L-21-037, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
| ML21090A336 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Pilgrim |
| Issue date: | 03/31/2021 |
| From: | Sterdis A Holtec Decommissioning International |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| HCI-OC-21-023, HDI-PIL-21-037 | |
| Download: ML21090A336 (24) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 HDI-PIL-21-037 Page 1 of 3 10 CFR 50.75 10 CFR 50.82 March 31, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044
SUBJECT:
Holtec Decommissioning International Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
REFERENCE:
- 1.
Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Oyster Creek Nuclear Generating Station, September 28, 2018 (ML18275A116)
- 2.
Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, November 16, 2018 (ML18320A040)
- 3.
Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2020 (ML20091M858)
In accordance with 10 CFR 50.75(f)(1), 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vi), and 10,CFR 50.82(a)(8)(vii), Holtec Decommissioning International, LLC (HDI) is submitting the annual status of decommissioning funding, status of funding for managing irradiated fuel, and the financial assurance report for Oyster Creek Nuclear Generating Station (Oyster Creek) and Pilgrim Nuclear Power Station (Pilgrim). The annual decommissioning funding assurance reports for Oyster Creek and Pilgrim Sites are provided in Enclosures 1 and 2 to this letter. Attachment 1 to this letter provides the methodology used to calculate the formula cost amount per 10 CFR 50.75(c).
The initial HDI Site-Specific Decommissioning Cost Estimates for Oyster Creek and Pilgrim, included in the revised Post-Shutdown Decommissioning Activities Reports (References 1 and 2 respectively) were based on the DECON method for decommissioning and were
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 HDI-PIL-21-037 Page 2 of 3 submitted in 2018. Subsequent to these initial decommissioning cost estimates, HDI prepared and submitted the annual report providing the decommissioning funding, irradiated fuel management funding, and financial assurance status through December 31, 2019 for Oyster Creek and Pilgrim (Reference 3). and Enclosure 2 to this letter, provide the Annual Decommissioning Funding, Irradiated Fuel Management Status and Financial Assurance Report for Oyster Creek and Pilgrim, respectively. The estimates provided in Enclosure 1 and 2, using the December 31, 2020 trust fund balances, indicate Oyster Creek and Pilgrim have met the NRCs funding requirements. Accordingly, HDI concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the Oyster Creek and Pilgrim sites.
There are no regulatory commitments contained within this letter.
If you should require any further information, please contact me at (856) 797-0900 x 3813.
Sincerely, Andrea L. Sterdis Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC ALS/mjg Digitally signed by Andrea Sterdis DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, email=a.sterdis@holtec.com Date: 2021.03.31 18:32:50 -04'00' Andrea Sterdis
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 HDI-PIL-21-037 Page 3 of 3
Enclosures:
(1)
Annual Decommissioning Funding Assurance and Spent Fuel Management Report for Oyster Creek Nuclear Generating Station (2)
Annual Decommissioning Funding Assurance and Spent Fuel Management Report for Pilgrim Nuclear Power Station
Attachment:
(1)
Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c) cc:
USNRC Regional Administrator, Region I USNRC Project Manager, NMSS Oyster Creek USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station Assistant Commissioner, Air Quality, Energy and Sustainability, NJ DEP Assistant Director Radiation Protection Element, NJ Bureau of Nuclear Engineering Commonwealth of Massachusetts, Executive Office of Environmental Affairs Commonwealth of Massachusetts, Department of Public Health Commonwealth of Massachusetts, Department of Environmental Protection Commonwealth of Massachusetts, Director, Massachusetts Emergency Management Agency
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 and HDI-PIL-21-037 Page 1 of 9 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2020 (9 pages including cover page)
HDI-OC-21-023 and HDI-PIL-21-037 Page 2 of 9 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2020 As required by 10 CFR 50.75(f) and 50.82(a)(8), Holtec Decommissioning International (HDI) reports the following information for Oyster Creek Nuclear Generating Station:
A. Formula Cost Amount per 10 CFR 50.75(c)
Pursuant to 10 CFR 50.75(c), the 2021 estimated NRC formula cost is $627,041,568. HDI does not use this calculation for any decommissioning cost estimates or evaluations.
B. Current Decommissioning Cost Estimate The required minimum funding assurance amount for Oyster Creek as of December 31, 2020 is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the HDI revised Post-Shutdown Decommissioning Activities Report (Reference 1) as amended in the annual decommissioning funding and spent fuel management status report for 2019 (Reference 2). Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides HDI revised total estimate information as required by 10 CFR 50.82. The revised total estimate to complete decommissioning for the Oyster Creek site is $615M (in 2020 dollars). Of that total cost estimate, the revised estimate for license termination expenses is $333M, the current separate estimate of spent fuel management costs is $246M and the current separate estimate for site restoration costs is $37M.
C. Current Decommissioning Fund Balance The Oyster Creek Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2020 was $713M. This amount represents the market value of the NDT fund as of December 31, 2020 net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. No additional amounts remain to be collected. The trust fund amount is the total available for decommissioning including costs of license termination decommissioning, spent fuel management, and site restoration activities. The total is provided because HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the Oyster Creek Trust fund to be used for site irradiated fuel management and site restoration costs (Reference 3).
D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earnings on Funds, and Other Factors Used in Funding Projections HDI has assumed a 2% real rate of return as allowed by 10 CFR 50.75(e)(1)(i).
E. Rates used to Inflate Decommissioning Costs The estimates in the 2018 HDI Oyster Creek Revised PSDAR/Decommissioning Cost Estimate (DCE) (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2020 dollars. The Bureau of Labor Statistics data provided the basis for the decommissioning cost estimate inflation rate forecast. Decommissioning costs are inflated using a weighted average of BLS indices for Labor, Energy, Consumer Price Index, Materials, and Equipment. For Burial inflation factor, HDI utilized NUREG-1307, Revision 18. HDI has used a factor of 1.01 to calculate the inflation to 2020 dollars. This is conservative as it does not credit the fixed price contracts.
HDI-OC-21-023 and HDI-PIL-21-037 Page 3 of 9 F. Current ISFSI Decommissioning Cost The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.054M (2020 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI Revised PSDAR/DCE (Reference 1) and amended in Reference 2 which were inflated using published inflation indices as previously discussed in item (E).
G. Decommissioning Financial Assurance Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1) as approved by NRC in their approval of the license transfer to Oyster Creek Environmental Protection (OCEP) and HDI.
H. Changes in the Decommissioning Funding Plan Trust Agreement No change.
Please refer to Tables 1 and 2 of this Enclosure for additional required reporting data.
Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI. This cash flow analysis demonstrates that the Oyster Creek decommissioning trust fund is sufficiently funded to cover costs as estimated for the license termination, spent fuel management and site restoration activities necessary to complete safe and compliant decommissioning of the site.
In addition, HDI has included an updated schedule that reflects the current decommissioning plan.
Figure 1 provides the revised schedule. The schedule revisions reflect actual work progress achieved from HDIs acquisition of the site through December 31, 2020. The schedule reflects revisions to the work plan resulting from more detailed project planning, subcontract execution, and optimization since HDIs submittal of the 2019 Annual Decommissioning and Spent Fuel Management Report (Reference 2). The changes reflected on the updated schedule have been reviewed to confirm that there are no significant schedule changes from the schedule submitted in Reference 2. The estimate to complete and cash flow analyses provided in Tables 1 and 2 confirm that these schedule revisions are not significant as defined in 10 CFR 50.82 (a)(7). HDI also has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the HDI Oyster Creek PSDAR (Reference 1).
References:
- 1) Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Oyster Creek Nuclear Generating Station, September 28, 2018 (ML18275A116)
- 2) Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 31, 2020 (ML20091M858)
- 3) Letter from US NRC to Exelon Generation Company, LLC, Oyster Creek Nuclear Power StationIssuance of Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) dated June 20, 2019 (ML19113A204)
HDI-OC-21-023 and HDI-PIL-21-037 Page 4 of 9 Table 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report HDI-OC-21-023 and HDI-PIL-21-037 Page 5 of 9 ENCLOSURE 1 Table 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Summary Information as of December 31, 2020 10 CFR 50.82(a)(8)(v)-(vii)
Decommissioning Trust Fund Balance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(A)
Year Type of Trust Fund Balance (2020 $)
Comments 2020 Decommissioning Trust
$713M As of 12/31/2020; net of tax liabilities Other Financial Assurance Methods Being Relied Upon 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(B)
NONE HDI Decommissioning Expenditures 10 CFR 50.82(a)(8)(v)(A) Since License Transfer Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2019
$54M
$8M
$0M
$62M 2019 Costs in as-Spent Dollars 2020
$105M
$79M
$8M
$192M 2020 Costs in as-Spent Dollars Total to Date
$159M
$87M
$8M
$254M As-Spent Dollars Prior Year Expenditures Variance to Total HDI Estimated Cost 10 CFR 50.82(a)(8)(v)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2020 Estimated
$89M
$71M
$17M
$178M Estimate in 2019 Dollars 2020 Actuals
$105M
$79M
$8M
$192M Variance due to Project Timing and Optimization Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2021
$333M
$246M
$37M
$615M Estimated in 2020 Dollars Decommissioning Criteria Upon Which the Estimate is Based 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(B)
DECON Any Modification to Method of Providing Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C)
NONE Any Material Changes to Trust Agreement Since Previous Report 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(D)
No material changes.
Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C)
NONE HDI-OC-21-023 and HDI-PIL-21-037 Page 6 of 9 Table 2 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Cash Flow Analysis HDI-OC-21-023 and HDI-PIL-21-037 Page 7 of 9 Table 2 Oyster Creek Nuclear Generating Station - DECON Method Annual Cash Flow in Millions of 2020 Dollars Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance Withdrawals NDT Earnings1 Year Ending NDT Balance 2021 127 97 16 240 7132
-2763 9
446 2022 53 7
5 65 446
-65 8
389 2023 64 7
6 77 389
-77 6
318 2024 56 8
8 72 318
-72 5
251 2025 20 9
1 30 251
-30 4
225 2026 0
7 0
8 225
-8 4
221 2027 0
8 0
8 221
-8 4
218 2028 0
8 0
8 218
-8 4
214 2029 0
8 0
8 214
-8 4
210 2030 0
8 0
8 210
-8 4
207 2031 0
8 0
8 207
-8 4
203 2032 0
8 0
8 203
-8 4
199 2033 9
27 0
36 199
-36 3
166 2034 2
27 0
29 166
-29 3
140 2035 1
9 1
11 140
-11 3
131 Total4 333 246 37 615
-651 69 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2021 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2021 NDT Withdrawal Amount includes $36M for the reimbursement of HDIs 2020 expenses that were not reimbursed in 2020.
4 Columns may not add due to rounding HDI-OC-21-023 and HDI-PIL-21-037 Page 8 of 9 Figure 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Decommissioning Schedule Timeline
Oyster Creek Decommissioning - Waterfall Chart J
2020 2021 2022 2024 2025 2023 2019 F
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D YEAR MONTH CLOSE DATE 07/01/2019 J
M 2018 PARTIAL SITE RELEASE 11/03/2025 COMPLETE FUEL SHIPMENT 03/28/2035 FINAL SITE SURVEY 08/29/2035 FINAL LICENSE TERMINATION 12/03/2035 D&D (DECON, ABATEMENT AND DISMANTLEMENT)
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REACTOR SEGMENTATION CHARACTERIZATION, INVESTIGATION & LTP ISFSI SITE RESTORATION FSS NRC REVIEW REACTOR INTERNALS SEGMENTATION VESSEL AND MISC. HARDWARE SEGMENTATION FUEL WET STORAGE FUEL POOL TO PAD D&D (DECON, ABATEMENT AND DISMANTLEMENT)
SITE RESTORATION WASTE MANAGEMENT NRC REVIEW LTP 2026 2026 TO 2036 2026 J
F M
A M J
J A
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2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 SITE CHARACTERIZATION/ REMEDIAL INVESTIGATION FUEL DRY ONLY STORAGE WASTE MANAGEMENT PREPARE LTP FSS REPORT FUEL ON PAD 07/01/2021 SUBMIT LTP 11/04/2022 SHUTDOWN START 09/17/2018 ZIRCONIUM FIRE ELIMINATED 06/29/2019 HDI-OC-21-023 and HDI-PIL-21-037 Page 9 of 9
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 and HDI-PIL-21-037 Page 1 of 9 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2020 (9 pages including cover page)
HDI-OC-21-023 and HDI-PIL-21-037 Page 2 of 9 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2020 As required by 10 CFR 50.75(f) and 50.82(a)(8), Holtec Decommissioning International (HDI) reports the following information for Pilgrim Nuclear Power Station:
A. Formula Cost Amount per 10 CFR 50.75(c)
Pursuant to 10 CFR 50.75(c), the 2021 estimated NRC formula cost is $628,612,907. HDI does not use this calculation for any decommissioning cost estimates or evaluations.
B. Current Decommissioning Cost Estimate The required minimum funding assurance amount for Pilgrim as of December 31, 2020 is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the HDI revised Post-Shutdown Decommissioning Activities Report (Reference 1) as amended in the annual decommissioning funding and spent fuel management status report for 2019 (Reference 2). Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides HDI revised total estimate information as required by 10 CFR 50.82. The revised total estimate to complete decommissioning for the Pilgrim site is $824M (in 2020 dollars). Of that total cost estimate, the revised estimate for license termination expenses is $370M, the current separate estimate of spent fuel management costs is $417M and the current separate estimate for site restoration costs is $37M.
C. Current Decommissioning Fund Balance The Pilgrim Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2020 was
$881M. This amount represents the market value of the NDT fund as of December 31, 2020 net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. No additional amounts remain to be collected. The trust fund amount is the total available for decommissioning including costs of license termination decommissioning, spent fuel management, and site restoration activities. The total is provided because HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the Pilgrim Trust fund to be used for site irradiated fuel management and site restoration costs (Reference 3).
D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earnings on Funds, and Other Factors Used in Funding Projections HDI has assumed a 2% real rate of return as allowed by 10 CFR 50.75(e)(1)(i).
E. Rates used to Inflate Decommissioning Costs The estimates in the 2018 HDI Pilgrim Revised PSDAR/Decommissioning Cost Estimate (DCE)
(Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2020 dollars. The Bureau of Labor Statistics data provided the basis for the decommissioning cost estimate inflation rate forecast. Decommissioning costs are inflated using a weighted average of BLS indices for Labor, Energy, Consumer Price Index, Materials, and Equipment. For Burial inflation factor, HDI utilized NUREG-1307, Revision 18. HDI has used a factor of 1.02 to calculate the inflation to 2020 dollars. This is conservative as it does not credit the fixed price contracts.
F. Current ISFSI Decommissioning Cost The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.324M (2020 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI Revised PSDAR/DCE (Reference 1) and amended in HDI-OC-21-023 and HDI-PIL-21-037 Page 3 of 9 Reference 2 which have been inflated using published inflation indices as previously discussed in item (E).
G. Decommissioning Financial Assurance Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1) as approved by NRC in their approval of the license transfer to Holtec Pilgrim, LLC and HDI.
H. Changes in the Decommissioning Funding Plan Trust Agreement The trust agreement has not been amended. Pursuant to the process for appointing a successor trustee set forth in the trust agreement, Holtec Pilgrim notified BNY Mellon to transition trustee responsibilities to the Northern Trust Company (who also serves as trustee for Oyster Creek).
The transition became effective after the reporting period.
Please refer to Tables 1 and 2 of this Enclosure for additional required reporting data.
Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI. This cash flow analysis demonstrates that the Pilgrim decommissioning trust fund is sufficiently funded to cover costs as estimated for the license termination, spent fuel management and site restoration activities necessary to complete safe and compliant decommissioning of the site.
In addition, HDI has included an updated schedule that reflects the current decommissioning plan. Figure 1 provides the revised schedule. The schedule revisions reflect actual work progress achieved from HDIs acquisition of the site through December 31, 2020. The schedule reflects revisions to the work plan resulting from more detailed project planning, subcontract execution, and optimization since HDIs submittal of the 2019 Annual Decommissioning and Spent Fuel Management Report (Reference 2). The overall decommissioning milestones are not significantly changed from those submitted in Reference 2.
The estimate to complete and cash flow analyses provided in Tables 1 and 2 confirm that these schedule revisions are not significant as defined in 10 CFR 50.82 (a)(7). HDI also has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the HDI Pilgrim PSDAR (Reference 1).
References:
- 1) Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, November 16, 2018 (ML18320A040)
- 2) Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 31, 2020 (ML20091M858)
- 3) Letter from US NRC to Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) for Holtec Decommissioning International, LLC dated August 22, 2019 (ML19192A083)
HDI-OC-21-023 and HDI-PIL-21-037 Page 4 of 9 Table 1 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report HDI-OC-21-023 and HDI-PIL-21-037 Page 5 of 9 ENCLOSURE 1 Table 1 Holtec Decommissioning International Pilgrim Nuclear Power Station Summary Information as of December 31, 2020 10 CFR 50.82(a)(8)(v)-(vii)
Decommissioning Trust Fund Balance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(A)
Year Type of Trust Fund Balance (2020 $)
Comments 2020 Decommissioning Trust
$881M As of 12/31/2020; net of tax liabilities Other Financial Assurance Methods Being Relied Upon 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(B)
NONE HDI Decommissioning Expenditures 10 CFR 50.82(a)(8)(v)(A) Since License Transfer Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2019
$45M
$56M
$0M
$101M 2019 Costs in as-Spent Dollars 2020
$106M
$67M
$3M
$175M 2020 Costs in as-Spent Dollars Total Spent to Date
$151M
$123M
$3M
$277M Prior Year Expenditures Variance to Total HDI Estimated Cost 10 CFR 50.82(a)(8)(v)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2020 Estimated
$59M
$66M
$0M
$125M Estimate in 2019 Dollars 2020 Actuals
$106M
$67M
$3M
$175M Variance due to project timing and optimization Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2021
$370M
$417M
$37M
$824M Estimated in 2020 Dollars Decommissioning Criteria Upon Which the Estimate is Based 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(B)
DECON Any Modification to Method of Providing Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C)
NONE Any Material Changes to Trust Agreement Since Previous Report 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(D)
No material changes. See item (H) in Enclosure 2 Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C)
NONE HDI-OC-21-023 and HDI-PIL-21-037 Page 6 of 9 Table 2 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Cash Flow Analysis HDI-OC-21-023 and HDI-PIL-21-037 Page 7 of 9 Table 2 Pilgrim Nuclear Power Station - DECON Method Annual Cash Flow in Millions of 2020 Dollars Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance Withdrawals NDT Earnings1 Year Ending NDT Balance 2021 140 92 3
235 8812
-2813 12 612 2022 33 32 6
70 612
-70 11 553 2023 54 7
12 72 553
-72 10 491 2024 57 7
5 69 491
-69 8
430 2025 38 6
6 49 430
-49 8
388 2026 33 7
1 41 388
-41 7
355 2027 1
9 5
14 355
-14 7
347 2028 6
6 347
-6 7
348 2029 6
6 348
-6 7
349 2030 7
7 349
-7 7
348 2031 7
7 348
-7 7
347 2032 7
7 347
-7 7
347 2033 7
7 347
-7 7
346 2034 7
7 346
-7 7
346 2035 7
7 346
-7 7
345 2036 7
7 345
-7 7
344 2037 7
7 344
-7 7
344 2038 7
7 344
-7 7
343 2039 7
7 343
-7 7
343 2040 7
7 343
-7 7
342 2041 7
7 342
-7 7
341 2042 7
7 341
-7 7
340 2043 7
7 340
-7 7
340 2044 7
7 340
-7 7
339 2045 7
7 339
-7 7
338 2046 7
7 338
-7 7
337 2047 7
7 337
-7 7
337 2048 7
7 337
-7 7
336 2049 7
7 336
-7 7
335 2050 7
7 335
-7 7
334 2051 7
7 334
-7 7
333 2052 7
7 333
-7 7
333 2053 7
7 333
-7 7
332 2054 7
7 332
-7 6
331 2055 7
7 331
-7 6
330 2056 7
7 330
-7 6
329 2057 7
7 329
-7 6
328 2058 7
7 328
-7 6
327 2059 7
7 327
-7 6
326 2060 4
7 12 326
-12 6
320 2061 4
7 12 320
-12 6
315 2062 4
7 12 315
-12 6
309 2063 1
2 1
4 309
-4 6
311 Total4 370 417 37 824
-869 299 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2021 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2021 NDT Withdrawal Amount includes $46M for the reimbursement of HDIs 2020 expenses that were not reimbursed in 2020.
4 Columns may not add due to rounding HDI-OC-21-023 and HDI-PIL-21-037 Page 8 of 9 Figure 1 Holtec Decommissioning International Pilgrim Nuclear Power Station Decommissioning Schedule Timeline
SITE RESTORATION Pilgrim Decommissioning - Waterfall Chart J
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YEAR MONTH CLOSE DATE 08/26/2019 J
M 2019 PARTIAL SITE RELEASE 09/24/2027 COMPLETE FUEL SHIPMENT 12/31/2062 FINAL SITE SURVEY 06/03/2063 FINAL LICENSE TERMINATION 09/07/2063 D&D (DECON, ABATEMENT AND DISMANTLEMENT)
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REACTOR SEGMENTATION CHARACTERIZATION, INVESTIGATION & LTP ISFSI SITE RESTORATION FSS NRC REVIEW REACTOR INTERNALS SEGMENTATION VESSEL & MISC.
HARDWARE SEGMENTATION FUEL WET STORAGE FUEL POOL TO PAD - PH2 D&D (DECON, ABATEMENT AND DISMANTLEMENT)
WASTE MANAGEMENT NRC REVIEW LTP 2026 2028 TO 2063 J
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D 2028 - 2061 2063 SITE CHARACTERIZATION / MARSAME SURVEYS FUEL DRY ONLY STORAGE WASTE MANAGEMENT PREPARE LTP FSS REPORT 2027 2062 FSS FUEL POOL TO PAD - PH1 FUEL ON PAD 11/15/2021 SUBMIT LTP 09/23/2025 SHUTDOWN START 05/31/2019 ZIRCONIUM FIRE ELIMINATED 03/31/2019 HDI-OC-21-023 and HDI-PIL-21-037 Page 9 of 9
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-21-023 and HDI-PIL-21-037 Page 1 of 3 Holtec Decommissioning International Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c)
(3 pages including cover page)
HDI-OC-21-023 and HDI-PIL-21-037 Page 2 of 3 Holtec Decommissioning International Annual Report on the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (ISFSIs)
Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c)
The labor, energy and burial indexes used are consistent with those described in NUREG-1307, Revision 18, issued January 2021.
The current labor cost indexes used are obtained from the Employment Cost Index published by the U.S. Department of Labor, Bureau of Labor Statistics (BLS). Specifically, HDI used the Employment Cost Index for total compensation for private industry workers in the Northeast Region. The labor adjustment factors were calculated according to Section 3.2 of NUREG-1307, Revision 18 using fourth quarter 2020 data. Table 1 shows the data used for this calculation.
Table 1: Northeast Region Labor Adjustment Factor Applicable Site Series ID 4Q2020 Index Number Labor Adjustment Factor (Lx)
Oyster Creek CIU2010000000210I 144.0 3.11 Pilgrim CIU2010000000210I 144.0 3.11 The current energy cost indexes used are obtained from Producer Price Indexes (PPI) -
Commodities, published by the U.S. Department of Labor, BLS. Specifically, HDI used the PPI for industrial electric power (WPU0543) and light fuel oils (WPU0573). The energy adjustment factors were calculated according to Section 3.3 of NUREG-1307, Revision 18, using December 2020 data. Table 2 shows the data used for this calculation.
Table 2: Energy Adjustment Factor WPU0543 - January 1986 (base value) 114.2 WPU0573 - January 1986 (base value) 82.0 WPU0543 - December 2020 (preliminary value) 232.7 WPU0573 - December 2020 (preliminary value) 209.8 Industrial Electric Power Adjustment Factor - (PX) 2.038 Light Fuel oil Adjustment Factor - (FX) 2.559 Energy Adjustment Factor - (BWR) 2.277 The waste burial adjustment factors are taken from Table 2-1 of NUREG-1307, Revision 18, based on 2020 data. The adjustment factors HDI used assume a combination of compact-affiliated and non-compact facilities as applicable. Table 3 shows the data used for this calculation.
HDI-OC-21-023 and HDI-PIL-21-037 Page 3 of 3 Table 3: Waste Burial Adjustment Factor LLW Burial Site Reactor Type Decommissioning Site Combination of Compact-Affiliated and Non-Compact Disposal Facilities Waste Adjustment Factor -
(BX)
Generators Located in Unaffiliated States
- (BX)
South Carolina Atlantic Compact Site BWR Oyster Creek 12.948 N/A Generic LLW BWR Pilgrim N/A 12.837 The calculation methodology used for all adjustment factors is consistent with NUREG-1307, Revision 18.
Site Escalation Factors -
(Lx), (Ex), (Bx)
Escalation Factor Formula 10 CFR 50.75(c)(2)
BWR Escalation Factor 1986 BWR Base Year $
Escalated
- Factor Oyster Creek (Lx) 3.11 0.65(L)+0.13(E)+0.22(B) 5.17
$627,041,568 (Ex) 2.28 (Bx) 12.948 Pilgrim (Lx) 3.11 0.65(L)+0.13(E)+0.22(B) 5.14
$628,612,907 (Ex) 2.28 (Bx) 12.837