LIC-25-0004, 2025 Annual Decommissioning Funding / Irradiated Fuel Management Status Report

2025 Annual Decommissioning Funding / Irradiated Fuel Management Status Report

ML25071A078
Person / Time
Site:	Fort Calhoun
Issue date:	03/11/2025
From:	Uehling T Omaha Public Power District
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
LIC-25-0004
Download: ML25071A078 (1)

Text

10 CFR 50.75 10 CFR 50.82 March 11, 2025 LIC-25-0004 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, 2025 Annual Decommissioning Funding / Irradiated Fuel Management Status Report

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 December 16, 2019 (LIC-19-0007)(ML19351E355)

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.

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 (FCS), Unit 1. 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 2025 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 Benjamin P. Pearson, Regulatory Assurance & Emergency Planning Manager, at 531-226-7249.

-~

Omaha Public Power District EMPLOYMENT WITH EQUAL OPPORTUNITY

U.S. Nuclear Regulatory Commission LIC-25-0004 Page 2 Respectfully, Timothy Uehling Senior Director Decommissioning TSU/akb

Enclosures:

1. 2025 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. G. Anderson, NRC Senior Health Physicist, Region IV

U.S. Nuclear Regulatory Commission LIC-25-0004 ENCLOSURE 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO.1 2025 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT As of December 31, 2024

U.S. Nuclear Regulatory Commission LIC-25-0004 Page 2 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2025 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT as of December 31, 2024 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 2024), the total estimated cost to decommission Fort Calhoun Station Unit No. 1 is $446,250,584 in 2024 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 $112,150,837, the current separate estimate of site restoration is

$11,533,781, and the current separate estimate of spent fuel management costs is $322,565,967.

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, 2024 was $403,660,557. 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, 2024, the balance in the fund for the NRC minimum decommissioning amount was $27,919,605. As of December 31, 2024, the balance in the funds accumulated for other decommissioning costs was $375,740,952.

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 The annual collections for 2023 and 2024 were $30,670,233, and $7,469,999, respectively. The total expected future collections for decommissioning are $0. With current assumptions the trust funds are adequately funded.

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

U.S. Nuclear Regulatory Commission LIC-25-0004 Page 3 provided the basis for the DCE inflation rate forecasts. Decommissioning costs are inflated using a blending of the Congressional Budget Offices forecasts for Consumer Price Index, All-Urban and Employment Cost Index, Total Private Compensation. Decommissioning trust earnings are projected using Barclays 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 non-bypassable charge to fund decommissioning.

F. Modifications to Method of Providing Financial Assurance There have been no modifications to OPPDs 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), 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-25-0004, Attachment A Year Type of Trust Fund Balance 2024 Decommissioning Trust '90 Plan 27,919,605 2024 Decommissioning Suppl '92 Plan 375,740,952 403,660,557 Year Decom Expenditures Spent Fuel Total 2016 574,826 574,826 2017 115,251,711 4,475,227 119,726,938 2018 83,845,046 30,408,102 114,253,148 2019 72,491,721 17,382,073 89,873,794 2020 109,969,342 39,221,912 149,191,254 2020 Cost in 2020 Dollars 2021 131,052,781 7,855,094 138,907,875 2021 Cost in 2021 Dollars 2022 138,050,637 9,667,090 147,717,727 2022 Cost in 2022 Dollars 2023 103,503,190 9,222,343 112,725,533 2023 Cost in 2023 Dollars 2024 92,756,761 5,995,173 98,751,934 2024 Cost in 2024 Dollars TOTAL 847,496,015 124,227,013 971,723,029 Year Decom Expenditures Spent Fuel Total 2024 Estimated 125,453,000 6,427,000 131,880,000 2024 Actual 92,756,761 5,995,173 98,751,934 Variance 32,696,239 431,827 33,128,066 Year Decom Expenditures Spent Fuel Total 2024 123,684,617 322,565,967 446,250,584 See Attachment B, Column 1, Annual Decommissioning Fund Collections 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 in 2021 to allow for a streamlined withdrawal process.

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

Estimated in 2024 Dollars Comments Variance:

• The variance in decommissioning expenditures is primarily attributed to two main drivers along with other miscellaneous savings throughout the project. The first is the inclusion of contingency in the DCE estimate that was not utilized in accomplishment of the work, which accounts for over half of the variance. The other main driver is a reduction in waste costs primarily due to a lower volume disposed of than projected due to an overestimation of the cumulative materials contained within containment. As noted by the updated cost estimate, the variance is not indicative of delaying costs to future years as the 2024 estimate for the remaining work is consistent with, and slightly lower than, the 2023 estimate.

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

Comments 2017 Cost in 2017 Dollars 2018 Cost in 2018 Dollars Prior Year Expenditures Variance to Estimated Cost 50.82(a)(8)(v)(B) 2016 Cost in as Spent Dollars 2019 Cost in 2019 Dollars Other Financial Assurance Methods Being Relied Upon 50.75(f)(1)

NONE Prior Years Decommissioning Expenditures 50.82(a)(8)(v)(A)

Comments Decommissioning Funding Status Report OMAHA PUBLIC POWER DISTRICT ATTACHMENT A Summary Information as of December 31, 2024 10 CFR 50.82 (a) (8) (v)-(vii)

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

Comments As of 12/31/24 As of 12/31/24

U.S. Nuclear Regulatory Commission LIC-25-0004, Attachment B Year Column 1 Total Annual Decommissioning Fund Collections1 Column 2 Earnings on Trust Funds Column 3 License Termination Expenditures Column 4 Spent Fuel Management Expenditures Column 5 Site Restoration Expenditures Column 6 Decommissioning Trust Fund Balance2 Column 7 Supplemental Decommissioning Trust Fund Balance3 2024 27,919,605 375,740,952 2025 15,022,721 91,354,087 7,799,085 11,752,724 11,757,425 296,019,957 2026 12,961,787 20,047,050 8,228,314 135,568 12,276,539 280,051,699 2027 12,929,529 58,720 10,526,109 12,829,536 281,843,402 2028 13,341,203 10,802,820 13,421,234 283,790,087 2029 13,444,428 11,085,712 14,039,884 285,530,153 2030 13,545,783 11,376,114 14,687,019 287,052,687 2031 13,635,939 11,674,147 15,363,834 288,337,664 2032 13,721,740 11,980,236 16,071,964 289,371,037 2033 13,798,013 12,294,640 16,812,908 290,133,467 2034 13,860,006 12,617,463 17,588,017 290,600,901 2035 9,051,433 12,948,939 18,115,658 286,175,755 2036 8,929,403 13,289,304 18,659,127 281,272,384 2037 8,813,187 12,317,191 19,218,901 277,208,607 2038 8,703,206 12,641,297 19,795,468 272,693,949 2039 8,580,071 12,974,107 20,389,332 267,706,048 2040 8,443,123 13,315,861 21,001,012 262,221,631 2041 8,291,677 13,666,805 21,631,043 256,216,473 2042 8,125,018 14,027,188 22,279,974 249,665,371 2043 7,942,401 14,397,271 22,948,373 242,542,101 2044 7,743,054 14,777,320 23,636,824 234,819,384 2045 7,526,172 15,167,608 24,345,929 226,468,844 2046 7,290,917 15,568,416 25,076,307 217,460,966 2047 7,036,418 15,980,034 25,828,596 207,765,061 2048 6,761,768 16,402,758 26,603,454 197,349,214 2049 6,466,027 16,836,893 27,401,557 186,180,244 2050 6,148,213 17,282,754 28,223,604 174,223,656 2051 5,807,308 17,740,664 29,070,312 161,443,592 2052 5,442,253 18,210,953 29,942,422 147,802,782 2053 5,051,947 18,693,964 30,840,694 133,262,492 2054 4,635,245 19,190,047 31,765,915 117,782,469 2055 4,190,958 19,699,561 32,718,893 101,320,888 2056 3,602,162 27,935,425 33,700,459 76,006,059 2057 2,737,490 36,913,674 34,711,473 40,818,861 2058 1,697,480 37,895,311 35,752,817 3,579,686 2059 966,886 11,287,644 2,918,269 25,368,443 725,034 2060 782,804 26,129,496 746,785 297,027,772 122,747,502 539,176,255 11,888,291 1 Annual Decommissioning Fund Collections for 2024 were $7,469,999 with Decommissioning Expenditures of $98,751,934.

2 In 2021, LTE expenses started being disbursed from the Decommissioning Trust ('90) Fund.

3 All collections and some expenditures flow through the Decommissioning Supplemental Trust through 2024. Continuing in 2025, some LTE expenses will be paid out of the Decommissioning Trust OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 2025 ANNUAL DECOMMISSIONING FUNDING STATUS REPORT ATTACHMENT B Decommissioning Fund Annual Collections, Earnings, Expenditures and Balances

U.S. Nuclear Regulatory Commission LIC-25-0004, Attachment C Inflation Earnings Year Rate Rate 2025 3.04%

4.31%

2026 2.78%

4.42%

2027 2.66%

4.50%

2028 2.62%

4.61%

2029 2.61%

4.61%

2030 2.61%

4.61%

2031 2.61%

4.61%

2032 2.61%

4.61%

2033 2.61%

4.61%

2034 2.61%

4.61%

2035-2060 2.61%

3.00%

ATTACHMENT C Decommissioning Funds Annual Inflation and Earning Rates