Text

Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
	ML14358A251
Person / Time
Site:	Vermont Yankee
Issue date:	12/19/2014
From:	Wamser C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BVY 14-085
	Download: ML14358A251 (23)
	v • d • e

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

---Entergy Vernon, VT 802-257-7711 Christopher J. Wamser Site Vice President BVY 14-085 10 CFR 50.54(bb)

December 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb),"

BVY 08-077, dated October 14, 2008 (ML082910294)

3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. MD8035 and MD8051)," NVY 09-009, dated February 3, 2009 (ML083390193)

4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)

5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan - RAI Response," BVY 09-048, dated August 18, 2009 (ML092370298)

6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC No. ME1152)," NVY 09-100, dated October 8, 2009 (ML092740238)

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

/4c0J hW&C(ý4

BVY 14-085 / Page 2 of 3

Dear Sir or Madam:

In accordance with 10 CFR 50.54(bb), Entergy Nuclear Operations, Inc. (ENO) is hereby notifying the NRC of significant changes to the Vermont Yankee Nuclear Power Station (VYNPS) Program for Management of Irradiated Fuel.

Pursuant to 10 CFR 50.54(bb), ENO initially submitted a Program for Maintenance of Irradiated Fuel on March 21, 2007 (Reference 1) and a Revised Program for Maintenance of Irradiated Fuel on October 14, 2008 (Reference 2). On February 3, 2009, the NRC staff approved the VYNPS irradiated fuel management program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).

On April 1, 2009, ENO submitted an update to its irradiated fuel management program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). The NRC staff approved the revised irradiated fuel management program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).

By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur in the fourth quarter of 2014 (Reference 7). As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program for Management of Irradiated Fuel. This submittal provides the required Section 50.54(bb) notification. Attachment 1 provides the Updated Program for Management of Irradiated Fuel (Program), which supersedes all prior versions of the Program.

In Reference 5, Entergy Nuclear Vermont Yankee, LLC committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. Based on the funding strategy described in the updated Program, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment. There are no new regulatory commitments made by this letter. of this letter contains one cancelled regulatory commitment.

Should you have any questions concerning this letter or require additional information, please contact Mr. Philip Couture at 802-451-3193.

Sincerely, CJW/plc/shr

BVY 14-085 / Page 3 of 3 Attachments: 1. Updated Program for Management of Irradiated Fuel

2. List of Cancelled Regulatory Commitments cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 14-085 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel

BVY 14-085 1 Attachment 1 / Page 1 of 17 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel I. Background and Introduction Entergy Nuclear Operations, Inc. (ENO) submitted a Program for Maintenance of Irradiated Fuel (Program) on March 21, 2007 (Reference 1) and a revised Program on October 14, 2008 (Reference 2) for Vermont Yankee Nuclear Power Station (VYNPS). ENO submitted these programs pursuant to 10 CFR 50.54(bb), which requires power reactor licensees to submit a spent fuel management and funding program for NRC review five years prior to the expiration of a reactor operating license. At the time, the VYNPS operating license was set to expire on March 21, 2012. On February 3, 2009, the NRC staff approved the VYNPS Program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).

On April 1, 2009, ENO submitted an update to the VYNPS Program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). In Reference 5, VYNPS owner Entergy Nuclear Vermont Yankee, LLC (ENVY) committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. The NRC staff approved the revised VYNPS Program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).

By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur later this month (Reference 7).

Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes to their proposed spent fuel management plans. As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program. This submittal provides the required Section 50.54(bb) notification. This updated Program supersedes all prior versions of the Program.

Pursuant to 10 CFR 50.82(a)(4)(i), on December 19, 2014, ENO submitted a Post Shutdown Decommissioning Activities Report (PSDAR) for VYNPS that included a site-specific decommissioning cost estimate (DCE) as an attachment (Reference 8). The DCE describes the bases for the assumptions regarding the DOE's acceptance of spent fuel from the industry and from VYNPS. As discussed in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the Program is based on the assumption that DOE will commence acceptance of VYNPS's spent fuel in 2026 and complete removal of all spent fuel from the site in 2052, consistent with the current DOE spent fuel management and acceptance strategy.'

As noted in the DCE, DOE's repository program assumes that spent fuel is accepted for disposal from the nation's commercial nuclear plants in the order ("queue") in which it was removed from service ("oldest fuel first"). The contracts that U.S. generators have with the DOE provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst generators, and the option of providing priority acceptance from permanently shutdown nuclear reactors. VYNPS will seek the most expeditious means of removing fuel from the site when DOE commences performance. Given DOE's failure to accept fuel under its contracts, however, it is unclear how these mechanisms will operate once DOE begins accepting

BVY 14-085 / Attachment 1 / Page 2 of 17 The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the Program, along with license termination and site restoration activities and costs.

II. Irradiated Fuel Management Strategy At the time of shutdown, there will be 368 fuel assemblies residing in the reactor as part of the current operating cycle, 2,628 spent fuel assemblies 2 stored in the spent fuel pool, and 884 assemblies stored in 13 dry storage casks on an independent spent fuel storage installation (ISFSI) pad. In 2008, construction of the first ISFSI pad was completed, which VYNPS operates under a 10 CFR Part 50 General License (in accordance with 10 CFR Part 72, Subpart K).

VYNPS selected the Holtec HI-STORM 1OOS dry cask storage system for the spent fuel that is currently stored on the ISFSI. The system consists of a multipurpose canister (MPC) with a nominal capacity of 68 fuel assemblies and a concrete storage overpack. The current ISFSI pad was constructed to support 36 dry storage casks (the pad has four additional unused storage locations to allow VYNPS to move the casks if needed). VYNPS completed fuel loading campaigns to the ISFSI in 2008, 2011, and 2012.

As indicated in the VYNPS PSDAR (Reference 8), ENVY has selected the SAFSTOR decommissioning option. The Program assumes that decommissioning is completed within 60 years of permanent plant shutdown (i.e., by the end of 2074). Following shutdown, the reactor building will be operated as an interim wet fuel storage facility for approximately five and one-half years after operations cease. During this time period, the spent fuel residing in the storage pool will be transferred to the ISFSI. The ISFSI will remain operational until DOE is able to accept title to the fuel and complete the transfer of the fuel off site.

The PSDAR and DCE describe three major phases related to spent fuel management at VYNPS, which are summarized below. 3 Spent fuel management activities are further broken out into two categories - "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, and "transfer to dry storage" activities, such as procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad.

spent fuel from commercial reactors. Accordingly, for planning purposes only, this Program assumes that DOE will accept spent fuel in an oldest fuel first order.

2 This figure includes one fuel debris canister.

3 Appendix C to the DCE (Reference 8, Attachment 1) includes a detailed cost analysis of all decommissioning activities, including spent fuel management activities, by period.

BVY 14-085 / Attachment 1 / Page 3 of 17 TABLE I - Irradiated Fuel Management Program: Summary Schedule and Costs Decommissioning Period Start End Duration Cost (thousands (Years) of 2014 dollars)

Periods 0 and 1: Planning and Preparations for 2013 2016 2.6 23,068 Dormancy Spent Fuel Management Operations 6,055 Transfer to Dry Storage 17,013 Period 2a: Dormancy with Wet Fuel Storage 2016 2020 4.2 217,318 Spent Fuel Management Operations 91,696 Transfer to Dry Storage 125,548 Period 2b: Dormancy with Dry Fuel Storage 2020 2052 32.5 127,961 Spent Fuel Management Operations 127,961 TOTAL 39.3 368,347

1. Pre-Shutdown Planning and Preparations for SAFSTOR Dormancy Pre-shutdown planning activities include designing an expanded ISFSI facility to include a second storage pad, which is expected to be located in close proximity to the existing pad. The second pad is being designed for storage of 25 casks, and combined with the existing pad, will allow for dry storage of all spent fuel assemblies generated during the plant operations.

The initial decommissioning activities to be performed after plant shutdown will focus primarily on preparing the plant for a period of safe-storage (also referred to as dormancy) and constructing a second ISFSI pad. During this phase, VYNPS plans to complete the design of the new ISFSI pad and initiate site work. VYNPS also plans to commence security modifications supporting future ISFSI and dormancy operations during this time period.

The estimated spent fuel management costs associated with ISFSI design and construction, site security modifications, and other expenses during this initial phase, such as emergency planning and preparations for dormancy, total approximately $23.1 million.

2. Dormancy with Wet Fuel Storage During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. VYNPS expects to complete expansion of the ISFSI in 2017, assuming the timely receipt of the required state regulatory approvals. The estimated costs associated with expanding the ISFSI, including construction of the second pad and related security modifications, total approximately $32.7 million. Table 2 below provides additional detail on certain estimated dry storage-specific expenditures.

VYNPS expects to begin transferring the remaining spent fuel from the spent fuel pool to the ISFSI in 2019 and to complete the transfer of all fuel to the ISFSI by mid-2020. In total, 3,879 spent fuel assemblies and one fuel debris canister will be stored in 58 dry cask systems on the two ISFSI pads. Costs associated with purchasing 45 additional dry cask systems, loading fuel, and transferring fuel from the spent fuel pool to the ISFSI are included in this phase. After the fuel transfer is completed, the pool will be drained and supporting systems will be de-energized for the remainder of the dormancy period.

The total estimated spent fuel -management costs associated with this phase is approximately

$217.3 million.

BVY 14-085 / Attachment 1 / Page 4 of 17

3. Dormancy with Dry Fuel Storaae During this phase, the spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the DCE (Reference 8, Attachment 1), for planning purposes, the current Program assumes that DOE will begin removing fuel from VYNPS in 2026 and will complete the removal of all spent fuel from the site in 2052, according to the schedule set forth in Table 3 below.

During this phase, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Equipment maintenance, monitoring, and inspection will be performed as necessary. VYNPS will also maintain a 24-hour security force, whose primary responsibility will be to safeguard the spent fuel for as long as it remains on site. A security barrier, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the spent fuel. The estimated average annual cost to operate the ISFSI during this phase is approximately $4 million.

Late in the dormancy period, additional activities will include transferring the spent fuel from the ISFSI to the DOE. The estimated cost for the eventual transfer of the MPCs to a DOE-provided transport vehicle for off-site disposal is approximately 4

$10 million, excluding a $4.4 million allowance for a spent fuel transfer facility.

The total estimated spent fuel management cost associated with this phase is approximately

$127.96 million.

As noted in the DCE (Reference 8, Attachment 1), DOE has breached its obligations to remove fuel from reactor sites on the contracted schedule, and has also failed to provide plant owners with information about how it will ultimately perform and fulfill its obligation. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to the Standard Contract, but DOE has not explained what costs any such amendment would involve.

Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will specifically deal with already-canistered fuel, and for purposes of the DCE only, the DCE assumes that there will be no additional costs associated with DOE's acceptance of such fuel. If this assumption is incorrect, it is assumed that DOE will have liability for costs incurred to transfer the fuel to DOE-supplied containers, and to dispose of existing containers.

BVY 14-085 / Attachment 1 / Page 5 of 17 Table 2 - Estimated Expenditures for ISFSI Construction, Spent Fuel Packagina and Canister Transfer (thousands, 2014 dollars?

Spent Fuel MPC and New ISFSI Related Storage ISFSI Fuel ISFSI to Pad Security Overpack Loading Transfer DOE Year Construction Modifications Costs Campaigns Facility Transfer Total 2014 4,753 0 0 0 0 0 4,753 2015 7,529 2,215 0 0 0 0 9,744 2016 7,613 0 0 0 0 0 7,613 2017 3,545 0 25,907 0 0 0 29,452 2018 0 1,400 37,940 1,375 0 0 40,715 2019 0 4,250 13,623 21,780 0 0 39,653 2020 0 1,400 1,311 7,920 0 0 10,631 2021 0 0 0 0 0 0 0 2022 0 0 0 0 0 0 0 2023 0 0 0 0 0 0 0 2024 0 0 0 0 0 0 0 2025 0 0 0 0 4,416 0 4,416 2026 0 0 0 0 0 863 863 2027 0 0 0 0 0 0 0 2028 0 0 0 0 0 518 518 2029 0 0 0 0 0 690 690 2030 0 0 0 0 0 518 518 2031 0 0 0 0 0 518 518 2032 0 0 0 0 0 345 345 2033 0 0 0 0 0 345 345 2034 0 0 0 0 0 345 345 2035 0 0 0 0 0 345 345 2036 0 0 0 0 0 345 345 2037 0 0 0 0 0 345 345 2038 0 0 0 0 0 345 345 2039 0 0 0 0 0 345 345 2040 0 0 0 0 0 0 0 2041 0 0 0 0 0 173 173 2042 0 0 0 0 0 173 173 2043 0 0 0 0 0 518 518 2044 0 0 0 0 0 345 345 2045 0 0 0 0 0 345 345 2046 0 0 0 0 0 345 345 2047 0 0 0 0 0 345 345 2048 0 0 0 0 0 345 345 2049 0 0 0 0 0 345 345 2050 0 0 0 0 0 345 345 2051 0 0 0 0 0 0 0 2052 0 0 0 0 0 863 863 Total 23,440 9,265 78,782 31,075 4,416 10,005 156,983 5

The costs identified in the first four columns (New ISFSI Pad Construction, Spent Fuel Related Security Modifications, MPC and Storage Overpack Costs, and ISFSI Loading Campaigns) are considered "transfer to dry storage" costs.

BVY 14-085 / Attachment 1/ Page 6 of 17 TABLE 3 - Spent Fuel Management Schedule (Fuel Assembly Totals by Location)

Pool ISFSl DOE Year Inventory Inventory Acceptance6 2014 2,996 884 2015 2,996 884 2016 21996 884 2017 2,996 884 2018 2,996 884 2019 820 3,060 2020 0 3,8807 2021 3,880 2022 3,880 2023 3,880 2024 3,880 2025 3,880 2026 3,502 378 2027 3,502 -

2028 3,284 218 2029 3,010 274 2030 2,784 226 2031 2,558 226 2032 2,422 136 2033 2,286 136 2034 2,157 129 2035 2,029 128 2036 1,901 128 2037 1,781 120 2038 1,661 120 2039 1,549 112 2040 1,549 _

2041 1,464 85 2042 1,405 59 2043 1,209 196 This schedule is provided for illustrative purposes only and assumes that DOE begins accepting VYNPS fuel in 2026. It is expected that VYNPS will seek to accelerate acceptance based on shutdown reactor priority, exchanges of acceptance allocations, and other Standard Contract provisions.

Includes one fuel debris canister, which, for purposes of this analysis and for convenience, is assumed to be picked up in the final year of DOE acceptance (2052).

BVY 14-085 / Attachment 1 / Page 7 of 17 TABLE 3 - Spent Fuel Management Schedule (cont'd)

(Fuel Assembly Totals by Location)

Pool ISFSI DOE, Year Inventory Inventory Acceptance 2044 1,073 136 2045 949 124 2046 821 128 2047 701 120 2048 585 116 2049 469 116 2050 349 120 2051 349 2052 349 Total 3,880 Ill. ISFSI Decommissioning The ISFSI pads and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site. The bases and assumptions used to formulate the cost estimate are discussed in the DCE (Reference 8, Attachment 1). As detailed in Appendix D to the DOE, the estimated cost to decommission the ISFSI is approximately $5.1 million.

IV. Funding Demonstration for License Termination and Spent Fuel Management Operations Costs As shown in the DCE (Reference 8, Attachment 1), the projected total cost to decommission VYNPS, after an extended period of safe storage, is estimated at $1.24 billion (in 2014 dollars).

This amount includes estimated costs associated with license termination ($817.22 million),

interim spent fuel storage ($368.35 million), and site restoration ($57.15 million) activities.

In Reference 9, ENO submitted an updated Decommissioning Funding Status report.

Reference 9 reported the VYNPS decommissioning trust fund balance to be approximately $655 million as of October 31, 2014. Tables 3.4 and 3.5 of the DCE (Reference 8, Attachment 1) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. For convenience, those tables are reproduced below as Tables 4 and 5. This annual expenditure information is used in the cash flow analysis in Table 6 below. The cash flow analysis demonstrates that the VYNPS trust fund is sufficiently funded for all license termination activities and certain spent fuel management activities. ENVY plans to fund "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, from the trust fund. Of the estimated $368 million total spent fuel management costs, the operational costs total approximately $225 million.

The remaining $143 million is associated with transfer of spent fuel to dry storage (e.g.,

procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad). To fund the "transfer to dry storage" portion of spent fuel management costs, ENVY intends to establish two separate revolving credit facilities from third party banks totaling $145 million. The first facility is planned be a committed credit facility with

BVY 14-085 / Attachment 1 / Page 8 of 17 an expected duration of three years and a capacity of $60 million. This facility would be guaranteed by Entergy Corporation, parent company of ENVY and ENO. The committed facility is intended to provide working capital for ENVY from the time it pays an expenditure to the time it receives reimbursement from the trust fund, as well as dry storage costs that are not reimbursable from the trust fund. The second credit facility is planned to be an uncommitted facility with a capacity of $85 million. 8 This facility would also be guaranteed by Entergy Corporation. This facility is intended to cover the balance of costs related to transferring fuel from the spent fuel pool to the ISFSI.

Thus, considering the current fund balance of $655 million (as of October 31, 2014), projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), and $145 million from the two planned external credit facilities to fund the transfer to dry fuel storage costs, the trust fund is expected to have an excess of $175.9 million over the estimated license termination and spent fuel management costs. As noted above, in Reference 5, ENVY committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities.

As shown in the updated funding strategy for license termination and spent fuel management activities, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment.

A committed credit facility is a legal agreement between the lender and the borrower outlining the conditions of the credit facility. Once signed, the agreement requires the lender to lend money to the borrower, provided that the borrower satisfies the agreement's conditions (e.g., paying fees).

Committed credit lines differ from uncommitted credit lines in that they legally bind the lender to provide the funds, rather than giving the lender the option of suspending or canceling the credit line based on market conditions.

BVY 14-085 / Attachment 1 / Page 9 of 17 Table 4 - License Termination Expenditures (thousands, 2014 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2014 0 0 0 0 15,165 15,165 2015 39,626 533 3,912 38 37,089 81,198 2016 15,512 442 1,004 22 19,145 36,126 2017 2,015 395 184 14 8,216 10,823 2018 1,898 395 184 14 7,057 9,548 2019 1,858 395 184 14 5,722 8,173 2020 5,716 1,234 1,288 1,200 8,326 17,763 2021 1,969 284 187 7 2,794 5,241 2022 1,969 284 187 7 2,744 5,191 2023 1,969 284 187 7 2,744 5,191 2024 1,974 285 187 7 1,196 3,650 2025 1,969 284 187 7 1,144 3,591 2026 1,969 284 187 7 1,286 3,733 2027 1,969 284 187 7 1,336 3,783 2028 1,974 285 187 7 1,288 3,742 2029 1,969 284 187 7 1,286 3,733 2030 1,969 284 187 7 1,336 3,783 2031 1,969 284 187 7 1,286 3,733 2032 1,974 285 187 7 1,288 3,742 2033 1,969 284 187 7 1,336 3,783 2034 1,969 284 187 7 1,286 3,733 2035 1,969 284 187 7 1,286 3,733 2036 1,974 285 187 7 1,338 3,792 2037 1,969 284 187 7 1,286 3,733 2038 1,969 284 187 7 1,286 3,733 2039 1,969 284 187 7 1,336 3,783 2040 1,974 285 187 7 1,288 3,742 2041 1,969 284 187 7 1,286 3,733 2042 1,969 284 187 7 1,336 3,783 2043 1,969 284 187 7 1,286 3,733 2044 1,974 285 187 7 1,288 3,742 2045 1,969 284 187 7 1,336 3,783 2046 1,969 284 187 7 1,286 3,733 2047 1,969 284 187 7 1,286 3,733 2048 1,974 285 187 7 1,338 3,792 2049 1,969 284 187 7 1,286 3,733 2050 1,969 284 187 7 1,286 3,733 2051 1,969 284 187 7 1,336 3,783 2052 1,974 285 187 7 1,288 3,742

BVY 14-085 / Attachment 1 / Page 10 of 17 Table 4 - License Termination Expenditures (cont'd)

(thousands, 2014 dollars)

Equip. & Waste Year Labor Materials Energy Disposal Other Total 2053 1,969 278 187 6 1,142 3,583 2054 1,969 278 187 6 1,192 3,633 2055 1,969 278 187 6 1,142 3,583 2056 1,974 279 187 6 1,144 3,591 2057 1,969 278 187 6 1,192 3,633 2058 1,969 278 187 6 1,142 3,583 2059 1,969 278 187 6 1,142 3,583 2060 1,974 279 187 6 1,194 3,641 2061 1,969 278 187 6 1,142 3,583 2062 1,969 278 187 6 1,142 3,583 2063 1,969 278 187 6 1,192 3,633 2064 1,974 279 187 6 1,144 3,591 2065 1,969 278 187 6 1,142 3,583 2066 1,969 278 187 6 1,192 3,633 2067 1,969 278 187 6 1,142 3,583 2068 35,936 1,912 1,873 32 3,524 43,277 2069 53,909 14,320 1,821 12,174 9,806 92,030 2070 53,452 15,787 1,689 18,228 15,362 104,519 2071 46,489 8,170 1,401 10,716 17,749 84,524 2072 46,616 8,192 1,405 10,745 17,995 84,953 2073 38,409 3,090 599 2,488 5,554 50,139 2074 151 0 0 0 360 512 2075 71.35 0 0 0 224 295 Total 434,259 68,148 24,326 56,003 234,483 817,219

BVY 14-085 / Attachment 1 / Page 11 of 17 Table 5 - Spent Fuel Management Expenditures (thousands, 2014 dollars)

Equip. &

Year Labor Materials Energy Waste Disposal Other Total 2014 0 0 0 0 4,753 4,753 2015 0 0 0 0 14,319 14,319 2016 9,093 0 1,622 0 18,790 29,506 2017 13,547 0 2,195 0 33,307 49,049 2018 13,547 0 2,195 0 46,588 62,330 2019 13,547 0 2,195 0 43,942 59,684 2020 6,755 0 1,092 0 12,898 20,745 2021 3,238 338 79 0 341 3,996 2022 3,238 338 79 0 341 3,996 2023 3,238 338 79 0 341 3,996 2024 3,246 339 80 0 342 4,007 2025 3,238 338 79 0 341 3,996 2026 3,238 338 79 0 341 3,996 2027 3,238 338 79 0 341 3,996 2028 3,246 339 80 0 342 4,007 2029 3,238 338 79 0 341 3,996 2030 3,238 338 79 0 341 3,996 2031 3,238 338 79 0 341 3,996 2032 3,246 339 80 0 342 4,007 2033 3,238 338 79 0 341 3,996 2034 3,238 338 79 0 341 3,996 2035 3,238 338 79 0 341 3,996 2036 3,246 339 80 0 342 4,007 2037 3,238 338 79 0 341 3,996 2038 3,238 338 79 0 341 3,996 2039 3,238 338 79 0 341 3,996 2040 3,246 339 80 0 342 4,007 2041 3,238 338 79 0 341 3,996 2042 3,238 338 79 0 341 3,996 2043 3,238 338 79 0 341 3,996 2044 3,246 339 80 0 342 4,007 2045 3,238 338 79 0 341 3,996 2046 3,238 338 79 0 341 3,996 2047 3,238 338 79 0 341 3,996 2048 3,246 339 80 0 342 4,007 2049 3,238 338 79 0 341 3,996 2050 3,238 338 79 0 341 3,996 2051 3,238 338 79 0 341 3,996

BVY 14-085 / Attachment 1 / Page 12 of 17 Table 5 - Spent Fuel Management Expenditures (cont'd)

(thousands, 2014 dollars)

Equip. &

Year Labor Materials Energy Waste Disposal Other Total 2052 3,246 339 80 0 342 4,007 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 0 2056 0 0 0 0 0 0 2057 0 0 0 0 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 0 0 0 0 0 0 2068 0 0 0 0 0 0 2069 0 0 0 0 0 0 2070 0 0 0 0 0 0 2071 0 0 0 0 0 0 2072 0 0 0 0 0 0 2073 0 0 0 0 0 0 2074 0 0 0 0 0 0 2075 0 0 0 0 0 0 Total 160,164 10,816 11,843 0 185,524 368,347

BVY 14-085 / Attachment 1 / Page 13 of 17 Table 6 - Annual Cash Flow Analysis Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands, 2014 Dollars)

Date Amount Current Value of Qualified Trust Fund 10/31/2014 $ 654,925 Current Value of Non-Qualified Trust Fund 10/31/2014 $ 38 Total Trust Fund Balance as of 10/31/2014 $ 654,963 Start of Decommissioning 12/29/2014 Decommissioning Funds value at Calculation Date 10/31/2014 $ 654,963 Total Estimated Costs at Calculation Date 10/31/2014 $ 1,042,748 Start of Decom to end of Decom - Assumes 0.0% Decom cost escalation Cost Escalation Rate rate Start of Decom to end of Decom - Assumes 2.0%

Fund Earnings Rate Earnings Rate Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)

Column 4 License Column 1 Column 2 Column 3 Termination Cost plus Bogumng Clm Column 8 Column 9

____ ____ ot ls 8 Begin ning of Colum ou 7 Trs YerEdn 50.75 50.54 (bb) Exclude Spent Fuel Year mn 6 C Trust Year Ending Year License Spent Fuel Transfer to Management Fund Withdraw Contribute Fund Trust Fund Termination Management Dry Fuel Cost less Balance Earnings Balance Cost Cost Storage Cost Transfer to Dry Fuel Storage Cost 2014 15,165 4,753 4,753 15,165 654,963 15,165 0 2,183 641,981 2015 81,198 14,319 10,001 85,515 641,981 85,515 0 11,984 568,450 2016 36,126 29,506 7,613 58,018 568,450 58,018 0 10,789 521,221 2017 10,823 49,049 28,873 31,000 521,221 31,000 0 10,114 500,335 2018 9,548 62,330 41,644 30,235 500,335 30,235 0 9,704 479,805 2019 8,173 59,684 39,516 28,342 479,805 28,342 0 9,313 460,776 2020 17,763 20,745 10,420 28,088 460,776 28,088 0 8,935 441,622 2021 5,241 3,996 9,237 441,622 9,237 0 8,740 441,125 2022 5,191 3,996 9,187 441,125 9,187 0 8,731 440,669 2023 5,191 3,996 9,187 440,669 9,187 0 8,722 440,204 2024 3,650 4,007 7,657 440,204 7,657 0 8,728 441,274 2025 3,591 3,996 7,587 441,274 7,587 0 8,750 442,437 2026 3,733 3,996 7,729 442,437 7,729 0 8,771 443,480 2027 3,783 3,996 7,779 443,480 7,779 0 8,792 444,493 2028 3,742 4,007 7,749 444,493 7,749 0 8,812 445,557 2029 3,733 3,996 7,729 445,557 7,729 0 8,834 446,662 2030 3,783 3,996 7,779 446,662 7,779 0 8,855 447,738

BVY 14-085 / Attachment 1 / Page 14 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands in 2014 Dollars)

Column 4 License Termination Clm Column 1 Column 2 Column 3 Cost plus Beinn fColumn 8 Column 9 50.75 50.54 (bb) Exclude Spent Fuel Bearn~n ofus Coum Column 7 Trust Year Ending Year License Spent Fuel Transfer to Management Fund Withdraw Contribute Fund Trust Fund Termination Management Dry Fuel Cost less Balance Earnings Balance Cost Cost Storage Cost Transfer to Dry Fuel Storage Cost 2031 1 3,733 3,996 7,729 447,738 7,729 0 8,877 448,887 2032 3,742 4,007 7,749 448,887 7,749 0 8,900 450,039 2033 3,783 3,996 7,779 450,039 7,779 0 8,923 451,183 2034 3,733 3,996 7,729 451,183 7,729 0 8,946 452,400 2035 3,733 3,996 7,729 452,400 7,729 0 8,971 453,642 2036 3,792 4,007 7,799 453,642 7,799 0 8,995 454,839 2037 3,733 3,996 7,729 454,839 7,729 0 9,019 456,129 2038 3,733 3,996 7,729 456,129 7,729 0 9,045 457,446 2039 3,783 3,996 7,779 457,446 7,779 0 9,071 458,738 2040 3,742 4,007 7,749 458,738 7,749 0 9,097 460,087 2041 3,733 3,996 7,729 460,087 7,729 0 9,124 461,482 2042 3,783 3,996 7,779 461,482 7,779 0 9,152 462,855 2043 3,733 3,996 7,729 462,855 7,729 0 9,180 464,306 2044 3,742 4,007 7,749 464,306 7,749 0 9,209 465,767 2045 3,783 3,996 7,779 465,767 7,779 0 9,238 467,225 2046 3,733 3,996 7,729 467,225 7,729 0 9,267 468,764 2047 3,733 3,996 7,729 468,764 7,729 0 9,298 470,333 2048 3,792 4,007 7,799 470,333 7,799 0 9,329 471,863 2049 3,733 3,996 7,729 471,863 7,729 0 9,360 473,494 2050 3,733 3,996 7,729 473,494 7,729 0 9,393 475,158 2051 3,783 3,996 7,779 475,158 7,779 0 9,425 476,804 2052 3,742 4,007 7,749 476,804 7,749 0 9,459 478,514 2053 3,583 0 3,583 478,514 3,583 0 9,534 484,4866 2054 3,633 0 3,633 484,466 3,633 0 9,653 490,487 2055 3,583 0 3,583 490,487 3,583 0 9,774 496,678 2056 3,591 0 3,591 496,678 3,591 0 9,898 502,984 2057 3,633 0 3,633 502,984 3,633 0 10,023 509,375 2058 1 3,583 0 3,583 509,375 3,583 0 10,152 515,944 2059 3,583 0 3,583 515,944 3,583 0 10,283 522,644 2060 3,641 0 3,641 522,644 3,641 0 10,416 529,419 2061 3,583 0 3,583 529,419 3,583 0 10,553 536,389 2062 3,583 0 1 3,583 536,389 3,583 0 10,692 543,499 2063 3,633 0 3,633 543,499 3,633 1 0 110,834 550,700 2064 3,591 0 3,591 550,700 3,591 1 0 110,978 558,086

BVY 14-085 / Attachment 1 / Page 15 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)

Column 4 License Termination Column 1 Column 2 Column 3 Cost plus Bogumng Column 8 Column 9 50.75 50.54 (bb) Exclude Spent Fuel Year Trustof Beginning Coun6 C olm7 7 Column Trs Trust YerEdg Year Ending Year License Spent Fuel Transfer to Management Fund Withdraw Contribute Fund Trust Fund Termination Management Dry Fuel Cost less Balance Earnings Balance Cost Cost Storage Cost Transfer to Dry Fuel Storage Cost 2065 3,583 0 3,583 558,086 3,583 0 11,126 565,630 2066 3,633 0 3,633 565,630 3,633 0 11,276 573,273 2067 3,583 0 3,583 573,273 3,583 0 11,430 581,120 2068 43,277 0 43,277 581,120 43,277 0 11,190 549,033 2069 92,030 0 92,030 549,033 92,030 0 10,060 467,064 2070 104,519 0 104,519 467,064 104,519 0 8,296 370,841 2071 84,524 0 84,524 370,841 84,524 0 6,572 292,889 2072 84,953 0 84,953 292,889 84,953 0 5,008 212,944 2073 50,139 0 50,139 212,944 50,139 0 3,757 166,563 2074 512 0 512 166,563 512 0 3,326 169,377 2075 295 0 295 169,377 295 0 3,385 172,466 2076 0 0 0 172,466 0 0 3,449 175,915 817,219 368,347 142,819 1,042,748 1,042,748 0 563,701 Table 6 Definitions:

Column 1: 50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2014 dollars at a 0.0%

escalation rate Column 2: 50.54 (bb) Spent Fuel Management Cost Reflects the Total Annual Irradiated Fuel Management Plan cost in 2014 dollars at a 0.0% escalation rate Column 3: Exclude Transfer to Dry Fuel Storage Cost Reflects the Transfer to Dry Fuel Storage Cost included in Column 2 that is planned to be funded by external credit facilities, in 2014 dollars at a 0.0% escalation rate Column 4: License Termination Cost plus Spent Fuel Management Cost less Transfer to Dry Fuel Storage Cost Reflects the Total Annual License Termination Plan cost plus Total Spent Fuel Management Plan cost less Transfer to Dry Fuel Storage cost all in 2014 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

BVY 14-085 / Attachment 1 / Page 16 of 17 Column 5: Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2014 dollars at a 0.0% escalation rate and 2.0% Fund Earnings Column 6: Withdraw Reflects the annual expenditures from the Trust Fund in 2014 dollars at a 0.0%

escalation rate (equals Column 4)

Column 7: Contribute Reflects the annual contributions to the Trust Fund in 2014 dollars at a 0.0% escalation rate Column 8: Trust Fund Earnings Reflects earnings on funds remaining in the trust. A 2.0% earnings rate is used over a 0.0% cost escalation rate. The annual 2.0% earnings are calculated on the beginning balance less 50% of the projected annual expenditure for each year. (Column 5 - 50% of Column 6

2.0%)

Column 9: Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted for year end specified at a 0.0% escalation rate and 2.0% Fund Earnings in 2014 dollars. (Column 5 - Column 6 + Column 7 + Column 8)

V. Reaulatory Activities The Program assumes withdrawals from the VYNPS decommissioning trust fund for operational spent fuel management costs. ENO will make appropriate submittals to request an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A), which would permit the use of decommissioning trust funds for spent fuel management expenses. The availability of decommissioning funding sources will be periodically revisited to ensure that withdrawals from the fund do not inhibit the ability to complete license termination and spent fuel management activities.

In addition, in accordance with 10 CFR 50.82(a)(8)(vii), ENO will submit a report on the status of spent fuel management funding by March 31 of each year. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing spent fuel, the projected cost of managing spent fuel until it is transferred to DOE, and if the funds accumulated do not cover the projected cost, a plan to provide additional funding assurance using one of the methods allowed by NRC regulations.

BVY 14-085 / Attachment 1 / Page 17 of 17 VI. Summary The spent fuel management activities described in this updated Program must be performed in conjunction with license termination activities. The annual cash flow analysis demonstrates that the VYNPS decommissioning trust fund with projected earnings, together with an additional

$145 million in credit available for transfer to dry fuel storage activities, will be sufficient to cover the estimated license termination and spent fuel management costs.

VII. References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)," BVY 08-077, dated October 14, 2008 (ML082910294)

3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC NOs.

MD8035 and MD8051)," dated February 3, 2009 (ML083390193)

4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)

5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan -

RAI Response)," BVY 09-048, dated August 18, 2009 (ML092370298)

6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC NO. ME1 152)," dated October 8, 2009 (ML092740238)

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

8. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report," BVY 14-078, dated December 19, 2014

9. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Decommissioning Funding Status Report," BVY 14-082, dated December 19, 2014

BVY 14-085 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station List of Cancelled Regulatory Commitments

BVY 14-085 / Attachment 2 / Page 1 of 1 List of Cancelled Regulatory Commitments This table identifies actions discussed in this letter for which ENVY no longer commits to perform.

DATE OF ORIGINAL COMMITMENT COMMITMENT CHANGED DATE Provide additional funding of $127.017 million dollars to trust fund for Spent Fuel Management. December 31, 2026 This commitment is cancelled.

Source: Letter BVY 09-048, dated August 18, 2009 (ML092370298)