ML21084A811

Indian Point Nuclear Generating, Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

ML21084A811
Person / Time
Site:	Palisades, Indian Point, Big Rock Point  File:Consumers Energy icon.png
Issue date:	03/25/2021
From:	Couture P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNRO2021-00004
Download: ML21084A811 (29)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5102 Phil Couture Sr. Manager, Fleet Regulatory Assurance 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)(v)

CNRO2021-00004 March 25, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Decommissioning Funding Status Report per 10 CFR §50.75(f)(1) and 10 CFR 50.82(a)(8)(v) -- Entergy Nuclear Operations, Inc.

Big Rock Point Nuclear Plant Indian Point Nuclear Generating NRC Docket No. 50-155 Stations 1, 2, & 3 License No. DPR-6 NRC Docket Nos. 50-3, 50-247, & 50-286 License Nos. DPR-5, DPR-26, & DPR-64 Palisades Nuclear Power Plant NRC Docket No. 50-255 License No. DPR-20 10 CFR 50.75(f)(1) requires each power reactor licensee to report to the NRC by March 31, 1999, and every two years thereafter with certain exceptions, on the status of its decommissioning funding for each reactor, or share of a reactor, that it owns. Additionally, any licensee for a plant that is within 5 years of the projected end of its operation, or where conditions have changed such that it will close within 5 years (before the end of its licensed life),

or that has already closed (before the end of its licensed life), or that is involved in a merger or an acquisition shall submit this report annually. 10 CFR 50.82(a)(8)(v) requires licensees of shutdown sites to report to the NRC annually, by March 31, on the status of decommissioning financial assurance for those sites. On behalf of Entergy Nuclear Indian Point 2, LLC (Indian Point 1 & 2), Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Palisades, LLC (Palisades and Big Rock Point), Entergy Nuclear Operations, Inc. (ENOI) hereby submits the information requested for power reactors operated by ENOI. The reports provided in Enclosures 1 through 8 for the licensed facilities addressed by this filing, were prepared in accordance with NUREG-1307 (Reference 1) and NRC Regulatory Issue Summary 2001-07 (Reference 2). The Minimum Funding Assurance calculation worksheets, (not required for this filing) derived from Datasheet 4 of LIC-205, Rev. 6 (Reference 3), are provided in Enclosure 9 for the convenience of the reviewer.

CNRO2021-00004 Page 2 of 4 The estimated minimum decommissioning fund values were determined using the NRCs methodology in NUREG-1307, Rev. 18 (Reference 1).

The trust fund amounts reported for each facility in the responses to item 3 represent the market value of decommissioning trust funds as of December 31, 2020 net of any material current income tax liability on realized gains, interest, dividends and other income of the trusts. The trusts for the following plants had estimated balances on their 2020 tax liabilities, not reflected in the trust fund balances, as follows (in thousands):

Indian Point 1 $ 0 Indian Point 2 $ 0 Indian Point 3 $ 0 Palisades $ 300 In accordance with guidance provided by the NRC Staff in April 2014 requests for additional information (Accession No. ML14120A273) that future 10 CFR 50.75(f) reports should clearly delineate estimated reactor and Independent Spent Fuel Storage Installation (ISFSI) decommissioning costs, the information in Enclosures 1, 2, 3, 5, and 7 includes line item 2 identifying the ISFSI decommissioning obligation, from the most recent 10 CFR 72.30 filing (escalated). This obligation is also accounted for in the Excess/Shortfall calculations for each plant in Enclosure 9 (or Enclosure 8 for Indian Point 1).

The aforementioned worksheets, using the December 31, 2020 trust fund balances and parent guarantee amount, indicate that all of the plants covered by this submittal met or exceeded the NRCs funding requirements. Accordingly, the licensees conclude that no further action is required at this time to demonstrate adequate funding assurance for decommissioning the plants covered by this submittal.

There are no new commitments made in this letter. Should you have any questions or require additional information, please contact me at 601-368-5102.

Respectfully, t

Phil Couture PC/ljs/chm

CNRO2021-00004 Page 3 of 4

Enclosures:

1) ENOI Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

2) ENOI Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

3) ENOI Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

4) ENOI Calculation of Minimum Amount - Indian Point 1, 2 & 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

5) ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

6) ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

7) ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

8) ENOI IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

9) ENOI Minimum Financial Assurance Calculation Worksheets

References:

1) NUREG-1307, Report on Waste Burial Charges, Revision 18, dated January 2021

2) NRC Regulatory Issue Summary (RIS) 2001-07, Rev. 1, 10 CFR 50.75 Reports and Recordkeeping for Decommissioning Planning

3) NRC LIC-205, Rev. 6, Procedures for NRCs Independent Analysis of Decommissioning Funding Assurance for Operating Nuclear Power Reactors and Power Reactors in Decommissioning, Date April 10, 2017

CNRO2021-00004 Page 4 of 4 cc: NRC Region I Regional Administrator NRC Region III Regional Administrator NRC Project Manager, Indian Point 1 NRC Project Manager, Indian Point 2 / 3 NRC Project Manager, Palisades NRC Project Manager, Entergy Fleet NRC Sr. Resident Inspector, Indian Point 2 / 3 NRC Sr. Resident Inspector, Palisades

Enclosure 1 CNRO2021-00004 ENOI Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

CNRO2021-00004 Page 1 of 2 ENOI Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Indian Point Nuclear Generating Unit No. 1 10 CFR 50.75(f)(1)

1. Minimum Financial Assurance (MFA) $606.15 million [Note1]

2. ISFSI Obligation as of 12/31/20

$1.79 million [Note2]

3. Decommissioning Trust Fund Total $631.25 million as of 12/31/20

4. A schedule of the annual amounts remaining to be collected None

5. Assumptions used in determining rates of escalation in 2% annual real rate of decommissioning costs, rates of earnings on decommissioning return per funds, and rates of other factors used in funding projections 10 CFR 50.75(e)(1)(i)

6. Any contracts upon which the licensee is relying pursuant to None 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of providing None financial assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Table 8-1 in Enclosure 8.

(Calculation of the NRC Minimum Amount is provided in Enclosure 4.)

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation. Total ISFSI obligation for Indian Point 1&2 is $10.76M with

$8.97M attributable to Indian Point 2 and $1.79M attributable to Indian Point 1, all in 2020$ (totals may not foot due to rounding).

CNRO2021-00004 Page 2 of 2 ENOI Status of Decommissioning Funding - Indian Point 1 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)

Plant Name: Indian Point Nuclear Generating Unit No. 1 10 CFR 50.82(a)(8)(v)

1. Cumulative decommissioning spending $136 million [Note 1]

2. 2020 decommissioning spending $12.4 million [Note 1]

3. Fund Balance See above in 10 CFR 50.75 information

4. No other financial assurance mechanism is being relied upon, but costs through 12/31/2020 have been funded by operations, and not the decommissioning fund.

5. Estimated costs to complete from latest estimate $606.15 million [Note 2]

6. Estimate is based on unrestricted release of the site per 10 CFR 20.1402

7. Modifications to financial assurance since last report See above in 10 CFR 50.75 information

8. Any material changes to trust agreements See above in 10 CFR 50.75 information Note 1: Entergy Nuclear Operations, Inc. (Entergy) does not possess records that would permit determination of charges to Indian Point 1 (IP1) prior to its acquisition in September 2001 by Entergy Nuclear Indian Point 2, LLC. The costs presented here represent those costs charged in 2020 and the total costs that have been assigned to IP1 since 2001. Entergy has not fully determined what portion of those costs would be considered decommissioning costs as that term is defined in 10 CFR 50.2.

Cumulative and 2020 decommissioning spending only consists of costs related to license termination.

Note 2: This amount is based upon total SAFSTOR expenditures for radiological remediation and license termination set forth in the updated Decommissioning Funding Assurance Plan and SAFSTOR analysis that are provided in Table 8-1 in Enclosure 8 (Calculation of the NRC Minimum Amount is provided in Enclosure 4). This estimate does not include 2020 spending because current costs are being paid out of operating funds.

Enclosure 2 CNRO2021-00004 ENOI Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Status of Decommissioning Funding - Indian Point 2 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 2

1. Minimum Financial Assurance (MFA) $529.89 million [Note 1]

estimated per 10 CFR 50.75(b) and (c) (2020)

2. ISFSI Obligation as of 12/31/20 $8.97 million [Note 2]

3. Decommissioning Trust Fund Total as of 12/31/20 $793.73 million [Note 3]

4. A schedule of the annual amounts remaining to be collected None

5. Assumptions used in determining rates of escalation in 2% annual real rate decommissioning costs, rates of earnings on decommissioning of return per funds, and rates of other factors used in funding projections 10 CFR 50.75(e)(1)(i)

6. Any contracts upon which the licensee is relying pursuant to None 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of providing None financial assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Enclosure 4.

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation. Total ISFSI obligation for Indian Point 1&2 is $10.76M with

$8.97M attributable to Indian Point 2 and $1.79M attributable to Indian Point 1, all in 2020$ (totals may not foot due to rounding).

Note 3: Includes provisional fund balance of $36.79 million.

Enclosure 3 CNRO2021-00004 ENOI Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Status of Decommissioning Funding - Indian Point 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Plant Name: Indian Point Nuclear Generating Unit No. 3

1. Minimum Financial Assurance (MFA) $529.89 million [Note 1]

estimated per 10 CFR 50.75(b) and (c) (2020$)

2. ISFSI Obligation as of 12/31/20 $10.76 million [Note 2]

3. Decommissioning Trust Fund Total $990.7 million as of 12/31/20

4. A schedule of the annual amounts remaining to be collected None

5. Assumptions used in determining rates of escalation in 2% annual real rate decommissioning costs, rates of earnings on decommissioning of return per funds, and rates of other factors used in funding projections 10 CFR 50.75(e)(1)(i)

6. Any contracts upon which the licensee is relying pursuant to None 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of providing None financial assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Enclosure 4.

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

Enclosure 4 CNRO2021-00004 ENOI Calculation of Minimum Amount - Indian Point 1, 2 & 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Calculation of Minimum Amount - Indian Point 1, 2 & 3 For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Entergy Nuclear Indian Point 2, LLC: 100% ownership interest of Indian Point 1 & 2 Entergy Nuclear Indian Point 3, LLC: 100% ownership interest of Indian Point 3 Plant Location: Buchanan, New York Reactor Type: Pressurized Water Reactor (PWR)

Indian Point Unit 1 Power Level: <3,400 MWt (615 MWt)

Indian Point Unit 1 PWR Base Year 1986$: $85,560,000 Indian Point Unit 2 Power Level: <3,400 MWt (3,216 MWt)

Indian Point Unit 2 PWR Base Year 1986$: $103,300,800 Indian Point Unit 3 Power Level: <3,400 MWt (3,216 MWt)

Indian Point Unit 3 PWR Base Year 1986$: $103,300,800 Labor Region: North Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (North) 3.111 E=Energy (PWR) 2.262 B=Waste Burial-Vendor (PWR) 12.7933 PWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B)= 5.12976 1986 PWR Base Year $ Escalated:

Indian Point 1: $85,560,000

• Factor = $438,884,739 Indian Point 2 & 3: $103,300,800

• Factor = $529,887,151 1

Bureau of Labor Statistics, Series Report ID: CIU2010000000210i (4th Quarter 2020) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2020) (Preliminary) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 18, Table 2-1 (2021)

Enclosure 5 CNRO2021-00004 ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Plant Name: Palisades Nuclear Plant

1. Minimum Financial Assurance (MFA) $486.73 million [Note 1]

estimated per 10 CFR 50.75(b) and (c) (2020$)

2. ISFSI Obligation as of 12/31/20 $8.48 million [Note 2]

3. Decommissioning Trust Fund Total $553.84 million as of 12/31/20

4. A schedule of the annual amounts remaining to be collected None

5. Assumptions used in determining rates of escalation in 2% annual real rate decommissioning costs, rates of earnings on decommissioning of return per funds, and rates of other factors used in funding projections 10 CFR 50.75(e)(1)(i)

6. Any contracts upon which the licensee is relying pursuant to None 10 CFR 50.75(e)(1)(v)

7. Modifications occurring to a licensee's current method of None providing financial assurance since the last submitted report

8. Any material changes to trust agreements None Note 1: Calculation of the NRC Minimum Amount is provided in Enclosure 6 Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

Enclosure 6 CNRO2021-00004 ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Entergy Nuclear Palisades LLC.: 100% ownership interest Plant Location: Covert, Michigan Reactor Type: Pressure Water Reactor (PWR)

Power Level: < 3,400 MWt (2565 MWt)

PWR Base Year 1986$: $97,572,000 Labor Region: Midwest Waste Burial Facility: Generic Disposal Site 10CFR50.75(c)(2) Escalation Factor Formula:

0.65(L) +0.13(E) +0.22(B)

Factor L=Labor (Midwest) 2.894 E=Energy (PWR) 2.265 B=Waste Burial-Vendor (PWR) 12.7936 PWR Escalation Factor:

0.65(L) +0.13(E) +0.22(B) = 4.98843 1986 PWR Base Year $ Escalated:

$97,572,000

• Factor = $486,730,814 4

Bureau of Labor Statistics, Series Report ID: CIU2010000000230i (4th Quarter 2020) 5 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2020) (Preliminary) 6 Nuclear Regulatory Commission: NUREG-1307 Revision 18, Table 2-1 (2021)

Enclosure 7 CNRO2021-00004 ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 1 ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

Plant Name: Big Rock Point ISFSl

1. Amount of decommissioning funds required from $2.7 million [Note 1]

most recent estimate (2020$).

2. Decommissioning Funding Assurance Method. Parent Guarantee ($5 million)

3. A schedule of the annual amounts remaining to None be collected

4. Assumptions used in determining rates of Escalation rate: 3%

escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of Rate of earnings: n/a other factors used in funding projections

5. Any contracts upon which the licensee is relying None pursuant to 10 CFR 50.75(e)(1)(v)

6. Modifications occurring to a licensee's current None method of providing financial assurance since the last submitted report

7. Any material changes to trust agreements None Note 1: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 17, 2018 (Accession No. ML18351A478), escalated at 3% per annum to account for inflation.

Enclosure 8 CNRO2021-00004 ENOI IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

CNRO2021-00004 Page 1 of 4 ENOI IP1 DTF Balance Based on Decommissioning Funding Assurance Plan For Year Ending December 31, 2020 - 10 CFR 50.75(f)(1)

On October 23, 2008, Entergy Nuclear Indian Point 2, LLC (ENIP2) submitted a preliminary decommissioning cost analysis to the NRC in conjunction with its spent fuel management plan under 10 CFR 50.75(f)(3) and 10 CFR 50.54(bb) (Accession No. ML083040378, as supplemented by ENIP2's reply to RAIs on July 15, 2009 (Accession No. ML092050204)). The preliminary decommissioning cost analysis contained separate site-specific decommissioning cost estimates for Indian Point 1 and Indian Point 2. The estimates were subsequently found to be reasonable by the NRC on March 17, 2010 (Accession No. ML100280544).

Pursuant to Regulatory Guide 1.159, Revision 2, adjustment to the site-specific cost estimates should be made at least once a year for the effects of inflation. Adjustment to site-specific cost estimates for the effects of technological and status changes should be made according to the amount of change experienced, as appropriate, but in no event, less than once every 5 years.

As such, ENIP2 has updated the aforementioned estimates consistent with the requirements of Regulatory Guide 1.159, Revision 2.

ENIP2 has determined that use of a SAFSTOR analysis shows that there is presently reasonable assurance that adequate funds will be available for the decommissioning process in compliance with NRC decommissioning funding assurance rules.

Pursuant to 10 CFR 50.75(e)(1)(i), "A licensee that has prepaid funds based on a site-specific estimate under § 50.75(b)(1) of this section may take credit for projected earnings on the prepaid decommissioning trust funds, using up to a 2 percent annual real rate of return from the time of future funds' collection through the projected decommissioning period, provided that the site-specific estimate is based on a period of safe storage that is specifically described in the estimate." ENIP2 understands that a facility-specific analysis may be used for demonstrating the adequacy of decommissioning funds, provided that "the NRC-required cost estimate for decommissioning costs as defined in 10 CFR 50.2 is equal to or greater than the amount stated in the formulas in 10 CFR 50.75(c)(1) and (2) as the basis for justifying a higher than minimum funding level." (Regulatory Guide 1.159 Rev. 2, Section 1.1.1) ENIP2 also understands that NRC should be provided the analysis, and that the analysis should include data for each year of the analysis.

The updated Indian Point 1 site-specific decommissioning cost estimate is based on a period of safe storage that is specifically described in the estimate, namely storage until 2073, at which time the plant decommissioning will be completed, and the site released for alternative use without restriction. Table 8-1 below provides the annual license termination costs computed in the updated estimate. These costs to date have been funded by operations, and not by the decommissioning fund. The decommissioning trust fund (DTF) ending balance is escalated each year by the 2% real growth figure allowed pursuant to 10 CFR 50.75(e)(1)(i).

CNRO2021-00004 Page 2 of 4 Table 8-1 NRC License Termination Cost

($ millions) 2020 $

Ending DTF Unit 1 Balance Radiological 2021 1.065 642.809 2022 4.259 651.405 2023 4.259 660.174 2024 4.271 669.106 2025 4.259 678.229 2026 4.259 687.534 2027 4.259 697.025 2028 4.271 706.695 2029 4.259 716.569 2030 4.259 726.641 2031 4.259 736.914 2032 4.271 747.381 2033 4.259 758.070 2034 4.259 768.971 2035 4.259 780.091 2036 4.271 791.422 2037 4.259 802.991 2038 4.259 814.791 2039 4.259 826.828 2040 4.271 839.093 2041 4.259 851.616 2042 4.259 864.388 2043 4.259 877.417 2044 4.271 890.694 2045 4.259 904.248 2046 4.259 918.074 2047 4.259 932.176 2048 4.271 946.548 2049 4.259 961.220 2050 4.259 976.185 2051 4.259 991.449 2052 4.271 1,007.007 2053 4.259 1,022.887 2054 4.259 1,039.086 2055 4.259 1,055.608 2056 4.271 1,072.449

CNRO2021-00004 Page 3 of 4 Table 8-1 NRC License Termination Cost

($ millions) 2020 $

Ending DTF Unit 1 Balance Radiological 2057 4.259 1,089.638 2058 4.259 1,107.172 2059 4.259 1,125.056 2060 4.271 1,143.286 2061 4.259 1,161.892 2062 4.259 1,180.870 2063 4.259 1,200.228 2064 4.271 1,219.962 2065 31.333 1,213.028 2066 68.725 1,168.564 2067 115.792 1,076.143 2068 124.361 973.305 2069 17.988 974.783 2070 18.194 976.085 2071 18.194 977.412 2072 18.244 978.716 2073 8.973 989.318 Total 606.154

CNRO2021-00004 Page 4 of 4 As can be seen from the information provided in Table 8-1, the required funding for SAFSTOR decommissioning, $606.15 million, is greater than the NRC formula amount per 10 CFR 50.75(b) and (c) of $438.88 million, therefore, the site-specific analysis complies with the requirement from Regulatory Guide 1.159 section 1.1.1 previously discussed. The foregoing SAFSTOR analysis shows that when the December 31, 2020 DTF balance is escalated at the allowable rate and compared against the annual figures for the SAFSTOR period, that an approximately $989 million surplus exists at the end of the decommissioning project. The present value of this surplus is approximately $346 million in 2020 dollars ($989 million/(1.02)(2073-2020)). This surplus is sufficient to cover the spent fuel management costs for Indian Point 1 as reflected in Reference 1, Enclosure 1, of approximately $56 million, as well as ISFSI decommissioning costs shown in Enclosure 1 from this filing, if not paid for by spent fuel litigation proceeds. Accordingly, ENIP2 concludes that no further action is required at this time to demonstrate adequate funding assurance for decommissioning Indian Point 1.

Reference 1: Letter, Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2020 - 10 CFR 50.82(a)(8)(vii), CNRO2021-00007, filed March 25, 2021.

Enclosure 9 CNRO2021-00004 ENOI Minimum Financial Assurance Calculation Worksheets

CNRO2021-00004 Page 1 of 4 ENOI Minimum Financial Assurance Calculation Worksheets Plant name: Indian Point Energy Center, Unit 1 Month Day Year Year of Biennial: 12 31 2020 Termi nation of Operation : 9 28 2013 MWth 1986$ ECI Base L.x Lx Px Fx Ex Bx PWR 615 $85,560,000 144.0 2.16 0.65 3. 11 2.038 2.559 0.13 2.26 0.22 12.793 NRC Mi nimum: $438,884,739 Site Specific: $606,154,000 From Table 8-1 Licensee :  % Owned: I Amount of NRC Minimum/ Site Specific: I Amount in Trust Fund :

Entergy 100.00% I $ 606, 154 ,ooo I $631,248.474 Note: See Enclosure 8 for adequacy of the trust fund.

CNRO2021-00004 Page 2 of 4 ENOI Minimum Financial Assurance Calculation Worksheets Plant Name: Indian Point Entergy Center, Unit 2 Month Day Year Year of Biennial: 12 31 2020 Termi nation of Operation : 4 30 2020 MWth 1986$ ECI Base Lx Lx Px Fx Ex Bx PW R 3216 $103 ,300 ,800 144.0 2.16 0.65 3.11 2.038 2.559 0.13 2.26 0.22 12.793 NRC Mi nimum: $529,887,151 Site Specific:

Licensee:  % Owned : Amount of NRC Minimum/ Site Specific: Amount in Trust Fund :

Entergy 100.00% $529,887,151 $793 ,729,179 Step 1:

Earn ings Credit:

Real Rate of I Y ears Left in I Total Real Trust Fund Balan ce: I Ret urn per y earl Li cense Rate of Total Earn inos:

$793,729,179 I 2% I o.oo 1.00000 $793,729,179 Total Earnings = T rust Fund balance x (1+RRR)"Years left in lkense Step 2:

Accumulation:

Real Rate of V alue of A nnu ity per y earl Return per y ear Y ears of Annu ity : Total Annuity :

$0 I 2% 0 $0 Step 3:

Decom Period:

Total Earn inos :

Real Rate of Return per y ear I De com Period:

Total Real Rate of I Total Earninos for De com:

$793,729,179 2% I 7 0.14869 I $59 ,008 ,076 !Total Earnings for Decom = (1 /2) x Tota l Earn ings x [(1+RRR)"Decom period - 1]

Total of Steps 1 - 3:

$852,737 ,256 Total= Total Earn ings+ Total Earnings for Decom Excess ( Shortfall) $ 322,850,105 to NRC minimum

$ (8,970,794) Less I SFSI

$ - Parent Co Guaranty

$ 313,879,31 1 Total Ex cess Financial Assurance

CNRO2021-00004 Page 3 of 4 ENOI Minimum Financial Assurance Calculation Worksheets Plant name: Indian Point Energy Ce nter, Unit 3 Month Day Year Year of Biennial: 12 31 2020 Termination of Operation : 4 30 2021 MWth 1986$ ECI Base Lx Lx Px Fx Ex Bx PW R 3216 $103,300 ,800 144_0 2_16 0_65 3_11 2_038 2_559 0_13 2-26 0-22 12-793 NRC Minimum: $529,887,151 Site Specific:

Licensee:  % Owned : Amount of NRC Minimum/ Site Specific: Amount in Trust Fund :

Entergy 100 _00% $529,88 7,151 $990,708 ,315 Step 1:

Earnings Credit:

Real Rate of I Y ears Left in I Total Real Trust Fund Balance: I Retu rn per yearl Li cense Rate of Total Earnin Qs :

$990 ,708,315 I 2% I 0_33 1-00657 $997 ,215,384 Tota l Earnings= Trust Fund balance x (1+RRR)"Years left in license Step 2:

Accumu lation :

Real Rat e of V alue of A nnuity per y earl Ret urn per y ear Y ears of A nnuity : Total A nnuity :

$0 I 2% o $0 Step 3:

Decom Period :

Total Eam inQs:

Real Rat e of Ret urn per y ear I Dec om Period :

Total Real Rate of I Total Earnin Qs for Decom:

$997,215,384 2% I 7 0_148 69 I $74,135,818 ITota l Earnings for Decom = (1 /2) x Total Earnings x 1(1 +RRR)"Decom period - 1]

Tota.I of Ste ps 1 - 3:

$1 ,071 ,351 ,201 Tota l = Tota l Earnings+ Total Earn ings for Decom Excess (Shortfall) $ 541,464,051 to NRC minimum

$ (10,764,952) Less ISF SI

$ - Parent Co Guarantv

$ 530,699,098 Total Ex cess Financial Assurance

CNRO2021-00004 Page 4 of 4 ENOI Minimum Financial Assurance Calculation Worksheets Plant name: Palisades Nuclear Plant Month Day Year Year of Biennial: 12 31 2020 Termination of Operation: 5 31 2022 MWth 1986$ ECI Base Lx Lx Px Fx Ex Bx PW R 2565 $97,572,000 139_1 2_08 0_65 2_89 2_038 2_559 o_13 2_26 0-22 12-793 NRC Minimum: $486,730,814 Site Specific:

Licensee:  % Owned: Amount of NRC Minimum/ Site Specific: Amount in Trust Fund:

Entergy 100_00 % $486,730 ,814 $553,835,941 Step 1:

Earnings Credit:

Real Rat e of ! Y ears Left inl Tot al Real Trust Fun d Bal ance: IReturn pe r y earl Lice nse Rat e of Tot al Eam inqs:

$553,835,94 1 I 2% I 1-42 1-02845 $569,593,090 Total Earnings= Trust Fund balance x (1+RRR)"Years left in license Step 2:

Accumu lation :

Real Rat e of V alue of A nnu ity per y earl Return per y ear Ye ars of A nnuity : Tot al A nnu ity :

$0 I 2% 0 $0 Step 3:

Decom Period :

Tot al Earn inq,s:

Real Rat e of Ret urn per y ear I De com Period:

Total Real Rate of Total Eam inqs for Dec om:

$569,593,090 2% I 7 0_14869 $42,345,164 !Tota l Earnings for Decom = (1 /2) x Tota l Earnings x [(1+RRR)"Decom period - 1)

Total of St eps 1 - 3:

$611 ,938,255 Tota l = Tota l Earnings+ Total Earni n gs for Decom Excess ,( Shortfall) $ 125,207 ,441 to NRC minimum

$ 18,482,956) Less ISFSI

$ Parent Co Guara nty

$ 116,724,484 Tota l Excess Fin a nci a l Assu ra n ce