LIC-19-0007, Post-Shutdown Decommissioning Activities Report

Post-Shutdown Decommissioning Activities Report

ML19351E355
Person / Time
Site:	Fort Calhoun
Issue date:	12/16/2019
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-19-0007
Download: ML19351E355 (83)

Text

444 South 16th Street Mall Omaha, NE 68102-2247 10 CFR 50.82(a)(4)

December 16, 2019 LIC-19-0007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report

References:

1. OPPD Letter (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067) (ML16242A127)

2. OPPD Letter (M. Fisher) to USNRC (Document Control Desk), Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report, Dated March 30, 2017 (LIC-17-0033)

(ML17089A759)

3. Letter from NRC (J. Rubenstone) to OPPD (M. Fisher), Fort Calhoun Nuclear Generating Station

- Foreign Obligations Compliance during Decommissioning, dated August 9, 2018 (ML18201A999)

Pursuant to 10 CFR 50.82(a)(4)(i), Omaha Public Power District (OPPD) is submitting a revised post-shutdown decommissioning activities report (PSDAR) for Fort Calhoun Station (FCS). By letter dated August 25, 2016 (Reference 1), OPPD notified the NRC of its intention to permanently cease power operations at FCS on October 24, 2016.

The Enclosure to this letter provides the revised FCS PSDAR. The PSDAR has been developed consistent with Regulatory Guide 1.185, Revision 1, Standard Format and Content for Post-Shutdown Decommissioning Activities Report. The FCS PSDAR includes a description of the planned decommissioning activities, a schedule for their accomplishments, a site specific decommissioning cost estimate and a discussion that provides a basis for concluding that the environmental impacts associated with site-specific decommissioning will be bounded by appropriate, previously issued, environmental impact statements. The PSDAR also includes a discussion of the schedule and costs associated with the management of spent fuel and site restoration. Funding for irradiated fuel management will be addressed as an update to the Irradiated Fuel Management Plan pursuant to 10 CFR 50.54(bb).

In Reference 2, OPPD submitted a Post-Shutdown Decommissioning Activities Report in accordance with 10 CFR 50.82, Termination of License paragraph (a)(4)(i). This letter is provided to notify the NRC of a significant schedule change to the 2017 PSDAR in accordance with 10 CFR 50.82, Termination of license, paragraph (a)(7), by which OPPD intends to accelerate the decommissioning schedule. The revised PSDAR is provided as an attachment to this letter. The attached revised PSDAR demonstrates our decision to transition to the DECON method of decommissioning.

LIC-19-0007 Page2 In accordance with 10 CFR 50.82(a){4)(i), a copy of the FCS PSADR is being provided to the States of Nebraska and Iowa by transmitting a copy of this letter and its attachments to the designated State Officials.

One (1) commitment is contained in this submittal. In an August 9, 2018, letter (Reference 3), the NRC recommended that OPPD provide a Regulatory Commitment, or some similar method, to ensure the U.S. Government can fulfill its international obligations with the Government of Japan. As a result, OPPD commits to the following:

Notify the NRC of the final dispositioa of the reactor closure vessel head (RCVH) which was obtained from Mitsubishi Heavy lnaostnes1n Japan-when-u1e RCVH is removed from the FCS site, by transfer to another facility, *sold as scrap* metal, or any other pathway implemented during the decommissioning process. --

It is anticipated that the RCVH will be disposed of as part of the FCS decommissioning process sometime In 2020. The above actions-have *been entered into the rCS commitment tracking system. of this letter contains the new regulatory commitment. **

If you should have any questions about the enclosed reports, please contact Mr. Bradley H. Blome at (402) 533-6041.

Respectfully, #.

-4.'~~~--

_,,# ~11 (',/ /

Mary J. Fisher Vice President Energy Production and Nu~~r Qeco_rnm1ssioning MJF/cac : Regulatory COmmibnents

Enclosure:

Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report c:

S. A. Morris, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager C. D. Steely, NRC Senior Health Physicist, Region IV Bureau Chief, Bureau of Radiological Health, Iowa Department of Public Health, State of Iowa Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-19-0007 Page 1 Regulatory Commitments This table identifies actions discussed in this letter for which OPPD commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

COMMITMENT TYPE (Check one)

SCHEDULED COMPLETION DATE (If Required)

ONE-TIME ACTION CONTINUING COMPLIANCE Notify the NRC of the final disposition of the reactor closure vessel head (RCVH) which was obtained from Mitsubishi Heavy Industries in Japan when the RCVH is removed from the FCS site, by transfer to another facility, sold as scrap metal, or any other pathway implemented during the decommissioning process.

It is anticipated that the RCVH will be disposed of as part of the FCS decommissioning process sometime in 2020. The above actions have been entered into the FCS commitment tracking system.

X Complete by 12/31/2020

LIC-19-0007 Enclosure Fort Calhoun Station Unit No. 1, Post-Shutdown Decommissioning Activities Report

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 1

Rev. 1 December 16, 2019 Table of Contents......................................................................................................................... 1 Acronyms........ 3 1.0 Introduction and Summary...................................................................................................... 4 1.1 Introduction.............................................................................................................................. 4 1.2 Background............................................................................................................................... 4 1.3 Summary of Decommissioning Alternatives........................................................................... 6 2.0 Description of Planned Decommissioning Activities.............................................................. 7 2.1 Discussion of Decommissioning Activities........................................................................... 10 2.1.1 Transition through SNF Transfer to ISFSI......................................................... 11 2.1.2 License Termination (Dismantling and Decontamination)..................................... 12 2.1.3 Site Restoration....................................................................... 14 2.1.4 SNF/GTCC Dry Storage & Transfer to DOE......................................... 14 2.1.5 ISFSI Decommissioning......................................................................................... 14 2.2 General Decommissioning Considerations............................................................................ 15 2.2.1 Major Decommissioning Activities........................................................................ 15 2.2.2 Decontamination and Dismantlement Activities.................................................... 15 2.2.3 Radioactive Waste Management............................................................................. 16 2.2.4 Removal of Mixed Wastes...................................................................................... 16 2.2.5 Site Characterization............................................................................................... 16 2.2.6 Groundwater Protection and Radiological Decommissioning Records Program........................................................................................................................... 17 2.2.7 Changes to Management and Staffing.................................................................... 17 3.0 Schedule of Planned Decommissioning Activities................................................................ 17 4.0 Estimate of Expected Decommissioning and Spent Fuel Management Costs.............. 17 4.1 Means of Adjusting Cost Estimates....................................................................................... 19 4.2 Means of Adjusting Associated Funding Levels................................................................... 19 5.0 Environmental Impacts.......................................................................................................... 19 5.1 Environmental Impact of FCS Decommissioning................................................................. 19 5.1.1 Onsite/Offsite Land Use........................................................................................ 20 5.1.2 Water Use.............................................................................................................. 20 5.1.3 Water Quality.......................................................................................................... 21 5.1.4 Air Quality.............................................................................................................. 21 5.1.5 Aquatic Ecology.................................................................................................... 22 5.1.6 Terrestrial Ecology................................................................................................ 22 5.1.7 Threatened and Endangered Species..................................................................... 23 5.1.8 Radiological........................................................................................................... 25 5.1.9 Radiological Accidents.......................................................................................... 26 5.1.10 Occupational Issues............................................................................................. 26 5.1.11 Cost...................................................................................................................... 27 5.1.12 Socioeconomics................................................................................................... 27 5.1.13 Environmental Justice.......................................................................................... 28 5.1.14 Cultural, Historic and Archeological Resources.................................................. 28 5.1.15 Aesthetic Issues.................................................................................................... 29 5.1.16 Noise.................................................................................................................... 29 5.1.17 Transportation...................................................................................................... 30 5.1.18 Irreversible and Irretrievable Commitment of Resources.................................... 30 5.2 Environmental Impacts of License Termination - NUREG-1496.......................................... 31 5.3 Discussion of Decommissioning in the SEIS......................................................................... 31 5.4 Additional Considerations...................................................................................................... 32 5.5 Conclusions............................................................................................................................ 32

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 2

Rev. 1 December 16, 2019 6.0 References............................................................................................................................. 34 Table 2.1 Decommissioning Schedule Summary..9 Table 2.2 Decommissioning Cost Summary....10

FCS Site-Specific Decommissioning Cost Estimate............36

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 3

Rev. 1 December 16, 2019 Acronyms AIF Atomic Industrial Forum ALARA As Low As Reasonably Achievable BMP Best Management Practices CFR Code of Federal Regulations DCE Decommissioning Cost Estimate DOE Department of Energy DSEIS Draft Supplemental Environmental Impact Statement (NUREG-1437)

EPA Environmental Protection Agency FCS Fort Calhoun Station FSAR Final Safety Analysis Report GEIS Generic Environmental Impact Statement (NUREG-0586)

GTCC Greater than Class C GW Groundwater IPaC Information for Planning and Consultation system ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MWt Megawatt-thermal NDEE Nebraska Department of Environment and Energy NEI Nuclear Energy Institute NESP National Environmental Studies Project NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission OPPD Omaha Public Power District PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor SEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437), Supplement 12 Regarding Fort Calhoun Station SFP Spent Fuel Pool SNF Spent Nuclear Fuel SSCs Structures, Systems and Components UFSAR Updated Final Safety Analysis Report USFWS United States Fish & Wildlife Service

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 4

Rev. 1 December 16, 2019

1.0 INTRODUCTION

AND

SUMMARY

1.1 Introduction In accordance with the requirements of Title 10 of the Code of Federal Regulations (CFR) 50.82, Termination of license, paragraph (a)(4)(i), this report constitutes the revised Post-Shutdown Decommissioning Activities Report (PSDAR) for Fort Calhoun Station (FCS). This PSDAR contains the following:

1. A description of the planned decommissioning activities along with a schedule for their accomplishment.

2. A discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements and updated environmental supplement.

3. A site-specific decommissioning cost estimate (DCE), including the projected cost of managing irradiated fuel and the post-decommissioning site restoration cost.

The revised PSDAR has been developed consistent with Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, (Reference 1). This report is based on currently available information and the plans discussed herein may be modified as additional information becomes available or conditions change. As required by 10 CFR 50.82(a)(7), Omaha Public Power District (OPPD) will notify the Nuclear Regulatory Commission (NRC) in writing, with copies sent to the affected State(s), before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR, including changes that significantly increase the decommissioning cost.

1.2 Background

The FCS owned property is approximately 660 acres in size and is located on the Missouri River, 19 miles north of Omaha, Nebraska. FCS employed a Combustion Engineering pressurized water reactor nuclear steam supply system licensed to generate 1,500 megawatts - thermal (MWt). The facility ceased operating on October 24, 2016. The principal structures at FCS site include:

Containment Building - Constructed of pre-stressed steel reinforced concrete with walls almost four feet thick, with an interior one-quarter inch thick steel liner for leak tightness. The containment building contains the reactor and nuclear steam supply system.

Auxiliary Building - Houses the reactor auxiliary systems, including waste treatment facilities, certain safety components, the control room, emergency diesel generators, and fuel handling and storage facilities. The Auxiliary Building is a heavily reinforced concrete structure that forms a U around the Containment Building.

Turbine Building - Houses the turbine generator, condensers, condensate and feedwater pumps, feedwater heaters and other turbine heat cycle components. The structural steel superstructure is enclosed with resin wall paneling, it has a reinforced concrete basement.

Service Building - Office space attached to, and of the same construction as, the Turbine Building.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 5

Rev. 1 December 16, 2019 Intake Structure - Houses the equipment that pumps cool river water into the plant for use in condensing the steam leaving the turbine. The building consists of a structural steel frame enclosed by resin wall panels. The intake structure is made of heavily reinforced concrete below the 1,014 foot elevation and extends over the Missouri River.

Security Access Facility - Serves as the main entrance to the plant.

Switchyard - Houses electrical transmission equipment that is connected to the main generator at the FCS.

Administration Building - Housed offices for management and engineering functions and NRC personnel, associated conference rooms and facilities, a fitness for duty laboratory, a radiological health area and a cafeteria.

Training Center - Includes office spaces, an auditorium, laboratories and control room simulator.

Radioactive Waste Processing Building - Used to sort, compact, decontaminate and store (short-term) low-level solid and liquid radioactive waste. In this building, radioactively contaminated equipment and objects can be decontaminated. The building has a ridged steel framework to support a precast concrete exterior panel siding.

Chemistry and Radiation Protection Building - Houses chemistry and radiological laboratories, a cafeteria, offices, locker and shower room.

Warehouse - A 40,000 square-foot building used for receiving deliveries and storage of spare parts and equipment.

A brief history of the major milestones related to FCS construction and operational history is as follows:

Construction Permit Issued: June 7, 1968 Operating License Issued: August 9, 1973 Commercial Operation: September 26, 1973 Major Plant Refurbishment: 2006 Original License Expiration: August 8, 2013 Renewed License Expiration: August 9, 2033 By letter dated June 24, 2016 (Reference 2), OPPD notified the NRC that it intended to permanently cease power operations of FCS at the end of October 2016. An August 25, 2016 supplement to this letter certified that operations would cease on October 24, 2016 (Reference 2), in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8). By letter dated November 13, 2016 (Reference 3) OPPD provided the certifications required by 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), pursuant to 10 CFR 50.82(a)(2), that all fuel had been permanently removed from the FCS reactor vessel and placed in the FCS spent fuel pool. As such, the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Pursuant to 10 CFR 50.51(b), Continuation of license, the license for a facility that has permanently ceased operations continues in effect beyond the expiration date to authorize ownership and

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 6

Rev. 1 December 16, 2019 possession of the utilization facility until the Commission notifies the licensee in writing that the license has been terminated.

During the period that the license remains in effect, 10 CFR 50.51(b) requires that OPPD:

Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including storage, control, and maintenance of the spent fuel in a safe condition.

Conduct activities in accordance with all other restrictions applicable to the facility in accordance with NRC regulations and the 10 CFR 50 facility license.

10 CFR 50.82(a)(9) states that power reactor licensees must submit an application for termination of the license at least two years prior to the license termination date and that the application must be accompanied or preceded by a license termination plan to be submitted for NRC approval.

1.3 Summary of Decommissioning Alternatives The NRC has evaluated the environmental impacts of three general methods for decommissioning power reactor facilities in NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, (GEIS) (Reference 4). The three general methods evaluated are summarized as follows:

DECON: The equipment, structures and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations.

SAFSTOR: After the plant is shut down and defueled, the facility is placed in a safe, stable condition and maintained in that state (safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license termination. During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, thereby lowering the level of contamination and radioactivity that must be disposed of during decontamination and dismantlement.

ENTOMB: Radioactive structures, systems and components (SSCs) are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits termination of the license.

The decommissioning approach that is being updated by OPPD for FCS is the DECON method. The primary objectives of the FCS decommissioning project are to remove the facility from service, reduce residual radioactivity to levels permitting unrestricted release, restore the site, perform this work safely, and complete the work in a cost effective manner. The selection of the updated, preferred decommissioning alternative is influenced by a number of factors. These factors include the cost of each decommissioning alternative, minimization of occupational radiation exposure, availability of a high-level waste (spent fuel) repository or a Department of Energy (DOE) interim storage facility, regulatory requirements, OPPDs selection of a decommissioning partner and public concerns. In

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 7

Rev. 1 December 16, 2019 addition, 10 CFR 50.82(a)(3) requires decommissioning to be completed within 60 years of permanent cessation of operations.

Under the DECON methodology, the facility is maintained in a safe and stable condition followed by decontamination and dismantlement. The facility will be decontaminated and dismantled to levels that permit license termination. In accordance with 10 CFR 50.82(a)(9), a license termination plan will be developed and submitted for NRC approval at least two years prior to termination of the license.

The decommissioning approach for FCS is described in the following sections.

Section 2.0 describes the planned decommissioning activities and the general timing of their implementation.

Section 3.0 describes the overall decommissioning schedule, including the spent fuel management activities.

Section 4.0 provides an analysis of expected decommissioning costs, including the costs associated with spent fuel management and site restoration.

Section 5.0 describes the basis for concluding that the environmental impacts associated with decommissioning FCS are bounded by the NRC generic environmental impact statement related to decommissioning.

Section 6.0 is a list of references.

2.0 DESCRIPTION

OF PLANNED DECOMMISSIONING ACTIVITIES OPPD is currently planning to decommission FCS using a DECON method. DECON is broadly defined in Section 1.3 of this report. This method still requires the management of spent fuel because of the DOEs failure to perform its spent fuel removal obligations under its contract with OPPD. To explain the basis for projecting the cost of managing spent nuclear fuel (SNF), a discussion of spent fuel management activities for the site is included herein.

The initial decommissioning activities to be performed after plant shutdown entailed de-fueling the reactor and transferring the fuel into the spent fuel pool; draining of fluids and de-energizing systems; reconfiguring the electrical distribution, ventilation, heating, and fire protection systems; and minor deconstruction activities. Systems temporarily needed for continued operation of the spent fuel pool may be reconfigured for operational efficiency.

Staffing and configuration requirements are expected to change during the period of DECON, principally dependent upon the work being performed and the status of the spent fuel being stored on-site. This can be characterized as one of two spent fuel conditions, as follows:

Wet and dry storage of spent fuel On-site dry storage of all spent fuel Spent fuel has remained in the spent fuel pool (SFP) meeting the criteria for transfer, and the spent fuel is being transferred in an efficient manner to the Independent Spent Fuel Storage Installation (ISFSI).

After all fuel is transferred to the ISFSI, the pool and supporting systems will be in a drained and de-energized condition. The spent fuel will be stored in the ISFSI until transfer to the Department of Energy (DOE). Dismantling and Decontamination (D&D) activities are scheduled to commence to enable the

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 8

Rev. 1 December 16, 2019 license to be terminated following transfer of the spent fuel to the ISFSI. Following completion of the D&D activities and termination of the NRC license, site restoration will be performed, to a to-be-determined condition, such that the site may be re-used for beneficial purposes. For the purposes of a current decommissioning cost estimate, it is assumed that remaining structures are to be demolished to three-feet below grade and the excavations backfilled with suitable material and erosion controls emplaced.

Decommissioning activities will be performed in accordance with written, reviewed and approved site procedures. There are no identified or anticipated decommissioning activities that are unique to the FCS site outside the bounds considered in the GEIS.

Radiological and environmental programs will be maintained throughout the decommissioning process to ensure occupational, public health and safety, and environmental compliance. Radiological programs will be conducted in accordance with the facilitys revised Technical Specifications, Operating License, Decommissioning Safety Analysis Report (DSAR), Radiological Environmental Monitoring Program, and the Offsite Dose Calculation Manual. Non-radiological Environmental Programs will be conducted in accordance with applicable requirements and permits.

Tables 2-1 and 2-2 provide summaries of the schedule / plant status and costs for decommissioning FCS.

The major decommissioning activities and the general sequence of activities are discussed in more detail in the sections that follow.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 9

Rev. 1 December 16, 2019 Table 2.1 Decommissioning Schedule and Plant Status Summary Decommissioning Activities /

Plant Status Start End Approximate Duration (years)

Pre-Shutdown Planning 2016 Oct 2016 Transition from Operations Plant Shutdown 24 Oct 2016 Preparations for SAFSTOR Dormancy 24 Oct 2016 01 Jul 2018 1.68 Spent Fuel Operations Wet Storage/Pool to Pad Operations 2018 2020 2.5 Dry Fuel Storage 2020 2058 37.5 Decommissioning Preparations Preparations for D&D 2019 2020 1.75 Dismantling &

Decontamination Large Component & Rad Systems Removal 2022 2023 1.5 Rad Building Decontamination &

Demolition 2023 2025 2.75 License Termination 2025 2026 0.5 Site Restoration Site Restoration 2025 2026 1

ISFSI Site Restoration 2057 2059 2

Total from Shutdown to Completion of License Termination 24 Oct 2016 31 Oct 2059 43

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 10 Rev. 1 December 16, 2019 Table 2.2 Decommissioning Cost Summary

[a] Columns may not add due to rounding 2.1 Discussion of Decommissioning Activities The following narrative describes the basic activities associated with decommissioning the FCS. The site specific DCE (detailed in Attachment 1) is divided into phases or periods based upon major milestones within the project or significant changes in the annual projected expenditures. The following sub-sections correspond to the five major decommissioning periods within the estimate.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 11 Rev. 1 December 16, 2019 2.1.1 Transition through SNF Transfer to ISFSI The NRC defines DECON as, A method of decommissioning, in which structures, systems, and components that contain radioactive contamination are removed from a site and safely disposed at a commercially operated low-level waste disposal facility, or decontaminated to a level that permits the site to be released for unrestricted use shortly after it ceases operation.

The facility is left intact (during the dormancy period), with structures maintained in a stable condition. Systems that are not required to support the spent fuel, HVAC, Emergency Plan or site security are drained, de-energized, and secured. Some cleaning/removal of loose contamination and or fixation and sealing of remaining contamination is performed. Access to contaminated areas is maintained secure to provide controlled access for inspection and maintenance.

The process of placing the plant in DECON will include, but is not limited to, the following activities:

Creation of an organizational structure to support the decommissioning plan and evolving emergency planning and site security requirements.

Revision of technical specifications, plans and operating procedures appropriate to the operating conditions and requirements.

Characterization of the facility and major components as may be necessary to plan and prepare for the dormancy phase.

Management of the spent fuel pool and reconfiguring fuel pool support systems so that draining and de-energizing may commence in other areas of the plant.

Deactivation (de-energizing and or draining) of systems that are no longer required during the dormancy period.

Processing and disposal of water and water filter and treatment media not required to support dormancy operation.

Disposition of incidental waste that may be present prior to the start of the dormancy period, such as excess tools and equipment and waste produced while deactivating systems and preparing the facility for dormancy.

Reconfiguration of power, lighting, heating, ventilation, fire protection, and any other services needed to decontamination and decommissioning activities as well as periodic plant surveillance and maintenance.

Stabilization by fixing or removing loose incidental surface contamination to facilitate future building access and plant maintenance. Decontamination of high-dose areas is anticipated.

Performance of interim radiation surveys of the plant, posting caution signs and establishing access requirements, where appropriate.

Maintenance of appropriate barriers for contaminated and radiation areas.

Reconfiguration of security boundaries and surveillance systems, as needed to support efficiency during the dormancy period.

Early activities include operating and maintaining the spent fuel pool and its associated systems, and transferring spent fuel from the pool to the ISFSI. Spent fuel transfer is expected to be

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 12 Rev. 1 December 16, 2019 complete by the end of 2020. After the fuel transfer is completed, the spent fuel pool and systems will be drained and de-energized.

Activities throughout this period will include a 24-hour security force, preventive and corrective maintenance on security systems, area lighting, general building maintenance, freeze protection heating, ventilation of buildings for periodic habitability, routine radiological inspections of contaminated structures, maintenance of structural integrity, and a site environmental and radiation monitoring program.

Security during this period will be conducted primarily to safeguard the spent fuel on site and prevent unauthorized entry. A security barrier, sensors, alarms, and other surveillance equipment will be maintained as required to provide security.

An environmental surveillance program will be carried out during this period to monitor for radioactive material in the environment. Appropriate procedures will be established and initiated for potential releases that exceed prescribed limits. The environmental surveillance program will consist of a version of the program in effect during normal plant operations that will be modified to reflect the plants conditions and risks at the time.

Later activities will include transferring the spent fuel from the ISFSI to the DOE. For planning purposes, OPPDs current spent fuel management plan for the Fort Calhoun spent fuel is based, in general, upon the following projections: 1) a 2030 start date for the DOE initiating transfer of commercial spent fuel to a federal facility, 2) a 2058 completion date for removal of all Fort Calhoun spent fuel from the site. It is acknowledged that the plant owner will seek the most expeditious means of removing fuel from the site when DOE commences performance. The ISFSI pad and associated facilities will be decommissioned along with the power block structures during the deferred decontamination and dismantling phases.

2.1.2 License Termination (Dismantling & Decontamination)

Prior to the commencement of major decommissioning operations, preparations will be undertaken to prime the site for decommissioning. Preparations include engineering and planning, a full site characterization, and the continued use of a decommissioning management organization. This includes the development of work plans, specifications and procedures.

Following the preparations for decommissioning, physical decommissioning activities will take place. This includes the removal and disposal of contaminated and activated components and structures, leading to the termination of the 10 CFR 50 operating license. Although much of the radioactivity will decrease during the dormancy period due to decay of 60Co and other short-lived radionuclides, the internal components of the reactor vessel will still exhibit radiation dose rates that will likely require remote sectioning under water due to the presence of long-lived radionuclides such as 94Nb, 59Ni, and 63Ni. Portions of the biological shield wall may also be radioactive due to the presence of activated trace elements with longer half-lives (such as 152Eu and 154Eu). It is assumed that radioactive contamination on structures, systems, and component surfaces will not have decayed to levels that will permit unrestricted release. These surfaces will be surveyed and items dispositioned in accordance with the existing radioactive release criteria.

Significant decommissioning activities in this phase include:

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 13 Rev. 1 December 16, 2019 Reconfiguration and modification of site structures and facilities, as needed, to support decommissioning operations. Modifications may also be required to the reactor or other buildings to facilitate movement of equipment and materials, support the segmentation of the reactor vessel and reactor vessel internals, and for large component removal.

Design and fabrication of temporary and longer-term shielding to support removal and transportation activities, construction of contamination control envelopes, and the procurement of specialty tooling.

Procurement or leasing of shipping cask, cask liners, and industrial packages for the disposition of low-level radioactive waste.

Decontamination or removal of components and piping systems, as required, to control (minimize) worker exposure.

Removal of piping and components no longer essential to support decommissioning operations.

Removal of control rod drive housings and the head service structure from reactor vessel head. Segmentation and disposal of the vessel closure head.

Removal and segmentation of the upper internals assemblies. Segmentation will maximize the loading of the shielded transport casks, i.e., by weight and activity. The operations are conducted under water using remotely operated tooling and contamination controls.

Disassembly and segmentation of the remaining reactor internals, including the lower core support assembly. Some material is expected to exceed Class C disposal requirements. As such, some material will be packaged into containers similar to spent fuel canisters.

Segmentation of the reactor vessel. A shielded platform is installed for segmentation as cutting operations are performed in-air using remotely operated equipment within a contamination control envelope. Segments are transferred in-air to containers for transfer and disposal.

Removal of the activated portions of the concrete biological shield and accessible contaminated concrete surfaces. If dictated by the steam generator and pressurizer removal scenarios, those portions of the associated cubicles necessary for access and component extraction are removed.

Removal of the steam generators and pressurizer for material recovery and controlled disposal. It is expected the upper portion of the steam domes will be removed and some of the internal components segregated for recycling. The generators will later be moved to an on-site processing center and the lower shell and tube bundle will be packaged for direct disposal. These components can serve as their own burial containers provided that all penetrations are properly sealed and the internal contaminants are stabilized, e.g., with grout.

Remediation of contaminated surface soil or sub-surface media will be performed as necessary to meet the unrestricted use criteria in 10 CFR 20.1402.

Underground piping (or similar items) and associated soil will be removed as necessary to meet license termination criteria.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 14 Rev. 1 December 16, 2019 At least two years prior to the anticipated date of license termination, a License Termination Plan (LTP) will be submitted to the NRC. That plan will include: a site characterization, description of the remaining dismantling / removal activities, plans for remediation of remaining radioactive materials, developed site-specific Derived Concentration Guideline Levels, plans for the final status (radiation) survey (FSS), designation of the end use of the site, an updated cost estimate to complete the decommissioning, and associated environmental concerns.

The FSS plan will identify the radiological surveys to be performed once the decontamination activities are completed and will be developed using the guidance provided in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). This document incorporates statistical approaches to survey design and data evaluation. It also identifies commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied. Once the FSS is complete, the results will be submitted to the NRC, along with a request for termination of the NRC license.

OPPD has already released some unaffected portions of the site on a partial site release basis, and may release more as they become available, before all site decommissioning work has been completed.

2.1.3 Site Restoration After the NRC terminates the license, site restoration activities will be performed, at the licensees discretion. OPPD currently assumes that remaining structures will be removed to a nominal depth of three feet below the surrounding grade level. Affected area(s) would then be backfilled with suitable fill materials, graded, and appropriate erosion controls established.

Non-contaminated concrete rubble produced by the demolition activities may be used for backfilling subsurface voids or may be transported to an offsite area for appropriate disposal as construction debris.

2.1.4 SNF/GTCC Dry Storage & Transfer to DOE Concurrent to site restoration activities, SNF/GTCC will remain in dry storage at the ISFSI until it is accepted by the Department of Energy (DOE) and transfers it to an off-site facility.

2.1.5 ISFSI Decommissioning Following transfer of the SNF/GTCC to the DOE the following activities will occur:

Decontamination of Storage Modules Final Status Survey of ISFSI Demolition of the Clean HSMs, ISFSI Pad and ISFSI Support Structures Restoration of ISFSI Site Preparation of Final Report in ISFSI Decommissioning and NRC Review 2.2 General Decommissioning Considerations 2.2.1 Major Decommissioning Activities

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 15 Rev. 1 December 16, 2019 As defined in 10 CFR 50.2, definitions, a major decommissioning activity is any activity that results in permanent removal of major radioactive components, permanently modifies the structure of the containment, or results in dismantling components for shipment containing greater than class C waste in accordance with § 61.55. The following discussion provides a summary of the major decommissioning activities currently planned for decommissioning of the FCS. These activities are envisioned to occur in the Dismantling and Decontamination Period.

The schedule may be modified as conditions dictate.

Prior to starting a major decommissioning activity, the affected components will be surveyed and decontaminated, as required, in order to minimize worker exposure, and a plan will be developed for the activity. Shipping casks and other equipment necessary to conduct major decommissioning activities will be procured.

The initial major decommissioning activity inside the containment building will be the removal, packaging, and disposal of systems and components attached to the reactor, to provide access, support removal, and RV/RVI segmentation. The reactor vessel internals will be removed from the reactor vessel and segmented, if necessary, for packaging, transport and disposal, or to separate greater than Class C (GTCC) waste. Internals classified as GTCC waste will be segmented and packaged into containers similar to spent fuel canisters for transfer to a high-level waste repository. Removal of the reactor vessel follows the removal of the reactor internals. Industry experience indicates that there may be several options available for the removal and disposal of the reactor vessel (i.e., segmentation or disposal as an intact package).

The viability of these options will be analyzed as a part of future planning and preparation activities. If segmented, it is likely that the work would be performed remotely in-air, using a contamination control envelope.

Other major decommissioning activities that would be conducted include the removal and disposal of the steam generators, pressurizer, turbine, condenser, main steam piping, feed water piping, pumps and heaters, spent fuel pool support equipment, and neutron activated /

contaminated concrete materials.

Other Decommissioning Activities In addition to the reactor and large components discussed above, all other plant components will be removed from the Reactor, Turbine, Auxiliary and associated support buildings, radiologically surveyed and dispositioned appropriately.

2.2.2 Decontamination and Dismantlement Activities The overall objective of D&D is to ensure that radioactively contaminated or activated materials will be removed from the site to allow the site to be released for unrestricted use. This may be accomplished by decontamination in place, off-site processing of the materials, or direct disposal of the materials as radioactive waste. A combination of these methods may be utilized.

The methods deemed most appropriate will be chosen those for the particular circumstances.

Low-level radioactive waste will be managed in accordance with approved procedures and commercial disposal facility requirements. This includes characterizing contaminated materials,

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 16 Rev. 1 December 16, 2019 packaging, transporting and disposal at a licensed low-level radioactive waste (LLRW) disposal facility.

2.2.3 Radioactive Waste Management A major component of the decommissioning work scope for the Fort Calhoun station is the packaging, transportation and disposing of primarily contaminated / activated equipment, piping, concrete, and if encountered, soil. A waste management plan will be developed to incorporate the most cost effective disposal strategy, consistent with regulatory requirements and disposal / processing options for each waste type at the time of the D&D activities.

Decommissioning wastes from FCS may be disposed of at the Waste Control Specialists site in Andrews County, Texas and or EnergySolutions site in Clive, Utah. If other licensed disposal facilities become available in the future, OPPD may elect to use them. Radioactive wastes from Fort Calhoun will be transported by licensed transporters. The waste management plan will be based on the evaluation of available methods and strategies for processing, packaging, and transporting radioactive waste in conjunction with the available disposal facility options and associated waste acceptance criteria.

2.2.4 Removal of Mixed Wastes If mixed wastes are generated they will be managed in accordance with applicable Federal and State regulations. If generated, mixed wastes from will be transported by authorized and licensed transporters and shipped to authorized and licensed facilities. If technology, resources, and approved processes are available, the processes will be evaluated to render the mixed waste non-hazardous.

2.2.5 Site Characterization During the decommissioning process, complete site characterization will be performed in which radiological, regulated, and hazardous wastes will be identified, categorized, and quantified.

Surveys will be conducted to establish the contamination and radiation levels throughout the plant. This information will be used in developing procedures to ensure that hazardous, regulated, and radiologically contaminated areas are remediated and to ensure that worker exposure is controlled. As decontamination and dismantlement work proceeds, surveys will be conducted to maintain a current site characterization and to ensure that decommissioning activities are adjusted accordingly.

As part of the site characterization process, a neutron activation analysis calculation study of the reactor internals and the reactor vessel was performed. Using the results of this analysis (along with benchmarking surveys), neutron irradiated components were classified (projected for the future D&D time-frame) in accordance with 10 CFR 61, Licensing requirements for land disposal of radioactive waste. The results of the analysis form the basis of the plans for removal, segmentation, packaging and disposal.

2.2.6 Groundwater Protection and Radiological Decommissioning Records Program

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 17 Rev. 1 December 16, 2019 A groundwater (GW) protection program currently exists at Fort Calhoun in accordance with the Nuclear Energy Institute (NEI) Technical Report 07-07, Industry Groundwater Protection Initiative - Final Guidance Document. This program is directed by procedures and will continue during decommissioning.

OPPD will also continue to maintain the existing radiological decommissioning records program required by 10 CFR 50.75(g). The program is directed by procedures.

Neither the monitoring results of the groundwater protection program nor events noted in 10 CFR 50.75(g) indicate the presence of long-lived radionuclides in sufficient concentrations to preclude unrestricted release under 10 CFR 20.1402, Radiological criteria for unrestricted use.

2.2.7 Changes to Management and Staffing Throughout the decommissioning process, plant management and staffing levels will be adjusted to reflect the ongoing transition of the site organization. Staffing levels and qualifications of personnel used to monitor and maintain the plant during the various periods after plant shutdown will be subject to appropriate Technical Specification and Emergency Plan requirements. These staffing levels do not include contractor staffing which may be used to carry out the future fuel movements, plant modifications in preparation for DECON, and the D&D / license termination / site restoration work. Contractors may also be used to provide general services, staff augmentation or replace permanent staff. The monitoring and maintenance staff will be comprised of radiation protection, radiological environmental monitoring program, plant engineering and craft workers, as appropriate for the anticipated work activities.

3.0 SCHEDULE OF PLANNED DECOMMISSIONING ACTIVITIES OPPD intends to pursue the decommissioning of Fort Calhoun utilizing a DECON methodology and will make appropriate filings with the NRC. The DECON method involves removal of radioactively contaminated or activated material from the site. Work activities associated with the planning and preparation period began before the plant was permanently shut down and will continue into 2020. The schedule of spent fuel management and major decommissioning activities is provided in Table 2-1.

Additional detail is provided in Appendix B of the DCE.

The schedule accounts for spent fuel being stored in the ISFSI until the assumed date of transfer to the DOE.

4.0 ESTIMATE OF EXPECTED DECOMMISSIONING AND SPENT FUEL MANAGEMENT COSTS 10 CFR 50.82(a)(4)(i) requires the submission of a PSDAR within two years following permanent cessation of operations that contains a site-specific DCE, including the projected cost of managing irradiated fuel.

EnergySolutions has prepared an updated site-specific decommissioning cost analysis for FCS, which also provides projected costs of managing spent fuel, as well as non-radiological decommissioning and site restoration costs, accounted for separately. The site-specific DCE is provided in Attachment 1 and fulfills

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 18 Rev. 1 December 16, 2019 the requirements of 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). A summary of the site-specific DCE, including the projected cost of managing spent fuel is provided in Table 2-2.

The methodology used by EnergySolutions to develop the site-specific DCE follows the basic approach originally advanced by the Atomic Industrial Forum (AIF) in its program to develop a standardized model for decommissioning cost estimates. The results of this program were published as AIF/NESP-036, A Guideline for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, (Reference 5). The AIF document presents a unit cost factor method for estimating direct activity costs, simplifying the estimating process. The unit cost factors used in the study reflect the latest available data, at the time of the study, concerning worker productivity during decommissioning.

Under NRC regulations (10 CFR 50.82(a)(8)), a licensee must provide reasonable assurance that funds will be available (or financial assurance) for decommissioning (i.e., license termination) costs. The regulations also describe the acceptable methods a licensee can use to demonstrate financial assurance.

Most licensees do this by funding a nuclear decommissioning trust (NDT). Nebraska State Statues provides the regulatory authority that allows OPPDs Board of Directors to establish the inflation rates and earning rates of OPPD.

OPPD maintains two separate trust accounts for this purpose, one for the License Termination Expenditures (NRC minimum decommissioning amount) and another for the Spent Fuel Management and Site Restoration Expenditures. The trustee for both trust funds is First National Bank of Omaha. As of December 31, 2018, the balance in the fund for the NRC minimum decommissioning amount was

$295,783,000 and the balance in the funds accumulated for other decommissioning costs was

$170,173,000.

The two trust funds are currently 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.

10 CFR 50.82(a)(6)(iii) states that, Licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2 that, Result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. OPPD does not intend to perform any decommissioning activities that would jeopardize the availability of adequate funds for the completion of decommissioning.

10 CFR 50.82(a)(8)(iv) states that, For decommissioning activities that delay completion of decommissioning by including a period of storage or surveillance, the licensee shall provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 19 Rev. 1 December 16, 2019 4.1 Means of Adjusting Cost Estimates Costs are inflated using a blending of the IHS Global Insights forecasts for Consumer Price Index, All-Urban and Employment Cost Index, Total Private Compensation. The indices are blended based on the ratio of labor and all other costs to the total DCE. For the years beyond the available forecast, the final forecast rate available is held constant for the duration of the analysis.

Consistent with Regulatory Guide 1.159 (Reference 6), OPPD will update the FCS DCE as required. In calculating projected earnings, OPPD uses the IHS Global Insights forecast for the yield on 5-year Treasury Notes which is within a two percent (2%) annual real rate of return.

4.2 Means of Adjusting Associated Funding Levels In the event that additional financial assurance beyond the amounts contained in the remaining trust fund for FCS is required pursuant to NRC regulations to complete radiological decommissioning and spent fuel management at FCS, OPPD will augment the NDTs with annual contributions to the NDTs.

As conditions may change, OPPD will adjust the funding, as appropriate, using alternative funding mechanisms acceptable to the NRC.

5.0 ENVIRONMENTAL IMPACTS OPPD has concluded that the environmental impacts associated with planned FCS site-specific decommissioning activities are less than and bounded by the previously issued environmental impact statements and updated environmental supplement. 10 CFR 50.82(a)(4)(i) requires that the PSDAR include, "...a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements." The following discussion provides the reasons for reaching this conclusion and is based on two previously issued environmental impact statements and updated environmental supplement:

NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (Reference 4)

(Referred to as the GEIS).

NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities (Reference 7).

File 127690-003, Updated Environmental Report for Fort Calhoun Station (Reference 17).

In evaluating whether the impacts in these previously issued environmental impact statements and updated environmental supplement are bounding, information from NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 12, Regarding Fort Calhoun Station, (Reference 8) was also considered (herein referred to as the SEIS).

5.1 Environmental Impact of FCS Decommissioning The following is a summary of the reasons for reaching the conclusion that the environmental impacts of decommissioning Fort Calhoun Station (FCS) are bounded by the GEIS and the environmental supplement. Each environmental impact standard in the GEIS is listed along with a summary as to why

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 20 Rev. 1 December 16, 2019 OPPD concludes the GEIS analysis bounds the impacts of FCS decommissioning on that standard.

Information that has changed (e.g., socioeconomics) or been updated (e.g., threatened and endangered species) has discussions as to why the original GEIS is still bounding inclusive of the new information. As a general matter, FCS is smaller than the reference pressurized water reactor used in the GEIS to evaluate the environmental impacts of decommissioning, and is therefore bounded by those assessments. Further, no unique site-specific features or unique aspects of the planned decommissioning have been identified.

5.1.1 Onsite/Offsite Land Use FCS has sufficient area onsite that has been previously disturbed (due to construction or operations activities) for use during decommissioning. Any construction activities that would disturb one acre or greater of soil would require a stormwater permit from the Nebraska Department of Environment and Energy (NDEE, formerly Nebraska Department of Environmental Quality, NDEQ) prior to proceeding with the activity. The stormwater permit would contain best management practices (BMPs) to control sediment and erosion effect on water courses and wetlands. Section 4.3.1 of the GEIS concluded that the impacts on land use are not detectable or small for facilities having only onsite land use changes as a result of large component removal, structure dismantlement, and low-level waste packaging and storage.

Currently, FCS will be able to conduct most of these decommissioning activities on previously disturbed land.

Based on the GEIS, the experience of plants that are being decommissioned has not included any needs for additional land offsite. Consistent with this determination, OPPD does not anticipate any changes in land use beyond the site boundary during decommissioning.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on onsite/offsite land use are bounded by the GEIS.

5.1.2 Water Use After plant shutdown, the operational demand for cooling water and makeup water has dramatically decreased. Additionally, after the plant is defueled, the amount of water used by the service water system will be much less than during normal operation of the plant. The need for cooling water will continue to decrease as the heat load of spent fuel in the spent fuel pool declines due to radioactive decay and as spent fuel is relocated from the spent fuel pool to the ISFSI. During plant shutdown, the use of potable water will decrease commensurate with the expected decrease in plant staffing levels. For these reasons, Section 4.3.2 of the GEIS concluded that water use at decommissioning nuclear reactor facilities is significantly smaller than water use during operation.

The GEIS also concluded that water use during the decontamination and dismantlement phase will be greater. However, there are no unique aspects associated with the decommissioning of FCS and water use for such activities as flushing piping, dust abatement, etc. Consequently, FCS water use impacts were addressed by the evaluation of the reference facility in the GEIS.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on water use are bounded by the GEIS.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 21 Rev. 1 December 16, 2019 5.1.3 Water Quality OPPD has chosen to decommission FCS using the DECON method which includes the prompt removal of all equipment, structures, and portions of the facility and site that contain radioactive contaminants and completion of D&D activities. Regulatory mandated programs and processes designed to minimize, detect, and contain spills will be maintained throughout the decommissioning process. OPPD will maintain all federal, state, and local permits pertaining to water quality throughout decommissioning activities and will obtain additional construction and NPDES permits to avoid and/or minimize impacts to water quality. FCS will also continue to receive potable water from the city of Blair throughout decommissioning and for the several buildings left onsite. In addition to the National Pollutant Discharge Elimination System (NPDES) permit, which regulates surface water discharges from the site (Reference 9), the permits that follow remain in place:

General NPDES Permit Number NER910000 for Stormwater Discharges from Industrial Activity to Waters of the State of Nebraska (Reference 10).

General NPDES Permit Number NEG671000, A General NPDES Permit Authorizing Dewatering Discharges (References 11).

Once decommissioning is complete, the above NPDES permits for Industrial Activity discharge will be terminated, as applicable. Industrial water discharge will cease and approximately 96 acres of developed land will be restored back to native grassland or repurposed for industrial or commercial use. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on water quality are bounded by the GEIS. With the native grassland, the decommissioning of FCS will have a positive impact on water quality once complete.

5.1.4 Air Quality Air Quality Construction Permit (CP07-0063) was issued by the NDEE and regulates air emission sources at FCS (Reference 12). This permit will remain in place during decommissioning. If new sources of air emissions are added or changed at the facility to support this process, the certificate will be modified as required. As new regulations are issued that impact these sources, these requirements will be addressed at the station. In addition, there are various other air quality regulations that will govern activities involving hazardous air pollutants and indoor air quality.

There are many types of decommissioning activities listed in the Section 4.3.4 of the GEIS that have the potential to affect air quality. For those activities applicable to the DECON option, OPPD does not anticipate any activities beyond those listed in the GEIS that could potentially affect air quality. In addition, federal, state and local regulations pertaining to air quality will remain in effect to regulate emissions associated with fugitive dust; criteria air pollutants, hazardous air pollutants, and ozone-depleting gases. Decommissioning activities will continue to be monitored by the ODCM which sets limits on doses caused by effluents, based upon ALARA (as low as reasonably achievable) objectives of 10 CFR 50.34a, 10 CFR 50.36a, and Section IV.B.1 of Appendix I to 10 CFR 50. These effluents are reported annually to the NRC. Therefore, based

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 22 Rev. 1 December 16, 2019 on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on air quality are bounded by the GEIS.

5.1.5 Aquatic Ecology Aquatic ecology encompasses the plants and animals in the Missouri River and wetlands near FCS. Aquatic ecology also includes the interaction of those organisms with each other and the environment. Section 4.3.5 of the GEIS evaluates both the direct and indirect impacts from decommissioning on aquatic ecology.

Direct impacts can result from activities such as the removal of shoreline structures or the active dredging of canals. FCS's shoreline structures are similar to the plants listed in Table E-2 of the GEIS, and there are no apparent discriminators based on the salient characteristics (size and location) listed in Table E-5 of the GEIS. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with BMPs outlined in permits issued by the and if necessary, the U. S. Army Corps of Engineers. Intake structure dredging will be greatly reduced due to the diminished residual heat removal requirements, and the relocation of the spent fuel to the ISFSI.

As previously discussed in Section 5.1.2, the amount of cooling water withdrawn from the Missouri River will significantly decrease thus reducing the potential impacts from impingement and entrainment of aquatic species. Additionally, any significant potential for sediment runoff or erosion on disturbed areas will be controlled in accordance with BMPs outlined in the stormwater permit. OPPD anticipates minimal disturbance of lands beyond the current operational areas of the plant, so there should be minimal, if any, new impacts to aquatic ecology from runoff associated with land disturbance activities.

OPPD will consult with regulatory and resource agencies to obtain permits and plan activities to minimize duration and extent of any impacts. Impacts to aquatic ecology would be limited to those areas previously disturbed during construction and operation, and there areas would be expected to recolonize as they did following initial construction. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on aquatic ecology are limited and bounded based on the GEIS.

5.1.6 Terrestrial Ecology Terrestrial ecology considers the plants and animals in the vicinity of FCS as well as the interaction of those organisms with each other and the environment. Evaluations of impacts to terrestrial ecology are usually directed at important habitats and species, including plant and animals that are important to industry, recreational activities, the area ecosystems, and those protected by endangered species regulations and legislation. Section 4.3.6 of the GEIS evaluates the potential impacts from both direct and indirect disturbance of terrestrial ecology.

Direct impacts can result from activities such as clearing native vegetation or filling a wetland.

OPPD anticipates minimal disturbance of habitat beyond the operational areas of the plant. All dismantlement, demolition, and waste staging activities are envisioned to be conducted within

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 23 Rev. 1 December 16, 2019 the operational area of the site. Also, the NDEE controls significant impacts to the environment through regulation of construction activities.

Indirect impacts may result from effects such as erosional runoff, dust or noise. Any construction activities that would disturb one acre or greater of soil would require a stormwater permit from the NDEE prior to proceeding with the activity. The stormwater permit would contain BMPs to control sediment and the effects of erosion associated with the construction activity. Fugitive dust emissions will be controlled through the judicial use of water spraying. The basis for concluding that the environmental impacts of noise are bounded by the GEIS is discussed in Section 5.1.16 below.

Section 4.3.6 of the GEIS concludes that if BMPs are used to control indirect disturbances and habitat disturbance is limited to operational areas, the potential impacts to terrestrial ecology are small. As discussed above, there are no unique disturbances to the terrestrial ecology anticipated during the decommissioning of FCS. Currently, FCS will be able to conduct all of these decommissioning activities on previously disturbed land. As required, the environmental impact will be reevaluated when activity is planned on previously undisturbed land. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on terrestrial ecology are bounded by the GEIS.

5.1.7 Threatened and Endangered Species There were thirteen (13) threatened and endangered species identified in the 2002 Environmental Report (Reference 18). In October 2018, a review for plant and wildlife species protected by the Nebraska Nongame and Endangered Species Act was requested by the Nebraska Game and Parks Commission (NGPC). The United States Department of Interior (UDSI) responded on 13 November 2018 (Reference 19) and identified five (5) state listed protected species (threatened or endangered) within the vicinity (3 miles) of the FCS. The only new species that was not listed in 2002 and that was identified in 2018 was the federal and state threatened northern long-eared bat (Myotis septentrionalis). The four (4) other species identified were three (3) fish species: the federal and state endangered pallid sturgeon (Scaphirhyncus albus), the state threatened lake sturgeon (Acipenser fulvescens), the state endangered sturgeon chub (Macrhybopsis gelida), and one (1) plant species: the state threatened American ginseng (Panax quinquifolium). A separate review was conducted in November 2018 per the federal Endangered Species Act with the U.S. Fish & Wildlife Services (USFWS) online Information for Planning and Consultation (IPaC) system. The results of the IPaC identified five (5) protected species. Similar to the NGPC review, it identified the federal threatened northern long-eared bat, the endangered least tern (Sterna antillarum), the threatened piping plover (Charadrius melodus), the endangered pallid sturgeon, and the threatened western prairie fringed orchid (Platanthera praeclara). Bald eagle (Haliaeetus leucocephalus) was mentioned in the NGPC response and IPaC, but it is not state or federally listed. However, the bald eagle is still protected by the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act. In addition, both the NGPC response and the IPaC review identified eleven (11) bird species that are protected under the Migratory Bird Treaty Act.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 24 Rev. 1 December 16, 2019 It was determined in the SEIS that due to channelization of the Missouri River and the removing of sandbars, both the least tern and piping plover are not likely to be found at FCS. The western prairie fringed orchid potentially occurs in Washington County based on historic observations.

However, no populations are known to occur in the County, and the potential for occurrence on or near FCS is low given the lack of appropriate prairie habitat in these areas.

To assess the presence or absence of the northern long-eared bat, acoustical studies and mist net surveys were conducted in August 2018 in accordance with USFWS and NGPC Scientific and Education Permits and a report was generated (Reference 20). Two (2) acoustic sites were recorded within the riparian corridor along the Missouri River and nine (9) mist net nights were completed across nine (9) separate net location on the FCS property. A total of 856 acoustic files were recorded at the two (2) acoustic sites. Nine (9) species were recorded including eight (8) northern long-eared bat call sequences. The statistical analysis of the data supported the presence of six (6) species: big brown bat (Eptesicus fuscus), eastern red bat (Lasiurus borealis),

hoary bat (Lasiurus cinereus), northern long-eared bat, evening bat (Nycticeius humeralis), and tri-colored bat (Perimyotis subflavus). Northern long-eared bat was confirmed at Site 1 by manual vetting. Nine complete net nights resulted in the capture of two eastern red bats: one adult male and one adult female. No federally listed species were captured.

Section 4.3.7 of the GEIS does not make a generic determination on the impact of decommissioning on threatened and endangered species. Rather it concludes that the adverse impacts and associated significance of the impacts must be determined on a site-specific basis.

With respect to the threatened and endangered aquatic species, the environmental impacts during decommissioning are expected to be minimal. Removal of the intake and discharge facilities as well as other shoreline structures will be conducted in accordance with BMPs outlined in permits issued by the NDEE and the U. S. Army Corps of Engineers. As previously discussed in Section 5.1.2, the amount of cooling water withdrawn from the Missouri River will significantly decrease thus reducing the potential impacts of impingement, entrainment, and thermal discharges on aquatic species. One potential adverse impact from the decrease in cooling water withdrawn may be the elimination of the thermal refuge for aquatic species in the discharge area which are preyed upon by the bald eagle in the winter months.

The environmental impacts during decommissioning are expected to be minimal on threatened and endangered terrestrial species. OPPD currently anticipates minimal disturbance of natural habitat beyond the operational areas of the plant for decommissioning and construction activities. Construction activities that disturb one acre or greater of soil necessitate permits by the NDEE and BMPs are required to be implemented to control sediment and the effects of erosion. Additionally, FCS has administrative controls in place which require that significant project activities undergo an environmental review prior to the activity occurring, which ensures that impacts are minimized through implementation of BMPs. Federal and state regulations pertaining to listed species will also remain in effect, which will further ensure that impacts to listed species and their habitats are minimized.

The Iowa Department of Natural Resources was not contacted as part of the updated environmental supplement because the decommissioning and construction activities including

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 25 Rev. 1 December 16, 2019 ground disturbance are not proposed in the state of Iowa; therefore, it is assumed that the decommissioning of FCS will not result in a significant adverse impact to Iowa protected threatened and endangered species.

Section 4.3.7 of the GEIS also suggests that care be exercised in conducting decommissioning activities after an extended period because there is a greater potential for rare species to colonize the disturbed portion of the site. However as previously discussed, administrative controls and federal and state regulations that will remain in effect would ensure that mitigation measures are implemented as appropriate to protect wildlife.

Based on the above, the planned decommissioning of FCS will not result in a direct mortality or otherwise jeopardize the local population of any threatened or endangered species. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on threatened and endangered species are bounded by the GEIS.

5.1.8 Radiological The GEIS considered radiological doses to workers and members of the public when evaluating the potential consequences of decommissioning activities.

Occupational Dose The occupational radiation exposure to FCS plant personnel will be maintained As Low as Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR Part 20 during decommissioning. The need for plant personnel to routinely enter radiological areas to conduct maintenance, calibration, inspection, and other activities associated with an operating plant has been reduced, thus the occupational dose to plant personnel has decreased since the plant is shutdown and defueled.

OPPD has elected to decommission FCS using the DECON alternative. It is expected that the occupational dose required to complete the decommissioning activities at FCS will be within the range of DECON dose estimates found in Section 4.3.8 of Supplement 1 to NUREG-0586 (Reference 4). This is based on the fact that FCS is bounded by the PWRs evaluated in the GEIS as previously discussed in Section 5.1, and because the ALARA program will be maintained to ensure that occupational dose is maintained ALARA and well within 10 CFR Part 20 limits.

Public Dose Section 4.3.8 of the GEIS considered doses from liquid and gaseous effluents when evaluating the potential impacts of decommissioning activities on the public. Table G-15 of the GEIS compared effluent releases between operating facilities and decommissioning facilities and concluded that decommissioning releases are lower. The GEIS also concluded that the collective dose and the dose to the maximally exposed individual from decommissioning activities are expected to be well within the regulatory standards in 10 CFR Part 20 and Part 50.

The expected radiation dose to the public from FCS decommissioning activities will be maintained within regulatory limits and below comparable levels when the plant was operating through the continued application of radiation protection and contamination controls combined

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 26 Rev. 1 December 16, 2019 with the reduced source term available in the facility. Also Section 4.12.2 of the SEIS (Reference

8) concluded that there were no site-specific radiological dose aspects associated with decommissioning of FCS. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on public dose are small and are bounded by the GEIS.

5.1.9 Radiological Accidents The likelihood of a large offsite radiological release that impacts public health and safety while FCS is shut down and defueled is considerably lower than the likelihood of a release from the plant during power operation. This is because the majority of the potential releases associated with power operation are not relevant after the fuel has been removed from the reactor.

Furthermore, handling of spent fuel assemblies will continue to be controlled under work procedures designed to minimize the likelihood and consequences of a fuel handling accident. In addition, emergency plans and procedures will remain in place to protect the health and safety of the public while the possibility of significant radiological releases exists.

Section 4.3.9 of the GEIS assessed the range of possible radiological accidents during decommissioning and separated them into two general categories; fuel related accidents and non-fuel related accidents. Fuel related accidents have the potential to be more severe and zirconium fire accidents, in particular, could produce offsite doses that exceed EPA's protective action guides (Reference 13). As part of its effort to develop generic, risk-informed requirements for decommissioning, the NRC staff performed analysis of the offsite radiological consequences of beyond-design-basis spent fuel pool accidents using fission product inventories at 30 and 90 days and 2, 5, and 10 years. The results of the study indicate that the risk at spent fuel pools is low and well within the Commission's Quantitative Health Objectives. The generic risk is low primarily due to the very low likelihood of a zirconium fire. (Reference 4)

The potential for decommissioning activities to result in radiological releases not involving spent fuel (i.e., releases related to decontamination, dismantlement, and waste handling activities) will be minimized by use of procedures designed to minimize the likelihood and consequences of such releases.

Therefore, OPPD concludes that the impacts of FCS decommissioning on radiological accidents are small and are bounded by the previously issued GEIS.

5.1.10 Occupational Issues Occupational issues are related to human health and safety. Section 4.3.10 of the GEIS evaluates physical, chemical, ergonomic, and biological hazards. OPPD has reviewed these occupational hazards in the GEIS and concluded that the decommissioning approach chosen for FCS poses no unique hazards from what was evaluated in the GEIS. OPPD will continue to maintain appropriate administrative controls and requirements to ensure occupational hazards are minimized and that applicable federal, state and local occupational safety standards and requirements continue to be met. Therefore, OPPD concludes that the impacts of FCS decommissioning on occupational issues are bounded by the GEIS.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 27 Rev. 1 December 16, 2019 5.1.11 Cost Decommissioning costs for FCS are discussed in Section 4.0 and in Attachment 1 to this report.

Section 4.3.11 of the GEIS recognizes that an evaluation of decommissioning cost is not a National Environmental Policy Act requirement. Therefore, a bounding analysis is not applicable.

5.1.12 Socioeconomics FCS is in largely rural and agricultural Washington County, Nebraska. According to 2010 Census data, approximately 981,137 people live within 50 miles of the station in both Nebraska and Iowa. Of these, 442,242 live within 20 miles of the station (see Updated Environmental Supplement, Section 5.1.11.1, Reference 17). As FCS transitions from shutdown and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff may result in decreases in revenues available to support the local economy.

Although FCS may have some effect on the region as a whole, the vast majority of FCS employees have resided in Washington, Douglas, and Sarpy Counties. Any effect on the local economy will be due to the approximately 400 jobs lost due to plant closure because FCS is a public utility and does not affect the local tax base. FCS employees may be expected to impact the economy the most in terms of real estate and consumer goods within the Counties where they live. Therefore, any effects of FCSs closure can be expected to be focused within these Counties. Although effects outside of the Counties are possible, if the effects within these Counties are negligible, it can be expected that effects in the surrounding areas are also negligible.

In general, the minority population numbers can be said to be relatively stable between 2014 and 2017 (Updated Environmental Supplement, Section 5.1.11.1.1, Reference 17). The changes that have occurred have been increases in minority population within the counties closest to FCS. These data demonstrate that the closing of FCS has not reduced minority populations. Due to the small size of the job losses and the lack of any effect on the tax base, there is no reason that minority populations should be affected.

Data from the 2000 and 2010 censuses and the 2012 - 2016 American Community Survey (ACS) 5-Year Estimates for Washington, Douglas, and Sarpy counties show that the poverty rates in Douglas, Sarpy, and Washington counties parallel a general trend of rising poverty in Nebraska as a whole. The rise in poverty has slowed somewhat due to the generally improved economy since 2010. According to the ACS 5-Year Estimates, there are a total of approximately 296,000 employed workers in Douglas County, 90,000 in Sarpy County, and 11,000 in Washington County. For the three counties together, losing 400 jobs would cause a loss of jobs of 0.1%.

Therefore FCS closure should not have a significant adverse impact on the local economy in the years following closure. The similarity between the trajectory of the local and regional numbers demonstrates that, according to the most recent available data, no difference in rates of poverty can be attributed to the closure FCS.

Section 4.3.12 of the GEIS evaluated changes in workforce and population, changes in local tax revenues, and changes in public services. The evaluation also examined large plants located in rural areas that permanently shut down early and selected the DECON option. The GEIS determined that this situation is the likeliest to have negative impacts. While FCS is in a rural

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 28 Rev. 1 December 16, 2019 area, it is a small plant and has chosen DECON as the decommissioning option, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on socioeconomic impacts are bounded by the GEIS.

5.1.13 Environmental Justice Executive Order 12898 dated February 16, 1994, makes achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionally high and adverse human health and environmental effects of its programs, policies, and activities on minority populations and low-income populations of the United States.

Based on 2010 census date, the minority population within a 20-mile radius comprises 21.2% of the total population, and within a 50-mile radius is 16.6% of the total population. Douglas County is composed of greater than 10% black and 10% Hispanic populations. Thurston County is composed of the Omaha and Winnebago reservations. Native Americans comprised 55% of Thurston Countys population according to 2010 data. Earlier census data found three counties in Nebraska (Thurston, Burt, and Douglas) and one in Iowa (Pottawattamie) within the 50 mile region exceeded the NRC thresholds defining low-income populations.

Section 4.13.3 of the GEIS reviewed environmental justice decommissioning impacts related to land use, environmental and human health, and socioeconomics. OPPD does not anticipate any offsite land disturbances during decommissioning, thus the land use impacts are not applicable for FCS. In addition as previously discussed in Section 5.1.12, it was determined that socioeconomic impacts from decommissioning are bounded by the GEIS. Potential impacts to minority and low-income populations would mostly consist of radiological effects. Based on the radiological environmental monitoring program data from FCS, the SEIS determined that the radiation and radioactivity in the environmental media monitored around the plant have been well within applicable regulatory limits. As a result, the SEIS found that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations (i.e., minority and or low income populations) in the region as a result of subsistence consumption of water, local food, fish, and wildlife.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FSC decommissioning on environmental justice are small and are bounded by the SEIS.

5.1.14 Cultural, Historic and Archeological Resources Based on a review of the FCS property through the Nebraska State Historic Preservation Office (NSHPO) files and information provided by the applicant, the NRC concluded in Section 4.4.5 of the SEIS (Reference 8) that the potential impacts from decommissioning of FCS on historic and archaeological resources would be small. The NRC identified the section of the plant site that lies north of the rail spur and is bounded on the west by U.S. Highway 75 as having Moderate to-High Potential. It contains remnants of the former town of Desoto, a historic property that is potentially eligible for listing on the National Register of Historic Places. Based on the impacts of past construction activities, the plant site being situated on floodplain alluvium, and having been developed since 1850, the section of the site that lies south of the current Union Pacific rail spur should be categorized as having No Potential for cultural resources, either prehistoric or historic.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 29 Rev. 1 December 16, 2019 Environmental review procedures have been put in place at FCS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas. These environmental protection procedures include contacting the SHPO to establish the actions necessary to protect known or as of yet undiscovered cultural resources before an action is allowed to occur. The cultural, historic, and archeological impact evaluation conducted in the GEIS (Reference 7) focused on similar attributes as the SEIS (Reference 8). The GEIS evaluated direct effects such as land clearing and indirect effects such as erosion and siltation.

The conclusion for the license renewal evaluation is also applicable to the decommissioning period because:

1) Decommissioning activities will be primarily contained to disturbed areas located away from areas of existing or high potential for archaeological sites,

2) Construction activities that disturb one acre or greater of soil are permitted by NDEE approval and BMPs are required to control sediment and the effects of erosion, and

3) Environmental protection procedures pertaining to archaeological and cultural resources will remain in effect during decommissioning.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on cultural, historic, and archeological resources are small and are bounded by the GEIS.

5.1.15 Aesthetic Issues During decommissioning, the impact of activities on aesthetic resources will be temporary and remain consistent with the aesthetics of an industrial plant. In most cases, Section 4.3.15 of the GEIS concludes that impacts such as dust, construction disarray, and noise would not easily be detectable offsite.

The GEIS concluded that the retention of structures during a decommissioning period or the retention of structures onsite at the time the license is terminated is likewise not an increased visual impact, but instead a continuation of the visual impact analyzed in the facility construction or operations final environmental statement.

After the decommissioning process is complete, site restoration activities may result in structures being removed from the site and the site being backfilled, graded and landscaped as needed. The GEIS concludes that the removal of structures is generally considered beneficial to the aesthetic impacts of the site. Under a DECON methodology, the removal of structures and grading will occur sooner than in a SAFSTOR methodology. Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on aesthetic issues are bounded by the GEIS.

5.1.16 Noise General noise levels during the decommissioning process are not expected to be any more severe than during refueling outages and are not expected to present an audible intrusion on the surrounding community. Some decommissioning activities may result in higher than normal

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 30 Rev. 1 December 16, 2019 onsite noise levels (i.e., some types of demolition activities). However, these noise levels will be temporary and are not expected to result in a significant audible intrusion on the surrounding community.

Section 4.3.16 of the GEIS indicates that noise impacts are not detectable or destabilizing and makes a generic conclusion that potential noise impacts are small. Based on the standard decommissioning approach proposed for FCS and the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on noise are bounded by the GEIS.

5.1.17 Transportation The transportation impacts of decommissioning are dependent on the number of shipments to and from the plant, the types of shipments, the distance the material is shipped, and the radiological waste quantities and disposal plans. The shipments from the plant would be primarily radioactive wastes and nonradioactive wastes associated with dismantlement and disposal of structures, systems and components.

OPPD compared the assumptions and analysis inputs used for NRCs analysis with waste volumes estimated for FCS decommissioning, transportation mode, and disposal facility options.

Due to the availability of the rail line, a substantial portion of the shipments will likely use that mode of transportation. The NRC indicates use of rail reduces radiological impacts by more than a factor of 10 over truck shipments. Furthermore, disposal facilities for FCS radiological waste are less than half the distance assumed by NRC in its analysis. The distance from FCS to the disposal site in Clive, Utah is approximately 1000 miles. Based on FCSs inputs compared the NRC analysis, FCS concludes that the generic impacts bound those associated with FCS.

OPPD will comply with all applicable NRC and U.S. Department of Transportation (DOT) regulations, including Federal Railroad Administration regulations and requirements, and will use approved packaging and shipping containers for waste shipment. OPPD will also comply with State of Nebraska regulations. The NRC has generically concluded that the radiological impacts of transporting radiological waste from decommission will be small and those for FCS are bounded by the GEIS.

The number of GTCC waste shipments expected to occur by truck during decommissioning is expected to be below the number referenced in Table 4-6 of the GEIS. These shipments will occur over an extended period of time and will not result in significant changes to local traffic density or patterns, the need for construction of new methods of transportation, or significant dose to workers or the public.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on transportation are bounded by the GEIS.

5.1.18 Irreversible and Irretrievable Commitment of Resources Irreversible commitments are commitments of resources that cannot be recovered, and irretrievable commitments of resources are those that are lost for only a period of time.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 31 Rev. 1 December 16, 2019 Uranium is a natural resource that is irretrievably consumed during power operation. After the plant is shutdown, uranium is no longer consumed. The use of the environment (air, water, land) is not considered to represent a significant irreversible or irretrievable resource commitment, but rather a relatively short term investment. Since the FCS site will be decommissioned to meet the unrestricted release criteria found in 10 CFR 20.1402, the land is not considered an irreversible resource. The only irretrievable resources that would occur during decommissioning would be materials used to decontaminate the facility (e.g., rags, solvents, gases, and tools), and the fuel used for decommissioning activities and transportation of materials to and from the site. However, the use of these resources is minor.

Therefore, based on the updated environmental report, OPPD concludes that the impacts of FCS decommissioning on irreversible and irretrievable commitment of resources are bounded by the GEIS.

5.2 Environmental Impacts of License Termination - NUREG-1496 According to the schedule provided in Section 3 of this report, a license termination plan for FCS will not be developed until approximately two years prior to the final site decontamination. At that time, a supplemental environmental report will be submitted as required by 10 CFR 50.82(a) (9). While detailed planning for license termination activities will not be performed until after the fuel transfer period, the absence of any unique site-specific factors, significant groundwater contamination, unusual demographics, or impediments to achieving unrestricted release suggest that impacts resulting from license termination will be similar to those evaluated in NUREG-1496.

5.3 Discussion of Decommissioning in the SEIS Postulated impacts associated with decommissioning are discussed in Section 7.0 of the SEIS (Reference 8), which identified six issues related to decommissioning as follows:

Radiation Doses Waste Management Air Quality Water Quality Ecological Resources Socioeconomic Impacts The NRC staff did not identify any new and significant information during their independent review of the FCS license renewal environmental report at that time (Reference 14), the site audit, or the scoping process for license renewal. Therefore, the NRC concluded that there are no impacts related to these issues beyond those discussed in the GEIS for license renewal (Reference 15) or the GEIS for decommissioning (Reference 4). For the issues above, the license renewal and decommissioning GEISs both concluded the impacts are small. The NRC found no site-specific issues related to decommissioning and there are no decommissioning activities contemplated that would alter that conclusion.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 32 Rev. 1 December 16, 2019 5.4 Additional Considerations While not quantitative, the following considerations are relevant to concluding that decommissioning activities will not result in significant environmental impacts not previously reviewed:

The release of effluents will continue to be controlled by plant license requirements and plant procedures.

FCS will continue to comply with the Offsite Dose Calculation Manual, Radiological Environmental Monitoring Program, and the Groundwater Protection Initiative Program during decommissioning.

Releases of non-radiological effluents will continue to be controlled per the requirements of the NPDES permit and applicable State of Nebraska permits.

Systems used to treat or control effluents during power operation will either be maintained or replaced by temporary or mobile systems for the decommissioning activities.

Radiation protection principles used during plant operations will remain in effect during decommissioning.

Sufficient decontamination and source term reduction prior to dismantlement will be performed to ensure that occupational dose and public exposure will be maintained below applicable limits.

Transport of hazardous and or radioactive waste will be in accordance with plant procedures, applicable Federal regulations, and the requirements of the receiving facility.

Site access control during decommissioning will minimize or eliminate radiation release pathways to the public.

Additionally, NUREG-2157 found that the generic environmental impacts of ongoing spent fuel storage are small (Reference 16).

5.5 Conclusions Based on the above discussions, OPPD concludes that the environmental impacts associated with planned FCS site-specific decommissioning activities will be bounded by appropriate, previously issued environmental impact statements and updated environmental supplement. Specifically, the environmental impacts are bounded by the GEIS (Reference 4) and SEIS (Reference 8) and File No.

127690-003 Fort Calhoun Updated Environmental Report (Reference 17).

The postulated impacts associated with the decommissioning method chosen, DECON, and have already been considered in the SEIS, GEIS and update environmental report.

There are no unique aspects of FCS or of the decommissioning techniques to be utilized that would invalidate the conclusions reached in the SEIS, GEIS and update environmental report.

The methods assumed to be employed to dismantle and decontaminate FCS are standard construction-based techniques fully considered in the SEIS, GEIS and update environmental report.

Therefore, it can be concluded that the environmental impacts associated with the site-specific decommissioning activities for FCS will be bounded by appropriate previously issued environmental impact statements and updated environmental supplement.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 33 Rev. 1 December 16, 2019 10 CFR 50.82(a) (6) (ii) states that licensees shall not perform any decommissioning activities, as defined in 10 CFR 50.2 that result in significant environmental impacts not previously reviewed. No such impacts have been identified.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 34 Rev. 1 December 16, 2019

6.0 REFERENCES

1. Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1. June 2013.

2. Letters, OPPD to USNRC, Certification of Permanent Cessation of Power Operations, dated June 24 and August 25, 2016. (ADAMS Accession Nos. ML16176A213 and ML16242A127).

3. Letter, OPPD to USNRC, Certification of Permanent of Fuel from the Reactor Vessel, dated November 13, 2016.(ADAMS Accession No. ML16319A254).

4. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, Final Report.

November 2002.

5. AIF/NESP-036, A Guideline for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates. May 1986.

6. Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision 2. October 2011.

7. NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination of NRC Licensed Nuclear Facilities. July 1997.

8. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 12, Regarding Fort Calhoun Nuclear Power Station. August 2003.

9. Fort Calhoun Station, NPDES Permit No. 0000418. January 2016.

10. Fort Calhoun Station, Stormwater Discharge Permit NER910000. July 2011.

11. Fort Calhoun Station, Dewatering Authorization. Permit NEG671000. January 2012.

12. Fort Calhoun Station, Air Quality Construction Permit. CP07-0063. February 2008.

13. PAG Manual, Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment. March 2013.

14. FCS Nuclear Power Station, License Renewal Application. Appendix E, Applicants Environmental Report. January 2002. LIC-02-0001 (ML020230166)

15. NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants. June 2013.

16. NUREG-2157, Waste Confidence Generic Environmental Impact Statement, Draft Report for Comment. September 2013.

17. Updated Environmental Report Fort Calhoun Station, File No. 127690-003. December 2018.

18. NGPC (Nebraska Game and Parks Commission). 2018. Conservation Planning Report, OPPD Fort Calhoun Property Record Request. October 2018.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 35 Rev. 1 December 16, 2019

19. USDI (United States Department of the Interior). 2018. List of Threatened and Endangered Species That May Occur in your Proposed Project Location, and/or may be Affected by your Proposed Project. Fish and Wildlife Service, Nebraska Ecological Services Field Office. November 2018.

20. ESI (Environmental Solutions & Innovations, Inc.). 2018. Northern Long-Eared Bat Acoustic and Mist Net Surveys on Fort Calhoun Station in Washington County, Nebraska. September 2018.

Fort Calhoun Station Revised Post-Shutdown Decommissioning Activities Report 36 Rev. 1 December 16, 2019

FCS Site-Specific Decommissioning Cost Estimate

DocumentNo.164074DCE01

SiteSpecificDecommissioningCostEstimate(DCE) for FortCalhounStation

ProjectNo.164074 FINALREV.0 Preparedfor:

OmahaPublicPowerDistrict

Preparedby:

EnergySolutions,LLC

AuthoredBy:

September10,2019

MarkRademacher,EstimatingDirector Date ReviewedBy:

September10,2019

MichaelS.Williams,TechnicalAdvisor/Sr.D&DSpecialist Date

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TableofContents

1.0EXECUTIVE

SUMMARY

.............................................................................................................6

2.0INTRODUCTION

.......................................................................................................................8 2.1 StudyObjective............................................................................................................8 2.2 RegulatoryFramework.................................................................................................8 2.3 DecommissioningAlternatives.....................................................................................9 2.4 PostShutdownSpentFuelManagementAlternatives.................................................9 3.0STUDYMETHODOLOGY.........................................................................................................10 3.1 GeneralDescription....................................................................................................10 3.2 ScheduleAnalysis.......................................................................................................10 3.3 DecommissioningStaff...............................................................................................10 3.4 WasteDisposal...........................................................................................................11 3.5 FinalStatusSurvey.....................................................................................................13 3.6 Contingency................................................................................................................13 3.7 CostReporting............................................................................................................14 4.0SITESPECIFICTECHNICALAPPROACH....................................................................................15 4.1 FacilityDescription.....................................................................................................15 4.2 MajorWorkPeriodsforPromptDECON.....................................................................15 4.3 DecommissioningStaff...............................................................................................21 4.4 SpentFuelManagement............................................................................................21 4.5 SpentFuelShipments.................................................................................................21 5.0BASESOFESTIMATEANDKEYASSUMPTIONS.......................................................................22 6.0STUDYRESULTS......................................................................................................................25

7.0REFERENCES

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Tables Table11 DecommissioningCostEstimateSummary........................................................................6 Table61 DecommissioningCostEstimateSummary.....................................................................25 Table62 DECONCostSummarybyPeriod......................................................................................27 Table63 DECONCostSummarybyCostType................................................................................28 Table64 OPPDEstimatedStaff&SecurityManpower...................................................................28 Table65 WasteDisposalVolumes..................................................................................................29 Table66 ProjectedAnnualSpending..............................................................................................30

Figures Figure11 PromptDECONSummarySchedule...................................................................................7 Figure61 PromptDECONSchedule..................................................................................................26

Appendices AppendixA WasteDisposalSummary AppendixB DECONProjectSchedule AppendixC DetailedCostEstimate

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AcronymsandAbbreviations AIF

AtomicIndustrialForum BWR

BoilingWaterReactors CFR

CodeofFederalRegulations D&D

Decontamination&Decommissioning DAW

DryActiveWaste DCE

DecommissioningCostEstimate DGC

DecommissioningGeneralContractor DOE

U.S.DepartmentofEnergy ES

EnergySolutions FSS

FinalStatusSurvey GTCC

GreaterThanClassCWaste HP

HealthPhysics ISFSI

IndependentSpentFuelStorageInstallation LLRW LowLevelRadioactiveWaste LTP

LicenseTerminationPlan MARSSIM MultiAgencyRadiationSurveyandSiteInvestigationManual MPC

MultiPurposeCanisters MWt

Megawattthermal NRC

NuclearRegulatoryCommission NSSS

NuclearSteamSupplySystem OPPD OmahaPublicPowerDistrict ORISE OakRidgeInstituteforScienceandEducation PCB

PolychlorinatedBiphenyl PSDAR PostShutdownDecommissioningActivitiesReport PWR

PressurizedWaterReactor SNF

SpentNuclearFuel WBS

WorkBreakdownStructure WCS

WasteControlSpecialistsLLC UCF

UnitCostFactor

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1.0EXECUTIVE

SUMMARY

TheOmahaPublicPowerDistrict,onbehalfoftheFortCalhounStation,contractedwithEnergySolutionsLLC (ES),forthepreparationofthisReport.ThereportpresentstheSiteSpecificDecommissioningCostEstimate (DCE)StudyoftheFortCalhounStation(FortCalhoun),hereinafterreferredtoastheDCE.FortCalhounis ownedbytheOmahaPublicPowerDistrict(OPPD).

FortCalhounisa1500MwtCombustionEngineeringPressurizedWaterReactor.

OnJune16,2016,theOmahaPublicPowerDistrictboardvotedunanimouslytoshutdownFortCalhounand theplantpermanentlyceasedoperationonOctober24,2016.Thepermanentcoreoffloadwascompleted onNovember13,2016.

ThedecommissioningalternativesprovidedbytheU.S.NuclearRegulatoryCommission(NRC)areasfollows:

DECON-isthealternativeinwhichtheplantstructures,systemsandcomponentscontainingradioactive contaminantsareremovedordecontaminatedtolevelsthatpermitthesitepropertytobereleasedfor unrestrictedusefollowingcessationofoperations.Thisisthemostexpeditiousofthedecommissioning alternativesandreleasesthesitepropertyforotherbeneficialuseintheshortestperiodoftime.

SAFSTOR-isthealternativeinwhichthefacilityisplacedintoandmaintainedinaconditionthatpermitsthe facilitytobesafelystoredundermonitoredconditionsandthensubsequentlydecommissionedfollowinga storageperiodthatprovidesforthesignificantreductioninplantradiationlevelsresultingfromradioactive decay.Thisalternativeprovidesfortheunrestrictedreleaseofthesitepropertywithina60yeartimeperiod.

ENTOMB-isnotconsideredapracticaldecommissioningalternativeforFortCalhounandisnotdefinedin thisreport.

The station initially selected the SAFSTOR decommissioning option. In October 2018, the OPPD board authorizedFortCalhountotransitionfromtheSAFSTORdecommissioningoptiontoaPromptDECONoption, whichcompletesthenucleardecommissioningactivitieswithinasignificantlyshortertimeperiod.

This study has been performed to furnish a Decommissioning Cost Estimate of the costs for license terminationunderthePromptDECONdecommissioningalternative,basedonEstimatedCoststoComplete asofDecember31,2018.

Allcostsrepresentedinthisreportareprovidedin2018dollars.

ThecostestimateresultsareprovidedinTable11below.ThistableprovidesLicenseTerminationcosts (correspondingto10CFR50.75(c)requirements);SpentFuelManagementcosts(correspondingto10CFR 50.54(bb) requirements) and Site Restoration costs (corresponding to activities such as clean building demolitionandsitegradingetc.).

TABLE11

License Termination Spent Fuel Site Restoration Total

$725,243

$358,944

$44,903

$1,129,091 PROMPT DECON SCENARIO Decommissioning Cost Estimate (thousands of 2018 Dollars)

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Page7of31 CostsforGreaterThanClassC(GTCC)casksandoperationsduringthedecommissioningperiodareincluded intheLicenseTerminationCosts.CostsforGreaterThanClassC(GTCC)duringlongtermSpentFuelStorage andtransfertoDOEareincludedintheSpentFuelCosts.

This estimate is based on current existing site and building drawings and plant systems data providedbyOPPDcombinedwithEnergySolutionsdecommissioningexperiencetoestablishplant systemsandbuildingsinventories.Theseinventories,EnergySolutionsproprietaryUnitCostFactors(UCFs) andotherplantdata,wereusedtogeneratetherequiredlaborhours,cost,wastevolumes,weightsand classifications.

IthasbeenassumedthatShutdownandTransitionPlanning,FuelSampling,andISFSIdesign/construction activitieshavebeencompletedpriortoDecember31,2018.

IthasalsobeenassumedSpentFuelPoolandTransfertoISFSIOperationsareinprogressasofDecember31, 2018, and the contract for removal, transportation and disposal of the Legacy Reactor Vessel Head, PressurizerandSteamGeneratorsisinprogressasofDecember31,2018.

Theschedulereflectstheeffectsofsequencedactivitydependentordistributeddecommissioningelements suchasspentfuelpooltopadoperations,planningandpreparations,majorcomponentremoval,building decontamination,buildingdemolition,siterestoration,spentfuelstorage,etc.

ThecostsandscheduleforthePromptDECONalternativearedividedintothreemajorprojectcategoriesas follows:

LicenseTermination SpentFuelStorage SiteRestoration Figure11belowshowsthesummarylevelscheduleforthePromptDECONalternative.

FIGURE11

Description SpentFuelPooltoPadOperations DecommissioningPlanning&Preparation SiteModifications&Upgrades Decontamination&Decommissioning NonRadBuilding&SiteDemolition SiteRestorationActivities LicenseTermination ISFSIOperations&DryFuelStorage SpentFuel&GTCCTransfertoDOE ISFSIDecommissioning&Restoration 2057 2058 2059 OPPDFORTCALHOUNDECON

SUMMARY

SCHEDULE 2019 2020 2021 2022 2023 2024 2025 2026 2027

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2.0INTRODUCTION

2.1 StudyObjective This report presents the Site Specific Decommissioning Cost Estimate (DCE) for Fort Calhoun Station, hereinafterreferredtoastheDCE.

ThisstudyhasbeenperformedtoprovideOPPDwithanupdatedDecommissioningCostEstimateforthe selectedPromptDECONdecommissioningalternative.Itaddresses:(1)thedecommissioningofFortCalhoun totheextentrequiredtoterminatetheplantsNRClicense,(2)managementofresidualspentfueluntil acceptancebytheU.S.DepartmentofEnergy(DOE),and(3)demolitionofuncontaminatedstructuresand restorationofthesite.

The study methodology follows the basic approach originally presented in the Atomic Industrial Forum/NationalEnvironmentalStudiesProjectReportAIF/NESP036,GuidelinesforProducingCommercial NuclearPowerPlantDecommissioningCostEstimates(Ref.No.2).Thereportwaspreparedinaccordance with Nuclear Regulatory Commission (NRC) Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Ref. No. 3). The estimate is based on compliancewithcurrentregulatoryrequirementsandprovendecommissioningtechnologies.

NRCrequirements,setforthinTitle10oftheCodeofFederalRegulations(CFR),differentiatebetweenthe postshutdowncostsassociatedwiththedecommissioningofthenuclearplantfacility,thoseassociatedwith storageofspentfuelonsite,andthoseassociatedwiththedecommissioningofaspentfuelstoragefacility.

TheCodeofFederalRegulations,however,doesnotaddresstheentirescopeofthedecommissioningliability for each nuclear facility. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and structuresthatdonotrequiredisposalasradioactivematerial.10CFR50.75(c)alsoexcludesthecostofsite restorationactivitiesthatdonotinvolvetheremovalofresidualradioactivitynecessarytoterminatetheNRC license(s).10CFR50.54(bb)requiresfundingbythelicensee(s)"forthemanagementofallirradiatedfuelat thereactoruponexpirationofthereactoroperatinglicense(s)untiltitletotheirradiatedfuelandpossession ofthefuelistransferredtotheSecretaryofEnergyforitsultimatedisposalinarepository."10CFR72.30 requiresfundingfordecommissioningoftheonsitespentfuelstoragefacilityaftertheirradiatedfuelis acceptedbytheDOE.

ThestudyanalyzestheDecommissioningCostEstimate(DCE)ofOPPDunderthePromptDECONlicense terminationscenario.

2.2 RegulatoryFramework Provisionsofcurrentlawsandregulationsaffectingdecommissioning,wastemanagement,andspentfuel managementareasfollows:

1. NRCregulationsrequirealicenseforonsitestorageofspentfuel.Wetstorageinaspentfuelpoolis authorizedbyafacility's10CFRPart50license(Ref.No.1).Onsitedrystorageofspentfuelatan IndependentSpentFuelStorageInstallation(ISFSI)islicensedbyeither:(a)thegenerallicenseset forthin10CFR72.210,whichrequiresthataPart50licensebeinplace;or(b)asitespecificISFSI licenseissuedpursuantto10CFRPart72.

2. 10CFR50.75(c)requiresfundingbythelicensee(s)ofthefacilityfordecommissioning.

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3. 10 CFR 50.54(bb) requires the licensee(s), within two years following permanent cessation of operationofthereactororfiveyearsbeforeexpirationoftheoperatinglicense(s),whicheveroccurs first,tosubmitwrittennotificationtotheNRCforitsreviewandpreliminaryapprovaloftheprogram bywhichthelicenseeintendstomanageandprovidefunding"forthemanagementofallirradiated fuelatthereactoruponexpirationofthereactoroperatinglicenseuntiltitletotheirradiatedfuel andpossessionofthefuelistransferredtotheSecretaryofEnergyforitsultimatedisposalina repository."

2.3 DecommissioningAlternatives ThethreebasicmethodsfordecommissioningareDECON,SAFSTOR,andENTOMB,whicharesummarized asfollows:

1. DECON:Theequipment,structures,andportionsofthefacilityandsitethatcontainradioactive contaminantsarepromptlyremovedordecontaminatedtoalevelthatpermitsterminationofthe licenseaftercessationofoperations.

2. SAFSTOR:Thefacilityisplacedinasafe,stableconditionandmaintainedinthatstate(safestorage).

Thefacilityisdecontaminatedanddismantledattheendofthestorageperiodtolevelsthatpermit licensetermination.NRCregulationsrequiredecommissioningtobecompletedwithin60yearsof cessationofoperation.

3. ENTOMB:Radioactivestructures,systems,andcomponentsareencasedinastructurallylonglived substance,suchasconcrete.Theentombedstructureisappropriatelymaintainedandmonitored untilradioactivitydecaystoalevelthatpermitsterminationofthelicense.Sinceentombmentwill exceed the requirement for decommissioning to be completed within 60 years of cessation of operation,NRChandlesentombmentrequestsonacasebycasebasis.

2.4 PostShutdownSpentFuelManagementAlternatives The options for longterm postshutdown spent fuel management currently available to power plant operatorsare(1)wetstorageconsistingofcontinuedmaintenanceandoperationofthespentfuelpool,and (2)drystorageconsistingoftransferofspentfuelfromthefuelpooltoonsitedrystoragemodulesaftera coolingperiodoranycombinationofthetwo.

Transfer to an as yet to be developed, privately owned Interim Spent Fuel Storage Facility, while contemplated,hasnotbeensufficientlydevelopedtowarrantdiscussionandevaluationatthistime.

TransferofSpentFueltoanISFSIrequiresadditionalexpendituresforpurchaseandconstructionofthe ISFSIandstoragemodulesandultimatedismantlementanddisposaloftheISFSIfollowingcompletionof spentfueltransfertoDOE.

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Page10of31 3.0STUDYMETHODOLOGY 3.1 GeneralDescription EnergySolutionsmaintainsaproprietarydecommissioningcostmodelbaseduponthefundamentaltechnical approach established in AIF/NESP036, "Guidelines for Producing Commercial Nuclear Power Plant DecommissioningCostEstimates,"datedMay1986(Ref.No.2).Thecostmodelhasbeenupdatedfrequently inaccordancewithregulatoryrequirementsandindustryexperience.Thecostmodelincludeselementsfor estimatingdistributedandundistributedcosts.Distributedcostsareactivityspecificandincludeplanning and preparation costs as well as costs for decontamination, packaging, disposal, and removal of major componentsandsystems.Forexample,costsforthesegmentation,packaging,anddisposalofthereactor internalsaredistributedcosts.Undistributedcosts,sometimesreferredtoascollateralcosts,aretypically timedependentcostssuchasutility(Licensee)anddecommissioninggeneralcontractorstaff,propertytaxes, insurance,regulatoryfeesandpermits,energycosts,andsecuritystaff.

The methodology for preparing cost estimates for a selected decommissioning alternative requires developmentofasitespecificdetailedworkactivitysequencebasedupontheplantinventory.Theactivity sequenceisusedtodefinethelabor,material,equipment,energyresources,anddurationrequiredforeach activity.Inthecaseofmajorcomponents,individualworksequenceactivityanalysesareperformedbased onthephysicalandradiologicalcharacteristicsofthecomponent,andthepackaging,transportation,and disposaloptionsavailable.

Inthecaseofstructuresandsmallcomponentsandequipmentsuchaspiping,pumps,andtanks,thework durationsandcostsarecalculatedbasedonUCFs.UCFsareeconomicparametersdevelopedtoexpresscosts perunitofworkoutput,pieceofequipment,ortime.Theyaredevelopedusingdecommissioningexperience, informationonthelatesttechnologyapplicabletodecommissioning,andengineeringjudgment.

3.2 ScheduleAnalysis Aftertheworkactivitydurationsarecalculatedforalldistributedactivities,ascheduleanalysisisperformed usingOraclePrimaveraP6.Thescheduleaccountsforconstraintsandregulatoryreviews.Thescheduleis typicallydelineatedintophasesortimeperiodsthatdifferentiatebetweendirectcostsrequirementsand undistributedcosts.

In order to differentiate between phase (period) elements of the decommissioning scope of work, EnergySolutionshasestablishedaWorkBreakdownStructure(WBS)andcostaccountingsystemtotreateach elementasasubproject.Accordingly,theoverallprojectscheduleisdividedintointerrelatedperiodswith majormilestonesdefiningthebeginningandendingofeachperiod.Themajormilestonesalsoserveasthe basisforintegratingtheperiodsofthethreesubprojects.

3.3 DecommissioningStaff EnergySolutions has assumed that the Fort Calhoun decommissioning project will be performed in an efficientlyplannedandexecutedmannerusingprojectpersonnelexperiencedindecommissioningandlarge scaleprojectmanagement.

This DCE also assumes that the decommissioning work will be performed by a highly experienced and qualifiedDecommissioningContractors,withoversightandmanagementofthedecommissioningoperations performedbytheOPPDstaff,workinginpartnershipwith,andsupplementedbyahighlyexperiencedand qualifiedDecommissioningGeneralContractor(DGC).

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Page11of31 EnergySolutionsanalyzedtheFortCalhounlicenseestaffingneedsanddevelopedasitespecificstaffingplan.

StaffandDGClaborcostsweredevelopedbyEnergySolutionsutilizingOPPDsuppliedvaluesandEShistorical data.

Staffinglevels,forbothstaffingplansandforeachprojectperiod,arebasedontheAtomicIndustrialForum (AIF)guidelines,industryandEnergySolutionshistoricalexperience.Thesizeofstaffisvariedineachperiod inaccordancewiththerequirementsoftheworkactivities.Staffingestimatesincludefollowingdepartments orfunctionalgroups:

Management&Administrative Engineering PlantOperations&Maintenance RadiationProtectionandChemistry HealthPhysics RegulatoryAffairs Quality WasteOperations Security DecommissioningGeneralContractor 3.4 WasteDisposal Wastemanagementcostscompriseasignificantportionofthedecommissioningcostestimate.Additionally, limitedfutureaccesstodisposalsiteslicensedforreceiptofClassBandCwastesintroducesasignificantlevel ofuncertaintywithrespecttotheappropriatenessofusingexistingratestructurestoestimatedisposalcosts ofthesewastes.EnergySolutions'approachtoestimatingwastedisposalcostsisdiscussedinthefollowing paragraphs.

WasteClassification Regulationsgoverningdisposalofradioactivewastearestringentinordertoensurecontrolofthewasteand precludeadverseimpactonpublichealthandsafety.Atpresent,LLRWdisposaliscontrolledby10CFR61, whichwentintoeffectinDecember1983.Thisregulationstipulatesthecriteriafortheestablishmentand operation of shallowland LLRW burial facilities. Embodied within this regulation are criteria and classificationsforpackagingLLRWsuchthatitisacceptableforburialatlicensedLLRWdisposalsites.

Foreachwasteclassification,10CFR61stipulatesspecificcriteriaforphysicalandchemicalpropertiesthat the LLRW must meet in order to be accepted at a licensed disposal site. The LLRW disposal criteria of 10CFR61 require that LLRW generators determine the proportional amount of a number of specific radioactiveisotopespresentineachcontainerofdisposableLLRW.Thisrequirementforisotopicanalysisof eachcontainerofdisposableLLRWis metbyemployinga combinationofanalyticaltechniquessuch as computerizedanalysesbaseduponscalingfactors,samplelaboratoryanalyses,anddirectassaymethods.

Having performed an isotopic analysis of each container of disposable LLRW, the waste must then be classifiedaccordingtooneoftheclassifications(ClassA,B,C,orGreaterThanClassC(GTCC))asdefinedin 10CFR61.

EnergySolutions'classificationofLLRWresultingfromdecommissioningactivitiesisbasedonAIF/NESP036 (Ref.No.2),NUREG/CR0130(Ref.No.4),plantspecificinformationandrecentindustryexperience.The estimated curie content of the reactor vessel and internals at shutdown is typically derived from

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Page12of31 NUREG/CR0130forPressurizedWaterReactors(PWRs)andNUREG/CR0672forBoilingWaterReactors (BWRs)andadjustedforthedifferentmassofcomponentsandperiodofdecay.

Packaging SelectionofthetypeandquantityofcontainersrequiredforClassBandCwastesisbasedonthemost restrictiveofeitherCuriecontent,doserate,containerweightlimit,orcontainervolume limit. Residual spentfuelandGTCCwastesfromsegmentationofthereactorvesselinternalsandotheraccidentrelated wasteisnormallypackagedinmodifiedspentfuelcanistersandthispackagingisassumedfortheDCE.The selectionofcontainertypeforClassAwasteisbasedonthetransportationmode(rail,truck,barge,etc.)and wasteform.ThequantityofClassAwastecontainersisdeterminedbythemostrestrictiveofeithercontainer weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactorrecirculationpumps,areshippedastheirowncontainerswithadditionalshieldingasrequired.

Container costs are obtained from manufacturers specializing in the design and fabrication of storage containersfornuclearmaterials.Shieldedtransportcaskandlinercostsareobtainedfromthecaskowners andoperators.

Transportation Transportationroutestoprocessinganddisposalfacilitiesaredeterminedbasedonavailabletransportation modes(truck,rail,barge,orcombinations).Transportationcostsfortheselectedroutesandmodesare obtainedfromvendorquotesorpublishedtariffswheneverpossible.

ClassADisposalOptionsandRates ClassAwastethatmeetsthewasteacceptancecriteriaaretobedisposedofatEnergySolutions'LLRW disposalfacilityinClive,Utah.Allreportedwastedisposalcostsincludepackaging,transportationandany applicablesurcharges.

ClassBandCDisposalOptionsandRates Currently, within the United States, there are only three operational commercial nearsurface disposal facilitieslicensedtoacceptClassBandCLLRW:theBarnwellfacility,operatedbyEnergySolutionsinBarnwell, SouthCarolina;theU.S.EcologyfacilityinRichland,Washington;andthefacilityinAndrewsCounty,Texas, operatedbyWasteControlSpecialists(WCS).BarnwellonlyacceptswastefromstateswithintheAtlantic Compact and U.S. Ecology only accepts waste from states within the Northwest and Rocky Mountain Compacts.However,theWCSfacilitywillacceptwastefromtheTexasCompact(comprisedofTexasand Vermont)andfromnonCompactgenerators.TheTexasCompactCommissiononMarch23,2012,approved amendmentstorulesallowingtheimportofnoncompactgeneratorLLRWfordisposalattheWCSAndrews Countyfacility.

TransportationcostsinthisestimatefortheClassBandCwastearebasedonadistanceof900milesone wayfromFortCalhountotheWCSfacility.

GreaterThanClassC(GTCC)

Wastesidentifiedas10CFR61ClassA,B,andCmaybedisposedofatnearsurfacedisposalfacilities.Certain componentsarehighlyactivatedandmayexceedtheradionuclideconcentrationlimitationsfor10CFR61 ClassCwaste.Inaccordancewith10CFR61,thesecomponents,whicharereferredtoasGTCCwastes,cannot bedisposedofinanearsurfaceLLRWdisposalfacilityandmustbetransferredtoageologicrepositoryora similarsiteapprovedbytheNRC.

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Page13of31 Highlyactivatedsectionsofthereactorvesselinternalsandcertaindecommissioningprocesseswillresultin GTCC waste. Presently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations.EnergySolutionsassumesthattheDOEwillacceptthiswastealongwithspentfuel.Although courtshaveheldthatDOEisobligatedtoacceptanddisposeofGTCC,issuesregardingpotentialcostsremain unsettled.Therefore,EnergySolutionsconservativelyestimatesaGTCCwastedisposalcost.

LLRWVolumeReduction Because current Class A LLRW disposal rates are significantly lower than LLRW volume reduction rates, EnergySolutionsdoes not assumeonsitevolumereductiontechniquessuch aswastecompactionor an aggressivedecontamination,surveyandreleaseeffort.

NonRadioactiveNonHazardousWasteDisposal EnergySolutionsassumesthatrecyclable,nonradioactivescrapmetalresultingfromthedecommissioning programwillbesoldtoascrapmetaldealer.

HazardousandIndustrialWasteDisposal Uncontaminatedleadshieldingremainingaftershutdownwasassumedtoberemovedfromitsinstalled locationsandshippedoffsitebyentitieshavinganeedforthematerial.Theentitieswillreceivetheleadat nochargeinreturnforprovidingtheremovalandshippingservices.NonRadioactivecontaminatedsurfaces coatedwithtightlyadheringandundamagedleadbasedpaintwillberemovedasnonhazardousbuilding demolitiondebris.Allotherchemicalsandhazardousmaterialspresentatshutdownwillberemovedand properlydisposedofduringdecommissioning.

3.5 FinalStatusSurvey Thecostofperformingafinalstatussurvey(FSS)isbasedonNUREG1575,"MultiAgencyRadiationSurvey and Site Investigation Manual (MARSSIM)" (Ref. No. 5). Estimates of MARSSIM Class I, II, and III survey designationsarebasedonradiologicalassumptionsregardingcontaminationresultingfromsmallandlarge component removal activities. The FSS activity cost calculation includes the inplace remote survey of undergroundmetalandconcretepipe,soil,andgroundwatersamplingandanalysis.EstimatedcostsforNRC andOakRidgeInstituteforScienceandEducation(ORISE)verificationarealsoincluded,andtheNRCreview periodisincorporatedintotheprojectschedule.

3.6 Contingency Contingenciesareappliedtocostestimatesprimarilytoallowforunknownorunplannedoccurrencesduring the actual program, e.g., increased radioactive waste materials volumes over that expected; equipment breakdowns,weatherdelays,andlaborstrikes.ThisisconsistentwiththedefinitionprovidedintheDOECost EstimatingGuide,DOEG430.11,32897(DOEG)(Ref.No.6).Contingency"coverscoststhatmayresult from incomplete design, unforeseen and unpredictable conditions, or uncertainties within the defined project scope. The amount of contingency will depend on the status of design, procurement, and construction;andthecomplexityanduncertaintiesofthecomponentpartsoftheproject.Contingencyisnot tobeusedtoavoidmakinganaccurateassessmentofexpectedcosts."EnergySolutionsdeterminessite specificcontingencyfactorstobeappliedtoeachestimatebasedonindustrypractices.

TheDOEhasestablishedarecommendedrangeofcontingenciesasafunctionofcompletenessofprogram design,DOEG.Therangesare:

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ContingencyRange

TypeofEstimate

asa%ofTotalEstimate

PlanningPhaseEstimate

2030

BudgetEstimate

1525

TitleI(PreliminaryDesignEstimate)

1020

TitleII(DefinitiveDesignEstimate)

515

TheFortCalhounDECONscenariohashadsubstantialdevelopmentandtheFuelPooltoPadprogramisin progressasofDecember31,2018.ForthepurposesofthisestimatewehaveconsideredthistobeaBudget Estimate designed to provide sufficient information to OPPD to assess its financial obligations for decommissioningFortCalhoun.Itisnotadetailedbudget,butafinancialanalysispreparedinadvanceofthe detailedexecutionplanningandbudgetingworkrequiredtocarryoutthedecommissioning.

AreactordecommissioningprogramwillbeconductedunderanNRCapprovedQualityAssuranceProgram whichmeetstherequirementsof10CFR50,AppendixB.However,thedevelopmentofthequalityassurance program,theperformanceofworkunderthatprogram,andtheeffortrequiredtoensurecompliancewith theprogram,isalreadyincludedinthedetailedcostestimate.Therefore,EnergySolutionsdoesnotinclude qualityassuranceasanelementofthecontingencyallowance.Thesameistrueforcontamination.Where radioactivecontaminationoractivatedmaterialsaredealtwith,thecostfactorsandassociatedcalculations fullyreflectthecostimpactofthatmaterial,andaseparatecontingencyisnotrequiredspecificallydueto workingwithcontamination.

3.7 CostReporting Totalprojectcostsareaggregatedfromthedistributedactivityandundistributedcostsintothefollowing categories:

Labor MaterialsandEquipment WastePackagingandTransportation WasteDisposal Subcontracts OtherCosts Othercostsincludepropertytaxes,insurance,licensefees,permits,andenergy.WasteDisposalcostsinclude anyapplicablesurcharges.Healthphysics(HP)suppliesandsmalltoolcostsarecalculatedasacomponent ofeachdistributedactivitycostandincludedinthecategoryofMaterialandEquipment,withtheexception thatHPsuppliesfortheUtilityHPstaffarecalculatedandreportedasanundistributedlineitem.Alineitem specificcontingencyisthencalculatedforeachactivitycostelement.

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Page15of31 4.0SITESPECIFICTECHNICALAPPROACH 4.1 FacilityDescription FortCalhounisownedbytheOmahaPublicPowerDistrict(OPPD)andislocatedbetweenFortCalhounand Blair,Nebraska,adjacenttotheMissouriRiver.

TheNuclearSteamSupplySystem(NSSS)consistsofa1500MwtPressurizedWaterReactorsuppliedby CombustionEngineering.

ThestationhasanonsiteIndependentSpentFuelStorageInstallation(ISFSI)consistingofTRANSNUCLEAR 32PTspentfuelstoragecanistersstoredinsideofNUHOMShorizontalstoragemodules.

4.2 MajorWorkPeriodsforPromptDECON TheestimatehasbeenorganizedintofiveMajorWorkPeriods,eachwithsubperiodsanddefinedscope activitiesasfollows:

Period1-TransitionthroughSNFTransfertoISFSI:

Period1a-SAFSTOR&Transition:

Period1a.1-Planning&Procedures(completed)

Period1a.2-ISFSIDesign&Construction(completed)

Period1a.3-ISFSISecurityModifications(completed)

Period1a.4-FuelPoolOperations(completed)

Period1b-SpentFuelTransfertoISFSI:

Period1b.1-SecuritythroughFuelTransfer(inprogress)

ISFSI&PlantSecurityStaff

Period1b.2-Design&ProcureFuel&GTCCCasks(inprogress)

Design&ProcureFuelCasks Design&ProcureGTCCCasks CaskVendorTechSupport

Period1b.3-FuelPoolOperations(inprogress)

SpentFuelOperationsSupport FuelPoolWaterProcessing FuelPoolCleanup

Period1b.4-FuelTransferOperations(inprogress)

ProcureTransport/TransferEquipment SpentFuelTransfer

Period1b.5-UtilityStaffthroughFuelTransfer(inprogress)

UtilityProjectStaff ISFSIOperations&Maintenance

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Page16of31 Period2-LicenseTermination:

Period2a-DecommissioningPlanning&Preparations:

Period2a.1-SiteAssessments(completed)

Period2a.2-LTPPlanning&Preparation LTPPreparation

Period2a.3-PlanningServices GeneralPlanningServices SiteSurveys&Characterization ProcurementPlanning BaselineDevelopment

Period2a.4-InfrastructureUpgrades RoadUpgrades RailUpgrades

Period2a.5-DecommissioningElectrical Cold&DarkOperations TemporaryPowerUpgrades

Period2b-RadDecommissioning&LicenseTermination:

Period2b.1-ReactorVessel DevelopRVI/RVPlans&Procedures ProcureRVIEquipment RVIEquipmentTechSupport RVISegmentation&Removal RVIGTCCOperations&Loading ProcureRVEquipment RVEquipmentTechSupport RVSegmentation&Removal

Period2b.2-LargeComponentRemoval HeavyLift/TransferEquipment RemainingLegacyLargeComponentRemoval SteamGeneratorRemoval PressurizerRemoval RCPRemoval

Period2b.3-RadBuildingInterior/SystemsD&D AsbestosAbatement ChemicalDecon ReactorBldg.Interior/SystemsDemo AuxBldg.Interior/SystemsDemo RadWasteBldg.InteriorDemo

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Page17of31 MiscRadSystemsRemoval D&DContractorStaff D&DContractorTools&Equipment D&DContractorScaffolding

Period2b.4-RadBuildingOpenAirDemolition ReactorBuildingDemo AuxBuildingDemo RadWasteBldg.InteriorDemo MiscRadBuilding&OpenAirDemo FiringRange DrainageLagoons D&DContractorStaff D&DContractorTools&Equipment D&DContractorScaffolding

Period2b.5-FieldWasteOperations WasteHandling&LoadoutEquipment WasteHandling&Loadout WasteRadTechs

Period2b.6-RadWasteTransportation&Disposal ClassAWasteDisposal ClassB&CWasteDisposal RemainingLegacyLargeComponentDisposal

Period2b.7-NonRad&HazardousWasteDisposal RecycleMaterials NonRadLocalLandfill

Period2b.8-FieldRadiationProtection RadProtectionTechs

Period2b.9-FieldRadSurveys&FinalSiteSurveys FinalSiteSurveys

Period2c-LicenseTerminationUndistributedCosts:

Period2c.1-UtilityStaffduringDecommissioning UtilityManagementStaff TemporaryFacilities EnvironmentalProgram DecommissioningNRCFees&Inspections SafetyProgram&Supplies TrainingProgram

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Period2c.2-PlantOperations&Maintenance PlantOperations&Maintenance(nonlabor)

WaterProcessing UtilityCosts

Period2c.3-PlantSecurityduringDecommissioning PlantSecurity

Period2c.4-ContractorProjectManagement DGCContractorMobilization DGCStaff ContractorRadProtectionProgram DGCContractorDemobilization

Period2c.5-InsuranceandTaxes ANIInsuranceCosts NEILInsuranceCosts PropertyTaxes UseTaxes

Period2c.6-CorporateAllocations CorporateA&GAllocations Communications&TelecomAllocations InformationTechnologyAllocations StoresExpenseAllocations Period3-SiteRestoration:

Period3a-CleanDemolition&SiteRestoration:

Period3a.1-CleanBuildingDemolition AsbestosAbatement TurbineBuilding IntakeStructure Mausoleum New&OldWarehouseDemo MiscCleanBuildingDemo UndergroundPiping&Utilities Yard/ParkingLotPavement&Concrete METTower D&DContractorStaff D&DContractorTools&Equipment

Period3a.2-Fill&BackfillMaterials Process&ReuseOnSiteFillMaterials ImportedFillMaterials

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Period3a.3-Backfill&GradeBuildings Backfill&GradeBuildings

Period3a.4-NonRadEnvironmentalRemediation NonRadEnvironmentalRemediation

Period3a.5-FinalSiteRestoration FinalSiteGrading

Period3b-SiteRestorationUndistributedCosts:

Period3b.1-UtilityStaffduringDecommissioning UtilityManagementStaff TemporaryFacilities EnvironmentalProgram SafetyProgram&Supplies TrainingProgram

Period3b.2-PlantOperations&Maintenance PlantOperations&Maintenance(nonlabor)

WaterProcessing UtilityCosts

Period3b.3-PlantSecurityduringDecommissioning PlantSecurity

Period3b.4-ContractorProjectManagement DGCContractorMobilization DGCStaff ContractorRadProtectionProgram DGCContractorDemobilization

Period3b.5-InsuranceandTaxes NEILInsuranceCosts PropertyTaxes UseTaxes

Period3b.6-CorporateAllocations CorporateA&GAllocations Communications&TelecomAllocations InformationTechnologyAllocations StoresExpenseAllocations

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Page20of31 Period4-SNF/GTCCDryStorage&TransfertoDOE:

Period4a-SpentFuelDryStorage:

Period4a.1-ISFSISecurity&Operations ISFSISecurityduringDecommissioning ISFSISecurityafterDecommissioning ISFSIOperations&Maintenance ISFSINRCFees ISFSIDAWWaste

Period4a.2-ISFSIInsurance&Taxes ISFSIInsurance

Period4a.3-ISFSIUtilityStaff ISFSIUtilityStaffduringDecommissioning ISFSIUtilityStaffafterDecommissioning

Period4a.4-ISFSICorporateAllocations CorporateA&GAllocations

Period4b-SpentFuel&GTCCTransfertoDOE:

Period4b.1-SpentFuel&GTCCTransfertoDOE Procure/RentTransport/TransferEquipment SpentFuel&GTCCTransferOperations Period5-ISFSIDecommissioning:

Period5a-ISFSIDemolition&SiteRestoration:

Period5a.1-ISFSIDemolition&SiteRestoration ISFSIDecommissioning&Demolition ISFSISiteRestoration

Period5b-ISFSIDecommissioningUndistributedCosts:

Period5b.1-ISFSIDecommissioningUndistributedCosts SecurityduringISFSIDecommissioning UtilityStaffduringISFSIDecommissioning

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Page21of31 4.3 DecommissioningStaff EnergySolutionsdevelopedstaffingbasedontheassumptionthattheFortCalhoundecommissioningproject willbeperformedinanefficientlyplannedandexecutedmannerusingprojectpersonnelexperiencedin decommissioningandlargescaleprojectmanagement.ThisDCEalsoassumesthatthedecommissioning workwillbeperformedbyahighlyexperiencedandqualifiedDecommissioningContractors,withoversight andmanagementofthedecommissioningoperationsperformedbytheOPPDstaff,workinginpartnership with,andsupplementedbyahighlyexperiencedandqualifiedDecommissioningGeneralContractor(DGC).

EstimatedStafflevelsareprovidedinSection6.0,Table64.

4.4 SpentFuelManagement Thelargestspentfuelstaffisinplacewhilethefuelpoolisoperationalduringthespentfuelcoolingperiod andthefuelassembliesarebeingtransferredtodrystorage.Afterallspentfuelhasbeenremovedfromthe spentfuelpool,thestaffisreduced.Duringspentfuelpooloperationsandthedrystorageperiod,thefull timespentfuelmanagementstaffissupplementedwithparttimestafftosupportfuelmovements.Details onthestafflevelsareprovidedinSection6.0.

4.5 SpentFuelShipments TheDOEcurrentlyhasnoplans,program,orscheduleinplaceforacceptanceofutilityspentfuel.However, forpurposesofthisDecommissioningCostEstimate,certainsimplifyingassumptionsmustbemaderegarding thescheduleandrateofDOEperformance.ThespentfuelshippingschedulesarebasedinpartontheDOEs AcceptancePriorityRanking&AnnualCapacityReport,datedJuly2004.(Ref.No.7).Baseduponthebest currentinformationavailable,thisDCEisbasedontransferofallSpentFuelandGTCCmaterialtotheDOE bytheendof2058.

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Page22of31 5.0BASESOFESTIMATEANDKEYASSUMPTIONS TheBasisofEstimateandkeyassumptionsforthisDecommissioningCostEstimatearepresentedbelow:

1.

TheDCEisbasedonPromptDECONDecommissioningusingaHybridmodel,whereOPPDworks in unison with a competent Decommissioning General Contractor, using currently available technologiesandinaccordancewithcurrentregulations.

2.

TheDCEispresentedin2018dollarsandisbasedonestimatedcostsforwardfromDecember 31,2018.

3.

IthasbeenassumedthatShutdown,TransitionPlanning,andFuelSamplingactivitieshavebeen completedpriortoDecember31,2018.

4.

IthasbeenassumedthatrequiredISFSIdesignandconstructionactivitieshavebeencompleted priortoDecember31,2018.

5.

SpentFuelPoolandPooltoPadOperationsareinprogressasofDecember31,2018.

6.

The contract for removal, transportation and disposal of the Legacy Reactor Vessel Head, PressurizerandSteamGeneratorsisinprogressasofDecember31,2018.

7.

OPPDstaffandsecuritylevelsarebasedonthestaffingplansprovidedbyOPPD,butmayvary basedonattrition.

8.

OPPDstaffandsecuritylaborcostsarebasedon2018informationprovidedbyOPPD.

9.

CorporateAllocationsandcostincludedintheDCEarebasedonthe2018DCEDataRequest including:

EmployeeSeveranceand/orRetentionCosts SiteO&M(nonlaborandrecurringcost)

CorporateA&G PostShutdownInsurancePremiums NEI,INPO,NEIPADSMemberships,Fees Taxes,Assessments,PaymentsinLieuofTaxes SupportServicesCosts

10.

Contingenciesincludedintheestimateareconsistentwithabudgetestimatedesignedtoprovide sufficient information to OPPD to assess its financial obligations for decommissioning Fort Calhoun.

11.

Costsfortransportationofcleanscrapmetaltoarecyclerareincludedintheestimate;however, acredithasbeenincludedforthevalueofscrapmetal.

12.

Costsforhazardouswastedisposal,aswellasasbestosandleadabatement,areincludedinthis study.

13.

AllClassAwasteisassumedtobedisposedofatEnergySolutionsfacilityinClive,Utah.

14.

Class A waste includes Dry Active Waste (DAW) arising from the disposal of contaminated protectiveclothingandhealthphysicssupplies.

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15.

ClassBandCwastedisposalcostsarebasedondisposalofactivatedhardwareandresinsatthe WasteControlSpecialists,Texasfacility.AllresinsandfilterwasteareassumedtobeClassB.

16.

TransportationcostsfortheClassBandCwastearebasedonadistanceof900milesoneway fromFortCalhountotheWCSfacility.

17.

TheDCEincludesestimatedcostsforGTCCwastetobepackagedinmodifiedspentfuelcanisters, orsimilarcontainers.

18.

ItisassumedSpentFuelandGTCCwastewillbetransferredtotheDOEattheFortCalhoun location,atOPPDexpense,andthattheDOEwilltakeresponsibilityforthetransportationand disposalofSpentFuelandGTCCwasteatalicensedDOEfacility.

19.

The10CFRPart50licensewillbemaintaineduntilDOEhastakenpossessionofthespentfuel andtheISFSIhasbeendecommissioned.

20.

TheDCEincludestheannualNRC10CFR171.15(c)(2)fees,forreactorsindecommissioninguntil decommissioning is completed as a license termination expense. Following completion of decommissioning,thisexpenseiscontinuedasaSNF/GTCCmanagementcostformaintenance ofthe10CFRPart50license.

21.

TheDCEincludesNRCinspectionfeesduringeachdecommissioningperiodbasedonthetype andlevelofactivitiesbeingperformed.

22.

ThePSDARwillrequirerevisiontoaddresspromptDECONversusSAFSTOR.

23.

TheDOEcurrentlyhasnoplans,program,orscheduleinplaceforacceptanceofutilityspentfuel.

However,forpurposesofthisDecommissioningCostEstimate,certainsimplifyingassumptions mustbemaderegardingthescheduleandrateofDOEperformance.Thespentfuelshipping schedules are based in part on the DOEs Acceptance Priority Ranking & Annual Capacity Report,datedJuly2004.(Ref.No.7).Baseduponthebestcurrentinformationavailable,this DCEisbasedontransferofallSpentFuelandGTCCmaterialtotheDOEbytheendof2058.

24.

Thisestimateisbasedoncurrentexistingsiteandbuildingdrawingsandplantsystemsdata provided by OPPD combined with EnergySolutions decommissioning experience to establish plantsystemsandbuildingsinventories.Theseinventories,EnergySolutionsproprietaryUnitCost Factors(UCFs)andotherplantdata,wereusedtogeneratetherequiredlaborhours,cost,waste volumes,weightsandclassifications.

25.

AlltransformersonsitefollowingshutdownareassumedtobePCBfree;therefore,thisstudy doesnotincludecostsfordispositionofPCBcontaminatedtransformers.

26.

Itisassumedthatuncontaminatedleadshieldingremainingisassumedtoberemovedfromits installedlocationsandshippedoffsitebyentitieshavinganeedforthematerial.Theentities receivetheleadatnochargeinreturnforprovidingremovalandshippingservices.

27.

Nonradconcretedebrisandallotherdemolitiondebrisnotsuitableforbackfillareassumedto beremovedfromthesiteanddisposedofatalocallandfill.

28.

Foundationsandbuildingexteriorswallsareremovedtoadepthofthreefeetbelownominal gradeelevation,surveyedandbackfilledwithappropriatefillmaterial.

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29.

Cleanbackfillwillbeimportedandplacedtoreestablishgrade.Theentiredisturbedareaofthe siteistobegraded,torestorethenaturalgradetotheextentpossible,andseeded.

30.

Theestimateisbasedonfinalsiterestoration,inwhichallexistingandproposedstructures,with theexceptionoftheTrainingCenter,AdministrationBuilding,FLEXBuildingandtheSwitchyard, willberemoved.Cleandemolitioncostsarebasedontheassumptionthatallsiteimprovements willberemovedintheirentirety.

31.

Water processing operations are estimated based upon an experienced decommissioning operationscontractorperformingthedecommissioningandunderstandingtheprojectedwater requirements.

32.

Thewastegeneratedfromthesegmentationofthereactorvesselinternalswillbepackagedin MultiPurposeCanisters(MPCs).Forthisestimate,theMPCsareassumedtobeacceptedbyDOE atthetimeofshipment.

33.

The ISFSI fuel storage structures are assumed to have no activated concrete or surface contamination.

34.

Theestimateincludescontingency,butgenerallydoesnotincludeanyallowanceforsubstantive scheduledelays,norcostallowanceforfieldlaborretainedonsitewhilewaitingforworkto becomeavailable.

35.

Thecostsofallrequiredsafetyanalysesandsafetymeasuresfortheprotectionofthegeneral public,theenvironment,anddecommissioningworkersareincludedinthecostestimates.This reflectstherequirementsof:

10CFR20 StandardsforProtectionAgainstRadiation 10CFR50 DomesticLicensingofProductionandUtilizationFacilities 10CFR61 LicensingRequirementsforLandDisposalofRadioactiveWaste 10CFR71 PackagingandTransportationofRadioactiveMaterial 10CFR72 LicensingRequirementsfortheIndependentStorageofSpentNuclearFuel

andHighLevelRadioactiveWaste 29CFR1910 OccupationalSafetyandHealthStandards 49CFR170189 DepartmentofTransportationRegulationsGoverningtheTransportof

HazardousMaterials Reg.Guide1.159 AssuringtheAvailabilityofFundsforDecommissioningNuclearReactors

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Page25of31 6.0STUDYRESULTS CostSummarybyLicenseTermination,SpentFuelandSiteRestoration AsummaryofthecostestimateisprovidedinTable61below.ThistableprovidesLicenseTerminationcost (correspondingto10CFR50.75(c)requirements);SpentFuelManagementcosts(correspondingto10CFR 50.54(bb) requirements) and Site Restoration costs (corresponding to activities such as clean building demolitionandsitegradingetc.).

TABLE61

GTCCcasksandoperationsareincludedintheLicenseTerminationCosts.GTCClongtermISFSIstorageand dispositionareincludedintheSpentFuelCosts.

AdetailedcosttableisprovidedinAppendixC.

SummarySchedule ThecostsandscheduleforthePromptDECONscenarioaredividedintomajorprojectperiods:

Period1TransitionthroughSNFTransfertoISFSI Period2LicenseTermination Period3SiteRestoration Period4SNF/GTCCDryStorage&TransfertoDOE Period5ISFSIDecommissioning

Figure61belowshowsasummarylevelPromptDECONschedule.

AdetailedscheduleisprovidedinAppendixB.

License Termination Spent Fuel Site Restoration Total

$725,243

$358,944

$44,903

$1,129,091 PROMPT DECON SCENARIO Decommissioning Cost Estimate (thousands of 2018 Dollars)

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Page26of31 FIGURE61 PromptDECONSchedule

CostSummarybyPeriod ThefollowingTable62providesacostsummaryforthePromptDECONScenariobyPeriod.

ThedetailedDecommissioningCostEstimateisprovidedinAppendixC.

Description EstimatedDecommissioningDuration=7years SpentFuelPooltoPadOperations DecommissioningContractorNoticetoProceed DecommissioningPlanning&Preparation FinalizeDecommissioningExecutionBaselines SiteCharacterization&Assessments ProcureRVI&RVSegmentationEquipment SiteModifications&InfrastructureUpgrades RVI&RVSegmentation&Disposal NonRadBuilding&SiteDemolition LargeComponents&RadSystemsRemoval RadBuildingDecontamination&Demolition FinalStatusSurveys SiteRestorationActivities NRCReviewsandApprovals LicenseTermination ISFSIOperations&DryFuelStorage SpentFuel&GTCCTransfertoDOE ISFSIDecommissioning&SiteRestoration ISFSISiteRestorationComplete 2059 OPPDFORTCALHOUNDECONSCHEDULE 2027 2057 2058 2025 2026 2019 2020 2021 2022 2023 2024

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Page27of31 TABLE62 DECONCostSummarybyPeriod

CostSummarybyCostType ThefollowingTable63providesacostsummaryforthePromptDECONScenariobyCostType.

ForTable63,OtherDirectCostsgenerallyincludemiscellaneousservicessuchasTemporaryFacilities; LicensingCosts;NRCFees,Insurances,Taxes,Permits,CorporateAllocations,etc.

ThedetailedDecommissioningCostEstimateisprovidedinAppendixC.

Period ItemDescription EstimatedCost Contingency Total 1aTotalSAFSTOR&Transition(Completed)

1bTotalSpentFuelTransfertoISFSI 50,465 5,046 55,511 Period1TotalTransitionthroughSNFTransfertoISFSI 50,465 5,046 55,511 2aTotalDecommissioningPlanning&Preparations 19,468 1,947 21,415 2bTotalRadDecommissioning&LicenseTermination 312,367 39,524 351,891 2cTotalLicenseTerminationUndistributedCosts 315,843 31,584 347,427 Period2TotalLicenseTermination 647,678 73,055 720,733 3aTotalCleanDemolition&SiteRestoration 28,052 2,805 30,857 3bTotalSiteRestorationUndistributedCosts 12,769 1,277 14,046 Period3TotalSiteRestoration 40,821 4,082 44,903 4aTotalSpentFuelDryStorage 260,402 28,426 288,828 4bTotalSpentFuel&GTCCTransfertoDOE 12,700 1,905 14,605 Period4TotalSNF/GTCCDryStorage&TransfertoDOE 273,102 30,331 303,433 5aTotalISFSIDemolition&SiteRestoration 3,111 467 3,578 5bTotalISFSIDecommissioningUndistributedCosts 848 85 933 Period5TotalISFSIDecommissioning 3,959 551 4,511 GrandTotal 1,016,025 113,066 1,129,091

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Page28of31 TABLE63 DECONCostSummarybyCostType

ProjectStaffing Table64showstheestimatedannualaverageDECONStaffing&SecurityManpower.

TABLE64

Labor Cost 449,408 Materials & Equipment Cost 68,160 Waste Packaging & Transportation 27,517 Waste Disposal 138,189 Subcontracts 177,654 Other Direct Costs 155,096 Contingency 113,066 Total Cost 1,129,091 PROMPT DECON SCENARIO Estimated Costs to Complete as of December 31, 2018 (thousands of 2018 Dollars) 2019 2020 2021 2022 2023 2024 2025 2026 2027-2058 2059 1b.1.1 OPPD Security Staff through Fuel Transfer 2

2 1b.5.1 OPPD Utility Staff through Fuel Transfer 18 14 2d.1.1 OPPD Utility Staff during Decommissioning 185 175 124 105 81 67 33 10 2d.3.1 OPPD Plant Security during Decommissioning 106 82 6

5 4

3 2

2 3a.1.1 OPPD ISFSI Security during Decommissioning 9

35 35 35 35 35 2

3a.1.2 OPPD ISFSI Security during Dry Fuel Storage 35 35 3a.3.1 OPPD ISFSI Staff during Decommissioning 10 10 10 10 10 13 5

3a.3.2 OPPD ISFSI Staff during Dry Fuel Storage 15 15 Average OPPD Personnel Count by Year 311 291 175 155 130 115 82 62 50 7

2a.3.4 DGC Baseline Development Staff 5

2 2d.4.2 Decommissioning General Contractor Staff 14 20 22 22 22 22 20 4

Average DGC Personnel Count by Year 19 22 22 22 22 22 20 4

TOTAL AVERAGE STAFF & SECURITY PERSONNEL 330 313 197 177 152 137 102 66 50 7

OPPD Estimated Staff & Security Manpower Average Personnel Count by Year

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Page29of31 WasteDisposalVolumes Table65belowprovidesasummaryofWasteDisposalVolumesbyWasteClassification.

TABLE65 WasteDisposalVolumes

AppendixA providesaWasteDisposalSummaryitemizedbyvolumes,wasteform,wasteclass,weight, volumeandcostsforpackaging,transportationanddisposal.

EstimatedAnnualSpending Table66belowshowstheestimatedAnnualSpending.

WasteClass Volume(cf)

ClassAWaste 2,497,082 ClassB&CWaste 1,666 GTCCWaste 1,180

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Page30of31 TABLE66

Year License Termination Spent Fuel Site Restoration Total 2019 95,185 29,326 124,510 2020 95,701 29,326 125,026 2021 87,270 7,674 4,315 99,260 2022 87,186 7,674 4,315 99,176 2023 99,523 7,674 11,984 119,181 2024 125,874 7,674 9,935 143,484 2025 114,298 7,674 14,042 136,014 2026 14,811 8,057 312 23,179 2027 885 8,057 8,942 2028 8,057 8,057 2029 8,057 8,057 2030 8,057 8,057 2031 8,057 8,057 2032 8,057 8,057 2033 8,057 8,057 2034 8,057 8,057 2035 8,057 8,057 2036 8,057 8,057 2037 7,213 7,213 2038 7,213 7,213 2039 7,213 7,213 2040 7,213 7,213 2041 7,213 7,213 2042 7,213 7,213 2043 7,213 7,213 2044 7,213 7,213 2045 7,213 7,213 2046 7,213 7,213 2047 7,213 7,213 2048 7,213 7,213 2049 7,213 7,213 2050 7,213 7,213 2051 7,213 7,213 2052 7,213 7,213 2053 7,213 7,213 2054 7,213 7,213 2055 7,213 7,213 2056 10,088 10,088 2057 13,078 13,078 2058 13,078 13,078 2059 4,511 4,511 Totals 725,243 358,944 44,903 1,129,091 PROMPTDECONSCENARIO ProjectedAnnualSpending (thousandsof2018Dollars)

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7.0REFERENCES

1. U.S.NuclearRegulatoryCommission,"DomesticLicensingofProductionandUtilizationFacilities,"10 CFRPart50,2008.

2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant DecommissioningCostEstimates,"AIF/NESP036,May1986.

3. U.S. Nuclear Regulatory Commission, "Standard Format and Content of Decommissioning Cost EstimatesforNuclearPowerReactors,"RegulatoryGuide1.202,February2005.

4. U.S.NuclearRegulatoryCommission,"Technology,SafetyandCostsofDecommissioningaReference PressurizedWaterReactorPowerStation,"NUREG/CR0130,June1978.

5. U.S.NuclearRegulatoryCommission,"MultiAgencyRadiationSurveyandSiteInvestigationManual (MARSSIM),"NUREG1575,Rev.1,August2000.

6. U.S.DepartmentofEnergy,"CostEstimatingGuide,"DOEG430.11,March1997.

7. U.S.DepartmentofEnergy,AcceptancePriorityRanking&AnnualCapacityReport,DOE/RW0567, July2004.

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APPENDIXA WasteDisposalSummary

Facility Waste Form Waste Class Waste Weight (LBs)

Waste Volume (CF)

Burial Volume (CF)

Packaging &

Transportation Burial Cost Total Waste Cost Rad Waste WCS Cask B/C 161,178 1,791 1,666 1,522 20,819 22,341 Clive CWF A

422,708 9,682 11,613 2,402 3,360 5,763 Clive Debris A

139,648,601 2,432,698 2,441,460 12,955 102,892 115,847 Clive Large Component A

2,604,487 26,650 28,132 7,517 6,427 13,944 Clive Legacy Components A

15,878 3,121 3,121 6,242 142,836,973 2,470,821 2,498,748 27,517 136,619 164,136 Other Local Landf Clean/Exempt F

1,982,766 72,184 72,200 2,922 3,327 Local RecycRecycled Metals F

24,497,545 1,224,877 1,225,692 (1,715)

(1,715)

On Site Clean/Exempt F

182,542,639 2,028,252 2,028,400 209,022,949 3,325,313 3,326,292 1,207 1,613 Grand Total 351,859,923 5,796,134 5,825,040 27,517 137,826 165,749 Appendix A OPPD - Fort Calhoun Station Waste Disposal Summary (thousands of 2018 dollars)

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APPENDIXB

DECONProjectSchedule

Activity ID Activity Name Original Duration Start Finish Major Milestones Major Milestones Major Milestones Major Milestones Major Milestones Milestones Milestones Milestones Milestones Milestones A1000 Decommissioning General Contractor Notice to Proceed (NTP) 0 02-Apr-2019*

A1100 Spent Fuel Pool to Pad Operations Complete 0

22-Dec-2020 A1200 GTCC Transfer to ISFSI Complete 0

30-Sep-2021 A1300 Reactor Vessel Segmentation Complete 0

30-Jun-2022 A1400 All Large Components Off Site 0

31-Jul-2023 A1500 All Building Demolition Complete 0

30-Jul-2025 A1600 All Rad Waste Off Site 0

31-Oct-2025 A1700 Site Restoration Complete 0

31-Mar-2026 A1800 License Termination Complete 0

30-Oct-2026 Period 1 Transition through SNF Pool to ISFSI Period 1 Transition through SNF Pool to ISFSI Period 1 Transition through SNF Pool to ISFSI Period 1 Transition through SNF Pool to ISFSI Period 1 Transition through SNF Pool to ISFSI 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1b.100 Security through Fuel Transfer 500 02-Jan-2019 22-Dec-2020 1b.200 Design & Procure Fuel & GTCC Casks 250 02-Jan-2019 27-Dec-2019 1b.300 Fuel Pool Operations 500 02-Jan-2019 22-Dec-2020 1b.400 Fuel Pool to Pad Transfer Operations 450 02-Jan-2019 09-Oct-2020 1b.500 Utility Staff through Fuel Transfer 500 02-Jan-2019 22-Dec-2020 Period 2 License Termination Period 2 License Termination Period 2 License Termination Period 2 License Termination Period 2 License Termination 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2a.300 General Planning Services 120 14-Mar-2019 30-Aug-2019 2a.310 Develop Decommissioning Execution Baselines 180 30-Apr-2019 16-Jan-2020 2a.320 Site Characterization & Assessments 180 29-May-2019 13-Feb-2020 2a.200 License Termination Plan (LTP) Preparation 320 25-Jul-2019 28-Oct-2020 2a.400 Infrastructure Upgrades 320 03-Sep-2019 08-Dec-2020 2a.500 Cold & Dark and Decommissioning Electrical 420 03-Sep-2019 03-May-2021 2.b Rad Decommissioning & License Termination 2.b Rad Decommissioning & License Termination 2.b Rad Decommissioning & License Termination 2.b Rad Decommissioning & License Termination 2.b Rad Decommissioning & License Termination 2b.200 Remove Remaining Legacy Large Components 300 02-Jan-2019 10-Mar-2020 2b.100 Develop Reactor Vessel Segmentation & Procurement Plan 120 30-Apr-2019 17-Oct-2019 2b.110 Procure & Deliver RVI Segmentation Equipment 240 19-Sep-2019 31-Aug-2020 2b.500 Field Waste Operations 1415 11-Mar-2020 17-Oct-2025 2b.120 Procure & Deliver RV Segmentation Equipment 240 24-Apr-2020 07-Apr-2021 2b.130 Reactor Vessel Internal (RVI) Segmentation 224 12-Oct-2020 31-Aug-2021 2b.600 Rad Waste Transportation & Disposal 1270 09-Dec-2020 23-Dec-2025 2b.140 GTCC Waste Transfer to ISFSI 120 13-Apr-2021 30-Sep-2021 2b.150 Reactor Vessel (RV) Segmentation 209 01-Sep-2021 30-Jun-2022 2b.210 Large Component Removal 292 03-Jun-2022 31-Jul-2023 2b.300 Rad Building Interior / Systems D&D 360 28-Oct-2022 04-Apr-2024 2b.400 Rad Building Open Air Demolition 365 21-Feb-2024 30-Jul-2025 2b.900 Field Rad Surveys & Final Site Surveys 240 23-Jan-2025 06-Jan-2026 2b.910 Final Survey Reports & Submittals 120 07-Oct-2025 31-Mar-2026 2b.920 NRC Reviews & Approvals 240 18-Nov-2025 30-Oct-2026 2.c ISFSI Security & Operations During Decommissioning 2.c ISFSI Security & Operations During Decommissioning 2.c ISFSI Security & Operations During Decommissioning 2.c ISFSI Security & Operations During Decommissioning 2.c ISFSI Security & Operations During Decommissioning 2c.100 ISFSI Security & Operations (2020 through 2026) 1526 12-Oct-2020*

30-Oct-2026 2c.300 ISFSI Utility Staff (2020 through 2026) 1526 12-Oct-2020*

30-Oct-2026 Period 3 Site Restoration Period 3 Site Restoration Period 3 Site Restoration Period 3 Site Restoration Period 3 Site Restoration Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Decommissioning General Contractor Notice to Proceed (NTP)

Spent Fuel Pool to Pad Operations Complete GTCC Transfer to ISFSI Complete Reactor Vessel Segmentation Complete All Large Components Off Site All Building Demolition Complete All Rad Waste Off Site Site Restoration Complete License Termination Complete Security through Fuel Transfer Design & Procure Fuel & GTCC Casks Fuel Pool Operations Fuel Pool to Pad Transfer Operations Utility Staff through Fuel Transfer General Planning Services Develop Decommissioning Execution Baselines Site Characterization & Assessments License Termination Plan (LTP) Preparation Infrastructure Upgrades Cold & Dark and Decommissioning Electrical Remove Remaining Legacy Large Components Develop Reactor Vessel Segmentation & Procurement Plan Procure & Deliver RVI Segmentation Equipment Field Waste Operations Procure & Deliver RV Segmentation Equipment Reactor Vessel Internal (RVI) Segmentation Rad Waste Transportation & Disposal GTCC Waste Transfer to ISFSI Reactor Vessel (RV) Segmentation Large Component Removal Rad Building Interior / Systems D&D Rad Building Open Air Demolition Field Rad Surveys & Final Site Surveys Final Survey Reports & Submittals NRC Reviews & Approvals ISFSI Security & Operations (2020 through 2026)

ISFSI Utility Staff (2020 through 2026)

Actual Work Remaining Work Critical Remaining Work Milestone OPPD - FORT CALHOUN STATION APPENDIX B - DECOMMISSIONING COST ESTIMATE SCHEDULE Page 1 of 2 Project: FCS DCE 01 - OPPD Fort Calhoun DCE - DECON Layout: FCS-01 TASK filter: All Activities Data Date: 01-Jan-2019 Printed: 07-Sep-2019

Activity ID Activity Name Original Duration Start Finish 3.a Clean Demolition & Site Restoration 3.a Clean Demolition & Site Restoration 3.a Clean Demolition & Site Restoration 3.a Clean Demolition & Site Restoration 3.a Clean Demolition & Site Restoration 3a.100 Clean Building & Site Demolition 1008 30-Jun-2021 30-Jun-2025 3a.300 Backfill & Grade Buildings 240 17-Oct-2024 30-Sep-2025 3a.500 Final Site Restoration 240 17-Apr-2025 31-Mar-2026 Period 4 SNF / GTCC Dry Storage & Transfer to DOE Period 4 SNF / GTCC Dry Storage & Transfer to DOE Period 4 SNF / GTCC Dry Storage & Transfer to DOE Period 4 SNF / GTCC Dry Storage & Transfer to DOE Period 4 SNF / GTCC Dry Storage & Transfer to DOE 4.a Spent Fuel Dry Storage 4.a Spent Fuel Dry Storage 4.a Spent Fuel Dry Storage 4.a Spent Fuel Dry Storage 4.a Spent Fuel Dry Storage 4a.100 ISFSI Security & Operations (2026 through 2058) 8352 02-Nov-2026* 31-Dec-2058 4a.300 ISFSI Utility Staff (2026 through 2058) 8352 02-Nov-2026* 31-Dec-2058 4.b Spent Fuel & GTCC Transfer to DOE 4.b Spent Fuel & GTCC Transfer to DOE 4.b Spent Fuel & GTCC Transfer to DOE 4.b Spent Fuel & GTCC Transfer to DOE 4.b Spent Fuel & GTCC Transfer to DOE 4b.100 Spent Fuel & GTCC Transfer to DOE (complete by end of 2058) 650 05-Jul-2056*

31-Dec-2058 Period 5 ISFSI Decommissioning Period 5 ISFSI Decommissioning Period 5 ISFSI Decommissioning Period 5 ISFSI Decommissioning Period 5 ISFSI Decommissioning 5.a ISFSI Demolition & Site Restoration 5.a ISFSI Demolition & Site Restoration 5.a ISFSI Demolition & Site Restoration 5.a ISFSI Demolition & Site Restoration 5.a ISFSI Demolition & Site Restoration 5a.200 ISFSI Decommissioning & Demolition (2059) 218 01-Jan-2059*

31-Oct-2059 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Clean Building & Site Demolition Backfill & Grade Buildings Final Site Restoration Actual Work Remaining Work Critical Remaining Work Milestone OPPD - FORT CALHOUN STATION APPENDIX B - DECOMMISSIONING COST ESTIMATE SCHEDULE Page 2 of 2 Project: FCS DCE 01 - OPPD Fort Calhoun DCE - DECON Layout: FCS-01 TASK filter: All Activities Data Date: 01-Jan-2019 Printed: 07-Sep-2019

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APPENDIXC DetailedCostEstimate

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours 1a

1a

1a.1 Planning&Procedures(completed)

0 1a 1a.2.1 ISFSIDesign&Engineering

1a 1a.2.2 ISFSIConstruction

1a.2 ISFSIDesign&Construction(completed)

0 1a 1a.3.1 ISFSISecurityModifications

1a.3 ISFSISecurityModifications(completed)

0 1a 1a.4.1 PerformFuelSampling&Analysis

1a 1a.4.2 FuelPoolOperations&Maintenance

1a.4 FuelPoolOperations(completed)

0 1aTotalSAFSTOR&Transition(Completed)

0 1b 1b.1.1 ISFSI&PlantSecurityStaff 395 39 434

434

7,280 1b.1 SecuritythroughFuelTransfer 395

39 434

434

7,280 1b 1b.2.1 Design&ProcureFuelCasks 10,908 1,091 11,999

11,999

1b 1b.2.2 Design&ProcureGTCCCasks 940 94 1,034

1,034

1b 1b.2.3 CaskVendorTechSupport(inclwithprocurement)

1b.2 Design&ProcureFuel&GTCCCasks

11,848

1,185 13,033

13,033

0 1b 1b.3.1 SpentFuelOperationsSupport 3,943 394 4,337

4,337

1b 1b.3.2 FuelPoolWaterProcessing 1,000 100 1,100

1,100

1b 1b.3.3 FuelPoolCleanup 1,500 150 1,650

1,650

1b.3 FuelPoolOperations

6,443 644 7,087

7,087

0 1b 1b.4.1 ProcureTransport/TransferEquipment

1b 1b.4.2 SpentFuelTransfer(includesequipment) 26,799 2,680 29,479

29,479

1b.4 FuelTransferOperations

26,799

2,680 29,479

29,479

0 1b 1b.5.1 UtilityProjectStaff 4,980 498 5,478

5,478

65,520 1b 1b.5.2 ISFSIOperations&Maintenance(inclwithUtilitystaff)

1b.5 UtilityStaffthroughFuelTransfer 4,980

498 5,478

5,478

65,520 1bTotalSpentFuelTransfertoISFSI 5,374 11,848

26,799 6,443 5,046 55,511

55,511

72,800 Period1TotalTransitionthroughSNFTransfertoISFSI 5,374 11,848

26,799 6,443 5,046 55,511

55,511

72,800 2a 2a.1.1 HistoricSiteAssessment(HSA)

2a 2a.1.2 EnvironmentalAssessments

2a.1 SiteAssessments(completed)

0 PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars)

Page1of6

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars) 2a 2a.2.1 LTPPreparation 682 68 750 750

2a.2 LTPPlanning&Preparation

682 68 750 750

0 2a 2a.3.1 GeneralPlanningServices(inclwithUtilityStaff)

2a 2a.3.2 SiteSurveys&Characterization 1,320 330 165 1,815 1,815

20,308

2a 2a.3.3 ProcurementPlanning(inclwithUtilityStaff)

2a 2a.3.4 BaselineDevelopment 2,133 1,148 328 3,609 3,609

15,260

2a.3 PlanningServices 3,453 330

1,148 493 5,424 5,424

35,568 2a 2a.4.1 RoadUpgrades

2a 2a.4.2 RailUpgrades 6,126 613 6,738 6,738

2a.4 InfrastructureUpgrades

6,126

613 6,738 6,738

0 2a 2a.5.1 Cold&DarkOperations 7,729 773 8,502 8,502

2a 2a.5.2 TemporaryPowerUpgrades(inclwithcold&dark)

2a.5 DecommissioningElectrical

7,729

773 8,502 8,502

0 2aTotalDecommissioningPlanning&Preparations 3,453 330

13,855 1,830 1,947 21,415 21,415

35,568 2b 2b.1.1 DevelopRVI/RVPlansandProcedures 411 221 63 695 695

2,000 2b 2b.1.2 ProcureRVIEquipment 20,009 2,001 22,010 22,010

2b 2b.1.3 RVIEquipmentTechSupport 2,354 235 2,589 2,589

2b 2b.1.4 RVISegmentation&Removal 8,214 821 9,035 9,035

2b 2b.1.5 RVIGTCCOperations&Loading(inclwithRVIRemoval)

2b 2b.1.6 ProcureRVEquipment 16,478 1,648 18,126 18,126

2b 2b.1.7 RVEquipmentTechSupport 412 41 453 453

2b 2b.1.8 RVSegmentation&Removal 3,791 379 4,170 4,170

2b.1 ReactorVessel 411 36,487

14,771 221 5,189 57,079 57,079

2,000 2b 2b.2.1 HeavyLift/TransferEquipment(inclwithsteamgenerator)

2b 2b.2.2 RemainingLegacyLargeComponentRemoval 5,056 506 5,562 5,562

2b 2b.2.3 SteamGeneratorRemoval 7,439 744 8,183 8,183

2b 2b.2.4 PressurizerRemoval 69 7

75 75

2b 2b.2.5 RCPRemoval 274 27 301 301

2b.2 LargeComponentRemoval

12,837

1,284 14,121 14,121

0 2b 2b.3.1 AsbestosAbatement 4,482 448 4,930 4,930

2b 2b.3.2 ChemicalDecon(inclwithwork)

2b 2b.3.3 ReactorBldg.Interior/SystemsDemo 3,457 346 3,803 3,803

2b 2b.3.4 AuxBldg.Interior/SystemsDemo 3,344 334 3,679 3,679

2b 2b.3.5 RadWasteBldg.InteriorDemo 1,729 173 1,902 1,902

2b 2b.3.6 MiscRadSystemsRemoval 6,820 682 7,502 7,502

2b 2b.3.7 D&DContractorStaff 1,729 173 1,902 1,902

2b 2b.3.8 D&DContractorTools&Equipment(inclwithwork)

2b 2b.3.9 D&DContractorScaffolding(inclwithwork)

2b.3 RadBldg.Interior/SystemsD&D

21,560

2,156 23,716 23,716

0 Page2of6

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars) 2b 2b.4.1 ReactorBuildingDemo 8,208 821 9,028 9,028

2b 2b.4.2 AuxBuildingDemo 10,260 1,026 11,286 11,286

2b 2b.4.3 RadWasteBldg.InteriorDemo 2,052 205 2,257 2,257

2b 2b.4.4 MiscRadBuilding&OpenAirdemo 6,356 636 6,991 6,991

2b 2b.4.5 FiringRange(included)

2b 2b.4.6 DrainageLagoons 437 44 481 481

2b 2b.4.7 D&DContractorStaff

2b 2b.4.8 D&DContractorTools&Equipment(inclwithwork)

2b 2b.4.9 D&DContractorScaffolding

2b.4 RadBuildingOpenAirDemolition

27,312

2,731 30,043 30,043

0 2b 2b.5.1 WasteHandling&LoadoutEquipment(inclwithwastehandling)

2b 2b.5.2 WasteHandling&Loadout 9,694 969 10,664 10,664

2b 2b.5.3 WasteRadTechs(inclwithwastehandling)

2b.5 FieldWasteOperations

9,694

969 10,664 10,664

0 2b 2b.6.1 ClassAWasteDisposal 22,874 112,679 20,333 155,887 155,887

2b 2b.6.2 ClassB&CWasteDisposal 1,522 20,819 3,351 25,692 25,692

2b 2b.6.3 RemainingLegacyLargeComponentDisposal 3,121 3,121 936 7,178 7,178

2b.6 RadWasteTransportation&Disposal

27,517 136,619

24,620 188,756 188,756

0 2b 2b.7.1 RecycleMaterials (1,715)

(257)

(1,972)

(1,972)

2b 2b.7.2 NonRadLocalLandfill 3,327 499 3,826 3,826

2b.7 NonRad&HazardousWasteDisposal

1,613 242 1,854 1,854

0 2b 2b.8.1 RadProtectionTechs 7,599 760 8,359 8,359

2b 2b.8.2 RadProtectionTechs 5,972 597 6,569 6,569

91,879

2b.8 FieldRadiationProtection 5,972

7,599

1,357 14,929 14,929

91,879 2b 2b.9.1 FinalSiteSurveys 5,852 1,951 1,951 975 10,728 10,728

90,029

2b.9 FieldRadSurveys&FinalSiteSurveys 5,852 1,951

1,951 975 10,728 10,728

90,029 2bTotalRadDecommissioning&LicenseTermination 12,235 38,438 27,517 136,619 93,774 3,784 39,524 351,891 351,891

183,908 2c 2c.1.1 UtilityManagementStaff 132,162 13,216 145,378 145,378

1,556,006 2c 2c.1.2 TemporaryFacilities 2,405 241 2,646 2,646

2c 2c.1.3 EnvironmentalProgram 960 96 1,056 1,056

2c 2c.1.4 DecommissioningNRCFees&Inspections 5,000 500 5,500 5,500

2c 2c.1.5 SafetyProgram&Supplies 2,400 240 2,640 2,640

2c 2c.1.6 TrainingProgram(InprocessingTime) 3,372 337 3,709 3,709

2c.1 UtilityStaffduringDecommissioning 132,162 2,400

3,372 8,365 14,630 160,929 160,929

1,556,006 2c 2c.2.1 PlantOperations&Maintenance(nonlabor) 5,760 576 6,336 6,336

2c 2c.2.2 WaterProcessing 960 96 1,056 1,056

2c 2c.2.3 UtilityCosts 1,482 148 1,630 1,630

2c.2 PlantOperations&Maintenance

5,760

2,442 820 9,022 9,022

0 Page3of6

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars) 2c 2c.3.1 PlantSecurity 22,704 2,270 24,974 24,974

418,829

2c.3 PlantSecurityduringDecommissioning 22,704

2,270 24,974 24,974

418,829 2c 2c.4.1 DGCContractorMobilization 528 53 581 581

2c 2c.4.2 DecommissioningGeneralContractorStaff 51,353 34,235 8,559 94,146 94,146

294,336

2c 2c.4.3 ContractorRadProtectionProgram 4,699 470 5,168 5,168

2c 2c.4.4 DGCContractorDemobilization 528 53 581 581

2c.4 ContractorProjectManagement 51,353 4,699

35,291 9,134 100,477 100,477

294,336 2c 2c.5.1 ANIInsuranceCosts 4,390 439 4,829 4,829

2c 2c.5.2 NEILInsuranceCosts 2,460 246 2,706 2,706

2c 2c.5.3 PropertyTaxes 154 15 169 169

2c 2c.5.4 UseTaxes 2,688 269 2,957 2,957

2c.5 InsuranceandTaxes

9,691 969 10,661 10,661

0 2c 2c.6.1 CorporateA&GAllocations 16,120 1,612 17,732 17,732

2c 2c.6.2 Communications(Telecom)Allocations 2,567 257 2,823 2,823

2c 2c.6.3 InformationTechnologyAllocations 17,741 1,774 19,515 19,515

2c 2c.6.4 StoresExpenseAdder 1,176 118 1,294 1,294

2c.6 CorporateAllocations

37,604 3,760 41,364 41,364

0 2cTotalLicenseTerminationUndistributedCosts 206,219 12,859

3,372 93,394 31,584 347,427 347,427

2,269,171 Period2TotalLicenseTermination 221,906 51,626 27,517 136,619 111,001 99,008 73,055 720,733 720,733

2,488,647 3a 3a.1.1 AsbestosAbatement 1,815 182 1,997

1,997 3a 3a.1.2 TurbineBuilding 4,497 450 4,947

4,947 3a 3a.1.3 IntakeStructure 3,518 352 3,869

3,869 3a 3a.1.4 AdminBuilding(notremoved)

3a 3a.1.5 FlexBldg.(notremoved)

3a 3a.1.6 Mausoleum 110 11 121

121 3a 3a.1.7 TrainingCenter(notremoved)

3a 3a.1.8 New&OldWarehouseDemo 348 35 382

382 3a 3a.1.9 MiscCleanBuildingDemo 1,098 110 1,207

1,207 3a 3a.1.10 UndergroundPiping&Utilities 4,613 461 5,075

5,075 3a 3a.1.11 Yard/Parkinglotpavement&concrete 1,944 194 2,139

2,139 3a 3a.1.12 METTower 28 3

30

30 3a 3a.1.13 D&DContractorStaff(inclwithwork)

3a 3a.1.14 D&DContractorTools&Equipment(inclwithwork)

3a.1 CleanBuildingDemolition

17,970

1,797 19,767

19,767 0

3a 3a.2.1 Process/ReuseOnSiteFillMaterials 6,050 605 6,655

6,655 3a 3a.2.2 ImportedFillMaterials 1,650 165 1,815

1,815 3a.2 Fill&BackfillMaterials

1,650

6,050

770 8,470

8,470 0

Page4of6

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars) 3a 3a.3.1 Backfill&GradeBuildings 682 68 751

751 3a.3 Backfill&GradeBuildings

682

68 751

751 0

3a 3a.4.1 NonRadEnvironmentalRemediation 1,150 115 1,264

1,264 3a.4 NonRadEnvironmentalRemediation

1,150

115 1,264

1,264 0

3a 3a.5.1 FinalSiteGrading 550 55 605

605 3a.5 FinalSiteRestoration

550

55 605

605 0

3aTotalCleanDemolition&SiteRestoration

1,650

26,402

2,805 30,857

30,857 0

3b 3b.1.1 UtilityManagementStaff 5,507 551 6,057

6,057 64,834 3b 3b.1.2 TemporaryFacilities 100 10 110

110 3b 3b.1.3 EnvironmentalProgram 40 4

44

44 3b 3b.1.4 SafetyProgram&Supplies 100 10 110

110 3b 3b.1.5 TrainingProgram(InprocessingTime) 140 14 155

155 3b.1 UtilityStaffduringDecommissioning 5,507 100

140 140 589 6,476

6,476 64,834 3b 3b.2.1 PlantOperations&Maintenance(nonlabor) 240 24 264

264 3b 3b.2.2 WaterProcessing 40 4

44

44 3b 3b.2.3 UtilityCosts 62 6

68

68 3b.2 PlantOperations&Maintenance

240

102 34 376

376 0

3b 3b.3.1 PlantSecurity 946 95 1,041

1,041 17,451

3b.3 PlantSecurityduringDecommissioning 946

95 1,041

1,041 17,451 3b 3b.4.1 DGCContractorMobilization 22 2

24

24 3b 3b.4.2 DecommissioningGeneralContractorStaff 2,140 1,426 357 3,923

3,923 12,264 3b 3b.4.3 ContractorRadProtectionProgram 196 20 215

215 3b 3b.4.4 DGCContractorDemobilization 22 2

24

24 3b.4 ContractorProjectManagement 2,140 196

1,470 381 4,187

4,187 12,264 3b 3b.5.1 NEILInsuranceCosts 103 10 113

113 3b 3b.5.2 PropertyTaxes 6

1 7

7 3b 3b.5.3 UseTaxes 112 11 123

123 3b.5 InsuranceandTaxes

221 22 243

243 0

3b 3b.6.1 CorporateA&GAllocations 672 67 739

739 3b 3b.6.2 Communications(Telecom)Allocations 107 11 118

118 3b 3b.6.3 InformationTechnologyAllocations 739 74 813

813 3b 3b.6.4 StoresExpenseAdder 49 5

54

54 3b.6 CorporateAllocations

1,567 157 1,724

1,724 0

3bTotalSiteRestorationUndistributedCosts 8,592 536

140 3,500 1,277 14,046

14,046 94,549 Period3TotalSiteRestoration 8,592 2,186

26,543 3,500 4,082 44,903

44,903 94,549 Page5of6

10Sep19 Period Item Number ItemDescription Labor Cost Materials&

Equipment WastePackaging

&Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours PROMPTDECONSCENARIO AppendixC OPPDFortCalhounStation (thousandsof2018Dollars) 4a 4a.1.1 ISFSISecurityduringDecommissioning 20,747 2,075 22,821

22,821

382,720 4a 4a.1.2 ISFSISecurityafterDecommissioning 111,735 11,174 122,909

122,909

2,402,400 4a 4a.1.3 ISFSIOperations&Maintenance 16,700 2,505 19,205

19,205

4a 4a.1.4 ISFSINRCFees 9,193 1,379 10,572

10,572

4a 4a.1.5 ISFSIDAWWaste 1,570 236 1,806

1,806

4a.1 ISFSISecurity&Operations 132,482

1,570

25,893 17,368 177,312

177,312

2,785,120 4a 4a.2.1 ISFSIPropertyTaxes(notrequired)

4a 4a.2.2 ISFSIInsurance 17,041 2,556 19,597

19,597

4a.2 ISFSIInsurance&Taxes

17,041 2,556 19,597

19,597

0 4a 4a.3.1 ISFSIUtilityStaffduringDecommissioning 9,880 988 10,868

10,868

130,000 4a 4a.3.2 ISFSIUtilityStaffafterDecommissioning 70,325 7,033 77,358

77,358

1,029,600 4a.3 ISFSIUtilityStaff 80,206

8,021 88,226

88,226

1,159,600 4a 4a.4.1 CorporateA&GAllocations 3,211 482 3,692

3,692

4a.4 ISFSICorporateAllocations

3,211 482 3,692

3,692

0 4aTotalSpentFuelDryStorage 212,688

1,570

46,145 28,426 288,828

288,828

3,944,720 4b 4b.1.1 Procure/RentTransport/TransferEquipment 2,500 375 2,875

2,875

4b 4b.1.2 SpentFuel&GTCCTransferOperations 10,200 1,530 11,730

11,730

4b.1 SpentFuel&GTCCTransfertoDOE

2,500

10,200

1,905 14,605

14,605

0 4bTotalSpentFuel&GTCCTransfertoDOE

2,500

10,200

1,905 14,605

14,605

0 Period4TotalSNF/GTCCDryStorage&TransfertoDOE 212,688 2,500

1,570 10,200 46,145 30,331 303,433

303,433

3,944,720 5a 5a.1.1 ISFSIDecommissioning&Demolition 3,111 467 3,578 3,578

5a 5a.1.2 ISFSISiteRestoration

5a.1 ISFSIDemolition&SiteRestoration

3,111

467 3,578 3,578

0 5aTotalISFSIDemolition&SiteRestoration

3,111

467 3,578 3,578

0 5b 5b.1.1 SecurityduringISFSIDecommissioning 177 18 195 195

4,160 5b 5b.1.2 UtilityStaffduringISFSIDecommissioning 670 67 737 737

10,400 5b.1 ISFSIDecommissioningUndistributedCosts 848

85 933 933

14,560 5bTotalISFSIDecommissioningUndistributedCosts 848

85 933 933

14,560 Period5TotalISFSIDecommissioning 848

3,111

551 4,511 4,511

14,560 GrandTotal 449,408 68,160 27,517 138,189 177,654 155,096 113,066 1,129,091 725,243 358,944 44,903 6,615,276 Page6of6