LIC-15-0047, Biennial Decommissioning Funding Status Report & Omaha Public Power District (OPPD) Nuclear Decommissioning Funding Plan for Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI)

Biennial Decommissioning Funding Status Report & Omaha Public Power District (OPPD) Nuclear Decommissioning Funding Plan for Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI)

ML15090A763
Person / Time
Site:	Fort Calhoun
Issue date:	03/31/2015
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-15-0047
Download: ML15090A763 (12)

Text

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UPiiU Omaha Public Power Oislrict 444 South ttfh Street Mall Omaha, NE 68102-2247 March 31, 2015 LIC-15-0047 10 CFR 50.75 10 CFR 72.30 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, 2015 Biennial Decommissioning Funding Status Report and Omaha Public Power District (OPPD) Nuclear Decommissioning Funding Plan for the Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI)

In accordance with 10 CFR 50.75(f), Enclosure 1 provides the, 2015 Biennial Decommissioning Funding Status Report. In accordance with 10 CFR 72.30, Enclosure 2 provides OPPD's 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. John W. Thurber at (402) 636-3056.

Respectfully, Louis P. Cortopassi Site Vice President and CNO LPC/mle

Enclosures:

1. 2015 Biennial Decommissioning Funding Status Report

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

Employment with Equal Opportunity

LIC-15-0047 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT N0.1 2015 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT As of March 25, 2015

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT N0.1 2015 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT As of March 25, 2015 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, 2015 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 2015 estimated NRC m1mmum decommissioning amount to decommission Fort Calhoun Station Unit No. 1 is

$436,054,000. See Attachment A for the 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 (completed in 2013), the total estimated cost to decommission Fort Calhoun Station Unit No. 1 is $878,295,000 in 2014 dollars. Of that total cost estimate, the current site-specific cost estimate for radiological decommissioning of Fort Calhoun Station Unit No. 1 is $614,806,000, the current separate estimate of site restoration is $48,306,000 and the current separate estimate of spent fuel management costs is $215,183,000.

The total cost estimate was reported as $755,467,000 in the 2013 Biennial Decommissioning Funding Status report.

B. Current Decommissioning Fund Balance The total OPPD Decommissioning Fund balance as of December 31, 2014 was

$364,096,000. 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, 2014, the balance in the fund for the NRC minimum decommissioning amount was $275,729,000. As of December 31, 2014, the balance in the funds accumulated for other decommissioning costs was $88,367,000. This balance is allocated as follows: $35,347,000 for additional radiological costs, $9,720,000 for site restoration costs and $43,300,000 for spent fuel management costs.

Omaha Public Power District 2015 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 2013 or 2014 and no expected future collections as of 2014 for the NRC minimum decommissioning amount as shown in Attachment C. The District restarted funding the supplemental decommissioning fund in 2014. The 2014 funding amount was $3.4 million and the 2015 funding amount is $7.7 million 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 through the license expiration in August 2033 are shown in Attachment C. Global Insight, Inc. of Waltham, Massachusetts provides the basis for the decommissioning cost estimate inflation and earnings rate forecasts. OPPD's Board of Directors approved both the inflation rates and earnings rates in January 2014. As previously documented in the May 13, 2011 Response to the NRC RAI Regarding 2011 Biennial Decommissioning Funding Status Report, OPPD's Board of Directors has the authority through Nebraska State Statutes to establish inflation rates and earning rates for OPPD.

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.

Omaha Public Power District 2015 Biennial Decommissioning Funding Status Report to NRC Page Three Dated: .J,..dl~-/5" J.

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. Thurber Division Manager - Finance

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO.1 2015 BIENNIAL DECOMMISSIONING FUNDING STATUS REPORT TO NRC ATTACHMENT A 2015 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 (.65l + .13E + .228)

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 Energy 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 "L", "E", and "B" =

"L" =Labor Index Change Employment Cost Index - Private Nonfarm Workers - Compensation Midwest Region (Quarterly Basis Increase) 12-2014 120.3/1 00 12-2005 x 2.08 (Re-indexed in December 2005) 2.50 (an increase of 20.2%)

"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 1-2015 221.8 = 94.2% increase 1-1986 114.2 Light Fuel Oils 1-2015 174.7 = 213.0% increase 1-1986 82.0 Application of the formula to 1-2015 leads to Energy= ((221.8/114.2) X .58) + ((174.7/82.0) X .42)

Energy = 1.126 + 0.894 Energy= 2.02 (an increase of 102.0%)

Attachment A Page Three nan= Waste Burial Index Change NUREG-1307 (Revision 15)

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 1-13 13.885 =13.885 (an increase of 1288.5%)

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

Generic LLW Disposal Site Index

$88.2 million x (.65(2.50) + .13(2.02) + .22(13.885)) =$436.054 million In summary, OPPD's Fort Calhoun Station Unit No. 1 NRC Minimum Decommissioning Amount estimate escalated to January 2015 is $436,054,000.

LIC-15-0047 Omaha Public Power District Nuclear Decommissioning Funding Plan for the Fort Calhoun Station Independent Spent Fuel Storage Installation (ISFSI)

Omaha Public Power District Nuclear Decommissioning Funding Plan for the Fort Calhoun Station 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 Decommissioning Fund Plan (DFP) for holders and applicants of both general and specific licenses under 10 CFR part 72. This rule was effective December 17, 2012. Omaha Public Power District (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 power reactor licensee under 10 CFR 50, OPPD utilizes the method of 10 CFR 50.75(b) and (e) to provide financial assurance for decommissioning the Fort Calhoun Station (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:

OPPD maintains a decommissioning cost estimate (DCE) for the Fort Calhoun Station, which is updated annually. Embedded in the DCE maintained by OPPD, are the costs associated with decommissioning the ISFSIIocated at the site. The following information, extracted from the TLG Services, Inc. May, 2013 decommissioning estimate for Fort Calhoun Station, details the costs of ISFSI decommissioning escalated to 2014 dollars.

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

Page Two TLG Services, Inc. - Decommissioning Cost Estimate for the Fort Calhoun Station (thousands of 2014 dollars)

Off-Site LLRW Jlctivity Dec on Removal Packaging Transport Processing Disposal Other Total Total Index ktMtv Cost Cost Cost Cost Cost Cost Costs Contingency Costs 3e.2.1 ISFSI Ucense Termination $128 $3 $4 $0 $104 $1,441 $420 $2,100 3e.3.1 Corporate Allocation $53 $8 $61 3e.3.2 SiteO&M $31 $5 $36 3e.4.1 Insurance $100 $10 $110 3e.4.3 Heavy Equipment Rental $226 $34 $260 3e.4.5 Security Staff Cost $232 $35 $267 3e.4.6 Utility Staff Cost $268 $40 $308

$3,142 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 extracted from the TLG Services, Inc.

Decommissioning Cost Estimate update for the Fort Calhoun Station, prepared May 2013 and escalated to 2014 dollars using a 3.1% escalation rate. The 3.1% escalation rate is the change of the decommissioning cost estimate since the last TLG Services update.

Requirement 4:

(4) A description of the method of assuring funds for decommissioning from paragraph (e) of this 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) every two years and annually at five years prior to the end of the plant's licensed life.

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

Page Three As of December 31, 2014, the trust fund assets were $364.1 million. Pursuant to 10 CFR 50.75(c), the January 2015 estimated NRC minimum decommissioning amount to decommission Fort Calhoun Station Unit No. 1 is $436.1 million and the 72.30 ISFSI decommissioning cost is $3.1 million.

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.

Dated: _.f_/_~_~_'ls' Y.W: Thurber Division Manager - Finance