ML18351A491

Entergy Operations, Inc. - ISFSI Decommissioning Funding Plans (10 CFR 72.30)

ML18351A491
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	12/17/2018
From:	Couture P Entergy Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CNRO 2018-00049
Download: ML18351A491 (53)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5102 Philip L. Couture Manager, Fleet Licensing Programs 10 CFR 72.30 CNRO 2018-00049 December 17, 2018 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Subject:

ISFSI Decommissioning Funding Plans (10 CFR 72.30)

Arkansas Nuclear One, Units 1 & 2 River Bend Station Docket No.72-013 Docket No.72-049 Grand Gulf Nuclear Station Waterford Steam Electric Station, Unit 3 Docket No.72-050 Docket No.72-075

Dear Sir or Madam:

The NRC Final Rule on Decommissioning Planning was published in 76 FR 35512 on June 17, 2011 with an effective date of December 17, 2012. The final rule includes a requirement (10 CFR 72.30) for each holder of a Part 72 License to submit, for NRC review and approval, a decommissioning funding plan for purposes of decommissioning the licensees Independent Spent Fuel Storage Installation (ISFSI), and to resubmit those plans with adjustments as necessary to account for changes in costs and the extent of contamination. Entergy Operations, Inc. (Entergy) is hereby submitting (Enclosures 1 through 4) the required Plans for the subject plants.

The enclosure for each plant shows that the surpluses in the 10 CFR 50.75 Decommissioning Trust Funds exceed the estimated costs of ISFSI decommissioning, as summarized in the following table. The Trust Fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI decommissioning cost estimates (DCE) assume all costs are incurred in the year following the year in which spent fuel has been fully removed from the ISFSI. The values are reported in 2018 dollars unless noted otherwise. This letter constitutes a certification that financial assurance is provided to cover the estimated cost of ISFSI decommissioning, as indicated in the following table:

CNRO 2018-00049 Page 2 of 3 Plant Site Trust Fund Surplus DCE Arkansas Nuclear One Unit 1: $ 344M Unit 2: $ 277M

$ 14.7M Grand Gulf:

SERI* share, 90%

CE** share, 10%

$ 1,116M

$ 118M

$ 12.8M River Bend Regulated share, 70%

Non-Regulated share, 30%

$ 246M

$ 338M

$ 10.4M Waterford 3

$ 245M

$ 9.04M

• System Energy Resources, Inc.

• • Cooperative Energy The NRC is expected to issue renewed licenses for River Bend and Waterford Steam Electric Station, Unit 3 (Waterford 3) in late December 2018. The renewed licenses will extend the license terms by 20 years on each respective license. However, this submittal does not account for the license renewals.

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at (601) 368-5102.

Respectfully, Philip L. Couture PLC/chm

Enclosures:

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

2. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Grand Gulf Nuclear Station

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

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

CNRO 2018-00049 Page 3 of 3 cc:

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

ENCLOSURE 1 CNRO 2018-00049 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One to CNRO-2018-0049 Page 1 of 12 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One ISFSI Docket 72-013

1.

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

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2015.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2015-00027, dated December 17, 2015 (NRC Accession No. ML15351A523).

to CNRO-2018-0049 Page 2 of 12

2.

Spent Fuel Management Strategy The operating licenses are currently set to expire on May 20, 2034 and July 17, 2038 for Units 1 and 2, respectively. Approximately 5,610 spent fuel assemblies are currently projected to be generated over the life of the two units. Primarily because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, a second set of pads to support decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Arkansas, Inc.s (Entergy) current spent fuel management plan for the ANO spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE for the ANO fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority.

Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the ANO site in 2078.

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 Obama 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.

to CNRO-2018-0049 Page 3 of 12 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.

Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030.

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

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

3.

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

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

4.

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

Repackaging is currently assumed to occur immediately after the cessation of plant operations, while the spent fuel pools are still available and the associate fuel handling systems are operable. As such, the VSCs are not expected to be on the ISFSI pad when it is decommissioned (and are not considered in this funding plan).

to CNRO-2018-0049 Page 4 of 12 The design and capacity of the dry storage modules on the additional pads are based upon the Holtec HI-STORM 100 dry cask storage system (Version C). The system consists of a multi-purpose canister, with a nominal capacity of 24 or 32 fuel assemblies, and a steel-lined concrete storage overpack.

Entergys current spent fuel management plan for the ANO spent fuel would result in 156 spent fuel storage casks (which includes the repackaged fuel from the VSCs) being placed on three storage pads at the site (including four future pads). This projected configuration is based upon the 2030 DOE spent fuel program start with a 2033 DOE start date for ANO spent fuel, a 3,000 MTU / year pickup rate, and the current cask capacity (including expansion capability) for the ISFSI pads built to support plant operations. This scenario would allow the spent fuel storage pools to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 156 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

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

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 14 of the 156 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 177 offloaded assemblies per reactor, 24 assemblies per cask for Unit 1 and 32 assemblies per cask for Unit 2) which results in 14 overpacks. It is assumed that these are the final casks offloaded; consequently, they have the least time for radioactive decay of the neutron activation products.

6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-1 (Accession Number ML16138A100).

to CNRO-2018-0049 Page 5 of 12 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads.[7] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pads in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

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

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

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

Entergy, as licensee, will oversee the site activities.

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

Costs are reported in 2018 dollars and based upon an internal decommissioning analysis prepared for ANO in 2014. Activity costs have been escalated to 2018 dollars using the Consumer Price Index, Services.[9]

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 that affect the decommissioning cost estimate.

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-2 (Accession Number ML16138A100).

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.

to CNRO-2018-0049 Page 6 of 12 (3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

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

6.

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

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

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

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

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 2079, the year following all spent fuel removal.

7.

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

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

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

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

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

to CNRO-2018-0049 Page 7 of 12 The projected amount necessary for decommissioning ANO is $466.476 million and

$485.739 million for Units 1 and 2, respectively, based upon the NRCs latest financial assurance funding determination.[10]

Based upon ANOs decommissioning trust fund balances as of September 30, 2018 and considering the allowed real rate of return on the fund between October 1, 2018 and the assumed end of ANO station decommissioning, the trust funds will contain surpluses of $343.817 million and $276.730 million for Units 1 and 2, respectively (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2). For purposes of this submittal, it is assumed that each ANO trust fund will bear half of the ISFSI decommissioning cost.

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

10 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 16, November 2016.

to CNRO-2018-0049 Page 8 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pads (existing) 421 (3 pads) 41 to 56 No ISFSI Storage Overpack (Holtec HI-STORM 100-229)

Item Value Notes Overall Height (inches) 229 Dimensions are nominal Outside Diameter (inches) 132.0 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 166 156 spent fuel + 10 GTCC Quantity (with residual radioactivity) 14 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 39,369 Cubic feet Low-Level Radioactive Waste (packaged density) 97 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Number of Overpacks used for GTCC storage 10 No residual radioactivity to CNRO-2018-0049 Page 9 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2018 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) 453 453 1,288 Decontamination/Demolition (activated cask disposition) 376 919 1,440 5,161 35 7,931 39,369 4,231 License Termination (radiological surveys) 2,116 2,116 17,346 Subtotal 376 919 1,440 5,161 2,605 10,500 39,369 21,578 1,288 Supporting Costs NRC and NRC Contractor Fees and Costs 496 496 1,153 Insurance 137 137 Property Taxes 0

0 Plant Energy Budget 53 53 Non-Labor Overhead 11 11 Corporate A&G 111 111 Security 154 154 5,103 Entergy Oversight Staff 312 312 3,866 Subtotal 1,276 1,276 10,121 Total (w/o contingency) 376 919 1,440 5,161 3,881 11,777 39,369 21,578 11,409 Total (w/25% contingency) 470 1,149 1,800 6,451 4,851 14,721

to CNRO-2018-0049 Page 12 of 12 Table 4 (continued)

Financial Assurance - Annuity ANO-2 2038 Year Annuity:

2015

$0 2.00%

$0 2016

$0 2.00%

$0 2017

$0 2.00%

$0 2018

$410,852 2.00%

$610,505 2019

$2,169,000 2.00%

$3,159,823 2020

$2,169,000 2.00%

$3,097,866 2021

$2,169,000 2.00%

$3,037,124 2022

$2,169,000 2.00%

$2,977,572 2023

$2,169,000 2.00%

$2,919,188 2024

$2,169,000 2.00%

$2,861,949 2025

$2,169,000 2.00%

$2,805,833 2026

$2,169,000 2.00%

$2,750,816 2027

$2,169,000 2.00%

$2,696,879 2028

$2,169,000 2.00%

$2,643,999 2029

$2,169,000 2.00%

$2,592,156 2030

$2,169,000 2.00%

$2,541,329 2031

$2,169,000 2.00%

$2,491,499 2032

$2,169,000 2.00%

$2,442,646 2033

$2,169,000 2.00%

$2,394,751 2034

$2,169,000 2.00%

$2,347,795 2035

$2,169,000 2.00%

$2,301,760 2036

$2,169,000 2.00%

$2,256,628 2037

$2,169,000 2.00%

$2,212,380 2038

$2,169,000 2.00%

$2,169,000 Total:

$53,311,500 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Termination of Operations:

Real Rate of Total Accumulation Plant name:

ENCLOSURE 2 CNRO 2018-00049 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station to CNRO-2018-0049 Page 1 of 11 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station ISFSI Docket 72-050

1.

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

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2015.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2015-00027, dated December 17, 2015 (NRC Accession No. ML1535A523).

to CNRO-2018-0049 Page 2 of 11

2.

Spent Fuel Management Strategy The operating license for Grand Gulf is currently set to expire on November 1, 2044.

Approximately 10,488 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will be expanded or a second pad constructed after shutdown to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2044, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the Grand Gulf spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the Grand Gulf fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the Grand Gulf site in 2079.

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 Obama 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.

to CNRO-2018-0049 Page 3 of 11 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.

Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030 The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

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

3.

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

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

4.

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

Some of the overpacks are assumed to have residual radioactivity due to some minor level of neutron-induced activation as a result of the long-term storage of the fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and to CNRO-2018-0049 Page 4 of 11 surrounding environs meet the NRCs radiological limits established for unrestricted use, forms the basis of the ISFSI decommissioning estimate.

Entergys current spent fuel management plan for the Grand Gulf spent fuel would result in 102 spent fuel storage casks being placed on the storage pads at the site. This projected configuration is based upon the 2030 DOE spent fuel program start with a 2037 DOE start date for Grand Gulf spent fuel, a 3,000 MTU / year pickup rate, and a 48 cask capacity for the ISFSI pad built to support plant operations (a second pad of comparable size would be needed to support decommissioning). This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 102 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 5) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2044) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, two pads, will be required to accommodate the number of casks anticipated.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[6] The decommissioning estimate is based on the premise that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 12 of the 102 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 800 offloaded assemblies, 68 assemblies per cask) which results in 12 overpacks. It is assumed that these are the final casks offloaded; consequently, they have the least time for radioactive decay of the neutron activation products.

6 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-1 (Accession Number ML16138A100).

to CNRO-2018-0049 Page 5 of 11 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[7] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

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

The latest decommissioning cost study for Grand Gulf (prepared in 2017) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license.

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

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

Entergy, as licensee, will oversee the site activities.

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

Costs are reported in 2018 dollars and based upon an internal decommissioning analysis prepared for Grand Gulf in 2017.

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

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-2 (Accession Number ML16138A100).

8 Enclosure to the NRC Inspection Report 05000416/2012009 and 072000050/2012001, dated October 26, 2012, p. 7 (Accession Number ML12303A002).

9 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S. Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

to CNRO-2018-0049 Page 6 of 11 (1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

(2) Facility modifications: There have been no facility modifications 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 pads, and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (overpack disposition) developed.

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

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

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

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2080, the year following all spent fuel removal.

7.

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

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

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

to CNRO-2018-0049 Page 7 of 11 Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

The projected amount necessary for decommissioning Grand Gulf is $665.448 million, based upon the NRCs latest financial assurance funding determination.[10]

Based upon Grand Gulfs decommissioning trust fund balances as of September 30, 2018 (and considering the and the allowed real rate of return on the fund between October 1, 2018 and the assumed end of Grand Gulf station decommissioning),[11]

the trust funds will contain a $1,116.328 million surplus for System Energy Resources, Inc. and a $117.687 million surplus for Cooperative Energy (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10CFR50.75(e). This surplus is more than sufficient to fund the cost to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

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

10 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 16, November 2016.

11 No further annuity collections are assumed for Grand Gulf for this filing.

to CNRO-2018-0049 Page 8 of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad (existing) 196 61 No New ISFSI Pad (conceptual design) 240 61 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.0 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 107 102 spent fuel + 5 GTCC Quantity (with residual radioactivity) 12 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 34,404 Cubic feet Low-Level Radioactive Waste (packaged density) 94 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Number of Overpacks used for GTCC storage 5

No residual radioactivity to CNRO-2018-0049 Page 9 of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes (100%, not adjusted for ownership share)

Costs (thousands, 2018 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) 338 338 1,144 Decontamination/Demolition (activated cask disposition) 310 255 1,400 5,203 25 7,193 34,404 3,539 License Termination (radiological surveys) 1,303 1,303 9,964 Subtotal 310 255 1,400 5,203 1,666 8,834 34,404 13,503 1,144 Supporting Costs NRC and NRC Contractor Fees and Costs 486 486 1,153 Insurance 82 82 Property Taxes Plant Energy Budget 72 72 Non-Labor Overhead 8

8 Corporate A&G 188 188 Security 217 217 4,999 Entergy Oversight Staff 319 319 3,792 Subtotal 1,371 1,371 9,945 Total (w/o contingency) 310 255 1,400 5,203 3,037 10,204 34,404 13,503 11,089 Total (w/25% contingency) 388 319 1,749 6,503 3,796 12,755 to CNRO-2018-0049 Page 10 of 11 Table 3 Financial Assurance System Energy Resources, Inc.

BWR 4408

$135,000,000 132.0 1.98 0.65 2.61 2.247 3.071 0.13 2.63 0.22 13.132

% Owned:

90.00%

2.0%

26.09 1.67631 2.0%

$0 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 1,105,985,400 1,116,328,200 (10,342,800)

$1,715,231,420 Total = Total Earnings + Total Earnings for Decom

$1,596,540,105

$118,691,316 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$1,596,540,105 Step 3:

Decom Period:

Total Step 2

$0 Accumulation:

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

Total Annuity:

See Annuity Sheet 0

Total Earnings:

$952,412,981

$1,596,540,105 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Return:

Trust Fund Balance:

Entergy

$598,903,220

$952,412,981 NRC Minimum:

$665,448,022 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

11 1

2044 MWth 1986$

ECI Base Lx Plant name:

Grand Gulf Nuclear Station (SERI 90%)

Month Day Year Year of Biennial:

9 30 2018 to CNRO-2018-0049 Page 11 of 11 Table 4 Financial Assurance South Mississippi Electric Power Association BWR 4408

$135,000,000 132.0 1.98 0.65 2.61 2.247 3.071 0.13 2.63 0.22 13.132

% Owned:

10.00%

2.91%

26.09 2.11341 2.91%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 116,537,964 117,687,164 (1,149,200)

$184,231,966 Total = Total Earnings + Total Earnings for Decom

$171,483,404

$12,748,562 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$171,483,404 Step 3:

Decom Period:

Total Step 2

$0 Accumulation:

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

Total Annuity:

See Annuity Sheet 0

$0 Total Earnings:

$81,140,668

$171,483,404 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Return:

Trust Fund Balance:

Entergy

$66,544,802

$81,140,668 NRC Minimum:

$665,448,022 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

11 1

2044 MWth 1986$

ECI Base Lx Plant name:

Grand Gulf Nuclear Station (Cooperative Energy 10%)

Month Day Year Year of Biennial:

9 30 2018

ENCLOSURE 3 CNRO 2018-00049 10 CFR 72.30 ISFSI Decommissioning Funding Plan River Bend Station to CNRO-2018-0049 Page 1 of 12 10 CFR 72.30 ISFSI Decommissioning Funding Plan River Bend Station ISFSI Docket 72-049

1.

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

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2015.[2]

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

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2015-00027, dated December 17, 2015 (NRC Accession No. ML15351A523).

to CNRO-2018-0049 Page 2 of 12

2.

Spent Fuel Management Strategy The operating license for River Bend is currently set to expire on August 29, 2025.3 Approximately 5,492 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will be expanded to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[4]).

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the River Bend spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the River Bend fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[5] the spent fuel is projected to be fully removed from the River Bend site in 2065.

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 Obama administrations Blue Ribbon Commission and as a framework for moving toward a sustainable program to 3

A 20-year license renewal is expected to be issued by the NRC in late December 2018, but that renewal is not assumed in this filing.

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.

to CNRO-2018-0049 Page 3 of 12 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.

Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030 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.

6 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S. DOE, January 11, 2013.

to CNRO-2018-0049 Page 4 of 12

4.

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

Entergys current spent fuel management plan for the River Bend spent fuel would result in 81 spent fuel storage casks being placed on the storage pad at the site. This projected configuration is based upon the 2030 DOE spent fuel program start with a 2037 DOE start date for River Bend spent fuel, a 3,000 MTU / year pickup rate, and a 44 cask capacity for the ISFSI pad built to support plant operations (a second pad of comparable size would be needed to support decommissioning). This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 81 casks projected to be on the ISFSI pad after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 4) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2025) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, two pads, will be required to accommodate the number of casks anticipated.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[7] The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 10 of the 81 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 624 offloaded assemblies, 68 assemblies per cask) which results in 10 overpacks. It is assumed that these are the final casks offloaded; consequently, they have the least time for radioactive decay of the neutron activation products.

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-1 (Accession Number ML16138A100).

to CNRO-2018-0049 Page 5 of 12 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[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 pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

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

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

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

Entergy, as licensee, will oversee the site activities.

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

Costs are reported in 2018 dollars and based upon an internal decommissioning analysis prepared for River Bend in 2018.

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.

8 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-2 (Accession Number ML16138A100).

9 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S. Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

to CNRO-2018-0049 Page 6 of 12 (2) Facility modifications: There have been no facility modifications 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.

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 2066, the year following all spent fuel removal.

7.

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

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

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

Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, to CNRO-2018-0049 Page 7 of 12 these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

The projected amount necessary for decommissioning River Bend is $649.768 million, based upon the NRCs latest financial assurance funding determination.[10]

Based upon Entergys decommissioning trust fund balances for River Bend as of September 30, 2018 (and considering the schedule of remaining principal payments into the decommissioning fund, and the allowed real rate of return on the fund between October 1, 2018 and the assumed end of River Bend Station decommissioning), the River Bend regulated trust funds will contain a $245.662 million surplus and the River Bend non-regulated11 trust funds will contain a

$338.187 million surplus (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10 CFR 50.75(e). These surplus values are more than sufficient to fund the cost to complete the decommissioning of the ISFSI (estimated cost provided in Table 2).

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

10 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 16, November 2016.

11 The licensee refers to the 30% share of River Bend formerly owned by Cajun Electric Cooperative as non-regulated, because at the time the licensee acquired the 30% share it was not governed by rate regulation. The 30% share is now governed by Federal Energy Regulatory Commission tariffs, and as such, is not non-regulated, but the naming convention has continued to distinguish the two shares.

to CNRO-2018-0049 Page 8 of 12 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad (existing) 210 61 No New ISFSI Pad (conceptual design) 210 61 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.0 Dimensions are nominal Inside Diameter (inches) 73.5 Dimensions are nominal Quantity (total) 85 81 spent fuel + 4 GTCC Quantity (with residual radioactivity) 10 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 20,058 Cubic feet Low-Level Radioactive Waste (packaged density) 83 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Number of Overpacks used for GTCC storage 4

No residual radioactivity to CNRO-2018-0049 Page 9 of 12 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2018 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) 300 300 1,096 Decontamination/Demolition (activated cask disposition) 262 215 1,194 3,794 25 5,490 50,626 2,965 License Termination (radiological surveys) 1,289 1,289 9,948 Subtotal 262 215 1,194 3,794 1,614 7,078 50,626 12,913 1,096 Supporting Costs NRC and NRC Contractor Fees and Costs 506 506 1,153 Insurance 80 80 Property Taxes 15 15 Plant Energy Budget 47 47 Non-Labor Overhead 1

1 Corporate A&G 99 99 Security 215 215 4,999 Entergy Oversight Staff 311 311 3,792 Subtotal 1,275 1,275 9,945 Total (w/o contingency) 262 215 1,194 3,794 2,889 8,353 50,626 12,913 11,041 Total (w/25% contingency) 328 268 1,492 4,742 3,611 10,441 to CNRO-2018-0049 Page 10 of 12 Table 3 Financial Assurance BWR 3091

$131,819,000 132.0 1.98 0.65 2.61 2.247 3.071 0.13 2.63 0.22 13.132

% Owned:

70.00%

2.00%

6.91 1.14673 2.00%

$88,089,863

$88,089,863 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 238,353,197 245,661,897 (7,308,700)

$66,479,570

$700,499,564 Total = Total Earnings + Total Earnings for Decom

$590,146,808

$43,873,186 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$590,146,808 Step 3:

Decom Period:

Total Step 2 Accumulation:

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

Total Annuity:

See Annuity Sheet 8

Total Earnings:

$437,816,394

$502,056,945 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Return:

Trust Fund Balance:

Entergy

$454,837,666

$437,816,394 NRC Minimum:

$649,768,095 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

8 29 2025 MWth 1986$

ECI Base Lx Plant name:

River Bend (Regulated 70%)

Month Day Year Year of Biennial:

9 30 2018 to CNRO-2018-0049 Page 11 of 12 Table 3 (continued)

Financial Assurance -

Annuity 2025 Year LPSC PUCT FERC Annuity:

2016

$0

$0

$0

$0 2.0%

$0 2017

$0

$0

$0

$0 2.0%

$0 2018

$2,249,000

$281,500

$28,229

$2,558,729 2.0%

$2,939,175 2019

$8,996,000

$1,126,000

$112,914

$10,234,914 2.0%

$11,526,176 2020

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,623,965 2021

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,376,436 2022

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$12,133,761 2023

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$11,895,844 2024

$10,195,000

$1,126,000

$112,914

$11,433,914 2.0%

$11,662,592 2025

$11,693,000

$1,126,000

$112,914

$12,931,914 2.0%

$12,931,914 Total:

$88,089,863 Accumulation During Decomm Period 2026

$11,693,000

$1,126,000

$112,914

$12,931,914

$12,931,914 2027

$11,693,000

$1,126,000

$112,914

$12,931,914

$12,931,914 2028

$11,693,000

$1,126,000

$112,914

$12,931,914

$12,931,914 2029

$11,693,000

$1,126,000

$112,914

$12,931,914

$12,931,914 2030

$13,513,000

$1,126,000

$112,914

$14,751,914

$14,751,914 2031

$0

$0

$0

$0

$0 2032

$0

$0

$0

$0

$0 2033

$0

$0

$0

$0

$0 2034

$0

$0

$0

$0

$0 Total:

$66,479,570 Total Accumulation = Annuity x (1+RRR)^Years left from Accum Termination of Operations:

Real Rate of Total Accumulation Plant name:

River Bend Station (Regulated 70%)

to CNRO-2018-0049 Page 12 of 12 Table 4 Financial Assurance BWR 3091

$131,819,000 132.0 1.98 0.65 2.61 2.247 3.071 0.13 2.63 0.22 13.132

% Owned:

30.00%

2%

6.91 1.14673 2%

2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 335,054,494 338,186,794 (3,132,300)

$533,117,222 Total = Total Earnings + Total Earnings for Decom

$496,226,349

$36,890,873 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

$496,226,349 Step 3:

Decom Period:

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

$0 6.913926941

$0 Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$432,731,851

$496,226,349 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

$194,930,428

$432,731,851 NRC Minimum:

$649,768,095 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

8 29 2025 MWth 1986$

ECI Base Lx Plant name:

River Bend (Non-Regulated 30%)

Month Day Year Year of Biennial:

9 30 2018

ENCLOSURE 4 CNRO 2018-00049 10 CFR 72.30 ISFSI Decommissioning Funding Plan Waterford Steam Electric Station, Unit 3 to CNRO-2018-0049 Page 1 of 11 10 CFR 72.30 ISFSI Decommissioning Funding Plan Waterford Steam Electric Station, Unit 3 ISFSI Docket 72-075

1.

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

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

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2015.[2]

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

in an amount reflecting:

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

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

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

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

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

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station, CNRO-2015-00027, dated December 17, 2015 (NRC Accession No. ML15351A523).

to CNRO-2018-0049 Page 2 of 11

2.

Spent Fuel Management Strategy The operating license for Waterford 3 is currently set to expire on December 18, 2024.3 Approximately 2,558 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will have sufficient capacity to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[4]).

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

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the Waterford 3 spent fuel is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository),

and 2) expectations for spent fuel receipt by the DOE for the Waterford 3 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 Waterford 3 site in 2066.

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 Obama administrations Blue Ribbon Commission and as a framework for moving toward a sustainable program to 3

A 20-year license renewal is expected to be issued by the NRC in late December 2018, but that renewal is not assumed in this filing.

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.

to CNRO-2018-0049 Page 3 of 11 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.

Although the DOE proposed it would start fuel acceptance in 2025, no progress has been made in the repository program since DOEs 2013 strategy was issued except for the completion of the Yucca Mountain safety evaluation report. Because of this continued delay, this estimate revises the assumed start date for DOE fuel acceptance from 2025 to 2030.

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.

6 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, U.S. DOE, January 11, 2013.

to CNRO-2018-0049 Page 4 of 11

4.

ISFSI Description The design and capacity of the Waterford 3 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 Waterford 3 spent fuel would result in 80 spent fuel storage casks being placed on the storage pad at the site. This projected configuration is based upon the 2030 DOE spent fuel program start with a 2037 DOE start date for Waterford 3 spent fuel, a 3,000 MTU / year pickup rate, and a 72 cask capacity for the ISFSI pad built to support plant operations (a second smaller pad would be needed to support decommissioning). This scenario would allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.

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

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

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current license (2024) and the DOEs spent fuel acceptance assumptions, as previously described. For purposes of this analysis, two pads, will be required to accommodate the number of casks anticipated.

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

7 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-1 (Accession Number ML16138A100).

to CNRO-2018-0049 Page 5 of 11 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pad.[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 pad will not be contaminated. As such, only verification surveys are included for the pad in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

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

The current ISFSI area was not part of the original plant Protected Area (the Protected Area was expanded to include the ISFSI area). The latest decommissioning cost study for Waterford 3 (prepared in 2015) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license. Therefore, there is no allowance for the remediation of any contaminated soil in the estimate to decommissioning the ISFSI.

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

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

Entergy, as licensee, will oversee the site activities.

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

Costs are reported in 2018 dollars and based upon an internal decommissioning analysis prepared for Waterford 3 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.

8 HI-STORM FSAR, Holtec International, Report HI-2002444, Rev. 13, at page 2.4-2 (Accession Number ML16138A100).

9 Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness, U.S. Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

to CNRO-2018-0049 Page 6 of 11 (2) Facility modifications: There have been no facility modifications 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.

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 2067, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at Waterford 3 are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract.

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

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

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

to CNRO-2018-0049 Page 7 of 11 The projected amount necessary for decommissioning Waterford 3 is $501.851 million, based upon the NRCs latest financial assurance funding determination.[10]

Based upon Entergys decommissioning trust fund balance for Waterford 3 as of September 30, 2018 (and considering the schedule of remaining principal payments into the decommissioning fund, and the allowed real rate of return on the fund between October 1, 2018 and the assumed end of Waterford 3 station decommissioning), the trust fund will contain a $244.697 million surplus (refer to Table 3) beyond the NRC minimum funding formula provided in 10 CFR 50.75(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 Report on Waste Burial Charges, U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 16, November 2016.

to CNRO-2018-0049 Page 8 of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pad (existing) 154 120 No ISFSI Storage Overpack Item Value Notes Overall Height (inches) 218 Dimensions are nominal Outside Diameter (inches) 132.0 Dimensions are nominal Inside Diameter (inches) 73.50 Dimensions are nominal Quantity (total) 86 80 spent fuel + 6 GTCC Quantity (with residual radioactivity) 7 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 20,094 Cubic feet Low-Level Radioactive Waste (packaged density) 94 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Number of Overpacks used for GTCC storage 6

No residual radioactivity to CNRO-2018-0049 Page 9 of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2018 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) 300 300 1,096 Decontamination/Demolition (activated cask disposition) 188 151 875 3,165 25 4,403 20,094 2.067 License Termination (radiological surveys) 1,346 1,346 9,768 Subtotal 188 151 875 3,165 1,671 6,049 20,094 11,835 1,096 Supporting Costs NRC and NRC Contractor Fees and Costs 485 485 1,153 Insurance 73 73 Property Taxes Plant Energy Budget 69 69 Non-Labor Overhead 11 11 Corporate A&G 78 78 Security 120 120 3,457 Entergy Oversight Staff 348 348 3,803 Subtotal 1,184 1,184 8,413 Total (w/o contingency) 188 151 875 3,165 2,855 7,232 20,094 11,835 9,509 Total (w/25% contingency) 234 188 1,093 3,956 3,569 9,040 to CNRO-2018-0049 Page 10 of 11 Table 3 Financial Assurance PWR 3716

$105,000,000 132.0 1.98 0.65 2.61 2.247 3.071 0.13 2.59 0.22 12.471

% Owned:

100.00%

2%

6.22 1.13101 2%

$50,677,433 2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 235,656,559 244,696,559 (9,040,000)

$54,581,000

$746,548,350 Total = Total Earnings + Total Earnings for Decom

$644,084,298

$47,883,052 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Accumulation during Decom Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Return:

Total Earnings for Decom:

Total Earnings:

Total Step 1 + Step 2

$644,084,298 Step 3:

Decom Period:

Total Step 2

$50,677,433 Accumulation:

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

Total Annuity:

See Annuity Sheet 7

Total Earnings:

$524,667,591

$593,406,865 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

Real Rate of Return per Years Left in License Total Real Rate of Return:

Trust Fund Balance:

Entergy

$501,851,791

$524,667,591 NRC Minimum:

$501,851,791 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

12 18 2024 MWth 1986$

ECI Base Lx Plant name:

Waterford 3 Month Day Year Year of Biennial:

9 30 2018 to CNRO-2018-0049 Page 11 of 11 Table 3 (continued)

Financial Assurance - Annuity Waterford 3 2025 Year LPSC CNO Annuity:

2016

$0

$0

$0 2.00%

$0 2017

$0

$0

$0 2.00%

$0 2018

$1,672,000

$33,250

$1,705,250 2.00%

$1,958,796 2019

$6,688,000

$133,000

$6,821,000 2.00%

$7,681,554 2020

$7,580,000

$151,000

$7,731,000 2.00%

$8,535,649 2021

$7,580,000

$151,000

$7,731,000 2.00%

$8,368,283 2022

$7,580,000

$151,000

$7,731,000 2.00%

$8,204,199 2023

$7,580,000

$151,000

$7,731,000 2.00%

$8,043,332 2024

$7,580,000

$151,000

$7,731,000 2.00%

$7,885,620 Total:

$50,677,433 Accumulation During Decomm Period 2025

$8,867,000

$0

$8,867,000 2026

$8,867,000

$0

$8,867,000 2027

$8,867,000

$0

$8,867,000 2028

$8,867,000

$0

$8,867,000 2029

$8,867,000

$0

$8,867,000 2030

$10,246,000

$0

$10,246,000 2031 0

$0

$0 Total:

$54,581,000 Plant name: Waterford Generating Station, Unit 3 Termination of Operations:

Real Rate of Total Accumulation Total Accumulation = Annuity x (1+RRR)^Years left from Accum Waterford Steam Electric Station, Unit 3