L-21-134, and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations

and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations

ML21350A264
Person / Time
Site:	Indian Point, Oyster Creek, Pilgrim
Issue date:	12/17/2021
From:	Fleming J Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
HDI-IPEC-21-039, HDI-OC-21-099, HDI-PIL-21-134
Download: ML21350A264 (18)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 72.30 December 17, 2021 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 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 Operating License No. DPR-35 NRC Docket No. 50-293 and 72-1044 Indian Point Nuclear Generating Stations 1, 2, & 3 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64 Docket Nos. 50-3, 50-247, 50-286 and 72-051

Subject:

Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations In accordance with 10 CFR 72.30, Financial assurance and recordkeeping for decommissioning, Holtec Decommissioning International, LLC (HDI) is submitting a report on the status of decommissioning funding plans for the independent spent fuel storage installations (ISFSIs) for Oyster Creek Nuclear Station (Oyster Creek), Pilgrim Nuclear Station (Pilgrim),

Indian Point Nuclear Stations Units 1, 2 and 3 (IPEC).

On July 1, 2019, Oyster Creek was transferred to Oyster Creek Environmental Protection, LLC (OCEP) as the licensed owner and HDI as the licensed operator for decommissioning. On August 27, 2019, Pilgrim was transferred to Holtec Pilgrim, LLC (Holtec Pilgrim) as the licensed owner and HDI as the licensed operator for decommissioning. On May 28, 2021, Indian Point was transferred to Holtec Indian Point 2, LLC and Holtec Indian Point 3, LLC as the licensed owners and HDI as the licensed operator for decommissioning. HDI prepared and submitted Post-Shutdown Decommissioning Activities Reports (PSDARs) including Site-Specific Decommissioning Cost Estimates (DCEs) for each of these sites (References 1, 2 & 3).

The HDI PSDARs and DCEs are based on a transition to the DECON decommissioning status.

Utilizing the DECON method allows for the prompt decommissioning and unrestricted release of each site except for the ISFSI sooner than was planned by the previous owners. The HDI PSDARs and DCEs describe the selected methods and estimated costs for the decontamination, dismantlement, spent fuel management and site restoration of each site. The site-specific DCEs also include the estimated costs to decommission ISFSIs following the removal of spent fuel and Greater than Class C (GTCC) waste from the site.

HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 1 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosures 1, 2, & 3, show that the surpluses in the Decommissioning Trust Funds exceed the estimated costs of ISFSI decommissioning, as summarized in Table 1. The Trust Fund balances account for the 10 CFR Part 50 license expiration dates and the ISFSI DCE assumes all costs are incurred in the year following the year in which spent fuel has been fully removed from the ISFSI. All estimates have been escalated to 2020 dollars.

The estimates provided in Enclosures 1, 2, & 3, indicate that Oyster Creek, Pilgrim, and IPEC 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, Pilgrim, and IPEC sites.

Table 1 Plant Site Trust Fund Surplus ISFSI DCE Oyster Creek $131M1 $3.99M Pilgrim $311M1 $4.29M Unit 1: $19.9M2 Units 1, 2 & 3:

Indian Point Unit 2: $72.7M2

$5.74M Unit 3: $170.6M2 This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at (856) 797-0900, ext. 3578.

Sincerely, Digitally signed by Jean A. Fleming Jean A. DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Fleming Environmental Affairs, email=J.Fleming@Holtec.com Date: 2021.12.16 14:06:30 -05'00' Jean A. Fleming Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC 1 Trust Fund Surplus value taken from Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2021 (ML21090A336) 2 Trust Fund Surplus value taken from Letter, Holtec Decommissioning International, LLC to US NRC, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3, December 19, 2019 (ML19354A698)

HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 2 of 3

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

Enclosures:

1. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Oyster Creek Nuclear Generating Station

2. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Pilgrim Nuclear Power Station

3. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Indian Point Nuclear Generating Station, Units 1, 2 & 3

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, 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, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3, December 19, 2019 (ML19354A698)

4. Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2021 (ML21090A336)

5. 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.

cc: NRC Region I Regional Administrator NRC NMSS Senior Project Manager - Indian Point NRC NMSS Senior Project Manager - Pilgrim NRC NMSS Senior Project Manager - Oyster Creek New York State Department of Public Service President and CEO, NYSERDA Massachusetts Emergency Management Agency (MEMA), Director Assistant Commissioner, Air Quality, Energy and Sustainability, NJ DEP Assistant Director Radiation Protection Element, NJ Bureau of Nuclear Engineering State of New York Commonwealth of Massachusetts State of New Jersey HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 3 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ENCLOSURE 1 To HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 10 CFR 72.30 ISFSI Decommissioning Funding Plan Oyster Creek Nuclear Generating Station

10 CFR 72.30 ISFSI Decommissioning Funding Plan Oyster Creek Nuclear Generating Station Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011 (Reference 5) 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 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. In accordance with the rule, this enclosure provides a detailed cost estimate for decommissioning the ISFSI constructed at Oyster Creek.

Key Assumptions / Estimating Approach 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.

A small number of the spent fuel storage canister overpack assemblies are assumed to have some level of neutron-induced activation as a result of the exposure to the fuel. Due to the leak-proof design of the spent fuel and GTCC canisters, it is assumed that there will be no contamination of ISFSI structures or components. The cost of the disposition of any material exceeding free release criteria, as well as the demolition of the ISFSI facility, is included in the cost estimate.

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 performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

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 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:

a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSI in to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 2 of 5

the past three years.

2. Facility modifications:

a. No impact. There have not been any modifications to the ISFSI at the facility in the past three years that would materially change the latest decommissioning cost estimate.

Actual costs for modifications to the ISFSI are bounded by the costs assumed in the decommissioning cost estimate.

3. Changes in authorized possession limits:

a. No impact. There have not been any changes in authorized possession limits at the ISFSI in the past three years that would materially change the decommissioning cost estimate.

4. Actual remediation costs that exceed the previous cost estimate:

a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 1-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2035, the year following all spent fuel removal.

Financial Assurance ISFSI operations at Oyster Creek are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such time that the costs can be recovered from the DOE, HDI 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 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 3 of 5

including ISFSI decommissioning costs.

• Based upon Oyster Creeks decommissioning trust fund balance as of December 31, 2020, the trust fund will contain a $131 million surplus. This surplus is more than sufficient to complete the decommissioning of the ISFSI.

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. to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 4 of 5

Table 1-1 Oyster Creek ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

Burial Removal Transport Disposal Other Volume License Spent Site Total Oyster Creek Activity FTE Costs Costs Costs Costs Class A Termination Fuel Restoration Costs (ft3)

ISFSI Demolition Non-664 664 664 Radiological ISFSI Clean Waste 78 78 78 ISFSI Final Site Survey 33 33 33 ISFSI NRC Confirmatory 11 11 11 Survey ISFSI Demolition 903 903 903 Radiological ISFSI Radiological Waste 76 304 6,000 380 380 NRC License Termination 228 1 228 228 Support Security Staff 317 3 317 317 Security Management 280 1 280 280 Property Tax 748 748 748 Insurance 130 130 130 NRC Regulatory Fees 224 224 224 Totals 1567 76 382 1972 1,175 2,080 742 3,997 Enclosure 1 to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 5 of 5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ENCLOSURE 2 To HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station

10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011 (Reference 5) 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 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. In accordance with the rule, this enclosure provides a detailed cost estimate for decommissioning the ISFSI constructed at Pilgrim.

Key Assumptions / Estimating Approach 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 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.

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.

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 performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

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: to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 2 of 5

a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSIs in the past three years.

2. Facility modifications:

a. No impact. There have not been any modifications to the ISFSIs at the facility in the past three years that would materially change the latest decommissioning cost estimate.

The ISFSI facility design at the time the cost estimate was prepared was incorporated into the estimate. Also, any ISFSI modifications (i.e. ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the cost estimate.

3. Changes in authorized possession limits:

a. No impact. There have not been any changes in authorized possession limits at the ISFSIs in the past three years that would materially change the decommissioning cost estimate.

4. Actual remediation costs that exceed the previous cost estimate:

a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2063, the year following all spent fuel removal.

Financial Assurance ISFSI operations at Pilgrim are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such time that the costs can be recovered from the DOE, HDI 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: to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 3 of 5

• 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 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

• Based upon Pilgrims decommissioning trust fund balance as of December 31, 2020, the trust fund will contain a $311 million surplus. This surplus is more than sufficient to complete the decommissioning of the ISFSI.

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. to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 4 of 5

Table 2-1 Pilgrim ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

Burial LLRW Removal Other Volume License Spent Site Total Pilgrim Activity Disposal FTE Costs Costs Class A Termination Fuel Restoration Costs Costs (ft3)

ISFSI Demolition Non-Radiological 640 640 640 ISFSI Final Site Survey 32 32 32 ISFSI NRC Confirmatory Survey 12 12 12 ISFSI Demolition Radiological 869 869 869 ISFSI Waste Class 482 6,000 400 82 482 A/Hazardous/Exempt NRC License Termination Support 163 0.5 163 163 Operations Staff 315 2.78 315 315 Operations Management 278 0.7 278 278 Property Tax 624 624 624 Insurance 647 647 647 NRC Regulatory Fees 234 234 234 Totals 1509 482 2306 3.98 1,076 2,499 722 4,297 Enclosure 2 to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 5 of 5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ENCLOSURE 3 To HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Generating Stations 1, 2, & 3

10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Generating Stations 1, 2, & 3 Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011 (Reference 5), 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 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. In accordance with the rule, this enclosure provides a detailed cost estimate for decommissioning the ISFSI constructed at IPEC.

Key Assumptions / Estimating Approach 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 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.

The storage overpacks used for the GTCC canisters 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.

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.

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 performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

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 to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 2 of 5

subsurface material:

a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSI in the past three years.

2. Facility modifications:

a. No impact. There have not been any modifications to the ISFSI at the facility in the past three years that would materially change the latest decommissioning cost estimate.

The ISFSI facility design at the time the cost estimate was prepared was incorporated into the estimate. Also, any ISFSI modifications (i.e. ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the cost estimate.

3. Changes in authorized possession limits:

a. No impact. There have not been any changes in authorized possession limits at the ISFSI in the past three years that would materially change the decommissioning cost estimate.

4. Actual remediation costs that exceed the previous cost estimate:

a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 3-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2062, the year following all spent fuel removal.

Financial Assurance ISFSI operations at IPEC are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such time that the costs can be recovered from the DOE, HDI 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: to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 3 of 5

• 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 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

• Based upon IPECs decommissioning trust fund balances taken from the IPEC PSDAR and DCE (Reference 3), the Unit 1, 2 & 3 trust funds will contain surpluses of $19.9 million, $72.7 million, and $170.6 million respectively. These surpluses are more than sufficient to complete the decommissioning of the ISFSI.

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. to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 4 of 5

Table 3-1 IPEC ISFSI Decommissioning Cost Estimate (thousands of 2020 dollars)

Removal Packaging Transport LLRW Disposal IPEC Activity Other Costs Total Costs Costs Costs Costs Costs Decommissioning Contractor Planning (characterization, specs, and procedures) 72 72 Decontamination (Overpack disposition) 1,624 34 298 641 2,596 License Termination (radiological surveys) 129 129 Subtotal 1,624 34 298 641 201 2,797 Supporting Costs NRC and NRC Contractor Costs 11 11 Site O&M 1,718 1,718 Insurance 547 547 NRC Regulatory Fees 670 670 Subtotal 2,946 2,946 Totals 1,624 34 298 641 3,147 5,743 Enclosure 3 to HDI-IPEC-21-039 HDI-OC-21-099 HDI-PIL-21-134 Page 5 of 5