activities are included in the cost estimate, they should be shown separately); and LLW disposition - LLW packaging, transportation, vendor processing, and disposal.

NUREG-1307, Revision 19, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities - Final Report (ML23044A207) provides guidance on how the licensees are to calculate the NRC minimum decommissioning formula fund amount and is the appropriate source for obtaining the adjustment factor for waste burial/disposition costs. Consistent with NUREG-1713, the preliminary DCE is compared to the NRC minimum decommissioning formula fund amount to determine whether the preliminary DCE is greater than or equal to the NRC minimum decommissioning formula fund amount.

4.0 TECHNICAL EVALUATION

4.1 Irradiated fuel management plan Review The IFMP was reviewed according to 10 CFR 50.54(bb) and the following factors were considered in the IFMP and preliminary DCE:

1.

Estimated cost to isolate the spent fuel pool and fuel handling systems (Pages 12 and 19 of the preliminary DCE),

2.

Estimated cost to maintain and expand an Independent Spent Fuel Storage Installation (ISFSI) (Pages 12 and 19 of the preliminary DCE, and Pages 1 - 2 of the IFMP),

3.

Estimated annual cost for the operation of the SAFSTOR option until the DOE takes possession of the fuel (Pages 12 and 19 of the preliminary DCE, table 6-2 of the preliminary DCE, and pages 1 - 2 of the IFMP),

4.

Estimated cost for the preparation, packaging, and shipping of the fuel to the DOE (Pages 12 and 19 of the preliminary DCE and pages 1 - 2 of the IFMP),

5.

Estimated cost to decommission the spent fuel storage facility (Pages 2 and 19 of the preliminary DCE),

6.

Brief discussion of the selected storage method or methods and the estimated time for these activities (Page 1 of the IFMP), and

7.

Information identifying the source of funds for managing spent fuel (Page 2 of the cover letter).

As stated by CEG, [t]he estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the Independent Spent Fuel Storage Installation (ISFSI) and to decommission the ISFSI (Page 2 of the IFMP). CEG assumes the spent fuel will be packaged into multi-purpose containers (MPCs) over the first 5 years after shutdown. It is assumed that this period provides the necessary cooling for the spent fuel from the final core to meet the transport and/or storage requirements for decay heat. The estimate includes the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel containers from the ISFSI onto the transport vehicle (Page 12 of the preliminary DCE). CEG further states that,

[p]ending transfer of the fuel to the DOE [Secretary of Energy], CEG will store fuel on an interim basis in the spent fuel pool and/or the ISFSI located at the DNPS site (Page 1 of the IFMP).

Regarding the ISFSI, CEG states that [t]he ISFSI facility will be expanded to accommodate the inventory of spent fuel in the spent fuel pool following the final reactor defueling. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. Once the spent fuel pool is emptied of fuel, the facility will be placed in a SAFSTOR condition. The ISFSI will continue to operate until the transfer of spent fuel to the DOE is complete (Page 1 of the IFMP). CEG adds that [a]ssuming the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2035 with an annual capacity of 3,000 metric tons of uranium, spent fuel is projected to remain at the DNPS site for approximately 21 years after the termination of operation (i.e., spent fuel is projected to be removed from the DNPS site by the end of 2050). Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will correspondingly prolong the transfer process and result in spent fuel remaining at the site longer than anticipated (Page 1 of the IFMP).

CEG states that [w]hen DNPS Unit 2 ceases operations in 2029, DNPS Unit 2 will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the DNPS Unit 2 spent fuel pool and ISFSI, as necessary, under the decommissioning scenario ultimately selected (Page 2 of the IFMP).

CEG acknowledges that an exemption from 10 CFR 50.82(a)(8)(i)(A) is required to use decommissioning trust funds for expenses other than decommissioning activities as the term "decommission" is defined in 10 CFR 50.2 (Page 2 of the cover letter). CEG further states that

[t]o the extent that the trust fund balance exceeds costs required for radiological decommissioning, trust fund monies, subject to receipt of NRC approval of an exemption as discussed in Section 4, in conjunction with CEG operating revenues, will be used to pay for spent fuel management costs (Page 2 of the IFMP). As demonstrated in Attachment 4, CEG should have sufficient funds in their decommissioning trust fund to cover both costs of decommissioning activities and spent fuel management.

The cost estimate for the IFMP and related activities at DRE-2 in the amount of $220.8 million (in 2023 dollars) were evaluated for reasonableness. In a study, Blue Ribbon Commission on Americas Nuclear Future (Blue Ribbon Commission report), dated January 2012, provided to the DOE cost and cost considerations for the operation and maintenance of spent fuel storage at shutdown sites. Costs cited in this report range from $4.5 million to $8 million per year (in 2012 dollars) for spent fuel management at shutdown sites. These costs adjusted for inflation (in 2023 dollars) are $6.1 million to $10.8 million per year, respectively. Accounting for inflation and considering the IFMP operational period (21 years) with the DRE-2 site-specific costs, the cost estimate provided by CEG, on the average (approximately $10.5 million per year), is within the range of costs cited in the study. In addition, a comparison was made with other licensees IFMP cost estimates previously reviewed by the NRC staff.1 Based on the foregoing, CEGs

$220.8 million cost estimate for spent fuel management at DRE-2 is reasonable.

CEG intends to pay for costs related to spent fuel management using any remaining funds in the decommissioning trust fund, pending NRC approval of an exemption, and CEG operating revenue. Attachment 4 shows that there will always be sufficient funds in the decommissioning trust fund to cover both costs of decommissioning and spent fuel management, and the cash flow analysis presented in the attachment has been checked for accuracy. CEG also states that

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

4.2 Preliminary Decommissioning Cost Estimate Evaluation The preliminary DCE was evaluated according to 10 CFR 50.75, 10 CFR 50.82, and NUREG-1713. The preliminary DCE properly incorporates the following specific attributes:

Presents costs in 2023 dollars, and properly inflates costs from 2023 dollars to 2024 dollars for the cash flow analyses contained in Attachments 3 and 4, Includes contingency factors for major activities, ranging from 10 to 75 percent, States that cost estimates and financial levels will be adjusted in accordance with Regulatory Guidance 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," and Provides a site-specific cost estimate that is greater than the minimum formula cost amount using the formula in 10 CFR 50.75(c).2 The preliminary DCE addressed the five major factors identified in NUREG-1713, section 1.4.2:

1. Decommissioning option/method anticipated:

The submission states that CEG has not made a final determination of the decommissioning approach for DNPS, Unit 2. For purposes of this submittal, the SAFSTOR option has been selected. CEG reserves the right to choose an alternative decommissioning option at the actual time of decommissioning in accordance with its business needs, recognizing the need to assure the chosen option meets NRC 1 Comparison was done for preliminary DCEs submitted by CEG and Energy Harbor Nuclear Generation Corp. for Clinton Power Station, Unit 1 (ML22108A263), and Perry Nuclear Power Plant, Unit No. 1 (ML23090A233), respectively, which have average spent fuel management costs of approximately $12.3 million and $11.2 million, respectively.

2 The minimum required cost (approximately $670 million) is based on the following inputs: P = 2,957; LX

= 3.297 (Q3 2023 ECI = 158.5); Ex = 3.203 (Px = 295.404, Fx = 321.916 (December 2023)); Bx = 11.658 (2024). These values were retrieved and calculated using data from the U.S. Bureau of Labor Statistics and NUREG-1307, Rev.20, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities Final Report.

requirements for decommissioning funding (Page 1 of the cover letter).

2. Potential for known or suspected contamination of the facility or site:

The submission states that soil and groundwater remediation costs are included in the cost estimate. The required soil remediation is based on evaluation of 10 CFR 50.75(g)(1) reports (Page 2 of the cover letter). Additionally, the preliminary DCE references a report previously submitted by CEG, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ( ML23082A312), which states on Page 4 of Attachment 30, [t]here 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, 2022.

3. Low-level radioactive waste (LLW) disposition plan:

In section 4.5.1, Low-Level Radioactive Waste Disposal, the preliminary DCE states that

[a] significant portion of the waste material may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. The estimates reflect the savings from waste recovery/volume reduction when feasible. Additionally, the preliminary DCE states that [a]ll options and services currently available were taken into consideration regarding the disposition of the various waste streams produced by the decommissioning process. Disposal fees are calculated using representative costs. The preliminary DCE further states that [c]lass A processed and oil waste are assumed to be disposed of at a facility in Tennessee. All other Class A waste is assumed to be disposed of at a facility in Utah. Class B and C waste is assumed to be disposed of at a facility in Texas (Page 10 of the preliminary DCE). Additionally, table 4-1 of the preliminary DCE provides a breakdown of waste volumes by regulatory disposal classification (Page 15 of the preliminary DCE).

4. Preliminary schedule of decommissioning activities:

Table 5-1 of the preliminary DCE provides a project schedule for the SAFSTOR decommissioning scenario (Page 17 of the preliminary DCE), which includes the following six phases:

Pre-Shutdown (2 years)

Preparations for Dormancy (7.2 years)

Dormancy (45.5 years)

Site Reactivation (1 year)

Decommissioning Operations (6.4 years)

Site Restoration (2.5 years)

Section 2.2 of the preliminary DCE provides the following description of the major phases of decommissioning in the SAFSTOR scenario:

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

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

Permanent Defuel through Zirconium Fire Window - This period runs from permanent defuel until the end of the Zirconium fire (Zirc fire) window when the fuel no longer has enough heat to generate Zirc fire conditions in less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. A Decommissioning Organization (DO) is established during this period to meet all security, emergency planning, and fire protection requirements, but also performs activities to deenergize and deactivate plant systems and initiate the pool to pad activities required to move all the spent fuel from the SFP to the ISFSI.

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

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

Site Restoration - Final demolition of any non-radiological structures, site grading and preparation for reuse of the land (Pages 3 - 4 of the preliminary DCE).

5. Any other factors that could significantly affect the decommission cost.

Section 4 of the preliminary DCE provides a discussion of assumptions used in developing the estimate, including assumptions for labor costs, transition activities, non-radioactive and radioactive waste, component removal, spent fuel management, the onsite ISFSI, site restoration, and site conditions following decommissioning, as well as general assumptions (Pages 8 - 13 of the preliminary DCE). The preliminary DCE also includes contingency values for all major activities examined (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal). CEG also assumes that

[t]he ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed and states that [a]ny delay in transfer of fuel to DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer (Page 12 of the preliminary DCE).

CEG states that, since there are multiple units at the DNPS, there can be opportunities to achieve economies of scale by sharing costs between units and coordinating the sequence of work activities The work associated with developing activity specifications and procedures are essentially identical between units 2 and 3, therefore costs associated with additional units are less than the first. CEG further states that [t] here will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitation on when final status surveys can take place. There may also be common systems that reduce the overall site scope and cost. All of these aspects of a multi-unit site are factored into the work planning and associated costs for DRE-2 (Pages 8 - 9 of the preliminary DCE).

Additionally, according to NUREG-1713, section 1.4.2, a licensee should provide costs for five major decommissioning phases. The cost estimate included costs associated with these major decommissioning phases in table 6-3 of the preliminary DCE (Pages 22 - 26 of the preliminary DCE):

1. Pre-decommissioning engineering and planning costs, including utility staff, NRC fees, and contracted engineering analyses.

2. Reactor deactivation costs, including utility staff, security staff, insurance, heavy equipment, health physics supplies, maintenance supplies, spent fuel pool O&M

[Operations and Maintenance] supplies, plant energy, hazardous liquid remediation, NRC fees, emergency planning fees, modifications, process decommissioning water waste, site upkeep, disposal of dry active waste, and severance.

3. Safe storage costs, including utility staff, security staff, insurance, health physics supplies, maintenance supplies, plant energy, NRC fees, process decommissioning water waste, site upkeep, and disposal of dry active waste.

4. Dismantlement costs, including utility staff, security staff, decommissioning operations contractor staff, structure removal, system removal, insurance, reactor pressure vessel, reactor pressure vessel internals, greater than Class C waste disposal, heavy equipment, health physics supplies, maintenance supplies, plant preparation and temporary services, plant energy, hazardous liquid remediation, lead remediation, NRC fees, asbestos, condenser, turbine generator, recirc pumps/reactor coolant pumps, site excavation, scaffolding, process decommissioning water waste, site upkeep, spent fuel rack removal, disposal of dry active waste, decommissioning operations contractor relocation, miscellaneous decommissioning waste, site grading and landscaping, remove rubble/backfill site, radiation surveys, and severance.

5. LLW disposition - LLW packaging, transportation, vendor processing, and disposal is included above under Dismantlement costs. Waste disposal and waste processing are included in table 6-1 of the preliminary DCE (Page 19 of the preliminary DCE).

The estimated total cost of $1.2 billion is divided into the following principal categories/activities:

decontamination; removal; packaging; transportation; waste disposal; waste processing; program management; security; spent fuel storage; insurance and regulatory fees; energy; characterization and licensing surveys; property taxes; and miscellaneous equipment and supply costs. CEG included a timeline and an annual cost projection that identifies when these activities will take place, and the costs associated with each of these items.

5.0 CONCLUSION

The NRC staff finds CEGs costs for the long-term storage of irradiated fuel and the preliminary cost estimate for radiological decommissioning of DRE-2 are reasonable and provide sufficient details associated with the funding mechanisms. The NRC staff, therefore, concludes that the licensees costs for IFMP for DRE-2 comply with 10 CFR 50.54(bb) and approves the costs on a preliminary basis. In addition, the NRC staff finds that the preliminary cost estimates for radiological decommissioning of DRE-2 are reasonable and comply with the requirements of 10 CFR 50.75(f)(3).

Principal Contributor: Kenneth Kline, NMSS Date: November 28, 2025

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNIT 2 - SAFETY EVALUATION FOR REVIEW OF PRELIMINARY DECOMMISSIONING COST ESTIMATE AND IRRADIATED FUEL MANAGEMENT PLAN (EPID L-2024-LLL-0025) DATED NOVEMBER 28, 2025 DISTRIBUTION:

Public RidsNrrPMDresden Resource RidsACRSMailCTR Resource RidsNrrDorlLpl3 Resource RidsRgn3MailCenter Resource RidsNmssRefsFab Resource RidsNrrLASLent Resource KKline, NMSS Accession No.: ML25329A107 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NMSS/REFS/FAB/BC NAME SArora SLent FMiller DATE 11/25/2025 11/25/2025 08/21/2025 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME IBerrios SArora (SWall for)

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