View source for BVY 14-085, Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)

{{Adams
| number = ML14358A251
| issue date = 12/19/2014
| title = Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
| author name = Wamser C
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000271
| license number = DPR-028
| contact person = 
| case reference number = BVY 14-085
| document type = Letter type:BVY, Report, Miscellaneous
| page count = 23
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Operations, Inc.
Vermont Yankee 320 Governor Hunt Rd.
---Entergy                                                              Vernon, VT 802-257-7711 Christopher J. Wamser Site Vice President BVY 14-085                                                            10 CFR 50.54(bb)
December 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

==REFERENCES:==
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb),"
BVY 08-077, dated October 14, 2008 (ML082910294)
: 3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. MD8035 and MD8051)," NVY 09-009, dated February 3, 2009 (ML083390193)
: 4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)
: 5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan - RAI Response," BVY 09-048, dated August 18, 2009 (ML092370298)
: 6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC No. ME1152)," NVY 09-100, dated October 8, 2009 (ML092740238)
: 7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)
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BVY 14-085 / Page 2 of 3

==Dear Sir or Madam:==

In accordance with 10 CFR 50.54(bb), Entergy Nuclear Operations, Inc. (ENO) is hereby notifying the NRC of significant changes to the Vermont Yankee Nuclear Power Station (VYNPS) Program for Management of Irradiated Fuel.
Pursuant to 10 CFR 50.54(bb), ENO initially submitted a Program for Maintenance of Irradiated Fuel on March 21, 2007 (Reference 1) and a Revised Program for Maintenance of Irradiated Fuel on October 14, 2008 (Reference 2). On February 3, 2009, the NRC staff approved the VYNPS irradiated fuel management program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).
On April 1, 2009, ENO submitted an update to its irradiated fuel management program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). The NRC staff approved the revised irradiated fuel management program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).
By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur in the fourth quarter of 2014 (Reference 7). As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program for Management of Irradiated Fuel. This submittal provides the required Section 50.54(bb) notification. Attachment 1 provides the Updated Program for Management of Irradiated Fuel (Program), which supersedes all prior versions of the Program.
In Reference 5, Entergy Nuclear Vermont Yankee, LLC committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. Based on the funding strategy described in the updated Program, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment. There are no new regulatory commitments made by this letter. of this letter contains one cancelled regulatory commitment.
Should you have any questions concerning this letter or require additional information, please contact Mr. Philip Couture at 802-451-3193.
Sincerely, CJW/plc/shr

BVY 14-085 / Page 3 of 3 Attachments:       1. Updated Program for Management of Irradiated Fuel
: 2. List of Cancelled Regulatory Commitments cc:     Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 14-085 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel

BVY 14-085 1 Attachment 1 / Page 1 of 17 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel I.       Background and Introduction Entergy Nuclear Operations, Inc. (ENO) submitted a Program for Maintenance of Irradiated Fuel (Program) on March 21, 2007 (Reference 1) and a revised Program on October 14, 2008 (Reference 2) for Vermont Yankee Nuclear Power Station (VYNPS). ENO submitted these programs pursuant to 10 CFR 50.54(bb), which requires power reactor licensees to submit a spent fuel management and funding program for NRC review five years prior to the expiration of a reactor operating license. At the time, the VYNPS operating license was set to expire on March 21, 2012. On February 3, 2009, the NRC staff approved the VYNPS Program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).
On April 1, 2009, ENO submitted an update to the VYNPS Program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). In Reference 5, VYNPS owner Entergy Nuclear Vermont Yankee, LLC (ENVY) committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. The NRC staff approved the revised VYNPS Program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).
By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur later this month (Reference 7).
Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes to their proposed spent fuel management plans. As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program. This submittal provides the required Section 50.54(bb) notification. This updated Program supersedes all prior versions of the Program.
Pursuant to 10 CFR 50.82(a)(4)(i), on December 19, 2014, ENO submitted a Post Shutdown Decommissioning Activities Report (PSDAR) for VYNPS that included a site-specific decommissioning cost estimate (DCE) as an attachment (Reference 8). The DCE describes the bases for the assumptions regarding the DOE's acceptance of spent fuel from the industry and from VYNPS. As discussed in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the Program is based on the assumption that DOE will commence acceptance of VYNPS's spent fuel in 2026 and complete removal of all spent fuel from the site in 2052, consistent with the current DOE spent fuel management and acceptance strategy.'
As noted in the DCE, DOE's repository program assumes that spent fuel is accepted for disposal from the nation's commercial nuclear plants in the order ("queue") in which it was removed from service ("oldest fuel first"). The contracts that U.S. generators have with the DOE provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst generators, and the option of providing priority acceptance from permanently shutdown nuclear reactors. VYNPS will seek the most expeditious means of removing fuel from the site when DOE commences performance. Given DOE's failure to accept fuel under its contracts, however, it is unclear how these mechanisms will operate once DOE begins accepting

BVY 14-085 / Attachment 1 / Page 2 of 17 The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the Program, along with license termination and site restoration activities and costs.
II.      Irradiated Fuel Management Strategy At the time of shutdown, there will be 368 fuel assemblies residing in the reactor as part of the current operating cycle, 2,628 spent fuel assemblies 2 stored in the spent fuel pool, and 884 assemblies stored in 13 dry storage casks on an independent spent fuel storage installation (ISFSI) pad. In 2008, construction of the first ISFSI pad was completed, which VYNPS operates under a 10 CFR Part 50 General License (in accordance with 10 CFR Part 72, Subpart K).
VYNPS selected the Holtec HI-STORM 1OOS dry cask storage system for the spent fuel that is currently stored on the ISFSI. The system consists of a multipurpose canister (MPC) with a nominal capacity of 68 fuel assemblies and a concrete storage overpack. The current ISFSI pad was constructed to support 36 dry storage casks (the pad has four additional unused storage locations to allow VYNPS to move the casks if needed). VYNPS completed fuel loading campaigns to the ISFSI in 2008, 2011, and 2012.
As indicated in the VYNPS PSDAR (Reference 8), ENVY has selected the SAFSTOR decommissioning option. The Program assumes that decommissioning is completed within 60 years of permanent plant shutdown (i.e., by the end of 2074). Following shutdown, the reactor building will be operated as an interim wet fuel storage facility for approximately five and one-half years after operations cease. During this time period, the spent fuel residing in the storage pool will be transferred to the ISFSI. The ISFSI will remain operational until DOE is able to accept title to the fuel and complete the transfer of the fuel off site.
The PSDAR and DCE describe three major phases related to spent fuel management at VYNPS, which are summarized below. 3 Spent fuel management activities are further broken out into two categories - "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, and "transfer to dry storage" activities, such as procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad.
spent fuel from commercial reactors. Accordingly, for planning purposes only, this Program assumes that DOE will accept spent fuel in an oldest fuel first order.
2   This figure includes one fuel debris canister.
3   Appendix C to the DCE (Reference 8, Attachment 1) includes a detailed cost analysis of all decommissioning activities, including spent fuel management activities, by period.

BVY 14-085 / Attachment 1 / Page 3 of 17 TABLE I - Irradiated Fuel Management Program: Summary Schedule and Costs Decommissioning Period                     Start  End Duration     Cost (thousands (Years)     of 2014 dollars)
Periods 0 and 1: Planning and Preparations for        2013   2016 2.6                      23,068 Dormancy Spent Fuel Management Operations                             6,055 Transfer to Dry Storage                          17,013 Period 2a: Dormancy with Wet Fuel Storage             2016   2020 4.2                    217,318 Spent Fuel Management Operations                             91,696 Transfer to Dry Storage                          125,548 Period 2b: Dormancy with Dry Fuel Storage             2020   2052 32.5                   127,961 Spent Fuel Management Operations                             127,961 TOTAL                                                             39.3                   368,347
: 1. Pre-Shutdown Planning and Preparations for SAFSTOR Dormancy Pre-shutdown planning activities include designing an expanded ISFSI facility to include a second storage pad, which is expected to be located in close proximity to the existing pad. The second pad is being designed for storage of 25 casks, and combined with the existing pad, will allow for dry storage of all spent fuel assemblies generated during the plant operations.
The initial decommissioning activities to be performed after plant shutdown will focus primarily on preparing the plant for a period of safe-storage (also referred to as dormancy) and constructing a second ISFSI pad. During this phase, VYNPS plans to complete the design of the new ISFSI pad and initiate site work. VYNPS also plans to commence security modifications supporting future ISFSI and dormancy operations during this time period.
The estimated spent fuel management costs associated with ISFSI design and construction, site security modifications, and other expenses during this initial phase, such as emergency planning and preparations for dormancy, total approximately $23.1 million.
: 2. Dormancy with Wet Fuel Storage During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. VYNPS expects to complete expansion of the ISFSI in 2017, assuming the timely receipt of the required state regulatory approvals. The estimated costs associated with expanding the ISFSI, including construction of the second pad and related security modifications, total approximately $32.7 million. Table 2 below provides additional detail on certain estimated dry storage-specific expenditures.
VYNPS expects to begin transferring the remaining spent fuel from the spent fuel pool to the ISFSI in 2019 and to complete the transfer of all fuel to the ISFSI by mid-2020. In total, 3,879 spent fuel assemblies and one fuel debris canister will be stored in 58 dry cask systems on the two ISFSI pads. Costs associated with purchasing 45 additional dry cask systems, loading fuel, and transferring fuel from the spent fuel pool to the ISFSI are included in this phase. After the fuel transfer is completed, the pool will be drained and supporting systems will be de-energized for the remainder of the dormancy period.
The total estimated spent fuel -management costs associated with this phase is approximately
$217.3 million.

BVY 14-085 / Attachment 1 / Page 4 of 17
: 3. Dormancy with Dry Fuel Storaae During this phase, the spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the DCE (Reference 8, Attachment 1), for planning purposes, the current Program assumes that DOE will begin removing fuel from VYNPS in 2026 and will complete the removal of all spent fuel from the site in 2052, according to the schedule set forth in Table 3 below.
During this phase, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Equipment maintenance, monitoring, and inspection will be performed as necessary. VYNPS will also maintain a 24-hour security force, whose primary responsibility will be to safeguard the spent fuel for as long as it remains on site. A security barrier, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the spent fuel. The estimated average annual cost to operate the ISFSI during this phase is approximately $4 million.
Late in the dormancy period, additional activities will include transferring the spent fuel from the ISFSI to the DOE. The estimated cost for the eventual transfer of the MPCs to a DOE-provided transport vehicle for off-site disposal is approximately 4
                                                                $10 million, excluding a $4.4 million allowance for a spent fuel transfer facility.
The total estimated spent fuel management cost associated with this phase is approximately
$127.96 million.
As noted in the DCE (Reference 8, Attachment 1), DOE has breached its obligations to remove fuel from reactor sites on the contracted schedule, and has also failed to provide plant owners with information about how it will ultimately perform and fulfill its obligation. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to the Standard Contract, but DOE has not explained what costs any such amendment would involve.
Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will specifically deal with already-canistered fuel, and for purposes of the DCE only, the DCE assumes that there will be no additional costs associated with DOE's acceptance of such fuel. If this assumption is incorrect, it is assumed that DOE will have liability for costs incurred to transfer the fuel to DOE-supplied containers, and to dispose of existing containers.

BVY 14-085 / Attachment 1 / Page 5 of 17 Table 2 - Estimated Expenditures for ISFSI Construction, Spent Fuel Packagina and Canister Transfer (thousands, 2014 dollars?
Spent Fuel        MPC and New ISFSI         Related          Storage       ISFSI       Fuel     ISFSI to Pad           Security         Overpack     Loading     Transfer     DOE Year     Construction   Modifications         Costs     Campaigns    Facility   Transfer     Total 2014            4,753                  0             0             0          0         0      4,753 2015            7,529              2,215             0             0          0         0      9,744 2016            7,613                  0             0             0          0         0      7,613 2017            3,545                  0        25,907             0          0         0     29,452 2018                0              1,400        37,940         1,375          0         0     40,715 2019                0              4,250        13,623       21,780           0         0     39,653 2020                0              1,400         1,311         7,920          0         0     10,631 2021                0                  0             0             0          0         0           0 2022                0                  0             0             0          0         0           0 2023                0                  0             0             0          0         0           0 2024                0                  0             0             0          0         0           0 2025                0                  0             0             0     4,416          0      4,416 2026                0                  0             0             0          0       863        863 2027                0                  0             0             0          0         0           0 2028                0                  0             0             0          0       518        518 2029                0                  0             0             0          0       690        690 2030                0                  0             0             0          0       518        518 2031                0                  0             0             0          0       518        518 2032                0                  0             0             0          0       345        345 2033                0                  0             0             0          0       345        345 2034                0                  0             0             0          0       345        345 2035                0                  0             0             0          0       345        345 2036                0                  0             0             0          0       345        345 2037                0                  0             0             0          0       345        345 2038                0                  0             0             0          0       345        345 2039                0                  0             0             0          0       345        345 2040                0                  0             0             0          0         0           0 2041                0                  0             0             0          0       173        173 2042                0                  0             0             0          0       173        173 2043                0                  0             0             0          0       518        518 2044                0                  0             0             0          0       345        345 2045                0                  0             0             0          0       345        345 2046                0                  0             0             0          0       345        345 2047                0                  0             0             0          0       345        345 2048                0                  0             0             0          0       345        345 2049                0                  0             0             0          0       345        345 2050                0                  0             0             0          0       345        345 2051                0                  0             0             0          0         0           0 2052                0                  0             0             0          0       863        863 Total          23,440              9,265        78,782       31,075      4,416     10,005    156,983 5
The costs identified in the first four columns (New ISFSI Pad Construction, Spent Fuel Related Security Modifications, MPC and Storage Overpack Costs, and ISFSI Loading Campaigns) are considered "transfer to dry storage" costs.

BVY 14-085 / Attachment 1/ Page 6 of 17 TABLE 3 - Spent Fuel Management Schedule (Fuel Assembly Totals by Location)
Pool         ISFSl            DOE Year Inventory       Inventory      Acceptance6 2014         2,996          884 2015         2,996          884 2016         21996          884 2017         2,996          884 2018         2,996          884 2019           820        3,060 2020              0      3,8807 2021                      3,880 2022                      3,880 2023                      3,880 2024                      3,880 2025                      3,880 2026                      3,502                 378 2027                      3,502                     -
2028                      3,284                 218 2029                      3,010                 274 2030                      2,784                 226 2031                      2,558                 226 2032                      2,422                 136 2033                      2,286                 136 2034                      2,157                 129 2035                      2,029                 128 2036                      1,901                 128 2037                      1,781                 120 2038                      1,661                 120 2039                      1,549                 112 2040                      1,549   _
2041                      1,464                  85 2042                      1,405                  59 2043                      1,209                 196 This schedule is provided for illustrative purposes only and assumes that DOE begins accepting VYNPS fuel in 2026. It is expected that VYNPS will seek to accelerate acceptance based on shutdown reactor priority, exchanges of acceptance allocations, and other Standard Contract provisions.
Includes one fuel debris canister, which, for purposes of this analysis and for convenience, is assumed to be picked up in the final year of DOE acceptance (2052).

BVY 14-085 / Attachment 1 / Page 7 of 17 TABLE 3 - Spent Fuel Management Schedule (cont'd)
(Fuel Assembly Totals by Location)
Pool     ISFSI           DOE, Year Inventory    Inventory     Acceptance 2044                   1,073               136 2045                     949               124 2046                     821               128 2047                     701               120 2048                     585               116 2049                     469               116 2050                     349               120 2051                     349 2052                                       349 Total                                    3,880 Ill. ISFSI Decommissioning The ISFSI pads and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site. The bases and assumptions used to formulate the cost estimate are discussed in the DCE (Reference 8, Attachment 1). As detailed in Appendix D to the DOE, the estimated cost to decommission the ISFSI is approximately $5.1 million.
IV.      Funding Demonstration for License Termination and Spent Fuel Management Operations Costs As shown in the DCE (Reference 8, Attachment 1), the projected total cost to decommission VYNPS, after an extended period of safe storage, is estimated at $1.24 billion (in 2014 dollars).
This amount includes estimated costs associated with license termination ($817.22 million),
interim spent fuel storage ($368.35 million), and site restoration ($57.15 million) activities.
In Reference 9, ENO submitted an updated Decommissioning Funding Status report.
Reference 9 reported the VYNPS decommissioning trust fund balance to be approximately $655 million as of October 31, 2014. Tables 3.4 and 3.5 of the DCE (Reference 8, Attachment 1) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. For convenience, those tables are reproduced below as Tables 4 and 5. This annual expenditure information is used in the cash flow analysis in Table 6 below. The cash flow analysis demonstrates that the VYNPS trust fund is sufficiently funded for all license termination activities and certain spent fuel management activities. ENVY plans to fund "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, from the trust fund. Of the estimated $368 million total spent fuel management costs, the operational costs total approximately $225 million.
The remaining $143 million is associated with transfer of spent fuel to dry storage (e.g.,
procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad). To fund the "transfer to dry storage" portion of spent fuel management costs, ENVY intends to establish two separate revolving credit facilities from third party banks totaling $145 million. The first facility is planned be a committed credit facility with

BVY 14-085 / Attachment 1 / Page 8 of 17 an expected duration of three years and a capacity of $60 million. This facility would be guaranteed by Entergy Corporation, parent company of ENVY and ENO. The committed facility is intended to provide working capital for ENVY from the time it pays an expenditure to the time it receives reimbursement from the trust fund, as well as dry storage costs that are not reimbursable from the trust fund. The second credit facility is planned to be an uncommitted facility with a capacity of $85 million. 8 This facility would also be guaranteed by Entergy Corporation. This facility is intended to cover the balance of costs related to transferring fuel from the spent fuel pool to the ISFSI.
Thus, considering the current fund balance of $655 million (as of October 31, 2014), projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), and $145 million from the two planned external credit facilities to fund the transfer to dry fuel storage costs, the trust fund is expected to have an excess of $175.9 million over the estimated license termination and spent fuel management costs. As noted above, in Reference 5, ENVY committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities.
As shown in the updated funding strategy for license termination and spent fuel management activities, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment.
A committed credit facility is a legal agreement between the lender and the borrower outlining the conditions of the credit facility. Once signed, the agreement requires the lender to lend money to the borrower, provided that the borrower satisfies the agreement's conditions (e.g., paying fees).
Committed credit lines differ from uncommitted credit lines in that they legally bind the lender to provide the funds, rather than giving the lender the option of suspending or canceling the credit line based on market conditions.

BVY 14-085 / Attachment 1 / Page 9 of 17 Table 4 - License Termination Expenditures (thousands, 2014 dollars)
Equip. &                       Waste Year      Labor         Materials         Energy      Disposal     Other     Total 2014               0                0              0             0    15,165    15,165 2015         39,626               533          3,912            38   37,089     81,198 2016         15,512               442          1,004            22    19,145    36,126 2017          2,015               395            184            14     8,216    10,823 2018           1,898              395            184            14     7,057     9,548 2019           1,858              395            184            14     5,722     8,173 2020          5,716             1,234          1,288         1,200     8,326    17,763 2021           1,969              284            187             7     2,794     5,241 2022           1,969              284            187             7     2,744     5,191 2023           1,969              284            187             7     2,744     5,191 2024           1,974              285            187             7     1,196     3,650 2025           1,969              284            187             7     1,144     3,591 2026           1,969              284            187             7     1,286     3,733 2027           1,969              284            187             7     1,336     3,783 2028           1,974              285            187             7     1,288     3,742 2029           1,969              284            187             7     1,286     3,733 2030           1,969              284            187             7     1,336     3,783 2031           1,969              284            187             7     1,286     3,733 2032           1,974              285            187             7     1,288     3,742 2033           1,969              284            187             7     1,336     3,783 2034           1,969              284            187             7     1,286     3,733 2035           1,969              284            187             7     1,286     3,733 2036           1,974              285            187             7     1,338     3,792 2037          1,969               284            187             7     1,286     3,733 2038           1,969              284            187             7     1,286     3,733 2039          1,969               284            187             7     1,336     3,783 2040          1,974               285            187             7     1,288     3,742 2041          1,969               284            187             7     1,286     3,733 2042          1,969               284            187             7     1,336     3,783 2043          1,969               284            187             7     1,286     3,733 2044          1,974               285            187             7     1,288     3,742 2045          1,969               284            187             7     1,336     3,783 2046          1,969               284            187             7     1,286     3,733 2047           1,969               284            187             7     1,286     3,733 2048          1,974               285            187             7     1,338     3,792 2049           1,969              284            187             7     1,286     3,733 2050           1,969              284            187             7     1,286     3,733 2051           1,969              284            187             7     1,336     3,783 2052          1,974               285            187             7     1,288     3,742

BVY 14-085 / Attachment 1 / Page 10 of 17 Table 4 - License Termination Expenditures (cont'd)
(thousands, 2014 dollars)
Equip. &                       Waste Year      Labor         Materials         Energy      Disposal      Other     Total 2053           1,969              278            187              6     1,142     3,583 2054           1,969              278            187              6     1,192     3,633 2055           1,969              278            187              6     1,142     3,583 2056           1,974              279            187              6     1,144     3,591 2057           1,969              278            187              6     1,192     3,633 2058           1,969              278            187              6     1,142     3,583 2059           1,969              278            187              6     1,142     3,583 2060           1,974              279            187              6     1,194     3,641 2061           1,969              278            187              6     1,142     3,583 2062           1,969              278            187              6     1,142     3,583 2063           1,969              278            187              6     1,192     3,633 2064           1,974              279            187              6     1,144     3,591 2065           1,969              278            187              6     1,142     3,583 2066           1,969              278            187              6     1,192     3,633 2067           1,969              278            187              6     1,142     3,583 2068         35,936            1,912           1,873             32     3,524    43,277 2069         53,909           14,320           1,821        12,174      9,806    92,030 2070         53,452           15,787           1,689        18,228     15,362   104,519 2071         46,489            8,170           1,401        10,716     17,749    84,524 2072         46,616            8,192           1,405        10,745     17,995    84,953 2073         38,409            3,090             599         2,488      5,554    50,139 2074             151                0              0              0       360       512 2075           71.35                0              0              0       224       295 Total       434,259           68,148          24,326        56,003   234,483    817,219

BVY 14-085 / Attachment 1 / Page 11 of 17 Table 5 - Spent Fuel Management Expenditures (thousands, 2014 dollars)
Equip. &
Year       Labor          Materials          Energy     Waste Disposal   Other     Total 2014                 0                0               0               0      4,753      4,753 2015                 0                0               0               0     14,319    14,319 2016             9,093                0           1,622               0     18,790    29,506 2017           13,547                 0           2,195               0     33,307    49,049 2018           13,547                 0           2,195               0     46,588    62,330 2019            13,547                0           2,195               0     43,942    59,684 2020             6,755                0           1,092               0     12,898    20,745 2021             3,238              338              79               0        341      3,996 2022             3,238              338              79                0       341      3,996 2023             3,238              338              79               0        341      3,996 2024             3,246              339              80               0        342      4,007 2025             3,238              338              79                0       341      3,996 2026             3,238              338              79                0       341      3,996 2027             3,238              338              79                0       341      3,996 2028             3,246              339              80                0       342      4,007 2029             3,238              338              79                0       341      3,996 2030 3,238              338              79                0       341      3,996 2031             3,238              338              79                0       341      3,996 2032             3,246              339              80                0       342      4,007 2033             3,238              338              79               0        341      3,996 2034             3,238              338              79               0        341      3,996 2035             3,238              338              79               0        341      3,996 2036             3,246              339              80               0        342      4,007 2037             3,238              338              79               0        341      3,996 2038             3,238              338              79                0       341      3,996 2039             3,238              338              79                0       341      3,996 2040             3,246              339              80               0        342      4,007 2041             3,238              338              79               0        341      3,996 2042             3,238              338              79                0       341      3,996 2043             3,238              338              79               0        341      3,996 2044             3,246              339              80               0        342      4,007 2045             3,238              338              79                0       341      3,996 2046             3,238              338              79                0       341      3,996 2047             3,238              338              79                0       341      3,996 2048             3,246              339              80                0       342      4,007 2049             3,238              338              79                0       341      3,996 2050             3,238              338              79                0       341      3,996 2051             3,238              338              79                0       341      3,996

BVY 14-085 / Attachment 1 / Page 12 of 17 Table 5 - Spent Fuel Management Expenditures (cont'd)
(thousands, 2014 dollars)
Equip. &
Year     Labor       Materials        Energy    Waste Disposal  Other   Total 2052     3,246          339             80            0          342    4,007 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        0             0              0            0           0       0 2068        0             0              0            0           0       0 2069        0             0              0            0           0       0 2070        0             0              0            0           0       0 2071        0             0              0            0           0       0 2072        0             0              0            0           0       0 2073        0             0              0            0           0       0 2074        0             0              0            0           0       0 2075        0             0               0           0           0       0 Total   160,164        10,816          11,843         0        185,524 368,347

BVY 14-085 / Attachment 1 / Page 13 of 17 Table 6 - Annual Cash Flow Analysis Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands, 2014 Dollars)
Date               Amount Current Value of Qualified Trust Fund                                  10/31/2014        $         654,925 Current Value of Non-Qualified Trust Fund                              10/31/2014        $              38 Total Trust Fund Balance as of                                         10/31/2014        $         654,963 Start of Decommissioning                                               12/29/2014 Decommissioning Funds value at Calculation Date                        10/31/2014        $         654,963 Total Estimated Costs at Calculation Date                              10/31/2014        $      1,042,748 Start of Decom to end of Decom - Assumes 0.0% Decom cost escalation Cost Escalation Rate rate Start of Decom to end of Decom - Assumes 2.0%
Fund Earnings Rate Earnings Rate Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)
Column 4 License Column 1       Column 2         Column 3          Termination Cost plus     Bogumng Clm                                     Column 8  Column 9
____            ____                 ot ls        8 Begin  ning of   Colum           ou    7    Trs    YerEdn 50.75        50.54 (bb)       Exclude            Spent Fuel       Year                mn 6     C            Trust  Year Ending Year        License       Spent Fuel      Transfer to        Management          Fund         Withdraw      Contribute   Fund    Trust Fund Termination    Management        Dry Fuel             Cost less       Balance                                Earnings   Balance Cost           Cost        Storage Cost         Transfer to Dry Fuel Storage Cost 2014         15,165         4,753            4,753               15,165         654,963        15,165            0       2,183    641,981 2015        81,198          14,319          10,001              85,515          641,981        85,515            0      11,984    568,450 2016        36,126          29,506           7,613              58,018          568,450        58,018            0      10,789    521,221 2017         10,823        49,049           28,873              31,000          521,221        31,000            0      10,114    500,335 2018         9,548          62,330          41,644              30,235          500,335        30,235            0      9,704     479,805 2019         8,173          59,684          39,516              28,342          479,805        28,342            0       9,313    460,776 2020         17,763         20,745          10,420              28,088          460,776        28,088            0       8,935    441,622 2021         5,241           3,996                               9,237          441,622         9,237            0       8,740    441,125 2022         5,191           3,996                               9,187          441,125         9,187            0       8,731    440,669 2023         5,191           3,996                               9,187          440,669         9,187            0       8,722    440,204 2024         3,650          4,007                                7,657          440,204         7,657            0       8,728    441,274 2025         3,591           3,996                                7,587         441,274         7,587            0       8,750    442,437 2026         3,733           3,996                                7,729         442,437         7,729            0       8,771    443,480 2027         3,783           3,996                               7,779          443,480         7,779            0       8,792    444,493 2028         3,742          4,007                                 7,749         444,493         7,749            0       8,812    445,557 2029         3,733           3,996                                7,729         445,557         7,729            0       8,834    446,662 2030         3,783           3,996                                7,779         446,662         7,779            0       8,855    447,738

BVY 14-085 / Attachment 1 / Page 14 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands in 2014 Dollars)
Column 4 License Termination   Clm Column 1     Column 2        Column 3           Cost plus  Beinn fColumn                                8  Column 9 50.75      50.54 (bb)       Exclude          Spent Fuel  Bearn~n ofus Coum       Column 7       Trust   Year Ending Year       License     Spent Fuel     Transfer to      Management       Fund      Withdraw   Contribute     Fund    Trust Fund Termination  Management       Dry Fuel           Cost less    Balance                            Earnings    Balance Cost         Cost       Storage Cost        Transfer to Dry Fuel Storage Cost 2031  1     3,733        3,996                              7,729      447,738     7,729         0         8,877      448,887 2032        3,742        4,007                              7,749      448,887     7,749         0         8,900      450,039 2033        3,783        3,996                              7,779      450,039     7,779         0         8,923      451,183 2034        3,733        3,996                              7,729      451,183     7,729         0         8,946      452,400 2035        3,733        3,996                              7,729      452,400     7,729         0         8,971      453,642 2036        3,792        4,007                              7,799      453,642     7,799         0          8,995     454,839 2037        3,733        3,996                              7,729      454,839     7,729         0          9,019     456,129 2038        3,733        3,996                              7,729      456,129     7,729         0          9,045     457,446 2039        3,783        3,996                              7,779      457,446     7,779         0          9,071     458,738 2040        3,742        4,007                              7,749      458,738     7,749         0          9,097     460,087 2041        3,733        3,996                              7,729      460,087     7,729         0          9,124     461,482 2042        3,783        3,996                              7,779      461,482     7,779         0          9,152     462,855 2043        3,733        3,996                              7,729      462,855     7,729         0          9,180     464,306 2044        3,742        4,007                              7,749      464,306     7,749         0          9,209     465,767 2045        3,783        3,996                              7,779      465,767     7,779         0          9,238     467,225 2046        3,733        3,996                              7,729      467,225     7,729         0          9,267     468,764 2047        3,733        3,996                              7,729      468,764     7,729         0          9,298     470,333 2048        3,792        4,007                              7,799      470,333     7,799         0          9,329     471,863 2049        3,733        3,996                              7,729      471,863     7,729         0          9,360     473,494 2050        3,733        3,996                              7,729      473,494     7,729         0          9,393     475,158 2051        3,783        3,996                              7,779      475,158     7,779         0          9,425     476,804 2052        3,742        4,007                              7,749      476,804     7,749         0          9,459     478,514 2053        3,583          0                                3,583      478,514     3,583         0          9,534     484,4866 2054        3,633          0                                3,633      484,466     3,633         0          9,653     490,487 2055        3,583          0                                3,583      490,487     3,583         0          9,774     496,678 2056        3,591          0                                3,591      496,678     3,591         0          9,898     502,984 2057        3,633          0                                3,633      502,984     3,633         0         10,023     509,375 2058  1     3,583          0                                3,583      509,375     3,583         0         10,152     515,944 2059        3,583          0                                3,583      515,944     3,583         0         10,283     522,644 2060        3,641          0                                3,641      522,644     3,641         0         10,416     529,419 2061        3,583          0                                3,583      529,419     3,583         0         10,553     536,389 2062        3,583          0                         1      3,583      536,389     3,583         0         10,692     543,499 2063        3,633          0                                3,633      543,499     3,633   1     0       110,834      550,700 2064        3,591          0                                3,591      550,700     3,591   1     0      110,978       558,086

BVY 14-085 / Attachment 1 / Page 15 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)
Column 4 License Termination Column 1       Column 2     Column 3            Cost plus  Bogumng                           Column 8  Column 9 50.75       50.54 (bb)    Exclude           Spent Fuel  Year Trustof Beginning    Coun6 C          olm7 7 Column       Trs Trust  YerEdg Year Ending Year        License      Spent Fuel   Transfer to      Management       Fund      Withdraw  Contribute   Fund   Trust Fund Termination    Management     Dry Fuel           Cost less    Balance                         Earnings   Balance Cost           Cost     Storage Cost        Transfer to Dry Fuel Storage Cost 2065         3,583           0                              3,583      558,086       3,583      0       11,126    565,630 2066         3,633           0                              3,633      565,630       3,633      0       11,276    573,273 2067         3,583           0                              3,583      573,273       3,583      0       11,430    581,120 2068        43,277           0                             43,277      581,120      43,277      0       11,190    549,033 2069        92,030           0                             92,030      549,033      92,030      0       10,060    467,064 2070       104,519           0                            104,519      467,064     104,519      0       8,296     370,841 2071        84,524           0                             84,524      370,841      84,524      0       6,572     292,889 2072        84,953           0                             84,953      292,889      84,953      0        5,008    212,944 2073        50,139           0                             50,139      212,944      50,139      0        3,757    166,563 2074          512            0                               512       166,563        512       0        3,326    169,377 2075          295            0                               295       169,377        295       0       3,385     172,466 2076           0             0                                0        172,466         0        0       3,449     175,915 817,219        368,347      142,819           1,042,748                1,042,748     0      563,701 Table 6 Definitions:
Column 1:            50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2014 dollars at a 0.0%
escalation rate Column 2:            50.54 (bb) Spent Fuel Management Cost Reflects the Total Annual Irradiated Fuel Management Plan cost in 2014 dollars at a 0.0% escalation rate Column 3:            Exclude Transfer to Dry Fuel Storage Cost Reflects the Transfer to Dry Fuel Storage Cost included in Column 2 that is planned to be funded by external credit facilities, in 2014 dollars at a 0.0% escalation rate Column 4:            License Termination Cost plus Spent Fuel Management Cost less Transfer to Dry Fuel Storage Cost Reflects the Total Annual License Termination Plan cost plus Total Spent Fuel Management Plan cost less Transfer to Dry Fuel Storage cost all in 2014 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

BVY 14-085 / Attachment 1 / Page 16 of 17 Column 5:        Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2014 dollars at a 0.0% escalation rate and 2.0% Fund Earnings Column 6:        Withdraw Reflects the annual expenditures from the Trust Fund in 2014 dollars at a 0.0%
escalation rate (equals Column 4)
Column 7:        Contribute Reflects the annual contributions to the Trust Fund in 2014 dollars at a 0.0% escalation rate Column 8:        Trust Fund Earnings Reflects earnings on funds remaining in the trust. A 2.0% earnings rate is used over a 0.0% cost escalation rate. The annual 2.0% earnings are calculated on the beginning balance less 50% of the projected annual expenditure for each year. (Column 5 - 50% of Column 6
* 2.0%)
Column 9:        Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted for year end specified at a 0.0% escalation rate and 2.0% Fund Earnings in 2014 dollars. (Column 5 - Column 6 + Column 7 + Column 8)
V.      Reaulatory Activities The Program assumes withdrawals from the VYNPS decommissioning trust fund for operational spent fuel management costs. ENO will make appropriate submittals to request an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A), which would permit the use of decommissioning trust funds for spent fuel management expenses. The availability of decommissioning funding sources will be periodically revisited to ensure that withdrawals from the fund do not inhibit the ability to complete license termination and spent fuel management activities.
In addition, in accordance with 10 CFR 50.82(a)(8)(vii), ENO will submit a report on the status of spent fuel management funding by March 31 of each year. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing spent fuel, the projected cost of managing spent fuel until it is transferred to DOE, and if the funds accumulated do not cover the projected cost, a plan to provide additional funding assurance using one of the methods allowed by NRC regulations.

BVY 14-085 / Attachment 1 / Page 17 of 17 VI. Summary The spent fuel management activities described in this updated Program must be performed in conjunction with license termination activities. The annual cash flow analysis demonstrates that the VYNPS decommissioning trust fund with projected earnings, together with an additional
$145 million in credit available for transfer to dry fuel storage activities, will be sufficient to cover the estimated license termination and spent fuel management costs.
VII. References
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)," BVY 08-077, dated October 14, 2008 (ML082910294)
: 3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC NOs.
MD8035 and MD8051)," dated February 3, 2009 (ML083390193)
: 4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)
: 5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan -
RAI Response)," BVY 09-048, dated August 18, 2009 (ML092370298)
: 6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC NO. ME1 152)," dated October 8, 2009 (ML092740238)
: 7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)
: 8. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report," BVY 14-078, dated December 19, 2014
: 9. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Decommissioning Funding Status Report," BVY 14-082, dated December 19, 2014

BVY 14-085 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station List of Cancelled Regulatory Commitments

BVY 14-085 / Attachment 2 / Page 1 of 1 List of Cancelled Regulatory Commitments This table identifies actions discussed in this letter for which ENVY no longer commits to perform.
DATE OF ORIGINAL COMMITMENT                          COMMITMENT          CHANGED DATE Provide additional funding of $127.017 million dollars to trust fund for Spent Fuel Management.                                       December 31, 2026     This commitment is cancelled.
Source: Letter BVY 09-048, dated August 18, 2009 (ML092370298)

Entergy Nuclear Operations, Inc.
Vermont Yankee 320 Governor Hunt Rd.
---Entergy                                                              Vernon, VT 802-257-7711 Christopher J. Wamser Site Vice President BVY 14-085                                                            10 CFR 50.54(bb)
December 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54(bb)
Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

==REFERENCES:==
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb),"
BVY 08-077, dated October 14, 2008 (ML082910294)
: 3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC Nos. MD8035 and MD8051)," NVY 09-009, dated February 3, 2009 (ML083390193)
: 4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)
: 5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan - RAI Response," BVY 09-048, dated August 18, 2009 (ML092370298)
: 6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC No. ME1152)," NVY 09-100, dated October 8, 2009 (ML092740238)
: 7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)
                                                                                               /4c0J hW&C(&#xfd;4

BVY 14-085 / Page 2 of 3

==Dear Sir or Madam:==

In accordance with 10 CFR 50.54(bb), Entergy Nuclear Operations, Inc. (ENO) is hereby notifying the NRC of significant changes to the Vermont Yankee Nuclear Power Station (VYNPS) Program for Management of Irradiated Fuel.
Pursuant to 10 CFR 50.54(bb), ENO initially submitted a Program for Maintenance of Irradiated Fuel on March 21, 2007 (Reference 1) and a Revised Program for Maintenance of Irradiated Fuel on October 14, 2008 (Reference 2). On February 3, 2009, the NRC staff approved the VYNPS irradiated fuel management program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).
On April 1, 2009, ENO submitted an update to its irradiated fuel management program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). The NRC staff approved the revised irradiated fuel management program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).
By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur in the fourth quarter of 2014 (Reference 7). As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program for Management of Irradiated Fuel. This submittal provides the required Section 50.54(bb) notification. Attachment 1 provides the Updated Program for Management of Irradiated Fuel (Program), which supersedes all prior versions of the Program.
In Reference 5, Entergy Nuclear Vermont Yankee, LLC committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. Based on the funding strategy described in the updated Program, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment. There are no new regulatory commitments made by this letter. of this letter contains one cancelled regulatory commitment.
Should you have any questions concerning this letter or require additional information, please contact Mr. Philip Couture at 802-451-3193.
Sincerely, CJW/plc/shr

BVY 14-085 / Page 3 of 3 Attachments:       1. Updated Program for Management of Irradiated Fuel
: 2. List of Cancelled Regulatory Commitments cc:     Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 14-085 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel

BVY 14-085 1 Attachment 1 / Page 1 of 17 Vermont Yankee Nuclear Power Station Updated Program for Management of Irradiated Fuel I.       Background and Introduction Entergy Nuclear Operations, Inc. (ENO) submitted a Program for Maintenance of Irradiated Fuel (Program) on March 21, 2007 (Reference 1) and a revised Program on October 14, 2008 (Reference 2) for Vermont Yankee Nuclear Power Station (VYNPS). ENO submitted these programs pursuant to 10 CFR 50.54(bb), which requires power reactor licensees to submit a spent fuel management and funding program for NRC review five years prior to the expiration of a reactor operating license. At the time, the VYNPS operating license was set to expire on March 21, 2012. On February 3, 2009, the NRC staff approved the VYNPS Program on a preliminary basis and determined that the preliminary decommissioning cost estimate was reasonable (Reference 3).
On April 1, 2009, ENO submitted an update to the VYNPS Program to reflect changes in its decommissioning cost estimate, based on updated information from the Department of Energy (DOE) on when the government would begin accepting spent fuel from the industry (Reference 4), which it supplemented on August 18, 2009 (Reference 5). In Reference 5, VYNPS owner Entergy Nuclear Vermont Yankee, LLC (ENVY) committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities. The NRC staff approved the revised VYNPS Program, as supplemented, on a preliminary basis on October 8, 2009 (Reference 6).
By letter dated September 23, 2013, ENO notified the NRC of its intent to permanently cease power operations at VYNPS at the end of the current operating cycle, which is expected to occur later this month (Reference 7).
Pursuant to 10 CFR 50.54(bb), licensees are required to notify the NRC of any significant changes to their proposed spent fuel management plans. As a result of its decision to permanently cease operations at VYNPS, and related changes to the anticipated schedule of decommissioning activities, irradiated fuel management activities, and decommissioning funding assumptions, ENO is modifying the VYNPS Program. This submittal provides the required Section 50.54(bb) notification. This updated Program supersedes all prior versions of the Program.
Pursuant to 10 CFR 50.82(a)(4)(i), on December 19, 2014, ENO submitted a Post Shutdown Decommissioning Activities Report (PSDAR) for VYNPS that included a site-specific decommissioning cost estimate (DCE) as an attachment (Reference 8). The DCE describes the bases for the assumptions regarding the DOE's acceptance of spent fuel from the industry and from VYNPS. As discussed in the DCE (and subject to the assumptions, qualifications, and reservations stated therein), the Program is based on the assumption that DOE will commence acceptance of VYNPS's spent fuel in 2026 and complete removal of all spent fuel from the site in 2052, consistent with the current DOE spent fuel management and acceptance strategy.'
As noted in the DCE, DOE's repository program assumes that spent fuel is accepted for disposal from the nation's commercial nuclear plants in the order ("queue") in which it was removed from service ("oldest fuel first"). The contracts that U.S. generators have with the DOE provide mechanisms for altering the oldest fuel first allocation scheme, including emergency deliveries, exchanges of allocations amongst generators, and the option of providing priority acceptance from permanently shutdown nuclear reactors. VYNPS will seek the most expeditious means of removing fuel from the site when DOE commences performance. Given DOE's failure to accept fuel under its contracts, however, it is unclear how these mechanisms will operate once DOE begins accepting

BVY 14-085 / Attachment 1 / Page 2 of 17 The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the Program, along with license termination and site restoration activities and costs.
II.      Irradiated Fuel Management Strategy At the time of shutdown, there will be 368 fuel assemblies residing in the reactor as part of the current operating cycle, 2,628 spent fuel assemblies 2 stored in the spent fuel pool, and 884 assemblies stored in 13 dry storage casks on an independent spent fuel storage installation (ISFSI) pad. In 2008, construction of the first ISFSI pad was completed, which VYNPS operates under a 10 CFR Part 50 General License (in accordance with 10 CFR Part 72, Subpart K).
VYNPS selected the Holtec HI-STORM 1OOS dry cask storage system for the spent fuel that is currently stored on the ISFSI. The system consists of a multipurpose canister (MPC) with a nominal capacity of 68 fuel assemblies and a concrete storage overpack. The current ISFSI pad was constructed to support 36 dry storage casks (the pad has four additional unused storage locations to allow VYNPS to move the casks if needed). VYNPS completed fuel loading campaigns to the ISFSI in 2008, 2011, and 2012.
As indicated in the VYNPS PSDAR (Reference 8), ENVY has selected the SAFSTOR decommissioning option. The Program assumes that decommissioning is completed within 60 years of permanent plant shutdown (i.e., by the end of 2074). Following shutdown, the reactor building will be operated as an interim wet fuel storage facility for approximately five and one-half years after operations cease. During this time period, the spent fuel residing in the storage pool will be transferred to the ISFSI. The ISFSI will remain operational until DOE is able to accept title to the fuel and complete the transfer of the fuel off site.
The PSDAR and DCE describe three major phases related to spent fuel management at VYNPS, which are summarized below. 3 Spent fuel management activities are further broken out into two categories - "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, and "transfer to dry storage" activities, such as procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad.
spent fuel from commercial reactors. Accordingly, for planning purposes only, this Program assumes that DOE will accept spent fuel in an oldest fuel first order.
2   This figure includes one fuel debris canister.
3   Appendix C to the DCE (Reference 8, Attachment 1) includes a detailed cost analysis of all decommissioning activities, including spent fuel management activities, by period.

BVY 14-085 / Attachment 1 / Page 3 of 17 TABLE I - Irradiated Fuel Management Program: Summary Schedule and Costs Decommissioning Period                     Start  End Duration     Cost (thousands (Years)     of 2014 dollars)
Periods 0 and 1: Planning and Preparations for        2013   2016 2.6                      23,068 Dormancy Spent Fuel Management Operations                             6,055 Transfer to Dry Storage                          17,013 Period 2a: Dormancy with Wet Fuel Storage             2016   2020 4.2                    217,318 Spent Fuel Management Operations                             91,696 Transfer to Dry Storage                          125,548 Period 2b: Dormancy with Dry Fuel Storage             2020   2052 32.5                   127,961 Spent Fuel Management Operations                             127,961 TOTAL                                                             39.3                   368,347
: 1. Pre-Shutdown Planning and Preparations for SAFSTOR Dormancy Pre-shutdown planning activities include designing an expanded ISFSI facility to include a second storage pad, which is expected to be located in close proximity to the existing pad. The second pad is being designed for storage of 25 casks, and combined with the existing pad, will allow for dry storage of all spent fuel assemblies generated during the plant operations.
The initial decommissioning activities to be performed after plant shutdown will focus primarily on preparing the plant for a period of safe-storage (also referred to as dormancy) and constructing a second ISFSI pad. During this phase, VYNPS plans to complete the design of the new ISFSI pad and initiate site work. VYNPS also plans to commence security modifications supporting future ISFSI and dormancy operations during this time period.
The estimated spent fuel management costs associated with ISFSI design and construction, site security modifications, and other expenses during this initial phase, such as emergency planning and preparations for dormancy, total approximately $23.1 million.
: 2. Dormancy with Wet Fuel Storage During this phase, spent fuel will remain in the spent fuel pool until it meets the criteria for transfer to dry storage. VYNPS expects to complete expansion of the ISFSI in 2017, assuming the timely receipt of the required state regulatory approvals. The estimated costs associated with expanding the ISFSI, including construction of the second pad and related security modifications, total approximately $32.7 million. Table 2 below provides additional detail on certain estimated dry storage-specific expenditures.
VYNPS expects to begin transferring the remaining spent fuel from the spent fuel pool to the ISFSI in 2019 and to complete the transfer of all fuel to the ISFSI by mid-2020. In total, 3,879 spent fuel assemblies and one fuel debris canister will be stored in 58 dry cask systems on the two ISFSI pads. Costs associated with purchasing 45 additional dry cask systems, loading fuel, and transferring fuel from the spent fuel pool to the ISFSI are included in this phase. After the fuel transfer is completed, the pool will be drained and supporting systems will be de-energized for the remainder of the dormancy period.
The total estimated spent fuel -management costs associated with this phase is approximately
$217.3 million.

BVY 14-085 / Attachment 1 / Page 4 of 17
: 3. Dormancy with Dry Fuel Storaae During this phase, the spent fuel will remain stored on the ISFSI until DOE accepts the fuel and removes it from the site. As discussed above and in the DCE (Reference 8, Attachment 1), for planning purposes, the current Program assumes that DOE will begin removing fuel from VYNPS in 2026 and will complete the removal of all spent fuel from the site in 2052, according to the schedule set forth in Table 3 below.
During this phase, programs and procedures required to support safe operation of the ISFSI will be maintained in accordance with applicable requirements. Equipment maintenance, monitoring, and inspection will be performed as necessary. VYNPS will also maintain a 24-hour security force, whose primary responsibility will be to safeguard the spent fuel for as long as it remains on site. A security barrier, sensors, alarms, and other surveillance equipment will be maintained as required to provide security for the spent fuel. The estimated average annual cost to operate the ISFSI during this phase is approximately $4 million.
Late in the dormancy period, additional activities will include transferring the spent fuel from the ISFSI to the DOE. The estimated cost for the eventual transfer of the MPCs to a DOE-provided transport vehicle for off-site disposal is approximately 4
                                                                $10 million, excluding a $4.4 million allowance for a spent fuel transfer facility.
The total estimated spent fuel management cost associated with this phase is approximately
$127.96 million.
As noted in the DCE (Reference 8, Attachment 1), DOE has breached its obligations to remove fuel from reactor sites on the contracted schedule, and has also failed to provide plant owners with information about how it will ultimately perform and fulfill its obligation. DOE officials have stated that DOE does not have an obligation to accept already-canistered fuel without an amendment to the Standard Contract, but DOE has not explained what costs any such amendment would involve.
Consequently, the plant owner has no information or expectations on how DOE will remove fuel from the site in the future. In the absence of information about how DOE will specifically deal with already-canistered fuel, and for purposes of the DCE only, the DCE assumes that there will be no additional costs associated with DOE's acceptance of such fuel. If this assumption is incorrect, it is assumed that DOE will have liability for costs incurred to transfer the fuel to DOE-supplied containers, and to dispose of existing containers.

BVY 14-085 / Attachment 1 / Page 5 of 17 Table 2 - Estimated Expenditures for ISFSI Construction, Spent Fuel Packagina and Canister Transfer (thousands, 2014 dollars?
Spent Fuel        MPC and New ISFSI         Related          Storage       ISFSI       Fuel     ISFSI to Pad           Security         Overpack     Loading     Transfer     DOE Year     Construction   Modifications         Costs     Campaigns    Facility   Transfer     Total 2014            4,753                  0             0             0          0         0      4,753 2015            7,529              2,215             0             0          0         0      9,744 2016            7,613                  0             0             0          0         0      7,613 2017            3,545                  0        25,907             0          0         0     29,452 2018                0              1,400        37,940         1,375          0         0     40,715 2019                0              4,250        13,623       21,780           0         0     39,653 2020                0              1,400         1,311         7,920          0         0     10,631 2021                0                  0             0             0          0         0           0 2022                0                  0             0             0          0         0           0 2023                0                  0             0             0          0         0           0 2024                0                  0             0             0          0         0           0 2025                0                  0             0             0     4,416          0      4,416 2026                0                  0             0             0          0       863        863 2027                0                  0             0             0          0         0           0 2028                0                  0             0             0          0       518        518 2029                0                  0             0             0          0       690        690 2030                0                  0             0             0          0       518        518 2031                0                  0             0             0          0       518        518 2032                0                  0             0             0          0       345        345 2033                0                  0             0             0          0       345        345 2034                0                  0             0             0          0       345        345 2035                0                  0             0             0          0       345        345 2036                0                  0             0             0          0       345        345 2037                0                  0             0             0          0       345        345 2038                0                  0             0             0          0       345        345 2039                0                  0             0             0          0       345        345 2040                0                  0             0             0          0         0           0 2041                0                  0             0             0          0       173        173 2042                0                  0             0             0          0       173        173 2043                0                  0             0             0          0       518        518 2044                0                  0             0             0          0       345        345 2045                0                  0             0             0          0       345        345 2046                0                  0             0             0          0       345        345 2047                0                  0             0             0          0       345        345 2048                0                  0             0             0          0       345        345 2049                0                  0             0             0          0       345        345 2050                0                  0             0             0          0       345        345 2051                0                  0             0             0          0         0           0 2052                0                  0             0             0          0       863        863 Total          23,440              9,265        78,782       31,075      4,416     10,005    156,983 5
The costs identified in the first four columns (New ISFSI Pad Construction, Spent Fuel Related Security Modifications, MPC and Storage Overpack Costs, and ISFSI Loading Campaigns) are considered "transfer to dry storage" costs.

BVY 14-085 / Attachment 1/ Page 6 of 17 TABLE 3 - Spent Fuel Management Schedule (Fuel Assembly Totals by Location)
Pool         ISFSl            DOE Year Inventory       Inventory      Acceptance6 2014         2,996          884 2015         2,996          884 2016         21996          884 2017         2,996          884 2018         2,996          884 2019           820        3,060 2020              0      3,8807 2021                      3,880 2022                      3,880 2023                      3,880 2024                      3,880 2025                      3,880 2026                      3,502                 378 2027                      3,502                     -
2028                      3,284                 218 2029                      3,010                 274 2030                      2,784                 226 2031                      2,558                 226 2032                      2,422                 136 2033                      2,286                 136 2034                      2,157                 129 2035                      2,029                 128 2036                      1,901                 128 2037                      1,781                 120 2038                      1,661                 120 2039                      1,549                 112 2040                      1,549   _
2041                      1,464                  85 2042                      1,405                  59 2043                      1,209                 196 This schedule is provided for illustrative purposes only and assumes that DOE begins accepting VYNPS fuel in 2026. It is expected that VYNPS will seek to accelerate acceptance based on shutdown reactor priority, exchanges of acceptance allocations, and other Standard Contract provisions.
Includes one fuel debris canister, which, for purposes of this analysis and for convenience, is assumed to be picked up in the final year of DOE acceptance (2052).

BVY 14-085 / Attachment 1 / Page 7 of 17 TABLE 3 - Spent Fuel Management Schedule (cont'd)
(Fuel Assembly Totals by Location)
Pool     ISFSI           DOE, Year Inventory    Inventory     Acceptance 2044                   1,073               136 2045                     949               124 2046                     821               128 2047                     701               120 2048                     585               116 2049                     469               116 2050                     349               120 2051                     349 2052                                       349 Total                                    3,880 Ill. ISFSI Decommissioning The ISFSI pads and facilities will be decommissioned at the time of plant decommissioning or after DOE has removed all spent fuel from the site. The bases and assumptions used to formulate the cost estimate are discussed in the DCE (Reference 8, Attachment 1). As detailed in Appendix D to the DOE, the estimated cost to decommission the ISFSI is approximately $5.1 million.
IV.      Funding Demonstration for License Termination and Spent Fuel Management Operations Costs As shown in the DCE (Reference 8, Attachment 1), the projected total cost to decommission VYNPS, after an extended period of safe storage, is estimated at $1.24 billion (in 2014 dollars).
This amount includes estimated costs associated with license termination ($817.22 million),
interim spent fuel storage ($368.35 million), and site restoration ($57.15 million) activities.
In Reference 9, ENO submitted an updated Decommissioning Funding Status report.
Reference 9 reported the VYNPS decommissioning trust fund balance to be approximately $655 million as of October 31, 2014. Tables 3.4 and 3.5 of the DCE (Reference 8, Attachment 1) set forth the estimated annual expenditures for license termination and spent fuel management, respectively. For convenience, those tables are reproduced below as Tables 4 and 5. This annual expenditure information is used in the cash flow analysis in Table 6 below. The cash flow analysis demonstrates that the VYNPS trust fund is sufficiently funded for all license termination activities and certain spent fuel management activities. ENVY plans to fund "operational" spent fuel management activities, such as operating and maintaining the ISFSI and the spent fuel pool, from the trust fund. Of the estimated $368 million total spent fuel management costs, the operational costs total approximately $225 million.
The remaining $143 million is associated with transfer of spent fuel to dry storage (e.g.,
procurement of dry storage systems, transfer of fuel from the spent fuel pool to the ISFSI, and construction of the second ISFSI pad). To fund the "transfer to dry storage" portion of spent fuel management costs, ENVY intends to establish two separate revolving credit facilities from third party banks totaling $145 million. The first facility is planned be a committed credit facility with

BVY 14-085 / Attachment 1 / Page 8 of 17 an expected duration of three years and a capacity of $60 million. This facility would be guaranteed by Entergy Corporation, parent company of ENVY and ENO. The committed facility is intended to provide working capital for ENVY from the time it pays an expenditure to the time it receives reimbursement from the trust fund, as well as dry storage costs that are not reimbursable from the trust fund. The second credit facility is planned to be an uncommitted facility with a capacity of $85 million. 8 This facility would also be guaranteed by Entergy Corporation. This facility is intended to cover the balance of costs related to transferring fuel from the spent fuel pool to the ISFSI.
Thus, considering the current fund balance of $655 million (as of October 31, 2014), projected fund earnings during the SAFSTOR period (assuming an annual 2% growth rate), and $145 million from the two planned external credit facilities to fund the transfer to dry fuel storage costs, the trust fund is expected to have an excess of $175.9 million over the estimated license termination and spent fuel management costs. As noted above, in Reference 5, ENVY committed to make a $127.017 million contribution to the VYNPS decommissioning trust fund in 2026 to ensure adequate funding for license termination and spent fuel management activities.
As shown in the updated funding strategy for license termination and spent fuel management activities, this planned contribution is no longer necessary. As a result, ENO is hereby providing written notification on behalf of ENVY of ENVY's cancellation of this commitment.
A committed credit facility is a legal agreement between the lender and the borrower outlining the conditions of the credit facility. Once signed, the agreement requires the lender to lend money to the borrower, provided that the borrower satisfies the agreement's conditions (e.g., paying fees).
Committed credit lines differ from uncommitted credit lines in that they legally bind the lender to provide the funds, rather than giving the lender the option of suspending or canceling the credit line based on market conditions.

BVY 14-085 / Attachment 1 / Page 9 of 17 Table 4 - License Termination Expenditures (thousands, 2014 dollars)
Equip. &                       Waste Year      Labor         Materials         Energy      Disposal     Other     Total 2014               0                0              0             0    15,165    15,165 2015         39,626               533          3,912            38   37,089     81,198 2016         15,512               442          1,004            22    19,145    36,126 2017          2,015               395            184            14     8,216    10,823 2018           1,898              395            184            14     7,057     9,548 2019           1,858              395            184            14     5,722     8,173 2020          5,716             1,234          1,288         1,200     8,326    17,763 2021           1,969              284            187             7     2,794     5,241 2022           1,969              284            187             7     2,744     5,191 2023           1,969              284            187             7     2,744     5,191 2024           1,974              285            187             7     1,196     3,650 2025           1,969              284            187             7     1,144     3,591 2026           1,969              284            187             7     1,286     3,733 2027           1,969              284            187             7     1,336     3,783 2028           1,974              285            187             7     1,288     3,742 2029           1,969              284            187             7     1,286     3,733 2030           1,969              284            187             7     1,336     3,783 2031           1,969              284            187             7     1,286     3,733 2032           1,974              285            187             7     1,288     3,742 2033           1,969              284            187             7     1,336     3,783 2034           1,969              284            187             7     1,286     3,733 2035           1,969              284            187             7     1,286     3,733 2036           1,974              285            187             7     1,338     3,792 2037          1,969               284            187             7     1,286     3,733 2038           1,969              284            187             7     1,286     3,733 2039          1,969               284            187             7     1,336     3,783 2040          1,974               285            187             7     1,288     3,742 2041          1,969               284            187             7     1,286     3,733 2042          1,969               284            187             7     1,336     3,783 2043          1,969               284            187             7     1,286     3,733 2044          1,974               285            187             7     1,288     3,742 2045          1,969               284            187             7     1,336     3,783 2046          1,969               284            187             7     1,286     3,733 2047           1,969               284            187             7     1,286     3,733 2048          1,974               285            187             7     1,338     3,792 2049           1,969              284            187             7     1,286     3,733 2050           1,969              284            187             7     1,286     3,733 2051           1,969              284            187             7     1,336     3,783 2052          1,974               285            187             7     1,288     3,742

BVY 14-085 / Attachment 1 / Page 10 of 17 Table 4 - License Termination Expenditures (cont'd)
(thousands, 2014 dollars)
Equip. &                       Waste Year      Labor         Materials         Energy      Disposal      Other     Total 2053           1,969              278            187              6     1,142     3,583 2054           1,969              278            187              6     1,192     3,633 2055           1,969              278            187              6     1,142     3,583 2056           1,974              279            187              6     1,144     3,591 2057           1,969              278            187              6     1,192     3,633 2058           1,969              278            187              6     1,142     3,583 2059           1,969              278            187              6     1,142     3,583 2060           1,974              279            187              6     1,194     3,641 2061           1,969              278            187              6     1,142     3,583 2062           1,969              278            187              6     1,142     3,583 2063           1,969              278            187              6     1,192     3,633 2064           1,974              279            187              6     1,144     3,591 2065           1,969              278            187              6     1,142     3,583 2066           1,969              278            187              6     1,192     3,633 2067           1,969              278            187              6     1,142     3,583 2068         35,936            1,912           1,873             32     3,524    43,277 2069         53,909           14,320           1,821        12,174      9,806    92,030 2070         53,452           15,787           1,689        18,228     15,362   104,519 2071         46,489            8,170           1,401        10,716     17,749    84,524 2072         46,616            8,192           1,405        10,745     17,995    84,953 2073         38,409            3,090             599         2,488      5,554    50,139 2074             151                0              0              0       360       512 2075           71.35                0              0              0       224       295 Total       434,259           68,148          24,326        56,003   234,483    817,219

BVY 14-085 / Attachment 1 / Page 11 of 17 Table 5 - Spent Fuel Management Expenditures (thousands, 2014 dollars)
Equip. &
Year       Labor          Materials          Energy     Waste Disposal   Other     Total 2014                 0                0               0               0      4,753      4,753 2015                 0                0               0               0     14,319    14,319 2016             9,093                0           1,622               0     18,790    29,506 2017           13,547                 0           2,195               0     33,307    49,049 2018           13,547                 0           2,195               0     46,588    62,330 2019            13,547                0           2,195               0     43,942    59,684 2020             6,755                0           1,092               0     12,898    20,745 2021             3,238              338              79               0        341      3,996 2022             3,238              338              79                0       341      3,996 2023             3,238              338              79               0        341      3,996 2024             3,246              339              80               0        342      4,007 2025             3,238              338              79                0       341      3,996 2026             3,238              338              79                0       341      3,996 2027             3,238              338              79                0       341      3,996 2028             3,246              339              80                0       342      4,007 2029             3,238              338              79                0       341      3,996 2030 3,238              338              79                0       341      3,996 2031             3,238              338              79                0       341      3,996 2032             3,246              339              80                0       342      4,007 2033             3,238              338              79               0        341      3,996 2034             3,238              338              79               0        341      3,996 2035             3,238              338              79               0        341      3,996 2036             3,246              339              80               0        342      4,007 2037             3,238              338              79               0        341      3,996 2038             3,238              338              79                0       341      3,996 2039             3,238              338              79                0       341      3,996 2040             3,246              339              80               0        342      4,007 2041             3,238              338              79               0        341      3,996 2042             3,238              338              79                0       341      3,996 2043             3,238              338              79               0        341      3,996 2044             3,246              339              80               0        342      4,007 2045             3,238              338              79                0       341      3,996 2046             3,238              338              79                0       341      3,996 2047             3,238              338              79                0       341      3,996 2048             3,246              339              80                0       342      4,007 2049             3,238              338              79                0       341      3,996 2050             3,238              338              79                0       341      3,996 2051             3,238              338              79                0       341      3,996

BVY 14-085 / Attachment 1 / Page 12 of 17 Table 5 - Spent Fuel Management Expenditures (cont'd)
(thousands, 2014 dollars)
Equip. &
Year     Labor       Materials        Energy    Waste Disposal  Other   Total 2052     3,246          339             80            0          342    4,007 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        0             0              0            0           0       0 2068        0             0              0            0           0       0 2069        0             0              0            0           0       0 2070        0             0              0            0           0       0 2071        0             0              0            0           0       0 2072        0             0              0            0           0       0 2073        0             0              0            0           0       0 2074        0             0              0            0           0       0 2075        0             0               0           0           0       0 Total   160,164        10,816          11,843         0        185,524 368,347

BVY 14-085 / Attachment 1 / Page 13 of 17 Table 6 - Annual Cash Flow Analysis Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands, 2014 Dollars)
Date               Amount Current Value of Qualified Trust Fund                                  10/31/2014        $         654,925 Current Value of Non-Qualified Trust Fund                              10/31/2014        $              38 Total Trust Fund Balance as of                                         10/31/2014        $         654,963 Start of Decommissioning                                               12/29/2014 Decommissioning Funds value at Calculation Date                        10/31/2014        $         654,963 Total Estimated Costs at Calculation Date                              10/31/2014        $      1,042,748 Start of Decom to end of Decom - Assumes 0.0% Decom cost escalation Cost Escalation Rate rate Start of Decom to end of Decom - Assumes 2.0%
Fund Earnings Rate Earnings Rate Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)
Column 4 License Column 1       Column 2         Column 3          Termination Cost plus     Bogumng Clm                                     Column 8  Column 9
____            ____                 ot ls        8 Begin  ning of   Colum           ou    7    Trs    YerEdn 50.75        50.54 (bb)       Exclude            Spent Fuel       Year                mn 6     C            Trust  Year Ending Year        License       Spent Fuel      Transfer to        Management          Fund         Withdraw      Contribute   Fund    Trust Fund Termination    Management        Dry Fuel             Cost less       Balance                                Earnings   Balance Cost           Cost        Storage Cost         Transfer to Dry Fuel Storage Cost 2014         15,165         4,753            4,753               15,165         654,963        15,165            0       2,183    641,981 2015        81,198          14,319          10,001              85,515          641,981        85,515            0      11,984    568,450 2016        36,126          29,506           7,613              58,018          568,450        58,018            0      10,789    521,221 2017         10,823        49,049           28,873              31,000          521,221        31,000            0      10,114    500,335 2018         9,548          62,330          41,644              30,235          500,335        30,235            0      9,704     479,805 2019         8,173          59,684          39,516              28,342          479,805        28,342            0       9,313    460,776 2020         17,763         20,745          10,420              28,088          460,776        28,088            0       8,935    441,622 2021         5,241           3,996                               9,237          441,622         9,237            0       8,740    441,125 2022         5,191           3,996                               9,187          441,125         9,187            0       8,731    440,669 2023         5,191           3,996                               9,187          440,669         9,187            0       8,722    440,204 2024         3,650          4,007                                7,657          440,204         7,657            0       8,728    441,274 2025         3,591           3,996                                7,587         441,274         7,587            0       8,750    442,437 2026         3,733           3,996                                7,729         442,437         7,729            0       8,771    443,480 2027         3,783           3,996                               7,779          443,480         7,779            0       8,792    444,493 2028         3,742          4,007                                 7,749         444,493         7,749            0       8,812    445,557 2029         3,733           3,996                                7,729         445,557         7,729            0       8,834    446,662 2030         3,783           3,996                                7,779         446,662         7,779            0       8,855    447,738

BVY 14-085 / Attachment 1 / Page 14 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (in Thousands in 2014 Dollars)
Column 4 License Termination   Clm Column 1     Column 2        Column 3           Cost plus  Beinn fColumn                                8  Column 9 50.75      50.54 (bb)       Exclude          Spent Fuel  Bearn~n ofus Coum       Column 7       Trust   Year Ending Year       License     Spent Fuel     Transfer to      Management       Fund      Withdraw   Contribute     Fund    Trust Fund Termination  Management       Dry Fuel           Cost less    Balance                            Earnings    Balance Cost         Cost       Storage Cost        Transfer to Dry Fuel Storage Cost 2031  1     3,733        3,996                              7,729      447,738     7,729         0         8,877      448,887 2032        3,742        4,007                              7,749      448,887     7,749         0         8,900      450,039 2033        3,783        3,996                              7,779      450,039     7,779         0         8,923      451,183 2034        3,733        3,996                              7,729      451,183     7,729         0         8,946      452,400 2035        3,733        3,996                              7,729      452,400     7,729         0         8,971      453,642 2036        3,792        4,007                              7,799      453,642     7,799         0          8,995     454,839 2037        3,733        3,996                              7,729      454,839     7,729         0          9,019     456,129 2038        3,733        3,996                              7,729      456,129     7,729         0          9,045     457,446 2039        3,783        3,996                              7,779      457,446     7,779         0          9,071     458,738 2040        3,742        4,007                              7,749      458,738     7,749         0          9,097     460,087 2041        3,733        3,996                              7,729      460,087     7,729         0          9,124     461,482 2042        3,783        3,996                              7,779      461,482     7,779         0          9,152     462,855 2043        3,733        3,996                              7,729      462,855     7,729         0          9,180     464,306 2044        3,742        4,007                              7,749      464,306     7,749         0          9,209     465,767 2045        3,783        3,996                              7,779      465,767     7,779         0          9,238     467,225 2046        3,733        3,996                              7,729      467,225     7,729         0          9,267     468,764 2047        3,733        3,996                              7,729      468,764     7,729         0          9,298     470,333 2048        3,792        4,007                              7,799      470,333     7,799         0          9,329     471,863 2049        3,733        3,996                              7,729      471,863     7,729         0          9,360     473,494 2050        3,733        3,996                              7,729      473,494     7,729         0          9,393     475,158 2051        3,783        3,996                              7,779      475,158     7,779         0          9,425     476,804 2052        3,742        4,007                              7,749      476,804     7,749         0          9,459     478,514 2053        3,583          0                                3,583      478,514     3,583         0          9,534     484,4866 2054        3,633          0                                3,633      484,466     3,633         0          9,653     490,487 2055        3,583          0                                3,583      490,487     3,583         0          9,774     496,678 2056        3,591          0                                3,591      496,678     3,591         0          9,898     502,984 2057        3,633          0                                3,633      502,984     3,633         0         10,023     509,375 2058  1     3,583          0                                3,583      509,375     3,583         0         10,152     515,944 2059        3,583          0                                3,583      515,944     3,583         0         10,283     522,644 2060        3,641          0                                3,641      522,644     3,641         0         10,416     529,419 2061        3,583          0                                3,583      529,419     3,583         0         10,553     536,389 2062        3,583          0                         1      3,583      536,389     3,583         0         10,692     543,499 2063        3,633          0                                3,633      543,499     3,633   1     0       110,834      550,700 2064        3,591          0                                3,591      550,700     3,591   1     0      110,978       558,086

BVY 14-085 / Attachment 1 / Page 15 of 17 Vermont Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management less Transfer to Dry Fuel Storage Costs (In Thousands in 2014 Dollars)
Column 4 License Termination Column 1       Column 2     Column 3            Cost plus  Bogumng                           Column 8  Column 9 50.75       50.54 (bb)    Exclude           Spent Fuel  Year Trustof Beginning    Coun6 C          olm7 7 Column       Trs Trust  YerEdg Year Ending Year        License      Spent Fuel   Transfer to      Management       Fund      Withdraw  Contribute   Fund   Trust Fund Termination    Management     Dry Fuel           Cost less    Balance                         Earnings   Balance Cost           Cost     Storage Cost        Transfer to Dry Fuel Storage Cost 2065         3,583           0                              3,583      558,086       3,583      0       11,126    565,630 2066         3,633           0                              3,633      565,630       3,633      0       11,276    573,273 2067         3,583           0                              3,583      573,273       3,583      0       11,430    581,120 2068        43,277           0                             43,277      581,120      43,277      0       11,190    549,033 2069        92,030           0                             92,030      549,033      92,030      0       10,060    467,064 2070       104,519           0                            104,519      467,064     104,519      0       8,296     370,841 2071        84,524           0                             84,524      370,841      84,524      0       6,572     292,889 2072        84,953           0                             84,953      292,889      84,953      0        5,008    212,944 2073        50,139           0                             50,139      212,944      50,139      0        3,757    166,563 2074          512            0                               512       166,563        512       0        3,326    169,377 2075          295            0                               295       169,377        295       0       3,385     172,466 2076           0             0                                0        172,466         0        0       3,449     175,915 817,219        368,347      142,819           1,042,748                1,042,748     0      563,701 Table 6 Definitions:
Column 1:            50.75 License Termination Cost Reflects the Total Annual License Termination Plan cost in 2014 dollars at a 0.0%
escalation rate Column 2:            50.54 (bb) Spent Fuel Management Cost Reflects the Total Annual Irradiated Fuel Management Plan cost in 2014 dollars at a 0.0% escalation rate Column 3:            Exclude Transfer to Dry Fuel Storage Cost Reflects the Transfer to Dry Fuel Storage Cost included in Column 2 that is planned to be funded by external credit facilities, in 2014 dollars at a 0.0% escalation rate Column 4:            License Termination Cost plus Spent Fuel Management Cost less Transfer to Dry Fuel Storage Cost Reflects the Total Annual License Termination Plan cost plus Total Spent Fuel Management Plan cost less Transfer to Dry Fuel Storage cost all in 2014 dollars at a 0.0% escalation rate (Column 1 + Column 2 - Column 3)

BVY 14-085 / Attachment 1 / Page 16 of 17 Column 5:        Beginning of Year Trust Fund Balance Reflects the beginning of year Trust Fund balance in 2014 dollars at a 0.0% escalation rate and 2.0% Fund Earnings Column 6:        Withdraw Reflects the annual expenditures from the Trust Fund in 2014 dollars at a 0.0%
escalation rate (equals Column 4)
Column 7:        Contribute Reflects the annual contributions to the Trust Fund in 2014 dollars at a 0.0% escalation rate Column 8:        Trust Fund Earnings Reflects earnings on funds remaining in the trust. A 2.0% earnings rate is used over a 0.0% cost escalation rate. The annual 2.0% earnings are calculated on the beginning balance less 50% of the projected annual expenditure for each year. (Column 5 - 50% of Column 6
* 2.0%)
Column 9:        Year Ending Trust Fund Balance Reflects the end of year Trust Fund balance after all projected earnings are added and all projected expenditures are deducted for year end specified at a 0.0% escalation rate and 2.0% Fund Earnings in 2014 dollars. (Column 5 - Column 6 + Column 7 + Column 8)
V.      Reaulatory Activities The Program assumes withdrawals from the VYNPS decommissioning trust fund for operational spent fuel management costs. ENO will make appropriate submittals to request an exemption in accordance with 10 CFR 50.12 from the requirements of 10 CFR 50.82(a)(8)(i)(A), which would permit the use of decommissioning trust funds for spent fuel management expenses. The availability of decommissioning funding sources will be periodically revisited to ensure that withdrawals from the fund do not inhibit the ability to complete license termination and spent fuel management activities.
In addition, in accordance with 10 CFR 50.82(a)(8)(vii), ENO will submit a report on the status of spent fuel management funding by March 31 of each year. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing spent fuel, the projected cost of managing spent fuel until it is transferred to DOE, and if the funds accumulated do not cover the projected cost, a plan to provide additional funding assurance using one of the methods allowed by NRC regulations.

BVY 14-085 / Attachment 1 / Page 17 of 17 VI. Summary The spent fuel management activities described in this updated Program must be performed in conjunction with license termination activities. The annual cash flow analysis demonstrates that the VYNPS decommissioning trust fund with projected earnings, together with an additional
$145 million in credit available for transfer to dry fuel storage activities, will be sufficient to cover the estimated license termination and spent fuel management costs.
VII. References
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Report Pursuant to 10 CFR 50.54(bb)," BVY 07-007, dated March 21, 2007 (ML070860696)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Revised Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)," BVY 08-077, dated October 14, 2008 (ML082910294)
: 3. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Spent Fuel Management Program and Preliminary Decommissioning Cost Estimate (TAC NOs.
MD8035 and MD8051)," dated February 3, 2009 (ML083390193)
: 4. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Vermont Yankee Spent Fuel Management Plan," BVY 09-022, dated April 1, 2009 (ML091040287)
: 5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VY Spent Fuel Management Plan -
RAI Response)," BVY 09-048, dated August 18, 2009 (ML092370298)
: 6. Letter, USNRC to Entergy Nuclear Operations, Inc., "Safety Evaluation Re: Update to Spent Fuel Management Program (TAC NO. ME1 152)," dated October 8, 2009 (ML092740238)
: 7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)
: 8. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report," BVY 14-078, dated December 19, 2014
: 9. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Vermont Yankee Decommissioning Funding Status Report," BVY 14-082, dated December 19, 2014

BVY 14-085 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station List of Cancelled Regulatory Commitments

BVY 14-085 / Attachment 2 / Page 1 of 1 List of Cancelled Regulatory Commitments This table identifies actions discussed in this letter for which ENVY no longer commits to perform.
DATE OF ORIGINAL COMMITMENT                          COMMITMENT          CHANGED DATE Provide additional funding of $127.017 million dollars to trust fund for Spent Fuel Management.                                       December 31, 2026     This commitment is cancelled.
Source: Letter BVY 09-048, dated August 18, 2009 (ML092370298)}}