Text

Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(Iv)
	ML20056E054
Person / Time
Site:	Duane Arnold
Issue date:	02/25/2020
From:	Dean Curtland; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NG-20-0007
	Download: ML20056E054 (94)
	v • d • e

NEXTera ENERGY ~

DUANE ARNOLD February 25, 2020 NG-20-0007 10 CFR 50.12 10 CFR 50.82(a)(8)(i)(A) 10 CFR 50.75(h)(1)(iv)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Renewed Facility Operating License No. DPR-49 Docket No. 50-331 Request for Exemptions from 10 CFR 50 .82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv)

Reference:

NEDA Letter L-2019-009 to NRC dated January 18, 2019, Certification of Permanent Cessation of Power Operations (ADAMS Accession No. ML19023A196)

Pursuant to 10 CFR 50.12, NextEra Energy Duane Arnold, LLC (NEDA) requests an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow use of its nuclear decommissioning trust funds (DTFs) for spent fuel management and other non-radiological site restoration activities at the Duane Arnold Energy Center (DAEC) . These activities are described in the attached site specific decommissioning cost estimate (DCE) and will also be described in the DAEC Spent Fuel Management Plan (SFMP) and the Post-Shutdown Decommissioning Activities Report (PSDAR) that are expected to be submitted in the near future . The DCE transmitted with this exemption request will also support the SFMP and PSDAR filings. NEDA also requests, pursuant to 10 CFR 50.12, an exemption from 10 CFR 50.75(h)(1 )(iv) to allow DAEC DTF disbursements for spent fuel management and other non-radiological site restoration activities to be made without prior notice, similar to withdrawals in accordance with 10 CFR 50.82(a)(8) .

On January 18, 2019 (Reference), NEDA notified the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8) of its intention to permanently cease power operations at DAEC in the fourth quarter 2020.

Table 1 of Attachment 1 demonstrates that the DTF contains the amount needed to cover the estimated costs of radiological decommissioning, spent fuel management, and site restoration activities. However, 10 CFR 50.82(a)(8)(i)(A) states that DTFs may only "be used by licensees if ... [t]he withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in§ 50.2."

NextEra Energy Duane Arnold, LLC 3277 DAEC Road , Palo, IA 52324

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Page 2 of 3 10 CFR 50.75(h)(1)(iv) similarly requires that trust agreements restrict disbursements (other than for ordinary administrative and other incidental expenses of the fund) to those allowed under Section 50.82(a)(8) and requires a 30-day advance notification to the NRC prior to making disbursements for expenses not covered under Section 50.82(a)(8). Historically, the NRC has not interpreted the 10 CFR 50.2 definition of "decommission" as including activities associated with spent fuel management or site restoration. Therefore, exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are needed to allow NEDA to use DTFs for DAEC spent fuel management and site restoration activities.

The requested exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are permissible under 10 CFR 50.12 because they are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security (10 CFR 50.12(a)(1 )). In addition, application of the regulations in this particular circumstance is not necessary to achieve the underlying purpose of the rules being sought for exemption (10 CFR 50.12(a)(2)(ii)). The cost estimate provided in Table 1 of Attachment 1 identifies the estimated annual expenditures for radiological decommissioning, spent fuel management, and site restoration activities. Table 1 demonstrates that the DTF contains more than adequate funds to cover not only the estimated costs of radiological decommissioning, but also the estimated costs for spent fuel management and site restoration activities. Therefore, application of the restrictions in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) is not necessary to ensure adequate funding for radiological decommissioning of DAEC.

Additionally, the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow for continual NRC oversight of the status of the DTF.

NEDA requests these exemptions on its own behalf as 70% owner of the DAEC. The other licensed owners of the DAEC, 10% owner Corn Belt Power Cooperative (Corn Belt) and 20% owner Central Iowa Power Cooperative (CIPCO), are not seeking permission to use their DTF funds in this manner. The values in the DCE reflect 100%

of the decommissioning costs. Attachment 1 Table 1 reduces those costs to reflect NEDA's 70% share.

NEDA recognizes that if these exemption requests are approved, necessary amendments to its nuclear decommissioning trust agreements for DAEC will be subject to the prior notice requirements of 10 CFR 50.75(h)(1)(iii).

NEDA requests approval of these exemption requests by August 1, 2020 to support the schedule for post-defueled SFMP and site restoration activities. NEDA requests that the approved exemptions become effective upon approval.

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Page 3 of 3 There are no new regulatory commitments made in this submittal. If you have any questions regarding these exemption requests, please contact J. Michael Davis, Licensing Manager at 319-851-7032.

Dean Curtland Site Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Attachments: 1) Request for Exemptions

2) Site Specific Decommissioning Cost Estimate cc: Regional Administrator, USNRC, Region Ill Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa) to NG-20-0007 Requests for Exemption 16 pages follow

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 1 of 16

1. SPECIFIC EXEMPTION REQUESTS Pursuant to 10 CFR 50.12, "Specific exemptions," NextEra Energy Duane Arnold, LLC (NEDA) requests an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow it to use funds from its decommissioning trust funds (DTFs) for the Duane Arnold Energy Center (DAEC) for the management of spent fuel and non-radiological site restoration activities. NEDA also requests, pursuant to 10 CFR 50.12, an exemption from 10 CFR 50.75(h)(1)(iv) to allow NEDA's DTF to be amended to provide for disbursements for spent fuel management and site restoration activities to be made without prior notice, similar to withdrawals in accordance with 10 CFR 50.82(a)(8).

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

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

Decommissioning trust funds may be used by licensees if -- (A) The withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in § 50. 2.

Section (h)(1)(iv) of 10 CFR 50.75, "Reporting and recordkeeping for decommissioning planning," states, in part, that licensees that are not electric utilities shall provide in the terms of the arrangements governing the trust that:

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

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

Disbursements or payments from the trust, escrow account, Government fund, or other account used to segregate and manage the funds, other than for payment of ordinary administrative costs (including taxes) and other incidental expenses of the fund (including legal, accounting, actuarial, and trustee expenses) in connection with the operation of the fund, are restricted to decommissioning expenses or transfer to another financial assurance method acceptable under paragraph (e) of this section until final

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 2 of 16 decommissioning has been completed. After decommissioning has begun and withdrawals from the decommissioning fund are made under

§ 50.82(a)(8), no further notification need be made to the NRG.

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

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

The included Table 1 demonstrates that the DTF contains the amount needed to cover the estimated costs of radiological decommissioning, as well as spent fuel management and site restoration activities. However, 10 CFR 50.82(a)(8)(i)(A) states that DTFs may only be used by licensees if the withdrawals are for expenses for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2. Similarly, 10 CFR 50. 75(h)(1 )(iv) requires that trust agreements provide that disbursements (other than for ordinary administrative and other incidental expenses of the fund) are restricted to decommissioning expenses until final decommissioning is completed. The NRC construes the definition of "decommission" in 10 CFR 50.2 as not including activities associated with spent fuel management or site restoration.

10 CFR 50. 75(h)(1 )(iv) further provides that, except for withdrawals being made under 10 CFR 50.82(a)(8) or for payments of ordinary administrative and other incidental expenses, no disbursement may be made from the DTF without written notice to the NRC at least 30 working days in advance. Because disbursements for spent fuel management and site restoration activities would not be made under 10 CFR 50.82(a)(8), this provision would require advance notice to the NRC prior to any such disbursement.

Based on the above, NEDA has concluded that 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would prohibit use of DTFs for activities related to spent fuel management and site restoration prior to completion of radiological decommissioning. As reflected in the Attachment 2 Decommissioning Cost Estimate (DCE), NEDA anticipates maintaining DAEC in a safe storage condition (SAFSTOR method) for an extended period prior to completion of radiological decommissioning. This will allow radioactive decay to occur, thereby reducing the quantity of contamination and radioactivity that must be disposed of during the decontamination and dismantlement process, as well as reducing occupational radiation exposure.

Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are requested to allow NEDA to withdraw and use funds from the DTF for spent fuel management and site restoration activities. The exemptions would apply to NEDA's 70% share of all spent fuel management and site restoration activities at DAEC. As the NEDA DTF contains adequate funds to complete radiological decommissioning as well as spent fuel management activities and site restoration activities, these exemptions would not present

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 3 of 16 an undue risk to the public health and safety or prevent decommissioning from being completed as planned.

2. BASIS FOR EXEMPTION REQUESTS NEDA anticipates using the SAFSTOR method of decommissioning at DAEC, deferring completion of radiological decommissioning until after a storage period, thus delaying (absent an exemption) the availability of excess amounts in the DTF for spent fuel management and site restoration activities. Attachment 2 provides a site-specific DCE for radiological decommissioning, spent fuel management, and site restoration activities in 2018 dollars.

Table 1, columns 2 through 6, show the DCE costs for each year of decommissioning.

Table 1 reflects the projected annual cash flows required for decommissioning DAEC based on the SAFSTOR method from the DCE. The costs for site radiological decommissioning (license termination costs}, spent fuel management, independent spent fuel storage installation (ISFSI) radiological decommissioning, and site restoration (non-radiological decommissioning) efforts are reflected. Table 1, column 7 escalates the costs to 2019 dollars to allow for proper comparison with the fund balance as of December 31, 2019. Table 1, column 8 shows NEDA's 70% portion of expenses.

Table 1 column 9 includes a cash flow analysis demonstrating that, with credited earnings (i.e., 2% real rate of return) during the SAFSTOR period, NEDA's DTF contains sufficient funds needed to cover its portion of the cost of radiological decommissioning, spent fuel management, and site restoration activities.

Table 1 projects a NEDA DTF balance of over $211 million, as shown in 2019 dollars, at the end of decommissioning.

The DCE includes costs associated with site radiological decommissioning planning performed by a dedicated site organization prior to permanent shutdown. In accordance with 10 CFR 50.82(a)(8), NEDA was reimbursed $991,661.14 for radiological decommissioning planning costs. In accordance with 10 CFR 50.82(a)(8)(ii), pre-shutdown DTF withdrawals will continue to be limited to no more than 3% of the NEDA 70% share of the calculated estimate under 10 CFR 50.75(c).

3. ADJUSTING COST ESTIMATES AND FUNDING LEVELS 10 CFR 50.82(a)(8)(iv) states the following:

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

NEDA anticipates maintaining DAEC in a safe storage condition (SAFSTOR method) for an extended period prior to completion of radiological decommissioning. This will allow radioactive decay to occur, thereby reducing the quantity of contamination and radioactivity that must be disposed of during the decontamination and dismantlement

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 4 of 16 process as well as reducing the associated occupational radiation exposure.

NEDA's approach to address the requirements of 10 CFR 50.82(a)(8)(iv) with respect to "adjusting {decommissioning] cost estimates and associated funding levels over the storage or surveillance period" is discussed below.

During the SAFSTOR period, the site-specific DCE will be periodically updated in accordance with applicable regulatory requirements.

In accordance with 10 CFR 50.82(a)(8)(iv), decommissioning funding assurance will be reviewed and reported to the NRG annually during the SAFSTOR period. The latest DCE adjusted for inflation in accordance with applicable regulatory requirements will be used to demonstrate funding assurance. In addition, actual radiological and spent fuel management expenses will be included in the annual decommissioning status report. If the funding assurance demonstration shows the DTF is not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in Regulatory Guide 1.159 (Reference 1) will be put in place. This may include a cash contribution, a parent company guarantee, or other mechanism.

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

4.1 Exemptions A. The exemptions are authorized by law The proposed exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) would allow NEDA to use funds from the DTF for spent fuel management and site restoration activities, consistent with the DAEC Spent Fuel Management Plan (SFMP) and DCE. The SFMP is expected to be submitted in the near future. As stated above, 10 CFR 50.12 allows the NRG to grant exemptions from the requirements of 10 CFR Part 50. The proposed exemptions would not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations. The NRG has approved exemptions to other licensees to use DTFs for spent fuel management and site restoration (see Section 5). Therefore, the exemptions are authorized by law.

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 5 of 16 B. The exemptions will not present an undue risk to public health and safety The underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) is to provide reasonable assurance that adequate funds will be available for decommissioning of power reactors within 60 years of cessation of operations. Based on the site-specific cost estimate and the cash flow analysis provided in Table 1, use of funds in the DTF for spent fuel management and site restoration activities will not adversely impact NEDA's ability to terminate the DAEC license (i.e., complete radiological decommissioning) within 60 years. Furthermore, an exemption from 10 CFR 50.75(h)(1)(iv) to allow NEDA to make withdrawals from the DTF to cover expenses for spent fuel management and site restoration efforts without prior written notification to the NRC will not affect the sufficiency of funds in the DTF to accomplish radiological decontamination of the site. Additionally, the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow for continual NRC oversight of the status of the DTF.

Based on the above, no new accident precursors are created by using the DTF in the proposed manner. Thus, the probability of postulated accidents is not increased. Also, based on the above, the consequences of postulated accidents are not increased. No changes are being made in the types or amounts of effluents that may be released offsite. There is no significant increase in occupational or public radiation exposure.

These exemptions do not diminish the effectiveness of other regulations that ensure available funding for decommissioning, including 10 CFR 50.82(a)(6) which prohibits licensees from performing any decommissioning activities that could foreclose unrestricted release of the site, result in significant environmental impacts not previously reviewed, or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. Therefore, the exemptions will not present an undue risk to the public health and safety.

c. The exemptions are consistent with the common defense and security The proposed exemptions would allow NEDA to use its DTF for spent fuel management and site restoration efforts, consistent with the SFMP and cost estimate.

Spent fuel management and site restoration activities are an integral part of the planned DAEC decommissioning process and will not adversely affect NEDA's ability to physically secure the site or protect special nuclear material. This change to enable use of funds in the DTF for spent fuel management and site restoration activities will not alter the scope or availability of sufficient funding for the DAEC security program.

Therefore, the proposed exemptions are consistent with the common defense and security.

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

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 6 of 16 A. Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. (10 CFR 50.12(a)(2)(ii))

The underlying purpose of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv) is to provide reasonable assurance that adequate funds will be available for decommissioning of power reactors within 60 years of cessation of operations. Strict application of the rule would prohibit withdrawal of funds from the DTF for activities associated with spent fuel management and site restoration activities until final radiological decommissioning at DAEC has been completed. However, Table 1 (as discussed above) demonstrates that adequate funds are available in the DTF to complete radiological decommissioning, spent fuel management, and site restoration activities. The Table 1 cash flow analysis projects that the DTF will contain $211.154 million, as shown in 2019 dollars, at the end of the decommissioning project in 2080 (using a 2.0% real rate of return).

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

A comment, received during the rulemaking for the Decommissioning Trust Fund Provisions in 10 CFR 50.75(h)(1)(iv), noted that licensees that have complied with the requirements of 10 CFR 50.82(a)(4) regarding submittal of a Post-Shutdown Decommissioning Activities Report (PSDAR) and control disbursements in accordance with the provisions of 10 CFR 50.82(a)(6), (a)(?) and (a)(8) should be exempt from further restrictions on disbursements (Reference 2). The NRC agreed with the comment, because requiring notification in such circumstances would not provide any additional assurance that funding is available and would duplicate notification requirements in 10 CFR 50.82. If the NRC grants the requested exemption allowing NEDA to use funds in its DTF for spent fuel management and site restoration activities, the same consideration would justify dispensing with the 30-day notification requirement as well. The DCE identifies the estimated annual expenditures, and the annual reporting requirements in 10 CFR 50.82(a)(8)(v) and (vi) will allow continual NRC oversight of the status of the DTF. Applying the 30-day advance notification requirement in 10 CFR 50.75(h)(1 )(iv) to disbursements for spent management and site restoration activities would duplicate these other reporting requirements and is not necessary to achieve the underlying purposes of the rule.

Therefore, since the underlying purposes of the rules would be achieved by allowing NEDA to use the DTF to fund the activities as discussed in the DAEC DCE and pending Spent Fuel Management Plan, the special circumstances of 10 CFR 50.12(a)(2)(ii) are present.

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82{a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 7 of 16 B. Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated. (10 CFR 50.12(a)(2)(iii))

The NRC did not intend to prevent the use of these funds solely because they are commingled, and to do so would create an unnecessary financial burden without any corresponding safety benefit. The NRC does not preclude use of funds from the decommissioning trust in excess of those needed for radiological decommissioning for other purposes, such as spent fuel management and site restoration efforts. The NRC has stated that funding for spent fuel management and site restoration activities may be commingled in the decommissioning trust provided the licensee is able to identify and account for the radiological decommissioning funds separately from the funds set aside for spent fuel management and site restoration activities (see NRC Regulatory Issue Summary 2001-07, Revision 1, "10 CFR 50.75 Reporting and Recordkeeping for Decommissioning Planning" dated January 8, 2009 (Reference 3), and Regulatory Guide 1.184, Revision 1, "Decommissioning of Nuclear Power Reactors," (Reference 4)). The adequacy of the DTF to cover the cost of activities associated with decommissioning, the spent fuel management activities, and the site restoration activities is supported by the provided cash flow analysis. The amount of funds required for radiological decommissioning, spent fuel management, and site restoration activities will be identified and accounted for in the annual report required by 10 CFR 50.75(f) and 10 CFR 50.82(a)(8).

If NEDA cannot use its trust fund for spent fuel management and site restoration activities, it would be forced to provide additional funding that would not be recoverable from the DTF until the DAEC operating license is terminated. To prevent access to the excess funds in the trust would impose an unnecessary and undue burden in excess of that contemplated when the regulation was adopted without any corresponding safety benefit. Moreover, the precedents listed below in Section 5 show that not granting the exemption to NEDA would impose costs on NEDA in excess to those incurred by others similarly situated.

Therefore, compliance with the rule would result in an undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, and that are significantly in excess of those incurred by others similarly situated and the special circumstances of 10 CFR 50.12(a)(2)(iii) are present.

5. PRECEDENT This 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1)(iv) request for exemptions is consistent with similar requests granted by the NRC to the following licensees:

Dominion Energy Kewaunee, Inc. for Kewaunee Power Station (Reference 5)

ZionSolutions LLC for Zion Power Station, Units 1 and 2 (Reference 6)

Duke Energy Florida, Inc. for Crystal River Unit 3 (Reference 7)

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 8 of 16

Entergy Nuclear Operations, Inc. for Vermont Yankee Nuclear Power Station (Reference 8)

Exelon Generation Company, LLC for Oyster Creek Nuclear Generating Station (Reference 9)

Entergy Nuclear Operations, Inc. for Pilgrim Nuclear Power Station (Reference 10)

Pacific Gas and Electric Company for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Reference 11)

Exelon Generation Company, LLC for Three Mile Island Nuclear Station, Unit 1 (Reference 12)

6. ENVIRONMENTAL ASSESSMENT A. Environmental Considerations Consistent with the Environmental Assessments prepared by NRG staff to document its environmental reviews (References 13 and 14) for the previous similar requests for exemption from 10 CFR 50.82(a)(8)(i)(A) and/or 10 CFR 50.75(h)(1)(iv), and pursuant to 10 CFR 51.21, the following environmental considerations are provided.

1. Description of Action The proposed action would partially exempt NEDA from meeting the requirements set forth in 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv).

Specifically, the proposed action would allow NEDA to use funds from the DTF for spent fuel management and site restoration activities not associated with the radiological decontamination and would exempt NEDA from meeting the requirement for prior notification to the NRG for these activities.

2. Need for Action As required by 10 CFR 50.82(a)(8)(i)(A), DTFs may be used by NEDA if the withdrawals are for legitimate decommissioning activity expenses, consistent with the definition of decommissioning in 10 CFR 50.2. This definition addresses radiological decontamination and does not include activities associated with the spent fuel management or site restoration. Similarly, the requirements of 10 CFR 50.75(h)(1)(iv) restrict the use of decommissioning trust fund disbursements (other than for ordinary and incidental expenses) to decommissioning expenses until final decommissioning has been completed.

Therefore, partial exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) are needed to allow NEDA to use funds from the DTF for spent fuel management and site restoration activities.

The adequacy of funds in the DTF to cover the costs of activities associated with irradiated fuel management, site restoration, and radiological decontamination through license termination is supported by the DCE and the tables included in the attachments to this request. NEDA needs access to the

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 9of16 funds in the DTF in excess of those needed for radiological decontamination to support spent fuel management and site restoration activities not associated with the radiological decontamination.

The requirements of 10 GFR 50.75(h)(1)(iv) further provide that, except for decommissioning withdrawals being made under 10 GFR 50.82(a)(8)(i)(A) or for payments of ordinary administrative costs and other incidental expenses of the trust, no disbursements may be made from the trust until written notice of the intention to make a disbursement has been given to the NRG at least 30 working days in advance of the intended disbursement. Therefore, an exemption from 10 GFR 50.75(h)(1)(iv) is needed to allow NEDA to use funds from the DTF for spent fuel management and site restoration activities without prior NRG notification.

3. Environmental Impacts of the Proposed Action The proposed action involves exemptions from requirements that are of a financial or administrative nature and that do not have an impact on the environment. The exemptions do not authorize any additional regulatory or land-disturbing activities.

NEDA's exemption requests demonstrate that there is reasonable assurance that adequate funds are available in the DTF to complete all activities associated with decommissioning as well as spent fuel management and site restoration. There is no decrease in safety associated with the use of the DTF to fund activities associated with spent fuel management and site restoration.

Paragraph 50.82(a)(8)(v) of 10 GFR requires a licensee to submit a financial assurance status report annually between the time of submitting its decommissioning cost estimate and submitting its final radiation survey and demonstrating that residual radioactivity has been reduced to a level that permits termination of its license. 10 GFR 50.82(a)(8)(iv) requires that if the remaining balance plus expected rate of return, plus any other financial surety mechanism does not cover the estimated costs to complete the decommissioning, additional financial assurance must be provided to cover the cost of completion. These annual reports provide a means for the NRG to monitor the adequacy of available funding. Since the exemptions would allow NEDA to use funds from the DTF that are in excess of those required for radiological decontamination of the site and the adequacy of funds dedicated for radiological decontamination are not affected by the proposed exemptions, there is reasonable assurance that there will be no environmental impact due to lack of adequate funding for decommissioning.

The environmental impacts of decommissioning have been generically evaluated by the NRG and documented in NUREG-0586, Supplement 1, "Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities" (Decommissioning GEIS) (Reference 15). DAEG's PSDAR will discuss that the impacts from the planned decommissioning activities at

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82{a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 10of16 DAEC are less than and bounded by the impacts considered in the Decommissioning GEIS and NUREG-1496, "Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRG-Licensed Nuclear Facilities" (Reference 16). NEDA believes that the PSDAR will contain the required information, including discussion that provides the reasons for concluding that the environmental impacts associated with the decommissioning activities at DAEC will be bounded by previous activities.

The proposed activity will not significantly increase the probability or consequences of radiological accidents. Additionally, the proposed changes have no direct radiological impacts. There will be no change to the types or amounts of radiological effluents that may be released, therefore, no change in occupational or public radiation exposure from the proposed changes. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of effluents released offsite. In addition, the method of operation of waste processing systems will not be affected by the exemptions.

The proposed exemptions will not result in changes to the design basis requirements of structures, systems, or components (SSCs) that function to limit or monitor the release of effluents. All the SSCs associated with limiting the release of effluents will continue to be able to perform their functions.

Moreover, no changes would be made to plant buildings or the site property from the proposed changes. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

With regard to potential non-radiological impacts, the proposed changes would have no direct impact on land use or water resources, including terrestrial and aquatic biota, as they involve no new construction of modification of plant operational systems. There would be no changes to the quality or quantity of non-radiological effluents and no changes to NEDA's National Pollutant Discharge Elimination System permit would be needed as a result of these exemptions. In addition, there would be no noticeable effect on socioeconomic conditions in the region, no environment justice impacts, no air quality impacts, and no impacts to historic and cultural resources from the proposed changes.

Therefore, there are no significant non-radiological environment impacts associated with the proposed action.

Accordingly, it can be concluded that there are no significant environmental impacts associated with the proposed action.

4. Environmental Impacts of the Alternatives to the Proposed Action As an alternative to the proposed action, NEDA considered the "no-action" alternative. This would result in no change in current environmental impacts.

The environmental impacts of the proposed action and the alternative action are similar.

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 11 of 16

5. Alternative Use of Resources There are no unresolved conflicts concerning alternative uses of available resources under the proposed action.

B. Conclusion as to Environmental Impacts On the basis outlined above, the proposed exemptions will not have a significant effect on the quality of the human environment and will not involve potential incremental environmental impacts. The proposed exemptions do not require any additional Federal permits, licenses, or approvals.

7. CONCLUSION The proposed exemptions would allow NEDA to use the DAEC DTF for the full scope of activities described in the decommissioning cost estimate, including the management of spent fuel and site restoration, and to make such disbursements in the same manner as withdrawals for radiological decommissioning.

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

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

8. REFERENCES

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

2. Federal Register Notice (FRN) 67 FR 78332, Decommissioning Trust Provisions, December 24, 2002

3. NRC Regulatory Issue Summary 2001-07, Revision 1, 10 CFR 50.75 Reporting and Recordkeeping for Decommissioning Planning," January 8, 2009 (ADAMS Accession No. ML083440158)

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

October 2013 (ADAMS Accession No. ML13144A840)

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82{a){8){i)(A) and 10 CFR 50. 75(h)(1)(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 12of16

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

6. Letter from U.S. Nuclear Regulatory Commission to ZionSolutions LLC; "Zion Nuclear Power Station, Units 1 and 2 - Request for Exemption from Certain Decommissioning Trust Fund Requirements of the Decommissioning Regulations (TAC Nos. J52941 and J52942)," July 21, 2014 (ADAMS Accession No. ML14030A589)

7. Letter from U.S. Nuclear Regulatory Commission to Duke Energy Florida, Inc.;

"Crystal River Unit 3 Nuclear Generating Plant - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75(h)(2) (TAC NO. MF3875),"

January 26, 2015 (ADAMS Accession No. ML14247A545)

8. Letter from U.S. Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc.;

"Vermont Yankee Nuclear Power Station - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (TAC NO.

MF5575)," June 17, 2015 (ADAMS Accession No. ML15128A219)

9. Letter from U.S. Nuclear Regulatory Commission to Exelon Generation Company, LLC; "Oyster Creek Nuclear Generating Station - Exemptions from the Requirements of 10 CFR 50.82(a)(8)(i)(A) and 50.75(h)(1)(iv) (EPID L-2018-LLE-0002)," October 19, 2018 (ADAMS Accession No. ML18227A025)

10. Letter from U.S. Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc.;

Pilgrim Nuclear Power Station - Request for Exemption from 10 CFR 50.82(a)(8)(i)(A)

(EPID L-2018-LLE-0019), July 22, 2019 (ADAMS Accession No. ML19162A334)

11. Letter from U.S. Nuclear Regulatory Commission to Pacific Gas and Electric Company; "Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.82(a)(8)(ii) (EPID L-2018-LLE-0023)," September 10, 2019 (ADAMS Accession No. ML19163A104)

12. Letter from U.S. Nuclear Regulatory Commission to Exelon Generation Company, LLC; "Three Mile Island Nuclear Station, Unit 1 - Exemptions from the Requirements of 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) (EPID L-2019-LLE-0009),"

October 16, 2019 (ADAMS Accession No. ML19259A175)

13. Federal Register Notice 83FR46763, Environmental Assessment and Finding of No Significant Impact, Oyster Creek Generating Station, dated September 14, 2018

14. Federal Register Notice 84FR42025, Environmental Assessment and Finding of No Significant Impact, Diablo Canyon Nuclear Power Plant, dated August 16, 2019 (ML19136A102)

15. NUREG 0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," dated November, 2002

NextEra Duane Arnold, LLC IDuane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 13 of 16

16. NUREG 1496, "Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRG-Licensed Nuclear Facilities,"

dated July, 1997

NextEra Duane Arnold, LLC I Duane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 14of16 Table 1 Annual SAFSTOR Decommissioning Cost Cash Flow for Duane Arnold Energy Center Site ISFSI Site Total Cost NEDA Spent Fuel NEDA's Radiological Radiological Resto ratio in 2018 Total Cost Decommissioning Management 70% of Decommis- Decommis- n Cost Dollars Escalated at DTF Balance Year Cost Total Cost sioning Cost sioning Cost 2018 from DCEi 1.8% to 2019 Escalated at 2%

2018 Dollars 2019 2018 Dollars 2018 Dollars Dollars Dollarsi minus 70% of from DCE Dollars from DCE from DCE from DCE Expensesi 2019 454 454ii 2020 38,864iii 3 557iv 0 0 42,421 43, 184 30,229 433,314 2021 43,735 19,105 0 0 62,840 63,971 44,780 397,200 2022 15,949 57,546 0 0 73,495 74,818 52,373 352,772 2023 5, 110 50,910 0 0 56,020 57,028 39,920 319,907 2024 14,895 3,222 0 0 18, 117 18,443 12,910 313,395 2025 5,604 3,233 0 0 8,837 8,996 6,297 313,366 2026 2,201 3,233 0 0 5,434 5,532 3,872 315,761 2027 1,827 3,233 0 0 5,060 5,151 3,606 318,470 2028 1,827 3,233 0 0 5,060 5, 151 3,606 321,234 2029 1,827 3,233 0 0 5,060 5, 151 3,606 324,052 2030 1,884 3,233 0 0 5,117 5,209 3,646 326,887 2031 1,770 3,233 0 0 5,003 5,093 3,565 329,860 2032 1,770 3,504 0 0 5,274 5,369 3,758 332,699 2033 1,770 3,507 0 0 5,277 5,372 3,760 335,592 2034 1,770 3,507 0 0 5,277 5,372 3,760 338,544 2035 1,770 3,507 0 0 5,277 5,372 3,760 341,555 2036 1,770 3,507 0 0 5,277 5,372 3,760 344,625 2037 1,770 3,507 0 0 5,277 5,372 3,760 347,758 2038 1,770 3,507 0 0 5,277 5,372 3,760 350,953 2039 1,770 3,507 0 0 5,277 5,372 3,760 354,211 2040 2,411 3,507 0 0 5,918 6,025 4,218 357,078 2041 1,770 3,507 0 0 5,277 5,372 3,760 360,459 2042 1,770 3,507 0 0 5,277 5,372 3,760 363,908

NextEra Duane Arnold, LLC I Duane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 15of16 Table 1 Annual SAFSTOR Decommissioning Cost Cash Flow for Duane Arnold Energy Center Site ISFSI Site Total Cost NEDA Spent Fuel NEDA's Radiological Radiological Resto ratio in 2018 Total Cost Decommissioning Management 70% of Decommis- Decommis- n Cost Dollars Escalated at DTF Balance Year Cost Total Cost sioning Cost sioning Cost 2018 from DCEi 1.8% to 2019 Escalated at 2%

2018 Dollars 2019 2018 Dollars 2018 Dollars Dollars Dollarsi minus 70% of from DCE Dollars from DCE from DCE from DCE Exoensesi 2043 1,770 3,507 0 0 5,277 5,372 3,760 367,426 2044 1,770 3,507 0 0 5,277 5,372 3,760 371,014 2045 1,770 3,507 0 0 5,277 5,372 3,760 374,674 2046 1,770 3,507 0 0 5,277 5,372 3,760 378,408 2047 1,770 3,507 0 0 5,277 5,372 3,760 382,215 2048 1,770 3,507 0 0 5,277 5,372 3,760 386,099 2049 1,770 3,507 0 0 5,277 5,372 3,760 390,061 2050 1,770 3,507 0 0 5,277 5,372 3,760 394, 102 2051 1,770 3,507 0 0 5,277 5,372 3,760 398,224 2052 1,770 3,507 0 0 5,277 5,372 3,760 402,428 2053 1,770 3,507 0 0 5,277 5,372 3,760 406,716 2054 2,055 3,507 0 0 5,562 5,662 3,963 410,887 2055 2,126 3,507 0 0 5,633 5,735 4,015 415,091 2056 1,770 3,507 0 0 5,277 5,372 3,760 419,632 2057 1,770 3,507 0 0 5,277 5,372 3,760 424,265 2058 1,770 3,507 0 0 5,277 5,372 3,760 428,990 2059 2,159 2,909 0 0 5,069 5,160 3,612 433,957 2060 3,077 0 0 0 3,077 3,133 2,193 440,443 2061 2,634 0 0 0 2,634 2,681 1,877 447,376 2062 2,634 0 0 0 2,634 82,61 1,877 454,446 2063 2,634 0 0 0 2,634 2,681 1,877 461,659 2064 2,634 0 0 0 2,634 2,681 1,877 469,015 2065 2,634 0 0 0 2,634 2,681 1,877 476,519 2066 2,634 0 0 0 2,634 2,681 1,877 484,172

NextEra Duane Arnold, LLC I Duane Arnold Energy Center Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(iv)

Docket No. 50-331 NG-20-0007 Attachment 1 Page 16 of 16 Table 1 Annual SAFSTOR Decommissioning Cost Cash Flow for Duane Arnold Energy Center Site ISFSI Site Total Cost NEDA Spent Fuel NEDA's Radiological Radiological Resto ratio in 2018 Total Cost Decommissioning Management 70% of Decommis- Decommis- n Cost Dollars Escalated at DTF Balance Year Cost Total Cost sioning Cost sioning Cost 2018 from DCEi 1.8% to 2019 Escalated at 2%

2018 Dollars 2019 2018 Dollars 2018 Dollars Dollars Dollarsi minus 70% of from DCE Dollars from DCE from DCE from DCE Exoensesi 2067 2,634 0 0 0 2,634 2,681 1,877 491,979 2068 2,634 0 0 0 2,634 2,681 1,877 499,942 2069 2,634 0 0 0 2,634 2,681 1,877 508,064 2070 2,634 0 0 0 2,634 2,681 1,877 516,349 2071 2,634 0 0 0 2,634 2,681 1,877 524,799 2072 2,634 0 0 0 2,634 2,681 1,877 533,418 2073 15,440 0 0 0 15,440 15,718 11,003 533,084 2074 32,608 0 0 0 32,608 33, 195 23,237 520,509 2075 78,197 0 184 0 78,381 79,792 55,854 475,065 2076 94,001 0 403 0 94,404 96,103 67,272 417,295 2077 118,359 25 303 0 118,688 120,824 84,577 341,064 2078 101,052 4,873 731 6,212 112,868 114,899 80,429 267,456 2079 57,385 0 19 27,813 85,217 86,751 60,726 212,079 2080 4,828 0 0 2,422 7,250 7,381 5,167 211, 154 Totali 723,271 259,466 1,640 36,447 1,020,824 1,039, 199 727,439 i Value may sum incorrectly due to numerical rounding.

ii Actual DTF balance as of 12/31/2019 mOf the $4,099,000 Site Radiological Decommissioning costs estimated for 2019, as shown in the DCE, only $1,416,659 was incurred during 2019, of which 70% ($991,961) were reimbursed by NEDA from its DTF. The remaining expected 2019 costs of $2,682,341 have been added to the 2020 costs. This is done to ensure that the cash flow reflects the total estimated cost even if certain costs were not withdrawn from the DTF in 2019.

iv No Spent Fuel Management costs were withdrawn in 2019, therefore, the expected 2019 costs of $233,000 have been added to the 2020 costs.

This is done to ensure that the cash flow reflects the total estimated cost even if certain costs were not withdrawn from the DTF in 2019.

Attachment 2 to NG-20-0007 Site Specific Decommissioning Cost Estimate 72 pages follow

~

ENERGYSOLUTIONS Document No. 164053-DCE-021 2018 Decommissioning Cost Estimate for the Duane Arnold Energy Center Project No. 164053 Revision 2 Prepared for:

NextEra Energy Duane Arnold, LLC Central Iowa Power Cooperative Corn Belt Power Cooperative Prepared by:

EnergySolutions, LLC 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Approved By: Januaiy 27, 2020 Mike Williams, Project Manager Date Prepared By:

13; ~~ January 27, 2020 Barry Sims, Senior Technical Advisor Date 0NewRepo1t D Title Change

[K) Report Revision D Report Rewrite Effective Date January 27, 2020

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 TABLE OF CONTENTS Section Page 1.0 EXECUTIVE

SUMMARY

................................................................................................ 1

2.0 INTRODUCTION

.............................................................................................................. 4 2.1 Study Objective ....................................................................................................... 4 2.2 Regulatory Framework ........................................................................................... 4 3.0 STUDY METHODOLOGY ............................................................................................... 7 3.1 General Description ................................................................................................ 7 3.2 Schedule Analysis ................................................................................................... 7 3.3 Decommissioning Staff........................................................................................... 8 3.4 Waste Disposal ........................................................................................................ 8 3.5 Final Status Survey ............................................................................................... 10 3.6 Contingency .......................................................................................................... 11 3.7 Cost Reporting ...................................................................................................... 12 4.0 SITE SPECIFIC TECHNICAL APPROACH .................................................................. I 3 4.1 Facility Description ............................................................................................... 13 4.2 Decommissioning Periods for SAFSTOR ............................................................ 13 4.3 Decommissioning Staff......................................................................................... 16 4.4 Spent Fuel Management Staff............................................................................... I6 4.5 Spent Fuel Shipments ........................................................................................... 16 5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS ................................................... 17 6.0 STUDY RESULTS ........................................................................................................... 22 6.1 SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage ......................................... 22

7.0 REFERENCES

................................................................................................................. 30 FIGURES Figure 1-1 Summary SAFSTOR Schedule ............................................................................. 3 Figure 6-1 Summary SAFSTOR Schedule ........................................................................... 23

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 TABLES Table 1-1 Decommissioning Cost Summary ............................................................................ 2 Table 6-1 Cost and Schedule Summary ................................................................................. 24 Table 6-2 Utility Staff Levels ............................................................................................ 25 Table 6-3 Decommissioning General Contractor Staff Levels .............................................. 27 Table 6-4 Waste Disposal Volumes ....................................................................................... 29 APPENDICES Appendix A List of Systems and Structures Appendix B Spent Fuel Shipping Schedule Appendix C Detailed Project Schedule Appendix D Detailed Cost Table Appendix E Annual Cost By Account Table 11

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 ACRONYMS AND ABBREVIATIONS AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable BWR Boiling Water Reactor CFR Code of Federal Regulations CPM Critical Path Method DAEC Duane Arnold Energy Center D&D Decontamination and Demolition DGC Decommissioning General Contractor DOE U.S. Department of Energy DSC Dry Shielded Canister FEMA Federal Emergency Management Agency FSS Final Status Survey GSA U.S. General Services Administration GTCC Greater Than Class C HP Health Physics HSM Horizontal Storage Modules ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LLW Low Level Waste LLWP A Low-Level Waste Policy Act LOP Life-of-Plant MARS SIM Multi-Agency Radiation Survey and Site Investigation Manual MPC Multi-Purpose Canister MWt Megawatt thermal NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System ORISE Oak Ridge Institute for Science and Education PCB Polychlorinated Biphenyl PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor RCRA Resource Conservation and Recovery Act TCEQ Texas Commission on Environmental Quality WBS Work Breakdown Structure UCF Unit Cost Factor 111

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 1.0 EXECUTIVE

SUMMARY

This report presents an update to "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center", Revision 1 (Ref. No. 1). The Duane Arnold Energy Center (DAEC) is 70%

owned by NextEra Energy Duane Arnold, LLC. The other owners of DAEC are Central Iowa Power Cooperative (20%) and Corn Belt Power Cooperative (10% ). All numbers presented in this report are on a 100% basis.

This Decommissioning Cost Estimate (DCE) has been performed for financial planning purposes to determine costs for (1) decommissioning DAEC to the extent required to terminate the plant's operating license pursuant to 10 Code of Federal Regulations (CPR) 50.75(c), (2) post-shutdown management of spent fuel until acceptance by the U.S. Department of Energy (DOE) pursuant to 10 CPR 50.54(bb), (3) clean demolition of structures or Greenfield, and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to l 0 CFR 72.30.

The DCE methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Ref. No. 2).

The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," (Ref. No. 3). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

NRC requirements, set forth in Title 10 of the CFR, differentiate between the post-shutdown costs associated with storage of spent fuel on site and those associated with the decommissioning of the facility. 10 CFR 50.75(c) requires funding by the licensee of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and the removal of clean structures. 10 CFR 50.75(c) also excludes the cost of site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license, which restores the site to either "Brownfield" or "Greenfield" conditions depending on the desired end-state. 10 CFR 50.54 (bb) requires funding by the licensee "for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license 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, the costs and schedules for all activities are segregated for regulatory purposes as follows: costs for "License Termination" (10 CPR 50.75(c)), costs for "Spent Fuel Management," (10 CPR 50.54(bb)), costs for "Greenfield" (clean removal and site restoration) final site conditions, and Independent Spent Fuel Storage (ISFSI) Decontamination and Demolition (D&D) (10 CFR 72.30). EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to differentiate between these four project accounts.

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 This DCE analyzes the following scenario, as defined by DAEC:

60 Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage

Shutdown on October 30, 2020 .

DAEC's spent fuel shipping schedules based on a 2030 start date for DOE's acceptance of spent fuel.

Termination of spent fuel pool operation approximately three years after permanent shutdown.

Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transfened to Multi-Purpose Canisters (MPCs) for interim storage.

SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

Decommissioning will be pe1formed by the utility staff and a Decommissioning General Contractor (DGC).

The cost estimate results are provided in 2018 dollars in Table 1-1. Table 1-1 gives License Termination costs (which correspond to 10 CFR 50.75 (c) requirements), Spent Fuel Management costs (which correspond to 10 CFR 50.54 (bb) requirements), Greenfield costs (which correspond to activities such as clean building demolition and site grading and re-seeding), and ISFSI D&D (which conespond to 10 CFR 72.30).

Table 1-1 Decommissioning Cost Summary (2018 Dollars in Thousands)

Account Total License Termination - 50.75 (c) $724,688 Spent Fuel - 50.54 (bb) $259,466 Greenfield $36,447 ISFSI D&D 72.30 $1,640 Total $1,022,240 Note: Numbers may not add due to rounding.

The estimate is based on site-specific plant systems and buildings inventories. These inventories, and EnergySolutions' proprietary Unit Cost Factors (UCFs), were used to generate required manhours, activity schedule hours and costs, and waste volume, weight, and classification. Based on the activity schedule hours and a decommissioning activities analysis, a C1itical Path Method (CPM) analysis was performed to determine the decommissioning schedules. These schedules reflect the effects of sequenced activity-dependent or distributed decommissioning elements such as planning and preparations, major component removal, building decontamination, and spent fuel shipping. The schedules are divided into project phases (periods) and presented, as noted previously, by cost account "License Termination," "Spent Fuel Management," "ISFSI D&D," or "Greenfield." The summary schedule is shown in Figure 1-1 and may also be found in Section 6.0 of this report.

2

2018 Deeommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Figure 1-1 Summary SAFSTOR Schedule Spent FUQI ManagQtmnt

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2

2.0 INTRODUCTION

2.1 Study Objective This report presents an update to "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center", Revision 1 (Ref. No. 1). The Duane Arnold Energy Center (DAEC) is 70%

owned by NextEra Energy Duane Arnold, LLC. The other owners of DAEC are Central Iowa Power Cooperative (20%) and Corn Belt Power Cooperative (10%). All numbers presented in this report are on a 100% basis.

This Decommissioning Cost Estimate (DCE) has been performed for financial planning purposes to determine costs for (I) decommissioning DAEC to the extent required to terminate the plant's operating license pursuant to 10 Code of Federal Regulations (CPR) 50.75 (c), (2) post-shutdown management of spent fuel until acceptance by the U.S. Department of Energy (DOE) pursuant to 10 CPR 50.54 (bb), (3) clean demolition of structures or Greenfield, and (4) Independent Spent Fuel Storage Installation (ISFSI) decommissioning pursuant to 10 CPR 72.30.

The DCE methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (Ref. No. 2).

The report was prepared in accordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," (Ref. No. 3). The estimate is based on compliance with current regulatory requirements and proven decommissioning technologies.

This DCE analyzes the following scenario, as defined by DAEC:

60 Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage

Shutdown on October 30, 2020.

DAEC's spent fuel shipping schedules based on a 2030 start date for DOE's acceptance of spent fuel.

Termination of spent fuel pool operation approximately three years after permanent shutdown.

Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transferred to Multi-Purpose Canisters (MPCs) for interim.

SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

Decommissioning will be pe1formed by the utility staff and a Decommissioning General Contractor (DGC).

2.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, and spent fuel management are as follows:

1. NRC regulations require a license for on-site storage of spent fuel. Wet storage in a spent fuel pool is authorized by a facility's 10 CPR Part 50 license. On-site dry 4

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 storage of spent fuel at an Independent Spent Fuel Storage Installation (ISFSI) is licensed by either: (a) the general license set forth in 10 CFR 72.210, which requires that a Part 50 license be in place; or (b) a site-specific ISFSI license issued pursuant to 10 CFR Part 72.

2. 10 CFR 50.75 (c) requires funding by the licensee of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and the removal of clean structures.

3. 10 CFR 50.54 (bb) requires the licensee, within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license, whichever occurs first, to submit wiitten notification to the NRC 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 upon expiration of the reactor operating license until title to the iirndiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." However, the NRC does not currently consider post-shutdown spent fuel management costs to be decommissioning costs.

4. 10 CFR 72.30 (b) requires that a licensee under Part 72 must submit a decommissioning funding plan that contains information that provides assurance that funds will be available to decommission the ISFSI.

Decommissioning Alternatives The three methods for decommissioning are DECON, SAFSTOR, and ENTOMB, which are summarized as follows:

1. DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license after cessation of operations.

2. SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. NRC regulations require decommissioning to be completed within 60 years of cessation of operation.

3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained and monitored until radioactivity decays to a level that permits termination of the license. Since entombment will exceed the requirement for decommissioning to be completed within 60 years of cessation of operation, NRC handles entombment requests on a case-by-case basis.

The selection of a preferred decommissioning alternative is influenced by a number of factors pertinent at the time of final plant shutdown. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a 5

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 low-level waste disposal facility, availability of a high-level waste (spent fuel) repository, regulatory requirements, and public comments.

Post-Shutdown Spent Fuel Management Alternatives Selection of a decommissioning strategy and the associated schedule for completion is in part contingent upon an assumed start date for DOE acceptance of spent fuel and an assumed end date for completion of the transfer of all spent fuel assemblies projected to be generated during a power reactor's operating life. The basic options for long-term post-shutdown spent fuel management currently available to power plant operators are (1) wet storage consisting of continued maintenance and operation of the spent fuel pool, and (2) dry storage consisting of transfer of spent fuel from the fuel pool to on-site dry storage modules after a cooling period.

Maintaining the spent fuel pool for an extended duration following cessation of operations prevents termination of the Part 50 license and typically has a higher annual maintenance and operating cost than the dry storage alternative. Transfer of spent fuel to an ISFSI requires additional capital expenditures for purchase and construction of the ISFSI and dismantlement and disposal of the ISFSI following completion of spent fuel transfer to DOE. In both cases the decommissioning and spent fuel management costs are significantly affected by the assumed start and end dates for DOE acceptance of spent fuel.

In January 2013, DOE released its "Strategy for Management and Disposal of Used Nuclear Fuel and High Level Radioactive Waste" (Ref. No. 5). The DOE Strategy contemplates building the capability to begin executing DOE' s commitment to address waste disposal within the next ten years. Under this Strategy, by 2021, operation would begin of a "pilot storage facility" with an "initial focus on accepting spent fuel from shutdown reactor sites." By 2025, a "larger interim storage facility" would be available, and by 2048, a geologic repository would commence operations.

For purposes of this DCE, DAEC has conservatively assumed that the larger interim storage facility is delayed five years and commences operations in 2030. DAEC has further assumed that the DOE acceptance rate is consistent with the 2004 "Acceptance Priority Ranking &

Annual Capacity Report" (Ref. No. 6), which is the most current information regarding acceptance of fuel.

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2018 Decommissioning Cost Estimate Document No.164053-DCE-021 for the Duane Arnold Energy Center Revision 2 3.0 STUDY METHODOLOGY 3.1 General Description EnergySolutions maintains a proprietary decommissioning cost model based upon the fundamental technical approach established in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," dated May 1986 (Ref. No.

2). The cost model has been updated in accordance with regulatory requirements and industry experience. The cost model includes elements for estimating distributed and undistributed costs.

Distributed costs are activity specific and include planning and preparation costs as well as the decontamination, packaging, disposal, and removal of major components and systems. For example, the segmentation, packaging, and disposal of the reactor internals is a distributed cost.

Undistributed costs, sometimes referred to as collateral costs, are typically time dependent costs such as utility and DGC staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff.

The methodology for preparing cost estimates for a selected decommissioning alternative requires development of a site-specific detailed work activity sequence based upon the plant inventory. The activity sequence is used to define the labor, material, equipment, energy resources, and duration required for each activity. In the case of major components, individual work sequence activity analyses are performed based on the physical and radiological characteristics of the component and the packaging, transportation, and disposal options available.

In the case of structures and small components and equipment such as piping, pumps, and tanks, the work durations and costs are calculated based on Unit Cost Factors (UCFs). UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. They are developed using decommissioning experience, information on the latest technology applicable to decommissioning, and engineering judgment. The total cost of a specific decommissioning activity can be determined by multiplying the total number of units associated with that activity by the UCF, expressed as $/unit, for that activity. For example, the estimated demolition cost of a non-contaminated concrete structure can be obtained by multiplying the volume of concrete in the structure by the UCF for non-contaminated reinforced concrete demolition, expressed in $/unit volume. Each UCF has associated with it a man-hours/unit and schedule-hours/unit. From these values, total man-hours and total schedule-hours can be determined for a particular activity.

3.2 Schedule Analysis Once the work activity durations are calculated for all distributed actIV1tles, a critical path schedule analysis is performed using Microsoft Project. The schedule accounts for constraints such as spent fuel cooling periods and regulatory reviews. The schedule is typically delineated into phases or time periods (hereinafter referred to as period or periods) that differentiate manpower requirements and undistributed costs.

In order to differentiate between License Termination, Spent Fuel, Greenfield, and ISFSI D&D elements of the entire decommissioning scope of work, EnergySolutions has established a Work Breakdown Schedule (WBS) and cost accounting system to treat each element as a subproject.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Accordingly, the overall project schedule is divided into interrelated periods with major milestones defining the beginning and ending of each period. The major milestones also serve as the basis for integrating the periods of the four subprojects.

3.3 Decommissioning Staff A site-specific staffing plan was developed by DAEC and EnergySolutions based on the existing DAEC operational staff and the assumption that the decommissioning will be performed by a DGC, with oversight and management of the DGC peiformed by DAEC staff. It was also assumed that DAEC staff would be supplemented by professional consulting engineering, particularly in the planning and preparation phase. The DAEC existing salary structure serves as the basis for calculating DAEC staff labor costs. The DGC salary costs are based on industry data.

Staffing levels for each project period are based on the AIF guidelines and industry experience.

The sizes of the DAEC and DGC staffs are varied in each period in accordance with regulatory requirements and work activities.

3.4 Waste Disposal Waste management costs comprise a significant portion of the decommissioning cost estimate.

Additionally, limited future access to disposal sites licensed for receipt of Class B and C wastes introduces a significant level of uncertainty with respect to the appropriateness of using existing rate structures to estimate disposal costs of these wastes. The approach used in this DCE to estimate waste disposal costs is discussed in the following paragraphs.

Waste Classification Regulations governing disposal of radioactive waste are stringent in order to ensure control of the waste and preclude adverse impact on public health and safety. At present, LLRW disposal is controlled by NRC regulation IO CFR 61, which went into effect December, 1983. This regulation stipulates the criteria for the establishment and operation of shallow-land LLRW burial facilities. Embodied within this regulation are criteria and classifications for packaging LLRW such that it is acceptable for burial at licensed'LLRW disposal sites.

For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemical properties that the LLRW must meet in order to be accepted at a licensed disposal site. The LLRW disposal criteria of IO CFR 61 require that LLRW generators determine the proportional amount of a number of specific radioactive isotopes present in each container of disposable LLRW. This requirement for isotopic analysis of each container of disposable LLRW is met by employing a combination of analytical techniques such as computerized analyses based upon scaling factors, sample laboratory analyses, and direct assay methods. After peiforming an isotopic analysis of each container of disposable LLRW, the waste must then be classified according to one of the classifications (Class A, B, C, or Greater Than Class C (GTCC) as defined in 10 CFR 61.

The classification of LLRW resulting from decommissioning activities is based on AIF/NESP-036 (Ref. No. 2) and NUREG/CR-0672 for Boiling Water Reactors (BWRs) (Ref. No. 8), and 8

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 recent industry experience. The estimated curie content of the reactor vessel and internals at shutdown is derived from NUREG/CR-0672 and adjusted for the different mass of components as well as the period of decay.

Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on the most restrictive of the following constraints: curie content, dose-rate, container weight limit, or container volume limit. GTCC waste from segmentation of the reactor vessel internals is packaged in MPCs. The selection of container type for Class A waste is based on the transportation mode (rail, truck, barge, etc.) and waste form. The quantity of Class A waste containers is determined by the most restrictive of either container weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactor recirculation pumps, are shipped as their own container with shielding as required.

Container costs are obtained from manufacturers. Shielded transport cask and liner costs are obtained from the cask owners and operators.

Transportation Transportation routes to processing and disposal facilities are determined based on available transportation modes (truck, rail, barge, or combinations). Transportation costs for the selected routes and modes are obtained from vendor quotes or published tariffs whenever possible.

Class A Disposal Options and Rates In accordance with the existing LOP Disposal Agreement (Ref. No. 9), all Class A waste that meets the Clive facility waste acceptance criteria is to be disposed of at Clive. All reported waste disposal costs include packaging, transportation, and any applicable surcharges.

Class B and C Disposal Options and Rates Currently, within the United States, there are only three operational commercial disposal facilities licensed to accept Class B and C LLRW: the Barnwell facility, operated by EnergySolutions in Barnwell, South Carolina; the U.S. Ecology facility in Richland, Washington; and the facility in Andrews County, Texas operated by Waste Control Specialists.

Barnwell only accepts waste from states within the Atlantic Compact, and U.S. Ecology only accepts waste from states within the Northwest and Rocky Mountain Compacts. However, the WCS facility will accept waste from the Texas Compact (comprised of Texas and Vermont) and non-Compact generators. The Texas Compact Commission on March 23, 2012 approved amendments to rules allowing the import of non-compact generator LLRW for disposal at the Andrews County facility.

Greater Than Class C (GTCC)

Wastes identified as 10 CFR 61 Class A, B, and C may be disposed of at a near-surface disposal facility. Certain components are highly activated and may exceed the radionuclide concentration limitations for 10 CFR 61 Class C waste. In accordance with 10 CFR 61, these components 9

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 cannot be disposed of in a near-surface LLRW disposal facility and must be transferred to a geologic repository or a similar site approved by the NRC.

Highly activated sections of the reactor vessel internals will result in GTCC waste. Presently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations. The courts have held that DOE is obligated to accept and dispose of GTCC and, therefore, this estimate assumes that the DOE will accept this waste along with spent fuel. Although there may be no additional costs for DOE disposal of GTCC, this estimate conservatively assumes a GTCC waste disposal cost. This estimate further assumes that the GTCC waste will be packaged in DSCs and will be shipped to a storage or disposal facility by DOE along with the spent fuel at a shipping costs equivalent to the commercial cost of shipping a Type B licensed, shielded cask such as the CNS 8-120B cask.

LLRW Volume Reduction Based on current Class A LLRW disposal rates on-site volume reduction techniques such as waste compaction or an aggressive decontamination, survey and release effort are not currently considered to be cost effective over disposal.

Non-Radioactive Non-Hazardous Waste Disposal EnergySolutions assumes that recyclable, non-radioactive scrap metal resulting from the decommissioning program will be transported to a scrap metal dealer. However, no credit is assumed in the estimate for the value of the scrap metal. Concrete debris is assumed to be processed by size reduction, with removal of structural reinforcing steel, and used on site as engineered fill for voids. Asphalt from parking lots and roadways is assumed to be stockpiled on site and removed, at no cost to the project, by a recycler. All other demolition debris is removed from the site and disposed of at a local construction debris landfill.

Hazardous and Industrial Waste Disposal Lead shielding remaining after shutdown is assumed to be removed from its installed locations and disposed of as a mixed waste. In accordance with information furnished by DAEC thirty percent of insulated systems in radiologically controlled areas are assumed to contain asbestos, therefore; this DCE includes a line item for asbestos abatement. The decommissioning estimate also includes an estimate for hazardous and industrial waste disposal based on information provided by DAEC. The cost of hazardous and industrial waste disposal includes DAEC's estimated cost for closure of Resource Conservation and Recovery Act (RCRA) storage areas.

Additionally, surfaces coated with lead based paint will be remediated as required for demolition.

3.5 Final Status Survey The cost of performing a final status survey (PSS) is based on NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Ref. No. 10). Estimates of MARSSIM Class I, II, and III survey designations are based on radiological characterization data furnished by DAEC and assumptions regarding contamination resulting from small and large component removal activities. The PSS activity cost calculation includes the in-place remote 10

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 survey of underground metal and concrete pipe, soil, and groundwater sampling and analysis.

Estimated costs for NRC and Oak Ridge Institute for Science and Education (ORISE) verification are also included, and the NRC review period is incorporated into the project schedule.

3.6 Contingency Contingencies are applied to cost estimates primarily to allow for unknown or unplanned occmTences during the actual program, e.g. increased radioactive waste materials volumes over that expected, equipment breakdowns, weather delays, labor strikes, etc. This is consistent with the definition provided in the DOE Cost Estimating Guide, DOE G 430.1-1, 3-28-97 (DOE G)

(Ref. No. 11 ): Contingency "Covers costs that may result from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope. The amount of contingency will depend on the status of design, procurement, and construction; and the complexity and uncertainties of the component parts of the project. Contingency is not to be used to avoid making an accurate assessment of expected costs." EnergySolutions determines site-specific contingency factors to be applied to each estimate based on industry practices.

The DOE has established a recommended range of contingencies as a function of completeness of program design, DOE G. The ranges are:

Contingency Range Type of Estimate as a% of Total Estimate Planning Phase Estimate 20-30 Budget Estimate 15-25 Title I (Preliminary Design Estimate) 10-20 Title II (Definitive Design Estimate) 5-15 EnergySolutions' approach to assigning appropriate contingency rates is based on adaptations of published values for the specific decommissioning activities. One source for such published information is AIF/NESP-036 "Guidelines for Producing Nuclear Plant Decommissioning Cost Estimates" (Ref. No. 2). The AIF guideline identifies contingencies for activities specific to a nuclear power plant decommissioning, such as reactor internals removal. The contingencies presented in the AIF guideline are based on the assumption that the estimated costs are not well known; therefore, the recommended contingencies are greater than they would be if the estimated costs were well known. With the exception of the system decontamination, reactor vessel and reactor internals removal, and disposal, the contingencies presented in the AIF guideline are consistent with the values presented in DOE G 430.1-1 for a Budgetffitle I estimate. The system decontamination, reactor vessel and reactor internals removal, and disposal contingencies recommended in the AIF guideline are significantly higher than the ranges identified by the DOE, even for a planning phase document. This is due to the unique nature of these activities and the relatively small amount of historical data available at the time the AIF document was written.

This estimate applies site-specific contingency factors to each WBS element based on industry practices. The contingencies rates applied in this estimate are specific to decommissioning estimates consistent with information presented in AIF guideline and DOE G. The 11

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 decommissioning costs generated in the estimate are considered well known and, as such, the contingencies presented in AIF guideline were reduced for each category of costs. There have also been a number of large-scale decommissioning projects since AIF was published, providing some histmical information that has been used in prepaiing this estimate. This allows for additional reduction in contingency costs. The following table provides a summary of contingency values applied in this estimate where the plant structures, systems, and major component material inventories are well defined, as with this study.

Package Material & Ship &

Category Labor Egui12ment Bury Other Engineering 13%

Contaminated components/Concrete 23% 23% 23%

Clean components 13% 13% 13%

Reactor Vessel and Reactor Internals 50% 23% 25%

Other 15%

The above contingency categories address the difference in uncertainty associated with performance of the work. In the case of a power plant decommissioning project, the segmentation of the reactor internals and pressure vessel and removal of radiologically contaminated plant systems and structures have the highest degree of uncertainty and are therefore assigned the higher contingency rates.

3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into the following categories - Labor, Materials and Equipment, Waste Disposal, and Other costs. Other costs include property taxes, insurance, license fees, permits, and energy. Waste Disposal costs are the summation of packaging, transportation, base disposal rate, and any applicable surcharges. Health physics (HP) supplies and small tool costs are calculated as a component of each distributed activity cost and included in the category of Material and Equipment, with the exception that HP supplies for third party HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 4.0 SITE SPECIFIC TECHNICAL APPROACH 4.1 Facility Description DAEC is a nuclear powered electrical generating facility consisting of one BWR located on a site near Palo in Linn County, Iowa. The plant site comprises approximately 500 acres adjacent to the Cedar River approximately 2.5 miles northeast of the Village of Palo, Iowa.

The nuclear system includes a single-cycle, forced-circulation, General Electric (GE) BWR producing steam for direct use in the steam turbine. The nuclear steam supply system (NSSS) and the turbine-generator were furnished by GE. The balance of plant was designed and constructed by Bechtel Power Corporation (Bechtel) as architect engineer and constructor.

The unit was originally designed, analyzed, and licensed for a steady-state core power of 1,658 MWt, although the plant Technical Specifications restricted operation to a rated power of 1,593 MWt. In 1985, the Technical Specifications were amended to allow the DAEC to operate at a steady-state power level of 1,658 MWt (License Amendment #115). Then, in 2001, the rated power level was increased again to 1,912 MWt (License Amendment #243). The current shutdown date is October 30, 2020.

Spent fuel assemblies are stored in the spent fuel storage racks in the spent fuel pool or may, after appropriate decay, be transferred to an ISFSI for interim onsite storage. The re-rack project of 1994 increased the spent fuel pool capacity to 2,411 assemblies. In addition, racks were licensed for the cask pit to retain full-core offload capability. The cask pit racks have a storage capacity of 323 assemblies, but are not licensed for long term storage.

There is an ISFSI on site that houses 10 CPR 72 licensed spent fuel storage systems that can provide interim on-site storage of spent fuel and reactor-related GTCC waste.

Appendix A provides a list of the DAEC systems and structures included in the material inventory for this study.

4.2 Decommissioning Periods for SAFSTOR The project periods for SAFSTOR consist of eleven License Termination periods, seven Spent Fuel Management periods, two Greenfield periods, and two ISFSI D&D periods. The project periods defined for this site-specific study and the major activities performed during each period are as follows:

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 License Termination Periods Decon Pd I - SAFSTOR Planning Prior to Shutdown

SAFSTOR Planning and Design

Preparation of SAFSTOR Plan and License Documents Decon Pd 2 - Transition Following Shutdown

Perform Historical Site Assessment and Site Characterization

Flush, Drain, and De-Energize Non-Essential Systems

Volume Reduce Control Rod Blades, Fuel Channels, and LPRMs

General Area Cleanup Decon Pd 3 - SAFSTOR Preparation Delay During Spent Fuel Pool Operations

Periodic Maintenance, Surveillance and Inspection of Non-fuel Related Systems and Structures Decon Pd 4 - Completion of SAFSTOR Preparations

Flush and Drain Essential Systems Following Fuel Pool Closure

Secure Site for Dormancy Period

Drain and De-Energize Remaining Systems and Secure Site Decon Pd 5 - Dormancy With Dry Storage

Periodic Maintenance, Surveillance, and Inspection of Non-fuel Related Systems and Structures

Bituminous Roof Replacement - 20 year

Bituminous Roof Replacement - 40 year Decon Pd 6 - Dormancy Only

Periodic Maintenance, Surveillance and Inspection of Non-fuel Related Systems and Structures Decon Pd 7 - Decommissioning Planning During Dormancy

Decommissioning Planning and Design

Planning and Design of Site Revitalization Decon Pd 8 - Internals Segmentation and Site Preparations

Revitalize Infrastructure and Re-Power Site

Perform Post-SAFSTOR Baseline Radiation Survey

Remove and Dispose of Spent Fuel Storage Racks

Segment, Package, and Ship Reactor Internals

Construct Site Modifications

Preparation of License Termination Plan Decon Pd 9 - Major Component and Systems Removal

Remove, Package, and Dispose of Non-Essential Systems

Segment, Package, and Dispose of Nuclear Steam Supply System

Perform Asbestos Abatement on Plant Systems

Remove and Dispose of Control Rod Drives 14

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

Package and Ship Reactor Pressure Vessel

Remove, Package, and Dispose of Remaining Active Plant Systems Decon Pd 10 - Building Decontamination

Decontaminate Structures

Remove Underground Storm Drains and Manholes

Final Status Survey for Structures

Final Status Survey for Land Areas Decon Pd 11 - License Termination

NRC Review and Approval of the Final Status Survey Spent Fuel Management Periods SNF Pd 1 - Fuel Pool Island Design

Design Spent Fuel Support System Modification

Design Control Room Relocation

Design Spent Fuel Security Modification SNF Pd 2 - Spent Fuel Cooling During Zirc Fire Window

Install Spent Fuel Pool, Control Room, and Security Modifications SNF Pd 3 - Spent Fuel Transfer to Dry Storage

Fuel Pool Operation and Maintenance

Construction of ISFSI Phase II and III Expansion

Construction of ISFSI Monitoring Building

Transfer Fuel Assemblies into MPCs SNF Pd 4 - Dry Storage During Completion SAFSTOR Preparations SNF Pd 5 - Dry Storage Dming Dormancy

Periodic Fuel Shipments to DOE SNF Pd 6 - ISFSI Demolition Delay SNF Pd 7 - ISFSI and Support Structure Clean Demolition

Demolition of HSMs and ISFSI Foundation

Demolition of ISFSI Security Building and Support Structures

Site Restoration of ISFSI site ISFSI D&D Periods (10 CFR 72.30)

ISFSI D&D Pd 1 - ISFSI D&D Planning

Preparation and NRC Review of License Termination Plan ISFSI D&D Pd 2 - ISFSI Final Status Survey

Final Status Survey of ISFSI

Preparation of FSS Report and NRC Review 15

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Greenfield Periods Gm Pd 1 - Clean Building Demolition During Decommissioning

Demolition of Structures Gm Pd 2 - Site Restoration

Finish Grading and Re-Vegetate Site 4.3 Decommissioning Staff A site-specific staffing plan was developed by DAEC and EnergySolutions based on the existing DAEC operational staff and the assumption that the decommissioning will be performed by a DGC, with oversight and management of the decommissioning operations performed by DAEC staff. It is also assumed that the DAEC staff will be supplemented by professional consulting engineering, particularly in the planning and preparation phase. The sizes of the staffs are varied in each period in accordance with regulatory requirements and the work activities. Details on the staff levels during each period are provided in Section 6.0.

4.4 Spent Fuel Management Staff The largest spent fuel staff is in place while the fuel pool is operational during the cooling period and when fuel assemblies are being transferred to dry storage. Once all spent fuel has been removed from the spent fuel pool, the staff is reduced. Details on the staff levels during each period are provided in Section 6.0.

4.5 Spent Fuel Shipments The spent fuel shipping schedule was provided by DAEC. The spent fuel shipping schedule is based on the DOE 2004 "Acceptance P1iority Ranking & Annual Capacity Report" (Ref. No. 6).

The spent fuel shipping schedule is provided in Appendix B.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 5.0 BASES OF ESTIMATE AND KEY ASSUMPTIONS The bases of, and key assumptions for, this site-specific decommissioning estimate are presented below.

1. All cost data used in this study is cmrent as of 2018 or has been escalated to 2018 dollars. Totals and subtotals have been rounded to significant figures.

2. The estimate is based on a shutdown date of October 30, 2020.

3. The decommissioning will be performed under the current regulations. These regulations require a Post-Shutdown Decommissioning Activities Report (PSDAR) to be submitted prior to, or within, two years after permanent shutdown. In addition, a certificate of permanent cessation of operations must be submitted to the NRC within 30 days of permanent cessation of operations. Certification of the final core off-load must also be submitted to the NRC upon completion of this activity. 90 days after the NRC receives the PSDAR and after submittal of both certifications, major decommissioning activities that meet the criteria of 10 CPR Part 50.59 may be performed, provided the NRC does not notify DAEC of any deficiencies.

4. The decommissioning will be performed using currently available technologies.

5. The spent fuel shipping schedule assumes DOE begins accepting spent fuel in 2030.

6. The material inventory for this estimate is based on prior EnergySolutions' take-offs and has been updated, based on information furnished by DAEC, to reflect major structural modifications.

7. All transformers on site following shutdown are assumed to be polychlorinated biphenyl (PCB)-free; therefore, this estimate does not include costs for disposition of PCB contaminated transformers.

8. Cost for transportation of clean scrap metal to a recycler is included in the estimate; however, no credit is taken for the value of the scrap metal. A portion of the concrete debris is assumed to be processed by size reduction, with removal of structural reinforcing steel, and used on site as engineered fill for voids. All other concrete and demolition debris is removed from the site and disposed of at a local off-site construction landfill.

9. This estimate is based on final site restoration to Greenfield conditions, in which all existing and proposed structures, with the exception of the switchyard, will be removed.

Clean demolition costs are based on structures removal to three feet below grade.

Clean topsoil will be imported and placed on the top three feet. The entire disturbed area of the site is to be graded, to restore the natural grade to the extent possible, and seeded.

10. Lead shielding remaining after shutdown is assumed to be disposed of as a mixed waste.

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

11. A budget for hazardous material is included in the estimate, which is based on information provided by DAEC. All other chemicals and hazardous materials present at shutdown are assumed to be removed and disposed of by the plant staff prior to decommissioning, as a normal part of plant operations.

12. No known areas of radiologically contaminated soil have been identified. Additionally, documented tritium levels in groundwater are below drinking water standards.

Therefore, no soil or groundwater remediation costs will be assumed.

13. DAEC provided information on the current amount of asbestos insulation on systems piping. It is assumed that asbestos not replaced during an outage and still remaining at shutdown will be limited to areas with higher dose rates. Therefore, this study considers that 30% of the insulation on contaminated and insulated piping will be asbestos and disposed of as Class A waste.

14. Costs for disposition of greater than Class A LLRW either currently stored on site or anticipated to be on site at the time of decommissioning are included in this estimate.

The types and quantities of greater than Class A LLRW were provided by DAEC, and include, but are not limited to the following expected to be stored in the spent fuel pool at the time of shutdown:

27 control blades 24 Local Power Range Monitors 25 blade guides 6 half blade guides

15. All Class A waste is assumed to be disposed of at EnergySolutions' facility in Clive, Utah, in accordance with the existing LOP Disposal Agreement between EnergySolutions and DAEC (Ref. No. 9).

16. DAEC furnished Class Band C waste disposal rates.

17. DAEC provided costs used to estimate the assumed GTCC disposal cost.

18. GTCC waste generated from the segmentation of the reactor internals will be packaged in MPCs. In this estimate, the MPCs are assumed to be accepted by DOE at the time of the deferred decommissioning.

19. Vessel and internals curie estimates were derived from the values for the Reference BWR vessel and internals in NUREG/CR-0672 (Ref. No. 8) and adjusted for mass and the SAFSTOR decay period.

20. The site-specific classification of radioactive wastes for DAEC identified one components within the reactor vessel (the Core Shroud) will exceed Class C limitations.

Two NUHOMs MPCs are assumed to be required and DAEC provided the estimated costs.

18

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

21. Spent fuel will remain in the spent fuel pool for approximately three years before being transferred to the ISPSI.

22. Spent fuel management costs include the purchase of dry storage MPCs and HSMs required following shutdown. An estimated cost for labor, material, and equipment for the pool to pad transfer of spent fuel to the ISPSI was provided by DAEC.

23. The existing ISPSI will have to be expanded post-shutdown in order to accommodate all spent fuel. The cost for constructing the ISPSI expansion was furnished by DAEC.

24. The ISPSI pad and HSMs are assumed to have no activated concrete or surface contamination.

25. The 10 CPR Part 50 license will be maintained until DOE has taken possession of the spent fuel.

26. State emergency preparedness, Federal Emergency Management Agency (PEMA) fees, and Environmental Permits costs are based on data furnished by DAEC and were adjusted to meet the requirements of each period based on the status of on-site spent fuel.

27. An estimate of the annual property taxes was furnished by DAEC and included in the estimate.

28. Annual NRC 10 CPR 171.15 fees, for reactors in decommissioning, of $198,000 are included in the estimate.

29. The estimate includes annual NRC inspection fees during each decommissioning period based on the type and level of activities being performed along with NRC review fees for license amendment requests, exemption requests and the License Termination Plan based on NRC's hourly rate of $275 per hour.

30. Annual operating insurance premiums were supplied by DAEC. The premium amounts were adjusted to meet the requirements of each period based on information provided by DAEC.

31. DAEC provided an annual allowance for miscellaneous materials and services to account for costs such as communications, miscellaneous utilities and services, office supplies, and consumables not captured elsewhere in the estimate.

32. DAEC staff positions and average burdened salary data were supplied by DAEC and account for fringe benefits, overhead and payroll taxes.

33. DGC staff salaries, including overhead and profit, were determined by EnergySolutions and represent EnergySolutions' standard assumptions for these rates

34. DAEC staff severance and retention costs were supplied by DAEC.

19

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

35. The cunent utility staff size is considered to be sufficiently stable to remain virtually unchanged to end of life. For this reason, the utility staff is assumed to be the same size at the time of shutdown.

36. The professional personnel used for the planning and preparation activities are assumed to be paid per diem at the rate of $93/day, based on per diem rates from U.S. General Services Administration (GSA) for Cedar Rapids, Iowa.

37. Craft labor rates were furnished by DAEC. Craft labor rates for disciplines not furnished by DAEC have been taken from the 2018 RS Means Labor Rates for the Construction Industry (Ref. No. 12), for Cedar Rapids, Iowa. Since the skilled laborers are assumed to be supplied by the local union hall, they will not be paid per diem.

38. The security guard force included in this DCE is in accordance with NRC security regulations as implemented by an NRC approved security plan and anticipated amendments to that plan applicable during each decommissioning period following shutdown.

39. This study follows the occupational exposure principles of As Low As Reasonably Achievable (ALARA) through the use of productivity loss factors that incorporate such items as the use of respiratory protection and personnel protective clothing. These factors increase the work duration and cost.

40. The costs of all required safety analyses and safety measures for the protection of the general public, the environment, and decommissioning workers are included in the cost estimates. This reflects the requirements of:

10 CFR 20 Standards for Protection Against Radiation 10 CFR 50 Domestic Licensing of Production and Utilization Facilities 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CFR 71 Packaging of Radioactive Material for Transport 10 CFR 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 29 CFR 1910 Occupational Safety and Health Standards 49 CFR 170-189 Department of Transportation Regulations Governing the Transport of Hazardous Materials Regulatory guidance is also provided by Reg. Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors.

20

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

41. Activity labor costs do not include any allowance for delays between activities, nor is there any cost allowance for craft labor retained on site while waiting for work to become available.

21

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 6.0 STUDY RESULTS 6.1 60-Year SAFSTOR, 2030 DOE Acceptance, Dry Fuel Storage Based on the following:

Shutdown on October 30, 2020.

DOE begins accepting spent fuel in 2030.

Termination of spent fuel pool operation approximately three years after permanent shutdown.

Following shutdown Phase II and III of the ISFSI will be constructed and all spent fuel will be transferred to MPCs.

SAFSTOR methodology, with decommissioning completed within 60 years of shutdown.

Decommissioning will be performed by an independent Third Party.

Spent Fuel Shipping Schedule The spent fuel shipping schedule is provided in Appendix B. All spent fuel will be removed from the spent fuel pool by the end of 2023. All spent fuel will be removed from the ISFSI by the end of 2059.

Cost and Schedule A summary project schedule is shown in Figure 6-1. A detailed schedule is provided in Appendix C. Table 6-1 summarizes the period durations and total costs, including contingency, for License Termination, Spent Fuel, Greenfield and ISFSI D&D activities. A detailed cost table is provided in Appendix D, and a table of annual expenditures is provided in Appendix E.

Project Staffing Staffing is based on the assumption that decommissioning will be pe1formed by the utility staff and a DGC. Utility staffing levels, by organizational department and function, for each period are provided in Table 6-2. DGC staffing levels, by organizational department and function, for each period are provided in Table 6-3.

Waste Disposal Volumes The estimated cubic feet of waste are summaiized as follows:

Class A 503,709 Class B 1,203 Class C 226 GTCC 128 Waste disposal volumes and costs, itemized by packaging, transportation, surcharges, and disposal costs by waste class and facility, are provided in Table 6-4. The waste disposal costs provided in Table 6-4 do not include contingency.

22

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Figure 6-1 Summary SAFSTOR Schedule 0111a-2011

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Table 6-1 Cost and Schedule Summary (2018 Dollars in Thousands)

Period No. Period Description Start End Years Total Cost License Termination (50.75(c))

Decon Pd I SAFSTOR Planning Prior to Shutdown 4/1/2019 I 0/30/2020 1.58 $11,509 Decon Pd 2 Transition Following Shutdown 10/30/2020 10/30/2021 0.99 $71,649 SAFSTOR Preparation Delay During Spent Fuel Pool Decon Pd 3 10/30/2021 8/31/2023 1.83 $20,113 Operations Decon Pd 4 Completion of SAFSTOR Preparations 8/31/2023 8/1/2024 0.91 $19,315 Decon Pd 5 Dormancy With Dry Storage 8/1/2024 10/30/2059 35.24 $64,860 Decon Pd 6 Dormancy Only 10/30/2059 9/26/2073 13.90 $37,311 Decon Pd 7 Decommissioning Planning During Dormancy 9/26/2073 3/7/2075 1.44 $50,840 Decon Pd 8 Internals Segmentation and Site Preparations 3/7/2075 7116/2076 1.36 $120,283 Decon Pd 9 Major Component and Systems Removal 7116/2076 5/19/2078 1.83 $221,117 Decon Pd 10 Building Decontamination 5/19/2078 1/3/2080 1.62 $103,240 Decon Pd 11 License Termination 1/3/2080 9/19/2080 0.71 $4,451 Account Total 61.41 $724,688 Spent Fuel (50.54(bb))

SNFPd 1 Spent Fuel Planning 4/1/2019 10/30/2020 1.58 $443 SNFPd 2 Spent Fuel Cooling During Zirc Fire Window 10/30/2020 10/30/2021 0.99 $18,432 SNFPd 3 Spent Fuel Transfer to Dry Storage 10/30/2021 8/31/2023 1.83 $111,169 Dry Storage During Completion of SAFSTOR SNFPd4 8/31/2023 8/1/2024 0.91 $2,941 Preparations SNFPd5 Dry Storage During Dormancy 811/2024 10/30/2059 35.24 $121,582 SNFPd 6 ISFSI Demolition Delay 10/30/2059 12/31/2077 18.17 $0 SNFPd 7 ISFSI and Support Structure Clean Demolition 12/31/2077 7/28/2078 0.57 $4,898 Account Total 59.29 $259,466 Greenfield Gm Pd 1 Clean Building Demolition During Decommissioning 6/22/2078 1/3/2080 1.53 $34,233 Gm Pd 2 Site Restoration 1/3/2080 5/8/2080 0.34 $2,214 Account Total 1.87 $36,447 ISFSID&D (72.30)

ISFSI D&D Pd 1 ISFSI D&D Planning 8/23/207 5 12/30/2077 2.35 $887 ISFSI D&D Pd 2 ISFSI Final Status Survey 12/30/2077 1/12/2079 1.03 $754 Account Total 3.38 $1,640 Scenario Total $1,022,240 Note: Numbers may not add due to rounding.

24

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-2 Utility Staff Levels 1 L'tcense Termmahon-5 0.75(c Uhhtv staff Decou Decon Decou Decou Decon Decou Decon Decon Decou Decon Decou Department Pd I Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Pd8 Pd9 Pd 10 Pd 11 Administration and Support I 22 3 3 0 0 3.50 10 10 8.5 3 Emergency Preparedness 0.5 0 0 0 0 0 0 0 0 0 0 Engineering, Oversight and Licensing 9.75 43 3 3 0 0 12 16.75 15.25 11 2 Executive Management 0.25 10 I I 2 2 2.50 3 3 3 I Plant Maintenance 1.5 47 4 4 I I I 19 10 5 0 Plant Operations 2 1.25 44.83 3 3 0 0 0 4 4 l 0 Quality Assurance 0 2 0 0 0 0 0 2 3 3 2 Radiation Protection & Chemistry 2.75 26 5 5 2 2 4.5 19 37 37 I Period Totals 17 194.83 19 19 5 5 23.75 73.75 82.25 68.5 9 S;neut F*ue l - 50 54(bb) UTh 1tv S ta ff Department SNF SNF SNF SNF SNF SNF SNF Pdl Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Adminisuation and Support 0 0 0 0 0 0 0.5 Emergency Preparedness 0 4 4 0 0 0 0 Engineering, Oversight and Licensing 0.75 0 0 0 0 0 1.25 Plant Maintenance 0.25 0 0 0 0 0 0 Radiation Protection & Chemistry 0 0 0 0 0 0 0.5 Spent Fuel Pool Operations 0 45 45 0 0 0 0 Period Total 1 49 49 0 0 0 2.25 1

Security staff levels are safeguards information and therefore not included.

2 Plant Operations staff during Decou Pd 2 includes personnel required to defuel the reactor.

25

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-2 (Continued)

Utility Staff Levels Green fl1eId UT tJ 1tv Staff GrnPd GrnPd Department 1 2 Administration and Support 0.5 0.5 Engineering, Oversight and Licensing 2.5 2 Executive Management 0 0.25 Quality Assurance 0.75 0 Radiation Protection & Chemistrv 0 0.25 Period Totals 3.75 3 ISFSI D&D - Utilitv Staff ISFSID&D ISFSID&D Department Pdl Pd2 Enginee1ing, Oversight and Licensing l l Quality Assurance 0 0.75 Radiation Protection & Chemistry 0.5 0.5 Period Totals 1.5 2.25 26

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-3 Decommissioning General Contractor (DGC) Staff Levels License Termination -50.75(c) DGC Staff Decon Decou Decon Decon Decon Decon Decon Decon Dec on Decon Dec on Department Pdl Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Pd8 Pd9 PdlO Pdll Administration 0 0 0 0 0 0 4 9 9 9 1 Decon Operations 0 0 0 0 0 0 2 6 18 14 0 Engineering 0 0 0 0 0 0 2.5 6 6 4.50 I Environmental Health & Safety 0 0 0 0 0 0 1.5 5 6 6 0 Executive 0 0 0 0 0 0 3 4 4 4 2 Project Controls Work Planning 0 0 0 0 0 0 4.5 7 7 5 1 Quality Assurance 0 0 0 0 0 0 0.5 1 2 2 1 Radiation Protection 0 0 0 0 0 0 1 13 33 24 1 Site Closure 0 0 0 0 0 0 0.5 2 4 5 3 Waste Operations 0 0 0 0 0 0 1 4 11 10 0 Period Totals 0 0 0 0 0 0 19 57 99.5 84 8 S>11en t F1ue I - 50 54(bb) DGC St a ff Department SNF SNF SNF SNF SNF SNF SNF Pdl Pd2 Pd3 Pd4 Pd5 Pd6 Pd7 Administration 0 0 0 0 0 0 0 Decon Operations 0 0 0 0 0 0 I Engineering 0 0 0 0 0 0 1 Environmental Health & Safety 0 0 0 0 0 0 1 Executive 0 0 0 0 0 0 0 Project Controls Work Planning 0 0 0 0 0 0 0 Quality Assurance 0 0 0 0 0 0 0 Radiation Protection 0 0 0 0 0 0 0 Site Closure 0 0 0 0 0 0 1 Waste Operations 0 0 0 0 0 0 0 Period Total 0 0 0 0 0 0 4 27

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision2 Table 6-3 (Continued)

Decommissioning General Contractor (DGC) Staff Levels Greenfield - DGC Staff GrnPd GrnPd Department 1 2 Administration 0.5 0.5 Decon Operations 2.5 2 Engineering 0 0.25 Environmental Health & Safety 0.75 0 Executive 0 0.25 Project Controls Work Planning 0 6 Quality Assurance 0 0 Radiation Protection 0 0 Site Closure 0 0 Waste Operations 0 0 Period Totals 3.75 9 ISFSI D&D - DGC Staff ISFSID&D ISFSID&D Department Pdl Pd2 Engineering, Oversight and Licensing 0 0 Quality Assurance 0 0 Radiation Protection & Chemistry 0 0 Period Totals 0 0 28

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Table 6-4 Waste Disposal Volumes Waste Waste Burial Weight Volume Volume Facility and Waste Class (LBs) (CF) (CF)

Commercial Disposal Facility for B & C Wastes Class B - Activated Hardware 47,110 308 384 Class C - Activated Hardware 91,009 226 1,670 Class B - Resin and Filters 54,926 895 1,311 193,045 1,429 3,365 GTCC 62,590 128 1,018 Ener2ySolutio11s Class A - Debris 18,599,692 329,908 456,435 Class A - Oversized Debris 7,824,790 112,378 166,355 Class A- Cask Shipment 75,416 154 1,502 Class A - Containerized Waste 207,054 2,307 4,974 Class A - Large Component 4,236,090 58,878 78,614 Mixed Waste (Lead) 30,000 85 288 30,973,042 503,709 708,169 Other Local Construction Debris Landfill 90,303,566 1,031,207 1,306,313 Process for On-Site Fill 193,657,230 2,969,411 2,969,411 Scrap Metal Recycler 26,106,954 310,382 310,382 310,067,750 4,311,000 4,586,106 Grand Total Note: Numbers may not add due to rounding.

29

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2

7.0 REFERENCES

1. Energy Solutions, LLC, "Decommissioning Cost Estimate Study for the Duane Arnold Energy Center," Document Number 82A9634, January 27, 2010.

2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

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

4. Federal Register, Vol. 4, "Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste," NRC 10 CPR Part 961 (DOE), January 1, 1999.

5. U.S. Department of Energy, "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," January 26, 2013.

6. U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report,"

DOE/RW-0567, July 2004.

7. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NUREG/CR-0130, June 1978.

8. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672, June 1980.

9. Life-of-Plant Disposal Agreement, between EnergySolutions and FPL Energy Duane Arnold, LLC, January 1st, 2007.

10. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," NUREG-1575, Rev. 1, August 2000.

11. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.

12. RS Means, "Labor Rates for the Construction Industry," 2018 30

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Appendix A List of Systems and Structures

Duane Arnold Energy Center System and Structure List Unit I Type System Name or Description ESS Area Rad Monitoring ESS Breathing Air ESS C02 Fire Protection ESS Control Bldg HV AC ESS Diesel Generator HV AC ESS Diesel Oil System ESS Domestic Water ESS Drywell Sumps ESS Fire Protection ESS Fuel Pool Cooling & Cleanup ESS Instrument Air ESS Liquid Radwaste ESS LLRPSF Area HV AC ESS LLRPSF Area Sumps ESS Offgas Exhaust ESS Primary Containment ESS Primary Containment HV AC ESS Radwaste Bldg HV AC ESS Radwaste Bldg Sumps ESS Reactor Bldg HV AC ESS Reactor Bldg Sumps ESS Reliable Hard Pipe Vent Modification ESS RW Evaporator & Solid ESS SEDS Self Engaging Dewatering System ESS Service Air ESS Solid Radwaste ESS Spent fuel pool instrumentation ESS Stack Gas & Bldg Kaman Rad Monitoring ESS Standby Diesel Generator ESS Training Center & Equipment ESS Turbine Bldg HV AC ESS Turbine RB Radwaste Bldg Sampling ESS Well Water NON Admin Bldg Sumps NON Administration Bldg HV AC NON Aux Heating Sys Boiler NON Chlorination & Acid Feed NON Circulating Water NON Condensate & Demin Water NON Condensate Demineralizer NON Condenser Air Removal NON Containment Atm Dilution NON Containment Atmosphere Control NON Cooling Tower NON Data Acquisition Center HV AC NON Drywell Radiation Monitors Page I of 4

Duane Arnold Energy Center System and Structure List Unit 1 Type System Name or Description NON Electrical NON Extract Steam Htr-Vents-Drns NON Feed water NON General Service Water NON H2 Water Chemistry NON Hydrogen Seal Oil NON Intake Structure HY AC NON Lube Oil Transfer & Storage NON Mach Shop & OG Bldg HY AC NON Makeup Demineralizer NON MiscHVAC NON Nitrogen NON Offgas Bldg Sumps NON Offgas Recombiner NON Post Accident Sampling NON Pumphouse HY AC NON Reactor Bldg Closed Cooling Water NON Reactor Water Cleanup NON Residual Heat Removal NON RHR Service Water NON River Water Supply NON Sanitary Drains NON Standby Gas Treatment NON Stator Cooling NON Technical Suppor Center HY AC NON Torus Vacuum Breakers NON Turbine Bldg Sumps NSSS Condensate NSSS Condenser NSSS CRD Hydraulic NSSS Emergency Service Water NSSS High Pressure Coolant Injection NSSS Low Pressure Core Spray NSSS Main Steam NSSS Nuclear Boiler NSSS Reactor Core Isolation Cooling NSSS Reactor Vessel Recirculation NSSS Standby Liquid Control NSSS Traversing Incore Probe Cal NSSS Turbine NSSS Turbine Steam Seals & Drains STRUC Administration Building STRUC Badging Center STRUC Breathing Air Enclosure STRUC Circulating Water Pipe STRUC Circulating Water Tower No l Page 2 of 4

Duane Arnold Energy Center System and Structure List Unit I Type System Name or Description STRUC Circulating Water Tower No 2 STRUC Civil Shop STRUC Compressor Building STRUC Condensate Storage Tank Foundation STRUC Construction Support Center STRUC Control Building STRUC Cooling Tower Control & Valve House 1 STRUC Cooling Tower Control & Valve House 2 STRUC Cooling Tower Training STRUC Data Acquisition Center STRUC Discharge Structure STRUC East Warehouse STRUC Electrical Equipment Building - ISFSI STRUC Electrical Maintenance STRUC Existing Concrete Slabs STRUC Existing Waste Water Treatment Plant STRUC FLEX Storage Building STRUC Guard Facility and Security Structures STRUC HPCI and RCIC Building STRUC Intake Structure STRUC ISFSI - Phase 3 STRUC ISFSI Electrical Equipment Bldg STRUC ISFSI Monitoring Building STRUC Kelly Building STRUC LLRPSF Transformer Foundation STRUC Low Level Radwaste Storage and Processing STRUC Machine Shop STRUC Mechanical Maintenance STRUC New Site Support Building STRUC Off Gas Retention Building STRUC Off Gas Stack STRUC Oil Drum Storage Building STRUC Plant Support Center STRUC Pump House STRUC Radwaste Building STRUC Railroad Air-Lock STRUC Reactor Building STRUC Security Mods and Upgrades STRUC Site Transformer Foundations STRUC Sluice Gate Structure STRUC Sulfuric Acid Tank Foundation STRUC Support Shop STRUC Technical Support Center STRUC Trailer Pad STRUC Training Center STRUC Turbine Building Page 3 of 4

Duane Arnold Energy Center System and Structure List Unit 1 Type System Name or Description STRUC Turbine Pedestal STRUC Underground Diesel Oil Tank STRUC Underground Fuel Oil Tank STRUC Waste Staging Area STRUC Waste Water Treatment Plant STRUC Well Water Pump House 1,2,3,4 STRUC West Warehouse Page 4 of 4

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Appendix B Spent Fuel Shipping Schedule

Duane Arnold Energy Center Spent Fuel Shipping Schedule for October 30, 2020 Shutdown Based on 2030 DOE Acceptance Assemblies Assemblies Tra11,fered from Assemblies in Total Assemblies Shipped to DOE Cumulative Fuel No Dry PooltoDty Fuel Pool Assemblies in A'semblies in Shipped to DOE fromD1y A'semblies Year Discharged Modules Storage Storage DtyStorage On Site Storage From Pool Storage Shipped to DOE 2008 0 10 0 1758 610 2368 0 0 0 2009 152 0 0 1910 610 2520 0 0 0 2010 152 0 0 2062 610 2672 0 0 0 2011 0 10 610 1452 1220 2672 0 0 0 2012 152 0 0 1604 1220 2824 0 0 0 2013 0 0 0 1604 1220 2824 0 0 0 2014 152 0 0 1756 1220 2976 0 0 0 2015 0 0 0 1756 1220 2976 0 0 0 2016 152 0 0 1908 1220 3128 0 0 0 2017 0 0 0 1908 1220 3128 0 0 0 2018 152 0 0 2060 1220 3280 0 0 0 2019 0 0 0 2060 1220 3280 0 0 0 2020 368 10 610 1818 1830 3648 0 0 0 2021 0 0 0 1818 1830 3648 0 0 0 2022 0 0 0 1818 1830 3648 0 0 0 2023 0 30 1818 0 3648 3648 0 0 0 2024 0 0 0 0 3648 3648 0 0 0 2025 0 0 0 0 3648 3648 0 0 0 2026 0 0 0 0 3648 3648 0 0 0 2027 0 0 0 0 3648 3648 0 0 0 2028 0 0 0 0 3648 3648 0 0 0 2029 0 0 0 0 3648 3648 0 0 0 2030 0 0 0 0 3648 3648 0 0 0 2031 0 0 0 0 3648 3648 0 0 0 2032 0 0 0 0 3526 3526 0 122 122 2033 0 0 0 0 3282 3282 0 244 366 2034 0 0 0 0 3099 3099 0 183 549 2035 0 0 0 0 2916 2916 0 183 732 2036 0 0 0 0 2794 2794 0 122 854 2037 0 0 0 0 2611 2611 0 183 1037 2038 0 0 0 0 2489 2489 0 122 1159 2039 0 0 0 0 2367 2367 0 122 1281 2040 0 0 0 0 2245 2245 0 122 1403 2041 0 0 0 0 2062 2062 0 183 1586 2042 0 0 0 0 1879 1879 0 183 1769 2043 0 0 0 0 1757 1757 0 122 1891 2044 0 0 0 0 1635 1635 0 122 2013 2045 0 0 0 0 1635 1635 0 0 2013 2046 0 0 0 0 1513 1513 0 122 2135 2047 0 0 0 0 1330 1330 0 183 2318 2048 0 0 0 0 1269 1269 0 61 2379 2049 0 0 0 0 1147 1147 0 122 2501 2050 0 0 0 0 1025 1025 0 122 2623 2051 0 0 0 0 903 903 0 122 2745 2052 0 0 0 0 781 781 0 122 2867 2053 0 0 0 0 659 659 0 122 2989 2054 0 0 0 0 598 598 0 61 3050 2055 0 0 0 0 476 476 0 122 3172 2056 0 0 0 0 354 354 0 122 3294 2057 0 0 0 0 232 232 0 122 3416 2058 0 0 0 0 110 110 0 122 3538 2059 0 0 0 0 0 0 0 110 3648

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 Appendix C Detailed Project Schedule

Duane Arnold Energy Center Project Schedule for SAFSTOR, 2030 DOE Acceptance, Dry Storage 1 Spenl uel lbn agemenl _ 15600 ays 04/0112019 0111212079

- -Zirconfum Afi\'ilndo*N'OOiis- - - - - - * *- - o days ***ro'30i2o2f 1 0/3512021 Spent u Shlpling Com ete - -oaays ~ ~

--stiFPdf--SPen1 FUe1P1an*n1ng ----*--*------------*-*- - -.,"'3diYS - Q.Wii2o19 *-10!30/2020 s - -sNFPCfTeegi-, .- - - - - - - - - - - - - - Odays Q.l.0 1.12<119 o~

Pfepa1a lfradi.ited F~iel lfariaQGrniir\fRM*** ******* *** * * **** '226'Ci'.i)-S SubtM EA to AJow Speilt Fuel Cos!SIOTa~MFfom DTF - o-daYs

.. ~-e ~ig ~_SpOn1Fue1 PoOI Seiurlfy f.~~-!~-~- * *** -* * - 12s-days S~F Pd 1 Ends ..*....... (fda"Y$ . " fQ."29/2020 10129/2(i20 10 - SfiF-fiif2':"Spent Fui l Cooling OurfnQZifCFiieWindciW _ _ _ _ -* ~&Jdays 1013012020 --W13012ill

- -SNtfl'd28ijliiS- - - - - - -----o-aay, -*Tdi'2972020 1tll29l2020 12 - ---.mp!1ment spen1 Fuel POCitSecu~cations * - - - ~ - 02i22i2o21 -r6i30J2021 Submit liradiateifFu"ei Man"aQCirW!n"1Plari **- ** **

0 d3Y, '6412if202i **-o412ii2ci2°1

- --- Subml1°taSkVendof.Riivls&cf"Ciiitiliiiiti01 *eo;np,ranee-ceoc1 - ..o. diVS - -o:i/2172021 --<f.i.121rio21

~lsFslon!YEmergencyPfui ys - 1 21 06/18/2021

- -SulitrttJJffOtlSFSTOnty Tecl!Spe~Wf"OA-Pfan -- ---oaiVi -- ~ 06/18/2021 Submit LAA for Pe1maneni1Y Oetueled Security Pfiill - -0 ays 10l30/2021 --r-Cl/30/2021 1 --*-sNi:P<r:rrnas - ------------------ - * -ocrays 10i3M02T-ro/3Q12021-

- SNF Pd 3 "- Spe"n1-FueJTranS1!r iO o,y*sto r3~ie *-* *-* *-* *-* - * -479 days 10cio/2021 --*olii3fi202l

- SNFPd-38&gins- ---------- Odays 10'30/2021 - ffii30!2o2 1 21 - -con stitictfSFSIPhase 2 3 i'adExpaiiS!On - -T20"'days 1li01l202 1 -ol1"fSl20'22

- - - - speni*i:ueffio01*t0*pacrrrru1sier****** * **************** ***:i00*aays ****04*lisno22 * **6&1Ji"i26ij.

J -----*--eonr:irucn~sn:1on11onng-eulding -- ------------------- - *180"diY$ *- 1212Ji2022 ---Ga.i31t202J

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2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 AppendixD Detailed Cost Table

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Altemative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Altemative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total A. License Termination Decou Pd 1 SAFSTOR Planning Prior to Shutdown Distributed 1.01 Planning of Historical Site Assessment (HSA) and Scoping Survey $233 $4 $0 $0 $31 $269 1.02 Perform HSA $207 $2 $0 $0 $27 $236 1.03 Perform Scoping Survey $249 $122 $0 $565 $122 $1,058 1.04 Perform SAFSTOR Planning and Design $481 $29 $0 $0 $66 $576 1.05 NRC Review of PSDAR and DCE $0 $0 $0 $264 $34 $298 1.06 Preparation of SAFSTOR License Documents $2,741 $15 $0 $165 $380 S3,301 1.07 Prepare SAFSTOR Integrated Work Schedule $78 $9 $0 $0 $11 $97 1.08 Prepare SAFSTOR Activity Specifications $490 $4 $0 $0 $64 $558 1.09 Prepare Detailed SAFSTOR Work Procedures $764 $0 $0 $0 $99 $864 I.IO Pe1fon11 Prut 37 and SNM Assessment $0 $0 $0 $50 $7 $57 Distributed Subtotal $5,243 $185 $0 $1,044 $841 $7,314 Undistributed 1.01 Utility Staff $3,557 $0 $0 $0 $462 $4,020 1.03 Security $147 $0 $0 $0 $22 $169 l.16 Workers Comprehensive Insurance $0 $5 $0 $0 $1 $6 Undistributed Subtotal $3,705 $5 $0 $0 $485 $4,195 Decon Pd 1 Subtotal $8,948 $190 $0 $1,044 $1,327 $11,509 Pagel of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 2 Transition Following Shutdown Distributed 2.0 I Submit Notification of Cessation of Operations $0 $0 $0 $0 $0 so 2.02 Defuel Reactor $1,160 $0 $0 $0 $151 SI,311 2.03 Submit Notification of Fuel Removal from Vessel $0 $0 $0 $0 $0 so 2.04 NRC Review of Post-Shutdown LARs and ERs $0 $0 $0 $564 $73 $637 2.05 Perform Activation Analyses of Reactor and Internals $49 $4 $0 $308 $47 $408 2.06 Volume Reduce Control Rods, Fuel Channels and LPRMS $1,744 $672 $16,716 $0 $4,400 $23,533 2.07 Flush and Drain Non-Essential Systems $44 $8 $1,016 $0 $246 $1,313 2.08 Remove and Dispose of Hazardous Waste $0 $0 $0 $185 $28 $213 2.09 Drain and Process Suppression Pool Water and Hydrolase Torus Walls $0 $0 $0 $0 $0 so Distributed Subtotal $2,996 $685 $17,732 $1,057 $4,945 $27,414 Undistributed 1.01 Utility Staff $23,471 $0 $0 $0 $3,051 $26,522 1.02 Utility Staff HP Supplies $0 $581 $0 $0 $87 $668 1.04 Nuclear Properly and Liability Insurance $0 $0 $0 $271 $41 $311 1.05 Non-Nuclear Insurance $0 $0 $0 $45 $7 $52 1.06 Property Taxes $0 $0 $0 $100 $15 $115 1.07 NRC Annual Fees - LT $0 $0 $0 $462 $69 $531 1.08 Materials and Services $0 $3,238 $0 $0 $486 $3,724 1.09 Energy $0 $0 $0 $2,408 $361 $2,769 I.I 0 Environmental Penni ts and Fees $0 $0 $0 $8 $1 $9 1.13 DAW Disposal $0 $0 $27 $0 $4 $31 1.14 Severance $7,786 $0 $0 $0 $1,168 $8,954 1.15 Retention $443 $0 $0 $0 $66 $509 1.16 Workers Comprehensive Insurance $0 $35 $0 $0 $5 $40 Undistributed Subtotal $31,699 $3,853 $27 $3,294 $5,362 $44,234 Decon Pd 2 Subtotal $34,695 $4,538 $17,759 $4,350 $10,306 $71,649 Page 2 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: I0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Desctiption Labor Equipment Disposal Other Contingency Total Decon Pd 3 SAFSTOR Preparation Delay During Spent Fuel Pool Operations Undistributed 1.0 I Utility Staff $4,362 $0 $0 $0 $567 S4,929 1.02 Utility Staff HP Supplies $0 $199 $0 $0 $30 $229 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $170 $25 $195 1.05 Non-Nuclear Insurance $0 $0 $0 $83 $13 $96 1.06 Property Taxes $0 $0 $0 $183 $28 $211 1.07 NRC Annual Fees - LT $0 $0 $0 $508 $76 $585 1.08 Materials and Services $0 $604 $0 $0 $91 $694 1.09 Energy $0 $0 $0 $1,879 $282 $2,161 I. I 0 Environmental Permits and Fees $0 $0 $0 $14 $2 $17 1.13 DAW Disposal $0 $0 $5 $0 $1 $6 1.14 Severance $9,550 $0 $0 $0 $1,433 $10,983 1.16 Workers Comprehensive Insurance $0 $6 $0 $0 $1 $7 Undistributed Subtotal $13,912 $810 $5 $2,839 $2,548 $20,113 Decon Pd 3 Subtotal $13,912 $810 $5 $2,839 $2,548 $20,113 Page 3 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit I Shut Down: I0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decou Pd 4 Completion of SAFSTOR Preparations Distributed 4.01 Drain Spent Fuel Pool and Process Liquid Waste $0 $0 $0 $0 $0 $0 4.02 Plush and Drain Essential Systems Following Fuel Pool Closure $27 $14 $1,016 $0 $243 $1,300 4.03 Removal and Disposal of Spent Resins, Filter Media and Tank Sludge $28 $28 $2,540 $0 $597 $3,194 4.04 Segment, Package and Dispose of Spent Fuel Pool Island Equipment $7 $2 $190 $0 $46 $245 4.05 General Area Cleanup $1,511 $694 $195 $0 $552 $2,952 4.06 Secure Site for Dormancy Period $0 $0 $0 $1,845 $277 $2,122 Distributed Subtotal $1,574 $738 $3,941 $1,845 $1,715 $9,812 Undistributed 1.01 Utility Staff $2,187 $0 $0 $0 $284 $2,472 1.02 Utility Staff HP Supplies $0 $100 $0 $0 $15 $115 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $73 $11 $84 1.05 Non-Nuclear Insurance $0 $0 $0 $42 $6 $48 1.06 Property Taxes $0 $0 $0 $92 $14 $106 1.07 NRC Annual Fees - LT $0 $0 $0 $425 $64 $489 1.08 Materials and Services $0 $303 $0 $0 $45 $348 1.09 Energy $0 $0 $0 $497 $75 $572 1.10 Environmental Permits and Fees $0 $0 $0 $7 $1 $8 1.13 DAW Disposal $0 $0 $22 $0 $3 $25 1.14 Severance $4,550 $0 $0 $0 $683 $5,233 1.16 Workers Comprehensive Insurance $0 $3 $0 $0 $0 $4 Undistributed Subtotal $6,737 $406 $22 $1,137 $1,202 $9,504 Decou Pd 4 Subtotal $8,311 $1,144 $3,963 $2,981 $2,916 $19,315 Page4 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Altemative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 5 Dormancy With Dry Storage Distributed 5.01 Bituminous Roof Replacement - 20 year $421 $106 $31 $0 $84 $642 5.02 Bituminous Roof Replacement - 40 year $421 $106 $31 $0 $84 $642 Distributed Subtotal $842 $212 $61 $0 $167 $1,283 Undistributed 1.01 Utility Staff $25,720 $0 $0 $0 $3,344 $29,063 1.02 Utility Staff HP Supplies $0 $1,607 $0 $0 $241 Sl,848 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $2,798 $420 $3,217 1.05 Non-Nuclear Insurance $0 $0 $0 $801 $120 $921 1.06 Property Taxes $0 $0 $0 $641 $96 $737 1.06 Property Taxes $0 $0 $0 $1,491 $224 $1,715 1.07 NRC Annual Fees - LT $0 $0 $0 $9,770 $1,466 $11,236 1.08 Materials and Services $0 $3,053 $0 $0 $458 $3,511 1.09 Energy $0 $0 $0 $8,841 $1,326 $10,167 1.10 Environmental Pennits and Fees $0 $0 $0 $279 $42 $320 1.13 DAW Disposal $0 $0 $31 $0 $5 $36 1.14 Severance $668 $0 $0 $0 $100 $768 1.16 Workers Comprehensive Insurance $0 $33 $0 $0 $5 $38 Undistributed Subtotal $26,388 $4,693 $31 $24,620 $7,845 $63,577 Decon Pd 5 Subtotal $27,229 $4,905 $93 $24,620 $8,013 $64,860 Page 5 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit 1Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 6 Dormancy Only Undistributed l.01 Utility Staff $10,150 $0 $0 $0 $1,319 $11,469 l.02 Utility Staff HP Supplies $0 $634 $0 $0 $95 $729 1.03 Security $5,209 $0 $0 $0 $781 $5,991 l.04 Nuclear Property and Liability Insurance $0 $0 $0 $4,416 $662 $5,078 1.05 Non-Nuclear Insurance $0 $0 $0 $316 $47 $364 1.06 Property Taxes $0 $0 $0 $348 $52 $400 1.07 NRC Annual Fees - LT $0 $0 $0 $3,855 $578 $4,434 1.08 Materials and Services $0 $2,651 $0 $0 $398 $3,048 l.09 Energy $0 $0 $0 $4,299 $645 $4,944 1.10 Environmental Pennil) and Fees $0 $0 $0 $ll0 $16 $126 1.13 DAW Disposal $0 $0 $12 $0 $2 $14 1.14 Severance $592 $0 $0 $0 $89 $681 1.16 Workers Comprehensive Insurance $0 $28 $0 $0 $4 $33 Undistributed Subtotal $15,951 $3,313 $12 $13,345 $4,690 $37,311 Dccon Pd 6 Subtotal $15,951 $3,313 $12 $13,345 $4,690 $37,311 Page 6 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Dccon Pd 7 Decommissioning Planning During Dormancy Distributed 7.01 Install Office Trailer Complex $0 $0 $0 $3,543 $532 $4,075 7.02 Select Decommissioning General Conu*actor $351 $5 $0 $0 $46 $403 7.03 Post SAFSTOR Decommissioning Planning $225 $0 $0 $0 $29 $254 7.04 Planning Post SAFSTOR Site Characterization $131 $2 $0 $0 $17 $151 7.05 Planning for Asbestos Abatement $137 $2 $0 $0 $18 $157 7.06 Prepare Integrated Work Sequence and Schedule for Decommissioning $179 $0 $0 $0 $23 $202 7.07 Prepare Decommissioning Activity Specifications $2,201 $19 $0 $0 $289 $2,508 7.08 Prepare Detailed Work Procedures for Decommissioning $2,154 $0 $0 $0 $280 $2,434 7.09 Update Decommissioning Cost Estimate (DCE) $281 $1 $0 $0 $37 $318 7.10 Update Post-Shutdown Decommi"ioning Activities Report (PSDAR) $229 $1 $0 $0 $30 $259 7.ll Planning and Design of Site Revitilization $1,038 $18 $0 $0 $137 Sl,193 7.12 Planning and Design Rail Spur Upgrade $252 $10 $0 $0 $34 $296 7.13 Planning and Design Cold & Dark Site Repowering $593 $7 $0 $0 $78 $677 7.14 Develop Eftluenl Management Plan $93 $0 $0 $0 $12 $105 7.15 Design Liquid Radwaste Treatment and Demin Makeup Water Systems $175 $0 $0 $0 $23 $198 7.16 Prepare and Submit Environmental Permits $112 $0 $0 $0 $15 $126 7.17 Design Containment Access Modifications $227 $3 $0 $0 $30 $260 7.18 Design and Procure RPV /RV! Segmentation Tooling and Equipment $2,068 $19,000 $0 $0 $2,739 $23,807 7.19 Select Shipping Casks and Obtain Shipping Permits $38 $0 $0 $0 $5 $43 7.20 Purchase Canisters for Gree Waste $0 $1,588 $0 $0 $238 Sl,826 Distributed Subtotal $10,482 $20,656 $0 $3,543 $4,611 $39,293 Undistributed I.OJ Utility Staff $4,470 $0 $0 $0 $581 $5,051 1.02 Utility Staff HP Supplies $0 $157 $0 $0 $23 $180 1.03 Security $540 $0 $0 $0 $81 $621 1.04 Nuclear Properly and Liability Insurance $0 $0 $0 $458 $69 $527 Page 7 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit IShut Down: I0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.05 Non-Nuclear Insurance $0 $0 $0 $33 $5 $38 1.06 Property Taxes $0 $0 $0 S36 $5 $41 1.07 NRC Annual Fee., - LT $0 $0 $0 $400 $60 $460 1.08 Materials and Services $0 $744 $0 $0 $112 $855 1.09 Energy $0 $0 $0 $661 $99 $760 I.IO Environmental Permits and Fees $0 $0 $0 Sil $2 $13 1.11 Decommissioning General Contractor Staff $2,599 $0 $0 $0 $338 $2,936 l.12 DGC HP Supplies $0 $43 $0 $0 $6 $50 1.13 DAW Disposal $0 $0 $4 $0 $1 S4 1.16 Workers Comprehensive Insurance $0 $8 $0 $0 $1 S9 Undistributed Subtotal $7,609 $951 $4 $1,600 $1,383 $11,547 Decon Pd 7 Subtotal $18,091 $21,607 $4 $5,143 $5,994 $50,840 Page 8 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 8 Internals Segmentation and Sile Preparations Distributed 8.01 Revitalize Infrastructure $0 $0 $0 $17,683 $2,652 $20,336 8.02 Implement Cold & Dark $3,095 $5,023 $0 $0 $1,218 $9,336 8.03 Install Liquid Radwasle Treatment System $0 $0 $0 $1,750 $263 $2,013 8.04 Install Demin Makeup Water System for RV! Segementation $0 $0 $0 $313 $47 $360 8.05 Perform Post-SAFSTOR Site Characterization $367 $250 $0 $0 $80 $698 8.06 Prepare License Tcrntlnation Plan (L'l1') $331 $10 $0 $0 $44 $385 8.07 Remove and Dispose of Spent Fuel Storage Racks $124 $281 $1,683 $0 $480 $2,569 8.08 Segment and Dispose of Drywcll Head $142 $31 $49 $0 $51 $274 8.09 Reflood RPV and Steam Separator Pool for RV! Segmentation $129 $80 $0 $0 $48 $257 8.10 Remove and Dispose of Rx Head $151 $26 $757 $0 $271 $1,205 8.11 Test Special Cutting and Handling Equipment and Train Operators $1,335 $217 $0 $0 $202 $1,753 8.12 Finalize Internals and Vessel Segmenting Details $23 $0 $0 $0 $3 $26 8.13 Segment, Package and Ship Reactor Internals $4,247 $1,449 $12,486 $0 $5,578 $23,760 8.14 RVI GTCC Waste Transportation and Disposal $0 $0 $5,674 $2,288 $1,648 $9,610 8.15 Construct New Change Rooms, Hot Laundty, Waste Staging Area $0 $1,192 $0 $0 $179 $1,371 8.16 Modify Containment Access $454 $837 $0 $0 $194 Sl,484 8.17 Upgrade Rail Spur $0 $0 $0 $2,410 $362 $2,772 8.18 Install Truck Radiological Monitming System $0 $0 $0 $500 $75 $575 Distributed Subtotal $10,397 $9,397 $20,649 $24,944 $13,395 $78,782 Undistributed l.01 Utility Staff $12,716 $0 $0 $0 $1,653 $14,369 l.02 Utility Staff HP Supplies $0 $533 $0 $0 $80 $613 l.03 Secmity $5JO $0 $0 $0 $76 $586 l.04 Nuclear Properly and Liability Insurance $0 $0 $0 $432 $65 $497 l.05 Non~Nuclear Insurance $0 $0 $0 $62 $9 $71 1.06 Property Taxes $0 $0 $0 $34 $5 $39 Page 9 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: I0/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.07 NRC Annual Fees - LT $0 $0 $0 $629 $94 $723 1.08 Materials and Services $0 $1,880 $0 $0 $282 $2,162 1.09 Energy $0 $0 $0 $727 $109 $836 I.IO Environmental Pennits and Fees $0 $0 $0 $11 $2 $12 I.II Decommissioning General Conn*actor Staff $18,350 $0 $0 $0 $2,386 $20,736 1.12 DOC HP Supplies $0 $598 $0 $0 $90 $687 1.13 DAW Disposal $0 $0 $127 $0 $19 $146 1.16 Workers Comprehensive Insurance $0 $20 $0 $0 $3 $23 Undistrihutcd Subtotal $31,576 $3,031 $127 $1,894 $4,873 $41,501 Decon Pd 8 Subtotal $41,973 $12,428 $20,776 $26,838 $18,267 $120,283 Page 10 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 111/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decou Pd 9 Major Component and Systems Removal Distributed 9.01 Procure Non-Engineered Standard Equipment $0 $8,303 $0 $0 $1,079 $9,382 9.02 NRC Review and Approval of License Termination Plan $0 $0 $0 $1,078 $140 Sl,218 9.03 Remove, Package and Dispose of Non-Essential Systems $12,884 $3,111 $12,412 $0 $6,534 $34,941 9.04 Perform Asbestos Abatement on Plant Systems $750 $319 $1,096 $0 $498 $2,663 9.05 Removal and Disposal of Off Gas System Adsorber $28 $28 $3,175 $0 $743 $3,974 9.06 Segment, Package and Dispose of Nuclear Steam Supply System $4,432 $1,445 $39,047 $0 $10,333 $55,257 9.07 Remove, Package and Dispose of Remaining Active Plant Systems $4,379 $1,359 $4,451 $0 $2,344 $12,533 9.08 Remove and Dispose of Control Rod Drives $330 $79 $1,585 $0 $458 $2,452 9.09 Remove and Dispose of Shield Plugs, Pool Plugs and Stud Tensioners $82 $58 $1,774 $0 $440 $2,354 9.10 Reactor Vessel Insulation Removal and Disposal $123 $21 $384 $0 $122 $650 9.11 Segment, Package and Ship Reactor Pressure Vessel $3,328 $1,394 $5,761 $0 $3,425 $13,908 9.12 Drain Dryer Separator Pool and Process Liquid Waste $0 $0 $0 $0 $0 so 9.13 Transportation and Disposal of Liquid Rad waste Filters and Resins $13 $103 $272 $0 $89 $477 9.14 Removal and Disposal of Sacrificial Shield Wall and Reactor Pedestal $399 $606 $974 $0 $455 $2,433 9.15 Segment, Package and Dispose of Refueling Bridge 560 $13 $313 $0 $89 $475 9.16 Removal and Disposal of Lead Shielding $29 $8 $181 $0 $50 $267 Distributed Subtotal $26,836 $16,847 $71,426 $1,078 $26,799 $142,987 Undistributed 1.01 Utility Staff $18,319 $0 $0 $0 $2,381 $20,701 1.02 Utility Staff llP Supplies $0 $1,648 $0 $0 $247 $1,895 1.03 Security $689 $0 $0 $0 $103 $792 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $584 $88 $672 1.05 Non-Nuclear Insurance $0 $0 $0 $84 $13 $96 1.06 Property Taxes $0 $0 $0 $46 $7 $53 1.07 NRC Annual Fees - LT $0 $0 $0 $850 $128 $978 1.08 Materials and Services $0 $2,813 $0 $0 $422 $3,235 Pagel l of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total l.09 Energy $0 $0 $0 $834 $125 $960 l.10 Environmental Pennils and Fees $0 $0 $0 $15 $2 $17 [.(( Decommissioning General Contractor Staff $39,987 $0 $0 $0 $5,198 $45,186 1.12 DOC HP Supplies $0 $2,807 $0 $0 $421 $3,228 l.13 DAW Disposal $0 $0 $247 $0 $37 $284 l.16 Workers Comprehensive Insurance $0 $30 $0 $0 $5 $35 Undistributed Subtotal $58,995 $7,298 $247 $2,413 $9,177 $78,131 Decon Pd 9 Subtotal $85,831 $24,146 $71,674 $3,491 $35,976 $221,117 Page 12 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total Decon Pd 10 Building Decontamination Distributed 10.01 Procure Non-Engineered Standard Equipment $0 $1,453 $0 $0 $189 Sl,642 10.02 Decon Reactor Building $4,057 $3,031 $9,241 $0 $3,756 $20,085 10.03 Decon Turbine Building $745 $1,046 $771 $0 $589 $3,151 10.04 Decon Radwaste Building $162 $201 $253 $0 $142 $758 10.05 Decon HPCI and RCIC Building $35 $53 $35 $0 $29 $152 10.06 Decon Administration Building $13 $7 $14 $0 $8 $42 10.07 Decon Off-Gas Retention Building $60 $25 $29 $0 $26 $141 10.08 Decon Low Level Radwaste Storage and Processing $287 $426 $361 $0 $247 $1,321 10.09 Decon Off-Gas Stack $69 $53 $188 $0 $71 $382 10.10 Segment, Package and Dispose of Contaminated Decon Equipment and Tooling $24 $6 $172 $0 $46 $249 IO.I I Remove Underground Stonn Drains and Manholes $33 $30 $45 $0 $25 $133 10.12 Transpmtation and Disposal of Liquid Radwaste Filters and Resins $13 $3 $272 $0 $66 $354 10.13 Demolish Waste Staging Area $543 $322 $2,441 $0 $761 $4,067 10.14 Final Status Survey for Structures $4,564 $4,377 $0 $1,087 $1,304 $11,332 10.15 Final Status Survey for Land Areas $712 $392 $0 $0 $144 $1,248 Distributed Subtotal $11,318 $11,426 $13,823 $1,087 $7,402 $45,056 Undistributed 1.01 Utility Staff $13,175 $0 $0 $0 $1,713 $14,888 1.02 Utility Staff HP Supplies $0 $1,457 $0 $0 $219 Sl,675 1.03 Security $609 $0 $0 $0 $91 $700 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $516 $77 $594 1.05 Non-Nuclear Insurance $0 $0 $0 $74 $11 $85 1.06 Property Taxes $0 $0 $0 $41 $6 $47 1.07 NRC Annual Fees - LT $0 $0 $0 $751 $113 $864 1.08 Matetials and Services $0 $2,099 $0 $0 $315 $2,414 1.09 Energy $0 $0 $0 $690 $104 $794 Page 13 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit 1Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 1.10 Environmental Permits and Fees $0 $0 $0 $13 $2 $15 1.11 Decommissioning General Contractor Staff $29,651 $0 $0 $0 $3,855 $33,506 1.12 DOC HP Supplies $0 $2,071 $0 $0 $311 $2,382 1.13 DAW Disposal $0 $0 $168 $0 $25 $194 1.16 Workers Comprehensive Insurance $0 $23 $0 $0 $3 $26 Undistributed Subtotal $43,435 $5,650 $168 $2,086 $6,844 $58,184 Decon Pd 10 Subtotal $54,754 $17,076 $13,991 $3,173 $14,246 $103,240 Decon Pd 11 License Termination Distributed 11.01 Prepare Final Status Survey Report $64 $2 $0 $0 $9 $74 11.02 NRC Review and Approval of FSS Report $0 $0 $0 $539 $70 $609 Distributed Subtotal $64 $2 $0 $539 $79 $683 Undistributed 1.01 Utility Staff $828 $0 $0 $0 $108 $936 1.03 Security $267 $0 $0 $0 $40 $307 1.04 Nuclear Property and Liability Insurance $0 $0 $0 $226 $34 $260 1.05 NonwNuclear Insunmce $0 $0 $0 $16 $2 $19 1.06 Property Taxes $0 $0 $0 $18 $3 $20 1.07 NRC Annual Fees - LT $0 $0 $0 $141 $21 $162 1.08 Materials and Services $0 $185 $0 $0 $28 $213 1.09 Energy $0 $0 $0 $4 $1 $5 1.11 Decommissioning General Contractor Staff $1,632 $0 $0 $0 $212 Sl,844 1.16 Workers Comprehensive Insurance $0 $2 $0 $0 $0 $2 Undistributed Subtotal $2,727 $187 $0 $405 $449 $3,768 Decon Pd 11 Subtotal $2,791 $189 $0 $944 $527 $4,451 A. License Termination Subtotal $312,486 $90,346 $128,277 $88,768 $104,811 $724,688 Page 14 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unil 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Tola! B. Spent Fuel SNF Pd 1 Spent Fuel Planning Distributed 12.01 Prepare hrndiated Fuel Management Plan $101 $1 $0 $0 $13 $115 12.02 Submit ER to Allow Spent Fuel Costs to Taken From DTF $0 $0 $0 $0 $0 so 12.03 Design Spent Fuel Storage Security Modifications $50 $0 $0 $0 $7 $57 Distributed Subtotal $151 $1 $0 $0 $20 $172 Undistributed 2.01 Utility Staff $240 $0 $0 $0 $31 $271 2.13 Workers Comprehensive Insurance $0 $0 $0 $0 $0 so Undistributed Subtotal $240 $0 $0 $0 $31 $272 SNF Pd 1 Subtotal $391 $1 $0 $0 $51 $443 Page 15 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd2 Spent Fuel Cooling During Zirc Fire Window Distributed 13.01 Implement Spent Fuel Pool Security Modifications $50 $250 $0 $0 $45 $345 Distributed Subtotal $50 $250 $0 $0 $45 $345 Undistributed 2.01 Utility Staff $524 $0 $0 $0 $68 $592 2.02 Utility Staff HP Supplies $0 $!71 $0 $0 $26 $197 2.03 Secmity $5,679 $0 $0 $0 $852 $6,531 2.04 Spent Fuel Pool Operations Staff $6,084 $0 $0 $0 $791 $6,875 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $812 $122 $934 2.09 Materials and Services $0 $576 $0 $0 $86 $662 2.10 Emergency Preparedness Fees $0 $0 $0 $961 $144 Sl,105 2.11 EP!an On-Call Shift Pay $0 $76 $0 $0 $11 $88 2.13 Workers Comprehensive Insurance $0 $25 $0 $0 $4 $28 2.14 Spent Fuel Maintenance $0 $0 $0 $500 $75 $575 2.15 Energy $0 $0 $0 $431 $65 $495 2.17 DAW Disposal $0 $0 $4 $0 $1 $5 Undistributed Subtotal $12,287 $848 $4 $2,704 $2,244 $18,087 SNF Pd 2 Subtotal $12,337 $1,098 $4 $2,704 $2,289 $18,432 Page 16 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd3 Spent Fuel Transrer to Dry Storage Distributed 14.01 Construct ISFSI Phase 2 and 3 Pad Expansion $0 $0 $0 $2,250 $338 S2,588 14.02 Spent Fuel Pool to Pad Transfer $0 $49,208 $0 $16,948 $9,923 $76,079 14.03 Construct ISFSI Monitoring Building $0 $0 $0 $2,000 $300 52,300 Distributed Subtotal $0 $49,208 $0 $21,198 $10,561 $80,967 Undistributed 2.01 Utility Staff $961 $0 $0 $0 $125 Sl,086 2.02 Utility Staff HP Supplies $0 $315 $0 $0 $47 $362 2.03 Security $10,425 $0 $0 $0 $1,564 $11,989 2.04 Spent Fuel Pool Operations Staff $11,167 $0 $0 $0 $1,452 $12,619 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $509 $76 $585 2.09 Materials and Services $0 $1,057 $0 $0 $159 Sl,215 2.11 EPlan On-Call Shift Pay $0 $140 $0 $0 $21 $161 2.13 Workers Comprehensive Insurance $0 $45 $0 $0 $7 $52 2.14 Spent Fuel Maintenance $0 $0 $0 $917 $138 Sl,055 2.15 Energy $0 $0 $0 $930 $139 $1,069 2.17 DAW Disposal $0 $0 $8 $0 $1 $9 Undistributed Subtotal $22,554 $1,557 $8 $2,356 $3,729 $30,203 SNFPd3 Subtotal $22,554 $50,765 $8 $23,554 $14,289 $111,169 Page 17 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems .Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNF Pd4 Dry Storage During Completion of SAFSTOR Preparations Undistributed 2.03 Security $2,031 $0 $0 $0 $305 $2,336 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $219 $33 $252 2.08 NRC Annual Fees - SNF $0 $0 $0 $33 $5 $38 2.09 Materials and Services $0 $128 $0 $0 $19 $147 2.13 Workers Comprehensive Insurance $0 $5 $0 $0 $1 $6 2.14 Spent Fuel Maintenance $0 $0 $0 $115 $17 $132 2.15 Energy $0 $0 $0 $26 $4 $30 Undistributed Subtotal $2,031 $133 $0 $393 $384 $2,941 SNFPd4 Subtotal $2,031 $133 $0 $393 $384 $2,941 SNFPdS Dry Storage During Dormancy Distributed 16.01 Spent Fuel Transfer to DOE $0 $0 $0 $6,628 $994 $7,622 Distributed Subtotal $0 $0 $0 $6,628 $994 $7,622 Undistributed 2.03 Security $77,828 $0 $0 $0 $11,674 $89,502 2.05 Nuclear Property and Liability Insurance $0 $0 $0 $8,393 $1,259 $9,651 2.08 NRC Annual Fees - SNF $0 $0 $0 $1,265 $190 SI,455 2.09 Materials and Se1vices $0 $4,885 $0 $0 $733 $5,618 2.13 Workers Comprehensive Insurance $0 $210 $0 $0 $31 $241 2.14 Spent Fuel Maintenance $0 $0 $0 $4,406 $661 $5,067 2.15 Energy $0 $0 $0 $2,109 $316 $2,426 Undistributed Subtotal $77,828 $5,095 $0 $16,172 $14,864 $113,959 SNFPd5 Subtotal $77,828 $5,095 $0 $22,801 $15,858 $121,582 Page 18 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit I Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total SNFPd7 ISFSI and Support Structure Clean Demolition Distributed 18.01 Clean Demolition ofISFSI $802 $990 $1,351 $0 $409 $3,551 18.02 Demolish ISFSI Support Structures $!37 $110 $115 $0 $47 $409 18.03 Backfill and Grade JSFSI Site $23 $18 $0 $0 $5 $46 Distributed Subtotal $962 $1,118 $1,466 $0 $461 $4,006 Undistributed 2.0 I Utility Staff $173 $0 $0 $0 $23 $196 2.09 Materials and Services $0 $6 $0 $0 $1 $6 2.13 Workers Comprehensive Insurance $0 $0 $0 $0 $0 so 2.15 Energy $0 $0 $0 $45 $7 $52 2.16 Decommissioning General CmlU'actor Staff $564 $0 $0 $0 $73 $637 Undistributed Subtotal $737 $6 $0 $45 $103 $892 SNFPd7 Subtotal $1,699 $1,124 $1,466 $45 $564 $4,898 B. Spent Fuel Subtotal $116,840 $58,216 $1,478 $49,496 $33,436 $259,466 Page 19 of22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Reposito1y Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total C. Greenfield Grn Pd 1 Clean Building Demolition During Decommissioning Distributed 19.0l Prepare Site Restoration Demolition Plan and Schedule $!08 $15 $0 $0 $16 $140 19.02 Obtain Required Demolition Permits $28 $5 $0 $!0 $6 $49 19.03 Clean Building Demolition Equipment $0 $1,086 $0 $0 $163 $1,249 19.04 Perform Pre-Demolition Asbestos Abatement $12 $145 $0 $55 $32 $244 l 9.05 Remove and Dispose of Underground Storage Tanks $19 $27 $0 $0 $6 $53 19.06 Demolish Non-Essential Structures $972 $670 $682 $0 $302 $2,626 19.07 Demolish Training Center $91 $46 $47 $0 $24 $208 l 9.08 Demolish Plant Support Center and New Site Support Building $249 $159 $162 $0 $74 $644 19.09 Demolish Cooling Towers and Related Structures $741 $450 $249 $0 $187 Sl,627 19.10 Demolish Existing Waste Water Treatment Plant $27 $7 $4 $0 $5 $43

19. l l Demolish Intake and Discharge Structures $128 $187 $33 $0 $45 $393 19.12 Demolish Data Acquisition and Technical Support Building $212 $157 $147 $0 $67 $584 19.13 Demolish Guard Facility and Security Structures $545 $237 $184 $0 $126 Sl,092 19.14 Demolish Control and Administrative Buildings $470 $329 $284 $0 $141 $1,223 19.15 Demolish Turbine Building $2,366 $1,162 $206 $0 $485 $4,219 19.16 Demolish Low-Level Radwaste Building $1,413 $1,360 $826 $0 $468 $4,068 19.17 Demolish HPCl and RCIC Building $179 $79 $9 $0 $35 $302 19.18 Demolish Reactor Building $3,078 $1,902 $401 $0 $699 $6,080 19.19 Demolish Off-Gas Stack $78 $96 $24 $0 $26 $224 19.20 Demolish Misc Foundations $61 $78 $126 $0 $34 $300 Distributed Subtotal $10,779 $8,198 $3,383 $65 $2,941 $25,367 Undistributed 3.01 Utility Staff $768 $0 $0 $0 $!00 $868 3.03 Energy $0 $0 $0 $117 $17 $134 3.04 Decommissioning General Contractor Staff $6,837 $0 $0 $0 $1,026 $7,863 Page 20 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: 1/1/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total 3.06 Workers Comprehensive Insurance $0 $1 $0 $0 $0 SI Undistributed Subtotal $7,606 $1 $0 $117 $1,143 $8,866 Gm Pd 1 Subtotal $18,384 $8,200 $3,383 $181 $4,084 $34,233 Gm Pd 2 Site Restoration Distributed 20.01 Site Restoration Equipment $0 $171 $0 $0 $22 $193 20.02 Remove Temporruy Structures SI 1 $9 $0 $0 $3 $23 20.03 Finish Grading and Re-Vegetate Site $440 $354 $0 $0 $103 $898 Distributed Subtotal $452 $535 $0 $0 $128 $1,114 Undistributed 3.01 Utility Staff $147 $0 $0 $0 $19 $167 3.02 Secudty $129 $0 $0 $0 $19 $149 3.04 Decommissioning General Contractor Staff $681 $0 $0 $0 $102 $783 3.06 Workers Comprehensive Insurance $0 $1 $0 $0 $0 $1 Undistributed Subtotal $958 $1 $0 $0 $141 $1,099 Gm Pd 2 Subtotal $1,409 $535 $0 $0 $269 $2,214 C. Greenfield Subtotal $19,794 $8,735 $3,383 $181 $4,353 $36,447 Page 21 of 22

Table 1 Duane Arnold SAFSTOR, 2030 DOE Acceptance, Utility and DGC License Status Early Shutdown Unit !Shut Down: 10/30/2020 Decommissioning Alternative SAFSTOR Fuel Pool Systems Modified Unit 2 Shut Down: Spent Fuel Alternative Dry Repository Opening Date: l/l/2030 2018 Dollars in Thousands No Item Description Labor Equipment Disposal Other Contingency Total D.ISFSID&D ISFSI D&D Pd l ISFSI D&D Planning Distributed 21.0l Preparation of!SFSI Portion ofLTP $185 $0 $0 $0 $24 $209 21.02 NRC Review of ISFSI Portion LTP $0 $0 $0 $44 $6 $50 Distributed Subtotal $185 $0 $0 $44 $30 $259 Undistributed 4.01 Utility Staff $556 $0 $0 $0 $72 $628 Undistributed Subtotal $556 $0 $0 $0 $72 $628 ISFSID&DPd Subtotal $741 $0 $0 $44 $102 $887 ISFSI D&D Pd 2 ISFSI Final Status Survey Distributed 22.01 Final Status Survey of!SFSI $144 $50 $0 $0 $25 $220 22.02 Preparation of FSS Report and NRC Review $101 $0 $0 $33 $17 $151 Distributed Subtotal $245 $50 $0 $33 $43 $371 Undistributed 4.01 Utility Staff $338 $0 $0 $0 $44 $382 Undistributed Subtotal $338 $0 $0 $0 $44 $382 ISFSID&DPd Subtotal $584 $50 $0 $33 $87 $754 D.ISFSID&D Subtotal $1,324 $50 $0 $77 $189 $1,640 Total $450,444 $157,346 $133,138 $138,523 $142,789 $1,022,240 Page 22 of 22

2018 Decommissioning Cost Estimate Document No. 164053-DCE-021 for the Duane Arnold Energy Center Revision 2 AppendixE Annual Cost by Account Table

Duane Arnold Annual Cost By Account SAFSTOR, 2030 DOE Acceptance, Utility and DGC Unit No: Unit 1 2018 Dollars in Thousands Year License Spent Fuel Site Restoration ISFSI Total Termination Demolition 2019 $4,099 $233 $0 $0 $4,331 2020 $36,182 $3,324 $0 $0 $39,506 2021 $43,735 $19,105 $0 $0 $62,840 2022 $15,949 $57,546 $0 $0 $73,495 2023 $5,110 $50,910 $0 $0 $56,020 2024 $14,895 $3,222 $0 $0 $18,117 2025 $5,604 $3,233 $0 $0 $8,837 2026 $2,201 $3,233 $0 $0 $5,434 2027 $1,827 $3,233 $0 $0 $5,060 2028 $1,827 $3,233 $0 $0 $5,060 2029 $1,827 $3,233 $0 $0 $5,060 2030 $1,884 $3,233 $0 $0 $5,117 2031 $1,770 $3,233 $0 $0 $5,003 2032 $1,770 $3,504 $0 $0 $5,274 2033 $1,770 $3,507 $0 $0 $5,277 2034 $1,770 $3,507 $0 $0 $5,277 2035 $1,770 $3,507 $0 $0 $5,277 2036 $1,770 $3,507 $0 $0 $5,277 2037 $1,770 $3,507 $0 $0 $5,277 2038 $1,770 $3,507 $0 $0 $5,277 2039 $1,770 $3,507 $0 $0 $5,277 2040 $2,411 $3,507 $0 $0 $5,918 2041 $1,770 $3,507 $0 $0 $5,277 2042 $1,770 $3,507 $0 $0 $5,277 2043 $1,770 $3,507 $0 $0 $5,277 2044 $1,770 $3,507 $0 $0 $5,277 2045 $1,770 $3,507 $0 $0 $5,277 2046 $1,770 $3,507 $0 $0 $5,277 2047 $1,770 $3,507 $0 $0 $5,277 2048 $1,770 $3,507 $0 $0 $5,277 2049 $1,770 $3,507 $0 $0 $5,277 2050 $1,770 $3,507 $0 $0 $5,277 2051 $1,770 $3,507 $0 $0 $5,277 2052 $1,770 $3,507 $0 $0 $5,277 2053 $1,770 $3,507 $0 $0 $5,277 2054 $2,055 $3,507 $0 $0 $5,562 Page 1 of2

Duane Arnold Annual Cost By Account SAFSTOR, 2030 DOE Acceptance, Utility and DGC Unit No: Unit 1 2018 Dollars in Thousands Year License Spent Fuel Site Restoration ISFSI Total Termination Demolition 2055 $2,126 $3,507 $0 $0 $5,633 2056 $1,770 $3,507 $0 $0 $5,277 2057 $1,770 $3,507 $0 $0 $5,277 2058 $1,770 $3,507 $0 $0 $5,277 2059 $2,159 $2,909 $0 $0 $5,069 2060 $3,077 $0 $0 $0 $3,077 2061 $2,634 $0 $0 $0 $2,634 2062 $2,634 $0 $0 $0 $2,634 2063 $2,634 $0 $0 $0 $2,634 2064 $2,634 $0 $0 $0 $2,634 2065 $2,634 $0 $0 $0 $2,634 2066 $2,634 $0 $0 $0 $2,634 2067 $2,634 $0 $0 $0 $2,634 2068 $2,634 $0 $0 $0 $2,634 2069 $2,634 $0 $0 $0 $2,634 2070 $2,634 $0 $0 $0 $2,634 2071 $2,634 $0 $0 $0 $2,634 2072 $2,634 $0 $0 $0 $2,634 2073 $15,440 $0 $0 $0 $15,440 2074 $32,608 $0 $0 $0 $32,608 2075 $78,197 $0 $0 $184 $78,381 2076 $94,001 $0 $0 $403 $94,404 2077 $118,359 $25 $0 $303 $118,688 2078 $101,052 $4,873 $6,212 $731 $112,868 2079 $57,385 $0 $27,813 $19 $85,217 2080 $4,828 $0 $2,422 $0 $7,250 Total $724,688 $259,466 $36,447 $1,640 $1,022,240 Page 2 of 2}}

v t e Letter Sequence Request
EPID:L-2020-LLE-0011, Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(Iv) (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions 5 May 2020 20 February 2021 Answers 29 May 2020 Results Approval, Approval, Approval Other: ML20164A000, ML20164A001
MONTHYEAR2020-05-05 [Table View]

NG-20-0007, Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(Iv)

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NG-20-0007, Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50. 75(h)(1 )(Iv)

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