LIC-18-0009, Independent Spent Fuel Storage Installation - 2018 Annual Decommissioning Funding I Irradiated Fuel Management Status Report, and 2018 Triennial Omaha Public Power District Nuclear Decommissioning Funding Plan

Independent Spent Fuel Storage Installation - 2018 Annual Decommissioning Funding I Irradiated Fuel Management Status Report, and 2018 Triennial Omaha Public Power District Nuclear Decommissioning Funding Plan

ML18088B376
Person / Time
Site:	Fort Calhoun
Issue date:	03/29/2018
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-18-0009
Download: ML18088B376 (17)

Text

10 CFR 50.75 10 CFR 50.82 10 CFR 72.30 March 29, 2018 LIC-18-0009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

Fort Calhoun Station, Unit No. 1, 2018 Annual Decommissioning Funding I Irradiated Fuel Management Status Report, and 2018 Triennial Omaha Public Power District (OPPD)

Nuclear Decommissioning Funding Plan for the Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI)

References:

1. Letter from OPPD (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067)

(ML16242A127)

2. Letter from OPPD (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Removal of Fuel from the Removal of Fuel from the Reactor Vessel," dated November 13, 2016 (LIC-16-0074) (ML16319A254)

3. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated March 31, 2017 (LIC-17-0033)(ML17089A759)

4. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), "Fort Calhoun Station Irradiated Fuel Management Plan," dated March 31. 2017 (LIC-17-0031) (ML17093A594)

5. Letter from USNRC (J. S. Kim) to OPPD (M. J. Fisher) "Fort Calhoun Station, Unit 1-Review of Post-Shutdown Decommissioning Activities Report (CAC NO. MF9536; EPID 1-2017-LLL-0008)," dated March 23, 2018 (NRC-18-018) (ML18011A687)

In accordance with 10 CFR 50.75(f)(1), 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vi), and 10 CFR 50.82(a)(8)(vii), Omaha Public Power District (OPPD) is submitting the annual status of decommissioning funding, status of funding for managing irradiated fuel, and the financial assurance status report.

444 South 161h Street Mall Omaha, NE 68102-2247

U.S. Nuclear Regulatory Commission L1 C-18-0009 Page 2 In Reference 1 and 2, OPPD certified permanent cessation of power operation and permanent removal of fuel from the reactor vessel for the Fort Calhoun Station, Unit 1, (FCS). In Reference 3, OPPD submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) containing a site-specific Decommissioning Cost Estimate (DCE) pursuant to 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). In Reference 4, OPPD submitted its Irradiated Fuel Management Plan as required by 10 CFR 50.82(a)(4)(i). In Reference 5, the NRC found that the PSDAR contained the necessary information required by 10 CFR 50.82(a)(4)(i) and was consistent with the guidance of Regulatory Guide 1.185, revision 1. provides the 2018 Annual Decommissioning Funding I Irradiated Fuel Management Status Report. In accordance with 10 CFR 72.30, Enclosure 2 provides OPPD's 2018 Triennial Nuclear Decommissioning Funding Plan (DFP) for the Fort Calhoun Station (FCS) ISFSI.

No commitments to the NRC are made in this letter.

If you should have any questions about the enclosed reports, please contact Mr. Bradley H. Blome, Director Licensing & Regulatory Assurance, at 402-533-6041 .

Respectfully,

~~fl~

Mary J. Fisher Senior Director Fort Calhoun Station Decommissioning MJFiepm

Enclosures:

1. 2018 Annual Decommissioning Funding I Irradiated Fuel Management Status Report

2. 2018 Triennial Omaha Public Power District (OPPD) Nuclear Decommissioning Funding Plan for the Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI) c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager J. D. Parrott, NRC Senior Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV

U.S. Nuclear Regulatory Commission LIC-18-0009 ENCLOSURE 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT N0.1 2018 ANNUAL DECOMMISSIONING FUNDING /IRRADIATED FUEL MANAGEMENT STATUS REPORT As of December 31 , 2017

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment A Page 2 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT N0.1 2018 ANNUAL DECOMMISSIONING FUNDING /IRRADIATED FUEL MANAGEMENT STATUS REPORT as of December 31,2017 10 CFR 50.75 (f) and 50.82(8)

As required by 10 CFR 50.75 (f) and 50.82(8), OPPD reports the following information:

A. Current Decommissioning Cost Estimate Pursuant to 10 CFR 50.75(c), the 2018 estimated NRC minimum decommissioning amount to decommission Fort Calhoun Station Unit No 1 is $419,596,000. See Attachment A for the detailed decommissioning cost calculation and Attachment B for the applicable indices. Although required by 50.75(c) OPPD does not use this calculation for any other decommissioning cost estimates or evaluations. The estimate is superseded by the requirements of 10 CFR 50.82(8). Additional reporting requirements required by 10 CFR 50.82(8) are documented in Attachment C.

As required by 10 CFR 50.82, OPPD has completed a site-specific decommissioning cost analysis.

Based on the decommissioning cost analysis (completed in 2018), the total estimated cost to decommission Fort Calhoun Station Unit No. 1 is $1,295,453,000 in 2017 dollars. Of that total cost estimate, the current site-specific cost estimate for license termination expenses (LTE) of Fort Calhoun Station Unit No. 1 is $882,212,000, the current separate estimate of site restoration is $47,979,000 and the current separate estimate of spent fuel management costs is $365,262,000.

The total cost estimate was reported as $1.383 billion (2016 dollars) in the Decommissioning Cost Estimate as required by 10 CFR 50.82(a)(8)(iii) (reference 1). The cost estimate included monies anticipated to be spent for operating license termination (radiological remediation), interim spent fuel storage and site restoration activities.

B. Current Decommissioning Fund Balance The total OPPD Decommissioning Fund(s) balance as of December 31, 2017 was $421,257,000. 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 consultant cost study. As of December 31, 2017, the balance in the fund for the NRC minimum decommissioning amount was $294,458,000. As of December 31, 2017, the balance in the funds accumulated for other decommissioning costs was $126,799,000.

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.

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment A Page 3 C. Annual Decommissioning Collections There were no annual collections for 2016. The annual collection for 2017 was $147,469,000. The total expected future collections for decommissioning are $838,556,000 beginning in 2018 as shown in Attachment D, Column 1. The revenue source for collections is OPPD "cost-of-service" electric rates.

D. Rates Used to Escalate Decommissioning Costs and Fund Balances The rates used for the escalation of the site-specific decommissioning cost estimate and earnings rates on the Decommissioning Fund through the completion of decommissioning are shown in Attachment E.

IHS Global Insight, Inc. provides the basis for the decommissioning cost estimate inflation and earnings rate forecasts. Decommissioning costs are inflated using a blending of the IHS Global Insight's forecasts for Consumer Price Index, All-Urban and Employment Cost Index, Total Private Compensation.

Decommissioning trust earnings are projected using the IHS Global Insight's forecast for the yield on 5-year Treasury notes.

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 The Decommissioning Funding Plan Trust Agreement previously had a fund audit to cover the period July 1 through June 30. To align the Decommissioning Trust Fund audit with Omaha Public Power District's audit, the audit period for the Trust Fund was changed to January 1 through December 31. This change became effective January 1, 2018.

Additionally, the Trust Agreement previously stated Omaha Public Power District would submit to the NRC an annual accounting statement received from the Trustee on an annual basis. The Trust Agreement was changed to state that Omaha Public Power District will submit an annual accounting statement when requested by the NRC.

References:

1. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated March 31, 2017 (LIC 17 0033)

(ML17089A759)

2. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), "Fort Calhoun Station Irradiated Fuel Management Plan," dated March 31. 2017 (LIC-17-0031) (ML17093A594)

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment A Page 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO.1 2018 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT A 2018 Escalation of the Minimum Decommissioning Amount (MDA) Estimate for Fort Calhoun Station Unit No. 1 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 (0.65L + 0.13E + 0.22B)

Where: "L" is the Labor factor. The Labor factor is obtained from the "Employment Cost Indexes",

published by the U. S. Department of Labor- Bureau of Labor Statistics. Specifically, the appropriate regional data from the table entitled "Employment Cost Index for total compensation, for private industry workers, by bargaining status, census region and division, and metropolitan area status" should be used. In OPPD's case, data from the Midwest Region is to be used.

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

0.58P + 0.42F = 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.

"8" 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.

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment A Page 2 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 (0.65L + 0.13E + 0.22B)

Where "L", "E", and "B" =

"L" = Labor Index Change Employment Cost Index -Private Industry Workers - Total Compensation Midwest Region (Quarterly Basis Increase) 12-2005 Base Lx 2.08 12-2017 ECI 128.5 Lx = 2.08 X (128.5/1 00) = 2.67% increase "E" = Energy Index Change Energy Index Change = (Electric Power Index Change X 58%) +

(Light Fuel Oils Index Change X 42%)

Producer Price Indices Industrial Electric Power 12-2017 240.8 = 110.9% increase 1-1986 114.2 Light Fuel Oils 12-2017 178.0 = 117.1% increase 1-1986 82.0 Application of the formula to 12-2017 leads to Energy = ((240.8/114.2) X .58)+ ((178.0/82.0) X .42)

Energy = 1.223 + 0.912 Energy = 2.14 (an increase of 114.0%)

"B" =Waste Burial Index Change NUREG-1307 (Revision 16)

The Waste Burial escalation factor is found in Nuclear Regulation NUREG-1307 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 3-17 12.471 = 12.471 (an increaseof1147.1%)

(Waste Vendor Index) 1-86 1.00

U.S. Nuclear Regulatory Commission Ll C-18-0009 , Attachment A Page 3 The escalated cost formula is as follows:

Generic LLW Disposal Site Index

$88.2 million x (0.65(2.67) + 0.13(2.14) + 0.22(12.471)) = $419.596 million In summary, OPPD's Fort Calhoun Station Unit No. 1 NRC Minimum Decommissioning Amount estimate escalated to 2017 is $419,596,000.

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment B Page 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2018 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT B U.S. Department of Labor Bureau of Labor Statistics Employment Cost Index Series ID: CIU20100000002301 (B)

Not seasonally adjusted Total compensation for Series

Title:

private industry workers in Midwest, Index Ownership: Private industry workers Component: Total compensation Occupation: All workers Industry: All workers Subcategory: All workers Area: Midwest Region Periodicity: Index number Qtr4 2017 128.5 Producer Price Index- Commodities Series ID: WPU0543 Not seasonally adjusted Fuels & related products &

Group:

power Item: Industrial electric power Base Date: 198200 2017 Ann Avg 240.8(P)

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

Group:

power Item: Light fuel oi Is Base Date: 198200 2017 Ann Avg 178.0(P)

U.S. NRC- Report on Waste Burial Charges NUREG-1307, Rev. 16 Published: March 2017 Values for Generic LLW Disposal Site Direct Disposal with Vendors- PWR 2016 12.471

U.S. Nuclear Regulatory Commission L1 C-18-0009 , Attachment C Page 1 Decommissioning Funding Status Report OMAHA PUBLIC POWER DISTRICT ATTACHMENT C Summary Information as of December 31, 2017 10 CFR 50.82 (a) (8) (v)-(vii)

Decommissioning Trust Fund Balances 50.75(f)(1) 50.82(a)(8)(v)(A)

Year Type of Trust Fund Balance Comments 2017 Decommissioning Trust '90 Plan $ 294,458,649 k3 of 12/31/17 2017 Decommissioning Suppl '92 Plan $ 126,798,726 k3 of 12/31/17

$ 421,257,375 Other Financial Assurance Methods Being Relied Upon 50.75(f)(1)

NONE Prior Years Decommissioning Expenditures 50.82(a)(S)(v)(A)

Year Decom Expenditures Spent Fuel Total Comments 2016 $ 574,826 $ - $ 574,826 2016 Cost in as Spent Dollars 2017 $ 115,251,711 $ 4,475,227 $ 119,726,938 2017 Cost in 2017 Dollars

$ 115,826,537 $ 4,475,227 $ 120,301 '764 Prior Year Expenditures Variance to Estimated Cost 50.82(a)(B)(v)(B)

Year Decom Expenditures Spent Fuel Total Comments 2017 Estimated $ 135,676,000 $ 26,311,758 $ 161,987,758 2017 Actual $ 115,251,711 $ 4,475,227 $ 119,726,938

$ (20,424,289) $ (21,836,531) $ (42,260,820)

Variance: License Termination and Spent Fuel rvlanagement due to timing of activities.

Remaining Decommissioning Estimated Cost 50.82(a)(B)(v)(B) /(vii)(B)

Year Decom Expenditures Spent Fuel Total Comments 2018 $ 930,191,000 $ 365,262,000 $ 1,295,453,000 Estimated in 2017 Dollars Decommissioning Criteria Upon Which the Estimate is Based 50.75(f)(1) 50.82(a)(8)(v)(B)

SAFSTOR lvly Modification to Method of Providing Financial Assurance 50.75(f)(1) 50.82(a)(8)(v)(C)

NONE lvly Material Changes to Trust Agreement Since Previous Report 50.75(f)(1) 50.82(a)(8)(v)(D)

No material chanqes. See Section G.

Need for Additional Financial kssurance 50.75(f)(1) 50.82(a)(8)(vi) (vii)(C)

See Attachment D, Column 1, Annual Decommissioninq Fund Collections

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment D Page 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT N0.1 2018 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT ATTACHMENT D Decommissioning Fund Annual Collections, Earnings, Expenditures and Balances Column 7 Column 1 Col"mn 4 Column 6 Supplemental Total Annual Column 2 Column 3 Spent Fuel Column 5 Decommissioning Decommissioning Dec om miss ioning Earnings on Trust License Termination Mmagement Site Restoration Trust Fund Trust Fund 2 3 Year Fund Collections Funds Expenditures Expenditures Expenditures Balance Balance 2017' $ $ 294,458,649 $126,798,726 2018 $ 156,000,000 $ 12,737,491 $ 66,797,768 $ 34,050,302 $ $ 301,867,293 $187,279,503 2019 $ 143,000,000 $ 17,397,720 $ 62,123,139 $ 45,959,269 $ $ 311,167,234 $230,294,874 2020 $ 150,000,000 $ 20,308,672 $ 64,323,667 $ 47,587,121 $ $ 321,276,353 $278,583,639 2021 $ 155,000,000 $ 24,340,819 $ 6,781,302 $ 7,628,119 $ $ 657,172,331 $107,619,060 2022 $ 150,000,000 $ 29,586,317 $ 7,010,487 $ 7,885,924 $ $ 673,396,973 $256,084,323 2023 $ 84,556,000 $ 33,118,066 $ 7,246,250 $ 8,151,128 $ $ 689,159,250 $342,598,734 2024 $ $ 34,570,315 $ 7,505,011 $ 8,439,715 $ $ 704,798,466 $345,585,107 2025 $ $ 34,680,357 $ 7,723,181 $ 8,687,616 $ $ 720,400,223 $348,252,911 2026 $ $ 34,839,606 $ 7,959,326 $ 8,953,250 $ $ 735,983,515 $350,596,648 2027 $ $ 35,522,612 $ 8,193,149 $ 9,216,271 $ $ 751,910,532 $352,782,822 2028 $ $ 36,111,671 $ 8,451,793 $ 9,504,413 $ $ 768,100,307 $354,748,513 2029 $ $ 36,697,899 $ 8,670,731 $ 9,753,491 $ $ 784,598,079 $356,524,418 2030 $ $ 37,291,527 $ 8,914,479 $ 10,027,677 $ $ 801,391 '730 $358,080,136 2031 $ $ 37,887,567 $ 9,160,984 $ 10,304,965 $ $ 818,488,220 $359,405,264 2032 $ $ 38,485,034 $ 9,435,948 $ 10,611,138 $ $ 835,868,594 $360,462,839 2033 $ $ 39,084,572 $ 9,664,516 $ 10,871,375 $ $ 853,589,374 $361,290,740 2034 $ $ 39,686,775 $ 9,922,251 $ 11,161,295 $ $ 871,632,120 $361,851,223 2035 $ $ 40,290,679 $ 10,183,683 $ 11,455,374 $ $ 890,003,708 $362,131 ,257 2036 $ $ 40,878,650 $ 10,476,542 $ 12,780,339 $ $ 908,683,012 $361,073,723 2037 $ $ 41,495,390 $ 9,398,889 $ 11,669,307 $ $ 929,073,256 $361 '11 0,673 2038 $ $ 42,176,995 $ 9,638,615 $ 10,916,088 $ $ 949,891 '750 $361,914,471 2039 $ $ 42,872,009 $ 9,884,603 $ 11,732,578 $ $ 971 '146 ,237 $361,914,814 2040 $ $ 43,553,187 $ 10,167,696 $ 12,616,400 $ $ 992,813,362 $361,016,780 2041 $ $ 44,247,687 $ 10,396,787 $ 11,774,746 $ $ 1,014,961,621 $360,944,675 2042 $ $ 44,965,805 $ 10,664,094 $ 12,077,481 $ $ 1,037,568,047 $360,562,479 2043 $ $ 45,688,501 $ 10,939,800 $ 12,389,729 $ $ 1,060,639,196 $359,850,301 2044 $ $ 46,414,169 $ 11,257,916 $ 12,745,494 $ $ 1,084,147,235 $358,753,022 2045 $ $ 47,143,556 $ 11,514,945 $ 13,041,101 $ $ 1 '1 08,168,665 $357,319,101 2046 $ $ 47,877,424 $ 11,812,597 $ 13,378,203 $ $ 1 '132,679, 118 $355,495,272 2047 $ $ 48,603,448 $ 12,116,910 $ 14,382,225 $ $ 1,157,687,931 $352,590,774 2048 $ $ 49,319,388 $ 12,466,769 $ 14,790,443 $ $ 1 '183, 165,256 $349,175,624 2049 $ $ 50,047,262 $ 12,749,257 $ 14,439,005 $ $ 1,209,194,781 $346,005,099 2050 $ $ 50,765,502 $ 13,077,700 $ 16,236,780 $ $ 1,235,748,202 $340,902,700 2051 $ $ 51,484,032 $ 13,414,604 $ 15,192,535 $ $ 1,262,834,183 $336,693,612 2052 $ $ 52,236,756 $ 13,801,932 $ 14,874,256 $ $ 1,290,419,018 $332,669,345 2053 $ $ 52,977,032 $ 14,114,674 $ 16,753,481 $ $ 1,318,594,962 $326,602,278 2054 $ $ 53,692,483 $ 14,478,292 $ 17,185,079 $ $ 1,347,329,778 $319,896,574 2055 $ $ 54,404,968 $ 14,851,278 $ 17,627,797 $ $ 1,376,632,361 $312,519,884 2056 $ $ 55,112,183 $ 15,280,089 $ 18,128,135 $ $ 1,406,464,676 $304,391,528 2057 $ $ 55,800,716 $ 15,626,324 $ 19,401,056 $ $ 1,436,928,116 $294,701,425 2058 $ $ 56,469,891 $ 16,028,885 $ 19,931,253 $ $ 1,467,986,223 $284,153,071 2059 $ $ 54,971,835 $ 165,584,123 $ $ 2,316,320 $ 1,348,048,403 $291 '162,282 2060 $ $ 48,663,482 $ 320,544,678 $ $ 4,368,244 $ 1,066,644,510 $296,316,736 2061 $ $ 38,786,842 $ 367' 125,249 $ $ 4,726,794 $ 728,619,459 $301,276,587 2062 $ $ 29,820,666 $ 241,755,264 $ $ 8,145,992 $ 506,891,112 $302,924,345 2063 $ $ 22,462,277 $ 247,983,299 $ $ 8,355,846 $ 271 ,525,498 $304,413,089 2064 $ $ 15,300,078 $ 217,240,934 $ $ 6,036,241 $ 59,652,773 $308,308,717 2065 $ $ 10,315,373 $ 59,905,583 $ $ 49,951,582 $ 725,894 $267,693,805 2066 $ $ 7,354,897 $ 577,387 $ $ 89,874,910 $ 162,914 $185,159,385

$ 838,556,000 $ 2,224,943,380 $ 604,311,949 $ 173,775,928 Annua I Decommissioning Fund Collections for 2017 were $147,469,000 with De com missio ni ng Expenditures of $119,727,000.

In 2021, a lump sum of $324,350,000 will be transferred from the Decommissioning Supplemental Trust to fund the Decommissioning Trust All collections and expenditures flow through the Decommi~oning Supplemental Trust through 2023

U.S. Nuclear Regulatory Commission LIC-18-0009 , Attachment E Page 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO.1 2018 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT E Decommissioning Funds Annual Inflation and Earning Rates Inflation Earnings Year Rate Rate 2018 2.67% 2.84%

2019 2.90% 3.43%

2020 3.26% 3.62%

2021 3.36% 3.63%

2022 3.38% 3.55%

2023 3.36% 3.44%

2024 3.30% 3.38%

2025 3.18% 3.33%

2026 3.06% 3.29%

2027 2.94% 3.30%

2028 2.88% 3.30%

2029 2.86% 3.30%

2030 2.81% 3.30%

2031 2.77% 3.30%

2032 2.73% 3.30%

2033 2.69% 3.30%

2034 2.67% 3.30%

2035 2.63% 3.30%

2036 2.60% 3.30%

2037 2.57% 3.30%

2038 2.55% 3.30%

2039 2.55% 3.30%

2040 2.55% 3.30%

2041 2.56% 3.30%

2042 2.57% 3.30%

2043 2.59% 3.30%

2044 2.60% 3.30%

2045 2.59% 3.30%

2046-2066 2.58% 3.30%

U.S. Nuclear Regulatory Commission LIC-18-0009 ENCLOSURE 2 FORT CALHOUN STATION UNIT N0.1 2018 TRIENNIAL OMAHA PUBLIC POWER DISTRICT (OPPD)

NUCLEAR DECOMMISSIONING FUNDING PLAN FOR THE FORT CALHOUN STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

U.S. Nuclear Regulatory Commission Ll C-18-000 9 Page 2 Omaha Public Power District (OPPD)

Nuclear Decommissioning Funding Plan (DFP) for the Fort Calhoun Station (FCS)

Independent Spent Fuel Storage Installation (ISFSI)

The U.S. Nuclear Regulatory Commission (NRC) published the Decommissioning Planning final rule in the Federal Register on June 17, 2011 (76 FR 35512) which adds reporting requirements for a DFP for holders and applicants of both general and specific licenses under 10 CFR part 72. This rule was effective December 17, 2012. OPPD provides the following information required by 10 CFR 72.30(b) to be included in the DFP:

Requirement 1:

( 1) Information on how reasonable assurance will be provided that funds will be available to decommission the ISFSI or MRS.

Information for Requirement 1:

Pursuant to 10 CFR 72.30(e)(5), since OPPD is a reactor licensee under 10 CFR 50, OPPD utilizes the method of 10 CFR 50. 75{b) and (e) to provide financial assurance for decommissioning at FCS (external sinking fund).

Requirement 2:

(2) A detailed cost estimate for decommissioning, in an amount reflecting :

(i) The cost of an independent contractor to perform all decommissioning activities ;

(ii) An adequate contingency factor; and (iii) The cost of meeting the § 20.1402 of this chapter criteria for unrestricted use, provided that, if the applicant or licensee can demonstrate its ability to meet the provisions of § 20.1403 of the chapter, the cost estimate may be based on meeting the§ 20.1403 criteria.

Information for Requirement 2:

In Reference 1, OPPD submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) containing a site-specific Decommissioning Cost Estimate (DCE) pursuant to 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). In Reference 2, the NRC found that the PSDAR contained the necessary information required by 10 CFR 50.82(a)(4)(i) and was consistent with the guidance of Regulatory Guide 1.185, revision 1.

The cost estimate for decommissioning the ISFSI reflects: 1) the cost of an independent contractor performing the decommissioning activities; 2) an adequate contingency factor; and 3) the cost of meeting the criteria for unrestricted use. The cost of the disposition of this material, as well as the demolition of the ISFSI facility, is included in the estimate. The cost summary for decommissioning the ISFSI is presented in Attachment A.

U.S. Nuclear Regulatory Commission LIC-18-0009 Page 3 Requirement 3:

(3) Identification of and justification for using the key assumptions contained in the DCE.

Information for Requirement 3:

The ISFSI decommissioning costs were updated for the Fort Calhoun Station and prepared in February 2018. There are no additional key assumptions other than discussed in Requirement 2 above. The cost summary for decommissioning the ISFSI is presented in Attachment A.

Requirement 4:

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of th is section, including means for adjusting cost estimates and associated funding levels periodically over the life of the facility.

Information for Requirement 4:

As indicated in the information for Requirement 1, OPPD utilizes the method of 10 CFR 50. 75(b) and (e) to provide financial assurance for decommissioning the Fort Calhoun Station. OPPD adjusts the amount of financial assurance required by 10 CFR 50. 75(b) annually in accordance with paragraph (2) of that section, and further adjustment is required by 10 CFR 50. 75(f) annually as the FCS is decommissioning per 10 CFR50.82.

In addition, OPPD is an electric utility and, as such , can rely solely on the external sinking fund in accordance with 10 CFR 72 .30(e)(5). Cost estimates will be adjusted annually and plans submitted to NRC as required by 10 CFR 72.30(c). Per Nebraska State code OPPD is a rate setting authority and funding levels are periodically adjusted through rate recovery.

Requirement 5:

(5) The volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination.

Information for Requirement 5:

There is no known subsurface material containing residual radioactivity in the proximity of the ISFSI that will require remediation to meet the criteria for license termination.

Requirement 6:

(6) A certification that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning .

Information for Requirement 6:

In accordance with 10 CFR 72.30(b), financial assurance, for decommissioning, has been provided in an amount that meets or exceeds the requirements of 10 CFR 50.75(b ). As demonstrated in Requirement 4, this provides the requisite financial assurance for the ISFSI decommissioning cost.

U.S. Nuclear Regulatory Commission L1 C-18-0009 Page 4 10 CFR 72.30(c)(1)-(4) requires the following additional information:

Requirement 1:

(1) spills of radioactive material producing additional residual radioactivity in onsite subsurface

material, Information for Requirement (1)

1. No spills of radioactive material producing additional residual radioactivity in onsite subsurface material have occurred.

Requirement (2):

(2) facility modifications, Information for Requirement (2):

2. Facility modifications that affected the ISFSI , including those that were implemented within the licensed area, were assessed and had no impact.

Requirement 3:

(3) changes in authorized possession limits, Information for Requirement (3):

3. There were no changes in authorized possession limits.

Requirement 4:

(4) actual remediation costs that exceed the previous cost estimate.

Information for Requirement (4):

4. No active decommissioning of the ISFSI has occurred. Thus, there have not been any actual remediation costs that exceed the previous cost estimate.

REFERENCES:

1. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated March 31, 2017 (LIC-17-0033)(ML17089A759)

2. Letter from USNRC (J. S. Kim) to OPPD (M. J. Fisher) "Fort Calhoun Station, Unit 1-Review of Post-Shutdown Decommissioning Activities Report (CAC NO. MF9536; EPID 1-2017-LLL-0008),"

dated March 23, 2018 (NRC-18-018) (ML18011A687)

U.S. Nuclear Regulatory Commission LIC-18-0009 Attachment A OMAHA PUBLIC POWER DISTRICT ISFSI Decommissioning Cost Estimate Attachment A (thousands of 2017 dollars}

Burial Oversight llRW Removal Packaging Transport Volume Craft and Disposal Other Costs Total Costs Costs Costs Costs Class A Manhours Contractor Costs Activity Description (cubic feet) Manhours Decommissioning Contractor Planning (characterization, specs and procedures) . 186 186 1,000 Decontamination (activated disposition) 34 96 362 2,721 3,213 13,829 212 License Termination (radiological surveys) . . 724 724 i 5,327 Subtotal 34 96 362 2,721 910 4,122 13,829 ' 5,539 1,000 Supporting Costs NRC and NRC Contractor Fees and Costs . 352 352 776 Insurance 137 137 Property taxes 7 7 Corporate A&G 224 224 Non-labor Overhead 146 146 .

Security Staff Costs 219 219 4,9S8 Oversight Staff Costs 258 258 3,761 Subtotal . . 1,343 1,343 9,495 Total (w/o contingency) 34 96 362 2,721 2,252 5,465 13,829 5,539 10,495 Total (w/25% contingency) 43 120 452 3,401 2,815 6,831 The application of contingency (25%) is consistent with the evaluation criteria referenced by the NRC in NUREG-1757 ("Consoli dated Decommissioning Guidance, Financial Assurance, Recordkeeping, and Timelin ess, "U.S. NRC's Office of Nuclear Material Safety and Safeguards, NUREG-1757, Vol.3, Rev.1, February 2012)