L-25-005, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International
| ML25090A172 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Indian Point, Oyster Creek, Pilgrim, Big Rock Point |
| Issue date: | 03/31/2025 |
| From: | Fleming J Holtec Decommissioning International, Holtec |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| HDI-OC-25-006, HDI-PIL-25-005, HDI-IPEC-25-013, HDI-BRP-2025-006, PNP-2025-18 | |
| Download: ML25090A172 (1) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-25-006 HDI-PIL-25-005 HDI-IPEC-25-013 HDI-BRP 2025-006 PNP 2025 -18 Page 1 of 3 10 CFR 50.82 10 CFR 50.75 March 31, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044 Indian Point Nuclear Generating Stations 1, 2, and 3 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64 NRC Docket Nos.50-003, 50-247, 50-286, and 72-051 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket No. 50-255 and 72-007 Big Rock Point NRC License No. DPR-6 NRC Docket No. 50-155 and 72-043
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, 2024.
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
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-25-006 HDI-PIL-25-005 HDI-IPEC-25-013 HDI-BRP 2025-006 PNP 2025 -18 Page 2 of 3 irradiated fuel management status for Oyster Creek, Pilgrim, IPEC, PNP, and BRP respectively. 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, 2024 trust fund balances, indicate that Oyster Creek, Pilgrim, IPEC, PNP, and BRP have met the NRCs funding requirements. Accordingly, HDI concludes that no further action is required to demonstrate adequate funding assurance for decommissioning the plants included in this submittal.
PNP remains in a decommissioning status, will continue to adhere to the PSDAR, and will file annual decommissioning financial assurance reports until HDI reinstates the power operations licensing basis, which is planned for 2025. In anticipation of restart, HDI filed a 50.82(a)(7) notice indicating the decision to defer removal of all fuel to the ISFSI pad (Reference 2). This schedule change is reflected in the forward-looking projections in.
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, IPEC, PNP, and BRP for the period ending December 31, 2023.
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, Jean A. Fleming Vice President, Licensing and Regulatory Affairs Holtec International
References:
- 1) Letter, 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 29, 2024 (ML24089A117)
- 2) Letter, HDI to US NRC, Notification of Changes in Accordance with 10 CRF 50.82(a)(7), April 9, 2024 (ML24100A689)
Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2025.03.31 10:23:50 -04'00' Jean A.
Fleming
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-OC-25-006 HDI-PIL-25-005 HDI-IPEC-25-013 HDI-BRP 2025-006 PNP 2025 -18 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)
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) Milestone Summary Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report 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 Nuclear Plant and BRP USNRC Senior Project Manager, NRR - Palisades Nuclear Plant NRC Region 1 Lead Decommissioning Inspector - Oyster Creek NRC Region 1 Lead Decommissioning Inspector - Pilgrim Nuclear Power Station NRC Region 1 Lead Decommissioning Inspector, Indian Point Units 1, 2 & 3 NRC Region 3 Chief, Operations Branch - Palisades Nuclear Plant NRC Region 3 Lead Decommissioning Inspector - Palisades Nuclear Plant and BRP NRC Resident Inspectors - Palisades Nuclear Plant NRC Senior Financial Analyst 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
Page 1 of 7 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 7 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, 2024 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 amended in the annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (ISFSI) submitted for 2023 (Reference 2).
Table 1 of this Enclosure provides reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning.
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, 2024 was $362.4M. This amount represents the market value of the NDT fund as of December 31, 2024 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, 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 Oyster Creek Revised PSDAR and DCE (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2024 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 20, issued February 2025, for the burial inflation factor. HDI has used a factor of 1.02 to calculate the inflation to 2024 dollars.
D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]
The current detailed site-specific ISFSI decommissioning cost estimate is $4.6M (2024 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR and DCE (Reference 1) and amended in the report on the status of decommissioning funding for ISFSI (Reference 4) which were inflated using the published inflation indices 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 license transfer to Oyster Creek Page 3 of 7 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)]
Pursuant to 10 CFR 50.82(a)(7), HDI is notifying the NRC of Oyster Creek reactor pressure vessel schedule and cost changes from those described in the Revised PSDAR and Site-Specific DCE for Oyster Creek (Reference 1). Changes in the segmentation cost reflect the current HDI schedule to complete segmentation activity.
The updates to Oyster Creek decommissioning schedules are detailed in Enclosure 7. The updates to the cost estimates are noted in Tables 1 and 2 and reflect the expected cost impacts of changes to the reactor pressure vessel schedule.
Additionally, the 2024 spent fuel management and site restoration actual costs reflect early payments for the ISFSI canister protection program, vertical cask transporter device and non-radiological waste.
provides the decommissioning milestone summary with updated 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).
Tables 1 and 2 of this Enclosure provide the required reporting data. Table 1 provides a summary of information as of December 31, 2024 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-
(vii). Table 2 provides a cash flow analysis using the revised DCE 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 (HDI) 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, HDI to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 29, 2024 (ML24089A117)
- 3) Letter, 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 10, 2024 (ML24345A117)
Page 4 of 7 Table 1 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report Page 5 of 7 ENCLOSURE 1 Table 1 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$362.4M As of 12/31/2024; net 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
$95M 2022 Costs in as-Spent Dollars 2023
$40M
$18M
$0M
$58M 2023 Costs in as-Spent Dollars 2024
$30M
$14M
$9M
$53M 2024 Costs in as-Spent Dollars Total to Date1
$406M
$275M
$21M
$702M2 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 Total1 Comments 2024 Estimated
$31M
$7M
$6M
$44M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$30M
$14M
$9M
$53M 2024 Costs in as-Spent Dollars 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 2025
$162M
$116M
$24M
$302M Estimated in 2024 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)
NONE 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 $41.6M of incurred cost have not been reimbursed as of 12/31/24.
Page 6 of 7 Table 2 Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station Annual Decommissioning Cash Flow Analysis Page 7 of 7 ENCLOSURE 1 Table 2 Oyster Creek Nuclear Generating Station - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance4 2025 43.6 9.1
.2 52.9 362.4
-52.9 6.2 315.8 2026 16.6 8.0 0
24.7 315.8
-24.7 5.8 296.9 2027 22.3 6.1 4.2 32.6 296.9
-32.6 5.3 269.6 2028 30.2 5.9 5.1 41.2 269.6
-41.2 4.6 233.0 2029 35.6 5.8 13.5 54.9 233.0
-54.9 3.6 181.6 2030 0
14.1 0
14.1 181.6
-14.1 3.4 170.9 2031 0
14.1 0
14.1 170.9
-14.1 3.1 159.9 2032 0
14.1 0
14.1 159.9
-14.1 2.9 148.7 2033 10.0 14.1 0
24.1 148.7
-24.1 2.5 127.1 2034 1.9 14.1 0
16.0 127.1
-36.8 1.8 92.1 2035 1.8 10.4
.9 13.1 92.1
-33.9 1.2 59.3 Total4 161.9 115.9 23.9 301.8
-343.4 40.3 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $41.6M for the reimbursement of HDI expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2019-2024 actuals.
Page 1 of 7 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 7 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, 2024 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 amended in the annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (ISFSI) submitted for 2023 (Reference 2).
Table 1 of this Enclosure provides reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning.
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, 2024 was $484.7M. This amount represents the market value of the NDT fund as of December 31, 2024 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 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 and DCE (Reference 1) were provided in 2018 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2024 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 20, issued February 2025, for the burial inflation factor. HDI has used a factor of 1.01 to calculate the inflation to 2024 dollars.
D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]
The current detailed site-specific ISFSI decommissioning cost estimate is $4.8M (2024 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR and DCE (Reference 1) and amended in the report on the status of decommissioning funding for ISFSI (Reference 4) which were inflated using the published inflation indices 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 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).
Page 3 of 7 F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]
There have been no changes to the Pilgrim Master Decommissioning Trust Agreement.
G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]
There have been no material changes to the Pilgrim decommissioning milestone schedule or project cost.
provides the decommissioning milestone summary with updated completion dates. HDI has confirmed that 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 the required reporting data. Table 1 provides a summary of information as of December 31, 2024 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-
(vii). Table 2 provides a cash flow analysis using the revised DCE 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 (HDI) to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, November 16, 2018 (ML18320A040)
- 2) Letter, HDI to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 29, 2024 (ML24089A117)
- 3) Letter, 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, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 10, 2024 (ML24345A117)
Page 4 of 7 Table 1 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report Page 5 of 7 ENCLOSURE 2 Table 1 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$484.7M As of 12/31/2024; net 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
$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
$99M 2022 Costs in as-Spent Dollars 2023
$53M
$29M
$4M
$86M 2023 Costs in as-Spent Dollars 2024
$38M
$13M
$5M
$55M 2024 Costs in as-Spent Dollars Total Spent to Date1
$411M
$306M
$21M
$738M2 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 Total1 Comments 2024 Estimated
$44M
$13M
$6M
$63M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$38M
$13M
$5M
$55M 2024 Costs in as-Spent Dollars 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 2025
$212M
$330M
$15M
$557M Estimated in 2024 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)
NONE 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 $33M of incurred cost have not been reimbursed as of 12/31/24.
Page 6 of 7 Table 2 Holtec Decommissioning International, LLC Pilgrim Nuclear Power Station Annual Decommissioning Cash Flow Analysis
Page 7 of 7 ENCLOSURE 2 Table 2 Pilgrim Nuclear Power Station - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance4 2025 41.4 11.9 3.2 56.5 484.7
-56.5 8.6 436.8 2026 7.0 9.5
.0 16.5 436.8
-16.5 8.4 428.7 2027 7.0 9.5
.0 16.5 428.7
-16.5 8.2 420.4 2028 6.9 9.6
.0 16.4 420.4
-16.4 8.1 412.0 2029 6.9 9.6
.0 16.4 412.0
-16.4 7.9 403.5 2030 6.6 11.2
.0 17.8 403.5
-17.8 7.7 393.4 2031 6.6 11.2
.0 17.8 393.4
-17.8 7.5 383.1 2032 25.8 8.5 3.0 37.3 383.1
-37.3 6.9 352.8 2033 34.2 8.2 3.3 45.7 352.8
-45.7 6.1 313.2 2034 26.8 8.1 2.4 37.3 313.2
-37.3 5.5 281.4 2035 29.4 8.1 1.9 39.4 281.4
-39.4 4.8 246.9 2036
.0 8.2
.0 8.2 246.9
-8.2 4.8 243.4 2037
.0 8.2
.0 8.2 243.4
-8.2 4.7 239.9 2038
.0 8.2
.0 8.2 239.9
-8.2 4.6 236.4 2039
.0 8.2
.0 8.2 236.4
-8.2 4.6 232.7 2040
.0 8.2
.0 8.2 232.7
-8.2 4.5 229.0 2041
.0 8.2
.0 8.2 229.0
-8.2 4.4 225.2 2042
.0 8.2
.0 8.2 225.2
-8.2 4.3 221.3 2043
.0 8.2
.0 8.2 221.3
-8.2 4.3 217.4 2044
.0 8.2
.0 8.2 217.4
-8.2 4.2 213.3 2045
.0 8.2
.0 8.2 213.3
-8.2 4.1 209.2 2046
.0 8.2
.0 8.2 209.2
-8.2 4.0 205.1 2047
.0 8.2
.0 8.2 205.1
-8.2 3.9 200.8 2048
.0 8.2
.0 8.2 200.8
-8.2 3.9 196.4 2049
.0 8.2
.0 8.2 196.4
-8.2 3.8 192.0 2050
.0 8.2
.0 8.2 192.0
-8.2 3.7 187.4 2051
.0 8.2
.0 8.2 187.4
-8.2 3.6 182.8 2052
.0 8.2
.0 8.2 182.8
-8.2 3.5 178.1 2053
.0 8.2
.0 8.2 178.1
-8.2 3.4 173.3 2054
.0 8.2
.0 8.2 173.3
-8.2 3.3 168.3 2055
.0 8.2
.0 8.2 168.3
-8.2 3.2 163.3 2056
.0 8.2
.0 8.2 163.3
-8.2 3.1 158.2 2057
.0 8.2
.0 8.2 158.2
-8.2 3.0 153.0 2058
.0 8.3
.0 8.3 153.0
-8.3 2.9 147.6 2059
.0 8.2
.0 8.2 147.6
-8.2 2.8 142.2 2060 4.1 8.3
.0 12.4 142.2
-12.4 2.6 132.4 2061 4.1 8.2
.0 12.3 132.4
-28.8 2.1 105.7 2062 3.9 8.2
.0 12.1 105.7
-28.6 1.5 78.6 2063 1.2 2.8
.8 4.8 78.6
-4.8 1.5 75.3 Total4 211.9 330.1 14.5 556.5
-589.5 180 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $33M for the reimbursement of HDI expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2019-2024 actuals.
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 1 of 12 Holtec Decommissioning International, LLC Indian Point Units 1, 2, and 3 Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report
Page 2 of 12 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, 2024, 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 for the status of decommissioning funding for reactors and independent spent fuel storage installations (ISFSI) submitted for 2023 (Reference 2).
Tables 1A through 1C of this Enclosure provide reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning.
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, 2024 are listed in the table below:
Unit NDT Fund Balance Comment IP1
$661M NDT Fund balance as of 12/31/2024 IP2
$521M IP3
$480M These amounts represent the market value of the NDT fund as of December 31, 2024, 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 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, 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 HDI IPEC PSDAR and DCE (Reference 1) were provided in 2019 dollars. The estimates provided in Table 1A-1C of this Enclosure have been inflated to 2024 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 20, issued February 2025, for the burial inflation factor.
HDI has used a factor of 1.01 for IP1, IP2 and IP3 to calculate the inflation to 2024 dollars.
Page 3 of 12 D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]
The current detailed site-specific ISFSI decommissioning cost estimate is $8.2M (2024 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR and DCE (Reference 1) and amended in the report on the status of decommissioning funding for ISFSI (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 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)]
There have been no changes to the IPEC Decommissioning Trust Agreement.
G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]
Pursuant to 10 CFR 50.82(a)(7), HDI is notifying the NRC of Indian Point 3 (IP3) reactor segmentation schedule and cost changes from those described in the PSDAR and DCE for Indian Point Nuclear Generating Units 1, 2, and 3 (Reference 1).
The updates to the IP3 decommissioning schedules are detailed in Enclosure 7. The updates to the cost estimates are noted in Tables 1A, 1B, and 1C, and Tables 2A, 2B, and 2C and reflect the expected cost impacts of changes to the IP3 reactor segmentation schedule.
Schedule changes are due to ongoing challenges unique to IPEC reactor segmentation and the availability of the HI-TRAN Vertical Cask Transporter (VCT). The cost estimate adjustments account for the financial impact of cumulative delays in the reactor vessel segmentation schedule. The two main cost drivers are: 1) the time required to segment the reactor internals exceeded the original estimates; and 2) the time needed to mobilize, demobilize, and maintain the specialized segmentation tools exceeded the original estimates.
Additionally, HDI chose to minimize worker radiation exposure during these activities, which contributed to the schedule changes.
HDI will continue to annually report total project costs each year, and to the extent a future estimate of total project costs on Indian Point exceed the materiality thresholds in Reg Guide 1.185 relative to this years report, HDI will provide a subsequent 50.82(a)(7) notice.
Tables 1A through 1C and 2A through 2C of this Enclosure provide required reporting data for IP1, IP2 and IP3. Table 1A through 1C provides a summary of information as of December 31, 2024 in accordance with the requirements of 10 CFR 50.82(a)(8)(v)-(vii). Tables 2A through 2C provide a cash flow analysis using the revised decommissioning cost estimates developed by HDI.
provides the decommissioning milestone summary with updated 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).
The information provided in this enclosure demonstrates that the IPEC decommissioning trust
Page 4 of 12 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 Indian Point Nuclear Generating Units 1, 2, and 3, December 19, 2019 (ML19354A698)
- 1) Letter, HDI to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 29, 2024 (ML24089A117)
- 2) Letter, 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 (ML20309A577)
- 3) Letter, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 10, 2024 (ML24345A117)
Page 5 of 12 Table 1A, 1B, and 1C Holtec Decommissioning International, LLC Indian Point Units 1, 2 & 3 Annual Decommissioning Financial Assurance and Spent Fuel Management Report
Page 6 of 12 ENCLOSURE 3 Table 1A Holtec Decommissioning International, LLC Indian Point Unit 1 Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$660.8M As of 12/31/2024; 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 Termination Spent Fuel Mgmt Site Restoration Total1 Comments 2021
$18M
$2M
$0M
$20M 2021 Costs in as-Spent Dollars 2022
$32M
$-1M*
$1M
$32M 2022 Costs in as-Spent Dollars
- 2021 IP1 spent fuel management accrual reallocated to IP2 and IP3 2023
$34M
$2M
$0M
$37M 2023 Costs in as-Spent Dollars 2024
$31M
$0.4M
$0.3M
$32M 2024 Costs in as-Spent Dollars Total to Date1
$116M
$4M
$1M
$121M2 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 Total1 Comments 2024 Estimated
$34M
$2M
$2M
$39M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$31M
$0.4M
$0.3M
$32M 2024 Costs in as-Spent Dollars 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 2025
$500M
$103M
$47M
$650M Estimated in 2024 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)
NONE 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 $24.5M of incurred costs have not been reimbursed as of 12/31/24.
Page 7 of 12 ENCLOSURE 3 Table 1B Holtec Decommissioning International, LLC Indian Point Unit 2 Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$520.9M As of 12/31/2024; 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 2021
$33M
$20M
$0M
$53M 2021 Costs in as-Spent Dollars 2022
$76M
$73M
$1M
$150M 2022 Costs in as-Spent Dollars 2023
$80M
$87M
$1M
$167M 2023 Costs in as-Spent Dollars 2024
$31M
$15M
$3M
$49M 2024 Costs in as-Spent Dollars Total to Date1
$220M
$194M
$5M
$419M2 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 Total1 Comments 2024 Estimated
$47M
$19M
$0M
$66M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$31M
$15M
$3M
$49M 2024 Costs in as-Spent Dollars 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 2025
$383M
$183M
$54M
$620M Estimated in 2024 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)
NONE 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 $46.9M of incurred costs have not been reimbursed as of 12/31/24.
Page 8 of 12 ENCLOSURE 3 Table 1C Holtec Decommissioning International, LLC Indian Point Unit 3 Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$479.6M As of 12/31/2024; 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 2021
$38M
$63M
$0M
$101M 2021 Costs in as-Spent Dollars 2022
$103M
$44M
$1M
$148M 2022 Costs in as-Spent Dollars 2023
$69M
$203M
$1M
$273M 2023 Costs in as-Spent Dollars 2024
$37M
$16M
$3M
$56M 2024 Costs in as-Spent Dollars Total to Date1
$247M
$325M
$5M
$577M2 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 Total1 Comments 2024 Estimated
$39M
$26M
$4M
$68M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$37M
$16M
$3M
$56M 2024 Costs in as-Spent Dollars 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 2025
$375M
$174M
$58M
$606 Estimated in 2024 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)
NONE 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 $50.8M of incurred costs have not been reimbursed as of 12/31/24.
Page 9 of 12 Table 2A, 2B, 2C Holtec Decommissioning International, LLC Indian Point Units 1, 2 & 3 Annual Decommissioning Cash Flow Analysis
Page 10 of 12 ENCLOSURE 3 Table 2A Indian Point Nuclear Generating Station Unit 1 - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance 2025 32.1 1.3 3.9 37.3 660.8
-37.3 12.5 636.0 2026 14.8 1.8 1.7 18.3 636.0
-18.3 12.4 630.0 2027 14.5 1.8 1.7 18.0 630.0
-18.0 12.2 624.2 2028 18.8 1.6
.7 21.0 624.2
-21.0 12.1 615.3 2029 18.8 1.6
.6 21.0 615.3
-21.0 11.9 606.1 2030 9.2 2.0
.8 11.9 606.1
-11.9 11.9 606.1 2031 8.6 1.8
.7 11.2 606.1
-11.2 11.9 606.8 2032 23.7 1.5 3.0 28.1 606.8
-28.1 11.6 590.3 2033 35.6 1.4 2.9 39.9 590.3
-39.9 11.0 561.4 2034 38.8 1.4 4.0 44.2 561.4
-44.2 10.3 527.6 2035 45.1 1.4 3.9 50.5 527.6
-50.5 9.5 486.7 2036 40.2 1.4 3.9 45.6 486.7
-45.6 8.8 449.9 2037 43.6 1.4 3.9 48.9 449.9
-48.9 8.0 409.0 2038 41.9 1.4 3.9 47.2 409.0
-47.2 7.2 369.0 2039 44.6 1.4 3.9 49.9 369.0
-49.9 6.4 325.5 2040 49.7 1.4 5.8 56.8 325.5
-56.8 5.4 274.0 2041 10.4 1.6 2.0 14.1 274.0
-14.1 5.2 265.2 2042 0
3.4 0
3.4 265.2
-3.4 5.2 267.0 2043 0
3.4 0
3.4 267.0
-3.4 5.3 269.0 2044 0
3.4 0
3.4 269.0
-3.4 5.3 270.9 2045 0
3.4 0
3.4 270.9
-3.4 5.4 272.9 2046 0
6.0 0
6.0 272.9
-6.0 5.3 272.2 2047
.2 5.9 0
6.0 272.2
-6.0 5.3 271.5 2048
.5 3.7 0
4.1 271.5
-4.1 5.3 272.7 2049
.5 3.7 0
4.1 272.7
-4.1 5.4 274.0 2050
.5 3.7 0
4.1 274.0
-4.1 5.4 275.2 2051
.5 3.7 0
4.1 275.2
-4.1 5.4 276.6 2052
.5 3.7 0
4.1 276.6
-4.1 5.4 277.9 2053
.5 3.7 0
4.1 277.9
-4.1 5.5 279.3 2054
.5 3.7 0
4.1 279.3
-4.1 5.5 280.6 2055
.8 3.7 0
4.5 280.6
-4.5 5.5 281.7 2056
.8 3.7 0
4.5 281.7
-4.5 5.5 282.7 2057
.8 3.7 0
4.5 282.7
-4.5 5.6 283.8 2058
.8 3.7 0
4.5 283.8
-4.5 5.6 284.9 2059
.8 3.7 0
4.5 284.9
-4.5 5.6 286.0 2060
.8 3.7 0
4.5 286.0
-4.5 5.6 287.1 2061
.8 3.7 0
4.5 287.1
-4.5 5.7 288.3 2062
.3
.1
.4 288.3
-24.9 5.3 268.7 2063 268.7 268.7 Total4 500.0 102.7 47.4 650.1
-674.5 282.5 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $24.5M for the reimbursement of HDI expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2021-2024 actuals.
Page 11 of 12 ENCLOSURE 3 Table 2B Indian Point Nuclear Generating Station Unit 2 - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance 2025 52.2 12.5 4.2 68.9 520.9
-53.9 9.3 476.4 2026 22.1 2.4
.6 25.1 476.4
-25.1 9.0 460.4 2027 11.6 3.5
.7 15.9 460.4
-15.9 8.9 453.3 2028 11.6 3.5
.7 15.8 453.3
-15.8 8.8 446.3 2029 11.6 3.5
.7 15.8 446.3
-15.8 8.6 439.0 2030 10.7 7.1
.7 18.4 439.0
-18.4 8.4 429.0 2031 9.1 6.9 2.1 18.1 429.0
-18.1 8.2 419.1 2032 18.9 5.9 1.8 26.6 419.1
-26.6 7.8 400.3 2033 29.4 5.6 3.0 38.0 400.3
-38.0 7.2 369.6 2034 19.3 6.0 3.1 28.4 369.6
-28.4 6.8 348.0 2035 17.3 6.1 3.2 26.5 348.0
-26.5 6.4 327.9 2036 19.7 5.8 3.0 28.5 327.9
-28.5 6.0 305.4 2037 20.8 5.8 3.0 29.6 305.4
-29.6 5.5 281.3 2038 27.3 5.5 6.2 39.0 281.3
-39.0 4.8 247.1 2039 25.8 5.6 6.6 37.9 247.1
-37.9 4.2 213.4 2040 25.3 5.5 6.5 37.3 213.4
-37.3 3.5 179.7 2041 19.4 5.3 6.1 30.8 179.7
-30.8 3.0 151.8 2042 0
7.0 0
7.0 151.8
-7.0 2.9 147.7 2043 0
7.0 0
7.0 147.7
-7.0 2.8 143.6 2044 0
7.0 0
7.0 143.6
-7.0 2.7 139.3 2045 0
7.0 0
7.0 139.3
-7.0 2.6 134.9 2046 0
3.7 0
3.7 134.9
-3.7 2.6 133.9 2047
.2 3.9 0
4.1 133.9
-4.1 2.6 132.4 2048
.5 3.6 0
4.1 132.4
-4.1 2.6 130.9 2049
.5 3.6 0
4.1 130.9
-4.1 2.5 129.3 2050
.5 3.6 0
4.1 129.3
-4.1 2.5 127.8 2051
.5 3.6 0
4.1 127.8
-4.1 2.5 126.1 2052
.5 3.6 0
4.1 126.1
-4.1 2.4 124.5 2053
.5 3.6 0
4.1 124.5
-4.1 2.4 122.8 2054
.5 3.6 0
4.1 122.8
-4.1 2.4 121.1 2055 3.8 3.6 0
7.5 121.1
-7.5 2.3 115.9 2056 3.8 3.6 0
7.5 115.9
-7.5 2.2 110.6 2057 3.8 3.6 0
7.5 110.6
-7.5 2.1 105.2 2058 3.8 3.6 0
7.5 105.2
-7.5 2.0 99.7 2059 3.8 3.6 0
7.5 99.7
-7.5 1.8 94.0 2060 3.8 3.6 0
7.5 94.0
-7.5 1.7 88.3 2061 3.8 3.6 0
7.5 88.3
-30.9 1.1 58.5 2062 1.3 1.3 2.6 58.5
-41.1
.3 17.8 2063 17.8 17.8 Total4 383.4 183.0 53.7 620.0
-666.9 163.8 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $46.9M for the reimbursement of HDI decommissioning expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2021-2024 actuals.
Page 12 of 12 ENCLOSURE 3 Table 2C Indian Point Nuclear Generating Station Unit 3 - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Management Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance 2025 30.5 2.1 1.9 34.5 479.6
-17.2 9.2 471.6 2026 15.5 3.2 2.1 20.7 471.6
-10.4 9.2 470.5 2027 11.4 3.2 2.1 16.7 470.5
-16.7 9.1 462.8 2028 11.3 3.2 2.1 16.6 462.8
-16.6 8.9 455.1 2029 11.4 3.2 2.1 16.7 455.1
-16.7 8.8 447.2 2030 11.3 3.2 2.1 16.6 447.2
-16.6 8.6 439.2 2031 14.6 3.0 1.9 19.5 439.2
-19.5 8.4 428.1 2032 14.1 2.8 1.9 18.8 428.1
-18.8 8.2 417.5 2033 23.7 2.6
.9 27.2 417.5
-27.2 7.8 398.1 2034 24.1 2.6 1.2 28.0 398.1
-28.0 7.4 377.6 2035 27.3 2.5 3.5 33.4 377.6
-33.4 6.9 351.1 2036 22.2 2.5 4.7 29.5 351.1
-29.5 6.4 328.1 2037 27.0 2.5 3.5 33.0 328.1
-33.0 5.9 301.0 2038 25.4 2.5 5.1 33.0 301.0
-33.0 5.4 273.3 2039 26.3 2.5 6.7 35.5 273.3
-35.5 4.8 242.6 2040 25.7 2.5 6.7 34.8 242.6
-34.8 4.2 211.9 2041 24.5 2.4 8.0 34.9 211.9
-34.9 3.5 180.6 2042 0
4.4 0
4.4 180.6
-4.4 3.5 179.7 2043 0
4.4 0
4.4 179.7
-4.4 3.5 178.9 2044 0
4.4 0
4.4 178.9
-4.4 3.5 178.0 2045 0
4.4 0
4.4 178.0
-4.4 3.5 177.1 2046 0
5.4 0
5.4 177.1
-5.4 3.4 175.1 2047 0
5.1 0
5.1 175.1
-5.1 3.4 173.4 2048 0
6.9 0
6.9 173.4
-6.9 3.3 169.9 2049 0
6.9 0
6.9 169.9
-6.9 3.3 166.2 2050 0
6.9 0
6.9 166.2
-6.9 3.2 162.5 2051 0
6.9 0
6.9 162.5
-6.9 3.1 158.8 2052 0
6.9 0
6.9 158.8
-6.9 3.0 154.9 2053 0
6.9 0
6.9 154.9
-6.9 3.0 151.0 2054 0
6.9 0
6.9 151.0
-6.9 2.9 147.0 2055 3.5 6.9 0
10.4 147.0
-10.4 2.7 139.3 2056 3.5 6.9 0
10.4 139.3
-10.4 2.6 131.5 2057 3.5 6.9 0
10.4 131.5
-10.4 2.4 123.5 2058 3.5 6.9 0
10.4 123.5
-10.4 2.3 115.4 2059 3.5 6.9 0
10.4 115.4
-10.4 2.1 107.1 2060 3.5 6.9 0
10.4 107.1
-10.4 1.9 98.6 2061 3.5 6.9 0
10.4 98.6
-35.8 1.3 64.1 2062 3.7 3.0 1.2 7.9 64.1
-60.9
.1 3.2 2063 3.2 3.2 Total4 374.7 173.9 57.6 606.2
-657.0 180.6 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $50.8M for the reimbursement of HDI decommissioning expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2021-2024 actuals.
Page 1 of 7 Holtec Decommissioning International, LLC Palisades Nuclear Power Station Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 7 As required by 10 CFR 50.82(a)(7) and 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, 2024 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 for the status of decommissioning funding for reactors and independent spent fuel storage installations (ISFSI) submitted for 2023 (Reference 2).
Table 1 of this Enclosure provides reporting requirements and includes the HDI revised total estimate required by 10 CFR 50.82 based on the DECON method of decommissioning.
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, 2024 was $568.9M. This amount represents the market value of the NDT fund as of December 31, 2024 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 3).
C. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, 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 HDI Palisades PSDAR and DCE (Reference 1) were provided in 2020 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2024 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 20, issued February 2025, for the burial inflation factor. HDI has used a factor of 1.00 to calculate the inflation to 2024 dollars.
D. ISFSI Decommissioning Cost [10 CFR 50.82(a)(8)(v)(ii)(B)]
The current detailed site-specific ISFSI decommissioning cost estimate is $10.7M (2024 dollars). The ISFSI estimated costs are based on the estimated costs provided in the HDI revised PSDAR and DCE (Reference 1) and amended in the report on the status of decommissioning funding for ISFSI (Reference 4) which were inflated using the published inflation indices 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 license transfer to Holtec Palisades, LLC and HDI. There have been no changes to the method of providing financial assurance since the last submitted report (Reference 2).
Page 3 of 7 F. Material Changes to the Decommissioning Trust Agreement [10 CFR 50.82(a)(8)(v)(D)]
There have been no changes to the PNP Master Decommissioning Trust Agreement.
G. Material Changes to the Decommissioning Milestone Schedules or Project Cost [10 CFR 50.82(a)(7)]
PNP remains in a decommissioning status, will continue to adhere to the PSDAR (Reference 1), and will file annual decommissioning financial assurance reports until the HDI reinstates the power operations licensing basis, which is planned for 2025. In anticipation of restart, HDI filed a 50.82(a)(7) notice indicating the decision to defer removal of all fuel to the ISFSI pad (Reference 5). This schedule change is reflected in the forward-looking projections in Table 2. The 2024 delta between estimated costs versus actuals costs for license termination, spent fuel, and site restoration costs (Table 1) are attributed to the DOE loan closure and transition to the Palisades restart project.
provides the decommissioning milestone summary with updated 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 required reporting data. Table 1 provides a summary of information as of December 31, 2024 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, HDI to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 29, 2024 (ML24089A117)
- 3) Letter, 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 (ML21286A294)
- 4) Letter, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 10, 2024 (ML24345A117)
- 5) Letter, HDI to US NRC, Notification of Changes in Accordance with 10 CRF 50.82(a)(7),
April 9, 2024 (ML24100A689)
Page 4 of 7 Table 1 Holtec Decommissioning International, LLC Palisades Nuclear Station Annual Decommissioning Financial Assurance and Spent Fuel Management Report Page 5 of 7 ENCLOSURE 4 Table 1 Holtec Decommissioning International, LLC Palisades Nuclear Power Station Summary Information as of December 31, 2024 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 Comments 2024 Decommissioning Trust
$568.9M As of 12/31/2024; 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 Total1 Comments 2022
$38M
$6M
$0M
$44M 2022 Costs in as-Spent Dollars 2023
$43M
$56M
$0M
$99M 2023 Costs in as-Spent Dollars 2024
$8M
$20M
$0M
$28M 2024 Costs in as-Spent Dollars Total Spent to Date1
$89M
$82M
$0M
$171M2 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 Total1 Comments 2024 Estimates
$42M
$42M
$0M
$84M Estimate in 2023 Dollars (Reference 2) 2024 Actuals
$8M
$20M
$0M
$28M 2024 Costs in as-Spent Dollars 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 2025
$412M
$122M
$41M
$575M Estimated in 2024 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)
NONE 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 $43.1M of incurred costs have not been reimbursed as of 12/31/24.
Page 6 of 7 Table 2 Holtec Decommissioning International, LLC Palisades Nuclear Power Station Annual Decommissioning Cash Flow Analysis
Page 7 of 7 ENCLOSURE 4 Table 2 Palisades Nuclear Generating Station - DECON Method Annual Cash Flow in Millions (2024 Dollars)
Year License Termination Cost Spent Fuel Cost Site Restoration Cost Total Costs Beginning of Year NDT Balance1 Withdrawals3 NDT Earnings2 Year Ending NDT Balance 2025 16.5 38.1
.3 54.9 568.9
-54.9 10.3 524.3 2026 6.3 4.9 0
11.1 524.3
-11.1 10.3 523.4 2027 7.2 2.8 0
10.0 523.4
-10.0 10.3 523.7 2028 8.3 2.8 0
11.1 523.7
-11.1 10.3 522.8 2029 8.1 2.8 0
10.9 522.8
-10.9 10.2 522.1 2030 8.5 8.4 0
16.9 522.1
-16.9 10.1 515.3 2031 7.9 7.3 0
15.2 515.3
-15.2 10.0 510.2 2032 7.9 7.3 0
15.2 510.2
-15.2 9.9 504.9 2033 7.9 7.3 0
15.2 504.9
-15.2 9.8 499.5 2034 7.9 7.3 0
15.2 499.5
-15.2 9.7 494.0 2035 16.0 6.9
.2 23.1 494.0
-23.1 9.4 480.2 2036 49.5 5.4 2.0 56.9 480.2
-56.9 8.5 431.8 2037 45.5 5.1 6.8 57.4 431.8
-57.4 7.5 381.9 2038 101.5 5.5 8.4 115.4 381.9
-115.4 5.3 271.9 2039 65.2 5.0 8.4 78.5 271.9
-100.1 3.4 175.2 2040 37.9 5.7 7.0 50.6 175.2
-72.2 2.1 105.1 2041 9.5
.0 7.7 17.2 105.1
-17.2 1.8 89.6 Total4 411.7 122.3 40.9 574.9
-618.1 138.7 1 Beginning NDT fund value is based on the 12/31/24 market value of trust investments, net of realized tax liabilities.
2 NDT earnings reflect an assumed 2% Real Rate of Return (RRR).
3 The NDT Withdrawal Amount includes $43.1M for the reimbursement of HDI expenses not reimbursed in 2024.
4 Columns may not add due to rounding. Totals do not include 2022-2024 actuals.
Page 1 of 4 Holtec Decommissioning International, LLC Big Rock Point Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
Page 2 of 4 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 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 and 2). In December 2024, HDI filed a report on the status of decommissioning funding for ISFSI in the triennial update to its 10 CFR 72.30(c) report (Reference 3). For purposes of this annual 50.82(a)(8)(v) report, HDI has escalated the estimate to 2024 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 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 4).
The financial assurance requirements for the BRP ISFSI are satisfied through two mechanisms: the external trust fund and the BRP spent 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)]
HDI has not spent any amounts for BRP ISFSI decommissioning. The BRP reactor and most of the formerly licensed site were decommissioned and released for unrestricted use in 2007. The only remaining decommissioning activities are associated with decommissioning the ISFSI, which is expected to occur after DOE removes all irradiated fuel, which is assumed to occur in 2043.
B. Decommissioning Cost Estimate [10 CFR 50.82(a)(8)(v)(B)]
The estimated cost to complete decommissioning is $4.1M. This estimate is based on HDIs 2024 report on the status of decommissioning funding for ISFSI (Reference 3),
escalated to 2024 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, 2024 was $3.8M. This amount represents the market value of the NDT fund as of December 31, 2024 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, Earnings on 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 have been inflated to 2024 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
Page 3 of 4 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 1.03 to calculate the inflation to 2024 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.
ISFSI operations at BRP 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)]
There have been no changes to the BRP Decommissioning 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 and 4), on June 16, 2022 Holtec International funded the BRP spent fuel management costs by establishing and funding a dedicated fund that will continually contain one years worth of estimated operating costs ($4.1M, in 2024) 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 2024 were approximately $4.1M. Based on the assumption that DOE will complete removal of BRP fuel in 2043, total irradiated fuel management costs expected to be incurred during that period are approximately $78M in 2024 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.
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.
Page 4 of 4 provides the decommissioning milestone summary with updated completion dates for BRP. 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, 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 (ML20358A075)
- 2) Letter, 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, HDI to US NRC, Report on Status of Decommissioning Funding Independent Spent Fuel Storage Installations, December 10, 2024 (ML24345A117)
- 4) Letter, 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)
Page 1 of 3 Holtec Decommissioning International, LLC 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 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 3 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 20, issued February 2025. 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 20 using fourth quarter 2024 data. Table 1 shows the data used for this calculation.
Table 1: Labor Adjustment Factors Applicable Site Series ID 4Q2024 Index Number Labor Adjustment Factor (Lx)
Oyster Creek CIU2010000000210I 168.4 3.637 Pilgrim CIU2010000000210I 168.4 3.637 IPEC CIU2010000000210I 168.4 3.637 Palisades CIU2010000000230I 163.7 3.405 Big Rock Point CIU2010000000230I 163.7 3.405 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 20, using December 2024 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 2024(preliminary value) 295.399 WPU0573 - December 2024 (preliminary value) 277.481 Industrial Electric Power Adjustment Factor - (PX) 2.587 Light Fuel oil Adjustment Factor - (FX) 3.384 Energy Adjustment Factor - (BWR) 2.953 Energy Adjustment Factor - (PWR) 2.922 The waste burial adjustment factors are taken from Table 2-1 of NUREG-1307, Revision 20.
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.
Page 3 of 3 Table 3: Waste Burial Adjustment Factor LLW Burial Site Reactor Type Decommissioning Site Combination of Compact-Affiliated and Non-Compact Disposal Facilities Waste Adjustment Factor -
(BX)
Generators Located in Unaffiliated States
- (BX)
Generic LLW BWR Oyster Creek N/A 11.658 Generic LLW BWR Pilgrim N/A 11.658 Generic LLW PWR IPEC N/A 12.405 Generic LLW PWR Palisades N/A 12.405 Generic LLW BWR Big Rock Point N/A 11.658 The calculation methodology used for all adjustment factors and displayed in Table 4 is consistent with NUREG-1307, Revision 20.
Table 4: Escalation Factors and Calculated Adjustments for HDI Sites Site Escalation Factors -
(Lx), (Ex), (Bx)
Escalation Factor Formula 10 CFR 50.75(c)(2)
Escalation Factor 1986 Base Year $
Escalated Oyster Creek (Northeast BWR)
(Lx) 3.637 0.65(L)+0.13(E)+0.22(B) 5.313
$644,838,810 (Ex) 2.953 (Bx) 11.658 Pilgrim (Northeast BWR)
(Lx) 3.637 0.65(L)+0.13(E)+0.22(B) 5.313
$649,524,876 (Ex) 2.953 (Bx) 11.658 IPEC (Northeast PWR)
(Lx) 3.637 0.65(L)+0.13(E)+0.22(B) 5.473 Unit 1 - $468,269,880 (Ex) 2.922 Unit 2 - $565,366,373 (Bx) 12.405 Unit 3 - $565,366,373 Palisades (Midwest PWR)
(Lx) 3.405 0.65(L)+0.13(E)+0.22(B) 5.322
$519,299,472 (Ex) 2.922 (Bx) 12.405 Big Rock Point (Midwest BWR)
(Lx) 3.405 0.65(L)+0.13(E)+0.22(B) 5.162
$592,597,600 (Ex) 2.953 (Bx) 11.658 Page 1 of 4 Holtec Decommissioning International, LLC Milestone Summary Annual Decommissioning Funding and Spent Fuel Management Status and Financial Assurance Report Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Page 2 of 4 Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Update (2024)
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 Reactor Vessel Internals (RVI):
02/03/2022 01/27/2023 Complete Segmentation Reactor Pressure Vessel (RPV):
09/19/2022 03/31/2027*
- See Enclosure 1. G Partial Site Release 10/24/2025 11/03/2029 Fuel Shipment Begins 01/03/2025 01/03/2030 Fuel Shipment Ends 03/28/2035 03/28/2035 License Termination 12/01/2035 12/03/2035 Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Update (2024)
Notes 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 09/06/2024 Complete Segmentation RPV 09/18/2022 12/31/2032 Partial Site Release 09/24/2027 09/24/2035 Fuel Shipment Begins 01/02/2030 01/02/2030 Fuel Shipment Ends 12/31/2062 12/31/2062 License Termination 09/07/2063 09/07/2063 Page 3 of 4 Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Update (2024)
Notes Indian Point (PSDAR/DCE/LTA issued on 12/19/2019)
License Transfer 05/31/2021 05/28/2021 Complete Zirc Fire Elimination (IP3) 09/15/2022 08/01/2022 Complete Fuel on Pad:
IP1 12/11/2008 12/11/2008 Complete IP2 03/31/2023 02/01/2023 Complete IP3 04/04/2024 10/16/2023 Complete Segmentation RVI:
IP1*
- IP1 RVI will be removed with the reactor vessel during RPV segmentation IP2 12/21/2022 11/03/2026 IP3 12/21/2021 01/13/2027**
- See Enclosure 3. G Segmentation RPV:
IP1 04/13/2024 11/20/2031 IP2 06/30/2023 04/29/2034 IP3 06/30/2022 12/17/2032 Partial Site Release 07/09/2033 07/09/2041 Fuel Shipment Begins:
IP1 05/29/2046 05/29/2046 IP2 01/02/2030 01/02/2030 IP3 08/26/2047 08/26/2047 Fuel Shipment Ends:
IP1 08/23/2047 08/23/2047 IP2 05/25/2046 05/25/2046 IP3 12/30/2061 12/30/2061 License Termination 09/06/2062 09/06/2062 Page 4 of 4 Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Updates (2024)
Notes Palisades (PSDAR/DCE/LTA issued on 12/23/2021)
License Transfer 06/28/2022 06/28/2022 Complete Zirc Fire Elimination 09/20/2023 09/20/2023 Complete Fuel on Pad 07/02/2025 07/02/2025**
- See Enclosure 4. G Dormancy Period (10 Years) 11/30/2035 11/30/2035 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 &
License Termination 09/06/2041 09/06/2041 Project / Milestone PSDAR/DCE/LTA (per project below)
DCE Annual Updates (2024)
Notes 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