NL-10-123, Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (Bb) and 10 CFR 50.75(f)(3)

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Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in Accordance with 10 CFR 50.54 (Bb) and 10 CFR 50.75(f)(3)
ML103540233
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 12/10/2010
From: Joseph E Pollock
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-10-123
Download: ML103540233 (21)
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Text

Enterciv Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President NL-10-123 December 10, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Unit 3 Program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3)

Docket Nos. 50-286 License Nos. DPR-64

Dear Sir or Madam:

Pursuant to 10 CFR 50.54(bb) licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit to the NRC the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor facility following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U. S. Department of Energy for ultimate disposal. The Program for Maintenance of Irradiated Fuel at the IPEC Unit 3 is included as Attachment 2.

Pursuant to 10 CFR 50.75(f)(3), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit a preliminary decommissioning cost estimate to the NRC. The preliminary decommissioning cost analysis for the IPEC Unit 3 are included as Enclosure 1.

Additionally it should be noted that IP3 has submitted an application for License Renewal pursuant to 10 CFR 54. IP3 operating license is scheduled to expire on December 12, 2015. Based on this, Entergy requests that the NRC schedule the review of this information following a final decision on the License Renewal application.

In accordance with 10 CFR 50.91(b), a copy of this application, with the associated attachments, is being provided to the designated New York State official.

New commitments contained in this submittal are provided in Attachment 1. Should you have any questions concerning this submittal, please contact Mr. Robert Walpole at 914-734-6710.

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Docket No. 50-286 NL-10-123 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 4 day of December, 2010.

Sincerely, JEP/mb Attachments:

1. List of Regulatory Commitments
2. 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel

Enclosure:

1. Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3

cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 Mr. John P. Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspectors Office, Indian Point 2 & 3 Mr. Paul Eddy, NYS Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Mr. L. Jager Smith, P.E.

Attachment 1 TO NL-10-123 List of Regulatory Commitments ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

Docket No. 50-286 NL-10-123 Attachment 1 Page 1 of 1 List of Commitments Commitment Commitments Due Date Number NL-10-123 Provide additional funding June 30, 2023 of $55.634 million to trust fund for spent fuel management

Attachment 2 TO NL-1 0-123 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

Docket No. 50-286 NL-10-123 Attachment 2 Page 1 of 15 Background and Introduction Entergy Nuclear Indian Point 3, LLC and Entergy Nuclear Operations, Inc. (collectively herein, "Entergy") are seeking renewal of the operating license for the Indian Point Energy Center, Unit 3 (IP-3), currently set to expire at midnight on December 12, 2015.

However, pursuant to 10 CFR 50.54(bb), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit written notification to the Nuclear Regulatory Commission (NRC) for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of all irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U.S. Department of Energy (DOE) for ultimate disposal. Since Entergy has submitted an application for License Renewal pursuant to 10 CFR 54, Entergy requests that the NRC schedule the review of this information following a final decision on the License Renewal application.

2. Spent Fuel Management Strategy Completion of the decommissioning process is dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was discharged from the reactor. Entergy's current spent fuel management plan for the IP-3 spent fuel is based in general 'upon: 1) a 2020 start date for DOE initiating transfer of commercial spent fuel to a federal facility and 2) expectations for spent fuel receipt by the DOE for the IP-3 fuel. The Company projects that the IP-3 fuel could be completely removed from the site as early as 2047, based on an oldest fuel first priority, the DOE achieving an annual rate of transfer (3,000 metric tons of uranium per year) as reflected in DOE's latest Acceptance Priority Ranking and Annual Capacity Report dated June 2004 (DOE/RW-0567), and a transfer of approximately 30 additional MTUs in 2047, should IP-3 require refueling in 2015 prior to the cessation of operations.

The assumed 2020 DOE start date is nominally based on the last position stated by the DOE. On July 15, 2008, the then-Director of the DOE's Office of Civilian Radioactive Waste Management testified before Congress that DOE "could be ready to begin accepting spent nuclear fuel by 2020," but his statement was based on continued program funding (Reference 1). The current administration has cut the budget for the geological repository program, but the administration has also appointed a Blue Ribbon Commission on America's Nuclear Future to make recommendations for a new plan for nuclear waste disposal. That Commission's charter includes a requirement that the Commission consider "options for safe storage of used nuclear fuel while final disposition pathways are selected and deployed." Entergy believes that one or more monitored retrievable storage facilities could be put into place following a Blue Ribbon Commission recommendation for the same, within a relatively short time frame, at least by 2020. For example, a facility such as that licensed by the NRC to Private Fuel Storage could be

Docket No. 50-286 NL-10-123 Attachment 2 Page 2 of 15 used by the DOE to store fuel until a final disposition is determined. In any event, at this time, there is no basis for the use of another proposed start date for DOE performance.

The NRC requires (in 10 CFR 50.54(bb)) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. Interim storage of the IP-3 spent fuel, until the DOE takes receipt, will be in the IP-3 fuel handling building's storage pool, the IP-2 fuel handling storage pool, and/or at an Independent Spent Fuel Storage Installation (ISFSI).

IP-3 is projected to generate 1,683 spent fuel assemblies through the end of its currently licensed operations in 2015. An ISFSI has been constructed to support plant operations within the owner controlled area. The ISFSI is operated under the site's general license.

The current plan is that the IP-3 spent fuel will be put into on-site dry storage on either the existing ISFSI (space permitting), or to a new ISFSI pending delivery of the fuel to DOE. Article IV.B of Entergy's contract with the DOE for spent fuel disposal requires the DOE to bring a cask "suitable for use at the [IP-3] site." To date, the DOE has failed to provide casks, or even to identify what casks suitable for IP-3 it will provide. Because of this failure of DOE, for ease of planning, Entergy will assume only for the purpose of this plan that the assemblies stored in the IP-3 fuel handling building's spent fuel storage pool at the time of shutdown will be transferred to the IP-2 fuel storage pool and moved into storage casks on the ISFSI pads by 2023. From there, they will be loaded into DOE-supplied transport cask systems for transport to DOE's site. This is the approach Entergy will take to transfer fuel from IP-3 to the ISFSI in mitigation of DOE's breach, so Entergy believes this plan would be workable for transfer of fuel to DOE. The use of this assumption in this plan should not be construed by the DOE or any other party as a statement that Entergy believes this approach would or should be used when DOE ultimately performs its obligations under the contract to bring a cask suitable to IP-3.

Entergy advances this plan only because the DOE has not identified its cask system, and the system's attributes, including but not limited to its weight, fuel capacity, and loading and handling requirements.

This plan assumes that over the next 24 years, the IP-3 MPCs are periodically off-loaded into DOE transport casks such that all IP-3 canisters are removed from the site by the year 2047. The Company's analysis conservatively assumes, for purposes only of this report, that the Company does not employ DOE spent fuel disposal contract allowances for up to 20% additional fuel designation for shipment to DOE each year.

In the event that IP-3 does cease operations in 2015, Entergy will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and ISFSIs, as necessary, under the decommissioning scenario ultimately selected. In addition, Entergy will also comply with applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued storage of irradiated fuel.

Docket No. 50-286 NL-10-123 Attachment 2 Page 3 of 15

3. Cost Considerations The total costs to decommission IP-3 are delineated in the "Preliminary Decommissioning Cost Analysis" (Reference 2). In this document, decommissioning costs are allocated into the three major categories of license termination, spent fuel management and site restoration. The allocations are reproduced in Table 1 (Summary of Major Cost Contributors). All costs are reported in 2010 nominal dollars.

The timing of the spent fuel management expenditures ($227.954 million) is shown in Table 2. The expenditures include direct costs (e.g., for construction of a second ISFSI, handling, packaging, storing and transferring the spent fuel) as well as indirect costs such as program management and oversight, security, pool and ISFSI operating costs, fees, insurance, etc., projected to be incurred over the post-operations storage period.

The significant contributors to the direct cost of IP-3 spent fuel management are identified in Table 3. As shown, costs are included for the construction of the second ISFSI, procurement of MPCs, as well as the loading and transfer activities associated with transferring the spent fuel from the pools to the ISFSI pads, and the eventual transfer of the fuel at the ISFSIs to the DOE. The direct cost of $121.110 million is a subset of the

$227.954 million shown in Table 2. The timing of the direct spent fuel management expenditures ($121.110 million) is shown in Table 4.

It must also be noted that these figures will vary based on actual DOE performance, including the actual cask provisions and requirements that DOE settles upon. At this time, DOE has not identified any transport casks or requirements. Therefore, there is considerable uncertainty as to the actual costs that may have to be incurred; and uncertainty as to whether the DOE will agree to bear certain of those costs. Major scheduling milestones are identified in Table 5.

At shutdown, the IP-3 spent fuel pool is expected to contain freshly discharged assemblies from the most recent refueling cycles. It is assumed for purposes of this cost estimate that IP-3 will not transfer spent fuel directly from its pool to the ISFSI. As such, in accordance with the proposed changes to the operating licenses and technical specifications for IP-2 and IP-3 (Reference 3), the IP-3 assemblies are planned to be transferred in a specially designed, lightweight shielded transfer canister to the IP-2 spent fuel pit. The transfer would occur over an eight year period following the permanent cessation of IP-3 operations. Once in the IP-2 spent fuel pit, the IP-3 spent fuel will be moved into MPCs and placed out on one of the ISFSIs. It is assumed that this time period (eight years) is sufficient to meet the decay heat requirements for dry storage.

To support decommissioning operations, Entergy anticipates loading 41 MPCs with the IP-3 assemblies stored in the IP-2 fuel building's spent fuel pool. The MPCs will then be placed in storage casks at the ISFSI(s). The decommissioning scenario assumes that the existing ISFSI will need to be supplemented with capacity from a new ISFSI to accommodate the spent fuel remaining in the IP-3 pool at shutdown.

Docket No. 50-286 NL-10-123 Attachment 2 Page 4 of 15 In the absence of identifiable DOE cask requirements, for purposes of this plan only, the design and capacity of the MPCs is based upon the commercial dry cask storage system already in use at Indian Point (Holtec HI-STORM). The Holtec multi-purpose canister has a capacity of 32 fuel assemblies at a unit cost of approximately $675,000. An additional cost of $400,000 is allocated for the concrete storage overpack. It should be noted that Entergy's contract with the DOE requires DOE to provide transport casks to Entergy, but for present purposes, this estimate conservatively includes those costs.

An average unit cost of approximately $425,000 was estimated for the labor and equipment to load, seal and transfer each MPC from the IP-2 storage pool to the ISFSI.

A unit cost of approximately $75,000 was estimated for the final transfer of the MPC at the ISFSI into a DOE transport cask. It is not known what the loading, sealing and transport costs will be for actual DOE-supplied equipment, because DOE has not identified that equipment. It is assumed, for purposes of this plan only, that DOE will accept the Holtec MPCs, and will not require offloading of the fuel to the DOE-supplied equipment.

Operation of the IP-3 spent fuel pool is discontinued in 2023 once the fuel has been transferred to dry storage. ISFSI operations continue until such time that the DOE is able to complete the transfer of the fuel from all three units from the site (currently anticipated to be in 2047 for IP-3).

4. ISFSI Decommissioning With the spent fuel removed from the site, the ISFSIs are available for decommissioning.

It is assumed that once the MPCs containing the spent fuel assemblies have been removed, any required decontamination is performed on the storage modules, and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pads can then be removed and the area regraded. The cost estimated to decontaminate any activated overpacks to the extent necessary to release the facilities for conventional demolition is estimated at $1.1 million. Conventional demolition of the remaining overpacks and pads and restoration of the affected area of the site is estimated at $1.9 million.

5. Plan for Funding Spent Fuel Management As of October 31, 2010, the trust fund balance for IP-3 was approximately $486.4 million. The decommissioning liability is currently retained, and the trust fund held, by the New York Power Authority (NYPA). This analysis assumes that NYPA will exercise its option to transfer the liability along with the decommissioning trust fund for IP-3 to Entergy on December 12, 2015, in accordance with the terms of the decommissioning agreement for IP-3 between Entergy and NYPA.

Pursuant to the Decommissioning Agreement for Indian Point 3 between Entergy and NYPA, NYPA may terminate its obligation to decommission IP-3 by transferring to Entergy the lesser of the available trust fund balance or an "Inflation Adjusted Cost Amount," (IACA), or may contract with Entergy Nuclear, Inc. for decommissioning at an

Docket No. 50-286 NL-10-123 Attachment 2 Page 5 of 15 equivalent fixed price (Reference 4). The IACA starts at $564 million as of 2000, and increases over time. Between 2000 and 2015, the IACA escalates based on increases in the NRC minimum value calculated pursuant to 10 CFR §50.75(c). The growth for that figure for IP-3 averaged approximately 3.1% between 2000 and the end of 2009. Entergy estimates that as of the end of 2009, the IACA was approximately $695 million, and if the average continues, the value would be approximately $716 million at the end of 2010.

Pursuant to the Decommissioning Agreement, the IACA escalates at 6.5% per annum beginning in 2015. The IACA is substantially above the available trust fund balance, and may reasonably be assumed to remain so. Accordingly, for purposes of this analysis, Entergy assumes that NYPA will either transfer the available trust fund balance to Entergy for decommissioning, or will retain Entergy for the decommissioning project at a cost equivalent to the trust fund balance (the results being the same in either case).

Although Entergy assumes here that the funds transfer would occur on December 12, 2015, the actual date of the transfer will not affect the outcome, because Entergy escalates the trust fund balance (to which it will have access under the Decommissioning Agreement) at the 2% real growth rate allowed by 10 CFR §50.75(e)(1)(i) regardless of whether the funds are being held by NYPA, or whether the funds have been transferred to Entergy.

As shown in Reference 2, the cost to decommission IP-3 is estimated at approximately

$1,141.9 million (in 2010 dollars). The estimate is based upon a scenario under which the unit would cease operating in 2015 and be placed in safe-storage until decommissioning operations commence on the adjoining units. Decommissioning of all three units would be complete no later than 60 years after cessation of permanent operations of IP-2, i.e., in year 2073 (Reference 5).

Approximately 73% of the total or $836.445 million is estimated to be required to terminate the operating license and 20% of the total or $227.954 million to manage the spent fuel until such time that it can be transferred to the DOE (the remaining 7% is associated with site restoration activities).

The decommissioning funding plan is shown in Table 6. To demonstrate the adequacy of the existing funds to cover both license termination and spent fuel management, the fund balance going forward is escalated at 2% per year. In year 2023, Entergy Nuclear Indian Point 3, LLC deposits an additional $55.6 million (or $43.0 million in 2010 dollars) into the decommissioning fund. The results of this analysis demonstrate that the balance in the decommissioning trust, with the additional deposit, is adequate to fund both the license termination and spent fuel management costs.

Although the decommissioning trust fund is for radiological decommissioning cost only, to the extent that the trust fund balance exceeds costs required for radiological decommissioning, these funds would be available to address costs incurred by the licensee including spent fuel management costs. The licensee acknowledges the need for an exemption pursuant to 10 CFR 50.12(a) to use radiological decommissioning trust funds for anything beyond decommissioning activities as defined in 10 CFR 50.2.

Docket No. 50-286 NL-10-123 Attachment 2 Page 6 of 15 It should be noted that the projected expenditures for spent fuel management identified in the decommissioning cost analysis do not consider the outcome of the litigation (including compensation for damages) with the DOE with regards to the delays incurred by Entergy in the timely removal of the spent fuel from the site. Entergy views the extended spent fuel management costs to be damages that should be paid by the government because of the Department of Energy's breach of the spent fuel disposal contract. In addition, this analysis assumes no license renewal, which is another conservatism.

6. References
1. Statement of Edward F. Sproat, III, Director Office of Civilian Radioactive Waste Management, U.S. Department of Energy, Before the Subcommittee on Energy and Air Quality Committee on Energy and Commerce U.S. House of Representatives, July 15, 2008.
2. "Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3," No. Document El1-1583-006, TLG Services, Inc., November 2010.
3. Entergy Letter NL-09-076, dated July 08, 2009 (Accession No. ML091940177),

"Application for Unit 2 Operating License Condition Change and Units 2 and 3 Technical Specification Changes to Add Inter-Unit Spent Fuel Transfer Requirements."

4. Decommissioning Agreement (Indian Point 3) between Power Authority of the State of New York, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear, Inc., dated November 21, 2000.
5. Entergy Letter NL-08-144, dated October 27, 2008, "Unit 1 & 2 program for Maintenance of Irradiated Fuel and Preliminary Decommissioning Cost Analysis in accordance with 10 CFR 50.54 (bb) and 10 CFR 50.75(f)(3).

Docket No. 50-286 NL-10-123 Attachment 2 Page 7 of 15 Table 1 Summary of Major Cost Contributors (thousands, 2010 dollars)

License Spent Fuel Site Termination Management Restoration Total Decontamination 15,315 - - 15,315 Removal 126,758 1,960 37,996 166,715 Packaging 24,991 10 - 25,001 Transportation 61,929 46 - 61,975 Waste Disposal 151,520 59 - 151,579 Off-site Waste Processing 36,095 - - 36,095 Program Management tI 224,824 44,029 38,063 306,915 Corporate A&G 28,428 - - 28,428 Site O&M 20,770 1,104 - 21,874 Spent Fuel (Direct Costs) - 176,008 - 176,008 Spent Fuel Pool Isolation 7,652 - - 7,652 Insurance and Regulatory Fees 48,689 761 - 49,450 Energy 34,060 2,291 1,401 37,752 Radiological Surveys 19,778 - - 19,778 Property Taxes ......... -

Miscellaneous Equipment 16,542 - 5 16,547 Environmental Monitoring 19,096 1,687 - 20,782 Total 836,445 227,954 77,465 1,141,864

[1] Includes security and engineering

[2] Includes capital costs for the construction of a second ISFSI, multi-purpose dry storage containers and storage overpacks, packaging and handling (transfer from IP-3 pool to IP-2 pool and then to ISFSI, ISFSI to DOE transfer)

Docket No. 50-286 NL-10-123 Attachment 2 Page 8 of 15 Table 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2010 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2015 327 981 0 0 141 1,449 2016 5,726 17,179 0 0 2,572 25,477 2017 4,851 7,496 193 0 2,836 15,376 2018 7,602 10,053 350 0 3,054 21,059 2019 7,602 10,053 350 0 3,054 21,059 2020 7,623 10,081 351 0 3,062 21,117 2021 7,602 10,053 350 0 3,054 21,059 2022 7,602 10,053 350 0 3,054 21,059 2023 7,584 10,027 349 0 3,049 21,008 2024 744 203 0 0 1,408 2,355 2025 742 203 0 0 1,404 2,349 2026 742 203 0 0 1,404 2,349 2027 742 203 0 0 1,404 2,349 2028 744 203 0 0 1,408 2,355 2029 742 203 0 0 1,404 2,349 2030 742 203 0 0 1,404 2,349 2031 742 203 0 0 1,404 2,349 2032 744 203 0 0 1,408 2,355 2033 742 203 0 0 1,404 2,349 2034 742 203 0 0 1,404 2,349 2035 742 203 0 0 *1,404 2,349 2036 744 203 0 0 1,408 2,355 2037 742 203 0 0 1,404 2,349 2038 742 203 0 0 1,404 2,349 2039 742 203 0 0 1,404 2,349 2040 744 203 0 0 1,408 2,355 2041 742 203 0 0 1,404 2,349 2042 742 203 0 0 1,404 2,349 2043 742 203 0 0 1,404 2,349 2044 744 203 0 0 1,408 2,355 2045 742 203 0 0 1,404 2,349 2046 742 203 0 0 1,404 2,349

Docket No. 50-286 NL-10-123 Attachment 2 Page 9 of 15 Table 2 Schedule of Annual Expenditures Spent Fuel Management Allocation (thousands, 2010 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2047 707 193 0 0 1,339 2,240 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 0 0 0 0 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 0 2056 0 0 0 0 0 0 2057 0 0 0 0 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 1 17 0 15 234 267 2068 4 52 0 45 697 797 2069 99 28 .0 0 2 129 2070 368 105 0 0 7 480 2071 368 105 0 0 7 480 2072 369 106 0 0 7 481 2073 271 78 0 0 5 354 Total 75,784 91,324 2,291 59 58,496 227,954

Docket No. 50-286 NL-10-123 Attachment 2 Page 10 of 15 Table 3 Significant Cost Contributors (thousands, 2010 dollars)

Spent Fuel Management - Direct Expenditures Cost P]

Spent Fuel Transfer Facility [2J $ 2,060 ISFSI Construction (for 35 Casks) $13,340 Transfer Costs from IP-3 Pool to IP-2 Pool (170 transfers) $ 29,180 Capital Costs for ISFSI MPCs and Overpacks $ 50,686 TAD Loading and Transfer Costs from IP-2 Pool to DOE $1,464 MPC Loading and Transfer Costs from IP-2 Pool to ISFSIs $ 20,004 MPC Transfer Costs from ISFSIs to DOE $ 4,377 Total $121,110

[1] Contingency has been added to all costs (15%)

[2] Cost shared with IP-2

Docket No. 50-286 NL-10-123 Attachment 2 Page 11 of 15 Table 4 Estimated Expenditures for Spent Fuel Packaging, Storage and Canister Transfer *

(thousands, 2010 dollars)

IP-2 Pool IP-2 Pool to DOE to ISFSI Fuel IP-3 Pool to Loading Loading ISFSI Transfer ISFSI IP-2 Pool MPCs and and and to DOE Year Facility Construction Transfer Overpacks Transfer Transfer Transfer Total 2015 2016 4,447 3,647 12,363 - 4,879 - 25,336 2017 4,447 3,647 12,363 - 4,879 - 25,336 2018 4,447 3,647 4,945 - 1,952 - 14,991 2019 - 3,647 3,709 - 1,464 - 8,820 2020 - 3,647 3,709 - 1,464 - 8,820 2021 - 3,647 3,709 - 1,464 - 8,820 2022 - 3,647 3,709 - 1,464 - 8,820 2023 -- 3,647 6,181 1,464 2,439 - 13,732 2024 2,060 - - - - 172 2,231 2025 - - 172 172 2026 - 257 257 2027 - 172 172 2028 - 172 172 2029 - -- 172 172 2030 - - 257 257 2031 - - -

2032 -...

2033 - - -

2034 - - 172 172 2035 - - 257 257 2036 - - - ....

2037 - - 172 172 2038 - - - 257 257 2039 - - " -

2040 - - - - 257 257 2041 - - - - 257 257 2042 - - - - -

2043 - - - - 257 257 2044 - - - 257 257 2045 -- - 257 257 2046 - - 86 86 2047 - - - - 772 772 Total 2,060 13,340 29,180 1 50,686 1,464 20,004 4,377 121,110

  • A 15% contingency factor has been applied to all spent fuel related costs

Docket No. 50-286 NL-10-123 Attachment 2 Page 12 of 15 Table 5 Indian Point Energy Center, Unit 3 Projected Schedule and Milestones Major Milestones and Fuel-Related Events Currently scheduled cessation of plant operations December 2015 Second ISFSI available 2018 First MPC transferred post-shutdown from pool to ISFSI 2016 Last MPC transferred post-shutdown from pool to ISFSI 2023 End of wet storage pool operations 2023 DOE begins to receive commercial spent fuel 2020 First IP-3 fuel assembly removed from site 2023 Last IP-3 fuel assembly leaves site 2047 Last year of ISFSI operations 2047 ISFSI decommissioned t21 2067 - 2068 ISFSI demolition [I] 2069 - 2072

[1] ISFSIs operational until Indian Point 3 fuel transfer complete

[2] ISFSIs decontaminated and dismantled in conjunction with decommissioning of the three nuclear units on site

Docket No. 50-286 NL-1 0-123 Attachment 2 Page 13 of 15 Table 6 Decommissioning Funding Plan 2015 Shutdown and SAFSTOR Basis Year 2010 ______

Fund Balance $486.380 (millions) (as of 10/31/2010) ________

Annual Escalation 0.00%

Annual Earnings 2.00% ______

A B C D E F Total License Termination 50.75 5O.54(bb) and Spent Decommissioning License Spent Fuel Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%

Cost Cost Cost 0% to Trust Fund (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) 2010 0 0 0 0 486.380 2011 0 0 0 0 496.108 2012 0 0 0 0 506.030 2013 0 0 0 0 516.151 2014 0 0 0 0 526.474 2015 2.490 1.449 3.940 3.940 533.064 2016 47.191 25.477 72.669 72.669 471.056 2017 37.490 15.376 52.866 52.866 427.612 2018 3.466 21.059 24.526 24.526 411.638 2019 3.466 21.059 24.526 24.526 395.345 2020 3.476 21.117 24.593 24.593 378.659 2021 3.466 21.059 .24.526 24.526 361.707 2022 3.466 21.059 24.526 24.526 344.415 2023 3.466 21.008 24.474 24.474 55.634 382.463 2024 3.460 2.355 5.815 5.815 384.297 2025 3.450 2.349 5.799 5.799 386.184 2026 3.450 2.349 5.799 5.799 _______388.108 2027 3.450 2.349 5.799 5.799 390.071 2028 3.460 2.355 5.815 5.815 392.057 2029 3.450 2.349 5.799 5.799 394.099 2030 3.450 2.349 5.799 5.799 396.181 2031 3.450 2.349 5.799 5.799 398.306 2032 3.460 2.355 5.815 5.815 _______400.457 2033 3.450 2.349 5.799 5.799 _______402.666

Docket No. 50-286 NL-10-123 Attachment 2 Page 14 of 15 Table 6 (continued)

Decommissioning Funding Plan 2015 Shutdown and SAFSTOR Basis Year 2010 Fund Balance $486.380 (millions) (as of 10/31/2010)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C D E F Total License Termination 50.75 50.54(bb) and Spent Decommissioning License Spent Fuel Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%

Cost Cost Cost 0% -to Trust Fund (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) 2034 3.450 2.349 5.799 5.799 404.920 2035 3.450 2.349 5.799 5.799 407.219 2036 3.460 2.355 5.815 5.815 409.548 2037 3.450 2.349 5.799 5.799 411.940 2038 3.450 2.349 5.799 5.799 414.380 2039 3.450 2.349 5.799 5.799 416.868 2040 3.460 2.355 5.815 5.815 419.390 2041 3.450 2.349 5.799 5.799 421.978 2042 3,450 2.349 5.799 5.799 424.619 2043 31450 2.349 5.799 5.799 427.312 2044 31460 2.355 5.815 5.815 430.043 2045 31450 2.349 5.799 5.799 432.844 2046 3.450 2.349 5.799 5.799 43.5.702 2047 3.450 2.240 5.690 5.690 438.726 2048 3.460 0.000 3.460 3.460 444.040 2049 3.450 0.000 3.450 3.450 449.471 2050 3.450 0.000 3.450 3.450 455.010 2051 3.450 0.000 3.450 3.450 460.659 2052 3.460 0.000 3.460 3.460 466.413 2053 3.450 0.000 3.450 3.450 472.291 2054 3.450 0.000 3.450 3.450 478.286 2055 3.450 0.000 3.450 3.450 484.401 2056 3.460 0.000 3.460 3.460 490.629 2057 3.450 0.000 3.450 3.450 496.991

Docket No. 50-286 NL-10-123 Attachment 2 Page 15 of 15 Table 6 (continued)

Decommissioning Funding Plan 2015 Shutdown and SAFSTOR Basis Year 2010 Fund Balance $486.380 (millions) (as of 10/31/2010)

Annual Escalation 0.00%

Annual Earnings 2.00%

A B C D E F Total License Termination 50.75 50.54(bb) and Spent Decommissioning License Spent Fuel Fuel Total Cost Trust Fund Termination Management Management Escalated at Contributions Escalated at 2%

Cost Cost Cost 0% to Trust Fund (minus expenses)

Year (millions) (millions) (millions) (millions) (millions) (millions) 2058 3.450 0.000 3.450 3.450 503.481 2059 3.450 0.000 3.450 3.450 510.100 2060 3.460 0.000 3.460 3.460 516.842 2061 3.450 0.000 3.450 3.450 523.729 2062 3.450 0.000 3.450 3.450 530.753 2063 3.450 0.000 3.450 3.450 537.917 2064 3.460 0.000 3.460 3.460 545.216 2065 23.419 0.000 23.419 23.419 532.701 2066 83.467 0.000 83.467 83.467 459.887 2067 206.738 0.267 207.005 207.005 262.080 2068 114.077 0.797 114.874 114.874 152.448 2069 39.020 0.129 39.149 39.149 116.348 2070 32.134 0.480 32.614 32.614 86.061 2071 32.134 0.480 32.614 32.614 55.169 2072 32.222 0.481 32.703 32.703 23.569 2073 23.682 0.354 24.036 24.036 0.01 Total 836.445 227.954 1064.399 Calculations:

Column C = A + B Column D = (C)*(1+0%) A(current year - 2010) or for 0%, D = C Column F = (Previous year's fund balance) * (1 + .02) + E (contributions to the trust fund) - D (current year's decommissioning expenditures)

ENCLOSURE 1 TO NL-10-123 Preliminary Decommissioning Cost Analysis for the Indian Point Energy Center, Unit 3 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

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