View source for NMP1L3603, Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan

{{Adams
| number = ML24233A234
| issue date = 08/20/2024
| title = Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan
| author name = Mokkapati S
| author affiliation = Constellation Energy Generation, LLC
| addressee name = 
| addressee affiliation = NRC/NMSS, NRC/NRR, NRC/Document Control Desk
| docket = 05000220, 07201036
| license number = DPR-063
| contact person = 
| case reference number = NMP1L3603
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70, Letter type:NMP
| page count = 1
}}

=Text=
{{#Wiki_filter:10 CFR 50.54(bb) 10 CFR 50.75(f)(3)

NMP1L3603 August 20, 2024

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket Nos. 50-220 and 72-1036

==Subject:==
Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan

==Reference:==
Letter from Constellation Ener gy Generation, LLC to U.S. Nuclear Regulatory Commission, "Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations," dated March 23, 2023. (ML23082A312 )

In accordance with 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning," paragraph (f)(3), "Each power reacto r licensee shall at or about 5 years prior to the projected end of operations submit a preliminary decommissioning cost estimat e which includes an up-to-date assessment of the major factors that could affect the cost to decommission." Constellation Energy Generation, LLC (CEG) is submitting this letter to provide a preliminary Decommissioning Cost Estimate (DCE) in accordance with 10 CFR 50.75(f)(3) and irradiated fuel management plan in accordance with 10 CFR 50.54(bb) for Nine Mile Point Nuclear Statio n, Unit 1 (NMP1), as the Facility Operating License (FOL) expires in five (5) years (August 22, 2029).

CEG has not made a final determination of the decommissioning approach for NMP1.
For purposes of this submittal, the Shor tened 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 that it needs to assure the chosen option meets NRC requirements for decommissioning funding.
of this submittal contains a preliminary DCE for NMP1. The cost estimate is a preliminary estimate of anticipated costs from 2022 and will be updated at various times as deemed appropriate by CEG and/or in compliance with regulatory requirements. The attached preliminary DCE assumes that NMP1 permanently terminates operations on August 22, 2029, in accordance with the NMP1 FOL.
U.S. Nuclear Regulatory Commission Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan Docket Nos. 50-220 and 72-1036 August 20, 2024 Page 2

The latest Decommissioning Funding Report fo r NMP1 was submitted as Attachment 17 of the referenced letter. The minimum formula cost amount using the formula in 10 CFR 50.75(c) was calculated assumi ng the labor, energy, and burial factors described in Attachment 1 of the referenced letter. The site-specific cost amount reported in the DCE is greater than the m inimum formula cost amount, as required by 10 CFR 50.75(b)(1).

The major factors that could affect the cost estimate as well as contingencies to allow for unknown or unplanned occurrences during decommissioning are included in the attached preliminary decommissioning cost estimate. Additionally, soil and groundwater remediation costs are included in the cost estimate. The required soil remediation is based on evaluation of 10 CFR 50.75(g)(1) reports.

As discussed in 10 CFR 50.54(bb), "Condition s of licenses," paragraph (bb), a licensee shall "5 years before expiration of the reactor operating license, submit written notification to the Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." Accordingly, Attachment 2 of this submittal includes the NMP1 Spent Fuel Management Plan for NRC review and preliminary approval.
contains the projected annual cash flow from the NMP1 decommissioning trust fund for decommissioning the site based on the Attachment 1 DCE. The, Table 6-2 costs have been escalated from June 2021 dollars to the January 2024 dollars shown in Attachment 3 using an escalation rate of 11.13%. The costs for radiological decommissioning (license termination costs) and Independent Spent Fuel Storage Installation (ISFSI) decommi ssioning are reflected in Attachment 3 consistent with the definition of decommi ssioning in 10 CFR 50. 2. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period.
contains the projected annual cash flow from the NMP1 decommissioning trust fund for decommissioning (including radiological decommissioning and ISFSI d e c o m m i s s i o n i n g ) and spent fuel management b a s e d o n t h e A t t a c h m e n t 1 D C E. T h e, Table 6-2 costs have been escalated from June 2021 dollars to the January 2024 dollars shown in Attachment 4 using an escalation rate of 11.13%. The cash flow analysis conservatively assumes all expenses in a year are incurred at the beginning of year (i.e., beginning of year convention) during the decommissioning period. CEG recognizes that an exemption from 10 CFR 50.82(a)(8)(i)(A) is required to use decommissioning trust funds for expenses other than decommissioning activities as the term "decommissioning" is defined in 10 CFR 50.2.

U.S. Nuclear Regulatory Commission Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan Docket Nos. 50-220 and 72-1036 August 20, 2024 Page 3

As of December 31, 2023, NMP1 decommissioning trust fund balances totaled
$833.1 million, which exceeds the amount required for decommissioning of the site and spent fuel management.

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

In accordance with 10 CFR 50.54(bb), a copy of this notification will be maintained until the expiration of the NMP1 operating license. Additionally, NMP1 will notify the NRC of any significant changes in the proposed Irradiated Fuel Management Plan described in Attachment 2.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ron Reynolds at 267-533-5698.

Respectfully, Mokkapati, Digitally signed by Mokkapati, Sailaja Sailaja Date: 2024.08.20 13:09:29 -04'00' Sailaja Mokkapati Director, Licensing and Regulatory Affairs Co n ste llat ion Energy G e n e r a t i o n, L L C

Attachments: 1. Preliminary Decommission ing Cost Estimate for Nine Mile Point Nuclear Station, Unit 1
: 2. Irradiated Fuel Management Plan for Nine Mile Point Nuclear Station, Unit 1
: 3. Decommissioning Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1
: 4. Decommissioning and Spent Fuel Management Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1

cc: Region al Administrat or - NRC Region I NRC Senior Resident Inspector - Nine Mile Point Nuclear Station

Attachment 1 Preliminary Decommissioning Cost Estimate for Nine Mile Point Nuclear Station, Unit 1

DECOM-2021-DCE-NMP Rev. 0 22 0 2 1 D E C O M M I S S I O N I N G C O S T A N A L Y S I S R E P O R T

Nine Mile Point Nuclear Station - Unit 1 August 2022

DECOM-2021-DCE-NMP Rev. 0

APPROVALS

PREPARER:

Digitally signed by Baca, Adolfo Adolfo Baca Baca, Adolfo Date: 2022.08.30 15:47:14
______________________________________________________________________ -05'00'

PREPARER SIGNATURE DATE

REVIEWER:

Angela Cantrell Cantrell, Angela L. Digitally signed by Cantrell, Angela L. Date: 2022.08.30 16:29:18 -05'00' REVIEWER SIGNATURE DATE

APPROVER:
Digitally signed by Dunlap, Jeff Dunlap Dunlap, Jeffrey A. Jeffrey A.
Date: 2022.08.30 16:37:13 -05'00' APPROVER SIGNATURE DATE

Page i of vi DECOM-2021-DCE-NMP Rev. 0

EXECUTIVE 

==SUMMARY==
This report presents the cost to decontaminate and dismantle Nine Mile Point Unit 1. The primary objectives of the decommissioning project are to remove the unit from service, and reduce residual radioactivity to levels permitting unrestricted release, so that the units operating license can be terminated within 60-years after permanent cessation of operations. The costs to restore the site to a greenfield condition are included in the cost estimate.
This report presents a Shortened SAFSTOR License Termination method for Nine Mile Point Unit
: 1. In this Shortened SAFSTOR scenario, active decommissioning is deferred as long as possible before ultimately terminating the Unit 1 License approximately 37 years after shutdown. In accordance with regulatory requirements of the State of New York, Nine Mile Point Unit 1 will be fully decommissioned 20 years after the shutdown of Unit 2. Additionally, high-level waste will remain onsite after both units operating license has been terminated.
The selection of a preferred decommissioning alternative is influenced by numerous factors including the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns. Based on these factors, the Shortened SAFSTOR alternative has been selected at this time. The alternative and/or plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.
The cost elements are assigned to one of five subcategories: Radiological Decommissioning (radiological remediation), Spent Fuel Management, Site Restoration, ISFSI Radiological Decommissioning, Radiological Decommissioning Planning. The Radiological Decommissioning and Radiological Decommissioning Planning subcategories are used to accumulate costs that are consistent with decommissioning as defined by the NRC in its financial assurance regulations (i.e., 10 CFR 50.75). The cost reported for this subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.
Section 2 of this report, Decommissioning Scenario and Schedule, discusses three decommissioning scenarios, and provides the schedule for the selected scenario. The methodology used to develop the estimated costs, including financial aspects, is discussed in Section 3, Cost Estimate Methodology. Section 4, Assumptions, provides a discussion of the assumptions used in developing the various costs elements and considerations; including the cost associated with decontamination and component removal, waste disposal, and labor. These assumptions serve as the foundation in the development of the anticipated cost to decommission Nine Mile Point Unit 1.
Based on the Shortened SAFSTOR scenario, the major milestones associated with the decommissioning time periods are discussed in Section 5, Schedule Assumptions.
The following tables summarize the estimated costs for the Shortened SAFSTOR alternative reflecting the various cost elements. Additional detail regarding the estimated costs is provided in Section 6 of this report.

Page ii of vi DECOM-2021-DCE-NMP Rev. 0

Shortened SAFSTOR Alternative for Nine Mile Point Unit 1 (thousands, June 2021 dollars)

Cost Element Total Decontamination 23,930 Removal 164,032 Packaging 27,354 Transportation 15,385 Waste Disposal 88,870 Waste Processing 11,191 Program Management1 349,224 Security 114,115 Spent Fuel Storage 130,789 Insurance and Regulatory Fees 45,602 Energy 15,805 Characterization and Licensing Surveys 10,183 Property Taxes 80,088 Miscellaneous Equipment and Supplies 37,013 Total2 1,113,582

Cost Element Total Radiological Decommissioning 803,828 Spent Fuel Management 232,390 Site Restoration 63,789 ISFSI Radiological Decommissioning 7,215 Radiological Decommissioning Planning 6,359 Total2 1,113,582

1 Includes engineering costs.

2 Columns may not add up due to rounding.

Page iii of vi DECOM-2021-DCE-NMP Rev. 0

ACRONYMS

AE Architect Engineer AIF/NESP Atomic Industrial Forum/National Environmental Studies Project ALARA As Low as Reasonably Achievable BWI Babcock & Wilcox International BWR Boiling Water Reactor CE Combustion Engineering CEA Control Element Assembly CFR Code of Federal Regulations D.C. District of Columbia DCE Decommissioning Cost Estimate DOC Decommissioning Operations Contractor DOE Department of Energy DSAR Defueled Safety Analysis Report Constellation Constellation Energy Company FEMA Federal Emergency Management Agency FOL Facility Operating License GAO Government Accountability Office GTCC Greater than Class C [Waste]
HTGR High Temperature Gas-Cooled Reactor IP Industrial Package ISFSI Independent Spent Fuel Storage Installation LLW Low Level Waste LSA Low Specific Activity LTP License Termination Plan MPC Multi-Purpose Canister MTHM Metric Tons Heavy Metal NMPC Niagara Mohawk Power Corporation NRC United States Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Report (NRC)
NWPA Nuclear Waste Policy Act (1982)
PDCE Preliminary Decommissioning Cost Estimate PERT Program Evaluation and Review Technique PSDAR Post Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RCS Reactor Coolant System RPV Reactor Pressure Vessel SCO Surface Contaminated Object S&L Sargent and Lundy SWEC Stone and Webster Engineering Corporation UFSAR Updated Final Safety Analysis Report U.S. United States WDF Work Difficulty [Adjustment] Factor

Page iv of vi DECOM-2021-DCE-NMP Rev. 0

TABLE OF CONTENTS

EXECUTIVE 

==SUMMARY==
........................................................................................................... ii ACRO NYMS..............................................................................................................................iv
: 1. OVERVIEW........................................................................................................................ 1
: 2. DECOMMISSIONING SCENARIO AND SCHEDULE......................................................... 3 2.1. Decommissioning Methods.......................................................................................... 3 2.2. Decommissioning Schedule......................................................................................... 3
: 3. COST ESTIMATE METHODOLOGY.................................................................................. 6 3.1. Methodology Bases..................................................................................................... 6 3.2. Financial Components of the Cost Model..................................................................... 6
: 4. ASSUMPTIONS.................................................................................................................. 9 4.1. General........................................................................................................................ 9 4.2. Labor Costs................................................................................................................10 4.3. Transition Activities.....................................................................................................10 4.4. Non-Radioactive Waste..............................................................................................10 4.5. Radioactive Waste......................................................................................................11 4.6. Component Removal..................................................................................................12 4.7. Spent Fuel Management.............................................................................................13 4.8. Independent Spent Fuel Installation............................................................................13 4.9. Site Restoration..........................................................................................................13 4.10. Site Conditions Following Decommissioning...............................................................14
: 5. SCHEDULE.......................................................................................................................17 5.1. Schedule Assumptions...............................................................................................17
: 6. Cost Estimate...................................................................................................................18
: 7. REFERENCES..................................................................................................................22

Page v of vi DECOM-2021-DCE-NMP Rev. 0

Tables and Figures

Figure 4-1: Total Labor Hours...................................................................................................15 Table 4-1: Burial Volumes by Waste Category..........................................................................16 Table 5-1: Decommissioning Timeline......................................................................................17 Table 6-1: Shortened SAFSTOR Alternative for Nine Mile Point Unit 1.....................................19 Table 6-2: Total Annual Expenditures.......................................................................................20

Page vi of vi DECOM-2021-DCE-NMP Rev. 0
: 1. OVERVIEW

This report presents decommissioning cost estimates for Nine Mile Point Power Station - Unit 1.
Nine Mile Point Nuclear Station is located in Oswego County, New York. The site is approximately seven miles northeast of the city of Oswego and approximately 230 miles northwest of New York City. The station consists of two boiling water reactors. The site consists of approximately 900 acres along the shore of Lake Ontario.

Nine Mile Point Unit 1 is a General Electric Boiling Water Reactor (BWR), owned and operated by Constellation. Nine Mile Point Unit 1 is licensed to generate 1850 megawatts-thermal (MWt).
The primary objectives of the decommissioning project are to remove the Unit from service and reduce residual radioactivity to levels permitting unrestricted release, so that the Units operating license can be terminated approximately 37 years after permanent cessation of operations; Unit 1s license will be terminated 20 years after the shutdown of Unit 2. The costs to restore the site to a greenfield condition are included in the decommissioning cost estimate.

This analysis is not a detailed engineering evaluation, but an estimate prepared in advance of the detailed engineering processes required to carry out the decommissioning of the nuclear units. It also may not reflect the actual plan to decommission once Nine Mile Point Unit 1 is shutdown; the plan may differ from the assumptions made in this analysis based on facts that exist at the actual time of decommissioning.
The cost elements are assigned to one of five subcategories:
(1) Radiological Decommissioning - this subcategory is used to accumulate costs that are consistent with decommissioning as defined by the Nuclear Regulatory Commission (NRC) in its financial assurance regulations (i.e., 10 CFR 50.75) and separately address the cost of radiological decommissioning as defined by 10 CFR 50.2. The cost reported for this subcategory along with the Radiological Decommissioning Planning subcategory is generally sufficient to terminate the units operating license, recognizing that there may be some additional cost impact from spent fuel management.
(2) Spent Fuel Management - this subcategory contains costs associated with the containerization and transfer of spent fuel from the wet storage pool to a Department of Energy (DOE) transport cask or to the ISFSI for interim storage, as well as the transfer of the spent fuel in storage at the ISFSI to the DOE. Costs are included for management of the ISFSI until such time that the transfer is complete. It does not include any costs related to the final storage of the spent fuel at a national repository.
(3) Site Restoration - this subcategory is used to capture costs associated with the dismantling and demolition of buildings and facilities demonstrated to be free from contamination. This includes structures never exposed to radioactive materials, as well as those facilities that have been decontaminated to appropriate levels. Structures are removed to a depth of three feet below grade and backfilled to conform to local surface elevation.
(4) ISFSI Radiological Decommissioning - this subcategory is used to capture costs associated with activities directly related to radiological decontamination or dismantlement of the spent fuel dry storage facility as required by 10 CFR 72.30.

Page 1 of 22 DECOM-2021-DCE-NMP Rev. 0

(5) Radiological Decommissioning Planning - this subcategory is used to accumulate costs associated with planning for radiological decommissioning that are incurred prior to the cessation of plant operations.
It should be noted that the costs assigned to these subcategories are allocations. Delegation of cost elements is for the purposes of comparison (e.g., with NRC financial guidelines) or to permit specific financial treatment (e.g., Asset Retirement Obligation determinations). In reality, there can be considerable interaction between the activities in the five subcategories. For example, Constellation may decide to remove non-contaminated structures early in the project to improve access to highly contaminated facilities or plant components. In these instances, the non-contaminated removal costs could be reassigned from Site Restoration to a Radiological Decommissioning support activity. However, in general, the allocations represent a reasonable accounting of those costs that can be expected to be incurred for the specific subcomponents of the total estimated program cost, if executed as described.
The estimates were developed, and costs are presented in 2021 dollars. As such, the estimates do not reflect the escalation of costs (due to inflationary and market forces) over the remaining operating life of the station or during the decommissioning period.

Page 2 of 22 DECOM-2021-DCE-NMP Rev. 0
: 2. DECOMMISSIONING SCENARIO AND SCHEDULE

2.1. DECOMMISSIONING METHODS Constellation evaluated the following decommissioning scenarios:
(1) DECON - spent fuel is transferred to the ISFSI shortly after shutdown and decommissioning and dismantlement is performed concurrently with the spent fuel campaign.
(2) Shortened SAFSTOR (SHORTSTOR) - spent fuel is transferred to the ISFSI and decommissioning of Unit 1 is completed approximately 20 years after the permanent shutdown of Unit 2.
(3) SAFSTOR - spent fuel is transferred to the ISFSI and the plant facility is left intact until the decommissioning starts sometime in the future (dormancy phase), with structures maintained in a sound condition. Decommissioning commences such that license termination is completed within the required 60-years.
The scenarios also recognize that spent fuel will be stored at the site in the spent fuel storage pool(s) and/or in an ISFSI until such time that it can be transferred to a DOE facility. The estimates also include the cost to operate and eventually decommission the ISFSI.
The selection of a preferred decommissioning alternative is influenced by numerous factors at the time of plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or an interim storage facility, the status of other units at the site, regulatory requirements, and public concerns.

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

Page 3 of 22 DECOM-2021-DCE-NMP Rev. 0

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 reduced to only include the ISFSI land area.
Site Restoration - Final demolition of any non-radiological structures, site grading and preparation for reuse of the land outside the ISFSI boundary.
ISFSI Operations and Decommissioning - The ISFSI continues to operate until the fuel is transferred to the Department of Energy. Following fuel transfer, the ISFSI is decommissioned and the NRC license is terminated.
2.2.1. Shortened SAFSTOR Schedule 2.2.1.1. Pre-shutdown and Period 1 (Shutdown through Transition) - Preparations Prior to the permanent shutdown and defueling, detailed preparations are undertaken to provide a smooth transition from plant operations to site decommissioning. Preparations include the planning for permanent defueling of the reactor, revision of technical specifications applicable to the operating conditions and requirements, characterization of the facility and major components, and the development of the Post Shutdown Decommissioning Activities Report (PSDAR).
Following the final shutdown and defueling, the site will be prepared to minimize operation and maintenance to those systems/components/areas that are required to support the safe handling and management of spent fuel. Those systems/components that will not be required will be isolated and removed from service. Radiation controls will be put in place to reduce radiation and contamination in areas that will need to be accessed to support decommissioning. Areas not needed will have access restricted to minimize radiation/contamination exposure and potential safety hazards. ISFSI expansion will occur and spent fuel in the spent fuel storage pool will be transferred to the ISFSI. The security area will be adjusted to reflect protection of equipment and areas necessary to support the safe handling and management of spent fuel.
2.2.1.2. Period 2 - Dormancy Phase The second phase identified by the NRC in its rule addresses licensed activities during a storage period and is applicable to the dormancy phase of the Shortened SAFSTOR scenario. Dormancy activities include a 24-hour security force, preventive and corrective maintenance on security systems, maintenance of necessary area lighting, general building maintenance, heating and ventilation of buildings, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program. Resident maintenance personnel will perform maintenance and inspection activities to maintain safe conditions. The transfer of the spent fuel from the spent fuel pool to the ISFSI continues during this period until complete.

Page 4 of 22 DECOM-2021-DCE-NMP Rev. 0

2.2.1.3. Period 3 - Site Reactivation and Decommissioning Preparations Prior to the commencement of decommissioning operations, preparations are undertaken to reactivate site services and prepare for decommissioning. Preparations include engineering and planning, a detailed site characterization, and the assembly of a decommissioning management organization. Final planning for decommissioning activities and the writing of work packages, activity specifications and decommissioning procedures are initiated. The environmental impact associated with the planned decommissioning activities is also considered. If the consequences of a planned decommissioning activity are predicted to be greater than what is bounded by previously evaluated environmental assessments or impact statements, a license amendment would have to be submitted to the NRC for the specific activity and the environmental report would have to be updated.
2.2.1.4. Period 4 - Decommissioning Operations This period includes the physical decommissioning activities associated with the removal and disposal of contaminated and activated components and structures. Existing facilities will be modified, and/or temporary facilities will be constructed to support decommissioning, decontamination, and dismantling activities. Components and piping systems will be decontaminated as necessary to control (minimize) worker exposure and facilitate packaging and transportation. Piping and components no longer essential to support decommissioning operations will be removed. The reactor internal and external components will be removed. Some larger Nuclear Steam Supply System (NSSS) components may be decontaminated and sealed in such a manner as to serve as their own shipping/burial containers. The reactor will be segmented, removed, and placed in shielded casks. Activated portions of the reactor and other biological shield walls will be demolished by controlled processes.
The License Termination Plan (LTP), which includes the Final Survey Plan, is developed and submitted to the NRC. Once the survey is complete, the results are provided to the NRC for their review and evaluation. Once the NRC approves the LTP, the final remediation of site facilities and services may start. Subsequently, the NRC independently confirms the radiological site conditions and approves a license amendment that releases the property, excluding the ISFSI, for unrestricted use.
2.2.1.5. Period 5 - Site Restoration Following completion of decommissioning operations, site restoration activities will begin.
Remaining structures are removed, exterior walls and foundations are removed to a nominal depth of three feet below grade, and non-contaminated concrete rubble produced by demolition activities is processed and then used to backfill foundation voids. The plant area is graded and vegetation is established to inhibit erosion.
2.2.1.6 Period 6 - ISFSI Operations and Decommissioning Following Site Restoration, the Spent Fuel which remains on the ISFSI pad is transferred to the Department of Energy for final disposition. Once the fuel has been transferred, the ISFSI pad and support structures are demolished, the site is restored, and the license is terminated.

Page 5 of 22 DECOM-2021-DCE-NMP Rev. 0
: 3. COST ESTIMATE METHODOLOGY

3.1. METHODOLOGY BASES The systematic approach used herein for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting costs. The costs and schedules follow the general guidance and sequence in Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors (Reference 7.1). The format and content of the estimates is consistent with the recommendations of Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Reference 7.2). The methodology used to develop the estimates follows the basic approach originally presented in the AIF/NESP-036 study report, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates" (Reference 7.3) and the DOE "Decommissioning Handbook" (Reference 7.4).
The unit cost factors used in this analysis incorporate site-specific costs and the latest available information about worker productivity in decommissioning. The detail provided in the unit cost factors, including activity duration, labor costs (by craft), and equipment and consumable costs, ensures that essential elements have not been omitted. The activity-dependent costs were estimated with the item quantities based on plant drawings and inventory documents. Removal rates and material costs for the conventional disposition of components and structures are based on cost data from RSMeans (Reference 7.5).
Critical path was used to determine the total decommissioning program schedule and establish carrying costs, which include program management, administration, field engineering, equipment rental, quality assurance, and security.

3.2. FINANCIAL COMPONENTS OF THE COST MODEL The cost model used provides distinct cost elements, however these distinct cost elements do not comprise the total estimated cost to accomplish the project goal. Additional factors as described below are also taken into consideration.
3.2.1. Contingency Contingencies are necessary to provide assurance that sufficient funding will be available since the cost elements are based on ideal conditions and maximum efficiency. They are an integral part of the total cost to complete the decommissioning process and are expected to be fully expended. A contingency is then applied on a line-item basis. Contingency, in this analysis, is not intended to address changes in price escalation and inflation in the cost of decommissioning over the remaining operating life of the station, or duration of the decommissioning program and dry fuel storage period.
Constellation examined the major activities (decontamination, segmentation, equipment handling, packaging, transport, and waste disposal) that necessitate a contingency. Individual activity contingencies ranged from 10% to 75%, depending on the degree of difficulty judged to be appropriate. The contingency values used in this study are as follows:

Page 6 of 22 DECOM-2021-DCE-NMP Rev. 0

Engineering 15%
Staffing - Utility and DOC Staff 15%
Decontamination 50%
Contaminated Removal (includes contaminated component removal and 25%
contaminated concrete removal)
NSSS Component Removal 25%
Reactor Segmentation 75%
Reactor Waste Packaging 25%
Reactor Waste Transport 25%
Reactor Vessel Component Disposal 50%
Contaminated Component Packaging 10%
Contaminated Component Transport 15%
Low-Level Radioactive Waste Disposal 25%
Non-Radioactive Component Removal 15%
Supplies 25%
GTCC Disposal 25%
Other - includes: Operations and Maintenance Expense, Heavy 15%
Equipment and Tooling, and Construction Energy 15%
Characterization, Licensing and Termination Surveys 30%
Taxes, Fees, and Insurance 10%
Spent Fuel Transfer Costs 15%
ISFSI Decommissioning 25%
Low-Level Radioactive Waste Processing 15%

3.2.2. Financial Risk This cost study does not include any specific costs for financial risk since there is insufficient historical data from which to project future liabilities. Consequently, the areas of uncertainty or risk are revisited periodically and addressed through repeated revisions or updates of the base estimates.
3.2.3. Work Difficulty Factors Work difficulty factor (WDF) adjustments have been applied to account for the inefficiencies in working in a power plant environment. WDFs were assigned to each unique set of unit factors, commensurate with the inefficiencies associated with working in confined and/or hazardous environments. The study applies WDFs to account for use of radiological dose minimization practices (e.g., radiological protection instruction, mock-up training, and use of respiratory protection and protective clothing). Changes to worker exposure limits may also impact the decommissioning cost and project schedule.
The factors and their associated range of values were developed in conjunction with the process described in AIF/NESP-036 (Reference 7.3).

Page 7 of 22 DECOM-2021-DCE-NMP Rev. 0

3.2.4. Scheduling Program Durations The WDF adjusted unit factors are applied against the inventory of materials to be removed in the radiologically controlled areas. The resulting work hours are used to develop the decommissioning program schedule. The scheduling of conventional removal and dismantling activities are based upon productivity information from RSMeans (Reference 7.5). Dismantling of the fuel handing systems and decontamination of the spent fuel pools is dependent upon the timing of the transfer of the spent fuel assemblies to the ISFSI.
The program schedule is used to determine the period-dependent costs for program management, administration, field engineering, equipment rental, contracted services, etc. The study relies upon regional or site-specific salary and wage rates for the personnel associated with the intended program.

Page 8 of 22 DECOM-2021-DCE-NMP Rev. 0
: 4. ASSUMPTIONS

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

4.1. GENERAL 4.1.1. Energy The physical plant is assumed to be de-energized, except for those facilities associated with spent fuel storage. Minimal energy usage is assumed to support remaining plant staffing. Additional energy is required during active decommissioning.
4.1.2. Emergency Planning Federal Emergency Management Agency (FEMA) and state and local fees associated with emergency planning are assumed to continue through the end of the Zirc fire window following the cessation of operations.
4.1.3. Insurance Costs for continuing coverage (nuclear liability and property insurance) following cessation of plant operations and during decommissioning are included and based upon current operating premiums, and subsequent reductions based on regulatory requirements.
4.1.4. Taxes Property taxes are included for all decommissioning periods. Tax payments decrease during decommissioning until reaching a minimum property tax payment for the site; this level is maintained for the balance of the decommissioning program.
4.1.5. NRC Fees NRC charges are included to support the decommissioning program. The license fee is reduced based on the NRC fees for a reactor in a decommissioning (possession-only status). The charges associated with NRC professional services for inspections and reviews are based on the NRC hourly rate and the anticipated level of participation commensurate with the decommissioning alternative and schedule.
4.1.6. Contaminated Soil The estimate includes an allowance for the remediation of contaminated soil at the site as documented in the 10 CFR 50.57(g) file. This portion of the estimate may be affected by continued plant operations and/or future regulatory actions.
4.1.7. Impact of Decommissioning Multi-Unit Sites For sites that have more than one unit on a site, there can be opportunities to achieve economies of scale by sharing costs between units and coordinating the sequence of work activities. This is true for Nine Mile Point Nuclear Station. The work associated with developing activity specifications and procedures are essentially identical between units, therefore costs associated with additional units are less than the first.

Page 9 of 22 DECOM-2021-DCE-NMP Rev. 0

There will also be schedule constraints, particularly where there are requirements for specialty equipment and staff, or practical limitation on when final status surveys can take place. There may also be common systems that reduce the overall site scope and cost. All of these aspects of a multi-unit site are factored into the work planning and associated costs for NMP Unit 1.

4.2. LABOR COSTS For purposes of this analysis, it is assumed that Constellation will hire a Decommissioning Operations Contractor (DOC) to manage the decommissioning. Constellation will provide site security, radiological health and safety, quality assurance and overall site administration during the decommissioning and demolition phases. Constellation provides the total site scope during planning, transition periods, and dormancy periods. Contract personnel will provide engineering services under the direction of Constellation.
Average Constellation labor costs are based on industry wide average salaries. Craft labor rates are based on the current Constellation craft labor contract. DOC labor costs were based on industry wide average salaries. All costs include adders for pension and benefits, payroll taxes, corporate overhead, per diems, and profit where applicable. All labor costs are adjusted to account for regional differences between the sites. A profile of the projected staffing level for decommissioning is provided in Figure 4.1

4.3. TRANSITION ACTIVITIES Those systems and components that are not needed for the safe storage and handling of spent fuel will be removed from service and deactivated. Hazardous fluids will be drained and removed from retired plant equipment. Operating waste inventories will be processed by plant staff during the transition period.
Operation and maintenance costs for the spent fuel pool(s) are included within the estimates until the spent fuel has been transferred to the ISFSI.
The perimeter fence and in-plant security barriers will be moved, as appropriate, to conform to the Site Security Plan in force during the various stages of the project.

4.4. NON-RADIOACTIVE WASTE 4.4.1. Processed Water It is assumed that all water released will meet the state and federal release limits. These estimates assume that processed water which meets state and federal release limits is disposed of without additional cost.
4.4.2. Asbestos Abatement An allowance for the removal of asbestos has been added to the estimates to account for the removal and disposal costs.
4.4.3. Scrap and Salvage Metallic material generated is processed to the greatest extent possible to reduce the total cost of controlled disposal. Material meeting the regulatory and/or site release criterion, is released as scrap, requiring no further cost consideration.

Page 10 of 22 DECOM-2021-DCE-NMP Rev. 0

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

4.5. RADIOACTIVE WASTE The objectives of the decommissioning process are the removal of all radioactive material from the site that would restrict its future use and the termination of the NRC license. Most of the materials being transported for controlled burial are categorized as Low Specific Activity (LSA) or Surface Contaminated Object (SCO) materials containing Type A quantities of radioactive material.
The waste material generated in the decontamination and dismantling of the site is primarily generated during Period 4. Material that is considered potentially contaminated is sent to processing facilities in Tennessee for conditioning and disposal. Heavily contaminated components and activated materials are routed for controlled disposal.

The volumes of radioactive waste generated during the various decommissioning activities are calculated based on the container size and are summarized consistent with 10 CFR 61 classifications. Table 4.1 provides the radwaste volumes by class expected to be generated during decommissioning.
4.5.1. Low-Level Radioactive Waste Disposal A significant portion of the waste material may only be potentially contaminated by radioactive materials. This waste can be analyzed on site or shipped off site to licensed facilities for further analysis, for processing and/or for conditioning/recovery. The estimates reflect the savings from waste recovery/volume reduction when feasible.
All options and services currently available to Constellation were taken into consideration regarding the disposition of the various waste streams produced by the decommissioning process. Disposal fees are calculated using representative costs. The disposal costs for Class A, B and C waste were based upon a representative Constellation fleet cost. Class A waste is assumed to be disposed of at a facility in Utah. This facility is not licensed to receive Class B and C wastes. Class B and C waste is assumed to be disposed of at a facility in Texas.
The waste volumes are calculated based on the exterior package dimensions for containerized material or a specific calculation for components serving as their own waste containers.
4.5.2. Greater Than Class C Radioactive Waste The dismantling of the components residing closest to the reactor core generally generates radioactive waste considered unsuitable for shallow-land disposal (i.e., low-level waste with concentrations greater than the NRC limits for Class C waste (i.e., GTCC)). A small quantity of material generated during decommissioning will be GTCC waste; GTCC waste is expected to be a small percentage of the total waste volume. GTCC waste is assumed to be placed in spent fuel storage canisters and disposed of in a similar manner to that envisioned for spent fuel disposal.
The federal government has the responsibility for the disposal of this material. However, the federal government has not identified a cost for disposing of GTCC, a schedule for acceptance, nor acceptance criteria for this material. For purposes of this analysis, the GTCC radioactive waste is assumed to be packaged and disposed of in a similar manner as high-level waste and at a cost equivalent to that envisioned for the spent fuel.

Page 11 of 22 DECOM-2021-DCE-NMP Rev. 0

GTCC canisters will remain in storage until such time the DOE is ready to accept GTCC waste; it is assumed that the DOE would not accept this waste prior to completing the transfer of spent fuel.
4.5.3. Transportation Methods The transport of all waste material and components will be by a combination of truck and/or multi-wheeled transporter. Transportation costs for material requiring controlled disposal or processing are based upon the mileage to the respective disposal or processing site.

4.6. COMPONENT REMOVAL 4.6.1. Reactor Vessel and Internal Components The curie contents of the reactor vessel and internals are derived from those listed in NUREG/CR-3474, "Long-Lived Activation Products in Reactor Materials," (Reference 7.6) and are based on a generic model for the reactor design. Additional short-lived isotopes were derived from NUREG/CR-0130, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," (Reference 7.7) and NUREG/CR-0672, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," (Reference 7.7) and benchmarked to the long-lived values from NUREG/CR-3474 (Reference 7.6).
The reactor pressure vessel and internal components are assumed to be segmented for disposal in shielded, reusable transportation casks. Transportation cask specifications and transportation regulations dictate the segmentation and packaging methodology. Due to the uncertainty in the viability of disposing of the reactor vessel and internals as a self-contained package, segmentation is assumed as a bounding condition.
The disposal cost for the control blades removed from the vessel with the final core load are included within the estimates. Control blades are not Greater than Class C (GTCC) material.
4.6.2. System Components Reactor piping and other NSSS components will be removed. Specialized equipment will be brought in as necessary. With proper closure of all openings, access ways, and penetrations, some larger components may be used as their own shipping and burial containers.
Radioactive piping and components will be removed using methods appropriate with their potential contamination level. Non-contaminated piping and components will be removed using conventional dismantlement and removal processes.
Components will be packaged and readied for transport in accordance with the intended disposition.
4.6.3. Retired Components Any components that have been replaced and where the original components are stored on site at the time of shutdown are included in the cost of decommissioning. Since the components have already been removed from the plant, only packaging, disposal, and transportation costs are included for the components.

Page 12 of 22 DECOM-2021-DCE-NMP Rev. 0

4.7. SPENT FUEL MANAGEMENT Since the DOE is ultimately responsible for spent fuel disposal, the cost to dispose of spent fuel is not reflected within the estimates. However, the costs for spent fuel management while the fuel remains onsite are included and identified separately as "Spent Fuel Management.
Constellation assumes, for the purposes of this estimate, that the spent fuel will be packaged into multi-purpose containers (MPCs) over the first 3 to 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 estimates include the cost for the labor and equipment to transfer and load each MPC and relocate it to the ISFSI. For estimating purposes, an allowance is used to estimate the cost to transfer the fuel containers from the ISFSI onto the transport vehicle.
Given the status of the DOE spent fuel program, Constellation estimates that 2035 will be the most likely year when the DOE begins spent fuel removal from the industry. Constellation assumed that the DOEs repository will have a maximum annual capacity of receiving 3,000 metric tons of uranium from the industry (Reference 7.9) and that the repository will accept spent fuel in the order in which it was removed (oldest fuel first). Additionally, Constellation assumes that it is able to re-assign its DOE spent fuel allocations between its large fleet of units to minimize on-site storage costs.
Based on the above, the spent fuel is projected to remain onsite until the end of 2073. Any delay in transfer of fuel to DOE or decrease in the rate of acceptance will result in spent fuel remaining at the site longer.

4.8. INDEPENDENT SPENT FUEL INSTALLATION 4.8.1. Construction, Operation and Maintenance An ISFSI has been constructed on site to support storage of all spent fuel. Expansion of the ISFSI is modeled to support the transfer of all the fuel in the SFP to the ISFSI. The ISFSI will continue to operate until such time that the transfer of spent fuel to the DOE can be completed. Operation and maintenance costs for the ISFSI are included as "Spent Fuel Management" expenditures in the estimates.
4.8.2. ISFSI Decommissioning The ISFSI site and associated facilities also must have a proposed decommissioning plan. The cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities, 2) an adequate contingency factor (see Section 3.2.1),
and 3) the cost of meeting the criteria for unrestricted use.

4.9. SITE RESTORATION The cost for the site restoration of non-contaminated structures has been calculated and is separately presented as "Site Restoration expenditures in this report.
While some structures may be dismantled, and the costs included in the decontamination process, the dismantlement of the remaining site structures are included in the site restoration costs. All structures are assumed to be removed to a nominal depth of three feet below grade and the voids backfilled with clean debris then topped with soil. Bulk excavation of soil and material in the immediate vicinity of the reactor building is included to remove various duct banks, catch

Page 13 of 22 DECOM-2021-DCE-NMP Rev. 0

basins, and underground utilities that may exist. The site will then be graded to conform to the adjacent landscape and vegetation is established to inhibit erosion.
Site utility and service piping are abandoned in place and manholes are backfilled. Asphalt surfaces and facility roads, except for the site access road, will be broken up and the material used as backfill on site.
The existing electrical switchyard is assumed to remain functional in support of the regional electrical distribution system.
Site restoration costs are included in all estimates for completeness but may not be a required activity at all sites.

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

Page 14 of 22 DECOM-2021-DCE-NMP Rev. 0

Figure 4-1: Total Labor Hours

Page 15 of 22 DECOM-2021-DCE-NMP Rev. 0

Table 4-1: Burial Volumes by Waste Category

Class / Type Volume (cf) Mass (lb)

A / Bulk 116,590 5,548,352

A / Containerized 197,731 10,251,088

A / DAW 26,849 536,974 A / Lead 353 250,000

A/ Oil 2,005 125,175

A / Processed 361,620 14,993,313

B 2,224 342,699

B / Resin 2,622 173,042

C 840 129,346

GTCC 2,534 518,021

Total / Disposal 713,368 32,868,010

Page 16 of 22 DECOM-2021-DCE-NMP Rev. 0
: 5. SCHEDULE

5.1. SCHEDULE ASSUMPTIONS The schedules for the decommissioning scenarios follow the sequence presented in the AIF/NESP-036 study, with minor changes to reflect recent experience and site-specific constraints. In addition, the scheduling has been revised to reflect spent fuel management plans.
The work activity durations are based on adjusted actual person-hour estimates. Durations are established between several milestones in each decommissioning period; these durations are used to establish a critical path for the entire project. In turn, the critical path duration for each period is used as the basis for determining the period-dependent costs. A second critical path is also used for the spent fuel cooling period, which determines the release of the spent fuel building for final decontamination. The project schedule is included in Table 5-1.

Table 5-1: Decommissioning Timeline

Approximate Plant Status / Decommissioning Activities Start End Duration (years)
Pre-Shutdown Pre-Shutdown Planning Aug 2027 Aug 2029 2.0

Preparations for Dormancy Plant Shutdown / Defueling Outage Aug 2029 Aug 2029 0.1 System Abandonments and Fuel Transfer to ISFSI Sept 2029 Aug 2034 4.8 Final System Abandonments Sept 2034 June 2035.7

Dormancy Dormancy w/ Dry Fuel Storage June 2035 Dec 2059 24.5

Preparations for D&D Dec 2059 June 2060 0.5

Decommissioning Operations Large Component Removal June 2060 Jan 2064 3.6 Plant Systems Removal and Building Decontamination Jan 2064 Jan 2066 2.0 License Termination Jan 2066 Oct 2066 0.8

Total from Shutdown to Completion of 37 License Termination

Site Restoration Nov 2066 May 2069 2.5

ISFSI Operation and Decommissioning ISFSI Operation (Post License Termination) Nov 2066 Jul 2069 2.7 Fuel Shipping Aug 2069 Dec 2073 4.4 ISFSI Decontamination and License Termination Jan 2074 Sept 2074.7 ISFSI Site Restoration Sept 2074 Nov 2074.2

Page 17 of 22 DECOM-2021-DCE-NMP Rev. 0
: 6. COST ESTIMATE

The estimate presented in this document reflects the total cost to decontaminate the nuclear unit, manage the spent fuel until the DOE transfers it to a federal facility, dismantle the plant, and restore the site for alternative use. Costs are not inflated, escalated, or discounted over the period of expenditure (or projected lifetime of the plant).
Table 6.1 summarizes the estimated costs for the Shortened SAFSTOR scenario reflecting the various cost elements. Table 6.2 provides yearly expenditures broken down by cost contributor.

Page 18 of 22 DECOM-2021-DCE-NMP Rev. 0

Table 6-1: Shortened SAFSTOR Alternative for Nine Mile Point Unit 1 (thousands, June 2021 dollars)

Cost Element Total Decontamination 23,930 Removal 164,032 Packaging 27,354 Transportation 15,385 Waste Disposal 88,870 Waste Processing 11,191 Program Management1 349,224 Security 114,115 Spent Fuel Storage 130,789 Insurance and Regulatory Fees 45,602 Energy 15,805 Characterization and Licensing Surveys 10,183 Property Taxes 80,088 Miscellaneous Equipment and Supplies 37,013 Total2 1,113,582

Cost Element Total Radiological Decommissioning 803,828 Spent Fuel Management 232,390 Site Restoration 63,789 ISFSI Radiological Decommissioning 7,215 Radiological Decommissioning Planning 6,359 Total2 1,113,582

1 Includes engineering costs.

2 Columns may not add up due to rounding.

Page 19 of 22 DECOM-2021-DCE-NMP Rev. 0

Table 6-2: Total Annual Expenditures

Spent Fuel Site ISFSI Radiological Radiological Year Radiological Decommissioning Management Restoration Decommissioning Decommissioning Total Planning 2027 0 0 0 0 1,111 1,111 2028 0 0 0 0 3,057 3,057 2029 15,435 34,865 32 0 2,191 52,524 2030 36,132 53,006 57 0 0 89,196 2031 26,160 2,042 19 0 0 28,221 2032 26,232 7,579 19 0 0 33,830 2033 26,160 18,453 19 0 0 44,632 2034 20,317 12,965 48 0 0 33,331 2035 5,610 2,042 44 0 0 7,696 2036 3,426 2,047 0 0 0 5,473 2037 3,417 2,042 0 0 0 5,458 2038 3,417 2,042 0 0 0 5,458 2039 3,417 2,042 0 0 0 5,458 2040 3,426 2,047 0 0 0 5,473 2041 3,417 2,042 0 0 0 5,458 2042 3,417 2,042 0 0 0 5,458 2043 3,417 2,042 0 0 0 5,458 2044 3,426 2,047 0 0 0 5,473 2045 3,417 2,042 0 0 0 5,458 2046 6,282 2,042 0 0 0 8,324 2047 20,553 2,042 0 0 0 22,594 2048 19,663 2,047 0 0 0 21,710 2049 14,264 2,042 0 0 0 16,306 2050 10,006 2,042 0 0 0 12,048 2051 4,516 2,042 0 0 0 6,557 2052 4,528 2,047 0 0 0 6,575 2053 4,516 2,042 0 0 0 6,557 2054 4,516 2,042 0 0 0 6,557 2055 4,516 2,042 0 0 0 6,557 2056 4,528 2,047 0 0 0 6,575 2057 4,516 2,042 0 0 0 6,557 2058 4,516 2,042 0 0 0 6,557 2059 6,643 2,042 6 0 0 8,691

Page 20 of 22 DECOM-2021-DCE-NMP Rev. 0

Table 6-2: Total Annual Expenditures (cont)
(thousands, June 2021 dollars)

Spent Fuel Site ISFSI Radiological Year Radiological Decommissioning Management Restoration Radiological Decommissioning Total Decommissioning Planning 2060 72,297 2,047 141 0 0 74,486 2061 82,610 2,042 125 0 0 84,777 2062 82,610 2,042 125 0 0 84,777 2063 82,610 2,042 125 0 0 84,777 2064 72,594 2,047 2,220 0 0 76,861 2065 71,516 2,042 2,394 0 0 75,952 2066 19,435 2,357 3,895 0 0 25,687 2067 0 3,928 22,114 0 0 26,042 2068 0 3,939 22,174 0 0 26,113 2069 1,550 4,898 7,328 0 0 13,776 2070 3,698 6,252 0 0 0 9,950 2071 3,698 6,252 0 0 0 9,950 2072 3,708 6,269 0 0 0 9,977 2073 3,698 6,252 0 0 0 9,950 2074 0 0 2,901 7,215 0 10,116

Total1 803,828 232,390 63,789 7,215 6,359 1,113,582

1 Columns may not add up due to rounding.

Page 21 of 22 DECOM-2021-DCE-NMP Rev. 0
: 7. REFERENCES

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

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

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

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

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

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

7.7. NUREG/CR-0130 and addenda, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," Pacific Northwest Laboratory for the Nuclear Regulatory Commission, June 1978, R.I. Smith, G.J. Konzek, W.E. Kennedy, Jr.

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

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

Page 22 of 22 Attachment 2 Irradiated Fuel Management Plan for Nine Mile Point Nuclear Station, Unit 1 Irradiated Fuel Management Plan for Nine Mile Point Nuclear Station, Unit 1

===1. Background===
The Nine Mile Point Nuclear Station, Unit 1 (NMP1) operating license expires on August 22, 2029.
Constellation Energy Generation (CEG) has not made a final determination of the decommissioning approach for NMP1. For purposes of this Irradiated Fuel Management Plan (IFMP), the Shortened SAFSTOR option has been selected. In this Shortened SAFSTOR scenario, active decommissioning is deferred as long as possible before ultimately terminating the Unit 1 Lice nse approximately 37 years after shutdown.
In accordance with Joint Proposal with the New York Department of Public Ser vice (NYPSC) (Reference 4), NMP1 is projected to be decommissioned 20 years after the shutdown of Unit 2. CEG reserves the right to choose an alternative decommissioning option at the actual time of decommissioning in accordance with its business needs, recognizing that it needs to assure the chosen option meets U.S. Nuclear Regulatory Commission (NRC) requirements for decommissioning funding and the requirements of the Joint Proposal with the NYPSC.
In order to estimate the costs associated with maintenance of the NMP1 site in Shortened SAFSTOR and the eventual decommissi oning of the site, at the time of the estimate, CEG assumed 2035 as the first ye ar that the U.S. Department of Energy (DOE) will begin removing spent nuclear fu el from nuclear power reactor sites.
Pursuant to the Nuclear Waste Policy Act (Reference 2), the Federal government has the responsibility to remove all spent fuel from NMP1 and other commercial nuclear power reactor sites. However, the DOE spent fuel and high-level waste management program is currently stalled. Given the status of the DOE program, Constellation considered information made publicly available in 2021 when the cost estimate was performed by DOE, the Government Account ability Office (GAO), the Blue Ribbon Commission on America's Nuclear Future, and the political environment surrounding this issue, and concluded that 2035 was the mo st likely timeframe for DOE to initiate removal of commercial nuclear fuel from re actor sites. This date does change over time as new information becomes available and any changes would be incorporated into the cost estimate the next time it is updated.
: 2. Spent Fuel Management Strategy The NRC requires (as discussed in 10 CFR 50.54(bb)) that licensees establish a program "to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the Se cretary of Energy for its ultimate disposal in a repository." Pending tr ansfer of the fuel to the DOE [Secretary of Energy], Constellation will store fuel on an interim basis in the spent fuel pool and/or the Independent Spent Fuel Storage Installation (I SFSI) located at the NMP site.
A licensed ISFSI is currently operational at NMP. The ISFSI facility will be expanded to accommodate the inventory of spent fuel in the spent fuel pool following the final reactor defueling. After the required cooling time, the spent fuel will be loaded in fuel storage canisters and moved to the ISFSI. On ce the spent fuel pool is emptied of fuel,

Page 1 of 3 the facility will be placed in a SAFSTOR co ndition. Active decommissioning will begin approximately 30 years after shutdown so that Nine Mile Point Unit 1 will be fully decommissioned 20 years after the shutdown of Unit 2. The ISFSI will continue to operate after decommissioning until the transfer of spent fuel to the DOE is complete.
Assuming the DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority and that the DOE begins removing spent fuel from commercial facilities in 2035 with an annual capacity of 3,000 metric tons of uranium, spent fuel is projected to remain at the NMP site for approximately 44 years after the termination of operation (spent fuel is projected to be removed from the NMP site by the end of 2073). 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.
Operation and maintenance costs for the stor age facilities (ISFSI and spent fuel pool) are reflected in the NMP1 Decommissioning Cost Estimate (DCE) (Reference 1) and include the costs for staffing the facilities, maintenance of necessary operational requirements as well as security, insurance, and licensing fees. The estimate includes the costs to purchase, load, and transfer the fuel storage canisters to the ISFSI and to decommission the ISFSI. A discussion of site-specific considerations for the management of spent fuel at NMP1 is included in the DCE report.
When NMP1 terminates operations in 2029, NM P1 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 NMP1 spent fuel pool and ISFSI, as necessary, under the decommission ing scenario ultimately sel ected. In addition, NMP1 will also comply with ap plicable license termination requirements in accordance with 10 CFR 50.82, "Terminati on of license," with respect to plant shutdown and post-shutdown activities, including seeking NRC approvals as appropriate for the continued storage of irradiat ed fuel until transfer of the fuel to the DOE is complete.
: 3. Cost Estimate and Funding for Spent Fuel Management Total costs for spent fuel management under the SAFSTOR scenario will be approximately $232.4 million (2021 dollars). Further breakdown is included in the DCE (Reference 1).
As of December 31, 2023, the NMP1 decommissioning trust fund balance was $ 833.1 million. At this time, there are no annual contributions to the fund, and none are anticipated through the decommissioning peri od. To the extent that the trust fund balance exceeds costs required for radiological decommissioning, trust fund monies (subject to receipt of NRC approval of an exemption as discussed in Section 4), in conjunction with Constellation operating revenues, will be used to pay for spent fuel management costs.
An additional potential source of funding for NMP1 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 NMP (Reference 3).

Page 2 of 3
: 4. NRC Approvals This IFMP contemplates potential withdrawals from the decommissioning trust for spent fuel management purposes. Prior to any such withdrawals, in accordance with 10 CFR 50.12, "Specific exemptions," CEG will make appropriate submittals seeking an exemption from the requirements of 10 CF R 50.82(a)(8)(i)(A) in order to use the decommissioning trust funds for spent fuel management expenses. CEG will monitor the funding level of the decommissioning fund to ensure that spent fuel management withdrawals will not inhibit the ability of CEG to complete radiological decommissioning.
: 5. References
: 1. Report DECOM-2021-DCE-NMP, Revision 0, "2021 Decommissioning Cost Analysis Report Nine Mile Point Nuclear Station-Unit 1," August 2022
: 2. United States of America Public Law 97-425, "Nuclear Waste Policy Act of 1982,"
dated January 7, 1983
: 3. Settlement Agreement between the U.S. Department of Energy, Nine Mile Point Nuclear Station, LLC, and Constellation E nergy Nuclear Group, LLC, signed and executed December 20, 2012, as amended by the Addendum to the Settlement Agreement signed January 2014, as amended by the Addendum to the Settlement Agreement signed May 2017, as amended by the Addendum to the Settlement Agreement signed September 2020, as amended by the Addendum to the Settlement Agreement signed March 2023
: 4. Joint Proposal by and Among Exelon Corporation, Exelon Generation Company, LLC, Staff of the New York State Department of Public Service, New York State Office of the Attorney General, and Alliance for a Green Economy, Case 21-E-0130, dated November 23, 2021 (Exelon Generation Company, LLC renamed Constellation Generation Company, LLC fo llowing a February 1, 2022, corporate restructuring and spin-off)

Page 3 of 3 Attachment 3 Decommissioning Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 Decommissioning Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 (thousands of January 2024 dollars)

Radiological IS F S I BO Y Tr ust BO Y Tr ust Tr ust Fund EO Y Tr u st Year De com m issioning De com m issioning To t al C o st(a) Fund Value Fund L e ss Cost Ear n in gs(b) Fund Value (a)
Cost Cost 2027 (c)(d) 1,235 0 1,235 884,087 882,852 17,657 900,509 2028 (c) 3,397 0 3,397 900,509 897,112 17,942 915,054 2029 19,588 0 19,588 915,054 895,467 17,909 913,376 2030 40,153 0 40,153 913,376 873,223 17,464 890,688 2031 29,071 0 29,071 890,688 861,617 17,232 878,849 2032 29,151 0 29,151 878,849 849,698 16,994 866,692 2033 29,071 0 29,071 866,692 837,621 16,752 854,373 2034 22,578 0 22,578 854,373 831,796 16,636 848,432 2035 6,234 0 6,234 848,432 842,198 16,844 859,042 2036 3,807 0 3,807 859,042 855,234 17,105 872,339 2037 3,797 0 3,797 872,339 868,542 17,371 885,913 2038 3,797 0 3,797 885,913 882,116 17,642 899,759 2039 3,797 0 3,797 899,759 895,962 17,919 913,881 2040 3,807 0 3,807 913,881 910,074 18,201 928,276 2041 3,797 0 3,797 928,276 924,479 18,490 942,968 2042 3,797 0 3,797 942,968 939,171 18,783 957,955 2043 3,797 0 3,797 957,955 954,158 19,083 973,241 2044 3,807 0 3,807 973,241 969,434 19,389 988,823 2045 3,797 0 3,797 988,823 985,026 19,701 1,004,726 2046 6,981 0 6,981 1,004,726 997,745 19,955 1,017,700 2047 22,840 0 22,840 1,017,700 994,860 19,897 1,014,758 2048 21,851 0 21,851 1,014,758 992,906 19,858 1,012,764 2049 15,851 0 15,851 1,012,764 996,913 19,938 1,016,851 2050 11,120 0 11,120 1,016,851 1,005,731 20,115 1,025,846 2051 5,018 0 5,018 1,025,846 1,020,828 20,417 1,041,244 2052 5,032 0 5,032 1,041,244 1,036,212 20,724 1,056,936 2053 5,018 0 5,018 1,056,936 1,051,918 21,038 1,072,956 2054 5,018 0 5,018 1,072,956 1,067,938 21,359 1,089,297 2055 5,018 0 5,018 1,089,297 1,084,278 21,686 1,105,964 2056 5,032 0 5,032 1,105,964 1,100,932 22,019 1,122,951 2057 5,018 0 5,018 1,122,951 1,117,932 22,359 1,140,291 2058 5,018 0 5,018 1,140,291 1,135,273 22,705 1,157,978 2059 7,382 0 7,382 1,157,978 1,150,596 23,012 1,173,608 2060 80,342 0 80,342 1,173,608 1,093,265 21,865 1,115,131 2061 91,803 0 91,803 1,115,131 1,023,328 20,467 1,043,794 2062 91,803 0 91,803 1,043,794 951,991 19,040 971,031

Page 1 of 2 Decommissioning Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 (thousands of January 2024 dollars)
(continued)

Radiological IS F S I BO Y Tr ust BO Y Tr ust Tr ust Fund EO Y Tr u st Year De com m issioning De com m issioning To t al C o st(a) Fund Value Fund L e ss Cost Ear n in gs(b) Fund Value (a)
Cost Cost 2063 91,803 0 91,803 971,031 879,228 17,585 896,813 2064 80,672 0 80,672 896,813 816,141 16,323 832,464 2065 79,474 0 79,474 832,464 752,989 15,060 768,049 2066 21,598 0 21,598 768,049 746,451 14,929 761,380 2067 (e) 0 0 0 761,380 761,380 15,228 776,608 2068 (e) 000 776,608 776,608 15,532 792,140 2069 1,723 0 1,723 792,140 790,417 15,808 806,226 2070 4,109 0 4,109 806,226 802,117 16,042 818,159 2071 4,109 0 4,109 818,159 814,050 16,281 830,331 2072 4,120 0 4,120 830,331 826,211 16,524 842,735 2073 4,109 0 4,109 842,735 838,626 16,773 855,398 2074 0 8018 8,018 855,398 847,381 16,948 864,328 To ta l s (a) 900,341 8,018 908,359

(a) Cash flows may not add due to rounding (b) A 2% real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)
(c) 2027 and 2028 costs are for decommissioning planning (d) The 2027 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2027 decommissioning planning expenses (e) 2067 and 2068 show zero cost since all costs in these years are for spent fuel management and site restoration.

Page 2 of 2 Attachment 4 Decommissioning and Spent Fuel Management Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 Decommissioning and Spent Fuel Management Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 (thousands of January 2024 dollars)

De com m issioning Spe nt Fue l BO Y Tr ust BO Y Tr ust Tr ust Fund EO Y Tr u st Year Cost (Radiological Manage m e nt Cost To t al C o st(a) Fund Value Fund L e ss Cost Ear n in gs(b) Fund Value (a) an d ISF SI) 2027(c)(d) 1,235 0 1,235 884,087 882,852 17,657 900,509

2028 (c) 3,397 0 3,397 900,509 897,112 17,942 915,054 2029 19,588 38,745 58,333 915,054 856,722 17,134 873,856 2030 40,153 58,905 99,057 873,856 774,799 15,496 790,295 2031 29,071 2,269 31,340 790,295 758,955 15,179 774,134 2032 29,151 8,423 37,574 774,134 736,560 14,731 751,292 2033 29,071 20,506 49,577 751,292 701,714 14,034 715,749 2034 22,578 14,408 36,986 715,749 678,763 13,575 692,338 2035 6,234 2,269 8,503 692,338 683,835 13,677 697,512 2036 3,807 2,275 6,082 697,512 691,430 13,829 705,259 2037 3,797 2,269 6,065 705,259 699,193 13,984 713,177 2038 3,797 2,269 6,065 713,177 707,112 14,142 721,254 2039 3,797 2,269 6,065 721,254 715,188 14,304 729,492 2040 3,807 2,275 6,082 729,492 723,410 14,468 737,878 2041 3,797 2,269 6,065 737,878 731,813 14,636 746,449 2042 3,797 2,269 6,065 746,449 740,383 14,808 755,191 2043 3,797 2,269 6,065 755,191 749,126 14,983 764,108 2044 3,807 2,275 6,082 764,108 758,026 15,161 773,187 2045 3,797 2,269 6,065 773,187 767,121 15,342 782,463 2046 6,981 2,269 9,250 782,463 773,213 15,464 788,678 2047 22,840 2,269 25,108 788,678 763,569 15,271 778,841 2048 21,851 2,275 24,126 778,841 754,714 15,094 769,809 2049 15,851 2,269 18,120 769,809 751,689 15,034 766,722 2050 11,120 2,269 13,389 766,722 753,334 15,067 768,401 2051 5,018 2,269 7,287 768,401 761,113 15,222 776,336 2052 5,032 2,275 7,307 776,336 769,029 15,381 784,409 2053 5,018 2,269 7,287 784,409 777,122 15,542 792,665 2054 5,018 2,269 7,287 792,665 785,378 15,708 801,085 2055 5,018 2,269 7,287 801,085 793,798 15,876 809,674 2056 5,032 2,275 7,307 809,674 802,367 16,047 818,414 2057 5,018 2,269 7,287 818,414 811,127 16,223 827,350 2058 5,018 2,269 7,287 827,350 820,063 16,401 836,464 2059 7,382 2,269 9,651 836,464 826,813 16,536 843,349 2060 80,342 2,275 82,617 843,349 760,732 15,215 775,947 2061 91,803 2,269 94,072 775,947 681,875 13,638 695,513 2062 91,803 2,269 94,072 695,513 601,441 12,029 613,470

Page 1 of 2 Decommissioning and Spent Fuel Management Cash Flow Analysis for Nine Mile Point Nuclear Station, Unit 1 (thousands of January 2024 dollars)
(continued)

De com m issioning Spe nt Fue l BO Y Tr ust BO Y Tr ust Tr ust Fund EO Y Tr u st Year Cost (Radiological Manage m e nt To t al C o st(a) Fund Value Fund L e ss Cost Ear n in gs(b) Fund Value (a) an d ISF S I) Cost 2063 91,803 2,269 94,072 613,470 519,398 10,388 529,786 2064 80,672 2,275 82,947 529,786 446,839 8,937 455,776 2065 79,474 2,269 81,743 455,776 374,033 7,481 381,514 2066 21,598 2,619 24,217 381,514 357,297 7,146 364,443 2067 0 4,366 4,366 364,443 360,077 7,202 367,279 2068 0 4,377 4,377 367,279 362,901 7,258 370,159 2069 1,723 5,443 7,166 370,159 362,994 7,260 370,254 2070 4,109 6,948 11,057 370,254 359,197 7,184 366,381 2071 4,109 6,948 11,057 366,381 355,324 7,106 362,431 2072 4,120 6,967 11,087 362,431 351,344 7,027 358,370 2073 4,109 6,948 11,057 358,370 347,314 6,946 354,260 2074 8,018 0 8,018 354,260 346,242 6,925 353,167 To ta l s (a) 908,359 258,250 1,166,609

(a) Cash flows may not add due to rounding (b) A 2% real rate of return is used as allowed by 10 CFR 50.75(e)(1)(i)
(c) 2027 and 2028 costs are for decommissioning planning (d) The 2027 BOY Trust Fund Value is the value of the decommissioning trust fund prior to the 2027 decommissioning planning expenses

Page 2 of 2}}