ML19210E470
| ML19210E470 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/29/2019 |
| From: | Sterdis A Holtec Decommissioning International, Holtec |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| 2906004 | |
| Download: ML19210E470 (12) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 2906004 Page 1 of 3 July 29, 2019 10 CFR 50.82 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility Operating License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044
Subject:
Response to NRC Request for Additional Information
References:
[1]
Letter from A. Christopher Bakken III, (Entergy Nuclear Operations, Inc) to U.S.
Nuclear Regulatory Commission - Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment; and Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) for Pilgrim Nuclear Power Station, dated November 16, 2018 (ADAMS Accession No. ML18320A031).
[2]
Letter from Pamela B. Cowan, (Holtec Decommissioning International) to U.S.
Nuclear Regulatory Commission - Notification of Revised Post Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, dated November 16, 2018 (ADAMS Accession No. ML18320A040).
[3]
Email from Scott P. Wall, (U.S. Nuclear Regulatory Commission) to Philip Couture (Entergy Nuclear Operations, Inc)RAI-PFPB-1Pilgrim Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment, dated July 26, 2019 (ADAMS Accession No. ML19207B366).
Please find attached the Response to NRC Request for Additional Information (RAI) Regarding the Request for Direct and Indirect Pilgrim License Transfers, RAI-PFPB-1 and -2 prepared and submitted herein by Holtec Decommissioning International, LLC (HDI).
By letter dated November 16, 2018 (Reference 1), as supplemented by letter dated November 16, 2018 (Reference 2), Entergy Nuclear Operations, Inc. (ENOI), on behalf of itself and Entergy Nuclear Generation Company (ENGC) (to be known as Holtec Pilgrim, LLC), Holtec International (Holtec), and Holtec Decommissioning International, LLC (HDI) (together, "Applicants"), requested that the U.S.
Nuclear Regulatory Commission (NRC) consent to: (1) the indirect transfer of control of the Renewed Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station (Pilgrim), as well as the general license for the Pilgrim Independent Spent Fuel Storage Installation (ISFSI) (collectively the "Licenses"), to Holtec; and (2) the direct transfer of ENOI's operating authority (i.e., its authority to
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 2906004 Page 2 of 3 conduct licensed activities at Pilgrim) to HDI. In addition, the Applicants requested that the NRC approve a conforming administrative amendment to the Licenses to reflect the proposed direct transfer of the Licenses from ENOI to HDI; a planned name change for ENGC from ENGC to Holtec Pilgrim, LLC; and deletion of certain license conditions to reflect satisfaction and termination of all ENGC obligations after the license transfer and equity sale. In addition, HDI submitted an exemption request, as an enclosure to the letter dated November 16, 2018, to allow HDI to use a portion of the nuclear decommissioning trust for spent fuel management and site restoration costs.
In Reference 3, The NRC provided ENOI with a request for additional information. The HDI response to this RAI is provided in the Enclosure to this letter.
This letter contains no new regulatory commitments.
In the event that the NRC has any questions about the transactions described in this letter or needs to obtain any additional information, please contact the undersigned at 724-493-1833 or a.sterdis@holtec.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 29, 2019.
Respectfully, Andrea L. Sterdis Vice President Regulatory and Environmental Affairs Holtec Decommissioning International, LLC
Enclosure:
Response to NRC Request for Additional Information (RAI) Regarding the Request for Direct and Indirect Pilgrim License Transfers, RAI-PFPB-1 and -2
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 2906004 Page 3 of 3 cc (w/Enclosure):
Mr. David C. Lew Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Scott P. Wall, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. John Giarrusso, Jr.
Planning, Preparedness and Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 Mr. John Priest, Director Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1M2A Charlestown, MA 02129-1121 NRC Senior Resident Inspector Pilgrim Nuclear Power Station
Enclosure Pilgrim Nuclear Power Station HDI Response to U.S. NRC Requests for Additional Information (RAI)-PFPB-1 and -2 Regarding the Request for Direct and Indirect Pilgrim License Transfers
HDI Response to U.S. NRC RAI-PFPB-1 Page E-1 of E-5 Following are the references used in this response:
[1]
Letter from A. Christopher Bakken III, (Entergy Nuclear Operations, Inc) to U.S.
Nuclear Regulatory Commission - Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment; and Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) for Pilgrim Nuclear Power Station, dated November 16, 2018 (ADAMS Accession No. ML18320A031).
[2]
Letter from Pamela B. Cowan, (Holtec Decommissioning International) to U.S.
Nuclear Regulatory Commission - Notification of Revised Post Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, dated November 16, 2018 (ADAMS Accession No. ML18320A040).
[3]
Letter from Brian R. Sullivan, (Entergy Nuclear Operations, Inc) to U.S. Nuclear Regulatory Commission - Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated June 10, 2019 (ADAMS Accession No. ML19161A033).
[4]
Letter from Mandy K. Halter, (Entergy Nuclear Operations, Inc) to U.S. Nuclear Regulatory Commission - Decommissioning Funding Status Report per 10 CFR
§50.75(f)(1) and 10 CFR 50.82(a)(8)(v) -- Entergy Nuclear Operations, Inc. dated March 28, 2019 (ADAMS Accession No. ML19087A318).
[5]
Email from Scott P. Wall, (U.S. Nuclear Regulatory Commission) to Philip Couture (Entergy Nuclear Operations, Inc)RAI-PFPB-1Pilgrim Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment, dated July 26, 2019 (ADAMS Accession No. ML19207B366).
RAI PFPB-1:
As identified in the NRC regulations and guidance documents described above, the estimated radiological decommissioning costs, consistent with the definition in 10 CFR 50.2, may be more, but not less, than the amount specified in 10 CFR 50.75(c).
In the November 16, 2018, license transfer application, the Applicants state the following:
The required [DTF] value at closing exceeds the minimum financial assurance required by 10 CFR 50.75(b) and the site-specific estimate of the radiological decommissioning cost, providing sufficient confidence that decommissioning can be achieved without the need for additional financial assurance. Further, a cash-flow analysis based on the site-specific estimate demonstrates that the funds in the [DTF] at closing will be sufficient to fund all radiological decommissioning costs, spent fuel management costs, and site restoration costs through the expected license termination date, and thus demonstrates Holtec Pilgrims financial qualifications.
HDI Response to U.S. NRC RAI-PFPB-1 Page E-2 of E-5 However, there is no comparison in the application between the estimated radiological decommissioning costs of $592,553,000 and the 10 CFR 50.75(c) minimum amount of $633,267,558, as reported by ENOI in its March 28, 2019, decommissioning funding status report.
Based on the requirements and guidance cited above, please justify using a total radiological decommissioning cost estimate value, consistent with the definition in 10 CFR 50.2, that is less than the minimum amount calculated using 10 CFR 50.75(c) in support of the license transfer application and the exemption request.
Response
The information provided by the Applicants in support of the License Transfer Application and HDIs exemption request complies with applicable NRC regulations and is consistent with applicable NRC guidance. NRC regulations at 10 CFR 50.75(b) and related guidance in RG 1.202 and RG 1.159 apply to certifications of decommissioning funding amounts that licensees and applicants of operating reactors are required to make during the earlier stages of a plants operating life. 10 CFR 50.75(b)(1) requires an applicant for an operating license to provide a certification that financial assurance for decommissioning has or will be provided in an amount that may not be less than the minimum financial assurance amount calculated pursuant to the generic formula in 10 CFR 50.75(c). The minimum financial assurance amount does not, however, represent the actual cost of decommissioning. Rather, it is a reference level established to assure that licensees demonstrate adequate financial responsibility that the bulk of the funds necessary for a safe decommissioning are being considered and planned for early in facility life. General Requirements for Decommissioning Nuclear Facilities, 53 Fed. Reg. 24,018, 24,030 (June 27, 1988)
(emphasis added). As noted in the guidance, the certification required by 10 CFR 50.75(b) was intended to be a first step in providing reasonable assurance of decommissioning funds, followed by the submittal of a preliminary decommissioning cost estimate, a site-specific decommissioning cost estimate pursuant to 10 CFR 50.82, and then an updated site-specific decommissioning cost estimate as part of a license termination plan. RG 1.159, Rev. 2 at 5-7. The guidance further states, The purpose of the decommissioning report, required under 10 CFR 50.33(k) and described in 10 CFR 50.75(b) and (c), is to provide reasonable assurance that licensees have a viable plan to accumulate funds in the certification amount, adjusted for inflation, by the projected time of permanent cessation of operations. Id. at 8.
Accordingly, the requirements in 10 CFR 50.75(b) related to the submittal of a decommissioning report and certification of decommissioning financial assurance were intended to apply in the earlier stages of plant operations, and not after permanent cessation of operations.
Furthermore, even if 10 CFR 50.75(b) were to be applied to plants that had entered decommissioning, the regulation does not require that a site-specific cost estimate for decommissioning prepared pursuant to 10 CFR 50.82(a)(8)(iii) must be greater than the 10 CFR 50.75(c) formula amount. In that regard, RG 1.202 recognizes that the certification amount required by 10 CFR 50.75(b)(1) may be based on a site-specific cost estimate, which may be more (but not less) than the amount specified in 10 CFR 50.75(b)(1) when a higher funding level than 10 CFR 50.75(c) is desired. RG 1.202 at 1.202-4 (emphasis added).
Significantly, however, the guidance clarifies that the site-specific cost estimate used for the certification is not the same site-specific cost estimate required by 10 CFR 50.82(a)(8)(iii). Id. (emphasis added).
Thus, there is no requirement that a site-specific cost estimate submitted pursuant to 10 CFR 50.82(a)(8)(iii) must equal or exceed the minimum formula amount.
Nor is there any provision in the NRC rules that requires a licensee to maintain financial assurance equaling or exceeding the generic formula amount after a plant permanently ceases operation. Instead, at that
HDI Response to U.S. NRC RAI-PFPB-1 Page E-3 of E-5 juncture, the requirements in 10 CFR 50.82 apply.1 10 CFR 50.82(a)(4)(i) requires a site-specific cost estimate to be submitted as part of the PSDAR but contains no requirement that this estimate equal or exceed the formula amount. Indeed, the annual reporting requirement in 10 CFR 50.82(a)(8)(v)-(vi) clearly shows a licensee of a permanently shut down plant is not required to maintain funding assurance equaling or exceeding the generic formula amount. As reflected in those provisions, after submitting its site-specific decommissioning cost estimate, a licensee of a plant that has permanently ceased operation must annually report and provide assurance for the estimated cost to complete decommissioning. This estimate declines as decommissioning proceeds.
In November 2018, ENOI and Holtec jointly requested a transfer of the Pilgrim licenses, noting that the transfer will occur following docketing of ENOIs certifications of permanent removal of fuel from the reactor vessel (Reference 1). Because the application does not request transfer of the licenses until Pilgrim is permanently defueled, HDI submitted a revised site-specific decommissioning cost estimate (DCE) pursuant to 10 CFR 50.82(a)(7) in support of its demonstration that there would be reasonable assurance of decommissioning funding upon license transfer (Reference 2). On June 10, 2019, ENOI certified to the NRC that power operations permanently ceased at Pilgrim on May 31, 2019, and that it had permanently removed all fuel from the Pilgrim reactor on June 9, 2019 (Reference 3). Pursuant to 10 CFR 50.82(a)(2),
the Pilgrim 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Accordingly, the requirements in 10 CFR 50.82, rather than 10 CFR 50.75(b),
apply to Pilgrim effective May 31, 2019 and will continue to apply to Pilgrim after the proposed license transfer occurs.
Once a site-specific decommissioning cost estimate pursuant to 10 CFR 50.82(a)(8)(iii) has been submitted, NRC guidance suggests that NRC reviewers should compare the site-specific cost estimate against the minimum financial assurance amount to assist the staff in evaluating the reasonableness of the cost estimate.
See, e.g., RG 1.202 at 1.202-9; NUREG-1713 at 21. NUREG-1713 (at 21) states:
The [NRC] reviewer will use the following process to determine that the submitted [site-specific DCE] considers, in adequate detail, all major site-specific factors that could affect the cost to decommission, and to ensure that the [site-specific DCE] appears reasonable.
The [NRC] reviewer should compare the [site-specific DCE] with the minimum decommissioning financial assurance requirement amount derived per the algorithm discussed in [10 CFR 50.75(c)]. If the [site-specific DCE] is less than the amount derived from the algorithm in 10 CFR 50.75(c) and adequate justification is not provided, [the NRC] will inform the licensee in writing of additional information needed to resolve the deficiency.
Thus, the guidance indicates that a comparison between the 10 CFR 50.82(a)(8)(iii) site-specific cost estimate and the minimum financial assurance amount is intended to be just one of many factors that the staff should consider as it assesses a licensees site-specific cost estimate. If a site-specific 1
See, e.g., SECY-18-0078, Summary of Staff Review and Findings of the 2017 Decommissioning Funding Status Reports from Operating and Decommissioning Power Reactor Licensees (Aug. 6, 2018) at 2 (Pursuant to NRC regulations at 10 CFR 50.75(f)(1) (for operating power reactors) and 10 CFR 50.82(a)(8)(v)-(vi) (for power reactors in decommissioning), licensees are required to submit [decommissioning funding status] reports to the NRC.... For operating reactors, in accordance with 10 CFR 50.75(f)(1), the DFS reports must include: (1) the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and 10 CFR 50.75(c)... (emphasis added)).
HDI Response to U.S. NRC RAI-PFPB-1 Page E-4 of E-5 decommissioning cost estimate is less than the formula amount, and adequate justification is not provided, then the staff should obtain additional information from the licensee.
The justification for using a total radiological decommissioning cost estimate value, consistent with the definition in 10 CFR 50.2, that is less than the minimum amount calculated using 10 CFR 50.75(c) in support of the license transfer application and the exemption request is that HDIs site-specific DCE reflects an actual, detailed estimate of decommissioning costs. As the Commission explained when it promulgated 10 CFR 50.75, the formula amount represented a first step in establishing a general level of adequate financial responsibility early in life. 53 Fed. Reg. at 24,030. By contrast, HDIs site-specific cost estimate of the going forward costs that HDI expects to incur after license transfer is based on Pilgrim-specific plant data and historical information, actual site conditions, regulatory requirements applicable to Pilgrim, and actual pricing information, and is therefore significantly more reliable and precise than the formula amount, which is based on generic inputs. For example, with respect to waste disposal costs, which represent a significant portion of the estimated radiological decommissioning costs, the Application states that
[d]isposal facilities were selected and pricing was confirmed. In addition, as stated in the Application and DCE, HDI reviewed the estimates of costs associated with license termination in NUREG/CR-6174, Revised Analyses of Decommissioning for the Reference Boiling Water Reactor Power Station, in order to evaluate the reasonableness of the decommissioning estimate, benchmarked the estimated radiological decommissioning costs against nine comparable decommissioning projects, and compared the decommissioning cost estimate to costs from similar activities at seven boiling water reactors. The DCE includes considerable additional information supporting the reliability of the cost estimates. Therefore, ample justification for why HDIs site-specific DCE is less than the generic minimum formula amount has been provided.
RAI PFPB-2:
Using the 10 CFR 50.75(c) minimum amount for radiological decommissioning costs, please provide an updated, revised decommissioning cash flow analysis to support the license transfer application and exemption request.
Response
As an initial matter, as noted above in the response to RAI 1, the 10 CFR 50.75(c) minimum financial assurance amount is a reference level established to assure that licensees demonstrate adequate financial responsibility that the bulk of the funds necessary for a safe decommissioning are being considered and planned for early in facility life. 53 Fed. Reg. at 24,030. It is not a decommissioning cost estimate. Thus, a cash flow analysis that uses the 10 CFR 50.75(c) minimum amount as the total radiological decommissioning cost does not reflect HDIs actual projected cash flows for the decommissioning work it plans to perform at Pilgrim.
HDIs projected cash flow analysis was provided in Enclosure 1 to the License Transfer Application (Reference 1) and is based on HDIs site-specific DCE (Reference 2) and HDIs schedule of planned decommissioning activities. The Applicants respectfully submit that the actual Cash Flow Analysis table provided in Reference 1 should form the basis for the NRC staffs review of the Application and exemption request. As reflected in that table, HDI estimated a total of $592,553,322 for completing radiological decommissioning activities, which are referred to as license termination activities in HDIs site-specific DCE and Cash Flow Analysis table.2 This amount reflects HDIs detailed estimate of the going forward license termination costs that HDI expects to incur after license transfer, based on Pilgrim-specific plant 2
The dollar values in the Cash Flow Analysis table provided in Reference 1 reflect rounding.
HDI Response to U.S. NRC RAI-PFPB-1 Page E-5 of E-5 data and historical information, actual site conditions, regulatory requirements applicable to Pilgrim, actual pricing information, as well as HDIs schedule of planned decommissioning activities and projected annual expenditures based on the timing of those activities, which HDI plans to initiate promptly upon license transfer and purchase.
As required by 10 CFR 50.75(f)(1), ENOI submitted the annual report on the status of the Pilgrim Nuclear Power Station decommissioning trust fund to the NRC on March 29, 2019 (Reference 4). In this submittal, ENOI provided the escalated Minimum Funding Amount (MFA) for the Pilgrim Station using the 10 CFR 50.75(c)(2) Escalation Factor Formula. The formula takes into account the reactor type and power level, with generic adjustment factors for regional labor and energy costs taken from U.S. Department of Labor data and for waste burial costs taken from NRC guidance document NUREG-1307, Report on Waste Burial Charges. Using the generic formula in 10 CFR 50.75(c), ENOI calculated the MFA for Pilgrim for year ending December 31, 2018 to be $633,267,558, which is $40,714,236 more than HDIs detailed site-specific estimate of license termination costs submitted on November 16, 2018 (References 1 and 2).
Although the generic MFA calculation does not take into account any Pilgrim-specific data, cost estimates, assumptions, schedule for planned decommissioning activities, or timing of expenditures, HDI has developed a cash flow analysis with license termination costs adjusted to total the MFA of $633,267,558 (see Attachment 1 to this response). To do this, HDI distributed the difference between the MFA submitted by ENOI on March 29, 2019 and the amount of HDIs site-specific license termination cost estimate
($40,714,236) equally among the 11 years in which HDI expects to perform license termination activities.
This resulted in an increase in each of the annual amounts provided in the License Termination Cost column of the Cash Flow Analysis table provided in Reference 1 of $3,701,294 ($40,714,236/11 years = $3,701,294 per year). For example, for 2019, HDI increased the annual License Termination Cost value from
$84,927,000 to $88,628,788 ($84,927,000 + $3,701,294 = $88,628,788). A similar adjustment was performed for all other years in which HDI expects to perform license termination activities (i.e., 2020-2025 and 2060-2063).
In addition, the cash flow analysis in Attachment 1 incorporates the following assumptions:
- 1) The costs for a specific year are conservatively assumed to be withdrawn on January 1 of that year.
- 2) The earnings for a specific year are conservatively based on the NDT fund value on December 31 of that year.
- 3) The earnings utilize a 2% real rate of return on investment, consistent with NRC regulations.
The Cash Flow Analysis table provided in Reference 1 provided the annual earnings Net of Taxes and therefore resulted in a lower rate.
The attached table demonstrates that using the MFA as the total license termination cost estimate results in a remaining NDT balance of $11,595,232 at the time the Pilgrim license is terminated, after all license termination, spent fuel management, and site restoration activities have been completed. Accordingly, even if the generic MFA was used in place of HDIs site-specific cost estimate for license termination activities, HDI has demonstrated that the NDT provides reasonable assurance of the availability of decommissioning funding, and therefore, that Holtec Pilgrim and HDI are financially qualified to hold the Pilgrim licenses.
Enclosure Pilgrim Nuclear Power Station HDI Response to U.S. NRC Requests for Additional Information (RAI)-PFPB-1 and -2 Regarding the Request for Direct and Indirect Pilgrim License Transfers HDI Decommissioning Cost Estimate (DCE) Adjusted to include Additional License Termination Costs to Compare to 2018 Formula Amount
Pilgrim Nuclear Power Station -
HDI DECOMMISSIONING COST ESTIMATE (DCE) Adjusted to Include Additional License Termination Costs to Compare to 2018 Formula Amount Annual Cash Flow in 2018 Dollars No DOE Reimbursement of Spent Fuel Management Costs Year HDI 10 CFR 50.75 License Termination Cost Estimate Adjustment
$$ to compare to 2018 formula License Termination Cost Estimate Adj to compare to 2018 formula Spent Fuel Management Cost (unchanged)
Site Restoration Cost (unchanged)
Total Estimated Costs Adj to compare to 2018 formula Beginning of Year NDT Balance1 Withdrawals Adj to compare to 2018 formula NDT Earnings2 Year Ending NDT Balance Adj to compare to 2018 formula 2019
84,927,494 3,701,294
88,628,788
53,919,755 17,619 142,566,162 1,030,000,000 142,566,162 7,395,282 894,829,120 2020
79,292,448 3,701,294
82,993,743
84,905,227 27,597 167,926,566 894,829,120 167,926,566 14,538,051 741,440,604 2021
46,758,773 3,701,294
50,460,067
82,500,059 636,985 133,597,110 741,440,604 133,597,110 12,156,870 620,000,364 2022
103,197,395 3,701,294
106,898,690
3,331,593 23,629,849 133,860,131 620,000,364 133,860,131 9,722,805 495,863,038 2023
167,453,076 3,701,294
171,154,370
3,135,304 1,699,521 175,989,195 495,863,038 175,989,195 6,397,477 326,271,320 2024
95,693,887 3,701,294
99,395,182
3,225,310 9,235,554 111,856,046 326,271,320 111,856,046 4,288,305 218,703,579 2025
1,309,633 3,701,294
5,010,927
6,306,278 4,126,523 15,443,727 218,703,579 15,443,727 4,065,197 207,325,049 2026
0
0
5,952,309 0
5,952,309 207,325,049 5,952,309 4,027,455 205,400,195 2027
0
0
5,938,720 0
5,938,720 205,400,195 5,938,720 3,989,229 203,450,704 2028
0
0
5,952,309 0
5,952,309 203,450,704 5,952,309 3,949,968 201,448,363 2029
0
0
5,952,309 0
5,952,309 201,448,363 5,952,309 3,909,921 199,405,975 2030
0
0
7,211,549 0
7,211,549 199,405,975 7,211,549 3,843,889 196,038,314 2031
0
0
7,211,549 0
7,211,549 196,038,314 7,211,549 3,776,535 192,603,301 2032
0
0
7,211,549 0
7,211,549 192,603,301 7,211,549 3,707,835 189,099,587 2033
0
0
7,211,549 0
7,211,549 189,099,587 7,211,549 3,637,761 185,525,799 2034
0
0
7,192,982 0
7,192,982 185,525,799 7,192,982 3,566,656 181,899,472 2035
0
0
7,211,549 0
7,211,549 181,899,472 7,211,549 3,493,758 178,181,682 2036
0
0
7,230,115 0
7,230,115 178,181,682 7,230,115 3,419,031 174,370,598 2037
0
0
7,211,549 0
7,211,549 174,370,598 7,211,549 3,343,181 170,502,230 2038
0
0
7,192,982 0
7,192,982 170,502,230 7,192,982 3,266,185 166,575,432 2039
0
0
7,211,549 0
7,211,549 166,575,432 7,211,549 3,187,278 162,551,161 2040
0
0
7,211,549 0
7,211,549 162,551,161 7,211,549 3,106,792 158,446,404 2041
0
0
7,211,549 0
7,211,549 158,446,404 7,211,549 3,024,697 154,259,553 2042
0
0
7,211,549 0
7,211,549 154,259,553 7,211,549 2,940,960 149,988,964 1 The 2019 Beginning of Year NDT balance reflects the fund value post-closure of the equity sale. The value used does not include deductions for ENOI pre-closure costs.
The 2019 costs include HDI estimated pre-closure and post closure costs.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR)
Pilgrim Nuclear Power Station -
HDI DECOMMISSIONING COST ESTIMATE (DCE) Adjusted to Include Additional License Termination Costs to Compare to 2018 Formula Amount Annual Cash Flow in 2018 Dollars No DOE Reimbursement of Spent Fuel Management Costs Year HDI 10 CFR 50.75 License Termination Cost Estimate Adjustment
$$ to compare to 2018 formula License Termination Cost Estimate Adj to compare to 2018 formula Spent Fuel Management Cost (unchanged)
Site Restoration Cost (unchanged)
Total Estimated Costs Adj to compare to 2018 formula Beginning of Year NDT Balance1 Withdrawals Adj to compare to 2018 formula NDT Earnings2 Year Ending NDT Balance Adj to compare to 2018 formula 2043
0
0
7,211,549 0
7,211,549 149,988,964 7,211,549 2,855,548 145,632,963 2044
0
0
7,211,549 0
7,211,549 145,632,963 7,211,549 2,768,428 141,189,842 2045
0
0
7,192,982 0
7,192,982 141,189,842 7,192,982 2,679,937 136,676,797 2046
0
0
7,211,549 0
7,211,549 136,676,797 7,211,549 2,589,305 132,054,553 2047
0
0
7,211,549 0
7,211,549 132,054,553 7,211,549 2,496,860 127,339,864 2048
0
0
7,230,115 0
7,230,115 127,339,864 7,230,115 2,402,195 122,511,944 2049
0
0
7,192,982 0
7,192,982 122,511,944 7,192,982 2,306,379 117,625,341 2050
0
0
7,211,549 0
7,211,549 117,625,341 7,211,549 2,208,276 112,622,068 2051
0
0
7,192,982 0
7,192,982 112,622,068 7,192,982 2,108,582 107,537,667 2052
0
0
7,230,115 0
7,230,115 107,537,667 7,230,115 2,006,151 102,313,703 2053
0
0
7,211,549 0
7,211,549 102,313,703 7,211,549 1,902,043 97,004,197 2054
0
0
7,211,549 0
7,211,549 97,004,197 7,211,549 1,795,853 91,588,501 2055
0
0
7,192,982 0
7,192,982 91,588,501 7,192,982 1,687,910 86,083,429 2056
0
0
7,211,549 0
7,211,549 86,083,429 7,211,549 1,577,438 80,449,317 2057
0
0
7,211,549 0
7,211,549 80,449,317 7,211,549 1,464,755 74,702,524 2058
0
0
7,211,549 0
7,211,549 74,702,524 7,211,549 1,349,819 68,840,794 2059
0
0
7,211,549 0
7,211,549 68,840,794 7,211,549 1,232,585 62,861,830 2060
4,295,660 3,701,294
7,996,954
7,211,549 0
15,208,503 62,861,830 15,208,503 953,067 48,606,394 2061
4,375,107 3,701,294
8,076,401
7,211,549 0
15,287,950 48,606,394 15,287,950 666,369 33,984,813 2062
4,357,793 3,701,294
8,059,087
7,192,982 0
15,252,069 33,984,813 15,252,069 374,655 19,107,399 2063
892,056 3,701,294
4,593,351
2,440,549 705,625
7,739,524 19,107,399 7,739,524 227,357 11,595,232 Total13 592,553,322 40,714,236 633,267,558 501,466,571 40,079,271 1,174,813,400 (1,174,813,400) 156,408,632 1 The 2019 Beginning of Year NDT balance reflects the fund value post-closure of the equity sale. The value used does not include deductions for ENOI pre-closure costs.
The 2019 costs include HDI estimated pre-closure and post closure costs.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 3 Columns may not add due to rounding