ML20063L684

Comment from Henry Kelly on the Indian Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments (NRC-2020-0021)

ML20063L684
Person / Time
Site:	Indian Point
Issue date:	02/21/2020
From:	- No Known Affiliation
To:
SECY/RAS
References
85FR03947, NRC-2020-0021
Download: ML20063L684 (130)

Text

From: Henry Kelly To: Docket, Hearing

Subject:

[External_Sender] Indian Point Transfer D=NRC-2020-0021-0001 Date: Friday, February 21, 2020 5:18:04 PM Attachments: psdardec19.pdf Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemaking and Adjudications Staff D-NRC-2020-0021-0001 To whom it may concern, My name is Henry Kelly. My wife Corinne and myself live at 6 Mancuso Drive, Ossining New York 10562-2527.

We moved to Ossining in August of 1986.

We live within the ten mile Indian Point Evacuation Zone. Especially since the 9/11 terrorist attack, when a hijacked aircraft flew by the Indian Point reactors on the way to the twin towers, we have been burdened by the constant concern for ourselves and our neighbors of a possible terrorist attack on the Indian Point site. We have also been worried about an accident at the plant leading to a radiological release. Years have passed and luckily, no attack or serious accident has occurred. The plant and the evacuation plan were, and are, part of our lives. Sadly and unfortunately, the evacuation plan is completely untenable, as anyone who lives near the plant knows. If anything happened to cause a radiological release at Indian Point, due to prevailing winds, we would find ourselves in a radioactive plume coming from the plant. When the emergency sirens finally began to work properly, each time they were tested our hearts skipped a beat. Three Mile Island, Chernobyl, and most recently Fukushima Daiichi clearly showed that design errors, human error, and natural disaster can produce deadly accidents. The yearly Westchester County Indian Point Emergency Guide and the siren tests are reminders that a serious disaster is a real, not imagined. possibility. Frankly, if one were to happen, we would consider ourselves trapped and probably helpless to avoid being irradiated. Our neighbors like us live with that background fear.

I commuted to New York City for many years. I often wondered what would happen to the economic and cultural capital of our country if an accident sent a large airborne radiological release down the Hudson River toward Manhattan. Where could people go and how to escape the consequences. What would the aftermath be like?

While there have been issues at Indian Point such as Tritium leaks, shutdowns, small fires, gas releases and equipment failures, thankfully, Entergy has prevented a catastrophe from occurring. Approximately 25 million men women and children inhabit the possible radiological impact areas of an accident. Cleanup would be a long term, painfully slow, and extremely expensive task. Exposure would create a medical nightmare that would go on for generations. Like the nuclear plant at Shoreham on Long Island that was closed, the Indian Point site was, and still is, a poor choice for a nuclear plant location. The population has increased year after year while road systems have remained inadequate to the growing population on a good day. Population immediately around the plant has increased. Each year the plant became more problematic and remained a real threat.

Finally after much public pressure and activism and education, the reactors at Indian Point are due to close. However, unfortunately, the feeling of relief instead has turned now to concern and, sadly, dread in the surrounding communities and throughout the region as Entergy is looking to offload the decommissioning of Indian Point to a limited liability corporation, Holtec Decommissioning International, LLC(HDI,LLC. Holtec is a new player in this growing lucrative nuclear decommissioning business..Alarmingly in their recent PSDAR document of December 19, 2019, attached, Holtec clearly displays that their focus is on cost issues with very little focus at all on risk, contingency and accident avoidance, or public safety. Needless to say if you read the 117 page document you come away very concerned. Any accident has the potential to damage communities from Buchanan to New York City, to

New Jersey and Connecticut. Yet no mention is there of planning for avoidance or response to an accident. Glaringly absent is any statement of their concern for pubic safety and acceptance of their responsibility to plan and cost for it..

There are many documents, maps, and reports circulating about the risks of decommissioning a nuclear plant. The NRC itself in its GEIS Section 4.3.9.2 of NUREG-586 (Supplement 1) clearly states that "decommissioning increases the risk of accidents since activity is increased, raising accident potential above normal plant operations." When you add that to the history at the site where baffling decisions were made to allow pipelines to be laid to pump high pressure gas through and under and adjacent to the site raising danger of fire and explosion that could result in compromised nuclear waste storage, you realize that the proper focus is missing and that there is a real danger to the public.

How a limited liability corporation could even be considered to do this decommissioning work is stunning.

To insure the work is done correctly you need a company that fully realizes, accepts and commits to the financial, safety, and ethical responsibility to fully protect the public during their stewardship.

Responsibility for avoiding accidents and the possible financial impacts and the human costs should be the top priority for the company doing the work to help them plan and train to avoid the problem...They need to cost and plan that into their work. They should be bound to that in any contract.

Holtec in its current PSDAR cost plan has made a disturbing assumption on Page 64 in a footnote and in the text, that DOE is expected to accept nuclear material in 2030... Their costing is based on that assumption which is totally unrealistic. There is now no place for the waste to go. New Mexico does not want it..The Yucca Mountain repository project has been shut down and defunded. Any decommissioning company tasked with the Indian Point work should factor the reality of long term in situ waste storage into their cost plan. The U.S.House of Representatives has a bill, the Stranded Act of 2020 H.R.5608 which needs to be passed for communities to deal with the long term burden that stranded nuclear material will face them with. Holtec in their proposal also ignores the fact that the Indian Point site is contaminated by radiological leakages ongoing over many years. There is no mention by Entergy, Holtec,or even the NRC of any clean up of this contamination as part of decommissioning. New York State has a petition for leave to intervene that includes documents showing Tritium and Strontium 90 plumes underground. Holtec only mentions soil down to three feet around the structures at the site in its decommissioning statements.

There are also now concerns about nuclear waste storage. Cask types and their ability to safely store waste over longer periods of time and even susceptibility to issues with eventual movement are coming up...The feeling is growing that Entergy and perhaps the NRC itself are in too much of a hurry to unload this "hot potato" to whoever will do the work with not enough questions asked...There are many companies that could do the work.

Citizen and community groups and local governments across the country are dealing with issues and after effects of plant decommissioning. The San Onofre plant decommissioning being done in part by Holtec and its subsidiaries is having issues. It appears that communities are left holding the bag on stranded nuclear waste, crippling tax shortfalls, decommissioning cost overruns, and security issues.

Hoped for repurposing of sites is stalled..60 years after the first nuclear plants came online there is still no place to put the wastes..Nuclear waste seems to be stuck "in situ" for decades to come.

Given all the above issues there is a real need to halt and review in depth any transfer by Entergy to any LLC, including Holtec.

Full financial responsibility should be required of any decommissioning company. Decommissioning plans must include costs for long term robust secure storage. Sufficient infrastructure as well as associated support, monitoring, security, and accident avoidance and response costs must be identified and included.

Waste will be stuck at Indian Point for decades not years. That has to be realistically faced, planned for, and costed.

Pre decommissioning radiological contamination must be cleaned up.

Risks due to pipelines, fuel storage, power outages, possible terrorist attack must be identified and planned for.

Security and response plans are needed, based on thorough risk analysis and contingency planning for all possible scenarios.

Accident avoidance, response and training should be costed.

If decommissioning is not done correctly and an accident or accidents happen, the lives and futures of

millions of men ,women and children will be compromised. The center of our country's cultural and economic life could be crippled for decades.Videos showing the Chinese city of Wuhan turned into a ghost town by a virus are a chilling reminder of what can happen. They are a reminder that avoidance of a potential radiological disaster is crucial to the decommissioning. Monetary costs are but a fraction of the whole picture. Public safety is paramount.

Assumptions and scenarios of possible problems need to be created, planned for, and mitigation/contingency plans developed and costed and trained for.

Given human fallibility is a fact, it is hard to expect an error-free decommissioning. To avoid a tragedy, whoever gets the work should be fully aware and committed to their responsibility for public safety and held fully accountable legally and financially for the decommsioning of Indian.

Point.

Entergy alone should not have the final say in such a serious and important undertaking. New York State and the communities should also have a deciding say in the selection and approval process.

Sincerely,, Henry S. Kelly.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 December 19, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Indian Point Nuclear Generating Units 1, 2 and 3 Docket Nos. 50-3, 50-247, 50-286 and 72-051 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64

Subject:

Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3

Reference:

[1] Letter US NRC to Con Edison, Order to Authorize Decommissioning and Amendment No. 45 to License No. DR-5 for Indian Point Unit No.

1, January 31, 1996 (ML070310227)

[2] Letter from ENOI to US NRC, Notification of Permanent Cessation of Power Operations Indian Point Nuclear Generating Unit Nos. 2 and 3, Docket Nos. 50-247 and 50-286, License Nos. DPR-26 and DPR-64, dated February 8, 2017 (ML17044A004)

[3] Letter, ENOI to US NRC, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments, Indian Point Nuclear Generating Units 1, 2 and 3, November 21, 2019 (ML19326B953)

Pursuant to 10 CFR 50.82(a)(4), Holtec Decommissioning International, LLC (HDI) is submitting a Post Shutdown Decommissioning Activities Report (PSDAR) for the Indian Point Nuclear Generating Units 1, 2 and 3. On January 31, 1996, the US NRC issued an order to authorize decommissioning of IP1 and Amendment No. 45 to License No. DPR-5, which revised the license to possession-only status (Reference 1). By letter dated February 8, 2017, Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Indian Point 2, LLC (ENIP2), and Entergy Nuclear Indian Point 3, LLC (ENIP3) notified the Nuclear Regulatory Commission (NRC) that it would permanently cease power operations at IP2 and IP3 by April 30, 2020 and April 30, 2021, respectively, consistent with the terms of a certain settlement agreement with the State of New York and related parties (Reference 2).

Page 1 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 By letter dated November 21, 2019, ENOI, on behalf of itself, ENIP2, ENIP3, Holtec International (Holtec), and HDI, requested that the NRC consent to: (1) the transfer of control of Provisional Operating License No. DPR-5 and Renewed Facility Operating License Nos. DPR-26 and DPR-64 for IP1, 2 & 3, as well as the general license for the IP1, 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) to Holtec subsidiaries to be known as Holtec Indian Point 2, LLC (Holtec IP2) and Holtec Indian Point 3, LLC (Holtec IP3); and (2) the transfer of ENOIs operating authority (i.e., its authority to conduct licensed activities at IP1, 2 &

3) to HDI (Reference 3). The enclosed document provides the HDI PSDAR using the DECON method that is planned to be implemented following NRC approval of the requested license transfers and the sale of the entities that own IP1, 2 & 3 from Entergy to Holtec.

The enclosed PSDAR has been developed consistent with Regulatory Guide 1.185, Revision 1, Standard Format and Content for Post-Shutdown Decommissioning Activities Report. This HDI DECON PSDAR describes HDIs decommissioning plan and includes HDIs DECON Site-Specific Decommissioning Cost Estimate (DCE). The site-specific DCE for decommissioning IP1, 2 & 3 illustrates that adequate funding is available in the NDT fund for each unit to complete license termination activities for that unit. In addition to the license termination costs, site restoration and spent nuclear fuel management costs are included in this estimate; however, pursuant to regulatory requirements, the non-license termination cost estimates are segregated and listed separately. HDI will submit a request for NRC approval of an exemption to use Nuclear Decommissioning Trust (NDT) funds for spent fuel management and site restoration activities.

This DECON PSDAR is contingent upon NRC approval of the LTA, completion of transfer of the licenses and asset sale closure.

ENOI has reviewed the contents of this letter and is aligned.

In accordance with 10 CFR 50.82(a)(4)(i), a copy of the DECON PSDAR is being provided to the State of 1HZ<RUN by transmitting a copy of this letter and its enclosure to the designated State Officials.

This letter contains no new regulatory commitments.

If you have any questions, please contact me at (856) 797-0900, x3813 or via email at a.sterdis@holtec.com.

Sincerely, Andrea L. Sterdis Vice President, Regulatory & Environmental Affairs Holtec Decommissioning International, LLC Page 2 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

Enclosure:

Post Shutdown Decommissioning Activities Report and Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Station Units 1, 2, and 3 cc: w/ Enclosure Regional Administrator, NRC Region I Senior Resident Inspector, Indian Point Nuclear Generating Station Units 2 and 3 Senior Project Manager, NRC/NRR/DORL Page 3 of 3

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Rev. 0

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Table of Contents 1 INTRODUCTION AND

SUMMARY

...............................................................1 1.1 Introduction....................................................................................................................................1 1.2 Background....................................................................................................................................3 1.3 Summary of Decommissioning Methods .....................................................................................4 1.4 Decommissioning Method Selected .............................................................................................4 2 DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES...........6 Table 2-1 WBS Elements Mapped to Periods .7 2.1 Period 1 Pre-Decommissioning Planning & Preparation .............................................................7 2.1.1 Pre-Decommissioning Planning and Preparation (Pre-License Transfer) ................ 7 2.1.2 Period 1 - Pre-Decommissioning Planning and Preparation Activities ................... 7 2.2 Period 2 - Plant Deactivation........................................................................................................9 2.3 Period 3 - Safe Storage Operation.................................................................................................9 2.4 Period 4 - Dismantlement............................................................................................................10 2.4.1 Asbestos Containing Material, Hazardous, and Universal Waste Removal ........... 10 2.4.2 Site Characterization............................................................................................... 10 2.4.3 Segmentation and Dismantling of the RVIs and RPV............................................ 10 2.4.4 Fuel Pool and Reactor Cavity Dismantlement........................................................ 11 2.4.5 Large Component Dismantlement .......................................................................... 11 2.4.6 Radioactive Waste Management............................................................................. 12 2.4.7 Waste Transportation .............................................................................................. 12 2.4.8 Removal of Mixed Wastes...................................................................................... 13 2.4.9 License Termination including Final Status Surveys ............................................. 13 2.4.10 Site Restoration....................................................................................................... 13 2.5 Period 5 - Ongoing ISFSI Operations.........................................................................................13 2.6 Program Management .................................................................................................................14 2.7 Changes to Management and Staffing ........................................................................................14 3 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES..............15 3.1 IP1, 2 & 3 Decommissioning Schedule ......................................................................................15 4 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS .......................................................................................17 Table 4-1 IP1, 2 & 3 Decommissioning DECON Cost Summary (thousands of 2019 i

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report dollars) . .18 5 ENVIRONMENTAL IMPACTS .....................................................................19 5.1 Environmental Impact of IPEC Decommissioning ....................................................................19 5.1.1 Onsite/Offsite Land Use ......................................................................................... 19 5.1.1.1 Onsite Land Use .................................................................................................................20 5.1.1.2 Offsite Land Use ................................................................................................................20 5.1.2 Water Use ...........................................................................................................................21 5.1.3 Water Quality (Non-Radiological) ....................................................................................21 5.1.4 Air Quality..........................................................................................................................22 5.1.5 Aquatic Ecology.................................................................................................................23 5.1.6 Terrestrial Ecology.............................................................................................................24 5.1.7 Threatened and Endangered Species .................................................................................25 Table 5 .1 Effect Determinations for Federally Listed Species & Critical Habitats Related to Indian Point Energy Center ...26 5.1.7.1 Protected Terrestrial Species .............................................................................................26 5.1.7.2 Protected Aquatic Species .................................................................................................27 5.1.7.3 Conclusion..........................................................................................................................29 5.1.8 Radiological .......................................................................................................................29 5.1.8.1 Occupational Dose .............................................................................................................29 5.1.8.2 Public Dose ........................................................................................................................30 5.1.9 Radiological Accidents ......................................................................................................31 5.1.10 Occupational Issues............................................................................................................31 5.1.11 Cost.....................................................................................................................................32 5.1.12 Socioeconomics..................................................................................................................32 5.1.13 Environmental Justice ........................................................................................................32 5.1.14 Cultural, Historic and Archeological Resources ...............................................................34 5.1.15 Aesthetic Issues ..................................................................................................................34 5.1.16 Noise...................................................................................................................................35 5.1.17 Transportation ....................................................................................................................35 5.1.18 Irreversible and Irretrievable Commitment of Resources.................................................37 5.2 Environmental Impacts of License Termination ........................................................................37 5.3 Discussion of Decommissioning in the SEIS .............................................................................38 5.4 Additional Considerations...........................................................................................................38 ii

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.5 Conclusions.39 6 REFERENCES ............................................................................................................................40 Enclosure 1: IPEC Site-Specific Decommissioning Cost Estimate .42 Acronym List ...........................................................................................................46 Summary ..................................................................................................................48 HDI Decommissioning Cost Estimate Summary (thousands of 2019 dollars)..................... 49 1 Introduction .......................................................................................................50 1.1 Objectives ....................................................................................................................................51 1.2 Site Description ...........................................................................................................................51 1.3 Regulatory Guidance...................................................................................................................51 2 Decommissioning Options, the Method Selected and Approach .....................53 2.1 Decommissioning Methods.........................................................................................................53 2.2 Decommissioning Method Selected ...........................................................................................53 2.3 Decommissioning Approach.......................................................................................................53 Table 2-1 Decommissioning Periods and WBS Elements.................................................... 58 3 Decommissioning Cost Estimate ......................................................................59 3.1 Cost Estimate Summary ..............................................................................................................59 3.2 Site-Specific Matters Considered in DCE ..................................................................................60 Table 3-1a IP1 Decommissioning Activities and Costs by Period ....................................... 69 Table 3-1b IP2 Decommissioning Activities and Costs by Period....................................... 72 Table 3-1c IP3 Decommissioning Activities and Costs by Period ...................................... 75 Table 3-2a IP1 Program Management Cost Detail ............................................................... 78 Table 3-2b IP2 Program Management Cost Detail............................................................... 79 Table 3-2c IP3 Program Management Cost Detail ............................................................... 80 Table 3-3 HDI Decommissioning Cost Estimate Summary (thousands of 2019 dollars) .... 81 Table 3-4a IP1 Labor Costs and labor Requirements by Year ............................................. 82 Table 3-4b IP2 Labor Costs and Labor Requirements by Year............................................ 83 Table 3-4c IP3 Labor Costs and Labor Requirements by Year ............................................ 84 Table 3-5a IP1 Labor Costs and Labor Requirements by Period ........................................ 85 Table 3-5b IP2 Labor Costs and Labor Requirement by Period.......................................... 86 Table 3-5c IP3 Labor Costs and Requirements by Period.................................................... 87 Table 3-6 IPEC DOE Fuel Acceptance Allocation............................................................... 88 iii

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Table 3-7 IPEC Waste Volume and Weight ......................................................................... 89 4 Cost Estimating Approach ................................................................................90 4.1 Estimating Methodology .............................................................................................................90 4.2 Basis of Estimate .........................................................................................................................90 4.3 Assumptions ................................................................................................................................91 4.4 Inflation 93 4.5 Contingency.................................................................................................................................93 Table 4-1 Work Breakdown Structure .................................................................................. 96 5 Decommissioning Schedule and Funding.........................................................97 5.1 Decommissioning Schedule ........................................................................................................97 5.2 Decommissioning Funds .............................................................................................................97 Table 5-1a IP1 Decommissioning Funding Cash Flow Analysis ....................................... 100 Table 5-1b IP2 Decommissioning Funding Cash Flow Analysis ....................................... 102 Table 5-1c IP3 Decommissioning Funding Cash Flow Analysis ....................................... 104 6 Conclusion.......................................................................................................106 Table 6-1a IP1 Estimated Decommissioning Coast (thousand of 2019 dollars) ................ 107 Table 6-1b IP2 Estimated Decommissioning Cost (thousand of 2019 dollars).................. 109 Table 6-1c IP3 Estimated Decommissioning Cost (thousand of dollars) ........................... 111 7 References .......................................................................................................113 Table A-1 IP1 ISFSI Decommissioning Cost Estimate ..................................................... 115 Table A-2 IP2 ISFSI Decommissioning Cost Estimate...................................................... 116 Table A-3 IP3 ISFSI Decommissioning Cost Estimate...................................................... 117 iv

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Acronyms ACM Asbestos Containing Material ALARA As Low As Reasonably Achievable BMP Best Management Practice BOE Basis of Estimate CDI Comprehensive Decommissioning International, LLC.

CFR Code of Federal Regulations CPM Critical Path Method DCE Decommissioning Cost Estimate DCGL Derived Concentration Guideline Levels DECON A Method of Decommissioning defined by the NRC DGC Decommissioning General Contractor DOE Department of Energy DPS Distinct Population Segment EC European Commission ECOS Environmental Conservation Online System ENOI Entergy Nuclear Operations, Inc.

ENIP2 Entergy Nuclear Indian Point 2 ENIP3 Entergy Nuclear Indian Point 3 ENTERGY Entergy Corporation ENTOMB A Method of Decommissioning defined by the NRC FSS Final Status Survey GEIS Generic Environmental Impact Statement (NUREG-0586)

GTCC Greater than Class C HDI Holtec Decommissioning International Holtec Holtec International Holtec IP2 Holtec Indian Point 2, LLC Holtec IP3 Holtec Indian Point 3, LLC HSA Historical Site Assessment IAEA International Atomic Energy Agency IP1, 2 & 3 Indian Point Units 1, 2 and 3 IPaC Information for Planning and Consultation IPEC Indian Point Energy Center ISDC International Structure for Decommissioning Costing ISFSI Independent Spent Fuel Storage Installation IT Information Technology LLMW Low-Level Mixed Waste LLRW Low-Level Radioactive Waste LSA Low Specific Activity LTP License Termination Plan LTMP Long Term Monitoring Plan MNA Monitored Natural Attenuation MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual v

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report MWe Megawatts- Electric MWt Megawatts- Thermal NDT Nuclear Decommissioning Trust NEA Nuclear Energy Agency NEI Nuclear Energy Institute NEPA National Environmental Policy Act NLEP Norther Long-eared Bat NMFS National Marine Fisheries Services NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Commission technical report designation NYNHP New York Natural Heritage Program NYSDEC New York State Department of Environmental Conservation NYSHPO New York State Historic Preservation Office NYSERDA New York State Energy Research and Development Authority OECD Organization for Economic Cooperation and Development OSHA Occupational Safety and Health Association IP1, 2 & 3 Indian Point Units 1, 2 and 3 PSDAR Post-Shutdown Decommissioning Activities Report PSEP Permanently Shutdown Emergency Plan PWR Pressurized Water Reactor RPV Reactor Pressure Vessel RVI Reactor Vessel Internals SAFSTOR A Method of Decommissioning defined by the NRC SCO Surface Contaminated Object SEIS Supplemental Environmental Impact Statement SFP Spent Fuel Pool SME Subject Matter Expert SNF Spent Nuclear Fuel SPDES State Pollutant Discharge Elimination System SSC Structures, Systems and Components US United States USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency USFWS United States Fish and Wildlife Service WBS Work Breakdown Structure WCS Waste Control Specialists WMP Waste Management Plan WP Work Package vi

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 1 INTRODUCTION AND

SUMMARY

1.1 Introduction In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR)50.82, Termination of license, paragraph (a)(4)(i), this report constitutes the Holtec Decommissioning International, LLC (HDI) DECON Post-Shutdown Decommissioning Activities Report (PSDAR) for the decommissioning of the Indian Point Energy Center (IPEC) Unit Nos. 1, 2 and 3 (IP1, 2 & 3) following the scheduled permanent cessation of plant operations and permanent removal of fuel from the reactor vessels and subsequent transfer of the Part 50 and Part 72 licenses to Holtec International (Holtec) and HDI.

On January 31, 1996, the US NRC issued an order to authorize decommissioning of IP1 and Amendment No. 45 to License No. DPR-5, which revised the license to possession-only status (Reference 1). In accordance with 10 CFR 50.81(a)(1)(iii), certification of permanent cessation of operations of IP1 is deemed to have been submitted. In the same order, the staff required the licensee to submit a detailed dismantling plan for NRC review prior to commencing major dismantlement activities at IP1. Following the 1996 decommissioning rulemaking, the PSDAR satisfies this obligation (61 Fed. Reg. 39,278,39,291 (July 29, 1996)).

By letter dated February 8, 2017, Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Indian Point 2, LLC (ENIP2), and Entergy Nuclear Indian Point 3, LLC (ENIP3) notified the Nuclear Regulatory Commission (NRC) that it would permanently cease power operations at IP2 and IP3 by April 30, 2020 and April 30, 2021, respectively, consistent with the terms of a certain settlement agreement with the State of New York and related parties (Reference 2).

Pursuant to10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3), ENOI submitted a Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in October 2008 (Reference 3) and a Unit 3 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis (Reference 4) in December 2010.

By letter dated November 21, 2019, ENOI, on behalf of itself, ENIP2, ENIP3, Holtec International (Holtec), and HDI, requested that the NRC consent to: (1) the transfer of control of Provisional Operating License No. DPR-5 and Renewed Facility Operating License Nos. DPR-26 and DPR-64 for IP1, 2 & 3, as well as the general license for the IP1, 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) to Holtec subsidiaries to be known as Holtec Indian Point 2, LLC (Holtec IP2) and Holtec Indian Point 3, LLC (Holtec IP3); and (2) the transfer of ENOIs operating authority (i.e., its authority to conduct licensed activities at IP1, 2 & 3) to HDI (Reference 5).

This document provides the HDI PSDAR using the DECON method that is planned to be implemented following NRC approval of the requested license transfers and the sale of the 1

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report entities that own IP1, 2 & 3 from Entergy to Holtec. This HDI DECON PSDAR describes HDIs decommissioning plan and includes HDIs DECON Site-Specific Decommissioning Cost Estimate (DCE) as Enclosure 1.

The initiation of decommissioning activities will occur immediately following the sale and license transfers. The sale closure and license transfers are targeted to be completed by May 31, 2021, following IP3 permanent cessation of plant operations and permanent reactor defueling. In addition, HDI will submit a request for NRC approval of an exemption to use Nuclear Decommissioning Trust (NDT) funds for spent fuel management and site restoration activities.

Following the sale closure and transfer of the facility licenses, HDI will initiate decommissioning activities using the DECON method. Decommissioning is expected to be completed well before 60 years following permanent cessation of operations as required by 10 CFR 50.82(a)(3). HDI has a project goal to complete non-ISFSI decommissioning within 15 years following sale closure and license transfer. The plan described in this PSDAR and the cost estimate provided in Enclosure 1 reflect HDIs current decommissioning plan resulting in obtaining NRC issuance of a license amendment reducing the IP1, 2 & 3 licensed area to the ISFSI and permitting partial site release within 12 years of sale closure and license transfer. While the cost estimate presented herein is based on a 12-year schedule for partial site release, HDI expects that the cost estimates would bound a project schedule supporting partial site release out to 15 years.

In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR)50.82, Termination of license, paragraph (a)(4)(i), this DECON PSDAR is being submitted to notify the NRC of HDIs decommissioning plans based on an accelerated decommissioning schedule for the prompt decommissioning of IP1, 2 & 3 and unrestricted release of all portions of the site other than the ISFSI, if the license transfers are approved by the NRC and the transaction closes.

The DECON PSDAR is contingent upon NRC approval of the transfer of the IP 1, 2 and 3 licenses.

Prior to the IP2 and IP3 permanent shutdowns, ENOI, in coordination with HDI, is preparing for the safe and orderly transition from facility operations to dismantlement and decontamination. After transfer of the licenses is complete, the facility will be dismantled and decontaminated to levels that permit license termination. This DECON PSDAR contains the following:

1. A description of the planned decommissioning activities along with a schedule for accomplishment.

2. A discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements.

2

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report

3. A site-specific DCE, including the projected license termination, spent fuel management, and site restoration costs.

This DECON PSDAR has been developed consistent with Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report (Reference 6). The DECON PSDAR is based on currently available information, and the plans discussed herein may be modified as additional information becomes available or conditions change. As required by 10 CFR 50.82(a)(7), the NRC will be notified in writing, with copies sent to the State of New York, before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the DECON PSDAR, including changes that significantly increase the decommissioning cost.

1.2 Background

Indian Point is located on approximately 239 acres of land on the east bank of the Hudson River at the Village of Buchanan in upper Westchester County, New York.

There are three units on site, two operating units (IP2 & 3) and one in safe-storage (IP1). IP1 is located between IP2 to the north and IP3 to the south.

IP1 was a four-loop pressurized water reactor with a thermal rating of 615 megawatts thermal (MWt). Operation of the unit was suspended on October 31, 1974 and all spent fuel had been removed from the reactor vessel by January 1976. Since that time, the unit has remained in protective storage. In 2003, the NRC issued Amendment No. 52 to the Provisional Operating License for IP1. Included within the amendment was a change to expiration date of the IP1 license to be consistent with that of IP2.

In 2008, the remaining 160 spent fuel assemblies from IP1 (244 assemblies had previously been shipped to West Valley Reprocessing Plant, a commercial fuel reprocessing facility in upstate New York operated by Nuclear Fuel Services, Inc. from 1966 to 1972, for reprocessing) were transferred to an on-site ISFSI (Reference 7).

IP2 and IP3 each employ a pressurized water reactor and nuclear steam supply system (NSSS) furnished by Westinghouse Electric Corporation. The units are each currently licensed to generate 3,216 megawatts thermal which corresponds to a generator output of approximately 1,080 megawatts electric (MWe).

Pursuant to 10 CFR 50.51(b), Continuation of license, the license for a facility that has permanently ceased operations continues in effect beyond the expiration date to authorize ownership and possession of the facility until the NRC notifies the licensee in writing that the license has been terminated.

During the period that the license remains in effect, 10 CFR 50.51(b) requires that the licensee:

1. Take actions necessary to decommission and decontaminate the facility and 3

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report continue to maintain the facility (including storage, control, and maintenance of the spent fuel) in a safe condition.

2. Conduct activities in accordance with all other restrictions applicable to the facility in accordance with NRC regulations and the 10 CFR 50 renewed facility operating licenses.

10 CFR 50.82(a)(9) states that power reactor licensees must submit an application for termination of the license at least two (2) years prior to the license termination date, and that the application must be accompanied, or preceded, by a License Termination Plan (LTP) to be submitted for NRC approval.

1.3 Summary of Decommissioning Methods The NRC has evaluated the environmental impacts of three (3) general methods for decommissioning power reactor facilities in NUREG-0586, Final Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities:

Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (Reference 8). The three (3) general methods evaluated are summarized as follows:

x DECON: The equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

x SAFSTOR: After the plant is shut down and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact, or may be partially dismantled, but the fuel is removed from the reactor vessel, and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

x ENTOMB: Radioactive structures, systems, and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

1.4 Decommissioning Method Selected Following license transfers and sale closure, HDI plans to decommission and dismantle IP1, 2 & 3 using the DECON method. This DECON PSDAR describes the selected methods to be used for the decontamination and dismantlement of the site. The HDI decommissioning strategy for the project is to initiate the prompt decommissioning of IP1, 2 & 3 following shutdown, reactor defueling, and license transfers to support partial release of the IP1, 2 & 3 site, except for the ISFSI, within fifteen years after the license transfers and sale closure.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report The plan described in this PSDAR and the cost estimates provided in Enclosure 1 reflect HDIs current decommissioning plan resulting in a schedule for obtaining NRC issuance of a license amendment reducing the IP1, 2 & 3 licensed area to the ISFSI and permitting partial site release within 12 years of sale closure and license transfer. To execute this plan, once the licenses are transferred, the decommissioning objectives will be:

a. Decommissioning of IP1, 2 & 3 and site restoration of all areas, except for the ISFSI, for unrestricted use.

b. NRC approval of partial site release, including issuance of amended licenses to include only the operation of the ISFSI.

c. Department of Energy (DOE) acceptance of Spent Nuclear Fuel (SNF) from the IP1, 2 & 3 ISFSI.

d. Decommissioning of the ISFSI after DOE has removed the SNF.

e. Termination of the NRC licenses and site release of the ISFSI area.

f. Site restoration of the ISFSI area.

The HDI decommissioning strategy is to complete radiological decommissioning and release for unrestricted use of all portions of the site within twelve to fifteen years after license transfers, except for the ISFSI (partial site release) per the decommissioning schedule depicted in Figure 3-1. In accordance with 10 CFR 50.82(a)(9), the site LTP will be developed and submitted for NRC approval at least two (2) years prior to the expected date for partial site release. NRC license termination will occur following spent fuel and Greater than Class C (GTCC) waste removal from the site and decommissioning of the ISFSI.

The HDI decommissioning approach for IP1, 2 & 3 is described in the following sections.

x Section 2.0 describes the planned decommissioning activities and the general timing of their implementation.

x Section 3.0 presents the overall decommissioning schedule and milestones, including the spent fuel management activities, in a project timeline.

x Section 4.0 provides an analysis of expected decommissioning costs, including the costs associated with spent fuel management and site restoration.

x Section 5.0 describes the basis for concluding that the environmental impacts associated with decommissioning IP1, 2 & 3 are bounded by the NRC GEIS related to decommissioning.

x Section 6.0 provides the list of references.

x Enclosure 1 includes the IP1, 2 & 3 Site-Specific Decommissioning Cost Estimate (DCE) 5

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 2 DESCRIPTION OF PLANNED DECOMMISSIONING ACTIVITIES HDI will contract with Comprehensive Decommissioning International, LLC (CDI) to decommission IP1, 2 & 3 using the DECON method, as defined in Section 1.3 of this report. Use of the DECON method will require HDI to manage the spent fuel because of the DOE's failure to perform its contractual obligation to remove spent fuel in a timely manner. To explain the basis for projecting the cost of managing SNF, a discussion of spent fuel management activities for the site is included herein.

Prior to the sale and license transfer, ENOI will perform activities to permanently shut down and defuel the IP2 and IP3 reactors and place the units in a safe storage condition. To facilitate efficient transition of the site to DECON, ENOI, in coordination with HDI, will direct the activities that will facilitate transitioning to the HDI decommissioning plan.

In conjunction with HDI, CDI developed the decommissioning scope, schedule, and associated cost estimate for IP1, 2 & 3. CDI adopted the International Structure for Decommissioning Costing (ISDC) Work Breakdown Structure (WBS) (Reference 9) and corresponding WBS dictionary to develop the IP1, 2 & 3 site-specific DCE and decommissioning schedule. The ISDC, developed jointly by the Organization for Economic Cooperation and Development (OECD)/Nuclear Energy Agency (NEA), the International Atomic Energy Agency (IAEA) and the European Commission (EC), provides a method for developing standardized itemization of decommissioning costs. The ISDC WBS is a delivery-based, hierarchical structure that is identified as the international standard cost structure for nuclear facility decommissioning and is organized into eleven (11) groups. Of the eleven principal work groups, Activity 03-Additional Activities for Safe Enclosure and Entombment and Activity 09-Research and Development are not applicable to the prompt decommissioning approach planned for the IP1, 2 & 3 decommissioning.

Because the ISDC WBS is organized differently than those traditionally used for United States domestic decommissioning estimates, to facilitate a comparison of projected IP1, 2 &

3 decommissioning costs to the NRC Reference Pressurized Water Reactor (PWR) decommissioning costs contained in NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized-Water Reactor Power Station, (Reference

10) the decommissioning activities have been organized into periods similar to those described in NRC guidance.

For consistency with the DCE format found in Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, (Reference 11) the ISDC WBS has also been mapped into project periods. In addition to the periods described in the Regulatory Guide, Period 5 was established to account for long-term fuel storage costs, and Period 6 was established for instances where costs that are applicable to multiple periods are identified and quantified. The mapping of the 11 ISDC WBS elements to the project periods, is shown in Table 2-1.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Table 2-1 WBS Elements Mapped to Periods Period Period Title WBS Element Pre-Decommissioning 1 01.02.01 Pre-decommissioning actions Planning and Preparation 2 Plant Deactivation 01.02.02 Facility Shutdown Activities 3 Safe Storage Operations 01.02.10 Fuel and Nuclear Material (until fuel on pad) 01.02.04 Dismantling Activities Within the Radiological Controlled Area 4 Dismantlement 01.02.05 Waste Processing, Storage and Disposal 01.02.07 Conventional Dismantling, Demolition, and Site Restoration (LTP portion only) 5 Ongoing ISFSI Operations 01.02.10 Fuel and Nuclear Material (after fuel on pad) 01.02.06 Site Infrastructure and Operation 6 Program Management 01.02.08 Project Management, Engineering and Support 01.02.11 Miscellaneous Expenditures Note: WBS 01.02.03 and 01.02.09 are not used in the cost model The major decommissioning activities and the general sequence for performing the activities are discussed in more detail in the sections that follow. The project decommissioning schedule is shown in Figure 3-1.

2.1 Period 1 Pre-Decommissioning Planning & Preparation 2.1.1 Pre-Decommissioning Planning and Preparation (Pre-License Transfer)

HDI and CDI are working with ENOI to understand and support IP2 and IP3 plans for permanent shutdown, reactor defueling, and preparations for safe storage. These efforts are focused on facilitating the safe, compliant, and efficient license transfers and transition to prompt radiological decommissioning (i.e., DECON) once the sale and license transfers are complete.

The transition activities ensure that the decommissioning organization is fully prepared to assume the responsibilities of IP1, 2 & 3 decommissioning. Alignment with ENOI will begin well in advance of license transfer and sale closure. HDI will prepare a Transition Plan describing the process for conducting an orderly and effective transition in alignment with the NRC license transfers, site permits, licenses, etc. from ENOI to HDI.

2.1.2 Period 1 - Pre-Decommissioning Planning and Preparation Activities This section discusses the activities that will be performed by HDI and CDI prior to license transfer, and those that will be performed immediately following license transfer.

At the time of sale and license transfers, IP1, 2 & 3 will be in a defueled condition. HDIs decommissioning planning takes into account the IP2 and IP3 permanent shutdown and defueling transition activities in determining the expected site conditions at the time of the 7

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report license transfers. In the time leading up to, and immediately following, the sale closure and license transfers, the following activities will be performed:

x Decommissioning planning, including finalizing the plan for transitioning to DECON.

x Procurement of services, materials, and supplies.

x Stakeholder interaction.

x Review of the Historical Site Assessment (HSA) to support the identification, categorization, and quantification of radiological, regulated, and hazardous wastes in support of waste management planning.

x Development of the decommissioning As Low as Reasonably Achievable (ALARA) budget.

x Development of a Waste Management Plan (WMP), including determination of transportation and disposal container requirements and pathways.

x Performance of safety, security, and environmental studies, as required.

x Review of the IP1, 2 & 3 reclassification of plant SSCs.

x Reactor Vessel Internals (RVI) and Reactor Pressure Vessel (RPV) segmentation tooling design, fabrication, and testing.

x Licensing and permitting actions necessary to reflect the permanently defueled plant configurations During Period 1, planning and preparing for the prompt decontamination and dismantlement of IP1, 2 & 3 will begin by completing the following activities:

x Finalize the decommissioning organization, including integration of incumbent plant staff and CDI personnel. IP1, 2 & 3 personnel on site at the time of license transfer will be incorporated into the decommissioning organization according to their expertise and the position that they held within ENOI. Staffing and configuration requirements are expected to change during the period of decommissioning, principally dependent upon changes in license requirements, due to changes in the status of the spent fuel being stored onsite.

x Review the established IP1, 2 & 3 policies, programs, and procedures for ongoing activities, and identify changes to reflect the evolving plant status during decommissioning. The NRC requirements and functional needs for the anticipated plant conditions and DECON activities will be determined, and the procedures and programs will be evaluated for adoption, revision, replacement, or revocation using the appropriate NRC regulatory change processes. The plan is to adopt, revise, or eliminate existing IP1, 2 & 3 policies, programs, procedures, and work instructions, where applicable, since these documents have been used by IP1, 2 & 3 for operations in accordance with NRC regulations and the NRC license. As the plant statuses evolve due to decommissioning progress, these determinations and procedure/program evaluations and changes will periodically recur.

x Develop decommissioning Work Packages (WPs), including the radiation work 8

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report permits and job hazard analyses to support the WPs. Focus will be on the earliest activities in the schedule. To get input from the labor force who will be performing the work, area walkdowns with Subject Matter Experts (SMEs) and other appropriate personnel will be performed while preparing the WPs.

x Conduct site characterization activities so that radiological, regulated, and hazardous wastes are identified, categorized, and quantified to support decommissioning and waste management planning. Surveys will be conducted to establish the contamination and radiation levels throughout the plants. This information will be used in developing procedures to ensure that hazardous, regulated, and radiologically contaminated areas are remediated, and to ensure that worker exposure is controlled.

x Establish transportation and disposal contracts.

2.2 Period 2 - Plant Deactivation Many of the activities associated with termination of operations, plant stabilization, isolation, and initial inspection will be completed by ENOI. In the period between permanent reactor defueling and sale closure and license transfer, ENOI will execute activities to deactivate IP2 and IP3. The IP2 and IP3 deactivation activities include the following:

1. Continuing operation and maintenance of the systems required to safely manage the spent nuclear fuel and comply within NRC regulations and facility license requirements.

2. Isolating power equipment and installation of temporary power systems in preparation for decommissioning.

3. Removing combustibles and chemicals to permit fire protection system modifications.

Following the sale closure and license transfer, deactivation activities and other activities required to prepare the IP1, 2 & 3 for decommissioning will continue, as necessary.

2.3 Period 3 - Safe Storage Operation Since HDI has chosen the DECON method for IP1, 2 & 3 decommissioning, the activities in this period only include preparations for, and conduct of, fuel movement to an onsite dry fuel storage facility. This period concludes once the fuel has been removed from the spent fuel pools (SFPs) and placed into long-term storage at the ISFSI. Safe storage operation activities include the following:

x Construction of additional dry fuel storage capacity.

x Transfer of SNF to dry storage canisters.

x Movement of fuel to long-term storage at the ISFSI.

x Operation and maintenance of the ISFSI until the spent fuel is removed from the SFPs and placed in the ISFSI.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 2.4 Period 4 - Dismantlement The scope of Period 4 includes the dismantling and decontamination of plant systems and structures. The work scope described in this section concludes with the removed components packaged and placed in containers, and transported to storage, treatment, or disposal. The waste will be properly packaged, shipped and tracked until properly disposed.

Holtecs prompt decommissioning strategy does not rely on decontamination or offsite processing to accomplish free release of material and focuses instead on bulk removal of material as the most expedient and cost-effective solution to decommissioning. The end state of this work scope is to have the buildings cleared of all radioactive components and declared ready for free release or demolition. However, decontamination activities such as surface wipe-down will be performed as required to maintain worker exposure ALARA.

2.4.1 Asbestos Containing Material, Hazardous, and Universal Waste Removal Removal of all Asbestos Containing Material (ACM) is one of the first priorities. Asbestos removal is planned prior to dismantling SSCs. Work boundaries will be established and set up with containment structures, tents, glove bags, ventilation, etc., for ACM removal. Final verification survey of all facilities will be performed to ensure all ACM has been removed prior to dismantlement and decontamination.

Removal of hazardous and universal waste1 will also be conducted prior to dismantling SSCs, as constrained by the accessibility of the waste material. The waste will be placed in the proper containers for transportation to the appropriate disposal facility.

2.4.2 Site Characterization To supplement site historical knowledge and the IP1, 2 & 3 HSA, site characterization activities will be performed during the decommissioning process. The characterization will further the identification, categorization, and quantification of radiological, regulated, and hazardous wastes. Surveys will be conducted to establish the contamination and radiation levels throughout the site. The information will be used in developing procedures to ensure that hazardous, regulated, and radiologically contaminated areas are remediated, and to ensure that worker exposure is controlled. As decontamination and dismantlement work proceeds, surveys will be conducted to maintain current site characterization, and to ensure that decommissioning activities are adjusted accordingly.

2.4.3 Segmentation and Dismantling of the RVIs and RPV Segmenting, removing and packaging the RVI and RPV is critical to keeping the project on schedule. The RVI highly activated core grid segments are expected to generate most of the 1

Universal waste is a category of waste materials designated as hazardous waste but containing materials that are commonly generated by a wide variety of establishments. US Environmental Protection Agencys (USEPA) universal waste regulations streamline the hazardous waste management standards for these wastes.

It is identified in 40 CFR 273.9 by the USEPA and applies to four (4) specific categories of materials that can be managed as universal wastes: batteries, pesticides, mercury-containing equipment and lamps. States may have corollary regulations regarding these materials, as well as additional materials.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report GTCC waste. The decommissioning approach is to segment the RVI and RPV in parallel with the spent fuel cooling period, to shorten the overall decommissioning schedule.

Reactor vessel and internals segmentation activities will begin with IP3, proceed to IP2 and conclude with IP1. Due to the similarities in the design of the IP2 & IP3 reactors, the same tooling will be used to segment each of the IP2 and IP3 reactor vessels and reactor vessel internals. Lessons learned from the IP3 segmentation will result in efficiency gains for the IP2 work. The IP1 reactor will require a unique tooling design, segmentation plan and segmentation approach. Depending on the condition of the IP1 reactor vessel, there may be an opportunity to remove, ship and dispose of the vessel intact. However, for the purposes of this estimate, the IP1 reactor vessel is assumed to be size-reduced and shipped for disposal in a segmented configuration.

The GTCC waste that is generated during segmentation activities will be placed in dry storage canisters, transported away from the reactor buildings and stored at the ISFSI.

2.4.4 Fuel Pool and Reactor Cavity Dismantlement After the fuel has been removed from the IP2 and IP3 SFPs, the segmentation contractor will perform the fuel pool removal. The pools will be inspected with underwater cameras and radiation monitors to identify any special nuclear material or debris remaining after fuel movement. The IP1fuel was removed and the pool drained in 2008; however, inspection of the IP1 SFP will be performed to locate and remove any remaining special nuclear material or GTCC waste. Remote handling tools or vacuuming will be used to remove contamination found during the inspection. If any fuel fragments are identified, a regulatory compliant process will be used to remove and store the fragments.

The fuel racks will be removed from the pools, segmented, and size-reduced for disposal as Low-Level Radioactive Waste (LLRW). The SFP liners will be removed after the pools have been drained and decontaminated. Any GTCC waste generated from these activities will be placed in a dry storage cask, transported from the area, and stored on the ISFSI.

2.4.5 Large Component Dismantlement The WPs developed in Period 1 will be used to remove the large components and the plant systems by building or area, to avoid impacting other critical path work. Access limitations, crane availability, and radiological conditions will drive the technology used for cutting and segmenting components and piping. Systems and/or components will be breached, air gapped, and purged to eliminate liquid waste prior to segmenting. While many large components are expected to be radiologically contaminated, they are not expected to require pre-dismantling decontamination. Spray fixative will be used on components, or openings of piping will be capped to control contamination. Depending on the contamination levels and configuration of the segmented large components, CDI will either place the segments in an appropriate shipping container or send the component for disposal as its own package with suitable wrapping or capping.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report For each unit, the turbines, main condenser, moisture separator reheaters, feedwater pumps and heaters, and steam and feedwater piping are not expected to be radiologically contaminated. The subcontractor will remove large parts of the turbines (such as the low-pressure portion) intact and send the components offsite for disposal as intact packages suitably wrapped. The generators can be removed whole for recycling or reuse.

For each unit, the primary loop large components, including the steam generators and pressurizers will be removed from the Reactor Buildings. The auxiliary plant boilers, storage tanks, and the diesel generators will be removed.

2.4.6 Radioactive Waste Management A major component of the decommissioning work scope for IP1, 2 & 3 is the packaging, transportation, and disposing of contaminated/activated equipment, piping, concrete, and soil. A WMP will be developed in Period 1 to incorporate the most cost-effective disposal strategy, consistent with regulatory requirements and disposal/processing options for each waste type. Characterization will be performed with systems and components in place to determine the waste classification, maximizing the use of non-destructive assay techniques, and direct instrumentation readings correlated with hard analytical data gathered via direct smears and sampling. IP1, 2 & 3 decommissioning will include a number of discrete waste stream profiles and a range of shipping packages. A range of reusable and single use containers will be used, and some items will be transported as sealed components without containerization (they become their own packaging).

Most waste will meet Class A, Low Specific Activity (LSA), or Surface Contaminated Object (SCO) definitions. LLRW will be managed in accordance with the approved WMP and commercial disposal facility requirements. This includes characterizing contaminated materials, packaging, transporting, and disposal at a licensed LLRW disposal facility.

For Class B and C waste, an import petition will be filed with the Texas Compact Commission to gain approval to dispose of out-of-compact waste at the Waste Control Specialists (WCS) facility in Texas. The guidance in NUREG-2155, Implementation Guidance for Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material (Reference 12) will be used for radioactive material that meet the form, concentration and quantity-of-concern criteria in 10 CFR 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.

2.4.7 Waste Transportation The transportation approach for Class A, LSA, or SCO classes of waste is to use a combination of truck and rail to support bulk quantity removal of waste. Since there is no active rail at IP1, 2 & 3, trucks will be used to deliver the waste to a transload facility. The waste transportation process will be fully defined in the WMP to include the number of shipments, the disposal facilities and applicable requirements. HDI may elect to ship large plant components by barge.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 2.4.8 Removal of Mixed Wastes Low-Level Mixed Waste (LLMW) generation will be minimized through appropriate characterization, as well as the demolition techniques employed. If mixed wastes are generated, they will be managed in accordance with applicable federal and state regulations.

Mixed wastes from IP1, 2 & 3 will be transported by authorized and licensed transporters and shipped to authorized and licensed facilities.

2.4.9 License Termination including Final Status Surveys In accordance with the requirements of 10 CFR 50.82(a)(9), an LTP will be submitted to the NRC at least two (2) years prior to the anticipated date of partial site release (i.e.,

amendment of the facility licenses to limit the scope of the licenses to just the ISFSI). That plan will include: a site characterization, description of the remaining dismantling/removal activities, plans for remediation of remaining radioactive materials, developed site-specific Derived Concentration Guideline Levels (DCGLs), plans for the Final Status (radiation)

Survey (FSS), designation of the end use of the site, an updated cost estimate to complete the decommissioning, and associated environmental concerns.

The NRC-approved LTP will be used to perform the FSS, which will demonstrate that the remediated portion of the site (excluding the ISFSI containing the spent fuel and GTCC waste) can be released for unrestricted use and removed from the license. The site release criteria defined by the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (Reference 13) protocol will be used to demonstrate that the site release criteria have been met. The licenses will be amended to limit the NRC renewed facility operating licenses to the onsite ISFSI.

2.4.10 Site Restoration During demolition, above-ground structures will be removed to a nominal depth of three (3) feet below the surrounding grade level. Characterization surveys will then be performed in the remainder of the below ground structures and any areas with activity exceeding established DCGLs will be removed. Final Status Surveys, including NRC verification surveys, will be conducted. Once the NRC approves the Final Status Surveys, the affected area(s) will be backfilled with suitable fill materials, graded, and appropriate erosion controls established. Site restoration activities will begin in non-radiological areas after demolition of buildings and structures outside the radiological controlled area. Final site restoration will be completed after ISFSI decommissioning and demolition is completed.

2.5 Period 5 - Ongoing ISFSI Operations The HDI decommissioning plan includes the expansion of the existing ISFSI pad on the IPEC site to provide the dry cask storage capacity needed for the spent nuclear fuel currently in the IP2 and IP3 reactors and spent fuel pools. The expanded ISFSI will also include storage capacity for the GTCC waste. The spent fuel and GTCC waste will remain on the ISFSI until it is transferred to the DOE. The ISFSI will be staffed by a security force. In addition, personnel will be assigned to maintain the ISFSI and comply with the ISFSI 13

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report license requirements. Fuel and GTCC waste shipping will be performed when repositories for this type of waste are developed by the DOE. Approximately thirteen GTCC canisters are estimated to be needed for decommissioning activities. Following the removal of the spent fuel and GTCC waste, the ISFSI site will be decommissioned, remediated, and surveyed per the LTP. Following the Final Site Survey (FSS) and NRC approval, final license termination will occur.

2.6 Program Management Program management costs include infrastructure and operation, management, and fees that are applicable to decommissioning Periods 1 through 4. These costs include the following:

x Site infrastructure and operation costs, including security, maintenance, site upkeep, operation of support systems, and environmental monitoring.

x Project management, engineering, and support including the core management group, scheduling and cost control, quality assurance, health and safety, records management, general administration and accounting, warehousing, engineering, regulatory, and support services.

x Regulatory fees, taxes, and insurance.

2.7 Changes to Management and Staffing Following license transfers and sale closure, the management team will be comprised of HDI corporate leadership resources, supported by CDI leadership resources. The CDI management team will include Holtec and SNC-Lavalin personnel along with incumbent IPEC site personnel. This includes IP1, 2 & 3 personnel who transfer to CDI upon closure of the sale. These personnel will be integrated into the decommissioning organization according to their expertise and previous positions held while the plants were operating.

Additionally, corporate support from SNC-Lavalin and/or Holtec will be provided in areas such as legal, financial reporting systems, Information Technology (IT), procurement, and human resources.

The number of site personnel will vary throughout the life of the project, with increased or decreased staffing levels required as decommissioning activities ramp up or down, or as requirements for security and emergency planning are reduced. The staffing projections after license transfer and sale closure are described in Section 3 of the Enclosure 1 of this DECON PSDAR.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 3 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES 3.1 IP1, 2 & 3 Decommissioning Schedule Figure 3-1 IP1, 2 & 3 Decommissioning Schedule, provides a project timeline that presents the high-level project schedule and milestones for decommissioning, including spent fuel storage and licensing. The schedule provided herein assumes that the sale closure and license transfer are executed on May 31, 2021 and ends following ISFSI decommissioning and final license termination.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Figure 3-1 IP1, 2 & 3 Decommissioning Schedule 16

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 4 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS The HDI DECON site-specific DCE for the decommissioning of IP1, 2 & 3 following the scheduled permanent cessation of plant operations and an assumed license transfer date of May 31, 2021 is included as Enclosure 1 to this DECON PSDAR. Costs in the DCE were determined based on the selection of the DECON method for decommissioning IP1, 2 & 3.

CDI prepared the site-specific DECON DCE and schedule for HDI using several sources including the following:

x Information compiled by HDI and CDI during an extensive due diligence period.

x The site-specific decommissioning cost estimate in the ENOI preliminary DCE x Input and professional judgment of experienced specialty subcontractors and SMEs.

The site-specific DCE is based on regulatory requirements, site conditions, Basis of Estimate (BOE) assumptions, LLRW disposal standards, high-level radioactive waste management options, and site restoration requirements. The methods utilized to estimate decommissioning costs were based on the professional judgment of the experienced SMEs, considering the nature of the work, degree of scope definition, availability of quantifiable cost and pricing data, among other factors. The decommissioning costs presented in this report are reported in 2019 dollars. Escalation of future decommissioning costs over the remaining decommissioning project life-cycle are excluded.

The detailed decommissioning project schedule is used as the foundation for developing the DCE model and the risk model. The schedule baseline is a detailed Critical Path Method (CPM) schedule developed with input from the key decommissioning subcontractors and SMEs. The schedule and cost estimates are based on the ISDC WBS and corresponding WBS dictionary.

The site-specific DCE for decommissioning IP1, 2 & 3 demonstrates that adequate funding is available in the NDT fund for each unit to complete license termination activities for that unit. In addition to the license termination costs, site restoration and spent nuclear fuel management costs are included in this estimate; however, pursuant to regulatory requirements, the non-license termination cost estimates are segregated and listed separately.

The estimates are based on current and/or assumed regulatory requirements, site conditions, baseline assumptions, low-level radioactive waste disposal standards, high-level radioactive waste management options and site restoration requirements. The cost to decommission the site, safeguard the spent fuel until it can be transferred to the DOE and restore the affected area of the site is estimated to be $598 million for IP1, $702 million for IP2 and $1,002 million for IP3. The summary of the costs estimated for License Termination, Spent Fuel Management, and Site Restoration activities are presented in Table 4-1.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Table 4-1 IP1, 2 & 3 Decommissioning DECON Cost Summary (thousands of 2019 dollars)

Decommissioning Activity IP1 IP2 IP3 Decontamination Removal 162,256 186,173 197,721 Packaging 11,175 14,300 15,964 Transportation 41,043 19,637 28,135 Disposal 156,222 105,940 131,180 Off-site Waste Processing Program Management 119,726 144,384 182,529 Corporate A&G Spent Fuel (Direct Expenditures) 66,066 162,233 344,285 Insurance and Regulatory Fees 9,177 12,511 12,511 Energy 11,914 11,914 11,914 Characterization and Licensing Surveys 8,808 8,808 26,635 Property Taxes 22,537 38,676 Miscellaneous Equipment / Site Services 11,797 13,386 12,827 Spent Fuel Pool Isolation Grand Total 598,184 701,822 1,002,378 Cost Category IP1 IP2 IP3 License Termination 485,015 469,456 583,168 Spent Fuel Management 72,381 188,278 371,370 Site Restoration 40,788 44,088 47,840 Grand Total 598,184 701,822 1,002,378 18

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5 ENVIRONMENTAL IMPACTS 5.1 Environmental Impact of IPEC Decommissioning HDI has concluded that the environmental impacts associated with planned IPEC site-specific decommissioning activities are less than and bounded by the previously issued environmental impact statements and site-specific analysis summarized in this report.

10 CFR 50.82(a)(4)(i) requires that the PSDAR include, " ... a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." The following discussion provides the reasons for reaching this conclusion and is based on previously issued environmental impact statements:

1. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (herein referred to as the GEIS) (Reference 8).

2. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities (Reference 14)

3. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Final Report, Volume 1, December 2010 (herein referred to as the SEIS, Vol. 1) (Reference 15).

4. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Final, Volume 5, April 2018 (herein referred to as the SEIS, Vol.

5.) (Reference 16).

5. NUREG-1437, Revision 1, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, June 2013 (herein referred to as the SEIS, Revision 1) (Reference 17).

5.1.1 Onsite/Offsite Land Use The NRC concluded in the GEIS (Reference 8) that the experience of plants being decommissioned has not included any need for additional land offsite. Consistent with this determination, HDI does not anticipate any changes in land use beyond the site boundary during decommissioning.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.1.1.1 Onsite Land Use IPEC has sufficient previously disturbed area onsite (due to construction or operations activities) for use during decommissioning.

Stormwater discharges from the site are currently regulated by an existing State Pollutant Discharge Elimination System (SPDES) Permit No. NY0004472 (Reference 18), and any construction activities that would disturb one acre or greater of soil not covered by the existing permit would require a stormwater permit from the New York State Department of Environmental Conservation (NYSDEC) prior to proceeding with the activity. The SPDES permit, and any NYSDEC stormwater permit contain best management practices (BMPs) to control sediment and erosion effect on water courses and wetlands.

HDI may elect to ship large plant components by barge using an existing dock or other landing on the east bank of the Hudson River adjacent to the operational area of IPEC.

This shoreline was used during plant construction for delivery of the plant components and has continued to be used during operations for large component delivery. The dock or other landing location(s) are located on facility-owned property and would be accessed from within the operational area of the site. This land use would be for a short duration. No changes to land use patterns would result from the use of barge transportation.

HDI concludes that the impacts of IPEC decommissioning on onsite land use are bounded by the GEIS.

5.1.1.2 Offsite Land Use Section 4.3.1 of the GEIS (Reference 8) concluded that the impacts on land are not detectable or destabilizing and are small for facilities having only onsite land use changes resulting from large component removal, structure dismantlement, and LLRW packaging and storage. These decommissioning activities will be conducted on previously disturbed land within the site boundary.

The NRC concluded in the GEIS that the experience of plants being decommissioned has not included any needs for additional land offsite. Consistent with this determination, HDI does not anticipate any changes in land use beyond the site boundary during decommissioning.

If HDI elects to use barge transportation, it is not anticipated that dredging will be required to provide enough depth for barge navigation. However, if dredging is necessary, it will be conducted under U.S. Army Corps of Engineers (USACE) and appropriate NYSDEC permits.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report HDI concludes that the impacts of IPEC decommissioning on offsite land use are bounded by the GEIS.

5.1.2 Water Use After the shutdown of IP2 and IP3, the operational demand for once-through cooling water and makeup water will be dramatically decreased. The amount of water used by the service water system after shutdown will also be reduced over time. The need for cooling water will continue to decrease as the heat load of spent fuel in the SFPs declines due to radioactive decay, and as spent fuel is relocated from the SFPs to the ISFSI.

After the shutdown of IP2 and IP3, the use of potable water will decrease commensurate with the expected decrease in site staffing levels. For these reasons, Section 4.3.2 of the GEIS (Reference 8) concluded that water use at decommissioning nuclear reactor facilities is significantly smaller than water use during operation.

The GEIS also concluded that water use during the decontamination and dismantlement phase will be greater than that during the storage phase. There are no anticipated unique water uses associated with the decommissioning of IPEC that are not addressed by the evaluation of the reference facility in the GEIS.

Therefore, HDI concludes that the impacts of IPEC decommissioning on water use are bounded by the GEIS.

5.1.3 Water Quality (Non-Radiological)

During the DECON planning and defueling periods, stormwater runoff and drainage paths will be maintained in their current configuration. Regulatory mandated programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process. Federal, state, and local regulations and permits pertaining to water quality will also remain in effect.

IPEC will continue to receive potable water from the Village of Buchanan.

Industrial and stormwater discharges to surface water from the facility are subject to the terms and conditions of the existing SPDES permit (Reference 18). Areas of one acre or more disturbed during decommissioning that are not covered by the existing permits will require new stormwater permits from the NYSDEC. In addition to the specific permit requirements, selection and implementation of BMPs for stormwater that may be generated from areas disturbed by decommissioning activities is also required.

Sanitary waste water generated at the site is currently discharged to the Village of Buchanan publicly owned treatment works (POTW) and will continue to be discharged 21

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report to this facility. As decommissioning proceeds, management of sanitary wastewater may be transitioned to temporary, contained onsite facilities with transport of the sanitary waste to offsite facilities permitted to receive, treat and dispose of the wastes.

During decommissioning, IPEC will comply with applicable regulations requiring reporting of hazardous materials spills, and reasonable precautions will be taken to prevent or mitigate spills of hazardous materials.

There are no ongoing environmental investigations under NYSDEC regulations currently occurring at IPEC, and none are known to be required. In the event contamination subject to NYSDEC reporting and remediation requirements is discovered, it will be reported to the agency and addressed through an appropriate state cleanup program or agreement with the State.

The IPEC circulating water intake structures may be abandoned in place or removed.

The discharge structure may be returned to its owner,2 abandoned in place or removed.

Demolition of IPEC structures and buildings, and related earth-moving work (digging, grading, filling), has at least a limited potential to result in erosion and sedimentation that could affect water quality, but these kinds of construction activities routinely take place around operating nuclear power plants and are subject to the provisions of state-issued, and as applicable federal, permits and appropriate BMPs.

If barging is selected as a transportation method, dredging is not expected to be required.

However, if dredging is necessary, it will be conducted under USACE and appropriate NYSDEC permits and required certifications (e.g., Water Quality Certification). The NRC confirmed in the final SEIS, Vol. 5 (Reference 16) the NRCs prior findings in the GEIS (Reference 8) that the impact of dredging to remove accumulated sediments in the vicinity of intake and discharge structures and to maintain barge shipping has localized effects on water quality that tend to be short-lived, and that the impact of dredging on water quality is small for all nuclear plants.

The GEIS (Reference 8) concludes that the impacts of decommissioning on non-radioactive aspects of water quality are small and will be neither detectable nor destabilizing. The SEIS, Vol. 1 (Reference 15) found that that there would be no impacts on water quality associated with IPEC decommissioning beyond those discussed in the GEIS.

Therefore, HDI concludes that the impacts of IPEC decommissioning on water quality are bounded by the GEIS.

5.1.4 Air Quality There are many types of decommissioning activities listed in Section 4.3.4 of the GEIS (Reference 8) that have the potential to affect non-radiological air quality. For those 2

New York State Energy Research and Development Authority (NYSERDA) 22

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report activities applicable to the DECON method, IPEC does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality. HDI will maintain existing air permits, or obtain new permits as applicable, for equipment that will be used during IPEC decommissioning. Federal, state, county and local regulations pertaining to air quality will remain in effect to regulate emissions associated with fugitive dust, criteria air pollutants, hazardous air pollutants, and ozone depleting gases.

The GEIS concluded that air quality impacts associated with decommissioning are small. The SEIS, Vol. 1 (Reference 15) found that there would be no impacts on air quality associated with IPEC decommissioning beyond those discussed in the GEIS.

Therefore, HDI concludes that the impacts of IPEC decommissioning on air quality are bounded by the GEIS.

5.1.5 Aquatic Ecology Aquatic ecology encompasses the plants and animals in the intake structures and discharge canal, and the Hudson River. Aquatic ecology also includes the interaction of those organisms with each other and the environment. Section 4.3.5 of the GEIS (Reference 8) evaluates both the direct and indirect impacts from decommissioning on aquatic ecology.

Direct impacts can result from activities such as the removal of shoreline structures and active dredging. IPECs shoreline structures are similar to those present at the plants listed in Table E-2 of the GEIS, and there are no apparent discriminators based on the salient characteristics (size and location) listed in Table E-5 of the GEIS (Reference 8).

The area within the IPEC site boundary disturbed by original construction includes the existing dock, other shoreline structures and areas that may be used as a barge landing. The area proposed for moving large plant components during decommissioning from the IPEC power block to a dock or barge landing is within the plant operational area and was used for similar activities during original construction and operations. The GEIS (Reference 8) concludes that for decommissioning activities that do not disturb lands beyond operational areas, the effects on aquatic ecology are not detectable or destabilizing, and that effects on aquatic ecology related to use of a dock or barge loading area and dredging for barge navigation are small.

Abandonment or removal of intake and discharge facilities and other shoreline structures, and use of a dock or barge landing, including dredging if needed, will be conducted in accordance with BMPs defined in permits issued by the NYSDEC and USACE, as applicable. The NRC concluded in the GEIS (Reference 8) and confirmed in the SEIS, Vol. 5 (Reference 16) that the impact of dredging on aquatic resources would be small because dredging occurs infrequently over a relatively short duration and affects relatively small areas.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report As described in Section 5.1.2, the amount of cooling water withdrawn from the intake canal will dramatically decrease after IP2 and IP3 are shutdown and defueled, thus reducing the potential impacts from impingement and entrainment of aquatic species during the period when spent fuel continues to be stored in the SFPs and reducing the potential for thermal impacts. After transfer of the spent fuel to the ISFSI, the amount of water withdrawn will continue at a reduced flow rate as needed to support remaining decommissioning activities.

Any significant potential for sediment runoff or erosion on disturbed areas will be controlled in accordance with BMPs outlined in the current NYSDEC SPDES permit (Reference 18), and any new stormwater permit obtained from the NYSDEC.

The SEIS, Volume 1 (Reference 15) found that there would be no impacts on ecological resources associated with decommissioning beyond those discussed in the GEIS. Therefore, HDI concludes that the impacts of IPEC decommissioning on aquatic ecology are bounded by the GEIS.

5.1.6 Terrestrial Ecology Terrestrial ecology considers the plants and animals near IPEC, as well as the interaction of those organisms with each other and the environment. Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plants and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation.

Section 4.3.6 of the GEIS (Reference 8) evaluates the potential impacts from both direct and indirect disturbance of terrestrial ecology.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland. HDI does not anticipate disturbing habitat beyond the operational areas of the units. All dismantlement, demolition, and waste staging activities are envisioned to be conducted within the operational area of the site.

Indirect impacts may result from effects such as erosional runoff, dust or noise. Any construction activities that would disturb one acre or greater of soil would be subject to the requirements of the existing SPDES permit, or a new stormwater permit from the NYSDEC, prior to proceeding with the activity. The permits would contain BMPs to control sediment and the effects of erosion associated with the construction activity.

Fugitive dust emissions will be controlled through the judicial use of water spraying.

The basis for concluding that the environmental impacts of noise are bounded by the GEIS is discussed in Section 5.1.16 below.

Section 4.3.6 of the GEIS (Reference 8) concludes that if BMPs are used to control indirect disturbances and habitat disturbance is limited to operational areas, the potential impacts to terrestrial ecology are small. As discussed above, there are no unique disturbances to the terrestrial ecology anticipated during the decommissioning 24

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report of IPEC. Accordingly, HDI concludes that impacts of decommissioning activities within the IPEC operational area would be small.

An existing dock or a barge landing at the Hudson River shoreline within the operational area may be used to transfer large plant components and other materials to barges during decommissioning. These areas have been used during original construction and plant operation for similar activities. Any transfer of large plant components, soil or debris from demolition activities during decommissioning would be of short duration and would have minimal impact on terrestrial resources because the components will be transported to the barge loading area within the previously-disturbed operational area of the site that contains no unusual, rare, or sensitive plants or animals, and no important or sensitive habitats. Because no high-value terrestrial habitats will be disturbed, impacts are expected to be small and should not require mitigation beyond routine construction BMPs.

The SEIS, Vol. 1 (Reference 15) found that there would be no impacts on ecological resources associated with decommissioning beyond those discussed in the GEIS.

Therefore, HDI concludes that the impacts of IPEC decommissioning on terrestrial ecology, including those outside of the operational area, are small and bounded by the GEIS.

5.1.7 Threatened and Endangered Species Section 4.3.7 of the GEIS (Reference 8) does not make a generic determination of the impact of decommissioning on threatened and endangered species, and it concludes that the adverse impacts and associated significance of the impacts must be determined on a site- specific basis. The NRC noted in the GEIS that impacts to threatened and endangered species are expected to be minor and nondetectable if decommissioning activities are confined to site operational areas.

Table 5.1 identifies federally listed species potentially occurring in the vicinity of IPEC and the effect determinations found by the NRC in the SEIS, Vol. 5 (Reference 16).

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report TABLE 5.1 Effect Determinations for Federally Listed Species and Critical Habitats related to Indian Point Energy Center Listed Species(a) Common Name Federal Status SEIS Effect Determination Acipenser brevirostrum Shortnose Sturgeon Endangered May affect, not likely to jeopardize continued existence of Acipenser oxyrinchus Atlantic Sturgeon Endangered/ May affect, not likely to Threatened jeopardize continued existence of Clemmys muhlenbergii Bog Turtle Threatened No effect Myotis septentrionalis Northern Long-eared Threatened Not likely to adversely affect Bat Myotis sodalis Indiana Bat Endangered Not likely to adversely affect Critical Habitat New York Bight DPS3 Atlantic Sturgeon Not likely to destroy or adversely modify A review of threatened and endangered terrestrial species in the IPEC area was presented in the SEIS, Vol. 1 (Reference 15) and further discussed in the SEIS, Vol. 5 (Reference 16).

In 2008, the State of New York designated 194 species as endangered, threatened, of special concern (animals) or rare (plants), in Westchester County (SEIS, Vol. 1:

Reference 15). An updated list of State of New York threatened, endangered, special concern and rare terrestrial species potentially present in the vicinity of IPEC was requested from the New York Natural Heritage Program (NYNHP) in November 2019. The list from NYNHP will be reviewed to confirm that it is similar to the list of species potentially present in the vicinity of IPEC issued in 2008.

The federally-listed threatened and endangered species potentially present in the vicinity of IPEC that were identified and addressed in the SEIS, Vol. 5 (Reference 16) have been confirmed as current through review of available U.S. Fish and Wildlife Service (USFWS) on-line information resources.4 5.1.7.1 Protected Terrestrial Species A review of threatened and endangered terrestrial species in the IPEC area was presented in the SEIS, Vol. 1 (Reference 15) and further addressed in the SEIS, Vol. 5 (Reference 16).

In 2010, the NRC noted that three federally-listed species were present in the vicinity of IPEC: the endangered Indiana Bat (Myotis sodalis); threatened Bog Turtle 3

DPS - Distinct Population Segment 4

USFWS Information for Planning and Consultation (IPaC) Environmental Conservation Online System (ECOS).

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report (Clemmys muhlenbergii); and candidate (for listing) New England Cottontail rabbit (Sylvilagus transitionalis). NRC concluded that continued operation of IP2 and IP3 was not expected to adversely affect any federally-listed, threatened or endangered terrestrial species during the license renewal term (SEIS, Vol. 1; Reference 15).

The NRC concluded that the New England Cottontail rabbit was unlikely to occur on or in the vicinity of IPEC (SEIS, Vol. 1; Reference 15). In 2015, the USFWS issued a determination that listing of the New England Cottontail rabbit as an endangered species was not warranted. The State of New York continues to list the New England Cottontail rabbit as a species of special concern.

The Northern Long-Eared Bat (NLEB) (Myotis septentrionalis) was added to the federal list of endangered species in April 2015. In June 2015 Entergy submitted information to the NRC relevant to the potential for impacts to the NLEB and Indiana Bat related to license renewal (Reference 19). The NRC reinitiated consultation with the USFWS under Section 7 of the Endangered Species Act of 1973, as amended, for the NLEB and Indiana Bat, and issued a biological assessment with USFWS concurrence concluding that the proposed IP2 and IP3 license renewal may affect, but is not likely to adversely affect, the NLEB and Indiana Bat (SEIS, Vol. 5: 616).

The NRC concluded in the SEIS, Vol. 5 (Reference 16) that the Bog Turtle is unlikely to occur on or in the immediate vicinity of the site and further determined that license renewal (including refurbishment if conducted) would have no effect on the Bog Turtle.

There appears to be sufficient space within the operational area for all decommissioning activities and temporary storage of materials and equipment. If barge transportation is used, moving large plant components within the operational area to the barge landing will likely involve heavy equipment and could produce some minor soil disturbance. These activities will be of short duration and take place in previously disturbed areas on IPEC-owned land that has very little value as wildlife habitat. No protected terrestrial species will be affected by this activity.

5.1.7.2 Protected Aquatic Species In 2010, the NRC identified the Shortnose Sturgeon (Acipenser brevisrostrum) as a federally-listed endangered species, and the Atlantic Sturgeon (Acipenser oxyrinchus) as a candidate species, present in the Hudson River in the vicinity of IPEC and concluded that impacts from continued operation and maintenance of IPEC for the license renewal term was SMALL (SEIS, Vol. 1; Reference 15).

The New York Bight Distinct Population segment of the Atlantic Sturgeon (along with the Gulf of Maine, Chesapeake, Carolina and South Atlantic DPS) was federally-listed as a threatened species in April 2012. In January 2013, the National Marine Fisheries Service (NMFS) issued a Biological Opinion (Reference 20) concluding that the 27

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report continued operation of IP2 and IP3 was likely to adversely affect but not likely to jeopardize the continued existence of the Shortnose and Atlantic Sturgeons.

In 2016, NRC staff prepared and submitted to the NMFS an assessment evaluating the potential effects of continued IP2 and IP3 operation through the proposed license renewal term on proposed Atlantic Sturgeon critical habitat in the Hudson River and concluded that the proposed license renewal would not inhibit the growth, development, recruitment, or survival of juvenile, subadult or adult Atlantic Sturgeon or otherwise appreciably diminish the value of the proposed critical habitat (Reference 21).

In August 2017, the NMFS issued a conference report concluding that effects to the proposed critical habitat for the Atlantic Sturgeon population of the New York Bight Distinct Population Segment (DPS) are insignificant and discountable and the effects of license renewal are not likely to adversely affect the critical habitat proposed for the New York Bight DPS of Atlantic Sturgeon (Reference 22).

In the SEIS, Vol. 5 (Reference 16), the NRC documented the consultation process and the several NMFS and NRC findings, and concluded that the license renewal may affect but was not likely to jeopardize the continued existence of the Shortnose and Atlantic sturgeons and was not likely to destroy or adversely affect critical habitat of the Atlantic Sturgeon population of the New York Bight.

In the GEIS (Reference 8), the NRC anticipated that the potential impacts of decommissioning on aquatic threatened or endangered species will normally be no greater than and likely far less than the potential impacts of plant operations because the cooling system is not used at a unit undergoing decommissioning.

After permanent reactor shutdown and defueling, the potential for environmental impacts due to impingement and entrainment will be reduced by the dramatically lower flow rates and thermal differentials associated with decommissioning activities.

Discharges from the facility will be reduced to those associated with continued operation of the SFPs for several years, discharges associated with decommissioning activities, and stormwater. Flow rates will be further reduced after transfer of the spent fuel from the SFPs to the ISFSI, and shutdown of the SFPs. Discharges during decommissioning will continue to be regulated by the SPDES permit (Reference 18) or new NYSDEC stormwater permits, as applicable.

If selected as a transportation option, barging large plant components from IPEC on the Hudson River and beyond is not expected to require dredging for barge navigation; however, if dredging is needed, it will be conducted in accordance with applicable federal, state and local permits and certifications that include consideration of environmental impacts to threatened and endangered species. In the SEIS, Revision 1 (Reference 17), the NRC noted that if dredging could affect threatened or endangered 28

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report species or critical habitat, as established under the Endangered Species Act, the USACE must consult with the USFWS or the NMFS before it makes a permit decision.

Dredging would be conducted in accordance with BMPs defined in the applicable permits issued by the NYSDEC and USACE.

5.1.7.2 Conclusion HDI anticipates that decommissioning activities at IPEC will not encroach on the habitat of any state or federally-listed terrestrial species. Any indirect (disturbance-related) impacts from construction noise and human activity are expected to be localized, of short duration, and ecologically insignificant.

When the details of decommissioning activities, such as demolition or disturbance of land areas that could affect a protected species have been finally determined and scheduled, if potential impacts associated with those activities are considered unbounded by existing environmental impact statements and evaluations, the site-specific assessment of environmental impacts to protected species in the PSDAR will be updated, or provided through a separate and appropriate permit or certification process (e.g., USACE permitting).

Based on the site-specific information presented in this section, and conclusions reached by the NRC in the GEIS (Reference 8), SEIS, Vol. 1 (Reference 15, SEIS, Vol. 5 (Reference 16) and SEIS, Revision 1, (Reference 17) HDI concludes that IPEC decommissioning activities are unlikely to significantly affect any threatened or endangered species, and will have no effect on any designated critical habitat.

Therefore, HDI concludes that the impacts of IPEC decommissioning on threatened and endangered species are analogous to those presented in the SEIS, Vols. 1 and 5, and the SEIS, Revision 1, and are therefore bounded by them.

5.1.8 Radiological The GEIS (Reference 8) considered radiological doses to workers and members of the public when evaluating the potential consequences of decommissioning activities.

5.1.8.1 Occupational Dose The occupational radiation exposure to IPEC plant personnel will be maintained ALARA and below the occupational dose limits in 10 CFR Part 20 during decommissioning. The need for plant personnel to routinely enter radiological areas to conduct maintenance, calibration, inspection, and other activities associated with an operating plant will be reduced, thus it is expected that the occupational dose to plant personnel will significantly decrease after the plant is permanently shutdown and defueled.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report IPEC will be within the range of the cumulative occupational dose estimates for decommissioning PWR plants of 560 - 1,215 person-rem (per reactor) provided in Table 4-1 of the GEIS (Reference 8). Each of the three IPEC units are bounded by the PWRs evaluated in the GEIS, and because the ALARA program will be maintained to ensure that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits.

HDI concludes that the impacts of IPEC decommissioning on occupational dose are small and are bounded by the GEIS.

5.1.8.2 Public Dose Section 4.3.8 of the GEIS considered doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-15 of the GEIS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower.

The GEIS also concluded that the collective dose, and the dose to the maximally exposed individual from decommissioning activities, are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50. In Section 7.1 of the SEIS, Vol. 1 (Reference 15), no new or significant information was identified during the NRCs independent review of IPEC to indicate that public radiation dose impacts would occur during decommissioning beyond those discussed in the GEIS.

A plume of radiologically-contaminated ground water associated with the IP1 and IP2 spent fuel pools was discovered in 2005, fully investigated and subject to an ongoing Long-Term Monitoring Program (LTMP). The primary contaminants in the plume are tritium and strontium-90. The selected remedy is Monitored Natural Attenuation (MNA) being addressed under the oversight of the NRC. NRC has concluded that the LTMP has been effectively implemented and conforms to regulatory requirements that protect public health and safety and the environment (SEIS, Vol.5; Reference 16). HDI will continue the LTMP, including provisions of the program intended to detect inadvertent releases that may affect ground water, until the objectives of the selected MNA remedy are achieved.

The expected radiation dose to the public from IPEC decommissioning activities will be maintained within regulatory limits and below comparable levels when the plants were operating through the continued application of radiation protection and contamination controls, combined with the reduced source term available in the facility.

Also, Section 7.1 of the SEIS, Vol. 1 (Reference 15) concluded that there would be no public radiation dose impacts associated with decommissioning of IPEC beyond those discussed in the GEIS (Reference 8).

HDI concludes that the impacts of IPEC decommissioning on public dose are small and are bounded by the GEIS.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.1.9 Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety after IP2 and IP3 are permanently shutdown and defueled is considerably lower than the likelihood of a release from the plants during power operation. This is because most of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor. Furthermore, handling of spent fuel assemblies will continue to be controlled under work procedures designed to minimize the likelihood and consequences of a fuel handling accident. In addition, emergency plans and procedures will remain in place to protect the health and safety of the public while the possibility of significant radiological releases exists.

Section 4.3.9 of the GEIS (Reference 8) assessed the range of possible radiological accidents during decommissioning and separated them into two (2) general categories; fuel related accidents and non-fuel related accidents. Fuel related accidents have the potential to be more severe, and zirconium fire accidents could produce offsite doses that exceed the EPA's protective action guides. As part of its effort to develop generic, risk-informed requirements for decommissioning, the NRC staff performed analysis of the offsite radiological consequences of beyond-design-basis SFP accidents using fission product inventories at 30 and 90 days, and two (2), five (5), and ten (10) years.

The results of the study indicate that the risk at SFPs is low, and well within the NRCs Quantitative Health Objectives. The generic risk is low primarily due to the very low likelihood of a zirconium fire.

The potential for decommissioning activities to result in radiological releases not involving spent fuel (i.e., releases related to decontamination, dismantlement, and waste handling activities) will be minimized by use of procedures and methods designed to minimize the likelihood and consequences of such releases.

Therefore, HDI concludes that the impacts of IPEC decommissioning on radiological accidents are small and are bounded by the previously issued GEIS.

5.1.10 Occupational Issues Occupational issues are related to human health and safety. Section 4.3.10 of the GEIS (Reference 8) evaluates physical, chemical, ergonomic, and biological hazards. HDI has reviewed these occupational hazards in the GEIS and concluded that the decommissioning approach chosen for IPEC poses no unique hazards from those evaluated in the GEIS. HDI will continue to maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state, and local occupational safety standards and requirements continue to be met.

Section 4.3.10 in the GEIS concluded that impacts due to occupational issues would be small for all plants based on strict adherence to NRC and Occupational Safety and Health Administration (OSHA) standards, practices, and procedures. Therefore, HDI 31

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report concludes that the impacts of IPEC decommissioning on occupational issues are bounded by the GEIS.

5.1.11 Cost Decommissioning costs for IPEC are discussed in Section 4.0 and in Enclosure 1 to this report. Section 4.3.11 of the GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act (NEPA) requirement. Therefore, a bounding analysis is not applicable.

5.1.12 Socioeconomics Decommissioning of IPEC is expected to result in negative socioeconomic impacts. As IPEC ceases operation and transitions through the phases of decommissioning, an overall decrease in site workforce and tax payments will occur. The lost wages of these site staff will result in decreases in revenues available to support the local economy and local tax authorities. Some laid-off workers may relocate, thus potentially impacting the local cost of housing and availability of public services.

Section 4.3.12 of the GEIS (Reference 8) evaluated changes in workforce and population changes, changes in local tax revenue, and changes in public services. The decommissioning method selected for IPEC is DECON, with decommissioning planned to begin shortly after shutdown. The GEIS noted that when decommissioning begins shortly after shutdown, the impact of facility closure is mitigated, with less immediate negative impacts than would occur with the SAFSTOR and ENTOMB decommissioning methods.

The GEIS concluded that socioeconomic impacts of decommissioning are neither detectable nor destabilizing, and that mitigation measures are not warranted.

Therefore, HDI concludes that the impacts of IPEC decommissioning on socioeconomic impacts are bounded by the GEIS.

5.1.13 Environmental Justice Executive Order 12898 dated February 16, 1994, (Reference 23) directs federal executive agencies to make achieving environmental justice a part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects on minority and low-income populations. In a policy statement published in the Federal Register on August 24, 2004 (69 FR 52040) the NRC committed to meet the general goals of the executive order related to its regulatory or licensing actions through the NEPA review process (Reference 24).

Section 4.3.13 in the GEIS (Reference 8) determined environmental justice to be an environmental impact area for which no generic conclusion could be determined due to its site-specific nature. Therefore, the GEIS indicates that site-specific 32

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report assessments for each decommissioning nuclear power plant must be prepared.

HDI conducted a site-specific assessment of environmental justice as it relates to the effects of IPEC decommissioning. HDI examined the geographic distribution of minority and low-income populations within a 50-mile radius of IPEC using the 2013-2017 American Community Survey 5-year estimates. Census block groups containing minority populations were identified and were concentrated in the larger census defined urban areas, such as the New York-Newark urbanized area located from 25 to 50 miles south of IPEC. The nearest minority population is located about 1 mile north of IPEC in Peekskill, NY. Census block groups containing low-income populations were also concentrated in the census defined urbanized areas located 25 to 50 miles south of the site. The nearest low-income population is in Peekskill approximately 2 miles north of IPEC. The locations and population characteristics of minority and low-income populations are similar to those evaluated by the NRC in the SEIS, Vol. 5 (Reference 16).

HDI has determined that decommissioning impacts to all resource areas would be small, indicating that the effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. Because no member of the public will be substantially affected, there can be no disproportionately high and adverse impacts on minority and low-income populations resulting from the decommissioning of IPEC. Based on these site-specific findings, HDI concludes that the impacts of IPEC decommissioning on minority and low-income populations are small.

33

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.1.14 Cultural, Historic and Archeological Resources Section 4.3.14 in the GEIS (Reference 8) determined that potential effects of decommissioning on cultural, historical and archaeological resources would be small for all plants when the decommissioning activities are confined to the operational area. However, impacts outside the operational area "must be determined through site-specific analysis."

A review of New York State Historic Preservation Office (NYSHPO) regarding cultural, historical, and archaeological resources site showed that there were no previously recorded archeological or above-ground historic architectural resources identified on the IPEC property (SEIS, Vol. 1: Reference 15). The NRC concluded that the power block area and other areas south and east of the power block have been disturbed during site preparation and construction and have little to no potential for archeological resources. The NRC also found a potential for portions of the property not disturbed by construction activities south of the power block area and in the northeast portion of the IPEC property to contain intact subsurface archeological deposits (SEIS, Vol. 5: Reference 16).

HDI anticipates that decommissioning activities will take place within the IPEC operational and previously disturbed areas. In the event that ground disturbance is proposed in areas outside operational and previously disturbed areas, or historical or archeological resources are encountered during excavation, assessments and consultation with NYSHPO will be conducted, as appropriate.

Therefore, HDI concludes that potential for impacts to cultural, historical and archaeological resources is bounded by the GEIS.

5.1.15 Aesthetic Issues During decommissioning, the impact of activities on aesthetic resources will be temporary and remain consistent with the aesthetics of an industrial site. In most cases, Section 4.3.15 of the GEIS (Reference 8) concludes that impacts such as dust, construction disarray, and noise would not easily be detectable offsite.

The GEIS concluded that the demolition and dismantlement of structures during decommissioning using the DECON method could result in aesthetic impacts improving fairly rapidly as a result of the removal of structures and restoration of the site. The GEIS concludes that the removal of structures is generally considered beneficial to the aesthetic impacts of the site, and that the potential aesthetic impacts of decommissioning are small.

Therefore, HDI concludes that the impacts of IPEC decommissioning on aesthetic issues are bounded by the GEIS.

34

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.1.16 Noise General noise levels during the decommissioning process are not expected to be any more severe than during refueling outages and are not expected to present an audible intrusion on the surrounding community. Some decommissioning activities may result in higher than normal onsite noise levels (i.e., some types of demolition activities).

However, these noise levels would be temporary and are not expected to present an audible intrusion on the surrounding community.

Section 4.3.16 of the GEIS (Reference 8) indicates that noise impacts are not detectable or destabilizing and makes a generic conclusion that potential noise impacts are small.

Based on the standard decommissioning approach proposed for IPEC, HDI concludes that the impacts of IPEC decommissioning on noise are bounded by the GEIS.

5.1.17 Transportation The transportation impacts of decommissioning are dependent on the number of shipments to and from the site, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans. The shipments from the site would be primarily radioactive waste and non-radioactive waste associated with dismantlement and disposal of SSCs.

The total estimated cubic feet of radioactive waste associated with IPEC decommissioning destined for land disposal at an LLRW (Class A, B or C) disposal facility, or GTCC geologic repository is summarized below:

x Class A: 7,136,775 cubic feet x Class B: 2,413 cubic feet x Class C: 2,236 cubic feet x GTCC: 4,534 cubic feet The estimated LLRW volume (Class A, B, and C) for IPEC that is destined for land disposal will be approximately 7.1 million cubic feet using the DECON method. Of this volume, approximately 3.3 million cubic feet is estimated to be soil contaminated at very low levels.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report Estimated waste volumes by unit are provided below.

IP-1 IP-2 IP-3 Waste Class Waste Volume Waste Volume Waste Volume (cubic feet) (cubic feet) (cubic feet)

Low-Level A 3,586,546 1,365,109 2,185,120 Radioactive Waste B 1,411 501 501 C 1,088 574 574 Greater than Class C GTCC 412 2,061 2,061 Waste Total 3,589,457 1,368,245 2,188,256 Total LLRW 3,589,045 1,366,184 2,186,195 The waste volumes requiring disposal as LLRW are anticipated to exceed the high-end estimate listed in Table 4-7 of the GEIS (Reference 8) on a per unit basis due to comparatively greater volumes of very low-level radioactive waste. The greater volumes are primarily the result of the volume of very low-level contaminated soil. The NRC noted in the GEIS (Reference 8) that the volumes and number of shipments evaluated for transportation impacts were received from a limited number of plants and may have been significantly higher or lower than the average facility for each reactor type.

HDIs objective for decommissioning of IPEC under the DECON method is to achieve unrestricted release and is anticipated to include removal and offsite disposal of most, if not all, above grade structures and contaminated soil. The NRC recognized in the GEIS (Reference 8) that facilities being decommissioned using the DECON method with an objective of achieving unrestricted release, including removal of all structures, could result in disposal of considerable volumes of radioactive and non-radioactive waste.

HDI must comply with applicable regulations when shipping radioactive waste from decommissioning. The NRC has concluded in Section 4.3.17 of the GEIS that these regulations are adequate to protect the public against unreasonable risk from the transportation of radioactive materials. Shipments will occur over an extended period of time and will not result in significant changes to local traffic density or patterns, or significant dose to workers or the public.

A portion of the waste may be removed from the site by barge and transported to an appropriate offsite location where it will be transferred to railcars or trucks for shipment to an appropriate disposal facility. If implemented, barge transportation will reduce the number of shipments from the site over local roadways. The use of barge transportation will increase marine vessel traffic in the area. It is expected that these activities will not cause a navigational safety hazard or a substantial delay in the normal movements of commercial or recreational vessels.

Shipments of non-radioactive wastes from the site are not expected to result in measurable deterioration of affected roads or a destabilizing increase in traffic density.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report The GEIS (Reference 8) concludes that both non-radiological and radiological impacts of decommissioning transportation are not detectable or destabilizing. The NRC reached a generic conclusion that for all plants, the potential transportation impacts are small. No unique features or site-specific conditions are present at IPEC that would alter these findings. Therefore, HDI concludes that the potential impacts of IPEC decommissioning on transportation are bounded by the GEIS.

5.1.18 Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Uranium is a natural resource that is irretrievably consumed during power operation.

After the plants are permanently shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short-term investment.

Since the IPEC site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. The only irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (i.e., rags, solvents, gases, and tools), and the fuel used for decommissioning activities and transportation of materials to and from the site.

However, the use of these resources is minor.

The NRC concluded in Section 4.3.18 of the GEIS (Reference 8) that the impacts of decommissioning on irreversible and irretrievable commitments of resources are small. Therefore, HDI concludes that the impacts of IPEC decommissioning on irreversible and irretrievable commitment of resources are bounded by the GEIS.

5.2 Environmental Impacts of License Termination In accordance with 10 CFR 50.82(a)(9), the site LTP will be developed and submitted for NRC at least two (2) years prior to the expected date for partial site release.

According to the schedule provided in Section 3 of this PSDAR, an LTP for the IPEC site will be developed to support a planned partial site release date in 2033. The LTP is scheduled to be submitted to the NRC in 2030. NRC final license termination will occur following the removal of spent nuclear fuel and GTCC waste from the site as well as completion of ISFSI decommissioning. As shown on the schedule provided in Section 3, ISFSI decommissioning is planned to be completed in 2062At that time, a supplemental environmental report will be submitted as required by 10 CFR 50.82(a)

(9). While detailed planning for license termination activities will not be performed until after completion of most of the DECON decommissioning activities for site areas except the ISFSI, the absence of any unique site-specific factors, significant groundwater contamination, unusual demographics, or impediments to achieving unrestricted release suggest that impacts resulting from license termination will be similar to those evaluated in NUREG-1496 (Reference 14).

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 5.3 Discussion of Decommissioning in the SEIS Postulated impacts associated with decommissioning are discussed in Section 7.0 of the SEIS, Vol. 1 (Reference 15), which identified six (6) issues related to decommissioning as follows:

x Radiation Doses x Waste Management x Air Quality x Water Quality x Ecological Resources x Socioeconomic Impacts The NRC staff did not identify any new and significant information during their independent review of the IPEC license renewal environmental report at that time, the site audit, or the scoping process for license renewal. Therefore, the NRC concluded that there are no impacts related to these issues beyond those discussed in the SEIS, Vol. 1 (Reference 15), SEIS, Vol. 5 (Reference 16) or the GEIS (Reference 8) for decommissioning. For the issues above, the license renewal and decommissioning GEIS concluded the anticipated impacts are small. The NRC found no site-specific issues related to decommissioning and there are no decommissioning activities contemplated for IPEC that would alter that conclusion.

5.4 Additional Considerations While not quantitative, the following considerations are relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed:

x The release of effluents will continue to be controlled by license requirements and plant procedures.

x IPEC will continue to comply with the Offsite Dose Calculation Manual, Radiological Environmental Monitoring Program, and the Groundwater Protection Initiative Program during decommissioning.

x Releases of non-radiological effluents will continue to be controlled per the requirements of the SPDES permit (Reference 18) and applicable NYSDEC permits.

x Systems used to treat or control effluents during power operation will either be maintained or replaced by temporary or mobile systems for the decommissioning activities.

x Radiation protection principles used during plant operations will remain in 38

Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report effect during decommissioning.

x Sufficient decontamination and source term reduction prior to dismantlement will be performed to ensure that occupational dose and public exposure will be maintained below applicable limits.

x Transport of hazardous and or radioactive waste will be in accordance with plant procedures, applicable federal regulations, and the requirements of the receiving facility.

Site access control during decommissioning will minimize or eliminate radiation exposure pathways to the public.

Additionally, NUREG-2157 (Reference 25) found that the generic environmental impacts of ongoing spent fuel storage are small.

5.5 Conclusions Based on the above discussions, HDI concludes that the environmental impacts associated with planned IPEC site-specific decommissioning activities will be bounded by appropriate, previously issued environmental impact statements. Specifically, the environmental impacts are bounded by the GEIS (Reference 8), SEIS, Vol. 1 (Reference 15), SEIS, Vol. 5. (Reference 16), SEIS, Revision 1 (Reference 17) and the site-specific analyses summarized in this report.

1. The postulated impacts associated with the decommissioning method chosen, DECON, have already been considered in the SEIS and GEIS, or addressed in the site-specific analyses summarized in this report.

2. There are no unique aspects of IPEC or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the SEIS and GEIS.

3. The methods assumed to be employed to dismantle and demolish IPEC are standard construction-based techniques fully considered in the SEIS and GEIS.

Therefore, it can be concluded that the environmental impacts associated with the site-specific decommissioning activities for IPEC will be bounded by appropriate previously issued environmental impact statements.

10 CFR 50.82(a) (6) (ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2 that result in significant environmental impacts not previously reviewed. No such impacts have been identified.

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report 6 REFERENCES

1. Letter, US NRC to Con Edison, Order to Authorize Decommissioning and Amendment No. 45 to License No. DPR-5 for Indian Point Unit No. 1, January 31, 1996.

2. Letter, ENOI to US NRC, Notification of Permanent Cessation of Power Operations Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64, dated February 8, 2017.

3. Letter, ENOI to US NRC, Unit 1 & 2 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3), dated October 23, 2008.

4. Letter, ENOI to US NRC, Unit 3 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3), dated December 10, 2010.

5. Letter, ENOI to US NRC, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments, Indian Point Nuclear Generating Units 1, 2 and 3, November 21, 2019.

6. Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report.

7. Letter, J. Pollock, VP Entergy IPEC to USNRC: Unit 1 Transfer of 160 Spent Fuel Assemblies to the Indian Point Independent Spent Fuel Storage Installation. December 11, 2008.

8. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, NRC, November 2002 (ADAMS Accession No. ML023470304 (Vol 1) and ML023470323 (Vol 2)).

9. International Structure for Decommissioning Costing (ISDC) of Nuclear Installations, ISBN 978-92-64-99173-6, Joint NEA/EC/IAEA Publication, 2012.

10. NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized-Water Reactor Power Station, November 1995.

11. Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, February 2005.

12. NUREG-2155, Implementation Guidance for Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, January 2015.

13. NUREG-1575 Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).

14. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC Licensed Nuclear Facilities, NRC, July 1997 (ADAMS Accession No. ML042310492).

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Indian Point Energy Center DECON Post-Shutdown Decommissioning Activities Report

15. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Final Report, Volume 1, NRC, December 2010 (ADAMS Accession No. ML103350405.

16. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3, Final, Volume 5, NRC, April 2018 (ADAMS Accession No. ML18107A759).

17. NUREG-1437, Revision 1, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NRC, June 2013 (ADAMS Accession Nos.

ML13106A241 (Vol 1) and ML13106A244 (Vol 3)).

18. NYSDEC, State Pollutant Discharge Elimination System (SPDES) Discharge Permit, NYSDEC Permit No. NY 0004472, Entergy Nuclear Indian Point 2 and Entergy Nuclear Indian Point 3, April 2017.

19. Letter from Entergy Nuclear Operations, Inc. to the NRC,

Subject:

Reply to Request for Additional Information Regarding the License Renewal Application Environmental Review, June 8, 2015. (ADAMS Accession No. ML15166A069).

20. Endangered Species Act Section 7 Consultation Biological Opinion: Continued Operation of the Indian Point Nuclear Generating Station, Units 2 and 3, Pursuant to Existing and Proposed Renewed Operating Licenses, NER-2012-25252. January 30, 2013 NMFS, (ADAMS Accession No. ML13032A256).

21. Evaluation of Impacts to Proposed Critical Habitat for the Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus), Indian Point Nuclear Generating Units 2 and 3 Proposed License Renewal, NRC, September 2016 (ADAMS Accession No. ML16250A276).

22. Letter from K. Damon-Randall, NMFS, to B. Beasley, NRC.

Subject:

Conference Report - Proposed Indian Point Relicensing, NMFS, August 31, 2017 (ADAMS Accession No. ML17243A315).

23. Executive Order 12898 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, February 11, 1994.

24. Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions, (69 FR 52040).

25. NUREG-2157, Vol. 1, Final Report. Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, NRC, September 2014 (ADAMS Accession No. ML14196A105).

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IPEC Site-Specific Decommissioning Cost Estimate Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Indian Point Energy Center DECON Site-Specific Decommissioning Cost Estimate Prepared for Holtec Decommissioning International, LLC Prepared by Comprehensive Decommissioning International, LLC

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table of Contents

SUMMARY

51 HDI Decommissioning Cost Estimate Summary (Table) .52 1 INTRODUCTION53 1.1 Objectives ............................. 54 1.2 Site Description .................................................................................................................... 54 1.3 Regulatory Guidance..54 2 DECOMMISSIONING OPTIONS, THE METHOD SELECTED AND APPROACH .56 2.1 Decommissioning Methods .56 2.2 Decommissioning Method Selected 56 2.3 Decommissioning Approach ...56 Table 2-1 Decommissioning Periods and WBS Elements .61 3 DECOMMISSIONING COST ESTIMATE.....................................................62 3.1 Cost Estimate Summary .....62 3.2 Site-Specific Matters Considered in DCE .63 Table 3-1a IP1 Decommissioning Activities and Costs by Period 72 Table 3-1b IP2 Decommissioning Activities and Costs by Period.75 Table 3-1c IP3 Decommissioning Activities and Costs by Period 78 Table 3-2a IP1 Program Management Cost Detail 81 Table 3-2b IP2 Program Management Cost Detail82 Table 3-2c IP3 Program Management Cost Detail83 Table 3-3 HDI Decommissioning Cost Estimate Summary (thousands of 2019 dollars).84 Table 3-4a IP1 Labor Costs and Labor Requirements by Year.85 Table 3-4b IP2 Labor Costs and Labor Requirements by Year.86 Table 3-4c IP3 Labor Costs and Labor Requirements by Year 87 Table 3-5a IP1 Labor Costs and Labor Requirements by Period .88 Table 3-5b IP2 Labor Costs and Labor Requirements by Period..89 Table 3-5c IP3 Labor Costs and Labor Requirements by Period..90 Table 3-6 IPEC DOE Fuel Acceptance Allocation91 Table 3-7 IPEC Waste Volume and Weight..92 4 COST ESTIMATING APPROACH............................93 4.1 Estimating Methodology .93 4.2 Basis of Estimate ........................93 4.3 Assumptions .94 4.4 Inflation 96 4.5 Contingency .96 Table 4-1 Work Breakdown Structure ...99 5 DECOMMISSIONING SCHEDULE AND FUNDING100 44

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 5.1 Decommissioning Schedule ..100 5.2 Decommissioning Funds ....100 Table 5-1a IP1 Decommissioning Funding Cash Flow Analysis 103 Table 5-1b IP2 Decommissioning Funding Cash Flow Analysis 105 Table 5-1c IP3 Decommissioning Funding Cash Flow Analysis.107 6 CONCLUSION..109 Table 6-1a IP1 Estimated Decommissioning Cost (thousands of 2019 dollars) 110 Table 6-1b IP2 Estimated Decommissioning Cost (thousands of 2019 dollars) .112 Table 6-1c IP3 Estimated Decommissioning Cost (thousands of 2019 dollars)..114 7 REFERENCES... 116 Table A-1 IP1 ISFSI Decommissioning Cost Estimate.... ...118 Table A-2 IP2 ISFSI Decommissioning Cost Estimate. ...119 Table A-3 IP3 ISFSI Decommissioning Cost Estimate....120 45

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate ACRONYM LIST ACM Asbestos Containing Material ALARA As Low As Reasonably Achievable BOY Beginning of Year BOE Basis of Estimate CDI Comprehensive Decommissioning International, LLC CFR Code of Regulations CPM Critical Path Method DCE Decommissioning Cost Estimate DECON A Method of Decommissioning defined by the NRC DOE Department of Energy ENOI Entergy Nuclear Operations, Inc.

ENIP2 Entergy Indian Point 2, LLC ENIP3 Entergy Indian Point 3, LLC Entergy Entergy Corporation ENTOMB A Method of Decommissioning defined by the NRC GEIS Generic Environmental Impact Statement GTCC Greater Than Class C HDI Holtec Decommissioning, International, LLC Holtec Holtec International Holtec IP2 Holtec Indian Point 2, LLC Holtec IP3 Holtec Indian Point 3, LLC HSA Historical Site Assessment IAEA International Atomic Energy Agency IP1, 2 & 3 Indian Point Units 1, 2 and 3 IPEC Indian Point Energy Center ISDC International Structure for Decommissioning Costing ISFSI Independent Spent Fuel Storage Installation LLRW Low Level Radioactive Waste LTA License Transfer Application MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MWe Megawatts Electric MWt Megawatts Thermal MSS Master Summary Schedule MTU Metric Tons of Uranium MSS Master Summary Schedule NDT Nuclear Decommissioning Trust NEA Nuclear Energy Agency NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Commission technical report designation O&M Operations and Maintenance 46

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate IPEC Indian Point Energy Center PWR Pressurized Water Reactor RPV Reactor Pressure Vessel PSDAR Post Shutdown Decommissioning Activities Report RRR Real Rate of Return RSSI Radiation Survey and Site Investigation RPV Reactor Pressure Vessel RVI Reactor Vessel Internals SAFSTOR A Method of Decommissioning defined by the NRC SFP Spent Fuel Pool SME Subject Matter Expert SNF Spent Nuclear Fuel SSC Structures, Systems and Components US United States WBS Work Breakdown Structure WCS Waste Control Specialists 47

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate

SUMMARY

This report provides site-specific Decommissioning Cost Estimates (DCEs) estimating the costs to decommission the Indian Point Entergy Center (IPEC) Units 1, 2 and 3 (IP1, 2 & 3). This DECON DCE provides the Holtec Decommissioning International, LLC (HDI) site-specific estimates using the DECON method for decommissioning that is planned to be implemented following the license transfers and sale of IP1, 2 & 3 from Entergy to Holtec. This DCE is included as an enclosure to the IP1, 2 & 3 HDI DECON Post-Shutdown Decommissioning Activities Report (PSDAR) that describes HDIs decommissioning plan. These estimates have been prepared in accordance with the requirements of 10 CFR 50.82(a)(8)(iii).

Costs in this DCE were determined based on HDIs selection of the DECON method for decommissioning. These estimates are based on current and/or assumed regulatory requirements, site conditions, basis of estimate assumptions, low-level radioactive waste disposal standards, high-level radioactive waste management options, and site restoration requirements.

The methods utilized to estimate decommissioning costs were based on the professional judgment of experienced SMEs considering the nature of the work, degree of scope definition and the availability of quantifiable cost and pricing data. The decommissioning costs presented in this report are reported in 2019 dollars. Escalation of future decommissioning costs over the remaining decommissioning project life-cycle are excluded.

HDIs detailed decommissioning project schedule, implementing the DECON method, is used as the foundation for developing the decommissioning cost estimate model and the risk model. The schedule baseline is a detailed Critical Path Method (CPM) schedule developed with input from cost estimators, key decommissioning subcontractors and SMEs. The schedule and cost estimates are based on the International Structure for Decommissioning Costing (ISDC) for Nuclear Installations Work Breakdown Structure (WBS) and corresponding WBS dictionary.

This DECON DCE demonstrates that adequate funding is available in the Nuclear Decommissioning Trust (NDT) fund for each unit to complete license termination for IP1, 2 & 3.

In addition to the license termination costs site restoration and spent nuclear fuel management costs are included in the estimates; however, per regulatory requirements, the non-radiological estimates are segregated and listed separately. The HDI request for NRC approval of an exemption from the requirements of 10 CFR 50.82(a)(8)(i)(A) to use NDT funds for spent fuel management and site restoration activities is being submitted by HDI separately.

HDIs costs to decommission each of the three IPEC units, safeguard the spent fuel until it can be transferred to the Department of Energy (DOE) and restore the impacted area of the site are summarized by decommissioning activity and by cost category in the tables below.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate HDI Decommissioning Cost Estimate Summary (thousands of 2019 dollars)

Decommissioning Activity IP1 IP2 IP3 Decontamination Removal 162,256 186,173 197,721 Packaging 11,175 14,300 15,964 Transportation 41,043 19,637 28,135 Disposal 156,222 105,940 131,180 Off-site Waste Processing Program Management 119,726 144,384 182,529 Corporate A&G Spent Fuel (Direct Expenditures) 66,066 162,233 344,285 Insurance and Regulatory Fees 9,177 12,511 12,511 Energy 11,914 11,914 11,914 Characterization and Licensing Surveys 8,808 8,808 26,635 Property Taxes 22,537 38,676 Miscellaneous Equipment / Site Services 11,797 13,386 12,827 Spent Fuel Pool Isolation Grand Total 598,184 701,822 1,002,378 Cost Category IP1 IP2 IP3 License Termination 485,015 469,456 583,168 Spent Fuel Management 72,381 188,278 371,370 Site Restoration 40,788 44,088 47,840 Grand Total 598,184 701,822 1,002,378 49

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 1 INTRODUCTION This report presents a Site-Specific Decommissioning Cost Estimate (DCE), in accordance with the requirements of 10 CFR 50.82(a)(8)(iii), for the decommissioning of the Indian Point Energy Center (IPEC) Unit Nos. 1, 2 and 3 (IP1, 2 & 3) following the scheduled permanent cessation of plant operations and permanent removal of fuel from the IP2 and IP3 reactor vessels. This update provides the Holtec Decommissioning International (HDI) site-specific DCE using the DECON method that is planned to be implemented following the license transfers and sale of the entities that own IP1, 2 & 3 from Entergy to Holtec.

On January 31, 1996, the US NRC issued an order to authorize decommissioning of IP1 and Amendment No. 45 to License No. DPR-5, which revised the license to possession-only status (Reference 1). In accordance with 10 CFR 50.81(a)(1)(iii), certification of permanent cessation of operations of IP1 is deemed to have been submitted. In the same order, the staff required the licensee to submit a detailed dismantling plan for NRC review prior to commencing major dismantlement activities at IP1. Following the 1996 decommissioning rulemaking, the PSDAR satisfies this obligation (61 Fed. Reg. 39,278,39,291 (July 29, 1996)).

By letter dated February 8, 2017, Entergy Nuclear Operations, Inc. (ENOI), Entergy Nuclear Indian Point 2, LLC (ENIP2), and Entergy Nuclear Indian Point 3, LLC (ENIP3) notified the Nuclear Regulatory Commission (NRC) that it had decided to permanently cease power operations at IP2 and IP3 by April 30, 2020 and April 30, 2021, respectively (Reference 2).

By letter dated November 21, 2019, ENOI, on behalf of itself, Entergy Nuclear Indian Point 2, LLC (ENIP2), Entergy Nuclear Indian Point 3, LLC (ENIP3), Holtec International (Holtec), and HDI, requested that the U.S. Nuclear Regulatory Commission (NRC) consent to: (1) the transfer of control of Provisional Operating License No. DPR-5 and Renewed Facility Operating License Nos. DPR-26 and DPR-64 for IP1, 2 & 3, as well as the general license for the IP1, 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) to Holtec subsidiaries to be known as Holtec Indian Point 2, LLC (Holtec IP2) and Holtec Indian Point 3, LLC (Holtec IP3); and (2) the transfer of ENOIs operating authority (i.e., its authority to conduct licensed activities at IP1, 2 &

3) to HDI (Reference 3).

The initiation of decommissioning activities will occur immediately following the sale and license transfers. The sale closure and license transfers are targeted to complete by May 31, 2021, following IP3 cessation of plant operations and permanent reactor defueling. The cash flow forecasts provided in this DCE assume this date as the starting point. In addition, HDI will submit a request for NRC approval of an exemption to use NDT funds for spent fuel management and site restoration activities. The cash flows in this DCE are based on the assumption that the request will be approved.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 1.1 Objectives The goal for the project is the prompt decommissioning of the three reactors at the IPEC site following shutdown and permanent reactor defueling of IP2 & IP3, leading ultimately to the termination of the NRC licenses. Decommissioning objectives are:

a. Decommissioning and site restoration of all areas, except for the ISFSI.

b. NRC approval of partial site release, including issuance of amended licenses to include only the operation of the ISFSI.

c. DOE acceptance of Spent Nuclear Fuel (SNF) from the ISFSI.

d. Decommissioning of the ISFSI after DOE has removed the SNF.

e. Termination of the NRC licenses and site release of the ISFSI area.

f. Site restoration of the ISFSI area.

The objective of this DCE is to provide a description of the planned decommissioning activities and estimated costs, along with the detailed schedule of associated activities required to complete license termination for IP1, 2 & 3. The estimates and schedule are based on the assumptions delineated in this document.

1.2 Site Description Indian Point is located on approximately 239 acres of land on the east bank of the Hudson River at the Village of Buchanan in upper Westchester County, New York. There are three units on site, two operating units (IP2 & 3) and one in safe storage (IP1). IP1 is located between IP2 to the north and IP3 to the south.

IP1 was a four-loop pressurized water reactor with a thermal rating of 615 megawatts thermal (MWt). Operation of the unit was suspended on October 31, 1974 and all spent fuel had been removed from the reactor vessel by January 1976. Since that time, the unit has remained in protective storage. In 2003, the NRC issued Amendment No. 52 to the Provisional Operating License for IP1. Included within the amendment was a change to expiration date of the IP1 license to be consistent with that of IP2.

In 2008, the remaining 160 spent fuel assemblies (244 assemblies had previously been shipped to West Valley Reprocessing Plant, a commercial fuel reprocessing facility in upstate New York operated by Nuclear Fuel Services, Inc. from 1966 to 1972, for reprocessing) were transferred to an on-site ISFSI.

IP2 and IP3 each employ a pressurized water reactor and nuclear steam supply system (NSSS) furnished by Westinghouse Electric Corporation. The units are each currently licensed to generate 3,216 MWt which corresponds to a generator output of approximately 1,080 megawatts electric (MWe).

1.3 Regulatory Guidance Current regulations governing decommissioning, waste management, and spent fuel management; and the funding of those elements, include the following:

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate x Decommissioning is defined in 10 CFR 50.2 as the safe removal of a facility or site from service and the reduction of residual radioactivity to levels that permit release of the site and termination of the license.

x Pursuant to 10 CFR 50.51(b), each license for a facility that has permanently ceased operations continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated.

x Prior to, or within two years following permanent cessation of operations, the licensee is required by 10 CFR 50.82(a)(4)(i) to submit a PSDAR to the NRC. The PSDAR must contain a site-specific DCE, including the projected cost of managing irradiated fuel.

x Pursuant to 10 CFR 50.82(a)(7) the licensee is required to notify the NRC before performing any decommissioning activity inconsistent with, or making any significant changes from, those actions and schedules described in the PSDAR.

x Pursuant to 10 CFR 50.82(a)(8)(iii), within 2 years following permanent cessation of operations, if not already submitted, the licensee shall submit a site-specific DCE.

x In accordance with 10 CFR 72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

x Use of the decommissioning funds is limited by 10 CFR 50.82(a)(8)(i) to legitimate decommissioning expenses that neither reduces the value of the trust fund below that necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise, nor inhibits the ability of the licensee to complete funding of any shortfalls in the trust needed to ensure the availability of funds to ultimately release the site and terminate the license. .

x As provided in 10 CFR 50.82(a)(8)(ii), a licensee may withdraw funds from the decommissioning trust up to a cumulative total of 3 percent of the generic amount calculated under 10 CFR 50.75 for decommissioning planning purposes at any time.

After submittal of the certifications of permanent shutdown and fuel removal required under 10 CFR 50.82(a)(1) and commencing 90 days after the NRC has received the PSDAR, the licensee may use an additional 20 percent of the decommissioning funds prescribed in 10 CFR 50.75(c) for decommissioning purposes. The licensee is prohibited from using the remaining 77 percent of the generic decommissioning funds until a site-specific DCE is submitted to the NRC.

x Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, (Reference 4) provides the standard format and content to facilitate preparation and NRC review of required cost estimates.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 2 DECOMMISSIONING OPTIONS, THE METHOD SELECTED AND APPROACH 2.1 Decommissioning Methods The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, "Final Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," (Reference 5). The three general methods evaluated are summarized as follows:

x DECON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

x SAFSTOR: After the plant is shutdown and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

x ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

2.2 Decommissioning Method Selected Decommissioning activities will be planned and executed using the DECON method and will proceed following sale and license transfer to HDI. Decommissioning is expected to be completed well before 60 years following permanent cessation of operations as required by 10 CFR 50.82(a)(3).

The DECON PSDAR and this DECON DCE provides an estimate of the costs to decommission the facility utilizing the DECON method. Immediately following the sale and license transfer, HDI will finalize decommissioning preparations and transition the plants into DECON.

2.3 Decommissioning Approach The decommissioning approach reflected in this cost estimate is organized into activities based on the International Structure for Decommissioning Costing (ISDC) Work Breakdown Structure (WBS) and corresponding WBS dictionary. The ISDC WBS is a 53

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate delivery-based, hierarchical structure organized at the highest level of a decommissioning project into eleven groups of similar activities or principal work groups:

01 - Pre-decommissioning actions 02 - Facility shutdown activities 03 - Additional activities for safe enclosure and entombment 04 - Dismantling activities within the radiologically controlled area 05 - Waste processing, storage and disposal 06 - Site infrastructure and operation 07 - Conventional dismantling, demolition and site restoration 08 - Project management, engineering and support 09 - Research and development 10 - Fuel and nuclear material 11 - Miscellaneous expenditures Of the eleven principal work groups identified in the ISDC Level 1 WBS, activities 03 and 09 are not used for this project. Activity 03-Additional activities for safe enclosure and entombment is not applicable to the prompt decommissioning approach used by HDI. There are no experimental activities associated with the project, therefore Activity 09-Research and development is not used.

NRC guidance in Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, (Reference 4) provides the recommended method of summarizing total decommissioning costs by period. The four periods are: Planning & Preparation, Plant Deactivation, Safe Storage Operations, and Dismantlement. NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Reactors (Reference 6), and NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized-Water Reactor Power Station, (Reference 7) divides decommissioning activities associated with the DECON method into similar periods.

To facilitate a comparison of projected decommissioning costs to the reference Pressurized Water Reactor (PWR), decommissioning activities are organized into periods like those described in NRC guidance, with differences described below.

Periods 1 through 4 are generally consistent with the decommissioning periods in Regulatory Guide 1.202; however, a Program Management cost category is added to capture generic labor and project support costs that are applicable to periods 1 through 4 but not readily distributable into individual periods. Since acceptance of spent nuclear fuel by DOE is not assumed to be completed until the end of 2061, a fifth period is included in this cost estimate and is identified as Ongoing Independent Spent Fuel Storage Installation (ISFSI)

Operations. This fifth period captures the costs associated with storing spent fuel and Greater Than Class C (GTCC) waste following completion of dismantlement activities in addition to the costs of the eventual decommissioning of the storage facility.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 - Pre-decommissioning Planning & Preparation In the time leading up to and immediately following the sale and license transfers, preparations for performance of decommissioning will include the following activities:

1. Final decommissioning planning

2. Procurement of services, materials and supplies

3. Reactor Vessel Internals (RVI) and Reactor Pressure Vessel (RPV) segmentation, tooling design, fabrication, and testing

4. Licensing and permitting actions necessary to reflect the defueled and permanently shutdown plant configuration

5. Stakeholder interaction

6. Facility characterization so that radiological, regulated, and hazardous wastes are identified, categorized and quantified to support decommissioning and waste management planning

7. Waste management planning, including determination of transportation and disposal container requirements and disposal pathways

8. Performance of safety, security and environmental studies Period 2 - Plant Deactivation During the time between the permanent shutdown of IP2 and IP3, and the sale and license transfers, ENOI will defuel the reactors in preparation for decommissioning. Following sale and transfer of the licenses, HDI will operate and maintain the Spent Fuel Pools (SFPs) and supporting systems required for cooling of the Spent Nuclear Fuel (SNF) and perform the following activities:

1. Isolation of power equipment

2. Drainage and drying of systems

3. Removal of system fluids, operational waste and redundant material

4. Radiological inventory characterization to support detailed planning Due to the prompt decommissioning strategy utilized by HDI, reactor vessel and internals segmentation and removal activities are included in Period 4.

Period 3 - Safe Storage Operations Since the DECON method will be used, the activities in this period only include preparations for and conduct of IP2 & 3 fuel movement to an on-site dry fuel storage facility (IP1 fuel is already stored on the ISFSI). This period concludes once all the spent nuclear fuel has been removed from the SFPs and placed into long term storage at the ISFSI.

Activities include the following:

1. Construction of additional dry fuel storage capacity

2. Transfer of spent nuclear fuel to dry storage canisters

3. Movement and placement of fuel into long term storage at the ISFSI 55

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate

4. Operation of the ISFSI until all fuel is placed on the ISFSI Period 4 - Dismantlement The following dismantlement activities will be performed during this period according to the project decommissioning schedule. These activities include detailed work planning, procurement, mobilization and execution of the dismantlement and disposal work and support activities, including measures to maintain occupational dose As Low As Reasonably Achievable (ALARA).

1. Asbestos Containing Material (ACM), Hazardous, and Universal Waste removal

2. Dismantling of main process systems, structures and components

3. Dismantling of reactor internals, core components and reactor vessel

4. Dismantling of other primary loop components

5. Dismantling of other systems and components

6. Procurement of equipment, tools and services

7. Procurement of waste containers

8. Demolition of buildings and structures within the radiologically controlled area

9. Maintenance, surveillance and operational support for waste management

10. Low level waste management

11. Management of exempt waste and materials

12. Management of waste and materials generated outside the radiologically controlled area

13. Final status survey

14. Earthworks and landworks

15. Landscaping and site finishing Period 5 - Ongoing ISFSI Operations Ongoing ISFSI Operations activities are associated with storing spent fuel and GTCC waste following completion of dismantlement activities in addition to the costs of the eventual decommissioning of the storage facility. Activities for Period 5 include:

1. Operational activities from the time that all spent fuel is in storage at the ISFSI until all spent fuel and GTCC waste is removed from the ISFSI

2. Decommissioning of the ISFSI Program Management Program Management costs include infrastructure and operation, management and fees that are generic in nature and applicable across decommissioning Periods 1 through 4. These costs include the following:

1. Site infrastructure and operation costs, including security, maintenance, site upkeep, operation of support systems and environmental monitoring 56

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate

2. Project management, engineering and support including the core management group, scheduling and cost control, quality assurance, health and safety, records management, general administration and accounting, warehousing, engineering, regulatory and support services

3. Regulatory fees, taxes and insurance Due to the generic nature of Program Management costs and the fact that work activities associated with Periods 1 through 4 are performed concurrently, it is not feasible to allocate these costs to discrete Periods. Once decommissioning activities are complete, and the project enters Period 5, Ongoing ISFSI Operations, all costs, including Program Management, are captured within the Period.

WBS Principal Activities Mapping, The nine Level 1 WBS principal activities used for the project are mapped in Table 2-1 to the decommissioning periods described above in accordance with the following conventions:

x Period 1, Pre-Decommissioning Planning and Preparation maps directly to principal work group 01-Pre-decommissioning actions.

x Period 2, Plant Deactivation, maps directly to principal work group 02-Facility Shutdown.

x Period 3, Safe Storage Operations maps to principal work group 10-Fuel and Nuclear Material for those activities required to complete the movement of all spent nuclear fuel into dry storage, as indicated by the 2024 end date.

x Period 4, Dismantlement, maps to principal work groups 04-Dismantling Activities Within the Radiologically Controlled Area, 05-Waste Processing, Storage and Disposal and 07-Convential Dismantling Demolition and Site Restoration.

x Period 5, Ongoing ISFSI Operations, maps to principal work group 10- Fuel and Nuclear Materials like Period 2, but activities in this period begin once all spent nuclear fuel is placed in dry storage and end when the ISFSI is decommissioned in 2062.

x Program Management is applicable to activities performed across Periods 1 through 4 and is mapped to principal work groups 06-Site Infrastructure and Operation; 08-Project Management, Engineering and Support and 11-Miscellaneous Expenditures.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 2-1 Decommissioning Periods and WBS Elements IP1 IP2 IP3 Period WBS Element Start and End Dates Start and End Dates Start and End Dates

1. Pre-Decommissioning 01.02.01 Pre-decommissioning actions 05/31/2021 - 05/16/2022 05/31/2021 - 05/16/2022 05/31/2021 - 05/16/2022 Planning and Preparation

2. Plant Deactivation 01.02.02 Facility Shutdown Activities N/A 05/31/2021-03/31/2023 05/31/2021-04/12/2024

3. Safe Storage Operations 01.02.10 Fuel and Nuclear Material 05/31/2021 - 04/12/2024 05/31/2021 - 04/12/2024 05/31/2021 - 04/12/2024

4. Dismantlement 01.02.04 Dismantling Activities Within the 05/31/2021 - 09/22/2028 05/31/2021 - 09/23/2026 05/31/2021 - 09/23/2024 Radiological Controlled Area 01.02.05 Waste Processing, Storage and Disposal 05/31/2021 - 12/17/2032 05/31/2021 - 12/17/2032 05/31/2021 - 12/17/2032 01.02.07 Conventional Dismantling, Demolition, 07/01/2023 - 12/19/2032 09/24/2022 - 12/19/2032 01/07/2022 - 12/19/2032 and Site Restoration

5. Ongoing ISFSI Operations 01.02.10 Fuel and Nuclear Material 04/12/2024 - 03/31/2062 04/12/2024 - 03/31/2062 04/12/2024 - 03/31/2062 Program Management 01.02.06 Site Infrastructure and Operation 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 01.02.08 Project Management, Engineering and 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 Support 01.02.11 Miscellaneous Expenditures 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 05/31/2021 - 07/09/2033 58

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 3 DECOMMISSIONING COST ESTIMATE The DECON DCE for decommissioning IP1, 2 & 3 presented in this section demonstrates that adequate funding is available in the Nuclear Decommissioning Trust (NDT) funds to complete license termination. In addition to the License Termination costs, Site Restoration and Spent Fuel Management costs are included in the estimates; however, per regulatory requirements, the non-radiological licensing estimates are segregated and listed separately.

In addition, this section provides a cash flow analysis demonstrating the adequacy of decommissioning funding.

The decommissioning costs presented in this report are reported in 2019 dollars. Escalation of future decommissioning costs over the remaining decommissioning project life-cycle are excluded.

The cost estimate summary is presented, followed by a discussion of the site-specific details that were taken into consideration while developing this DCE. Site-specific matters include items that are applicable to the DECON method for Pressurized Water Reactors (PWRs).

Section 4.0 discusses the estimating methodology, basis of estimate and assumptions that were used in preparing the cost estimates.

3.1 Cost Estimate Summary This DECON DCE conforms with the guidance provided in NRC Regulatory Guide 1.202 (Reference 4). The estimates were developed and organized using the ISDC WBS and corresponding WBS dictionary (Reference 8). The ISDC WBS is a delivery-based, hierarchical structure and is identified as the international standard cost structure for nuclear facility decommissioning projects, addressing the entirety of work within the planned scope of a typical nuclear facility decommissioning project (i.e., license termination, site restoration, and spent nuclear fuel management). The ISDC WBS is organized at the highest level of a decommissioning project into eleven principal work groups of which nine are applicable to this project. As described in subsection 2.3 of this DCE, Activity 03-Additional activities for safe enclosure and entombment and Activity 09-Research and development are not used.

To organize the WBS information in a format consistent with regulatory guidance, Tables 3-1a, 3-1b and 3-1c present decommissioning costs by the five Periods and Program Management category described in Section 2.3.

Tables 3-2a, 3-2b and 3-2c provide a detailed view of the Program Management costs on an annualized basis. Program Management costs include expenses that are common to decommissioning Periods 1 through 4, and include site infrastructure and operation, project management, engineering, regulatory, support services, scheduling and cost control, quality assurance, general administration, materials management, insurance, taxes and fees. Due to the generic nature of Program Management costs and the fact that work activities associated with Periods 1 through 4 are performed concurrently, it is not feasible to allocate these costs 59

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate to discrete Periods. Once decommissioning activities are complete, and the project enters Period 5, Ongoing ISFSI Operations, all costs, including Program Management, are captured within the Period.

The decommissioning project cost estimate summary by activity and cost category for each unit is shown in Table 3-3.

The estimates capture costs associated with License Termination, in addition to costs associated with Spent Fuel Management and Site Restoration. License Termination costs are those costs associated with the collective work required to plan, mobilize and execute the removal of the radioactive contamination from the site, consistent with the definition of decommissioning per 10 CFR 50.2. Site Restoration costs are those costs associated with conventional dismantling, demolition, and removal from the site of structures and systems after confirmation that radioactive contaminants have been removed. Spent Fuel Management are the costs to safely manage spent fuel from sale and license transfers until successful transfer to the DOE. The costs of Spent Fuel Management and Site Restoration are not considered part of the 10 CFR 50.2 definition of decommissioning and are listed separately per regulatory requirements.

3.2 Site-Specific Matters Considered in DCE Based on the guidance in Regulatory Guide 1.202, the following site-specific matters are discussed. These items not only influence the methods used to decommission the plants, but many have significant cost impacts as well.

x Management after License Transfers, DECON Labor Requirements and Costs Following approval of license transfers and closing on the sale, the management team will be comprised of HDI and Comprehensive Decommissioning International, LLC (CDI) personnel as well as site incumbent personnel who accept offers of employment and are transferred to CDI upon closure of the sale. These personnel will be incorporated into the decommissioning organization according to their expertise and previous positions held while the plants were operating. HDI will ensure that positions filled by incumbent employees that are vacated due to attrition are backfilled with qualified personnel, subject to a determination of need to fill the position. The attrition strategy includes filling vacant positions with other qualified employees, hiring from the community of former employees, assigning qualified personnel from the HDI and CDI parent companies, and seeking qualified personnel from industry staff augmentation firms.

Tables 3-4a, 3-4b and 3-4c present the labor costs and the annualized labor requirements and Tables 3-5a, 3-5b and 3-5c present labor costs and the labor requirements by decommissioning period. The cost basis for labor resources was developed using a salary survey for comparable rates across the US and using plant staff salary information provided by ENOI. Neither the 3-4 or 3-5 tables include resources that will be mobilized by the subcontractors responsible for providing project management, supervisory, engineering and labor resources necessary to accomplish decommissioning 60

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate activities. Subcontractor labor resources and associated labor costs will be included in the subcontracts. For the decommissioning cost estimates documented herein, HDI has included subcontract cost estimates including labor costs using previous decommissioning experience, discussions with potential subcontractors, and SME judgement.

Following the license transfers, daily onsite staffing, excluding subcontractor resources, is estimated to be between 300 and 350 personnel and is expected to decrease as the spent fuel cools, as the fuel is moved from the pool to the ISFSI and as requirements for security and emergency planning are reduced. The subcontractor onsite staffing will be defined during contract development, bidding and selection. The maximum site population, inclusive of subcontractor resources, will vary throughout the life of the project, with increased and decreased staffing required as decommissioning activities ramp up or down. The maximum site population including subcontractors is not expected to exceed 450 personnel. Onsite HDI staffing changes (excluding subcontractor resources) are expected to occur at the following milestones:

o Emergency planning zone reduced following the spent fuel cooling period o All spent fuel moved from the SFPs to the ISFSI o Initiation of major demolition x Characterization Characterization will be performed with systems and components in place, maximizing the use of non-destructive assay techniques and direct reading survey instrumentation readings correlated with analytical data gathered via direct smears and sampling. Site characterization activities will follow the Radiation Survey and Site Investigation (RSSI) described in NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (Reference 9), The prompt decommissioning approach minimizes decontamination activities, resulting in maintaining occupational doses ALARA and reducing decommissioning costs.

x Segmentation of the RPV and Internals CDI will subcontract reactor and fuel system dismantling services. The subcontract will include project management, supervision, engineering, labor, tooling (including the design, fabrication, and testing of segmentation tooling) for the Reactor Pressure Vessels (RPV), Reactor Vessel Internals (RVI), irradiated hardware, SFPs, and cavity pool liner removals in addition to removal and disassembly of the refueling machine and bridge. GTCC waste generated during segmentation activities will be placed into dry storage canisters, transported away from the area and stored at the ISFSI until acceptance by the DOE.

Reactor vessel and internals segmentation activities will begin with IP3, proceed to IP2 and conclude with IP1. Due to the similarities in the design of the IP2 & IP3 reactors, the same tooling will be used to segment each of the IP2 and IP3 reactor vessels and reactor vessel internals. Lessons learned from the IP3 segmentation will result in efficiency gains for the 61

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate IP2 work. The IP1 reactor will require a unique tooling design, segmentation plan and segmentation approach. Depending on the condition of the IP1 reactor vessel, there may be an opportunity to remove, ship and dispose of the vessel intact. However, for the purposes of this estimate, the IP1 reactor vessel is assumed to be size-reduced and shipped for disposal in a segmented configuration.

The RVI will be reduced in size using specially designed tooling and mechanical techniques.

The tooling will be developed during the decommissioning planning period and will be mobilized to the site and tested prior to use. Segmentation of the RVI will be completed systematically from the top to the bottom of the reactor. Highly activated portions of the RVI will be segmented into pieces that are sized to fit within the dry storage casks used for GTCC waste.

The RPVs will be separated from the surrounding structure and segmented in stages.

The reactor support structures will be removed when they are no longer required to maintain needed structural support. RPV segments will be loaded into waste shipment casks using the reactor building crane and the loaded casks will be moved across the reactor building, lowered through the access hatch and readied for transport to the disposal site.

x Fuel Pool and Spent Fuel Racks The fuel pools will be inspected with underwater cameras and surveyed with radiation monitors to identify any radioactive material or debris remaining after removal of the spent fuel. Remote handling or vacuum lines will remove fuel contamination found during the inspection.

The fuel racks will be removed from the pool, segmented and size reduced for disposal as Low Level Radioactive Waste (LLRW). Pool liners will be segmented after they have been drained and decontaminated to protect workers. Any GTCC waste generated during these activities will be placed in a dry storage cask, transported away from the area and stored at the ISFSI. CDI intends to subcontract the Fuel Pool and Spent Fuel Rack removal scope.

x Turbine and Condenser Segmentation With the retirement of IP1, the turbine generator and some of its associated equipment was removed. The IP2 & IP3 turbine and condenser components will be segmented by a specialty subcontractor. The turbines and condensers are not expected to be radiologically contaminated, but due to the IP2 steam generator tube rupture in 2000, appropriate radiological precautions will be taken during the IP2 turbine and condenser segmentation activities. The subcontractor will remove large parts of the turbine (such as the low-pressure portion) intact and send the components offsite for disposal as intact packages suitably wrapped. The generator can be removed whole for later recycling or re-use.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate x Large Contaminated Components CDI will subcontract the removal of large contaminated components and piping from power block structures. The prompt decommissioning strategy involves minimal decontamination or offsite processing and focuses instead on bulk removal of material as the most expedient and cost-effective solution to decommissioning. The subcontractor will provide management, labor, tools and equipment to the complete removal of large components. Support services include radiation protection, security, engineering support, heavy lift services and segmentation of components, if required.

Containers or packaging will be provided by CDI.

x Building and Structure Removal Building demolition will be subcontracted with scope including equipment, personnel, permits, and surveys to perform the following activities:

1. Hazardous waste (asbestos and lead paint) removal from buildings and components

2. Demolition of site buildings to 3 feet below grade and backfill with clean fill material

3. Demolition of above ground tanks

4. Removal of parking lot surfaces

5. Final grading, and

6. Site restoration x Review of Decommissioning Records Based on a review of IP1, 2 & 3 decommissioning records required by 10 CFR 50.75(g), and the draft Historical Site Assessment (HSA) prepared for ENOI, HDI has concluded that events occurring during plant operation involving the spread of contamination in and around the facility, equipment, or site are well documented and the fate and transport of contaminants are generally understood. The decommissioning cost estimates include a conservative estimate of contaminated soil that will be removed, packaged, shipped and disposed as low level or exempt waste.

x Final Radiological Surveys After completing site decommissioning activities, the final status surveys will be performed to demonstrate that the remediated portion of the site (excluding the ISFSI containing the spent fuel and GTCC waste) can be released for unrestricted use and removed from the license. The site release criteria are defined by the MARSSIM protocol and is in general 25 mrem/year from all pathways. Adherence to the NRC-approved License Termination Plan (LTP) and MARSSIM guidance will ensure that the surveys are conducted so that applicable regulatory criteria are satisfied.

x Spent Fuel Management DOEs repository program assumes that spent fuel will be accepted for disposal from the nations commercial nuclear plants, with limited exceptions, in the order (the queue) in which it was discharged from the reactor.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate In January 2013, the DOE issued the Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste (Reference 10), indicating plans to implement a program over the next 10 years that begins operations of a pilot interim storage facility by 2021 with an initial focus of accepting used nuclear fuel from shutdown reactor sites with a larger interim storage facility to be available by 2025.

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

IP1 possesses some of the oldest fuel in the queue and is therefore eligible per the DOE Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567 (Reference 11), for capacity allocations beginning in the second year that the DOE begins accepting spent fuel from the commercial nuclear industry. Article V.E. of the DOE standard Contract provides Standard Contract Holders the right to determine which spent fuel and/or high level waste are delivered to DOE, including the right to exchange spent fuel acceptance allocations with other Standard Contract holders. As permitted by Article V.E., as the Standard Contract holders for IP1, 2, and 3, Holtec IP2 and Holtec IP3 would exchange acceptance allocations among the IPEC Units, such that IP2 sent fuel would be removed from the site first, followed by IP1 spent fuel and then followed by IP3 spent fuel.5 Accordingly, HDIs spent fuel management plan assumes that:

x DOE will commence transferring commercial spent fuel from the industry to a federal facility (not necessarily a final repository) in 2030 x IP2 spent fuel removal will begin in 2031and complete in 2048 x IP1 spent fuel removal will begin in 2048 and complete in 2049 x IP3 spent fuel removal will begin in 2049 and complete in 2061 These assumptions are based on DOE fuel acceptance allocations in Metric Tons of Uranium (MTU) provided by ENOI. Table 3-6 presents the assumed fuel removal quantities for each unit by year in MTU and number of fuel assemblies.

Spent fuel management activities will be funded from the NDT funds following receipt of an exemption from current NRC restrictions on use of the funds.

5 Holtecs position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out in this DCE, consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim. For planning purposes only, the fuel removal schedule assumed in this estimate is based upon DOE acceptance of fuel according to the Oldest Fuel First priority ranking. It is expected that Holtec IP2 and Holtec IP3 will seek the most expeditious means of removing fuel from the site, based on shutdown reactor priority, exchanges of acceptance allocations with other Standard Contract holders, and other contract provisions.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate x ISFSI Only License Amendment The dry fuel storage capacity will be expanded to accommodate all the fuel stored in the SFPs. Once all spent fuel is removed from the SFPs and stored at the ISFSI, the security, Technical Specifications and emergency planning requirements will be revised to reflect plant conditions.

Following site decommissioning, the NRC license will be amended to limit applicability to that portion of the site where the ISFSI containing the spent fuel and the GTCC waste is located, with the remainder of the site being released for unrestricted use. Once the fuel and the GTCC waste are removed from the site, the ISFSI will be decommissioned and the license terminated.

x ISFSI Decommissioning In accordance with 10 CFR §72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

The design and capacity of the current ISFSI is based upon the Holtec HISTORM 100S dry cask storage system (IP1 fuel is stored in a shorter version of the cask). The system consists of a multi-purpose canister, with a nominal capacity of 32 fuel assemblies, and a steel-lined concrete storage overpack. Currently the ISFSI Pad has a 75-cask capacity, with an expansion planned for 65 additional casks. Plans for spent fuel management would result in 62 IP2 spent fuel storage casks (in addition to the existing 5 casks for IP1 spent fuel) and 58 IP3 spent fuel storage casks being placed on the storage pad(s) at the site.

The canister overpack assemblies are not expected to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. The decommissioning estimate assumes that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 7 of the 67 IP2 overpacks and 7 of the 58 IP3 overpacks are assumed to be affected, i.e., contain residual radioactivity and therefore require the use of radiological demolition methods. The waste generated from the demolition of the overpack assemblies is assumed to meet criteria for free release and therefore the packaging, transportation and disposal costs are conservatively allocated to Site Restoration expense.

The storage overpacks used for the GTCC canisters (estimated quantity of thirteen) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a radiological release survey.

65

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate No contamination or activation of the ISFSI pads is assumed. As such, only verification surveys are included for the pad in the decommissioning estimate. The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use The estimated cost to decommission the ISFSI and release the facility for unrestricted use, allocated to each unit, is provided in Appendix A. The ISFSI decommissioning cost estimate Contingency Allowance has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757, Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness (Reference 12). Costs are reported in 2019 dollars.

In accordance with the specific requirements of 10 CFR §72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of CDI performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

x Waste Management CDI developed waste volume estimates for IP1, 2 & 3 based on plant design and industry data. The estimates were modified to reflect the decommissioning approach and were used to perform a disposition analysis to determine the type, size, and quantity of waste containers required to hold the anticipated waste volume. Disposal facilities were selected, and pricing was confirmed, and various methods of transportation to the disposal facility were evaluated. Transportation logistics were evaluated to ensure that the overall shipping strategy would be efficient and balanced with respect to container utilization, transport cycles and support for shipping during peaks in demolition periods.

Greater-Than-Class C (GTCC) Waste GTCC waste will be managed and stored onsite until the DOE accepts the waste for final disposition, or until an appropriately licensed facility becomes available. The GTCC waste will be present in the SFPs and generated during reactor internal segmentation. The segmentation plan will use characterization information and an activation analysis to minimize the quantity of GTCC waste, and the packaging plan will reflect the segmentation plan. It is anticipated that no more than thirteen GTCC canisters will be required for the storage of GTCC waste from decommissioning activities.

Low-Level Radioactive Waste (LLRW)

A major component of the decommissioning work scope is the packaging, transportation and disposal of contaminated/activated equipment, piping, concrete, and soil. Most of the waste volume will meet Class A, Low Specific Activity, or Surface Contaminated Object definitions, and higher activity items will be segmented and loaded to avoid complex transportation modes (e.g., cask transport.) as much as possible. Some components will be capped and shipped with minimal sectioning but 66

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate will require special conveyance equipment for at least a portion of the haul route. This is most likely for the RPV, large components, and some bulk debris items. Most of the radioactive debris will be shipped in metal shield boxes or standard combination intermodal containers.

HDI will consider novating contracts that are currently in place, including life of plant agreements for disposal of low-level waste, but will also seek bids from the EnergySolutions Clive facility and Waste Control Specialist (WCS) to find optimum disposal terms.

For Class B and C waste, the HDI intends to file an import petition with the Texas Compact Commission to gain approval to dispose of out-of-compact waste at the WCS site in Andrews, Texas. Holtec currently holds a contract with WCS that permits disposal of radioactive waste from any decommissioning project in the United States.

One or more disposal facilities licensed in accordance with 10 CFR 20.2002 will be utilized for disposal of low activity waste since it is estimated that a significant portion of the heterogeneous bulk debris will be compatible with these facilities. In addition to lower disposition costs, the transportation route is shorter than the route to 10 CFR 61 licensed facilities, offering reduced shipping costs and better cycling efficiency for reusable bulk containers.

Mixed Wastes Mixed Low-Level Waste generation will be minimized through appropriate characterization and demolition techniques and will be managed in accordance with applicable Federal and State regulations. Onsite treatment will not be pursued; rather, treatment needs will be procured from vendors such as Perma-Fix, Waste Control Specialists, and EnergySolutions.

Waste Transportation The transportation approach for Class A, Low Specific Activity, or Surface Contaminated Object classes of waste will use a combination of truck, rail and potentially barge to support bulk quantity removal of waste. Since there is no active rail line at the site, a truck will be used to deliver the waste to a transload facility.

Transportation of waste by barge to a nearby facility with rail access is an opportunity warranting further investigation due to the potential for a reduction in waste transportation vehicle road traffic and costs. However, transportation by barge is not used as a basis for costs in these estimates.

The transportation of all other classes of waste (Class B and C, GTCC, hazardous, and mixed), as well as the transportation of the spent fuel to the DOE repository, when it becomes available, will be by truck, as this mode of transportation minimizes transit time and is consistent with cask use requirements.

67

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-7 presents IP1, 2 & 3 waste volume and weight estimates by Class. The HDI estimated costs do not include off-site processing since this option would only be utilized if items require decontamination to meet transportation criteria or if the item has significant residual value and can be salvaged or reused.

68

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-1a IP1 Decommissioning Activities and Costs by Period Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation License Termination (Decommissioning) Activities 8,807,656 0 8,111,819 331,690,286 0 136,405,526 485,015,286 Radioactive Component Removal 0 0 0 62,289,988 0 0 62,289,988 Dismantling of main process systems, structures and components 0 0 0 23,939,988 0 0 23,939,988 Dismantling of reactor internals 0 0 0 38,350,000 0 0 38,350,000 Decontamination and Dismantlement 0 0 0 5,949,044 0 0 5,949,044 Procurement of equipment for decontamination and dismantling 0 0 0 5,900,000 0 0 5,900,000 Procurement of general site-dismantling equipment 0 0 0 983,333 0 0 983,333 Procurement of special tools for dismantling the reactor systems 0 0 0 4,916,667 0 0 4,916,667 Dismantling of other systems and components 0 0 0 49,044 0 0 49,044 Conventional dismantling, demolition and site restoration 0 0 0 63,436,800 0 0 63,436,800 Demolition of buildings and structures 0 0 0 63,436,800 0 0 63,436,800 Demolition of buildings and structures from the formerly controlled area 0 0 0 63,436,800 0 0 63,436,800 Fuel and nuclear material 0 0 8,111,819 0 0 0 8,111,819 Dedicated ISFSI for fuel and/or nuclear material 0 0 2,299,525 0 0 0 2,299,525 Transfer of fuel and/or nuclear material away from the ISFSI 0 0 2,299,525 0 0 0 2,299,525 Decommissioning of ISFSI 0 0 5,812,294 0 0 0 5,812,294 Decommissioning of ISFSI 0 0 5,812,294 0 0 0 5,812,294 Decommissioning of ISFSI - Decommissioning of ISFSI - License Termination costs 0 0 5,812,294 0 0 0 5,812,294 Waste 0 0 0 200,014,454 0 0 200,014,454 Waste management system 0 0 0 3,545,890 0 0 3,545,890 Maintenance, surveillance and operational support for waste management system 0 0 0 3,545,890 0 0 3,545,890 Management of decommissioning intermediate-level waste/GTCC 0 0 0 1,445,500 0 0 1,445,500 Containers 0 0 0 1,445,500 0 0 1,445,500 Management of decommissioning low-level waste 0 0 0 29,066,369 0 0 29,066,369 69

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Management of decommissioning exempt waste and materials 0 0 0 165,956,696 0 0 165,956,696 Management and Support 8,807,656 0 0 0 0 136,405,526 145,213,182 Pre-decommissioning actions 8,807,656 0 0 0 0 0 8,807,656 Facility characterization 8,807,656 0 0 0 0 0 8,807,656 Site infrastructure and operation 0 0 0 0 0 35,482,009 35,482,009 Site security and surveillance 0 0 0 0 0 3,757,563 3,757,563 Site operation and maintenance 0 0 0 0 0 4,949,174 4,949,174 Operation of support systems 0 0 0 0 0 15,215,581 15,215,581 Radiation and environmental safety monitoring 0 0 0 0 0 11,559,692 11,559,692 Project management, engineering and support 0 0 0 0 0 50,361,588 50,361,588 Project management 0 0 0 0 0 18,648,632 18,648,632 Support services 0 0 0 0 0 30,505,415 30,505,415 Miscellaneous expenditures 0 0 0 0 0 50,561,929 50,561,929 Owner costs 0 0 0 0 0 32,883,705 32,883,705 Implementation of transition plans 0 0 0 0 0 27,833,250 27,833,250 Payments (fees) to authorities 0 0 0 0 0 5,050,455 5,050,455 Taxes 0 0 0 0 0 14,221,176 14,221,176 Insurances 0 0 0 0 0 3,457,048 3,457,048 Nuclear related insurances 0 0 0 0 0 2,871,694 2,871,694 Other insurances 0 0 0 0 0 585,354 585,354 Spent Fuel Management Activities 0 0 66,066,413 0 0 6,314,372 72,380,785 Fuel and nuclear material 0 0 66,066,413 0 0 0 66,066,413 Dedicated ISFSI for fuel and/or nuclear material 0 0 66,066,413 0 0 0 66,066,413 Operation of ISFSI 0 0 56,995,972 0 0 0 56,995,972 Transfer of fuel and/or nuclear material away from the ISFSI 0 0 3,164,800 0 0 0 3,164,800 Management and Support 0 0 0 0 0 6,314,372 6,314,372 Project management, engineering and support 0 0 0 0 0 4,703,539 4,703,539 Project management 0 0 0 0 0 1,820,879 1,820,879 Support services 0 0 0 0 0 2,764,862 2,764,862 Miscellaneous expenditures 0 0 0 0 0 1,610,832 1,610,832 Taxes 0 0 0 0 0 1,295,014 1,295,014 Insurances 0 0 0 0 0 315,819 315,819 Nuclear related insurances 0 0 0 0 0 262,344 262,344 Other insurances 0 0 0 0 0 53,475 53,475 Site Restoration Activities 0 0 65,700 34,373,769 0 6,348,356 40,787,825 70

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Conventional dismantling, demolition and site restoration 0 0 0 22,402,300 0 0 22,402,300 Demolition of buildings and structures 0 0 0 22,402,300 0 0 22,402,300 Demolition of buildings and structures outside the controlled area 0 0 0 22,402,300 0 0 22,402,300 Fuel and nuclear material 0 0 65,700 0 0 0 65,700 Decommissioning of ISFSI 0 0 65,700 0 0 0 65,700 Decommissioning of ISFSI 0 0 48,000 0 0 0 48,000 Decommissioning of ISFSI - Decommissioning of ISFSI - Site Restoration costs 0 0 48,000 0 0 0 48,000 Management of waste 0 0 17,700 0 0 0 17,700 Decommissioning of ISFSI - Management of waste -

Site Restoration costs 0 0 17,700 0 0 0 17,700 Waste 0 0 0 11,971,469 0 0 11,971,469 Management of decommissioning waste and materials generated outside controlled areas 0 0 0 11,971,469 0 0 11,971,469 Management and Support 0 0 0 0 0 6,348,356 6,348,356 Project management, engineering and support 0 0 0 0 0 4,150,597 4,150,597 Project management 0 0 0 0 0 1,159,945 1,159,945 Support services 0 0 0 0 0 2,888,369 2,888,369 Miscellaneous expenditures 0 0 0 0 0 2,197,759 2,197,759 Taxes 0 0 0 0 0 1,843,745 1,843,745 Insurances 0 0 0 0 0 354,014 354,014 Nuclear related insurances 0 0 0 0 0 294,072 294,072 Other insurances 0 0 0 0 0 59,942 59,942 Grand Total 8,807,656 0 74,243,932 366,064,054 0 149,068,253 598,183,896 71

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-1b IP2 Decommissioning Activities and Costs by Period Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation License Termination (Decommissioning) Activities 8,807,656 0 26,957,544 265,925,367 0 167,765,803 469,456,370 Radioactive Component Removal 0 0 0 66,278,019 0 0 66,278,019 Dismantling of main process systems, structures and components 0 0 0 27,928,019 0 0 27,928,019 Dismantling of reactor internals 0 0 0 38,350,000 0 0 38,350,000 Decontamination and Dismantlement 0 0 0 5,949,044 0 0 5,949,044 Procurement of equipment for decontamination and dismantling 0 0 0 5,900,000 0 0 5,900,000 Procurement of general site-dismantling equipment 0 0 0 983,333 0 0 983,333 Procurement of special tools for dismantling the reactor systems 0 0 0 4,916,667 0 0 4,916,667 Dismantling of other systems and components 0 0 0 49,044 0 0 49,044 Conventional dismantling, demolition and site restoration 0 0 0 63,436,800 0 0 63,436,800 Demolition of buildings and structures 0 0 0 63,436,800 0 0 63,436,800 Demolition of buildings and structures from the formerly controlled area 0 0 0 63,436,800 0 0 63,436,800 Fuel and nuclear material 0 0 26,957,544 0 0 0 26,957,544 Dedicated ISFSI for fuel and/or nuclear material 0 0 20,281,250 0 0 0 20,281,250 Transfer of fuel and/or nuclear material away from the ISFSI 0 0 20,281,250 0 0 0 20,281,250 Decommissioning of ISFSI 0 0 6,676,294 0 0 0 6,676,294 Decommissioning of ISFSI 0 0 6,676,294 0 0 0 6,676,294 Decommissioning of ISFSI - Decommissioning of ISFSI - License Termination costs 0 0 6,676,294 0 0 0 6,676,294 Waste 0 0 0 130,261,505 0 0 130,261,505 Waste management system 0 0 0 2,372,405 0 0 2,372,405 Maintenance, surveillance and operational support for waste management system 0 0 0 2,372,405 0 0 2,372,405 Management of decommissioning low-level waste 0 0 0 13,978,756 0 0 13,978,756 Management of decommissioning exempt waste and materials 0 0 0 105,060,343 0 0 105,060,343 Management and Support 8,807,656 0 0 0 0 167,765,803 176,573,459 72

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Pre-decommissioning actions 8,807,656 0 0 0 0 0 8,807,656 Facility characterization 8,807,656 0 0 0 0 0 8,807,656 Site infrastructure and operation 0 0 0 0 0 53,622,023 53,622,023 Site security and surveillance 0 0 0 0 0 18,975,947 18,975,947 Site operation and maintenance 0 0 0 0 0 6,458,108 6,458,108 Operation of support systems 0 0 0 0 0 16,469,064 16,469,064 Radiation and environmental safety monitoring 0 0 0 0 0 11,718,904 11,718,904 Project management, engineering and support 0 0 0 0 0 47,506,418 47,506,418 Project management 0 0 0 0 0 19,740,712 19,740,712 Support services 0 0 0 0 0 26,520,829 26,520,829 Health and safety 0 0 0 0 0 1,244,878 1,244,878 Miscellaneous expenditures 0 0 0 0 0 66,637,362 66,637,362 Owner costs 0 0 0 0 0 36,217,819 36,217,819 Implementation of transition plans 0 0 0 0 0 27,833,250 27,833,250 Payments (fees) to authorities 0 0 0 0 0 8,384,569 8,384,569 Taxes 0 0 0 0 0 27,554,936 27,554,936 Local, community, federal taxes 0 0 0 0 0 15,541,856 15,541,856 Insurances 0 0 0 0 0 2,864,607 2,864,607 Nuclear related insurances 0 0 0 0 0 2,379,566 2,379,566 Other insurances 0 0 0 0 0 485,041 485,041 Spent Fuel Management Activities 0 60,196,850 102,035,675 0 0 26,045,191 188,277,716 Fuel and nuclear material 0 0 102,035,675 0 0 0 102,035,675 Dedicated ISFSI for fuel and/or nuclear material 0 0 102,035,675 0 0 0 102,035,675 Operation of ISFSI 0 0 62,792,155 0 0 0 62,792,155 Waste Management and Support 0 60,196,850 0 0 0 26,045,191 86,242,041 Project management, engineering and support 0 0 0 0 0 15,484,155 15,484,155 Project management 0 0 0 0 0 6,565,432 6,565,432 Support services 0 0 0 0 0 8,442,924 8,442,924 Health and safety 0 0 0 0 0 475,799 475,799 Miscellaneous expenditures 0 0 0 0 0 10,561,036 10,561,036 Taxes 0 0 0 0 0 9,678,352 9,678,352 Local, community, federal taxes 0 0 0 0 0 6,153,233 6,153,233 Insurances 0 0 0 0 0 882,684 882,684 Nuclear related insurances 0 0 0 0 0 733,226 733,226 Other insurances 0 0 0 0 0 149,458 149,458 Site Restoration Activities 0 0 1,149,259 34,389,994 0 8,548,296 44,087,548 73

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Fuel and nuclear material 0 0 1,149,259 0 0 0 1,149,259 Decommissioning of ISFSI 0 0 1,149,259 0 0 0 1,149,259 Decommissioning of ISFSI 0 0 1,131,559 0 0 0 1,131,559 Decommissioning of ISFSI - Decommissioning of ISFSI - Site Restoration costs 0 0 1,131,559 0 0 0 1,131,559 Management of waste 0 0 17,700 0 0 0 17,700 Decommissioning of ISFSI - Management of waste -

Site Restoration costs 0 0 17,700 0 0 0 17,700 Waste 0 0 0 11,987,694 0 0 11,987,694 Management of decommissioning waste and materials generated outside controlled areas 0 0 0 11,987,694 0 0 11,987,694 Management and Support 0 0 0 0 0 8,548,296 8,548,296 Project management, engineering and support 0 0 0 0 0 5,505,360 5,505,360 Project management 0 0 0 0 0 2,104,275 2,104,275 Support services 0 0 0 0 0 3,285,031 3,285,031 Health and safety 0 0 0 0 0 116,055 116,055 Miscellaneous expenditures 0 0 0 0 0 3,042,936 3,042,936 Taxes 0 0 0 0 0 2,663,345 2,663,345 Local, community, federal taxes 0 0 0 0 0 841,610 841,610 Insurances 0 0 0 0 0 379,590 379,590 Nuclear related insurances 0 0 0 0 0 315,317 315,317 Other insurances 0 0 0 0 0 64,273 64,273 Grand Total 8,807,656 60,196,850 130,142,478 300,315,361 0 202,359,290 701,821,634 74

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-1c IP3 Decommissioning Activities and Costs by Period Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation License Termination (Decommissioning) Activities 8,807,656 0 21,063,233 334,314,600 0 218,982,937 583,168,426 Radioactive Component Removal 0 0 0 73,677,725 0 0 73,677,725 Dismantling of main process systems, structures and components 0 0 0 35,327,725 0 0 35,327,725 Dismantling of reactor internals 0 0 0 38,350,000 0 0 38,350,000 Decontamination and Dismantlement 0 0 0 5,949,044 0 0 5,949,044 Procurement of equipment for decontamination and dismantling 0 0 0 5,900,000 0 0 5,900,000 Procurement of general site-dismantling equipment 0 0 0 983,333 0 0 983,333 Procurement of special tools for dismantling the reactor systems 0 0 0 4,916,667 0 0 4,916,667 Removal of materials requiring specific procedures 0 0 0 0 0 0 0 Removal of asbestos 0 0 0 0 0 0 0 Dismantling of other systems and components 0 0 0 49,044 0 0 49,044 Dismantling of remaining components 0 0 0 0 0 0 0 Conventional dismantling, demolition and site restoration 0 0 0 89,193,417 0 0 89,193,417 Demolition of buildings and structures 0 0 0 71,366,400 0 0 71,366,400 Demolition of buildings and structures from the formerly controlled area 0 0 0 71,366,400 0 0 71,366,400 Final radioactivity survey of site 0 0 0 17,827,017 0 0 17,827,017 Final survey 0 0 0 17,827,017 0 0 17,827,017 Fuel and nuclear material 0 0 21,063,233 0 0 0 21,063,233 Dedicated ISFSI for fuel and/or nuclear material 0 0 20,281,250 0 0 0 20,281,250 Transfer of fuel and/or nuclear material away from the ISFSI 0 0 20,281,250 0 0 0 20,281,250 Decommissioning of ISFSI 0 0 781,983 0 0 0 781,983 Decommissioning of ISFSI 0 0 781,983 0 0 0 781,983 Decommissioning of ISFSI - Decommissioning of ISFSI - License Termination costs 0 0 781,983 0 0 0 781,983 Waste 0 0 0 165,494,414 0 0 165,494,414 Waste management system 0 0 0 2,179,018 0 0 2,179,018 Maintenance, surveillance and operational support for waste management system 0 0 0 2,179,018 0 0 2,179,018 75

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Management of decommissioning low-level waste 0 0 0 15,176,111 0 0 15,176,111 Management of decommissioning exempt waste and materials 0 0 0 139,259,784 0 0 139,259,784 Management and Support 8,807,656 0 0 0 0 218,982,937 227,790,593 Pre-decommissioning actions 8,807,656 0 0 0 0 0 8,807,656 Facility characterization 8,807,656 0 0 0 0 0 8,807,656 Safety, security and environmental studies 0 0 0 0 0 0 0 Site infrastructure and operation 0 0 0 0 0 71,261,060 71,261,060 Site security and surveillance 0 0 0 0 0 35,616,098 35,616,098 Site operation and maintenance 0 0 0 0 0 8,220,872 8,220,872 Operation of support systems 0 0 0 0 0 14,341,197 14,341,197 Radiation and environmental safety monitoring 0 0 0 0 0 13,082,892 13,082,892 Project management, engineering and support 0 0 0 0 0 67,453,747 67,453,747 Project management 0 0 0 0 0 37,376,845 37,376,845 Support services 0 0 0 0 0 28,138,204 28,138,204 Health and safety 0 0 0 0 0 1,938,698 1,938,698 Miscellaneous expenditures 0 0 0 0 0 80,268,130 80,268,130 Owner costs 0 0 0 0 0 36,217,819 36,217,819 Implementation of transition plans 0 0 0 0 0 27,833,250 27,833,250 Payments (fees) to authorities 0 0 0 0 0 8,384,569 8,384,569 Specific external services and payments 0 0 0 0 0 0 0 Taxes 0 0 0 0 0 40,890,781 40,890,781 Local, community, federal taxes 0 0 0 0 0 27,189,670 27,189,670 Insurances 0 0 0 0 0 3,159,530 3,159,530 Nuclear related insurances 0 0 0 0 0 2,624,552 2,624,552 Other insurances 0 0 0 0 0 534,977 534,977 Spent Fuel Management Activities 0 106,198,906 238,086,472 0 0 27,084,193 371,369,571 Fuel and nuclear material 0 0 238,086,472 0 0 0 238,086,472 Dedicated ISFSI for fuel and/or nuclear material 0 0 235,626,413 0 0 0 235,626,413 Operation of ISFSI 0 0 198,914,733 0 0 0 198,914,733 Waste Management and Support 0 106,198,906 0 0 0 27,084,193 133,283,099 Project management, engineering and support 0 0 0 0 0 14,192,876 14,192,876 Project management 0 0 0 0 0 7,740,162 7,740,162 Support services 0 0 0 0 0 6,071,192 6,071,192 Health and safety 0 0 0 0 0 381,523 381,523 Miscellaneous expenditures 0 0 0 0 0 12,891,316 12,891,316 Taxes 0 0 0 0 0 12,293,241 12,293,241 76

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Period 1 Period 2 Period 3 Period 4 Period 5 Pre-Program decommissioning Plant Safe Storage Ongoing ISFSI Activities Dismantlement Management Total Planning & Deactivation Operations Operations Costs Preparation Local, community, federal taxes 0 0 0 0 0 10,509,370 10,509,370 Insurances 0 0 0 0 0 598,075 598,075 Nuclear related insurances 0 0 0 0 0 496,808 496,808 Other insurances 0 0 0 0 0 101,267 101,267 Site Restoration Activities 0 0 996,460 36,631,994 0 10,211,626 47,840,080 Fuel and nuclear material 0 0 996,460 0 0 0 996,460 Decommissioning of ISFSI 0 0 996,460 0 0 0 996,460 Decommissioning of ISFSI 0 0 978,760 0 0 0 978,760 Decommissioning of ISFSI - Decommissioning of ISFSI - Site Restoration costs 0 0 978,760 0 0 0 978,760 Management of waste 0 0 17,700 0 0 0 17,700 Decommissioning of ISFSI - Management of waste

- Site Restoration costs 0 0 17,700 0 0 0 17,700 Waste 0 0 0 11,964,094 0 0 11,964,094 Management of decommissioning waste and materials generated outside controlled areas 0 0 0 11,964,094 0 0 11,964,094 Management and Support 0 0 0 0 0 10,211,626 10,211,626 Project management, engineering and support 0 0 0 0 0 6,990,644 6,990,644 Project management 0 0 0 0 0 3,750,342 3,750,342 Support services 0 0 0 0 0 3,024,159 3,024,159 Health and safety 0 0 0 0 0 216,143 216,143 Miscellaneous expenditures 0 0 0 0 0 3,220,981 3,220,981 Taxes 0 0 0 0 0 2,851,706 2,851,706 Local, community, federal taxes 0 0 0 0 0 976,753 976,753 Insurances 0 0 0 0 0 369,276 369,276 Nuclear related insurances 0 0 0 0 0 306,749 306,749 Other insurances 0 0 0 0 0 62,526 62,526 Grand Total 8,807,656 106,198,906 260,146,165 370,946,594 0 256,278,755 1,002,378,076 77

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-2a IP1 Program Management Cost Detail Cost By Year By WBS - Program Management Cost 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 WBS_Code WBS_Name Total 01.02 IPEC Unit 1 19,838,969 23,764,642 15,473,526 15,012,208 9,053,783 9,066,845 9,055,905 8,665,645 8,648,928 8,648,928 8,648,928 8,673,413 4,516,532 149,068,253 01.02.06 Site infrastructure and operation 3,464,395 6,222,171 4,682,030 2,923,632 2,199,772 2,212,833 2,207,949 2,212,833 2,212,833 2,212,833 2,212,833 1,856,083 861,813 35,482,009 01.02.06.01 Site security and surveillance 154,875 781,750 265,500 276,563 265,500 265,500 265,500 265,500 265,500 265,500 265,500 276,563 143,813 3,757,563 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 0 516,250 0 0 0 0 0 0 0 0 0 0 0 516,250 01.02.06.01.04 Deployment of officers forces 154,875 265,500 265,500 276,563 265,500 265,500 265,500 265,500 265,500 265,500 265,500 276,563 143,813 3,241,313 01.02.06.02 Site operation and maintenance 641,145 1,068,430 893,148 424,352 239,123 239,123 238,114 239,123 239,123 239,123 239,123 173,453 75,796 4,949,174 Inspection and maintenance of buildings and 01.02.06.02.01 systems 641,145 1,068,430 893,148 424,352 239,123 239,123 238,114 239,123 239,123 239,123 239,123 173,453 75,796 4,949,174 01.02.06.03 Operation of support systems 1,312,548 2,204,670 2,143,597 1,344,529 957,742 957,742 957,034 957,742 957,742 957,742 957,742 990,653 516,095 15,215,581 01.02.06.03.01 Electricity supply systems 921,506 1,579,725 1,579,725 1,053,150 789,862 789,862 789,862 789,862 789,862 789,862 789,862 822,773 427,842 11,913,759 01.02.06.03.02 Ventilation systems 293,525 504,841 501,515 266,821 167,880 167,880 167,172 167,880 167,880 167,880 167,880 167,880 88,253 2,997,285 01.02.06.03.07 Other systems 97,517 120,104 62,358 24,558 0 0 0 0 0 0 0 0 0 304,536 01.02.06.04 Radiation and environmental safety monitoring 1,355,827 2,167,322 1,379,784 878,189 737,407 750,468 747,301 750,468 750,468 750,468 750,468 415,414 126,109 11,559,692 01.02.06.04.02 Radiation protection and monitoring 1,146,034 1,885,048 1,233,841 829,072 737,407 750,468 747,301 750,468 750,468 750,468 750,468 415,414 126,109 10,872,566 01.02.08 Project management, engineering and support 8,026,904 7,455,962 6,069,938 4,605,486 3,850,395 3,850,395 3,844,339 3,850,395 3,850,395 3,850,395 3,850,395 4,006,158 2,104,569 59,215,724 01.02.08.02 Project management 4,893,115 3,669,470 2,701,461 1,514,305 1,007,558 1,007,558 1,003,822 1,007,558 1,007,558 1,007,558 1,007,558 1,159,050 642,883 21,629,456 01.02.08.02.01 Core management group 1,351,819 2,141,069 2,062,408 1,016,808 540,048 540,048 537,769 540,048 540,048 540,048 540,048 817,919 495,081 11,663,159 Project implementation planning, detailed ongoing 01.02.08.02.02 planning 2,564,069 102,915 134,573 135,714 135,143 135,143 134,573 135,143 135,143 135,143 135,143 103,984 47,362 4,034,051 01.02.08.02.03 Scheduling and cost control 151,679 261,123 114,533 65,556 65,281 65,281 65,005 65,281 65,281 65,281 65,281 65,281 34,318 1,149,181 01.02.08.02.05 Quality assurance and quality surveillance 455,323 624,242 115,915 23,442 0 0 0 0 0 0 0 0 0 1,218,922 01.02.08.02.06 General administration and accounting 299,017 418,049 151,961 145,628 145,016 145,016 144,404 145,016 145,016 145,016 145,016 44,708 0 2,073,859 01.02.08.02.07 Public relations and stakeholders involvement 71,208 122,071 122,071 127,157 122,071 122,071 122,071 122,071 122,071 122,071 122,071 127,157 66,122 1,490,283 01.02.08.03 Support services 2,970,682 3,557,594 3,270,464 2,992,337 2,744,407 2,744,407 2,742,503 2,744,407 2,744,407 2,744,407 2,744,407 2,748,679 1,409,943 36,158,647 01.02.08.03.01 Engineering support 459,633 614,841 446,694 296,621 232,388 232,388 231,408 232,388 232,388 232,388 232,388 146,418 56,827 3,646,770 01.02.08.03.02 Information system and computer support 57,238 98,538 56,099 12,279 0 0 0 0 0 0 0 39,128 29,737 293,019 01.02.08.03.03 Waste management support 45,053 0 0 0 0 0 0 0 0 0 0 0 0 45,053 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 31,373 54,011 53,783 54,239 54,011 54,011 53,783 54,011 54,011 54,011 54,011 54,011 28,393 653,660 01.02.08.03.05 Personnel management and training 229,914 372,827 309,495 207,870 164,914 164,914 164,218 164,914 164,914 164,914 164,914 90,960 30,489 2,395,260 01.02.08.03.07 Procurement, warehousing, and materials handling 61,483 105,846 105,399 30,967 0 0 0 0 0 0 0 36,607 27,821 368,123 01.02.08.03.08 Housing, office equipment, support services 2,085,988 2,311,532 2,298,994 2,390,360 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,381,556 1,236,676 28,756,763 01.02.08.04 Health and safety 163,107 228,898 98,013 98,844 98,429 98,429 98,013 98,429 98,429 98,429 98,429 98,429 51,743 1,427,621 01.02.08.04.01 Health physics 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety 163,107 228,898 98,013 98,844 98,429 98,429 98,013 98,429 98,429 98,429 98,429 98,429 51,743 1,427,621 01.02.11 Miscellaneous expenditures 8,347,671 10,086,509 4,721,558 7,483,091 3,003,617 3,003,617 3,003,617 2,602,417 2,585,701 2,585,701 2,585,701 2,811,172 1,550,150 54,370,520 01.02.11.01 Owner costs 8,150,482 9,748,471 4,383,520 5,729,717 797,245 797,245 797,245 396,045 379,329 379,329 379,329 590,715 355,032 32,883,705 01.02.11.01.01 Implementation of transition plans 7,854,867 9,369,142 4,004,191 5,334,583 417,917 417,917 417,917 16,717 0 0 0 0 0 27,833,250 01.02.11.01.03 Payments (fees) to authorities 295,615 379,329 379,329 395,134 379,329 379,329 379,329 379,329 379,329 379,329 379,329 590,715 355,032 5,050,455 01.02.11.01.04 Specific external services and payments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes 0 0 0 1,401,250 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,012,014 17,359,935 01.02.11.02.02 Local, community, federal taxes 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.03 Insurances 197,189 338,038 338,038 352,123 338,038 338,038 338,038 338,038 338,038 338,038 338,038 352,123 183,104 4,126,881 01.02.11.03.01 Nuclear related insurances 163,800 280,801 280,801 292,501 280,801 280,801 280,801 280,801 280,801 280,801 280,801 292,501 152,100 3,428,109 01.02.11.03.02 Other insurances 33,388 57,237 57,237 59,622 57,237 57,237 57,237 57,237 57,237 57,237 57,237 59,622 31,003 698,771 78

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-2b IP2 Program Management Cost Detail Cost By Year By WBS - Program Management Cost 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 Total WBS_Code WBS_Name 01.02 IPEC Unit 2 32,785,435 42,913,142 23,872,304 17,767,059 10,355,724 10,368,785 10,352,352 9,967,585 9,950,869 9,950,869 9,950,869 9,377,623 4,746,676 202,359,290 01.02.06 Site infrastructure and operation 8,560,612 14,845,638 6,464,804 3,049,150 2,543,694 2,556,755 2,550,420 2,556,755 2,556,755 2,556,755 2,556,755 1,962,115 861,813 53,622,023 01.02.06.01 Site security and surveillance 4,975,512 9,080,716 2,364,281 276,563 265,500 265,500 265,500 265,500 265,500 265,500 265,500 276,563 143,813 18,975,947 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 0 516,250 0 0 0 0 0 0 0 0 0 0 0 516,250 01.02.06.01.04 Deployment of officers forces 4,975,512 8,564,466 2,364,281 276,563 265,500 265,500 265,500 265,500 265,500 265,500 265,500 276,563 143,813 18,459,697 01.02.06.02 Site operation and maintenance 1,224,339 1,842,027 1,016,193 453,449 239,123 239,123 238,114 239,123 239,123 239,123 239,123 173,453 75,796 6,458,108 Inspection and maintenance of buildings and 01.02.06.02.01 systems 1,224,339 1,842,027 1,016,193 453,449 239,123 239,123 238,114 239,123 239,123 239,123 239,123 173,453 75,796 6,458,108 01.02.06.03 Operation of support systems 1,312,548 2,203,714 2,077,896 1,438,460 1,125,622 1,125,622 1,124,206 1,125,622 1,125,622 1,125,622 1,125,622 1,042,411 516,095 16,469,064 01.02.06.03.01 Electricity supply systems 921,506 1,579,725 1,579,725 1,053,150 789,862 789,862 789,862 789,862 789,862 789,862 789,862 822,773 427,842 11,913,759 01.02.06.03.02 Ventilation systems 293,525 456,109 331,000 336,194 335,760 335,760 334,343 335,760 335,760 335,760 335,760 219,637 88,253 4,073,621 01.02.06.03.07 Other systems 97,517 167,880 167,172 49,116 0 0 0 0 0 0 0 0 0 481,684 01.02.06.04 Radiation and environmental safety monitoring 1,048,212 1,719,181 1,006,434 880,679 913,449 926,510 922,601 926,510 926,510 926,510 926,510 469,688 126,109 11,718,904 01.02.06.04.02 Radiation protection and monitoring 838,419 1,413,020 901,620 796,385 829,509 842,570 839,015 842,570 842,570 842,570 842,570 443,809 126,109 10,400,738 01.02.08 Project management, engineering and support 8,022,689 7,752,642 6,656,525 5,476,238 4,808,413 4,808,413 4,798,315 4,808,413 4,808,413 4,808,413 4,808,413 4,604,336 2,334,713 68,495,934 01.02.08.02 Project management 4,563,869 3,375,196 3,102,083 2,231,279 1,824,748 1,824,748 1,817,564 1,824,748 1,824,748 1,824,748 1,824,748 1,591,709 780,230 28,410,419 01.02.08.02.01 Core management group 1,192,327 1,938,213 2,308,472 1,677,560 1,338,252 1,338,252 1,332,605 1,338,252 1,338,252 1,338,252 1,338,252 1,244,725 632,428 18,355,841 Project implementation planning, detailed ongoing 01.02.08.02.02 planning 2,615,335 231,827 134,573 71,597 45,048 45,048 44,858 45,048 45,048 45,048 45,048 76,207 47,362 3,492,046 01.02.08.02.03 Scheduling and cost control 257,580 443,437 296,078 165,353 130,562 130,562 130,011 130,562 130,562 130,562 130,562 85,407 34,318 2,195,553 01.02.08.02.04 Safety and environmental analysis, ongoing studies 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.05 Quality assurance and quality surveillance 269,151 394,949 115,915 80,464 80,126 80,126 79,788 80,126 80,126 80,126 80,126 24,703 0 1,445,726 01.02.08.02.06 General administration and accounting 158,268 244,699 124,975 109,148 108,690 108,690 108,231 108,690 108,690 108,690 108,690 33,509 0 1,430,969 01.02.08.02.07 Public relations and stakeholders involvement 71,208 122,071 122,071 127,157 122,071 122,071 122,071 122,071 122,071 122,071 122,071 127,157 66,122 1,490,283 01.02.08.03 Support services 3,132,605 3,923,773 3,435,200 3,146,114 2,885,236 2,885,236 2,882,737 2,885,236 2,885,236 2,885,236 2,885,236 2,914,199 1,502,741 38,248,784 01.02.08.03.01 Engineering support 448,947 706,750 538,216 388,919 324,298 324,298 322,929 324,298 324,298 324,298 324,298 174,753 56,827 4,583,127 01.02.08.03.02 Information system and computer support 57,238 98,538 56,099 12,279 0 0 0 0 0 0 0 39,128 29,737 293,019 01.02.08.03.03 Waste management support 176,606 217,512 0 0 0 0 0 0 0 0 0 0 0 394,118 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 31,373 54,011 53,783 54,239 54,011 54,011 53,783 54,011 54,011 54,011 54,011 54,011 28,393 653,660 01.02.08.03.05 Personnel management and training 196,225 300,908 254,576 231,703 213,833 213,833 212,931 213,833 213,833 213,833 213,833 65,925 0 2,545,266 01.02.08.03.06 Documentation and records control 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.03.07 Procurement, warehousing, and materials handling 136,228 234,523 233,533 68,614 0 0 0 0 0 0 0 198,826 151,108 1,022,830 01.02.08.03.08 Housing, office equipment, support services 2,085,988 2,311,532 2,298,994 2,390,360 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,381,556 1,236,676 28,756,763 01.02.08.04 Health and safety 326,215 453,673 119,242 98,844 98,429 98,429 98,013 98,429 98,429 98,429 98,429 98,429 51,743 1,836,731 01.02.08.04.01 Health physics 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety 326,215 453,673 119,242 98,844 98,429 98,429 98,013 98,429 98,429 98,429 98,429 98,429 51,743 1,836,731 01.02.11 Miscellaneous expenditures 16,202,134 20,314,862 10,750,975 9,241,671 3,003,617 3,003,617 3,003,617 2,602,417 2,585,701 2,585,701 2,585,701 2,811,172 1,550,150 80,241,334 01.02.11.01 Owner costs 9,662,947 11,570,121 4,383,520 5,729,717 797,245 797,245 797,245 396,045 379,329 379,329 379,329 590,715 355,032 36,217,819 01.02.11.01.01 Implementation of transition plans 7,854,867 9,369,142 4,004,191 5,334,583 417,917 417,917 417,917 16,717 0 0 0 0 0 27,833,250 01.02.11.01.03 Payments (fees) to authorities 1,808,080 2,200,978 379,329 395,134 379,329 379,329 379,329 379,329 379,329 379,329 379,329 590,715 355,032 8,384,569 01.02.11.01.04 Specific external services and payments 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.11.02 Taxes 6,341,999 8,406,704 6,029,417 3,159,830 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,012,014 39,896,634 01.02.11.02.02 Local, community, federal taxes 6,341,999 8,406,704 6,029,417 1,758,580 0 0 0 0 0 0 0 0 0 22,536,699 01.02.11.03 Insurances 197,189 338,038 338,038 352,123 338,038 338,038 338,038 338,038 338,038 338,038 338,038 352,123 183,104 4,126,881 01.02.11.03.01 Nuclear related insurances 163,800 280,801 280,801 292,501 280,801 280,801 280,801 280,801 280,801 280,801 280,801 292,501 152,100 3,428,109 01.02.11.03.02 Other insurances 33,388 57,237 57,237 59,622 57,237 57,237 57,237 57,237 57,237 57,237 57,237 59,622 31,003 698,771 79

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-2c IP3 Program Management Cost Detail Cost By Year By WBS - Program Management Cost 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 WBS_Code WBS_Name Total 01.02 IPEC Unit 3 38,183,597 53,718,166 39,014,159 24,750,501 12,453,285 12,466,346 12,441,062 12,065,146 12,048,429 12,048,429 12,048,429 10,177,840 4,863,365 256,278,755 01.02.06 Site infrastructure and operation 8,563,512 14,549,325 17,382,809 7,685,123 2,868,590 2,881,652 2,873,946 2,881,652 2,881,652 2,881,652 2,881,652 2,065,350 864,146 71,261,060 01.02.06.01 Site security and surveillance 4,975,512 9,080,716 13,590,409 4,785,865 389,365 389,365 388,843 389,365 389,365 389,365 389,365 314,750 143,813 35,616,098 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 0 516,250 0 0 0 0 0 0 0 0 0 0 0 516,250 01.02.06.01.04 Deployment of officers forces 4,975,512 8,564,466 13,590,409 4,785,865 389,365 389,365 388,843 389,365 389,365 389,365 389,365 314,750 143,813 35,099,848 01.02.06.02 Site operation and maintenance 1,281,549 1,773,740 918,740 633,800 478,245 478,245 476,228 478,245 478,245 478,245 478,245 215,568 51,775 8,220,872 Inspection and maintenance of buildings and 01.02.06.02.01 systems 1,281,549 1,773,740 918,740 633,800 478,245 478,245 476,228 478,245 478,245 478,245 478,245 215,568 51,775 8,220,872 01.02.06.03 Operation of support systems 1,114,589 1,914,038 1,855,054 1,247,279 957,742 957,742 957,034 957,742 957,742 957,742 957,742 990,653 516,095 14,341,197 01.02.06.03.01 Electricity supply systems 921,506 1,579,725 1,579,725 1,053,150 789,862 789,862 789,862 789,862 789,862 789,862 789,862 822,773 427,842 11,913,759 01.02.06.03.02 Ventilation systems 95,566 166,433 170,515 169,571 167,880 167,880 167,172 167,880 167,880 167,880 167,880 167,880 88,253 2,032,669 01.02.06.03.07 Other systems 97,517 167,880 104,814 24,558 0 0 0 0 0 0 0 0 0 394,769 01.02.06.04 Radiation and environmental safety monitoring 1,191,861 1,780,831 1,018,607 1,018,179 1,043,237 1,056,299 1,051,842 1,056,299 1,056,299 1,056,299 1,056,299 544,378 152,463 13,082,892 01.02.06.04.02 Radiation protection and monitoring 869,793 1,360,276 935,021 933,885 959,297 972,359 968,256 972,359 972,359 972,359 972,359 518,500 152,463 11,559,285 01.02.08 Project management, engineering and support 9,729,448 10,739,887 7,523,086 6,844,498 6,581,077 6,581,077 6,563,499 6,581,077 6,581,077 6,581,077 6,581,077 5,301,318 2,449,069 88,637,267 01.02.08.02 Project management 6,138,627 6,156,554 3,865,474 3,642,732 3,693,900 3,693,900 3,678,829 3,693,900 3,693,900 3,693,900 3,693,900 2,323,385 898,346 48,867,348 01.02.08.02.01 Core management group 2,603,983 4,442,980 2,912,181 3,035,035 3,215,035 3,215,035 3,201,469 3,215,035 3,215,035 3,215,035 3,215,035 1,995,918 763,589 38,245,361 Project implementation planning, detailed ongoing 01.02.08.02.02 planning 2,614,267 309,103 179,431 116,835 90,096 90,096 89,715 90,096 90,096 90,096 90,096 27,776 0 3,877,700 01.02.08.02.03 Scheduling and cost control 257,580 443,437 344,574 137,994 65,281 65,281 65,005 65,281 65,281 65,281 65,281 110,436 68,635 1,819,346 01.02.08.02.04 Safety and environmental analysis, ongoing studies 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.02.05 Quality assurance and quality surveillance 352,130 479,297 159,576 103,906 80,126 80,126 79,788 80,126 80,126 80,126 80,126 24,703 0 1,680,156 01.02.08.02.06 General administration and accounting 239,459 359,667 147,641 121,804 121,292 121,292 120,781 121,292 121,292 121,292 121,292 37,394 0 1,754,501 01.02.08.02.07 Public relations and stakeholders involvement 71,208 122,071 122,071 127,157 122,071 122,071 122,071 122,071 122,071 122,071 122,071 127,157 66,122 1,490,283 01.02.08.03 Support services 3,427,713 4,302,535 3,440,358 3,004,078 2,690,319 2,690,319 2,688,643 2,690,319 2,690,319 2,690,319 2,690,319 2,781,076 1,447,237 37,233,555 01.02.08.03.01 Engineering support 593,339 827,667 339,051 188,066 124,289 124,289 123,765 124,289 124,289 124,289 124,289 38,318 0 2,855,940 01.02.08.03.02 Information system and computer support 114,476 197,076 196,244 57,658 0 0 0 0 0 0 0 0 0 565,453 01.02.08.03.03 Waste management support 176,606 217,512 0 0 0 0 0 0 0 0 0 0 0 394,118 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 62,747 108,022 107,566 108,478 108,022 108,022 107,566 108,022 108,022 108,022 108,022 108,022 56,786 1,307,320 01.02.08.03.05 Personnel management and training 258,330 406,204 264,969 190,902 164,914 164,914 164,218 164,914 164,914 164,914 164,914 90,960 30,489 2,395,558 01.02.08.03.07 Procurement, warehousing, and materials handling 136,228 234,523 233,533 68,614 0 0 0 0 0 0 0 162,219 123,287 958,403 01.02.08.03.08 Housing, office equipment, support services 2,085,988 2,311,532 2,298,994 2,390,360 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,293,094 2,381,556 1,236,676 28,756,763 01.02.08.04 Health and safety 163,107 280,797 217,255 197,688 196,858 196,858 196,027 196,858 196,858 196,858 196,858 196,858 103,486 2,536,364 01.02.08.04.01 Health physics 0 0 0 0 0 0 0 0 0 0 0 0 0 0 01.02.08.04.02 Industrial safety 163,107 280,797 217,255 197,688 196,858 196,858 196,027 196,858 196,858 196,858 196,858 196,858 103,486 2,536,364 01.02.11 Miscellaneous expenditures 19,890,637 28,428,955 14,108,264 10,220,880 3,003,617 3,003,617 3,003,617 2,602,417 2,585,701 2,585,701 2,585,701 2,811,172 1,550,150 96,380,428 01.02.11.01 Owner costs 9,662,947 11,570,121 4,383,520 5,729,717 797,245 797,245 797,245 396,045 379,329 379,329 379,329 590,715 355,032 36,217,819 01.02.11.01.01 Implementation of transition plans 7,854,867 9,369,142 4,004,191 5,334,583 417,917 417,917 417,917 16,717 0 0 0 0 0 27,833,250 01.02.11.01.03 Payments (fees) to authorities 1,808,080 2,200,978 379,329 395,134 379,329 379,329 379,329 379,329 379,329 379,329 379,329 590,715 355,032 8,384,569 01.02.11.02 Taxes 10,030,502 16,520,797 9,386,706 4,139,040 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,868,334 1,012,014 56,035,728 01.02.11.02.02 Local, community, federal taxes 10,030,502 16,520,797 9,386,706 2,737,789 0 0 0 0 0 0 0 0 0 38,675,793 01.02.11.03 Insurances 197,189 338,038 338,038 352,123 338,038 338,038 338,038 338,038 338,038 338,038 338,038 352,123 183,104 4,126,881 01.02.11.03.01 Nuclear related insurances 163,800 280,801 280,801 292,501 280,801 280,801 280,801 280,801 280,801 280,801 280,801 292,501 152,100 3,428,109 01.02.11.03.02 Other insurances 33,388 57,237 57,237 59,622 57,237 57,237 57,237 57,237 57,237 57,237 57,237 59,622 31,003 698,771 80

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-3 HDI Decommissioning Cost Estimate Summary (thousands of 2019 dollars)

Decommissioning Activity IP1 IP2 IP3 Decontamination Removal 162,256 186,173 197,721 Packaging 11,175 14,300 15,964 Transportation 41,043 19,637 28,135 Disposal 156,222 105,940 131,180 Off-site Waste Processing Program Management 119,726 144,384 182,529 Corporate A&G Spent Fuel (Direct Expenditures) 66,066 162,233 344,285 Insurance and Regulatory Fees 9,177 12,511 12,511 Energy 11,914 11,914 11,914 Characterization and Licensing Surveys 8,808 8,808 26,635 Property Taxes 22,537 38,676 Miscellaneous Equipment / Site Services 11,797 13,386 12,827 Spent Fuel Pool Isolation Grand Total 598,184 701,822 1,002,378 Cost Category IP1 IP2 IP3 License Termination 485,015 469,456 583,168 Spent Fuel Management 72,381 188,278 371,370 Site Restoration 40,788 44,088 47,840 Grand Total 598,184 701,822 1,002,378 81

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-4a IP1 Labor Costs and Labor Requirements by Year Labor Costs ($Millions) and Labor Requirements (FTE) per Year Labor Category 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 Management Labor Cost 1.59 2.462 2.05 1.098 .675 .675 .672 .675 .675 .675 .675 .8 .45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Management Labor FTEs 5.10 7.79 6.24 3.34 2.15 2.15 2.15 2.15 2.15 2.15 2.15 2.58 1.43 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 4.072 6.435 4.147 2.562 2.089 2.089 2.08 2.089 2.089 2.089 2.089 1.921 1.889 1.905 1.905 1.91 1.905 1.905 1.905 1.91 1.905 1.905 1.905 Professional Labor FTEs 27.18 43.55 29.82 17.59 13.48 13.48 13.48 13.48 13.48 13.48 13.48 12.66 10.65 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 Craft Labor Cost 2.132 3.439 2.499 1.499 1.123 1.123 1.118 1.123 1.123 1.123 1.123 .679 .253 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Craft Labor FTEs 12.49 20.08 14.82 8.86 6.64 6.64 6.64 6.64 6.64 6.64 6.64 3.96 1.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 7.794 12.336 8.697 5.16 3.887 3.887 3.87 3.887 3.887 3.887 3.887 3.4 2.592 1.905 1.905 1.91 1.905 1.905 1.905 1.91 1.905 1.905 1.905 Total Labor FTEs 44.77 71.41 50.88 29.79 22.26 22.27 22.27 22.27 22.27 22.27 22.27 19.20 13.53 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 Labor Category Total 2044 2045 2046 2047 2048 2049 2050 2052 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 Cost Management Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 13.17 Management Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 1.91 1.905 2.479 1.84 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 62.838 Professional Labor FTEs 8.67 8.67 11.28 8.37 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Craft Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 18.358 Craft Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 1.91 1.905 2.479 1.84 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 94.366 Total Labor FTEs 8.67 8.67 11.28 8.37 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 82

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-4b IP2 Labor Costs and Labor Requirements by Year Labor Costs ($Millions) and Labor Requirements (FTE) per Year Labor Category 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2036 2038 2039 2040 2041 2042 2043 Management Labor Cost 1.44 2.27 2.27 1.72 1.44 1.44 1.43 1.44 1.44 1.44 1.44 1.22 .59 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Management Labor FTEs 4.63 7.19 6.90 5.25 4.57 4.58 4.58 4.58 4.58 4.58 4.58 3.92 1.87 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 7.41 12.27 5.84 2.76 2.22 2.22 2.21 2.22 2.22 2.22 2.22 2.08 1.98 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 Professional Labor FTEs 49.43 83.02 41.96 18.98 14.30 14.30 14.30 14.30 14.30 14.30 14.30 13.73 11.17 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 Craft Labor Cost 2.21 3.49 2.15 1.56 1.38 1.38 1.38 1.38 1.38 1.38 1.38 .76 .25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Craft Labor FTEs 12.96 20.40 12.73 9.22 8.17 8.18 8.18 8.18 8.18 8.18 8.18 4.43 1.45 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 11.06 18.04 10.25 6.05 5.04 5.04 5.02 5.04 5.04 5.04 5.04 4.06 2.82 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 Total Labor FTEs 67.0 110.6 61.6 33.4 27.0 27.1 27.1 27.1 27.1 27.1 27.1 22.1 14.5 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 Labor Category Total 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 Cost Management Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 19.56 Management Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 1.91 1.91 .76 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 71.48 Professional Labor FTEs 8.67 8.67 3.44 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Craft Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 20.1 Craft Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 1.91 1.91 .76 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 111.14 Total Labor FTEs 8.7 8.7 3.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 83

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-4c IP3 Labor Costs and Labor Requirements by Year Labor Costs ($Millions) and Labor Requirements (FTE) per Year Labor Category 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2043 2035 2036 2037 2038 2039 2040 2041 2042 2043 Management Labor Cost 2.61 4.44 3.08 3.01 3.21 3.22 3.21 3.22 3.22 3.22 3.22 2.26 .94 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Management Labor FTEs 8.36 14.03 9.36 9.16 10.22 10.27 10.27 10.27 10.27 10.27 10.27 7.30 3.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 8.19 13.28 15.77 6.79 2.36 2.36 2.35 2.36 2.36 2.36 2.36 1.91 1.76 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 Professional Labor FTEs 54.65 89.89 113.41 46.64 15.22 15.22 15.22 15.22 15.22 15.22 15.22 12.58 9.93 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 8.67 Craft Labor Cost 1.93 2.96 1.91 1.64 2.94 3.75 3.73 3.75 3.75 3.75 3.75 2.61 .23 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Craft Labor FTEs 11.30 17.26 11.35 9.71 17.39 22.18 22.18 22.18 22.18 22.18 22.18 15.23 1.33 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 12.72 20.68 20.76 11.44 8.51 9.33 9.29 9.33 9.33 9.33 9.33 6.78 2.93 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 1.91 Total Labor FTEs 74.3 121.2 134.1 65.5 42.8 47.7 47.7 47.7 47.7 47.7 47.7 35.1 14.3 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7 Labor Category Total 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061 2062 Cost Management Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 38.84 Management Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Professional Labor Cost 1.91 1.91 2.48 3.88 5.73 5.72 5.72 5.72 5.73 5.72 5.72 5.72 5.73 5.72 5.72 5.72 5.73 5.7 0.00 173.52 Professional Labor FTEs 8.67 8.67 11.28 17.63 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 26.00 25.93 0.00 Craft Labor Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 36.71 Craft Labor FTEs 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total Labor Cost 1.91 1.91 2.48 3.88 5.73 5.72 5.72 5.72 5.73 5.72 5.72 5.72 5.73 5.72 5.72 5.72 5.73 5.7 0.00 249.07 Total Labor FTEs 8.7 8.7 11.3 17.6 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 26.0 25.9 0.0 84

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-5a IP1 Labor Costs and Labor Requirements by Period Labor (FTEs) and Labor Costs ($Millions)

Program Period 1 Period 2 Period 3 Period 4 Period 5 Total IPEC Unit 1 Management Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost PWR DECON Decommissioning Crews 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 64.59 12.608 64.59 12.608 Management/Support Staff 0.00 0.00 0.00 0.00 0.00 0.00 20.67 3.154 240.93 46.097 166.53 32.507 428.13 81.758 Total 0.00 0.00 0.00 0.00 0.00 0.00 20.67 3.154 240.93 46.097 231.13 45.116 492.72 94.366 85

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-5b IP2 Labor Costs and Labor Requirements by Period Labor (FTEs) and Labor Costs ($Millions)

Program Period 1 Period 2 Period 3 Period 4 Period 5 Total IPEC Unit 2 Management Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost PWR DECON Decommissioning Crews 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 69.35 13.537 69.35 13.537 Management/Support Staff 0.00 0.00 0.00 0.00 0.00 0.00 12.98 1.980 191.62 36.629 302.24 58.999 506.84 97.608 Total 0.00 0.00 0.00 0.00 0.00 0.00 12.98 1.980 191.62 36.629 371.59 72.536 576.19 111.145 86

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-5c IP3 Labor Costs and Labor Requirements by Period Labor (FTEs) and Labor Costs ($Millions)

Program Period 1 Period 2 Period 3 Period 4 Period 5 Total IPEC Unit 3 Management Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor Labor FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost FTE Cost PWR DECON Decommissioning Crews 0.00 0.00 0.00 0.00 0.00 0.00 81.28 12.401 0.00 0.00 71.02 13.863 152.30 26.264 Management/Support Staff 0.00 0.00 0.00 0.00 0.00 0.00 47.27 7..12 622.83 119.140 494.13 96.454 1164.23 222.806 Total 0.00 0.00 0.00 0.00 0.00 0.00 128.55 19.614 622.83 119.140 565.15 110.316 1316.53 249.070 87

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-6 IPEC DOE Fuel Acceptance Allocation Fuel YEAR MTU Unit 1 Unit 2 Unit 3 Assemblies 2031 30.58 160 160 2032 32.73 72 72 2033 56.24 124 124 2034 87.38 193 193 2035 68.49 151 151 2036 96.48 212 212 2037 67.14 147 147 2038 61.45 134 134 2039 59.52 129 129 2040 36.50 79 79 2041 40.17 87 87 2042 41.00 89 89 2043 0 2044 78.33 170 170 2045 33.19 72 72 2046 31.46 69 69 2047 40.54 89 89 2048 79.56 176 155 21 2049 80.26 178 5 173 2050 2050 92 92 2051 43.53 97 97 2052 83.49 186 186 2053 43.55 96 96 2054 43.62 96 96 2055 80.76 178 178 2056 43.55 96 96 2057 42.13 92 92 2058 83.50 185 185 2059 41.73 92 92 2060 45.37 101 101 2061 174.30 386 386 160 1,998 1,870 88

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 3-7 IPEC Waste Volume and Weight IP1 IP2 IP3 Waste Volume Weight Waste Volume Weight Waste Volume Weight Waste Class (cubic feet) (pounds) (cubic feet) (pounds) (cubic feet) (pounds)

A 3,586,546 264,662,579 1,365,109 88,044,580 2,185,120 138,466,106 Low-Level Radioactive Waste B 1,411 87,409 501 50,254 501 50,254 C 1,088 102,716 574 71,218 574 71,218 Greater than Class C Waste GTCC 412 73,789 2,061 11,642 2,061 411,642 Total 3,589,457 264,926,493 1,368,245 88,577,694 2,188,256 138,999,220 89

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 4 COST ESTIMATING APPROACH 4.1 Estimating Methodology The CDI estimating methodology is an iterative process which is compatible with the development of integrated scope, schedule, cost, risk, and contingency baselines. Summary highlights of the key steps in the estimating process include:

x Initiating the cost estimate process with a discovery period, and cataloging project specific details, due diligence, applicable industry standards, and available benchmarking data x Capturing and organizing the work scope into the hierarchical structure of standard decommissioning activities outlined in the major decommissioning elements and sub-elements contained within the ISDC WBS along with a corresponding WBS dictionary x Identifying the major decommissioning project milestones and developing a Decommissioning Project Milestone Summary Schedule capturing the relationship and sequencing of the milestones x Assigning each WBS sub-element to subject matter experts to develop a detailed basis of estimate (BOE) for each WBS sub-element capturing the project specific scope of work, technical approach, deliverables, assumptions, existing and verifiable data, judgmental factors, exclusions, and resources x Identifying and qualitatively ranking the discrete risk events having a potential impact on the project scope, schedule and budget; and populating the risk register x Developing detailed schedule fragnets for each WBS sub-element, fully defining the activities, durations and logic ties and compiling these detailed schedule fragnets into a detailed activity schedule model in Oracle Primavera, P6 x Identifying quantities, resources, and cost elements to accomplish the detailed scope of work in alignment with the Oracle Primavera, P6 schedule activities x Compiling the estimate details into the cost model and validating results x Assigning estimate uncertainty categories to WBS sub-elements x Developing an integrated estimate and schedule risk model to validate schedule integrity and to establish and define cost and schedule contingency reserves x Verifying and validating the cost, schedule, and risk models, model input and model results x Documenting the estimate development details, basis methodologies and assumptions 4.2 Basis of Estimate The decommissioning scope of work was organized into 39 Level 4 WBS elements, and an individual BOE was developed for each of the elements. These BOEs capture the essential cost estimating and schedule development data; including the site-specific scope, technical approach, key deliverables, assumptions, judgmental factors, existing and verifiable data, 90

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate exclusions, and resources (quantities and pricing). Table 4-1 includes the 39 WBS elements for which the detailed BOEs were developed.

A site-specific detailed WBS and sequence of work was developed based on current plant commodities that will make up the decommissioning waste streams. The sequence of work was used to define the labor, material, equipment, energy resources and durations required for each activity. In the case of major components, individual work sequence activity analyses were performed based on the physical and radiological characteristics of the component, removal method, packaging requirements, modes of transportation and disposal location together with required system dependencies and logic ties.

In the case of structures, small components and equipment such as piping, pumps and tanks, the work durations and cost were calculated based a review of previous IP1, 2 & 3 decommissioning cost analyses, decommissioning experience, estimates from specialty subcontractors, information on the latest technology applicable to decommissioning, and engineering judgment. After the work activity durations were calculated for all distributed cost activities, a detailed schedule was developed. The DCE and schedule were prepared using information collected by HDI and CDI during the due diligence period in addition to the input and professional judgment of experienced SMEs. The schedule accounts for constraints such as spent fuel cooling periods and regulatory reviews.

The DCE and schedule took into consideration regulatory requirements, site conditions, basis of estimate assumptions, LLRW disposal standards, high-level radioactive waste management options, opportunities identified in walkdowns and site restoration requirements. Cost estimates were based on the professional judgment of experienced SMEs, considering the nature of the work, degree of scope definition, availability of quantifiable cost and pricing data, among other factors.

The estimates of costs associated with license termination in NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized-Water Reactor Power Station, (Reference 7) were reviewed in order to evaluate the reasonableness of the CDI estimates.

In addition, CDI compared the IP1, 2 & 3 decommissioning cost estimates for license termination, spent fuel management and site restoration activities to costs from similar activities from seven decommissioned pressurized water reactor nuclear power plants.

The estimates include provisions for storage of spent fuel and GTCC wastes at the on-site ISFSI until acceptance by the DOE. Escalation of future decommissioning costs over the remaining decommissioning project life-cycle are excluded.

4.3 Assumptions Work planning, schedule development and cost estimating for the decommissioning rely on a set of assumptions regarding the type and quality of inputs and the nature of the work.

Pre-Decommissioning Planning x Entergy has provided reasonable and accurate information in good faith regarding the history and current condition of the plants and site 91

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate x No decontamination efforts will be carried out to free release contaminated material x In determining the waste management strategy and volume estimates, all contaminated material will be characterized as LLRW, or its respective waste classification x Waste classification for transport will be supported by an initial site waste characterization effort Facility Shutdown Activities x All wastes and waste streams generated during decommissioning have a disposition path x No orphan waste will be generated during decommissioning Dismantling Activities within the Radiologically Controlled Area x Local ventilation will be required for most tasks and building ventilation is adequate for these tasks and will not require upgrading or replacement x The reactor building overhead crane will be available and has adequate lift capacity for casks containing RPV internals, water and the shielding cover x The turbine building overhead crane has adequate lift capacity for the low-pressure turbines and the generator Waste Processing, Storage and Disposal x Transportation of waste offsite will include truck conveyance to rail x No radioactive waste systems or processing areas will be refurbished or refit for use during decommissioning x Waste sampling and data verification/validation is accomplished by a subcontractor Site Infrastructure and Operation x Existing site security is adequate for transition and CDI decommissioning activities x The existing Operations and Maintenance (O&M) procedures are available and adequate for all active plant systems x SMEs are available in the existing work force and a sufficient number will transition to CDI to support decommissioning Project Management, Engineering, and Support x The CDI project management team will mobilize to the site during the pre-decommissioning planning phase to be ready to begin decommissioning following the sale and transfer of the facility licenses Fuel and Nuclear Material x All plant systems required to carry out the spent fuel to ISFSI pad transfer campaign are operational 92

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 4.4 Inflation The decommissioning cost estimates presented in this report were developed and reported in 2019 dollars. Escalation of future decommissioning costs over the remaining decommissioning project life-cycle are excluded.

4.5 Contingency Any project has inherent uncertainty in the estimated quantities, unit rates, productivity, pricing, and schedule durations. Concurrently there are also a vast number of project specific discrete risks, e.g., risk events that may also affect cost and schedule estimates. A sound risk management approach is used to establish the appropriate levels of cost and schedule contingency reserves for establishing achievable target schedules and budgets, making well-informed decisions during the decommissioning project lifecycle.

A Monte-Carlo simulation risk modeling tool is used to quantitatively evaluate the integrated impact of uncertainty and discrete risk events on the project objectives, baseline schedule and costs. Risk analysis tools integrate directly with project schedules and cost estimates and provides simple techniques to model uncertainty and discrete risk events to forecast the cost and schedule impacts. Risk analysis output is used with expert judgement to provide an objective view to validate the integrity of the schedule model, evaluate the effectiveness of risk response plans, identify and prioritize key risk drivers, quantify schedule and cost reserves based on desired levels of confidence, and publish risk-adjusted schedules. CDI used Primavera Risk as a model to evaluate schedule risk. Primavera Risk Analysis is a full lifecycle risk analysis solution for schedule risk management. Primavera Risk Analysis provides a comprehensive means of determining confidence levels for project success together with quick and easy techniques for determining contingency and risk response plans. CDI used the software to help determine schedule uncertainty.

Estimate Uncertainty Uncertainty in estimates is generally a function of the level of maturity in the project definition. Estimate uncertainty is also a function of various factors including:

x Expected site conditions (physical and radiological) x Decommissioning processes and tools x New and/or non-familiar technology x Complexity x Labor skills and productivity x Stakeholder/regulatory requirements x Quality of cost estimating assumptions and data x Experience and skill level of the estimator x Pricing x Estimating techniques x Time and level of effort allowed to prepare the cost estimate and schedule To provide a basis to account for the uncertainty in a decommissioning project schedule 93

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate duration and/or cost, subject matter experts assign evaluate segments of decommissioning work as to the low, expected, and high value estimate uncertainty. This assignment was based on estimate methodology, available data, and professional judgement as to the level of confidence of the estimate.

Estimate uncertainty profiles were developed to show the cumulative impacts from the estimate type and level of accuracy on schedules and costs. These estimate uncertainty profiles were used to establish the schedule and cost Uncertainty Allowance that is added to the decommissioning project baseline schedule and cost estimate to address the estimate uncertainty within the defined decommissioning scope of work and execution strategy.

Uncertainty Allowance is included in the baseline cost and schedule to cover ill-defined work scope or elements of costs and schedules expected to be incurred, which cannot be explicitly foreseen or estimated because of a lack of complete, accurate or detailed information. The amount of time/duration and costs to be included in the schedule and cost baselines for Uncertainty Allowance to account for these uncertainties is derived using the quantitative risk model in @Risk for the 85% probability or level of confidence.

Discrete Risk Events Discrete risks events on a project can be either threats or opportunities. Discrete risk events are considered a threat when the risk event may negatively impact the project baseline objectives, such as schedule delays and cost increases. Discrete risk events are considered an opportunity when the event may positively impact the project objectives, such as schedule and/or cost savings. Unlike uncertainty, discrete risk events may or may not occur. The risk analysis process used to evaluate discrete risk events is both qualitative and quantitative.

Qualitative risk analysis is the process of examining each identified risk event to refine the description of the risk event, isolate the contributing factors, define the risk event probability of occurrence, measure impacts (positive or negative) to the cost and schedule baseline should the risk event occur, and assessment of the manageability of exposure to the risk event. CDI uses a risk event scoring matrix to qualitatively grade/prioritize the discrete risk events as extremely high, high, medium, and low based on the probability of occurrence and impacts. This qualitative assessment is used to prioritize the discrete risk events for more detailed risk analysis and risk response planning with primary focus on the medium, high and extremely high-risk events.

In addition to a qualitative analysis of discrete risk events, a quantitative analysis is performed on all the active discrete risk events classified as threats. The quantitative risk analysis process relies on risk modeling/risk simulation tools to evaluate the individual and cumulative effects of the identified discrete risk events in concert with estimate uncertainty on overall project objectives and baseline schedule and costs. The primary goal of quantitative analysis is to produce measurable risk information to establish appropriate levels of reserves in the cost and schedule baselines and to support management decision making to increase project certainty.

Risk Allowance is funds added to the baseline schedule and estimate to account for discrete 94

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate risk events (both threats and opportunities) that may or may not occur during the decommissioning project lifecycle. The amount of time/duration and costs to be included in the schedule and cost baselines for Risk Allowance to account for discrete risk events that may materialize during the decommissioning project lifecycle is also derived from the quantitative risk model Stature, for the 85% probability or level of confidence. Stature, a licensed proprietary software from SNC-Lavalin, in combination with @Risk was used on IPEC to determine Risk and contingency levels. A risk log was built within Stature in order to assess the magnitude of Risks and level of confidence in managing those risks. Output from the model was then used to run a Monte Carlo in @Risk to determine the P85 or 85th percentile probability of confidence an output contingency value would give.

Contingency Allowance Based on an integrated evaluation of estimate uncertainty and discrete risk events utilizing industry accepted risk modeling tools and techniques in addition to a review of industry experience with similar decommissioning projects, a Contingency Allowance of 18 percent was determined to be reasonable for the IPEC decommissioning project. This Contingency Allowance is incorporated into the estimate of License Termination, Spent Fuel Management and Site Restoration costs presented herein. The exception is ISFSI decommissioning costs, which include a 25% Contingency Allowance consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757 (Reference 12).

The Contingency Allowance is an integral part of the cost to complete the IPEC decommissioning and is expected to be fully consumed. Contingency does not account for inflation or escalation of the price of goods and services over the course of the project.

95

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 4-1 Work Breakdown Structure WBS Code WBS Name 01.02.01.01 Decommissioning planning 01.02.01.02 Facility characterization 01.02.01.03 Safety, security and environmental studies 01.02.01.04 Waste management planning 01.02.01.05 Authorization 01.02.01.06 Preparing management group and contracting 01.02.02.01 Plant shutdown and inspection 01.02.02.02 Drainage and drying of systems 01.02.02.05 Removal of system fluids, operational waste and redundant material 01.02.04.01 Procurement of equipment for decontamination and dismantling 01.02.04.02 Preparations and support for dismantling 01.02.04.04 Removal of materials requiring specific procedures 01.02.04.05 Dismantling of main process systems, structures and components 01.02.04.06 Dismantling of other systems and components 01.02.04.08 Removal of contamination from areas outside buildings 01.02.04.09 Final radioactivity survey for release of buildings 01.02.05.01 Waste management system 01.02.05.08 Management of decommissioning intermediate-level waste/GTCC 01.02.05.09 Management of decommissioning low-level waste 01.02.05.12 Management of decommissioning exempt waste and materials 01.02.05.13 Management of decommissioning waste and materials generated outside controlled areas 01.02.06.01 Site security and surveillance 01.02.06.02 Site operation and maintenance 01.02.06.03 Operation of support systems 01.02.06.04 Radiation and environmental safety monitoring 01.02.07.02 Dismantling of systems and building components outside the controlled area 01.02.07.03 Demolition of buildings and structures 01.02.07.04 Final cleanup, landscaping and refurbishment 01.02.07.05 Final radioactivity survey of site 01.02.08.01 Mobilization and preparatory work 01.02.08.02 Project management 01.02.08.03 Support services 01.02.08.04 Health and safety 01.02.10.01 Removal of fuel or nuclear material from facility to be decommissioned 01.02.10.02 Dedicated storage for fuel and/or nuclear material 01.02.10.03 Decommissioning of the ISFSI 01.02.11.01 Owner costs 01.02.11.02 Taxes 01.02.11.03 Insurances 96

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 5 DECOMMISSIONING SCHEDULE AND FUNDING 5.1 Decommissioning Schedule The schedule and cost estimate to decommission IP1, 2 & 3 is based on the DECON method. The detailed decommissioning project schedule, developed in Primavera P6, is used as the foundation for developing the decommissioning cost estimate and risk model.

The schedule baseline is a detailed CPM schedule model built with input from the key decommissioning subcontractors and subject matter experts.

The major steps in the decommissioning project schedule development methodology include the following:

1. Identify and define the major decommissioning project milestones

2. Develop a decommissioning project MSS in Oracle Primavera P6, capturing the relationship and sequencing of the key project milestones

3. Prepare milestone-focused, activity-based schedule fragnets by WBS, comprised of detailed activities, durations, sequencing, and constraints in alignment with the technical solutions and MSS

4. Capture all the activity-based schedule fragnets into an integrated, logically linked master decommissioning project schedule model in Oracle Primavera P6

5. Verify and validate the integrated master decommissioning project schedule model in Oracle P6 against the MSS. Confirm the schedule integrity/reasonableness of the overall project primary/secondary critical paths as well as for each MSS milestone Figure 5-1 provides the Master Summary Schedule, which is based on the assumption that the IP1, 2 & 3 licenses are transferred to HDI by May 31, 2021.

As described in Subsection 3.2, HDIs spent fuel management is based in general upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel to a federal facility (not necessarily a final repository), and 2) expectations for spent fuel receipt by the DOE beginning in 2031. All spent fuel is expected to be removed from the site by 2061.

5.2 Decommissioning Funds 10 CFR 50.82(a)(6)(iii) states that, "Licensees shall not perform any decommissioning activities," as defined in 10 CFR 50.2 that, "Result in there no longer being reasonable assurance that adequate funds will be available for decommissioning." HDI does not intend to perform any decommissioning activities that would jeopardize the availability of adequate funds for the completion of decommissioning.

Tables 5-1a, 5-1b and 5-1c show the amount of decommissioning funds expected to be available at the time the licenses are transferred, the accumulation of additional funds, and the expenditure of the funds for IP1, IP2 and IP3 respectively.

Prior to the license transfers, ENIP2 and ENIP are expected to seek reimbursement from the NDTs to pay for accrued but un-reimbursed decommissioning expenses, including 97

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate decommissioning planning and other decommissioning activities. The 2021 beginning of year (BOY) Trust Fund Values (analysis starting trust fund balances) in Tables 5-1a, 5-1b and 5-1c are the fund amounts expected to be in the NDT funds for IP1, 2 & 3 at the date of sale of the units to Holtec (targeted for May 31, 2021). These values are exclusive of funds expected to be withdrawn from the NDT by ENIP2 and ENIP3 for reimbursable expenses incurred prior to transaction closing.

98

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Figure 5-1 Master Summary Schedule 99

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 5-1a IP1 Decommissioning Funding Cash Flow Analysis IPEC Unit 1 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.54 (bb) 50.75 License Spent Fuel Site Beginning of Year Ending Termination Management Restoration Year Trust Fund Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Balance1 Withdraw Earnings 3 Balance 29,941 2,676 32,617 533,532 -32,617 5,844 506,759 2021 27,637 4,546 32,183 506,759 -32,183 9,492 484,068 2022 52,768 2,516 2,113 57,397 484,068 -57,397 8,533 435,204 2023 65,344 1,654 4,550 71,547 435,204 -71,547 7,273 370,930 2024 22,059 1,708 5,224 28,992 370,930 -28,992 6,839 348,777 2025 25,850 1,660 5,076 32,586 348,777 -32,586 6,324 322,515 2026 34,183 1,582 4,850 40,615 322,515 -40,615 5,638 287,538 2027 30,731 1,613 4,943 37,287 287,538 -37,287 5,005 255,256 2028 22,503 1,702 5,204 29,410 255,256 -29,410 4,517 230,363 2029 50,400 1,523 1,804 53,727 230,363 -53,727 3,533 180,169 2030 75,149 1,465 1,498 78,112 180,169 -78,112 2,041 104,097 2031 37,915 1,569 5,460 44,944 104,097 -44,944 1,183 60,336 2032 2,422 4,209 6,631 60,336 -6,631 1,074 54,779 2033 2,870 2,870 54,779 -2,870 1,038 52,948 2034 2,870 2,870 52,948 -2,870 1,002 51,079 2035 2,875 2,875 51,079 -2,875 964 49,169 2036 2,870 2,870 49,169 -2,870 926 47,225 2037 2,870 2,870 47,225 -2,870 887 45,242 2038 2,870 2,870 45,242 -2,870 847 43,220 2039 2,875 2,875 43,220 -2,875 807 41,152 2040 2,870 2,870 41,152 -2,870 766 39,048 2041 2,870 2,870 39,048 -2,870 724 36,902 2042 2,870 2,870 36,902 -2,870 681 34,713 2043 2,875 2,875 34,713 -2,875 637 32,474 2044 2,870 2,870 32,474 -2,870 592 30,197 2045 5,162 5,162 30,197 -5,162 501 25,536 2046 145 4,343 4,488 25,536 -4,488 421 21,468 2047 386 386 21,468 -386 422 21,503 2048 386 386 21,503 -386 422 21,539 2049 386 386 21,539 -386 423 21,576 2050 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 1 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $59.3M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

100

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate IPEC Unit 1 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.54 (bb) 50.75 License Spent Fuel Site Beginning of Year Ending Termination Management Restoration Year Trust Fund Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Balance1 Withdraw Earnings 3 Balance 386 386 21,576 -386 424 21,613 2051 386 386 21,613 -386 425 21,651 2052 386 386 21,651 -386 425 21,690 2053 386 386 21,690 -386 426 21,730 2054 714 714 21,730 -714 420 21,436 2055 715 715 21,436 -715 414 21,136 2056 715 715 21,136 -715 408 20,829 2057 715 715 20,829 -715 402 20,516 2058 715 715 20,516 -715 396 20,197 2059 715 715 20,197 -715 390 19,871 2060 715 715 19,871 -715 383 19,539 2061 257 66 323 19,539 -323 384 19,601 2062 19,601 392 19,993 2063 Total 4 485,015 72,381 40,788 598,184 -598,184 84,645 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 1 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $59.3M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

4 Columns may not add due to rounding.

101

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 5-1b IP2 Decommissioning Funding Cash Flow Analysis IPEC Unit 2 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.75 50.54 (bb) Beginning of License Spent Fuel Site Year Trust Year Ending Termination Management Restoration Fund Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Balance1 Withdraw Earnings 3 Balance 2021 42,737 27,287 70,024 654,078 -70,024 6,814 590,868 2022 69,990 34,019 1,825 105,834 590,868 -105,834 9,701 494,735 2023 67,919 11,439 6,137 85,496 494,735 -85,496 8,185 417,424 2024 33,157 4,337 6,618 44,113 417,424 -44,113 7,466 380,777 2025 36,136 1,608 6,250 43,993 380,777 -43,993 6,736 343,520 2026 32,379 1,636 6,358 40,373 343,520 -40,373 6,063 309,210 2027 32,796 1,635 5,266 39,697 309,210 -39,697 5,390 274,903 2028 51,731 1,548 1,884 55,164 274,903 -55,164 4,395 224,134 2029 50,554 1,553 1,853 53,960 224,134 -53,960 3,403 173,577 2030 8,592 6,857 15,449 173,577 -15,449 3,163 161,291 2031 8,592 6,857 15,449 161,291 -15,449 2,917 148,758 2032 5,994 5,905 6,747 18,646 148,758 -18,646 2,602 132,714 2033 1,922 7,701 9,623 132,714 -9,623 2,462 125,553 2034 5,990 5,990 125,553 -5,990 2,391 121,954 2035 6,000 6,000 121,954 -6,000 2,319 118,274 2036 6,014 6,014 118,274 -6,014 2,245 114,505 2037 6,000 6,000 114,505 -6,000 2,170 110,675 2038 5,990 5,990 110,675 -5,990 2,094 106,779 2039 6,000 6,000 106,779 -6,000 2,016 102,795 2040 6,005 6,005 102,795 -6,005 1,936 98,725 2041 6,000 6,000 98,725 -6,000 1,855 94,580 2042 6,000 6,000 94,580 -6,000 1,772 90,352 2043 6,000 6,000 90,352 -6,000 1,687 86,040 2044 6,005 6,005 86,040 -6,005 1,601 81,636 2045 5,990 5,990 81,636 -5,990 1,513 77,158 2046 3,152 3,152 77,158 -3,152 1,480 75,486 2047 145 749 894 75,486 -894 1,492 76,084 2048 386 386 76,084 -386 1,514 77,212 2049 386 386 77,212 -386 1,537 78,362 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 2 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $15.15M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

102

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate IPEC Unit 2 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.75 50.54 (bb) Beginning of License Spent Fuel Site Year Trust Year Ending Termination Management Restoration Fund Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Balance1 Withdraw Earnings 3 Balance 2050 386 386 78,362 -386 1,560 79,535 2051 386 386 79,535 -386 1,583 80,731 2052 386 386 80,731 -386 1,607 81,952 2053 386 386 81,952 -386 1,631 83,196 2054 386 386 83,196 -386 1,656 84,466 2055 3,274 3,274 84,466 -3,274 1,624 82,816 2056 3,285 3,285 82,816 -3,285 1,591 81,121 2057 3,285 3,285 81,121 -3,285 1,557 79,393 2058 3,285 3,285 79,393 -3,285 1,522 77,629 2059 3,285 3,285 77,629 -3,285 1,487 75,831 2060 3,285 3,285 75,831 -3,285 1,451 73,996 2061 3,285 3,285 73,996 -3,285 1,414 72,125 2062 1,121 1,149 2,270 72,125 -2,270 1,397 71,252 2063 71,252 1,425 72,677 Total 4 469,456 188,278 44,088 701,822 -701,822 120,420 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 2 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $15.15M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

4 Columns may not add due to rounding.

103

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 5-1c IP3 Decommissioning Funding Cash Flow Analysis IPEC Unit 3 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.54 (bb) 50.75 License Spent Fuel Site Beginning of Year Ending Termination Management Restoration Year Trust Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Fund Balance1 Withdraw Earnings3 Balance 2021 63,590 46,741 442 110,773 916,100 -110,773 9,395 814,722 2022 103,657 16,745 3,833 124,235 814,722 -124,235 13,810 704,297 2023 68,921 35,203 3,616 107,740 704,297 -107,740 11,931 608,488 2024 51,552 30,858 3,514 85,924 608,488 -85,924 10,451 533,016 2025 49,120 1,421 3,630 54,171 533,016 -54,171 9,577 488,421 2026 52,082 1,407 3,594 57,084 488,421 -57,084 8,627 439,964 2027 42,955 1,451 3,714 48,119 439,964 -48,119 7,837 399,682 2028 26,334 1,638 4,192 32,164 399,682 -32,164 7,350 374,868 2029 26,318 1,638 4,185 32,142 374,868 -32,142 6,855 349,581 2030 26,314 1,638 4,186 32,138 349,581 -32,138 6,349 323,792 2031 26,314 1,638 4,186 32,138 323,792 -32,138 5,833 297,487 2032 22,366 1,561 7,751 31,679 297,487 -31,679 5,316 271,124 2033 2,581 4,763 7,343 271,124 -7,343 5,276 269,057 2034 3,607 3,607 269,057 -3,607 5,309 270,759 2035 3,607 3,607 270,759 -3,607 5,343 272,494 2036 3,612 3,612 272,494 -3,612 5,378 274,260 2037 3,607 3,607 274,260 -3,607 5,413 276,066 2038 3,607 3,607 276,066 -3,607 5,449 277,907 2039 3,607 3,607 277,907 -3,607 5,486 279,786 2040 3,612 3,612 279,786 -3,612 5,523 281,697 2041 3,607 3,607 281,697 -3,607 5,562 283,652 2042 3,607 3,607 283,652 -3,607 5,601 285,646 2043 3,607 3,607 285,646 -3,607 5,641 287,679 2044 3,612 3,612 287,679 -3,612 5,681 289,748 2045 3,607 3,607 289,748 -3,607 5,723 291,864 2046 4,433 4,433 291,864 -4,433 5,749 293,179 2047 7,453 7,453 293,179 -7,453 5,715 291,441 2048 11,953 11,953 291,441 -11,953 5,590 285,078 2049 11,917 11,917 285,078 -11,917 5,463 278,624 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 3 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $15.15M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

104

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate IPEC Unit 3 - DECON Method Annual Cash Flow in Thousands of 2019 Dollars No DOE Reimbursement of Spent Fuel Management Costs 50.54 (bb) 50.75 License Spent Fuel Site Beginning of Year Ending Termination Management Restoration Year Trust Trust Fund Trust Fund Year Cost 2 Cost 2 Cost 2 Total Cost 2 Fund Balance1 Withdraw Earnings3 Balance 2050 11,927 11,927 278,624 -11,927 5,334 272,030 2051 11,917 11,917 272,030 -11,917 5,202 265,315 2052 11,953 11,953 265,315 -11,953 5,067 258,429 2053 11,927 11,927 258,429 -11,927 4,930 251,432 2054 11,927 11,927 251,432 -11,927 4,790 244,294 2055 2,888 11,917 14,805 244,294 -14,805 4,590 234,079 2056 2,899 11,943 14,842 234,079 -14,842 4,385 223,622 2057 2,899 11,927 14,826 223,622 -14,826 4,176 212,972 2058 2,899 11,927 14,826 212,972 -14,826 3,963 202,108 2059 2,899 11,927 14,826 202,108 -14,826 3,746 191,028 2060 2,899 11,943 14,842 191,028 -14,842 3,524 179,709 2061 2,899 11,912 14,811 179,709 -14,811 3,298 168,196 2062 782 2,459 996 4,238 168,196 -4,238 3,279 167,237 2063 167,237 3,345 170,582 Total 4 583,168 371,370 47,840 1,002,378 -1,002,378 256,860 1

The 2021 Beginning of Year NDT balance reflects the fund value post-closure of the sale transition. The value used is based on the October 31, 2019 Unit 3 NDT fund balance and includes deductions for estimated ENOI and HDI pre-closure costs of approximately $15.15M.

2 The 2021 costs include HDI estimated 2021 post-closure costs.

3 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).

4 Columns may not add due to rounding 105

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 6 CONCLUSION The submittal of this DECON DCE complies with NRC requirements set forth in 10 CFR 50.82(a)(8)(iii), which requires the licensee to submit a site-specific Decommissioning Cost Estimate within 2 years of permanent cessation of operation. CDI prepared this cost estimate and schedule on behalf of HDI using several sources, including information compiled during a due diligence period and the input and professional judgment of experienced specialty subcontractors and SMEs.

The estimate is based on regulatory requirements, site conditions, baseline assumptions, low-level radioactive waste disposal standards, high-level radioactive waste management options and site restoration requirements. The cost to decommission the site, safeguard the spent fuel until it can be transferred to the DOE and restore the affected area of the site is estimated to be $598 million for IP1, $702 million for IP2 and $1,002 million for IP3. The majority of these costs are associated with decommissioning and license termination. A significant amount of the remaining cost is associated with spent fuel management since the fuel will be removed from the SFPs and remain in storage at the ISFSI until acceptance by DOE. A relatively small amount of the decommissioning cost is for the demolition of uncontaminated structures and restoration of the site. The summary of the costs estimated for License Termination, Spent Fuel Management and Site Restoration activities for each unit are presented in Table 6-1a, 6-1b and 6-1c.

The largest contributors to the overall decommissioning costs are removal of contaminated components and buildings, disposal costs, and program management costs. Removal costs reflect the labor-intensive nature of the decommissioning process, as well as the management controls required to ensure a safe and successful program. The disposal of low-level radioactive waste that is generated from dismantling activities makes up the bulk of the disposal cost category. The magnitude of the program management costs is a function of both the size of the organization needed to manage the decommissioning, as well as the duration.

In accordance with 10 CFR 50.82(a)(8)(v), decommissioning funding assurance will be reviewed and reported to the NRC annually until residual radioactivity has been reduced to a level that permits termination of the licenses. The site-specific DCE adjusted for inflation, in accordance with applicable regulatory requirements, will be used to demonstrate funding assurance. In addition, actual radiological and spent fuel management expenses will be included in the annual report in accordance with applicable regulatory requirements.

If the funding assurance demonstration shows that the NDTs are not sufficient, then an alternate funding mechanism allowed by 10 CFR 50.75(e) and the guidance provided in Regulatory Guide 1.159 (Reference 13) will be put in place.

106

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 6-1a IP1 Estimated Decommissioning Cost (thousands of 2019 dollars)

License Site WBS_Code WBS_Name Spent Fuel Total Termination Restoration 01.02 IPEC Unit 1 485,015 72,381 40,788 598,184 01.02.01 Pre-decommissioning actions 8,808 8,808 01.02.01.02.01 Detailed facility characterization 8,808 8,808 01.02.04 Dismantling activities within the controlled area 68,239 68,239 Procurement of equipment for decontamination and 01.02.04.01 dismantling 5,900 5,900 01.02.04.01.01 Procurement of general site-dismantling equipment 983 983 Procurement of special tools for dismantling the 01.02.04.01.03 reactor systems 4,917 4,917 Dismantling of main process systems, structures and 01.02.04.05 components 62,290 62,290 01.02.04.05.01 Dismantling of reactor internals 38,350 38,350 01.02.04.06 Dismantling of other systems and components 49 49 01.02.05 Waste processing, storage and disposal 200,014 11,971 211,986 01.02.05.01 Waste management system 3,546 3,546 Management of decommissioning intermediate-01.02.05.08 level waste/GTCC 1,446 1,446 01.02.05.08.07 Containers 1,446 1,446 01.02.05.09 Management of decommissioning low-level waste 29,066 29,066 Management of decommissioning exempt waste 01.02.05.12 and materials 165,957 165,957 Management of decommissioning waste and 01.02.05.13 materials generated outside controlled areas 11,971 11,971 01.02.06 Site infrastructure and operation 35,482 35,482 01.02.06.01 Site security and surveillance 3,758 3,758 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 516 516 01.02.06.01.04 Deployment of officers forces 3,241 3,241 01.02.06.02 Site operation and maintenance 4,949 4,949 Inspection and maintenance of buildings and 01.02.06.02.01 systems 4,949 4,949 01.02.06.02.02 Site upkeep activities 01.02.06.03 Operation of support systems 15,216 15,216 01.02.06.03.01 Electricity supply systems 11,914 11,914 01.02.06.03.02 Ventilation systems 2,997 2,997 01.02.06.03.07 Other systems 305 305 01.02.06.04 Radiation and environmental safety monitoring 11,560 11,560 01.02.06.04.02 Radiation protection and monitoring 10,873 10,873 Environmental protection and radiation 01.02.06.04.03 environmental monitoring 687 687 Conventional dismantling, demolition and site 01.02.07 restoration 63,437 22,402 85,839 01.02.07.03 Demolition of buildings and structures 63,437 22,402 85,839 Demolition of buildings and structures from the 01.02.07.03.01 formerly controlled area 63,437 63,437 Demolition of buildings and structures outside the 01.02.07.03.02 controlled area 22,402 22,402 01.02.07.03.02.10 Phase I Demolition 4,278 4,278 01.02.08 Project management, engineering and support 50,362 4,704 4,151 59,216 01.02.08.02 Project management 18,649 1,821 1,160 21,629 01.02.08.02.01 Core management group 9,952 1,030 681 11,663 Project implementation planning, detailed ongoing 01.02.08.02.02 planning 3,590 308 137 4,034 01.02.08.02.03 Scheduling and cost control 980 99 70 1,149 01.02.08.02.04 Safety and environmental analysis, ongoing studies 01.02.08.02.05 Quality assurance and quality surveillance 1,082 131 6 1,219 107

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate License Site WBS_Code WBS_Name Spent Fuel Total Termination Restoration 01.02.08.02.06 General administration and accounting 1,797 138 139 2,074 01.02.08.02.07 Public relations and stakeholders involvement 1,248 114 128 1,490 01.02.08.03 Support services 30,505 2,765 2,888 36,159 01.02.08.03.01 Engineering support 3,143 261 243 3,647 01.02.08.03.02 Information system and computer support 244 42 8 293 01.02.08.03.03 Waste management support 41 4 45 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 548 50 56 654 01.02.08.03.05 Personnel management and training 2,063 161 170 2,395 01.02.08.03.06 Documentation and records control 01.02.08.03.07 Procurement, warehousing, and materials handling 314 44 10 368 01.02.08.03.08 Housing, office equipment, support services 24,153 2,203 2,401 28,757 01.02.08.04 Health and safety 1,208 118 102 1,428 01.02.08.04.01 Health physics 01.02.08.04.02 Industrial safety 1,208 118 102 1,428 01.02.08.05 Demobilization - NOT USED 01.02.10 Fuel and nuclear material 8,112 66,066 66 74,244 01.02.10.02 Dedicated ISFSI for fuel and/or nuclear material 2,300 66,066 68,366 01.02.10.02.01 Construction of ISFSI 5,906 5,906 01.02.10.02.02 Operation of ISFSI 56,996 56,996 Transfer of fuel and/or nuclear material away from 01.02.10.02.03 the ISFSI 2,300 3,165 5,464 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.01 the ISFSI - License Termination costs 2,300 2,300 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.02 the ISFSI - Spent Fuel Management costs 3,165 3,165 01.02.10.03 Decommissioning of ISFSI 5,812 66 5,878 01.02.10.03.01 Decommissioning of ISFSI 5,812 48 5,860 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.01 ISFSI - License Termination costs 5,812 5,812 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.03 ISFSI - Site Restoration costs 48 48 01.02.10.03.02 Management of waste 18 18 Decommissioning of ISFSI - Management of waste -

01.02.10.03.02.03 Site Restoration costs 18 18 01.02.11 Miscellaneous expenditures 50,562 1,611 2,198 54,371 01.02.11.01 Owner costs 32,884 32,884 01.02.11.01.03 Payments (fees) to authorities 5,050 5,050 01.02.11.01.04 Specific external services and payments 01.02.11.02 Taxes 14,221 1,295 1,844 17,360 01.02.11.03 Insurances 3,457 316 354 4,127 01.02.11.03.01 Nuclear related insurances 2,872 262 294 3,428 01.02.11.03.02 Other insurances 585 53 60 699 108

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 6-1b IP2 Estimated Decommissioning Cost (thousands of 2019 dollars)

License Site WBS_Code WBS_Name Termination Spent Fuel Restoration Total 01.02 IPEC Unit 2 469,456 188,278 44,088 701,822 01.02.01 Pre-decommissioning actions 8,808 8,808 01.02.01.02.01 Detailed facility characterization 8,808 8,808 01.02.02 Facility shutdown activities 60,197 60,197 01.02.02.01 Plant shutdown and inspection 60,197 60,197 Management of fuel, fissile and other nuclear 01.02.02.01.04 materials 60,197 60,197 01.02.04 Dismantling activities within the controlled area 72,227 72,227 Procurement of equipment for decontamination and 01.02.04.01 dismantling 5,900 5,900 01.02.04.01.01 Procurement of general site-dismantling equipment 983 983 Procurement of special tools for dismantling the 01.02.04.01.03 reactor systems 4,917 4,917 Dismantling of main process systems, structures and 01.02.04.05 components 66,278 66,278 01.02.04.05.01 Dismantling of reactor internals 38,350 38,350 01.02.04.06 Dismantling of other systems and components 49 49 01.02.05 Waste processing, storage and disposal 130,262 11,988 142,249 01.02.05.01 Waste management system 2,372 2,372 Management of decommissioning intermediate-01.02.05.08 level waste/GTCC 8,850 8,850 01.02.05.08.07 Containers 8,850 8,850 01.02.05.09 Management of decommissioning low-level waste 13,979 13,979 Management of decommissioning exempt waste 01.02.05.12 and materials 105,060 105,060 Management of decommissioning waste and 01.02.05.13 materials generated outside controlled areas 11,988 11,988 01.02.06 Site infrastructure and operation 53,622 53,622 01.02.06.01 Site security and surveillance 18,976 18,976 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 516 516 01.02.06.01.04 Deployment of officers forces 18,460 18,460 01.02.06.02 Site operation and maintenance 6,458 6,458 Inspection and maintenance of buildings and 01.02.06.02.01 systems 6,458 6,458 01.02.06.03 Operation of support systems 16,469 16,469 01.02.06.03.01 Electricity supply systems 11,914 11,914 01.02.06.03.02 Ventilation systems 4,074 4,074 01.02.06.03.07 Other systems 482 482 01.02.06.04 Radiation and environmental safety monitoring 11,719 11,719 01.02.06.04.02 Radiation protection and monitoring 10,401 10,401 Environmental protection and radiation 01.02.06.04.03 environmental monitoring 1,318 1,318 Conventional dismantling, demolition and site 01.02.07 restoration 63,437 22,402 85,839 01.02.07.03 Demolition of buildings and structures 63,437 22,402 85,839 Demolition of buildings and structures from the 01.02.07.03.01 formerly controlled area 63,437 63,437 Demolition of buildings and structures outside the 01.02.07.03.02 controlled area 22,402 22,402 01.02.07.03.02.10 Phase I Demolition 4,278 4,278 01.02.08 Project management, engineering and support 47,506 15,484 5,505 68,496 01.02.08.02 Project management 19,741 6,565 2,104 28,410 01.02.08.02.01 Core management group 12,901 3,884 1,571 18,356 109

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate License Site WBS_Code WBS_Name Termination Spent Fuel Restoration Total Project implementation planning, detailed ongoing 01.02.08.02.02 planning 2,189 1,229 75 3,492 01.02.08.02.03 Scheduling and cost control 1,554 492 150 2,196 01.02.08.02.04 Safety and environmental analysis, ongoing studies 01.02.08.02.05 Quality assurance and quality surveillance 1,021 348 76 1,446 01.02.08.02.06 General administration and accounting 1,041 294 96 1,431 01.02.08.02.07 Public relations and stakeholders involvement 1,034 319 137 1,490 01.02.08.03 Support services 26,521 8,443 3,285 38,249 01.02.08.03.01 Engineering support 3,291 958 335 4,583 01.02.08.03.02 Information system and computer support 172 99 22 293 01.02.08.03.03 Waste management support 252 139 4 394 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 455 139 59 654 01.02.08.03.05 Personnel management and training 1,878 478 189 2,545 01.02.08.03.07 Procurement, warehousing, and materials handling 569 350 103 1,023 01.02.08.03.08 Housing, office equipment, support services 19,904 6,280 2,573 28,757 01.02.08.04 Health and safety 1,245 476 116 1,837 01.02.08.04.02 Industrial safety 1,245 476 116 1,837 01.02.10 Fuel and nuclear material 26,958 102,036 1,149 130,142 01.02.10.02 Dedicated ISFSI for fuel and/or nuclear material 20,281 102,036 122,317 01.02.10.02.02 Operation of ISFSI 62,792 62,792 Transfer of fuel and/or nuclear material away from 01.02.10.02.03 the ISFSI 20,281 39,244 59,525 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.01 the ISFSI - License Termination costs 20,281 20,281 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.02 the ISFSI - Spent Fuel Management costs 39,244 39,244 01.02.10.03 Decommissioning of ISFSI 6,676 1,149 7,826 01.02.10.03.01 Decommissioning of ISFSI 6,676 1,132 7,808 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.01 ISFSI - License Termination costs 6,676 6,676 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.03 ISFSI - Site Restoration costs 1,132 1,132 01.02.10.03.02 Management of waste 18 18 Decommissioning of ISFSI - Management of waste -

01.02.10.03.02.03 Site Restoration costs 18 18 01.02.11 Miscellaneous expenditures 66,637 10,561 3,043 80,241 01.02.11.01 Owner costs 36,218 36,218 01.02.11.01.03 Payments (fees) to authorities 8,385 8,385 01.02.11.01.04 Specific external services and payments 01.02.11.02 Taxes 27,555 9,678 2,663 39,897 01.02.11.02.02 Local, community, federal taxes 15,542 6,153 842 22,537 01.02.11.03 Insurances 2,865 883 380 4,127 01.02.11.03.01 Nuclear related insurances 2,380 733 315 3,428 01.02.11.03.02 Other insurances 485 149 64 699 110

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table 6-1c IP3 Estimated Decommissioning Cost (thousands of 2019 dollars)

License Site WBS_Code WBS_Name Termination Spent Fuel Restoration Total 01.02 IPEC Unit 3 583,168 371,370 47,840 1,002,378 01.02.01 Pre-decommissioning actions 8,808 8,808 01.02.01.02.01 Detailed facility characterization 8,808 8,808 01.02.02 Facility shutdown activities 106,199 106,199 01.02.02.01 Plant shutdown and inspection 106,199 106,199 Management of fuel, fissile and other nuclear 01.02.02.01.04 materials 106,199 106,199 01.02.04 Dismantling activities within the controlled area 79,627 79,627 Procurement of equipment for decontamination 01.02.04.01 and dismantling 5,900 5,900 01.02.04.01.01 Procurement of general site-dismantling equipment 983 983 Procurement of special tools for dismantling the 01.02.04.01.03 reactor systems 4,917 4,917 Dismantling of main process systems, structures and 01.02.04.05 components 73,678 73,678 01.02.04.05.01 Dismantling of reactor internals 38,350 38,350 01.02.04.06 Dismantling of other systems and components 49 49 01.02.05 Waste processing, storage and disposal 165,494 11,964 177,459 01.02.05.01 Waste management system 2,179 2,179 Management of decommissioning intermediate-01.02.05.08 level waste/GTCC 8,880 8,880 01.02.05.08.07 Containers 8,880 8,880 01.02.05.09 Management of decommissioning low-level waste 15,176 15,176 Management of decommissioning exempt waste 01.02.05.12 and materials 139,260 139,260 Management of decommissioning waste and 01.02.05.13 materials generated outside controlled areas 11,964 11,964 01.02.06 Site infrastructure and operation 71,261 71,261 01.02.06.01 Site security and surveillance 35,616 35,616 Security fencing and protection of remaining 01.02.06.01.03 entrances against trespassing 516 516 01.02.06.01.04 Deployment of officers forces 35,100 35,100 01.02.06.02 Site operation and maintenance 8,221 8,221 Inspection and maintenance of buildings and 01.02.06.02.01 systems 8,221 8,221 01.02.06.03 Operation of support systems 14,341 14,341 01.02.06.03.01 Electricity supply systems 11,914 11,914 01.02.06.03.02 Ventilation systems 2,033 2,033 01.02.06.03.07 Other systems 395 395 01.02.06.04 Radiation and environmental safety monitoring 13,083 13,083 01.02.06.04.02 Radiation protection and monitoring 11,559 11,559 Environmental protection and radiation 01.02.06.04.03 environmental monitoring 1,524 1,524 Conventional dismantling, demolition and site 01.02.07 restoration 89,193 24,668 113,861 01.02.07.03 Demolition of buildings and structures 71,366 24,668 96,034 Demolition of buildings and structures from the 01.02.07.03.01 formerly controlled area 71,366 71,366 Demolition of buildings and structures outside the 01.02.07.03.02 controlled area 24,668 24,668 01.02.07.03.02.10 Phase I Demolition 4,278 4,278 01.02.07.05 Final radioactivity survey of site 17,827 17,827 01.02.07.05.01 Final survey 17,827 17,827 01.02.08 Project management, engineering and support 67,454 14,193 6,991 88,637 01.02.08.02 Project management 37,377 7,740 3,750 48,867 01.02.08.02.01 Core management group 29,799 5,248 3,198 38,245 111

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate License Site WBS_Code WBS_Name Termination Spent Fuel Restoration Total Project implementation planning, detailed ongoing 01.02.08.02.02 planning 2,502 1,272 103 3,878 01.02.08.02.03 Scheduling and cost control 1,314 399 106 1,819 01.02.08.02.05 Quality assurance and quality surveillance 1,263 327 90 1,680 01.02.08.02.06 General administration and accounting 1,357 278 119 1,755 01.02.08.02.07 Public relations and stakeholders involvement 1,141 216 133 1,490 01.02.08.03 Support services 28,138 6,071 3,024 37,234 01.02.08.03.01 Engineering support 2,132 578 147 2,856 01.02.08.03.02 Information system and computer support 390 160 15 565 01.02.08.03.03 Waste management support 283 104 7 394 Decommissioning support including chemistry, 01.02.08.03.04 decontamination 1,003 188 117 1,307 01.02.08.03.05 Personnel management and training 1,833 390 173 2,396 01.02.08.03.06 Documentation and records control 01.02.08.03.07 Procurement, warehousing, and materials handling 622 278 58 958 01.02.08.03.08 Housing, office equipment, support services 21,876 4,374 2,507 28,757 01.02.08.04 Health and safety 1,939 382 216 2,536 01.02.08.04.02 Industrial safety 1,939 382 216 2,536 01.02.10 Fuel and nuclear material 21,063 238,086 996 260,146 01.02.10.02 Dedicated ISFSI for fuel and/or nuclear material 20,281 235,626 255,908 01.02.10.02.01 Construction of ISFSI 01.02.10.02.02 Operation of ISFSI 198,915 198,915 Transfer of fuel and/or nuclear material away from 01.02.10.02.03 the ISFSI 20,281 36,712 56,993 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.01 the ISFSI - License Termination costs 20,281 20,281 Transfer of fuel and/or nuclear material away from 01.02.10.02.03.02 the ISFSI - Spent Fuel Management costs 36,712 36,712 01.02.10.03 Decommissioning of ISFSI 782 2,460 996 4,239 01.02.10.03.01 Decommissioning of ISFSI 782 2,442 979 4,203 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.01 ISFSI - License Termination costs 782 782 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.02 ISFSI - Spent Fuel Management costs 2,442 2,442 Decommissioning of ISFSI - Decommissioning of 01.02.10.03.01.03 ISFSI - Site Restoration costs 979 979 01.02.10.03.02 Management of waste 18 18 35 Decommissioning of ISFSI - Management of waste -

01.02.10.03.02.02 Spent Fuel Management costs 18 18 Decommissioning of ISFSI - Management of waste -

01.02.10.03.02.03 Site Restoration costs 18 18 01.02.11 Miscellaneous expenditures 80,268 12,891 3,221 96,380 01.02.11.01 Owner costs 36,218 36,218 01.02.11.01.03 Payments (fees) to authorities 8,385 8,385 01.02.11.02 Taxes 40,891 12,293 2,852 56,036 01.02.11.02.02 Local, community, federal taxes 27,190 10,509 977 38,676 01.02.11.03 Insurances 3,160 598 369 4,127 01.02.11.03.01 Nuclear related insurances 2,625 497 307 3,428 01.02.11.03.02 Other insurances 535 101 63 699 112

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate 7 REFERENCES

1. Letter, US NRC to Con Edison, Order to Authorize Decommissioning and Amendment No. 45 to License No. DPR-5 for Indian Point Unit No. 1, January 31, 1996

2. Letter, ENOI to US NRC, Notification of Permanent Cessation of Power Operations Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64, dated February 8, 2017

3. Letter, ENOI to US NRC, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments, Indian Point Nuclear Generating Units 1, 2 and 3, November 21, 2019.

4. Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors.

5. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors," (GEIS).

6. NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Reactors.

7. NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized-Water Reactor Power Station, November 1995.

8. International Structure for Decommissioning Costing (ISDC) of Nuclear Installations, ISBN 978-92-64-99173-6, Joint NEA/EC/IAEA Publication, 2012.

9. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual.

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

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

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

13. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors.

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Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Appendix A ISFSI Decommissioning Cost Estimate 114

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table A-1 IP1 ISFSI Decommissioning Cost Estimate Activity Removal Packaging Transport LLRW Other Total Costs Costs Costs Costs Disposal Costs Costs Decommissioning Contractor Planning (characterization, specs and procedures) 17,700 17,700 Decontamination (Overpack disposition) 0 License Termination (radiological Surveys) 42,344 42,344 Subtotal 60,044 60,044 Supporting Costs NRC and NRC Contractor Costs 3,638 3,638 Site O&M 0 Insurance 0 NRC Regulatory Fees 224,706 224,706 Subtotal 228,345 228,345 Total w/25% Contingency 288,389 288,389 115

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table A-2 IP2 ISFSI Decommissioning Cost Estimate LLRW Removal Packaging Transport Other Activity Disposal Total Costs Costs Costs Costs Costs Costs Decommissioning Contractor Planning (characterization, specs and procedures) 17,700 17,700 Decontamination (Overpack disposition) 864,000 19,492 171,301 340,766 1,395,559 License Termination (radiological Surveys) 42,344 42,344 Subtotal 864,000 19,492 171,301 340,766 48,244 1,455,604 Supporting Costs NRC and NRC Contractor Costs 3,638 3,638 Site O&M 0 Insurance 0 NRC Regulatory Fees 224,706 224,706 Subtotal 228,345 228,345 Total w/25% Contingency 864,000 19,492 171,301 340,766 276,589 1,683,948 116

Indian Point Energy Center Site-Specific Decommissioning Cost Estimate Table A-3 IP3 ISFSI Decommissioning Cost Estimate LLRW Removal Packaging Transport Other Activity Disposal Total Costs Costs Costs Costs Costs Costs Decommissioning Contractor Planning (characterization, specs and procedures) 35,400 35,400 Decontamination (Overpack disposition) 736,000 13,924 122,360 290,476 1,162,760 License Termination (radiological Surveys) 42,344 42,344 Subtotal 736,000 13,924 122,360 290,476 77,744 1,240,505 Supporting Costs NRC and NRC Contractor Costs 3,638 3,638 Site O&M 1,692,563 1,692,563 Insurance 538,748 538,748 NRC Regulatory Fees 211,048 211,048 Subtotal 2,445,997 2,445,997 Total w/25% Contingency 736,000 13,924 122,360 290,476 2,523,741 3,686,501 117