LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report

Annual Decommissioning Funding / Irradiated Fuel Management Status Report

ML22090A078
Person / Time
Site:	Fort Calhoun
Issue date:	03/30/2022
From:	Uehling T Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-22-0009
Download: ML22090A078 (8)

Text

March 30, 2022 LIC-22-0009 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

10 CFR 50.75 10 CFR 50.82

Subject:

Fort Calhoun Station, Unit No. 1, 2021 Annual Decommissioning Funding / Irradiated Fuel

Management Status Report

References:

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

(ML16242A127)

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

3. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), âFort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report,â dated December 16, 2019 (LIC-19-0007)(ML19351E355)

is submitting

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) the annual status of decommissioning funding, status of funding for managing irradiated fuel, and the financial assurance status report.

In References 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)..

provides the 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report.

No commitments to the NRC are made in this letter.

If you should have any questions about the enclosed reports, please contact Andrea K. Barker, Regulatory Assurance & Emergency Planning Manager, at 531-226-6051.

U.S. Nuclear Regulatory Commission LIC-22-0009 Page 2 Respectfully, Timothy Uehling Senior Director Decommissioning TSU/akb/cac

Enclosures:

1. 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report

c: S. A. Morris, NRC Regional Administrator, Region IV

J. D. Parrott, NRC Senior Project Manager S. Anderson, NRC Health Physicist, Region IV

l 6:49 PM CDTU.S. Nuclear Regulatory Commission LIC-22-0009

2022 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT

As of December 31, 2021

ENCLOSURE 1

OMAHA PUBLIC POWER DISTRICT

FORT CALHOUN STATION UNIT NO.1

U.S. Nuclear Regulatory Commission LIC-22-0009 , Attachment A Page 2

OMAHA PUBLIC POWER DISTRICT

FORT CALHOUN STATION UNIT NO. 1

2021 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT

as of December 31, 2021

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 As required by 10 CFR 50.82, OPPD completed a site-specific Decommissioning Cost Estimate (DCE),

contracting with Energy Solutions LLC for the preparation of the report. The study was performed under the DECON decommissioning alternative method. Based on the DCE (completed in 2022), the total estimated cost to decommission Fort Calhoun Station Unit No. 1 is $809,749,864 in 2021 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 $494,390,034, the current separate estimate of site restoration is $34,295,183 and the current separate estimate of spent fuel management costs is $281,058,647.

The total cost estimate reported in 2018 dollars was $1,213,203,000 in the DCE, using the SAFSTOR decommissioning alternative method 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, 2021 was $519,701,336. 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, 2021, the balance in the fund for the NRC minimum decommissioning amount was $265,007,627. As of December 31, 2021, the balance in the funds accumulated for other decommissioning costs was $254,693,709.

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 were no annual collections for 2016. The annual collections for 2017, 2018, 2019, 2020, and 2021 were $147,469,000, $156,000,000, $143,004,000, $112,552,080, and $121,148,000 respectively. The total expected future collections for decommissioning are $323,702,475 beginning in 2022 as shown in Attachment B, Column 1. The revenue source for collections is OPPD âcost-of-serviceâ electric rates.

U.S. Nuclear Regulatory Commission LIC-22-0009 , Attachment A Page 3 D. Rates Used to Escalate Decommissioning Costs and Fund Balances The rates used for the escalation of the site-specific DCE and earnings rates on the Decommissioning Fund through the completion of decommissioning are shown in Attachment C. Congressional Budget Office data provided the basis for the DCE inflation rate forecasts. Decommissioning costs are inflated using a blending of the Congressional Budget Officeâs forecasts for Consumer Price Index, All-Urban and Employment Cost Index, Total Private Compensation. Decommissioning trust earnings are projected using Barclayâs forecasted yield on 2-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 ânon-bypassable chargeâ to fund decommissioning.

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

References:

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

(ML17089A759)

2. Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk), âFort Calhoun Station

Irradiated Fuel Management Plan,â dated March 31. 2017 (LIC-17-0031) (ML17093A594)

U.S. Nuclear Regulatory Commission LIC-22-0009 , Attachment A Page 1

Decommissioning Funding Status Report

OMAHA PUBLIC POWER DISTRICT

ATTACHMENT A

Summary Information as of December 31, 2021

10 CFR 50.82 (a) (8) (v)-(vii)

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

Fund Balance

Type of Trust

Decommissioning Trust '90 Plan Decommissioning Suppl '92 Plan

265,007,627 254,693,709 519,701,336

Year 2021 2021

Other Financial Assurance Methods Being Relied Upon 50.75(f)(1)

NONE

Prior Years Decommissioning Expenditures 50.82(a)(8)(v)(A)

Year 2016 2017 2018 2019 2020 2021 TOTAL

Decom Expenditures

574,826 115,251,711 83,845,046 72,491,721 109,969,342 131,052,781 513,185,427

Spent Fuel

4,475,227 30,408,102 17,382,073 39,221,912 7,855,094 99,342,408

Prior Year Expenditures Variance to Estimated Cost 50.82(a)(8)(v)(B)

Year

Decom Expenditures

Spent Fuel

2021 Estimated 2021 Actual Variance

96,461,000 131,052,781 (34,591,781)

9,933,000 7,855,094 2,077,906

Comments

As of 12/31/21 As of 12/31/21

Comments

2016 Cost in as Spent Dollars 2017 Cost in 2017 Dollars 2018 Cost in 2018 Dollars 2019 Cost in 2019 Dollars 2020 Cost in 2020 Dollars 2021 Cost in 2021 Dollars

Total

574,826 119,726,938 114,253,148 89,873,794 149,191,254 138,907,875 612,527,835

Total

106,394,000 138,907,875 (32,513,875)

Comments

Variance:

⢠We saw higher waste disposal costs than projected for material, based on radiation activity levels or waste class, which was discovered during the work (approximately $10M)

⢠The remainder was primarily due to performing work that was planned for the following year (2022) in 2021. This included preparation for open air demolition of radiological structures.

Remaining Decommissioning Estimated Cost 50.82(a)(8)(v)(B) /(vii)(B)

Year 2022

Decom Expenditures

Spent Fuel

528,685,120

281,059,090

Total

809,744,210

Comments

Estimated in 2021 Dollars

Decommissioning Criteria Upon Which the Estimate is Based 50.75(f)(1) 50.82(a)(8)(v)(B)

DECON

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

No

Any Material Changes to Trust Agreement Since Previous Report 50.75(f)(1) 50.82(a)(8)(v)(D)

Updated the Decommissioning Trust '90 agreement to allow for a streamlined withdrawal process.

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

See Attachment B, Column 1, Annual Decommissioning Fund Collections

U.S. Nuclear Regulatory Commission LIC-22-0009 , Attachment B Page 1

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1

2022 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT

ATTACHMENT B

Decommissioning Fund Annual Collections, Earnings, Expenditures and Balances

Column 7

Column 1

Total Annual

Decommissioning Fund Collections1

Column 2

Column 3

Earnings on Trust

Funds

License Termination

Expenditures

Column 4 Spent Fuel Management Expenditures

Site Restoration Expenditures

Column 5

Decommissioning

Decommissioning

Column 6

Supplemental

Year

2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 2055 2056 2057 2058 2059 2060 2061

130,597,500 130,597,500 62,507,475

323,702,475

10,106,602 10,065,320 9,046,944 7,216,155 5,886,422 6,156,909 6,539,722 6,916,095 7,286,407 7,650,963 7,577,683 7,494,711 7,401,570 7,297,762 7,182,769 7,075,767 6,977,274 6,868,117 6,747,785 6,615,742 6,471,435 6,314,286 6,143,696 5,959,043 5,759,680 5,544,934 5,314,107 5,066,475 4,801,283 4,517,750 4,215,065 3,892,410 3,548,914 3,183,642 2,685,617 1,930,391 1,014,240 271,743 0

224,745,430

124,009,250 112,370,508 139,604,905 137,132,780 12,532,200

12,848,978

538,498,622

7,356,080 7,448,296 7,653,193 7,862,989 8,077,759 9,099,296 9,340,353 9,586,947 9,837,205 10,094,119 10,357,872 10,628,648 10,906,638 11,192,038 11,485,049 10,400,497 10,673,051 10,952,886 11,240,197 11,535,190 11,838,074 12,149,063 12,468,379 12,796,249 13,132,906 13,478,592 13,833,551 14,198,038 14,572,314 14,956,645 15,351,309 15,754,625 16,170,757 16,598,092 24,769,880 33,677,836 34,569,147 6,792,329

492,836,090

7,717,148 9,953,711 8,041,655 10,890,571 211,444

36,814,528

Trust Fund Balance2 265,007,627 181,345,635 120,226,811 59,516,593 5,140,133 5,244,688 5,359,884 5,486,312 5,624,629 5,775,563 5,939,924 6,108,963 6,282,812 6,461,608 6,645,492 6,834,610 7,029,109 7,229,143 7,434,870 7,646,452 7,864,055 8,087,850 8,318,014 8,554,728 8,798,179 9,048,557 9,306,061 9,570,893 9,843,261 10,123,381 10,411,472 10,707,762 11,012,483 11,325,876 11,648,188 11,979,672 12,320,590 12,671,209 (0)

(0)

(0)

Trust Fund Balance3 254,693,709 339,977,324 411,986,453 388,951,336 294,657,612 279,618,076 276,560,493 273,633,434 270,824,266 268,122,533 265,515,015 262,565,787 259,258,001 255,574,136 251,495,975 247,004,578 243,485,348 239,589,536 235,299,041 230,595,047 225,457,997 219,867,563 213,802,622 207,241,225 200,160,569 192,536,964 184,345,803 175,561,527 166,157,595 156,106,445 145,379,459 133,946,924 121,779,989 108,844,753 95,107,991 72,692,244 40,603,882 6,698,355 0

0 0

1 Annual Decommissioning Fund Collections for 2021 were $121,148,000.03 with Decommissioning Expenditures of $138,907,874.49.

2 In 2021, LTE expenses started being disbursed from the Decommissioning Trust ('90) Fund. The initial amount disbursed for LTE expenses was $69,444,792.48 for 2021.

3 All collections and some expenditures flow through the Decommissioning Supplemental Trust through 2021. Continuing in 2022, some LTE expenses will be paid out of the Decommissioning Trust ('90) fund.

U.S. Nuclear Regulatory Commission LIC-22-0009 Attachment C

ATTACHMENT C

Decommissioning Funds

Annual Inflation and Earning Rates

Year

Inflation Rate

Earnings

Rate

2022 2023 2024 2025 2026 2027 2028 2029 2030 2031

2032-2060

2.77%

2.74%

2.80%

2.75%

2.74%

2.72%

2.71%

2.64%

2.63%

2.60%

2.60%

1.96%

1.93%

1.86%

1.95%

2.03%

2.20%

2.36%

2.52%

2.68%

2.85%

2.85%