L-22-022, And Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec.
| ML22084A059 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Oyster Creek, Pilgrim |
| Issue date: | 03/25/2022 |
| 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-22-029, HDI-OC-22-018, HDI-PIL-22-022 | |
| Download: ML22084A059 (34) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-22-018 HDI-PIL-22-022 HDI-IPEC-22-029 Page 1 of 3 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)
March 25, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
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 Indian Point Nuclear Generating Stations 1, 2, & 3 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64 NRC Docket Nos. 50-3, 50-247, 50-286 and 72-051 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI)
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 (Accession No. 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 (Accession No. 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 (Accession No. ML19354A698) 4.
Letter, Holtec Decommissioning International, LLC to US NRC, Holtec Decommissioning International Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2021 (Accession No. ML21090A336) 5.
Letter, Entergy to US NRC, Decommissioning Funding Status Report per 10 CFR 50.75(f)(1) and 10 CRF 50.82(a)(8)(v) - Entergy Nuclear Operations, Inc., March 25, 2021 (Accession No. ML21084A811)
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-22-018 HDI-PIL-22-022 HDI-IPEC-22-029 Page 2 of 3 In accordance with 10 CFR 50.75(f)(1) and 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 report on the status of decommissioning funding, the financial assurance report, and the status of funding for managing irradiated fuel as of December 31, 2021 for Oyster Creek Nuclear Generating Station (Oyster Creek), Pilgrim Nuclear Power Station (Pilgrim) and Indian Point Nuclear Generating Station Units 1, 2 and 3 (IPEC). The annual decommissioning funding assurance reports for Oyster Creek, Pilgrim, and IPEC are provided in Enclosures 1, 2, and 3 to this letter. Enclosure 4 to this letter provides the methodology used to calculate the formula cost amount per 10 CFR 50.75(c). Enclosure 5 to this letter provides the decommissioning milestone summary.
The initial HDI Site-Specific Decommissioning Cost Estimates for Oyster Creek and Pilgrim included in the revised Post-Shutdown Decommissioning Activities Reports (PSDAR) (References 1, 2) were based on the DECON method for decommissioning and were 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, 2020, for Oyster Creek and Pilgrim (Reference 4). HDI prepared and submitted the initial Site-Specific Decommissioning Cost Estimates for IPEC included in the PSDAR (Reference 3) which was based on the DECON method for decommissioning and was submitted in 2019. Entergy submitted the IPEC Decommissioning Funding Status report for financial assurance through December 31, 2020 (Reference 5)., Enclosure 2, and Enclosure 3 to this letter provide the Annual Decommissioning Funding, Financial Assurance Report, and Irradiated Fuel Management Status for Oyster Creek, Pilgrim, and IPEC, respectively. The estimates provided in Enclosures 1, 2, and 3, using the December 31, 2021, trust fund balances, indicate Oyster Creek, Pilgrim, and IPEC sites 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.
There are no regulatory commitments contained within this letter.
If you should require any further information, please contact me at (856) 797-0900 x 3578 Sincerely, Jean Fleming Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Jean A.
Fleming Digitally signed by Jean A. Fleming Date: 2022.03.25 09:15:46 -04'00'
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-22-018 HDI-PIL-22-022 HDI-IPEC-22-029 Page 3 of 3
Enclosures:
(1)
Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report (2)
Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report (3)
Indian Point Nuclear Generating Station Units 1, 2, and 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report (4)
Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c)
(5)
Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Milestone Summary cc:
USNRC Regional Administrator, Region I USNRC Senior Project Manager, NMSS - Oyster Creek USNRC Senior Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Senior Project Manager, NMSS - Indian Point Units 1, 2 & 3 NRC Region 1 Lead Inspector, Indian Point Units 1, 2 & 3 NRC Region 1 Lead Inspector - Oyster Creek NRC Region 1 Lead Inspector - Pilgrim Nuclear Power Station New York State Department of Public Service New York State Liaison Officer Designee, NYSERDA New Jersey DEP - Assistant Commissioner, Air Quality, Energy and Sustainability New Jersey Bureau of Nuclear Engineering, Assistant Director Radiation Protection Element, 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 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 As required by 10 CFR 50.75(f), 50.82(a)(7), 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 2022 estimated NRC formula cost is $648,014,501. 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, 2021, 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 (PSDAR) (Reference 1) and updated in the 2020 Annual Decommissioning and Spent Fuel Management Report (Reference 2). Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides HDIs revised total estimate information as required by 10 CFR 50.82. The revised total estimate to complete decommissioning for the Oyster Creek site is $444M (in 2021 dollars) as shown in cash flow analysis in Table 2. Of that total cost estimate, the revised estimate for license termination expenses is $224M, the current separate estimate of spent fuel management costs is $187M and the current separate estimate for site restoration costs is $32M.
C.
Current Decommissioning Fund Balance The Oyster Creek Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2021, was $593M. This amount represents the market value of the NDT fund as of December 31, 2021, 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/DCE (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2021 dollars. The Bureau of Labor Statistics (BLS) 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 2021 dollars. This is conservative as it does not credit the fixed price contracts.
F.
Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.093M (2021 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 the 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.
Refer to Tables 1 and 2 of this Enclosure for additional required reporting data. Table 2 provides a cashflow 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 accordance with 10 CFR 50.82(a)(7), HDI is notifying the NRC of a schedule change from that described in the Oyster Creek Revised PSDAR (Reference 1). HDI has updated its schedule to reflect the current decommissioning plan. The schedule revisions reflect actual work progress achieved since HDIs acquisition of the site and includes revisions to the work plan resulting from more detailed project planning and optimization since HDIs submittal of the Oyster Creek Revised PSDAR (Reference 1). The PSDAR (Reference 1) indicates that the Reactor Pressure Vessel (RPV) will be segmented and packaged for disposal directly following the completion of RVI segmentation. HDI will further evaluate optimization of RPV segmentation and commence segmentation activities associated with the RPV in 2024. Enclosure 5 provides the major decommissioning project milestones and their updated scheduled completion dates.
The estimate to complete and cash flow analyses provided in Tables 1 and 2 confirm that the schedule revisions in Enclosure 5 are not financially 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 (Accession No. ML18275A116) 2.
Letter, Holtec Decommissioning International, LLC to US NRC, Holtec Decommissioning International Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2021 (Accession No. ML21090A336) 3.
Letter from US NRC to Exelon Generation Company, LLC, Oyster Creek Nuclear Power Station Issuance of Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv), June 20, 2019 (Accession No. ML19113A204)
Table 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report ENCLOSURE 1 Table 1 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Summary Information as of December 31, 2021 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) / (vii)(A)
Year Type of Trust Fund Balance (2021 $)
Comments 2021 Decommissioning Trust
$593M As of 12/31/2021; 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 2021
$115M
$125M
$3M
$242M 2021 Costs in as-Spent Dollars Total to Date
$273M
$212M
$11M
$496M 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 2021 Estimated
$127M
$97M
$16M
$240M Estimate in 2020 Dollars 2021 Actuals
$115M
$125M
$3M
$242M 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 2022
$224M
$187M
$32M
$444M Estimate in 2021 Dollars. Columns may not add due to rounding.
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) / (vii)(C)
NONE Table 2 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Cash Flow Analysis ENCLOSURE 1 Table 2 Oyster Creek Nuclear Generating Station - DECON Method Annual Cash Flow in Millions (2021 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 2022 81 39 6
125 5932
-2413 7
359 2023 41 10 7
58 359
-58 6
308 2024 50 9
9 68 308
-68 5
245 2025 41 8
10 59 245
-59 4
190 2026 0
9 0
9 190
-9 4
185 2027 0
8 0
8 185
-8 4
180 2028 0
8 0
8 180
-8 3
176 2029 0
8 0
8 176
-8 3
171 2030 0
8 0
8 171
-8 3
167 2031 0
8 0
8 167
-8 3
162 2032 0
8 0
8 162
-8 3
157 2033 9
28 0
37 157
-37 2
122 2034 2
28 0
30 122
-30 2
95 2035 1
9 1
11 95
-11 2
85 Total4 224 187 32 444
-559 51 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2022 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2022 NDT Withdrawal Amount includes $116M for the reimbursement of HDIs 2021 expenses that were not reimbursed in 2021.
4 Columns may not add due to rounding Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 As required by 10 CFR 50.75(f), 50.82(a)(7), 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 2022 estimated NRC formula cost is $649,738,251. 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, 2021, 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 (PSDAR) (Reference 1) and updated in the 2020 Annual Decommissioning and Spent Fuel Management Report (Reference 2). Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides HDIs revised total estimate information as required by 10 CFR 50.82. The revised total estimate to complete decommissioning for the Pilgrim site is $661M (in 2021 dollars) as shown in cash flow analysis in Table 2. Of that total cost estimate, the revised estimate for license termination expenses is $292M, the current separate estimate of spent fuel management costs is $342M and the current separate estimate for site restoration costs is $28M.
C.
Current Decommissioning Fund Balance The Pilgrim Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2021, was
$825M. This amount represents the market value of the NDT fund as of December 31, 2021, 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/DCE (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2021 dollars.
The Bureau of Labor Statistics (BLS) 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 2021 dollars. This is conservative as it does not credit the fixed price contracts.
F.
Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.4M (2021 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 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 No change.
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 accordance with 10 CFR 50.82(a)(7), HDI is notifying the NRC of a schedule change from that described in the Pilgrim Revised PSDAR (Reference 1). HDI has updated its schedule to reflect the current decommissioning plan. The schedule revisions reflect actual work progress achieved since HDIs acquisition of the site and includes revisions to the work plan resulting from more detailed project planning and optimization since HDIs submittal of the Pilgrim Revised PSDAR (Reference 1). The PSDAR (Reference 1) indicates that segmentation activities for the Reactor Vessel Internals (RVI) and Reactor Pressure Vessel (RPV) will complete in 2020 and 2022, respectively.
HDI will now complete RVI segmentation in 2022 and will further evaluate optimization of RPV segmentation and commence segmentation activities associated with the RPV in 2024. Enclosure 5 provides the major decommissioning project milestones and their updated scheduled completion dates.
The estimate to complete and cash flow analyses provided in Tables 1 and 2 confirm that the schedule revisions in Enclosure 5 are not financially 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 (Accession No. ML18320A040) 2.
Letter, Holtec Decommissioning International, LLC to US NRC, Holtec Decommissioning International Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 31, 2021 (Accession No. ML21090A336) 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, August 22, 2019 (Accession No. ML19192A083)
Table 1 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report ENCLOSURE 2 Table 1 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Summary Information as of December 31, 2021 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) / (vii)(A)
Year Type of Trust Fund Balance (2021 $)
Comments 2021 Decommissioning Trust
$825M As of 12/31/2021; 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 2021
$105M
$113M
$2M
$221M 2021 Costs in as-Spent Dollars Total Spent to Date
$256M
$237M
$5M
$497M 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 2021 Estimated
$140M
$92M
$3M
$235M Estimate in 2020 Dollars 2021 Actuals
$105M
$113M
$2M
$221M Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2022
$292M
$342M
$28M
$661M Estimated in 2021 Dollars. Columns may not add due to rounding.
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) / (vii)(C)
NONE Table 2 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Cash Flow Analysis ENCLOSURE 2 Table 2 Pilgrim Nuclear Power Station - DECON Method Annual Cash Flow in Millions (2021 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 2022 91 29 7
127 8252
-2973 11 539 2023 39 11 7
56 539
-56 10 492 2024 43 10 7
60 492
-60 9
441 2025 48 10 3
61 441
-61 8
388 2026 42 10 2
54 388
-54 7
341 2027 14 8
1 24 341
-24 6
323 2028 6
6 323
-6 6
323 2029 6
6 323
-6 6
323 2030 8
8 323
-8 6
322 2031 8
8 322
-8 6
321 2032 8
8 321
-8 6
319 2033 8
8 319
-8 6
318 2034 8
8 318
-8 6
317 2035 8
8 317
-8 6
315 2036 8
8 315
-8 6
314 2037 8
8 314
-8 6
313 2038 8
8 313
-8 6
311 2039 8
8 311
-8 6
310 2040 8
8 310
-8 6
308 2041 8
8 308
-8 6
307 2042 8
8 307
-8 6
305 2043 8
8 305
-8 6
303 2044 8
8 303
-8 6
302 2045 8
8 302
-8 6
300 2046 8
8 300
-8 6
298 2047 8
8 298
-8 6
297 2048 8
8 297
-8 6
295 2049 8
8 295
-8 6
293 2050 8
8 293
-8 6
291 2051 8
8 291
-8 6
289 2052 8
8 289
-8 6
287 2053 8
8 287
-8 6
285 2054 8
8 285
-8 6
283 2055 8
8 283
-8 6
281 2056 8
8 281
-8 5
279 2057 8
8 279
-8 5
277 2058 8
8 277
-8 5
275 2059 8
8 275
-8 5
273 2060 5
8 12 273
-12 5
266 2061 5
8 12 266
-12 5
259 2062 5
8 12 259
-12 5
252 2063 1
3 1
4 252
-4 5
252 Total4 292 342 28 661
-832 259 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2022 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2022 NDT Withdrawal Amount includes $170M for the reimbursement of HDIs 2021 expenses that were not reimbursed in 2021.
4 Columns may not add due to rounding Holtec Decommissioning International Indian Point Nuclear Generating Station Units 1, 2, and 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 Holtec Decommissioning International Indian Point Nuclear Generating Station Units 1, 2 & 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2021 As required by 10 CFR 50.75(f), 50.82(a)(7), and 50.82(a)(8), Holtec Decommissioning International (HDI) reports the following information for Indian Point Nuclear Generating Station Units 1, 2 and 3:
A.
Formula Cost Amount per 10 CFR 50.75(c)
Pursuant to 10 CFR 50.75(c), the 2022 estimated NRC formula cost for Unit 1 is $453,129,154, for Unit 2 is $547,085,134, and for Unit 3 is $547,085,134. 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 Indian Point Units 1, 2 & 3 (IP1, IP2, and IP3), collectively referred to as Indian Point Energy Center (IPEC) as of December 31, 2021, is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the HDI Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 1). Additional reporting requirements are documented on Tables 1A through 1C of this Enclosure. Tables 1A through 1C provide HDIs revised total estimate information as required by 10 CFR 50.82.
The revised total estimate to complete decommissioning for IP1 is $604M (in 2021 dollars) as shown in cash flow analysis in Table 2A. Of that total cost estimate, the revised estimate for license termination expenses is $485M, the current separate estimate of spent fuel management costs is $76M and the current separate estimate for site restoration costs is $43M.
For IP2, the revised total estimate to complete decommissioning for is $721M (in 2021 dollars) as shown in cash flow analysis in Table 2B. Of that total cost estimate, the revised estimate for license termination expenses is $475M, the current separate estimate of spent fuel management costs is $199M and the current separate estimate for site restoration costs is $46M.
For IP3, the revised total estimate to complete decommissioning for is $957M (in 2021 dollars) as shown in cash flow analysis in Table 2C. Of that total cost estimate, the revised estimate for license termination expenses is $582M, the current separate estimate of spent fuel management costs is $327M and the current separate estimate for site restoration costs is $48M.
C.
Current Decommissioning Fund Balance The IP1 Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2021, was
$655M, the IP2 NDT fund balance as of December 31, 2021, was $786M, and the IP3 NDT fund balance as of December 31, 2021, was $931M. These amounts represent the market value of the NDT fund as of December 31, 2021, 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 each of the respective Indian Point Trust funds 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 2019 HDI IPEC PSDAR/DCE (Reference 1) were provided in 2019 dollars.
The estimates provided in Tables 1A through 1C of this Enclosure have been inflated to 2021 dollars.
The Bureau of Labor Statistics (BLS) 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 1.06 to calculate the inflation to 2021 dollars. This is conservative as it does not credit the fixed price contracts.
F.
Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $5.992M (2021 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI PSDAR/DCE (Reference 1) 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 Holtec Indian Point 2, LLC, Holtec Indian Point 3, LLC, and HDI.
H.
Changes in the Decommissioning Funding Plan Trust Agreement After the license transfer and sale of the Indian Point site to Indian Point 2, LLC and Indian Point 3, LLC, the Provisional Decommissioning Trust for Nuclear Generating Units 1 & 2 expended all non-qualified funds for Unit 1. The custodian, BNY Mellon, was directed to terminate the trust since all the non-qualified funds were expended for Unit 1. The NRC was notified of the termination request to the custodian, BNY Mellon on November 10, 2021 (Reference 4). The termination of the Provisional Trust does not affect the funds governed by the Master Decommissioning Trust Agreement, which includes the Unit 1 qualified funds.
Refer to Tables 1A through 1C and 2A through 2C of this Enclosure for additional required reporting data for IP1, IP2 and IP3. Tables 2A through 2C provide cash flow analyses using revised decommissioning cost estimates developed by HDI. These cash flow analyses demonstrate that the IP1, IP2 and IP3 decommissioning trust funds are 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 IPEC.
In accordance with 10 CFR 50.82(a)(7), HDI is notifying the NRC of revisions to the decommissioning schedule from that described in the IPEC PSDAR. (Reference 1). HDI has updated its schedule to reflect the current decommissioning plan. The schedule revisions reflect actual work progress achieved since HDIs acquisition of the site and includes revisions to the work plan resulting from more detailed project planning and optimization since HDIs submittal of the IPEC PSDAR/DCE (Reference 1). HDI will further evaluate optimization of Reactor Pressure Vessel (RPV) segmentation and will now complete segmentation activities for the Reactor Vessel Internals and the RPV for Units 2 and 3 in 2024 and Unit 1 in 2025. Enclosure 5 provides the major decommissioning project milestones and their updated scheduled completion dates.
The estimate to complete and cash flow analyses provided in Tables 1A through 1C and 2A through 2C confirm that these schedule revisions are not financially 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 IPEC PSDAR (Reference 1).
References:
1.
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 (Accession No. ML19354A698) 2.
Letter, Entergy to US NRC, Decommissioning Funding Status Report per 10 CRF 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) - Entergy Nuclear Operations Inc, March 25, 2020 (Accession No. ML21084A811) 3.
Letter from US NRC to HDI, Indian Point Nuclear Generating Station, Unit Nos. 1, 2 and 3 Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Holtec Decommissioning International, LLC November 23, 2020 (Accession No. ML20309A781) 4.
Letter, Holtec Decommissioning International, LLC to US NRC, Notice of Termination of Provisional Trust Agreement, November 10, 2021 (Accession No. ML21314A416)
Tables 1A, 1B, and 1C Holtec Decommissioning International Indian Point Nuclear Generating Station Units 1, 2 & 3 Annual Decommissioning Financial Assurance and Spent Fuel Management Report ENCLOSURE 3 Table 1A Holtec Decommissioning International, LLC Indian Point Nuclear Generating Station Unit 1 Summary Information as of December 31, 2021 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) / (vii)(A)
Year Type of Trust Fund Balance (2021 $)
Comments 2021 Decommissioning Trust
$655M As of 12/31/2021; 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 2021
$18M
$2M
$0M
$20M 2021 Costs in as-Spent Dollars Total to Date
$18M
$2M
$0M
$20M 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 2021 Estimated
$30M
$3M
$0M
$33M Estimate in 2019 Dollars 2021 Actuals
$18M
$2M
$0M
$20M Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2022
$485M
$76M
$43M
$604M Estimated in 2021 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 3 Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C) / (vii)(C)
NONE ENCLOSURE 3 Table 1B Holtec Decommissioning International, LLC Indian Point Nuclear Generating Station Unit 2 Summary Information as of December 31, 2021 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) / (vii)(A)
Year Type of Trust Fund Balance (2021 $)
Comments 2021 Decommissioning Trust
$786M As of 12/31/2021; 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 2021
$33M
$20M
$0M
$53M 2021 Costs in as-Spent Dollars Total to Date
$33M
$20M
$0M
$53M 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 2021 Estimated
$43M
$27M
$0M
$70M Estimate in 2019 Dollars 2021 Actuals
$33M
$20M
$0M
$53M Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2022
$475M
$199M
$46M
$721M Estimated in 2021 Dollars. Columns may not add due to rounding.
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 3 Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C) / (vii)(C)
NONE ENCLOSURE 3 Table 1C Holtec Decommissioning International, LLC Indian Point Nuclear Generating Station Unit 3 Summary Information as of December 31, 2021 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) / (vii)(A)
Year Type of Trust Fund Balance (2021 $)
Comments 2021 Decommissioning Trust
$931M As of 12/31/2021; 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 2021
$38M
$63M
$0M
$101M 2021 Costs in as-Spent Dollars Total to Date
$38M
$63M
$0M
$101M 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 2021 Estimated
$64M
$47M
$0M
$111M Estimate in 2019 Dollars 2021 Actuals
$38M
$63M
$0M
$101M Remaining Decommissioning Estimated Cost 10 CFR 50.82(a)(8)(v)(B) / (vii)(B)
Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2022
$582M
$327M
$48M
$957M Estimated in 2021 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 3 Need for Additional Financial Assurance 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)(C) / (vii)(C)
NONE Tables 2A, 2B, and 2C Holtec Decommissioning International Indian Point Nuclear Generating Station Units 1, 2 & 3 Annual Decommissioning Cash Flow Analyses ENCLOSURE 3 Table 2A Indian Point Nuclear Generating Station Unit 1 - DECON Method Annual Cash Flow in Millions (2021 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 2022 52 2
1 55 6552
-683 12 599 2023 50 7
2 59 599
-59 11 551 2024 68 2
5 75 551
-75 10 486 2025 22 2
6 29 486
-29 9
466 2026 26 2
5 33 466
-33 9
441 2027 34 2
5 41 441
-41 8
408 2028 31 2
5 38 408
-38 7
378 2029 23 2
5 29 378
-29 7
355 2030 52 2
2 56 355
-56 6
306 2031 77 2
2 80 306
-80 5
230 2032 39 2
6 46 230
-46 4
188 2033 2
5 7
188
-7 4
184 2034 3
3 184
-3 4
185 2035 3
3 185
-3 4
186 2036 3
3 186
-3 4
186 2037 3
3 186
-3 4
187 2038 3
3 187
-3 4
187 2039 3
3 187
-3 4
188 2040 3
3 188
-3 4
189 2041 3
3 189
-3 4
189 2042 3
3 189
-3 4
190 2043 3
3 190
-3 4
191 2044 3
3 191
-3 4
191 2045 3
3 191
-3 4
192 2046 5
5 192
-5 4
190 2047
.2 5
5 190
-5 4
189 2048
.4
.4 189 4
193 2049
.4
.4 193 4
196 2050
.4
.4 196 4
200 2051
.4
.4 200 4
203 2052
.4
.4 203 4
207 2053
.4
.4 207 4
211 2054
.4
.4 211 4
214 2055 1
1 214
-1 4
218 2056 1
1 218
-1 4
222 2057 1
1 222
-1 4
225 2058 1
1 225
-1 4
229 2059 1
1 229
-1 5
233 2060 1
1 233
-1 5
237 2061 1
1 237
-1 5
241 2062
.3
.1
.3 241 5
245 Total4 485 76 43 604
-616 211 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2022 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2022 NDT Withdrawal Amount includes $13M for the reimbursement of HDIs 2021 expenses that were not reimbursed in 2021.
4 Columns may not add due to rounding ENCLOSURE 3 Table 2B Indian Point Nuclear Generating Station Unit 2 - DECON Method Annual Cash Flow in Millions (2021 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 2022 119 78 2
199 7862
-2283 11 569 2023 60 2
6 68 569
-68 10 511 2024 41 2
7 50 511
-50 9
470 2025 29 2
7 37 470
-37 9
441 2026 33 2
7 41 441
-41 8
408 2027 34 2
5 41 408
-41 7
374 2028 52 2
2 55 374
-55 6
325 2029 53 2
2 56 325
-56 5
274 2030 9
7 16 274
-16 5
263 2031 9
7 16 263
-16 5
252 2032 6
6 7
20 252
-20 5
237 2033 2
8 10 237
-10 5
232 2034 6
6 232
-6 5
230 2035 6
6 230
-6 4
228 2036 6
6 228
-6 4
226 2037 6
6 226
-6 4
224 2038 6
6 224
-6 4
222 2039 6
6 222
-6 4
220 2040 6
6 220
-6 4
218 2041 6
6 218
-6 4
216 2042 6
6 216
-6 4
214 2043 6
6 214
-6 4
211 2044 6
6 211
-6 4
209 2045 6
6 209
-6 4
207 2046 3
3 207
-3 4
207 2047
.2 1
1 207
-1 4
211 2048
.4
.4 211 4
214 2049
.4
.4 214 4
218 2050
.4
.4 218 4
222 2051
.4
.4 222 4
226 2052
.4
.4 226 5
230 2053
.4
.4 230 5
235 2054
.4
.4 235 5
239 2055 3
3 239
-3 5
240 2056 3
3 240
-3 5
241 2057 3
3 241
-3 5
243 2058 3
3 243
-3 5
244 2059 3
3 244
-3 5
245 2060 3
3 245
-3 5
247 2061 3
3 247
-3 5
248 2062 1
1 2
248
-2 5
251 Total4 475 199 46 721
-750 220 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2022 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2022 NDT Withdrawal Amount includes $29M for the reimbursement of HDIs 2021 expenses that were not reimbursed in 2021.
4 Columns may not add due to rounding ENCLOSURE 3 Table 2C Indian Point Nuclear Generating Station Unit 3 - DECON Method Annual Cash Flow in Millions (2021 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 2022 155 36 3
195 9312
-2433 14 702 2023 70 33 3
106 702
-106 12 608 2024 54 1
4 59 608
-59 11 560 2025 49 2
4 54 560
-54 10 515 2026 54 1
4 59 515
-59 9
466 2027 45 2
4 50 466
-50 8
424 2028 27 2
4 33 424
-33 8
399 2029 27 2
4 33 399
-33 7
373 2030 27 2
4 33 373
-33 7
347 2031 27 2
4 33 347
-33 6
320 2032 23 2
8 33 320
-33 6
293 2033 3
5 8
293
-8 6
291 2034 4
4 291
-4 6
293 2035 4
4 293
-4 6
295 2036 4
4 295
-4 6
297 2037 4
4 297
-4 6
299 2038 4
4 299
-4 6
301 2039 4
4 301
-4 6
304 2040 4
4 304
-4 6
306 2041 4
4 306
-4 6
308 2042 4
4 308
-4 6
310 2043 4
4 310
-4 6
312 2044 4
4 312
-4 6
315 2045 4
4 315
-4 6
317 2046 5
5 317
-5 6
319 2047 8
8 319
-8 6
317 2048 13 13 317
-13 6
311 2049 13 13 311
-13 6
304 2050 13 13 304
-13 6
297 2051 13 13 297
-13 6
290 2052 13 13 290
-13 6
283 2053 13 13 283
-13 5
276 2054 13 13 276
-13 5
268 2055 3
13 16 268
-16 5
258 2056 3
13 16 258
-16 5
247 2057 3
13 16 247
-16 5
236 2058 3
13 16 236
-16 4
225 2059 3
13 16 225
-16 4
213 2060 3
13 16 213
-16 4
201 2061 3
13 16 201
-16 4
189 2062 1
3 1
4 189
-4 4
188 Total4 582 327 48 957
-1005 266 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) 2 2022 Beginning of Year NDT Balance is net of realized tax liabilities 3 The 2022 NDT Withdrawal Amount includes $48M for the reimbursement of HDIs 2021 expenses that were not reimbursed in 2021.
4 Columns may not add due to rounding 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)
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)
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 2021 data. Table 1 shows the data used for this calculation.
Table 1: Northeast Region Labor Adjustment Factor Applicable Site Series ID 4Q2021 Index Number Labor Adjustment Factor (Lx)
Oyster Creek CIU2010000000210I 149.6 3.23 Pilgrim CIU2010000000210I 149.6 3.23 IPEC CIU2010000000210I 149.6 3.23 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 2021 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 2021 (preliminary value) 251.614 WPU0573 - December 2021 (preliminary value) 322.997 Industrial Electric Power Adjustment Factor - (PX) 2.203 Light Fuel Oil Adjustment Factor - (FX) 3.939 Energy Adjustment Factor - (BWR) 3.002 Energy Adjustment Factor - (PWR) 2.932 The waste burial adjustment factors are taken from Table 2-1 of NUREG-1307, Revision 18, based on 2021 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.
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 Generic LLW PWR IPEC N/A 12.793 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)
Escalation Factor 1986 Base Year $
Escalated
- Factor Oyster Creek (Lx) 3.23 0.65(L)+0.13(E)+0.22(B) 5.34
$648,014,501 (Ex) 3.002 (Bx) 12.948 Pilgrim (Lx) 3.23 0.65(L)+0.13(E)+0.22(B) 5.31
$649,738,251 (Ex) 3.002 (Bx) 12.837 IPEC (Lx) 3.23 0.65(L)+0.13(E)+0.22(B) 5.30 Unit 1 - $453,129,154 (Ex) 2.932 Unit 2 - $547,085,134 (Bx) 12.793 Unit 3 - $547,085,134 Holtec Decommissioning International Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Milestone Summary Holtec Decommissioning International Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Milestone Summary Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Updates (2021)
Notes Oyster Creek (PSDAR/DCE/LTA issued on 09/28/2018)
License Transfer 07/01/2019 07/01/2019 Complete Zirc Fire Elimination 09/17/2019 06/29/2019 Complete Fuel on Pad 06/23/2023 05/23/2021 Complete Segmentation RVI 02/03/2022 05/13/2022 Segmentation RPV 09/19/2022 08/19/2024 Partial Site Release 10/24/2025 11/03/2025 Fuel Shipment 03/28/2035 03/28/2035 License Termination 12/01/2035 12/03/2035 Pilgrim (PSDAR/DCE/LTA issued on 11/16/2018)
License Transfer 07/31/2019 08/26/2019 Complete Zirc Fire Elimination 03/30/2020 03/31/2020 Complete Fuel on Pad 11/26/2021 12/13/2021 Complete Segmentation RVI 10/12/2020 10/26/2022 Segmentation RPV 09/18/2022 12/31/2024 Partial Site Release 01/28/2025
[09/24/2027]
- 09/24/2027
- Schedule change incorporated in 2019 Annual Decommissioning Funding & Spent Fuel Management Report (ML20091M858)
Fuel Shipment 12/31/2062 12/31/2062 License Termination 09/07/2063 09/07/2063 Indian Point (PSDAR/DCE/LTA issued on 12/19/2019)
License Transfer 05/31/2021 05/28/2021 Complete Zirc Fire Elimination (#3) 09/15/2022 08/01/2022 Fuel on Pad (#3) 04/04/2024 10/31/2023 Segmentation RVI (#2) 12/21/2022 05/28/2024 Segmentation RPV (#1) 04/13/2024 11/20/2025 Partial Site Release 07/09/2033 07/09/2033 Fuel Shipment 12/30/2061 12/30/2061 License Termination 09/06/2062 09/06/2062