CNRO-2018-00019, Entergy Nuclear Operations, Inc. ISFSI - Submittal of Response to Request for Additional Information Re ISFSI Decommissioning Funding Plans

Entergy Nuclear Operations, Inc. ISFSI - Submittal of Response to Request for Additional Information Re ISFSI Decommissioning Funding Plans

ML18155A576
Person / Time
Site:	Palisades, Indian Point, Pilgrim, Vermont Yankee, Big Rock Point, FitzPatrick
Issue date:	06/04/2018
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CNRO-2018-00019
Download: ML18155A576 (79)

Text

Entergy Nuclear Operations, Inc 1340 Echelon Parkway Jackson, MS 39213 Mandy K. Halter Director, Nuclear Licensing Tel: (601) 368-5573 mhalter@entergy.com CNRO-2018-00019 June 4, 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)

Big Rock Point Palisades Nuclear Plant Docket No.72-043 Docket No.72-007 EPID: L-2017-FPR-0007 EPID: L-2017-FPR-0050 Indian Point Nuclear James A. FitzPatrick Generating Stations 1, 2, & 3 Nuclear Power Plant Docket No.72-051 Docket No.72-012 EPID: L-2017-FPR-0035 EPID: L-2017-FPR-0026 Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station Docket No. 72-1044 Docket No.72-059 EPID: L-2017-FPR-0054 EPID: L-2017-FPR-0071

REFERENCES:

1. Entergy letter CNRO-2015-00028; ISFSI Decommissioning Funding Plans (10 CFR 72.30), dated December 17, 2015 (ML15351A524).

2. NRC letter dated April 5, 2018, Request for Additional Information Regarding Entergy [Nuclear] Operations, Inc.s Decommissioning Funding Plan Update for Big Rock Point, Indian Point Nuclear Generating Stations Units 1, 2, and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick Nuclear Power Plant, and Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installations Docket Nos. 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59 (CAC No. 001028, ML18094B091, ML18094B093, ML18094B092).

CNRO-2018-00019 Page 2 of 3

Dear Sir or Madam:

By letter dated December 17, 2015 (Reference 1), Entergy Nuclear Operations, Inc. (ENOI),

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 April 5, 2018 (Reference 2), the NRC issued a Request for Additional Information (RAI) related to the Reference 1 report for Big Rock Point, Indian Point Nuclear Generating Stations Units 1, 2, and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick Nuclear Power Plant, and Vermont Yankee Nuclear Power Station. The attachments to this letter provide ENOIs responses on behalf of the subject licensees to the RAI as relevant to the period encompassed by the Reference 1 report.

In March 2017, Entergy Corporation sold Entergy Nuclear FitzPatrick, LLC, the owner of the James A. FitzPatrick plant, to Exelon Corporation. The Reference 1 ISFSI decommissioning plans are stated as of December 31, 2015. As the revised decommissioning funding plans provided as attachments to this correspondence are as of the same date, and ENOI was the operator of James A. FitzPatrick as of that date, ENOI is providing the response for the James A. FitzPatrick RAI herein.

This submittal contains no new commitments.

If you have any questions, please contact Mr. Bryan Ford, Senior Manager, Fleet Regulatory Assurance, at 601-368-5516.

Sincerely, MKH / ljs/chm Attachments:

1.

Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Big Rock Point

2.

Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Palisades Nuclear Plant 3A. Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Indian Point Nuclear Power Plant, Units 1 and 2 3B. Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Indian Point Nuclear Power Plant, Unit 3

4.

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

5.

Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Pilgrim Nuclear Power Station

6.

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

CNRO-2018-00019 Page 3 of 3 cc:

Mr. L. Jager Smith (ECH)

Mr. W. A. Cloutier (TLG)

Mr. A. J. Vitale (IPEC)

Mr. C. F. Arnone (PAL)

Mr. B. R. Sullivan (PIL)

Mr. C. R. Daniels (VTY)

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

ATTACHMENT 1 CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Big Rock Point ISFSI Docket 72-043

- Big Rock Point CNRO-2018-00019 Page 1 of 8 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Big Rock Point ISFSI Docket 72-043

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

- Big Rock Point CNRO-2018-00019 Page 2 of 8

2.

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

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

Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI was constructed for interim storage and fuel casks have been emplaced thereon. The operating license for the ISFSI was subsequently transferred from Consumers Energy to Entergy Nuclear Palisades and site operator Entergy Nuclear Operations (Entergy) in April of 2007.[3] The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[4]).

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. Entergys current spent fuel management plan for the Big Rock Point 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 Big Rock Point 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,[5] the spent fuel is projected to be fully removed from the Big Rock Point site in 2038.

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 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...[6]

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:

3 News release NRC Staff Approves Big Rock Point ISFSI License Transfer, dated April 10, 2007 (Accession Number ML071000477) 4 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites.

5 Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004 6

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

DOE, January 11, 2013

- Big Rock Point CNRO-2018-00019 Page 3 of 8

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

4.

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

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

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

5.

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

- Big Rock Point CNRO-2018-00019 Page 4 of 8 The dry storage vendor, BNFL, does not expect the overpacks to have any interior or exterior radioactive surface contamination (that could not be easily removed). Any neutron activation of the steel and concrete is expected to be minimal.[7] 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, 2 of the 7 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., 84 off-loaded assemblies, 64 assemblies per cask) which results in 2 overpacks.

The dry storage vendor, BNFL, expects that any activation of the concrete ISFSI pad would be significantly less than of the storage casks.[8] 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 a small portion of the ISFSI pad (directly underneath the two impacted casks) will be activated to a level that would require remediation for termination of the license. Verification surveys are included for the remainder of the pad. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the 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.

Prior to ISFSI pad construction, the NRC took radiological samples of the ground and fill upon which the ISFSI pad was constructed. No significant or unexpected radiological conditions were found, and no nuclear plant-related isotopes were identified in any sample.[9] As such, the decommissioning estimate contains no cost allowance for soil remediation.

Waste volumes are based on estimates provided by FuelSolutions'[10]. 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 7

FuelSolutions' Storage System FSAR, Document No. WSNF-220, Rev. 3, June 2005, at page 14.1-2 (Accession Number ML073610500) 8 FuelSolutions' Storage System FSAR, Document No. WSNF-220, Rev. 3, June 2005, at page 14.1-2 (Accession Number ML073610500) 9 Big Rock Point Restoration Project, NRC Inspection Report 05000155/2001-003 (DNMS), dated June 2001 (Accession Number ML011730211) 10 FuelSolutions' Storage System FSAR, Document No. WSNF-220, Rev. 3, June 2005, at page 14.3-1 (Accession Number ML073610500)

- Big Rock Point CNRO-2018-00019 Page 5 of 8 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.[11]

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

(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.

11 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.

- Big Rock Point CNRO-2018-00019 Page 6 of 8 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 2039, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Big Rock Point 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, according to the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon a Parent Guarantee established in the amount of $5 million[12] to terminate the ISFSI license and release the facility for unrestricted use.

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

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.

12 Status of Decommissioning Funding for Plants Operated by Entergy Nuclear Operations, Inc. for Year Ending December 31, 2014, dated March 30, 2015 (Accession Number ML15092A141)

- Big Rock Point CNRO-2018-00019 Page 7 of 8 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad 99 75 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 230 Dimensions are nominal Outside Diameter (inches) 138 Dimensions are nominal Inside Diameter (inches) 73 Dimensions are nominal Inner Liner Thickness (inches) 2.0 Dimensions are nominal Quantity (total) 8 7 spent fuel + 1 GTCC Quantity (with residual radioactivity) 2 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 153,979 Concrete and steel Other Low-Level Radioactive Waste (pounds) 1,273 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 2,094 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 1

No residual radioactivity

- Big Rock Point CNRO-2018-00019 Page 8 of 8 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) 157 157 928 Decontamination/Demolition (activated cask disposition) 59 46 46 320 470 2,094 681 License Termination (radiological surveys) 686 686 3,852 Subtotal 59 46 46 320 842 1,312 2,094 4,534 928 Supporting Costs NRC and NRC Contractor Fees and Costs 404 404 776 Insurance 37 37 Property Taxes Plant Energy Budget 16 16 Non-Labor Overhead 9

9 Corporate A&G 4

4 Security (industrial) 31 31 1,710 Entergy Oversight Staff 131 131 1,881 Subtotal 632 632 4,366 Total (w/o contingency) 59 46 46 320 1,474 1,944 2,094 4,534 5,294 Total (w/25% contingency) 74 57 57 399 1,843 2,430

ATTACHMENT 2 CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Palisades Nuclear Point ISFSI Docket 72-007

- Palisades Nuclear Plant CNRO-2018-00019 Page 1 of 10 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Palisades Nuclear Point ISFSI Docket 72-007

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

- Palisades Nuclear Plant CNRO-2018-00019 Page 2 of 10

2.

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

Approximately 2,442 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, two ISFSI pads have been constructed and fuel casks have been emplaced thereon to support continued plant operations. The ISFSIs are 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 2031, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI.

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

Completion of the ISFSI decommissioning process is dependent upon the 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 Nuclear Palisades (Entergy) current spent fuel management plan for the Palisades 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 Palisades 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 Palisades site in 2068.

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 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]

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 5

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

DOE, January 11, 2013

- Palisades Nuclear Plant CNRO-2018-00019 Page 3 of 10 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 There are two ISFSI pads on the Palisades site. The original pad was used to store 18 Sierra Nuclear VSC-24 Ventilated Storage Casks (VSCs). Consumers Power transferred 432 assemblies into the VSCs between 1995 and 1999. It is possible that the spent fuel in these casks will have to be repackaged before it can be shipped off-site. Repackaging is currently assumed to occur immediately after the cessation of plant operations, while the spent fuel pool is still available and the associate fuel handling systems are operable. As such, the VSCs are not expected to be on the pad when it is decommissioned (and not considered in this funding plan).

- Palisades Nuclear Plant CNRO-2018-00019 Page 4 of 10 A horizontal dry storage system is currently in use at the second ISFSI pad. There are 24 modules loaded with spent fuel; 11 NUHOMS-32PT modules and 13 NUHOMS-24PTH modules. The system consists of a dry storage canister, with a nominal capacity of 24 or 32 fuel assemblies, and a horizontal concrete storage module. Entergy intends to use Holtecs HI-STORM FW System (with a 37 spent fuel assembly capacity) for storing all future spent fuel on-site. The Holtec dry storage system consists of an inner multi-purpose canister (containing the spent fuel) and an outer concrete and steel overpack.

The current spent fuel management plan for the Palisades spent fuel would result in 51 spent fuel storage modules/casks (24 NUHOMS and 27 Holtec FW) being placed on the storage pad(s) at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2027 DOE start date for Palisades spent fuel, a 3,000 MTU / year pickup rate, and the current cask capacity (including expansion capability) for the ISFSI pad(s) built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 51 modules/casks projected to be on the ISFSI pad(s) after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 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 (2031) 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, 6 of the 27 Holtec 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., 204 offloaded assemblies, 37 assemblies per cask which results in 6 overpacks). It is assumed 6

HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev.0, at page 2-83 (Accession Number ML11270A045)

- Palisades Nuclear Plant CNRO-2018-00019 Page 5 of 10 that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. The older NUHOMS modules are not expected to be activated to a level requiring remediation.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[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.

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

Low-level radioactive waste disposal costs are based on 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 Palisades 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 FW FSAR, Holtec International, Report HI-2114830, Rev. 0, at page 2-84 (Accession Number ML11270A045) 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.

- Palisades Nuclear Plant CNRO-2018-00019 Page 6 of 10 (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(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 remove 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 2069, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at the second Palisades ISFSI are in response to the DOEs failure to

- Palisades Nuclear Plant CNRO-2018-00019 Page 7 of 10 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 second 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 Palisades is $484.769 million, based upon the NRCs latest financial assurance funding determination.[9]

Based upon Palisades decommissioning trust fund balance as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of Palisades station decommissioning, the trust fund will contain a

$60.084 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

- Palisades Nuclear Plant CNRO-2018-00019 Page 8 of 10 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad No. 1 (old) 200 30 No ISFSI Pad No. 2 (new) 354 33 No ISFSI Storage Overpack (Holtec FW)

Item Value Notes Overall Height (inches) 239.5 Dimensions are nominal Outside Diameter (inches) 139 Dimensions are nominal Inside Diameter (inches) 81 Dimensions are nominal Quantity (total, excluding VSCs) 56 51 Spent fuel + 5 GTCC Quantity (with residual radioactivity) 6 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 954,968 Concrete and steel Low-Level Radioactive Waste from Transfer Cask (pounds) 155,000 Other Low-Level Radioactive Waste (pounds) 1,584 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 13,127 Cubic feet Low-Level Radioactive Waste (packaged density) 85 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Potentially contaminated Number of Overpacks used for GTCC storage 5

No residual radioactivity

- Palisades Nuclear Plant CNRO-2018-00019 Page 9 of 10 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) 308 308 1,168 Decontamination/Demolition (activated cask disposition) 626 42 302 1,685 346 3,000 13,127 9,361 License Termination (radiological surveys) 1,716 1,716 13,402 Subtotal 626 42 302 1,685 2,370 5,025 13,127 22,763 1,168 Supporting Costs NRC and NRC Contractor Fees and Costs 415 415 776 Insurance 67 67 Property Taxes 31 31 Plant Energy Budget 63 63 Non-Labor Overhead 19 19 Corporate A&G 115 115 Security (industrial) 120 120 3,457 Entergy Oversight Staff 265 265 3,803 Subtotal 1,094 1,094 8,036 Total (w/o contingency) 626 42 302 1,685 3,464 6,118 13,127 22,763 9,204 Total (w/25% contingency) 782 52 377 2,106 4,330 7,648

- Palisades Nuclear Plant CNRO-2018-00019 Page 10 of 10 PWR 2565

$97,572,000 122.1 2.08 0.65 2.54 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2%

15.48 1.35882 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 52,435,486 60,083,545 (7,648,059)

$544,852,668 Total = Total Earnings + Total Earnings for Decom

$507,149,720

$37,702,947 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:

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:

$373,228,587

$507,149,720 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

$484,769,122

$373,228,587 NRC Minimum:

$484,769,122 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

3 24 2031 MWth 1986$

ECI Base Lx Plant name:

Palisades Nuclear Plant Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance

ATTACHMENT 3A CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Power Plant, Units 1 and 2 ISFSI Docket 72-051 A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 1 of 11 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Power Plant, Units 1 and 2 ISFSI Docket 72-051

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 2 of 11

2.

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

IP-1 ceased operation on October 31, 1974, generating 404 spent fuel assemblies over its operating life. The operating license for IP-2 was set to expire on September 28, 2013. A license renewal application was submitted in 2007. Because Entergy filed a timely and sufficient application, IP-2 will continue to operate under its current license until the NRC makes a final determination on the license renewal application. However, for purposes of this submittal, permanent cessation of operations is assumed to occur on December 31, 2015.

Approximately 1,805 spent fuel assemblies are projected to be generated if IP-2 ceases operation at the end of 2015. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations of IP-2 as well as IP-3 (IP-2 and IP-3 have both applied for license renewal and an additional 20 years of operations). Based upon the current projection of the DOEs ability to remove spent fuel from the site, a second pad will need to be constructed to support decommissioning. Since the projected spent fuel storage requirements for both IP-2 and IP-3 are similar, and the casks will be comingled on the two pads, the funding requirements are assumed to be allocated equally between the two nuclear units (the IP-1 casks are included with the IP-2 inventory). The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

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

Because of the DOEs breach, it is envisioned that the IP-2 spent fuel pool will contain a significant number of spent fuel assemblies at the time operations cease, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the IP-2 fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

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

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 3 of 11 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 Nuclear Indian Point 2, LLCs (Entergy) current spent fuel management plan for the IP-2 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 IP-2 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 Indian Point site in 2059.

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 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.

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

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

DOE, January 11, 2013 A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 4 of 11 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 current Indian Point ISFSI is based upon the Holtec HI-STORM 100S dry cask storage system (IP-1 fuel is stored in a shorter version of the cask). The system consists of a multi-purpose canister, with a nominal capacity of 32 fuel assemblies, and a steel-lined concrete storage overpack.

Entergys current spent fuel management plan for the IP-2 spent fuel would result in 57 spent fuel storage casks (in addition to the 5 casks for IP-1 spent fuel) being placed on the storage pad(s) at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2026 (based on IP-1s allotment) DOE start date for Indian Point spent fuel, a 3,000 MTU / year pickup rate, and a 78 cask capacity for the current ISFSI pad. This scenario would allow the spent fuel storage pool to be emptied within the twelve years that the pool remains operational following the permanent cessation of operations (twelve years is based upon the need to use the IP-2 pool for packaging IP-3 spent fuel for dry storage).

The 62 casks (57 IP-2 + 5 IP-1 casks) projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 7, including 1 for IP-1) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 5 of 11

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the IP-2 unit operating until the end of 2015 and the DOEs spent fuel acceptance assumptions, as previously described. The existing ISFSI pad is approximately 96 feet by 208 feet, and has a maximum capacity of 75 casks. The supplemental pad (future) is assumed to have a capacity of 53 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 57 IP-2 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., 193 assemblies and 32 assemblies per cask) which results in 7 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products. Due to the age of the IP-1 spent fuel when it was placed in dry storage, the IP-1 casks are not expected to be activated to a level requiring remediation.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[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 latest decommissioning cost studies for IP-1 and IP-2 (prepared in 2013) included the cost for the remediation of contaminated (radiological) soil, based upon a detailed characterization of the site and affected areas. The ISFSI was constructed at the north end 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)

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 6 of 11 of the site which was previously undeveloped and outside the existing Protected Area.[8]

Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommissioning the ISFSI.

Low-level radioactive waste disposal costs are based on 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]

Costs are reported in 2015 dollars and based upon internal decommissioning analyses prepared in 2013. The original spent fuel management plan for IP-2 was revised to reflect a 2015 cessation of plant operations. Activity costs were updated to 2015 dollars.

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.

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

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

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 7 of 11 (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 IP-1/IP-2 casks and the IP-1/IP-2 allocated cost to decommissioning the ISFSI pads (the remaining portion will be funded by IP-3) and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (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 2061, the year following all spent fuel removal (including any from IP-3 stored on the pads).

7.

Financial Assurance ISFSI operations at Indian Point are in response to the 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 according to a judgment entered against the DOE under federal law and the Standard Contract.[10] 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, 10 Entergy Nuclear Indian Point 2, LLC v. United States, Court of Federal Claims, No. 03-2622-C (2005)

A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 8 of 11 these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

Since the 5 IP-1 casks are not expected to be activated due to the age of the spent fuel when placed into storage, IP-1's contribution to the ISFSI decommissioning liability is very small. For purposes of this filing, the licensee assumes that the surplus in the IP-2 trust would be used for ISFSI decommissioning purposes.

The projected amount necessary for decommissioning IP-2 is $524.141 million, based upon the NRCs latest financial assurance funding determination. [11]

Based upon IP-2s decommissioning trust fund balance as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of IP-2 decommissioning, the trust fund will contain a $33.260 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.

11 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 9 of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Current ISFSI Pad 208 96 No ISFSI Storage Overpack Item Value Notes HI-STORM 100S-185 Overall Height (inches) 185 Dimensions are nominal HI-STORM 100S-218 Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.5 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 69 57 IP-2 + 5 IP-1 spent fuel + 7 GTCC Quantity (with residual radioactivity)

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) 1,351 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 15,764 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 7 (IP-1 and 2)

No residual radioactivity A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 10 of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes (50% of total cost)

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) 193 193 608 Decontamination/Demolition (activated cask disposition) 210 65 454 2,429 3,126 15,764 2,686 License Termination (radiological surveys) 972 972 7,294 Subtotal 210 65 423 2,429 1,164 4,290 15,764 9,980 608 Supporting Costs NRC and NRC Contractor Fees and Costs 211 211 388 Insurance Property Taxes 646 646 Plant Energy Budget Non-Labor Overhead 7

7 Corporate A&G 38 38 Security (industrial) 73 73 1,991 Entergy Oversight Staff 169 169 1,949 Subtotal 1,142 1,142 4,328 Total (w/o contingency) 210 65 423 2,429 2,307 5,432 15,764 9,980 4,936 Total (w/25% contingency) 262 81 528 3,036 2,884 6,790 A - Indian Point Nuclear 1 & 2 CNRO-2018-00019 Page 11 of 11 PWR 3216

$103,300,800 125.1 2.16 0.65 2.70 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2%

0.25 1.00502 2%

2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 26,469,950 33,260,446 (6,790,496)

$557,401,895 Total = Total Earnings + Total Earnings for Decom

$518,830,561

$38,571,334 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

$518,830,561 Step 3:

Decom Period:

Real Rate of Return per Years remaining after annuity Total Annuity Total Step 2

$0 0.252739726

$0 Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$516,240,348

$518,830,561 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

$524,141,450

$516,240,348 NRC Minimum:

$524,141,450 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 31 2015 MWth 1986$

ECI Base Lx Plant name:

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

9 30 2015 Table 3 IP-2 Financial Assurance

ATTACHMENT 3B CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Power Plant, Unit 3 ISFSI Docket 72-051 B - Indian Point Nuclear 3 CNRO-2018-00019 Page 1 of 10 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Power Plant, Unit 3 ISFSI Docket 72-051

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

B - Indian Point Nuclear 3 CNRO-2018-00019 Page 2 of 10

2.

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

Approximately 1,676 spent fuel assemblies are currently projected to be generated over the operating life. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations of IP-3 as well as IP-2 (IP-3 and IP-2 have both applied for license renewal and an additional 20 years of operations).

Based upon the current projection of the DOEs ability to remove spent fuel from the site, a second pad will need to be constructed to support decommissioning. Since the projected spent fuel storage requirements for both IP-3 and IP-2 are similar, and the casks will be comingled on the two pads, the funding requirements are assumed to be allocated equally between the two nuclear units (the IP-1 casks are included with the IP-2 inventory). The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]). The operating license for IP-3 is currently set to expire on December 12, 2015, and this submittal assumes that date as an end date for the financial assurance calculations. Because Entergy filed a timely and sufficient application, IP-3 will continue to operate under its current license until the NRC makes a final determination on the license renewal application. However, for purposes of this submittal, permanent cessation of operations is assumed to occur on December 12, 2015.

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

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

Completion of the ISFSI decommissioning process is dependent upon the 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 Nuclear Indian Point 3, LLCs (Entergy) current spent fuel management plan for the IP-3 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 IP-3 fuel. The 3

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

B - Indian Point Nuclear 3 CNRO-2018-00019 Page 3 of 10 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 Indian Point site in 2060.

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 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).

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

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

DOE, January 11, 2013 B - Indian Point Nuclear 3 CNRO-2018-00019 Page 4 of 10 For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

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

Entergys current spent fuel management plan for the IP-3 spent fuel would result in 53 spent fuel storage casks being placed on the storage pad(s) at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2026 (based on IP-1s allotment) DOE start date for Indian Point spent fuel, a 3,000 MTU / year pickup rate, and a 78 cask capacity for the current ISFSI pad. This scenario would allow the spent fuel storage pool to be emptied within the ten years following the permanent cessation of operations (ten years is based upon the need to use the IP-2 pool for packaging IP-3 spent fuel for dry storage).

The 53 IP-3 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 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 IP-3 unit operating until the end of its current license (2015) and the DOEs spent fuel acceptance assumptions, as previously described. The existing ISFSI pad is approximately 96 feet by 208 feet, and has a maximum capacity of 75 casks.

The supplemental pad (future) is assumed to have a capacity of 53 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 6

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

B - Indian Point Nuclear 3 CNRO-2018-00019 Page 5 of 10 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 53 IP-3 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., 193 assemblies, 32 assemblies per cask) which results in approximately 7 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[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 latest decommissioning cost study for IP-3 (prepared in 2013) included the cost for the remediation of contaminated (radiological) soil, based upon a detailed characterization of the site and affected areas. The ISFSI was constructed at the north end of the site which was previously undeveloped and outside the existing Protected Area.[8]

Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommissioning the ISFSI.

Low-level radioactive waste disposal costs are based on 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.

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) 8 Indian Point Energy Center, Applicants Environmental Report, Operating License Renewal Stage, p. 3-6 (Accession Number ML071210530)

B - Indian Point Nuclear 3 CNRO-2018-00019 Page 6 of 10 Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[9]

Costs are reported in 2015 dollars and based upon internal decommissioning analyses prepared in 2013. Activity costs were updated to 2015 dollars.

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 IP-3 casks and the IP-3 allocated cost to decommissioning the ISFSI pads (the remaining portion will be funded by IP-2) and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase. During this phase the empty overpacks, ISFSI pad, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (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 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.

B - Indian Point Nuclear 3 CNRO-2018-00019 Page 7 of 10 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 2061, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Indian Point 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 according to a judgment entered against the DOE under federal law and the Standard Contract.[10] 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 IP-3 is $524.141 million, based upon the NRCs latest financial assurance funding determination.[11]

Based upon IP-3s decommissioning trust fund balance as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of IP-3 decommissioning, the trust fund will contain a $196.185 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.

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

United States, Court of Federal Claims, No. 03-2627-C (2009) 11 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013 B - Indian Point Nuclear 3 CNRO-2018-00019 Page 8 of 10 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Current ISFSI Pad 208 96 No ISFSI Storage Overpack Item Value Notes HI-STORM 100S-218 Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.5 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 59 53 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) 1,351 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 15,764 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 6

No residual radioactivity B - Indian Point Nuclear 3 CNRO-2018-00019 Page 9 of 10 Table 2 ISFSI Decommissioning Costs and Waste Volumes (50% of total cost)

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) 193 193 608 Decontamination/Demolition (activated cask disposition) 210 65 454 2,429 3,126 15,764 2,686 License Termination (radiological surveys) 972 972 7,294 Subtotal 210 65 423 2,429 1,164 4,290 15,764 9,980 608 Supporting Costs NRC and NRC Contractor Fees and Costs 211 211 388 Insurance Property Taxes 646 646 Plant Energy Budget Non-Labor Overhead 7

7 Corporate A&G 38 38 Security (industrial) 73 73 1,991 Entergy Oversight Staff 169 169 1,949 Subtotal 1,142 1,142 4,328 Total (w/o contingency) 210 65 423 2,429 2,307 5,432 15,764 9,980 4,936 Total (w/25% contingency) 262 81 528 3,036 2,884 6,790 B - Indian Point Nuclear 3 CNRO-2018-00019 Page 10 of 10 PWR 3216

$103,300,800 125.1 2.16 0.65 2.70 2.052 1.980 0.13 2.02 0.22 13.885

% Owned:

100.00%

2%

0.20 1.00398 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 189,394,426 196,184,922 (6,790,496)

$720,326,372 Total = Total Earnings + Total Earnings for Decom

$670,480,920

$49,845,452 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:

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:

$667,821,657

$670,480,920 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

$524,141,450

$667,821,657 NRC Minimum:

$524,141,450 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 12 2015 MWth 1986$

ECI Base Lx Plant name:

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

9 30 2015 Table 3 IP-3 Financial Assurance

ATTACHMENT 4 CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan James A. Fitzpatrick Nuclear Power Plant ISFSI Docket 72-012

- James A. FitzPatrick CNRO-2018-00019 Page 1 of 10 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan James A. Fitzpatrick Nuclear Power Plant ISFSI Docket 72-012

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

- James A. FitzPatrick CNRO-2018-00019 Page 2 of 10

2.

Spent Fuel Management Strategy Entergy Corporation has announced that it will close FitzPatrick in late 2016 or early 2017. Assuming the plant operates through 2016, approximately 4,408 spent fuel assemblies are currently projected to be generated. 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, construction of additional pad(s) after shutdown 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 pool will contain a significant number of spent fuel assemblies at the time of operations cease, 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 Nuclear FitzPatricks (Entergy) current spent fuel management plan for the FitzPatrick 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 FitzPatrick 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 FitzPatrick site in 2057.

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 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]

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 5

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

DOE, January 11, 2013

- James A. FitzPatrick CNRO-2018-00019 Page 3 of 10 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 FitzPatrick ISFSI is based upon the Holtec HI-STORM 100S dry cask storage system. The system consists of a multi-purpose canister, with a nominal capacity of 68 fuel assemblies, and a steel-lined concrete storage overpack.

Entergys current spent fuel management plan for the FitzPatrick spent fuel would result in 65 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 FitzPatrick spent fuel, a 3,000 MTU / year pickup rate, and a 22 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow

- James A. FitzPatrick CNRO-2018-00019 Page 4 of 10 the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 65 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 2016 and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, the additional ISFSI pads would be constructed to accommodate the casks needed to off load the spent fuel pool after the cessation of plant operations. Based upon the additional capacity needed, a second ISFSI pad is assumed to be constructed to accommodate the additional 48 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, 9 of the 65 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., 560 offloaded assemblies, 68 assemblies per cask) which results in 9 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads.[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 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)

- James A. FitzPatrick CNRO-2018-00019 Page 5 of 10 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 FitzPatrick (prepared in 2014) included an allowance for the remediation of contaminated (radiological) soil as being required to terminate the site operating license. However, there is no indication that any additional remediation of the soil in the vicinity of the current ISFSI pad would be necessary. As such, there is no allowance for the remediation of contaminated soil included with the decommissioning cost of the current ISFSI pad. There has also been no decision on the location of the future pad, but it is reasonable to assume that the site would be free of plant-related radionuclides or remediated prior to construction. Therefore, there is no allowance for the remediation of any additional contaminated soil in the estimate to decommission the second pad.

Low-level radioactive waste disposal costs are based on 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 FitzPatrick in 2014. The spent fuel management assumptions were revised to reflect a 2016 shutdown. 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

- James A. FitzPatrick CNRO-2018-00019 Page 6 of 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: In 2015, the ISFSI was expanded, and this expansion has been accounted for in the decommissioning cost estimate. 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 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 surveys, verification surveys, and the associated equipment and laboratory support.

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 2058, the year following all spent fuel removal.

- James A. FitzPatrick CNRO-2018-00019 Page 7 of 10

7.

Financial Assurance ISFSI operations at FitzPatrick 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 according to a judgment entered against the DOE under federal law and the Standard Contract.[11] It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

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

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

The projected amount necessary for decommissioning FitzPatrick is $651.122 million, based upon the NRCs latest financial assurance funding determination.[12]

Based upon FitzPatricks decommissioning trust fund balance as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of FitzPatrick station decommissioning, the trust fund will contain a $151.432 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.

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

United States, Court of Federal Claims, No. 03-2627-C (2009) 12 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013

- James A. FitzPatrick CNRO-2018-00019 Page 8 of 10 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Existing ISFSI Pad 170 35 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) 70 65 spent fuel + 5 GTCC Quantity (with residual radioactivity) 9 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,488,623 Concrete and steel Other Low-Level Radioactive Waste (pounds) 2,146 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 20,288 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 5

No residual radioactivity

- James A. FitzPatrick CNRO-2018-00019 Page 9 of 10 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) 269 269 1,072 Decontamination/Demolition (activated cask disposition) 244 85 580 3,124 4,033 20,288 3,384 License Termination (radiological surveys) 1,123 1,123 8,954 Subtotal 244 85 580 3,124 1,392 5,425 20,288 13,410 Supporting Costs NRC and NRC Contractor Fees and Costs 412 412 776 Insurance 69 69 Property Taxes 1

1 Plant Energy Budget 77 77 Non-Labor Overhead 29 29 Corporate A&G 96 96 Security (industrial) 139 139 5,137 Entergy Oversight Staff 290 290 3,897 Subtotal 1,112 1,112 9,810 Total (w/o contingency) 244 85 580 3,124 2,504 6,537 20,288 11,675 9,810 Total (w/25% contingency) 305 107 725 3,904 3,130 8,172

- James A. FitzPatrick CNRO-2018-00019 Page 10 of 10 BWR 2536

$126,824,000 125.1 2.16 0.65 2.70 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

100.00%

2%

1.25 1.02512 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 143,260,092 151,431,601 (8,171,509)

$802,554,130 Total = Total Earnings + Total Earnings for Decom

$747,018,647

$55,535,483 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:

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:

$728,714,927

$747,018,647 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

$651,122,528

$728,714,927 NRC Minimum:

$651,122,528 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 31 2016 MWth 1986$

ECI Base Lx Plant name:

James A. FitzPatrick Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance

ATTACHMENT 5 CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station ISFSI Docket 72-1044

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 1 of 10 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station ISFSI Docket 72-1044

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 Nuclear Operations in December 2012.[2]

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Pilgrim Nuclear Power Station (Pilgrim), 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 2 of 10

2.

Spent Fuel Management Strategy Entergy Corporation announced that it will close Pilgrim no later than June 1, 2019.

Assuming the plant operates to that date, approximately 4,118 spent fuel assemblies are currently projected to be generated. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI is needed to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, the construction of a second ISFSI after shutdown to support decommissioning. The ISFSI(s) is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart 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 operations cease, 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 Nuclear Generation Companys (Entergy) current spent fuel management plan for the Pilgrim 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 Pilgrim 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 the Pilgrim 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 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]

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 5

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

DOE, January 11, 2013

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 3 of 10 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 ISFSIs will be promptly decommissioned (similar to the power reactor DECON alternative).

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

4.

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

Entergys current spent fuel management plan for the Pilgrim spent fuel would result in 61 spent fuel storage casks being placed on two separate storage pads at the site. This projected configuration is based upon the 2025 DOE spent fuel program start with a 2027 DOE start date for Pilgrim spent fuel, a 3,000 MTU / year pickup rate, and a 40 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 4 of 10 the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 61 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI(s) expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI(s) is based on the station operating until mid-2019 and the DOEs spent fuel acceptance assumptions, as previously described. The current Pilgrim ISFSI pad is approximately 52 feet by 239 feet, with a maximum capacity of 40 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, nine of the 61 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., 580 offloaded assemblies, 68 assemblies per cask) which results in 9 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete 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.

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)

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 5 of 10 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.

During the construction of the ISFSI, the top six inches of soil at the excavation was sampled and analyzed. [8] There was no plant-related radioactive material in the samples, only naturally-occurring isotopes and background levels of 137Cs in the soil. Therefore, there is no allowance for the remediation of any contaminated soil in the estimate to decommission the ISFSI. There has also been no decision on the location of the future pad, but it is reasonable to assume that the site would be free of plant-related radionuclides or remediated prior to construction. Therefore, there is no allowance for the remediation of any additional contaminated soil in the estimate to decommission the second pad.

Low-level radioactive waste disposal costs are based on 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.[9]

Costs are reported in 2015 dollars and based upon an internal decommissioning analysis prepared for Pilgrim in 2012. Activity costs were updated to 2015 dollars.

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 8

Addendum to Radiological Engineering Evaluation 12-017, ISFSI On-Site Soil Sample Results, June 2012 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.

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 6 of 10 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(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 remove 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.

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 7 of 10

7.

Financial Assurance ISFSI operations at Pilgrim 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 according to a judgment entered against the DOE under federal law and the Standard Contract.[10] It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

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

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

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

The projected amount necessary for decommissioning Pilgrim is $627.650 million, based upon the NRCs latest financial assurance funding determination.[11]

Based upon Pilgrims decommissioning trust fund balance as of September 30, 2015 and considering the allowed real rate of return on the fund between October 1, 2015 and the start of Pilgrim station decommissioning, the trust fund will contain a

$378.840 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.

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

11 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 8 of 10 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Primary ISFSI Pad 238.5 52 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.50 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Quantity (total) 65 61 spent fuel + 4 GTCC Quantity (with residual radioactivity) 9 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 1,488,623 Concrete and steel Other Low-Level Radioactive Waste (pounds) 2,166 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 20,289 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 4

No residual radioactivity

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 9 of 10 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) 269 269 1,072 Decontamination/Demolition (activated cask disposition) 245 84 632 3,124 4,085 20,289 3,456 License Termination (radiological surveys) 1,216 1,216 9,700 Subtotal 245 84 632 3,124 1,485 5,569 20,289 14,228 Supporting Costs NRC and NRC Contractor Fees and Costs 412 412 776 Insurance 209 209 Property Taxes 246 246 Plant Energy Budget Non-Labor Overhead Corporate A&G 98 98 Security (industrial) 321 321 5,013 Entergy Oversight Staff 325 325 3,803 Subtotal 1,611 1,611 9,592 Total (w/o contingency) 245 84 632 3,124 3,096 7,180 20,289 14,228 9,592 Total (w/25% contingency) 306 105 790 3,904 3,869 8,975

- Pilgrim Nuclear Power Station CNRO-2018-00019 Page 10 of 10 BWR 2028

$122,252,000 125.1 2.16 0.65 2.70 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

100.00%

2%

3.67 1.07537 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 369,864,863 378,839,963 (8,975,100)

$1,006,489,551 Total = Total Earnings + Total Earnings for Decom

$936,842,057

$69,647,493 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:

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:

$871,181,920

$936,842,057 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

$627,649,588

$871,181,920 NRC Minimum:

$627,649,588 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

5 31 2019 MWth 1986$

ECI Base Lx Plant name:

Pilgrim Nuclear Generating Station Month Day Year Year of Biennial:

9 30 2015 Table 3 Financial Assurance

ATTACHMENT 6 CNRO-2018-00019 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Vermont Yankee Nuclear Power Station ISFSI Docket 72-059

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 1 of 10 Revised 10 CFR 72.30 ISFSI Decommissioning Funding Plan Vermont Yankee Nuclear Power Station ISFSI Docket 72-059

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 Nuclear Operations in December 2012.[2]

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

1. The work 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 Big Rock Point, Indian Point Generating Stations 1, 2, & 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant, James A. FitzPatrick and Vermont Yankee Nuclear Power Station, ENOC-12-00039, dated December 13, 2012 (NRC Accession No. ML12352A126)

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 2 of 10

2.

Spent Fuel Management Strategy Vermont Yankee permanently ceased reactor operations on December 29, 2014.[3]

Approximately 3,880 spent fuel assemblies (3,879 assemblies and 1 fuel debris canister) were generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI had been constructed and fuel casks have been emplaced thereon to support plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, a second pad will need to be constructed to support decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[4]).

Because of the DOEs breach, the spent fuel pool contains a significant number of spent fuel assemblies. 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 Nuclear Vermont Yankees (Entergy) current spent fuel management plan for the Vermont 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 Vermont 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,[5] the spent fuel is projected to be fully removed from the Vermont Yankee site in 2052.

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

SVY 15-001 Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, January 12, 2015 (Accession Number ML15085A047) 4 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites.

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

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 3 of 10 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...[6]

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

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

DOE, January 11, 2013

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 4 of 10 Entergys current spent fuel management plan for the Vermont Yankee spent fuel would result in 58 spent fuel storage casks being placed on the storage pads at the site (including the casks generated during plant operations). This projected configuration is based upon the 2025 DOE spent fuel program start with a 2026 DOE start date for Vermont Yankee spent fuel, a 3,000 MTU / year pickup rate, and a 36 cask capacity for the ISFSI pad built to support plant operations. This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 58 casks projected to be on the pad 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 1) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the current spent fuel inventory at the site (3,880 assemblies) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, the second pad is needed to accommodate all the casks used to store spent fuel at the site, including those casks placed on the initial ISFSI pad during plant operations. The second ISFSI pad is expected to be approximately 93 feet by 106 feet, and have a maximum capacity of 25 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.[7] The decommissioning estimate is based on the premise that some of the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 6 of the 58 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., 368 offloaded assemblies, 68 assemblies per cask) which results in 6 overpacks. It is assumed that these are the final casks offloaded; consequently they have the least time for radioactive decay of the neutron activation products.

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

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 5 of 10 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads.[8] 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 decommissioning cost study[ 9] developed for Vermont Yankee and filed with the NRC, included the cost for the remediation of contaminated (radiological) soil, based upon a review of the sites radiological records and associated affected areas. During the construction of the existing ISFSI, the soil excavated was replaced with engineered fill.

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

The second pad is expected to be located adjacent to the first. Soil removed during construction will be sampled and analyzed for both radiological and non-radiological contaminants. Entergy does not expect to find contamination in the soil beneath the excavation. Therefore, there is no allowance for the remediation any additional contaminated soil in the estimate to decommission the ISFSI.

Low-level radioactive waste disposal costs are based on 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.[10]

Costs are reported in 2015 dollars and based upon the estimate included with the Post Shutdown Decommissioning Activities Report[8] in 2014. Activity costs with the 8

HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 3, at page 2.4-2 (Accession Number ML081350153) 9 Site Specific Decommissioning Cost Estimate for the Vermont Yankee Nuclear Power Station, dated December 2014 (Accession Number ML14357A110) 10 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.

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 6 of 10 exception of those associated with low-level radioactive waste disposal, have been escalated to 2015 dollars using the Consumer Price Index, Services.[11] Low-level radioactive waste disposal costs have been escalated to 2015 dollars using the Consumer Price Index, All Items.[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 pads and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase.

During this phase the empty overpacks, ISFSI pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (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 Andrews, TX 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.

11 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS 12 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, All Items, Series ID:

CUUR0000AA0

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 7 of 10 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 2053, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Vermont Yankee 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 according to a judgment entered against the DOE under federal law and the Standard Contract.[13] It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

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

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

The projected amount necessary for decommissioning Vermont Yankee is $622.290 million, based upon the NRCs latest financial assurance funding determination.[14]

Thus, considering the current fund balance of $596 million (as of October 31, 2015),

projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), the trust fund is expected to have an excess of $17.775 million over the estimated license termination and spent fuel management costs.

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.

13 Vermont Yankee Nuclear Power Corporation and Entergy Nuclear Vermont Yankee, LLC v. United States, Court of Federal Claims, Nos. 02-898C and 03-2663C (2006) 14 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 15, January 2013

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 8 of 10 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity Existing ISFSI Pad 132 76 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) 59 58 spent fuel + 1 GTCC Quantity (with residual radioactivity) 6 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste from Overpack (pounds) 876,621 Concrete and steel Transfer Cask (pounds) 202,400 Other Low-Level Radioactive Waste (pounds) 1,350 DAW, filters and other secondary waste Low-Level Radioactive Waste (total packaged volume) 12,370 Cubic feet Low-Level Radioactive Waste (packaged density) 87 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Potentially contaminated Number of Overpacks used for GTCC storage 1

No residual radioactivity

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 9 of 10 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) 252 252 1,048 Decontamination/Demolition (activated cask disposition) 149 142 375 639 1,306 12,370 1,537 License Termination (radiological surveys) 1,223 1,223 10,260 Subtotal 149 142 375 639 1,475 2,781 12,370 11,797 1,048 Supporting Costs NRC and NRC Contractor Fees and Costs 407 407 776 Insurance 50 50 Property Taxes 2

2 Plant Energy Budget 55 55 Non-Labor Overhead 283 283 Corporate A&G 51 51 Security (industrial) 226 226 4,996 Entergy Oversight Staff 187 187 2,067 Subtotal 1,261 1,261 7,839 Total (w/o contingency) 149 142 375 639 2,736 4,042 12,370 11,797 8,887 Total (w/25% contingency) 187 178 469 799 3,420 5,053

- Vermont Yankee Nuclear Power Station CNRO-2018-00019 Page 10 of 10 Table 3 Financial Assurance BWR 1912

$121,208,000 125.1 2.16 0.65 2.70 2.052 1.980 0.13 2.02 0.22 14.16

% Owned:

100.00%

2%

0.00 1.00000 2%

2%

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

Vermont Yankee Power Station Month Day Year Year of Biennial:

9 30 2015 Termination of Operation:

12 29 2014 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$817,219,461

$595,773,175 NRC Minimum:

$622,289,625 Site Specific:

$817,219,461

$595,773,175

$595,773,175 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$595,773,175

$44,291,466 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

$640,064,641 Total = Total Earnings + Total Earnings for Decom 12,722,451 17,775,016 (5,052,565)

$