L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations

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Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
ML23090A140
Person / Time
Site: Palisades, Indian Point, Oyster Creek, Pilgrim, Big Rock Point, 07100963
Issue date: 03/31/2023
From: Fleming J
Holtec Decommissioning International
To:
Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
References
HDI-OC-23-016, HDI-PIL-23-003, HDI-IPEC-23-013, HDI PNP 2023-010
Download: ML23090A140 (53)
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Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.82 March 31, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1004 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 Palisades Nuclear Plant Docket No. 50-255 and 72-007 Renewed Facility Operating License No. DPR-20 Big Rock Point NRC Docket No. 50-155 License No. DPR-6

SUBJECT:

Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI)

In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR),

Part 50 Section 82, Termination of License, (10 CFR 50.82), Holtec Decommissioning International, LLC (HDI), on behalf of Oyster Creek Nuclear Generating Station (Oyster Creek), Pilgrim Nuclear Power Station (Pilgrim), Indian Point Nuclear Generating Station Units 1, 2 and 3 (IPEC), Palisades Nuclear Plant (PNP), and Big Rock Point (BRP), hereby submits the annual report on the status of decommissioning funding, the financial assurance report, and the status of funding for managing irradiated fuel for the period ending December 31, 2022.

The reports provided in Enclosures 1 through 5, for the licensed facilities addressed by this filing, provide the Annual Decommissioning Funding, Financial Assurance Report, and HDI-OC-23-016 HDI-PIL-23-003 HDI-IPEC-23-013 HDI PNP 2023-010 Page 1 of 4

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Irradiated Fuel Management Status for Oyster Creek, Pilgrim, IPEC, PNP, and BRP respectively.

Enclosure 6 to this letter provides the methodology used to calculate the formula cost amount per 10 CFR 50.75(c). Enclosure 7 to this letter provides the decommissioning milestone summary.

The estimates provided in Enclosures 1 through 5 using the December 31, 2022 trust fund balances, indicate that Oyster Creek, Pilgrim, IPEC, PNP, and BRP sites have met the NRCs funding requirements. Funding margins are lower than HDIs year-end 2021 report due to the combined effect of poor market performance and higher than usual inflation during 2022. These economic factors are not unique to HDI. The lower market value of trust fund investments in 2022, compounded over the life of the project in the cash flow reporting format, account for the considerable majority of the reduced funding margins.

HDI is taking steps to mitigate the long term effect of current market conditions by (1) deferring withdrawals of 2022 costs to avoid locking in market losses, and (2) flattening the schedule for some projects, where prudent, to defer costs until broader economic conditions return to historical norms. After accounting for higher than usual inflation over the past year, the estimates in this years report are consistent with prior years estimates (i.e., apart from economy-wide cost drivers, project costs have not materially changed).

Even with current market conditions, HDI continues to maintain sufficient funds to cover the remaining costs on each project. Accordingly, HDI concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the plants included in this submittal.

In Reference 1, HDI submitted the Report on the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (ISFSI) for Oyster Creek, Pilgrim and IPEC for the period ending December 31, 2021. In Reference 2, Entergy Nuclear Operations, Inc. (Entergy) submitted the Decommissioning Funding Status report for PNP and BRP for the period ending December 31, 2021.

On December 23, 2020, HDI submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) including Site-Specific Decommissioning Cost Estimates (DCE) for PNP (Reference 5). On June 28, 2022, the indirect transfer of control of Renewed Facility Operating License No. DPR-20 for Palisades and the general license for the Palisades Independent Spent Fuel Storage Installation (ISFSI) and Facility Operating License No.

DPR-6 for Big Rock Point and the general license for the Big Rock Point ISFSI was transferred to Holtec Palisades, LLC (Holtec Palisades); and the transfer of authority to conduct licensed activities at PNP to HDI (Reference 3 and 4).

HDI-OC-23-016 HDI-PIL-23-003 HDI-IPEC-23-013 HDI PNP 2023-010 Page 2 of 4

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 There are no regulatory commitments contained within this letter. Should you have any questions or require any further information, please contact me at (856) 797-0900 x 3578.

Sincerely, Digitally signed by Jean A.

Jean A. Fleming Fleming Date: 2023.03.31 10:26:10 -04'00' Jean A. Fleming Vice President, Licensing, Regulatory Affairs and PSA Holtec International

References:

1) Letter, Holtec Decommissioning International, LLC (HDI) to US Nuclear Regulatory Commission (US NRC), Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 25, 2022 (ML22084A059)
2) Letter from Entergy Nuclear Operations, Inc. (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 28, 2022 (ML22087A500)
3) Letter from Entergy to US NRC, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments, December 23, 2020 (ML20358A075)
4) Letter from US NRC to Entergy, Palisades Nuclear Plant and Big Rock Point Plant - Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendments (EPID L-2020-LLM-0003), December 13, 2021 (ML21292A145)
5) Letter from HDI to US NRC, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Palisades Nuclear Plant, December 20, 2020 (ML20358A232)

HDI-OC-23-016 HDI-PIL-23-003 HDI-IPEC-23-013 HDI PNP 2023-010 Page 3 of 4

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

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) Palisades Nuclear Plant Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report
5) Big Rock Point Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report
6) Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c)
7) Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Milestone Summary cc:

USNRC Regional Administrator, Region 1 USNRC Regional Administrator, Region 3 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 USNRC Senior Project Manager, NMSS - Palisades and BRP NRC Region 1 Lead Inspector - Oyster Creek NRC Region 1 Lead Inspector - Pilgrim Nuclear Power Station NRC Region 1 Lead Inspector, Indian Point Units 1, 2 & 3 NRC Region 3 Lead Inspector - Palisades Nuclear Site and BRP 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 HDI-OC-23-016 HDI-PIL-23-003 HDI-IPEC-23-013 HDI PNP 2023-010 Page 4 of 4

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel ManagementStatus and Financial Assurance Report As of December 31, 2022 As required by 10 CFR 50.82(a)(7), and 50.82(a)(8), Holtec Decommissioning International, LLC (HDI) reports the following information for Oyster Creek Nuclear Generating Station (Oyster Creek):

A. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B), 50.82(a)(8)(vii)(B)]

The required minimum funding assurance amount for Oyster Creek as of December 31, 2022 is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the HDI revised Post-Shutdown Decommissioning Activities Report (Reference 1) and amended in the annual report for the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations submitted for 2021 (Reference 2).

Table 1 of this Enclosure provides additional reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning. The revised total estimate to complete decommissioning for the Oyster Creek site is $362M (in 2022 dollars). Of that total cost estimate,the revised estimate for license termination expenses is $172M, the current separate estimate of spent fuel management costs is $161M and the current separate estimate for site restoration costs is $30M.

B. Decommissioning Fund Balance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(vii)(A)]

The Oyster Creek Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2022 was $395M. This amount represents the market value of the NDT fund as of December 31, 2022 net any material current income tax liability on realized gains, interest, dividends, and other income of the trust. The trust fund amount is the total available for decommissioning including costs of license termination, 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).

C. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earningson Funds, and Other Factors Used in Funding Projections [10 CFR 50.82(a)(8)(v)(B)]

In accordance with 10 CFR 50.75(e)(1)(i), HDI has assumed a 2% real rate of return.

The estimates in the 2018 HDI Oyster Creek Revised PSDAR/Decommissioning Cost Estimate (DCE) (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2022 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. HDI utilized NUREG-1307, Revision 19, issued February 2023, for the burial inflation factor. HDI has used a factor of 1.08 to calculate the inflation to 2022 dollars.

D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]

The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.42M (2022 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR/DCE (Reference

1) and amended in the report on the Status of Decommissioning Funding for Independent Spent Fuel Storage Installations (Reference 4) which were inflated using published inflation indices as discussed in Item (C).

E. Decommissioning Financial Assurance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(v)(D)]

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 the approval of the license transfer to Oyster Creek Environmental Protection (OCEP) and HDI. There have been no changes to the method of providing financial assurance since the last submitted report (Reference 2).

F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]

There have been no changes to the Oyster Creek Master Decommissioning Trust Agreement.

G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]

Milestone Schedule Update:

In accordance with 10 CFR 50.82(a)(7), HDI is notifying the US NRC that HDI is planning to delay the start of activities associated with the Reactor Pressure Vessel (RPV) segmentation and the partial site release milestone dates provided in the Oyster Creek revised PSDAR (Reference 1) and updated in the report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (Reference 2). There is no impact to the scheduled license termination date. The milestone extensions are due to the following factors:

  • Optimizing market conditions, including the effects of escalated inflation and labor, and preserving NDT fund growth by flattening the schedule and cost curves.
  • Ongoing site-specific characterization in support of potential free release of materials and waste minimization, specifically in the reactor and turbine buildings.

The RPV segmentation activities are aligned to coincide with the demolition of the reactor building. The movement of RPV segmentation activities maximizes efficiencies associated with waste management, reactor building characterization efforts, and contractor resource allocation for efficiency.

  • Thorough equipment and material processing to increase the reuse and recycling of materials and components.
  • Additional evaluation of RPV segmentation options based on industry lessons learned and innovative technologies.

Enclosure 7 provides the major decommissioning project milestones and their updated scheduled completion dates. HDI has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the Oyster Creek Revised PSDAR (Reference 1).

Enclosure 1 DCE Update:

The Oyster Creek DCE has been updated to reflect a 2030 Department of Energy (DOE) start date for spent fuel pick up. In the revised PSDAR (Reference 1), HDI assumed that DOE would begin removal of industry spent fuel in 2025, based on then-current information regarding DOEs plans for meeting its obligations, and that the DOE would complete removal of Oyster Creeks fuel by 2035. HDI has since reevaluated and updated its projected schedule for DOEs removal of Oyster Creek fuel. The most recent DOE planning document remains the 2013 Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste (Reference 5). The 2013 study contemplated an interim storage facility capable of storing at least 20,000 MTUs would begin accepting fuel from shutdown facilities beginning in 2025, with a larger repository following shortly thereafter.

While DOE has not progressed in lockstep with the 2013 strategy document, there are ongoing corporate and legislative initiatives aimed at providing interim storage options. Given this information, HDI believes it is reasonable to assume that a facility will be available to begin accepting industry fuel beginning in 2030.

Moreover, based on program cost and logistics and DOEs latest planning documents, it is reasonable to assume that DOE will prioritize removal of fuel from shut-down reactors like Oyster Creek and will do so in one mobilization campaign rather than multiple mobilization efforts extending over several years. Oyster Creek was the 18th commercial reactor to shut down in the U.S., placing about 6,800 MTUs of spent fuel from other shutdown plants ahead of Oyster Creek. Oyster Creek has about 800 MTUs of fuelmeaning its fuel will be removed under a shutdown paradigm when the program is capable of receiving 7,600 MTUs of fuel (6,800 + 800). At the commonly accepted transfer rate required by the Standard Contract (based on DOEs 1987 Annual Capacity Report), the program would reach a level capable of receiving 8,000 MTUs of cumulative industry fuel by 2035. Accordingly, under a shutdown first paradigm, it is reasonable to expect that DOE would be capable of completing all fuel pickup at Oyster Creek by 2035.

Tables 1 and 2 of this Enclosure provide additional required reporting data. Table 1 provides a summary of information as of December 31, 2022 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii). Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI.

The information provided in this enclosure 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.

References:

1) Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Oyster Creek Nuclear Generating Station, September 28, 2018 (ML18275A116)
2) Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 25, 2022 (ML22084A059)
3) Letter from US NRC to Exelon Generation Company, LLC, Oyster Creek Nuclear Power StationIssuance of Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)dated June 20, 2019 (ML19113A204)
4) Letter, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 17, 2021 (ML21350A264)
5) "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S. DOE, January 11, 2013.

Table 1 Holtec Decommissioning International Oyster Creek Nuclear Generating Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report

Enclosure 1 ENCLOSURE 1 Table 1 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Summary Information as of December 31, 2022 Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $395M As of 12/31/2022; net of tax liabilities Other Financial Assurance Methods Being Relied Upon - 10 CFR 50.82(a)(8)(v)(B)

NONE HDI Decommissioning Expenditures Since License Transfer - 10 CFR 50.82(a)(8)(v)(A)

Year License Termination Spent Fuel Mgmt Site Restoration Total1 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 2022 $63M $31M $1M $95M2 2022 Costs in as-Spent Dollars Total to Date $336M $243M $12M $591M 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 2022 Estimated $81M $39M $6M $125M Estimate in 2021 Dollars (Reference 2)

Variance due to Project Timing 2022 Actuals $63M $31M $1.4M $95M and Optimization Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total1 Comments 2023 $172M $161M $30M $362M Estimated in 2022 Dollars (Table 2)

Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 1 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1

Columns may not add due to rounding.

2

$61.7M of the $95M incurred in 2022 have not been reimbursed to date.

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 (2022 Dollars)

License Spent Fuel Site Beginning of Year Ending NDT Year Termination Management Restoration Total Costs Year NDT Withdrawal3 NDT Earnings1 Cost Cost Cost Balance Balance 2023 25.6 13.4 4.8 43.8 395.32 -43.8 7 358.6 2024 7.6 12.3 0 19.9 358.6 -19.9 6.7 345.4 2025 7.9 12.0 0 19.9 345.4 -19.9 6.5 332.0 2026 7.0 11.5 0 18.5 332 -18.5 6.3 319.8 2027 24 5.9 5.2 35.1 319.8 -35.1 5.7 290.4 2028 37.9 5.6 9.0 52.5 290.4 -83.4 4.1 211.1 2029 48.8 5.5 10.2 64.5 211.1 -95.3 2.3 118.1 2030 0 16.5 0 16.5 118.1 -16.5 2.0 103.7 2031 0 16.5 0 16.5 103.7 -16.5 1.7 89.0 2032 0 17.1 0 17.1 89 -17.1 1.4 73.3 2033 9.7 17.1 0 26.8 73.3 -26.8 0.9 47.5 2034 1.9 17.1 0 19.0 47.5 -19.0 0.6 29.0 2035 1.6 9.9 .8 12.4 29 -12.4 0.3 17.0 Total4 172 161 30 362 -424 46 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$49.2M relative to 12/31/21 baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities.

3 The NDT Withdrawal Amount includes $61.7M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 2 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel ManagementStatus and Financial Assurance Report As of December 31, 2022 As required by 10 CFR 50.82(a)(7), and 50.82(a)(8), Holtec Decommissioning International, LLC (HDI) reports the following information for Pilgrim Nuclear Power Station (Pilgrim):

A. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B), 50.82(a)(8)(vii)(B)]

The required minimum funding assurance amount for Pilgrim as of December 31, 2022 is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with10 CFR 50.82(a) and included in the HDI Revised Post-Shutdown Decommissioning Activities Report (Reference 1) and amended in the annual report for the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations submitted for 2021 (Reference 2).

Table 1 of this Enclosure provides additional reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning. The revised total estimate to complete decommissioning for the Pilgrim site is $586M (in 2022 dollars). Of that total cost estimate, the revised estimate for license termination expenses is $238M, the current separate estimate of spent fuel management costs is $328M and the current separate estimate for site restoration costs is $20M.

B. Decommissioning Fund Balance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(vii)(A)]

The Pilgrim Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2022 was $518M. This amount represents the market value of the NDT fund as of December 31, 2022 net any material current income tax liability on realized gains, interest, dividends, and other incomeof the trust. The trust fund amount is the total available for decommissioning including costs of license termination, 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).

C. Assumptions Regarding Rates of Escalation for Decommissioning Costs, Rates of Earnings on Funds, and Other Factors Used in Funding Projections [10 CFR 50.82(a)(8)(v)(B)]

In accordance with 10 CFR 50.75(e)(1)(i), HDI has assumed a 2% real rate of return.

The estimates in the 2018 HDI Pilgrim Revised PSDAR/Decommissioning Cost Estimate (DCE) (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2022 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. HDI utilized NUREG-1307, Revision 19, issued February 2023, for the burial inflation factor. HDI has used a factor of 1.04 to calculate the inflation to 2022 dollars.

D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]

The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $4.39M (2022 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR/DCE (Reference 1) and amended in the report on the Status of Decommissioning Funding for Independent Spent Fuel Storage Installations (Reference 5) which were inflated using published inflation indices as discussed in Item (C).

E. Decommissioning Financial Assurance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(v)(D)]

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 the approval of the license transfer to Holtec Pilgrim, LLC and HDI. There have been no changes to the method of providing financial assurance since the last submitted report (Reference 2).

F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]

By letter dated November 8, 2022 (Reference 4), HDI provided notification to the NRC of anticipated changes to the Holtec Pilgrim Master Decommissioning Trust Agreement. In accordance with Pilgrim License Condition 3.J.(5)(b) and 10 CFR 50.75(h)(1)(iii) written notification of any material changes to the decommissioning trust agreement is to be provided to the Director of the Office of Nuclear Reactor Regulation (NRR) or Nuclear Material Safety and Safeguards (NMSS) at least 30 working days before the proposed effective date of the amendment. The proposed changes to the Holtec Pilgrim, LLC Nuclear Master Decommissioning Trust Agreement took effect on December 23, 2022.

Compliance with the requirements of 10 CFR 50.75(h) remained intact and the proposed changes to the trust agreement included:

  • Standardizing compliance language to address the Pilgrim operating license conditions and the requirements of 50.75(h)(1)(iii) that are applicable to the other HDI operated facilities.

G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]

In accordance with 10 CFR 50.82(a)(7), HDI is notifying the NRC that HDI is planning to delay the start of activities associated with the Reactor Pressure Vessel (RPV) segmentation and partial site release milestone dates provided in the Pilgrim revised PSDAR (Reference 1) and updated in the report on the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (Reference 2). There is no impact to the scheduled license termination date. The milestone extensions are due to the following factors:

  • Optimizing market conditions, including the effects of escalated inflation and labor, and preserving NDT fund growth by flattening the schedule and cost curves.
  • Ongoing site-specific characterization in support of potential free release of materials and waste minimization, specifically in the reactor and turbine buildings.

The RPV segmentation activities are aligned to coincide with the demolition of the reactor building. The movement of RPV segmentation activities maximizes efficiencies associated with waste management, reactor building characterization efforts, and contractor resource allocation.

  • Uncertainty associated with the projected timeline of the Pilgrim NPDES permit modification process.
  • Additional evaluation of Reactor Pressure Vessel (RPV) segmentation options based on industry lessons learned and innovative technologies.

provides the major decommissioning project milestones and their updated scheduled completion dates. HDI has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the HDI Revised PSDAR(Reference 1).

Tables 1 and 2 of this Enclosure provide additional required reporting data. Table 1 provides a summary of information as of December 31, 2022 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii). Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI.

The information provided in this enclosure 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.

References:

1) Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning CostEstimate for Pilgrim Nuclear Power Station, November 16, 2018 (ML18320A040)
2) Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 25, 2022 (ML22084A059)
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 (ML19192A083)
4) Letter from HDI to NRC, Holtec Pilgrim, LLC Nuclear Decommissioning Trust Fund Agreement November 8, 2022 (ML ML22312A410)
5) Letter, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 17, 2021 (ML21350A264)

Table 1 Holtec Decommissioning International Pilgrim Nuclear Power Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report

Enclosure 2 ENCLOSURE 2 Table 1 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Summary Information as of December 31, 2022 Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $518M As of 12/31/2022; net of tax liabilities Other Financial Assurance Methods Being Relied Upon - 10 CFR 50.82(a)(8)(v)(B)

NONE HDI Decommissioning Expenditures Since License Transfer - 10 CFR 50.82(a)(8)(v)(A)

Year License Termination Spent Fuel Mgmt1 Site Restoration Total1 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 2022 $64M $28M $7M $99M2 2022 Costs in as-Spent Dollars Total Spent to Date $320M $265M $12M $596M 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 2022 Estimated $91M $29M $7M $127M Estimate in 2021 Dollars Variance due to project timing 2022 Actuals $64M $28M $7M $99M and optimization Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2023 $238M $328M $20M $586M Estimated in 2022 Dollars Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 2 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1

Columns may not add due to rounding.

2 $45.6M of the $99M incurred in 2022 have not been reimbursed to date.

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 (2022 Dollars)

License Spent Fuel Site Beginning of Year Ending NDT Year Termination Management Restoration Total Costs Year NDT Withdrawal3 NDT Earnings1 Cost Cost Cost Balance Balance 2023 44 13 5 63 5182 -63 9 464 2024 9 10 0 19 464 -19 9 455 2025 9 10 0 19 455 -19 9 444 2026 8 10 0 18 444 -18 9 435 2027 25 8 0 33 435 -33 8 410 2028 25 7 7 38 410 -38 7 379 2029 38 7 3 48 379 -48 7 337 2030 37 8 2 48 337 -48 6 295 2031 27 9 2 38 295 -38 5 263 2032 0 8 0 8 263 -31 5 237 2033 0 8 0 8 237 -31 4 210 2034 0 8 0 8 210 -8 4 206 2035 0 8 0 8 206 -8 4 202 2036 0 8 0 8 202 -8 4 198 2037 0 8 0 8 198 -8 4 194 2038 0 8 0 8 194 -8 4 190 2039 0 8 0 8 190 -8 4 186 2040 0 8 0 8 186 -8 4 182 2041 0 8 0 8 182 -8 3 177 2042 0 8 0 8 177 -8 3 173 2043 0 8 0 8 173 -8 3 168 2044 0 8 0 8 168 -8 3 164 2045 0 8 0 8 164 -8 3 159 2046 0 8 0 8 159 -8 3 154 2047 0 8 0 8 154 -8 3 149 2048 0 8 0 8 149 -8 3 144 2049 0 8 0 8 144 -8 3 139 2050 0 8 0 8 139 -8 3 134 2051 0 8 0 8 134 -8 3 129 2052 0 8 0 8 129 -8 2 123 2053 0 8 0 8 123 -8 2 118 2054 0 8 0 8 118 -8 2 112 2055 0 8 0 8 112 -8 2 106 2056 0 8 0 8 106 -8 2 100 2057 0 8 0 8 100 -8 2 94 2058 0 8 0 8 94 -8 2 88 2059 0 8 0 8 88 -8 2 82 2060 5 8 0 13 82 -13 1 71 2061 5 8 0 13 71 -13 1 60 2062 5 8 0 13 60 -13 1 48 2063 1 3 1 4 48 -4 1 44 Total4 238 328 20 586 -639 146 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$49.2M relative to 12/31/21 baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities 3 The NDT Withdrawal Amount includes $61.7M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 3 Holtec Decommissioning International Indian Point Units 1, 2 and 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 Holtec Decommissioning International Indian Point Units 1, 2 & 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 As required by 10 CFR 50.82(a)(7), and 50.82(a)(8), Holtec Decommissioning International, LLC (HDI) reports the following information for Indian Points Units 1, 2 and 3 (IP1, IP2, and IP3),

collectively referred to as Indian Point Energy Center (IPEC):

A. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B), 50.82(a)(8)(vii)(B)]

The required minimum funding assurance amounts for IPEC, as of December 31, 2022, 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) and amended in the annual report on the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations submitted for 2021 (Reference 2).

Tables 1A through 1C of this Enclosure provide additional reporting requirements and includes HDIs revised total estimate information as required by 10 CFR 50.82 based on the DECON method of decommissioning.

IP1 - The revised total estimate to complete decommissioning is $629M (in 2022 dollars) as shown in Table 1A. Of that total cost estimate, the revised estimate for license termination expenses is $462M, the current separate estimate of spent fuel management costs is $123M and the current separate estimate for site restoration costs is $43M.

IP2 - The revised total estimate to complete decommissioning for is $635M (in 2022 dollars) as shown in Table 1B. Of that total cost estimate, the revised estimate for license termination expenses is $380M, the current separate estimate of spent fuel management costs is $210M and the current separate estimate for site restoration costs is $45M.

IP3 - The revised total estimate to complete decommissioning for is $770M (in 2022 dollars) as shown in Table 1C. Of that total cost estimate, the revised estimate for license termination expenses is $450M, the current separate estimate of spent fuel management costs is $272M and the current separate estimate for site restoration costs is $48M.

B. Decommissioning Fund Balance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(vii)(A)]

The IPEC Nuclear Decommissioning Trust (NDT) fund balances as of December 31, 2022, are listed in the table below:

Unit NDT Fund Balance (as of Comment December 31, 2022)

IP1 $558M Rounded to the nearest million IP2 $619M IP3 $742M These amounts represent the market value of the NDT fund as of December 31, 2022, net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. 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).

C. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earningson Funds, and Other Factors Used in Funding Projections [10 CFR 50.82(a)(8)(v)(B)]

In accordance with 10 CFR 50.75(e)(1)(i), HDI has assumed a 2% real rate of return.

The estimates in the 2019 HDI IPEC PSDAR/Decommissioning Cost Estimate (DCE)

(Reference 1) were provided in 2019 dollars. The estimates provided in Table 1A-1C of this Enclosure have been inflated to 2022 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. HDI utilized NUREG-1307, Revision 19, issued February 2023, for the burial inflation factor. HDI has used a factor of 1.06 for IP1, 1.05 for IP2, and 1.06 for IP3 to calculate the inflation to 2022 dollars.

D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]

The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $7.6M (2022 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR/DCE (Reference 1) and amended in the report on the Status of Decommissioning Funding for Independent Spent Fuel Storage Installations (Reference 5) which were inflated using published inflation indices as discussed in Item (C).

E. Decommissioning Financial Assurance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(v)(D)]

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 the approval of the license transfer to Holtec Indian Point and HDI. There have been no changes to the method of providing financial assurance since the last submitted report (Reference 2).

F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)] By letter dated November 17, 2022 (Reference 4) HDI provided notification to the NRC of anticipated changes to the Nuclear Decommissioning Master Trust Agreement for Indian Point Units 1 and 2 and Indian Point 3. In accordance with 10 CFR 50.75(h)(iii), written notification of any material changes to the decommissioning trust agreement is to be provided to the Director of the Office of Nuclear Reactor Regulation (NRR) or Director of the Office of Nuclear Material Safety and Safeguards (NMSS) at least 30 working days before the proposed effective date of the amendment. The proposed changes to the IPEC Nuclear Decommissioning Master Trust Agreement took effect on December 14, 2022.

Compliance with the requirements of 10 CFR 50.75(h) remained intact and the proposed changes to the trust agreement included:

  • Change of Trustee to Northern Trust
  • Trust Agreements will reflect trustees updated standard terms and conditions G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]

In accordance with 10 CFR 50.82(a)(7), HDI is notifying the US NRC that HDI is planning to delay the start of activities associated with the reactor pressure vessel (RPV) and reactor vessel internals (RVI) segmentation milestone dates provided in the IPEC PSDAR (Reference 1) and updated in the report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations (Reference 2). There is no impact to the milestones for partial site release or overall scheduled license termination date. The milestone extension of segmentation activities are due to the following factors:

  • Optimizing market conditions, including the effects of escalated inflation and labor, and preserving NDT fund growth by flattening the schedule and cost curves.
  • RPV segmentation activities are aligned to be performed in series. The movement of RPV segmentation activities maximizes efficiencies associated with waste management, reactor building characterization efforts, and contractor resource allocations for efficiency.
  • IP2 RPV segmentation activities are aligned to permit the segmentation of Steam Generators within the reactor cavity, if required.
  • Additional evaluation of IP1 RPV segmentation options based on industry lessons learned and innovative technologies.

Enclosure 7 provides the major decommissioning project milestones and their updated scheduled completion dates. HDI has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the HDI IPEC PSDAR(Reference 1).

Tables 1A through C and 2A through C of this Enclosure provide additional required reporting data for IP1, IP2 and IP3. Table 1A through 1C provides a summary of information as of December 31, 2022 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii). Tables 2A through 2C provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI.

The information provided in this enclosure demonstrates that the IPEC 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.

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 (ML19354A698)
2) Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 25, 2022)
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, LLCNovember 23, 2020 (ML20309A781)
4) Letter from HDI to NRC, Holtec Indian Point 2, LLC Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Units 1 and 2 and Holtec Indian Point 3, LLC Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Unit 3 November 17, 2022 (ML22321A286)
5) Letter, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 17, 2021 (ML21350A264)

Table 1A, 1B, and 1C Holtec Decommissioning International Indian Point Units 1, 2 & 3 Annual Decommissioning Financial Assurance and Spent Fuel Management Report

Enclosure 3 ENCLOSURE 3 Table 1A Holtec Decommissioning International, LLC Indian Point Unit 1 Summary Information as of December 31, 2022 Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $558M As of 12/31/2022; 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 Since License Transfer - 10 CFR 50.82(a)(8)(v)(A)

Year License Termination1 Spent Fuel Mgmt Site Restoration Total1 Comments 2021 $18M $2M $0M $20M 2021 Costs in as-Spent Dollars 2022 $32M $-1M* $0.6M $32M2 2022 Costs in as-Spent Dollars Total to Date $51M $1M $0.6M $52M 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 2022 Estimated $52M $2M $1M $55M Estimate in 2022 Dollars (Reference 2)

  • 2021 IP1 SFM accrual designated as IP1 2022 Actuals $32M $-1M* $0.6M $32M costs should have been designated as IP2 and IP3 SFM costs. HDI identified this issue prior to withdrawal from the IP1 NDT. Reallocated IP1 accrual to IP2 and IP3 SFM in 2022.

Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2023 $462M $123M $43M $629M Estimated in 2022 Dollars (Table 2A)

Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 3 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1 Columns may not add due to rounding.

2

$25.2M of the $32M incurred in 2022 have not been reimbursed to date.

ENCLOSURE 3 Table 1B Holtec Decommissioning International, LLC Indian Point Unit 2 Summary Information as of December 31, 202210 CFR Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $619M As of 12/31/2022; net of tax liabilities Other Financial Assurance Methods Being Relied Upon - 10 CFR 50.82(a)(8)(v)(B)

NONE HDI Decommissioning Expenditures Since License Transfer - 10 CFR 50.82(a)(8)(v)(A)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2021 $33M $20M $0M $53M 2021 Costs in as-Spent Dollars 2022 $76M $73M $1M $150M1 2022 Costs in as-Spent Dollars Total to Date $109M $93M $1M $203M 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 2022 Estimated $119M $78M $2M $199M Estimate in 2021 Dollars (Reference 2)

Variance due to Project Timing 2022 Actuals $76M $73M $1M $150M and Optimization Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2023 $380M $210M $45M $635M Estimated in 2022 Dollars (Table 2B)

Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 3 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1 $100M of the $150M incurred in 2022 have not been reimbursed to date.

ENCLOSURE 3 Table 1C Holtec Decommissioning International, LLC Indian Point Unit 3 Summary Information as of December 31, 2022 10 CFR 50.82(a)(8)(v)-(vii)

Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $742M As of 12/31/2022; net of tax liabilities Other Financial Assurance Methods Being Relied Upon - 10 CFR 50.82(a)(8)(v)(B)

NONE HDI Decommissioning Expenditures Since License Transfer - 10 CFR 50.82(a)(8)(v)(A)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2021 $38M $63M $0M $101M 2021 Costs in as-Spent Dollars 2022 $103M $44M $1M $148M1 2022 Costs in as-Spent Dollars Total to Date $141M $107M $1M $249M 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 2022 Estimated $155M $36M $3M $195M Estimate in 2021 Dollars (Reference 2)

Variance due to Project Timing 2022 Actuals $103M $44M $1M $148M and Optimization Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2022 $450M $272M $48M $770M Estimated in 2022 Dollars (Table 2C)

Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 3 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1 $97M of the $148M incurred in 2022 have not been reimbursed to date.

Table 2A, 2B, 2C Holtec Decommissioning International Indian Point Units 1, 2 & 3 Annual Decommissioning Cash Flow Analysis

Enclosure 3 ENCLOSURE 3 Table 2A Indian Point Nuclear Generating Station Unit 1 - DECON Method Annual Cash Flow in Millions (2022 Dollars) 50.75 50.54(bb) Site Beginning of Year Ending NDT Year Restoration Total Costs Year NDT Withdrawal3 NDT License Spent Fuel Earnings1 Cost Balance Balance Termination Management Cost Cost 2023 28.5 3.2 3.8 35.6 557.62 -35.6 10.4 532.5 2024 45.2 1.9 5.0 52.1 532.5 -52.1 9.6 489.9 2025 46.4 1.7 4.9 53.0 489.9 -53.1 8.7 445.6 2026 53.2 1.7 4.2 59.0 445.6 -59.0 7.7 394.3 2027 42.7 1.8 4.6 49.0 394.3 -49.0 6.9 352.2 2028 31.3 1.8 5.4 38.6 352.2 -38.6 6.3 319.9 2029 24.1 1.9 5.1 31.2 320.0 -31.2 5.8 294.5 2030 52.1 1.7 1.9 55.8 294.5 -55.8 4.8 243.5 2031 81.6 1.7 1.6 84.9 243.5 -84.9 3.2 161.8 2032 45.3 1.7 6.6 53.7 161.8 -53.7 2.1 110.3 2033 2.5 4.9 0 7.3 110.3 -7.3 2,.1 105.0 2034 0 3.2 0 3.2 105.0 -3.2 2.0 103.8 2035 0 3.2 0 3.2 103.8 -3.2 2.0 102.6 2036 0 3.2 0 3.2 102.6 -3.2 2.0 101.4 2037 0 3.2 0 3.2 101.4 -3.2 2.0 100.1 2038 0 3.2 0 3.2 100.1 -3.2 1.9 98.9 2039 0 3.2 0 3.2 98.9 -3.2 1.9 97.5 2040 0 3.2 0 3.2 97.5 -3.2 1.9 96.2 2041 0 3.2 0 3.2 96.2 -3.2 1.9 94.8 2042 0 3.2 0 3.2 94.8 -3.2 1.8 93.5 2043 0 3.2 0 3.2 93.5 -3.2 1.8 92.0 2044 0 3.2 0 3.2 92.0 -3.2 1.8 90.6 2045 0 3.2 0 3.2 90.6 -3.2 1.7 89.1 2046 0 5.8 0 5.8 89.1 -5.8 1.7 85.0 2047 .16 5.6 0 5.8 85.0 -5.8 1.6 80.8 2048 .43 3.5 0 3.9 80.8 -3.9 1.5 78.4 2049 .43 3.5 0 3.9 78.4 -3.9 1.5 76.0 2050 .43 3.5 0 3.9 75.9 -3.9 1.4 73.4 2051 .43 3.5 0 3.9 73.4 -3.9 1.4 70.9 2052 .43 3.5 0 3.9 70.9 -3.9 1.3 68.3 2053 .43 3.5 0 3.9 68.3 -3.9 1.3 65.6 2054 .43 3.5 0 3.9 65.6 -3.9 1.2 63.0 2055 .8 3.5 0 4.3 62.9 -4.3 1.2 59.8 2056 .8 3.5 0 4.3 59.8 -4.3 1.1 56.6 2057 .8 3.5 0 4.3 56.6 -4.3 1.0 53.3 2058 .8 3.5 0 4.3 53.3 -4.3 1.0 50.0 2059 .8 3.5 0 4.3 50.0 -4.3 .9 46.6 2060 .8 3.5 0 4.3 46.6 -4.3 .9 43.2 2061 .8 3.5 0 4.3 43.2 -4.3 .8 39.6 2062 .3 0 .1 .4 39.6 -25.5 .3 14.4 2063 0 0 0 0 14.4 14.4 Total4 462 123 43 629 -654 110 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$78.5M relative to 12/31/21 baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities 3 The NDT Withdrawal Amount includes $25M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Enclosure 3 ENCLOSURE 3 Table 2B Indian Point Nuclear Generating Station Unit 2 - DECON Method Annual Cash Flow in Millions (2022 Dollars) 50.75 50.54(bb) Site Beginning of Year Ending NDT Year Restoration Total Costs Year NDT Withdrawal3 NDT License Spent Fuel Earnings1 Cost Balance Balance Termination Management Cost Cost 2023 64.6 32.9 2.8 100.3 618.82 -100.3 10.4 528.9 2024 43.6 1.9 6.7 52.2 528.9 -53.9 9.5 484.5 2025 32.5 1.7 6.7 40.9 484.5 -42.6 8.8 450.7 2026 37.2 1.7 9.3 48.2 450.7 -49.9 8.0 408.9 2027 38.5 1.8 6.7 46.9 408.9 -48.6 7.2 367.5 2028 51.6 1.8 1.9 55.2 367.5 -56.8 6.2 316.8 2029 53.3 1.7 2 57.0 316.8 -58.7 5.2 263.3 2030 10.8 7.3 0 18.1 263.3 -19.8 4.9 248.3 2031 9.4 7.7 0 17.0 248.3 -18.7 4.6 234.3 2032 6.6 6.6 7.5 20.7 234.2 -22.3 4.2 216.2 2033 2.1 8.6 0 10.7 216.1 -12.4 4.1 207.8 2034 0 6.7 0 6.7 207.8 -8.3 4.0 203.5 2035 0 6.7 0 6.7 203.5 -8.4 3.9 199.0 2036 0 6.7 0 6.7 199.0 -8.4 3.8 194.5 2037 0 6.7 0 6.7 194.5 -8.4 3.7 189.8 2038 0 6.7 0 6.7 189.8 -8.3 3.6 185.1 2039 0 6.7 0 6.7 185.1 -8.4 3.5 180.3 2040 0 6.7 0 6.7 180.3 -8.4 3.4 175.4 2041 0 6.7 0 6.7 175.4 -8.4 3.3 170.4 2042 0 6.7 0 6.7 170.4 -8.4 3.2 165.2 2043 0 6.7 0 6.7 165.2 -8.4 3.1 160.0 2044 0 6.7 0 6.7 160.0 -8.4 3.0 154.7 2045 0 6.7 0 6.7 154.7 -8.3 2.9 149.3 2046 0 3.5 0 3.5 149.3 -5.2 2.9 147.0 2047 .2 3.7 0 3.9 147.0 -5.5 2.8 144.3 2048 .4 3.5 0 3.9 144.2 -5.6 2.8 138.6 2049 .4 3.5 0 3.9 141.4 -5.6 2.7 135.7 2050 .4 3.5 0 3.9 138.6 -5.6 2.7 132.7 2051 .4 3.5 0 3.9 136.7 -5.6 2.6 133.4 2052 .4 3.5 0 3.9 132.7 -5.6 2.5 130.4 2053 .4 3.5 0 3.9 129.6 -5.6 2.5 129.6 2054 .4 3.5 0 3.9 126.5 -3.9 2.5 126.5 2055 3.7 3.5 0 7.1 125.0 -7.1 2.4 125.0 2056 3.7 3.5 0 7.1 120.3 -7.2 2.3 115.4 2057 3.7 3.5 0 7.1 115.4 -7.1 2.2 110.4 2058 3.7 3.5 0 7.1 110.4 -7.1 2.1 105.3 2059 3.7 3.5 0 7.1 105.3 -7.1 2.0 101.2 2060 3.7 3.5 0 7.1 100.2 -7.2 1.9 94.9 2061 3.7 3.5 0 7.1 94.9 -7.1 1.8 89.5 2062 1.3 0 1.3 2.5 89.5 -52.5 .74 37.7 2063 0 0 0 0 37.7 0 0 37.7 Total4 380 210 45 635 -735 154 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$93.9M relative to 12/31/21 baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities 3 The NDT Withdrawal Amount includes $100M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Enclosure 3 ENCLOSURE 3 Table 2C Indian Point Nuclear Generating Station Unit 3 - DECON Method Annual Cash Flow in Millions (2022 Dollars) 50.75 50.54(bb) Site Beginning of Year Ending NDT Year Restoration Total Costs Year NDT Withdrawal3 NDT License Spent Fuel Earnings1 Cost Balance Balance Termination Management Cost Cost 2023 77.5 102.4 4.3 184.2 741.72 -184.2 11.2 568.7 2024 45.9 1.3 4.1 51.3 568.7 -52.9 10.3 526.1 2025 41.4 1.6 3.9 46.9 526.1 -48.6 9.6 487.1 2026 47.0 1.5 3.8 52.4 487.1 -54.0 8.7 441.7 2027 41.5 1.7 4.1 47.3 441.7 -49.0 7.9 400.6 2028 37.3 1.7 4.2 43.2 400.6 -44.8 7.1 362.9 2029 37.5 1.7 4.3 43.5 362.9 -45.2 6.4 324.0 2030 38.6 1.7 4.3 44.6 324.1 -46.2 5.6 283.4 2031 30.9 1.8 4.5 37.2 283.4 -38.8 4.9 249.5 2032 26.5 1.7 8.8 37.0 249.5 -38.6 4.2 215.1 2033 2.7 5.4 0 8.1 215.1 -9.7 4.1 209.5 2034 0 4.0 0 4.0 209.5 -5.7 4.1 207.9 2035 0 4.0 0 4.0 209.1 -5.7 4.0 206.3 2036 0 4.0 0 4.0 207.9 -5.7 4.0 204.7 2037 0 4.0 0 4.0 206.3 -5.7 4.0 203.0 2038 0 4.0 0 4.0 204.7 -5.7 3.9 201.3 2039 0 4.0 0 4.0 203.0 -5.7 3.9 199.5 2040 0 4.0 0 4.0 201.3 -5.7 3.9 197.8 2041 0 4.0 0 4.0 199.6 -5.7 3.8 196.0 2042 0 4.0 0 4.0 197.8 -5.7 3.8 194.1 2043 0 4.0 0 4.0 196.0 -5.7 3.8 192.2 2044 0 4.0 0 4.0 194.1 -5.7 3.7 190.3 2045 0 4.0 0 4.0 192.3 -5.7 3.7 188.3 2046 0 5.0 0 5.0 190.3 -6.6 3.6 185.4 2047 0 4.7 0 4.7 188.3 -6.3 3.6 182.7 2048 0 6.4 0 6.4 184.4 -8.0 3.5 178.2 2049 0 6.3 0 6.3 182.7 -8.0 3.4 173.6 2050 0 6.4 0 6.4 178.2 -8.0 3.3 168.9 2051 0 6.3 0 6.3 173.6 -8.0 3.2 164.2 2052 0 6.4 0 6.4 168.9 -8.0 3.1 159.3 2053 0 6.4 0 6.4 164.2 -8.0 3.0 154.4 2054 0 6.4 0 6.4 159.3 -6.4 3.0 151.0 2055 3.2 6.3 0 9.6 154.4 -9.6 2.8 144.3 2056 3.2 6.4 0 9.6 151.0 -9.6 2.7 137.3 2057 3.2 6.4 0 9.6 144.3 -9.6 2.6 130.3 2058 3.2 6.4 0 9.6 137.3 -9.6 2.4 123.1 2059 3.2 6.4 0 9.6 130.3 -9.6 2.3 115.8 2060 3.2 6.4 0 9.6 123.1 -9.6 2.1 108.3 2061 3.2 6.3 0 9.5 108.3 -9.6 2.0 100.7 2062 .87 2.8 1.1 4.7 100.7 -53.3 .95 48.4 2063 0 0 0 0 48.4 0 48.4 Total4 450 272 48 770 -867 174 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$90.3M relative to 12/31/21 baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities.

3 The NDT Withdrawal Amount includes $97M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 4 Holtec Decommissioning International Palisades Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 Holtec Decommissioning International Palisades Nuclear Plant Annual Decommissioning Funding and Spent Fuel ManagementStatus and Financial Assurance Report As of December 31, 2022 As required by 10 CFR 50.82(a)(8), Holtec Decommissioning International, LLC (HDI) reports the following information for Palisades Nuclear Plant (PNP):

A. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B), 50.82(a)(8)(vii)(B)]

The required minimum funding assurance amount for PNP as of December 31, 2022 is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with10 CFR 50.82(a) and included in the HDI Post-Shutdown Decommissioning Activities Report (Reference 1).

Table 1 of this Enclosure provides additional reporting requirements and includes the HDI revised total estimate information as required by 10 CFR 50.82 based on the DECON method of decommissioning. The revised total estimate to complete decommissioning for the PNP site is $633M (in 2022 dollars). Of that total cost estimate, the revised estimate for license termination expenses is $447M, the current separate estimate of spent fuel management costs is $146M and the current separate estimate for site restoration costs is $39M.

B. Decommissioning Fund Balance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(vii)(A)]

The Palisades Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2022 was $547M. This amount represents the market value of the NDT fund as of December 31, 2022 net any material current income tax liability on realized gains, interest, dividends, and other income of the trust. The trust fund amount is the total available for decommissioning including costs of license termination, 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 Palisades trust fund to be used for site irradiated fuel management and site restoration costs (Reference 2).

C. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earningson Funds, and Other Factors Used in Funding Projections [10 CFR 50.82(a)(8)(v)(B)]

In accordance with 10 CFR 50.75(e)(1)(i), HDI has assumed a 2% real rate of return.

The estimates in the 2020 HDI Palisades PSDAR/Decommissioning Cost Estimate (DCE)

(Reference 1) were provided in 2020 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2022 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. HDI utilized NUREG-1307, Revision 19, issued February 2023, for the burial inflation factor. HDI has used a factor of 1.09 to calculate the inflation to 2022 dollars.

D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]

The current detailed site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $10.1M (2022 dollars). The ISFSI estimated costs are based on the estimated costs provided in the Entergy ISFSI Decommissioning Funding Plans (Reference 5) which have been inflated using published inflation indices as discussed in Item (C).

E. Decommissioning Financial Assurance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(v)(D)]

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 Holtec Palisades, LLC and HDI. There have been no changes to the method of providing financial assurance since the indirect transfer of control of Renewed Facility Operating License No. DPR-20 for Palisades and the general license for the Palisades ISFSI was transferred to Holtec Palisades, LLC (Holtec Palisades) and the transfer of authority to conduct licensed activities at PNP to HDI was executed on June 28, 2022 (Reference 3).

F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]

By letter dated November 17, 2022 (Reference 4), HDI provided notification to the NRC of anticipated changes to the Master Decommissioning Trust Agreement for Palisades Nuclear Plant (PNP). In accordance with 10 CFR 50.75(h)(iii), written notification of any material changes to the decommissioning trust agreement is to be provided to the Director of the Office of Nuclear Reactor Regulation (NRR) or Director of the Office of Nuclear Material Safety and Safeguards (NMSS) at least 30 working days before the proposed effective date of the amendment. The proposed changes to the Palisades Master Decommissioning Trust Agreement took effect on December 14, 2022.

Compliance with the requirements of 10 CFR 50.75(h) remained intact and the proposed changes to the trust agreement included:

  • Change of Trustee to Northern Trust
  • Trust Agreement reflects new custodian language and investment standards.

G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]

HDI has evaluated decommissioning activities, cost, and schedule against the Palisades PSDAR and determined that there are no activities inconsistent with, or scheduled impacts that constitute a significant change to, nor any financially significant cost increase from the description in the PSDAR. provides the major decommissioning project milestones and their updated scheduled completion dates. HDI has confirmed that the changes to the schedule remain bounded by the environmental evaluation included in the HDI Palisades PSDAR (Reference 1).

Tables 1 and 2 of this Enclosure contain additional required reporting data. Table 1 provides a summary of information as of December 31, 2022 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii). Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by HDI.

The information provided in this enclosure demonstrates that the Palisades 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.

References:

1) Letter, Holtec Decommissioning International, LLC (HDI) to US NRC, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Palisade Nuclear Plant, December 23, 2020 (ML20358A232)
2) Letter from US NRC to HDI, Palisades Nuclear Plant 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 December 13, 2021 (ML2186A294)
3) Letter from US NRC to Entergy, Palisades Nuclear Plant and Big Rock Point Plant -

Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendments (EPID L-2020-LLM-0003), December 13, 2021 (ML21292A145)

4) Letter from HDI to US NRC, Amended and Restated Holtec Palisades, LLC Master Decommissioning Trust Agreement for Palisades Nuclear Plant November 17, 2022 (ML22321A285)
5) Letter from Entergy Nuclear Operations , Inc (Entergy) to US NRC, ISFSI Decommissioning Funding Plans (10 CFR 72.30) December 15, 2021 (ML21349A374)

Table 1 Holtec Decommissioning International Palisades Nuclear Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report

Enclosure 4 ENCLOSURE 4 Table 1 Holtec Decommissioning International, LLC Palisades Nuclear Power Station Summary Information as of December 31, 2022 Decommissioning Trust Fund Balance - 10 CFR 50.82(a)(8)(v)(A), 10 CFR 50.82(a)(8)(vii)(A)

Year Type of Trust Fund Balance (2022 $) Comments 2022 Decommissioning Trust $547M As of 12/31/2022; net of tax liabilities Other Financial Assurance Methods Being Relied Upon - 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 2022 $38M $6M $0M $44M1 2022 Costs in as-Spent Dollars Total Spent to Date $38M $6M $0M $44M 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 2022 Estimates $37M $ 1M $0M $38M Estimate in 2022 Dollars 2022 Actuals $38M $6M* $0M $44M Variance due to early milestone payment for Spent Fuel Management Project (paid in 2022)

Remaining Decommissioning Estimated Cost - 10 CFR 50.82(a)(8)(v)(B); 50.82(a)(8)(vii)(B)

Year License Termination Spent Fuel Mgmt Site Restoration Total Comments 2023 $447M $146M $39M $633M Estimated in 2022 Dollars Decommissioning Criteria Upon Which the Estimate is Based - 10 CFR 50.82(a)(8)(v)(B)

DECON Any Modification to Method of Providing Financial Assurance - 10 CFR 50.82(a)(8)(v)(A) and 50.82(a)(8)(v)(C)

NONE Any Material Changes to Trust Agreement Since Previous Report - 10 CFR 50.82(a)(8)(v)(D)

See item (F) in Enclosure 4 Need for Additional Financial Assurance - 10 CFR 50.82(a)(8)(v)(C) and 50.82(a)(8)(vii)(C)

NONE 1 $44M of the $44M incurred in 2022 have not been reimbursed to date.

Table 2 Holtec Decommissioning International Palisades Nuclear Power Station Annual Decommissioning Cash Flow Analysis ENCLOSURE 4 Table 2 Palisades Nuclear Power Station - DECON Method Annual Cash Flow in Millions (2022 Dollars)

License Spent Fuel Site Beginning of NDT Year Ending Year Termination Management Restorati Total Costs Year NDT Withdrawal3 Earnings1 NDT Cost Cost onCost Balance Balance 2023 63.8 22.8 2.7 89.3 546.82 -69.3 9.6 487.0 2024 27.1 18.9 0 46.0 487.1 -38.1 9.0 458.0 2025 25.0 24.4 0 49.4 458.0 -41.4 8.3 424.9 2026 2.7 4.2 0 6.9 424.9 -6.9 8.4 426.4 2027 5.1 1.9 0 7.0 426.4 -7.0 8.4 427.8 2028 5.2 1.9 0 7.0 427.8 -7.0 8.4 429.2 2029 5.0 1.9 0 6.8 429.2 -6.8 8.4 430.8 2030 5.4 8.1 0 13.5 430.8 -13.4 8.3 425.7 2031 4.8 7.0 0 11.9 425.7 -11.9 8.3 422.1 2032 4.8 7.0 0 11.9 422.1 -11.9 8.2 418.5 2033 4.8 7.0 0 11.9 418.5 -11.9 8.1 414.7 2034 4.8 7.0 0 11.9 414.7 -11.9 8.1 411.0 2035 9.6 6.7 .2 16.6 411.0 -16.6 7.9 402.3 2036 35.4 6.1 1.9 43.4 402.3 -43.4 7.2 366.0 2037 42.6 5.8 5.6 54.0 366.1 -54.0 6.2 318.3 2038 95.1 5.3 8.0 108.3 318.3 -108.3 4.2 214.1 2039 61.6 4.7 7.9 74.2 214.1 -74.2 2.8 142.9 2040 35.8 5.4 6.6 47.8 142.7 -65.8 1.5 78.4 2041 8.9 0 6.3 15.3 78.4 -77.3 .2 1.2 2042 Total3 447 146 39 633 -677 131 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR). Variance in 2022 market value of trust assets is -$5.2M relative to 2020 DCE baseline.

2 2023 Beginning of Year NDT Balance is based on 12/31/22 market value of trust investments, net of realized tax liabilities.

3 The NDT Withdrawal Amount includes $44M for the reimbursement of HDIs 2022 expenses not reimbursed in 2022.

4 Columns may not add due to rounding. Totals do not include 2022 actuals.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 5 Holtec Decommissioning International Big Rock Point Annual Decommissioning Funding and Spent Fuel ManagementStatus and Financial Assurance Report As of December 31, 2022

Holtec Decommissioning International Big Rock Point Annual Decommissioning Funding and Spent Fuel ManagementStatus and Financial Assurance Report As of December 31, 2022 As required by 10 CFR 50.82(a)(8), Holtec Decommissioning International, LLC (HDI) reports the following information for Big Rock Point (BRP):

Big Rock Point ISFSI Funding Overview:

BRP has been decommissioned and all portions of the site, other than the ISFSI and certain adjacent, non-impacted property, have been released. A cost estimate for the decommissioning of the BRP ISFSI and supporting information was provided in the Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments for Palisades and BRP (Reference 1). That cost estimate was based on Entergy Nuclear Operations, Inc.s (ENOI) then-current 10 CFR 72.30(c) ISFSI decommissioning funding report, escalated to 2020 dollars. In December 2021, after submission of the Application but before transfer of the BRP license, ENOI filed an updated cost estimate of approximately $2.8 million (2021 dollars) in the triennial update to its 10 CFR 72.30(c) report (Reference 4). HDI will file the next BRP triennial update in 2024. For purposes of this annual 50.82(a)(8)(v) report, HDI has escalated the prior ENOI estimate into 2022 dollars.

Financial assurance for ISFSI decommissioning is provided by 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 Palisades, LLC and HDI.

Additionally, in accordance with the conditions of the license transfer, Holtec has funded the BRP spent fuel management costs from a dedicated fund that continually contains one years worth of estimated operating costs and a parent support agreement to continually maintain that fund (Reference 3).

While HDI has not credited any DOE recoveries for purposes of its BRP decommissioning or irradiated fuel management funding obligations, BRP ISFSI operations are 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, according to the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. At the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned.

The financial assurance requirements for the BRP ISFSI are satisfied through these two mechanisms: the external trust fund and the BRP spend fuel management fund backed by a parent support agreement.

Radiological Decommissioning [10 CFR 50.82(a)(8)(v)]

A. Amount spent on ISFSI decommissioning. [10 CFR 50.82(a)(8)(v)(A)]

Neither HDI nor prior BRP owners have spent any amounts for BRP ISFSI decommissioning. The BRP reactor and most of the formerly licensed site were decommissioning and released for unrestricted use in 2007. The only decommissioning activities that remain are those associated with decommissioning

the ISFSI, which is expected to occur after DOE removes all irradiated fuel.

B. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B)]

The estimated cost to complete is $2.9M. This estimate is based on ENOIs 2021 10 CFR 72.30(c) report (Reference 4), escalated to 2022 dollars.

C. Decommissioning Fund Balance [10 CFR 50.82(a)(8)(v)(A)]

The BRP Nuclear Decommissioning Trust (NDT) fund balance as of December 31, 2022 was $2.8M. This amount represents the market value of the NDT fund as of December 31, 2022 net any material current income tax liability on realized gains, interest, dividends, and other income of the trust.

D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earningson Funds, and Other Factors Used in Funding Projections [10 CFR 50.82(a)(8)(v)(B)]

In accordance with 10 CFR 50.82(a)(8)(vi), HDI has assumed a 2% real rate of return.

The estimates provided in Reference 4 has been inflated to 2022 dollars using the same methodology used to escalate HDIs reactor decommissioning cost estimates. The Bureau of Labor Statistics (BLS) data provided the basis for the decommissioning cost estimate inflation rate forecast. Reactor decommissioning costs are inflated using a weighted average of BLS indices for labor, energy, consumer price index, materials, and equipment.

HDI has used a factor of 1.10 to calculate the inflation to 2022 dollars.

E. Decommissioning Financial Assurance [10 CFR 50.82(a)(8)(v)(A), 50.82(a)(8)(v)(D)]

Financial assurance for ISFSI decommissioning is provided by the funds held in the BRP decommissioning trust fund. In Reference 4, ENOI assumed BRP decommissioning would be completed in 2044, one year after DOE removal of fuel, which ENOI assumed to occur in 2043. With 2% real growth of the current trust fund balance relative to cost escalation, BRPs trust fund balance will exceed decommissioning costs by 2044. Even assuming a more expeditious DOE removal schedule, which HDI intends to pursue, the BRP trust value will be more than two times the estimated BRP ISFSI decommissioning costs by 2030the year in which HDI believes it is reasonable to expect that a repository will be available to begin receiving industry spent fuel.

ISFSI operations at Big Rock Point are 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, according to the Standard Contract. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense. Notwithstanding the expectation of DOE recoveries, HDI will fund decommissioning costs from the Decommissioning Trust Fund to terminate the ISFSI license and release the facility for unrestricted use.

F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]

On June 22, 2022, to satisfy the conditions to transfer the BRP license, Holtec International executed a Trust Agreement with Northern Trust to hold the funds for BRP ISFSI decommissioning and funded that trust in an amount of $2.67M (Reference 3). Upon transfer of the BRP license and Holtecs acquisition of the entity now known as Holtec Palisades, LLC, Holtec International assigned the trust agreement to Holtec Palisades, LLC (the licensed owner of BRP) pursuant to the terms of the trust agreement.

Since the BRP license transfer and completion of these steps in June 2022, there have been no changes to the trust agreement.

G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]

None Irradiated Fuel Management [10 CFR 50.82(a)(8)(vii)]

A. Funds Accumulated to Cover the Cost of Managing Irradiated Fuel In accordance with the conditions of the license transfer (Reference 2), on June 16, 2022 Holtec funded the Big Rock Point spent fuel management costs by establishing and funding a dedicated fund that will continually contain one years worth of estimated operating costs

($2.7M, in 2022) and a parent support agreement to continually maintain that fund.

B. Projected Cost of Managing Irradiated Fuel Until Title to the Fuel and Possession of the Fuel is Transferred to the Secretary of Energy Total ISFSI operating costs in 2022 were approximately $1.5M (which spanned ENOIs and HDIs period of responsibility). Based on ENOIs assumptions in Reference 4 that DOE will complete removal of BRP fuel in 2043, total irradiated fuel management costs expected to be incurred during that period are approximately $61M in 2022 dollars. Pursuant to the Parent Support Agreement, Holtec International will continually supplement the operating fund to ensure that the operating account maintains the requisite funding amount. HDI believes it is reasonable to assume that DOE will remove BRP fuel earlier than this amount, but given the structure of the BRP funding mechanisms, the precise timing of DOE removal is irrelevant to the funding demonstration required for BRP.

C. Additional Funding Plan If Accumulated Funds do Not Cover Projected Cost The Parent Support Agreement provides a continual source of funds to backstop BRP irradiated fuel management until DOE takes title to all fuel. While HDI does not rely on DOE recoveries to support its funding demonstration, in light of the fact that BRPs ongoing operational costs and eventual decommissioning costs are all a result of DOEs failure to fulfill its obligations under the Standard Contract, HDI expects to recover these costs from DOE.

The information provided in this enclosure demonstrates that decommissioning funding assurance at BRP is sufficient to cover costs as estimated for the ISFSI decommissioning and irradiated fuel management activities necessary to complete safe and compliant decommissioning of the site.

References:

1) Letter from Entergy Nuclear Operations , Inc (Entergy) to US NRC, Application for Order Consenting to Transfers of Control of Licenses and Approving Conforming License Amendments December 23, 2020 (ML30258A075)
2) Letter from US NRC to Entergy, Palisades Nuclear Plant and Big Rock Point Plant - Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendment (EPID L-2020-LLM-0003) December 13, 2021 (ML21292A145)
3) Letter from HDI to US NRC, Holtec Decommissioning International, LLC (HDI) satisfactory documentary evidence required before the planned closing date of the purchase and sale transaction of Palisades Nuclear Plant and Big Rock Point Plant June 24, 2022 (ML22178A077)
4) Letter from Entergy Nuclear Operations , Inc (Entergy) to US NRC, ISFSI Decommissioning Funding Plans (10 CFR 72.30) December 15, 2021 (ML21349A37)

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 6 Holtec Decommissioning International Methodology Used to Calculate the Formula Cost Amounts per 10 CFR 50.75(c)

Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report

Enclosure 6 Holtec Decommissioning International Methodology Used to Calculate the Formula Cost Amount per 10 CFR 50.75(c)

Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 This Enclosure provides the methodology used to calculate the formula cost per 10 CFR 50.75(c). HDI does not use this calculation for any decommissioning cost estimates or evaluations.

The labor, energy and burial indexes used are consistent with those described in NUREG-1307,Revision 19, issued February 2023. 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 and midwest regions. The labor adjustment factors were calculated according to Section 3.2 of NUREG-1307, Revision 19 using fourth quarter 2022 data. Table 1 shows the data used for this calculation.

Table 1: Labor Adjustment Factors Applicable Site Series ID 4Q2022 Index Labor Adjustment Number Factor (Lx)

Oyster Creek CIU2010000000210I 157.0 3.39 Pilgrim CIU2010000000210I 157.0 3.39 IPEC CIU2010000000210I 157.0 3.39 Palisades CIU2010000000230I 152.8 3.18 Big Rock Point CIU2010000000230I 152.8 3.18 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 industrialelectric power (WPU0543) and light fuel oils (WPU0573). The energy adjustment factors were calculated according to Section 3.3 of NUREG-1307, Revision 19, using December 2022 data. Table 2 shows the dataused for this calculation.

Table 2: Energy Adjustment Factor WPU0543 - January 1986 (base value) 114.2 WPU0573 - January 1986 (base value) 82.0 WPU0543 - December 2022(preliminary value) 279.934 WPU0573 - December 2022 (preliminary value) 394.700 Industrial Electric Power Adjustment Factor - (PX) 2.451 Light Fuel oil Adjustment Factor - (FX) 4.813 Energy Adjustment Factor - (BWR) 3.538 Energy Adjustment Factor - (PWR) 3.443 The waste burial adjustment factors are taken from Table 2-1 of NUREG-1307, Revision 19, basedon 2022 data. The adjustment factors HDI used assume non-compact waste disposal facilities. Although Oyster Creek is located in New Jersey, which is a member of the Atlantic Compact, HDI has selected and is under contract to use the WCS Texas facility. HDI has not forecasted waste disposal to the Atlantic Compact since 2021. Table 3 shows the data used for this calculation.

Table 3: Waste Burial Adjustment Factor Combination of Compact-Affiliated and Generators LLW Burial Site Reactor Decommissioning Site Non-Compact Disposal Located in Type Facilities Waste Unaffiliated States Adjustment Factor - - (BX)

(BX)

Generic LLW BWR Oyster Creek N/A 12.296 Generic LLW BWR Pilgrim N/A 12.296 Generic LLW PWR IPEC N/A 13.711 Generic LLW PWR Palisades N/A 13.711 Generic LLW BWR Big Rock Point N/A 12.296 The calculation methodology used for all adjustment factors and displayed in Table 4 is consistent with NUREG-1307, Revision 19.

Table 4: Escalation Factors and Calculated Adjustments for HDI Sites Escalation Factors - Escalation Factor Escalation 1986 Base Year $

Site Formula Factor Escalated (Lx), (Ex), (Bx) 10 CFR 50.75(c)(2)

Oyster Creek (Lx) 3.39 0.65(L)+0.13(E)+0.22(B) 5.369 $651,635,530 (Ex) 3.538 (Bx) 12.296 Pilgrim (Lx) 3.39 0.65(L)+0.13(E)+0.22(B) 5.369 $656,370,988 (Ex) 3.538 (Bx) 12.296 IPEC (Lx) 3.39 0.65(L)+0.13(E)+0.22(B) 5.668 Unit 1 - $484,954,080 (Ex) 3.443 Unit 2 - $585,510,068 (Bx) 13.711 Unit 3 - $585,510,068 Palisades (Lx) 3.18 0.65(L)+0.13(E)+0.22(B) 5.530 $539,595,280 (Ex) 3.443 (Bx) 13.711 Big Rock Point (Lx) 3.18 0.65(L)+0.13(E)+0.22(B) 5.231 $600,518,800 (Ex) 3.538 (Bx) 12.296

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Enclosure 7 Holtec Decommissioning International Milestone Summary Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report As of December 31, 2022 Holtec Decommissioning International Milestone Summary Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report PSDAR/DCE/LTA DCE Annual DCE Annual Project / Milestone (per project Updates (2021) Updates (2022) Notes below)

Oyster Creek (PSDAR/DCE/LTA issued on 09/28/2018)

License Transfer 07/01/2019 07/01/2019 07/01/2019 Complete Zirc Fire Elimination 09/17/2019 06/29/2019 06/29/2019 Complete Fuel on Pad 06/23/2023 05/23/2021 05/23/2021 Complete Segmentation Reactor 02/03/2022 05/13/2022 01/27/2023 Complete Vessel Internals (RVI):

Segmentation Reactor 09/19/2022 08/19/2024 08/19/2028* *See Enclosure 1 Item (G)

Pressure Vessel (RPV):

Partial Site Release 10/24/2025 11/03/2025 11/03/2029* *See Enclosure 1 Item (G)

Fuel Shipment Begins 01/03/2025 01/03/2025 01/03/2030* *See Enclosure 1 Item (G)

Fuel Shipment Ends 03/28/2035 03/28/2035 03/28/2035 License Termination 12/01/2035 12/03/2035 12/03/2035 Pilgrim (PSDAR/DCE/LTA issued on 11/16/2018)

License Transfer 07/31/2019 08/26/2019 08/26/2019 Complete Zirc Fire Elimination 03/30/2020 03/31/2020 03/31/2020 Complete Fuel on Pad 11/26/2021 12/13/2021 12/13/2021 Complete Segmentation RVI 10/12/2020 10/26/2022 05/25/2023* *See Enclosure 2 Item (G)

Segmentation RPV 09/18/2022 12/31/2024 12/31/2028* *See Enclosure 2 Item (G)

  • 2021 Schedule change noticed in 2019 Annual Decommissioning Funding and Spent Fuel 01/28/2025 Partial Site Release 09/24/2027 09/24/2031** Management Report (ML20091M858)

[09/24/2027] *

    • See Enclosure 2 Item (G)

Fuel Shipment Begins 01/02/2030 01/02/2030 01/02/2030 Fuel Shipment Ends 12/31/2062 12/31/2062 12/31/2062 License Termination 09/07/2063 09/07/2063 09/07/2063 PSDAR/DCE/LTA DCE Annual DCE Annual Project / Milestone (per project Updates (2021) Updates (2022) Notes below)

Indian Point (PSDAR/DCE/LTA issued on 12/19/2019)

License Transfer 05/31/2021 05/28/2021 05/28/2021 Complete Zirc Fire Elimination 09/15/2022 08/01/2022 08/01/2022 Complete (IP3)

Fuel on Pad:

IP1 12/11/2008 - 12/11/2008 Complete IP2 03/31/2023 03/31/2023 02/01/2023 Complete IP3 04/04/2024 10/31/2023 10/31/2023 Segmentation RVI:

  • IP1 RVI will be removed with the reactor IP1* - - - vessel during RPV segmentation IP2 12/21/2022 05/28/2024 07/18/2025* *See Enclosure 3 Item (G)

IP3 12/21/2021 11/30/2023 03/07/2024* *See Enclosure 3 Item (G)

Segmentation RPV:

IP1 04/13/2024 11/20/2025 11/20/2027* *See Enclosure 3 Item (G)

IP2 06/30/2023 11/26/2024 04/29/2026* *See Enclosure 3 Item (G)

IP3 06/30/2022 05/37/2024 12/17/2024 Partial Site Release 07/09/2033 07/09/2033 07/09/2033 Fuel Shipment Begins:

IP1 05/29/2046 05/29/2046 05/29/2046 IP2 01/02/2030 01/02/2030 01/02/2030 IP3 08/26/2047 08/26/2047 08/26/2047 Fuel Shipment Ends:

IP1 08/23/2047 08/23/2047 08/23/2047 IP2 05/25/2046 05/25/2046 05/25/2046 IP3 12/30/2061 12/30/2061 12/30/2061 License Termination 09/06/2062 09/06/2062 09/06/2062 PSDAR/DCE/LTA DCE Annual DCE Annual Project / Milestone (per project Updates (2022) Notes Updates (2021) below)

Palisades (PSDAR/DCE/LTA issued on 12/23/2021)

License Transfer 06/28/2022 - 06/28/2022 Complete Zirc Fire Elimination 09/20/2023 - 05/31/2023 Fuel on Pad 07/02/2025 - 07/02/2025 Dormancy Period (10 11/30/2035 11/30/2035 Years)

Segmentation RVI 12/31/2037 - 12/31/2037 Segmentation RPV 12/31/2038 - 12/31/2038 Fuel Shipment Begins 01/01/2030 01/01/2030 Fuel Shipment Ends 12/30/2040 - 12/30/2040 Partial Site Release &

09/06/2041 - 09/06/2041 License Termination Big Rock Point (PSDAR/DCE/LTA issued on 12/23/2021)

Fuel Shipment Begins 01/01/2030 01/01/2030 Fuel Shipment Ends 12/31/2043 - 12/31/2043 License Termination 12/31/2044 - 12/31/2044

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