ML17100A308

Decommissioning Funding Status Report, Financial Test and Independent Public Accountants' Letter of Attestation

ML17100A308
Person / Time
Site:	Kewaunee
Issue date:	03/31/2017
From:	Stoddard D Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
17-080
Download: ML17100A308 (12)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com March 31, 2017 United States Nuclear Regulatory Commission Serial IINo.17-080 Attention: Document Control Desk NRA/TJS Rev. 0 Washington, D. C. 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DECOMMISSIONING FUNDING STATUS REPORT, FINANCIAL TEST AND INDEPENDENT PUBLIC ACCOUNTANTS' LETTER OF ATTESTATION Pursuant to' 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)-(vii), Dominion Energy Kewaunee, Irie.* (DEK) is providing this report on the status of decommissioning funding for Kewaunee Power Station (KPS). provides the following information for KPS:

Table I - Decommissioning f=unding Status Report for KPS Summary Information as of December 31, 2016 Table II - Decommissioning Funding Status Report for KPS Annual Cash Flow Analysis Starting January 1, 2017 through End of Decommissioning The following information is provided in support and as part of this filing:

1. The escalation of decommissioning costs from the Cost Study's 2012 dollars to 2017 dollars is 1.56% and is based upon the average of CPl-U rates for that period. The mnemonics are "FCPIU.US, CPI: Urban Consumer - All Items (Index, 1982-84=100, SA)."

2. The escalation of decommissioning costs, shown in Table II is held at 0.0% based on assuming a 2.0% Real Rate of Return.

3. The growth rate on Trust Funds is held at the allowed 2.0% Real Rate of Return over the escalation rate.

4. No rate regulatory authority citation for KPS is referenced because KPS is a merchant unit.

5. There are no contracts upon which DEK is relying under paragraph 10 CFR 50.75(e)(1)(v) and there were no modifications to the current method of providing financial assurance since the last submitted report.

6. There are no annual funding amounts for KPS.

7. Trust Fund balances shown in this report are market value and after-tax on realized gains and losses. The Trust Fund balances have not been adjusted for unrealized gain or loss positions not currently taxable.

8. Since the previous annual submittal on March 24, 2016 (Serial No.16-106, ADAMS Accession No. ML16088A089) there have been no changes to the Trust agreements established for nuclear decommissioning for KPS.

Serial No.17-080 KPS Decommissioning Funding Status Report Page 2 of 2

9. Remaining Decommissioning Estimated Cost is adjusted to reflect timing differences and higher costs during plant dormancy.

Additionally, in a submittal dated January 28, 2015 (Serial No.15-001, ADAMS Accession No. ML15034A312), Dominion Resources, Inc. (ORI) committed to provide ongoing information pertaining to its continuing ability to provide additional financial assurance by submitting, by March 31 of each year in connection with DEK's annual financial assurance status report; (1) information demonstrating the results of the financial test in either Paragraph 11.A.1 or Paragraph 11.A.2 of Appendix A to 10 CFR Part 30 for the immediately preceding calendar year, and; (2) a letter from its independent certified public accountant attesting to the data and accuracy of the financial test 1 . This information is included in Attachments 1 and 2, respectively.

Please contact Mr. Craig D. Sly at (804) 273-2784 if you have any questions or require additional information.

Sincerely, D. G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Enclosure:

1. Decommissioning Funding Status Report for KPS Summary Information as of December 31, 2016 Attachments:

1. Financial Test for Year Ended December 31, 2016, Paragraph 11.A.2 of Appendix A to 10 CFR Part 30

2. Deloitte & Touche LLP Attesting Letter of Accuracy of the Financial Test Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Mr. T. H. Carter NRC Senior Project Manager (KPS)

U. S. Nuclear Regulatory Commission, Mail Stop T-8 F5 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 1

DEK is aware that the American Institute of Certified Public Accountants (AICPA) has informed the NRC that certified public accountants are precluded from issuing any form of report or assurance on matters related to solvency. (See ADAMS Accession No. ML13094A316.)

Serial No.17-080 KPS Decommissioning Funding Status Report Enclosure 1 Decommissioning Funding Status Report for KPS Summary Information as of December 31, 2016 Kewaunee Power Station Dominion Energy Kewaunee, Inc. (DEK)

Serial No.17-080 Enclosure 1 Page 1 of 3 Kewaunee Power Station Decommissioning Funding Status Report as of December 31, 2016 Table I Decommissioning Funding Status Report for KPS Summary Information as of December 31, 2016 10 CFR 50.82 (a)(8)(v)-(vii)

(in millions)

Decommissionin ::i Trust Fund Balances 10 CFR Reference ls0.82(a)(8)(v)(A) Is0.82(a)(8)(vii)(A)

Fund Balance Type of Trusts Comments

$ 686.065 Qualified fund balance As of: 12/31/2016

$ - Non-qualified fund balance As of: 12/31/2016

$ 95.543 Less costs incurred prior years but not vet billed to Trust Actual Cost in: As Scent Dollars

$ 590.522 Adiusted decommissionina fund balance As of: 12/31/2016 Other Financial Assurance Methods Being Relied Upon 10 CFR Reference I 50.82(a)(8)(v)(A) I None Prior Years DecommissioninQ Expenditures 10 CFR Reference l50.82(a)(8)(v)(A) I Total License Term Spent Fuel Mi:imt Site Restoration Corrunents

$ 36.138 $ 11.798 $ 24.340 $ - 2016 Cost in: 2016 Dollars

$ 167.160 $ 81.844 $ 85.316 $ - 2012-2015 Cost in: As Scent Dollars

$ 203.298 $ 93.642 $ 109.656 $ - Total Prior Year in: As Scent Dollars Prior Year Expenditures - Variance to Estimated Escalated Cost 10 CFR Reference I50.82(a)(8)(v)(B) I Total License Term Spent Fuel Mi:imt Site Restoration Convnents

$ 36.138 $ 11.798 $ 24.340 $ - Actual Cost in: 2016 Dollars

$ 36.638 $ 6.437 $ 30.201 $ - NRC Auth. $ in 2016 Dollars

$ <0.500 $ 5.361 $ (5.861) $ -

Variance: License Termination and Spent Fuel Management due to timing of activities Remaining Decommissioning Estimated Cost <11 10 CFR Reference Iso.82(a)(8)(v)(B) Is0.82(a)(8)(vii)(B)

Tn+~1 (Z) License Term Spent Fuel Mgmt Site Restoration Comments

$ 846.464 $ 453.622 $ 355.246 $ 37.597 Estimate in: 2017 Dollars Decommissioning Criteria Upon Which the Estimate is Based 10 CFR Reference I50.82(a)(8)(v)(B) I SAFSTOR Any Modification To Method of Providing Financial Assurance 110 CFR Reference l50.82(a)(8)(v)(C) I None Any Material Changes To Trust Agreement Since Previous Report 10 CFR Reference l50.82(a)(8)(v)(D) I None I Need.For Additional Financial Assurance 10 CFR Reference l50.82(a)(8)(vi) l50.82(a)(8)(vii)(C)

None I See Annual Cash Flow Analysis in Table II Inputs to Remaining Cost and Funding Analysis I I I 2017 Start vear of analvsis 1.56% Escalate study dollars from 2012$ to Start Year of Analysis using CPI average (2012 to Start Year of Analysis) 0.00% Escalation rate 2017 & bevond 2.00% Fund Qrowth rate 2017 & beyond (Reflects NRC allowed 2% Real Rate of Return)

Annual expenditures Projected annual exoenditures - see Annual Cash Flow Analysis in Table II (1) Remaining Decommissioning Estimated Cost is adjusted to reflect timing differences and higher costs during plant dormancy.

(2) Differences are due to rounding.

Serial No.17-080 Enclosure 1 Page 2 of 3 Kewaunee Power Station Decommissioning Funding Status Report as of December 31, 2016 Table II Decommissioning Funding Status Report for KPS Annual Cash Flow Analysis Starting January 1, 2017 through End of Decommissioning 10 CFR 50.82 (a)(8)(v)-(vii)

Un millions)

Column 3 Column 1 Column 2 Remaining Column 4 Column 5 Column 6 Column 7 Beginning Earnings License Remaining Remaining Remaining End of on Termination Spent Fuel Mgmt Site Restoration SAFSTOR of Year Trust Funds Expenditures Expenditures Expenditures Expenditures Year Year Balance IReflects 2% RRoRl IReflects 0% Escl IReflects 0% Escl IReflects 0% Escl IReflects 0% Escl Balance 2017 $ 590.522 $ 11.308 $ 8.813 $ 41.440 $ - $ 50.254 $ 551.576 2018 $ 551.576 $ 10.838 $ 4.045 $ 15.268 $ - $ 19.313 $ 543.102 2019 $ 543.102 $ 10.731 $ 2.214 $ 10.922 $ - $ 13.136 $ 540.697 2020 $ 540.697 $ 10.689 $ 2.010 $ 10.442 $ - $ 12.452 $ 538.934 2021 $ 538.934 $ 10.655 $ 1.995 $ 10.354 $ - $ 12.348 $ 537.241 2022 $ 537.241 $ 10.621 $ 1.995 $ 10.354 $ - $ 12.348 $ 535.514 2023 $ 535.514 $ 10.587 $ 1.995 $ 10.354 $ - $ 12.348 $ 533.753 2024 $ 533.753 $ 10.552 $ 1.995 $ 10.354 $ - $ 12.348 $ 531.956 2025 $ 531.956 $ 10.516 $ 1.995 $ 10.354 $ - $ 12.348 $ 530.124 2026 $ 530.124 $ 10.486 $ 1.895 $ 9.703 $ - $ 11.598 $ 529.012 2027 $ 529.012 $ 10.464 $ 1.895 $ 9.703 $ - $ 11.598 $ 527.878 2028 $ 527.878 $ 10.442 $ 1.895 $ 9.703 $ - $ 11.598 $ 526.721 2029 $ 526.721 $ 10.418 $ 1.895 $ 9.703 $ - $ 11.598 $ 525.541 2030 $ 525.541 $ 10.395 $ 1.895 $ 9.703 $ - $ 11.598 $ 524.338 2031 $ 524.338 $ 10.371 $ 1.895 $ 9.703 $ - $ 11.598 $ 523.111 2032 $ 523.111 $ 10.346 $ 1.895 $ 9.703 $ - $ 11.598 $ 521.858 2033 $ 521.858 $ 10.313 $ 2.698 $ 9.703 $ - $ 12.401 $ 519.770 2034 $ 519.770 $ 10.279 $ 1.895 $ 9.703 $ - $ 11.598 $ 518.451 2035 $ 518.451 $ 10.253 $ 1.895 $ 9.703 $ - $ 11.598 $ 517.106 2036 $ 517.106 $ 10.226 $ 1.895 $ 9.703 $ - $ 11.598 $ 515.734 2037 $ 515.734 $ 10.199 $ 1.895 $ 9.703 $ - $ 11.598 $ 514.334 2038 $ 514.334 $ 10.171 $ 1.895 $ 9.703 $ - $ 11.598 $ 512.907 2039 $ 512.907 $ 10.142 $ 1.895 $ 9.703 $ - $ 11.598 $ 511.451 2040 $ 511.451 $ 10.113 $ 1.895 $ 9.703 $ - $ 11.598 $ 509.965 2041 $ 509.965 $ 10.083 $ 1.895 $ 9.703 $ - $ 11.598 $ 508.450 2042 $ 508.450 $ 10.053 $ 1.895 $ 9.703 $ - $ 11.598 $ 506.905 2043 $ 506.905 $ 10.022 $ 1.895 $ 9.703 $ - $ 11.598 $ 505.329 2044 $ 505.329 $ 9.991 $ 1.895 $ 9.703 $ - $ 11.598 $ 503.721 2045 $ 503.721 $ 9.958 $ 1.895 $ 9.703 $ - $ 11.598 $ 502.081 2046 $ 502.081 $ 9.926 $ 1.895 $ 9.703 $ - $ 11.598 $ 500.409 2047 $ 500.409 $ 9.892 $ 1.895 $ 9.703 $ - $ 11.598 $ 498.703 2048 $ 498.703 $ 9.858 $ 1.907 $ 9.703 $ - $ 11.610 $ 496.951 2049 $ 496.951 $ 9.920 $ 1.870 $ - $ - $ 1.870 $ 505.001 2050 $ 505.001 $ 10.081 $ 1.870 $ - $ - $ 1.870 $ 513.213 2051 $ 513.213 $ 10.246 $ 1.870 $ - $ - $ 1.870 $ 521.589 2052 $ 521.589 $ 10.413 $ 1.870 $ - $ - $ 1.870 $ 530.132 2053 $ 530.132 $ 10.584 $ 1.870 $ - $ - $ 1.870 $ 538.847 2054 $ 538.847 $ 10.758 $ 1.870 $ - $ - $ 1.870 $ 547.735 2055 $ 547.735 $ 10.936 $ 1.870 $ - $ - $ 1.870 $ 556.802 2056 $ 556.802 $ 11.117 $ 1.870 $ - $ - $ 1.870 $ 566.049 2057 $ 566.049 $ 11.302 $ 1.870 $ - $ - $ 1.870 $ 575.482 2058 $ 575.482 $ 11.491 $ 1.870 $ - $ - $ 1.870 $ 585.103 2059 $ 585.103 $ 11.683 $ 1.870 $ - $ - $ 1.870 $ 594.917 2060 $ 594.917 $ 11.880 $ 1.870 $ - $ - $ 1.870 $ 604.927 2061 $ 604.927 $ 12.080 $ 1.870 $ - $ - $ 1.870 $ 615.137 2062 $ 615.137 $ 12.284 $ 1.870 $ - $ - $ 1.870 $ 625.551 2063 $ 625.551 $ 12.492 $ 1.870 $ - $ - $ 1.870 $ 636.174 2064 $ 636.174 $ 12.705 $ 1.870 $ - $ - $ 1.870 $ 647.009 2065 $ 647.009 $ 12.921 $ 1.870 $ - $ - $ 1.870 $ 658.061 2066 $ 658.061 $ 13.143 $ 1.870 $ - $ - $ 1.870 $ 669.334 2067 $ 669.334 $ 13.250 $ 13.716 $ - $ - $ 13.716 $ 668.867 2068 $ 668.867 $ 13.131 $ 24.682 $ - $ - $ 24.682 $ 657.316 2069 $ 657.316 $ 12.668 $ 47.869 $ - $ - $ 47.869 $ 622.115 2070 $ 622.115 $ 11.348 $ 109.390 $ - $ - $ 109.390 $ 524.073 2071 $ 524.073 $ 9.483 $ 99.824 $ - $ - $ 99.824 $ 433.733 2072 $ 433.733 $ 8.025 $ 52.907 $ - $ 12.054 $ 64.961 $ 376.797 2073 $ 376.797 $ 7.257 $ 0.118 $ 2.238 $ 25.542 $ 27.898 $ 356.155 Remaining $ in 2017 Dollars $ 453.622 $ 355.246 $ 37.597 $ 846.464 Est. Fund Balance (end of Deconnissioning) (in Future$ escalated at 0.0% & 2.0% Real Rate of Return Fund Growth Rate) $ 356.155 Est. Fund Balance (end of Deconnissioning) discount to 2017 Dollars =

Discount Rate 2.00% $ 117.498

Serial No.17-080 Enclosure 1 Page 3 of 3 Table II Definitions:

Column 1: Beginning of Year Balance:

Reflects the beginning-of-year Trust Fund balance at a 0.0% cost escalation rate and a 2.0%

Real Rate of Return (RRoR) on fund growth.

Column 2: Earnings on Trust Funds:

Reflects earnings on funds remaining in the Trust. A 2.0% RRoR Fund growth rate is used for 2017 through 2073 which reflects the allowed 2.0% RRoR over a 0.0% cost escalation rate.

The annual 2.0% RRoR earnings are calculated on the beginning balance less 50% of the projected annual expenditure for each year.

Column 3: Remaining License Termination Expenditures:

Reflects the annual License Termination Plan cost portion at a 0.0% escalation rate from the Site Specific Estimate.

Column 4: Remaining Spent Fuel Management Expenditures:

Reflects the annual Irradiated Fuel Management Plan cost portion at a 0.0% escalation rate from the Site Specific Estimate. This column provides information related to funding for managing irradiated fuel as required by 10 CFR 50.82(a)(8)(vii).

Column 5: Remaining Site Restoration Expenditures:

Reflects the annual Site Restoration Plan cost portion at a 0.0% escalation rate from the Site Specific Estimate.

Column 6: Remaining SAFSTOR Expenditures:

Reflects the annual SAFSTOR Decommissioning Plan cost at a 0.0% escalation rate from the Site Specific Estimate.

Column 7: End of Year Balance:

Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted for the year specified at a 0.0% escalation rate and a 2.0% RRoR on fund growth.

Tables I and II General Notes: (Any minor differences in totals are due to rounding.)

1) The cost estimates contained in Tables I and II are obtained from revised site-specific cost and schedule tables that were provided in an update to the KPS Post-Shutdown Decommissioning Activities Report (Serial No.14-116, ADAMS Accession No. ML14118A382) dated April 25, 2014.

Further revisions are made with this filing to reflect timing differences and higher costs during plant dormancy.

2) The Trust Fund Balance reflects market value on December 31, 2016, net of taxes on realized gains and losses.

3) The 2.0% RRoR is based on the rate allowed by 10 CFR 50.75(e)(1 )(i) and 10 CFR 50.82(a)(8)(vi) and not on any order of rate setting authority.

4) The funding method for providing financial assurance for decommissioning KPS remains prepayment.

This cash flow analysis demonstrates that the amounts accumulated in the Trust are sufficient; with credited earnings at a 2.0% RRoR, to cover the estimated cost of radiological decommissioning, spent fuel management and site restoration.

5) By letter dated January 28, 2015 (ADAMS Accession No. ML15034A312) DEK submitted a Commitment for Parent Company Guarantee (PCG) and Notice of Request to Discontinue Existing Parent Support Agreement (PSA) from Dominion Resources, Inc. (DRI). The PCG provides additional assurance to address any potential shortfalls in decommissioning funding assurance for KPS, up to

$60 million. By letter dated December 14, 2015 (ADAMS Accession No. ML15344A503), the NRC notified DEK that it has no objection to the cancellation of the $60 million PSA, issued by DRI, for KPS.

6) The cash flow analysis in Table II shows that the funds accumulated in the Trust are sufficient; with credited earnings at a 2.0% real rate of return, to cover the estimated cost of radiological decommissioning, spent fuel management and site restoration. On May 21, 2014 (ADAMS Accession No. ML13337A287), the NRC granted DEK an exemption allowing the Trust to be used for spent fuel management costs.

Serial No.17-080 KPS Decommissioning Funding Status Report Attachment 1 Financial Test for Year Ended December 31, 2016 Paragraph 11.A.2 of Appendix A to 10 CFR Part 30 Kewaunee Power Station Dominion Energy Kewaunee, Inc. (DEK)

James R. Chapman Senior Vice President - Mergers & Aquisitions and Treasurer Dominion Resources, Inc.

120 Tredegar Street, Richmond, VA 23219 dam.com March 27, 2017 FINANCIAL TEST FOR YEAR ENDED DECEMBER 31, 2016

• Paragraph II. A.2 of Appendix A to 10 CFR Part 30 A. Maximum Guarantee Amount for Facility License No. DPR-43: $60 million B. Dominion Resources Inc. issued $400,000,000 of 2 year unsecured senior notes and $400,000,000 of 5 year unsecured senior notes on January 12, 2017. The issuances were rated BBB by Standard and Poor's and Baa2 by Moody's at the time of settlement and maintain these ratings today.

C. DRl's tangible net worth (millions of dollars):

Total Equity $16,840 Less: Net Book Value of the N_uclear Facility and Site (KPS)

Goodwill of the Nuclear Facility and Site (KPS)

(i) Total Net Worth $16.840 Less: Goodwill 6,399 Intangible Assets 618 (ii) Tangible Net Worth $ 9,823 ORI Total Assets $ 71,610 Less: Foreign Assets Total US Assets $ 71,610 FINANCIAL TESTS YES NO

1. Is line C (ii) at least $21 Million? 181 D

2. Is line C (i) at least 6 times the guarantee amount of $60 million? 181 .D

3. a. Are at least 90 percent of the firm's assets located in the U.S.? 181 D or,

b. Is line C (i) at least 6 times the guarantee amount of $60 million? D

4. a. Are bond ratings BBB (including +/-adjustments) or above as D

issued by Standard and Poor's or,

b. Are bond ratings Baa (including+/- adjustments) or above as issued by Moody's D I hereby certify that the content of this Financial Test: Paragraph 11.A.2 of Appendix A to 10 CFR Part 30 is true and correct to the best of my knowledge.

dent Mergers & Acquisitions and Treasurer, ources, Inc.

Serial No.17-080 Decommissioning Funding Status Report Attachment 2 Deloitte & Touche LLP Attesting Letter of Accuracy of the Financial Test Kewaunee Power Station Dominion Energy Kewaunee, Inc. (DEK)

Deloitte & Touche LLP Deloitte(, Suite 820 901 East Byrd Street Richmond, VA 23219 USA Tel: +1 804 697 1500 www.deioitte.com INDEPENDENT ACCOUNTANTS' REPORT ON APPL YING AGREED-UPON PROCEDURES To the Board of Directors of Dominion Resources, Inc.

Richmond, Virginia We have performed the procedures enumerated below, which were agreed to by Dominion Resources, Inc. ("Dominion" or the "Company"), as parent company of Dominion Energy Kewaunee, Inc., licensed operator of the Kewaunee Power Station, solely to assist the Company and the U.S. Nuclear Regulatory Commission in evaluating the information in the Company's financial test for the year ended December 31, 2016, as required by Appendix A, Part 30 of Title 10 of the United States Code of Federal Regulations, included in the accompanying Attachment 1 (the "Financial Test") to the financial assurance letter dated March 27, 2017 from James Chapman, Senior Vice President Mergers & Acquisitions and Treasurer of Dominion Resources, Inc. to the U.S. Nuclear Regulatory Commission (the "Financial Assurance Letter"). Dominion's management is responsible for the Financial Test.

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose.

The procedures that we performed and related findings are as follows:

1. We compared the bond rating in Attachment I to the Company's Financial Assurance Letter to third-party sources, noting no differences.

2. We compared amounts identified as "Total Equity, "Goodwill", "Intangible Assets",

and "DRl Total Assets" in Attachment I to the Company's Financial Assurance Letter to the Company's audited consolidated financial statements as of December 31, 2016, on which we have issued our report dated February 28, 2017, noting no differences.

3. We compared amounts identified as "Net Book Value of the Nuclear Facility and Site (KPS)", "Goodwill of the Nuclear Facility and Site (KPS)", and "Foreign Assets" in Attachment I to the Company's Financial Assurance Letter to the corresponding amounts in a schedule prepared by the Company. We agreed the total per the schedule to the Company's audited consolidated financial statements as of December 31, 2016, on which we have issued our report dated February 28, 2017, noting no differences.

Member of Deloitte Touche Tohmatsu Limited

4. We recomputed the mathematical accuracy of the amounts identified as "Total Net Worth, "Tangible Net Worth", and "Total US Assets" in Attachment 1 to the Company's Financial Assurance Letter, noting no differences.

With respect to procedures outlined in Paragraph II.B of Appendix A, Part 3 0 of Title 10 of the United States Code of Federal Regulations, professional standards preclude us from providing any form of report or assurance on matters relating to solvency. Accordingly, no such form of report or assurance is provided.

We were not engaged to, and did not, conduct an examination, the objective of which would be the expression of an opinion on the Financial Test. Accordingly, we do not express such an opinion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information and use of the board of directors and management of the Company and Dominion Energy Kewaunee, Inc., and the U.S. Nuclear Regulatory Commission, and is not intended to be and should not be used by anyone other than these specified parties.

D~ ,.; /~{_L/;7 March31,2017