ML18101A902

Unit 3 - Response to Request for Additional Information Regarding ISFSI Decommissioning Funding Plans (10 CFR 72.30)

ML18101A902
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	04/10/2018
From:	Ford B Entergy Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CAC 001028, CNRO-2018-0010, EPID L-2017-FRP-0005, EPID L-2017-FRP-0029, EPID L-2017-FRP-0060, EPID L-2017-FRP-0073
Download: ML18101A902 (54)

Text

Entergy Operations, Inc 1340 Echelon Parkway Jackson, MS 39213 Bryan S. Ford Senior Manager, Fleet Regulator Assurance Tel: (601) 368-5516 bford@entergy.com CNRO-2018-0010 April 10, 2018 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

Response to Request for Additional Information Regarding ISFSI Decommissioning Funding Plans (10 CFR 72.30)

Arkansas Nuclear One, Units 1 & 2 River Bend Station Docket No.72-013 Docket No.72-049 EPID: L-2017-FRP-0005 EPID: L-2017-FRP-0060 Grand Gulf Nuclear Station Waterford 3 Steam Electric Station Docket No.72-050 Docket No.72-075 EPID: L-2017-FRP-0029 EPID: L-2017-FRP-0073

REFERENCES:

1. Entergy letter CNRO-2015-00027; ISFSI Decommissioning Funding Plans (10 CFR 72.30), dated December 17, 2015 (ML15351A523).

2. NRC letter dated February 23, 2018, Request for Additional Information Regarding Entergy Operations, Inc.s Decommissioning Funding Plan Update for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station Independent Spent Fuel Storage Installations, Docket Nos. 72-13, 72-49, 72-50, 72-75 (CAC No. 001028, ML18058A057 and ML18058A056).

Dear Sir or Madam:

By letter dated December 17, 2015 (Reference 1), Entergy Operations, Inc. (EOI), acting as agent for the owner licensees, submitted Independent Spent Fuel Storage Installation (ISFSI) decommissioning funding plans pursuant to 10 CFR 72.30. By letter dated February 23, 2018 (Reference 2), the NRC issued a Request for Additional Information (RAI) related to the Reference 1 report for Arkansas Nuclear One Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station. The attachment to this letter provides EOIs responses on behalf of the subject licensees to the RAI.

This submittal contains no new commitments.

CN RO-2018-001 0 Page 2 of 2 If you have any questions, please contact Mr. Bryan Ford, Senior Manager, Fleet Regulatory Assurance, at 601-368-5516.

Sincerely, BSF / ljs/chm Attachments:

1. Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Arkansas Nuclear One

2. Revised 1 O CFR 72.30 ISFSI Decommissioning Funding Plan - Grand Gulf Nuclear Station

3. Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - River Bend Station

4. Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Waterford 3 Steam Electric Station

CNRO-2018-0010 Page 3 of 3 cc:

Mr. L. Jager Smith (ECH)

Mr. W. A. Cloutier (TLG)

Mr. R. L. Anderson (ANO)

Mr. E. A. Larson (GGN)

Mr. W. F. Maguire (RBS)

Mr. J. Dinelli (WF3)

USNRC Regional Administrator, Region IV USNRC Project Manager, ANO USNRC Project Manager, GGN USNRC Project Manager, RBS USNRC Project Manager, WF3 USNRC Resident Inspector, ANO USNRC Resident Inspector, GGN USNRC Resident Inspector, RBS USNRC Resident Inspector, WF3 Arkansas Department of Health Mississippi Department of Health Louisiana Department of Environmental Quality

ATTACHMENT 1 CNRO-2018-0010 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One ISFSI Docket 72-013 to CNRO-2018-0010 Page 1 of 12 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One Docket No.72-013

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations in December 2012.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

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

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2012-00011, dated December 17, 2012 (NRC Accession No. ML12354A131) to CNRO-2018-0010 Page 2 of 12

2.

Spent Fuel Management Strategy The operating licenses are currently set to expire on May 20, 2034 and July 17, 2038 for Units 1 and 2, respectively. Approximately 5,669 spent fuel assemblies are currently projected to be generated over the life of the two units. Primarily because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, a second set of pads to support decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pools will contain a significant number of spent fuel assemblies at the time of expiration of the current operating licenses in 2034 for Unit 1 and 2038 for Unit 2, assuming the units operate to those dates, and including assemblies off-loaded from the reactor vessels. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pools is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Once the spent fuel pools are emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Arkansas, Inc.s (Entergy) current spent fuel management plan for the ANO spent fuel is based in general upon: 1) a 2025 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the ANO fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority.

Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the ANO site in 2072.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the current administrations Blue Ribbon 3

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

4 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 to CNRO-2018-0010 Page 3 of 12 Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[5]

The report stated that [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

[A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

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

3.

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

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

4.

ISFSI Description The ISFSI at ANO comprises three independent but adjoining pads. The original pad is used to store 24 Sierra Nuclear VSC-24 Ventilated Storage Casks (VSCs). Entergy transferred 576 assemblies into the VSCs between 1996 and 2003. It is possible that the spent fuel in these casks will have to be repackaged before it can be shipped off-site.

Repackaging is currently assumed to occur immediately after the cessation of plant 5

Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S.

DOE, January 11, 2013 to CNRO-2018-0010 Page 4 of 12 operations, while the spent fuel pools are still available and the associate fuel handling systems are operable. As such, the VSCs are not expected to be on the ISFSI pad when it is decommissioned (and are not considered in this funding plan).

The design and capacity of the dry storage modules on the other (and future) pads is based upon the Holtec HI-STORM 100 dry cask storage system (Version C). The system consists of a multi-purpose canister, with a nominal capacity of 24 or 32 fuel assemblies, and a steel-lined concrete storage overpack.

Entergys current spent fuel management plan for the ANO spent fuel would result in 130 spent fuel storage casks (which includes the repackaged fuel from the VSCs) being placed on five storage pads at the site (including two future pads). This projected configuration is based upon the 2025 DOE spent fuel program start with a 2028 DOE start date for ANO spent fuel, a 3,000 MTU / year pickup rate, and the current cask capacity (including expansion capability) for the ISFSI pads built to support plant operations. This scenario would allow the spent fuel storage pools to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 130 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current licenses (2034 and 2038) and the DOEs spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 14 of the 130 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 177 offloaded 6

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) to CNRO-2018-0010 Page 5 of 12 assemblies per reactor, 24 assemblies per cask for Unit 1 and 32 assemblies per cask for Unit 2) which results in 14 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads.[7] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pads in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

The latest decommissioning cost study for ANO (prepared in 2014) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license. As such, there is no allowance for soil remediation in this estimate.

Low-level radioactive waste disposal costs are based on Entergys negotiated rates with EnergySolutions.

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

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[8]

Costs are reported in 2015 dollars and based upon an internal decommissioning analysis prepared for ANO in 2014. Activity costs with the exception of those associated with low-level radioactive waste disposal, have been escalated to 2015 dollars using the 7

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) 8 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.

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

to CNRO-2018-0010 Page 6 of 12 Consumer Price Index, Services.[9] Low-level radioactive waste disposal costs have been escalated to 2015 dollars using the Consumer Price Index, All Items.[10]

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate. However, for purposes of bounding the decommissioning cost estimate, 1) future expansion of the ISFSI is assumed in the current estimate based upon continuing delays by the DOE in removing the spent fuel from the site, and 2) the potential volume of low-level radioactive waste volume generated from storage cask overpack disposition is also increased.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

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

During this phase the empty overpacks, ISFSI pad(s), and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (overpack disposition) developed.

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

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

9 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS 10 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, All Items, Series ID:

CUUR0000AA0 to CNRO-2018-0010 Page 7 of 12 The estimate also contains costs for the NRC (and NRC contractor), Entergys oversight staff, site security (industrial), and other site operating costs.

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2073, the year following all spent fuel removal.

7.

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

It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would primarily be a DOE-reimbursable expense.

Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

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

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

The projected amount necessary for decommissioning ANO is $479.918 million and

$499.736 million for Units 1 and 2, respectively, based upon the NRCs latest financial assurance funding determination.[11]

Based upon ANOs decommissioning trust fund balances as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of ANO station decommissioning, the trust funds will contain surpluses of $212.459 million and $276.401 million for Units 1 and 2, respectively (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2). For purposes of this submittal, it is assumed that each ANO trust fund will bear half of the ISFSI decommissioning cost.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

11 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 to CNRO-2018-0010 Page 8 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pads (existing) 421 (3 pads) 41 to 55 No ISFSI Storage Overpack (Holtec HI-STORM 100-229)

Item Value Notes Overall Height (inches) 229 Dimensions are nominal Outside Diameter (inches) 132.5 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 140 130 spent fuel + 10 GTCC Quantity (with residual radioactivity) 14 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,669,921 Concrete and steel Low-Level Radioactive Waste from Transfer Cask (pounds) 202,400 Other Low-Level Radioactive Waste (pounds) 1,770 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 21,177 Cubic feet Low-Level Radioactive Waste (packaged density) 88 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Potentially contaminated Number of Overpacks used for GTCC storage 10 No residual radioactivity to CNRO-2018-0010 Page 9 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2015 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (cubic feet)

Craft Oversight and Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 403 403 1,240 Decontamination/Demolition (activated cask disposition) 809 409 450 2,246 3,915 21,177 2,039 License Termination (radiological surveys) 1,815 1,815 Subtotal 809 409 450 2,246 2,218 6,133 21,177 2,039 1,240 Supporting Costs NRC and NRC Contractor Fees and Costs 429 429 776 Insurance 126 126 Property Taxes 0

0 Plant Energy Budget 49 49 Non-Labor Overhead 10 10 Corporate A&G 102 102 Security (industrial) 142 142 5,103 Entergy Oversight Staff 288 288 3,866 Subtotal 1,148 1,148 9,744 Total (w/o contingency) 809 409 450 2,246 3,366 7,281 21,177 2,039 10,984 Total (w/25% contingency) 1,012 512 563 2,807 4,208 9,102 to CNRO-2018-0010 Page 10 of 12 PWR 2568

$97,598,400 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2.35%

18.64 1.54181 2.35%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 207,908,002 212,458,872 (4,550,869)

$692,376,662 Total = Total Earnings + Total Earnings for Decom

$644,465,286

$47,911,376 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$644,465,286 Step 3:

Decom Period:

Total Step 2

$0 Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$417,993,406

$644,465,286 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 Return:

Trust Fund Balance:

Entergy

$479,917,790

$417,993,406 NRC Minimum:

$479,917,790 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

5 20 2034 MWth 1986$

ECI Base Lx Plant name:

Arkansas Nuclear One, Unit 1 Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance to CNRO-2018-0010 Page 11 of 12 PWR 3026

$101,628,800 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2.70%

22.80 1.83561 2.70%

$119,373,325 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 271,849,901 276,400,770 (4,550,869)

$776,137,129 Total = Total Earnings + Total Earnings for Decom

$722,429,661

$53,707,468 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

$119,373,325 Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$722,429,661 Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

See Annuity Sheet 23 Total Earnings:

Total Step 2

$328,532,386

$603,056,336 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 Return:

Trust Fund Balance:

Entergy

$499,736,359

$328,532,386 NRC Minimum:

$499,736,359 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

7 17 2038 MWth 1986$

ECI Base Lx Plant name:

Arkansas Nuclear One, Unit 2 Month Day Year Year of Biennial:

9 30 2015 Table 4 Financial Assurance to CNRO-2018-0010 Page 12 of 12 Year Annuity:

2015

$0 2.70%

$0 2016

$2,870,032 2.70%

$5,157,467 2017

$2,941,782 2.70%

$5,147,423 2018

$3,016,403 2.70%

$5,139,233 2019

$3,093,894 2.70%

$5,132,676 2020

$3,177,125 2.70%

$5,132,185 2021

$3,263,226 2.70%

$5,132,686 2022

$3,355,067 2.70%

$5,138,405 2023

$3,449,778 2.70%

$5,144,555 2024

$3,550,229 2.70%

$5,155,165 2025

$3,656,420 2.70%

$5,169,778 2026

$3,768,352 2.70%

$5,187,961 2027

$3,886,023 2.70%

$5,209,310 2028

$4,009,434 2.70%

$5,233,443 2029

$4,141,456 2.70%

$5,263,650 2030

$4,279,217 2.70%

$5,295,755 2031

$4,425,589 2.70%

$5,332,909 2032

$4,580,570 2.70%

$5,374,552 2033

$4,744,162 2.70%

$5,420,156 2034

$4,919,234 2.70%

$5,472,418 2035

$5,105,786 2.70%

$5,530,622 2036

$5,303,818 2.70%

$5,594,091 2037

$5,513,331 2.70%

$5,662,191 2038

$3,346,696 2.70%

$3,346,696 Total:

$119,373,325 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Real Rate of Total Accumulation Table 4 (continued)

Financial Assurance - Annuity Arkansas Nuclear One, Unit 2

ATTACHMENT 2 CNRO-2018-0010 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station ISFSI Docket 72-050 to CNRO-2018-0010 Page 1 of 12 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station ISFSI Docket 72-050

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations in December 2012.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

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

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2012-00011, dated December 17, 2012 (NRC Accession No. ML12354A131) to CNRO-2018-0010 Page 2 of 12

2.

Spent Fuel Management Strategy The operating license for Grand Gulf is currently set to expire on November 1, 2024.

Approximately 7,380 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will be expanded or a second pad constructed after shutdown to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2024, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the Grand Gulf spent fuel is based in general upon: 1) a 2025 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the Grand Gulf fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the Grand Gulf site in 2063.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the current administrations Blue Ribbon 3

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

4 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 to CNRO-2018-0010 Page 3 of 12 Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[5]

The report stated that [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

[A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

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

3.

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

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

4.

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

Some of the overpacks are assumed to have residual radioactivity due to some minor 5

Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S.

DOE, January 11, 2013 to CNRO-2018-0010 Page 4 of 12 level of neutron-induced activation as a result of the long-term storage of the fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRCs radiological limits established for unrestricted use, forms the basis of the ISFSI decommissioning estimate.

Entergys current spent fuel management plan for the Grand Gulf spent fuel would result in 109 spent fuel storage casks being placed on the storage pads at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2028 DOE start date for Grand Gulf spent fuel, a 3,000 MTU / year pickup rate, and a 48 cask capacity for the ISFSI pad built to support plant operations (a second pad of comparable size would be needed to support decommissioning). This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 109 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 5) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2024) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, two pads, each approximately 61 feet by 196 feet (size of the current pad),

will be required to accommodate the number of casks anticipated.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 12 of the 109 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 800 offloaded assemblies, 68 assemblies per cask) which results in 12 overpacks. It is assumed that 6

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) to CNRO-2018-0010 Page 5 of 12 these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[7] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

A survey conducted by the licensee in July 2012 found no detectible contamination on the ISFSI pad or cask surfaces.[8] Therefore, contamination is not expected within the current ISFSI footprint and there is no allowance for soil remediation included within the current ISFSI decommissioning estimate.

The latest decommissioning cost study for Grand Gulf (prepared in 2015) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license.

Low-level radioactive waste disposal costs are based on Entergys negotiated rates with EnergySolutions.

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

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[9]

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) 8 Enclosure to the NRC Inspection Report 05000416/2012009 and 072000050/2012001, dated October 26, 2012,

p. 7 (Accession Number ML12303A002) 9 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.

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

to CNRO-2018-0010 Page 6 of 12 Costs are reported in 2015 dollars and based upon an internal decommissioning analysis prepared for Grand Gulf in 2015.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate. However, for purposes of bounding the decommissioning cost estimate, 1) future expansion of the ISFSI is assumed in the current estimate based upon continuing delays by the DOE in removing the spent fuel from the site, and 2) the potential volume of low-level radioactive waste volume generated from storage cask overpack disposition is also increased.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

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

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

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

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

to CNRO-2018-0010 Page 7 of 12 For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2064, the year following all spent fuel removal.

7.

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

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

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

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

The projected amount necessary for decommissioning Grand Gulf is $671.949 million, based upon the NRCs latest financial assurance funding determination.[10]

Based upon Grand Gulfs decommissioning trust fund balances as of September 30, 2015 (and considering the schedule of remaining principal payments into the decommissioning fund,[11] and the allowed real rate of return on the fund between October 1, 2015 and the start of Grand Gulf station decommissioning), the trust funds will contain a $485.215 million surplus (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to fund the cost to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

10 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 11 Collection details provided in Entergy letter CNRO-2015-00011, "Decommissioning Funding Status Report -

Entergy Operations, Inc," dated March 27, 2015 (ML15092A183) to CNRO-2018-0010 Page 8 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Current ISFSI Pad 392 61 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.5 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 114 109 spent fuel + 5 GTCC Quantity (with residual radioactivity) 12 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,984,830 Concrete and steel Other Low-Level Radioactive Waste (pounds) 2,488 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 27,033 Cubic feet Low-Level Radioactive Waste (packaged density) 74 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 5

No residual radioactivity to CNRO-2018-0010 Page 9 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes (100%, not adjusted for ownership share)

Costs (thousands, 2015 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (cubic feet)

Craft Oversight and Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 361 361 1,192 Decontamination/Demolition (activated cask disposition) 279 110 598 4,164 5,151 27,033 4,606 License Termination (radiological surveys) 1,367 1,367 11,293 Subtotal 279 110 598 4,164 1,729 6,880 27,033 15,899 1,192 Supporting Costs NRC and NRC Contractor Fees and Costs 420 420 776 Insurance 67 67 Property Taxes Plant Energy Budget 73 73 Non-Labor Overhead 10 10 Corporate A&G 84 84 Security (industrial) 111 111 3,457 Entergy Oversight Staff 298 298 3,803 Subtotal 1,062 1,062 8,036 Total (w/o contingency) 279 110 598 4,164 2,791 7,942 27,033 15,899 9,228 Total (w/25% contingency) 349 137 748 5,205 3,489 9,927 to CNRO-2018-0010 Page 10 of 12 BWR 4408

$135,000,000 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

90.00%

2.0%

9.09 1.19716 2.0%

$198,684,490 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 466,908,658 475,843,306 (8,934,648)

$1,080,597,523 Total = Total Earnings + Total Earnings for Decom

$1,005,821,874

$74,775,648 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$1,005,821,874 Step 3:

Decom Period:

Total Step 2

$198,684,490 Accumulation:

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

Total Annuity:

See Annuity Sheet 8

Total Earnings:

$674,211,036

$807,137,385 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 Return:

Trust Fund Balance:

Entergy

$604,754,217

$674,211,036 NRC Minimum:

$671,949,130 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

11 1

2024 MWth 1986$

ECI Base Lx Plant name:

Grand Gulf Nuclear Station (SERI 90%)

Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance System Energy Resources, Inc.

to CNRO-2018-0010 Page 11 of 12 Year Annuity:

2015

$5,571,250 2.00%

$6,791,323 2016

$24,550,000 2.00%

$29,339,523 2017

$24,550,000 2.00%

$28,764,238 2018

$24,550,000 2.00%

$28,200,233 2019

$24,550,000 2.00%

$27,647,287 2020

$24,550,000 2.00%

$27,105,184 2021

$29,878,000 2.00%

$32,340,908 2022

$17,429,000 2.00%

$18,495,794 2023

$0 2.00%

$0 2024

$0 2.00%

$0 2025

$0 2.00%

$0 Total:

$198,684,490 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Real Rate of Total Accumulation Table 3 (continued)

Financial Assurance - Annuity System Energy Resources, Inc.

Grand Gulf Nuclear Station (SERI 90%)

to CNRO-2018-0010 Page 12 of 12 BWR 4408

$135,000,000 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

10.00%

2.91%

9.09 1.29779 2.91%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 8,378,979 9,371,718 (992,739)

$76,566,631 Total = Total Earnings + Total Earnings for Decom

$71,268,340

$5,298,290 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1 Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$71,268,340 Step 3:

Decom Period:

Total Step 2

$0 Accumulation:

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

Total Annuity:

See Annuity Sheet 8

$0 Total Earnings:

$54,915,123

$71,268,340 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 Return:

Trust Fund Balance:

Entergy

$67,194,913

$54,915,123 NRC Minimum:

$671,949,130 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

11 1

2024 MWth 1986$

ECI Base Lx Plant name:

Grand Gulf Nuclear Station (SMEPA 10%)

Month Day Year Year of Biennial:

9 30 2015 Table 4 Financial Assurance South Mississippi Electric Power Association

ATTACHMENT 3 CNRO-2018-0010 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan River Bend Station ISFSI Docket 72-049 to CNRO-2018-0010 Page 1 of 12 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan River Bend Station ISFSI Docket 72-049

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations in December 2012.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

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

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2012-00011, dated December 17, 2012 (NRC Accession No. ML12354A131) to CNRO-2018-0010 Page 2 of 12

2.

Spent Fuel Management Strategy The operating license for River Bend is currently set to expire on August 29, 2025.

Approximately 5,738 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will be expanded after shutdown to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2025, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the River Bend spent fuel is based in general upon: 1) a 2025 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the River Bend fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the River Bend site in 2062.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the current administrations Blue Ribbon 3

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

4 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 to CNRO-2018-0010 Page 3 of 12 Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[5]

The report stated that [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

[A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

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

3.

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

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

4.

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

5 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S.

DOE, January 11, 2013 to CNRO-2018-0010 Page 4 of 12 Entergys current spent fuel management plan for the River Bend spent fuel would result in 85 spent fuel storage casks being placed on the storage pad at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2032 DOE start date for River Bend spent fuel, a 3,000 MTU / year pickup rate, and a 44 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 85 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2025) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis the expanded ISFSI pad is expected to be approximately 122 feet by 210 feet (double the size of the current pad), and have a maximum capacity of 88 casks.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 10 of the 85 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 624 offloaded assemblies, 68 assemblies per cask) which results in 10 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[7] It would be expected that this assumption would 6

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) 7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) to CNRO-2018-0010 Page 5 of 12 be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

The current ISFSI area was not part of the original plant Protected Area (the Protected Area was expanded to include the ISFSI area). The ISFSI was built by bringing in clean fill to raise the area to the same grade elevation as the original plant Protected Area. The fill would not have been subject to radioactive contamination; therefore, there is no allowance for soil remediation included within the current ISFSI decommissioning estimate.

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

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

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[8]

Costs are reported in 2015 dollars and based upon an internal decommissioning analysis prepared for River Bend in 2014. Activity costs with the exception of those associated with low-level radioactive waste disposal, have been escalated to 2015 dollars using the Consumer Price Index, Services.[9] Low-level radioactive waste disposal costs have been escalated to 2015 dollars using the Consumer Price Index, All Items.[10]

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

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

9 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS 10 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, All Items, Series ID:

CUUR0000AA0 to CNRO-2018-0010 Page 6 of 12 The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate. However, for purposes of bounding the decommissioning cost estimate, 1) future expansion of the ISFSI is assumed in the current estimate based upon continuing delays by the DOE in removing the spent fuel from the site, and 2) the potential volume of low-level radioactive waste volume generated from storage cask overpack disposition is also increased.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

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

The next phase includes the cost for craft labor to demolish the activated overpacks, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies. The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

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

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2063, the year following all spent fuel removal.

to CNRO-2018-0010 Page 7 of 12

7.

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

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

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

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

The projected amount necessary for decommissioning River Bend is $656.116 million, based upon the NRCs latest financial assurance funding determination.[11]

Based upon Entergys decommissioning trust fund balances for River Bend as of September 30, 2015 (and considering the schedule of remaining principal payments into the decommissioning fund,[12] and the allowed real rate of return on the fund between October 1, 2015 and the start of River Bend station decommissioning), the trust funds will contain a $359.910 million surplus (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10 CFR 50.75(e). This surplus is more than sufficient to fund the cost to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

11 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 12 Collection details provided in Entergy letter CNRO-2015-00011, "Decommissioning Funding Status Report -

Entergy Operations, Inc," dated March 27, 2015 (ML15092A183) to CNRO-2018-0010 Page 8 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Current ISFSI Pad 210 61 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.5 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 89 85 spent fuel + 4 GTCC Quantity (with residual radioactivity) 10 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,461,035 Concrete and steel Low-Level Radioactive Waste from Transfer Cask (pounds) 202,400 Other Low-Level Radioactive Waste (pounds) 1,452 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 20,058 Cubic feet Low-Level Radioactive Waste (packaged density) 83 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Potentially contaminated Number of Overpacks used for GTCC storage 4

No residual radioactivity to CNRO-2018-0010 Page 9 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2015 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (cubic feet)

Craft Oversight and Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 309 309 1,120 Decontamination/Demolition (activated cask disposition) 228 257 485 1,955 2,925 20,058 2,565 License Termination (radiological surveys) 1,312 1,312 10,767 Subtotal 228 257 485 1,955 1,621 4,546 20,058 13,332 1,120 Supporting Costs NRC and NRC Contractor Fees and Costs 400 400 776 Insurance 69 69 Property Taxes 16 16 Plant Energy Budget 48 48 Non-Labor Overhead 15 15 Corporate A&G 140 140 Security (industrial) 126 126 3,457 Entergy Oversight Staff 277 277 3,803 Subtotal 1,090 1,090 8,036 Total (w/o contingency) 228 257 485 1,955 2,711 5,636 20,058 13,332 9,156 Total (w/25% contingency) 285 321 607 2,444 3,388 7,045 to CNRO-2018-0010 Page 10 of 12 BWR 3091

$131,819,000 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

70.00%

2.00%

9.91 1.21692 2.00%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 132,189,696 137,121,227 (4,931,531)

$66,479,570

$596,402,440 Total = Total Earnings + Total Earnings for Decom

$493,253,041

$36,669,829 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$493,253,041 Step 3:

Decom Period:

Total Step 2

$124,341,390 Accumulation:

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

Total Annuity:

See Annuity Sheet 11

$124,341,390 Total Earnings:

$303,152,320

$368,911,651 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 Return:

Trust Fund Balance:

Entergy

$459,281,213

$303,152,320 NRC Minimum:

$656,116,018 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

8 29 2025 MWth 1986$

ECI Base Lx Plant name:

River Bend (Regulated 70%)

Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance to CNRO-2018-0010 Page 11 of 12 Year LPSC PUCT FERC Annuity:

2015

$2,324,000

$281,500

$28,229

$2,633,728 2.0%

$3,210,500 2016

$8,996,000

$1,126,000

$112,914

$10,234,914 2.0%

$12,231,670 2017

$8,996,000

$1,126,000

$112,914

$10,234,914 2.0%

$11,991,833 2018

$8,996,000

$1,126,000

$112,914

$10,234,914 2.0%

$11,756,699 2019

$8,996,000

$1,126,000

$112,914

$10,234,914 2.0%

$11,526,176 2020

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,623,965 2021

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,376,436 2022

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,133,761 2023

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$11,895,844 2024

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$11,662,592 2025

$11,693,000

$1,126,000

$112,914

$12,931,914 2.0%

$12,931,914 Total:

$124,341,390 Accumulation During Decomm Period 2026

$12,931,914

$0

$0

$12,931,914

$12,931,914 2027

$12,931,914

$0

$0

$12,931,914

$12,931,914 2028

$12,931,914

$0

$0

$12,931,914

$12,931,914 2029

$12,931,914

$0

$0

$12,931,914

$12,931,914 2030

$14,751,914

$0

$0

$14,751,914

$14,751,914 2031

$0

$0

$0

$0

$0 2032

$0

$0

$0

$0

$0 2033

$0

$0

$0

$0

$0 2034

$0

$0

$0

$0

$0 Total:

$66,479,570 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Real Rate of Total Accumulation Table 3 (continued)

Financial Assurance - Annuity River Bend (Regulated 70%)

to CNRO-2018-0010 Page 12 of 12 BWR 3091

$131,819,000 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

30.00%

2%

9.91 1.21692 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 220,674,968 222,788,481 (2,113,513)

$419,623,287 Total = Total Earnings + Total Earnings for Decom

$390,586,015

$29,037,271 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$390,586,015 Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$320,963,181

$390,586,015 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:

Entergy

$196,834,805

$320,963,181 NRC Minimum:

$656,116,018 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

8 29 2025 MWth 1986$

ECI Base Lx Plant name:

River Bend (Non-Regulated 30%)

Month Day Year Year of Biennial:

9 30 2015 Table 4 Financial Assurance

ATTACHMENT 4 CNRO-2018-0010 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Waterford 3 Steam Electric Station ISFSI Docket 72-075 to CNRO-2018-0010 Page 1 of 11 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Waterford 3 Steam Electric Station ISFSI Docket 72-075

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations in December 2012.[2]

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Waterford Steam Electric Station, Unit 3 (Waterford),

in an amount reflecting:

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

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

Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011 2

ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2012-00011, dated December 17, 2012 (NRC Accession No. ML12354A131) to CNRO-2018-0010 Page 2 of 11

2.

Spent Fuel Management Strategy The operating license for Waterford is currently set to expire on December 18, 2024.

Approximately 2,555 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will have sufficient capacity to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2024, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the Waterford spent fuel is based in general upon: 1) a 2025 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the Waterford fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the Waterford site in 2061.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, in response to the recommendations made by the current administrations Blue Ribbon 3

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

4 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 to CNRO-2018-0010 Page 3 of 11 Commission and as a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel...[5]

The report stated that [W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

[A]dvances toward the siting and licensing of a larger interim storage facility to be available by 2025 that will have sufficient capacity to provide flexibility in the waste management system and allows for acceptance of enough used nuclear fuel to reduce expected government liabilities.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

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

3.

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

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

4.

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

5 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S.

DOE, January 11, 2013 to CNRO-2018-0010 Page 4 of 11 Entergys current spent fuel management plan for the Waterford spent fuel would result in 80 spent fuel storage casks being placed on the storage pad at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2032 DOE start date for Waterford spent fuel, a 3,000 MTU / year pickup rate, and a 72 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 80 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 6) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2024) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis the ISFSI pad is approximately 154 feet by 120 feet and has a maximum capacity of 72 casks.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 80 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 217 offloaded assemblies, 32 assemblies per cask) which results in 7 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-1 (Accession Number ML081350153) to CNRO-2018-0010 Page 5 of 11 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[7] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

The current ISFSI area was not part of the original plant Protected Area (the Protected Area was expanded to include the ISFSI area). The latest decommissioning cost study for Waterford (prepared in 2015) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license. Therefore, there is no allowance for the remediation of any contaminated soil in the estimate to decommissioning the ISFSI.

Low-level radioactive waste disposal costs are based on Entergys negotiated rates with EnergySolutions.

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

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[8]

Costs are reported in 2015 dollars and based upon an internal decommissioning analysis prepared for Waterford in 2015.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) 8 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S.

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

to CNRO-2018-0010 Page 6 of 11 (1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications in the past three years that affect the decommissioning cost estimate. However, for purposes of bounding the decommissioning cost estimate, 1) future expansion of the ISFSI is assumed in the current estimate based upon continuing delays by the DOE in removing the spent fuel from the site, and 2) the potential volume of low-level radioactive waste volume generated from storage cask overpack disposition is also increased.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

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

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

For estimating purposes it is conservatively assumed that all expenditures will be incurred in the year 2062, the year following all spent fuel removal.

to CNRO-2018-0010 Page 7 of 11

7.

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

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

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

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

The projected amount necessary for decommissioning Waterford is $516.313 million, based upon the NRCs latest financial assurance funding determination.[9]

Based upon Entergys decommissioning trust fund balance for Waterford as of September 30, 2015 (and considering the schedule of remaining principal payments into the decommissioning fund,[10] and the allowed real rate of return on the fund between October 1, 2015 and the start of Waterford station decommissioning), the trust fund will contain a $104.009 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

9 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 10 Collection details provided in Entergy letter CNRO-2015-00011, "Decommissioning Funding Status Report -

Entergy Operations, Inc," dated March 27, 2015 (ML15092A183) to CNRO-2018-0010 Page 8 of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad 187 120 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Quantity (total) 86 80 spent fuel + 6 GTCC Quantity (with residual radioactivity) 7 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,157,818 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,951 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 15,794 Cubic feet Low-Level Radioactive Waste (packaged density) 73 Average weight density Other Potentially Impacted Items Item Value Notes Number of Overpacks used for GTCC storage 6

No residual radioactivity to CNRO-2018-0010 Page 9 of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2015 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (cubic feet)

Craft Oversight and Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 306 306 1,120 Decontamination/Demolition (activated cask disposition) 167 67 341 2,430 3,005 15,794 2,689 License Termination (radiological surveys) 1,273 1,273 9,862 Subtotal 167 67 341 2,430 1,579 4,583 15,794 12,551 1,120 Supporting Costs NRC and NRC Contractor Fees and Costs 416 416 776 Insurance 67 67 Property Taxes Plant Energy Budget 63 63 Non-Labor Overhead 10 10 Corporate A&G 72 72 Security (industrial) 111 111 3,457 Entergy Oversight Staff 321 321 3,803 Subtotal 1,059 1,059 8,036 Total (w/o contingency) 167 67 341 2,430 2,638 5,642 15,794 12,551 9,156 Total (w/25% contingency) 209 83 426 3,038 3,297 7,053 to CNRO-2018-0010 Page 10 of 11 PWR 3716

$105,000,000 124.3 1.98 0.65 2.46 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2%

9.22 1.20024 2%

$74,765,059 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 96,956,461 104,009,372 (7,052,911)

$54,581,000

$620,322,836 Total = Total Earnings + Total Earnings for Decom

$526,593,391

$39,148,445 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$526,593,391 Step 3:

Decom Period:

Total Step 2

$74,765,059 Accumulation:

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

Total Annuity:

See Annuity Sheet 10 Total Earnings:

$376,447,673

$451,828,332 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 Return:

Trust Fund Balance:

Entergy

$516,313,463

$376,447,673 NRC Minimum:

$516,313,463 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 18 2024 MWth 1986$

ECI Base Lx Plant name:

Waterford 3 Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance to CNRO-2018-0010 Page 11 of 11 Year LPSC CNO Annuity:

2015

$1,672,000

$24,170

$1,696,170 2.00%

$2,067,622 2016

$6,688,000

$133,000

$6,821,000 2.00%

$8,151,726 2017

$6,688,000

$133,000

$6,821,000 2.00%

$7,991,889 2018

$6,688,000

$133,000

$6,821,000 2.00%

$7,835,185 2019

$6,688,000

$133,000

$6,821,000 2.00%

$7,681,554 2020

$7,580,000

$151,000

$7,731,000 2.00%

$8,535,649 2021

$7,580,000

$151,000

$7,731,000 2.00%

$8,368,283 2022

$7,580,000

$151,000

$7,731,000 2.00%

$8,204,199 2023

$7,580,000

$151,000

$7,731,000 2.00%

$8,043,332 2024

$7,580,000

$151,000

$7,731,000 2.00%

$7,885,620 Total:

$74,765,059 Accumulation During Decomm Period 2025

$8,867,000

$0

$8,867,000 2026

$8,867,000

$0

$8,867,000 2027

$8,867,000

$0

$8,867,000 2028

$8,867,000

$0

$8,867,000 2029

$8,867,000

$0

$8,867,000 2030

$10,246,000

$0

$10,246,000 2031 0

$0

$0 Total:

$54,581,000 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Real Rate of Total Accumulatio Table 3 (continued)

Financial Assurance - Annuity Waterford 3