ML083540651
| ML083540651 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 12/19/2008 |
| From: | Price J Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 08-0754 | |
| Download: ML083540651 (11) | |
Text
Dominion Energy Kewaunee, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 December 19" 2008 Attention: Document Control Desk Serial No. 08-0754 U. S. Nuclear Regulatory Commission NL&OSfTJS RO Washington, D. C. 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION REPORT PURSUANT TO 10 CFR 50.54(bb)
The Kewaunee Power Station (KPS) operating license expires on December 21, 2013.
Pursuant to 10 CFR 50.54(bb), Dominion Energy Kewaunee, Inc. (DEK) is required to submit the program by which DEK intends to manage and provide funding for the management of all irradiated fuel until title to the irradiated fuel is transferred to the Secretary of Energy. This report is due five years prior to the current KPS license expiration (Le., by December 21, 2008). Although a license renewal application has been submitted and ac:cepted for review, this five year requirement remains in effect.
The attachment provides the DEK irradiated fuel management plan for KPS as required by 10 CFR 50.54(bb).
Please contact Mr. David A. Sommers at (804) 273-2823 if you have any questions or require additional information.
Sincerely, JAn Price ic President - Nucle~ar Engineering minion Energy Kewaunee, Inc.
Attachment - Irradiated Fuel Management Plan Commitments made in this letter: None cc: U. S. Nuclear Regulatory Commission Region III 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 NRC Senior Resident Inspector Kewaunee Power Station
Serial No. 08-0754 Docket No. 50-305 Page 2 of2 Mr. P. S. Tam NRC Project Manager Kewaunee U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. J. R. Hall NRC Senior Projject Manager U. S. Nuclear RE~gulatory Commission One White Flint North Mail Stop EBB-3,D-02M 11555 Rockville Pike Rockville, MD 20852-2738
Serial No. 08-0754 Docket No. 50-305 Attachment IRRADIATED FUEL MANAGEMENT PLAN KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
Serial No. 08-0754 Docket No. 50-305 Attachment Page 1 of 8 Irradiated Fuel Management Plan Irradiated Fuel Managl!ment Plan - Background and Introduction As stated in the cover letter, Dominion Energy Kewaunee, Inc. (DEK) is seeking renewal of the operating license for thE~ Kewaunee Power Station (KPS), currently set to expire on December 21 , 2013. Pursuant to 10 CFR 50. 54(bb), licensees of nuclear power plants that are within five years of the expiration Clf the reactor operating license must submit written notification to the Nuclear Regulatory Commission for its review and preliminary approval of the program by which the licensee intends to manage and provide funding for the management of irradiated fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U.S. Department of Energy (DOE) for ultimate disposal. DEK is submitting this plan to comply with the requirements of 10 CFR 50.54(bb).
An updated site-specific estimate of the cost to decommission KPS was recently prepared. The analysis updated the "DECON" methodology scenario from an earlier 2006 study. This updated estimate, which is bein£1 submitted as part of KPS' Report Pursuant to 10 CFR 50.75(f)(3), also identifies the estimated costs of spent fuel management associated with the selected decommissioning scenario.
Irradiated Fuel Management Plan - Updated Cost Estimate Study Assumptions The updated 2008 study reflects the following revised assumptions specific to the Irradiated Fuel Management Plan:
- Escalating costs from 2005 to 2008 dollars using aggregate annual escalation rates.
- Increasing spent fuel management costs due to the delay in the Yucca Mountain opening date from 2017 to 2020 using a revised spent fuel shipping schedule as shown in Table 3.
- Incorporating the Independent Spent Fuel Storage Installation (ISFSI) as-built Pad 1 and design information for Pad 2 that was not available at the time of the 2006 cost study into the estimated cost of demolishing the ISFSI.
Irradiated Fuel Management Plan - Summary Cost The Irradiated Fuel Management Plan 50.54(bb) cost, assuming operating license termination in 2013, is $322.5 Million iin 2008 dollars based upon the updated site specific analysis. This cost estimate is substantially higher than the cost estimate for a license termination that is assumed to occur later, due to the costs associated with maintaining the irradiated fuel for an extended period before DOE takes ownership.
Irradiated Fuel Management Plan - Major Activities The major activities, Stclrt and stop dates, and associated costs for the Irradiated Fuel Management Plan are identified in Table 1 below. Costs are included for the design and construction of Pad 2 at the ISFSI, the relocation of the spent fuel from the pool to the ISFSI, and eventual transfer of the fuel to the DOE.
Serial No. 08-0754 Docket No. 50-305 Attachment Page 2 of 8 Table 1
- Irradiated Fuel Management Plan* Summary Schedule Schedule Summary - Major Decommissioning Activities, Start & Stop Dates and Costs (2008 Dollars in millions)
Period No. IPeriod Description I Start I End Years I Total Cost B. Spent Fuel - 50.54 (bb)
Dry Period 1 Fuel Pool Island Planning and Design 12/21/2013 04/03/2015 1.28 $ 22.8 Dry Period 2 Spent Fuel Cooling and Transfer to Dry Storage 04/03/2015 12/21/2020 5.71 $ 119.4 Dry Period 3 Dry Storace* 12/21/2020 05/09/2050 29.38 $ 174.0 Dry Period 4 ISFSI Demcllition and Final Site Restoration 05/09/2050 09/12/2050 0.34 $ 6.2 Category Total 36.71 $ 322.5 KPS 50.75(f)(3) Annuul Cash Flow Analysis The 50. 75(f)(3) estimatE~ of radiological decommissioning is referenced for the purpose of this filing to show that there will be a trust fund balance that could be applied to the Irradiated Fuel Management Plan 50.54(bb) Annual Cash Flow calculations.
The annual cash flow analysis for the radiological portion of the Kewaunee decommissioning cost is contained in DEI< submittal 08-0702 dated December 19, 2008.
The 50.75(f)(3) analysis, which is also based on the recently updated decommissioning cost study, applies a 2% real rate of return during the decommissioning period and reflects the total DEK Decommissioning Trust Fund balance as of 10/31/2008. The analysis demonstrated that sufficient funding exists for the radiological portion of decommissioning per 50.75(c). Moreover, the radiological analysis projects that there will be a potential $208.5 million of available funds (in 2026 dollars) at the conclusion of the 50.75(c) radiological portion of decommissioning in 2026. This excess in funds could be applied to irradiated fuel management. While DEK affirms that all of the funds in the trust are dedicated, and holds the radiological portion of decommissioning as the first priority, it is DEK's intent to apply these potentially available remaining trust funds to the Irradiated Fuel Management Plan only after radiological decommissioning is completed.
Irradiated Fuel Managlement Plan* Annual Cash Flow Analysis The DEK annual cash flow analysis for the 50.54(bb) Irradiated Fuel Management Plan is shown in Table 2 below. This analysis assumes the "DECON" decommissioning methodology using the recently updc:lted decommissioning cost study, applies a 2% real rate of return during the decommissioning period and applies $208.5 million (in 2026 dollars) of potentially available funds, after radiological decommissioning is complete in 2026.
Additionally, Dominion has in place a Parent Support Agreement in the amount of $60 million for the purposes of supplementing DEK in the event of an operational outage lasting six months or more and for decommissioning the plant. The analysis applies this Parent Support Agreement to 50.54(bb) irradiated fuel management costs at 2013, the year that decommissioning is assumed to start.
Finally, the analysis assumes an increase in the Parent Support Agreement or other additional parental assurance in the amount of $131.8 million to be put in place in 2016, if needed, to fully fund the Irradiated Fuel Management Plan 50.54(bb) portion of decommissioning.
Serial No. 08-0754 Docket No. 50-305 Attachment Page 3 of 8 The assumptions discussed above and associated annual cash flow calculations are shown in Table 2 below:
Table 2 - Annual Cash Flow Calculation - Inputs Kewaunee - No License Renewa I Decommissioning Annual Cash Flow Analysis -Irradiated Fuel Management Plan 10 CFR 50.54{bb)
(in whole dollars)
Dates Amounts Notes Initially assumes Trust funds are for 50.75( c 1013112008 onl 0110112013 0110112016 01101/2027 2008 10/3112008 $ 322,509,110 2013 1--_6;;.::.2:..;.40:..;.%'----1Fund Growth Rate (2008-2013)* "after* tax" growth rate for DomR Trusts 1--_3;;.::.2:::.33:..;.'Io'----1Cost Esc Rate (2008
- 2013)
- Site Spec Decom cost escalation rate 1--_3;;.::.2:::.33:..;.%'----1Cost Esc Rate (2013- end of Decom)
- Site Spec Decom cost escalation rate 1-_5"".2=:33""'%=-----1Fund Growth rate (2014- end of Decom)* "after* tax" growth rate (assumes 2% Real Rate of Return)
'---_6:.;;.2:.;,40:.;,'Io=----....JDiscount Rate (Based on Corporate Treasury or Corporate Modeling)
Table 2 - Annual Cash Flow Calculations Column 1: Reflects the beginning of each year except for 2008 which reflects a partial year.
Column 2: Reflects the beginning Trust Fund balance for each year:
- Applies the $60 million existing Parent Support Agreement in 2013
- Applies an additional $131.8 million parent assurance in 2016 if needed
- Applies the $208.5 million in remaining trust funds in 2027, if needed, after radiological decommissioning is complete.
Column 3: Reflects annual earnings on funds in the trust. A 6.24% Fund growth rate is used for 2008 through 2013. A 2% real rate of return (5.233% fund growth rate less 3.233% cost escalation) is used for 2014 and after. 2008 earnings are pro-rated.
Column 4: Reflects the Irradiated Fuel Management Plan portion of the EnergySolutions updated study annual cash flows in future dollars.
Column 5: Reflects the end of year trust fund balance, after earnings are added and expenditures are subtracted, for that year.
Column 6: Reflects the Irradiated Fuel Management Plan portion of the EnergySolutions updated study annual cash flows in nominal 10/31/2008 dollars.
Serial No. 08-0754 Docket No. 50-305 Attachment Page 4 of 8 Table 2 - Annual Cash Flow Calculations (continued)
KPS Annual Summary Cash Flow - Irradiated Fuel Management Plan 50.54(bb)
(in future dollars)
Beg of Year Irradiated Fuel End of Year Irradiated Fuel Balance Earnings Expenditures Balance Expenditures Year (Future $) (Future $) (Future $) (Future $) (in 10/31/2008 $)
10/31/2008 $ - $ - $ - $ - $
01/01/2009 $ - $ - $ - $ - $
01/01/2010 $ - $ - $ - $ - $
01/01/2011 $ - $ - $ - $ - $
01/01/2012 $ - $ - $ - $ - $
01/01/2013 $ 60,000,000 $ 3,724,481 $ 625,608 $ 63,098,873 $ 533,605
$ 63,098,873 $ 3,301,649 $ 20,775,729 $ 45,624,793 $ 17,720,421 01/01/2015 $ 45,624,793 1-=$---==:...:....!.:;...:.::.,~--==::.:...J.:=~--=...:..!...:.=....:..!..:....=.::4--=~-~-=-=.~:......j 2,387,318 $ 23,887,382 $ 24,124,729 $ 19,736,487 01/01/2016 $ 155,946,621 $ 8,159,909 $ 25,999,251 $ 138,107,278 $ 20,808,735 01/01/2017 $ 138,107,278 $ 7,226,465 $ 27,151,183 $ 118,182,560 $ 21,050,245 01/01/2018 $ 118,182,560 $ 6,183,904 $ 27,891,767 $ 96,474,697 $ 20,947,296 01/01/2019 $ 96,474,697 $ 5,048,040 $ 28,447,111 $ 73,075,625 $ 20,695,392 01/01/2020 $ 73,075,625 $ 3,823,683 $ 28,863,173 $ 48,036,136 $ 20,340,569 01/01/2021 $ 48,036,136 $ 2,513,492 $ 8,758,120 $ 41,791,508 $ 5,978,792 01/01/2022 $ 41,791,508 $ 2,186,741 $ 9,013,583 $ 34,964,666 $ 5,960,513 01/01/2023 $ 34,964,666 $ 1,829,527 $ 9,282,566 $ 27,511,626 $ 5,946,176 01/01/2024 $ 27,511,626 $ 1,439,546 $ 9,543,665 $ 19,407,508 $ 5,922,000 01/01/2025 $ 19,407,508 $ 1,015,498 $ 10,325,342 $ 10,097,664 $ 6,206,421 01/01/2026 $ 528,360 $ 10,626,025 $
10,097,664 f---"-$_ _-==z.:c::..::..+-"-_---:...==..c::=-t--"' --lo.:"+-'~_....:;..,..;C":O":"'L.:...::..:......j 0 $ 6,187,157 01/01/2027 $ 208,465,523 $ 10,907,961 $ 10,499,578 $ 208,873,906 $ 5,922,100 01/01/2028 $ 208,873,906 $ 10,929,330 $ 10,838,977 $ 208,964,259 $ 5,922,100 01/01/2029 $ 208,964,259 $ 10,934,058 $ 11,189,347 $ 208,708,970 $ 5,922,100 01/01/2030 $ 208,708,970 $ 10,920,700 $ 11,551,043 $ 208,078,626 $ 5,922,100
Serial No. 08-0754 Docket No. 50-305 Attachment Page 5 of 8 Table 2 - Annual Cash Flow Calculations (continued)
KPS Annual Summary Cash Flow - Irradiated Fuel Management Plan 50.54(bb)
(in future dollars)
Beg of Year Irradiated Fuel End of Year Irradiated Fuel Balance Earnings Expenditures Balance Expenditures Year (Future $) (Future $) (Future $) (Future $) (in 10/31/2008 $)
01/01/2031 $ 208,078,626 $ 10,887,717 $ 11,924,431 $ 207,041,913 $ 5,922,100 01/01/2032 $ 207,041,913 $ 10,833,471 $ 12,309,888 $ 205,565,496 $ 5,922,100 01/01/2033 $ 205,565,496 $ 10,756,217 $ 12,707,805 $ 203,613,908 $ 5,922,100 01/01/2034 $ 203,613,908 $ 10,654,101 $ 13,118,585 $ 201,149,423 $ 5,922,100 01/01/2035 $ 201,149,423 $ 10,525,146 $ 13,542,644 $ 198,131,925 $ 5,922,100 01/01/2036 $ 198,131,925 $ 10,367,256 $ 13,980,410 $ 194,518,771 $ 5,922,100 01/01/2037 $ 194,518,771 $ 10,178,197 $ 14,432,327 $ 190,264,642 $ 5,922,100 01/01/2038 $ 190,264,642 $ 9,955,600 $ 14,898,852 $ 185,321,390 $ 5,922,100 01/01/2039 $ 185,321,390 $ 9,696,944 $ 15,380,458 $ 179,637,876 $ 5,922,100 01/01/2040 $ 179,637,876 $ 9,399,554 $ 15,877,631 $ 173,159,799 $ 5,922,100 01/01/2041 $ 173,159,799 $ 9,060,589 $ 16,390,876 $ 165,829,512 $ 5,922,100 01/01/2042 $ 165,829,512 $ 8,677,032 $ 16,920,711 $ 157,585,833 $ 5,922,100 01/01/2043 $ 157,585,833 $ 8,245,681 $ 17,467,673 $ 148,363,840 $ 5,922,100 01/01/2044 $ 148,363,840 $ 7,763,140 $ 18,032,316 $ 138,094,664 $ 5,922,100 01/01/2045 $ 138,094,664 $ 7,225,805 $ 18,615,211 $ 126,705,258 $ 5,922,100 01/01/2046 $ 126,705,258 $ 6,629,854 $ 19,216,948 $ 114,118,165 $ 5,922,100 01/01/2047 $ 114,118,165 $ 5,971,235 $ 19,838,136 $ 100,251,263 $ 5,922,100 01/01/2048 $ 100,251,263 $ 5,245,649 $ 20,479,404 $ 85,017,508 $ 5,922,100 01/01/2049 $ 85,017,508 $ 4,448,542 $ 21,141,401 $ 68,324,649 $ 5,922,100 01/01/2050 $ 68,324,649 $ 3,575,088 $ 30,466,490 $ 41,433,247 $ 8,267,000 01/01/2051 $ 41,433,247 $ 2,167,995 $ - $ 43,601,242 $
01/01/2052 $ 43,601,242 $ 2,281,436 $ - $ 45,882,678 $
01/01/2053 $ 45,882,678 $ 2,400,812 $ - $ 48,283,490 $
01/01/2054 $ 48,283,490 $ 2,526,434 $ - $ 50,809,924 $
01/01/2055 $ 50,809,924 $ 2,658,630 $ - $ 53,468,554 $
01/01/2056 $ 53,468,554 $ 2,797,743 $ - $ 56,266,297 $
01/01/2057 $ 56,266,297 $ 2,944,135 $ - $ 59,210,431 $
01/01/2058 $ 59,210,431 $ 3,098,187 $ - $ 62,308,618 $
01/01/2059 $ 62,308,618 $ 3,260,299 $ - $ 65,568,917 $
01/01/2060 $ 62,308,618 $ 3,260,299 $ - $ 65,568,917 $
50.54(bb) Cost Estimate (in 10/31/2008$) $ 322,509,110 50.54(bb) Cost Estimate (in Future $) $ 622,011,650 Remaining funds at end of 50.54(bb) (discounted to 2008 $) $ 3,260,246
Serial No. 08-0754 Docket No. 50-305 Attachment Page 6 of 8 Additionally, as noted in the cover letter, DEK has submitted an application for license renewal pursuant to 10 CFR 54. DEK anticipates that if license renewal is approved, there will be sufficient funding in the KPS decommissioning trust for the Irradiated Fuel Management without the need for additional parent support or assurance.
Irradiated Fuel Management Strategy Completion of the decommissioning process and irradiated fuel management strategy is highly dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel allocations will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions, in the order (the "queue") in which it was removed from service ("oldest fuel first allocation"). KPS's current Irradiated Fuel Management Plan is based upon:
- 1) a 2020 start date for repository operations, consistent with testimony in July 2008 from Edward Sproat, III Director of the Office of Civilian Radioactive Waste Management given to the U.S. House of Representatives that 2020 will be the earliest possible opening date for the Department of Energy's Yucca Mountain repository,1 and
- 2) the DOE's expectations for spent fuel receipt as delineated in the "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, last updated in July 2004. Optimally, DEK projects that fuel could be removed from the site as early as 2022, if the oldest fuel allocation receives the highest priority and the geologic repository is able to achieve the DOE's stated annual rate of transfer (3,000 metric tons of uranium/ year).2 The NRC requires in 10 CFR 50.54(bb) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. Interim storage of the spent fuel, until the DOE has completed the transfer, will be in the reactor bUilding storage pool and/or at an ISFSI located at KPS.
An ISFSI facility (Pad 1) is already constructed to support continued plant operations. An addition to the ISFSI facility (Pad 2) will be constructed to support spent fuel in Multi-Purpose Canisters (MPC's). For financial planning purposes, the cost to construct Pad 2 is included within the decommissioning cost reported for the Irradiated Fuel Management Plan scenario. In the assumed scenario, 1,344 assemblies are generated through the end of currently licensed operations in 2013. To maintain core off-load capability, ten MPCs are loaded during operations and placed on Pad 1. Pad 2 is constructed to permit post-shutdown dry fuel storage. The assemblies stored in the reactor building's spent fuel storage pool at the time of shutdown (1,014 fuel assemblies) are loaded into multi-purpose canisters (MPCs) and moved into modules on Pads 1 and 2 by late 2020. The detailed spent fuel shipping schedule can be found in Table 3 below:
i Congressional Testimony, Edward F. Sproat, III, Director Office of Civilian Radioactive Waste Management, U.S.
Department of Energy before the Subcommittee on Energy and Air Quality, Committee on Energy and Commerce, U.S. House of Representatives, July 15,2008.
2 U.S. Department of Energy, "Acceptance Priority Ranking & Annual Capacity Report," DOE/RW-0567, July 2004.
Serial No. 08-0754 Docket No. 50-305 Attachment Page 7 of 8 Table 3 - Spent Fuel Shipping Schedule Kewaunee Power Station Scenario 2 - Spent Fuel Shipping Schedule, Existing License and Repository Open in 2020 On-Site Transfers On-Site Inventory Off-Site Xfer Assemblies Assemblies Total Assemblies Fuel Transfered in Assemblies Assemblies in Shipped to Assemblies No. Dry from Pool to Fuel Pool in On Site DOE from Dry Year Discharged Modules Dry Storage Storage Dry Storage Storage Storage 2008 44 0 0 1,081 0 1,081 0 2009 44 2 64 1,061 64 1,125 0 2010 0 2 64 997 64 1,125 0 2011 44 0 0 1,041 128 1,169 0 2012 44 4 64 1,021 192 1,213 0 2013 121 4 128 1,014 320 1,334 0 2014 0 23 736 278 1,056 1,334 0 2015 0 1 32 246 1,088 1,334 0 2016 0 2 64 182 1,152 1,334 0 2017 0 0 0 182 1,152 1,334 0 2018 0 1 32 150 1,184 1,334 0 2019 0 1 32 118 1,216 1,334 0 2020 0 4 118 0 1,334 1,334 0 2021 0 0 0 0 1,334 1,334 0 2022 0 0 0 0 1,302 1,302 32 2023 0 0 0 0 1,238 1,238 64 2024 0 0 0 0 1,174 1,174 64 2025 0 0 0 0 1,110 1,110 64 2026 0 0 0 0 982 982 128 2027 0 0 0 0 918 918 64 2028 0 0 0 0 854 854 64 2029 0 0 0 0 790 790 64 2030 0 0 0 0 758 758 32 2031 0 0 0 0 694 694 64 2032 0 0 0 0 630 630 64 2033 0 0 0 0 566 566 64 2034 0 0 0 0 566 566 0 2035 0 0 0 0 534 534 32 2036 0 0 0 0 502 502 32 2037 0 0 0 0 470 470 32 2038 0 0 0 0 406 406 64 2039 0 0 0 0 374 374 32 2040 0 0 0 0 342 342 32 2041 0 0 0 0 310 310 32 2042 0 0 0 0 246 246 64 2043 0 0 0 0 214 214 32 2044 0 0 0 0 182 182 32 2045 0 0 0 0 150 150 32 2046 0 0 0 0 118 118 32 2047 0 0 0 0 54 54 64 2048 0 0 0 0 22 22 32 2049 0 0 0 0 0 0 22 2050 0 0 0 0 0 0 0 Total Number MPCs 42 No. Post SID MPCs for fuel assemblies 32 No. Post SID MPCs for GTCC 1 Number MPCs Required During Operation 10 In the event that KPS does permanently cease operations in 2013, DEK will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and ISFSI under the DECON decommissioning scenario selected. In addition, DEK will also comply with
Serial No. 08-0754 Docket No. 50-305 Attachment Page 8 of 8 applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued storage of irradiated fuel.
At shutdown, the spent fuel pool is expected to contain freshly discharged assemblies from the most recent refueling cycles. Over the next five and one-half years the assemblies are packaged into MPCs for transfer to dry storage. It is assumed that the five and one-half years provides the necessary cooling period for the final core to meet the decay heat requirements for the dry cask storage system. Once the pool is emptied, the reactor building and the spent fuel storage and handling facilities are decommissioned. After all fuel has been transferred to dry storage, the annual cost to maintain the ISFSI and transfer fuel to the DOE is estimated at approximately $5.9 million annually in 2008 dollars.
Additional Considerations As stated previously, DEK is seeking renewal of the operating license for KPS. With the potential for an additional 20 years of fund growth, there is a corresponding and significant decrease in the earning requirements. DEK fully expects that the Irradiated Fuel Management Plan costs will be fully funded without parent assurance once license renewal is approved and factored into the calculations.