ML18320A036

Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54 (Bb)

ML18320A036
Person / Time
Site:	Pilgrim
Issue date:	11/16/2018
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.18.071
Download: ML18320A036 (20)

Text

10 CFR 50.54 November 16, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)

Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35 LETTER NUMBER:

2.18.071

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Spent Fuel Management Plan Submittal in accordance with 10 CFR 50.54(bb),

2.07.055, dated June 7, 2007 (ML071700121)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, Response to NRC Request for Additional Information (RAI) Regarding Pilgrim Nuclear Power Station Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb), 2.08.018, dated April 9, 2008 (ML081060520)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, Response to Request for Additional Information to Support the Review of the Pilgrim Nuclear Power Station Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) and the Preliminary Decommissioning Cost Estimate Pursuant to 10 CFR 50.75(f)(3),

2.08.052, dated October 14, 2008 (ML082910039)

4. Letter, USNRC to Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station - Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. MD8036 and MD9416), 1.09.001, dated January 7, 2009 (ML083190292)

5. Letter, Entergy Nuclear Operations, Inc. to USNRC, Notification of Permanent Cessation of Power Operations, 2.15.080, dated November 10, 2015 (ML15328A053)

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel: (601)368-5000 Mandy K. Halter Director, Nuclear Licensing

2.18.071 I Page 2 of 3

Dear Sir or Madam:

In accordance with 10 CFR 50.54(bb), Entergy Nuclear Operations, Inc. (ENOl) is hereby notifying the NRC of significant changes to the Pilgrim Nuclear Power Station (PNPS) Spent Fuel Management Plan.

Pursuant to 10 CFR 50.54(bb), ENOl initially submitted a Spent Fuel Management Plan on June 7, 2007 (Reference 1 ), as supplemented by its responses to the NRC staff's Requests for Additional Information, which ENOl submitted on April 9, 2008 (Reference 2) and October 14, 2008 (Reference 3). On January 7, 2009, the NRC staff approved the PNPS Spent Fuel Management Plan on a preliminary basis (Reference 4).

By letter dated November 10, 2015, ENOl notified the NRC of its intent to permanently cease power operations at PNPS no later than June 1, 2019 (Reference 5). As a result of its decision to permanently cease operations at PNPS and related changes to the anticipated schedule of decommissioning activities, spent fuel management activities, and decommissioning funding assumptions, ENOl is modifying the PNPS Spent Fuel Management Plan. This submittal provides the required Section 50.54(bb) notification. Attachment 1 provides the Updated Spent Fuel Management Plan (SFMP), which supersedes all prior versions of the SFMP.

There are no new regulatory commitments contained in this letter.

Should you have any questions concerning this letter or require additional information, please contact Mr. Peter J. Miner at (508) 830-7127.

Attachment:

1.

Pilgrim Nuclear Power Station Updated Spent Fuel Management Plan

2.18.071 / Page 3 of 3 cc:

Mr. David C. Lew Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. John Lamb, Senior Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-9D12 Washington, DC 20555-0001 Mr. John Giarrusso, Jr.

Planning, Preparedness and Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 Mr. John Priest, Director Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1M2A Charlestown, MA 02129-1121 NRC Resident Inspector Pilgrim Nuclear Power Station

Letter 2.18.071 Pilgrim Nuclear Power Station Updated Spent Fuel Management Plan

2.18.071/ Attachment 1 / Page 1 of 16 Pilgrim Nuclear Power Station Updated Spent Fuel Management Plan I.

Background and Introduction Entergy Nuclear Operations, Inc. (ENOI) submitted a Spent Fuel Management Plan on June 7, 2007 (Reference 1), as supplemented by its responses to the NRC staffs Requests for Additional Information, which ENOI submitted on April 9, 2008 (Reference

2) and October 14, 2008 (Reference 3). ENOI submitted its plan pursuant to 10 CFR 50.54(bb), which requires power reactor licensees to submit a spent fuel management and funding program for NRC review five years prior to the expiration of a reactor operating license. At the time, the PNPS operating license was set to expire on June 8, 2012. On January 7, 2009, the NRC staff approved the PNPS Spent Fuel Management Plan on a preliminary basis (Reference 4).

By letter dated November 10, 2015, ENOI notified the NRC of its intent to permanently cease power operations at PNPS no later than June 1, 2019 (Reference 5).

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

Pursuant to 10 CFR 50.82(a)(4)(i), on November 16, 2018, ENOI submitted a Post Shutdown Decommissioning Activities Report (PSDAR) for PNPS that included a site-specific decommissioning cost estimate (DCE) as an attachment (Reference 6). The DCE describes the bases for the assumptions regarding the U.S. Department of Energys (DOE) acceptance of spent fuel from the industry and from PNPS. As discussed in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the SFMP is based on the assumption that DOE will commence acceptance of PNPSs spent fuel in 2030 and complete removal of all spent fuel from the site in 2062, consistent with the current DOE spent fuel management and acceptance strategy.1 The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the SFMP, along with license termination and site restoration activities and costs.

1 As noted in the DCE, DOEs repository program assumes that spent fuel is accepted for disposal from the nations commercial nuclear plants in the order in which it was removed from service (oldest fuel first). The contracts that U.S. generators have with the DOE provide a number of mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst generators, and the option of providing priority acceptance from permanently shut down nuclear reactors. PNPS will seek the most expeditious means of removing fuel from the site when DOE commences performance. Given DOEs failure to accept fuel under its contracts, however, it is unclear how these mechanisms will operate once DOE begins accepting spent fuel from commercial reactors. Accordingly, for planning purposes only, this SFMP conservatively assumes that DOE will accept spent fuel in an oldest fuel first order.

2.18.071/ Attachment 1 / Page 2 of 16 II.

Spent Fuel Management Strategy At the time of shutdown, there will be a total of 4,114 spent fuel assemblies at the PNPS site, including 580 fuel assemblies residing in the reactor as part of the current operating cycle, 2,378 spent fuel assemblies stored in the spent fuel pool, and 1,156 assemblies stored in 17 dry storage casks on an independent spent fuel storage installation (ISFSI) facility. In 2014, construction of the ISFSI pad was completed, which PNPS operates under the General License in 10 CFR 72.210. PNPS uses the Holtec HI-STORM 100 dry cask storage system for the spent fuel that is currently stored on the ISFSI. The system consists of a multipurpose canister (MPC) with a nominal capacity of 68 fuel assemblies and a concrete storage overpack. The existing ISFSI pad was constructed with a capacity of 40 dry storage casks, which is administratively limited to a capacity of 38 casks to allow for cask movement and access. PNPS completed fuel loading campaigns to the ISFSI in 2015, 2016, and 2018.

As indicated in the PNPS PSDAR (Reference 6), PNPS owner Entergy Nuclear Generation Company (ENGC) has selected the SAFSTOR decommissioning option.

The SFMP assumes that radiological decommissioning is completed within 60 years of permanent plant shutdown (i.e., by June 1, 2079). Following shutdown, the reactor building will be operated as an interim wet fuel storage facility for approximately three years after operations cease. During this time period, the spent fuel residing in the storage pool will be transferred to dry storage. The ISFSI will remain operational until DOE is able to complete the transfer of the fuel to a repository or interim storage facility.

The PSDAR and DCE describe three major phases related to spent fuel management at PNPS, which are summarized below.2 Table 1 - Spent Fuel Management Plan: Summary Schedule and Costs Decommissioning Period Start End Approximate Duration (Years)

Estimated Cost (thousands of 2018 dollars)

Periods 0 and 1: Planning and Preparations for Dormancy 2018 March 2020 1.84

$93,869 Period 2a: Dormancy with Wet Fuel Storage March 2020 2022 2.8

$134,770 Period 2b: Dormancy with Dry Fuel Storage 2022 2062 40

$191,611 TOTAL 44.64

$420,250 2

Appendix C to the DCE (Reference 6, Attachment 1) includes a detailed cost analysis of all decommissioning activities, including spent fuel management activities, by period.

2.18.071/ Attachment 1 / Page 3 of 16

1. Pre-Shutdown Planning and Preparations for SAFSTOR Dormancy Pre-shutdown spent fuel management planning activities include designing a consolidated ISFSI facility that will include a single storage pad that will have space to accommodate a total of 61 casks, which will allow for dry storage of all spent fuel assemblies generated during the plants operational history. The planned location for the consolidated ISFSI facility is in an area of the site that is southwest of the power block.

The estimated spent fuel management costs associated with ISFSI design, and other expenses during this initial phase, such as emergency planning and preparations for dormancy, total approximately $93.9 million.

2. Dormancy with Wet Fuel Storage The initial decommissioning activities to be performed after plant shutdown will focus primarily on preparing the plant for a period of safe-storage (also referred to as dormancy) and constructing the consolidated ISFSI facility. During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. PNPS expects to begin construction of the consolidated ISFSI pad in 2019, assuming the timely receipt of required permits.

PNPS expects to begin transferring the remaining spent fuel from the spent fuel pool to dry storage in 2020 and to complete the transfer of all fuel to the consolidated ISFSI by mid-2022. In addition, the 17 casks that are currently stored on the existing ISFSI pad will be relocated to the consolidated ISFSI facility. In total, 4,114 spent fuel assemblies will be stored in 61 dry cask systems on the new consolidated ISFSI pad. After the fuel transfer is completed, the pool will be drained and supporting systems will be de-energized for the remainder of the dormancy period.

Costs in this phase total approximately $134.8 million and include: construction of the consolidated ISFSI facility (including the new storage pad, other ISFSI infrastructure, and related security modifications), 44 additional dry cask systems, and transferring fuel from the spent fuel pool to the ISFSI.

3. Dormancy with Dry Fuel Storage During this phase, the spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the DCE (Reference 6, Attachment 1), for planning purposes, the SFMP assumes that DOE will begin removing fuel from PNPS in 2030 and will complete the removal of all spent fuel from the site in 2062, according to the schedule set forth in Table 2 below.

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

2.18.071/ Attachment 1 / Page 4 of 16 approximately $5 million, which reflects the portion of the total site caretaking costs that is allocated to the Spent Fuel Management cost category.

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

$10.5 million.3 The total estimated spent fuel management cost associated with this phase is approximately $191.6 million.

Table 2 - Spent Fuel Management Schedule (Fuel Assembly Totals by Location)

Year Pool Inventory ISFSI Inventory DOE Acceptance 2018 2,378 1,156 2019 2,958 1,156 2020 2,958 1,156 2021 2,958 1,156 2022 0

4,114 2023 4,114 2024 4,114 2025 4,114 2026 4,114 2027 4,114 2028 4,114 2029 4,114 2030 4,094 20 2031 3,962 132 2032 3,534 428 2033 3,534 0

2034 3,442 92 3

As noted in the DCE (Reference 6, Attachment 1), DOE has breached its obligations to remove fuel from reactor sites on the contracted schedule, and has also failed to provide plant owners with information about how it will ultimately perform and fulfill its obligation. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to the Standard Contract, but DOE has not explained what costs any such amendment would involve.

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

2.18.071/ Attachment 1 / Page 5 of 16 Table 2 - Spent Fuel Management Schedule (continued)

(Fuel Assembly Totals by Location)

Year Pool Inventory ISFSI Inventory DOE Acceptance 2035 3,210 232 2036 2,986 224 2037 2,986 0

2038 2,794 192 2039 2,794 0

2040 2,794 0

2041 2,626 168 2042 2,486 140 2043 2,350 136 2044 2,350 0

2045 2,144 206 2046 2,128 16 2047 1,984 144 2048 1,840 144 2049 1,676 164 2050 1,676 0

2051 1,516 160 2052 1,356 160 2053 1,356 0

2054 1,200 156 2055 1,048 152 2056 1,048 0

2057 896 152 2058 896 0

2059 752 144 2060 580 172 2061 580 0

2062 0

580 Total 4,114 III.

ISFSI Decommissioning The ISFSI pads and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site. The bases and assumptions used to formulate the cost estimate are discussed in the DCE (Reference 6, Attachment 1). As detailed in Appendix D to the DCE, the estimated cost to decommission the ISFSI is approximately $9.4 million (assuming a 25% contingency).

2.18.071/ Attachment 1 / Page 6 of 16 IV.

Funding Demonstration for License Termination and Spent Fuel Management Operations Costs As shown in the DCE (Reference 6, Attachment 1), the projected total cost to decommission PNPS, after an extended period of safe storage, is estimated at $1.66 billion (in 2018 dollars). This amount includes estimated costs associated with license termination ($1.19 billion), spent fuel management ($420.25 million), and site restoration

($53.01 million) activities.

As of October 31, 2018, the PNPS decommissioning trust fund balance was

$1,051,722,466. Tables 3.2a and 3.2b of the DCE (Reference 6, Attachment 1) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. For convenience, those tables are reproduced below as Tables 3 and 4.

This annual expenditure information is used in the cash flow analysis in Table 5 below.4 The cash flow analysis demonstrates that the PNPS trust fund is sufficiently funded for all license termination, spent fuel management, and site restoration activities.

Thus, considering the fund balance of $1.05 billion (as of October 31, 2018) and projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), the trust fund is expected to have an excess of approximately $152.87 million over the estimated license termination, spent fuel management costs, and site restoration costs.

4 The same cash flow analysis table is reproduced as Table 4 of ENOIs November 16, 2018 Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) (Reference 7).

2.18.071/ Attachment 1 / Page 7 of 16 Table 3 - License Termination Expenditures (thousands, 2018 dollars)

Year Labor Equip. &

Materials Energy Waste Disposal Other Total 2018 0

0 0

0 19,142 19,142 2019 45,256 1,040 1,409 276 52,043 100,024 2020 22,178 1,040 1,572 539 36,245 61,574 2021 13,526 454 1,157 323 30,572 46,032 2022 13,526 454 1,157 323 28,339 43,799 2023 2,276 130 524 7

11,579 14,516 2024 2,282 130 525 7

3,953 6,897 2025 2,276 130 524 7

3,322 6,259 2026 2,276 130 524 7

2,947 5,884 2027 2,276 130 524 7

2,947 5,884 2028 2,282 130 525 7

2,953 5,897 2029 2,276 130 524 7

2,947 5,884 2030 2,276 130 524 7

2,947 5,884 2031 2,276 130 524 7

2,947 5,884 2032 2,282 130 525 7

2,953 5,897 2033 2,276 130 524 7

2,947 5,884 2034 2,276 130 524 7

2,947 5,884 2035 2,276 130 524 7

2,947 5,884 2036 2,282 130 525 7

2,953 5,897 2037 2,276 130 524 7

2,947 5,884 2038 2,276 130 524 7

2,947 5,884 2039 2,276 130 524 7

2,947 5,884 2040 2,282 130 525 7

2,953 5,897 2041 2,276 130 524 7

2,947 5,884 2042 2,276 130 524 7

2,947 5,884 2043 2,276 130 524 7

2,947 5,884 2044 2,282 130 525 7

2,953 5,897 2045 2,276 130 524 7

2,947 5,884 2046 2,276 130 524 7

2,947 5,884 2047 2,276 130 524 7

2,947 5,884 2048 2,282 130 525 7

2,953 5,897 2049 2,276 130 524 7

2,947 5,884 2050 2,276 130 524 7

2,947 5,884 2051 2,276 130 524 7

2,947 5,884 2052 2,282 130 525 7

2,953 5,897 2053 2,276 130 524 7

2,947 5,884 2054 2,276 130 524 7

2,947 5,884 2055 2,276 130 524 7

2,947 5,884 2056 2,282 130 525 7

2,953 5,897 2057 2,276 130 524 7

2,947 5,884 2058 2,276 130 524 7

2,947 5,884

2.18.071/ Attachment 1 / Page 8 of 16 Table 3 - License Termination Expenditures (continued)

(thousands, 2018 dollars)

Year Labor Equip. &

Materials Energy Waste Disposal Other Total 2059 2,276 130 524 7

2,947 5,884 2060 2,282 130 525 7

2,953 5,897 2061 2,276 130 524 7

2,947 5,884 2062 2,276 130 524 7

2,947 5,884 2063 1,663 298 216 6

2,514 4,697 2064 1,668 298 217 6

2,521 4,710 2065 1,663 298 216 6

2,514 4,697 2066 1,663 298 216 6

2,514 4,697 2067 1,663 298 216 6

2,514 4,697 2068 1,668 298 217 6

2,521 4,710 2069 1,663 298 216 6

2,514 4,697 2070 1,663 298 216 6

2,514 4,697 2071 1,663 298 216 6

2,514 4,697 2072 1,668 298 217 6

2,521 4,710 2073 22,411 1,183 1,324 21 3,694 28,634 2074 38,252 8,293 2,154 5,384 7,668 61,751 2075 47,682 24,256 2,053 68,469 17,586 160,046 2076 63,341 15,092 1,775 41,144 16,992 138,344 2077 66,082 10,159 1,621 26,451 16,606 120,920 2078 56,725 7,373 1,230 17,765 13,112 96,205 2079 15,548 693 178 12 2,457 18,888 2080 137 0

0 0

0 137 Total 512,400 78,223 38,769 161,050 397,552 1,187,994

2.18.071/ Attachment 1 / Page 9 of 16 Table 4 - Spent Fuel Management Expenditures (thousands, 2018 dollars)

Year Labor Equip. &

Materials Energy Waste Disposal Other Total 2018 4,033 12,100 0

0 0

16,133 2019 11,838 35,513 0

0 12,665 60,016 2020 12,611 28,315 0

0 13,768 54,694 2021 12,272 24,230 0

0 12,396 48,898 2022 12,272 24,230 0

0 12,396 48,898 2023 4,188 0

0 0

8,694 12,882 2024 4,200 0

0 0

122 4,322 2025 4,188 0

0 0

122 4,310 2026 4,188 0

0 0

122 4,310 2027 4,188 0

0 0

122 4,310 2028 4,200 0

0 0

122 4,322 2029 4,188 0

0 0

122 4,310 2030 4,188 0

0 0

122 4,310 2031 4,274 259 0

0 122 4,655 2032 4,501 906 0

0 122 5,529 2033 4,188 0

0 0

122 4,310 2034 4,231 129 0

0 122 4,482 2035 4,361 518 0

0 122 5,000 2036 4,329 388 0

0 122 4,839 2037 4,188 0

0 0

122 4,310 2038 4,317 388 0

0 122 4,827 2039 4,188 0

0 0

122 4,310 2040 4,200 0

0 0

122 4,322 2041 4,317 388 0

0 122 4,827 2042 4,274 259 0

0 122 4,655 2043 4,274 259 0

0 122 4,655 2044 4,200 0

0 0

122 4,322 2045 4,317 388 0

0 122 4,827 2046 4,188 0

0 0

122 4,310 2047 4,274 259 0

0 122 4,655 2048 4,286 259 0

0 122 4,667 2049 4,317 388 0

0 122 4,827 2050 4,188 0

0 0

122 4,310 2051 4,274 259 0

0 122 4,655 2052 4,286 259 0

0 122 4,667 2053 4,188 0

0 0

122 4,310 2054 4,274 259 0

0 122 4,655 2055 4,274 259 0

0 122 4,655 2056 4,200 0

0 0

122 4,322 2057 4,274 259 0

0 122 4,655 2058 4,188 0

0 0

122 4,310

2.18.071/ Attachment 1 / Page 10 of 16 Table 4 - Spent Fuel Management Expenditures (continued)

(thousands, 2018 dollars)

Year Labor Equip. &

Materials Energy Waste Disposal Other Total 2059 4,274 259 0

0 122 4,655 2060 4,329 388 0

0 122 4,839 2061 4,188 0

0 0

122 4,310 2062 4,576 1,164 0

0 122 5,862 2063 0

0 0

0 0

0 2064 0

0 0

0 0

0 2065 0

0 0

0 0

0 2066 0

0 0

0 0

0 2067 0

0 0

0 0

0 2068 0

0 0

0 0

0 2069 0

0 0

0 0

0 2070 0

0 0

0 0

0 2071 0

0 0

0 0

0 2072 0

0 0

0 0

0 2073 0

0 0

0 0

0 2074 0

0 0

0 0

0 2075 0

0 0

0 0

0 2076 0

0 0

0 0

0 2077 0

0 0

0 0

0 2078 0

0 0

0 0

0 2079 0

0 0

0 0

0 2080 0

0 0

0 0

0 Total 223,294 132,279 0

0 64,677 420,250

2.18.071/ Attachment 1 / Page 11 of 16 Table 5 - Annual Cash Flow Analysis Pilgrim Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management, and Site Restoration Costs (In Thousands, 2018 Dollars)

Date Amount Total Trust Fund Balance as of 10/31/2018

$ 1,051,722 Start of Decommissioning 06/01/2019 Decommissioning Funds value at Calculation Date 10/31/2018

$ 1,051,722 Total Estimated Costs at Calculation Date 10/31/2018

$ 1,661,258 0.000%

Cost Escalation Rate Start of Decom to end of Decom - Assumes 0.0% Decom cost escalation rate 2.000%

Fund Earnings Rate Start of Decom to end of Decom - Assumes 2.0% Earnings Rate Pilgrim Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management, and Site Restoration Costs (In Thousands in 2018 Dollars)

Year Column 1 50.75 License Termination Cost Column 2 50.54 (bb)

Spent Fuel Management Cost Column 3 Site Restoration Column 4 Total Cost Column 5 Beginning of Year Trust Fund Balance Column 6 Withdraw Column 7 Contribute Column 8 Balance for Earnings Calculation Column 9 Trust Fund Earnings Column 10 Year Ending Trust Fund Balance 2018 19,142 16,133 0

35,275 1,051,722 0

0 1,051,722 3,506 1,055,228 2019 100,024 60,016 0

160,040 1,055,228 195,315 0

859,913 17,198 877,112 2020 61,574 54,694 0

116,268 877,112 116,268 0

760,844 15,217 776,061 2021 46,032 48,898 0

94,930 776,061 94,930 0

681,131 13,623 694,753 2022 43,799 48,898 0

92,697 694,753 92,697 0

602,056 12,041 614,097 2023 14,516 12,882 0

27,398 614,097 27,398 0

586,699 11,734 598,433 2024 6,897 4,322 0

11,219 598,433 11,219 0

587,214 11,744 598,958 2025 6,259 4,310 0

10,569 598,958 10,569 0

588,390 11,768 600,158 2026 5,884 4,310 0

10,194 600,158 10,194 0

589,964 11,799 601,763 2027 5,884 4,310 0

10,194 601,763 10,194 0

591,570 11,831 603,401 2028 5,897 4,322 0

10,219 603,401 10,219 0

593,182 11,864 605,046 2029 5,884 4,310 0

10,194 605,046 10,194 0

594,852 11,897 606,749

2.18.071/ Attachment 1 / Page 12 of 16 Year Column 1 50.75 License Termination Cost Column 2 50.54 (bb)

Spent Fuel Management Cost Column 3 Site Restoration Column 4 Total Cost Column 5 Beginning of Year Trust Fund Balance Column 6 Withdraw Column 7 Contribute Column 8 Balance for Earnings Calculation Column 9 Trust Fund Earnings Column 10 Year Ending Trust Fund Balance 2030 5,884 4,310 0

10,194 606,749 10,194 0

596,556 11,931 608,487 2031 5,884 4,655 0

10,539 608,487 10,539 0

597,948 11,959 609,907 2032 5,897 5,529 0

11,427 609,907 11,427 0

598,481 11,970 610,450 2033 5,884 4,310 0

10,194 610,450 10,194 0

600,257 12,005 612,262 2034 5,884 4,482 0

10,366 612,262 10,366 0

601,896 12,038 613,934 2035 5,884 5,000 0

10,884 613,934 10,884 0

603,050 12,061 615,111 2036 5,897 4,839 0

10,737 615,111 10,737 0

604,375 12,087 616,462 2037 5,884 4,310 0

10,194 616,462 10,194 0

606,268 12,125 618,394 2038 5,884 4,827 0

10,711 618,394 10,711 0

607,683 12,154 619,837 2039 5,884 4,310 0

10,194 619,837 10,194 0

609,643 12,193 621,836 2040 5,897 4,322 0

10,219 621,836 10,219 0

611,617 12,232 623,849 2041 5,884 4,827 0

10,711 623,849 10,711 0

613,138 12,263 625,401 2042 5,884 4,655 0

10,539 625,401 10,539 0

614,862 12,297 627,159 2043 5,884 4,655 0

10,539 627,159 10,539 0

616,621 12,332 628,953 2044 5,897 4,322 0

10,219 628,953 10,219 0

618,734 12,375 631,109 2045 5,884 4,827 0

10,711 631,109 10,711 0

620,398 12,408 632,806 2046 5,884 4,310 0

10,194 632,806 10,194 0

622,612 12,452 635,065 2047 5,884 4,655 0

10,539 635,065 10,539 0

624,526 12,491 637,017 2048 5,897 4,667 0

10,564 637,017 10,564 0

626,452 12,529 638,981 2049 5,884 4,827 0

10,711 638,981 10,711 0

628,270 12,565 640,836 2050 5,884 4,310 0

10,194 640,836 10,194 0

630,642 12,613 643,255 2051 5,884 4,655 0

10,539 643,255 10,539 0

632,717 12,654 645,371 2052 5,897 4,667 0

10,564 645,371 10,564 0

634,807 12,696 647,503 2053 5,884 4,310 0

10,194 647,503 10,194 0

637,309 12,746 650,056 2054 5,884 4,655 0

10,539 650,056 10,539 0

639,517 12,790 652,307 2055 5,884 4,655 0

10,539 652,307 10,539 0

641,769 12,835 654,604 2056 5,897 4,322 0

10,219 654,604 10,219 0

644,385 12,888 657,273 2057 5,884 4,655 0

10,539 657,273 10,539 0

646,734 12,935 659,669 2058 5,884 4,310 0

10,194 659,669 10,194 0

649,476 12,990 662,465

2.18.071/ Attachment 1 / Page 13 of 16 Year Column 1 50.75 License Termination Cost Column 2 50.54 (bb)

Spent Fuel Management Cost Column 3 Site Restoration Column 4 Total Cost Column 5 Beginning of Year Trust Fund Balance Column 6 Withdraw Column 7 Contribute Column 8 Balance for Earnings Calculation Column 9 Trust Fund Earnings Column 10 Year Ending Trust Fund Balance 2059 5,884 4,655 0

10,539 662,465 10,539 0

651,927 13,039 664,965 2060 5,897 4,839 0

10,737 664,965 10,737 0

654,228 13,085 667,313 2061 5,884 4,310 0

10,194 667,313 10,194 0

657,119 13,142 670,262 2062 5,884 5,862 0

11,746 670,262 11,746 0

658,516 13,170 671,686 2063 4,697 0

0 4,697 671,686 4,697 0

666,989 13,340 680,329 2064 4,710 0

0 4,710 680,329 4,710 0

675,619 13,512 689,131 2065 4,697 0

0 4,697 689,131 4,697 0

684,434 13,689 698,122 2066 4,697 0

0 4,697 698,122 4,697 0

693,425 13,869 707,294 2067 4,697 0

0 4,697 707,294 4,697 0

702,596 14,052 716,648 2068 4,710 0

0 4,710 716,648 4,710 0

711,938 14,239 726,177 2069 4,697 0

0 4,697 726,177 4,697 0

721,480 14,430 735,909 2070 4,697 0

0 4,697 735,909 4,697 0

731,212 14,624 745,836 2071 4,697 0

0 4,697 745,836 4,697 0

741,139 14,823 755,962 2072 4,710 0

0 4,710 755,962 4,710 0

751,252 15,025 766,277 2073 28,634 0

325 28,959 766,277 28,959 0

737,318 14,746 752,065 2074 61,751 0

713 62,464 752,065 62,464 0

689,601 13,792 703,393 2075 160,046 0

261 160,307 703,393 160,307 0

543,086 10,862 553,947 2076 138,344 0

339 138,683 553,947 138,683 0

415,264 8,305 423,570 2077 120,920 0

379 121,298 423,570 121,298 0

302,271 6,045 308,317 2078 96,205 0

254 96,460 308,317 96,460 0

211,857 4,237 216,094 2079 18,888 0

19,836 38,724 216,094 38,724 0

177,371 3,547 180,918 2080 137 0

30,907 31,044 180,918 31,044 0

149,874 2,997 152,872 Total 1,187,994 420,250 53,014 1,661,258 1,661,258 0

38,996,799 762,407 152,872

2.18.071/ Attachment 1 / Page 14 of 16 Table 5 Definitions:

Column 1:

50.75 License Termination Cost Reflects the total annual License Termination costs in 2018 dollars at a 0.0% escalation rate Column 2:

50.54 (bb) Spent Fuel Management Cost Reflects the total annual Spent Fuel Management costs in 2018 dollars at a 0.0%

escalation rate Column 3:

Site Restoration Cost Reflects the total annual Site Restoration costs in 2018 dollars at a 0.0% escalation rate Column 4:

Total Cost Reflects the total annual License Termination costs plus total annual Spent Fuel Management costs plus total annual Site Restoration costs, all in 2018 dollars at a 0.0%

escalation rate (Column 1 + Column 2 + Column 3)

Column 5:

Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2018 dollars at a 0.0% escalation rate and 2.0% Fund Earnings Column 6:

Withdraw Reflects the annual expenditures from the Trust Fund in 2018 dollars at a 0.0%

escalation rate Column 7:

Contribute Reflects the annual contributions to the Trust Fund in 2018 dollars at a 0.0% escalation rate Column 8:

Balance for Earnings Calculation Reflects the Trust Fund balance in 2018 dollars used to calculate the Trust Fund Earnings (Column 5 - Column 6)

Column 9:

Trust Fund Earnings Reflects earnings on funds remaining in the Trust Fund. A 2.0% earnings rate is used over a 0.0% cost escalation rate. The annual 2.0% earnings are calculated on the balance after the annual expenditures are removed (Column 8

• 2.0%)

Column 10:

Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted for year-end, specified at a 0.0% escalation rate and 2.0% fund earnings in 2018 dollars (Column 5 - Column 6 + Column 9)

2.18.071/ Attachment 1 / Page 15 of 16 V.

Regulatory Activities The SFMP assumes withdrawals from the PNPS decommissioning trust fund for spent fuel management. ENOI is making a separate submittal to request an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A), which if approved, would permit the use of decommissioning trust funds for spent fuel management and site restoration expenses (Reference 7). The availability of decommissioning funding sources will be periodically revisited to ensure that withdrawals from the fund do not inhibit the ability to complete license termination and spent fuel management activities.

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

VI.

Summary The spent fuel management activities described in this Updated SFMP must be performed in conjunction with license termination activities. The annual cash flow analysis provided in Table 5 demonstrates that the PNPS decommissioning trust fund with projected earnings is sufficient to cover the estimated license termination and spent fuel management costs.

VII.

References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Spent Fuel Management Plan Submittal in accordance with 10 CFR 50.54(bb), 2.07.055, dated June 7, 2007 (ML071700121)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, Response to NRC Request for Additional Information (RAI) Regarding Pilgrim Nuclear Power Station Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb), 2.08.018, dated April 9, 2008 (ML081060520)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, Response to Request for Additional Information to Support the Review of the Pilgrim Nuclear Power Station Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) and the Preliminary Decommissioning Cost Estimate Pursuant to 10 CFR 50.75(f)(3), 2.08.052, dated October 14, 2008 (ML082910039)

4. Letter, USNRC to Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station -

Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. MD8036 and MD9416), 1.09.001, dated January 7, 2009 (ML083190292)

5. Letter, Entergy Nuclear Operations, Inc. to USNRC, Notification of Permanent Cessation of Power Operations, 2.15.080, dated November 10, 2015 (ML15328A053)

2.18.071/ Attachment 1 / Page 16 of 16

6. Letter, Entergy Nuclear Operations, Inc. to USNRC, Pilgrim Nuclear Power Station Post-Shutdown Decommissioning Activities Report, 2.18.070, dated November 16, 2018

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, Request for Exemption from 10 CFR 50.82(a)(8)(i)(A), 2.18.069, dated November 16, 2018