ENOC-12-00039, ISFSI Decommissioning Funding Plans (10 CFR 72.30)

ISFSI Decommissioning Funding Plans (10 CFR 72.30)

ML12352A126
Person / Time
Site:	Palisades, Indian Point, Pilgrim, Vermont Yankee, Big Rock Point, FitzPatrick
Issue date:	12/13/2012
From:	Mccann J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ENOC-12-00039, FOIA/PA-2013-0151
Download: ML12352A126 (76)

Text

-Entergy Entergy Nuclear Operations, Inc 440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3370 John F. McCann Vice President - Nuclear Safety, Emergency Planning and Licensing ENOC-12-00039 December 13, 2012 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

ISFSI Decommissioning Funding Plans (10 CFR 72.30)

Big Rock Point Docket No.72-043 Indian Point Nuclear Generating Stations 1, 2, & 3 Docket 72-051 Pilgrim Nuclear Power Station Docket No. 50-293 Palisades Nuclear Plant Docket No.72-007 James A. FitzPatrick Nuclear Power Plant Docket 72-012 Vermont Yankee Nuclear Power Station Docket No.72-059

Dear Sir or Madam:

The NRC Final Rule on Decommissioning Planning was published in 76 FR 35512 on June 17, 2011 with an effective date of December 17, 2012. The final rule includes a requirement (10 CFR 72.30) for each holder of a Part 72 License to submit, for NRC review and approval, a decommissioning funding plan for purposes of decommissioning the licensee's Independent Spent Fuel Storage Installation (ISFSI). Entergy Nuclear Operations, Inc (Entergy) is hereby submitting (Attachments 1 through 6) the required Plans for the subject plants. The ISFSI for Pilgrim is in the development phase and is not yet licensed under 10 CFR 72. However, a decommissioning funding plan for Pilgrim is included in this submittal for your information.

The attachment for each plant shows that the surpluses in the 1 OCFR50.75 Decommissioning Trust Funds exceed the estimated costs of ISFSI decommissioning, as summarized in the following table. The Trust Fund balances account for the 10CFR50 license expiration dates and the ISFSI decommissioning cost estimates (DCE) assume all costs are incurred in the year following the year in which spent fuel has been fully removed from the ISFSI. The values are reported in 2012 dollars. The fund value for Big Rock Point is in the form of a Parent Guarantee, since the 10CFR50.75 Decommissioning Trust Fund is no longer applicable for that

ENOC-12-00039 Page 2 of 3 site. This letter constitutes a certification that financial assurance is provided to cover the estimated costs of ISFSI decommissioning as indicated in the following table:

Plant Site Trust Fund surplus DCE Big Rock Point

$ 5M

$ 1.36M Palisades

$ 25.OM

$ 3.52M Unit 1: $ 427M Indian Point Unit 2: $ 238M

$ 3.71 M Unit 3: $ 162M (Units 1,2 & 3)

James A. FitzPatrick

$ 422M

$ 2.66M Pilgrim

$ 563M

$ 2.53M Vermont Yankee

$ 276M

$ 2.53M The NRC held a public telecom on December 3, 2012 to take questions regarding implementation of the10 CFR 72.30 reporting requirements. Answers to those questions were not provided during the telecom and the attached reports are based on our best efforts to interpret the new regulations prior to receipt of NRC responses to the questions.

This submittal contains no new commitments. Please address any comments or questions to Mr. Dave Mannai, Senior Manager, Nuclear Safety & Licensing at 802-380-1175.

S' cerely, FM/bsf / Ijs / krk Attachments:

1.

10 CFR 72.30 ISFSI Decommissioning Funding Plan for Big Rock Point

2.

10 CFR 72.30 ISFSI Decommissioning Funding Plan for Palisades Nuclear Plant 3A. 10 CFR 72.30 ISFSI Decommissioning Funding Plan for Indian Point Nuclear Generating Stations 1 & 2 3B. 10 CFR 72.30 ISFSI Decommissioning Funding Plan for Indian Point Nuclear Generating Station 3

4.

10 CFR 72.30 ISFSI Decommissioning Funding Plan for James A. FitzPatrick Nuclear Power Plant

5.

Illustrative 10 CFR 72.30 ISFSI Decommissioning Funding Plan for Pilgrim Nuclear Power Station

6.

10 CFR 72.30 ISFSI Decommissioning Funding Plan for Vermont Yankee Nuclear Power Station

ENOC-12-00039 Page 3 of 3 cc:

Mr. J. F. McCann (WPO)

Mr. T. G. Mitchell (WPO)

Mr. K. H. Bronson (WPO)

Ms. W. C. Curry (ECH)

Mr. J. A. Aluise (ENT)

Mr. L. Jager Smith (ECH)

Mr. B. F. Ford (ECH)

Mr. D. J. Mannai (WPO)

Mr. J. A. Ventosa (IPEC)

Mr. M. J. Colomb (JAF)

Mr. T. J. Vitale (PLP)

Mr. R. G. Smith (PNP)

Mr. C. J. Wamser (VTY)

USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Indian Point 1 USNRC Project Manager, Indian Point 2/3 USNRC Project Manager, FitzPatrick USNRC Project Manager, Big Rock Point USNRC Project Manager, Palisades USNRC Project Manager, Pilgrim USNRC Project Manager, Vermont Yankee USNRC Resident Inspector, Indian Point USNRC Resident Inspector, FitzPatrick USNRC Resident Inspector, Palisades USNRC Resident Inspector, Pilgrim USNRC Resident Inspector, Vermont Yankee State of New York State of Michigan State of Vermont

ATTACHMENT 1 TO ENOC-12-00039 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR BIG ROCK POINT ISFSI DOCKET 72-043 ENTERGY NUCLEAR OPERATIONS, INC

Entergy Nuclear Palisades ENOC-12-00039 Big Rock Point ISFSI 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,tl with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Big Rock Point site, in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The Big Rock Point nuclear plant was located in Charlevoix County, Michigan. The boiling water reactor operated from 1962 to 1997, when it was permanently shut down on August 29, 1997. The plant was deconunissioned and the structures demolished, with all site work completed in 2006.

Approximately 441 spent fuel assemblies were generated over the life of the plant.

Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI was constructed for interim storage and fuel casks have been emplaced thereon. The operating license for the ISFSI was subsequently transferred from U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40,50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 7

Entergy Nuclear Palisades ENOC-12-00039 Big Rock Point ISFSI Consumers Energy to Entergy Nuclear Palisades and site operator Entergy Nuclear Operations (Entergy) in April of 2007.[21 The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K133).

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy's current spent fuel management plan for the Big Rock Point spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Big Rock Point fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority.

Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,141 the spent fuel is projected to be fully removed from the Big Rock Point site in 2033.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,"'1 DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

2 News release "NRC Staff Approves Big Rock Point ISFSI License Transfer," dated April 10, 2007 (Accession Number ML071000477)

U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

4 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 5

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 2 of 7

Entergy Nuclear Palisades ENOC-12-00039 Big Rock Point ISFSI

3.

ISFSI Decommissioning Strategy For purposes of this funding plan, at the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

4.

ISFSI Description The Big Rock Point ISFSI consists of 7 BNFL FuelSolutionsTM W-150 modular concrete overpacks (each containing the spent fuel canister) and a 75 foot by 99 foot reinforced concrete pad. There is also one additional overpack containing Greater-than-Class C (GTCC) waste.

The storage overpack used for the GTCC canister is not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the current configuration of the ISFSI, once all spent fuel and GTCC material has been removed from the site.

The dry storage vendor, BNFL, does not expect the overpacks to have any interior or exterior radioactive surface contamination (that could not be easily. removed). Any neutron activation of the steel and concrete is expected to be minimal.16 ] The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 2 of the 7 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 84 off-loaded assemblies, 64 assemblies per cask) which results in 2 overpacks.

The dry storage vendor, BNFL, expects that any activation of the concrete ISFSI pad would be significantly less than of the storage casks.171 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this 6

FuelSolutionsTM Storage System FSAR. Document No. WSNF-220, Rev. 3, June 2005. at page 14.1-2 (Accession Number ML073610500)

FuelSolutionsTM Storage System FSAR, Document No. WSNF-220, Rev. 3, June 2005, at page 14.1-2 (Accession Number ML073610500)

Page 3 of 7

_ Entergy Nuclear Palisades ENOC-12-00039 Big Rock Point ISFSI Attachment I analysis that a small portion of the ISFSI pad (directly underneath the two impacted casks) will be activated to a level that would require remediation for termination of the license. Verification surveys are included for the remainder of the pad. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Prior to ISFSI pad construction, the NRC took radiological samples of the ground and fill upon which the ISFSI pad was constructed. No significant or unexpected radiological conditions were found, and no nuclear plant-related isotopes were identified in any sample.J81 As such, the decommissioning estimate contains no cost allowance for soil remediation.

Waste volumes are based on estimates provided by FuelSolutionsTM[91. Low-level radioactive waste disposal costs are based on Entergy's negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.t' 0 1 8

Big Rock Point Restoration Project, NRC Inspection Report 05000155/2001-003 (DNMS), dated June 2001 (Accession Number ML011730211)

FuelSolutionsTM Storage System FSAR, Document No. WSNF-220, Rev. 3, June 2005, at page 14.3-1 (Accession Number ML073610500) 10 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards. NUREG-1757, Volume

3. Revision 1, February 2012.

Page 4 of 7

Entergy Nuclear Palisades ENOC-12-00039 Big Rock Point ISFSI

6.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed.

The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies.

The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Entergy's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2034, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Big Rock Point are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible, according to the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon a Parent Guarantee established in the amount of $5 million[111 to terminate the ISFSI license and release the facility for unrestricted use.

The Guarantee is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

Status of Decommissioning Funding for Plants Operated by Entergy Nuclear Operations, Inc. for Year Ending December 31, 2010, dated March 31, 2011 (Accession Number ML110940051)

Page 5 of 7

Entergy Nuclear Palisades Big Rock Point ISFSI ENOC-12-00039 Attachment I Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity ISFSI Pad 99 75 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 220 Dimensions are nominal Outside Diameter (inches) 138 Dimensions are nominal Inside Diameter (inches) 73 Dimensions are nominal Inner Liner Thickness (inches) 2.0 Dimensions are nominal Quantity (total) 8 7 spent fuel + 1 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 2 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 648 Low-Level Radioactive Waste (cubic feet) 1,282 Low-Level Radioactive Waste (packaged density) 84 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 1

No residual radioactivity Page 6 of 7

Entergy Nuclear Palisades Big Rock Point ISFSI ENOC-12-00039 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 146 146 928 Decontamination/Demolition (activated liner removal) 13 4

27 72 53 170 1,282 116 License Termination (radiological surveys) 446 446 3,574 Subtotal 13 4

27 72 645 762 1,282 4,618 Supporting Costs NRC and NRC Contractor Fees and Costs 209 209 776 Insurance 34 34 Security (industrial) 94 94 2,479 Entergy Oversight Staff 141 141 1,881 Subtotal 478 478 2,479 1,881 776 Total (w/o contingency) 13 4

27 72 1,123 1,240 1,282 7,097 1,881 776 Total (w/25% contingency) 16 6

34 91 1,404 1,550 1

Page 7 of 7

ATTACHMENT 2 TO ENOC-12-00039 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR PALISADES NUCLEAR PLANT ISFSI DOCKET 72-007 ENTERGY NUCLEAR OPERATIONS, INC

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant

.10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,tl with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Palisades Nuclear Plant (Palisades), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for Palisades is currently set to expire on March 24, 2031.

Approximately 2,442 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, two ISFSI pads have been constructed and fuel casks have been emplaced thereon to support continued plant operations. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2]).

U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 201.1 2

U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

Page 1 of 9

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant Because of the DOE's breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2031, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear Palisades' (Entergy) current spent fuel management plan for the Palisades spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the Palisades fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[3 1 the spent fuel is projected to be fully removed from the Palisades site in 2060.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,"'] DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning 3

"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 4

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 2 of 9

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description There are two ISFSI pads on the Palisades site. The original pad was used to store 18 Sierra Nuclear VSC-24 Ventilated Storage Casks (VSCs). Consumers Power transferred 432 assemblies into the VSCs between 1995 and 1999. It is possible that the spent fuel in these casks will have to be repackaged before it can be shipped off-site. Repackaging is currently assumed to occur immediately after the cessation of plant operations, while the spent fuel pool is still available and the associate fuel handling systems are operable. As such, the VSCs are not expected to be on the pad when it is decommissioned (and not considered in this funding plan).

A horizontal dry storage system is currently in use at the second ISFSI pad. There are 24 modules loaded with spent fuel; 11 NUHOMS-32PT modules and 13 NUHOMS-24PTH modules. The system consists of a dry storage canister, with a nominal capacity of 24 or 32 fuel assemblies, and a horizontal concrete storage module. Starting in 2014, Entergy intends to use Holtec's HI-STORM FW System (with a 37 spent fuel assembly capacity) for storing all future spent fuel on-site. The Holtec dry storage system consists of an inner multi-purpose canister (containing the spent fuel) and an outer concrete and steel overpack.

The current spent fuel management plan for the Palisades spent fuel would result in 45 spent fuel storage modules/casks (24 NUHOMS and 21 Holtec FW) being placed on the storage pad(s) at the site. This projected configuration is based upon the 2020 DOE spent fuel program start with a 2022 DOE start date for Palisades spent fuel, a 3,000 MTU / year pickup rate, and the current cask capacity (including expansion capability) for the ISFSI pad(s) built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 45 modules/casks projected to be on the ISFSI pad(s) after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 3) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

Page 3 of 9

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2031) and the DOE's spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.J51 The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 6 of the 21 Holtec overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 204 offloaded assemblies, 37 assemblies per cask) which results in 6 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. The older NUHOMS modules are not expected to be activated to a level requiring remediation.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[6] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

There is no indication the soil in the immediate vicinity of the ISFSI pads would require remediation to meet the criteria for license termination. As such, there is no allowance for soil remediation in the estimate.

Low-level radioactive waste disposal costs are based on Entergy's currently negotiated rates with EnergySolutions.

HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev.0, at page 2-83 (Accession Number MLI 1270A045) 6 HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev. 0, at page 2-84 (Accession Number MLI 1270A045)

Page 4 of 9

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the* NRC in NUREG-1757.tT' Costs are reported in 2012 dollars.

6.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad(s), and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed. The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Entergy's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2060, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Palisades are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract.

It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

7 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

Page 5 of 9

Entergy Nuclear Palisades Palisades Nuclear Plant ENOC-12-00039 Using the decommissioning trust fund is reasonable based on the following:

• Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

" The projected amount necessary for decommissioning Palisades is $452.157 million, based upon the NRC's latest financial assurance funding determination. [8

• Based upon Palisades' decommissioning trust fund balance as of September 30, 2012 and considering the allowed real rate of return on the fund between October 1, 2012 and the start of Palisades station decommissioning, the trust fund will contain a

$24.977 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

8 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 14, November 2010 Page 6 of 9

Entergy Nuclear Palisades Palisades Nuclear Plant ENOC-12-00039 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Primary ISFSI Pads 353.5 and 421 32.5 each No ISFSI Storage Overpack (Holtec FW)

Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) 139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Inner Liner Thickness (inches) 0.75 Dimensions are nominal Quantity (total) 48 45 spent fuel + 3 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 6 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 2,260 Low-Level Radioactive Waste (cubic feet) 3,668 Low-Level Radioactive Waste (packaged density) 73 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 3

No residual radioactivity Page 7 of 9

Entergy Nuclear Palisades Palisades Nuclear Plant ENOC-12-00039 Table 2 ISFSI Decommissioning Costs and Waste Volumes

. Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 218 218 13,045 Decontamination/Demolition (activated liner removal) 141 14 61 207 397 819 3,668 396 License Termination (radiological surveys) 1,196 1,196 12,133 Subtotal 141 14 61 207 1,811 2,234 3,668 25,574 Supporting Costs NRC and NRC Contractor Fees and Costs 255 255 776 Insurance 62 62 Security (industrial) 190 190 4,999 Entergy Oversight Staff 284 284 3,792 Subtotal 790 790 4,999 3,792 776 Total (w/o contingency) 141 14 61 207 2,601 3,023 3,668 30,573 3,792 776 Total (w/25% contingency) 176 17 76 259 3,251 3,779 Page 8 of 9

Entergy Nuclear Palisades ENOC-12-00039 Palisades Nuclear Plant Table 3 Financial Assurance Plant name:

Palisades Nuclear Plant Month Day Year Year of Biennial:

10 1

2012 Termination of Operation:

3 24 2031 MWthI 1986.$

ECI Base Lx L.

Ix Px Fx g

Ex PWR 2565 r $97,572,000 r 115.7 2.08 0.65 r

2.41 r 1.971 r 4.022 0.13 r 2.83 0.22 12.28 NRC Minimum:

$452,156,817 Amount of NRC Minimum/Site Licensee:

% Owned:

Specific:

Amount in Trust Fund:

Entergy 100.00%

$452,156,817

$308,013,056 Step 1:

Earnings Credit:

Real Rate of IYears Lefti Total Real Trust Fund Balance:

Return per lin Ucensel Rate of Total Earnings:

$308,013,056 2%-/

18.48 1

1.44188

$444,117,157 ITotal Earnings= Trust Fund balance x (l+RRR)AYearsleft in license Step 2:

Accumulation:

Real Rate of Value of Annuity per year Return per I Years of Annuity:

Total Annuity:

$0 20/

0

$0 Step 3:

Decom Period:

Real Rate of Decorn Total Real Total Earnings for Total Earnings:

Return per Period:

Rate of Decom:

$444,117,157 2%

0 7

0.14869

$33,016,928 Total Earnings for Decom = (1/2)x Total Earnings x [(1+RRR)ADecom period -1]

Total of Steps 1 -3:

$477,134,0"85Total = Total Earnings+ Total Earnings for Decom Excess (Shortfall)

$24,977,267 to NRC minimum I

Page 9 of 9

ATTACHMENTS 3A and 3B TO ENOC-12-00039 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLANS FOR INDIAN POINT NUCLEAR GENERATING UNITS 1, 2, & 3 ISFSI DOCKET 72-051 ENTERGY NUCLEAR OPERATIONS, INC

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units 1 and 2 A 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,t'l with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI constructed at Indian Point Energy Center (Indian Point), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy There are three nuclear units on the Indian Point site, two operating (IP-2 and IP-3) and one permanently shutdown (IP-1). This funding plan addresses the disposition of IP-1 and IP-2 spent fuel, as it relates to on site dry storage (the IP-3 spent fuel is addressed in a separate funding plan).

IP-I ceased operation on October 31, 1974, generating 404 spent fuel assemblies over its operating life. The operating license for IP-2 is currently set to expire on September 28, 2013. Approximately 1,721 spent fuel assemblies are projected to be generated over the U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 14

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units 1 and 2 A life of IP-2. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations of IP-2 as well as IP-3 (IP-2 and IP-3 have applied for license renewal and an additional 20 years of operations). Based upon the current projection of the DOE's ability to remove spent fuel from the site, a second pad will need to be constructed to support decommissioning. Since the projected spent fuel storage requirements for both IP-2 and IP-3 are similar, and the casks will be comingled on the two pads, the funding requirements are assumed to be allocated equally between the two nuclear units (the IP-1 casks are included with the IP-2 inventory). The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K"2').

The IP-1 spent fuel on site (160 assemblies), has been relocated to the current ISFSI pad (in 5 dry storage casks). The remaining 244 assemblies had been shipped to West Valley for reprocessing.

Because of the DOE's breach, it is envisioned that the IP-2 spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2013, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the IP-2 fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear Indian Point 2, LLC's (Entergy) current spent fuel management plan for the IP-2 spent fuel is based in general upon: 1) a 2020 start datefor DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the IP-2 fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest prioiity. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year, 3] the spent fuel is projected to be fully removed from the Indian Point site in 2046.

2 U.S. Code of Federal Regulations, Title 10, Part 72. Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

"Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 Page 2 of 14

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units I and 2 A Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,ta' DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The design and capacity of the current Indian Point ISFSI is based upon the Holtec HI-STORM 100S dry cask storage system (IP-1 fuel is stored in a shorter version of the cask). The system consists of a multi-purpose canister, with-a nominal capacity of 32 fuel assemblies, and a steel-lined concrete storage overpack.

Entergy's current spent fuel management plan for the IP-2 spent fuel would result in 48 spent fuel storage casks. (in addition to the 5 casks for IP-1 spent fuel) being placed on the storage pad(s) at the site. This projected configuration is based upon the 2020 DOE spent fuel program start with a 2021 DOE start date for Indian Point spent fuel, a 3,000 MTU /

year pickup rate, and a 78 cask capacity for the current ISFSI pad. This scenario would allow the spent fuel storage pool to be emptied within the ten years that the pool remains operational following the permanent cessation of operations (ten years is based upon the need to use the IP-2 pool for packaging IP-3 spent fuel for dry storage).

The 53 casks (48 IP-2 + 5 IP-1 casks) projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4, a

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 3 of 14

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units 1 and 2 A including 1 for IP-1) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the IP-2 unit operating until the end of its current license (2013) and the DOE's spent fuel acceptance assumptions, as previously described. The existing ISFSI pad is approximately 96 feet by 208 feet, and has a maximum capacity of 78 casks.

The supplemental pad (future) is assumed to have a maximum capacity of 40 casks and dimensions of approximately 52 feet by 238.5 feet (using the Pilgrim pad as a proxy).

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[51 The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 48 IP-2 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 193 assemblies and 32 assemblies per cask) which results in 7 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. Due to the age of the IP-1 spent fuel when it was placed in dry storage, the IP-1 casks are not expected to be activated to a level requiring remediation.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad. 63 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) 6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153)

Page 4 of 14

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units 1 and 2 A The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The decommissioning cost studies173 developed for IP-1 and IP-2 included the cost for the remediation of contaminated (radiological) soil, based upon a detailed characterization of the site and affected areas. The ISFSI was constructed at the north end of the site which was previously undeveloped and outside the existing Protected Area.[83 Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommissioning the ISFSI.

Low-level radioactive waste disposal costs are based on Entergy's negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757. 9" Costs are reported in 2012 dollars and based upon preliminary decommissioning cost analyses prepared in 2007[IOI and 2010.J 13 The original spent fuel management plan for IP-2 was updated from a 2017 DOE start date to year 2020, consistent with the current assumption used for Entergy's fleet, and revised to reflect IP-3's need to use the IP-2 pool for spent fuel packaging for dry storage/transport. Activity costs originally reported in 2010 dollars (in the latest IP-3 study) have been escalated to 2012 dollars using the Consumer Price Index, Services. 12]

Submittal of the Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis, dated October 23, 2008 (Accession Number ML083040378) 8 Indian Point Energy Center, Applicant's Environmental Report, Operating License Renewal Stage, p. 3-6 (Accession Number ML071210530)

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping. and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

10 "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3," December 2010 (Accession Number ML103550608)

"Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3," December 2010 (Accession Number ML103550608) 2 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS Page 5 of 14

Entergy Nuclear Indian Point 2, LLC ENOC-12-00039 Indian Point Energy Center, Units I and 2 A

6.

Cost Considerations The estimated cost to decommission the IP-1/IP-2 casks and the IP-1/IP-2 allocated cost to decommissioning the ISFSI pads (the remaining portion will be funded by IP-3) and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed. The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Entergy's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2048, the year following all spent fuel removal (including any from IP-3 stored on the pads).

7.

Financial Assurance ISFSI operations at Indian Point are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract. r31 It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

13 Entergy Nuclear Indian Point 2, LLC v. United States, Court of Federal Claims, No. 03-2622-C (2005)

Page 6 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units 1 and 2 ENOC-12-00039 A

• The projected amount necessary for decommissioning is $403.922 million and

$487.675 million for IP-1 and IP-2, respectively, based upon the NRC's latest financial assurance funding determination. [141 The calculations are shown in Table 3.

" On October 23, 2008, Entergy submitted site specific decommissioning cost estimates for EP-I and IP-2, along with a spent fuel management plan.'151 As can be seen in Tables 4 and 5, the required funding for both units is greater than the NRC formula amount per 10 CFR 50.75(b) and 1 (c), therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1. When the September 30, 2012 decommissioning trust fund balance is escalated at the allowable rate and compared against the annual figures for the associated decommissioning expenditures, that the trust funds will contain a $426.725 million surplus for IP-1 and a $238.447 million surplus for IP-2. This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

14 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 14, November 2010 15 Submittal of the Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis, dated October 23, 2008 (Accession Number ML083040378)

Page 7 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units I and 2 ENOC-12-00039 A Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Current ISFSI Pad 208 96 No ISFSI Storage Overpack Item Value Notes HI-STORM 100S-185 Overall Height (inches) 185 Dimensions are nominal HI-STORM 100S-218 Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 57 53 spent fuel + 4 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 2,385 Low-Level Radioactive Waste (cubic feet) 1,464 Low-Level Radioactive Waste (packaged derisity) 84 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 3 (IP-2)

No residual radioactivity Page 8 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units 1 and 2 ENOC-12-00039 A Table 2 ISFSI Decommissioning Costs and Waste Volumes (50% of total cost)

Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 179 179 596 Decontamination/Demolition (activated liner removal) 115 7

36 83 27 267 1,464 416 License Termination (radiological surveys) 749 749 5,772 Subtotal 115 7

36 83 954 1,195 1,464 6,784 Supporting Costs NRC and NRC Contractor Fees and Costs 134 134 388 Insurance 31 31 Security (industrial) 102 102 2,500 Entergy Oversight Staff 118 118 1,896 Subtotal 385 385 2,500 1,896 388 Total (w/o contingency) 115 7

36 83 1,339 1,580 1,464 9,283 1,896 388 Total (w/25% contingency) 144 9

45 103 1,674 1,975 Page 9 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units 1 and 2 ENOC-12-00039 A Table 3 NRC Minimum Plant name:

Indian Point, Unit 1 Day Year Year of Biennial:

Termination of Operation:

Month 1

9 1

28 2012 2066 SAFSTOR Site Specific IMWth 1986$

ECI Base Lx I

I Px Fx I

E Bx PWR 615 r $85,560,000 r 117.6 2.16 0.65 r 2.54 r 1.971 r 4.022 0.13 r 2.832 0.22 12.28 NRC Minimum:

$403,922,234 Site Specific:

See Table 4 Plant name:

Year of Biennial:

Termination of Operation:

Indian Point, Unit 2 Month 1

9 Day 1

28 Year 2012 2064 SAFSTOR Site Specific PMWth 1986$

1 2.1 0B65

[

2.54 I

Lx I

40 I

2.2 I FxI Ax B

PWR 13216

[$103,300,8oor 117.6 r 2.16 0.o65 r

2.54 r 1. 971 r 4.022 1 0.13 r 2.832 10.22 112.281 NRC Minimum:

$487,675,198 Site Specific:

See Table 5 Page 10 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units 1 and 2 Table 4 Indian Point 1 Radiological (License Termination) Cost

($ millions)

ENOC-12-00039 A 2007$

2012$

Unit 1 Unit 1 Ending DTF Radiological Radiological Balance 2012 329.812 2013 1.059 1.168 335.240 2014 4.236 4.673 337.272 2015 4.236 4.673 339.344 2016 2.656 2.930 343.201 2017 2.649 2.922 347.143 2018 2.649 2.922 351.163 2019 2.649 2.922 355.265 2020 2.656 2.930 359.440 2021 2.649 2.922 363.707 2022 2.649 2.922 368.059 2023 2.649 2.922 372.498 2024 2.656 2.930 377.018 2025 2.649 2.922 381.637 2026 2.649 2.922 386.347 2027 2.649 2.922 391.152 2028 2.656 2.930 396.045 2029 2.649 2.922 401.044 2030 2.649 2.922 406.143 2031 2.649 2.922 411.344 2032 2.656 2.930 416.641 2033 2.649 2.922 422.052 2034 2.649 2.922 427.571 2035 2.649 2.922 433.200 2036 2.656 2.930 438.934 2037 2.649 2.922 444.791 2038 2.649 2.922 450.765 2039 2.649 2.922 456.858 2040 2.656 2.930 463.065 2041 2.649 2.922 469.405 2042 2.649 2.922 475.871 2043 2.649 2.922 482.466 2044 2.656 2.930 489.185 2045 2.611 2.880 496.089 Page II of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units I and 2 Table 4 (continued)

Indian Point 1 Radiological (License Termination) Cost

($ millions)

ENOC-12-00039 A 2007$

2012$

Unit 1 Unit 1 Ending DTF Radiological Radiological Balance 2046 1.826 2.017 503.994 2047 1.826 2.017 512.056 2048 1.831 2.023 520.274 2049 1.826 2.017 528.662 2050 1.826 2.017 537.218 2051 1.826 2.017 545.945 2052 1.831 2.023 554.841 2053 1.826 2.017 563.920 2054 1.826 2.017 573.181 2055 1.826 2.017 582.627 2056 1.831 2.023 592.257 2057 1.826 2.017 602.084 2058 1.826 2.017 612.109 2059 1.826 2.017 622.333 2060 1.831 2.023 632.757 2061 1.826 2.017 643.395 2062 1.826 2.017 654.245 2063 1.826 2.017 665.313 2064 1.831 2.023 676.596 2065 1.826 2.017 688.110 2066 18.899 20.825 681.048 2067 68.313 74.554 620.115 2068 148.490 162.372 470.145 2069 17.216 18.981 460.567 2070 17.216 18.981 450.798 2071 17.216 18.981 440.833 2072 17.235 19.001 430.649 2073 11.400 12.537 426.725 Total 441.549 484.804 Page 12 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units I and 2 Table 5 Indian Point 2 Radiological (License Termination) Cost

($ millions)

ENOC-12-00039 A 2007$

2007$

2012$

Unit 2 Unit 2 Updated Unit 2 Ending DTF Radiological Radiological Radiological Balance 2012 427.699 2013 11.164 11.164 12.382 423.871 2014 49.271 49.271 54.494 377.855 2015 25.307 25.307 27.920 357.492 2016 3.711 3.711 4.106 360.536 2017 3.701 3.701 4.095 363.652 2018 3.701 3.701 4.095 366.830 2019 3.701 3.701 4.095 370.072 2020 3.711 3.711 4.106 373.368 2021 3.688 3.701 4.095 376.740 2022 3.676 3.701 4.095 380.180 2023 3.676 3.701 4.095 383.689 2024 3.686 3.686 4.079 387.284 2025 3.676 3.676 4.068 390.962 2026 3.676 3.676 4.068 394.713 2027 3.676 3.676 4.068 398.539 2028 3.686 3.686 4.079 402.430 2029 3.676 3.676 4.068 406.411 2030 3.676 3.676 4.068 410.471 2031 3.676 3.676 4.068 414.613 2032 3.686 3.686 4.079 418.826 2033 3.676 3.676 4.068 423.134 2034 3.676 3.676 4.068 427.529 2035 3.676 3.676 4.068 432.011 2036 3.686 3.686 4.079 436.572 2037 3.676 3.676 4.068 441.236 2038 3.676 3.676 4.068 445.992 2039 3.676 3.676 4.068 450.844 2040 3.686 3.686 4.079 455.782 2041 3.676 3.676 4.068 460.830 2042 3.676 3.676 4.068 465.978 2043 3.676 3.676 4.068 471.230 2044 3.686 3.686 4.079 476.575 2045 3.675 3.676 4.068 482.038 Page 13 of 14

Entergy Nuclear Indian Point 2, LLC Indian Point Energy Center, Units I and 2 Table 5 (continued)

Indian Point 2 Radiological (License Termination) Cost

($ millions)

ENOC-12-00039 A 2007 $

2007 $

2012 $

Unit 2 Unit 2 Updated Unit 2 Ending DTF Radiological Radiological Radiological Balance 2046 3.668 3.676 4.068 487.611 2047 3.668 3.675 4.068 493.296 2048 3.678 3.678 4.071 499.091 2049 3.668 3.668 4.060 505.013 2050 3.668 3.668 4.060 511.053 2051 3.668 3.668 4.060 517.214 2052 3.678 3.678 4.071 523.488 2053 3.668 3.668 4.060 529.898 2054 3.668 3.668 4.060 536.436 2055 3.668 3.668 4.060 543.105 2056 3.678 3.678 4.071 549.896 2057 3.668 3.668 4.060 556.834 2058 3.668 3.668 4.060 563.911 2059 3.668 3.668 4.060 571.129 2060 3.678 3.678 4.071 578.481 2061 3.668 3.668 4.060 585.991 2062 3.668 3.668 4.060 593.651 2063 3.668 3.668 4.060 601.464 2064 24.751 24.751 27.436 586.057 2065 55.625 55.625 61.435 536.343 2066 168.560 168.560 184.998 362.072 2067 71.834 71.834 79.170 290.143 2068 25.113 25.113 27.692 268.254 2069 6.046 6.046 6.659 266.961 2070 6.046 6.046 6.659 265.641 2071 6.046 6.046 6.659 264.296 2072 6.547 6.547 7.210 262.372 2073 26.485 26.485 29.173 238.447 Total 659.351 659.430 727.366 Page 14 of 14

Entergy Nuclear Indian Point 3, LLC ENOC-12-00039 Indian Point Energy Center, Unit 3 B 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,lI with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI constructed at Indian Point Energy Center (Indian Point), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy There are three nuclear units on the Indian Point site, two operating (IP-2 and IP-3) and one permanently shutdown (IP-1). This funding plan addresses the disposition of IP-3 spent fuel, as it relates to dry storage (the IP-1 and IP-2 spent fuel is addressed in a separate plan).

The operating license for IP-3 is currently set to expire on December 12, 2015.

Approximately 1,683 spent fuel assemblies are currently projected to be generated over the operating life. Because of the breach by the Department of Energy (DOE) of its U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50. 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission. Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 10

Entergy Nuclear Indian Point 3, LLC ENOC-12-00039 Indian Point Energy Center, Unit 3 B contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations of IP-3 as well as IP-2 (IP-3 and IP-2 have applied for license renewal and an additional 20 years of operations). Based upon the current projection of the DOE's ability to remove spent fuel from the site, a second pad will need to be constructed to support decommissioning. Since the projected spent fuel storage requirements for both IP-3 and IP-2 are similar, and the casks will be comingled on the two pads, the funding requirements are assumed to be allocated equally between the two nuclear units (the IP-1 casks are included with the IP-2 inventory). The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart KE23).

Because of the DOE's breach, it is envisioned that the IP-3 spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2015, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the IP-3 fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear Indian Point 3, LLC's (Entergy) current spent fuel management plan for the IP-3 spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the IP-3 fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,133 the spent fuel is projected to be fully removed from the Indian Point site in 2047.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,[4" DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

3 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 4

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 2 of 10

Entergy Nuclear Indian Point 3, LLC ENOC-12-00039 Indian Point Energy Center, Unit 3 B Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

3.

ISFSl Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The design and capacity of the current Indian Point ISFSI is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 32 fuel assemblies, and a steel-lined concrete storage overpack.

Entergy's current spent fuel management plan for the IP-3 spent fuel would result in 51 spent fuel storage casks being placed on the storage pad(s) at the site. This projected configuration is based upon the 2020 DOE spent fuel program start with a 2021 DOE start date for Indian Point spent fuel, a 3,000 MTU / year pickup rate, and a 78 cask capacity for the current ISFSI pad. This scenario would allow the spent fuel storage pool to be emptied within the eight years following the permanent cessation of operations (eight years is based upon the need to use the IP-2 pool for packaging IP-3 spent fuel for dry storage).

The 51 IP-3 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 3) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

Page 3 of 10

Entergy Nuclear Indian Point 3, LLC ENOC-12-00039 Indian Point Energy Center, Unit 3 B

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after.

all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the IP-3 unit operating until the end of its current license (2015) and the DOE's spent fuel acceptance assumptions, as previously described. The existing ISFSI pad is approximately 96 feet by 208 feet, and has a maximum capacity of 78 casks.

The supplemental pad (future) is assumed to have a maximum capacity of 40 casks and dimensions of approximately 52 feet by 238.5 feet (using the Pilgrim pad as a proxy).

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.1 51 The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 51 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 193 assemblies, 32 assemblies per cask) which results in approximately 7 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.161 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The decommissioning cost study 71 developed for IP-3 included the cost for the remediation of contaminated (radiological) soil, based upon a detailed characterization of the site and affected areas. The ISFSI was constructed at the north end of the site which HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153)

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153)

Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center. Unit 3, dated December 2010 (Accession Number ML1035500608)

Page 4 of 10

Entergy Nuclear Indian Point 3, LLC Indian Point Energy Center, Unit 3 ENOC-12-00039 B was previously undeveloped and outside the existing Protected Area.E8S Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommissioning the ISFSI.

Low-level radioactive waste disposal costs are based on Entergy's negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications, such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757. "1 Costs are reported in 2012 dollars and based upon a preliminary decommissioning cost analyses prepared in 2010.[J'1 Activity costs originally reported in 2010 dollars have been escalated to 2012 dollars using the Consumer Price Index, Services.tl 1]

8 Indian Point Energy Center, Applicant's Environmental Report, Operating License Renewal Stage, p. 3-6 (Accession Number ML071210530) 9 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

10 "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3," December 2010 (Accession Number ML103550608)

Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUROOOOSAS Page 5 of 10

Entergy Nuclear Indian Point 3, LLC ENOC-12-00039 Indian Point Energy Center, Unit 3 B

6.

Cost Considerations The estimated cost to decommission the IP-3 casks and the IP-3 allocated cost to decommissioning the ISFSI pads (the remaining portion will be funded by IP-2) and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed. The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Entergy's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2048, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Indian Point are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract.Jl1 It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

12 Entergy Nuclear FitzPatrick. LLC, Entergy Nuclear Indian Point 3, and Entergy Nuclear Operations, Inc. v.

United States, Court of Federal Claims, No. 03-2627-C (2009)

Page 6 of 10

Entergy Nuclear Indian Point 3, LLC Indian Point Energy Center, Unit 3 ENOC-12-00039 B

" The projected amount necessary for decommissioning IP-3 is $487.675 million, based upon the NRC's latest financial assurance funding determination.[1 31

" Based upon IP-3's decommissioning trust fund balance as of September 30, 2012 and considering the allowed real rate of return on the fund between October 1, 2012 and the start of IP-3 decommissioning, the trust fund will contain a $161.680 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in IOCFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

13 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 14, November 2010 Page 7 of 10

Entergy Nuclear Indian Point 3, LLC Indian Point Energy Center, Unit 3 ENOC-12-00039 B Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Current ISFSI Pad 208 96 No ISFSI Storage Overpack Item Value Notes HI-STORM 100S-218 Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 54 51 spent fuel + 3 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 7 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 2,385 Low-Level Radioactive Waste (cubic feet) 1,464 Low-Level Radioactive Waste (packaged density) 84 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 3

No residual radioactivity Page 8 of 10

Entergy Nuclear Indian Point 3, LLC Indian Point Energy Center, Unit 3 ENOC-12-00039 B Table 2 ISFSI Decommissioning Costs and Waste Volumes (50% of total cost)

Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 179 179 596 Decontamination/Demolition (activated liner removal) 115 7

36 83 27 267 1,464 416 License Termination (radiological surveys) 749 749 5,772 Subtotal 115 7

36 83 954 1,195 1,464 6,784 Supporting Costs NRC and NRC Contractor Fees and Costs 134 134 388 Insurance 31 31 Security (industrial) 102 102 2,500 Entergy Oversight Staff 118 118 1,896 Subtotal 385 385 2,500 1,896 388 Total (w/o contingency) 115 7

36 83 1,339 1,580 1,464 9,283 1,896 388 Total (w/25% contingency) 144 9

45 103 1,674 1,975 Page 9 of 10

Entergy Nuclear Indian Point 3, LLC Indian Point Energy Center, Unit 3 ENOC-12-00039 B Table 3 IP-3 Financial Assurance Plant name:

Year of Biennial:

Termination of Operation:

Month 10 12 Day 1

12 Indian Point, Unit 3 Year 2012 2015 MWth 1

1986$

PWR 1

3216 r$103,300,800 [

ECI I

Base Lx 117.6 2.16

• Lx Px I

EXi I oxl I

Lx-P.

I 1

0.65 r

2.54 r

1.971 r

0.13 [

2.83 I

0.22 1 12.28 I NRC Minimum:

$487,675,198 Site Specific:

I.

Licensee:

%Owned:

Entergy 100.00%

Amount of NRC Minimum/Site Specific:

$487,675,198 -I-Amount in Trust Fund:

$567,343,681

]

Step 1:

Earnings Credit:

Trust Fund Balance:

$567,343,681 I Step 2:

Accumulation:

Va of Annuity r earl Real Rate of Return per 2%

Real Rate of Return per 21/o Years Left in Ucensel 3.20 1

Total Real Rate of 1.065351-Total Earnings:

$604,420,635 ITotal Earnings = Trust Fund balance x (1+RRR)AYears left in license I

Years of Annuity:

0 H-Total Annuity:

$0 H

Step 3:

Decom Period:

I.

Real Rate of Total Earnings:

Return per

$604,420,635 29/o Decom Period:

7 Total Real Rate of 0.14869 Total Earnings for Decom:

$44,934,343 ITotal Earnings for Decom = (1/2) x Total Earnings x [(l+RRR)ADecom period - 1]

I Total of Steps 1 - 3:

1

$649,354,978 I Total = Total Earnings+ Total Earnings for Decom Excess (Shortfall)

$161,679,780 to NRC minimum Page 10 of 10

ATTACHMENT 4 TO ENOC-12-00039 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR JAMES A. FITZPATRICK NUCLEAR POWER PLANT ISFSI DOCKET 72-012 ENTERGY NUCLEAR OPERATIONS, INC

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,E'3 with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the James A. FitzPatrick Nuclear Power Station (FitzPatrick), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for FitzPatrick is currently set to expire on October 17, 2034.

Approximately 6,228 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOE's ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, the construction of a second pad after shutdown to support U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40,50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 9

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K 21).

Because of the DOE's breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2034, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear FitzPatrick's (Entergy) current spent fuel management plan for the FitzPatrick spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the FitzPatrick fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year, the spent fuel is projected to be fully removed from the FitzPatrick site in 2059.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,E41 DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

3 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 4

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 2 of 9

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The design and capacity of the FitzPatrick ISFSI is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 68 fuel assemblies, and a steel-lined concrete storage overpack.

Entergy's current spent fuel management plan for the FitzPatrick spent fuel would result in 50 spent fuel storage casks being placed on the storage pads at the site. This projected configuration is based upon the 2020 DOE spent fuel program start with a 2023 DOE start date for FitzPatrick spent fuel, a 3,000 MTU / year pickup rate, and a 22 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 50 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 3) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

Page 3 of 9

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2034) and the DOE's spent fuel acceptance assumptions, as previously described. For purposes of this analysis, the second, larger pad would be constructed to accommodate the casks needed to off load the spent fuel pool after the cessation of plant operations. Based upon the additional capacity needed, the second ISFSI pad would be similar in size to the one being constructed at Pilgrim. The Pilgrim pad (approximately 52 feet by 239 feet) is used as a proxy for the second pad at FitzPatrick.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. 5 3 The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 9 of the 50 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 560 offloaded assemblies, 68 assemblies per cask) which results in 9 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads. 61 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pads in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The latest decommissioning cost study for FitzPatrick (prepared in 2007) included an allowance for the remediation of contaminated (radiological) soil as being required to terminate the site operating license. However, there is no indication that any additional HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3. at page 2.4-1 (Accession Number ML081350153) 6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153)

Page 4 of 9

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station remediation of the soil in the vicinity of the current ISFSI pad would be necessary. As such, there is no allowance for the remediation of contaminated soil included with the decommissioning cost of the current ISFSI pad. There has also been no decision on the location of the future pad, but it is reasonable to assume that the site would be free of plant-related radionuclides or remediated prior to construction. Therefore, there is no allowance for the remediation of any additional contaminated soil in the estimate to decommission the second pad.

Low-level radioactive waste disposal costs are based on Entergy's negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.17' Costs are reported in 2012 dollars and based upon an internal decommissioning analysis prepared for Fitzpatrick in 2007. The spent fuel management plan was updated from a 2017 DOE start date to year 2020, consistent with the current assumption used for Entergy's fleet. Activity costs originally reported in 2007 dollars have been escalated to 2012 dollars using the Consumer Price Index, Services. 81

6.

Cost Considerations The estimated cost to decommission the ISFSI pads and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase.

During this phase the empty overpacks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed. The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies.

The final phase includes the cost for the license termination surveys, verification surveys, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor), Entergy's oversight staff, site security (industrial), and other site operating costs.

7 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February, 2012.

8 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS Page 5 of 9

Entergy Nuclear FitzPatrick, LLC ENOC-12-00039 James A. FitzPatrick Nuclear Power Station For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2066, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at FitzPatrick are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract.1 91 It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

" Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

" The projected amount necessary for decommissioning FitzPatrick is $607.333 million, based upon the NRC's latest financial assurance funding determination. [°0

• Based upon FitzPatrick's decommissioning trust fund balance as of September 30, 2012 and considering the allowed real rate of return on the fund between October 1, 2012 and the start of FitzPatrick station decommissioning, the trust fund will contain a $421.789 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

Entergy Nuclear FitzPatrick, LLC, Entergy Nuclear Indian Point 3, and Entergy Nuclear Operations, Inc. v.

United States, Court of Federal Claims, No. 03-2627-C (2009) 10 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 14, November 2010 Page 6 of 9

Entergy Nuclear FitzPatrick, LLC James A. FitzPatrick Nuclear Power Station ENOC-12-00039 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Existing ISFSI Pad 170 35 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 53 50 spent fuel + 3 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 9 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 3,067 Low-Level Radioactive Waste (cubic feet) 1,880 Low-Level Radioactive Waste (packaged density) 84 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 3

No residual radioactivity Page 7 of 9

Entergy Nuclear FitzPatrick, LLC James A. FitzPatrick Nuclear Power Station ENOC-12-00039 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 240 240 1,048 Decontamination/Demolition (activated liner removal) 108 8

48 106 53 324 1,880 536 License Termination (radiological surveys) 948 948 7,394 Subtotal 108 8

48 106 1,242 1,513 1,880 8,978 Supporting Costs NRC and NRC Contractor Fees and Costs 258 258 776 Insurance 62 62 Security (industrial) 190 190 4,999 Entergy Oversigt Staff 284 284 3,792 Subtotal 792 792 4,999 3,792 776 Total (w/o contingency) 108 8

48 106 2,034 2,305 1,880 13,977 3,792 776 Total (w/25% contingency) 136 10 60 133 2,543 2,881 Page 8 of 9

Entergy Nuclear FitzPatrick, LLC James A. FitzPatrick Nuclear Power Station ENOC-12-00039 Table 3 Financial Assurance Plant name: James A. Fitzpatrick Month Year of Biennial:

Termination of Operation:

10 10 Day 1

17 Year 2012 2034 I MWth 1986$

ECI Base Lx Lx Px I

Fx B

I gxI BWR 2536 r$126,824,oo0 r 117.6 2.16 0.65 2.54 1.971 r

4.022 0.13 r 2.91 0.22 12.54 NRC Minimum:

$607,333,267 Licensee:

%owned:

Amount of NRC Minimum/Site Specific: Amount in Trust Fundl Entergy 100.00%

1

$607,333,267 1

$619,075,175 1

Step 1:

Earnings Credit:

Real Rate of Years Left in Total Real Trust Fund Balance:

Retu per License Rate of Total Earnings:

$619,075,175 2%

22.04 1.54732

$957,908,797 ITotal Earnings = Trust Fund balance x (1+RRR)AYears left in license Step 2:

Accumulation:

Real Rate of Value of Annuity per year Return per Years of Annuity:

Total Annuity:

$0 2%

0

$0 Step 3:

Decom Period:

Real Rate of Decorn Total Real Total Earnings for Total Earnings:

Return per Period:

Rate of Decorn:

$957,908,797 2%

7 0.14869

$71,213,655 Total Earnings for Decom = (1/2) x Total Earnings x [(l+RRR)ADecom period - 1]

Total of Steps 1 - 3:

$1,029,122,452 Total = Total Earnings + Total Earnings for Decom Excess (Shortfall)

$421,789,185 to NRC minimum Page 9 of 9

ATTACHMENT 5 TO ENOC-12-00039 ILLUSTRATIVE 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR PILGRIM NUCLEAR POWER STATION DOCKET 50-293*

ENTERGY NUCLEAR OPERATIONS, INC

• currently no ISFSI Docket

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station Illustrative 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011llE with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

Although no ISFSI has been licensed at Pilgrim, for information purposes only, this letter provides a detailed cost estimate for decommissioning the ISFSI to be constructed at Pilgrim Nuclear Power Station (Pilgrim), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for Pilgrim is currently set to expire on June 8, 2032.

Approximately 5,146 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI is needed to support continued plant operations. Based upon the current projection of the DOE's ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, the construction of a U.S. Code of Federal Regulations. Title 10, Parts 20, 30, 40,50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 9

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station second ISFSI after shutdown to support decommissioning. The ISFSI(s) is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart KE21).

Because of the DOE's breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2032, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear Generation Company's (Entergy) current spent fuel management plan for the Pilgrim spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Pilgrim fuel. The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,t 3] the spent fuel is projected to be fully removed the Pilgrim site in 2059.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,ý4] DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

3 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 4

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive' Waste Management, December 2008 Page 2 of 9

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSIs will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The design and capacity of the Pilgrim ISFSI(s) is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 68 fuel assemblies, and'a steel-lined concrete storage overpack.

Entergy's current spent fuel management plan for the Pilgrim spent fuel would result in 43 spent fuel storage casks being placed on two separate storage pads at the site. This projected configuration is based upon the 2020 DOE spent fuel program start with a 2022 DOE start date for Pilgrim spent fuel, a 3,000 MTU / year pickup rate, and a 40 cask capacity for the ISFSI pad expected to be built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 43 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI(s) expected

• after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI(s) is based on the station operating until the end of its current license (2032) and the DOE's spent fuel acceptance assumptions, as previously described. A single (yet-to-be-constructed) Pilgrim ISFSI pad is expected to be approximately 52 feet by 239 feet, and have a maximum capacity of 40 casks.

Page 3 of 9

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.l51 The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, nine of the 43 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 580 offloaded assemblies, 68 assemblies per cask) which results in 9 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISItSI pad.I61 It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

During the construction of the ISFSI, the top six inches of soil at the excavation was sampled and analyzed. 171 There was no plant-related radioactive material in the samples, only naturally-occurring isotopes and background levels of 137Cs in the soil. Therefore, there is no allowance for the remediation of any contaminated soil in the estimate to decommission the ISFSI. There has also been no decision on the location of the future pad, but it is reasonable to assume that the site would be free of plant-related radionuclides or remediated prior to construction. Therefore, there is no allowance for the remediation of any additional contaminated soil in the estimate to decommission the second pad.

Low-level radioactive waste disposal costs are based on Entergy's currently negotiated rates with EnergySolutions.

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) 6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153)

Addendum to Radiological Engineering Evaluation 12-017, ISFSI On-Site Soil Sample Results, June 2012 Page 4 of 9

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757."8' Costs are reported in 2012 dollars and based upon an internal decommissioning analysis prepared for Pilgrim in 2012.

6.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad(s), and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed.

The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies.

The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor to perform the verification survey), Entergy's oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2060, the year following all spent fuel removal.

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

Page 5 of 9

Entergy Nuclear Operations, Inc.

ENOC-12-00039 Pilgrim Nuclear Power Station

7.

Financial Assurance ISFSI operations at Pilgrim are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract.J91 It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

• Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

" The projected amount necessary for decommissioning Pilgrim is $585.439 million, based upon the NRC's latest financial assurance funding determination. [0]

" Based upon Pilgrim's decommissioning trust fund balance as of September 30, 2012 and considering the allowed real rate of return on the fund between October 1, 2012 and the start of Pilgrim station decommissioning, the trust fund will contain a

$562.885 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

9 For Pilgrim, sub norn. Boston Edison Co. v. United States, 64 Fed. Cl. 167 (2005).

10 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation. NUREG-1307, Rev. 14, November 2010 Page 6 of 9

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station ENOC-12-00039 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Primary ISFSI Pad 239 52 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 47 43 spent fuel + 4 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 9 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 3,067 Low-Level Radioactive Waste (cubic feet) 1,878 Low-Level Radioactive Waste (packaged density) 84 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 4

No residual radioactivity Page 7 of 9

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station ENOC-12-00039 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 221 221 1,024 Decontamination/Demolition (activated liner removal) 99 8

55 106 53 321 1,878 536 License Termination (radiological surveys) 925 925 7,614 Subtotal 99 8

55 106 1,199 1,467 1,878 9,174 Supporting Costs NRC and NRC Contractor Fees and Costs 291 291 776

• Insurance 62 62 Security (industrial) 75 75 4,999 Entergy Oversight Staff 303 303 3,792 Subtotal 730 730 4,999 3,792 776 Total (w/o contingency) 99 8

55 106 1,929 2,197 1,878 14,173 3,792 776 Total (w/25% contingency) 124 10 69 133 2,411 2,746 1_1 Page 8 of 9

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station ENOC-12-00039 Table 3 Financial Assurance Plant name:

Pilgrim Year of Biennial:

Termination of Operation:

Month 10 6

Day 1

8 Year 2012 2032 BWR MWth 1

1986$

ECI 2028 r$122,252,000 117.6 Base Lx 1 2.16 1

0.65 2.54 Px I

Fx I I EK I I

I I

I 1.971 r

4.022 I

0.13 r

2.91 1

0.22 1 NRC Minimum:

$585,438,927 Site Specific:

H Licensee:

%Owned:

Entergy 100.00%

1 Amount of NRC Minimum/Site Specific:

$585,438,927 Amount in Trust Fund:

$723,802,070 I

I Step 1:

Earnings Credit:

I Trust Fund Balance:

$723,802,070 I

Real Rate of Return per 2%

Years Left in Licensel 19.69 1

Total Real Rate of 1.47673 I Total Earnings:

$1,068,861,580

]Total Earnings = Trust Fund balance x (1+RRR)AYears left in license Step 2:

Accumulation:

Value of Annuity per yearl Va0ueo Real Rate of Return per 2%

I-Years of Annuity:

0

-1 Total Annuity:

$0 Step 3:

Decom Period:

Total Earnings:

$1,068,861,580 I

I Real Rate of Return per 2%

I Decom Period:

7 Total Real Rate of 0.14869 Total rnins for Decom:

$79,462,199

]Total Earnings for Decom = (1/2) x Total Earningsx [(l+RRR)^Decom period - 1]

S Total of Steps 1 - 3:

1

$1,148,323,7 Total = Total Earnings;+ Total Earnings for Decom lExcess (Shortfall) 562,884,852 to NRC minimum Page 9 of 9

ATTACHMENT 6 TO ENOC-12-00039 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN FOR VERMONT YANKEE NUCLEAR POWER STATION ISFSI DOCKET 72-059 ENTERGY NUCLEAR OPERATIONS, INC

Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station 10 CFR 72.30 ISFSI Decommissioning Funding Plan

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 201 1,(l with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Vermont Yankee Nuclear Power Station (Vermont Yankee), in an amount reflecting:

1. The work is performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

2.

Spent Fuel Management Strategy The operating license for Vermont Yankee is currently set to expire on March 21, 2032.

Approximately 5,319 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOE's ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, a second, larger pad after shutdown to support U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 Page 1 of 9

Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station decommissioning and also accommodate the casks from operations. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K [21).

Because of the DOE's breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2032, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy Nuclear Vermont Yankee's (Entergy) current spent fuel management plan for the Vermont spent fuel is based in general upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the Vermont fuel.

The DOE's generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year, 3 3 the spent fuel is projected to be fully removed from the Vermont Yankee site in 2060.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In a report delivered to Congress in 2009,'4] DOE presented a six-year timeline for siting and constructing an interim storage facility (pending legislation eliminating the linkage in the Nuclear Waste Policy Act of 1982, as amended, between interim storage and the opening of the Yucca Mountain repository).

The six-year time span would allow fuel receipt by the 2020 date.

Entergy's position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

2 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

3 "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004 4

"Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel from Decommissioned Nuclear Power Reactor Sites," DOE/RW-0596, U.S. Department of Energy Office of Civilian Radioactive Waste Management, December 2008 Page 2 of 9

Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The design and capacity of the Vermont Yankee ISFSI(s) is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 68 fuel assemblies, and a steel-lined concrete storage overpack.

Entergy's current spent fuel management plan for the Vermont Yankee spent fuel would result in 42 spent fuel storage casks being placed on the future storage pad at the site (including the casks generated during plant operations). This projected configuration is based upon the 2020 DOE spent fuel program start with a 2021 DOE start date for Vermont Yankee spent fuel, a 3,000 MTU / year pickup rate, and a 36 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 42 casks projected to be on the pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 5) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

Page 3 of 9

Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2032) and the DOE's spent fuel acceptance assumptions, as previously described. For purposes of this analysis, the second, larger pad would be able to accommodate all the casks used to store spent fuel at the site, including those casks placed on the initial ISFSI pad during plant operations. The second, larger ISFSI pad is expected to be approximately 70 feet by 342 feet, and have a maximum capacity of 84 casks.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. 5j The decommissioning estimate is based on the premise that some of the inner steel-liners of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 6 of the 42 overpack liners are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 368 offloaded assemblies, 68 assemblies per cask) which results in 6 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.E6J It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSI's NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The decommissioning cost study 7] developed for Vermont Yankee and filed with the NRC, included the cost for the remediation of contaminated (radiological) soil, based HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) 6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153)

Decommissioning Cost Analysis for the Vermont Yankee Nuclear Power Station, dated January 2007 (Accession Number ML080430658)

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Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station upon a review of the site's radiological records and associated affected areas. During the construction of the existing ISFSI, the soil excavated was replaced with engineered fill.

This material is not expected to become contaminated from the operation of the ISFSI.

There has been no decision on the location of the future pad, but it is reasonable to assume that the site selected would be free of plant-related radionuclide or remediated prior to construction. Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommission the ISFSI.

Low-level radioactive waste disposal costs are based on Entergy's currently negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as R.S. Means' Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists. Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[81 Costs are reported in 2012 dollars and based upon an updated, internal decommissioning analysis prepared for Vermont Yankee in 2011. Activity costs originally reported in 2011 dollars have been escalated to 2012 dollars using the Consumer Price Index, Services.[91

6.

Cost Considerations The estimated cost to decommission the ISFSI pads and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase.

During this phase the empty overpacks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (liner removal) developed. The next phase includes the cost for craft labor to remove the activated liners, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies.

The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor), Entergy's oversight staff, site security (industrial), and other site operating costs.

"Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness," U.S.

Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS Page 5 of 9

Entergy Nuclear Vermont Yankee ENOC-12-00039 Vermont Yankee Nuclear Power Station For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2061, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Vermont Yankee are in response to the DOE's failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible according to a judgment entered against the DOE under federal law and the Standard Contract."01 It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

The projected amount necessary for decommissioning Vermont Yankee is $580.439 million, based upon the NRC's latest financial assurance funding determination. [11]

Based upon Vermont Yankee's decommissioning trust fund balance as of September 30, 2012 and considering the allowed real rate of return on the fund between October 1, 2012 and the start of Vermont Yankee station decommissioning, the trust fund will contain a $275.775 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in IOCFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

10 Vermont Yankee Nuclear Power Corporation and Entergy Nuclear Vermont Yankee, LLC v. United States, Court of Federal Claims, Nos. 02-898C and 03-2663C (2006)

"Report on Waste Burial Charges," U.S. Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 14, November 2010 Page 6 of 9

Entergy Nuclear Vermont Yankee Vermont Yankee Nuclear Power Station ENOC-12-00039 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Residual Item Length (ft)

Width (ft)

Radioactivity Current ISFSI Pad 132 76 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Inner Liner Thickness (inches) 1.25 Dimensions are nominal Quantity (total) 47 42 spent fuel + 5 GTCC Equivalent to the number of overpacks Quantity (with residual radioactivity) 6 used to store last complete core offload Total Surface Area of Overpack Liner with Residual Radioactivity (square feet) 2,044 Low-Level Radioactive Waste (cubic feet) 1,262 Low-Level Radioactive Waste (packaged density) 83 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 5

No residual radioactivity Page 7 of 9

Entergy Nuclear Vermont Yankee Vermont Yankee Nuclear Power Station ENOC-12-00039 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs Waste (thousands, 2012 dollars)

Volume Person-Hours NRC / NRC Removal Packaging Transport Disposal Other Total (ft3)

Contractor Licensee Contractor Deconunissioning Contractor Planning (characterization, specs and procedures) 221 221 1,024 Decontamination/Demolition (activated liner removal) 80 5

33 71 53 242 1,262 358 License Termination (radiological surveys) 940 940 8,354 Subtotal 80 5

33 71 1,213 1,402 1,262 9,736 Supporting Costs NRC and NRC Contractor Fees and Costs 303 303 1,014 Insurance 62 62 Security (industrial) 180 180 4,999 Entergy Oversight Staff 252 252 3,792 Subtotal 797 797 4,999 3,792 1,014 Total (w/o contingency) 80 5

33 71 2,010 2,199 1,262 14,736 3,792 1,014 Total (w/25% contingency) 100 6

42 89 2,513 2,749 Page 8 of 9

Entergy Nuclear Vermont Yankee Vermont Yankee Nuclear Power Station ENOC-12-00039 Table 3 Financial Assurance Plant name: Vermont Yankee Power Station Month Day Year of Biennial:

Termination of Operation:

10 3

1 21 Year 2012 2032 BWRI MWth 1986$

ECI Base Lx 1912

[$121,208,000?

117.6 2.16 Lxl Px I

I ExiI I ix l I

I I

-I 0.65 r 2.54 r 1.971 r

0.13

[

2.91 I

0.22 1 12.54 I

NRC Minimum:

$580,439,432 I

Licensee:

% Owned: I Amount of NRC Minimum/Site Specific:

Entergy 100.00%

$580,439,432 Site Specific:

IAmount in Trust Fund

$541,978,251 Step 1:

Earnings Credit:

Trust Fund Balance:

$541,978,251 I Real Rate of Return per 2%

Years LeftI Total Real in Licensel Rate of 19.47 1 1.47048 I Total Earnings:

$796,965,956 I

ITotal Earnings= Trust Fund balance x (1+RRR)AYears left in license Step 2:

Accumulation:

Value of Annuity per Real Rate of year Return per Years of Annuity:

Total Annuity:

$0 2%

0

$0 Step 3:

Decom Period:

Real Rate of Decorn Total Real Total Earnings:

Return per Period:

Rate of Total Earnings for Decom:

$796,965,956 2%

7 0.14869

$59,248,708 ITotal Earnings for Decom = (1/2) x Total Eamings x [(l+RRR)ADecom period - 1]

Total of Steps 1 - 3:

1

$856,21, i

Total = Total Earnings+ Total Earnings for Decom lExcess (Shortfall) 275,775,231 to NRC minimum I

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