CNRO-2019-00005, Stations - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) - Entergy Nuclear Operations, Inc

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

ML19087A318
Person / Time
Site:	Palisades, Indian Point, Pilgrim, Vermont Yankee, Big Rock Point
Issue date:	03/28/2019
From:	Halter M Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2019-00005
Download: ML19087A318 (42)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.75(f)(1)

CNRO-2019-00005 10 CFR 50.82(a)(8)(v)

March 28, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

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

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

Dear Sir or Madam:

10 CFR 50.75(f)(1) requires each power reactor licensee to report to the NRC by March 31, 1999, and every two years thereafter with certain exceptions, on the status of its decommissioning funding for each reactor, or share of a reactor, that it owns. 10 CFR 50.82(a)(8)(v) requires licensees of shutdown sites to report to the NRC annually, by March 31, on the status of decommissioning financial assurance for those sites. On behalf of Entergy Nuclear Indian Point 2, LLC (Indian Point 1 & 2), Entergy Nuclear Indian Point 3, LLC, Entergy Nuclear Vermont Yankee, LLC, Entergy Nuclear Generation Company (Pilgrim Station), and Entergy Nuclear Palisades, LLC (Palisades and Big Rock Point), Entergy Nuclear Operations, Inc. (ENOI) hereby submits the information requested for power reactors operated by ENOI.1 1 In January 2019, Entergy Nuclear Vermont Yankee, LLC was acquired by NorthStar Nuclear Decommissioning Company, LLC, and after the acquisition, Entergy Nuclear Operations, Inc. (ENOI) was no longer the Licensee for Vermont Yankee. ENOI is submitting this report pertaining to Vermont Yankee because as of December 31, 2018, ENOI was the Licensee for the plant. Following the acquisition, ENOI is no longer responsible for Vermont Yankee decommissioning plans.

CNRO-2019-00005 Page 2 of 4 The reports provided in Attachments 1 through 14 for the licensed facilities addressed by this filing, were prepared in accordance with NUREG-1307 (Reference 1) and NRC Regulatory Issue Summary 2001-07 (Reference 2). Attachments 12, 13, and 14 are updated site specific decommissioning cost estimates for Indian Point Unit 1, Vermont Yankee, and Pilgrim, respectively. The Minimum Funding Assurance calculation worksheets, (not required for this filing) derived from LIC-205, Rev. 4, are provided in Attachment 15 for the convenience of the reviewer.

The estimated minimum decommissioning fund values were determined using the NRCs methodology in NUREG-1307, Rev 17 (Reference 1).

The trust fund amounts reported for each facility in the responses to item 3 represent the market value of decommissioning trust funds as of December 31, 2018 net of any material current income tax liability on realized gains, interest, dividends and other income of the trusts. The trusts for the following plants had estimated balances on their 2018 tax liabilities, not reflected in the trust fund balances, as follows (in thousands):

Indian Point 1

$ 0 Indian Point 2

$ 0 Indian Point 3

$ 0 Vermont Yankee $ 0 Pilgrim

$ 20,330 Palisades

$ 0 In accordance with guidance provided by the NRC Staff in April 2014 requests for additional information (Accession No. ML14120A273) that future 10 CFR 50.75(f) reports should clearly delineate estimated reactor and ISFSI decommissioning costs, the information in Attachments 1, 2, 3, 5, 7, 9, and 11 includes line item 2 identifying the ISFSI decommissioning obligation, from the most recent 10 CFR 72.30 filing. This obligation is also accounted for in the Excess/Shortfall calculations for each plant in Attachment 15 The aforementioned worksheets, using the December 31, 2018 trust fund balances and parent guarantee amounts, indicate that all of the plants covered by this submittal met or exceeded the NRCs funding requirements. Accordingly, the licensees conclude that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the plants covered by this submittal.

There are no new commitments made in this letter. If you have any questions, please contact me at 601-368-5573.

Respectfully, MKH/LJS/gpn

CNRO-2019-00005 Page 3 of 4 Attachments:

1.

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

2.

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

3.

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

4.

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

5.

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

6.

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

7.

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

8.

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

9.

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

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

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

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

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

14. Entergy Nuclear Operations, Inc. Pilgrim Annual Cash Flow Analysis

15. Entergy Nuclear Operations, Inc. Minimum Financial Assurance Calculation Worksheets

References:

1) NUREG-1307, Report on Waste Burial Charges, Revision 17, dated February 2019

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

CNRO-2019-00005 Page 4 of 4 cc:

USNRC Regional Administrator, Region I USNRC Regional Administrator, Region III USNRC Project Manager, Indian Point 1 USNRC Project Manager, Indian Point 2 / 3 USNRC Project Manager, Palisades USNRC Project Manager, Pilgrim USNRC Project Manager, Vermont Yankee Ms. Margaret OBanion, Project Manager, NRC/NRR/DORL USNRC Resident Inspector, Indian Point 2 / 3 USNRC Resident Inspector, Palisades USNRC Resident Inspector, Pilgrim USNRC Resident Inspector, Vermont Yankee

CNRO-2019-00005 Page 1 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

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

1. Minimum Financial Assurance (MFA)

2. ISFSI Obligation as of 12/31/18

$583.42million [Note 1]

$1.69 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/18

$471.20 million

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

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

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478). Total ISFSI obligation for Indian Point 1&2 is

$10.15M with $8.46M attributable to Indian Point 2 and $1.69M attributable to Indian Point 1 (totals may not foot due to rounding).

CNRO-2019-00005 Page 2 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

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

1. Cumulative decommissioning spending

$115.89million [Note 1]

2. 2018 decommissioning spending

$8.12million [Note 1]

3.

Fund Balance See above in 10 CFR 50.75 information

4.

No other financial assurance mechanism is being relied upon, but costs through 12/31/2018 have been funded by operations, and not the decommissioning fund.

5.

Estimated costs to complete from latest estimate

$583.42million [Note 2]

6.

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

7.

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

8.

Any material changes to trust agreements See above in 10 CFR 50.75 information Note 1: Entergy Nuclear Operations, Inc. (Entergy) does not possess records that would permit determination of charges to Indian Point 1 (IP1) prior to its acquisition in September 2001 by Entergy Nuclear Indian Point 2, LLC. The costs presented here represent those costs charged in 2018 and the total costs that have been assigned to IP1 since 2001. Entergy has not fully determined what portion of those costs would be considered decommissioning costs as that term is defined in 10 CFR 50.2.

Cumulative and 2018 decommissioning spending only consists of costs related to license termination.

Note 2: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Attachment 12 (Calculation of the NRC Minimum Amount is provided in Attachment 4). This estimate does not include 2018 spending because current costs are being paid out of operating funds.

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 2

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2018$)

$521.83 million [Note 1]

2. ISFSI Obligation as of 12/31/18

3. Decommissioning Trust Fund Total as of 12/31/18

$8.46million [Note 2]

$598.41 million [Note 3]

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

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

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478). Total ISFSI obligation for Indian Point 1&2 is

$10.15M with $8.46M attributable to Indian Point 2 and $1.69M attributable to Indian Point 1 (totals may not foot due to rounding).

Note 3: Includes provisional fund balance of $33.16 million.

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 3

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2018$)

$521.83 million [Note 1]

2. ISFSI Obligation as of 12/31/18

3. Decommissioning Trust Fund Total as of 12/31/18

$10.15 million [Note 2]

$780.59 million

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

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

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2018 (Accession No. ML18351A478)

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Indian Point For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

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

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

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

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

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

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

Factor L=Labor (North) 2.952 E=Energy (PWR) 2.373 B=Waste Burial-Vendor (PWR) 12.8534 PWR Escalation Factor:

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

5.05160 1986 PWR Base Year $ Escalated:

Indian Point 1: $85,560,000

• Factor=

$432,214,534 Indian Point 2 & 3: $103,300,800

• Factor=

$521,833,884 2

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2018) 3 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2018) 4 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2.1 (2019)

CNRO-2019-00005 Page 1 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding Vermont Yankee For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

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

1. Minimum Financial Assurance (MFA)

$668.37 million [Note 1]

2. ISFSI Obligation as of 12/31/18

3. Decommissioning Trust Fund Total as of 12/31/18

$6.56 million [Note 2]

$498.43 million

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

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

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2018 (Accession No. ML18351A478)

CNRO-2019-00005 Page 2 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding Vermont Yankee For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

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

1. Cumulative decommissioning spending through 12/31/2018

$ 189.53 million [Note1]

2. 2018 decommissioning spending

$ 46.81 million [Note2]

3.

Fund Balance See above in 10 CFR 50.75 information

4.

No other financial assurance mechanism is being relied upon.

5.

Estimated costs to complete from latest estimate

$ 668.37 million

6.

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

7.

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

8.

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

Note 2: This estimate only includes 2018 decommissioning costs. 2014 through 2017 qualified costs are included in item 1 and have been reimbursed in 2018.

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Vermont Yankee For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

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

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

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

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

Factor L=Labor (North) 2.951 E=Energy (BWR) 2.392 B=Waste Burial-Vendor (BWR) 13.4223 BWR Escalation Factor:

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

5.18002 1986 BWR Base Year $ Escalated:

$121,208,000

• Factor=

$627,859,619 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2018) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2018) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2.1 (2019)

CNRO-2019-00005 Page 1 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Pilgrim For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Pilgrim Nuclear Power Station

1. Minimum Financial Assurance (MFA)

2.

ISFSI Obligation as of 12/31/18

$1,188.0 million [Note 1]

$9.42 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/18 as of 02/28/19

$1,027.7 million

$1,043.4 million

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

Any material changes to trust agreements None Note 1: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis provided in Attachment 14 (Calculation of the NRC Minimum Amount is provided in Attachment 8).

Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2018 (Accession No. ML18351A478)

CNRO-2019-00005 Page 2 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Pilgrim For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

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

1. Cumulative decommissioning spending through 12/31/2018

$ 8.25 million [Note 1]

2. 2018 decommissioning spending

$ 5.99 million

3.

Fund Balance See above in 10 CFR 50.75 information

4.

No other financial assurance mechanism is being relied upon.

5.

Estimated costs to complete from latest estimate

$ 1,188.0 million

6.

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

7.

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

8.

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

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Pilgrim For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

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

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

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

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

Factor L=Labor (North) 2.951 E=Energy (BWR) 2.392 B=Waste Burial-Vendor (BWR) 13.4223 BWR Escalation Factor:

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

5.18002 1986 BWR Base Year $ Escalated:

$122,252,000

• Factor=

$633,267,558 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2018) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2018) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2.1 (2019)

CNRO-2019-00005 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Plant Name: Palisades Nuclear Plant

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2018$)

2.

ISFSI Obligation as of 12/31/18

$480.43 million [Note 1]

$8.00 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/18

$443.63 million

4.

A schedule of the annual amounts remaining to be collected None

5.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections 2% annual real rate of return per 10 CFR 50.75(e)(1)(i)

6.

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

None

7.

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

8.

Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Attachment 10 Note 2: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2018 (Accession No. ML18351A478)

CNRO-2019-00005 0 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

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

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

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

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

Factor L=Labor (Midwest) 2.751 E=Energy (PWR) 2.372 B=Waste Burial-Vendor (PWR) 12.8533 PWR Escalation Factor:

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

4.92383 1986 PWR Base Year $ Escalated:

$97,572,000

• Factor=

$480,428,114 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000230i (4th Quarter 2018) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2018) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2.1 (2019)

CNRO-2019-00005 1 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Plant Name: Big Rock Point ISFSl

1.

Amount of decommissioning funds required from most recent estimate (2018$).

$2.57 million [Note 1]

2.

Decommissioning Funding Assurance Method.

Parent Guarantee ($5 million)

3.

A schedule of the annual amounts remaining to be collected None

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections Escalation rate: CPIU Rate of earnings: n/a

5.

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

None

6.

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

7.

Any material changes to trust agreements None Note 1: From Entergys ISFSI Decommissioning Funding Plans Pursuant to 10 CFR 72.30, December 17, 2018 (Accession No. ML18351A478), escalated for inflation.

CNRO-2019-00005 2 Page 1 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

On October 23, 2008, Entergy Nuclear Indian Point 2, LLC (ENIP2) submitted a preliminary decommissioning cost analysis to the NRC in conjunction with its spent fuel management plan under 10 CFR 50.75(f)(3) and 10 CFR 50.54(bb) (Accession No. ML083040378, as supplemented by ENIP2's reply to RAIs on July 15, 2009 (Accession No. ML092050204)). The preliminary decommissioning cost analysis contained separate site-specific decommissioning cost estimates for Indian Point 1 and Indian Point 2. The estimates were subsequently found to be reasonable by the NRC on March 17, 2010 (Accession No. ML100280544).

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

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

ENIP2 has determined that use of a SAFSTOR analysis shows that there is presently reasonable assurance that adequate funds will be available for the decommissioning process in compliance with NRC decommissioning funding assurance rules.

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site-specific estimate under § 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." ENIP2 understands that a facility-specific analysis may be used for demonstrating the adequacy of decommissioning funds, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2) as the basis for justifying a higher than minimum funding level." (Regulatory Guide 1.159 Rev. 2, Section 1.1.1) ENIP2 also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis.

The updated Indian Point 1 site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until 2073, at which time the plant decommissioning will be completed and the site released for alternative use without restriction. Table 12-1 below provides the annual license termination costs computed in the updated estimate. These costs to date have been funded by operations, and not by the decommissioning fund. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

CNRO-2019-00005 2 Page 2 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 12-1 NRC License Termination Cost

($ millions) 2018 $ Unit 1 Radiological Ending DTF Balance 2019 1.029 479.599 2020 4.127 485.063 2021 4.116 490.649 2022 4.116 496.346 2023 4.116 502.157 2024 4.127 508.073 2025 4.116 514.119 2026 4.116 520.285 2027 4.116 526.575 2028 4.127 532.980 2029 4.116 539.523 2030 4.116 546.198 2031 4.116 553.006 2032 4.127 559.939 2033 4.116 567.022 2034 4.116 574.247 2035 4.116 581.616 2036 4.127 589.121 2037 4.116 596.788 2038 4.116 604.607 2039 4.116 612.584 2040 4.127 620.708 2041 4.116 629.007 2042 4.116 637.471 2043 4.116 646.105 2044 4.127 654.900 2045 4.116 663.882 2046 4.116 673.043 2047 4.116 682.389 2048 4.127 691.909 2049 4.116 701.632 2050 4.116 711.548 2051 4.116 721.663 2052 4.127 731.970 2053 4.116 742.493 2054 4.116 753.227 2055 4.116 764.176

CNRO-2019-00005 2 Page 3 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 12-1 NRC License Termination Cost

($ millions) 2018 $ Unit 1 Radiological Ending DTF Balance 2056 4.127 775.332 2057 4.116 786.723 2058 4.116 798.342 2059 4.116 810.193 2060 4.127 822.270 2061 4.116 834.599 2062 4.116 847.175 2063 4.116 860.003 2064 4.127 873.076 2065 30.136 860.401 2066 65.661 811.949 2067 109.504 718.684 2068 116.483 616.574 2069 16.838 612.068 2070 16.711 607.598 2071 16.711 603.039 2072 16.757 598.343 2073 8.241 602.069 Total 583.418

CNRO-2019-00005 2 Page 4 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

As can be seen from the information provided in Table 12-1, the required funding for SAFSTOR decommissioning, $583.42 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $432.21 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2018 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $602.07 million surplus exists at the end of the decommissioning project. The present value of this surplus is $206.7 million in 2019 dollars ($602.07 million/(1.02)(2073-2019)).

This surplus is sufficient to cover the spent fuel management costs for Indian Point 1 as reflected in Reference 1, Attachment 1, of approximately $55 million, as well as ISFSI decommissioning costs shown in Attachment 1 from this filing, if not paid for by spent fuel litigation proceeds. Accordingly, ENIP2 concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Indian Point 1.

Reference 1: Letter, Status of Funding for Managing Irradiated Fuel For Year Ending December 31, 2018 - 10 CFR 50.82(a)(8)(vii), CNRO-2019-00006, filed March 2019.

CNRO-2019-00005 3 Page 1 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Vermont Yankee Nuclear Power Station (Vermont Yankee) permanently ceased operations on December 29, 2014. In January 2019, Entergy Nuclear Vermont Yankee, LLC was acquired by NorthStar Nuclear Decommissioning Company, LLC, and after the acquisition, Entergy Nuclear Operations, Inc. (ENOI) was no longer the Licensee for Vermont Yankee. ENOI is submitting this report pertaining to Vermont Yankee because as of December 31, 2018, ENOI was the Licensee for the plant. Following the acquisition, ENOI is no longer responsible for Vermont Yankee decommissioning plans.

The Vermont Yankee decommissioning trust fund balance was approximately $498.4 million as of December 31, 2018. Tables 3.4 and 3.5 of the site-specific decommissioning cost estimate (Reference 1, Enclosure) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. Subsequent to the filing of Reference 1, two significant schedule changes were submitted to reflect the accelerated completion of the dry fuel loading campaign (Reference 2) and preparations for dismantling and decontamination occurring in 2017-2018 versus 2068-2069 (Reference 3). A cash flow analysis utilizing this annual expenditure and significant schedule change information is included as Table 13-1.

The cash flow analysis demonstrates that the Vermont Yankee decommissioning trust fund was sufficiently funded for all license termination activities and certain spent fuel management activities (i.e., operational costs) as of December 31, 2018. As discussed in the Irradiated Fuel Management Program Update (Reference 4) costs related to spent fuel management operations (e.g., operations and maintenance costs for the spent fuel pool and Independent Spent Fuel Storage Installation, totaling approximately $148 million, Table 13-1 Column 2, minus Column 3 amounts funded by external credit facilities) were planned to be funded from the decommissioning trust fund. This information also reflects the significant schedule change submitted for completion of the dry fuel storage campaign in 2018 (Reference 2). ENOI obtained an exemption that allows the use of trust funds for spent fuel management activities (Reference 5).

ENOI has determined that use of a SAFSTOR analysis shows that as of December 31, 2019 there was reasonable assurance that adequate funds will be available for the decommissioning process in compliance with NRC decommissioning funding assurance rules.

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site-specific estimate under § 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." ENOI understands that a facility-specific analysis may be used for demonstrating the adequacy of decommissioning funds, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2) as the basis for justifying a higher than minimum funding level." (Regulatory Guide 1.159 Rev. 2, Section 1.1.1.) ENOI also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis. An updated decommissioning estimate was provided with the licensees Post Shutdown Decommissioning Activities Report on December 19, 2014 (Reference 1).

CNRO-2019-00005 3 Page 2 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

The updated Vermont Yankee site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until approximately 2075, at which time the plant decommissioning will be completed and the site released for alternative use without restriction. Table 13-1 below provides the annual license termination and spent fuel management costs computed in the updated estimate. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

Thus, considering the fund balance of $498.4 million, as of December 31, 2018, and projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), the trust fund was expected to have an excess of $276.0 million after completion of license termination and the operational spent fuel management activities that will be funded by the trust fund.

REFERENCES:

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

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

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

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

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

CNRO-2019-00005 3 Page 3 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2019 5,727 4,356 0

10,083 498,432 10,083 0

9,767 498,116 2020 5,672 4,356 10,028 498,116 10,028 0

9,762 497,850 2021 5,672 4,356 10,028 497,850 10,028 0

9,756 497,578 2022 3,963 4,356 8,319 497,578 8,319 0

9,785 499,045 2023 3,963 4,356 8,319 499,045 8,319 0

9,815 500,541 2024 3,963 4,368 8,331 500,541 8,331 0

9,844 502,054 2025 3,898 4,356 8,254 502,054 8,254 0

9,876 503,677 2026 4,055 4,356 8,411 503,677 8,411 0

9,905 505,171 2027 4,110 4,356 8,466 505,171 8,466 0

9,934 506,639 2028 4,064 4,368 8,432 506,639 8,432 0

9,964 508,171 2029 4,055 4,356 8,411 508,171 8,411 0

9,995 509,755 2030 4,110 4,356 8,466 509,755 8,466 0

10,026 511,314 2031 4,055 4,356 8,411 511,314 8,411 0

10,058 512,961 2032 4,064 4,368 8,432 512,961 8,432 0

10,091 514,619 2033 4,110 4,356 8,466 514,619 8,466 0

10,123 516,276 2034 4,055 4,356 8,411 516,276 8,411 0

10,157 518,022 2035 4,055 4,356 8,411 518,022 8,411 0

10,192 519,804 2036 4,120 4,368 8,488 519,804 8,488 0

10,226 521,542 2037 4,055 4,356 8,411 521,542 8,411 0

10,263 523,394 2038 4,055 4,356 8,411 523,394 8,411 0

10,300 525,283 2039 4,110 4,356 8,466 525,283 8,466 0

10,336 527,152 2040 4,064 4,368 8,432 527,152 8,432 0

10,374 529,094 2041 4,055 4,356 8,411 529,094 8,411 0

10,414 531,097 2042 4,110 4,356 8,466 531,097 8,466 0

10,453 533,083 2043 4,055 4,356 8,411 533,083 8,411 0

10,493 535,166 2044 4,064 4,368 8,432 535,166 8,432 0

10,535 537,268

CNRO-2019-00005 3 Page 4 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2045 4,110 4,356 8,466 537,268 8,466 0

10,576 539,378 2046 4,055 4,356 8,411 539,378 8,411 0

10,619 541,586 2047 4,055 4,356 8,411 541,586 8,411 0

10,664 543,839 2048 4,120 4,368 8,488 543,839 8,488 0

10,707 546,058 2049 4,055 4,356 8,411 546,058 8,411 0

10,753 548,400 2050 4,055 4,356 8,411 548,400 8,411 0

10,800 550,789 2051 4,110 4,356 8,466 550,789 8,466 0

10,846 553,169 2052 4,064 4,368 8,432 553,169 8,432 0

10,895 555,631 2053 3,889 0

3,889 555,631 3,889 0

11,035 562,777 2054 3,944 0

3,944 562,777 3,944 0

11,177 570,009 2055 3,889 0

3,889 570,009 3,889 0

11,322 577,443 2056 3,898 0

3,898 577,443 3,898 0

11,471 585,015 2057 3,944 0

3,944 585,015 3,944 0

11,621 592,692 2058 3,889 0

3,889 592,692 3,889 0

11,776 600,579 2059 3,889 0

3,889 600,579 3,889 0

11,934 608,624 2060 3,954 0

3,954 608,624 3,954 0

12,093 616,763 2061 3,889 0

3,889 616,763 3,889 0

12,257 625,132 2062 3,889 0

3,889 625,132 3,889 0

12,425 633,668 2063 3,944 0

3,944 633,668 3,944 0

12,594 642,318 2064 3,898 0

3,898 642,318 3,898 0

12,768 651,188 2065 3,889 0

3,889 651,188 3,889 0

12,946 660,245 2066 3,944 0

3,944 660,245 3,944 0

13,126 669,427 2067 3,889 0

3,889 669,427 3,889 0

13,311 678,848 2068 35,546 0

35,546 678,848 35,546 0

12,866 656,169 2069 78,735 0

78,735 656,169 78,735 0

11,549 588,982 2070 112,853 0

112,853 588,982 112,853 0

9,523 485,652 2071 91,796 0

91,796 485,652 91,796 0

7,877 401,732 2072 92,267 0

92,267 401,732 92,267 0

6,189 315,655

CNRO-2019-00005 3 Page 5 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 13-1 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2073 54,739 0

54,739 315,655 54,739 0

5,218 266,134 2074 566 0

566 266,134 566 0

5,311 270,879 2075 327 0

327 270,879 327 0

5,411 275,963 668,374 148,201 0

816,575 816,575 0

594,106 275,963 As can be seen from the information provided in Table 13-1, the required funding for SAFSTOR decommissioning, $668.37 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $627.86 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2018 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $275.96 million surplus exists at the end of the decommissioning project. ISFSI decommissioning costs were planned to be paid for out of the aforementioned excess funds if not paid for by spent fuel litigation proceeds. Accordingly, the ENOI concludes that no further action is required as of December 31, 2018 to demonstrate adequate funding assurance for decommissioning Vermont Yankee.

CNRO-2019-00005 3 Page 6 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 13-1 Definitions:

Column 1:

50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2018 dollars at a 0.0% escalation rate Column 2:

50.54 (bb) Spent Fuel Management Cost Reflects the Total Annual Irradiated Fuel Management Plan cost in 2018 dollars at a 0.0% escalation rate Column 3:

Exclude Transfer to Dry Fuel Storage Cost Reflects the Transfer to Dry Fuel Storage Cost included in Column 2 that is planned to be funded by external credit facilities, in 2018 dollars at a 0.0%

escalation rate Column 4:

License Termination Cost plus Spent Fuel Management Cost less Transfer to Dry Fuel Storage Cost Reflects the Total Annual License Termination Plan cost plus Total Spent Fuel Management Plan cost less Transfer to Dry Fuel Storage cost all in 2018 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

Column 5:

Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2018 dollars at a 0.0%

escalation rate and 2.0% Fund Earnings Column 6:

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

escalation rate (equals Column 4)

Column 7:

Contribute Reflects the annual contributions to the Trust Fund in 2018 dollars at a 0.0%

escalation rate

CNRO-2019-00005 3 Page 7 of 7 Entergy Nuclear Operations, Inc.

Vermont Yankee Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Column 8:

Trust Fund Earnings Reflects earnings on funds remaining in the trust. A 2.0% Earnings rate is used over a 0.0% cost escalation rate. The Annual 2.0% earnings are calculated on the beginning balance less 100% of the projected annual expenditure for each year. (Column 5 - 100% of Column 6)

• 2.0%

Column 9:

Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted specified at a 0.0%

escalation rate and 2.0% Fund Earnings in 2018 dollars. (Column 5 - Column 6 +

Column 7 + Column 8)

CNRO-2019-00005 4 Page 1 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Pilgrim Nuclear Power Station (Pilgrim) will permanently cease operations on May 31, 2019.

The Pilgrim decommissioning trust fund balance is approximately $1,028 million as of December 31, 2018. Tables 3.2a and 3.2b of the site-specific decommissioning cost estimate (Reference 1, Attachment 1) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. A cash flow analysis utilizing this annual expenditure and significant schedule change information is included as Table 14-1 below.

The cash flow analysis demonstrates that the Pilgrim decommissioning trust fund is sufficiently funded for all license termination activities and spent fuel management activities (i.e.,

operational costs). As discussed in the Irradiated Fuel Management Program Update (Reference 2) costs related to spent fuel management operations (e.g., operations and maintenance costs for the spent fuel pool and Independent Spent Fuel Storage Installation, totaling approximately $420 million, Table 14-1 Column 2) will be funded from the decommissioning trust fund. Entergy Nuclear Operations, Inc. understands that an exemption from 10 CFR 50.82(a)(8)(i)(A) must be granted prior to reimbursing any spent fuel management-related expenses from the Pilgrim decommissioning trust. A request for such an exemption was submitted as Reference 3.

The licensee has determined that use of a SAFSTOR analysis shows that there is presently reasonable assurance that adequate funds will be available for the decommissioning process in compliance with NRC decommissioning funding assurance rules.

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site-specific estimate under § 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." The licensee understands that a facility-specific analysis may be used for demonstrating the adequacy of decommissioning funds, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2) as the basis for justifying a higher than minimum funding level." (Regulatory Guide 1.159 Rev. 2, Section 1.1.1.) The licensee also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis. An updated decommissioning estimate was provided with the licensees Post Shutdown Decommissioning Activities Report on November 16, 2018 (Reference 1).

The Pilgrim site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until approximately 2080, at which time the plant decommissioning will be completed and the site released for alternative use without restriction. Table 14-1 below provides the annual license termination and spent fuel management costs computed in the updated estimate. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

Thus, considering the fund balance of $1,028 million, as of December 31, 2018, and projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), the trust fund

CNRO-2019-00005 4 Page 2 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1) is expected to have an excess of $113.7 million after completion of license termination and the operational spent fuel management activities that will be funded by the trust fund.

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Pilgrim, Post Shutdown Decommissioning Activities Report, dated November 16, 2018 (Accession No. ML18320A034).

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb), dated November 16, 2018 (Accession No. ML18320A036).

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, Request for Exemption from 10 CFR 50.82(a)(8)(i)(A), Pilgrim Nuclear Power Station, dated November 16, 2018 (Accession No. ML18320A037).

CNRO-2019-00005 4 Page 3 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 14-1 Pilgrim Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2019 119,166 76,149 0

195,315 1,027,714 195,315 0

16,648 849,047 2020 61,574 54,694 0

116,268 849,047 116,268 0

14,656 747,435 2021 46,032 48,898 0

94,930 747,435 94,930 0

13,050 665,555 2022 43,799 48,898 0

92,697 665,555 92,697 0

11,457 584,315 2023 14,516 12,882 0

27,398 584,315 27,398 0

11,138 568,055 2024 6,897 4,322 11,219 568,055 11,219 0

11,137 567,973 2025 6,259 4,310 10,569 567,973 10,569 0

11,148 568,552 2026 5,884 4,310 10,194 568,552 10,194 0

11,167 569,526 2027 5,884 4,310 10,194 569,526 10,194 0

11,187 570,519 2028 5,897 4,322 10,219 570,519 10,219 0

11,206 571,506 2029 5,884 4,310 10,194 571,506 10,194 0

11,226 572,539 2030 5,884 4,310 10,194 572,539 10,194 0

11,247 573,592 2031 5,884 4,655 10,539 573,592 10,539 0

11,261 574,315 2032 5,897 5,529 11,427 574,315 11,427 0

11,258 574,146 2033 5,884 4,310 10,194 574,146 10,194 0

11,279 575,231 2034 5,884 4,482 10,366 575,231 10,366 0

11,297 576,163 2035 5,884 5,000 10,884 576,163 10,884 0

11,306 576,585 2036 5,897 4,839 10,737 576,585 10,737 0

11,317 577,165 2037 5,884 4,310 10,194 577,165 10,194 0

11,339 578,311 2038 5,884 4,827 10,711 578,311 10,711 0

11,352 578,952 2039 5,884 4,310 10,194 578,952 10,194 0

11,375 580,134 2040 5,897 4,322 10,219 580,134 10,219 0

11,398 581,313 2041 5,884 4,827 10,711 581,313 10,711 0

11,412 582,014 2042 5,884 4,655 10,539 582,014 10,539 0

11,430 582,905 2043 5,884 4,655 10,539 582,905 10,539 0

11,447 583,813 2044 5,897 4,322 10,219 583,813 10,219 0

11,472 585,066 2045 5,884 4,827 10,711 585,066 10,711 0

11,487 585,842

CNRO-2019-00005 4 Page 4 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 14-1 Pilgrim Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2046 5,884 4,310 10,194 585,842 10,194 0

11,513 587,162 2047 5,884 4,655 10,539 587,162 10,539 0

11,532 588,156 2048 5,897 4,667 10,564 588,156 10,564 0

11,552 589,143 2049 5,884 4,827 10,711 589,143 10,711 0

11,569 590,001 2050 5,884 4,310 10,194 590,001 10,194 0

11,596 591,404 2051 5,884 4,655 10,539 591,404 10,539 0

11,617 592,482 2052 5,897 4,667 10,564 592,482 10,564 0

11,638 593,557 2053 5,884 4,310 10,194 593,557 10,194 0

11,667 595,030 2054 5,884 4,655 10,539 595,030 10,539 0

11,690 596,182 2055 5,884 4,655 10,539 596,182 10,539 0

11,713 597,356 2056 5,897 4,322 10,219 597,356 10,219 0

11,743 598,879 2057 5,884 4,655 10,539 598,879 10,539 0

11,767 600,108 2058 5,884 4,310 10,194 600,108 10,194 0

11,798 601,713 2059 5,884 4,655 10,539 601,713 10,539 0

11,823 602,998 2060 5,897 4,839 10,737 602,998 10,737 0

11,845 604,106 2061 5,884 4,310 10,194 604,106 10,194 0

11,878 605,791 2062 5,884 5,862 11,746 605,791 11,746 0

11,881 605,926 2063 4,697 0

4,697 605,926 4,697 0

12,025 613,253 2064 4,710 0

4,710 613,253 4,710 0

12,171 620,714 2065 4,697 0

4,697 620,714 4,697 0

12,320 628,337 2066 4,697 0

4,697 628,337 4,697 0

12,473 636,113 2067 4,697 0

4,697 636,113 4,697 0

12,628 644,044 2068 4,710 0

4,710 644,044 4,710 0

12,787 652,120 2069 4,697 0

4,697 652,120 4,697 0

12,948 660,371 2070 4,697 0

4,697 660,371 4,697 0

13,113 668,788 2071 4,697 0

4,697 668,788 4,697 0

13,282 677,372 2072 4,710 0

4,710 677,372 4,710 0

13,453 686,115 2073 28,634 0

28,634 686,115 28,634 0

13,150 670,632

CNRO-2019-00005 4 Page 5 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 14-1 Pilgrim Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Dry Fuel Costs (In Thousands in 2018 Dollars) (see column definitions below)

Year Column 1 50.75 License Termination Cost

($000s)

Column 2 50.54 (bb)

Spent Fuel Management Cost

($000s)

Column 3 Exclude Dry Fuel Spent Fuel Management Cost

($000s)

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

($000s)

Column 5 Beginning of Year Trust Fund Balance

($000s)

Column 6 Withdraw

($000s)

Column 7 Contribute

($000s)

Column 8 Trust Fund Earnings

($000s)

Column 9 Year Ending Trust Fund Balance

($000s) 2074 61,751 0

61,751 670,632 61,751 0

12,178 621,058 2075 160,046 0

160,046 621,058 160,046 0

9,220 470,233 2076 138,344 0

138,344 470,233 138,344 0

6,638 338,526 2077 120,920 0

120,920 338,526 120,920 0

4,352 221,959 2078 96,205 0

96,205 221,959 96,205 0

2,515 128,268 2079 18,888 0

18,888 128,268 18,888 0

2,188 111,568 2080 137 0

137 111,568 137 0

2,229 113,660 Total 1,187,994 420,250 0

1,608,244 1,608,244 0

694,190 113,660 As can be seen from the information provided in Table 14-1, the required funding for SAFSTOR decommissioning, $1,188.00 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $633.27 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2018, DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $113.7 million surplus exists at the end of the decommissioning project. ISFSI decommissioning costs will be paid for out of the aforementioned excess funds if not paid for by spent fuel litigation proceeds. Accordingly, the licensee concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Pilgrim.

CNRO-2019-00005 4 Page 6 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Table 13-1 Definitions:

Column 1:

50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2018 dollars at a 0.0% escalation rate Column 2:

50.54 (bb) Spent Fuel Management Cost Reflects the Total Annual Irradiated Fuel Management Plan cost in 2018 dollars at a 0.0% escalation rate Column 3:

Exclude Transfer to Dry Fuel Storage Cost Reflects the Transfer to Dry Fuel Storage Cost included in Column 2 that is planned to be funded by external credit facilities, in 2018 dollars at a 0.0%

escalation rate Column 4:

License Termination Cost plus Spent Fuel Management Cost less Transfer to Dry Fuel Storage Cost Reflects the Total Annual License Termination Plan cost plus Total Spent Fuel Management Plan cost less Transfer to Dry Fuel Storage cost all in 2018 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

Column 5:

Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2018 dollars at a 0.0%

escalation rate and 2.0% Fund Earnings Column 6:

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

escalation rate (equals Column 4)

Column 7:

Contribute Reflects the annual contributions to the Trust Fund in 2018 dollars at a 0.0%

escalation rate Column 8:

Trust Fund Earnings

CNRO-2019-00005 4 Page 7 of 7 Entergy Nuclear Operations, Inc.

Pilgrim Annual Cash Flow Analysis For Year Ending December 31, 2018 - 10 CFR 50.75(f)(1)

Reflects earnings on funds remaining in the trust. A 2.0% Earnings rate is used over a 0.0% cost escalation rate. The Annual 2.0% earnings are calculated on the beginning balance less 100% of the projected annual expenditure for each year. (Column 5 - 100% of Column 6)

• 2.0%

Column 9:

Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted specified at a 0.0%

escalation rate and 2.0% Fund Earnings in 2018 dollars. (Column 5 - Column 6 +

Column 7 + Column 8)

CNRO-2019-00005 5 Page 1 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 615

$85,560,000 136.5 2.16 0.65 2.95 2.103 2.727 0.13 2.37 0.22 12.853

$583,418,090

% Owned:

100.00%

Plant name:

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

12 31 2018 Termination of Operation:

9 28 2013 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$583,418,090

$471,203,402 NRC Minimum:

$432,214,534 Site Specific:

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

CNRO-2019-00005 5 Page 2 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 136.5 2.16 0.65 2.95 2.103 2.727 0.13 2.37 0.22 12.853

% Owned:

100.00%

2%

5.33 1.11133 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 184,185,837 192,641,670 (8,455,833)

$714,475,555 Total = Total Earnings + Total Earnings for Decom

$665,034,970

$49,440,584 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$598,412,232

$665,034,970 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

$521,833,884

$598,412,232 NRC Minimum:

$521,833,884 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

4 30 2024 MWth 1986$

ECI Base Lx Plant name:

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

12 31 2018

CNRO-2019-00005 5 Page 3 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 136.5 2.16 0.65 2.95 2.103 2.727 0.13 2.37 0.22 12.853

% Owned:

100.00%

2%

6.33 1.13356 2%

2%

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

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

12 31 2018 Termination of Operation:

4 30 2025 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$521,833,884

$780,593,070 NRC Minimum:

$521,833,884 Site Specific:

$780,593,070

$884,848,428 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$950,630,568 Total = Total Earnings + Total Earnings for Decom

$884,848,428

$65,782,140 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

418,649,683 428,796,683 (10,147,000)

CNRO-2019-00005 5 Page 4 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets BWR 1912

$121,208,000 136.5 2.16 0.65 2.95 2.103 2.727 0.13 2.39 0.22 13.422

% Owned:

100.00%

Plant name:

Vermont Yankee Power Station Month Day Year Year of Biennial:

12 31 2018 Termination of Operation:

12 29 2014 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$668,374,404

$498,431,965 NRC Minimum:

$627,859,619 Site Specific:

$668,374,404 Note: See Attachment 13 for adequacy of the trust fund.

CNRO-2019-00005 5 Page 5 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets BWR 2028

$122,252,000 136.5 2.16 0.65 2.95 2.103 2.727 0.13 2.39 0.22 13.422

% Owned:

100.00%

Entergy

$1,187,994,231

$1,027,714,005 NRC Minimum:

$633,267,558 Site Specific:

$1,187,994,231 Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

5 31 2019 MWth 1986$

ECI Base Lx Plant name:

Pilgrim Nuclear Generating Station Month Day Year Year of Biennial:

12 31 2018 Note: See Attachment 14 for adequacy of the trust fund.

CNRO-2019-00005 5 Page 6 of 6 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 2565

$97,572,000 132.3 2.08 0.65 2.75 2.103 2.727 0.13 2.37 0.22 12.853

% Owned:

100.00%

2%

3.42 1.07000 2%

2%

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

Palisades Nuclear Plant Month Day Year Year of Biennial:

12 31 2018 Termination of Operation:

5 31 2022 MWth 1986$

ECI Base Lx Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Entergy

$480,428,114

$443,626,004 NRC Minimum:

$480,428,114 Site Specific:

$443,626,004

$474,679,980 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

$474,679,980

$35,289,055 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

$509,969,035 Total = Total Earnings + Total Earnings for Decom 21,544,921 29,540,921 (7,996,000)

$