Entergy requested in November 2024 that the NRC exempt it from certain regulations, allowing the company to use funds from the Unit 1 DTF to dispose of two steam generators and one reactor vessel closure head (RVCH) that were removed from service in 2005, and to use funds from the Unit 2 DTF to dispose of two steam generators that were removed from service in 2000.
As published in the July 10 Federal Register, the NRC issued an environmental assessment and finding of no significant impact on the proposed exemptions, determining that the actions would not have any environmental or radiological impacts.
Background: While DTFs are generally intended for activities after a plant permanently ceases operations, the NRC does allow the use of these funds for the prompt disposal of MRCs while a facility is still operational through exemptions to its regulations in 10 CFR 50.82.
In August 2024, the NRC issued the interim staff guidance Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal (REFS-ISG-2024-01), which provides the NRC staff’s regulatory position regarding the use a reactor’s DTF for the disposal of MRCs while the plant is still operational.
According to the guidance document, an exemption may be granted if the NRC determines that the DTF contains funds in excess of the total estimated cost of completing all required radiological decommissioning of the reactor. The NRC allows the licensee to use economic projections for future years in calculating the amount of excess funds in the DTF.
Entergy’s argument: In seeking the exemptions, Entergy said that the limited long-term on-site storage space at ANO makes it practical to dispose of the retired components now instead of waiting until plant closure. The retired MRCs currently are stored in a mausoleum at the ANO site in Russellville, Ark. Entergy, however, is planning on replacing Unit 2’s RVCH during a refueling scheduled for the spring of 2026, and, according to the company, there currently is not enough room in the mausoleum to store all the components.
In addition, Entergy claims that the disposal of the MRCs would be considered a legitimate decommissioning activity for which DTF funds may be used once ANO ceases operations, and as such, there is no controversy over whether the funds can be used to dispose of the components. “Rather, it is merely a matter of timing of when those funds may be used,” the company stated in its request.
Entergy estimates it will cost $28 million to dispose of the four steam generators and one RVCH from Units 1 and 2. As of June 2024, ANO had a DTF balance of approximately $834 million for Unit 1 and approximately $689 million for Unit 2.
The company projects that the Unit 1 and Unit 2 DTFs will have surpluses of approximately $612 million and $294 million, respectively, when the reactor licenses expire in 2034 and 2038. This includes the proposed withdrawals from the funds for disposing of the MRCs. Entergy notes that those margins would increase should ANO renew its operating licenses.
