ML11258A090

Email from R. Walpole, FW: Enne Distribution of Enoc 10-00010 10 CFR 50.75(f)(1)

ML11258A090
Person / Time
Site:	Palisades, Indian Point, Pilgrim, Vermont Yankee, Big Rock Point, FitzPatrick
Issue date:	04/01/2010
From:	Robert Walpole Entergy Nuclear Operations
To:	Paul Cataldo, Brian Haagensen NRC Region 1
References
FOIA/PA-2011-0272
Download: ML11258A090 (18)

Text

Waples, Langston From:

Sent:

To:

Subject:

Attachments:

Walpole, Robert W [rwalpol@entergy.com]

Thursday, April 01, 2010 3:03 PM Cataldo, Paul; Haagensen, Brian FW: ENNE Distribution of ENOC 10-00010 10 CFR 50.75(f)(1) Status of Decomriissioning Funding submittal dated 3/31/2010 Signed ENOC-10-00010 NRC.pdf Attached for your information and use is a copy of a letter that Entergy provided to the NRC. The letter relates to the status of decommissioning funds at Entergy's sites, including IPEC.

Bob Walpole

<<Signed ENOC-10-00010 NRC.pdf>>

1

-PSýEntergy Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 914-272-3370 John F. McCann Vice President, Nuclear Safety, Emergency Planning and Licensing ENOC-10-00010 March 31, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2738 (301) 415-7000

SUBJECT:

Status of Decommissioning Funding for Plants Operated by Entergy Nuclear Operations, Inc.

For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Entergy Nuclear Operations, Inc.

Indian Point Nuclear Generating Stations 1, 2 and 3 Docket Nos. 50-3, 50-247 and 50-286 Vermont Yankee Nuclear Power Station Docket No. 50-271 Pilgrim Nuclear Power Station Docket No. 50-293 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Palisades Nuclear Plant Docket No. 50-255 Big Rock Point Docket No. 50-155

1.

NUREG-1307, "Report on Waste Burial Charges," Revision 13, dated November 2008.

References:

2.

NRC Regulatory Issue Summary 2001-07, "10 CFR 50.75(f)(1) Reports on the Status of Decommissioning Funds (Due March 31, 2001)."

3.

Entergy letter NL-09068, "Reply to Request for Additional Information Regarding Decommissioning Cost Estimate and Irradiated Fuel Management Program," dated July 15, 2009 (ML092050204).

4.

Entergy letter ENOC-09-00024, "Decommissioning Funding Assurance Plans," dated August 13, 2009 (ML092260720).

Dear Sir or Madam:

10 CFR 50.75(f)(1).requires each power reactor licensee to report to the NRC by

ENOC-o10-00010 March 31, 1999, and every two years thereafter, on the status of its decommissioning funding for each reactor, or share of a reactor, that it owns. These reports are being provided as a result of our determination that Entergy's proposed indirect license transfer satisfies the "merger or acquisition" clause in 10 CFR 50.75(f)(1) and for plants within 5 years of the projected end of their operation. On behalf of Entergy Nuclear Indian Point 2 LLC (Indian Point 1&2), Entergy Nuclear Indian Point 3 LLC (Indian Point 3), Entergy Nuclear Vermont Yankee LLC (Vermont Yankee), Entergy Nuclear Generation Company (Pilgrim Station), Entergy Nuclear FitzPatrick LLC (James A. FitzPatrick), and Entergy Nuclear Palisades LLC (Palisades and Big Rock Point), Entergy Nuclear Operations, Inc. hereby submits the information requested for power reactors operated by Entergy Nuclear Operations, Inc. The reports, provided in Attachments 1 thru 8 for the above listed facilities, were prepared in accordance with NUREG-1307 (Reference

1) and NRC Regulatory Issue Summary 2001-07 (Reference 2). Attachment 9 provides an updated Decommissioning Funding Assurance Plan for Indian Point 1, which updates the SAFSTOR analysis previously provided in Reference 3. Attachment 10 provides an updated Decommissioning Funding Assurance Plan for Indian Point 2, which updates the SAFSTOR analysis previously provided in Reference 4.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Les England at 601-368-5766.

Sincerely, JFM/CDF/LAE Attachments: As described above cc: Next page.

2

ENOC-10-00010 cc: all w/attachments USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Indian Point 1 USNRC Project Manager, Indian Point 2 USNRC Project Manager, Indian Point 3 USNRC Project Manager, FitzPatrick USNRC Project Manager, Vermont Yankee USNRC Project Manager, Pilgrim USNRC Project Manager, Palisades USNRC Project Manager, Big Rock Point USNRC Resident Inspector, Indian Point 2 USNRC Resident Inspector, Indian Point 3 USNRC Resident Inspector, FitzPatrick USNRC Resident Inspector, Vermont Yankee USNRC Resident Inspector, Pilgrim USNRC Resident Inspector, Palisades Michigan Department of Environmental Quality Michigan Public Service Commission Mr. David O'Brien, Commissioner Department of Public Service 120 State Street - Drawer 20 Montpelier, VT 05602 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza Albany, NY 12223 Mr. Francis J. Murray, Jr.

President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Ms. Victoria J. Brown, Esq.

Primmer Piper Eggleston & Cramer, PC 150 S. Champlain Street P.O. Box 1489 Burlington, VT 05402 Mr. L. Jager Smith, Esq.

1340 Echelon Parkway Jackson, MS 39213-8298 3

ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Endinq December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 1

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance and total expenditures with 2.0% annual growth based upon a SAFSTOR analysis.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

$ 457.814 million [Note]

$ 260.15 million See Attachment 9 ($ 743.524 million)

None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

5.

Any contracts upon which the licensee is relying None.

pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current None.

method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

None.

Note: This amount is based upon total SAFSTOR expenditures set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in.

1 ENOC-10-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 2 For Year Endinq December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 2

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance and total expenditures with 2.0% annual growth based upon a SAFSTOR analysis.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial. assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 411.70 million or

$ 682.74 million [Note 1]

$ 342.23 million [Note 2]

See Attachment 10 ($ 780.202 million)

None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

None.

None.

Note 1 :This amount is based upon total SAFSTOR expenditures set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis provided in 0.

Note 2:lncludes provisional fund balance of $29.68 million.

2 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 3

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on current operating license.

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on 20 year license renewal.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 411.70 million

$ 450.65 million

$ 544.66 million

$ 809.33 million None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

None.

None.

3 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding Vermont Yankee For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Vermont Yankee Nuclear Power Station

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on current operating license.

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on 20 year license renewal.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 518.91 million

$ 428.37 million[Note 1]

$ 480.91 millionINote 1]

$ 714.61 million[Note 11 None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

Parent Guarantee

($ 40 million)fNote 21 None.

Note 1 :Does not include the Parent Guarantee amount as indicated in Note 2.

Note 2:A $40 million Parent Guarantee is now in place, and the required certifications of the financial test establishing Entergy Corporation's qualifications to provide the guarantee based upon 2008 financial results were provided in an Entergy Nuclear Operations, Inc.

submittal, BVY 10-008, January 28, 2010, "Decommissioning Funding Assurance Documentation," Vermont Yankee Nuclear Power Station (Accession No. ML100470701). Updated certifications of the financial test establishing Entergy Corporation's qualifications to provide the guarantee based upon 2009 financial results are being provided separately.

4 ENOC-10-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Pilgrim For Year Endina December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Pilgrim Nuclear Power Station

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on current operating license.

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on 20 year license renewal.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 523.38 million

$ 609.31 million

$ 686.96 million

$ 1,020.78 million None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

None.

None.

5 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - James A. Fitzpatrick For Year Endinq December 31, 2009 - 10 CFR 50:75(f)(1)

Plant Name: James A. Fitzpatrick Nuclear Power Plant

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance with 2.0% annual growth to the midpoint of decommissioning based on current operating license.

3.

A schedule of the annual arrmounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 542.96 million

$ 491.74 million

$ 863.19 million None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

None.

None.

6 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31. 2009 - 10 CFR 50.75(f)(1)

Plant Name: Palisades Nuclear Plant

1.

Amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75 (b) and (c).

2.

Amount accumulated to the end of the calendar year preceding the date of the report (December 31, 2009).

Fund balance with 2.0% annual growth to the midpoint of decommissioning.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 380.07 million

$ 245.27 million

$ 401.20 million None.

2% annual real rate of return on funds per 10 CFR 50.75(e)(1)(i)

None.

None.

None.

7 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Big Rock Point For Year Endinq December 31, 2009 - 10 CFR 50.75(f)(1)

Plant Name: Big Rock Point ISFSI

1.

Amount of decommissioning funds required from most recent estimate (2003 dollars).

Decommissioning cost estimate escalated at 3% per year to 2009 dollars.

2.

Decommissioning Funding Assurance Method.

3.

A schedule of the annual amounts remaining to be collected.

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections.

5.

Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report.

7.

Any material changes to trust agreements.

$ 2.74 million

$ 3.27 million Parent Guarantee ($5 million)

None.

Escalation rate: 3.0%

Rate of earnings: n/a None.

None.

None.

8 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

On October 23, 2008, Entergy Nuclear Indian Point 2, LLC (ENIP2) submitted a preliminary decommissioning cost analysis to the NRC in conjunction with its spent fuel management plan under 10 CFR 50.75(f)(3) and 10 CFR 50.54(bb) (Accession No. ML083040378, as supplemented by ENIP2's reply to RAIs on July 15, 2009 (Accession No. ML092050204). The preliminary decommissioning cost analysis contained separate site-specific decommissioning cost estimates for Indian Point 1 and Indian Point 2. The estimates were subsequently found to be reasonable by the NRC on March 17, 2010 (Accession No. ML100280544).

The Indian Point 1 site-specific decommissioning cost estimate that was submitted was based on a period of safe storage that is specifically described in the estimate, namely storage until 2066, at which time the plant will be decommissioned and the site released for alternative use without restriction. Table 7 in the Indian Point 1 site-specific estimate (page 34 of 36) provides the annual license termination phase expenditures for Indian Point 1 in 2007 dollars (excluding those costs expended to date and through the 3 rd quarter of 2013 which are funded by operations). Table 9-1 below escalates those 2007 dollar figures to 2009 dollars using escalation values obtained from data provided by IHS Global Insight. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

9 ENOC-10-00010 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Table 9-1 NRC License Termination Cost

($ millions) 2007$

2009$

Unit 1 Unit 1 Ending DTF Radiological Radiological Balance 2009 260.149 2010 265.352 2011 270.659 2012 276.072 2013 1.059 1.096 280.497 2014 4.236 4.385 281.722 2015 4.236 4.385 282.971 2016 2.656 2.745 285.885 2017 2.649 2.738 288.865 2018 2.649 2.738 291.904 2019 2.649 2.738 295.004 2020 2.656 2.745 298.159 2021 2.649 2.738 301.384 2022 2.649 2.738 304.674 2023 2.649 2.738 308.029 2024 2.656 2.745 311.445 2025 2.649 2.738 314.936 2026 2.649 2.738 318.497 2027 2.649 2.738 322.129 2028 2.656 2.745 325.827 2029 2.649 2.738 329.606 2030 2.649 2.738 333.460 2031 2.649 2.738 337.391 2032 2.656 2.745 341.394 2033 2.649 2.738 345.484 2034 2.649 2.738 349.656 2035 2.649 2.738 353.911 2036 2.656 2.745 358.244 2037 2.649 2.738 362.671 2038 2.649 2.738 367.186 2039 2.649 2.738 371.792 2040 2.656 2.745 376.483 2041 2.649 2.738 381.275 2042 2.649 2.738 386.163 2043 2.649 2.738 391.148 2044 2.656 2.745 396.226 2045 2.611 2.697 401.454 10 ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Table 9-1 (continued)

NRC License Termination Cost

($ millions) 2007$

2009$

Unit 1 Unit 1 Ending DTF Radiological Radiological Balance 2046 1.826 1.873 407.610 2047 1.826 1.873 413.889 2048 1.831 1.878 420.289 2049 1.826 1.873 426.822 2050 1.826 1.873 433.485 2051 1.826 1.873 440.282 2052 1.831 1.878 447.210 2053 1.826 1.873 454.281 2054 1.826 1.873 461.494 2055 1.826 1.873 468.851 2056 1.831 1.878 476.350 2057 1.826 1.873 484.004 2058 1.826 1.873 491.811 2059 1.826 1.873 499.774 2060 1.831 1.878 507.891 2061 1.826 1.873 516.176 2062 1.826 1.873 524.627 2063 1.826 1.873 533.247 2064 1.831 1.878 542.034 2065 1.826 1.873 551.002 2066 18.899 19.667 542.355 2067 68.313 70.906 482.296 2068 148.490 154.149 337.793 2069 17.216 17.911 326.638 2070 17.216 17.911 315.260 2071 17.216 17.911 303.654 2072 17.235 17.932 291.795 2073 11.400 11.921 285.710 441.549 457.814 The foregoing SAFSTOR analysis shows that when the December 31, 2009 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $285.71 million surplus exists at the end of the decommissioning project. Accordingly, ENIP2 concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Indian Point 1.

11 0

ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

IP2 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

On August 13, 2009, Entergy Nuclear Indian Point 2, LLC (ENIP2) submitted a decommissioning funding assurance plan for Indian Point Energy Center, Unit 2 (Indian Point 2)

(Accession No. ML092260720). The plan was in response to a projected decommissioning funding shortfall for ENIP2 and the subsequent need to describe how and when the licensee intends to make adjustments to its financial assurance mechanisms. This attachment provides an update to the August 13, 2009 funding plan.

ENIP2 has determined that use of a SAFSTOR analysis shows that there is presently reasonable assurance that adequate funds will be available for the decommissioning process in compliance with NRC decommissioning funding assurance rules.

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site-specific estimate under § 50.75(b)(1) of this section may take, credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." ENIP2 understands that a facility specific analysis may be used for demonstrating the adequacy of decommissioning funds, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2) as the basis for justifying a higher than minimum funding level." (Regulatory Guide 1.159, section 1.1.1; Draft Regulatory Guide-1229, section 1.1.1.) ENIP2 also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis.

On October 23, 2008, ENIP2 submitted a site specific decommissioning cost estimate to the NRC in conjunction with its preliminary decommissioning cost estimate, and spent fuel management plan under 10 CFR 50.75(f)(3) and 10 CFR 50.54(bb) (Accession No. ML083040378, as supplemented by ENIP2's reply to RAIs on July 15, 2009 (Accession No. ML092050204). That submittal contained separate site-specific decommissioning cost estimates for Indian Point 1 and Indian Point 2. The Indian Point 2 site-specific decommissioning cost estimate that was submitted was based on a period of safe storage that is specifically described in the estimate, namely storage until 2064, at which time the plant will be decommissioned and the site released for alternative use without restriction. Table 4 in the Indian Point 2 site-specific estimate (page 31 of 38) provides the annual license termination phase expenditures for Indian Point 2 in 2007 dollars. Table 10-1 below escalates those 2007 dollar figures to 2009 dollars using escalation values obtained from data provided by IHS Global Insight. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

Table 10-1 below uses the December 31, 2009 balance and indicates that there is now a

$97.462 million surplus in 2073 in decommissioning trust funds at the end of radiological decommissioning of Indian Point 2.

12 0

ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

IP2 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2009 - 10 CFR 50.75(f)(1)

Table 10-1 NRC License Termination Cost

($ millions) 2007$

2009$

Unit 2 Unit 2 Ending DTF Radiological Radiological Balance 2009 342.226 2010 349.071 2011 356.052 2012 363.173 2013 11.164 11.528 358.908 2014 49.271 50.920 315.166 2015 25.307 26.328 295.141 2016 3.711 3.828 297.216 2017 3.701 3.817 299.343 2018 3.701 3.817 301.513 2019 3.701 3.817 303.726 2020 3.711 3.828 305.973 2021 3.688 3.804 308.288 2022 3.676 3.791 310.663 2023 3.676 3.791 313.085 2024 3.686 3.802 315.545 2025 3.676 3.791 318.065 2026 3.676 3.791 320.635 2027 3.676 3.791 323.257 2028 3.686 3.802 325.920 2029 3.676 3.791 328.647 2030 3.676 3.791 331.429 2031 3.676 3.791 334.267 2032 3.686 3.802 337.150 2033 3.676 3.791 340.102 2034 3.676 3.791 343.113 2035 3.676 3.791 346.184 2036 3.686 3.802 349.306 2037 3.676 3.791 352.501 2038 3.676 3.791 355.760 2039 3.676 3.791 359.084 2040 3.686 3.802 362.464 2041 3.676 3.791 365.922 2042 3.676 3.791 369.449 2043 3.676 3.791 373.047 2044 3.686 3.802 376.706 2045 3.675 3.791 380.449 2046 3.668 3.783 384.275 13 0

ENOC-1 0-00010 Entergy Nuclear Operations, Inc.

IP2 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Endinq December 31, 2009 - 10 CFR 50.75(f)(1)

Table 10-1 (continued)

NRC License Termination Cost

($ millions) 2007$

2009$

Unit 2 Unit 2 Ending DTF Radiological Radiological Balance 2047 3.668 3.783 388.178 2048 3.678 3.794 392.148 2049 3.668 3.783 396.208 2050 3.668 3.783 400.349 2051 3.668 3.783 404.573 2052 3.678 3.794 408.870 2053 3.668 3.783 413.264 2054 3.668 3.783 417.746 2055 3.668 3.783 422.318 2056 3.678 3.794 426.970 2057 3.668 3.783 431.726 2058 3.668 3.783 436.578 2059 3.668 3.783 441.527 2060 3.678 3.794 446.564 2061 3.668 3.783 451.712 2062 3.668 3,783 456.963 2063 3.668 3.783 462.319 2064 24.751 25.534 446.031 2065 55.625 57.545 397.407 2066 168.560 174.850 230.505 2067 71.834 74.431 160.684 2068 25.113 26.019 137.879 2069 6.046 6.317 134.320 2070 6.046 6.317 130.689 2071 6.046 6.317 126.986 2072 6.547 6.840 122.686 2073 26.485 27.678 97.462 659.351 682.740 As can be seen from the information provided in Table 10-1, the required funding for SAFSTOR decommissioning, $682.74 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and 1(c) of $411.70 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2009 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $97.5 million surplus exists at the end of the decommissioning project.

Accordingly, ENIP2 concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Indian Point 2.

14