L-24-017, Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations

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Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations
ML24345A117
Person / Time
Site: Palisades, Indian Point, Oyster Creek, Pilgrim, Big Rock Point
Issue date: 12/10/2024
From: Fleming J
Holtec Decommissioning International
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI-IPEC-24-046, HDI-OC-24-039, HDI-PIL-24-017, HDI-PNP-2024-042, HDI-BRP-2024-002
Download: ML24345A117 (1)
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Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 4 10 CFR 72.30 December 10, 2024 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility Operating License No. DPR-35 NRC Docket No. 50-293 and 72-1044 Indian Point Nuclear Generating Stations 1, 2, & 3 Provisional Operating License No. DPR-5 Renewed Facility Operating License Nos. DPR-26 and DPR-64 NRC Docket Nos. 50-3, 50-247, 50-286, and 72-051 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket No. 50-255 and 72-007 Big Rock Point NRC License No. DPR-6 NRC Docket No. 50-155 and 72-043

Subject:

Report on Status of Decommissioning Funding for Independent Spent Fuel Storage Installations In accordance with 10 CFR 72.30, Financial assurance and recordkeeping for decommissioning, Holtec Decommissioning International, LLC (HDI) is submitting a report on the status of decommissioning funding plans for the independent spent fuel storage installations (ISFSIs) for Oyster Creek Nuclear Station (Oyster Creek), Pilgrim Nuclear Station (Pilgrim),

Indian Point Nuclear Stations Units 1, 2, and 3 (IPEC), Palisades Nuclear Plant (Palisades), and Big Rock Point (BRP).

The ISFSI estimated costs are provided in the HDI Post-Shutdown Decommissioning Activities Report (PSDAR) and site-specific Decommissioning Cost Estimates (DCE) (References 2-6).

The site-specific DCEs, as updated in the annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (Reference 1), includes the estimated costs to decommission ISFSIs following the removal of spent fuel and Greater than

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 4 Class C (GTCC) waste from the site. All estimates have been escalated to 2023 dollars.

Financial assurance for BRP ISFSI decommissioning is provided by an external trust fund in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1), as approved by NRC staff in the license transfer to Holtec Palisades, LLC and HDI.

The estimates provided in Enclosures 1, 2, 3, 4, and 5 indicate that the decommissioning trust funds, using the December 31, 2023 fund balances, exceed the estimated costs of ISFSI decommissioning, as summarized in Table 1, and meet the NRCs funding requirements.

Accordingly, HDI concludes that adequate funding assurance exists for ISFSI decommissioning for Oyster Creek, Pilgrim, IPEC, Palisades, and BRP.

Table 1 (amounts rounded)

Plant Site Trust Fund Surplus1 ISFSI DCE Oyster Creek

$45.6M

$4.5M Pilgrim

$83.8M

$4.6M Indian Point2 Unit 1: $136.7M Units 1,2, and 3:

$8.1M Unit 2: $17.8M Unit 3: $36.5M Palisades

$23.6M

$10.5M BRP

$300,000

$3.0M This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at (856) 797-0900, ext. 3578.

1 Trust Fund Surplus value from Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, March 29, 2024 (ML24089A117) 2 As provided in Section II of the DEC Order, Holtec has also established restoration-specific, third-party financial assurance in the amount of $110.593M, with the NYSDEC named as beneficiary. This financial assurance is required so long as the DEC Order remains in effect, subject to certain adjustments, as set forth therein. (DPS CASE19-E-0730)

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 4 Sincerely, Jean A. Fleming Vice President, Licensing and Regulatory Affairs Holtec Decommissioning International, LLC

Enclosures:

1. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Oyster Creek Nuclear Generating Station
2. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Pilgrim Nuclear Power Station
3. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Indian Point Nuclear Generating Station, Units 1, 2, & 3
4. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Palisades Nuclear Plant
5. 10 CFR 72.30 ISFSI Decommissioning Funding Plan - Big Rock Point

References:

1. Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI) March 29, 2024 (ML24089A117)
2. Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Oyster Creek Nuclear Generating Station, September 28, 2018 (ML18275A116)
3. Letter, Holtec Decommissioning International, LLC to US NRC, Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, November 16, 2018 (ML18320A040)
4. Letter, Holtec Decommissioning International, LLC to US NRC, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Indian Point Nuclear Generating Units 1, 2, and 3, December 19, 2019 (ML19354A698)
5. Letter, Holtec Decommissioning International, LLC to US NRC, Post Shutdown Decommissioning Activities Report including Site-Specific Decommissioning Cost Estimate for Palisades Nuclear Plant, December 23, 2022 (ML20358A232)
6. Letter, Holtec Decommissioning International, LLC to US NRC, Holtec Decommissioning International, LLC (HDI) satisfactory documentary evidence required before the planned closing date of the purchase and sale transaction of Digitally signed by Jean A. Fleming DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Environmental Affairs, email=J.Fleming@Holtec.com Date: 2024.12.10 10:52:20 -05'00' Jean A.

Fleming

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 4 Palisades Nuclear Plant and Big Rock Point Plant, June 24, 2022 (ML22178A077)

7. Exemption from requirements 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Oyster Creek, spent fuel management and site restoration activities in accordance with the Oyster Creek PSDAR and DCE (ML18228A498)
8. Exemption from requirements 10 CFR 50.82(a)(8)(i)(A) for Pilgrim, spent fuel management and site restoration activities in accordance with the Pilgrims PSDAR and DCE (ML19163A001)
9. Exemption from requirements 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for IPEC, spent fuel management and site restoration activities in accordance with the IPECs PSDAR and DCE (ML20309A781)
10. Exemption from requirements 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) for Palisades, spent fuel management and site restoration activities in accordance with the Palisades PSDAR and DCE (ML21286A506) cc:

USNRC Regional Administrator, Region 1 USNRC Regional Administrator, Region 3 USNRC Senior Project Manager, NMSS - Oyster Creek USNRC Senior Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Senior Project Manager, NMSS - Indian Point Units 1, 2 & 3 USNRC Senior Project Manager, NMSS - Palisades Nuclear Plant and BRP USNRC Senior Project Manager, NRR - Palisades Nuclear Plant NRC Region 1 Lead Decommissioning Inspector - Oyster Creek NRC Region 1 Lead Decommissioning Inspector - Pilgrim Nuclear Power Station NRC Region 1 Lead Decommissioning Inspector, Indian Point Units 1, 2 & 3 NRC Region 3 Chief, Operations Branch - Palisades Nuclear Plant NRC Region 3 Lead Decommissioning Inspector - Palisades Nuclear Plant and BRP New York State Department of Public Service New York State Liaison Officer Designee, NYSERDA New Jersey DEP - Assistant Commissioner, Air Quality, Energy and Sustainability New Jersey Bureau of Nuclear Engineering, Assistant Director Radiation Protection Element Commonwealth of Massachusetts, Executive Office of Environmental Affairs Commonwealth of Massachusetts, Department of Public Health Commonwealth of Massachusetts, Department of Environmental Protection Commonwealth of Massachusetts, Director, Massachusetts Emergency Management Agency

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 ENCLOSURE 1 10 CFR 72.30 ISFSI Decommissioning Funding Plan Oyster Creek Nuclear Generating Station

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Oyster Creek Nuclear Generating Station Background and Introduction As required by 10 CFR 72.30(c), Holtec Decommissioning International, LLC (HDI) reports the following information on the detailed cost estimate for decommissioning the ISFSI at Oyster Creek Nuclear Generating Station (Oyster Creek).

Key Assumptions / Estimating Approach In accordance with 10 CFR 72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

The canister overpack assemblies are not expected to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. The decommissioning estimate assumes that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning.

The storage overpacks used for the GTCC canisters are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a radiological release survey.

No contamination or activation of the ISFSI pads is assumed. As such, only verification surveys are included for the pads in the decommissioning estimate. The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use.

In accordance with the specific requirements of 10 CFR 72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 5 The effects, if any, since the last submittal of the ISFSI decommissioning funding plan, of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

1. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSI in the past three years.
2. Facility modifications:
a. No impact. There have not been any modifications to the ISFSI at the facility in the past three years that would materially change the latest decommissioning cost estimate.

Actual costs for modifications to the ISFSI are bounded by the costs assumed in the decommissioning cost estimate.

3. Changes in authorized possession limits:
a. No impact. There have not been any changes in authorized possession limits at the ISFSI in the past three years that would materially change the decommissioning cost estimate.
4. Actual remediation costs that exceed the previous cost estimate:
a. No impact. No actual remediation costs have been incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 1-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys, and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2035, the same year all spent fuel removal.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 5 Financial Assurance ISFSI operations at Oyster Creek are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such a time that the costs can be recovered from the DOE, HDI will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

The projected amount necessary to complete decommissioning of Oyster Creek is

$331M, based on HDIs 2023 annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (Reference 1).

HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the Oyster Creek trust fund to be used for site irradiated fuel management and site restoration costs (Reference 7). To the extent that the trust fund balance exceeds costs required for 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

Based upon Oyster Creeks decommissioning trust fund balance as of December 31, 2023, the trust fund will contain a $45.6 million surplus (Reference 1). This surplus is more than sufficient to complete the decommissioning of the ISFSI.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 5 of 5 Table 1-1 Oyster Creek ISFSI Decommissioning Cost Estimate (thousands of 2023 dollars)

Oyster Creek Activity WBS PSDAR License Termination Spent Fuel Site Restoration Total Costs ISFSI Demolition Non-Radiological 10.03.02.03 836 836 ISFSI Final Site Survey 10.03.01.01 37 37 ISFSI NRC Confirmatory Survey 10.03.01.01 12 12 ISFSI Demolition Radiological 10.03.01.01 1,017 1,017 ISFSI Radiological Waste 10.03.02.02 428 428 NRC License Termination Support 10.03.01.01 257 257 Security and O&M 10.03.02.02 672 672 Property Tax 10.03.02.02 842 842 Insurance 10.03.02.02 147 147 NRC Regulatory Fees 10.03.02.02 253 253 Totals 1,323 2,342 836 4,500

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 ENCLOSURE 2 10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Pilgrim Nuclear Power Station Background and Introduction As required by 10 CFR 72.30(c), Holtec Decommissioning International, LLC (HDI) reports the following information on the detailed cost estimate for decommissioning the ISFSI at the Pilgrim Nuclear Power Station (Pilgrim).

Key Assumptions / Estimating Approach In accordance with 10 CFR 72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

The canister overpack assemblies are not expected to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. The decommissioning estimate assumes that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning.

The storage overpacks used for the GTCC canisters are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a radiological release survey.

No contamination or activation of the ISFSI pads is assumed. As such, only verification surveys are included for the pads in the decommissioning estimate. The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use.

In accordance with the specific requirements of 10 CFR 72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 5

1. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSIs in the past three years.
2. Facility modifications:
a. No impact. There have not been any modifications to the ISFSI at the facility in the past three years that would materially change the latest decommissioning cost estimate.

Actual costs for modifications to the ISFSI are bounded by the costs assumed in the decommissioning cost estimate.

3. Changes in authorized possession limits:
a. No impact. There have not been any changes in authorized possession limits at the ISFSIs in the past three years that would materially change the decommissioning cost estimate.
4. Actual remediation costs that exceed the previous cost estimate:
a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 2-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys, and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2063, the year following all spent fuel removal.

Financial Assurance ISFSI operations at Pilgrim are in response to the DOEs failure to remove spent nuclear fuel

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 5 from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such a time that the costs can be recovered from the DOE, HDI will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

The projected amount necessary to complete decommissioning of Pilgrim is $592M, based on HDIs 2023 annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (Reference 1).

HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the Pilgrim trust fund to be used for site irradiated fuel management and site restoration costs (Reference 8).

To the extent that the trust fund balance exceeds costs required for 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

Based upon Pilgrims decommissioning trust fund balance as of December 31, 2023, the trust fund will contain a $83.8 million surplus (Reference 1). This surplus is more than sufficient to complete the decommissioning of the ISFSI.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 Table 2-1 Pilgrim ISFSI Decommissioning Cost Estimate (thousands of 2023 dollars)

Pilgrim Activity WBS PSDAR License Termination Spent Fuel Site Restoration Total Costs ISFSI Demolition Non-Radiological 10.03.02.03 688 688 ISFSI Final Site Survey 10.03.01.01 34 34 ISFSI NRC Confirmatory Survey 10.03.01.01 13 13 ISFSI Demolition Radiological 10.03.01.01 934 934 ISFSI Waste Class A/Hazardous/Exempt 10.03.02.03 10.03.02.02 430 88 518 NRC License Termination Support 10.03.01.01 175 175 Security & O&M 10.03.02.02 638 638 Property Tax 10.03.02.02 671 671 Insurance 10.03.02.02 696 696 NRC Regulatory Fees 10.03.02.02 252 252 Totals 1,157 2,687 776 4,620

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 ENCLOSURE 3 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Generating Stations 1, 2, & 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Indian Point Nuclear Generating Stations 1, 2, & 3 Background and Introduction As required by 10 CFR 72.30(c), Holtec Decommissioning International, LLC (HDI) reports the following information on the detailed cost estimate for decommissioning the ISFSI at the Indian Point Units 1, 2, and 3 (IP1, IP2, and IP3), collectively referred to as Indian Point Energy Center (IPEC).

Key Assumptions / Estimating Approach In accordance with 10 CFR 72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

The canister overpack assemblies are not expected to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. The decommissioning estimate assumes that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning.

The storage overpacks used for the GTCC canisters are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a radiological release survey.

No contamination or activation of the ISFSI pads is assumed. As such, only verification surveys are included for the pads in the decommissioning estimate. The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use.

In accordance with the specific requirements of 10 CFR 72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

1. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSI in

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 5 the past three years.

2. Facility modifications:
a. No impact. There have been modifications to the ISFSIs at the facility in the past three years that would not materially change the latest decommissioning cost estimate.

The ISFSI facility design at the time the cost estimate was prepared was incorporated into the estimate. Also, any ISFSI modifications (i.e. ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the cost estimate.

3. Changes in authorized possession limits:
a. No impact. There have not been any changes in authorized possession limits at the ISFSI in the past three years that would materially change the decommissioning cost estimate.
4. Actual remediation costs that exceed the previous cost estimate:
a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 3-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys, and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2062, the year following all spent fuel removal.

Financial Assurance ISFSI operations at IPEC are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such a time that the costs can be recovered from the DOE, HDI will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 5 Using the decommissioning trust fund is reasonable based on the following:

The projected amount necessary to complete decommissioning of IPEC is $668 million (Unit 1), $627 million (Unit 2), and $688 million (Unit 3), based on HDIs 2023 annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations (Reference 1).

HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the IPECs trust funds to be used for site irradiated fuel management and site restoration costs (Referencec 9).

To the extent that the trust fund balance exceeds costs required for 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

Based upon IPECs (Unit 1, 2 & 3) decommissioning trust fund balance as of December 31, 2023, the trust fund will contain surpluses of 136.7 million (Unit 1), $17.8 million (Unit 2), and $36.5 million (Unit 3), totaling $191 million (Reference 1). This surplus is more than sufficient to complete the decommissioning of the ISFSI.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 5 of 5 Table 3-1 IPEC ISFSI Decommissioning Cost Estimate (thousands of 2023 dollars)

IPEC Activity WBS PSDAR License Termination Spent Fuel Site Restoration Total Costs ISFSI Demolition Non-Radiological 10.03.02.03 971 971 ISFSI Final Site Survey 10.03.01.01 182 182 ISFSI NRC Confirmatory Survey 10.03.01.01 ISFSI Demolition Radiological 10.03.01.01 1,839 1,839 ISFSI Waste Class A/Hazardous/Exempt 10.03.02.03 10.03.02.02 389 463 851 NRC License Termination Support 10.03.01.01 16 16 Security & O&M 10.03.02.02 2,423 2,423 Planning (Characterization, Specs and Procedures) 10.03.01.01 101 101 Insurance 10.03.02.02 771 771 NRC Regulatory Fees 10.03.02.02 945 945 Totals 2,138 4,528 1,434 8,100

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 ENCLOSURE 4 10 CFR 72.30 ISFSI Decommissioning Funding Plan Palisades Nuclear Plant

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Palisades Nuclear Plant Background and Introduction As required by 10 CFR 72.30(c), Holtec Decommissioning International, LLC (HDI) reports the following information on the detailed cost estimate for decommissioning the ISFSI at the Palisades Nuclear Plant (PNP).

Key Assumptions / Estimating Approach In accordance with 10 CFR 72.30, licensees must have a proposed decommissioning plan for the ISFSI site and facilities that includes a cost estimate for the plan. The plan should contain sufficient information on the proposed practices and procedures for the decontamination of the ISFSI and for the disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor related GTCC waste have been removed.

The canister overpack assemblies are not expected to have any interior or exterior radioactive surface contamination. Any neutron activation of the steel and concrete is expected to be extremely small. The decommissioning estimate assumes that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning.

The storage overpacks used for the GTCC canisters are not expected to have any interior contamination or residual activation and can be reused or disposed of by conventional means after a radiological release survey.

No contamination or activation of the ISFSI pads is assumed. As such, only verification surveys are included for the pad in the decommissioning estimate. The estimate is limited to the costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use.

In accordance with the specific requirements of 10 CFR 72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use.

The effects, if any, since the last submittal of the ISFSI decommissioning funding plan of the following events listed in 10 CFR 72.30(c)(1)-(4) have been specifically considered in the decommissioning cost estimate:

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 5

1. Spills of radioactive material producing additional residual radioactivity in onsite subsurface material:
a. No impact. There have not been any spills of radioactive material producing additional residual radioactivity in onsite subsurface material at the ISFSI in the past three years.
2. Facility modifications:
a. No impact. There have been modifications to the ISFSIs at the facility in the past three years that would not materially change the latest decommissioning cost estimate.

The ISFSI facility design at the time the cost estimate was prepared was incorporated into the estimate. Also, any ISFSI modifications (i.e. ISFSI pad expansions) required to accommodate spent fuel storage after permanent shutdown were incorporated in the cost estimate.

3. Changes in authorized possession limits:
a. No impact. There have not been any changes in authorized possession limits at the ISFSI in the past three years that would materially change the decommissioning cost estimate.
4. Actual remediation costs that exceed the previous cost estimate:
a. No impact. No actual remediation costs have incurred that exceed the latest cost estimate.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 4-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2041, the year following all spent fuel removal.

Financial Assurance ISFSI operations at Palisades are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 5 needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such a time that the costs can be recovered from the DOE, HDI will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

The projected amount necessary to complete decommissioning of Palisades is $595M, based on HDIs 2023 annual report for the status of decommissioning funding for reactors and independent spent fuel storage installations. (Reference 1)

HDI received an exemption from 10 CFR 50.82(a)(8)(i)(A) to allow the Palisades trust fund to be used for site irradiated fuel management and site restoration costs.

(Reference 10) To the extent that the trust fund balance exceeds costs required for 10 CFR Part 50 radiological decommissioning, these funds would be available to address costs incurred by HDI, including ISFSI decommissioning costs.

Based upon Palisades decommissioning trust fund balance as of December 31, 2023, the trust fund will contain a $23.6 million surplus (Reference 1). This surplus is more than sufficient to complete the decommissioning of the ISFSI.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 5 of 5 Table 4-1 Palisades ISFSI Decommissioning Cost Estimate (thousands of 2023 dollars)

Palisades Activities WBS PSDAR License Termination Spent Fuel Site Restoration Total Costs ISFSI Demolition Non-Radiological 10.03.02.03 4,804 4,804 ISFSI Final Site Survey 10.03.01.01 113 113 ISFSI NRC Confirmatory Survey 10.03.01.01 11 11 ISFSI Demolition Radiological 10.03.01.01 559 559 ISFSI Radiological Waste 10.03.02.03 1,953 1,953 NRC License Termination Support 10.03.01.01 Security and O&M 10.03.02.02 1,110 1,110 Property Tax 10.03.02.02 15 15 Insurance 10.03.02.02 380 380 NRC Regulatory Fees 10.03.02.02 1,560 1,560 Totals 682 3,065 6,757 10,504

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 1 of 5 ENCLOSURE 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Big Rock Point

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 2 of 5 10 CFR 72.30 ISFSI Decommissioning Funding Plan Big Rock Point Background and Introduction As required by 10 CFR 72.30(c), Holtec Decommissioning International, LLC (HDI) reports the following information on the detailed cost estimate for decommissioning the ISFSI at Big Rock Point (BRP).

Key Assumptions / Estimating Approach The decommissioning estimate is based on the current configuration of the ISFSI, once all spent fuel and GTCC material has been removed from the site.

The dry storage vendor, BNFL, does not expect the overpacks to have any interior or exterior radioactive surface contamination (that could not be easily removed). Any neutron activation of the steel and concrete is expected to be minimal. The decommissioning estimate is based on the premise that some of the inner steel liners and the concrete overpacks will contain low levels of neutron-induced residual radioactivity that would necessitate remediation at the time of decommissioning. As an allowance, 2 of the 7 overpacks are assumed to be affected, i.e.,

contain residual radioactivity. The allowance quantity is based upon the number of casks required for the final core off-load (i.e., 84 off-loaded assemblies, 64 assemblies per cask) which results in 2 overpacks.

The dry storage vendor, BNFL, expects that any activation of the concrete ISFSI pad would be significantly less than of the storage casks. It would be expected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign. It is assumed for this analysis that a small portion of the ISFSI pad (directly underneath the two impacted casks) will be activated to a level that would require remediation for termination of the license. Verification surveys are included for the remainder of the pad. An allowance is also included for surveying any transfer equipment.

The estimate is limited to costs necessary to terminate the ISFSIs NRC license and meet the 10 CFR 20.1402 criteria for unrestricted use. Disposition of released material and structures is outside the scope of the estimate.

Prior to ISFSI pad construction, the NRC took radiological samples of the ground and fill upon which the ISFSI pad was constructed. No significant or unexpected radiological conditions were found, and no nuclear plant-related isotopes were identified in any sample. As such, the decommissioning estimate contains no cost allowance for soil remediation.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 3 of 5 In accordance with the specific requirements of 10 CFR 72.30 for the ISFSI work scope, the cost estimate for decommissioning the ISFSI reflects: 1) the cost of performing the decommissioning activities; 2) a Contingency Allowance of 25%; and 3) the cost of meeting the criteria for unrestricted use ISFSI Decommissioning Strategy For purposes of this funding plan, at the conclusion of the spent fuel transfer process the ISFSI will be promptly decommissioned (similar to the power reactor DECON alternative).

ISFSI Description The Big Rock Point ISFSI consists of 7 British Nuclear Fuels, Ltd. (BNFL) Fuel Solutions' W-150 modular concrete overpacks (each containing the spent fuel canister) and a 75 foot by 99 foot reinforced concrete pad. There is also one additional overpack containing Greater-than-Class C (GTCC) waste.

The storage overpack used for the GTCC canister is not expected to have any interior contamination from residual activation and can be reused or disposed of by conventional means after a final status survey.

Cost Considerations The estimated cost to decommission the ISFSI and release the facility for unrestricted use is provided in Table 5-1. The estimate includes costs for work planning, survey, and characterization work in preparation for decommissioning in addition to costs for demolition, packaging, transportation, and disposal of radioactive and non-radioactive waste. Costs are included for HDIs management staff, industrial security, and other site operating costs as well as the costs for the supporting equipment, materials, and supplies. Finally, costs are included for the final site survey, verification surveys, and activities necessary to release the ISFSI site for unrestricted use and terminate the licenses.

For estimating purposes, it is conservatively assumed that all expenditures will be incurred in the year 2044, the year following all spent fuel removal.

Financial Assurance ISFSI operations at Big Rock Point are in response to the DOEs failure to remove spent nuclear fuel from the site in a timely manner. It is therefore expected that, once the ISFSI is no longer needed, the cost to decommission the ISFSI would be a DOE-reimbursable expense.

Until such a time that the costs can be recovered from the DOE, HDI will rely upon the money available in its decommissioning trust fund to terminate the ISFSI license and release the facility for unrestricted use.

Using the decommissioning trust fund is reasonable based on the following:

The projected amount necessary to complete decommissioning of Big Rock is $3M, based on HDIs 2023 annual report for the status of decommissioning funding for

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 4 of 5 reactors and independent spent fuel storage installations (Reference 1).

Upon BRP license transfer to HDI, HDI created a trust fund to decommission the ISFSI as required as part of the license conditions and estimated in the NRC approved License Termination Plan.

Based upon Big Rock Points decommissioning trust fund balance as of December 31, 2023, the trust fund contains a $300,000 surplus (Reference 1). This surplus with 25%

contingency built into the estimate is more than sufficient to complete the decommissioning of the ISFSI.

This certifies that, based on the trust fund balance and costs as shown as of the dates reflected in this report, financial assurance has been provided in the amount of the cost estimate for decommissioning of the ISFSI.

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to HDI-IPEC-24-046 HDI-OC-24-039 HDI-PIL-24-017 HDI PNP 2024-042 HDI BRP 2024 -002 Page 5 of 5 Table 5-1 Big Rock ISFSI Decommissioning Cost Estimate (thousands of 2023 dollars)

Big Rock Activity WBS PSDAR License Termination Spent Fuel Site Restoration Total Costs ISFSI Demolition Non-Radiological 10.03.02.03 16 16 ISFSI Final Site Survey 10.03.01.01 833 833 ISFSI NRC Confirmatory Survey 10.03.01.01 ISFSI Demolition Radiological 10.03.01.01 ISFSI Waste Class A/Hazardous/Exempt 10.03.02.03 10.03.02.02 213 630 843 NRC License Termination Support 10.03.01.01 Security & O&M 10.03.02.02 305 305 Planning (Characterization, Specs and Procedures) 10.03.02.02 238 238 Insurance 10.03.02.02 58 58 NRC Regulatory Fees 10.03.02.02 687 687 Totals 1,502 1,479 2,981

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