CNRO-2018-00012, Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

ML18088B369
Person / Time
Site:	Palisades, Indian Point, Pilgrim, Vermont Yankee, Big Rock Point
Issue date:	03/29/2018
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNRO-2018-00012
Download: ML18088B369 (33)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel: 601-368-5000 Mandy K. Halter Director, Nuclear Licensing CNRO-2018-00012 March 29, 2018 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Decommissioning Funding Status Report per 10 CFR §50.75(f)(1) and 10 CFR 50.82(a)(8)(v) -- Entergy Nuclear Operations, Inc.

Big Rock Point Nuclear Plant Docket No. 50-155 License No. DPR-6 Indian Point Nuclear Generating Stations 1, 2, & 3 Docket Nos. 50-3, 50-247, & 50-286 License Nos. DPR-5, DPR-26, & DPR-64 Palisades Nuclear Power Plant Docket No. 50-255 License No. DPR-20 Pilgrim Nuclear Power Station Docket 50-293 License No. DPR-35 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1.

NUREG-1307, Report on Waste Burial Charges, Revision 16, dated November 2016

2.

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

Dear Sir or Madam:

10 CFR 50.75(f)(1) requires each power reactor licensee to report to the NRC by March 31, 1999, and every two years thereafter with certain exceptions, on the status of its decommissioning funding for each reactor, or share of a reactor, that it owns. 10 CFR 50.82(a)(8)(v) requires licensees of shutdown sites to report to the NRC annually, by March 31, on the status of decommissioning financial assurance for those sites. On behalf of Entergy Nuclear Indian Point 2, LLC (Indian Point 1 & 2), Entergy Nuclear Indian Point 3, LLC, Entergy Nuclear Vermont Yankee, LLC, Entergy Nuclear Generation Company (Pilgrim Station), 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 through 13 for the licensed facilities addressed by this filing, were prepared in accordance with NUREG-1307 (Reference 1) and NRC Regulatory Issue Summary 2001-07 (Reference 2). Attachments 12 and 13 are updated 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)(v)

CNRO-2018-00012 / Page 2 of 4 site specific decommissioning cost estimates for Indian Point Unit 1 and Vermont Yankee, respectively. The Minimum Funding Assurance calculation worksheets, (not required for this filing) derived from LIC-205, Rev. 4, are provided in Attachment 14 for the convenience of the reviewer.

The estimated minimum decommissioning fund values were determined using the NRCs methodology in NUREG-1307, Rev 16 (Reference 1).

The trust fund amounts reported for each facility in the responses to item 3 represent the market value of decommissioning trust funds as of December 31, 2017 net of any material current income tax liability on realized gains, interest, dividends and other income of the trusts. The trusts for the following plants had estimated balances on their 2017 tax liabilities, not reflected in the trust fund balances, as follows (in thousands):

Indian Point 1

$ 2,406 Indian Point 2

$ 2,882 Indian Point 3

$ 0 Vermont Yankee $ 0 Pilgrim

$ 2,845 Palisades

$ 1,296 In accordance with guidance provided by the NRC Staff in April 2014 requests for additional information (Accession No. ML14120A273) that future 10 CFR 50.75(f) reports should clearly delineate estimated reactor and ISFSI decommissioning costs, the information in Attachments 1, 2, 3, 5, 7, 9, and 11 includes line item 2 identifying the ISFSI decommissioning obligation, escalated from the most recent 10 CFR 72.30 filing. This obligation is also accounted for in the Excess/Shortfall calculations for each plant in Attachment 14.

The aforementioned worksheets, using the December 31, 2017 trust fund balances and parent guarantee amounts, indicate that all of the plants covered by this submittal met or exceeded the NRCs funding requirements. Accordingly, the licensees conclude that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the plants covered by this submittal.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Philip Couture at 601-368-5102.

Sincerely, MKH/ljs/plc Attachments:

1.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Indian Point 1

2.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Indian Point 2

3.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Indian Point 3

4.

Entergy Nuclear Operations, Inc. Calculation of Minimum Amount - Indian Point

5.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Vermont Yankee

6.

Entergy Nuclear Operations, Inc. Calculation of Minimum Amount - Vermont Yankee

CNRO-2018-00012 / Page 3 of 4

7.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Pilgrim

8.

Entergy Nuclear Operations, Inc. Calculation of Minimum Amount - Pilgrim

9.

Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Palisades

10. Entergy Nuclear Operations, Inc. Calculation of Minimum Amount - Palisades

11. Entergy Nuclear Operations, Inc. Status of Decommissioning Funding - Big Rock Point

12. Entergy Nuclear Operations, Inc. IP1 DTF Balance Based on Decommissioning Funding Assurance Plan

13. Entergy Nuclear Operations, Inc. Vermont Yankee Annual Cash Flow Analysis

14. Entergy Nuclear Operations, Inc. Minimum Financial Assurance Calculation Worksheets cc: See next page

CNRO-2018-00012 / Page 4 of 4 cc: Mr. A. C. Bakken (ECH)

Mr. K. R. Jury (ECH)

Mr. B. E. Green (TMBR)

Mr. L. M. Coyle (ECH)

Mr. C. F. Arnone (PAL)

Mr. C. R. Costanzo (ECH)

Mr. L. J. Smith (ECH)

Mr. A. J. Vitale (IPEC)

Mr. C. R. Daniels (VTY)

Mr. B. Sullivan (PIL)

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, Palisades USNRC Project Manager, Pilgrim USNRC Project Manager, Vermont Yankee Ms. Margaret OBanion, Project Manager, NRC/NRR/DORL USNRC Resident Inspector, Indian Point 2 / 3 USNRC Resident Inspector, Palisades USNRC Resident Inspector, Pilgrim USNRC Resident Inspector, Vermont Yankee CNRO-2018-00012 (Page 1 of 2)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Indian Point Nuclear Generating Unit No. 1 10 CFR 50.75(f)(1)

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

2. ISFSI Obligation as of 12/31/17

$569.23 million [Note1]

$1.15 million [Note2]

3. Decommissioning Trust Fund Total as of 12/31/17

$ 493.1 million

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

8.

Any material changes to trust agreements None Note 1: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Attachment 12. (Calculation of the NRC Minimum Amount is provided in Attachment 4.)

Note 2: From 10 CFR 50.82(a)(8)(vii) filing for Indian Point 1 of March 2018 (Reference 1).

REFERENCE:

1.

Letter, Entergy Nuclear Operations, Inc. to USNRC, Status of Funding for Managing Irradiated Fuel For Year Ending December 31, 2017 - 10 CFR 50.82(a)(8)(vii), CNRO-2018-00014, dated March 2018 CNRO-2018-00012 (Page 2 of 2)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Indian Point Nuclear Generating Unit No. 1 10 CFR 50.82(a)(8)(v)

1. Cumulative decommissioning spending

$107.78 million [Note1]

2. 2017 decommissioning spending

$8.34 million [Note1]

3.

Fund Balance See above in 10 CFR 50.75 information

4.

No other financial assurance mechanism is being relied upon, but costs through 12/31/2017 have been funded by operations, and not the decommissioning fund.

5.

Estimated costs to complete from latest estimate

$569.23 million [Note2]

6.

Estimate is based on unrestricted release of the site per 10 CFR 20.1402

7.

Modifications to financial assurance since last report See above in 10 CFR 50.75 information

8.

Any material changes to trust agreements See above in 10 CFR 50.75 information Note 1: Entergy Nuclear Operations, Inc. (Entergy) does not possess records that would permit determination of charges to Indian Point 1 (IP1) prior to its acquisition in September 2001 by Entergy Nuclear Indian Point 2, LLC. The costs presented here represent those costs charged in 2017 and the total costs that have been assigned to IP1 since 2001. Entergy has not fully determined what portion of those costs would be considered decommissioning costs as that term is defined in 10 CFR 50.2.

Cumulative and 2017 decommissioning spending only consists of costs related to license termination.

Note 2: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Attachment 12 (Calculation of the NRC Minimum Amount is provided in Attachment 4). This estimate does not include 2017 spending because current costs are being paid out of operating funds.

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 2

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

$505.68 million [Note 1]

2. ISFSI Obligation as of 12/31/17

3. Decommissioning Trust Fund Total as of 12/31/17

$5.99 million [Note 2]

$624.39 million [Note 3]

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

8.

Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Attachment 4.

Note 2: From Entergys Status of Funding for Managing Irradiated Fuel For Year Ending December 31, 2017 - 10 CFR 50.82(a)(8)(vii). Total ISFSI obligation for Indian Point 1&2 is $7.13M with $5.99M attributable to Indian Point 2 and $1.15M attributable to Indian Point 1 (totals may not foot due to rounding).

Note 3: Includes provisional fund balance of $32.75 million.

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 3

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

$505.68 million [Note 1]

2. ISFSI Obligation as of 12/31/17

3. Decommissioning Trust Fund Total as of 12/31/17

$7.13 million [Note 2]

$798.17 million

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report Note 3

8.

Any material changes to trust agreements Note 3 Note 1: Calculation of the NRC Minimum Amount is provided in Attachment 4.

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2015 (Accession No. ML15351A524), escalated for inflation.

Note 3: While the method for financial assurance (prepaid decommissioning fund) did not change, the decommissioning trust fund has been transferred from New York Power Authority to the licensee. See Order Approving Transfer Of Control Of Master Decommissioning Trust For Indian Point Nuclear Generating Unit No. 3 and James A.

Fitzpatrick Nuclear Power Plant From the Power Authority Of The State Of New York To Entergy Nuclear Operations, Inc., dated January 27, 2017 (Accession No. ML16336A492), and application dated August 16, 2016 (Accession No. 16230A308).

The trust agreement amendments were provided in the August 16, 2016 application, hereby incorporated by reference, and were approved in the January 27, 2017 order.

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Indian Point For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Entergy Nuclear Indian Point 2, LLC: 100% ownership interest of Indian Point 1 & 2 Entergy Nuclear Indian Point 3, LLC: 100% ownership interest of Indian Point 3 Plant Location: Buchanan, New York Reactor Type: Pressurized Water Reactor (PWR)

Indian Point Unit 1 Power Level: <3,400 MWt (615 MWt)

Indian Point Unit 1 PWR Base Year 1986$: $85,560,000 Indian Point Unit 2 Power Level: <3,400 MWt (3,216 MWt)

Indian Point Unit 2 PWR Base Year 1986$: $103,300,800 Indian Point Unit 3 Power Level: <3,400 MWt (3,216 MWt)

Indian Point Unit 3 PWR Base Year 1986$: $103,300,800 Labor Region: North Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (North) 2.851 E=Energy (PWR) 2.292 B=Waste Burial-Vendor (PWR) 12.4713 PWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B)=

4.89520 1986 PWR Base Year $ Escalated:

Indian Point 1: $85,560,000

• Factor=

$418,833,686 Indian Point 2 & 3: $103,300,800

• Factor=

$505,678,528 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2017) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2017) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 16, Table 2.1 (2016)

CNRO-2018-00012 (Page 1 of 2)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Vermont Yankee For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Vermont Yankee Nuclear Power Station 10 CFR 50.75(f)(1)

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

$713.4 million [Note 1]

2. ISFSI Obligation as of 12/31/17

3. Decommissioning Trust Fund Total as of 12/31/17

$5.33 million [Note 2]

$581.54 million

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

8.

Any material changes to trust agreements None Note 1: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis provided in Attachment 13. (Calculation of the NRC Minimum Amount is provided in Attachment 6).

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2015 (Accession No. ML15351A524), escalated for inflation.

CNRO-2018-00012 (Page 2 of 2)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Vermont Yankee For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Vermont Yankee Nuclear Power Station 10 CFR 50.82(a)(8)(v)

1. Cumulative decommissioning spending through 12/31/2017

$ 142.72 million

[Note1]

2. 2017 decommissioning spending

$ 31.75 million [Note2]

3.

Fund Balance See above in 10 CFR 50.75 information

4.

No other financial assurance mechanism is being relied upon.

5.

Estimated costs to complete from latest estimate

$ 713.4 million

6.

Estimate is based on unrestricted release of the site per 10 CFR 20.1402

7.

Modifications to financial assurance since last report See above in 10 CFR 50.75 information

8.

Any material changes to trust agreements See above in 10 CFR 50.75 information Note 1: Some decommissioning costs have been paid by the parent company, and not refunded from the decommissioning trust.

Note 2: This estimate only includes 2017 decommissioning costs. 2014 through 2016 qualified costs are included in item 1 and have been reimbursed in 2017.

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Vermont Yankee For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Entergy Nuclear Vermont Yankee LLC.: 100% ownership interest Plant Location: Vernon, Vermont Reactor Type: Boiling Water Reactor (BWR)

Power Level: <3,400 MWt (1912 MWt)

BWR Base Year 1986$: $121,208,000 Labor Region: North Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (North) 2.851 E=Energy (BWR) 2.322 B=Waste Burial-Vendor (BWR) 13.1323 BWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B)=

5.04333 1986 BWR Base Year $ Escalated:

$121,208,000

• Factor=

$611,291,846 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2017) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2017) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 16, Table 2.1 (2016)

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Pilgrim For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Plant Name: Pilgrim Nuclear Power Station

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

2.

ISFSI Obligation as of 12/31/17

$616.56 million [Note 1]

$9.43 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/17

$1,070.74 million

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

8.

Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Attachment 8.

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2015 (Accession No. ML15351A524), escalated for inflation.

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Pilgrim For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Entergy Nuclear Generation Co.: 100% ownership interest Plant Location: Plymouth, Massachusetts Reactor Type: Boiling Water Reactor (BWR)

Power Level: <3,400 MWt (2028 MWt)

BWR Base Year 1986$: $122,252,000 Labor Region: North Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (North) 2.851 E=Energy (BWR) 2.322 B=Waste Burial-Vendor (BWR) 13.1323 BWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B)=

5.04333 1986 BWR Base Year $ Escalated:

$122,252,000

• Factor=

$616,557,082 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2017) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2017) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 16, Table 2.1 (2016)

CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Plant Name: Palisades Nuclear Plant

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2017$)

2.

ISFSI Obligation as of 12/31/17

$466.32 million [Note 1]

$8.05 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/17

$459.70 million

4.

A schedule of the annual amounts remaining to be collected None

5.

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

6.

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

None

7.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

8.

Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Attachment 10 Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2015 (Accession No. ML15351A524), escalated for inflation.

0 CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Palisades For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Entergy Nuclear Palisades LLC.: 100% ownership interest Plant Location: Covert, Michigan Reactor Type: Pressure Water Reactor (PWR)

Power Level: <3,400 MWt (2565 MWt)

PWR Base Year 1986$: $97,572,000 Labor Region: Midwest Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (Midwest) 2.671 E=Energy (PWR) 2.292 B=Waste Burial-Vendor (PWR) 12.4713 PWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B)=

4.77924 1986 PWR Base Year $ Escalated:

$97,572,000

• Factor=

$466,320,432 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000230i (4th Quarter 2017) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2017) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 16, Table 2.1 (2016) 1 CNRO-2018-00012 (Page 1 of 1)

Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Plant Name: Big Rock Point ISFSl

1.

Amount of decommissioning funds required from most recent estimate (2017$).

$2.56 million [Note 1]

2.

Decommissioning Funding Assurance Method.

Parent Guarantee ($5 million)

3.

A schedule of the annual amounts remaining to be collected None

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 Escalation rate: CPIU Rate of earnings: n/a

5.

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

None

6.

Modifications occurring to a licensee's current method of providing financial assurance since the last submitted report None

7.

Any material changes to trust agreements None Note 1: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2015 (Accession No. ML15351A524), escalated for inflation.

2 CNRO-2018-00012 (Page 1 of 4)

Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2017 - 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).

Pursuant to Regulatory Guide 1.159, Revision 2, adjustment to the site-specific cost estimates should be made at least once a year for the effects of inflation. Adjustment to site-specific cost estimates for the effects of technological and status changes should be made according to the amount of change experienced, as appropriate, but in no event, less than once every 5 years.

As such, ENIP2 has updated the aforementioned estimates consistent with the requirements of Regulatory Guide 1.159, Revision 2.

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 Rev. 2, 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.

The updated Indian Point 1 site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until 2073, at which time the plant will be decommissioned and the site released for alternative use without restriction. Table 12-1 below provides the annual license termination costs computed in the updated estimate. These costs to date have been funded by operations, and not by the decommissioning fund. 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).

2 CNRO-2018-00012 (Page 2 of 4)

Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Table 12-1 NRC License Termination Cost

($ millions) 2017 $ Unit 1 Radiological Ending DTF Balance 2018 0.997 511.153 2019 3.987 517.389 2020 3.998 523.739 2021 3.987 530.227 2022 3.987 536.845 2023 3.987 543.595 2024 3.998 550.469 2025 3.987 557.492 2026 3.987 564.655 2027 3.987 571.961 2028 3.998 579.403 2029 3.987 587.004 2030 3.987 594.757 2031 3.987 602.666 2032 3.998 610.721 2033 3.987 618.949 2034 3.987 627.341 2035 3.987 635.901 2036 3.998 644.621 2037 3.987 653.527 2038 3.987 662.611 2039 3.987 671.876 2040 3.998 681.316 2041 3.987 690.956 2042 3.987 700.788 2043 3.987 710.817 2044 3.998 721.035 2045 3.987 731.469 2046 3.987 742.112 2047 3.987 752.967 2048 3.998 764.029 2049 3.987 775.323 2050 3.987 786.842 2051 3.987 798.592 2052 3.998 810.567 2053 3.987 822.791 2054 3.987 835.260 2

CNRO-2018-00012 (Page 3 of 4)

Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Table 12-1 NRC License Termination Cost

($ millions) 2017 $ Unit 1 Radiological Ending DTF Balance 2055 3.987 847.978 2056 3.998 860.940 2057 3.987 874.172 2058 3.987 887.669 2059 3.987 901.436 2060 3.998 915.467 2061 3.987 929.789 2062 3.987 944.398 2063 3.987 959.299 2064 3.998 974.487 2065 29.204 964.773 2066 63.819 920.250 2067 106.283 832.372 2068 112.783 736.236 2069 16.291 734.670 2070 16.112 733.251 2071 16.112 731.803 2072 16.156 730.283 2073 7.946 736.943 Total 569.228 2

CNRO-2018-00012 (Page 4 of 4)

Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

As can be seen from the information provided in Table 12-1, the required funding for SAFSTOR decommissioning, $569.23 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $418.83 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, 2017 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $736.94 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.

3 CNRO-2018-00012 (Page 1 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Vermont Yankee Nuclear Power Station (Vermont Yankee) permanently ceased operations on December 29, 2014. The Vermont Yankee decommissioning trust fund balance is approximately $582 million as of December 31, 2017. Tables 3.4 and 3.5 of the site-specific decommissioning cost estimate (Reference 1, Enclosure) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. Subsequent to the filing of Reference 1, two significant schedule changes were submitted to reflect the accelerated completion of the dry fuel loading campaign (Reference 2) and preparations for dismantling and decontamination occurring in 2017-2018 vice 2068-2069 (Reference 3). A cash flow analysis utilizing this annual expenditure and significant schedule change information is included as Table 13-1.

The cash flow analysis demonstrates that the Vermont Yankee decommissioning trust fund is sufficiently funded for all license termination activities and certain spent fuel management activities (i.e., operational costs). As discussed in the Irradiated Fuel Management Program Update (Reference 4) costs related to spent fuel management operations (e.g., operations and maintenance costs for the spent fuel pool and Independent Spent Fuel Storage Installation, totaling approximately $161 million, Table 13-1 Column 2, minus Column 3 amounts funded by external credit facilities) will be funded from the decommissioning trust fund. This information also reflects the significant schedule change submitted for completion of the dry fuel storage campaign in 2018 (Reference 2). Entergy Nuclear Operations, Inc. obtained an exemption that allows the use of trust funds for spent fuel management activities (Reference 5).

The licensee 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." The licensee 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 Rev. 2, Section 1.1.1.) The licensee also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis. An updated decommissioning estimate was provided with the licensees Post Shutdown Decommissioning Activities Report on December 19, 2014 (Reference 1).

The updated Vermont Yankee site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until approximately 2075, at which time the plant will be decommissioned and the site released for alternative use without restriction. Table 13-1 below provides the annual license termination and spent fuel 3

CNRO-2018-00012 (Page 2 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1) management costs computed in the updated estimate. 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).

Thus, considering the fund balance of $582 million, as of December 31, 2017, and projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), the trust fund is expected to have an excess of $348.9 million after completion of license termination and the operational spent fuel management activities that will be funded by the trust fund.

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Post Shutdown Decommissioning Activities Report, BVY 14-078, dated December 19, 2014 (Accession No. ML14357A110).

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, Notification of Schedule Change for Dry Fuel Loading Campaign, BVY 17-013, dated April 12, 2017 (Accession No. ML17104A050).

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, Notification of Schedule Change for Preparations for Dismantling and Decontamination, BVY 17-028, dated August 28, 2017 (Accession No. ML17248A468).

4. Letter, Entergy Nuclear Operations, Inc. to USNRC, Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb), BVY 14-085, dated December 19, 2014 (Accession No. ML14358A251).

5. NRC Approval of Exemption Request for Spent Fuel Management, 80 Fed. Reg. 35992 (June 23, 2015).

3 CNRO-2018-00012 (Page 3 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2017 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

Column 4 License Termination Cost plus Spent Fuel Management Cost less Dry Fuel Cost

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2018 63,992 76,992 59,715 81,269 581,539 81,269 0

10,005 510,275 2019 5,560 4,232 9,791 510,275 9,791 0

10,010 510,493 2020 5,506 4,232 9,737 510,493 9,737 0

10,015 510,771 2021 5,506 4,232 9,737 510,771 9,737 0

10,021 511,054 2022 3,842 4,232 8,074 511,054 8,074 0

10,060 513,040 2023 3,842 4,232 8,074 513,040 8,074 0

10,099 515,066 2024 3,842 4,243 8,085 515,066 8,085 0

10,140 517,121 2025 3,779 4,232 8,010 517,121 8,010 0

10,182 519,293 2026 3,932 4,232 8,163 519,293 8,163 0

10,223 521,352 2027 3,986 4,232 8,217 521,352 8,217 0

10,263 523,397 2028 3,941 4,243 8,184 523,397 8,184 0

10,304 525,517 2029 3,932 4,232 8,163 525,517 8,163 0

10,347 527,701 2030 3,986 4,232 8,217 527,701 8,217 0

10,390 529,873 2031 3,932 4,232 8,163 529,873 8,163 0

10,434 532,144 2032 3,941 4,243 8,184 532,144 8,184 0

10,479 534,438 2033 3,986 4,232 8,217 534,438 8,217 0

10,524 536,745 2034 3,932 4,232 8,163 536,745 8,163 0

10,572 539,154 2035 3,932 4,232 8,163 539,154 8,163 0

10,620 541,610 2036 3,995 4,243 8,238 541,610 8,238 0

10,667 544,039 2037 3,932 4,232 8,163 544,039 8,163 0

10,718 546,593 2038 3,932 4,232 8,163 546,593 8,163 0

10,769 549,198 2039 3,986 4,232 8,217 549,198 8,217 0

10,820 551,800 2040 3,941 4,243 8,184 551,800 8,184 0

10,872 554,488 2041 3,932 4,232 8,163 554,488 8,163 0

10,926 557,251 2042 3,986 4,232 8,217 557,251 8,217 0

10,981 560,015 2043 3,932 4,232 8,163 560,015 8,163 0

11,037 562,888 2044 3,941 4,243 8,184 562,888 8,184 0

11,094 565,798 2045 3,986 4,232 8,217 565,798 8,217 0

11,152 568,732 3

CNRO-2018-00012 (Page 4 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2017 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

Column 4 License Termination Cost plus Spent Fuel Management Cost less Dry Fuel Cost

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2046 3,932 4,232 8,163 568,732 8,163 0

11,211 571,780 2047 3,932 4,232 8,163 571,780 8,163 0

11,272 574,889 2048 3,995 4,243 8,238 574,889 8,238 0

11,333 577,984 2049 3,932 4,232 8,163 577,984 8,163 0

11,396 581,216 2050 3,932 4,232 8,163 581,216 8,163 0

11,461 584,514 2051 3,986 4,232 8,217 584,514 8,217 0

11,526 587,823 2052 3,941 4,243 8,184 587,823 8,184 0

11,593 591,231 2053 3,770 0

3,770 591,231 3,770 0

11,749 599,210 2054 3,824 0

3,824 599,210 3,824 0

11,908 607,293 2055 3,770 0

3,770 607,293 3,770 0

12,070 615,593 2056 3,780 0

3,780 615,593 3,780 0

12,236 624,050 2057 3,824 0

3,824 624,050 3,824 0

12,405 632,630 2058 3,770 0

3,770 632,630 3,770 0

12,577 641,437 2059 3,770 0

3,770 641,437 3,770 0

12,753 650,420 2060 3,834 0

3,834 650,420 3,834 0

12,932 659,518 2061 3,770 0

3,770 659,518 3,770 0

13,115 668,863 2062 3,770 0

3,770 668,863 3,770 0

13,302 678,394 2063 3,824 0

3,824 678,394 3,824 0

13,491 688,061 2064 3,780 0

3,780 688,061 3,780 0

13,686 697,967 2065 3,770 0

3,770 697,967 3,770 0

13,884 708,081 2066 3,824 0

3,824 708,081 3,824 0

14,085 718,342 2067 3,770 0

3,770 718,342 3,770 0

14,291 728,863 2068 34,428 0

34,428 728,863 34,428 0

13,889 708,324 2069 76,618 0

76,618 708,324 76,618 0

12,634 644,340 2070 109,833 0

109,833 644,340 109,833 0

10,690 545,197 2071 89,271 0

89,271 545,197 89,271 0

9,119 465,045 2072 89,728 0

89,728 465,045 89,728 0

7,506 382,823 2073 53,202 0

53,202 382,823 53,202 0

6,592 336,213 3

CNRO-2018-00012 (Page 5 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2017 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

Column 4 License Termination Cost plus Spent Fuel Management Cost less Dry Fuel Cost

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2074 551 0

551 336,213 551 0

6,713 342,375 2075 318 0

318 342,375 318 0

6,841 348,898 713,385 220,956 59,715 874,625 581,539 874,625 0

641,985 348,898 As can be seen from the information provided in Table 13-1, the required funding for SAFSTOR decommissioning, $713.39 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $611.29 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The cash flows for the years 2018-2020 reflect completion of the transfer to dry fuel storage in 2018. The cash flows for the year 2018 reflects the preparations for dismantling and decontamination previously scheduled in 2068-2069. The foregoing SAFSTOR analysis shows that when the December 31, 2017 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $348.90 million surplus exists at the end of the decommissioning project. Accordingly, the licensee concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Vermont Yankee.

Table 15-1 Definitions:

Column 1:

50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2017 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 2017 dollars at a 0.0% escalation rate 3

CNRO-2018-00012 (Page 6 of 6)

Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2017 - 10 CFR 50.75(f)(1)

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 2017 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 2017 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

Column 5:

Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2017 dollars at a 0.0%

escalation rate and 2.0% Fund Earnings Column 6:

Withdraw Reflects the annual expenditures from the Trust Fund in 2017 dollars at a 0.0%

escalation rate (equals Column 4)

Column 7:

Contribute Reflects the annual contributions to the Trust Fund in 2017 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 100% of the projected annual expenditure for each year. (Column 5 - 100% 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 specified at a 0.0%

escalation rate and 2.0% Fund Earnings in 2017 dollars. (Column 5 - Column 6 +

Column 7 + Column 8) 4 CNRO-2018-00012 (Page 1 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 615

$85,560,000 132.0 2.16 0.65 2.85 2.076 2.596 0.13 2.29 0.22 12.471

$569,227,756

% Owned:

100.00%

Plant name:

Indian Point Energy Center, Unit 1 Month Day Year Year of Biennial:

12 31 2017 Termination of Operation:

9 28 2013 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$569,227,756

$493,103,037 NRC Minimum:

$418,833,686 Site Specific:

Note: See Attachment 12 for adequacy of the trust fund.

4 CNRO-2018-00012 (Page 2 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 132.0 2.16 0.65 2.85 2.076 2.596 0.13 2.29 0.22 12.471

% Owned:

100.00%

2%

0.00 1.00000 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance Plant name:

Indian Point Energy Center, Unit 2 Month Day Year Year of Biennial:

12 31 2017 Termination of Operation:

9 28 2013 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$505,678,528

$624,390,278 NRC Minimum:

$505,678,528 Site Specific:

$624,390,278

$624,390,278 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Trust Fund Balance:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$624,390,278

$46,418,943 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

$670,809,221 Total = Total Earnings + Total Earnings for Decom 157,996,536 165,130,692 (7,134,157) 4 CNRO-2018-00012 (Page 3 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 132.0 2.16 0.65 2.85 2.076 2.596 0.13 2.29 0.22 12.471

% Owned:

100.00%

2%

0.00 1.00000 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance Plant name:

Indian Point Energy Center, Unit 3 Month Day Year Year of Biennial:

12 31 2017 Termination of Operation:

12 12 2015 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$505,678,528

$798,169,140 NRC Minimum:

$505,678,528 Site Specific:

$798,169,140

$798,169,140 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Trust Fund Balance:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$857,507,296 Total = Total Earnings + Total Earnings for Decom

$798,169,140

$59,338,156 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

344,694,611 351,828,767 (7,134,157) 4 CNRO-2018-00012 (Page 4 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets BWR 1912

$121,208,000 132.0 2.16 0.65 2.85 2.076 2.596 0.13 2.32 0.22 13.132

% Owned:

100.00%

Entergy

$713,384,534

$581,538,826 NRC Minimum:

$611,291,846 Site Specific:

$713,384,534 Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 29 2014 MWth 1986$

ECI Base Lx Plant name:

Vermont Yankee Power Station Month Day Year Year of Biennial:

12 31 2017 Note: See Attachment 13 for adequacy of the trust fund.

4 CNRO-2018-00012 (Page 5 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets BWR 2028

$122,252,000 132.0 2.16 0.65 2.85 2.076 2.596 0.13 2.32 0.22 13.132

% Owned:

100.00%

2%

1.42 1.02845 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance Plant name:

Pilgrim Nuclear Generating Station Month Day Year Year of Biennial:

12 31 2017 Termination of Operation:

5 31 2019 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$616,557,082

$1,070,744,356 NRC Minimum:

$616,557,082 Site Specific:

$1,070,744,356

$1,101,208,032 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Trust Fund Balance:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$1,183,074,958 Total = Total Earnings + Total Earnings for Decom

$1,101,208,032

$81,866,926 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

557,086,929 566,517,876 (9,430,947) 4 CNRO-2018-00012 (Page 6 of 6)

Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets Plant name:

Palisades Nuclear Plant PWR 2565

$97,572,000 128.5 2.08 0.65 2.67 2.076 2.596 0.13 2.29 0.22 12.471

% Owned:

100.00%

2%

4.42 1.09140 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance Month Day Year Year of Biennial:

12 31 2017 Termination of Operation:

5 31 2022 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$466,320,432

$459,695,131 NRC Minimum:

$466,320,432 Site Specific:

$459,695,131

$501,711,431 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Trust Fund Balance:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$501,711,431

$37,298,650 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

$539,010,080 Total = Total Earnings + Total Earnings for Decom 64,634,738 72,689,648 (8,054,909)

$