LIC-11-0050, Response to NRC Request for Additional Information Regarding 2011 Biennial Decommissioning Funding Status Report

Response to NRC Request for Additional Information Regarding 2011 Biennial Decommissioning Funding Status Report

ML11136A265
Person / Time
Site:	Fort Calhoun
Issue date:	05/13/2011
From:	Goodell J Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-11-0050, TAC ME5485
Download: ML11136A265 (90)

Text

m mm Omaha PublicPowerDistdct 444 South 16th Street Mall Omaha, NE 68102-2247 May 13, 2011 LIC-1 1-0050 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

1. Docket No. 50-285

2. Letter from OPPD (S. E. Baughn) to NRC (Document Control Desk),

"Fort Calhoun Station, Unit No.1, 2011 Biennial Decommissioning Funding Status Report," dated March 16, 2011 (LIC-11-0028)

(ML110750572)

3. Email from NRC (L. Wilkins) to OPPD (B. R. Hansher), "DRAFT RAIs for Fort Calhoun Station Re: 2011 Decommissioning Funding Status Report (ME5485)," dated April 4, 2011 (NRC-11-0039)

(ML110940487)

SUBJECT:

Response to NRC Request for Additional Information (RAI)

Regarding 2011 Biennial Decommissioning Funding Status Report In Reference 2, the Omaha Public Power District (OPPD) submitted the Fort Calhoun Station, Unit No. 1, Biennial Decommissioning Funding Status Report for 2011. In Reference 3, the NRC requested additional information regarding the Reference 2 submittal; the OPPD response is attached.

A teleconference between the NRC and OPPD was held on April 14, 2011, to review the questions and as a result, the allotted response time (30 days) was adjusted accordingly.

No commitments to the NRC are contained in this submittal.

ADM Wýk Employment with Equal Opportunit.

U. S. Nuclear Regulatory Commission LIC-1 1-0050 Page 2 If you have any questions regarding this submittal, please contact Mr. Bill Hansher at (402) 533-6894.

Sincerely, Di ision Manager-Nuclear Performance Improvement & Support JRG/KRD/mle

Attachment:

OPPD Response to NRC Request for Additional Information

Enclosures:

1. 2011 Biennial Decommissioning Funding Status Report (Revised)

2. 2008 Site-Specific Decommissioning Cost Study

3. Escalation of Site-Specific Cost Estimate - Dismantlement Period

4. Fort Calhoun Station Unit No.1 Decommissioning Fund Trust Agreement

5. 1992 Supplemental Plan Trust Agreement

6. Board Resolutions Approving Trust Agreements

7. OPPD 2011 Corporate Operating Plan O&M Expense Information

8. Board Resolution Approving the Corporate Operating Plan

9. 2010 Global Insight Forecast Rates c: E. E. Collins, Jr., NRC Regional Administrator, Region IV (w/o Enclosures)

L. E. Wilkins, NRC Project Manager (w/o Enclosures)

J. C. Kirkland, NRC Senior Resident Inspector (w/o Enclosures)

LIC-1 1-0050 Attachment Page 1 OPPD Response to NRC Request for Additional Information

LIC-1 1-0050 Attachment Page 2 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR FORT CALHOUN STATION, UNIT 1 The requests for additional information (RAIs) provided are in response to the Omaha Public Power District (OPPD) 2011 Decommissioning Funding Status (DFS) report. On March 16, 2011, OPPD submitted to the Nuclear Regulatory Commission (NRC) the 2011 DFS report for the Fort Calhoun Station, Unit 1, as required under Title 10 of the Code of Federal Regulations (10 CFR) Part 50.75(f)(1). OPPD should provide a response to all RAIs within 30 days from the date of this letter.

RAI #1: Current Decommissioning Cost Estimate Please provide an explanation as to the differences between OPPD's calculation and the NRC staffs calculation of the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) and, if necessary, a corrected submittal for that part of the DFS report. In OPPD's submission, the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) differs from the amount calculated by the NRC staff. For determining the Labor Index (Lx), OPPD should follow the formula provided on page 8 of NUREG-1307, Rev. 14. According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be "the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c)".

OPPD Response In the previous report, the Labor Index (Lx) was determined using a "rebased" index for 1986, which provided a slightly lower factor than the NUREG-1307 Rev. 14 table. The 2011 Biennial Decommissioning Funding Status Report was revised using the formula provided on page 8 of NUREG-1307, Rev. 14 (Enclosure 1). Revision bars in the right margin denote the location of revised text.

RAI # 2: Current Decommissioning Cost Estimate Please provide the dismantlement period for the site-specific cost estimate. If the site-specific cost estimate is for a longer period of time (e.g. SAFSTOR), then the licensee must provide all expenses for the decommissioning period. Within the DFS report, OPPD provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required. Pursuant to 10 CFR 50.75(e)(1)(ii), unless provided otherwise, the NRC staff assumes the site-specific cost estimate is for an immediate dismantlement decommissioning period.

LIC-1 1-0050 Attachment Page 3 Also, the NRC staff requests that the licensee provide the site-specific cost estimate to the NRC. The NRC requires an annual schedule of expenses for radiological decommissioning, including the costs to maintain the facility in a safe condition, in order to evaluate the amount of earnings credit available during the decommissioning period.

Finally, while providing the site-specific cost estimate in relation to the costs, OPPD did not state the current year dollars for the estimate. Therefore, OPPD should provide the site-specific cost estimate in current year dollars. If the site-specific cost estimate is from a year previous to 2010, then OPPD should escalate the site-specific cost estimate to 2010 and should provide the cost escalation factor(s) used to escalate the site-specific cost estimate.

OPPD Response A copy of the 2008 site-specific decommissioning cost study (in 2007 dollars) for the Fort Calhoun Station prepared by TLG Services, Inc. is enclosed (Enclosure 2).

The Renewed Facility Operating License for Fort Calhoun Station expires August 9, 2033. The dismantlement period for the site-specific cost estimate begins in 2033 and lasts through 2041 with a final charge for license termination in 2058. Table 3.2 of the enclosed TLG study details the annual schedule of costs for the years 2033 - 2041 and 2058 in 2007 dollars and Enclosure 3 details the annual costs for those years in 2010 dollars.

The formula used to escalate site-specific cost estimate to 2010 is 84.4% labor, 2.4%

energy, 11.2% waste burial and 2.0% other as provided to the District by TLG in Table D-3 of Enclosure 2. The index for each component is escalated from 2007 to 2010 leading to the following formula:

.844(0.05698) + .024(1.013) + .112(0.24392) + .02(0.04351) = .10059 The indices used are as follows:

Labor - CIU20100000002301 (B), Total compensation, private industry, Midwest Energy - WPU0543, Fuels & related products & power, industrial electric power WPU0573, Fuels & related products & power, light fuel oils Burial - from NUREG-1 307 Rev. 14 Table 2.1 Values for Generic LLW Disposal Site for PWR Other - CUUROOOOSAO, U.S. city average, all items Applying this formula with rounding to the annual costs in Table 3.2 of Enclosure 2 leads to the results provided in Enclosure 3.

LIC-1 1-0050 Attachment Page 4 RAI #3: Current Decommissioning Fund Balance Please provide the trust agreements for both trust accounts: the NRC minimum decommissioning amount outlined in 10 CFR 50.75(c) and the one for other costs.

Please provide an explanation as to how the trust account for other costs is managed (e.g. external sinking fund). Specifically, whether the trust fund for other costs is intended to provide an assurance method pursuant to 10 CFR 50.75(e)(1). Also, please provide the information that allows funds accumulated in the trust account for other costs to be available for radiological decommissioning without prior approval by a State regulatory authority and are not subject to disapproval for radiological decommissioning by a State regulatory authority.

Within the OPPD's 2011 DFS report, OPPD states that it:

maintains two separate trust accounts, one for the NRC minimum decommissioning amount outlined in 10 CFR 50.75(c) and one for other costs including additional radiological, site restoration and spent fuel management as determined by the cost study. [... ] The two trust funds are not commingled. The funds accumulated for the additional decommissioning costs including additional radiological, site restoration and spent fuel management are available for radiological decommissioning without prior approval by a State regulatory authority and are not subject to disapproval for radiological decommissioning by a State regulatory authority.

Pursuant to 10 CFR 50.75(e)(1), financial assurance is to be provided by the methods listed under 10 CFR 50.75(e)(1).

OPPD Response Copies of the Omaha Public Power District, Fort Calhoun Station, Unit No. 1, Decommissioning Fund trust agreement (Enclosure 4) and the 1992 Supplemental Plan trust agreement (Enclosure 5), used for other costs are enclosed. The Board Resolutions (Enclosure 6) approving the trust agreements are also enclosed. Both trust funds have been established as external sinking funds. TLG Engineering estimates that OPPD will incur additional costs beyond those described in the Decommissioning Fund trust agreement to decommission the radiological and non-radiological areas at Fort Calhoun Station, Unit No.l.

As such, although the Decommissioning Fund trust agreement alone meets NRC regulations for financial assurance, the 1992 Supplemental Plan trust agreement was developed to ensure that funds are available to cover the additional costs identified by TLG Engineering.

Section 5 of the 1992 Supplemental Plan trust agreement states that the District can make withdrawals for radiological decommissioning or other decommissioning needs as determined solely by the Omaha Public Power District. As such, a State regulatory

LIC-1 1-0050 Attachment Page 5 authority is not required to approve nor can it disapprove the use of these funds for decommissioning Fort Calhoun Station, Unit No. 1.

To clarify this matter within the report itself, a statement was added to Section B of the 2011 Biennial Decommissioning Funding Status Report indicating that the funds of the 1992 Supplemental Plan are not included as funds for the NRC minimum decommissioning amount.

RAI #4: Rates Used to Escalate Decommissioning Cost and Fund Balances Please provide the State regulatory authority that allows OPPD's Board of Directors to determine the inflations rates and the earnings rates of OPPD. Also, the NRC requests the OPPD Board of Directors determination that allows for the assumption of the stated rates. Within the DFS report, OPPD states that OPPD is allowed to assume rates used regarding the rate of escalation in decommissioning costs, rates of earnings on decommissioning funds and rates of other actors used in funding projections. OPPD also states that the rates are provided by OPPD's Board of Directors. According to 10 CFR 50.75(f)(1):

the information in [the DFS] report must include [...] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections...

Enclosure C of your March 16, 2011, submittal provides a variable inflation rate and earnings rate with the annual collection next to it. Please confirm that the earnings rates are allowed by a regulatory authority over OPPD for both the annual collections as well as the decommissioning trust fund.

OPPD Response Nebraska State Statutes provide the regulatory authority that allows OPPD's Board of Directors to establish the inflation rates and earning rates of OPPD. The District's Corporate Operating Plan indicates that Global Insight is the source for the inflation rates and earnings rates used in decommissioning funding projections. OPPD's Board of Directors approved the District's Corporate Operating Plan.

Following are the links to the Nebraska State Statutes establishing OPPD's Board power and authority to set reasonable rates:

http://uniweb.legislature.ne.gov/laws/statutes.php?statute=70-655 http://uniweb.legislature.ne.gov/laws/statutes.php?statute=70-61 9 A copy of the OPPD 2011 Corporate Operating Plan - Operation & Maintenance Expense information (Enclosure 7), which includes the statement regarding inflation and

LIC-1 1-0050 Attachment Page 6 earnings rates used for the decommissioning cost and fund balances and a copy of the Board Resolution (Enclosure 8) approving the Corporate Operating Plan is enclosed.

A copy of the 2010 Global Insight Forecast Rates (Enclosure 9) is enclosed.

LIC-1 1-0050 Page 1 2011 Biennial Decommissioning Funding Status Report (Revised)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. I 2011 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT REVISED as of May 9, 2011 Based on Nuclear Regulatory Commission (NRC)

Regulation 10 CFR 50.75 (f)

The NRC requires that Omaha Public Power District (OPPD) report by March 31, 2011 and at least once every two years thereafter on the status of its decommissioning funding for Fort Calhoun Station Unit No. 1. Based on the decommissioning funding requirement as outlined in 10 CFR 50.75 (f), OPPD reports the following information:

A. Current Decommissioning Cost Estimate Pursuant to 10 CFR 50.75 (c), the January 2011 estimated NRC minimum decommissioning amount to decommission Fort Calhoun Station Unit No. I is

$396,948,000. See Attachment A for detailed decommissioning cost calculation and Attachment B for the applicable indices.

In addition to the minimum NRC decommissioning amount calculation, OPPD employs a consultant to complete a decommissioning cost update every five years. Based on the escalation of the consultant's most recent study, the total estimated cost to decommission Fort Calhoun Station Unit No. 1 is $717,593,000 in 2010 dollars. Of that total costI estimate, the current site-specific cost estimate for radiological decommissioning of Fort Calhoun Station Unit No. 1 is $477,199,000, the current separate estimate of site restoration (State costs) is $31,574,000 and the current separate estimate of spent fuel management costs is $208,820,000.

The total cost estimate was reported as $809,200,000 in the 2009 Biennial Decommissioning Funding Status report. The total cost estimate should have been reported as $687,484,000. The overstatement was a result of misapplied indices.

B. Current Decommissionina Fund Balance The total OPPD Decommissioning Fund balance as of December 31, 2010 was

$321,188,300. OPPD maintains two separate trust accounts, one for the NRC minimum decommissioning amount as outlined in 10 CFR 50.75 (c) and one for other costs including additional radiological, site restoration and spent fuel management as determined by the cost study. As of December 31, 2010, the balance in the fund for the NRC minimum decommissioning amount was $246,125,500. As of December 31, 2010, the balance in the funds accumulated for other decommissioning costs was $75,062,800. This balance is allocated as follows: $18,765,700 for additional radiological costs, $7,506,300 for siteI restoration costs and $48,790,800 for spent fuel management costs.

Omaha Public Power District 2011 Biennial Decommissioning Funding Status Report to NRC Page Two The two trust funds are not commingled and the funds accumulated for the additional decommissioning cost are not included as funds for the NRC minimum decommissioning amount. The funds accumulated for the additional decommissioning costs including additional radiological, site restoration and spent fuel management are available for radiological decommissioning without prior approval by a State regulatory authority and are not subject to disapproval for radiological decommissioning by a State regulatory authority.

C. Annual Decommissioning Collections There was no annual collection for 2009 or 2010 as shown in Attachment C. The revenue source for any collections is "cost-of-service" electric rates.

D. Rates Used to Escalate Decommissioning Costs and Fund Balances The rates used for the escalation of the decommissioning cost estimate and earnings rates on the Decommissioning Fund are shown in Attachment B. Global Insight, Inc. of Waltham, Massachusetts provides the decommissioning cost estimate inflation and earnings rates forecasts. OPPD's Board of Directors approved both the inflation rates and eamings rates in December 2010 as part of OPPD's Corporate Operating Plan.

E. Contracts to Help Fund Decommissioning OPPD does not have any contracts pursuant to 10 CFR 50.75 (e)(1)(ii)(C) and is not relying on contracts with a "non-bypassable charge" to fund decommissioning.

F. Modifications to Method of Providing Financial Assurance There have been no modifications to OPPD's method of providing financial assurance since the decommissioning funding plan began in 1982 and continued pursuant to NRC Regulations in 1990.

G. Changes in the Decommissioning Funding Plan Trust Agreement There have been no changes to OPPD's Decommissioning Funding Plan Trust Agreement since the Plan began pursuant to NRC Regulations in 1990.

Dated: //

J/.Thurber Division Manager - Finance

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2011 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT A 2011 Escalation of the Minimum Decommissioning Amount (MDA) Estimate for Fort Calhoun Station Unit No. I Based on Nuclear Regulatory Commission (NRC) Formulas and Application to OPPD The NRC accepted OPPD's Decommissioning Funding Plan in 1990. As part of the Decommissioning Funding Plan, OPPD annually calculates the MDA as follows:

NRC Formula for MDA

$75 million + $8800(P) = MDA for a Pressurized Water Reactor (PWR) Plant where: P = MWt reactor rating Fort Calhoun = 1500 MDA expressed in 1986 Dollars (to be escalated)

Escalation of NRC Formula for MDA Estimated Decommissioning Cost in Year XX = MDA X (.65L + .1 3E + .22B)

Where: "L" is the Labor factor. The Labor factor is to be obtained from "Monthly Labor Review", published by the U. S. Department of Labor - Bureau of Labor Statistics. Specifically, the appropriate regional data from the table entitled "Employment Cost Index - Private Nonfarm Workers", subtitled "Compensation" is to be used. In OPPD's case, data from the Midwest Region is to be used.

"E" is the Enermy factor. The Energy factor is to be obtained from the following two component formula specifically weighted for PWR plants:

.58P + .42F = E (Energy Factor) where: "P" is the component for electric power, and "F" is the component for fuel oil Both "P" and "F" can be found in "Producer Price Indices", published by the U. S. Department of Labor - Bureau of Labor Statistics. "P" is to be obtained from the Industrial Electric Power Index and "F" is to be obtained from the Light Fuel Oils Index.

Attachment A Page Two "B" is the Waste Burial factor. The Waste Burial factor is to be obtained from NRC report NUREG-1307, "Report on Waste Burial Charges" or its updates.

OPPD's MDA and Escalation MDA = $75 million + $8800(P) (where P = 1500 MWt)

$75 million + $8800(1500)

$75 million + $13.2 million = $88.2 million (1986 Dollars)

OPPD Escalation of MDA = $88.2 million X (.65L + .13E + .22B)

Where "I", "E", and "B" =

"L" = Labor Index Chan-e Employment Cost Index - PrivateNonfarm Workers - Compensation Midwest Region (Quarterly Basis Increase) 12-2010 111.3/100 12-2005 x 2.08 (Re-indexed in December 2005) 2.31 (an increase of 131.0%)

"E" = Energy Index Chanae Energy Index Change = (Electric Power Index Change X 58%) +

(Light Fuel Oils Index Change X 42%)

ProducerPriceIndices IndustrialElectric Power 12-2010 191.3 = 67.51% increase change 1-1986 114.2 Light Fuel Oils 12-2010 252.1 = 207.40% increase change 1-1986 82.0 Application of the formula to 12-2010 leads to Energy = ((191.3/114.2)X .58) + ((252.1/82.0) X .42)

Energy = 0.9716 + 1.2912 Energy = 2.26 (an increase of 126.2%)

Attachment A Page Three "B" = Waste Burial Index Chanae NUREG-1307 (Revision 14)

The Waste Burial escalation factor is found in Nuclear Regulation NUREG-1 307 and its updates. OPPD's Biennial Decommissioning Funding Status Report will use the Generic LLW Disposal Site Index in calculating the NRC Minimum Decommissioning Amount.

Generic LLW Disposal Site Index 11-10 12.28 = 12.28 (an increase of 1128.0%)

(Waste Vendor Index) 1-86 1.00 The escalated cost formula is as follows:

Generic LLW Disposal Site Index

$88.2 million x (.65(2.31)+.13(2.26)+.22(12.28)) = $396.948 million In summary, OPPD's Fort Calhoun Station Unit No. 1 NRC Minimum Decommissioning Amount estimate escalated to January 2011 is $396,948,000.

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2011 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT B U. S. Department of Labor Bureau of Labor Stat~stics Employment Cost Index Series ID: CIU20100000002301 (B)

Not seasonally adjusted Compensation: Total compensation Sector: Private industry Periodicity: Index number Industryocc: Midwest Qtr 4 2010 111.3 Producer Price Index - Commodities Series ID: WPU0543 Not seasonally adjusted Group: Fuels & related products

& power Item: Industrial electric power Base Date: 198200 Dec-10 191.3(P)

Series ID: WPU0573 Not seasonally adjusted Group: Fuels & related products

& power Item: Light fuel oils Base Date: 198200 Dec-10 252.1(P)

U.S. NRC - Report on Waste Burial Charges NUREG-1307, Rev. 14 Published: November 2010 Values for Generic LLW Disposal Site Direct Disposal with Vendors - PWR 2010 12.280

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2011 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT C Minimum Decommissioning Amount Decommissioning Fund Annual Collections, Inflation Rates and Earnings Rates Decommissioning Fund Annual Collection Inflation Earnings Year for NRC MDA Rate Rate 2009 $0 2.00% 2.14%

2010 $0 2.20% 2.61%

2011 $0 2.10% 3.44%

2012 $0 1.90% 4.24%

2013 $0 1.90% 4.42%

2014 $0 1.90% 5.26%

2015 $0 2.00% 5.29%

2016 $0 .2.00% 5.29%

2017 $0 1.90% 5.29%

2018 $0 1.90% 5.29%

2019 $0 1.80% 5.29%

2020 $0 1.60% 5.29%

2021 $0 1.60% 5.29%

2022 $0 1.70% 5.29%

2023 $0 1.70% 5.29%

2024 $0 1.80% 5.29%

2025 $0 1.80% 5.29%

2026 $0 1.90% 5.29%

2027 $0 1.90% 5.29%

2028 $0 2.00% 5.29%

2029 $0 1.90% 5.29%

2030 $0 1.90% 5.29%

2031 $0 1.90% 5.29%

2032 $0 1.90% 5.29%

2033 $0 1.90% 5.29%

LIC-1 1-0050 Page 1 2008 Site-Specific Decommissioning Cost Study

Document 002-1588-002, Rev. 0 preparedfor Omaha Public Power District preparedby TLG Services, Inc.

Bridgewater, Connecticut July 2008

FortCalhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page ii of iv APPROVALS Project Manager '/ '?ý ") Date2 William A. Cloutier, Jr. Date Project Engineer Date Technical Manager Date Quality Assurance Manager (acting) J eph .pler Date TLG Services, Inc.

Fort CalhounStation Document 002-1588-002, Rev. 0 DecommissioningCost Update Page iii of iv TABLE OF CONTENTS PAGE DECOMMISSIONING COST STUDY UPDATE ..................................................... 1

1. Decontamination ................................................................................................... 2

2. Rem oval ...................................................................................................................... 2

3. Packaging ................................................................................................................... 2

4. Transportation .................................................................................................... 2

5. Low-Level Radioactive W aste Disposal .............................................................. 2

6. W aste Processing and Recycling ........................................................................... 3 7 Program M anagement .......................................................................................... 3

8. Security ...................................................................................................................... 3

9. Spent Fuel M anagement ...................................................................................... 4

10. Characterization and Licensing Surveys ............................................................ 4

11. Regulatory Fees and Insurance ........................................................................... 4

12. Energy ........................................................................................................................ 5

13. Equipment and M aterial ..................................................................................... 5 14 . Oth er ........................................................................................................................... 5 TABLES 1 Comparison of Cost Elem ents ........................................................................ 6 3.1 Schedule of Annual Expenditures ................................................................... 7 3.2 Schedule of Annual Expenditures, License Termination Cost ..................... 8 3.3 Schedule of Annual Expenditures, Spent Fuel Management Costs ................. 9 3.4 Schedule of Annual Expenditures, Site Restoration Costs .......................... 10 C DECON Decom missioning Cost Estim ate .................................................... 11 D-1 Spent Fuel M anagem ent .............................................................................. 21 D-2 Cost Allocations .............................................................................................. 23 D-3 Escalation Elements ..................................................................................... 24 TLG Services, Inc.

FortCalhoun Station Document 002-1588-002,Rev. 0 DecommissioningCost Update Page iv of iv REVISION LOG No. CRA No. Date Item Revised If Reason for Revision 0 07/28/2008 Original Issue TLG Services, Inc.

Fort Calhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page I of 24 DECOMMISSIONING COST STUDY UPDATE This summary report presents an updated estimate of the cost to promptly decommission the Fort Calhoun Station. The update is based upon an analysis issued in 2003,[11 revised to incorporate major changes in the economic (and limited technical) assumptions of the previous study. Although the previous report was issued in January of 2003, the results were reported in 2001 dollars.

The current cost estimate was developed by updating the economic inputs and spent fuel strategy from the previous decommissioning cost model. The current estimate is reported in 2007 dollars and reflects updated labor costs (both utility and craft), post-9/11 security levels, current material and equipment costs, energy and transportation costs, as well as current costs for low-level radioactive waste processing and controlled disposal.

A comparison table is provided at the end of this section (comparing the major cost elements in the 2001 and 2007 estimates). Updated schedules of expenditures are provided in a format consistent with the 2003 study (labeled as Tables 3.1 through 3.4). A detail cost table (Table C) is included for the 2007 estimate along with the associated tables from Appendix D.

The current estimate was developed using the basic inventory and plant design information from the 2001 or previous cost model. The cost model inputs, estimating assumptions and site-specific considerations were reviewed for the 2007 analysis. The cost model was modified when new information was provided, updated site-specific information was obtained from the client, or experience from recent decommissioning projects justified a change.

Overall, the estimate to decommission Fort Calhoun increased 40% over the six-year period (2001-2007 financial years). As can be seen in Table 1, the increase in the cost is primarily associated with the management of the spent fuel (+$93.3 million),

program management (+$59.9 million), and site security (+$30.2 million). A decrease in low-level radioactive waste management (-$2.8 million) was realized by using a lower-cost disposal site.

The rationale for specific changes in several major cost centers is discussed in more detail within the following narrative. Comparisons are focused on permutations in the technical work scope and modifications to assumptions that have affected the cost of "Decommissioning Cost Analysis for the Fort Calhoun Station," TLG Document 002-1429-002, Rev. 0, January 2003 TLG Services, Inc.

Fort CalhounStation Document 002-1588-002, Rev. 0 DecommissioningCost Update Page2 of 24 decommissioning (inflationary effects are generally ignored for purposes of this analysis).

The overall decommissioning scope of the current cost estimate has not significantly changed from that presented in 2001. While the scope may not have changed, there are differences in the base assumptions between the two studies. These differences are identified in the discussion of the following cost elements.

1. Decontamination The $3.6 million increase in the 2007 estimate is primarily due to labor costs. For example, rates for laborer and craftsmen increased 41% and 46%, respectively, over the six year period.

2. Removal The increase in craft labor rates (see Decontamination) was offset by a decrease in the cost of the asbestos abatement activity. The 2001 study assumed that remediation of the asbestos at Fort Calhoun would cost approximately $28.6 million. On the basis that considerable abatement work would have been done in containment to support the replacement of the steam generators, pressurizer and reactor closure head, the material quantities and associated effort to remove and abate asbestos in the 2007 cost model were reduced.

3. Packaging The $1.8 million increase in the 2007 cost element is primarily a result of higher labor costs and additional components designated for disposal (i.e., retired components).

4. Transportation The general increase in transportation tariffs (due to rising fuel prices) over the six-year period was the primary contributor to the $4.8 million increase in the 2007 transportation cost as well as the additional components generated in the recent change-out programs that were designated for controlled disposal.

5. Low-Level Radioactive Waste Disposal The 2001 cost model assumed that the majority of material requiring controlled disposal would be disposed of at prices comparable to those being charged by the TLG Services, Inc.

FortCalhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page 3 of 24 Barnwell facility. Disposal of the remaining volume was estimated using Envirocare pricing as a proxy.

The 2007 cost model uses the EnergySolutions (Envirocare) pricing for disposal of the majority of the low-level radioactive waste generated from decontamination and dismantling, with the exception of the activated metal from the reactor vessel and the more highly activated resin produced from liquid waste processing. This change in the waste management model produced a $2.8 million reduction in the 2007 cost component for low-level radioactive disposal. The change in the pricing model had the greatest cost impact on the steam generators and other large plant components (even with the addition of the retired pressurizer and reactor closure head to the waste stream).

6. Waste Processing and Recycling A small increase in the unit cost to process and condition waste at a centralized, off-site facility and a change in the assumed density of this waste (lower) contributed to the $3.4 million increase in the 2007 study.

7. Program Management The increase in the cost of program management is primarily due to a corresponding increase in the reported level of compensation for the individuals designated to oversee the decommissioning process. The 2001 cost model relied upon escalated salaries from an earlier study. Current salaries were provided by OPPD for the 2007 estimate.

The 2007 organization is also larger during certain phases, based upon experience at recently decommissioned sites. The spent fuel schedule is also three years longer in 2007, adding to the program management costs.

8. Security Changes in plant security as a result of terrorist acts or threats since 2001 have increased security-related costs. This increase has also been seen at sites that have undergone decommissioning. Consequently, the 2007 decommissioning cost model incorporates a larger security force throughout decommissioning and until the spent fuel is removed from the site. This larger force (and associated increase in compensation level), are the primary factors in the $30 million increase in the 2007 estimate.

TLG Services, Inc.

Fort CalhounStation Document 002-1588-002, Rev. 0 DecommissioningCost Update Page 4 of 24

9. Spent Fuel Management The 2001 and 2007 cost models include the expense to remove the spent fuel from the storage pool, place the assemblies in a multi-purpose canister and load the canister within a DOE-provide transport cask. The major assumptions and schedules of expenditure were provided by OPPD. The appreciable changes are identified below:

Total Major Activities 1 2007 2001 Delta Impact 1't year fuel removed from site 2021 2012 9 Cessation of Operations (year) i 20321 2032 0 ISFSI Operations (last year) 1 2058 2055 3 Decommissioning Fuel Storage Duration (years) _ 26 23 3 DSC or TADs purchased 32 30 2 Overpacks purchased for ISFSI 20 19 1 DSC unit cost I $897,000 $600,000 $297,000 $10,704,000 Overpack unit cost j $249,800 $250,000 -$200 $246,000 1 Loading/Handling unit cost $275,000 $110,000 $165,000 $5,225,000 Operating Costs (annual) $5,040,000 $4,000,000 $1,040,000 Operating Duration (years) 25 17 8] $58,000,000 ISFSI Licensing Fee (annual) $215,800 - $215,800 $3,884,400 Total $78,059,400 Total (w/contingency) $89,768,310 Total Delta in Spent Fuel Management $195,525,000 $102,227,000 $93,298,000

10. Characterization and Licensing Surveys There was essentially no change in the cost associated with this activity over the six-year period as methodology changes (added efficiencies) off-set the increase in labor.

11. Regulatory Fees and Insurance Cost in this category decreased slightly over the six year period. Greater savings were realized in the 2007 insurance model with the application of a shutdown credit. While insurance premiums for the operating unit increased significantly, the credit was the primary contributor to this $0.7 million decrease in the 2007 total cost for this cost category.

TLG Services, Inc.

Fort Calhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page 5 of 24

12. Energy Energy costs increased by $1.7 million commensurate with the higher price of electricity (from $0.031 per kilowatt hour in 2001 to $0.0723 in 2007). The increase was partially offset by a lower usage profile.

13. Equipment and Materials The cost for supplemental equipment and material increased slightly ($503 thousand) over the period.

14. Other Other expenses, including those associated with asbestos and hazardous waste disposition and concrete process, increased $1.8 million over the six year period.

TLG Services, Inc.

FortCalhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page6 of 24 TABLE 1 FORT CALHOUN STATION COMPARISON OF COST ELEMENTS (thousands of dollars)

Cost Elements ($ 2007) ($ 2001) Delta Decontamination 11,442 7,846 3,596 Removal 78,494 90,022 (11,528)

Packaging 11,465 9,620 1,845 Transportation 8,505 3,750 4,755 Low-Level Radioactive Waste Disposal 46,397 49,164 (2,767)

Off-site Waste Processing 29,438 26,058 3,380 Program Management (including engineering) 194,786 134,905 59,881 Security 43,424 13,188 30,236 Spent Fuel Management 195,525 102,227 93,298 Characterization and Licensing Surveys 8,971 8,277 694 Regulatory Fees and Insurance 7,332 8,083 (751)

Energy 7,036 5,329 1,707 Equipment and Material 5,937 5,434 503 Other (including asbestos/hazardous waste 3,255 1,429 1,826 disposition and concrete processing)

Total 652,009 465,332 186,677 TLG Services, Inc.

FortCalhoun Station Document 002-1588.002, Rev. 0 DecommissioningCost Update Page 7 of 24 TABLE 3.1 FORT CALHOUN STATION SCHEDULE OF ANNUAL EXPENDITURES (thousands of 2007 dollars)

Equip & Yearly Year i Labor Materials Eneryv 1. Burial Other I Totals

-!i L herTotal ......

2033 1 17,839 494 483 13 6,747 25,577 2034 48,177 4,855 1,700 3,052 29,310 87,094 2035 46,743 16,621 1,292 27,085 17,201 108,942 2036 + 44,352 10,998 1,043 19,782 14,599.1 90,773 2037 , 42,303 3,900 912 9,042 15,710 71,867 2038 42,303 3,900- 912 9,042 15,710 71,867 2039 27,315 2,815 456 5,130 10,561 46,277 2040 17,574 4,932 175 11 9,861 32,552 2041 9,474 4,171 63 . 0 5,636 19,343 2042 0 0. o 0 5,275 5,275 2043 0 0 0[ 0 5,275 5,275 2044 0 0 01 0 5,289 5,289 2045 0 0 04 0 5,275 5,275 2046 0 0 0 0 5,275; 5,275 2047 0 0 0 0 5, 2 7 5 5,275 2048 0 0 0 0 5,289 5,289 2049 0 0 0 0 5,25,275 2050 1 0 0 0 0 5,275 5,275 2051 0 0 0 0 5,275 5,275 2052 0 0 0 0 5,289 5,289 2053 0 0 0 0 5,275 5,275 2054 1 0 0 0 0 5,275 5,275 2055 0000 5,275 5,275 2056 0 0 0 0 5,289 5,289 2057 0 0 0 0 5,275 5,275 2058 0 303 0 0 12,957 13,260

! 296,080 52,987 7,036 73,157 222,749 652,009 TLG Services, Inc.

FortCalhoun Station Document 002-1588-002, Rev. 0 Decommissioning Cost Update Page8 of 24 TABLE 3.2 FORT CALHOUN STATION SCHEDULE OF ANNUAL EXPENDITURES LICENSE TERMINATION COST (thousands of 2007 dollars)

Equip& I Yearly Year Labor Materials Energy I Burial Other Totals 2033 I 17,700 494 483 13 580 19,270 2034 47,584 4,855 1,700 3,052 12,034 69,225 2035 i 46,130 16,608 1,292 27,085 7,282 98,397 2036 43,346 10,981 1,043 19,782 3,376 78,527 2037_1 40,823 3,880 912 9,042 1,792 56,449 2038 1 40,823 3,880 912 9,042 1,792 56,449 2039 - 27,157 2,813 456. 5,130 4,378 39,933 2040 7,316 388 106 11 4,188 12,009 2041 58 0 01 0 0 58 2042 0 0 0 0 0 0 2043 2044 00 0 0_

00_ 0 000 0 0 2044 0 0 0 0 0 0 20456 0 0 0o 0 0 0 2046 0 0 01 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 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 j0 0 0] 0 0 0 2058 0 303 0 0 2,679 2,982 1 270,935 44,202 6,904 73,157 38,102 433,300 TLG Services, Inc.

FortCalhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page 9 of 24 TABLE 3.3 FORT CALHOUN STATION SCHEDULE OF ANNUAL EXPENDITURES SPENT FUEL MANAGEMENT COSTS (thousands of 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other . Totals 2033 0 0 0 0 6,167, 6,167 2034 0 0 0 0 17,276 17,276 2035 0 0 0 0 9,919 9,919 2036 0 0 0 0 11,222 11,222 2037 0 0 0 0 13,918 13,918 2038 0 0 0 0 13,918 13,918 2039 0 01 0 0 6,183 6,183 2040 2,639 0 21 0 5,668! 8,328 2041 2,422 0 19 0 5,631 8,073 2042 0 0 0 0 5,275 5,275 2043 0 0 0 0 5,275 5,275 2044 0 0 0 0 5,289 5,289 20445 0 0 0 0 5,2 895, 2045 0 0 0 0 5,275 5,275 2046 0 0 0 0 5,275 5,275 2047 0 0 0 0 5,275 5,275 2048 0 0 0 0 5,289 5,289 2049 0 0 0 0 5,275 5,275 2051 0 0 0 0 5,275 5,275 2051 0 0 0 0 5,275 5,275 2052 0 0 0 0 5,289 5,289 2053 0 0 0 0 5,275 5,275 2054 0 0 0 0 5,275 5,275 2055 0 0 0 0 5,275 5,275 2056 0 0 0 0 5,289 5,289 2057 0 0 0 0 5,275 5,275 2058 0 0 0 0 10,278 10,278 5,061 0 40 0 184,639 189,739 TLG Services, Inc.

FortCalhounStation Document 002-1588-002, Rev. 0 DecommissioningCost Update Page 10 of 24 TABLE 3.4 FORT CALHOUN STATION SCHEDULE OF ANNUAL EXPENDITURES SITE RESTORATION COSTS (thousands of 2007 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other I Totals 2033 139 0 0 0 01 139 2034 594 0 01 0 0 594 2035 613 13 0 0 0 626 2036 1,006 17 0 0 0 1,023 2037 1,480 20 0 0 0 1,500 2038 1,480 20 0 0 0 1,500 2039 158 2 0 0 0 160 2040 7,619 4,544 48 0 4 12,216 2041 6,994 4,171 44 0 4 11,213 2042 0 0 0 0 0 0 2043 0 0 OF 0 0o 2044 0 0 01 0 0 0 2045 0 0 0i 0 0 0 2046 0 0 0 0 0 0 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 O 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 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 20,084 8,786 93 0 9 28,971 TLG Services, Inc.

FortCalhoun Station Document 002-1588.002, Rev. 0 Decommissioning Cost Update Page 21 of 24 TABLE D-1 FORT CALHOUN STATION SPENT FUEL MANAGEMENT (thousands of 2007 dollars)

Base Contingency Total Period 1 MPCs and Overpacks, Period la 8,701 8,701 Spent Fuel Loading and Handling, Period la 1 2,206 2,206 ISFSI Operating Costs, Period laf 3,275 - 3,275 Emergency Planning Fees, Period la 450 45 495 Spent Fuel Pool O&M, Period la 738 111 849 MPCs and Overpacks, Period lb 5,460 5,460 Spent Fuel Loading and Handling, Period lb I 1,370 - 1,370 ISFSI Operating Costs, Period lb 2,541 - 2,541 Emergency Planning Fees, Period lb 227 [ 23 249 Spent Fuel Pool O&M, Period lb { 372 56 428 Period 2 MPCs and Overpacks, Period 2a 2,543 i - 2,543 Spent Fuel Loading and Handling, Period 2a 780 [ - 780 ISFSI Operating Costs, Period 2a 7,147 F - 7,147 Emergency Planning Fees, Period 2a 638 64 702 Spent Fuel Pool O&M, Period 2a 1,047 157 1,204 MPCs and Overpacks, Period 2b 15,909 15,909 Spent Fuel Loading and Handling, Period 2b 3,561 3,561 ISFSI Operating Costs, Period 2b 13,017 - 13,017 Emergency Planning Fees, Period 2b 1,162 116 1,278 Spent Fuel Pool O&M, Period 2b 1,906 286 2,192 ISFSI Operating Costs, Period 2c 2,928 - 2,928 Emergency Planning Fees, Period 2c 116 12 128 ISFSI Operating Costs, Period 2e 3,764 - 3,764 Emergency Planning Fees, Period 2e 149 15 164 Period 3 Insurance, Period 3b 464 46 510 Plant Energy Budget, Period 3b 35 5 40 NRC ISFSI Fees, Period 3b 235 23 258 Emergency Planning Fees, Period 3b 217 22 239 ISFSI Operating Costs, Period 3b 5,475 - 5,475 Security Staff, Period 3b 3,608 541 4,149 TLG Services, Inc.

Fort CalhounStation Document 002-1588-002, Rev. 0 DecommissioningCost Update Page22 of 24 TABLE D-1 (continued)

FORT CALHOUN STATION SPENT FUEL MANAGEMENT (thousands of 2007 dollars)

Base Contingency Total Period 3 (continued)

Utility Staff, Period 3b 793 119 912 ISFSI Operating Costs, Period 3c 85,366 85,366 NRC ISFSI Fees, Period 3c 3,654 365 4,020 ISFSI Operating Costs, Period 3d 207 207 NRC ISFSI Fees, Period 3d 9 1 10 ISFSI License Termination, Period 3e 4,033 - 4,033

[ ISFSI Operating Costs, Period 3e 1,699 1,699 NRC ISFSI Fees, Period 3e 1 73 7 80 ISFSI demolition, Period 3f 1,008 1,008 ISFSI Operating Costs, Period 3f F 842 842 Total Spent Fuel Storage Cost I 187,725 j 2,014 189,739 TLG Services, Inc.

FortCalhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page23 of 24 TABLE D-2 FORT CALHOUN STATION COST ALLOCATIONS (thousands of 2007 dollars)

Base Contingency Total Non-Nuclear Costs _ __

Period 1 _ _830__ 6 836 Period 2 4,675 1 31 4,706 Period 3 1 23,272 I 156 23P429 Total 28,777 193 28,971 LNuclear or License Termination Cost _

Total Decommissioning Cost 574,253 77,757 652,009 Less Non-Nuclear Less [above]

Spent Fuel Management [Table

_ D-11 28,777 187,725 193 2,014 28,971 '1 189,739 Total Nuclear or License Termination Cost } 357,750 75,549 433,300 1 Cost Summary

. Nuclear 357,750 75,549 433,300 Non-Nuclear 28,777 193 28,971 Fuel Management (Nuclear) 187,725 2,014 189,739 Total 574,253 { 77,757 652,009 TLG Services, Inc.

Fort Calhoun Station Document 002-1588-002, Rev. 0 DecommissioningCost Update Page24 of 24 TABLE D-3 FORT CALHOUN STATION ESCALATION ELEMENTS (thousands of 2007 dollars)

Escalation Cost Cost Elements I Category (w/contingency)

Decon Craft Labor Labor 6,537 Decon Equipment & Materials Labor 4,904 Removal Craft Labor Labor 38,395 Removal Equipment & Materials Labor 40,099 Packaging Craft Labor Labor 4,031 Packaging Equipment & Materials F Labor 7,433 Transportation Energy 8,505 Low-Level Radioactive Waste Disposal I Burial 43,718 Greater-than-Class C Waste Disposal I Other 2,679 Off-Site Waste Processing Burial 29,438 Decommissioning Management Staff Labor 185,858 Non-craft Contract Staff / Engineering Labor 8,928 Insurance Other 4,888 ISFSI Capital Expense/Site Alterations Labor 32,613 Other ISFSI-related Labor 147,736 Spent Fuel Pool O&M Labor 4,673 NRC and EP Fees Other 2,445 Energy Energy 7,036 Security (Decommissioning) Labor 43,424 Characterization and Licensing Surveys Labor 8,971 Miscellaneous Equipment Labor 5,937 Spent Fuel Pool Isolation Labor 10,503 Other Other 3,255 Total 652,009 TLG Services, Inc.

LIC-1 1-0050 Page 1 Escalation of Site-Specific Cost Estimate - Dismantlement Period

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2011 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ESCALATION OF SITE-SPECIFIC COST ESTIMATE - DISMANTLEMENT PERIOD

$ in millions YEAR COST IN2010 S 2033 $21.2 2034 $76.2 2035 $108.3 2036 $86.4 2037 $62.2 2038 $62.2 2039 $44.0 2040 $13.2 2041 $0.1 2058 $3.4

$477.2

LIC-1 1-0050 Page 1 Fort Calhoun Station Unit No.1 Decommissioning Fund Trust Agreement

• ° Fort Calhoun Station Unit No. 1 Decommissioning Funding Plan (the "1990 Plan")

Fort Calhoun Station Unit No. 1 Decommissioning Funding Plan (the "1990 Plan")

Section 1 - Introduction Omaha Public Power District's (the "District") Fort Calhoun Nuclear Power Generating Station Unit No. l's (the "Station")

current operating license (the "License") issued by the Nuclear Regulatory Commission (the "NRC") expires in the year 2008. For planning purposes, it is assumed the Station will be retired at that time. In order to terminate the License, it will be necessary to Decommission the Station which the NRC defines as:

"to remove [the Station) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of the License" (the "Decommissioning").

The District established a formal plan for the funding of the Decommissioning of the Station in February, 1983 (the "1983 Plan"). The 1983 Plan resulted from the efforts of an internal task force and a nationally recognized consultant. The District's Board of Directors have implemented the 1983 Plan and its current status is detailed further below.

Section 2 - NRC Financial Regulations For Decommissioning The NRC issued regulations in June 1988 and a subsequent Regulatory Guide setting forth financial criteria for Decommissioning licensed nuclear facilities. This 1990 Plan addresses those regulations and criteria.

Section 3 - NRC Decommissioning Estimate - Fort Calhoun Station Unit No. 1 NRC regulation 10 CFR 50.75(c) elaborates on three items to provide adequate funding for Decommissioning.

First, a Minimum Decommissioning Amount for Decommissioning licensed facilities is calculated based on a pressurized water reactor ("PWR") and on the facility's megawatt thermal rating

("MWt"). The Station is a PWR of 1500 MWt rating. The computation for the Minimum Decommissioning Amount in 1986 dollars for the Station is as follows:

($75 million + $8800 P),

where P equals the reactor's MWt rating

$75 million i- $8800(1500 MWt)

$75 million - $13.2 million = S88.2 million

1. 1 Second, the Minimum Decommissioning Amount is to be adjusted annually using the following formula.

(Minimum Decommissioning Amount) X (.65L + .13E + .22B)

The "L", "E" and "B" in the formula are escalation factors for Labor, Energy, and Waste Burial, respectively. Further, the Energy Index is composed of two factors - Industrial Power and Light Fuel Oils weighted as indicated. For the Station, the January 1986 NRC Minimum Decommissioning Amount of $88.2 million is escalated as follows:

Indices Labor U. S. Department of Labor - Bureau of Labor Statistics Employment Cost Index Private Nonfarm Workers *12-88 138.0 = .104 increase Compensation (Midwest Region) 1-86 125.0

• index available on quarterly basis only Energy U. S. Department of Labor - Bureau of Labor Statistics Producer Price Index Industrial Power 1-89 128.2 = .1085 increase (West North Central Region) 1-86 115.65 Light Fuel Oils 1-89 54.9 = .3305 decrease 1-86 82.0 Application of the formula to 1-1989 leads to =

Energy = ((128.2/115.65)X.58)+((54.9/82.0)X.42)

Energy = .6429 + .2812 Energy = .9241 a decrease of 7.59%

Waste Burial Washington Index 1-88 1.01 = .01 increase NUREG-1307 1-86 1.00 Nevada Index 1-88 .959 = .041 decrease 1-86 1.000 South Carolina Index 1-88 1.536 = .536 increase 1-86 1.000 Due to three Waste Burial indices provided in the NRC regulations, three separate escalated cost formulas were developed.

Washington Index

$88.2 million + (($88.2 million)(.65(.104)+.13(-.0759)+.22(.01)) =

$ 93,486,000 Nevada Index

$88.2 million + (($88.2 million)(.65(.104)+.13(-.0759)+.22(-.041))

= $ 92,496,000 South Carolina Index

$88.2 million + (($88.2 million)(.65(.104)+.13(-.0759)+.22(.536))

= $103,693,000 An average of the Minimum Decommissioning Amount for the three burial sites results in the following average escalated cost:

Washington Index $ 93,486,000 Nevada Index = $ 92,496,000 South Carolina Index = $103F693,000

$289,675,000 divided by 3

$ 96,558,000 The 1990 Plan will use the average of the three burial site indices in calculating the annual adjustment to the Minimum Decommissioning Amount until such time as a specific site is determined, or upon NRC direction.

Third, a method of providing for financial assurance must be selected. This 1990 Plan provides for the establishment of an external trust fund.

Additionally, five years prior to the projected end of the Station's operation, a site specific plan will be submitted with an up-to-date estimate of the cost of Decommissioning.

Section 4 - Current Status of the 1983 Plan The January 1982 estimated Decommissioning cost of $63 million has been adjusted annually and has received two separate reviews at three-year intervals by the District's external consultant.

Accordingly, the January 1989 estimated Decommissioning cost is

$105,400,000. The current Decommissioning Fund Balance (that amount which has been collected from the District's customers plus interest earnings) is herein defined as the "Balance Amount". The Balance Amount is invested in U. S. Treasury Securities as directed by the District's Bond Indenture and will be transferred to the new external Decommissioning trust fund as provided in Section 5.

Section 5 - Annual Deposits to the Decommissioning Trust Fund To comply with the new NRC regulations, a Trust Agreement is created as Attachment A to this 1990 Plan. The Trust Agreement establishes an external trust fund (the "Fund") for the accumulation of sufficient monies to meet the estimated costs of Decommissioning the Station. Annual deposits to the Fund (the "Annual Payments") will be calculated as follows:

First Year The first Annual Payment to be deposited into the Fund will be the greater of the two following:

A. The District's Minimum Decommissioning Cost as determined using the herein defined NRC regulated formula divided by 26 (the years of remaining License life at the time of the 1983 Plan) times 7 (the number of years monies have been funded internally);

or B. The Balance Amount (as herein defined).

The first Annual Payment shall be met by depositing into the Fund, on the Effective Date of the Trust Agreement, such monies and unmatured securities (valued at amortized book cost) now held by the District in the District's presently existing internal Fort Calhoun Station Unit No. 1 Decommissioning Fund pursuant to the 1983 Plan, plus any additional funds, as are necessary to meet this first Annual Payment.

Subsequent Years The Annual Payment required to be deposited to the Fund by the District for the second and subsequent years during the term of the Trust Agreement is calculated according to the following formula:

Decommissioning Cost Estimate Revised for the Annual Adjustment (as determined by NRC regulation 10 CFR 50.75(c))

A. Equals the Estimated Revised Minimum Decommissioning Amount $

B. Less the current balance in the Fund after the remittance of any "Paid Earnings",

any "Certification" payments and any "General Withdrawals" (as defined in the Trust Agreement) made in the present year $

C. Equals the Uncollected Estimated Minimum Decommissioning Amount $

D. Divided by the Station's Remaining Years of Operating Life E. Equals Amount of Present Year's Annual Payment $

Section 6 - Normal Plant Life becommissioning As indicated in Section 1, the Station's License expires in 2008.

That date is used for planning purposes and serves as a basis for this 1990 Plan. The District may apply for an extension of the License expiration date at some future time and in the event such application is made and approved by the NRC, the applicable Sections of this 1990 Plan will be changed accordingly.

This 1990 Plan is designed to cover a normal Decommissioning of the Station. In the event of a premature Decommissioning of the Station, separate financial considerations may become necessary and accordingly a new funding plan would be developed at that time in conformance with NRC direction.

ATTACHMENT "A" TRUST AGREEMENT This Trust Agreement, (the "Agreement") dated as of July 2, 1990, by and between Omaha Public Power District, a public corporation and political subdivision of the State of Nebraska (the "District") and The First National Bank of Omaha, a National Bank chartered and doing business by virtue of the laws of the United States of America with its principal place of business in Omaha, Nebraska, as External Fund Trustee (the "Trustee");

WITNESSETH WHEREAS, the District presently owns and operates the Fort Calhoun Nuclear Power Generating Station Unit No. 1 (the "Station") under Operating License Number DPR-40 (the "License")

issued by the Nuclear Regulatory Commission (the "NRC"); and WHEREAS, the License is expected to expire on June 7, 2008, at which time the District desires to remove the Station safely from service and reduce residual radioactivity to a level that permits termination of the License (the "Decommissioning"); and WHEREAS, to ensure that sufficient funds are available to pay the costs of Decommissioning the Station, NRC regulations 10 C.F.R. Part 50, as amended from time to time, require the District to establish and maintain an External Trust Fund (hereinafter defined) by depositing funds in an account segregated from the District's assets; and WHEREAS, Resolution No. 3945 was adopted by the Board of Directors of the District on June 7, 1990, (the "Resolution")

which Resolution permits the District to establish such External Trust Fund with the Trustee upon the terms and conditions hereinafter set forth in this Agreement.

NOW THEREFORE, in consideration of the foregoing and the mutual covenants hereinafter set forth, the parties hereto agree as follows:

SECTION 1. RESOLUTION The Trustee hereby acknowledges receipt of a true and correct copy of the Resolution establishing the Fund (as herein defined).

SECTION 2. ESTABLISHMENT OF FUND There is hereby established for the benefit of the NRC, the customer-owners of the District and the citizens of the State cf Nebraska; and for the purpose of discharging the District's legal obligation to accomplish the Decommissioning, a segregated External Trust Fund designated the "Omaha Public Power District Fort Calhoun Station Decommissioning External Trust Fund" (the "Fund") to be held in the custody of the Trustee. On the Effective Date (hereinafter defined) of the Agreement, there shall be deposited in the Fund, the First Annual Payment (as herein defined). After the date of the aforementioned First Annual Payment, the District shall make periodic additional deposits to the Fund, the frequency of which shall be determined by the District in its sole discretion; except that such additional deposits must be remitted to the Trustee at least annually, and in such amounts which at least equal the Annual Payment (hereinafter defined) required for each twelve (12) month period during the term of the Agreement. The minimum aggregate annual amount of such deposit or deposits required by the Agreement to be deposited in the Fund shall be determined in the manner set forth in Section 4 herein.

SECTION 3. GRANTOR TRUST The parties hereby acknowledge that the District is an entity exempt from taxation under Section 501(c) of the Internal Revenue Code of 1986, as amended. The parties agree that the Fund herein established is a Grantor Trust pursuant to Section 671 et. sea. of the Internal Revenue Code of 1986, as amended; that the D'is-ri:=

is the owner of the entire Fund for federal income zax.urposes.

and that the Trustee shall not be required to :il-e federal nccme tax return with respect to the Fund for any taxable year during which the Fund is in existence.

SECTION 4. MINIMUM ANNUAL DEPOSIT In order to ensure that as of the Termination Date, (here-inafter defined), the Fund will contain sufficient monies to meet estimated costs of Decommissioning, the following computations shall be used to determine the minimum aggregate annual amount (the "Annual Payment") which the District shall be required to deposit into the Fund:

A. First Year. The Annual Payment to be deposited in the Fund during the first twelve (12) month period from the Effective Date (the "First Annual Payment") shall be that amount as calculated pursuant to the formula set forth in Section 5 of the District's Fort Calhoun Station Unit No. 1 Decommissioning Funding Plan (the "1990 Plan").

On the Effective Date, the District shall deposit into, or assign to, the Fund all or that part of such monies and securities then held by the District in the District's pre-sently existing internal Fort Calhoun Station Unit No. 1 Decommissioning Fund as required to meet the First Annual Payment; which monies and securities are delineated in Exhibit "1" attached hereto. Should the funds held in the existing internal Fort Calhoun Station Unit No. 1 Decommissioning Fund be insufficient to meet the First Annual Payment, the District shall make up any such deficiency by an additional deposit or deposits to the Fund during the twelve (12) month period from and after the Effective Date of the Agreement.

B. Subsequent Years. The Annual Payment required to be deposited into the Fund by the District for the second and all subsequent years during the term of the Agreement, shall be determined as set forth in the 199C Plan. The Trustee hereby acknowledges receipt of the 199u 7+/-1= which is incorporated herein by this reference and made a part hereof.

The District and the Trustee hereby acknowledge that the 1990 Plan may be amended from time to time by the NRC, and that any and all such amendments to the 1990 Plan effectuated during the term hereof shall constitute a part of the Agreement.

SECTION 5. TRUSTEE DUTIES The Trustee hereby establishes the Fund and accepts the cash and securities deposited therein pursuant to the Agreement. The Trustee has the duty to execute the investment of any and all monies held hereunder in the following investments:

A. Any obligations of the United States Government having the backing of the full faith and credit of the United States of America; and/or B. Any and all investments permitted to be made by Public Power Districts under the laws of the State of Nebraska, as amended from time to time, (collectively the "Permitted Investments").

The Trustee shall exercise its investment duties pursuant to this Section 5 only in accordance with the oral instructions (followed by prompt written confirmation thereof) of the District.

The District hereby retains sole authority to determine which among the Permitted Investments the Trustee shall make, and the District hereby agrees to be bound by the terms and conditions of the Agreement when making such investment determinations. Not-withstanding any of the foregoing to the contrary, the District may, in its sole discretion, and at any time during the term of the Agreement, delegate its power to direct the investment of the Fund's assets to an investment manager. Any such investment manager to whom the District may delegate its investment powers granted herein, shall be required to execute and deliver to the Trustee any and all documents as may be necessary to evidence said investment manager's agreement to be bound by all terms and condi-tions respecting the Permitted Investments contained in this Section 5 of the Agreement. In the event the Trustee follows ai].

such directions received fro. the District or such investment manager appointed by the District, the Trustee shall not be liable for any losses incurred by reason of any action taken pursuant to such directions provided such directions are in compliance with the requirements of this Section 5.

The maturity date of any Permitted Investment made pursuant to the Agreement shall not unreasonably extend beyond the Termi-nation Date (hereinafter defined) of the Agreement.

If the District shall so request the Trustee, in writing, income received on the Permitted Investments shall be paid by the Trustee to the District as received (the "Paid Earnings"). All Paid Earnings shall be used by the District first in meeting its Annual Payment due to the Fund. Should the Paid Earnings exceed the Annual Payment due for any year during the term of the Agreement, any such excess may be used by the District for valid corporate purposes.

The Trustee shall submit to the District a written annual accounting of the Fund as of the end of each calendar year during which the Agreement shall be in effect (the "Accounting"). The Accounting, which shall be delivered to the District no later than January 31st of each year during the term hereof, shall include:

A. The balance of the Fund at the close of the last previous Accounting, and all amounts received from whatever source during the period covered by the Accounting; B. A listing of all disbursements from the Fund; C. An inventory of all investments held by the Trustee as of the date of the Accounting; and D. Such other information as the District may, from time to time, request be included in any such Accounting.

A copy of all Accountings shall be submitted by the District to the NRC within thirty (30) days after receipt thereof by the District.

During the term of the Agreement, the Trustee shall give the District (or the District's representatives) full access, during Trustee's normal business hours, tc all books and records relating to the Fund, and shall provide the District (or the District's representatives) wit _ such iniormation regarding the Fund as the District (or the District's representatives) may reasonably request.

SECTION 6. DECOMMISSIONING EXPENSES To enable the District to meet Decommissioning expenses as they arise, the District is hereby empowered to make withdrawals from the Fund upon the following terms and conditions:

A. Four (4) times in every twelve (12) month period during the term of the Agreement, the District may submit to the Trustee an itemized written request for Decommissioning funds (the "Certification"). The Certification shall contain the following information and be calculated according to the following formula:

1. a) The total amount of Decommissioning expenditures, if any, actually incurred by the District during the prior three (3) month period, b) minus the total aggregate amount received by the District, if any, out of the Fund for Decommissioning purposes during the prior three month period, EQUALS c) The total unfunded Decommissioning expenditures for the prior three (3) month period ("Prior Unfunded I Expenditures") I$

PLUS 1 1In the event that, during any three (3) month period, the District shall have received monies out of the Fund for Decommissioning purposes in excess of Decommissioning expenses actually incurred during the same period, the Prior Unfunded Expenditures would be a negative number thereby decreasing the Certification Amount received pursuant to any Certification submitted to the Trustee at the end of an%, such three (3) montn period.

2. All expenditures for Decommissioning purposes, if any, which the District reasonably anticipates it shall incur in the ensuing three (3) month period ("Future Unfunded Expenditures") $

The net of Prior Unfunded Expenditures and Future Unfunded Expenditures shall constitute the "Certification Amount".

All Certifications shall be made by such Treasury Officer(s) as appointed by the District's Board of Directors (the "Treasury Officer") and shall be submitted to the Trustee in the form attached hereto as Exhibit "2". Provided a Certification is in compliance with the requirements of this Section 6, the Trustee shall pay to the District, out of the Fund, the Certification Amount on or before the date specified by the District in any such Certification.

B. Notwithstanding any of the foregoing, should the District be required to make any Decommissioning expenditure, which Decommissioning expenditure should exceed the sum of One Hundred Thousand Dollars ($100,000.00), and for which prospective provision was not made in any prior Certification to the Trustee, the District may, at any time, submit a "Special Certification" to the Trustee in the same form re-quired for a Certification. Upon receipt of a Special Certi-fication, the Trustee shall pay to the District, out of the Fund, the amount so requested by the Special Certification on or before the date specified by the District in any such Special Certification.

No Certification, except a Special Certification, shall be made to the Trustee prior to the first day of the fourth month from the Effective Date (the "Initial Certification").

All subsequent Certifications shall be made at three month intervals from the date of the Initial Certification.

C. Notwithstanding anything in this Section 6 to the contrary, in the event that the amortized book value of the Fund should exceed the total cost estimate of Decommissioning (as determined pursuant :c the NRC regulated formula set forth in the 1990 Plan as amended) for any year during the term of the Agreement, the District may withdraw such excess funds from the corpus of the Fund to be used by the District for valid corporate purposes (a "General Withdrawal"). All requests for General Withdrawals: (1) shall be submitted to the Trustee in writing specifying the date by which any sums so requested must be received by the District; and (2) shall be made by a Treasury Officer. In no event shall the total amounts received by the District pursuant to General With-drawals in any year during the term hereof exceed the differ-ence between the adjusted book value of the Fund and the cost estimate of Decommissioning (as calculated pursuant to the NRC Regulated Formula set forth in the 1990 Plan, as amended) for the year in which such General Withdrawals are made.

D. The District shall submit copies of all Certifications, Special Certifications and General Withdrawals to the NRC.

SECTION 7. INDEPENDENT AUDIT To provide adequate assurance to the NRC that the District and the Fund are in compliance with all NRC Regulations respecting Decommissioning funds, the District shall cause to be conducted an annual audit of the Fund and all transactions relating thereto (the "Annual Audit"). The Annual Audit shall be conducted by either: (1) the District's independent accountants (the "District's Auditor"); or (2) the auditors of the Trustee (the "Trustee's Auditor"). The District shall have sole discretion to determine whether the Annual Audit be conducted by the District's Auditor or the Trustee's Auditor; and all costs of each Annual Audit shall be borne by the District.

Each Annual Audit shall take place in the month immediately following each twelve (12) month period during which the Agreemenz:

shall be in effect. In the event the District snail l4rec :

Trustee's Auditor to conduct any Annual Audit, the District sna.'_

cive the Trustee's Auditor at least sixty (60) days' prior written nctice thereof. Reports of all such Annual Audits shall be submitted to the NRC, the District and the Trustee within sixty (60) days of the completion of each such Annual Audit. Such report shall contain, in addition to an analysis of the Fund and all transactions relating thereto, a certification by the District's Auditor, or the Trustee's Auditor (whichever is applicable), to the NRC that all payments from the Fund by the Trustee to the District were made pursuant to the terms of Sections 5 and 6 herein.

SECTION 8. COMPENSATION OF TRUSTEE The District shall compensate the Trustee for its performance of the services specified in the Agreement. During the first five (5) years of the term of the Agreement, the Trustee shall be entitled to compensation as follows: year one - $950.00 per quarter; year two - $1,200.00 per quarter; year three - $1,400.00 per quarter; year four - $1,700.00 per quarter; and year five -

$2,000.00 per quarter. On a quarterly retrospective basis, the Trustee shall submit to the District an invoice for the Trustee's quarterly compensation as set forth in this Section 8, which quarterly compensation includes any and all administrative expenses incurred by the Trustee in connection with the administration of the Fund.

The District shall pay such quarterly invoices no later than thirty (30) days following the end of the applicable calendar quarter or ten (10) days following the receipt by the District of such quarterly invoices, whichever occurs later.

For all successive years that the Agreement shall be in effect, the Trustee shall receive compensation for its services hereunder in such amounts and upon such terms as shall be agreed upon by the parties hereto in writing. In the event that the parties are unable to agree upon the Trustee's compensation for any such successive year, the Trustee shall continue to receive the quarterly compensation for year five as stated in the preceding paragraph of this Section 8 for each sucn successive year.

SECTION 9. LIMITED USE Except as provided in Sections 5 and 6 of the Agreement, all monies, deposits, and securities held in the Fund pursuant to the Agreement shall be used solely for the costs of Decommissioning.

No principal or income payable to, or to become payable under, the Fund shall vest in the District for any other purposes except those specifically authorized herein. No principal or income of the Fund shall be taken or reached by any legal or equitable process in satisfaction of any debt of the District.

SECTION 10. TERMINATION This Agreement shall terminate on such date as the Decommis-sioning shall be completed (the "Termination Date").

Prior to the Termination Date, the District shall submit its final Certification to the Trustee which shall disburse funds to cover final Decommissioning costs. On the Termination Date, the Trust herein established shall terminate, and any amounts remain-ing in the Fund shall be returned to the District.

SECTION 11. STANDARD OF CARE The Trustee shall perform such duties as are specifically set forth in the Agreement. The Trustee shall exercise its duties with the degree of care and skill that a prudent person would exercise in the conduct of his own affairs.

No provision of the Agreement, however, shall be construed to relieve Trustee from liability for its own neglect or willful misconduct except that:

A. In the absence of bad faith on the part of the Trustee, the Trustee may conclusively rely, as to truth, authenticity and correctness, upon all documents and writings, including but not limited to all investment instructions, certifications, Special Certificat-i2ons anc General Withdrawals pursuant to Sections 5 anc e Agreement, furnished to the Trustee bv the Districz, or by any investment manager appointea under Section - ofr the Agreement; B. The Trustee shall not be liable with respect to any action taken or omitted to be taken by it in good faith at the direction of the District or any investment manager respecting any Permitted Investments allowed by the Agreement; and C. The Trustee shall have no responsibility to collect from the District any payments necessary to discharge any liabilities of the District established by the NRC.

SECTION 12. MAINTENANCE OF OFFICE There shall at all times be a Trustee hereunder which shall be a national bank organized, chartered and doing business by virtue of the laws of the United States of America and authorized under such laws to exercise corporate trust powers, having combined capital and surplus and retained earnings of at least Fifty Million Dollars ($50,000,000.00), and subject to supervision or examination by Federal authority. For purposes of determining whether such corporation meets the requirement of the preceding sentence, the combined capital and surplus and retained earnings of such corporation shall be deemed to be its combined capital and surplus and retained earnings as set forth in its most recent published report of condition. If at any time the Trustee shall cease to be eligible in accordance with the provisions of this Section 12, the District shall have the authority to request the immediate resignation of the Trustee in the manner and with the effect specified in Section 13 below.

SECTION 13. RESIGNATION OR REMOVAL OF TRUSTEE The Trustee may at any time resign by giving 90 days' prior written notice to the District and the NRC by certified mail of such resignation, provided that no such resignation shall take effect until a successor Trustee is appointed. :f a successor Trustee has not: (1) been so appointed; ana ý2) accepted such appointment within ninety (90) days after the District has received Trustee's notice of resignation, the resigning Trustee may petition any court of competent jurisdiction for the appointment of a successor Trustee. Such court may thereupon, after receiving such petition, appoint a successor Trustee.

Upon written notification by the District to the NRC, the Trustee may be removed by the District, and a Successor Trustee appointed, upon the occurrence of any of the following:

A. The Trustee ceases to be eligible in accordance with the provisions of Section 12 above and fails to resign after request therefore by the District; B. The Trustee shall become incapable of acting or shall be adjudged bankrupt or insolvent, or a receiver shall have been appointed of the Trustee, or of its property or affairs for the purpose of rehabilitation, conservation or liquidation; or C. The District shall determine, in its sole discretion, that the Trustee should be removed.

Should the Trustee resign or be removed for any reason, an independent audit of the Fund, pursuant to the terms of Section 7 herein, ,shall be conducted prior to the appointment of any successor Trustee. Any resignation or removal of the Trustee and appointment of a successor Trustee pursuant to the provisions of this Section 13 shall become effective only upon acceptance of appointment by the successor Trustee as provided in Section 14 below.

SECTION 14. SUCCESSOR TRUSTEE Any successor Trustee appointed as provided in Section 13 herein shall execute, acknowledge and deliver to the District, the NRC, and to its predecessor Trustee, an instrument accepting such appointment hereunder and thereupon the resignation or removal of the predecessor Trustee shall become effective and such successor Trustee, without any further act, deed or conveyance, shall become vested with all the rights, powers, duties and obligations hereunder, with like efrecz is if originally named as Trustee herein. Notwithstanding anything in the foregoing sentence to the contrary, on the request of the District, or on the request of the successor Trustee, the Trustee ceasing to act hereunder shall execute and deliver all such instruments of transfer as may be necessary to transfer to such successor Trustee: (1) all assets of the Fund; and (2) all the rights and powers of the Trustee ceasing to act under the Agreement.

No successor Trustee shall accept appointment as provided in this Section 14 unless at the time of such acceptance such successor Trustee shall be eligible under the provisions of Section 12 of the Agreement.

SECTION 15. DEFAULT BY DISTRICT.

In the event of the District's failure, whether by default or inability, to exercise any of its rights or obligations under this Agreement, the NRC may assume any and all of such rights and/or obligations as the NRC may, in its sole discretion, deem necessary or appropriate. If, pursuant to the terms of this Section 15, the NRC assumes any rights and/or obligations of the District hereunder, the NRC shall provide the Trustee with written notification of any such assumption. Thereafter, the Trustee shall make payments from the Fund, as the NRC shall direct in writing, solely for: i) payment of the costs of the Decommissioning covered by this Agreement; and ii) payment of all other expenses incurred by the District, the NRC or any other party in the discharge of any obligations under this Agreement.

In addition, the Trustee shall refund to the District any amounts as the NRC shall specify in writing, and upon such refund, such amounts shall no longer constitute part of the Fund.

In the event it becomes necessary for the NRC to undertake any rights or obligations of the District pursuant to this Section 15, the Trustee shall not be liable with respect to any action taken or omitted to be taken by it in good faith at the direction of the NRC.

SECTION 16. IRREVOCABLE TRUST.

The Fund herein established shall constitute an Irrevocable Trust as required by NRC regulations, as amended from time to time, for the purpose of providing sufficient available funds to accomplish Decommissioning. The District shall have no rights to the monies held in the Fund except as provided in the Agreement.

Notwithstanding anything herein to the contrary, however, should NRC regulations be amended, the effect of which would be that the Fund is no longer required, the District may terminate the Agreement and revoke the Fund herein established and all assets of the Fund as of the date of any such termination shall be returned to the District.

SECTION 17. EFFECTIVE DATE This Agreement shall commence and become operative on July 2, 1990 (the "Effective Date").

SECTION 18. SUCCESSORS AND ASSIGNS All the covenants and representations made by the District and contained in the Agreement shall bind and inure to the benefit of its successors and assigns, whether so expressed or not.

SECTION 19. SEVERABILITY If any provision of the Agreement should be determined by a court of competent jurisdiction to be contrary to law, such provision shall be deemed and construed to be severable from the remaining provisions herein contained, and shall in no way affect the validity of the remaining provisions of the Agreement.

SECTION 20. ENTIRE AGREEMENT The Agreement supersedes all prior negotiations, agreements and understandings among the parties with respect to the subject matter hereof. To be effective, any amendment to, or modification of, the Agreement must be in writing, executed by the District and the Trustee, and approved by the NRC.

SECTION 21. NOTICES Unless otherwise specified herein, all notices required to be given by or to either party pursuant to the terms of the Agreement, including but not limited to, all Certifications, Special Certifications, General Withdrawals, invoices, reports, requests and communications, shall be sufficiently given only if in writing and if sent by first class United States mail, postage prepaid, by or to the appropriate addressee indicated below:

To the Trustee:

First National Bank of Omaha One First National Center Omaha, NE 68102 Attn: Marc M Diehl, Trust Officer-Manager Corporate Trust Division To the NRC:

U. S. Nuclear Regulatory Commission OWSN 12E4 Washington, DC 20555 Attn: Robert S. Wood To the District:

With a Copy To:

The Division Manager - Finance Omaha Public Power District Stephen G. Olson, Esq.

444 South 16th Street Mall 500 Energy Plaza Omaha, NE 68102 Omaha, NE 68102 Changes to the above addresses may be made from time to time by either of the above-listed entities, by notice to the other entity from the above-named representative of the respective entity or from any other duly authorized officer of that entity as certified by the Secretary of that entity.

SECTION 22. HEADLINES The headings of the Sections used in the Agreement are for convenience only and shall not control or affect the meaning of any of the provisions thereof.

SECTION 23. REPRESENTATIONS A. The Trustee represents that it has the power, authority and legal right to enter into and perform its obligations set forth in the Agreement and that the execution, delivery and performance hereof have been duly authorized and will not violate any applicable law, regulation or by-law of the Trustee.

B. The District represents that it has the power, authority and legal right to enter into and perform its obligations set forth in the Agreement, and that the Agreement and the Fund herein established have been duly approved by the NRC as being in conformity with its requirements set forth in 10 C.F.R. §50.75, as amended from time to time. The District further represents that the execution, delivery and performance of the Agreement have been duly authorized and will not violate any applicable law, regulation or by-law of the District.

SECTION 24. COUNTERPARTS The Agreement may be executed in several counterparts, all or any of which shall be regarded for all purposes as an original and shall constitute and be one and the same Agreement.

SECTION 25. GOVERNING LAW The Agreement and any questions concerning its validity, construction or performance shall be governed by the laws of the State of Nebraska.

IN WITNESS WHEREOF, the parties hereto have each caused the Agreement to be executed by their duly authorized officers and their corporate seals to be hereunto affixed and attested as of the date first above written, but actually on June 27 1990.

ATTEST: OMAHA PUBLIC POWER DISTRICT ATTEST* .I.: x ec d 4, t,*.*T.'r*._

• Its: Executive VcFrsident FIRST NATIONAL BANK OF OMAHA, ATTEST: Trustee By: J Its: ~ ~ ,~

ATTEST: _- vV sgo/mmh Alan *E. -Schul 4*rust Officer EXHIBIT "I" THE FIRST ANNUAL PAYMENT

1. Cash: $

2. Securities:

Amortized Book Cost Description of Security a.

b.

C.

d.

e.

f.

g.

etc.

Subtotal FIRST ANNUAL PAYMENT

EXHIBIT "2" Check One:

Ii Certification

~i Special Certification CERTIFICATION

[Insert name and address of Trustee]

Attention: Trust Department In accordance with the terms of that certain Trust Agreement dated , I, _, [insert title officer] of Omaha Public Power District (the "District")

hereby request a withdrawal from the Omaha Public Power District Fort Calhoun Decommissioning External Trust Fund (the "Fund") as follows:

1. Total Decommissioning Expenditures incurred during the prior 3 month period: $

minus Aggregate amount of all withdrawals for Decommissioning during the prior 3 month period:

equals Prior Unfunded Expenditures: $

PLUS

2. Anticipated Decommissioning Expenditures for the period

,19 to

,19_  : $

EQUALS CERTIFICATION AMOUNT $

The Certification Amount shall be paid to the District via wire transfer to the District's account number at finsert name of Depository Bank] on or before f 19 The undersigned hereby certifies that the Certification Amount reauested from the Fund shall be used solely for the

purpose of meeting the District's expenses in connection with the Decommissioning of the District's Fort Calhoun Nuclear Power Generating Station Unit Number 1. The undersigned further certifies that a copy of this Certification has been submitted to the Nuclear Regulatory Commission.

DATED OMAHA PUBLIC POWER DISTRICT By Its LIC-1 1-0050 Page 1 1992 Supplemental Plan Trust Agreement

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DECOMMISSIONING TRUST - 1992 SUPPLEMENTAL PLAN TRUST AGREEMENT This Trust Agreement, (the 'Agreement") dated as of.July 1, 1993 has been entered into by and between Omaha Public Power District, a public corporation and political subdivision of the State of Nebraska (the "District") and the, First National Bank of Omaha as trustee ((he 'Trustee").

WHEREAS, the District presently owns and operates the Fort Calhoun Nuclear Power Generating Station Unit No. 1 (the "Station*) under Operating License Number DPR-40 (the "License") issued by the

.Nuclear Regulatory Commission (the "NRC'); and WHEREAS, Resolution Number 3945 adopted by the Board of Directors of the District on June 7, 1990, established the 1990 Decommissioning Plan in compliance with NRC regulations 10 C.F.R. Part 50, as amended from time to time; and WHEREAS, to ensure that additional funds are available to pay the direct and indirect costs of decommissioning the Station (the "Decommissioning') Resolution Number 4220 was adopted by the Board of Directors of the District on October 15, 1992, (the "Resolution"> providing for the 1992 Supplemental Plan which creates a Supplemental External Trust Fund (hereinafter defined) by depositing funds in an account segregated from the District's assets; and WHEREAS, the Resolution permits the District to establish such Supplemental External Trust Fund with the Trustee upon the terms and conditions hereinafter set forth in this agreement; and NOW THEREFORE, in consideration of the foregoing and the mutual covenants hereinafter set forth, the parties hereto agree as follows:

1. Establishment of Trust Fund. There is hereby established for the benefit of the District and for the purpose of accumulating funds for the Decommissioning, a segregated Supplemental External Trust Fund designated the *Omaha Public Power District Fort Calhoun Station Supplemental External Trust Fund - 1992 Supplemental Plan" (the "1992 Supplemental Fund") to be held in the custody of the Trustee. All funds deposited pursuant to Section 3 of this Agreement (the "Principal') and all income earned on the Principal and any income earned on the reinvestment of such income (the 'Earnings") shall be held by the Trustee, in trust, pursuant to the terms and conditions hereof. The 1992 Supplemental Fund shall be held by the Trustee, not individually, but solely as trustee. The 1992 Supplemental Fund shall be segregated from any other funds held or owned by the Trustee and held in such a manner so as not to be subject to the claims of any creditors of the Trustee.

2. Grantor Trust The parties hereby acknowledge that the District is an entity exempt from taxation under Section 501(c) of the Internal Revenue Code of 1986, as amended. The parties agree that the 1992 Supplemental Fund herein established is a Grantor Trust pursuant to Section 673 et. sea. of the Internal Revenue Code of 1986, as amended; that the District is the owner of the entire 1992 Supplemental Fund for federal income tax purposes; and that the Trustee shall not be required to file a federal income tax return with respect to the 1992 Supplemental Fund for any taxable year during which the 1992 Supplemental Fund is in existence.

3. Deposits. All deposits (other than deposits of Earnings) to the 1992 Supplemental Fund shall be made in an amount and frequency of which shall be determined by the District at its sole discretion.

4. Investments. The Trustee hereby establishes the 1992 Supplemental Fund and accepts any cash and securities deposited therein pursuant to the Agreement. The Trustee has the duty to execute the investment of I

any and all monies held hereunder in the rollowing investments permittcd of Public Power Districts in the Stale of Nebraska:

A. Any obligations of the United Slates Government having the backing or the full faith and credit of the United States or America; and/or B. Any and all investments permitted to be made by Public Power Districts under the laws of the State of Nebraska, as amended from time to time.

C. Repurchase Agreements collateralized by securities listed in Section 4(A) or (B) (collectively the "Permitted Investments").

The Trustee shall exercise its investment duties pursuant (0 LhiS Section 4 only in accordance with the oral instructions (followed by prompt written confirmation thereof) of the District. The District hereby retains sole authority to determine which among the Permitted Investments the Trustee shall make, and the District hereby agrees to be bound by the terms and conditions of the Agreement when making such investment detcrminations.

Notwithstanding any of the foregoing to the contrary, the District may, in its sole discretion, and at any time during the term of the Agreement, delegate its power to direct the investment of the 1992 Supplemental Fund's assets to an investment manager. Any such investment manager to whom the District may delegate its investment powers granted herein, shall be required to execute and deliver to tie Trustee any and all documents as may be necessary to evidence said investment manager's agreement to be bound by all terms and conditions respecting the Permitted Investments contained in this Section 4 of the Agreement. In the event the Trustee follows all such directions received from the District or such investment manager appointed by the District, the Trustee shall not be liable for any losses incurred by reason of any action taken pursuant to such directions provided such directions are in compliance with the requirements of this Section 4.

S. Withdrawals. The District is hereby empowered to make withdrawals from the 1992 Supplemental Fund as solely determined by the District. Withdrawal requests will occtur in writing executed by a Treasury Officer as appointed by the District's Board of Directors. Such withdrawal requests will contain detailed instructions directing the movement of the withdrawn cash or securities.

6. Account Maintenance. The Trustee shall maintain records of deposits, disbursements, expenses, income and loss with respect to Principal and Earnings and from time to time upon the request of the District, and no less than quarterly, shall provide an account with respect thereto to the District. The District retains the right to cause an audit of the 1992 Supplemental Fund and all transactions relating thereto to be conducted by its own or independent accountants; and al. costs of said audit to be borne by the District-

7. Compensation or Trustee. The District shall compensate the Trustee for its performance of the services specified in the Agreement. During the initial two (2) years of the Agreement, the Trustee shall be entitled to quarterly compensation in the amount of $1,360.00 per quarter for the first year and $1,600.00 per quarter for the second year. On a quarterly retrospective basis, the Trustee shall submit to the District an invoice for the Trustee's quarterly compensation as set forth in this Section 7 including all fair and reasonable administrative expenses incurred by the Trustee in connection with the administration of the 1992 Supplemental Fund.

The District shall pay such quarterly invoices no later than thirty (30) days following the end of the applicable calendar quarter or ten (10) days following the receipt by the District of such quarterly invoices, whichever occurs later.

For all successive years that the Agreement shall be in effect, the Trustee shall receive compensation for its services hereunder in such amounts and upon such terms as shall be agreed upon by the parties hereto in writing. In the event that the parties are unable to agree upon the TrUstee's compensation for any such successive year, the Trustee shall continue to receive the quarterly compensation stated in the preceding paragraph of this Section 7 for each such successive year.

2

8. Termination. This Agrcemcnt shall termhnatc on such daic as the Decommissioning shall be completed (the "Termination Date") or on such other daLe us determined by the District. On the Termination Date, the Trust herein establishcd shall terminate, and any amounts remaining in thc 1992 Supplemental Fund shall be returned to the District.

9. Standard of Care. The Trustee's duties hereunder shall be limited to hold the 1992 Supplemental Fund and to nmake investments thereof and distributions therefrom in accordance with the terms of this Agreement. The Trustee shall exercise its duties with the degree or care and skill that a prudent person would exercise in the conduct of his own affairs.

No provision of the Agrecmcnt, however, shall be construed to relieve the Trustee from liability for its own neglect or willful misconduct except that:

A. In the absence of bad faith on the part of the Trustee, the Trustee may conclusively rely, ,as to truth, authenticity and corrctrness, upon all documents and writings, including but not limited to all investment instructions and withdrawals pursuant to Sections 4 and 5 of the AgrenmenL, furnished to the Trustee by the District, or by any investment manager appointed under Section 4 of the Agreement; and B. The Trustee shall not be liable with respect to any action taken or omitted to be taken by it in good faith at the direction of the District or any investment manager respecting any Permitted Investments allowed by the Agreement.

10. Resignation, Removal and Appointment.

A. The Trustee and any successor Trustee shall be a bank or trust company organized and doing business under the laws of the United States or any of the several states of tbe United States, having a combined capital and surplus of at least Fifty Million Dollars ($50,000,000), and subject to supervision by federal authority. In the event that the Trustee at any time shall cease to meet the requirements of this Section 10(A), the Trustee shall immediately inorm the District and if so requested by the District resign in the manner provided in Section 10(B) below.

B. The Trustee may resign by giving not less than 90 days prior notice to the District; provided, however that no such resignation shall become effective until a successor trustee is appointed and accepts such appointment.

C. The Trustee may be removed at any time by the District upon notice of termination delivered to the Trustee by the District 30 days prior to such removal.

D. If at any time the Trustee shall resign, be removed or the position of the Trustee shall become vacant for any reason, the District shall promptly appoint a successor to the Trustee. Upon any such appointment such successor shall execute, acknowledge and deliver to its predecessor and the District, an instrument aeceptingsuch appointment hereunder, and thereupon such successor, without any further act, shall be vested with all rights, immunities and powers and shall be subject to all duties and obligations of its predecessor; provided, however, that no successor trustee shall be liable for 3

any act or omission of any predecessor trustee. In the event that a successor has not been appointed within ninety (W) days of the date of notice of such resignation, resignation, removal or vacancy, the Trustee may petition any court of competent jurisdiction for the appointment of a successor. Such court may thereupon, appoint a successor Trustee to serve until a successor shall be appointed by the District as provided above.

11. Successors and Assigns. All the covenants and representations madek by the District and contained in the Agreement shall bind and inure to the benefit of its successors and assigns, whether so expressed or not.

12. Severability. If any provision of the Agreement should be determined by a court of competent jurisdiction to be contrary to law, such provision shall be deemed and construed to be severable from the remaining provisions herein contained, and shall in no way affect the validity of the remaining provisions of the Agreement.

13. Entire Agreement. The Agreement supersedes all prior negotiations, agreements and understandings among the parties with respect to the subject matter hereof with the exception of the Trust Agreement known as the Fort Calhoun Station Unit No. I DecomnissioningFunding Plan (the "1990 Plan"). To be effective, any amendment to, or modification of, the Agreement must be in writing, executed by the District and the Trustee.

14. Notices. Unless otherwise specified herein, all notices required to be given by or to either party pursuant to the terms of the Agreement, including but not limited to, all withdrawals, invoices, reports, requests, and communications, shall. be sufficiently given only if in writing and if sent by first class United States mail, postage prepaid, by or to the appropriate addressee indicated below:

To the Trustee:

Corporate Trust Coordinator First National Bank of Omaha One First Nationas Center Omaha, Nebraska 68102-1596 To the District:

Division Manager - Finance Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247 Changes to the above addresses may be made from time to time by either of the above-listed entities by notice to the other entity from the above-named representative of the respective entity or from any other duly authorized officer of that entity as certified by the Secretary of that entity.

15. Section Headings. The headings of the Sections used in the Agreement are for convenience only and shall not control or affect the meaning of any of the provisions thereof.

16. Representations. Each Party represents that it has the power, authority and legal right to enter into and perform its respective obligations set forth in [he Agreement and that the execution, delivery and performance hereof have been duly authorized and will not violate any applicable judgement, order, law or regulation or any rules or by-laws of each party.

4

17. Counterparts. The Agreement may be execited in several counterparts, all or any of which shall be regarded for all purposes as an original and shall constitute and be one and the same Agreement.

18. Governing Low. The Agreement and any questions concerning its validity, construction or performance shall be governed by the laws of the State of Nebraska.

IN WITNESS WHEREOF, each of the partics his caused this Agreement to be executed by its duly authorized representative on the date set forth beneath its signaturc below, and the signature below on bt-half of the Trustee is intended as evidence of the Trustee's acceplance of the trmsts created hereunder. This Agreement shall be effective upon execulion by all parties hereto.

SO1CPow,,

,O, OMAHA PUBLIC POWER DISTRICT o S* ~A L

• a public corporation and

.

• political subdivision of the

• • " *CREATED

• state of Nebraska ATET

A M/  %:1945

.. 3$4 , 6,

( ~~~~y ZC***", E,C. Pap 4"//D.

Assist t Secretar' ' By.

Title:

Executive Vice President Date: _____.

FIRST NATIONAL BANK OF OMAHA, Trustee ATTEST:rI

- John E. lcnihan

Title:

Corporate Trust Coordinator Date: _ _.9_ _ _ _ _

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LIC-1 1-0050 Page 1 Board Resolutions Approving Trust Agreements 1 1 Resolution No. 3945: Decommissioning Fund Trust Agreement Resolution No. 4220: 1992 Supplemental Plan Trust Agreement

Ii~~I OMAHA PUBLIC POWER DISTRICT CERTIFIED COPY OF RESOLUTION NO, 3945 WHEREAS, the Omaha Public Power District (the "District") owns and operates the Fort Calhoun Nuclear Power Generating Station Unit No. I (the "Station") under Operating License No. DPR-40 (the "License") issued by the Nuclear Regulatory Commission (the "NRC"), and WHEREAS, the License is expected to expire on June 7, 2008, at which time the District desires to remove the Station safely from service and reduce residual radioactivity to a level that permits release of the Station for unrestricted use and termination of the License (the "Decommissioning"), and WHEREAS, in February, 1983, the District adopted a plan establishing an internal fund for the accumulation of monies for Decommissioning purposes (the "1983 Plan"), and WHEREAS, in June, 1988, the NRC issued new regulations to 10 C.F.R. Part 50 to ensure that sufficient funds will be available to pay the costs of Decommissioning, and WHEREAS, pursuant to said new NRC regulations, the District was required to submit to the NRC, by July 27, 1990, a plan for funding the Decommissioning of the Station, which plan must require that funds for Decommissioning purposes are segregated from the District's assets (the "1990 Plan"), and WHEREAS, on October 27, 1989, the District submitted the 1990 Plan to the NRC, and in accordance with NRC regulations, said 1990 Plan calls for the establishment of an external trust fund (the "Fund") to be held in the custody of a trustee (the "Trustee") pursuant to the terms of the "Trust Agreement" attached to, and made a part of, the 1990 Plan, and WHEREAS, the 1990 Plan was accepted by the NRC on February 1, 1990, and WHEREAS, the 1990 Plan provides that the Balance Amount held in the internal fund established pursuant to the 1983 Plan be transferred to the Fund upon establishment of same, and WHEREAS, the District has obtained proposals from five national banks to act as Trustee of the Fund, and WHEREAS, the First National Bank of Omaha has submitted the most competitive of the aforementioned proposals and is otherwise qualified to act as Trustee of the Fund.

NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the Omaha Public Power District as follows:

Resolution No. 3945 Page 2

1. That the District's 1990 Plan for funding the Decommissioning of the Fort Calhoun Nuclear Power Generating Station Unit No. 1, and the Trust Agreement establishing the Fund, are hereby approved and adopted.

2. That the First National Bank of Omaha is hereby authorized to act as Trustee of the Fund pursuant to the Trust Agreement.

3. That the President or Vice President, Treasurer or Assistant Treasurer, Secretary or Assistant Secretary are hereby authorized and directed to take such actions and to execute such documents as shall be necessary and proper to implement the 1990 Plan and the Trust Agreement.

I hereby certify that the above is a true and correct copy of Resolution No. 3945 adopted by the Board of Directors of Omaha Public Power District at a meeting held on June 7, 1990.

CERTIFIED COPY OF RESOLUTION NO. 1220 WHEREAS, the Omaha Public Power District has previously adopted a Decommissioning Funding Plan and established the Decommissioning Trust to fund the estimated cost of decommissioning Fort Calhoun Station - Unit No. 1 when its operating license expires in 2008, and WHEREAS, the current Decommissioning Funding Plan uses the funding requirement of $116.5 million (1992 dollars) as provided by the Nuclear Regulatory Commission regulations, and WHEREAS, the studies recently completed by TLG Engineering produced estimates to decommission the Radiated and Non-radiated Plant at the Fort Calhoun Station, and to provide a Fuel Storage Facility, and WHEREAS, the new estimates for decommissioning the Fort Calhoun Station compare favorably to estimates of these costs for similar nuclear generating stations, and WHEREAS, it would be advisable for the District to adopt and fund a decommissioning estimate based on the recently completed TLG Engineering studies for the Radiated Plant, including contingency, and the Fuel Storage Facility in the total estimated amount of $312.0 million in 1992 dollars starting in January 1993, and WHEREAS, funding of the TLG Engineering estimates will require additional contributions to the decommissioning fund of approximately $7.0 million in 1993.

NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the Omaha Public Power District:

1. That the decommissioning estimates of TLG Engineering dated September 1992 for the Fort Calhoun Station covering the Radiated Plant plus contingency and the Fuel Storage Facility are adopted and funding of these new estimates shall commence effective January 1, 1993.

2. That Management is hereby authorized and directed to establish the appropriate funding mechanisms to accommodate the increased funding.

I hereby certify that the foregoing is a true and correct copy of Resolution No. 4220, adopted by the Board of Directors of the Omaha Public Power District at a eld October 15, 1992.

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LIC-1 1-0050 Page 1 OPPD 2011 Corporate Operating Plan O&M Expense Information

26 2011 CORPORATE OPERATING PLAN OPERATION AND MAINTENANCE EXPENSE The District's 2011 total budgeted operation and maintenance (O&M) expense is $758.1 million, which is $39.1 million or 5.4% more than the 2010 projected amount.

Fuel expense is the largest category of O&M expense, representing 35.3% of total O&M expense. Fuel expense is budgeted at $267.3 million for 2011, an increase of $14.3 million or 5.6% more than the 2010 projected amount.

Production expense represents 29.8% of the total and is budgeted to be $226.0 million in 2011, which is $7.2 million or 3.3% more than the 2010 projected amount.

Purchased power, including wind purchases, represents 5.0% of total O&M expense and is budgeted at $37.6 million for 2011. This represents a decrease of $2.0 million or 5.0% below the 2010 projected amount. This decrease includes the reduction for the prepayment for 2011 wind energy purchases in 2010.

Transmission and distribution expense represents 7.9% of total O&M expense and is budgeted at $59.6 million, which is $5.7 million or 10.5% more than the 2010 projected amount. This increase includes the cost of energy transmission through the Southwest Power Pool (SPP) of $7.1 million.

Customer accounting and services expense represents 4.9% of total O&M expense and is budgeted at $37.1 million for 2011. This represents an increase of $7.8 million or 26.4% more than the 2010 projected amount.

Administrative and general expense represents 17.1% of total O&M expense and is budgeted at $130.5 million for 2011. This category reflects an increase of $6.2 million or 5.0% greater than the 2010 projected amount.

The nuclear decommissioning fund does not require any additional funding in 2011; decommissioning cost estimate escalation is derived using IHS Global Insight - Consumer Price Index - All Urban Customers and decommissioning fund return is escalated using IHS Global Insight interest rates on Three to Five Year Government Bonds.

LIC-1 1-0050 Page 1 Board Resolution Approving the Corporate Operating Plan

Omaha Puhili Power 0Isitot Thompsoi/Easterlin RESOLUTION NO. 5845 WHEREAS, the Board of Directors has reviewed the Omaha Public Power District's 2011 Corporate Operating and Capital Expenditure Plan ("Plan"), and WHEREAS, the Plan does not include a general rate adjustment, and WHEREAS, the Plan includes the use of regulatory accounting, with Board approval, to expense a $4.2 million prepayment for 2011 wind energy in 2010 to reduce the Fuel and Purchased Power Adjustment (FPPA) from 2.6% to 2.0%, or a 2011 FPPA rate of $0.00149 per kWh, and WHEREAS, the District's consulting engineer, R. W. Beck, Inc., has reviewed the 2011 Corporate Operating and Capital Expenditure Plan, as requested by the Board of Directors, and recommends it for approval by the Board of Directors.

NOW, THEREFORE, BE IT RESOLVED that the Board of Directors of the Omaha Public Power District hereby approves the 2011 Corporate Operating and Capital Expenditure Plan.

Adopted December 16, 2010

LIC-1 1-0050 Page 1 2010 Global Insight Forecast Rates

GLOBAL INSIGHT FORECAST RATES AS OF 03/10 29-LO agJj. 2012 90-113L 201 5 2016 2017 2018 &1Q2 GROSS NATIONAL PRODUCT($) 13436 13812 14310 14751 15105 15457 15819 16099 16619 17076 GROSS NATIONAL PRODUCT (GRTH RT) 2.70 2.80 3.61 3.08 2.40 2.33 2,34 2.40 259 2.75 C.P I (ALL URBAN) GROWTH RATE 2.2 2.1 1.9 1.9 19 20 2.0 1.9 1.9 1.8 C.P.I. (WAGE EARN.)GROWTH RATE 0.90 2.76 1.96 1.97 2.06 2.27 2.06 1.81 1.86 1.55 PRIME RATE ON S.T. BUSINESS LOANS 3,3, 4.70 6.34 6.55 7 59 7 75 7.75 7.75 7.75 7.75 MONEY RATE ON COMMERCIAL PAPER 3-MTH 0.56 2.35 3.83 4.08 5.03 5.07 5.07 5.07 5.07 5.07 YIELD ON DOMESTIC MUNICIPAL BONDS-OND BUYER 4.47 4.71 5.22 5.24 5.82 585 5.85 5.85 5.85 5.85 DISCOUNT RATE - FEDERAL RES. OF N.Y. 0.58 2.07 4.22 4.55 5 59 5 75 5.75 5.75 5.75 5.75 AVE MKT YLD ON U.S. GOVT 6-MTH BILLS 0.56 2.25 3.49 3.72 466 470 4.70 4.70 4.70 4.70 AVE MKT YLD ON U.S. GOVT 10-YR BONDS 3.80 4.03 4.54 4.72 5.54 5.57 5.57 5.57 5.57 5.57 HOUSING STARTS (MILLIONS) 0.75 1.27 1.61 1.73 1 73 1.76 1.78 I 78 1.79 1.82 EFFECTIVE RATE ON FEDERAL FUNDS 0.24 1.70 3.34 3.55 4.59 4.75 4.75 4.75 4.75 4.75 WHOLESALE PRICE -COAL (GROWTH RATE) -6.26 -0.23 0.29 1.90 1.47 t.39 1.43 1.41 1.44 1.42 WHOLESALE PRICE - GAS FUELS (GROWTH RATE) -22.02 42.94 -1.74 -2.46 11.94 13.08 2.47 -2101 2.72 5.18 WHOLESALE PRICE - ELECTRICITY (GROWTH RATE) -0,22 2.93 3.17 2.08 2.04 2.35 2.00 1.87 1.78 1 85 WHOLESALE PRICE- CRUDE PET. (GROWTH RATE) -7.74 9.57 4.95 4.27 3.84 4.64 3.42 1.86 0.75 -1.37 WHOLESALE PRICE - REFINED PET. (GROWTH RATE) -0.38 7.92 4.24 3.65 3.44 3.91 3.01 1.77 0.80 -0.97 THREE-MONTH T-BILLS 0.43 2.08 3.39 3.62 4.56 4.60 4.60 4.60 4.60 4.60 ONE-YEAR T-BILLS 0.74 2.41 3.65 3.88 4.82 4.86 4.86 4.86 4.86 4.86 THREE - FIVE YEAR GOVT BONDS 2.61 3.44 4.24 4.42 5.26 5.29 5.29 5 29 5.29 5.29 OUTPUT/HOUR (NON-FARM BUSINESS SECT.) 1.52 1.53 1..54 1.55 1.57 1.60 1.63 I 66 1.70 1.74 2020 2021 2022 2023 2020 25 2021 29* 2029 GROSS NATIONAL PRODUCT($) 17559 18028 18482 18930 19391 19888 20376 20860 21343 2t831 GROSS NATIONAL PRODUCT (GRTH RT) 2.83 2.67 2.52 2.42 2.43 2.57 2.45 2.37 2.32 2.29 C.P.I, (ALL URBAN) GROWTH RATE 1.6 1.6 1.7 I 7 1.8 1.8 1.9 1.9 2.0 1.9 C.P.I, (WAGE EARN.) GROWTH RATE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 PRIME RATE ON ST. BUSINESS LOANS 7.75 7.75 7.75 7.75 7.75 7.75 7.75 7.75 7.75 7.75 MONEY RATE ON COMMERCIAL PAPER 3-MTH 5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07 YIELD ON DOMESTIC MUNICIPAL BONDS-BND BUYER 5.85 5.85 5.85 5.85 5.85 5.85 5.85 5.85 5.85 5.85 DISCOUNT RATE. FEDERAL RES. OF N.Y. 5.75 5.75 5.75 5.75 575 5.75 5.75 5.75 5.75 5.75 AVE MKT YLD ON U.S. GOVT 6-MTH BILLS 4.70 4.70 4.70 4.70 4.70 470 4.70 4.70 4.70 4.70 AVE MKT YLD ON U.S. GOVT 10-YR BONDS 5.57 5.57 5.57 5.57 5.57 5.57 5.57 5.57 5.57 557 HOUSING STARTS (MILLIONS) 1.82 I "19 1.77 1.75 1.73 1.73 1 72 I 69 1.64 1.61 EFFECTIVE RATE ON FEDERAL FUNDS 4.75 4.75 4.75 475 4.75 4.75 4.75 475 475 4.75 WHOLESALE PRICE - COAL (GROWTH RATE) 1.40 1.43 1.36 1.34 1.42 1.60 2.19 1.63 1.70 1.80 WHOLESALE PRICE -GAS FUELS (GROWTH RATE) 1.12 2.59 1.31 1.39 2.84 2.36 388 3 12 3.08 1.59 WHOLESALE PRICE - ELECTRICITY (GROWTH RATE) 1.90 1.38 1.36 1.56 145 1.64 1.78 1.62 1 88 1.84 WHOLESALE PRICE - CRUDE PET. (GROWTH RATE) -4.84 -4.93 -4.23 -3.77 -0,90 -163 -1,75 -1.64 -0.91 -0.96 WHOLESALE PRICE - REFINED PET. (GROWTH RATE) -1.53 -0.48 -0.19 0.45 2.22 1.85 1.88 2-23 2.63 2.49 THREE-MONTH T-BILLS 4.60 4.60 4.60 4.60 4.60 4.60 4.60 4.60 4.60 4.60 ONE-YEAR T-BILLS 4.86 4.86 4.86 4.86 4.86 4.86 4.86 4.86 4.86 4.86 THREE - FIVE YEAR GOVT BONDS 5.29 5.29 5,29 5.29 5.29 5.29 5.29 5.29 5.29 5.29 OUTPUT!HOUR (NON-FARM BUSINESS SECT) 1.78 1.82 1.87 1.91 1.95 2.00 2.04 2.08 2.12 2.17