Text

And Waterford Steam Electric Station, Unit 3, ISFSI Decommissioning Funding Plans (10 CFR 72.30)
	ML21350A155
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	12/15/2021
From:	Couture P; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	CNRO2021-00026
	Download: ML21350A155 (52)
	v • d • e

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5102 Philip L. Couture Senior Manager Fleet Regulatory Assurance 10 CFR 72.30 CNRO2021-00026 December 15, 2021 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Subject:

ISFSI Decommissioning Funding Plans (10 CFR 72.30)

Arkansas Nuclear One, Units 1 & 2 Docket No.72-013 River Bend Station Docket No.72-049 Grand Gulf Nuclear Station Docket No.72-050 Waterford Steam Electric Station, Unit 3 Docket No.72-075 The NRC Final Rule on Decommissioning Planning was published in 76 FR 35512 on June 17, 2011 with an effective date of December 17, 2012. The final rule includes a requirement (10 CFR 72.30) for each holder of a Part 72 License to submit, for NRC review and approval, a decommissioning funding plan for purposes of decommissioning the licensees Independent Spent Fuel Storage Installation (ISFSI), and to resubmit those plans with adjustments as necessary to account for changes in costs and the extent of contamination.

Entergy Operations, Inc. (Entergy) is hereby submitting (Enclosures 1 through 4) the required Plans for the subject plants.

The enclosure for each plant shows that the surpluses in the 10 CFR 50.75 Decommissioning Trust Funds exceed the estimated costs of ISFSI decommissioning, as summarized in the following table. The Trust Fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI decommissioning cost estimates (DCE) assume all costs are incurred in the year following the year in which spent fuel has been fully removed from the ISFSI. The values are reported in 2021 dollars unless noted otherwise. This letter constitutes a certification that financial assurance is provided to cover the estimated cost of ISFSI decommissioning, as indicated in the following table:

CNRO2021-00026 Page 2 of 3 Plant Site Trust Fund Surplus DCE Arkansas Nuclear One Unit 1: $ 553M Unit 2: $ 413M

$10.95M Grand Gulf:

SERI* share, 90%

CE** share, 10%

$1,608M

$ 177M

$11.86M River Bend Regulated share, 70%

Non-Regulated share, 30%

$ 798M

$ 829M

$10.50M Waterford 3

$ 873M

$ 8.01M

System Energy Resources, Inc.

- Cooperative Energy This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at (601) 368-5102.

Respectfully, Philip L. Couture PLC/chm

Enclosures:

1. 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One

2. 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station

3. 10 CFR 72.30 ISFSI Decommissioning Funding Plan River Bend Station

4. 10 CFR 72.30 ISFSI Decommissioning Funding Plan Waterford Steam Electric Station, Unit 3

CNRO2021-00026 Page 3 of 3 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - ANO NRC Senior Resident Inspector - GGN NRC Senior Resident Inspector - RBS NRC Senior Resident Inspector - WF3 NRC Project Manager - ANO NRC Project Manager - GGN NRC Project Manager - RBS NRC Project Manager - WF3 Arkansas Department of Health Mississippi Department of Health Louisiana Department of Environmental Quality

ENCLOSURE 1 CNRO2021-00026 10 CFR 72.30 ISFSI Decommissioning Funding Plan Arkansas Nuclear One

CNRO2021-00026 Page 1 of 11 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN ARKANSAS NUCLEAR ONE

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2018.[2]

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at Arkansas Nuclear One (ANO), in an amount reflecting:

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 "ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station,"

CNRO2018-00049, (NRC Accession No. ML18351A491), dated December 17, 2018.

CNRO2021-00026 Page 2 of 11

2.

Spent Fuel Management Strategy The operating licenses are currently set to expire on May 20, 2034 and July 17, 2038 for Units 1 and 2, respectively. Approximately 5,610 spent fuel assemblies are currently projected to be generated over the life of the two units. Primarily because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate includes, for financial planning purposes, a second set of pads to support decommissioning. The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pools will contain a significant number of spent fuel assemblies at the time of expiration of the current operating licenses in 2034 for Unit 1 and 2038 for Unit 2, assuming the units operate to those dates, and including assemblies off-loaded from the reactor vessels. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pools is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Once the spent fuel pools are emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations 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. Entergy Arkansas, Inc.s (Entergy) current spent fuel management plan for the ANO spent fuel 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 for the ANO fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority.

Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the ANO site in 2078.

Entergy believes that one or more monitored retrievable storage facilities could be put into place within a reasonable time. In January 2013, the DOE issued the "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," in response to the recommendations made by the Obama administrations Blue Ribbon Commission and as "a framework for moving toward a sustainable program to deploy an integrated system capable of transporting, storing, and disposing of used nuclear fuel..."[5]

3 U.S. Code of Federal Regulations, Title 10, Part 72, Subpart K, "General License for Storage of Spent Fuel at Power Reactor Sites."

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

5 "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013.

CNRO2021-00026 Page 3 of 11 The report stated that "[W]ith the appropriate authorizations from Congress, the Administration currently plans to implement a program over the next 10 years that:

Sites, designs and licenses, constructs and begins operations of a pilot interim storage facility by 2021 with an initial focus on accepting used nuclear fuel from shut-down reactor sites. [6] Therefore, in 2013, DOE assumed it could begin fuel acceptance within 8 years of its report at in interim facility. While as in 2013 no further progress has currently been made on a disposal facility, its estimate of an 8-year development time for an interim facility would still allow fuel to be removed beginning in 2030.

The DOE has taken the position that under the Standard Contract, it does not have an obligation to accept canistered fuel from licensees. This position, coupled with the DOEs failure to perform, has increased the difficulty of estimating future requirements under 10 CFR 72.30. The estimates presented in this report are for budgeting purposes only, and do not represent any conclusion by the licensee about how the DOE will actually perform in the future. This report should not be taken as any indication that the licensee knows how the DOE will eventually perform its obligations, or has any specific expectation concerning that performance. If DOEs failure to perform results in specific additional costs beyond those reflected in this report, it is expected that the DOE will compensate the licensee for those costs.

Entergys position is that the DOE has a contractual obligation to accept the spent fuel earlier than the projections set out above consistent with its contract commitments. No assumption made in this study should be interpreted to be inconsistent with this claim.

3.

ISFSI Decommissioning Strategy At the conclusion of the spent fuel transfer process the ISFSI pads will be promptly decommissioned (similar to the power reactor DECON alternative).

For purposes of the funding plan, financial assurance is provided on the basis of a prompt ISFSI decommissioning scenario, i.e., independent of other station decommissioning strategies. ISFSI decommissioning is considered an independent project, regardless of the decommissioning alternative identified for the nuclear power plant.

4.

ISFSI Description The ISFSI at ANO comprises several separate pads. The original pad is used to store 24 Sierra Nuclear VSC-24 Ventilated Storage Casks (VSCs). Entergy transferred 576 assemblies into the VSCs between 1996 and 2003. It is possible that the spent fuel in these casks will have to be repackaged before it can be shipped off-site. Repackaging is currently assumed to occur immediately after the cessation of plant operations, while the spent fuel pools are still available and the associate fuel handling systems are operable. As such, the VSCs are not expected to be on the ISFSI pad when it is decommissioned (and are not considered in this funding plan).

6 Ibid. at page 2.

CNRO2021-00026 Page 4 of 11 The design and capacity of the dry storage modules on the additional pads are based upon the Holtec HI-STORM 100 dry cask storage system (Version C). The system consists of a multi-purpose canister, with a nominal capacity of 24 or 32 fuel assemblies, and a steel-lined concrete storage overpack. Entergy intends to use Holtecs HI-STORM FW System (with a 37 spent fuel assembly capacity) for storing all future spent fuel on-site, starting in 2023 for ANO-1 and 2025 for ANO-2 respectively. The Holtec dry storage system consists of an inner multi-purpose canister (containing the spent fuel) and an outer concrete and steel overpack.

Entergys current spent fuel management plan for the ANO spent fuel would result in 131 (74 100S and 57 FW) spent fuel storage casks (which includes the repackaged fuel from the VSCs) being placed on seven storage pads at the site. This projected configuration is based upon the 2030 DOE spent fuel program start with a 2033 DOE start date for ANO spent fuel, a 3,000 MTU (metric ton of uranium) / year pickup rate, and the current cask capacity (including expansion capability) for the ISFSI pads built to support plant operations. This scenario would allow the spent fuel storage pools to be emptied within approximately five and one-half years following the permanent cessation of operations.

The 131 casks projected to be on the ISFSI pads after shutdown excludes any additional casks that may be used for Greater-than-Class-C (GTCC) storage. The storage overpacks used for the GTCC canisters (estimated quantity of 10) are not expected to have any interior contamination of residual activation and can be reused or disposed of by conventional means after a final status survey.

Table 1 provides the significant quantities and physical dimensions used as the basis in developing the ISFSI decommissioning estimate.

5.

Key Assumptions / Estimating Approach The decommissioning estimate is based on the configuration of the ISFSI expected after all spent fuel and GTCC material has been removed from the site. The configuration of the ISFSI is based on the station operating until the end of its current licenses (2034 and 2038) and the DOEs spent fuel acceptance assumptions, as previously described.

The dry storage vendor, Holtec International, does not expect the overpacks to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small.[7] The decommissioning estimate is based on the premise that some of the inner steel liners and concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 10 of the 131 overpacks are assumed to be affected, i.e., contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 177 offloaded assemblies per reactor, 37 assemblies per cask) which results in 10 overpacks. It is assumed that these are the final casks offloaded; consequently, they have the least time for radioactive decay of the neutron activation products.

7 HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev.0, at page 2-83 (Accession Number ML15075A203).

CNRO2021-00026 Page 5 of 11 The dry storage vendor, Holtec International, does not expect any residual contamination to be left on the concrete ISFSI pads.[8] It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that the ISFSI pads will not be contaminated. As such, only verification surveys are included for the pads in the decommissioning estimate. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the §20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

The latest decommissioning cost study for ANO (prepared in 2019) did not include the remediation of contaminated (radiological) soil as being required to terminate the site operating license. As such, there is no allowance for soil remediation in this estimate.

Low-level radioactive waste disposal costs are based on Entergys negotiated rates with EnergySolutions.

Decommissioning is assumed to be performed by an independent contractor. As such, labor, equipment, and material costs are based on national averages, i.e., costs from national publications such as RSMeans Building Construction Cost Data (adjusted for regional variations), and laboratory service costs are based on vendor price lists.

Entergy, as licensee, will oversee the site activities.

Contingency has been added at an overall rate of 25%. This is consistent with the contingency evaluation criteria referenced by the NRC in NUREG-1757.[9]

Costs are reported in 2021 dollars and based upon an internal decommissioning analysis prepared for ANO in 2019. Activity costs have been escalated to 2021 dollars using the Consumer Price Index, Services.[10]

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material: There have been no spills at the ISFSI.

8 HI-STORM FW FSAR, Holtec International, Report HI-2114830, Rev. 0, at page 2-84 (Accession Number ML15075A203).

9 "Consolidated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timeliness,"

U.S. Nuclear Regulatory Commissions Office of Nuclear Material Safety and Safeguards, NUREG-1757, Volume 3, Revision 1, February 2012.

10 Bureau of Labor Statistics, Consumer Price Index - All Urban Consumers, Services, Series ID: CUUR0000SAS.

CNRO2021-00026 Page 6 of 11 (2) Facility modifications: There have been no facility modifications that affect the decommissioning cost estimate.

(3) Changes in authorized possession limits: There are no changes in authorized possession limits that affect the decommissioning cost estimate.

(4) Actual remediation costs that exceed the previous cost estimate: No actual remediation costs have been incurred, so no actual remediation costs exceed the previous cost estimate.

6.

Cost Considerations The estimated cost to decommission the ISFSI pads and release the facility for unrestricted use is provided in Table 2. The cost includes an initial planning phase.

During this phase the empty overpacks, ISFSI pad(s), and surrounding environs are characterized and the activity specifications and work procedures for the decontamination (overpack disposition) developed.

The next phase includes the cost for craft labor to demolish the activated overpacks, package in certified waste containers, transportation to the Clive, Utah site, disposal, as well as the costs for the supporting equipment, materials and supplies.

The final phase includes the cost for the license termination survey, verification survey, and the associated equipment and laboratory support.

The estimate also contains costs for the NRC (and NRC contractor), Entergys oversight staff, site security (industrial), and other site operating costs.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2079, the year following all spent fuel removal.

7.

Financial Assurance ISFSI operations at ANO are primarily in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. The costs for management of the spent fuel are costs for which the DOE is responsible under federal law and the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would primarily be a DOE-reimbursable expense. Until such time that the costs can be recovered from the DOE, Entergy will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

Although the decommissioning trust fund is for radiological decommissioning costs only, the ISFSI decommissioning is a radiological cost. Also, to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by Entergy, including ISFSI decommissioning costs.

CNRO2021-00026 Page 7 of 11 The projected amount necessary for decommissioning ANO is $493.297 million and

$513.669 million for Units 1 and 2, respectively, based upon the NRCs latest financial assurance funding determination.[11]

Based upon ANOs decommissioning trust fund balances as of September 30, 2021 and considering the allowed real rate of return on the fund between October 1, 2021 and the assumed end of ANO station decommissioning, the trust funds will contain surpluses of $552.574 million and $412.836 million for Units 1 and 2, respectively (refer to Tables 3 and 4) beyond the NRC minimum funding formula provided in 10 CFR 50.75(e). This surplus is more than sufficient to complete the decommissioning of the ISFSI (estimated cost provided in Table 2). For purposes of this submittal, it is assumed that each ANO trust fund will bear half of the ISFSI decommissioning cost.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

11 "Report on Waste Burial Charges," U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, NUREG-1307, Rev. 18, January 2021.

CNRO2021-00026 Page 8 of 11 Table 1 Significant Quantities and Physical Dimensions ISFSI Pad Item Length (ft)

Width (ft)

Residual Radioactivity ISFSI Pads (existing) 421 (3 pads) 41 to 56 No ISFSI Pads (expansion) 660 (4 pads) 50 No ISFSI Storage Overpack (Holtec HI-STORM FW PWR)

Item Value Notes Overall Height (inches) 217.3 Dimensions are nominal Outside Diameter (inches) 139.0 Dimensions are nominal Inside Diameter (inches) 81.0 Dimensions are nominal Quantity (total) 141 131 spent fuel (74 100S + 57 Holtec FW) + 10 GTCC (Holtec FW)

Quantity (with residual radioactivity) 10 Equivalent to the number of overpacks used to store last complete core offload Low-Level Radioactive Waste (total packaged volume) 25,058 Cubic feet Low-Level Radioactive Waste (packaged density) 124 Average weight density Other Potentially Impacted Items Item Value Notes Transfer Cask 1

Number of Overpacks used for GTCC storage 10 No residual radioactivity

CNRO2021-00026 Page 9 of 11 Table 2 ISFSI Decommissioning Costs and Waste Volumes Costs (thousands, 2021 dollars)

Waste Volume Person-Hours Removal Packaging Transport Disposal Other Total Class A (cubic feet)

Craft Oversight and Contractor Decommissioning Contractor Planning (characterization, specs and procedures) 445 445 1,240 Decontamination/Demolition (activated cask disposition) 221 181 1,390 2,649 47 4,488 25,058 2,644 License Termination (radiological surveys) 2,286 2,286 17,228 Subtotal 221 181 1,390 2,649 2,778 7,220 25,058 19,872 1,240 Supporting Costs NRC and NRC Contractor Fees and Costs 548 548 1,153 Insurance 178 178 Property Taxes 1

1 Plant Energy Budget 87 87 Non-Labor Overhead 21 21 Corporate A&G 136 136 Security 235 235 5,082 Entergy Oversight Staff 334 334 3,855 Subtotal 1,540 1,540 10,090 Total (w/o contingency) 221 181 1,390 2,649 4,319 8,760 25,058 19,872 11,330 Total (w/25% contingency) 277 226 1,738 3,312 5,398 10,950 Note: Columns/Rows may not add due to rounding

CNRO2021-00026 Page 10 of 11 Table 3 Financial Assurance

CNRO2021-00026 Page 11 of 11 Table 4 Financial Assurance

ENCLOSURE 2 CNRO2021-00026 10 CFR 72.30 ISFSI Decommissioning Funding Plan Grand Gulf Nuclear Station

CNRO2021-00026 Page 1 of 11 10 CFR 72.30 ISFSI DECOMMISSIONING FUNDING PLAN GRAND GULF NUCLEAR STATION

1.

Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011,[1] with the rule becoming effective on December 17, 2012.

Subpart 72.30, "Financial assurance and recordkeeping for decommissioning," requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the Independent Spent Fuel Storage Installation (ISFSI).

The rule also requires resubmittal of the decommissioning funding plan at intervals not to exceed 3 years, with adjustments as necessary to account for changes in costs and the extent of contamination. This document is intended to update the funding plans previously submitted by Entergy Operations, Inc. in December 2018.[2]

In accordance with the rule, this letter provides a detailed cost estimate for decommissioning the ISFSI at the Grand Gulf Nuclear Station (Grand Gulf), in an amount reflecting:

1. The work performed by an independent contractor;

2. An adequate contingency factor; and

3. Release of the facility and dry storage systems for unrestricted use, as specified in 10 CFR Part 20.1402 This letter also provides:

1. Identification of and justification for using the key assumptions contained in the cost estimate;

2. A description of the method of assuring funds for decommissioning; and

3. The volume of onsite subsurface material containing residual radioactivity, if any, that will require remediation to meet the criteria for license termination.

1 U.S. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning," Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011.

2 "ISFSI Decommissioning Funding Plans (10 CFR 72.30) for Arkansas Nuclear One, Units 1 & 2, Grand Gulf Nuclear Station, River Bend Station and Waterford 3 Steam Electric Station,"

CNRO2018-00049, (NRC Accession No. ML18351A491), dated December 17, 2018.

CNRO2021-00026 Page 2 of 11

2.

Spent Fuel Management Strategy The operating license for Grand Gulf is currently set to expire on November 1, 2044.

Approximately 10,488 spent fuel assemblies are currently projected to be generated over the life of the plant. Because of the breach by the Department of Energy (DOE) of its contract to remove fuel from the site, an ISFSI has been constructed and fuel casks have been emplaced thereon to support continued plant operations. Based upon the current projection of the DOEs ability to remove spent fuel from the site, this estimate assumes that the current ISFSI will be expanded or a second pad constructed after shutdown to support decommissioning. The ISFSI is assumed to be operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[3]).

Because of the DOEs breach, it is envisioned that the spent fuel pool will contain a significant number of spent fuel assemblies at the time of expiration of the current operating license in 2044, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations or safe-storage operations, the fuel that cannot be transferred directly to the DOE from the pool is assumed to be packaged in dry storage casks for interim storage at the ISFSI. Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas can be either decontaminated and dismantled or prepared for long-term storage.

Completion of the ISFSI decommissioning process is dependent upon the DOEs ability to remove spent fuel from the site. DOEs repository program assumes that spent fuel allocations 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. Entergy Operations, Inc.s (Entergy) current spent fuel management plan for the Grand Gulf spent fuel 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 for the Grand Gulf fuel. The DOEs generator allocation/receipt schedules are based upon the oldest fuel receiving the highest priority. Assuming a maximum rate of transfer of 3,000 metric tons of uranium/year,[4] the spent fuel is projected to be fully removed from the Grand Gulf site in 2079.