ML20086Q904

Units 1, 2, and 3; and Palisades - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

ML20086Q904
Person / Time
Site:	Palisades, Indian Point, Big Rock Point
Issue date:	03/26/2020
From:	Gaston R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CNRO2020-00002
Download: ML20086Q904 (28)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)(v)

CNRO2020-00002 March 26, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

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

Big Rock Point Nuclear Plant NRC Docket No. 50-155 License No. DPR-6 Indian Point Nuclear Generating Stations 1, 2, & 3 NRC Docket Nos. 50-3, 50-247, & 50-286 License Nos. DPR-5, DPR-26, & DPR-64 Palisades Nuclear Power Plant NRC Docket No. 50-255 License No. DPR-20 10 CFR 50.75(f)(1) requires each power reactor licensee to report to the NRC by March 31, 1999, and every two years thereafter with certain exceptions, on the status of its decommissioning funding for each reactor, or share of a reactor, that it owns. Additionally, any licensee for a plant that is within 5 years of the projected end of its operation, or where conditions have changed such that it will close within 5 years (before the end of its licensed life),

or that has already closed (before the end of its licensed life), or that is involved in a merger or an acquisition shall submit this report annually. 10 CFR 50.82(a)(8)(v) requires licensees of shutdown sites to report to the NRC annually, by March 31, on the status of decommissioning financial assurance for those sites. On behalf of Entergy Nuclear Indian Point 2, LLC (Indian Point 1 & 2), Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Palisades, LLC (Palisades and Big Rock Point), Entergy Nuclear Operations, Inc. (ENOI) hereby submits the information requested for power reactors operated by ENOI. The reports provided in Enclosures 1 through 8 for the licensed facilities addressed by this filing, were prepared in accordance with NUREG-1307 (Reference 1) and NRC Regulatory Issue Summary 2001-07 (Reference 2). The Minimum Funding Assurance calculation worksheets, (not required for this filing) derived from LIC-205, Rev. 4, are provided in Enclosure 9 for the convenience of the reviewer.

CNRO2020-00002 Page 2 of 3 The estimated minimum decommissioning fund values were determined using the NRCs methodology in NUREG-1307, Rev 17 (Reference 1).

The trust fund amounts reported for each facility in the responses to item 3 represent the market value of decommissioning trust funds as of December 31, 2019 net of any material current income tax liability on realized gains, interest, dividends and other income of the trusts. The trusts for the following plants had estimated balances on their 2019 tax liabilities, not reflected in the trust fund balances, as follows (in thousands):

Indian Point 1

$ 0 Indian Point 2

$ 0 Indian Point 3

$ 0 Palisades

$ 0 In accordance with guidance provided by the NRC Staff in April 2014 requests for additional information (Accession No. ML14120A273) that future 10 CFR 50.75(f) reports should clearly delineate estimated reactor and Independent Spent Fuel Storage Installation (ISFSI) decommissioning costs, the information in Enclosures 1, 2, 3, 5, and 7 includes line item 2 identifying the ISFSI decommissioning obligation, from the most recent 10 CFR 72.30 filing (escalated). This obligation is also accounted for in the Excess/Shortfall calculations for each plant in Enclosure 9 (or Enclosure 8 for Indian Point 1).

The aforementioned worksheets, using the December 31, 2019 trust fund balances and parent guarantee amount, indicate that all of the plants covered by this submittal met or exceeded the NRCs funding requirements. Accordingly, the licensees conclude that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the plants covered by this submittal.

There are no new commitments made in this letter. Should you have any questions or require additional information, please contact Phil Couture, Manager, Fleet Licensing Programs at 601-368-5102.

Respectfully, Ron Gaston RWG/ljs/chm

CNRO2020-00002 Page 3 of 3

Enclosures:

1.

ENOI Status of Decommissioning Funding - Indian Point 1

2.

ENOI Status of Decommissioning Funding - Indian Point 2

3.

ENOI Status of Decommissioning Funding - Indian Point 3

4.

ENOI Calculation of Minimum Amount - Indian Point 1, 2 & 3

5.

ENOI Status of Decommissioning Funding - Palisades

6.

ENOI Calculation of Minimum Amount - Palisades

7.

ENOI Status of Decommissioning Funding - Big Rock Point

8.

ENOI IP1 DTF Balance Based on Decommissioning Funding Assurance Plan

9.

ENOI Minimum Financial Assurance Calculation Worksheets

References:

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

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

NRC Region I Regional Administrator NRC Region III Regional Administrator NRC Project Manager, Indian Point 1 NRC Project Manager, Indian Point 2 / 3 NRC Project Manager, Palisades NRC Project Manager, Entergy Fleet NRC Sr. Resident Inspector, Indian Point 2 / 3 NRC Sr. Resident Inspector, Palisades

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

CNRO2020-00002 Page 1 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name:

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

1. Minimum Financial Assurance (MFA)

2. ISFSI Obligation as of 12/31/19

$592.89 million [Note1]

$1.74 million [Note2]

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

$555.740 million

4. A schedule of the annual amounts remaining to be collected None

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

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

None

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

8. Any material changes to trust agreements None Note 1: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Table 8-1 in Enclosure 8.

(Calculation of the NRC Minimum Amount is provided in Enclosure 4.)

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation. Total ISFSI obligation for Indian Point 1&2 is $10.45M with $8.71M attributable to Indian Point 2 and $1.74M attributable to Indian Point 1, all in 2019$

(totals may not foot due to rounding).

CNRO2020-00002 Page 2 of 2 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name:

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

1. Cumulative decommissioning spending

$123.6 million [Note 1]

2. 2019 decommissioning spending

$7.68 million [Note 1]

3. Fund Balance See above in 10 CFR 50.75 information

4. No other financial assurance mechanism is being relied upon, but costs through 12/31/2019 have been funded by operations, and not the decommissioning fund.

5. Estimated costs to complete from latest estimate

$592.89 million [Note 2]

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

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

8. Any material changes to trust agreements See above in 10 CFR 50.75 information Note 1: Entergy Nuclear Operations, Inc. (Entergy) does not possess records that would permit determination of charges to Indian Point 1 (IP1) prior to its acquisition in September 2001 by Entergy Nuclear Indian Point 2, LLC. The costs presented here represent those costs charged in 2019 and the total costs that have been assigned to IP1 since 2001. Entergy has not fully determined what portion of those costs would be considered decommissioning costs as that term is defined in 10 CFR 50.2.

Cumulative and 2019 decommissioning spending only consists of costs related to license termination.

Note 2: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Table 8-1 in Enclosure 8 (Calculation of the NRC Minimum Amount is provided in Enclosure 4). This estimate does not include 2019 spending because current costs are being paid out of operating funds.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Plant Name:

Indian Point Nuclear Generating Unit No. 2

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2019)

$527.7 million [Note 1]

2. ISFSI Obligation as of 12/31/19

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

$8.71 million [Note 2]

$701.3 million [Note 3]

4. A schedule of the annual amounts remaining to be collected None

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

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

None

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

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

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation. Total ISFSI obligation for Indian Point 1&2 is $10.45M with $8.71M attributable to Indian Point 2 and $1.74M attributable to Indian Point 1, all in 2019$

(totals may not foot due to rounding).

Note 3: Includes provisional fund balance of $34.84 million.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Plant Name:

Indian Point Nuclear Generating Unit No. 3

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2019$)

$527.7 million [Note 1]

2. ISFSI Obligation as of 12/31/19

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

$10.45 million [Note 2]

$929.97 million

4. A schedule of the annual amounts remaining to be collected None

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

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

None

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

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

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Indian Point 1, 2 & 3 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Indian Point 1, 2 & 3 For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Entergy Nuclear Indian Point 2, LLC:

100% ownership interest of Indian Point 1 & 2 Entergy Nuclear Indian Point 3, LLC:

100% ownership interest of Indian Point 3 Plant Location:

Buchanan, New York Reactor Type:

Pressurized Water Reactor (PWR)

Indian Point Unit 1 Power Level:

<3,400 MWt (615 MWt)

Indian Point Unit 1 PWR Base Year 1986$: $85,560,000 Indian Point Unit 2 Power Level:

<3,400 MWt (3,216 MWt)

Indian Point Unit 2 PWR Base Year 1986$: $103,300,800 Indian Point Unit 3 Power Level:

<3,400 MWt (3,216 MWt)

Indian Point Unit 3 PWR Base Year 1986$: $103,300,800 Labor Region:

North Waste Burial Facility:

Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

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

Factor L=Labor (North) 3.041 E=Energy (PWR) 2.352 B=Waste Burial-Vendor (PWR) 12.8533 PWR Escalation Factor:

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

5.10838 1986 PWR Base Year $ Escalated:

Indian Point 1: $85,560,000

• Factor =

$437,072,937 Indian Point 2 & 3: $103,300,800

• Factor =

$527,699,674 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2019) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2019) (Preliminary) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2-1 (2020)

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Palisades For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Plant Name:

Palisades Nuclear Plant

1. Minimum Financial Assurance (MFA) estimated per 10 CFR 50.75(b) and (c) (2019$)

2. ISFSI Obligation as of 12/31/19

$484.70 million [Note 1]

$8.24 million [Note 2]

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

$497.83 million

4. A schedule of the annual amounts remaining to be collected None

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

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

None

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

8. Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Enclosure 6 Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Palisades For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Calculation of Minimum Amount - Palisades For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Entergy Nuclear Palisades LLC.: 100% ownership interest Plant Location:

Covert, Michigan Reactor Type:

Pressure Water Reactor (PWR)

Power Level:

< 3,400 MWt (2565 MWt)

PWR Base Year 1986$:

$97,572,000 Labor Region:

Midwest Waste Burial Facility:

Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

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

Factor L=Labor (Midwest) 2.824 E=Energy (PWR) 2.355 B=Waste Burial-Vendor (PWR) 12.8536 PWR Escalation Factor:

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

4.96762 1986 PWR Base Year $ Escalated:

$97,572,000

• Factor =

$484,700,165 4

Bureau of Labor Statistics, Series Report ID: CIU2010000000230i (4th Quarter 2019) 5 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2019) (Preliminary) 6 Nuclear Regulatory Commission: NUREG-1307 Revision 17, Table 2-1 (2020)

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 1 Entergy Nuclear Operations, Inc.

Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

Plant Name:

Big Rock Point ISFSl

1.

Amount of decommissioning funds required from most recent estimate (2019$).

$2.64 million [Note 1]

2.

Decommissioning Funding Assurance Method.

Parent Guarantee ($5 million)

3.

A schedule of the annual amounts remaining to be collected None

4.

Assumptions used in determining rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections Escalation rate: 3%

Rate of earnings: n/a

5.

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

None

6.

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

7.

Any material changes to trust agreements None Note 1: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

CNRO2020-00002 Page 1 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

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

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

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

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

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

The updated Indian Point 1 site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until 2073, at which time the plant decommissioning will be completed, and the site released for alternative use without restriction. Table 8-1 below provides the annual license termination costs computed in the updated estimate. These costs to date have been funded by operations, and not by the decommissioning fund. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

CNRO2020-00002 Page 2 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1) 2019 $

Unit 1 Radiological Ending DTF Balance 2020 1.053 565.802 2021 4.202 572.916 2022 4.202 580.173 2023 4.202 587.574 2024 4.213 595.113 2025 4.202 602.813 2026 4.202 610.668 2027 4.202 618.679 2028 4.213 626.840 2029 4.202 635.175 2030 4.202 643.677 2031 4.202 652.349 2032 4.213 661.182 2033 4.202 670.204 2034 4.202 679.407 2035 4.202 688.793 2036 4.213 698.356 2037 4.202 708.121 2038 4.202 718.082 2039 4.202 728.242 2040 4.213 738.593 2041 4.202 749.163 2042 4.202 759.945 2043 4.202 770.942 2044 4.213 782.148 2045 4.202 793.589 2046 4.202 805.259 2047 4.202 817.163 2048 4.213 829.293 2049 4.202 841.677 2050 4.202 854.309 2051 4.202 867.193 2052 4.213 880.324 2053 4.202 893.728 2054 4.202 907.401 2055 4.202 921.348 Table 8-1 NRC License Termination Cost

($ millions)

CNRO2020-00002 Page 3 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1) 2056 4.213 935.561 2057 4.202 950.071 2058 4.202 964.870 2059 4.202 979.966 2060 4.213 995.352 2061 4.202 1,011.058 2062 4.202 1,027.077 2063 4.202 1,043.417 2064 4.213 1,060.072 2065 30.804 1,050.470 2066 67.239 1,004.240 2067 112.221 912.104 2068 119.414 810.931 2069 17.264 809.886 2070 17.134 808.950 2071 17.134 807.995 2072 17.181 806.974 2073 8.450 814.664 Total 592.896

CNRO2020-00002 Page 4 of 4 Entergy Nuclear Operations, Inc.

IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2019 - 10 CFR 50.75(f)(1)

As can be seen from the information provided in Table 8-1, the required funding for SAFSTOR decommissioning, $592.89 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $437.07 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2019 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $815 million surplus exists at the end of the decommissioning project. The present value of this surplus is approximately $280 million in 2019 dollars ($815 million/(1.02)(2073-2019)). This surplus is sufficient to cover the spent fuel management costs for Indian Point 1 as reflected in Reference 1, Enclosure 1, of approximately $56 million, as well as ISFSI decommissioning costs shown in Enclosure 1 from this filing, if not paid for by spent fuel litigation proceeds. Accordingly, ENIP2 concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Indian Point 1.

Reference 1: Letter, Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2019 - 10 CFR 50.82(a)(8)(vii), CNRO-2020-00003, filed March 26, 2020.

CNRO2020-00002 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets

CNRO2020-00002 Page 1 of 4 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets Note: See Enclosure 8 for adequacy of the trust fund.

PWR 615

$85,560,000 140.7 2.16 0.65 3.04 2.083 2.715 0.13 2.35 0.22 12.853

$592,896,000 From Table 8-1

% Owned:

100.00%

Entergy

$592,896,000

$555,740,321 NRC Minimum:

$437,072,937 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

9 28 2013 MWth 1986$

ECI Base Lx Plant name:

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

12 31 2019

CNRO2020-00002 Page 2 of 4 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 140.7 2.16 0.65 3.04 2.083 2.715 0.13 2.35 0.22 12.853

% Owned:

100.00%

2%

0.33 1.00657 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 221,973,748 230,683,256 (8,709,508)

$758,382,930 Total = Total Earnings + Total Earnings for Decom

$705,904,025

$52,478,906 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$701,297,832

$705,904,025 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Entergy

$527,699,674

$701,297,832 NRC Minimum:

$527,699,674 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

4 30 2020 MWth 1986$

ECI Base Lx Plant name:

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

12 31 2019

CNRO2020-00002 Page 3 of 4 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 3216

$103,300,800 140.7 2.16 0.65 3.04 2.083 2.715 0.13 2.35 0.22 12.853

% Owned:

100.00%

2%

1.33 1.02670 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 487,632,780 498,084,190 (10,451,410)

$1,025,783,864 Total = Total Earnings + Total Earnings for Decom

$954,801,234

$70,982,629 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$929,971,497

$954,801,234 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Entergy

$527,699,674

$929,971,497 NRC Minimum:

$527,699,674 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

4 30 2021 MWth 1986$

ECI Base Lx Plant name:

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

12 31 2019

CNRO2020-00002 Page 4 of 4 Entergy Nuclear Operations, Inc.

Minimum Financial Assurance Calculation Worksheets PWR 2565

$97,572,000 135.7 2.08 0.65 2.82 2.083 2.715 0.13 2.35 0.22 12.853

% Owned:

100.00%

2%

2.42 1.04902 2%

2%

7 0.14869 Excess (Shortfall) to NRC minimum Less ISFSI Parent Co Guaranty Total Excess Financial Assurance 68,118,598 76,354,478 (8,235,880)

$561,054,643 Total = Total Earnings + Total Earnings for Decom

$522,230,545

$38,824,099 Total Earnings for Decom = (1/2) x Total Earnings x [(1+RRR)^Decom period - 1]

Total of Steps 1 - 3:

Real Rate of Return per Decom Period:

Total Real Rate of Total Earnings for Decom:

Total Earnings:

Step 3:

Decom Period:

Accumulation:

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

Total Annuity:

$0 0

$0 Total Earnings:

$497,827,085

$522,230,545 Total Earnings = Trust Fund balance x (1+RRR)^Years left in license Step 2:

Step 1:

Earnings Credit:

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

Entergy

$484,700,165

$497,827,085 NRC Minimum:

$484,700,165 Site Specific:

Amount of NRC Minimum/Site Specific:

Licensee:

Amount in Trust Fund:

Lx Px Fx Ex Bx Termination of Operation:

5 31 2022 MWth 1986$

ECI Base Lx Plant name:

Palisades Nuclear Plant Month Day Year Year of Biennial:

12 31 2019