ML22087A500

And Palisades Nuclear Power Plant - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) -- Entergy Nuclear Operations, Inc

ML22087A500
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	03/28/2022
From:	Couture P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNRO2022-00002
Download: ML22087A500 (11)

Text

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102

CNRO2022-00002 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)(v)

March 28, 2022

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 Palisades Nuclear Power Plant NRC Docket No. 50-155 NRC Docket No. 50-255 License No. DPR-6 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 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 3 for the licensed facilities addressed by this filing, were prepared in accordance with NUREG-1307 (Reference 1) and NRC Regulatory Iss ue 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 4 for the convenience of the reviewer.

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

The trust fund amount reported for Palisades in the response to item 3 represents the market value of decommissioning trust funds as of December 31, 2021 net of any material current income tax liability on realized gains, interest, dividends and other income of the trusts. The

Entergy Nuclear Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2022-00002 Page 2 of 3

trusts for the following plant had estimated balances on its 2021 tax liabilities (already deducted from the trust fund balances shown below), as follows (in thousands):

Palisades $ 550

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 and 3 includes line item 2 identifying the ISFSI decommissioning obligation, from the most recent 10 CFR 72.30 filing. This obligation is also accounted for in the Excess/Shortfall calculations for Palisades in Enclosure 4.

The aforementioned worksheets, using the December 31, 2021 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 lic ensees 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,

Phil Couture

PC/ljs/chm

CNRO2022-00002 Page 3 of 3

Enclosures:

1) ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

2) ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

3) ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

4) ENOI Minimum Financial Assurance Calculation Worksheet

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," Dated January 8, 2009

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

cc: NRC Region III Regional Administrator NRC Project Manager, Palisades NRC Sr. Resident Inspector, Palisades

State of Michigan

Enclosure 1

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ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

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ENOI Status of Decommissioning Funding - Palisades For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

Plant Name: Palisades Nuclear Plant

1. Minimum Financial Assurance (MFA) $503.75 million [Note 1]

estimated per 10 CFR 50.75(b) and (c) (2021$)

2. ISFSI Obligation as of 12/31/21 $8.85 million [Note 2]

3. Decommissioning Trust Fund Total $576.26 million as of 12/31/21

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 4

Note 2: From Entergys Decommissioning Funding Plans (10 CFR 72.30) dated December 15, 2021 (Accession No. ML21349A374).

Enclosure 2

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ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

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ENOI Calculation of Minimum Amount - Palisades For Year Ending December 31, 2021 - 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) 3.031 E=Energy (PWR) 2.932 B=Waste Burial-Vendor (PWR) 12.793 3

PWR Escalation Factor:

0.65(L) + 0.13(E) + 0.22(B) = 5.1628

1986 PWR Base Year $ Escalated:

$97,572,000

• Factor = $503,746,250

(Note - Numbers may not sum due to rounding)

1 Bureau of Labor Statistics, Series Report ID: CIU2010000000230i (4th Quarter 2021) 2 Bureau of Labor Statistics, Series Report ID: wpu0543 and wpu0573 (December 2021) (Preliminary) 3 Nuclear Regulatory Commission: NUREG-1307 Revision 18, Table 2-1 (2021)

Enclosure 3

CNRO2022-00002

ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

CNRO2022-00002 Page 1 of 1

ENOI Status of Decommissioning Funding - Big Rock Point For Year Ending December 31, 2021 - 10 CFR 50.75(f)(1)

Plant Name: Big Rock Point ISFSl

1. Amount of decommissioning funds required from $2.79 million Note 1 most recent estimate (2021$).

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: n/a 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 15, 2021 (Accession No. ML21349A374).

Enclosure 4

CNRO2022-00002

ENOI Minimum Financial Assurance Calculation Worksheet