RA-18-034, Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

ML18081A201
Person / Time
Site:	Oyster Creek
Issue date:	03/22/2018
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RA-18-034
Download: ML18081A201 (20)

Text

Michael P. Gallagher Exelon Generation Exelon Nuclear Vice President License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp .com michaelp.gallagher@exeloncorp.com 10 CFR 50.12 10 CFR 50.82(a}(8}(i)(A) 10 CFR 50.75(h}(1 }(iv)

RA-18-034 March 22, 2018 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Request for Exemption from 10 CFR 50.82(a}(8}(i}(A) and 10 CFR 50. 75(h)(1 )(iv)

Reference:

1) Letter from Keith R. Jury, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Permanent Cessation of Operations at Oyster Creek Nuclear Generating Station," dated January 7, 2011, (ML110070507)

2) Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S.

Nuclear Regulatory Commission - "Certification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Power Station," dated February 14, 2018 (ML18045A084}

3) Letter from James Barstow, (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - "Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan," dated December 30, 2014 (ML14365A067)

4) Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - "Submittal of Updated Decommissioning Cost Analysis for Oyster Creek Nuclear Generating Station," dated March 30, 2016 (ML16090A067)

Pursuant to 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) requests an exemption from 10 CFR 50.82(a)(8)(i)(A) for Oyster Creek Nuclear Generating Station (OCNGS) to allow use of a portion of the funds from the OCNGS decommissioning trust funds (DTF) for the management of spent fuel and site restoration activities, based on the OCNGS decommissioning cost estimate (Reference 4). Exelon also requests, pursuant to 10 CFR 50.12, an exemption from 10 CFR 50.75(h)(1)(iv) to allow OCNGS DTF disbursements for spent fuel

U.S. Nuclear Regulatory Commission OCNGS Request for Exemption Docket Nos. 50-219 and 72-15 March 22, 2018 Page2 management and site restoration activities to be made without prior notice, similar to withdrawals in accordance with 10 CFR 50.82(a)(8).

On January 7, 2011, Exelon informed the U.S. Nuclear Regulatory Commission (NRC) that OCNGS will permanently cease power operations by December 31, 2019 (Reference 1). On February 2, 2018, Exelon announced that it now plans to retire OCNGS no later than October 31, 2018, at the end of the current two-year operating cycle. Exelon informed the NRC of this change in Reference 2. By a letter dated December 30, 2014 (Reference 3), Exelon submitted the OCNGS Spent Fuel Management Plan pursuant to 10 CFR 50.54(bb) and Preliminary Decommissioning Cost Estimate (DCE). The DCE was updated in March 2016 (Reference 4);

however, there were no significant changes to the Spent Fuel Management Plan as a result of the 2016 updated cost estimate.

Table 2 of the Attachment demonstrates that the DTF contains the amount needed to cover the estimated costs of radiological decommissioning, spent fuel management, and site restoration activities. However, 10 CFR 50.82(a)(8)(i)(A) states that DTFs "may be used by licensees if ...

[t]he withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in§ 50.2."

10 CFR 50.75(h)(1 )(iv) similarly requires that trust agreements restrict disbursements (other than for ordinary administrative and other incidental expenses of the fund) to those allowed under Section 50.82(a)(8) and requires a 30-day advance notification to the NRC prior to making disbursements for expenses not covered under Section 50.82(a)(8). The NRC does not construe the 10 CFR 50.2 definition of "decommission" as including activities associated with spent fuel management or site restoration. Therefore, exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv) are needed to allow Exelon to use DTFs for spent fuel management and site restoration activities.

The requested exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are permissible under 10 CFR 50.12 because they are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

(1 O CFR 50.12(a)(1 ).) In addition, application of the regulations in this particular circumstance is not necessary to achieve the underlying purpose of the rule (10 CFR 50.12(a)(2)(ii).) The cost estimate provided in Reference 4 and Table 1 of the Attachment identifies the estimated annual expenditures for radiological decommissioning, spent fuel management, and site restoration activities. Table 2 of the Attachment demonstrates that the DTF contains more than adequate funds to cover not only the estimated costs of radiological decommissioning, but also the estimated costs for spent fuel management and site restoration activities. Therefore, application of the restrictions in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv) is not necessary to ensure adequate funding for radiological decommissioning of OCNGS. Additionally, the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow for continual NRC oversight of the status of the DTF.

Exelon recognizes that if this exemption request is approved, amendments to its nuclear decommissioning trust agreements for OCNGS will be necessary, and that prior notice of the amendments is required by 10 CFR50.75(h)(1 )(iii).

Exelon requests approval of this exemption request by October 1, 2018. The expedited request for approval is intended to allow for planning for and actions to facilitate the movement of fuel to the independent spent fuel storage installation (ISFSI) as quickly as possible. This will result in

U.S. Nuclear Regulatory Commission OCNGS Request for Exemption Docket Nos. 50-219 and 72-15 March 22, 2018 Page 3 the most efficient decommissioning process, which will preserve the trust fund, maintaining the most funding assurance margin.

The exemption request is provided in the Attachment to this letter.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (61 O} 765-5264.

Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC

Attachment:

Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv) cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Attachment Oyster Creek Nuclear Generating Station Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-1 of A-16 1.0 SPECIFIC EXEMPTION REQUEST Pursuant to 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) requests an exemption from 10 CFR 50.82(a)(8)(i)(A) for Oyster Creek Nuclear Generating Station (OCNGS) to allow use of a portion of the funds from the OCNGS decommissioning trust funds (DTF) for the management of spent fuel and site restoration activities. Exelon also requests, pursuant to 10 CFR 50.12, an exemption from 10 CFR 50.75(h)(1)(iv) to allow DTF disbursements for spent fuel management and site restoration activities to be made without prior notice, similar to withdrawals in accordance with 10 CFR 50.82(a)(8).

10 CFR 50.82(a)(8)(i)(A) and the applicable provisions of 10 CFR 50.75(h)(1)(iv) are provided below:

Section (a)(8)(i)(A) of 10 CFR 50.82, "Termination of license," states the following:

Decommissioning trust funds may be used by licensees if-- (A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in § 50.2.

Section (h)(1)(iv) of 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning,"

states, in part:

Except for withdrawals being made under § 50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, no disbursement or payment may be made from the trust, escrow account, Government fund, or other account used to segregate and manage the funds until written notice of the intention to make a disbursement or payment has been given to the Director, Office of Nuclear Reactor Regulation, Director, Office of New Reactors, or Director, Office of Nuclear Material Safety and Safeguards, as applicable, at least 30 working days before the date of the intended disbursement or payment.

Section (h)(1)(iv) of 10 CFR 50.75 also states, in part:

Disbursements or payments from the trust, escrow account, Government fund, or other account used to segregate and manage the funds, other than for payment of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, are restricted to decommissioning expenses or transfer to another financial assurance method acceptable under paragraph (e) of this section until final decommissioning has been completed. After decommissioning has begun and withdrawals from the decommissioning fund are made under § 50.82(a)(8), no further notification need be made to the NRC.

10 CFR 50.2, "Definitions," contains the following definition of "decommission:"

to remove a facility or site safely from service and reduce residual radioactivity to a level that permits - (1) Release of the property for unrestricted use and termination of the license; or (2) Release of the property under restricted conditions and termination of the license.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-2 of A-16 Table 2 demonstrates that the DTF contains the amount needed to cover the estimated costs of radiological decommissioning, as well as spent fuel management and site restoration activities.

However, 10 CFR 50.82(a)(8)(i)(A) states that DTFs may be used by licensees if the withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2. Similarly, 10 CFR 50.75(h)(1)(iv) requires that trust agreements provide that disbursements (other than for ordinary administrative and other incidental expenses of the fund) are restricted to decommissioning expenses until final decommissioning is completed.

The NRC construes the definition of "decommission" in 10 CFR 50.2 as not including activities associated with spent fuel management or site restoration.

10 CFR 50.75(h)(1)(iv) further provides that, except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative and other incidental expenses, no disbursement may be made from the DTF without written notice to the NRC at least 30 working days in advance. Because disbursements for spent fuel management and site restoration activities would not be made under 10 CFR 50.82(a)(8), this provision would require advance notice to the NRC prior to any such disbursement.

Based on the above, Exelon has concluded that 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would prohibit use of DTFs for activities related to spent fuel management and site restoration prior to completion of radiological decommissioning. Exelon anticipates maintaining OCNGS in a safe storage condition (SAFSTOR) for an extended period prior to completion of radiological decommissioning. This will allow radioactive decay to occur, thereby reducing the quantity of contamination and radioactivity that must be disposed of during the decontamination and dismantlement process as well as reducing the associated occupational exposure. As specified in the Spent Fuel Management Plan (Reference 3), spent fuel management activities begin shortly after the reactor is defueled under the SAFSTOR option.

Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are requested to allow Exelon to withdraw and use funds from the DTF for spent fuel management and site restoration activities. The exemptions would cover all spent fuel management and site restoration activities at OCNGS. As the DTF contains adequate funds to complete radiological decommissioning as well as spent fuel management activities and site restoration activities, these exemptions would not present an undue risk to the public health and safety or prevent decommissioning from being completed as planned.

2.0 BACKGROUND

The OCNGS site is a single unit facility located near the Atlantic Ocean within the State of New Jersey. The facility site, approximately 152 acres, is in Lacey Township, Ocean County. The OCNGS facility employs a General Electric boiling water reactor nuclear steam supply system licensed to generate 1930 megawatts-thermal. The boiling water reactor and supporting facilities are owned and operated by Exelon. The licensee (Exelon) is the holder of the OCNGS Renewed Facility Operating License No. DPR-16. The license provides, among other things, that the facility is subject to all rules, regulations, and orders of the NRC now or hereafter in effect.

By letter dated January 7, 2011 (Reference 1), and pursuant to 10 CFR 50.82(a)(1)(i), Exelon notified the U.S. Nuclear Regulatory Commission (NRC) of its intention to permanently cease power operations at OCNGS by December 31, 2019. On February 2, 2018, Exelon announced that it now planned to retire OCNGS no later than October 31, 2018, at the end of the current two-

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-3 of A-16 year operating cycle. Exelon informed the NRC of this change in a letter dated February 14, 2018 (Reference 2). Once fuel has been permanently removed from the reactor vessel, Exelon will submit a written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon docketing of these certifications, the 10 CFR 50 operating license for OCNGS will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

By a letter dated December 30, 2014 (Reference 3), Exelon submitted the OCNGS Spent Fuel Management Plan pursuant to 10 CFR 50.54(bb) and Preliminary Decommissioning Cost Estimate (Preliminary DCE). The submittal was based on the annual cash flow required for decommissioning OCNGS based on the SAFSTOR scenario. The OCNGS Preliminary DCE was based on a retirement date of 2019 and was originally developed in 2011.

By letter dated March 30, 2016, Exelon submitted an Updated Decommissioning Cost Estimate (Updated DCE) for OCNGS (Reference 4). The OCNGS Updated DCE information included in this submittal was updated in accordance with Exelon's normal practice of updating DCEs every five years. There were no significant changes to the Spent Fuel Management Plan as a result of the 2016 cost estimate.

3.0 BASIS FOR EXEMPTION REQUEST Exelon anticipates using the SAFSTOR method of decommissioning at OCNGS, which defers completion of radiological decommissioning until after a storage period, thus delaying (absent an exemption) the availability of excess amounts in the DTF for spent fuel management and site restoration activities. Reference 4 provided a site-specific decommissioning cost estimate, which estimates the cost of radiological decommissioning, spent fuel management, and site restoration efforts. Table 2 includes a cash flow analysis demonstrating that, with credited earnings during the SAFSTOR period, the DTF contains sufficient funds needed to cover the cost of radiological decommissioning, spent fuel management, and site restoration activities.

Table 1 reflects the projected annual cash flows required for decommissioning OCNGS based on the SAFSTOR scenario from the Reference 4 cost estimate. The costs for site radiological decommissioning (license termination costs), spent fuel management, independent spent fuel storage installation (ISFSI) radiological decommissioning, and site restoration (non-radiological decommissioning) efforts are reflected in Table 1. The costs from Reference 4 have been updated to reflect the current situation at OCNGS as follows:

(1) The Reference 4 cost estimate is in thousands of 2016 dollars. The costs have been escalated to December 31, 2017 dollars in two steps. The first step increased the cost estimate to June 30, 2017, dollars and the second step increased the cost estimate to December 31, 2017, dollars.

The first step was performed by the vendor that prepared the OCNGS decommissioning cost estimate using actual escalation indices applied to the five component parts of Total Cost (Labor, Equipment and Material, Energy, Low-Level Radioactive Waste Disposal, and Other Costs). The component parts were then summed to determine the Total Cost in June 30, 2017, dollars.

• Labor cost escalation was based on the Employment cost index, Total Private Compensation.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-4 of A-16

• Equipment and Material cost escalation was based on the Producer Price Index, Machinery, and Equipment.

• Energy cost escalation was based on the Producer Price Index, Fuels and Related Products and Power.

• Low Level Radioactive Waste Disposal cost escalation was based upon published Barnwell, South Carolina disposal rates.

• Other cost escalation was based on the Consumer Price Index, Services.

The second step was performed by Exelon using a forecasted average annual escalation rate of 2.6848% (based on the most recent data at the time of this submittal). This rate was calculated by the vendor that prepared the OCNGS decommissioning cost estimate using forecasted indices from a subcontractor with expertise in economic forecasting. The subcontractor does not forecast low level radioactive waste disposal rates. The Consumer Price Index for Services, plus 1%, was used for this component in the calculation of the forecasted average annual escalation rate based on vendor experience with historical rates.

(2) The escalated cash flows were moved one-year earlier to reflect a 2018 shutdown.

The Reference 4 cost estimate is based on a December 31, 2019, shutdown. In Reference 2, Exelon indicated OCNGS will permanently cease operation no later than October 31, 2018. To fully align the estimated cash flows with the updated shutdown date, the cash flows should be moved 14 months earlier; however, the straightforward adjustment of 12 months was made. Table 2 indicates an OCNGS DTF balance of over $400 million at the end of decommissioning. The impact of expenses occurring two months earlier than estimated will not materially impact this ending balance.

(3) Site radiological decommissioning planning costs and spent fuel management planning costs were included in 2018. These costs have not yet been reimbursed from the DTF.

The Reference 4 cost estimate includes costs associated with site radiological decommissioning planning performed by a dedicated site organization prior to permanent shutdown (costs occur in 2016 through 2019 in the estimate). In 2018, the site decommissioning planning organization will continue to function. Therefore, the estimated cost for this organization has been included in Table 1 in 2018 under site radiological decommissioning costs. None of the 2018 radiological decommissioning costs have been reimbursed from the DTF.

Spent fuel management planning costs are included in the Reference 4 cost estimate starting in 2020 (2019 in the Table 1 adjusted cash flows); however, Exelon actually began spent fuel management planning at OCNGS in 2017. These planning activities will continue in 2018. The 2018 projected costs have been included in Table 1 under the Spent Fuel Management Cost heading in 2018. No adjustment to future year cash flows have been made to account for the earlier start to spent fuel management planning.

Consequently, Table 1 double counts these costs. Spent fuel management costs have NOT been reimbursed from the OCNGS DTF. Spent fuel management costs will only be reimbursed from the DTF if this exemption request is approved.

Table 2 contains the projected annual cash flow from the OCNGS DTF for decommissioning the site (including site radiological decommissioning, spent fuel management, ISFSI radiological decommissioning, and site restoration) based on the SAFSTOR scenario annual costs from Table

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-5 of A-16

1. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period. A 2%

annual real rate of return on the DTF as allowed by 10 CFR 50.75(e)(1)(i) is used in the analysis.

Additionally, contributions to the DTF and cost escalation are both assumed to be zero in the Table 2 analysis.

The 2018 beginning of year (BOY) Trust Fund Value (analysis starting trust fund balance) in Table 2 is the December 31, 2017, trust value less the 2017 site radiological decommissioning planning and spent fuel management planning costs which are $3,146k and $155k, respectively.

The Reference 4 cost estimate included costs associated with site radiological decommissioning planning performed by a dedicated site organization prior to permanent shutdown (costs occur in 2016 through 2019 in the estimate). The costs associated with this organization in 2016 have been reimbursed from the OCNGS DTF and are accounted for in the December 31, 2017, DTF balance. The 2017 costs associated with this organization have not yet been reimbursed from the DTF. Consequently, the 2017 estimated costs of $3,146k are subtracted from the December 31, 2017, DTF balance.

Spent fuel management planning costs are included in the Reference 4 cost estimate starting in 2020 (2019 in the Table 1 adjusted cash flows). However, Exelon actually began spent fuel management planning at OCNGS in 2017. The 2017 spent fuel management planning costs of approximately $155k have not been reimbursed from the DTF. These costs are subtracted from the December 31, 2017, DTF balance to reflect future reimbursement if this exemption is approved.

Table 2 demonstrates that the OCNGS DTF as of December 31, 2017, exceeds the amount required to complete decommissioning of the site under the SAFSTOR scenario. At the end of the decommissioning project, an estimated $473.8 million will remain in the DTF.

4.0 ADJUSTING COST ESTIMATES AND FUNDING LEVELS 10 CFR 50.82(a)(8)(iv) states the following [emphasis added]:

For decommissioning activities that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period.

Exelon anticipates maintaining OCNGS in a safe storage condition (SAFSTOR) for an extended period prior to completion of radiological decommissioning. This will allow radioactive decay to occur, thereby reducing the quantity of contamination and radioactivity that must be disposed of during the decontamination and dismantlement process as well as reducing the associated occupational exposure.

Exelons approach to address the requirements of 10 CFR 50.82(a)(8)(iv) with respect to "adjusting [decommissioning] cost estimates and associated funding levels over the storage or surveillance period" is discussed below and is consistent with the approach specified in the response to request for additional information (RAI) 1 of Reference 5.

During the SAFSTOR period, the site-specific decommissioning cost estimate will be periodically updated in compliance with Exelon procedures and applicable regulatory requirements.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-6 of A-16 In accordance with 10 CFR 50.82(a)(8)(iv), decommissioning funding assurance will be reviewed and reported to the NRC annually during the SAFSTOR period. The latest site-specific decommissioning cost estimate adjusted for inflation, in accordance with applicable regulatory requirements, will be used to demonstrate funding assurance. In addition, actual radiological and spent fuel management expenses will be included in the annual report in accordance with the applicable regulatory requirements. If the funding assurance demonstration shows the DTF is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in Regulatory Guide 1.159 (Reference 6) (applicable revision at the time) will be put in place.

5.0 JUSTIFICATION FOR EXEMPTIONS AND SPECIAL CIRCUMSTANCES Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of Part 50 which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. 10 CFR 50.12 also states that the Commission will not consider granting an exemption unless special circumstances are present. As discussed below, this exemption request satisfies the provisions of Section 50.12.

5.1 Exemptions A. The exemptions are authorized by law The proposed exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would allow Exelon to use a portion of the funds from the decommissioning trust fund for spent fuel management and site restoration activities, consistent with the OCNGS Spent Fuel Management Program and decommissioning cost estimate. As stated above, 10 CFR 50.12 allows the NRC to grant exemptions from the requirements of 10 CFR Part 50. The proposed exemptions would not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations. The NRC has granted exemptions to other licensees to use DTFs for spent fuel management and site restoration (see Section 6.0 of this attachment).

Therefore, the exemptions are authorized by law.

B. The exemptions will not present an undue risk to public health and safety The underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1)(iv) is to provide reasonable assurance that adequate funds will be available for decommissioning of power reactors within 60 years of cessation of operations. Based on the site-specific cost estimate and the cash flow analysis provided in Tables 1 and 2, use of some of the funds in the trust fund for spent fuel management and site restoration activities will not adversely impact Exelon's ability to terminate the OCNGS license (i.e., complete radiological decommissioning) within 60 years. Furthermore, an exemption from 10 CFR 50.75(h)(1)(iv) to allow Exelon to make withdrawals from the trust fund to cover expenses for spent fuel management and site restoration efforts without prior written notification to the NRC will not affect the sufficiency of funds in the trust fund to accomplish radiological decontamination of the site. Additionally, the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow for continual NRC oversight of the status of the DTF.

Based on the above, no new accident precursors are created by using the trust fund in the proposed manner. Thus, the probability of postulated accidents is not increased. Also, based

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-7 of A-16 on the above, the consequences of postulated accidents are not increased. No changes are being made in the types or amounts of effluents that may be released offsite. There is no significant increase in occupational or public radiation exposure. Therefore, the exemptions will not present an undue risk to the public health and safety.

C. The exemptions are consistent with the common defense and security The proposed exemptions would allow Exelon to use a portion of trust funds for spent fuel management and site restoration efforts, consistent with the OCNGS Spent Fuel Management Program and cost estimate. Spent fuel management and site restoration activities are an integral part of the planned OCNGS decommissioning process and will not adversely affect Exelons ability to physically secure the site or protect special nuclear material. This change to enable use of some of the funds in the trust fund for spent fuel management and site restoration activities will not alter the scope or availability of sufficient funding for the OCNGS security program. Therefore, the proposed exemptions are consistent with the common defense and security.

5.2 Special Circumstances Pursuant to 10 CFR 50.12(a)(2), the NRC will not consider granting an exemption to its regulations unless special circumstances are present. Exelon has determined that special circumstances are present as discussed below.

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

The underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1)(iv) is to provide reasonable assurance that adequate funds will be available for decommissioning of power reactors within 60 years of cessation of operations. Strict application of the rule would prohibit withdrawal of funds from the DTF for activities associated with spent fuel management and site restoration activities until final radiological decommissioning at OCNGS has been completed. However, Tables 1 and 2 (as discussed above) demonstrate that adequate funds are available in the DTF to complete radiological decommissioning, spent fuel management, and site restoration activities. The Table 2 cash flow analysis projects that the DTF will contain

$473.8 million at the end of the decommissioning project in 2080 (using a 0.0% escalation rate and a 2.0% annual fund growth rate on remaining funds).

The 30-day notification provision in 10 CFR 50.75(h)(1)(iv) was not intended to duplicate other reporting requirements that would exist after a plant commences decommissioning. The underlying purpose of notifying the NRC prior to withdrawal of funds from the DTF is to provide opportunity for NRC intervention, when deemed necessary, if the withdrawals are for expenses other than those authorized by 10 CFR 50.75(h)(1)(iv) and 10 CFR 50.82(a)(8) that could result in insufficient funds in the DTF to accomplish radiological decontamination of the site.

A comment, received during the rulemaking for the Decommissioning Trust Fund Provisions in 10 CFR 50.75(h)(1)(iv), noted that licensees that have complied with the requirements of 10 CFR 50.82(a)(4) regarding submittal of a Post-Shutdown Decommissioning Activities Report (PSDAR) and control disbursements in accordance with the provisions of 10 CFR

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-8 of A-16 50.82(a)(6), (a)(7) and (a)(8) should be exempt from further restrictions on disbursements (Reference 7). The NRC agreed with the comment, because requiring notification in such circumstances would not provide any additional assurance that funding is available and would duplicate notification requirements in 10 CFR 50.82. If the NRC grants the requested exemption allowing Exelon to use some of the funds in its DTF for spent fuel management and site restoration activities, the same consideration would justify dispensing with the 30-day notification requirement as well. The decommissioning cost estimate identifies the estimated annual expenditures, and the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow continual NRC oversight of the status of the trust fund. Applying the 30-day advance notification requirement in 10 CFR 50.75(h)(1)(iv) to disbursements for spent management and site restoration activities would duplicate these other reporting requirements and is not necessary to achieve the underlying purposes of the rule.

Therefore, since the underlying purposes of the rules would be achieved by allowing Exelon to use the DTF to fund the activities as discussed in the OCNGS cost estimate and Spent Fuel Management Program, the special circumstances of 10 CFR 50.12(a)(2)(ii) are present.

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

The NRC did not intend to prevent the use of these funds solely because they are commingled, and to do so would create an unnecessary financial burden without any corresponding safety benefit. The NRC does not preclude use of funds from the decommissioning trust in excess of those needed for radiological decommissioning for other purposes, such as spent fuel management and site restoration efforts. The NRC has stated that funding for spent fuel management and site restoration activities may be commingled in the decommissioning trust provided the licensee is able to identify and account for the radiological decommissioning funds separately from the funds set aside for spent fuel management and site restoration activities (see NRC Regulatory Issue Summary 2001-07, Revision 1, "10 CFR 50.75 Reporting and Recordkeeping for Decommissioning Planning" dated January 8, 2009 (Reference 8), and Regulatory Guide 1.184, Revision 1, "Decommissioning of Nuclear Power Reactors," (Reference 9)). The adequacy of the trust fund to cover the cost of activities associated with decommissioning, the spent fuel management activities, and the site restoration activities is supported by the provided cash flow analysis. The amount of funds required for radiological decommissioning, spent fuel management, and site restoration activities will be identified and accounted for in the annual report required by 10 CFR 50.75(f) and 10 CFR 50.82(a)(8).

If Exelon cannot use its trust fund for spent fuel management and site restoration activities, it would be forced to provide additional funding that would not be recoverable from the trust fund until the OCNGS operating license is terminated. To prevent access to the excess funds in the trust would impose an unnecessary and undue burden in excess of that contemplated when the regulation was adopted without any corresponding safety benefit.

Therefore, compliance with the rule would result in an undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-9 of A-16 significantly in excess of those incurred by others similarly situated and the special circumstances of 10 CFR 50.12(a)(2)(iii) are present.

6.0 PRECEDENT The exemption request for 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1)(iv) is consistent with exemption requests that recently have been issued by the NRC for other nuclear power reactor facilities beginning decommissioning. Specifically, the NRC granted similar exemptions to Entergy Nuclear Operations, Inc., for Vermont Yankee (Reference 10); to Duke Energy Florida, Inc. for Crystal River Unit 3 (Reference 11); and to Dominion Energy Kewaunee, Inc. for KPS (Reference 12).

7.0 ENVIRONMENTAL ASSESSMENT The proposed exemption meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25), because the proposed exemption involves: (i) no significant hazards consideration; (ii) no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (iii) no significant increase in individual or cumulative public or occupational radiation exposure; (iv) no significant construction impact; (v) no significant increase in the potential for or consequences from radiological accidents; and (vi) the requirements from which the exemption is sought involve: (H) surety, insurance or indemnity requirements.

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed exemption.

(i) No Significant Hazards Consideration Determination Exelon has evaluated the proposed exemption to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92 as discussed below:

1. Does the proposed exemption involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed exemptions would allow Exelon to withdraw funds from the Oyster Creek Nuclear Generating Station's (OCNGS) decommissioning trust fund (DTF) to conduct activities associated with spent fuel management and site restoration activities in accordance with the OCNGS decommissioning cost estimate and Spent Fuel Management Program. The proposed exemptions have no effect on plant structures, systems, and components (SSCs) and no effect on the capability of any plant SSC to perform its design function. The proposed exemptions would not increase the likelihood of the malfunction of any plant SSC. The proposed exemptions would have no effect on any of the previously evaluated accidents in the OCNGS Updated Final Safety Analysis Report. Use of funds in the DTF as allowed under the exemptions will not affect the probability of occurrence of any previously analyzed accident. The proposed exemptions do not change the requirements pertaining to spent fuel management.

Therefore, the proposed exemption does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-10 of A-16

2. Do the proposed exemptions create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed exemption does not involve a physical alteration of the plant. No new or different type of equipment will be installed and there are no physical modifications to existing equipment associated with the proposed exemption. Similarly, the proposed exemption will not physically change any SSCs involved in the mitigation of any accidents. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed exemption does not create the possibility of a new accident as a result of new failure modes associated with any equipment or personnel failures. No changes are being made to parameters within which the plant is normally operated, or in the setpoints which initiate protective or mitigative actions, and no new failure modes are being introduced.

Therefore, the proposed exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed exemptions involve a significant reduction in a margin of safety?

Response: No.

The proposed exemption does not alter the design basis or any safety limits for the plant. The proposed exemption does not impact station operation or any plant SSC that is relied upon for accident mitigation.

Therefore, the proposed exemption does not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed exemption presents no significant hazards consideration, and, accordingly, a finding of "no significant hazards consideration" is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

There are no expected changes in the types, characteristics, or quantities of effluents discharged to the environment associated with the proposed exemption. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of effluents released offsite. In addition, the method of operation of waste processing systems will not be affected by the exemption. The proposed exemption will not result in changes to the design basis requirements of SSCs that function to limit or monitor the release of effluents. All the SSCs associated with limiting the release of effluents will continue to be able to perform their functions. Therefore, the proposed exemption will result in no significant change to the types or significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative public or occupational radiation exposure.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-11 of A-16 The proposed exemptions do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

(iv) There is no significant construction impact.

No construction activities are associated with the proposed exemption.

(v) There is no significant increase in the potential for or consequences from radiological accidents.

See the no significant hazards considerations discussion in Item (i)(1) above.

(vi) The requirements from which exemption is sought involve: (H) surety, insurance or indemnity requirements.

The underlying purpose of the requirements from which exemptions are sought is to provide reasonable assurance that adequate funds will be available for decommissioning of power reactors within 60 years of cessation of operations. These requirements provide surety for decommissioning funding.

8.0 CONCLUSION

The proposed exemptions would allow Exelon to use the OCNGS decommissioning trust fund for the full scope of activities described in the decommissioning cost estimate, including the management of spent fuel and site restoration, and to make such disbursements in the same manner as withdrawals for radiological decommissioning.

Granting these exemptions will be consistent with the purposes underlying NRC decommissioning regulations as the exemptions: (1) would not foreclose release of the site for possible unrestricted use; (2) would not result in significant environmental impacts not previously reviewed by the NRC; and (3) would not undermine the existing and continuing reasonable assurance that adequate funds will be available for decommissioning.

Pursuant to the provisions of 10 CFR 50.12, Exelon is requesting a permanent exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for OCNGS. Based on the considerations discussed above, the requested exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances are present as set forth in 10 CFR 50.12(a)(2)(ii) and (iii).

9.0 REFERENCES

1. Letter from Keith R. Jury, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Permanent Cessation of Operations at Oyster Creek Nuclear Generating Station," dated January 7, 2011 (ADAMS Accession No. ML110070507)

2. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Certification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Power Station," dated February 14, 2018 (ADAMS Accession No ML18045A084)

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-12 of A-16

3. Letter from James Barstow, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan," dated December 30, 2014 (ADAMS Accession No. ML14365A067)

4. Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Submittal of Updated Decommissioning Cost Analysis for Oyster Creek Nuclear Generating Station," dated March 30, 2016 (ADAMS Accession No. ML16090A067)

5. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate," dated April 5, 2016 (ADAMS Accession No. ML16096A397)

6. Regulatory Guide 1.159, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors," Revision 2, dated October 2011 (ADAMS Accession No. ML112160012)

7. Federal Register Notice, 67 FR 78332, Decommissioning Trust Provisions, dated December 24, 2002

8. NRC Regulatory Issue Summary 2001-07, Revision 1, "10 CFR50.75 Reporting and Recordkeeping for Decommissioning Planning," dated January 8, 2009 (ADAMS Accession No. ML083440158)

9. Regulatory Guide 1.184, Revision 1, "Decommissioning of Nuclear Power Reactors,"

dated October 2013 (ADAMS Accession No. ML13144A840)

10. Letter from U.S. Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc; Vermont Yankee Nuclear Power Station, Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(1)(iv) (TAC NO. MF5575), dated June 17, 2015 (ADAMS Accession No. ML15128A219)

11. Letter from U.S. Nuclear Regulatory Commission to Duke Entergy Florida, Inc; Crystal River Unit 3 Nuclear Generating Plant; Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(1)(iv) (TAC NO. MF3875), dated January 26, 2015 (ADAMS Accession No. ML14247A545)

12. Letter from U.S. Nuclear Regulatory Commission to Dominion Entergy Kewaunee, Inc; Kewaunee Power Station, Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(1)(iv) (TAC NO. MF1438), dated May 21, 2014 (ADAMS Accession No. ML13337A287)

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-13 of A-16 Table 1 ANNUAL SAFSTOR DECOMMISSIONING COST CASH FLOW FOR OYSTER CREEK NUCLEAR GENERATING STATION (December 31, 2017 dollars, thousands)

Site Radiological Spent Fuel Management ISFSI Radiological Site Restoration Year Decommissioning Cost Cost Decommissioning Cost Cost Total Cost(a) 2018(b) 3,268 4,700 0 0 7,968 2019 84,002 24,096 0 0 108,098 2020 73,536 34,364 0 0 107,900 2021 7,791 44,874 0 0 52,666 2022 7,791 44,874 0 0 52,666 2023 7,813 44,997 0 0 52,810 2024 7,585 25,064 0 0 32,649 2025 7,381 5,577 0 0 12,958 2026 7,381 5,577 0 0 12,958 2027 7,401 5,592 0 0 12,993 2028 7,381 5,577 0 0 12,958 2029 7,381 5,577 0 0 12,958 2030 7,381 5,577 0 0 12,958 2031 7,401 5,592 0 0 12,993 2032 7,381 6,174 0 0 13,555 2033 7,381 10,952 0 0 18,333 2034 7,381 10,952 0 0 18,333 2035 7,367 0 0 0 7,367 2036 7,347 0 0 0 7,347 2037 7,347 0 0 0 7,347 2038 7,347 0 0 0 7,347 2039 7,367 0 0 0 7,367 2040 7,347 0 0 0 7,347 2041 7,347 0 0 0 7,347 2042 7,347 0 0 0 7,347 2043 7,367 0 0 0 7,367 2044 7,347 0 0 0 7,347 2045 7,347 0 0 0 7,347 2046 7,347 0 0 0 7,347 2047 7,367 0 0 0 7,367 2048 7,347 0 0 0 7,347 2049 7,347 0 0 0 7,347 2050 7,347 0 0 0 7,347 2051 7,367 0 0 0 7,367 2052 7,347 0 0 0 7,347 2053 7,347 0 0 0 7,347

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-14 of A-16 Table 1 (Continued)

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

Decommissioning Cost Year Management Cost Cost Cost 2054 7,347 0 0 0 7,347 2055 7,367 0 0 0 7,367 2056 7,347 0 0 0 7,347 2057 7,347 0 0 0 7,347 2058 7,347 0 0 0 7,347 2059 7,367 0 0 0 7,367 2060 7,347 0 0 0 7,347 2061 7,347 0 0 0 7,347 2062 7,347 0 0 0 7,347 2063 7,367 0 0 0 7,367 2064 7,347 0 0 0 7,347 2065 7,347 0 0 0 7,347 2066 7,347 0 0 0 7,347 2067 7,367 0 0 0 7,367 2068 7,347 0 0 0 7,347 2069 7,347 0 0 0 7,347 2070 7,347 0 0 0 7,347 2071 7,367 0 0 0 7,367 2072 7,347 0 0 0 7,347 2073 7,347 0 0 0 7,347 2074 45,937 0 0 490 46,427 2075 108,464 0 0 681 109,145 2076 179,949 0 927 498 181,373 2077 146,288 0 3,932 1,560 151,781 2078 70,483 0 970 385 71,838 (c) 2079 159 0 0 36,528 36,687 2080 88(c) 0 0 20,060 20,148 Totals(a) 1,103,747 290,116 5,829 60,202 1,459,895 (a)

Cash flows may not add due to rounding.

(b) 2018 costs are for planning and do not include any physical work.

(c) 2079 and 2080 Site Radiological Decommissioning Costs are administrative expenses associated with submitting a final report to the NRC following license termination and do not include any physical decommissioning work.

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-15 of A-16 Table 2 ANNUAL SAFSTOR DECOMMISSIONING FUND CASH FLOW FOR OYSTER CREEK NUCLEAR GENERATING STATION (December 31, 2017 dollars, thousands)

BOY Trust BOY Trust Fund Trust Fund EOY Trust Fund Year Total Cost(a) Fund Value Less Cost Earnings(b) Value(c) 2018 7,968 978,794(d) 970,827 19,417 990,243 2019 108,098 990,243 882,145 17,643 899,788 2020 107,900 899,788 791,887 15,838 807,725 2021 52,666 807,725 755,060 15,101 770,161 2022 52,666 770,161 717,495 14,350 731,845 2023 52,810 731,845 679,035 13,581 692,616 2024 32,649 692,616 659,967 13,199 673,167 2025 12,958 673,167 660,209 13,204 673,413 2026 12,958 673,413 660,455 13,209 673,664 2027 12,993 673,664 660,671 13,213 673,884 2028 12,958 673,884 660,926 13,219 674,145 2029 12,958 674,145 661,187 13,224 674,411 2030 12,958 674,411 661,453 13,229 674,682 2031 12,993 674,682 661,689 13,234 674,922 2032 13,555 674,922 661,367 13,227 674,595 2033 18,333 674,595 656,262 13,125 669,387 2034 18,333 669,387 651,054 13,021 664,075 2035 7,367 664,075 656,708 13,134 669,842 2036 7,347 669,842 662,495 13,250 675,745 2037 7,347 675,745 668,397 13,368 681,765 2038 7,347 681,765 674,418 13,488 687,907 2039 7,367 687,907 680,539 13,611 694,150 2040 7,347 694,150 686,803 13,736 700,539 2041 7,347 700,539 693,192 13,864 707,055 2042 7,347 707,055 699,708 13,994 713,702 2043 7,367 713,702 706,335 14,127 720,462 2044 7,347 720,462 713,115 14,262 727,377 2045 7,347 727,377 720,030 14,401 734,430 2046 7,347 734,430 727,083 14,542 741,625 2047 7,367 741,625 734,257 14,685 748,942 2048 7,347 748,942 741,595 14,832 756,427 2049 7,347 756,427 749,080 14,982 764,062 2050 7,347 764,062 756,714 15,134 771,849

Attachment Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket Nos. 50-219 and 72-15 Page A-16 of A-16 Table 2 (Continued)

Year Total Cost(a) BOY Trust BOY Trust Fund Trust Fund EOY Trust Fund Fund Value Less Cost Earnings(b) Value(c) 2051 7,367 771,849 764,481 15,290 779,771 2052 7,347 779,771 772,424 15,448 787,872 2053 7,347 787,872 780,525 15,610 796,135 2054 7,347 796,135 788,788 15,776 804,564 2055 7,367 804,564 797,197 15,944 813,141 2056 7,347 813,141 805,793 16,116 821,909 2057 7,347 821,909 814,562 16,291 830,853 2058 7,347 830,853 823,506 16,470 839,976 2059 7,367 839,976 832,609 16,652 849,261 2060 7,347 849,261 841,914 16,838 858,752 2061 7,347 858,752 851,405 17,028 868,433 2062 7,347 868,433 861,086 17,222 878,308 2063 7,367 878,308 870,940 17,419 888,359 2064 7,347 888,359 881,012 17,620 898,632 2065 7,347 898,632 891,285 17,826 909,110 2066 7,347 909,110 901,763 18,035 919,799 2067 7,367 919,799 912,431 18,249 930,680 2068 7,347 930,680 923,333 18,467 941,799 2069 7,347 941,799 934,452 18,689 953,141 2070 7,347 953,141 945,794 18,916 964,710 2071 7,367 964,710 957,342 19,147 976,489 2072 7,347 976,489 969,142 19,383 988,525 2073 7,347 988,525 981,178 19,624 1,000,801 2074 46,427 1,000,801 954,374 19,087 973,461 2075 109,145 973,461 864,316 17,286 881,602 2076 181,373 881,602 700,229 14,005 714,234 2077 151,781 714,234 562,453 11,249 573,702 2078 71,838 573,702 501,865 10,037 511,902 2079 36,687 511,902 475,215 9,504 484,719 2080 20,148 484,719 464,571 9,291 473,863 Total(c) 1,459,895 (a)

Annual SAFSTOR decommissioning cost (radiological + spent fuel + ISFSI decommissioning + site restoration)

(b)

A 2% annual real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)

(c)Cash flows may not add due to rounding (d)The 2018 BOY Trust Fund Value is the value of the decommissioning trust as of 12/31/2017 less the 2017 site radiological decommissioning and spent fuel management costs, $3,146k and $155k respectively.