LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information

Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information

ML22167A199
Person / Time
Site:	Fort Calhoun
Issue date:	06/15/2022
From:	Allan Barker Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EPID L-2021-LIT-0000, LIC-22-0010
Download: ML22167A199 (75)

Text

444SOUTH16THSTREETMALL

• OMAHA,NE681022247 10 CFR 50.90 10 CFR 50.82 LIC-22-0010 June 15, 2022 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information (EPID L-2021-LIT-0000)

References:

1.

Letter from OPPD (M. Fisher) to USNRC (Document Control Desk), "License Amendment Request (LAR) 21-01: Revised Fort Calhoun Station License to Add License Condition 3.D to include License Termination Plan Requirements," dated August 3, 2021 (LIC-21-0005) (ML21271A143) 2.

Letter from NRC (J. Parrot) to OPPD (T. Via), Fort Calhoun Station, Unit No. 1 -

Review of License Termination Plan Requirements - Request for Additional Information (EPID L-2021-LIT-0000), dated May 3, 2022 (ML22119A247)

By letter dated August 3, 2021 (Reference 1) (ML21271A143), Omaha Public Power District (OPPD) submitted a License Amendment Request (LAR) to add a license condition, 3.D, to include License Termination Plan Requirements.

On May 3, 2022 (Reference 2), the NRC provided OPPD with a Request for Additional Information (RAI) regarding the Environmental aspects (Chapter 8) of the License Termination Plan (LTP) LAR. of this letter provides the responses to the RAIs. Attachment 2 provides the requested maps of De Soto. Attachments 3 thru 6 provide supporting documentation resulting from the RAI responses.

U. S. Nuclear Regulatory Commission LIC-22-0010 Page 2 This letter contains no regulatory commitments.

If you should have any questions regarding this submittal or require additional information, please contact Mrs. Andrea K. Barker, CHP - Regulatory Assurance and Emergency Planning Manager at (531) 226-6051.

Respectfully, Andrea K. Barker, CHP, MHP Regulatory Assurance and Emergency Planning Manager AKB/akb Attachments: 1.

Response to Request for Additional Information 2.

De Soto Maps 3.

Letter from Nebraska State Historical Preservation Office 4.

Fort Calhoun 2022 Decommissioning Cost Estimate 5.

Results of Testing at 25WN16, Nebraska Department of Roads Project NH-75-3(116), CN 22447, [Ft. Calhoun to Blair], Washington County, Nebraska 6.

Payment In Lieu of Taxes (PILOT) Summary 2017 - 2021 c:

S. A. Morris, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager S. Anderson, NRC Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-22-0010 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENCE AMENDMENT REQUEST OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 DOCKET NO. 50-285,72-054 By application dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21271A143), Omaha Public Power District requested changes to the Fort Calhoun Station (FCS) license to add License Condition (LC) 3.D to include License Termination Plan requirements.

The NRC staff has reviewed the licensees application and LTP and determined that additional information is needed to enable the NRC staff to complete its technical review:

Historic and Cultural Resources

RAI-1

The historic town of De Soto has been deemed eligible as a historic property.

In the Post-Shutdown Activities Report (PSDAR) closeout letter dated November 3, 2020, staff also requested that the record be updated to identify De Soto as an eligible historic property. Please provide information regarding the location of the Town of De Soto and Mitigation measures to assure that the property will not be affected by license termination plan activities

Response

A map of the De Soto area is included as Attachment 2 to this response. The mitigation measures discussed in the PSDAR, Section 5.1.14, are still applicable. The Nebraska State Historic Preservation Office (SHPO) has reviewed the FCS site and decommissioning project. SHPO determined there would be no effects on any historical sites; however, the environmental review processes discussed in the PSDAR are still in place. These processes are regarding undertakings that involve land-disturbing activities in undisturbed surface and subsurface areas. These environmental protection processes include contacting the SHPO to establish any actions necessary to protect known or as of yet undiscovered cultural resources before an action is allowed to occur.

These statements, paraphrased from Section 5.1.14 of the PSDAR, are still applicable and are as follows:

1.) decommissioning activities will be contained primarily to previously disturbed areas; 2.) construction activities that disturb one acre or greater of soil are permitted by the Nebraska Department of Environment and Energy (NDEE) approval and

LIC-22-0010 Best Management Practices (BMPs) are required to control sediment and the effects of erosion; and, 3.) environmental protection processes pertaining to archaeological and cultural resources will remain in effect during decommissioning.

RAI-2

The NRC staff requested that OPPD consult with the Nebraska State Historic Preservation Officer (SHPO) to determine if the FCS itself could be considered an eligible historic property. Please provide confirmation of the determination from the Nebraska SHPO regarding the eligibly of the FCS itself.

Response

OPPDs Environmental and Regulatory Affairs (ERA) department contacted the Nebraska SHPO office in conjunction with our Updated Environmental Supplement. In the Nebraska SHPO offices response dated November 5, 2018, the Deputy State Historic Preservation Officer concluded that there will be no historic properties affected by this [decommissioning] project, This position was reaffirmed by a letter from Nebraska SHPO dated June 8, 2022 (Attachment 3). Nebraska SHPOs response was provided in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended, and implementing regulations 36 CFR Part 800. This letter will be retained by OPPD to show compliance with Section 106 of the NHPA, as amended.

As part of their review, Nebraska SHPO considers historical places and existing structures for inclusion as historical properties. The SHPO conclusion that no historic properties would be impacted by the decommissioning of FCS signifies their determination that FCS will not be considered a historic property. This was confirmed by ERA in June 2022, also.

RAI-3

The NRC staff requested in an RAI on the PSDAR that revised PSDARs designation of the eligibility for listing of the townsite of De Soto on the National Register of Historic Places be corrected based on records that identify that the De Soto townsite was formally determined eligible for listing on the National Register of Historic Places in 1989. This information should be corrected in the LTP application

Response

The following verbiage (in red) has been updated in the PSDAR, Section 5.1.14:

LIC-22-0010 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 De Soto, a historic property that is eligible for listing on the National Register of Historic Places.

The following verbiage (in red) has been added to the LTP revision log to be included in Section 8.6.3.13 of Chapter 8 at the next revision:

A section of the plant site that lies north of the rail spur and is bounded on the southwest by U.S. Highway 75 was determined as having Moderate to High Potential. It contains remnants of the former town of De Soto, Nebraska a historic property that is 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, and 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.

RAI-4

The Environmental Report (ER) for the LTP states that Environmental review procedures have been put in place at FCS regarding undertakings that involve land disturbing activities in undisturbed surface and subsurface areas. Are there any planned decommissioning activities on previously undisturbed land?

Response

There are no activities planned on previously undisturbed land for the duration of the decommissioning project. The removal of the lines running to the Sanitary Lagoons in the area behind the Administration Building will involve digging to remove those lines.

However, this activity will follow the area as close as possible to that which was disturbed when they were installed during the facilitys operation. During flooding preparations and mitigation, sand readied for use in sandbags and subsequently returned after use in sandbags was stored in piles near the Original Steam Generator Storage Facility (the mausoleum). This will be disposed of via the appropriate processes. The already constructed Waste Processing Structure (WPS) was built near the existing rail line and areas where there had been storage of materials and trucks traversing. As indicated above, no previously undisturbed land areas are anticipated to be disturbed during the decommissioning; however, processes are in place in the event that an unforeseen event necessitates disturbing an area previously untouched by facility operation.

LIC-22-0010

RAI-5

What are the results of the 2013 and 2014 reviews of historic, cultural, and archaeological resources mentioned on page 8-23 of the LTP? What did these reviews involve? Were the reviews coordinated or shared with the SHPO?

Response

In 2013, Nebraska SHPO began a survey looking at historical, cultural, and archaeological resources at and near Fort Calhoun Station as part of a Department of Roads project. Attachment 6 contains the SHPO report of their testing and findings.

The SHPO evaluation involved fieldwork and testing of any gathered items along with observations from the field. Their testing found that no, intact cultural layers were encountered, in the 14 test units and artifacts were few in number and not positively attributable to De Soto. The results of that evaluation concluded that work in this area would, not affect significant archeological deposits, which give the site its research potential, and, further, recommended, [a] finding of no historic properties affected.

The tests and reviews were coordinated and conducted by SHPO themselves.

Waste Management

RAI-6

Application page 8-12 of the LTP states that The total volume of LLRW [low-level radioactive waste] for disposal was estimated in the Decommissioning Plan to be approximately 6,000,000 cubic feet. The LTP application, page 3-21, states the total volume of radioactive waste for disposal has been estimate at 3,222,861 cubic feet. Please explain the difference between these two estimates.

Response

The estimate used in Chapter 8 of the LTP was used in error. The following revision is being added to the log to update this chapter at the next revision:

The total volume of LLRW [low-level radioactive waste] for disposal was estimated in the Decommissioning Plan to be approximately 3,222,861 cubic feet.

LIC-22-0010 Cumulative Impacts

RAI 7

Provide a discussion on past, present, and reasonably foreseeable future actions that may result in a potential for cumulative environmental impacts within an 80-km [50-mi] radius of the FCS site or within the boundaries of each resource area. This additional Information is needed in accordance with CFR 51.45(c), which requires that the ER contain an analysis of cumulative impacts that may result from the proposed action.

Response

The updated Environmental Report for the PSDAR update in 2019 did not provide a Cumulative Impacts section since cumulative impacts were not considered in the 2002 Environmental Report prepared for license renewal. CFR 51.45(c) also contains the following verbiage:

In addition, environmental reports prepared under § 51.53(c) [Post construction Environmental Reports, Operating license renewal stage] need not discuss issues not related to the environmental effects of the proposed action and its alternatives. The analyses for environmental reports shall, to the fullest extent practicable, quantify the various factors considered. To the extent that there are important qualitative considerations or factors that cannot be quantified, those considerations or factors shall be discussed in qualitative terms. The environmental report should contain sufficient data to aid the Commission in its development of an independent analysis.

The FCS 2002 ER was prepared in support of the Initial License Renewal stage. Since that time, SRM-SECY-21-0066 was issued which concluded that 10 CFR 51.53(c)(3) only applies to an initial license renewal applicants preparation of an environmental report and that the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) did not address subsequent license renewal. Pursuant to this decision and previous Environmental Report requirements, a thorough discussion was not included. Fort Calhoun Station requests guidance on how SRM-SECY-21-0066 might affect us and the requirements for any additional Environmental Report items.

However, for purposes of the License Termination Plan and the proposed decommissioning and license termination activities, there would be a reduction in overall environmental impacts to the community due to the removal and restoration of the site. The only other impact from a cumulative perspective would be temporary transportation impacts due to the increase in truck and rail traffic during decommissioning activities. In addition, the loss of jobs is also a potential cumulative

LIC-22-0010 impact which is addressed in Section 8.6.3.11 Socioeconomic Impacts of the 2020 updated ER.

RAI 8

The Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NUREG-0586, Supplement 1) states that the two primary pathways through which nuclear power plants activities create socioeconomic impacts on the area surrounding the plant include: 1) through expenditures in the community by the facility workforce and direct purchases of goods and services necessary for facility operation; and 2) the effects on local government tax revenues and services. Section 8.6.3.5.1 of the LTP application states that the work force at FCS has decreased significantly from the time the plant ceased operation in 2016 to a work force of approximately 300 people and will temporarily increase during decommissioning by approximately 150 people. However, the LTP does not include the workforce at the time the plant ceased operation or any potential decreases in workforce as decommissioning progresses.

To support the staffs evaluation of socioeconomic impacts of decommissioning, the NRC requests the following information:

a.) Provide the workforce at the time the plant ceased operation?

b.) Has there been any changes to the estimated 300 current workforce or the additional 150 anticipated during decommissioning? If so, provide this information.

c.) After the temporary increase in workforce, does OPPD anticipate the workforce will remain at 300 workers as decommissioning progresses, or will the workforce decrease below 300 workers? If the workforce will decrease below 300, provide the anticipated number of workers.

Response

a.) At the time of the announcement of the plan to decommission the plant, there were approximately 700 OPPD employees. At the time of the final shutdown in October 2016, there were about 650 remaining employees.

b.) There have been no changes to the estimated headcounts needed for decommissioning for neither OPPD employees nor supplemental contract personnel.

There are natural fluctuations in on-site personnel related to contractor and subcontractor staffing needed for a given project at a given position in time. There are currently approximately 135 OPPD employees on-site performing deconstruction related

LIC-22-0010 activities and dry fuel storage duties. The deconstruction effort is supplemented by approximately 200 additional contractor and subcontractor personnel for a total of approximately 335 personnel working on-site at this time.

c.) The OPPD workforce will continue to decline through the conclusion of decommissioning, which is expected to be in 2026. The latest projections for OPPD staffing are found in the Decommissioning Cost Estimate completed in February 2022, included as Attachment 4. OPPD employee staffing projections for both decommissioning and dry fuel storage activities by year are as follows:

Year 2023 2024 2025 2026

>2026 Staffing1 125 100 68 40 40 Contract and sub-contract staffing will fluctuate with the activities in progress and will fluctuate throughout the calendar years, with a general continuous decline in total population expected through license termination.

Total workforce staffing projections, including OPPD and contractor/subcontractor personnel are as follows:

Year 2023 2024 2025 2026

>2026 Staffing2 250 200 150 45 40 After decommissioning is completed (considered beyond 2026), only OPPD employees (40) are expected to remain.

RAI 9

The NUREG-0586 Supplement 1 states that the two primary pathways through which nuclear power plants activities create socioeconomic impacts on the area surrounding the plant include: 1) through expenditures in the community by the facility workforce and direct purchases of goods and services necessary for facility operation; and 2) the effects on local government tax revenues and services. The Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Fort Calhoun Station Unit 1 -

Final Report (NUREG-1437, Supplement 12 identifies that OPPD is exempt from paying State-occupational, personal-property, and real-estate taxes and instead OPPD makes payments in lieu of taxes to municipalities and counties.

The LTP does not provide tax payment information, payments in lieu of taxes, 1 All staff figures are estimations and, as such, are considered approximate.

2 All staff figures are estimations and, as such, are considered approximate. Contractor staffing numbers will fluctuate with project needs.

LIC-22-0010 or other forms of payments to local jurisdictions and any anticipated changes during the decommissioning phase.

To support the staffs evaluation of socioeconomic impacts of decommissioning, the NRC requests the following information:

a.) Provide payments in lieu of taxes to local jurisdictions for the past 5 years OPPD made on behalf of FCS and identify the distribution to each local jurisdiction.

b.) Provide anticipated changes to payments in lieu of taxes and other types of payments to local jurisdictions during the decommissioning phase of FCS.

Response

a.) The payments in lieu of taxes (PILOT) to local jurisdictions for the past five (5) years, which OPPD made pursuant to state statute, are included as Attachment

6.

b.) There will be little change with consideration of tax revenue and the continuation of OPPD to provide electricity as a political subdivision of Nebraska. The Nebraska State Constitution Article VII, Section 11, stipulates that every corporation and political subdivision (of which OPPD is one) which is organized primarily to provide electricity shall annually make the same payments in lieu of taxes as it made in 1957 to the same public bodies. Also, if the public corporation sells electricity at retail, it will also pay to the treasurer of the county a sum of five percent of the annual gross revenue of the utility within incorporated cities and towns. OPPD fits these descriptions and pays the required payments. The 1957 payments are processed across the counties throughout the year and total approximately six in lieu of tax payments each year. These payments include those counties surrounding FCS (in particular Washington, Burt, Dodge, and Douglas counties). These counties also receive in lieu of tax payments of five percent of the total gross revenue that OPPD receives from electricity sales within incorporated cities and towns of the county.

As a publicly owned entity, OPPD will still be responsible for producing and distributing electricity and the resulting in lieu of payments, even with Fort Calhoun Station decommissioning. The station's lack of generation does not stop the delivery of electricity to the area surrounding the site or the payments required as a result. Some low-income or minority areas identified in the PSDAR and 2019 Environmental Report are not located within the District's service area; and, therefore, will not have any tax revenue changes from Decommissioning.

LIC-22-0010 Environmental Justice

RAI 10

Section 8.6.3.12 of the LTP states that low-income and minority populations are present in the vicinity of the former FCS. The LTP further states that a refurbished rail spur will be used to transport waste and that decommissioning activities will cause an increase in truck traffic and that there will be no environmental justice impact relative to rail and truck transportation because of decommissioning. The LTP, however, does not provided a discussion or basis for why there will be no environmental justice impacts to minority and low-income populations along route rail and truck transportation routes.

Discuss and provide the basis for concluding there would be no disproportionately high and adverse human health and environmental effects (e.g., noise, traffic) on minority and low-income populations that live along rail and truck transportation routes.

Response

The PSDAR (Section 5.1.13) and GEIS (Section 4.13.3), discuss disproportionately high and adverse human health and environmental effects. Following the guidance from NUREG-05863 for assessing disproportionately high and adverse human health effects, these documents concluded 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. Also, from these analyses, potential impacts to minority and low-income populations would mostly consist of radiological effects. The SEIS was able to reach this conclusion 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.

Haley & Aldrich addressed Environmental Justice from the perspective of job loss to the 3 From NUREG-0956, When determining whether human health effects are disproportionately high and adverse, agencies are to consider the following three factors to the extent practicable: (a) whether the health effects, which may be measured in risks and rates are significant (as used by NEPA), or above generally accepted norms-(adverse health effects may include bodily impairment, infirmity, illness, or death); (b) whether the risk or rate of hazard exposure by a minority or low-income population, to an environmental hazard is significant (as used by NEPA) and appreciably exceeds or is likely to appreciably exceed the risk or rate to the general population or other appropriate comparison group; and (c) whether health effects occur in a minority or low-income population, affected by cumulative or multiple adverse exposures from environmental hazards.

LIC-22-0010 community and concluded that the number of jobs lost due to the plant shutdown was insignificant. The effects of the transportation through neighboring low income communities were not included in Section 8.6.3.12 Environmental Justice since the transportation route utilizes existing roads and rail corridors and the impacts are temporary in nature. FCS rail shipments would amount to a small fraction of normal rail transport activity and provide no additional traffic impact on those railways.

Previous transportation analyses have found that the impacts would be small from normal operations or from accidents. While truck traffic due to shipments may increase temporarily at times, the overall reduction in personnel onsite (approximately 50% of that at the height of operation) should effectively offset any small increase. Thus, no disproportionately high and adverse effects are expected for any particular segment of the population, including minority and low income populations that may live along proposed rail and truck routes. As excerpted from the PSDAR submittal (LIC-19-007, ML19351E355) section 5.1.17:

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 []

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 []

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 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.

From the PSDAR (LIC-19-007, ML19351E355):

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 onsite noise levels (i.e., some types of demolition activities). However, these noise levels will be temporary and are not expected to

LIC-22-0010 result in a significant audible intrusion on the surrounding community. (Section 5.1.16)

Although this discussion does not specifically address sound intrusion attributed to any activity which is removed by space or time from the FCS site, the same conclusions can be logically inferred based on the amount of shipping that is expected. As discussed, only a small increase in truck volume is expected, but overall traffic from the plant is less due to personnel decreases and would be less than a refueling outage. The rail shipments will follow all applicable DOT and Federal Railroad Administration regulations and requirements; none of which apply any additional noise effects from the type of rail cars used. Therefore, the FCS rail shipments, being transported on existing rail lines, should not exert any disproportionate effects on any rail adjacent populations, including those in low income or minority areas.

LIC-22-0010 ATTACHMENT 2 DE SOTO MAPS

LIC-22-0010 ATTACHMENT 3 NEBRASKA STATE HISTORICAL PRESERVATION OFFICE UPDATED LETTER AFFIRMING IMPACT TO HISTORICAL PROPERTIES JUNE 8, 2022

LIC-22-0010 ATTACHMENT 4 2022 FORT CALHOUN STATION DECOMMISSIONING COST ESTIMATE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 2 of 31 Revision Log No.

Date Reason for Revision Item(s) Revised 0

02/18/2021 Update for 2020 Estimate and Scope Updated for 2020 1

04/16/2022 Corrections Varying verbiage in paragraphs throughout 2

02/10/2022 Update for 2021 Estimate and Scope

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 3 of 31 Table of Contents 1.0 EXECUTIVE

SUMMARY

............................................................................................................. 7

2.0 INTRODUCTION

........................................................................................................................ 9 2.1 Study Objective.......................................................................................................................... 9 2.2 Regulatory Framework.............................................................................................................. 9 2.3 Decommissioning Alternatives................................................................................................ 10 2.4 Post-Shutdown Spent Fuel Management Alternatives........................................................... 10 3.0 STUDY METHODOLOGY......................................................................................................... 11 3.1 General Description................................................................................................................. 11 3.2 Schedule Analysis.................................................................................................................... 11 3.3 Decommissioning Staff............................................................................................................ 11 3.4 Waste Disposal........................................................................................................................ 12 3.5 Final Status Survey................................................................................................................... 14 3.6 Contingency............................................................................................................................. 15 3.7 Cost Reporting......................................................................................................................... 15 4.0 SITE-SPECIFIC TECHNICAL APPROACH................................................................................... 17 4.1 Facility Description.................................................................................................................. 17 4.2 Major Work Periods for DECON.............................................................................................. 17 4.3 Decommissioning Staff............................................................................................................ 22 4.4 Spent Fuel Management......................................................................................................... 22 4.5 Spent Fuel Shipments.............................................................................................................. 22 5.0 BASIS OF ESTIMATE AND KEY ASSUMPTIONS........................................................................ 23 6.0 STUDY RESULTS...................................................................................................................... 26 6.1 Cost Summary by License Termination, Spent Fuel, and Site Restoration............................. 26 6.2 Summary Schedule.................................................................................................................. 26 6.3 Cost Summary by Phase and Cost Type................................................................................... 27

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 4 of 31 6.4 Project Staffing........................................................................................................................ 28 6.5 Waste Disposal Volumes......................................................................................................... 29 6.6 Estimated Annual Spending.................................................................................................... 30

7.0 REFERENCES

............................................................................................................................ 31

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 5 of 31 Tables Table 1-1 Decommissioning Cost Estimate........................................................................................ 7 Table 6-1 Decommissioning Cost Estimate...................................................................................... 26 Table 6-2 DECON Cost Summary by Phase....................................................................................... 28 Table 6-3 DECON Cost Summary by Cost Type................................................................................ 28 Table 6-4 OPPD Estimated Staff & Security Manpower................................................................... 29 Table 6-5 Waste Disposal Volumes.................................................................................................. 29 Table 6-6 Projected Annual Spending.............................................................................................. 30 Figures Figure 1-1 DECON Summary Schedule................................................................................................ 8 Figure 6-1 DECON Schedule............................................................................................................... 27 Appendices Appendix A Waste Disposal Summary Appendix B DECON Project Schedule Appendix C Detailed Cost Estimate

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 6 of 31 Acronyms and Abbreviations AIF Atomic Industrial Forum BWR Boiling Water Reactors CFR Code of Federal Regulations D&D Decontamination & Decommissioning DAW Dry Active Waste DCE Decommissioning Cost Estimate DGC Decommissioning General Contractor DOE U.S. Department of Energy ES EnergySolutions FCS Fort Calhoun Nuclear Generating Station FSS Final Status Survey GTCC Greater Than Class C Waste HP Health Physics IOF ISFSI Operation Facility ISFSI Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Waste LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MPC Multi-Purpose Canisters MWt Megawatt thermal NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System OPPD Omaha Public Power District ORISE Oak Ridge Institute for Science and Education PCB Polychlorinated Biphenyl PSDAR Post-Shutdown Decommissioning Activities Report PWR Pressurized Water Reactor QAP Quality Assurance Program SNF Spent Nuclear Fuel WBS Work Breakdown Structure WCS Waste Control Specialists LLC UCF Unit Cost Factor

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 7 of 31 1.0 EXECUTIVE

SUMMARY

The Omaha Public Power District (OPPD), on behalf of the Fort Calhoun Nuclear Station (FCS), contracted with EnergySolutions LLC (ES), for the preparation of this Report. The report presents the FCS Site-Specific Decommissioning Cost Estimate (DCE) Study, hereinafter referred to as the DCE. OPPD owns FCS.

FCS is a 1500 Mwt Combustion Engineering Pressurized Water Reactor (PWR).

On June 16, 2016, the OPPD board voted unanimously to shut down FCS and the plant permanently ceased operation on October 24, 2016. The permanent core off-load was completed on November 13, 2016.

The decommissioning alternatives provided by the U. S. Nuclear Regulatory Commission (NRC) are as follows:

DECON -Plant structures, systems, and components containing radioactive contaminants are removed or decontaminated to levels that permit the site property to be released for unrestricted use following cessation of operations. DECON is the most expeditious of the decommissioning alternatives and releases the site property for other beneficial use in the shortest period of time.

SAFSTOR - The facility is shut down and safely stored under monitored conditions. Decommissioning follows a storage period that results in significantly reduced plant radiation levels due to radioactive decay. This alternative provides for the unrestricted release of the site property within a 60-year time period.

ENTOMB - This report does not define the Entomb decommissioning option as it is not practical for FCS.

The station initially selected the SAFSTOR decommissioning option. In October 2018, the OPPD board authorized FCS to transition from the SAFSTOR decommissioning option into the DECON option, which completes the nuclear decommissioning activities within a significantly shorter time period.

This study furnishes a Decommissioning Cost Estimate of the costs for license termination under the DECON decommissioning alternative, based on Estimated Costs to Complete as of December 31, 2021.

All costs represented in this report are provided in 2021 dollars.

The cost estimate results are provided in Table 1-1 below. This table provides License Termination costs (corresponding to 10 CFR 50.75(c) requirements); Spent Fuel Management costs (corresponding to 10 CFR 50.54(bb) requirements) and Site Restoration costs (corresponding to activities such as clean building demolition and site grading etc.).

TABLE 1-1 DECON DCE

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 8 of 31 Costs for Greater Than Class C (GTCC) casks and operations during the decommissioning period are included in the License Termination Costs. Costs for GTCC during long-term Spent Fuel Storage and transfer to DOE are included in the Spent Fuel Costs.

OPPDs plant systems data and current site/building drawings, combined with EnergySolutions decommissioning experience are the basis for this estimates inventories. These inventories, EnergySolutions proprietary Unit Cost Factors (UCFs), and other plant data were used to generate the required labor-hours, cost, waste volumes, weights, and classifications.

Shutdown and Transition Planning, Fuel Sampling, and ISFSI design/construction activities were completed prior to December 31, 2019.

Spent Fuel Pool and Pool-to-Pad Operations are complete as of December 31, 2020. The removal, transportation, and disposal of Legacy Reactor Vessel Head and Pressurizer are also 100% complete as of December 31, 2020.

The schedule reflects the effects of sequenced activity-dependent or distributed decommissioning elements such as spent fuel pool-to-pad operations, planning and preparations, major component removal, building decontamination, building demolition, site restoration, spent fuel storage, etc.

The costs and schedule for the DECON alternative are divided into three major project categories as follows:

License Termination Spent Fuel Storage Site Restoration Figure 1-1 shows the summary-level schedule for the DECON alternative.

Figure 1-1 DECON Summary Schedule

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 9 of 31

2.0 INTRODUCTION

2.1 Study Objective This report presents the Site-Specific DCE for FCS.

This study has been performed to provide OPPD with an updated DCE for the selected DECON decommissioning alternative. It addresses: (1) FCS decommissioning to the extent required to terminate the plants NRC license; (2) management of residual spent fuel until acceptance by the U.S. Department of Energy (DOE); and (3) demolition of uncontaminated structures and restoration of the site.

The study methodology follows the basic approach originally presented in the Atomic Industrial Forum/National Environmental Studies Project Report AIF/NESP036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates (Ref. No. 2). The report was prepared in accordance with 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 compliance with current regulatory requirements and proven decommissioning technologies.

NRC requirements, set forth in Title 10 of the Code of Federal Regulations (CFR), differentiate between the postshutdown costs associated with the decommissioning of the nuclear plant facility, those associated with storage of spent fuel on site, and those associated with the decommissioning of a spent fuel storage facility.

However, the CFR does not address the entire scope of the decommissioning Cost for each nuclear facility.

10 CFR 50.75(c) requires funding by the facility licensee(s) for the decommissioning program, but specifically excludes the cost of removal and disposal of spent fuel and structures that do not require disposal as radioactive material. 10 CFR 50.75(c) also excludes the cost of site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license(s). 10 CFR 50.54(bb) requires funding by the licensee(s) "for the management of all irradiated fuel at the reactor upon expiration of the reactor operating license(s) until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository." 10 CFR 72.30 requires funding for decommissioning of the onsite spent fuel storage facility after the irradiated fuel is accepted by the DOE.

2.2 Regulatory Framework Provisions of current laws and regulations affecting decommissioning, waste management, and spent fuel management are as follows:

1. NRC regulations require a license for on-site storage of spent fuel. Wet storage in a spent fuel pool is authorized by a facility's 10 CFR Part 50 license (Ref. No. 1). On-site dry storage of spent fuel at an Independent Spent Fuel Storage Installation (ISFSI) is licensed by either: (a) the general license set forth in 10 CFR 72.210, which requires that a Part 50 license be in place; or (b) a site-specific ISFSI license issued pursuant to 10 CFR Part 72.

2. 10 CFR 50.75(c) requires funding by the licensee(s) of the facility for decommissioning.

3. 10 CFR 50.54(bb) requires the licensee(s), within two years following permanent cessation of operation of the reactor or five years before expiration of the operating license(s), whichever occurs first, to submit written notification to the NRC for its review and preliminary approval of the program by which the licensee intends to manage and provide funding "for the management of all irradiated

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 10 of 31 fuel at the reactor upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository."

2.3 Decommissioning Alternatives The three basic methods for decommissioning are DECON, SAFSTOR, and ENTOMB, which are summarized as follows:

1. 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 after cessation of operations.

2. SAFSTOR: 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. NRC regulations require decommissioning to be completed within 60 years of cessation of operation.

3. ENTOMB: Radioactive structures, systems, and components are encased in a structurally long-lived substance, such as concrete. The entombed structure is appropriately maintained and monitored until radioactivity decays to a level that permits termination of the license. Since entombment will exceed the requirement for decommissioning to be completed within 60 years of cessation of operation, NRC handles entombment requests on a case-by-case basis.

2.4 Post-Shutdown Spent Fuel Management Alternatives The options for long-term post-shutdown spent fuel management currently available to power plant operators are (1) wet storage consisting of continued maintenance and operation of the spent fuel pool, and (2) dry storage consisting of transfer of spent fuel from the fuel pool to onsite dry storage modules after a cooling period or any combination of the two.

Transfer to an as yet to be developed, privately owned Interim Spent Fuel Storage Facility, while contemplated, has not been sufficiently developed to warrant discussion and evaluation at this time.

Transfer of Spent Fuel to an ISFSI requires additional expenditures for purchase and construction of the ISFSI and storage modules and ultimate dismantlement and disposal of the ISFSI following completion of spent fuel transfer to DOE.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 11 of 31 3.0 STUDY METHODOLOGY 3.1 General Description EnergySolutions maintains a proprietary decommissioning cost model based on the fundamental technical approach established in AIF/NESP-036, "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," dated May 1986 (Ref. No. 2). The cost model, which is updated frequently in accordance with regulatory requirements and industry experience, includes elements for estimating distributed and undistributed costs. Distributed costs are activity specific and include planning and preparation costs as well as costs for decontamination, packaging, disposal, and removal of major components and systems. For example, costs for the segmentation, packaging, and disposal of the reactor internals are distributed costs. Undistributed costs, sometimes referred to as collateral costs, are typically time-dependent costs such as utility (Licensee) and Decommissioning General Contractor (DGC) staff, property taxes, insurance, regulatory fees and permits, energy costs, and security staff.

Preparing a decommissioning cost estimate requires a site-specific detailed work activity sequence based on the plant inventory. The activity sequence is used to define the required labor, material, equipment, energy resources, and duration for each activity. For major components, ES analyzes individual work sequence activity based on the physical and radiological characteristics of the component and the available packaging, transportation, and disposal options.

The work durations and costs for structures, small components, and equipment such as piping, pumps, and tanks are calculated based on Unit Cost Factors (UCFs). UCFs are economic parameters developed to express costs per unit of work output, piece of equipment, or time. Decommissioning experience, information on the latest technology applicable to decommissioning, and engineering judgment are applied to develop the UCFs.

3.2 Schedule Analysis EnergySolutions uses Oracle Primavera 6 to perform a schedule analysis after calculating the work activity durations for all distributed activities. The schedule accounts for constraints and regulatory reviews. The schedule is delineated into phases or time periods that differentiate between direct cost requirements and undistributed costs.

In order to differentiate between the decommissioning scope of work phases/periods, EnergySolutions has established a Work Breakdown Structure (WBS) and cost accounting system to treat each phase as a subproject. Accordingly, the overall project schedule is divided into interrelated periods with major milestones defining the beginning and end of each. The major milestones also serve as the basis for integrating the periods of the three subprojects.

3.3 Decommissioning Staff EnergySolutions has assumed the Fort Calhoun Nuclear Station decommissioning project will be efficiently planned and executed by project personnel experienced in decommissioning and large-scale project management.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 12 of 31 This DCE also assumes the decommissioning work will be performed by a highly experienced and qualified Decommissioning General Contractor in partnership with OPPD for staff oversight and management of decommissioning operations.

EnergySolutions analyzed the FCS licensee staffing needs and developed a site-specific staffing plan. Staff and DGC labor costs are based on OPPD-supplied values and ES historical data.

Staffing levels, for the OPPD and DGC staffing plans for each project period, are based on the Atomic Industrial Forum (AIF) guidelines, as well as industry and EnergySolutions experience. The staff size varies in each period according to the work activity requirements. Staffing estimates include the following departments or functional groups:

Management & Administrative Engineering Plant Operations & Maintenance Radiation Protection and Chemistry Health Physics Regulatory Affairs Quality Waste Operations Security DGC Staff 3.4 Waste Disposal Waste management costs comprise a significant portion of the decommissioning Cost estimate. Additionally, limited future access to disposal sites licensed for receipt of Class B and C wastes introduces significant uncertainty regarding the use of existing rate structures to estimate disposal costs of these wastes.

EnergySolutions' approach to estimating waste disposal costs is outlined in the following paragraphs.

Waste Classification Radioactive waste disposal regulations are stringent in order to ensure responsible oversight of the waste and preclude adverse public health and safety impacts. LLRW disposal is controlled by 10 CFR 61, which went into effect in December 1983. This regulation stipulates the criteria to establish and operate shallow-land LLRW burial facilities. Embodied within this regulation are criteria and classifications for packaging LLRW for burial at licensed LLRW disposal sites.

For each waste classification, 10 CFR 61 stipulates specific criteria for physical and chemical properties required for acceptance at a licensed disposal site. 10 CFR 61 requires LLRW generators to calculate the proportion of numerous specific radioactive isotopes present in each container. This isotopic analysis includes a combination of techniques including computerized analyses based on scaling factors, sample laboratory analyses, and direct assay methods. After the proportion of radioactive isotopes is determined, the waste is classified as Class A, B, C, or Greater Than Class C (GTCC) per 10 CFR 61.

EnergySolutions' classification of LLRW resulting from decommissioning activities is based on AIF/NESP-036 (Ref. No. 2), NUREG/CR-0130 (Ref. No. 4), plant-specific information, and recent industry experience. The estimated curie content of the reactor vessel and internals at shutdown is typically derived from

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 13 of 31 NUREG/CR-0130 for Pressurized Water Reactors (PWRs) and NUREG/CR-0672 for Boiling Water Reactors (BWRs) and adjusted for the different mass of components and period of decay.

Packaging Selection of the type and quantity of containers required for Class B and C wastes is based on the most restrictive of either curie content, dose rate, container weight limit, or container volume limit. Residual spent fuel and GTCC wastes from segmentation of the reactor vessel internals and other accident-related waste is normally packaged in modified spent fuel canisters, so this packaging is assumed for the DCE. The selection of container type for Class A waste is based on the transportation mode (rail, truck, barge, etc.) and waste form. The quantity of Class A waste containers is determined by the most restrictive of either container weight limit or container volume limit. Large components, such as steam generators, pressurizers, and reactor recirculation pumps, are shipped as their own containers with additional shielding as required.

ES obtains container costs from manufacturers specializing in the design and fabrication of storage containers for nuclear materials. Cask owners and operators provide the costs for shielded transport casks and liners.

Transportation Available transportation modes (truck, rail, barge, or combinations) will determine the routes to processing and disposal facilities. Transportation costs for the selected routes and modes are obtained from vendor quotes or published tariffs whenever possible.

Class-A Disposal Options and Rates Class A waste that meets the waste acceptance criteria will be disposed of at EnergySolutions' LLRW disposal facility in Clive, Utah. All reported waste disposal costs include packaging, transportation, and any applicable surcharges.

Class B and C Disposal Options and Rates Currently, within the United States, there are only three operational commercial near-surface disposal facilities licensed to accept Class B and C LLRW:

Barnwell operated by EnergySolutions in Barnwell, South Carolina U.S. Ecology facility in Richland, Washington WCS Andrews County operated by Waste Control Specialists (WCS) in Andrews County, Texas,.

Barnwell accepts waste only from states within the Atlantic Compact and U.S. Ecology accepts waste only from states within the Northwest and Rocky Mountain Compacts. However, the WCS facility will accept waste from the Texas Compact (comprised of Texas and Vermont) and from non-Compact generators. On March

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 14 of 31 23, 2012, the Texas Compact Commission approved amendments to rules allowing the import of non-compact generator LLRW for disposal at the WCS Andrews County facility.

Transportation costs in this estimate for the Class B and C waste are based on a distance of 900 miles one way from FCS to the WCS facility.

Greater-Than-Class-C (GTCC)

Waste identified as 10 CFR 61 Class A, B, and C may be disposed of at near-surface disposal facilities. GTCC components are highly activated and exceed the radionuclide concentration limitations for Class C waste. In accordance with 10 CFR 61, GTCC components cannot be disposed of in a near-surface LLRW disposal facility and must be transferred to a geologic repository or a similar site approved by the NRC.

Highly activated sections of the reactor vessel internals and certain decommissioning processes will result in GTCC waste. Currently, a facility does not exist for the disposal of wastes exceeding 10 CFR 61 Class C limitations. EnergySolutions assumes the DOE will accept this waste along with spent fuel. Although courts have held that DOE is obligated to accept and dispose of GTCC, issues regarding potential costs remain unsettled. Therefore, EnergySolutions conservatively estimates a GTCC waste disposal cost.

LLRW Volume Reduction Because current Class A LLRW disposal rates are significantly lower than LLRW volume reduction rates, EnergySolutions does not assume on-site volume reduction techniques such as waste compaction or an aggressive decontamination, survey, and release effort.

Non-Radioactive Non-Hazardous Waste Disposal EnergySolutions assumes that recyclable, non-radioactive scrap metal resulting from the decommissioning program will be sold to a scrap metal dealer.

Hazardous and Industrial Waste Disposal Uncontaminated lead shielding remaining after shutdown was assumed to be removed from its installed locations and shipped offsite by entities having a need for the material. The entities will receive the lead at no charge in return for providing the removal and shipping services. Non-Radioactive contaminated surfaces coated with tightly adhering and undamaged lead-based paint will be removed as non-hazardous building demolition debris. All other chemicals and hazardous materials present at shutdown will be removed and properly disposed of during decommissioning.

3.5 Final Status Survey The cost of performing a final status survey (FSS) is based on NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)" (Ref. No. 5). Estimates of MARSSIM Class I, II, and III survey designations are based on radiological assumptions regarding contamination resulting from small and large component removal activities. The FSS activity cost calculation includes the in-place remote survey of underground metal and concrete pipe, soil, and groundwater sampling and analysis. Estimated costs for NRC

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 15 of 31 and Oak Ridge Institute for Science and Education (ORISE) verification are also included, and the NRC review period is incorporated into the project schedule.

3.6 Contingency Contingencies are applied to cost estimates primarily to allow for unknown or unplanned occurrences during the actual program, e.g., higher than expected radioactive waste materials volumes, equipment breakdowns, weather delays, or labor strikes. The DOE Cost Estimating Guide, DOE G 430.1-1, 3-28-97 (DOE G) (Ref. No. 6) advises that contingency "covers costs that may result 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; and the complexity and uncertainties of the component parts of the project. Contingency is not to be used to avoid making an accurate assessment of expected costs." EnergySolutions determines site-specific contingency factors for each estimate based on industry practices.

The DOE has established a recommended range of contingencies as a function of completeness of program design (DOE G). The ranges are:

Contingency Range Type of Estimate as a % of Total Estimate Planning Phase Estimate 20-30 Budget Estimate 15-25 Title I (Preliminary Design Estimate) 10-20 Title II (Definitive Design Estimate) 5-15 The Fort Calhoun DECON scenario has had substantial development and the Fuel-Pool-to-Pad program is complete as of December 2020. This DCE is a Budget Estimate designed to provide sufficient information to OPPD to assess its financial obligations for decommissioning Fort Calhoun. It is not a detailed budget, but a financial analysis prepared in advance of the detailed execution planning and budgeting work required to carry out the decommissioning.

A reactor decommissioning program will be conducted under an NRC-approved QAP that meets the requirements of 10 CFR 50, Appendix B. The QAP development, the performance of work under that program, and the effort required to ensure compliance with the program are already included in the detailed cost estimate. Therefore, EnergySolutions does not include quality assurance as an element of the contingency allowance. The same is true for contamination. Where radioactive contamination or activated materials are dealt with, the cost factors and associated calculations fully reflect the cost impact of that material, and a separate contingency is not required specifically due to working with contamination.

3.7 Cost Reporting Total project costs are aggregated from the distributed activity and undistributed costs into the following categories:

Labor Materials and Equipment Waste Packaging and Transportation Waste Disposal Subcontracts

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 16 of 31 Other Costs Other costs include property taxes, insurance, license fees, permits, and energy. Waste disposal costs include any applicable surcharges. Health physics (HP) supplies and small tool costs are calculated as components of each distributed activity cost and included in the category of Material and Equipment, with the exception that HP supplies for the Utility HP staff are calculated and reported as an undistributed line item. A line item specific contingency is then calculated for each activity cost element.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 17 of 31 4.0 SITE-SPECIFIC TECHNICAL APPROACH 4.1 Facility Description FCS is located between Fort Calhoun and Blair, Nebraska, adjacent to the Missouri River.

The Nuclear Steam Supply System (NSSS) consists of a 1500 Mwt PWR supplied by Combustion Engineering.

The station has an on-site ISFSI consisting of TRANSNUCLEAR 32PT spent storage canisters stored inside NUHOMS horizontal storage modules.

4.2 Major Work Periods for DECON The estimate is organized into three major work periods, each with sub-periods and defined scope activities as follows:

Period 1 - Transition through SNF Pool to Pad:

Period 1a - SAFSTOR & Transition:

Period 1a.1 - Planning & Procedures (completed)

Period 1a.2 - ISFSI Design & Construction (completed)

Period 1a.3 - ISFSI Security Modifications (completed)

Period 1a.4 - Fuel Pool Operations (completed)

Period 1b -Spent Fuel Pool to Pad:

Period 1b.1 - Security through Fuel Transfer (completed)

ISFSI & Plant Security Staff Period 1b.2 - Design & Procure Fuel & GTCC Casks (in progress)

Design & Procure Fuel Casks (completed)

Design & Procure GTCC Casks (in progress)

Cask Vendor Tech Support (N/A)

Period 1b.3 - Fuel Pool Operations (completed)

Spent Fuel Operations Support Fuel Pool Water Processing Fuel Pool Clean-up Period 1b.4 - Fuel Transfer Operations (completed)

Procure Transport / Transfer Equipment Spent Fuel Transfer Period 1b.5 - Utility Staff through Fuel Transfer (completed)

Utility Project Staff ISFSI Operations & Maintenance

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 18 of 31 Period 2 - Decommissioning & License Termination:

Period 2a - Decommissioning Planning & Transition:

Period 2a.1 - Site Assessments (completed)

Period 2a.2 - License Termination Plan (LTP) Planning & Preparation (in progress)

LTP Preparation Period 2a.3 - Planning Services (completed)

General Planning Services Site Surveys & Characterization Procurement Planning Baseline Development Period 2a.4 - Infrastructure Upgrades (completed)

Road Upgrades Rail Upgrades Period 2a.5 - Decommissioning Electrical (completed)

Cold & Dark Operations Temporary Power Upgrades Period 2b - License Termination:

Period 2b.1 - Reactor Vessel Develop RVI/RV Plans & Procedures Procure RVI Equipment RVI Equipment Tech Support RVI Segmentation & Removal RVI GTCC Operations & Loading Procure RV Equipment RV Equipment Tech Support RV Segmentation & Removal Period 2b.2 - Large Component Removal Heavy Lift / Transfer Equipment Remaining Legacy Large Component Removal (completed)

Steam Generator Removal Pressurizer Removal RCP Removal Period 2b.3 - Rad Building Interior / Systems D&D Asbestos Abatement (in progress)

Chemical Decon Reactor Bldg. Interior / Systems Demo Aux Bldg. Interior / Systems Demo

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 19 of 31 Rad Waste Bldg. Interior Demo Misc. Rad Systems Removal (completed)

D&D Contractor Staff D&D Contractor Tools & Equipment Period 2b.4 - Rad Building Open Air Demolition Reactor Building Demo Aux Building Demo Rad Waste Bldg. Interior Demo Misc. Rad Building & Open Air Demo Firing Range (completed)

Drainage Lagoons D&D Contractor Staff D&D Contractor Tools & Equipment Period 2b.5 - Field Waste Operations Waste Handling Equipment Waste Handling & Loadout Waste Rad Techs Period 2b.6 - Rad Waste Transportation & Disposal Waste Packaging & Transportation Class A Waste Disposal Class B & C Waste Disposal Remaining Legacy Large Component Disposal (completed)

Period 2b.7 - Non-Rad & Hazardous Waste Disposal Recycle Materials Non-Rad Local Landfill Period 2b.8 - Field Radiation Protection Rad Protection Techs Period 2b.9 - Field Rad Surveys & Final Site Surveys Final Site Surveys Period 2c - Site Restoration:

Period 2c.1 - Clean Building Demolition Asbestos Abatement (completed)

Turbine Building Demo Intake Structure Demo Admin Building Demo Mausoleum Demo New & Old Warehouse Demo Misc. Clean Building Demo (completed)

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 20 of 31 Underground Piping & Utilities Yard/Parking Lot Pavement & Concrete MET Tower Demo (completed)

D&D Contractor Staff D&D Contractor Tools & Equipment Period 2c.2 - Fill & Backfill Materials Process & Reuse On-Site Fill Materials Imported Fill Materials Period 2c.3 - Backfill & Grade Buildings Backfill & Grade Buildings Period 2c.4 - Non-Rad Environmental Remediation Non-Rad Environmental Remediation Period 2c.5 - Final Site Restoration Final Site Grading Period 2d - Decommissioning Undistributed Costs:

Period 2d.1 - Utility Staff during Decommissioning Utility Management Staff Engineering Work Control / Document Control Office Equipment, Misc. Expenses Temporary Facilities Environmental Program Decommissioning NRC Fees & Inspections Regulatory Affairs Program Characterization Program Waste Management QAP Safety Program & Supplies Training Program Period 2d.2 - Plant Operations & Maintenance Plant Operations & Maintenance (non-labor)

Water Processing Utility Costs Period 2d.3 - Plant Security during Decommissioning Plant Security

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 21 of 31 Period 2d.4 - Decommissioning General Contractor Project Management DGC Mobilization DGC Project Management Staff Regulatory Affairs Program DGC Rad Protection Program Characterization Program Waste Management DGC Demobilization Period 2d.5 - Insurance and Taxes ANI Insurance Costs NEIL Insurance Costs Iowa Property Taxes Nebraska Use Taxes Period 2d.6 - Corporate Allocations Corporate A&G Allocations Communications & Telecom Allocations Information Technology Allocations Stores Expense Allocations Period 3 - SNF/GTCC Spent Storage & Disposition:

Period 3a -Spent Fuel Storage:

Period 3a.1 - ISFSI Security & Operations ISFSI Security ISFSI Operations & Maintenance ISFSI NRC Fees ISFSI DAW Waste Period 3a.2 - ISFSI Insurances ISFSI Insurances Period 3a.3 - ISFSI Utility Staff ISFSI Utility Staff Period 3a.4 - ISFSI Corporate Allocations Corporate A&G Allocations Period 3b -Fuel Transfer & ISFSI Decommissioning:

Period 3b.1 - Spent Fuel & GTCC Transfer to DOE Procure/Rent Transfer Equipment GTCC Transfer Operations Spent Fuel Transfer Operations

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 22 of 31 Period 3b.2 - ISFSI Decommissioning & Demolition ISFSI Decommissioning & Demolition ISFSI Site Restoration 4.3 Decommissioning Staff EnergySolutions developed staffing based on the assumption that the FCS decommissioning project will be performed in an efficiently planned and executed manner using project personnel experienced in decommissioning and large-scale project management. This DCE also assumes the decommissioning work will be performed by a highly experienced and qualified Decommissioning General Contractor in partnership with OPPD for staff oversight and management of decommissioning operations.

Estimated Staff levels are provided in Section 6.0, Table 6-4.

4.4 Spent Fuel Management Spent fuel staffing is greatest while the fuel pool is operational during the spent fuel cooling period and the fuel assemblies are being transferred to dry storage. After all spent fuel has been removed from the spent fuel pool, the staff is reduced. During spent fuel pool operations and the dry storage period, the full-time spent fuel management staff is supplemented with part-time staff to support fuel movements. Staff level details are provided in Section 6.0.

4.5 Spent Fuel Shipments The DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel. However, for purposes of this DCE, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. The spent fuel shipping schedules are based in part on the DOEs Acceptance Priority Ranking & Annual Capacity Report, dated July 2004. (Ref. No. 7). Applying the best current information available, this DCE assumes transfer of all Spent Fuel and GTCC material to the DOE by the end of 2058.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 23 of 31 5.0 BASIS OF ESTIMATE AND KEY ASSUMPTIONS The Basis of Estimate and key assumptions for this DCE are:

1.

The DCE is based on DECON Decommissioning Hybrid model, where OPPD works in unison with a competent DGC, using currently available technologies and in accordance with current regulations.

2.

The DCE is presented in 2021 dollars and is based on estimated costs forward from December 31, 2021.

3.

ES assumes SAFSTOR and Transition Planning, and Fuel Sampling activities have been completed prior to December 31, 2019. OPPD IOF Building Construction building costs are complete based on 2020 DCE data provided by OPPD.

4.

ES assumes required ISFSI design and construction activities are complete.

5.

Spent Fuel Pool Clean-up is complete as of December 31, 2021.

6.

The contract for removal, transportation and disposal of Legacy Reactor Vessel Head and Pressurizer is 100% complete as of December 31, 2020.

7.

OPPD staff and security levels are based on the staffing plan previously provided by OPPD.

8.

OPPD staff and security labor costs are based on 2021 DCE Data Request provided by OPPD.

9.

Corporate allocations and costs are based on the 2021 DCE Data Request including:

Employee Severance and/or Retention Costs Site O&M (non-labor and recurring cost)

Corporate A&G Post-Shutdown Insurance Premiums NEI, NEI PADS Memberships, Fees Taxes, Assessments, Payments in Lieu of Taxes Support Services Costs

10.

Contingencies included in the estimate are consistent with a budget estimate designed to provide sufficient information to OPPD to assess its financial obligations for decommissioning Fort Calhoun.

11.

Costs for transportation of clean scrap metal to a recycler are included in the estimate; however, a credit is included for the value of scrap metal.

12.

Costs for hazardous waste disposal, as well as asbestos and lead abatement, are included in this study.

13.

All Class-A waste is assumed to be disposed of at EnergySolutions facility in Clive, Utah.

14.

Class A waste includes Dry Active Waste (DAW) arising from the disposal of contaminated protective clothing and health physics supplies.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 24 of 31

15.

Class B and C waste disposal costs are based on disposal of activated hardware and resins at the WCS, Texas facility. All resins and filter waste are assumed to be Class B.

16.

Transportation costs for the Class B and C waste are based on a distance of 900 miles one way from Fort Calhoun to the WCS facility.

17.

The DCE includes estimated costs for GTCC waste to be packaged in modified spent fuel canisters or similar containers.

18.

Spent Fuel and GTCC waste will be transferred to the DOE at OPPD expense, and the DOE will be responsible for the Spent Fuel and GTCC waste transportation from FCS and disposal at a licensed DOE facility.

19.

The DOE currently has no plans, program, or schedule in place for acceptance of utility spent fuel.

However, for purposes of this DCE, certain simplifying assumptions must be made regarding the schedule and rate of DOE performance. The spent fuel shipping schedules are based in part on the DOEs Acceptance Priority Ranking & Annual Capacity Report, dated July 2004. (Ref. No. 7).

Based upon the best current information available, this DCE assumes transfer of all Spent Fuel and GTCC material to the DOE by the end of 2058.

20.

The 10 CFR Part 50 license will be maintained until DOE takes possession of the spent fuel and the ISFSI is decommissioned.

21.

The current DCE includes 25% contingency for demolition and disposal of the ISFSI. The contingency can be used to decontaminate and/or dispose of low levels of radioactive materials if discovered during the decommissioning process

22.

The DCE includes, as a license termination expense, the annual NRC 10 CFR 171.15(c)(2) fees, for reactors in decommissioning until decommissioning is completed. Following completion of decommissioning, this expense is continued as a SNF/GTCC management cost for maintenance of the 10 CFR Part 50 license.

23.

The DCE includes NRC inspection fees during each decommissioning period based on the type and level of activities being performed.

24.

The PSDAR was revised and submitted in 2019 and accepted by NRC in 2020.

25.

This estimate is based on current existing site and building drawings and plant systems data provided by OPPD combined with EnergySolutions decommissioning experience to establish plant systems and buildings inventories. These inventories, EnergySolutions proprietary Unit Cost Factors (UCFs) and other plant data, were used to generate the required labor-hours, cost, waste volumes, weights and classifications.

26.

All transformers on site following shutdown are assumed to be PCB-free; therefore, this study does not include costs for disposition of PCB contaminated transformers.

27.

It is assumed that remaining uncontaminated lead shielding will be removed from its installed locations and shipped offsite by entities having a need for the material. The entities receive the lead at no charge in return for providing removal and shipping services.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 25 of 31

28.

Non-rad concrete debris and all other demolition debris not suitable for backfill are assumed to be removed from the site and disposed of at a local landfill.

29.

Foundations and building exterior walls are removed to a depth of three feet below nominal grade elevation, surveyed, and backfilled with appropriate fill material.

30.

Clean backfill will be imported and placed to reestablish grade. The entire disturbed area of the site is to be graded, restored to the natural grade to the extent possible, and seeded.

31.

The estimate is based on final site restoration in which all existing and proposed structures, except for the Training Center, FLEX Building and the Switchyard will be removed. Clean demolition costs are based on the assumption that all site improvements will be removed in their entirety.

32.

Water processing operations estimates assume an experienced decommissioning operations contractor performs the decommissioning and understands the projected water requirements.

33.

The waste generated from the segmentation of the reactor vessel internals will be packaged in shielded containers. For this estimate, the MPCs are assumed to be accepted by DOE at the time of shipment.

34.

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

35.

The estimate includes contingency, but generally does not include any allowance for substantive schedule delays, nor cost allowance for field labor retained on site while waiting for work to become available.

36.

The costs of all required safety analyses and safety measures for the protection of the general public, the environment, and decommissioning workers are included in the cost estimates, per the following regulations:

10 CFR 20 Standards for Protection Against Radiation 10 CFR 50 Domestic Licensing of Production and Utilization Facilities 10 CFR 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CFR 71 Packaging and Transportation of Radioactive Material 10 CFR 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 29 CFR 1910 Occupational Safety and Health Standards 49 CFR 170-189 Department of Transportation Regulations Governing the Transport of Hazardous Materials Reg. Guide 1.159 Assuring the Availability of Funds for Decommissioning Nuclear Reactors

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 26 of 31 6.0 STUDY RESULTS 6.1 Cost Summary by License Termination, Spent Fuel, and Site Restoration A DCE summary is provided in Table 6-1. This table identifies License Termination cost (corresponding to 10 CFR 50.75(c) requirements); Spent Fuel Management costs (corresponding to 10 CFR 50.54(bb) requirements); and Site Restoration costs (corresponding to activities such as clean building demolition and site grading etc.).

TABLE 6-1 DECON DCE GTCC casks and operations are included in the License Termination Costs. GTCC long-term ISFSI storage and disposition are included in the Spent Fuel Costs.

A detailed cost table is provided in Appendix C.

6.2 Summary Schedule The costs and schedule for the DECON scenario are divided into major project phases (periods) and presented as Transition through SNF Pool to Pad, Decommissioning and License Termination or SNF/GTCC Spent Storage and Disposition. Figure 6-1 shows the summary-level DECON schedule.

A detailed schedule is provided in Appendix B.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 27 of 31 FIGURE 6-1 DECON Schedule 6.3 Cost Summary by Phase and Cost Type Tables 6-2 and 6-3 provide cost summaries for the DECON scenario by period and by cost type.

In Table 6-3, Other Direct Costs includes miscellaneous services such as Temporary Facilities, Licensing Costs, NRC Fees, Insurances, Taxes, Permits, Corporate Allocations, etc.

The detailed Decommissioning Cost Estimate is provided in Appendix C.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 28 of 31 TABLE 6 DECON Cost Summary by Phase TABLE 6-3 DECON Cost Summary by Cost Type 6.4 Project Staffing Table 6-4 shows the estimated average annual DECON staffing & security manpower.

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 29 of 31 TABLE 6-4 DECON Staffing & Security Manpower 6.5 Waste Disposal Volumes Table 6-5 below provides a summary of waste disposal volumes by waste classification.

TABLE 6-5 Waste Disposal Volumes Appendix A provides a Waste Disposal Summary itemized by volumes, waste form, waste class, weight, volume and costs for packaging, transportation and disposal.

Waste Class Volume (cf)

Class A Waste 2,497,082 Class B & C Waste 1,666 GTCC Waste 1,180

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 30 of 31 6.6 Estimated Annual Spending Table 6-6 shows the estimated annual spending.

TABLE 6-6 DECON Projected Annual Spending

Site-Specific Decommissioning Cost Estimate for Document No. 164074-DCE-00 Fort Calhoun Nuclear Station Rev. 2 Page 31 of 31

7.0 REFERENCES

1. U.S. Nuclear Regulatory Commission, "Domestic Licensing of Production and Utilization Facilities," 10 CFR Part 50, 2008.

2. Atomic Industrial Forum, Inc., "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," AIF/NESP-036, May 1986.

3. U.S. Nuclear Regulatory Commission, "Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors," Regulatory Guide 1.202, February 2005.

4. U.S. Nuclear Regulatory Commission, "Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station," NUREG/CR- 0130, June 1978.

5. U.S. Nuclear Regulatory Commission, "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," NUREG-1575, Rev. 1, August 2000.

6. U.S. Department of Energy, "Cost Estimating Guide," DOE G 430.1-1, March 1997.

7. U.S. Department of Energy, Acceptance Priority Ranking & Annual Capacity Report, DOE/RW-0567, July 2004.

SiteSpecificDecommissioningEstimateforFort CalhounNuclearStation

AppendixA

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 1,639 22,420 24,058 Clive CWF A

422,708 9,682 11,613 2,587 3,360 5,947 Clive Debris A

139,648,601 2,432,698 2,441,460 13,951 102,892 116,843 Clive Large Component A

2,604,487 26,650 28,132 8,095 6,427 14,522 Clive Legacy Components A

15,878 3,279 3,121 6,400 142,836,973 2,470,821 2,498,748 29,551 138,220 167,771 Other Local Landf Clean/Exempt F

1,982,766 72,184 72,200 3,147 3,573 Local RecycRecycled Metals F

24,497,545 1,224,877 1,225,692 (1,847)

(1,847)

On Site Clean/Exempt F

182,542,639 2,028,252 2,028,400 209,022,949 3,325,313 3,326,292 1,300 1,726 Grand Total 351,859,923 5,796,134 5,825,040 29,551 139,520 169,496 Appendix A OPPD - Fort Calhoun Nuclear Generating Station Waste Disposal Summary (thousands of 2021 dollars)

SiteSpecificDecommissioningEstimateforFort CalhounNuclearStation

AppendixB

Activity ID Activity Name Start Finish Major Milestone Major Milestones Major Milestones Major Milestones Milestones Milestones Milestones Milestones A1200 GTCC Transfer to ISFSI Complete 09-Dec-22 A1300 Reactor Vessel Segmentation Complete 29-Aug-23 A1400 All Large Components Off Site 17-Sep-24 A1500 All Building Demolition Complete 05-Aug-25 A1700 Site Restoration Complete 17-Sep-25 A1800 License Termination Complete 23-Sep-26 A1600 All Rad Waste Off Site 13-Oct-26 Period 1 Trans 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 Fu 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1.b Spent Fuel Transfer to ISFSI 1b.300 Fuel Pool Operations 02-Jan-19 A 31-Jan-22 Period 2 Decom Period 2 Decommissioning & License Termination Period 2 Decommissioning & License Termination Period 2 Decommissioning & License Termination 2.a Decomm 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2.a Decommissioning Planning & Preparation 2a.200 License Termination Plan (LTP) Preparation 25-Jul-19 A 22-Mar-23 2.b License 2.b License Termination 2.b License Termination 2.b License Termination 2b.100 Develop Reactor Vessel Segmentation & Procurement Plan 30-Apr-19 A 01-Feb-22 2b.500 Field Waste Operations 01-Jun-20 A 13-Oct-25 2b.300 Rad Building Interior / Systems D&D 19-Mar-21 A 24-Jan-25 2b.120 Procure & Deliver RV Segmentation Equipment 12-Aug-21 A 06-Jan-23 2b.130 Reactor Vessel Internal (RVI) Segmentation 02-Nov-21 A 07-Nov-22 2b.900 Field Rad Surveys & Final Site Surveys 03-Jan-22 A 17-Feb-26 2b.210 Large Component Removal 31-Jan-22 17-Sep-24 2b.400 Rad Building Open Air Demolition 01-Feb-22 01-Jul-25 2b.600 Rad Waste Transportation & Disposal 13-Sep-22*

13-Oct-26 2b.140 GTCC Waste Transfer to ISFSI 07-Nov-22*

09-Dec-22 2b.150 Reactor Vessel (RV) Segmentation 21-Feb-23*

29-Aug-23 2b.910 Final Survey Reports & Submittals 15-Jan-24*

25-Mar-26 2b.920 NRC Reviews & Approvals 25-Mar-26 23-Sep-26 2.c Site Rest 2.c Site Restoration 2.c Site Restoration 2.c Site Restoration 2c.100 Clean Building & Site Demolition 15-Mar-21 A 05-Aug-25 2c.300 Backfill & Grade Buildings 22-Jul-21 A 17-Sep-25 2c.500 Final Site Restoration 12-Jan-24*

17-Sep-25 2.d Decomm 2.d Decommissioning Undistributed Costs 2.d Decommissioning Undistributed Costs 2.d Decommissioning Undistributed Costs 2d.400 Decommissioning General Contractor Staff 02-Jan-19 A 23-Sep-26 2d.100 Utility Staff during Decommissioning 02-Jan-19 A 23-Sep-26 2d.200 Plant Operations & Maintenance 02-Jan-19 A 23-Sep-26 2d.300 ISFSA Security During Decommissioning 02-Jan-19 A 23-Sep-26 2d.310 Plant Security during Decommissioning 02-Jan-19 A 23-Sep-26 Period 3 SNF/G Period 3 SNF/GTCC Dry Storage & Disposition Period 3 SNF/GTCC Dry Storage & Disposition Period 3 SNF/GTCC Dry Storage & Disposition 3.a Dry Fuel 3.a Dry Fuel Storage 3.a Dry Fuel Storage 3.a Dry Fuel Storage 3a.100 ISFSI Security & Operations (2026 through 2059) 02-Jan-26*

01-Jan-59 3a.300 ISFSI Utility Staff (2026 through 2059) 02-Jan-26*

01-Jan-59 3.b Fuel Tran 3.b Fuel Transfer & Decommissioning 3.b Fuel Transfer & Decommissioning 3.b Fuel Transfer & Decommissioning 3b.100 Spent Fuel & GTCC Transfer to DOE (complete by end of 2059 02-Jan-19 A 20-Dec-60 3b.200 ISFSI Decommissioning & Demolition (2059) 02-Jan-19 A 20-Dec-60 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 2022 2023 2024 2025 2026 2027 2028 OPPD Fort Calhoun 2022 31-Jan-22 14:01 Remaining Level of Effort Actual Level of Effort Actual Work Remaining Work Critical Remaining Work Milestone Page 1 of 1 TASK filter: 100%.

© Oracle Corporation

SiteSpecificDecommissioningEstimateforFort CalhounNuclearStation

AppendixC

10Feb22 Period Item Number ItemDescription Labor Cost Materials&

Equipment Waste Packaging 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

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

0 1b 1b.1.1 ISFSI&PlantSecurityStaff

0 1b.1 SecuritythroughFuelTransfer

0 1b 1b.2.1 Design&ProcureFuelCasks

1b 1b.2.2 Design&ProcureGTCCCasks 96 10 105

105

1b 1b.2.3 CaskVendorTechSupport(inclwithprocurement)

1b.2 Design&ProcureFuel&GTCCCasks

96

10 105

105

0 1b 1b.3.1 SpentFuelOperationsSupport

1b 1b.3.2 FuelPoolWaterProcessing

1b 1b.3.3 FuelPoolCleanup

1b.3 FuelPoolOperations

0 1b 1b.4.1 ProcureTransport/TransferEquipment

1b 1b.4.2 SpentFuelTransfer(includesequipment)

1b.4 FuelTransferOperations

0 1b 1b.5.1 UtilityProjectStaff

0 1b 1b.5.2 ISFSIOperations&Maintenance(inclwithUtilitystaff)

1b.5 UtilityStaffthroughFuelTransfer

0 1bTotalSpentFuelPooltoPad

96

10 105

105

0 2a 2a.1.1 HistoricSiteAssessment(HSA)

2a 2a.1.2 EnvironmentalAssessments

2a.1 SiteAssessments(completed)

0 2a 2a.2.1 LTPPreparation

2a.2 LTPPlanning&Preparation

0 2a 2a.3.1 GeneralPlanningServices(inclwithUtilityStaff)

2a 2a.3.2 SiteSurveys&Characterization

2a 2a.3.3 ProcurementPlanning(inclwithUtilityStaff)

2a 2a.3.4 BaselineDevelopment

2a.3 PlanningServices

0 2a 2a.4.1 RoadUpgrades

2a 2a.4.2 RailUpgrades

2a.4 InfrastructureUpgrades

0 2a 2a.5.1 Cold&DarkOperations

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

2a.5 DecommissioningElectrical

0 2aTotalDecommissioningPlanning&Transition

0 2b 2b.1.1 DevelopRVI/RVPlansandProcedures 177 95 27 299 299

800 EstimatedCoststoCompleteasofDecember31,2021 AppendixC OPPDFortCalhounNuclearGeneratingStation DECON (thousandsof2021Dollars)

Page1of4

10Feb22 Period Item Number ItemDescription Labor Cost Materials&

Equipment Waste Packaging WastePackaging&

Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours EstimatedCoststoCompleteasofDecember31,2021 AppendixC OPPDFortCalhounNuclearGeneratingStation DECON (thousandsof2021Dollars) 2b 2b.1.2 ProcureRVIEquipment 1,075 107 1,182 1,182

2b 2b.1.3 RVIEquipmentTechSupport 2,352 235 2,588 2,588

2b 2b.1.4 RVISegmentation&Removal 8,208 821 9,029 9,029

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

2b 2b.1.6 ProcureRVEquipment 15,935 1,594 17,529 17,529

2b 2b.1.7 RVEquipmentTechSupport 443 44 487 487

2b 2b.1.8 RVSegmentation&Removal 4,074 407 4,481 4,481

2b.1 ReactorVessel 177 17,010

15,077 95 3,236 35,594 35,594

800 2b 2b.2.1 HeavyLift/TransferEquipment(inclwithsteamgenerator)

2b 2b.2.2 RemainingLegacyLargeComponentRemoval

2b 2b.2.3 SteamGeneratorRemoval 6,394 639 7,034 7,034

2b 2b.2.4 PressurizerRemoval 74 7

81 81

2b 2b.2.5 RCPRemoval 294 29 323 323

2b.2 LargeComponentRemoval

6,762

676 7,438 7,438

0 2b 2b.3.1 AsbestosAbatement 963 96 1,059 1,059

2b 2b.3.2 ChemicalDecon(inclwithwork)

2b 2b.3.3 ReactorBldg.Interior/SystemsDemo 3,715 371 4,086 4,086

2b 2b.3.4 AuxBldg.Interior/SystemsDemo 180 18 198 198

2b 2b.3.5 RadWasteBldg.InteriorDemo 93 9

102 102

2b 2b.3.6 MiscRadSystemsRemoval

2b 2b.3.7 D&DContractorStaff 557 56 613 613

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

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

2b.3 RadBldg.Interior/SystemsD&D

5,508

551 6,059 6,059

0 2b 2b.4.1 ReactorBuildingDemo 8,819 882 9,701 9,701

2b 2b.4.2 AuxBuildingDemo 11,024 1,102 12,126 12,126

2b 2b.4.3 RadWasteBldg.InteriorDemo 2,205 220 2,425 2,425

2b 2b.4.4 MiscRadBuilding&OpenAirdemo 6,829 683 7,512 7,512

2b 2b.4.5 FiringRange(included)

2b 2b.4.6 DrainageLagoons 470 47 517 517

2b 2b.4.7 D&DContractorStaff

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

2b 2b.4.9 D&DContractorScaffolding

2b.4 RadBuildingOpenAirDemolition

29,347

2,935 32,282 32,282

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

2b 2b.5.2 WasteHandling&Loadout 10,417 1,042 11,458 11,458

2b 2b.5.3 WasteRadTechs(inclwithwastehandling)

2b.5 FieldWasteOperations

10,417

1,042 11,458 11,458

0 2b 2b.6.1 WastePackaging&Transportation 29,255 4,388 33,644 33,644

2b 2b.6.2 ClassAWasteDisposal 114,642 17,196 131,838 131,838

2b 2b.6.3 ClassB&CWasteDisposal 22,195 3,329 25,525 25,525

2b 2b.6.4 RemainingLegacyLargeComponentDisposal

2b.6 RadWasteTransportation&Disposal

29,255 136,837

24,914 191,007 191,007

0 2b 2b.7.1 RecycleMaterials (1,200)

(180)

(1,380)

(1,380)

2b 2b.7.2 NonRadLocalLandfill 2,322 348 2,670 2,670

2b.7 NonRad&HazardousWasteDisposal

1,122 168 1,290 1,290

0 2b 2b.8.1 RadProtectionTechs 8,084 808 8,892 8,892

2b 2b.8.2 RadProtectionTechs 5,775 578 6,353 6,353

88,852

2b.8 FieldRadiationProtection 5,775

8,084

1,386 15,245 15,245

88,852 2b 2b.9.1 FinalSiteSurveys 6,288 2,096 2,096 1,048 11,528 11,528

96,737

2b.9 FieldRadSurveys&FinalSiteSurveys 6,288 2,096

2,096 1,048 11,528 11,528

96,737 2bTotalRadDecommissioning&LicenseTerm 12,240 19,106

29,255 136,837 75,194 3,313 35,955 311,900 311,900

186,388 2c 2c.1.1 AsbestosAbatement

Page2of4

10Feb22 Period Item Number ItemDescription Labor Cost Materials&

Equipment Waste Packaging WastePackaging&

Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours EstimatedCoststoCompleteasofDecember31,2021 AppendixC OPPDFortCalhounNuclearGeneratingStation DECON (thousandsof2021Dollars) 2c 2c.1.2 TurbineBuilding 4,590 459 5,049

5,049 2c 2c.1.3 IntakeStructure 3,402 340 3,742

3,742 2c 2c.1.4 AdminBuilding 769 77 846

846 2c 2c.1.5 FlexBldg.(notremoved)

2c 2c.1.6 Mausoleum 118 12 130

130 2c 2c.1.7 TrainingCenter(notremoved)

2c 2c.1.8 New&OldWarehouseDemo 19 2

21

21 2c 2c.1.9 MiscCleanBuildingDemo(TSC/CARP/OldSecurity)

2c 2c.1.10 UndergroundPiping&Utilities 3,222 322 3,544

3,544 2c 2c.1.11 Yard/Parkinglotpavement&concrete 2,089 209 2,298

2,298 2c 2c.1.12 METTower

2c 2c.1.13 D&DContractorStaff(inclwithwork)

2c 2c.1.14 D&DContractorTools&Equipment(inclwithwork)

2c.1 CleanBuildingDemolition

14,209

1,421 15,630

15,630 0

2c 2c.2.1 Process/ReuseOnSiteFillMaterials 6,176 618 6,793 0

6,793 2c 2c.2.2 ImportedFillMaterials 1,773 177 1,950

1,950 2c.2 Fill&BackfillMaterials

1,773

6,176

795 8,743 0

8,743 0

2c 2c.3.1 Backfill&GradeBuildings 733 73 807

807 2c.3 Backfill&GradeBuildings

733

73 807

807 0

2c 2c.4.1 NonRadEnvironmentalRemediation 1,235 124 1,359

1,359 2c.4 NonRadEnvironmentalRemediation

1,235

124 1,359

1,359 0

2c 2c.5.1 FinalSiteGrading 591 59 650

650 2c.5 FinalSiteRestoration

591

59 650

650 0

2cSiteRestoration

1,773

22,944

2,472 27,188 0

27,188 0

2d 2d.1.1 UtilityManagementStaff 46,883 4,688 51,571 49,508

2,063 516,360 2d 2d.1.2 Engineering(inclwithutilitystaff)

2d 2d.1.3 WorkControl/DocumentControl(inclwithutilitystaff)

2d 2d.1.4 OfficeEquipment,MiscExpenses

2d 2d.1.5 TemporaryFacilities 2,698 270 2,968 2,849

119 2d 2d.1.6 EnvironmentalProgram 1,077 108 1,185 1,137

47 2d 2d.1.7 DecommissioningNRCFees&Inspections 5,384 538 5,923 5,923

2d 2d.1.8 RegulatoryAffairsProgram(inclwithutilitystaff)

2d 2d.1.9 CharacterizationProgram(inclwithutility&contractorstaff)

2d 2d.1.10 WasteManagement(inclwithutility&contractorstaff)

2d 2d.1.11 QualityAssuranceProgram

2d 2d.1.12 SafetyProgram&Supplies 1,346 135 1,481 1,421

59 2d 2d.1.13 TrainingProgram(InprocessingTime) 1,891 189 2,080 1,997

83 2d.1 UtilityStaffduringDecommissioning 46,883 1,346

1,891 9,159 5,928 65,207 62,836

2,371 516,360 2d 2d.2.1 PlantOperations&Maintenance(nonlabor) 3,000 300 3,300 3,168

132 2d 2d.2.2 WaterProcessing 571 57 629 603

25 2d 2d.2.3 UtilityCosts 882 88 970 932

39 2d.2 PlantOperations&Maintenance

3,000

1,454 445 4,899 4,703

196 0

2d 2d.3.1 PlantSecurity 11,072 1,107 12,179 11,692

487 88,920

2d.3 PlantSecurityduringDecommissioning 11,072

1,107 12,179 11,692

487 88,920 2d 2d.4.1 DGCContractorMobilization 538 54 592 569

24 2d 2d.4.2 DecommissioningGeneralContractorStaff 38,550 25,700 6,425 70,675 67,848

2,827 189,000

2d 2d.4.3 RegulatoryAffairsProgram(inclwithDGCstaff)

2d 2d.4.4 ContractorRadProtectionProgram 4,792 479 5,271 5,060

211 2d 2d.4.5 CharacterizationProgram(inclwithDGCstaff)

2d 2d.4.6 WasteManagement(inclwithDGCstaff)

2d 2d.4.7 DGCContractorDemobilization 538 54 592 569

24 2d.4 ContractorProjectManagement 38,550 4,792

26,777 7,012 77,130 74,045

3,085 189,000 2d 2d.5.1 ANIInsuranceCosts(postshutdown)

Page3of4

10Feb22 Period Item Number ItemDescription Labor Cost Materials&

Equipment Waste Packaging WastePackaging&

Transportation Waste Disposal Subcontracts OtherDirect Cost(ODC)

Contingency TotalCost (Estimated)

License Termination SpentFuel Management Site Restoration ManHours EstimatedCoststoCompleteasofDecember31,2021 AppendixC OPPDFortCalhounNuclearGeneratingStation DECON (thousandsof2021Dollars) 2d 2d.5.2 ANIInsuranceCosts(postfueltransfer) 2,750 275 3,025 2,904

121 2d 2d.5.3 NEILInsuranceCosts(postshutdown)

2d 2d.5.4 NEILInsuranceCosts(postfueltransfer) 1,650 165 1,815 1,815

2d 2d.5.5 IowaPropertyTax 100 10 110 106

4 2d 2d.5.6 NebraskaUseTax(5.5%)

1,600 160 1,760 1,690

70 2d.5 InsuranceandTaxes

6,100 610 6,710 6,514

196 0

2d 2d.6.1 CorporateA&GAllocations 6,540 654 7,194 6,906

288 2d 2d.6.2 Communications(Telecom)Allocations 990 99 1,089 1,045

44 2d 2d.6.3 InformationTechnologyAllocations 9,600 960 10,560 10,138

422 2d 2d.6.4 StoresExpenseAdder 400 40 440 422

18 2d.6 CorporateAllocations

17,530 1,753 19,283 18,512

771 0

2dDecommissioningUndistributedCosts 96,504 9,138

1,891 61,020 16,855 185,408 178,302

7,107 794,280 Period2TotalDecommissioning&LicenseTermination 108,744 30,017

29,255 136,837 100,028 64,333 55,282 524,497 490,202

34,295 980,668 3a 3a.1.1 ISFSISecurityduringDecommissioning 13,849 1,385 15,234

15,234

238,160 3a 3a.1.2 ISFSISecurityduringDFS 78,566 7,857 86,423

86,423

1,530,880 3a 3a.1.3 ISFSIOperations&Maintenance 17,984 2,698 20,682

20,682

3a 3a.1.4 ISFSINRCFees 9,900 1,485 11,385

11,385

3a 3a.1.5 ISFSIDAWWaste 1,691 254 1,944

1,944

3a.1 ISFSISecurity&Operations 92,415

1,691

27,884 13,678 135,667

135,667

1,769,040 3a 3a.2.1 ISFSIPropertyTaxes(notrequired)

3a 3a.2.2 ISFSIInsurance 18,351 2,753 21,104

21,104

3a.2 ISFSIInsurance&Taxes

18,351 2,753 21,104

21,104

0 3a 3a.3.1 ISFSIUtilityStaffduringDecommissioning 13,719 1,372 15,091

15,091

175,760 3a 3a.3.2 ISFSIUtilityStaffduringDFS 81,261 8,126 89,387

89,387

1,131,520 3a.3 ISFSIUtilityStaff 94,980

9,498 104,478

104,478

1,307,280 3a 3a.4.1 CorporateA&GAllocations 3,458 519 3,976

3,976

3a.4 ISFSICorporateAllocations

3,458 519 3,976

3,976

0 3aSpentFuelStorage 187,395

1,691

49,693 26,447 265,225

265,225

3,076,320 3b 3b.1.1 Procure/RentTransport/TransferEquipment 2,692 404 3,096

3,096

3b 3b.1.2 GTCCTransferOperations

3b 3b.1.3 SpentFuelTransferOperations 10,984 1,648 12,632

12,632

3b.1 SpentFuel&GTCCTransfertoDOE

2,692

10,984

2,051 15,728

15,728

0 3b 3b.2.1 ISFSIDecommissioning&Demolition 3,351 838 4,188 4,188

3b 3b.2.2 ISFSISiteRestoration

3b.2 ISFSIDecommissioning&Demolition

3,351

838 4,188 4,188

0 3bFuelTransfer&ISFSIDecommissioning

2,692

14,335

2,889 19,916 4,188 15,728

0 Period3TotalSNF/GTCCDryStorage&Disposition 187,395 2,692

1,691 14,335 49,693 29,336 285,142 4,188 280,953

3,076,320 GrandTotal 296,139 32,805

29,255 138,528 114,363 114,025 84,628 809,744 494,390 281,059 34,295 4,056,988 Page4of4

LIC-22-0010 ATTACHMENT 5 2013 NEBRASKA STATE HISTORICAL PRESERVATION OFFICE RESULTS OF TESTING AT 25WN16 NEBRASKA DEPARTMENT OF ROADS PROJECT NH-75-3(116)

CN 22447 [FT. CALHOUN TO BLAIR]

WASHINGTON COUNTY, NEBRASKA

1

ResultsofTestingat25WN16,Nebraska DepartmentofRoadsProjectNH753(116),

CN22447,[Ft.CalhountoBlair],

WashingtonCounty,Nebraska

NolanJohnson(NebraskaHighwayArcheologyProgram)

December2013 Introduction

AsdescribedinArcheologicalTestingPlanforDeSotoTownsite25WN16,Nebraska DepartmentofRoadsProjectNH753(116),[Ft.CalhountoBlair],WashingtonCounty,Nebraska archeologicaltestingoccurredat25WN16onJuly3031andAugust8,2013.25WN16wasformally determinedeligibleforlistingontheNationalRegisterofHistoricPlacesbytheNebraskaStateHistoric PreservationOffice(NeSHPO)onJanuary27,1989(InventoryofNationalRegisterofHistoricPlaces ArchaeologicalDeterminationsofEligibility,onfileNeSHPO).Thetestingwasdesignedtodetermineif theproposedNebraskaDepartmentofRoads(NDOR)projectwouldhaveanadverseeffectonit.The sitewastestedbystafffromtheNebraskaHighwayArcheologyProgram(NHAP)attheNebraskaState HistoricalSociety(NSHS)underthedirectionofNolanJohnson.OtherfieldcrewincludedCourtney Ziska,ShaunLynch,KatieLamb,andNickFogerty.Toachievetheabovegoaltheportionofthesitethat wasintheAreaofPotentialEffects(APE)wassurveyedand14testunitswereexcavated.Allcollected materialwascatalogedandexaminedandtheresultscombinedinthisreportwithobservationsfrom thefield.

SiteOverview

DeSotowasathrivingrivertownfrom1856to1866.ItwasthecountyseatofWashington Countyfrom18581866.Thetownwasdoomedbythedeclineinrivertrafficandthefinalnailwasa railroadbridgeovertheMissouriRiveratBlairinsteadofDeSotoin1869.Thehistorictownisunrelated totheunincorporatedclusterofhousescurrentlyknownasDeSoto.Thesiteislocatedonthewestside oftheMissouriRiver.Itextendsfromthehistoricriverchanneltothetopofthebluffsandisroughly2.5 milessoutheastofBlair,NE(Figure1).HighwayUS75runsthroughthesitefromsoutheastto northwest.TheOmahaPublicPowerDistrictFt.CalhounNuclearPowerPlantwasbuiltonaportionof thesite,andthemainaccessroadfollowsoneofthemajorstreetsfromDeSoto(Figure2).Thereareno extantbuildingsassociatedwiththetown,althoughNSHSexcavationsin1976associatedwithan unrelatedundertakingconfirmedthepresenceofintactarcheologicalfeaturesanddepositssuchas buildingfoundations,basements,privies,andotherfeaturesrelatedtothehistorictown.Fieldnotes andthefieldreportfromthe1976excavationsindicatethatmanyfeatureswereleftintactbecausethey wouldnotbedisturbedbyconstructionatthattime(Steinacher1976).The1976excavationstookplace verynearthepresentAPEandsubsurfacefeatureslikelystillexistinthegeneralarea.Theportionofthe siteintheAPEofprojectNH753(116)wassurveyedinApril2013byNHAPpersonnel.Twoareaswithin thesiteboundarywereselectedforadditionaltestingbasedontopography,location,andplanned constructionactivities(Figure3).

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FieldInvestigations

Atotalof14controlledtestunitswereexcavatedinthetwoconstructionareasseeninFigure3.

AnadditionalareawasalsosurveyednearConstructionAreaA.Thishayfieldhadrecentlybeencutand offeredexcellentvisibilityonapromisingtopographicfeature.However,noartifactswereencountered.

SeventestswereexcavatedinConstructionAreaA,ofthosesixwere.5mx.5mandTestUnit3was1m x.5m(Figure4).Thedepthofthetestsrangedfrom40to60cm.Thetestswereexcavatedintenand twentycentimeterlevels,andallthesoilfromtheexcavationswasscreenedthrough1/4inchdrymesh.

ThetestunitsweremappedusingahandheldTrimbleGeoXTGPSunit.InConstructionAreaBseven.5m x.5mtestunitswereexcavated.Theyrangedindepthfrom40cmto60cm.Manyofthetestunitswere furtherassessedwithapostholediggeror3/4inchsoilprobetogreaterdepth.Thegreatestdepth achievedwas1.5mbelowsurfaceinTestUnit7usingasoilprobe.Inalloftheseextensionsofthetest unitsnoartifactsorfeatureswerediscovered.WiththeexceptionofTestUnit14thesoilremained unchanged.InTestUnit14averydarkbrown10YR2/2layerofsoilwasencountered80cmbelowthe surface.

Thetestunitscanbelumpedintofourgroupsbasedontheirlocationandstratigraphy:Test Units14,57,89,and1014(Figures4and5).TestUnits14werelocatedonsmallterracebetween twosteepdrainages.Becausethislandformisverysmallandnarrowaswellassurroundedonthree sidesbysteepslopesithaslikelyavoidedintensivemechanizedagricultureandconstruction.Itwasthe leastmodifiedareatested.HoweverlittlewasfoundinTestUnits14.Thefourtestshadasimilarsoil profile.Atthesurfacewasa10YR4/4siltylayer.Therewasahigherclaycontentasdepthincreased andthecoloratthebottomoftheunitsrangedfrom10YR5/6to10YR6/8.Figures6and7areaphoto andthesoilprofileofTestUnit2shownasexamples.

TestUnits57werelocatedonaflatareathathaslikelybeenfilledandleveledtoserveasan overflowparkingareafortheFt.CalhounNuclearPowerPlant.Thesoilintheunitswasstrikinglysimilar throughout.TestUnit6and7wereidenticalwithsoilsof10YR4/4graduallychangingto10YR4/3.Test Unit5wasslightlydifferentwitha10YR6/3to10YR5/3gradient.TestUnit7wasprobedtoadepthof 1.5mwithnochangebeingnoted.Thesoilwasverylooseandtheprobewasburiedtothehandleand couldhavegonefarther.

TestUnits8and9werelocatedintherightofwayonthesouthwestsideofUS75.Thesoilin thesetwotestswaslighterandmoreyellowthanalltheothertests,10YR6/4lightyellowishbrownand 10YR5/4yellowishbrowninTestUnits8and9respectively.Thesoilwasunchangedinthefirst40cmof eachtest.Thesetestsmostlikelywerelocatedinanareathathadbeenfilledandleveledaftertheroad cuthadbeenmade.ThisishighlyprobableinlightofplasticconstructionnettinglocatedinTestUnit9 at28cmbelowthesurface.

TestUnits1014wereplacedonalowterraceontheedgeofacornfield.TestUnit10was similartoTestUnits8and9.Itwaslocatedclosetoanearthenbermmeanttochannelwaterfroma concreteflumeintoaculvert.Thesoilwassimilarandplasticconstructionnettingwasfound30cm belowthesurface.TestUnits1114hadsoilprofilesthatvariedslightlyincolor,butallweresiltywith increasingclaywithdepth.Thesoilprofilesdidnotvarysignificantlywiththedescriptionofthesoilfor thislocationfoundintheNaturalResourcesConservationService2004SoilSurveyofWashington County,Nebraska.

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Nofeaturesandveryfewartifactswerediscoveredinthetestunits.Norwasthereany indicationonthesurface(i.e.depressions,mounds,etc.)ofburiedculturalremains.Thestratigraphyof thetestunitsdidnotrevealanydiscretesoillayersrelatedtothehistoricoccupationofDeSoto.

MaterialRecovered

Theartifactscollectedinclude:twowirenails,twoferrousmetalfragments,threeferrouswire fragments,onewhitewaresherd,onestonewaresherd,sixcontainerglassfragmentsofassortedcolors, fiveverysmallcoalfragments,and17smalllimestonerocks(Figure8).Noneoftheseitemscanbe definitivelyattributedtoDeSoto,andsomearecertainlynotremnantsfromthetown.Thetwowire nailsaretooyoungbyseveraldecadestobefromDeSotoandtheycanberemovedfromfurther discussion(Wells1998:8687).Alsothesmalllimestonerocksarenaturallyoccurringandnotculturally relatedtoDeSotoandcanalsoberemovedfromdiscussion.Theremainingartifactsarediscussed brieflybelowandsummarizedinTable1.AlloftheartifactsthatmightrelatetoDeSotowerefoundin TestUnits17inConstructionAreaA(Figure3).

InTestUnit1,Level1020cmweretwosmallferrouswirefragmentsandonebrowncontainer glassfragment.Thewirefragmentsaresmoothandsmall.Wirehasandhashadenumerableuseson EuroAmericansitesfromalltimeperiodsandthefragmentsareofuncertainage.Theglassfragmentis alsonotdateable,butdoesresemblemodernbrownbeerbottleglass.InTestUnit1,Level22030cm wereoneflatmetalfragmentandonestonewaresherd.Theferrousmetalfragmentisthinandroughly triangular.Itcannotbedated.Thestonewarefragmenthasatanpasteandatansaltglaze.Itissmall andundecorated.StonewarewasapopularceramicduringtheoccupationofDeSotoandcontinuesto beusedtoday.Thecontinueduseofstonewaremakesthesherdofunknownage.InTestUnit1,Level3 3040cmwasonebrowncontainerglassfragment.Thisfragmentwasdarkerandthickerthanthepiece fromLevel1.Itisverysmall,weighingonly.6gandcannotbedated.

InTestUnit2,Level1020cmwasablackcontainerglassfragment.Thefragmentisverysmall, weighing.2g.Itcannotbedated.InTestUnit2,Level22030cmwasoneclearcontainerglassfragment.

Itwasverysmall,weighing.3g.Italsocannotbedated.

InTestUnit3,Level1020cmwasoneferrousmetalwirefragment.Thispiecewasstraightbut otherwiseidenticaltothosefromTestUnit1.

InTestUnit4,Level22040cmwerefivesmallpiecesofcoal.Thepiecesweighedatotalof.8g.

CoalwouldhavebeenusedinDeSototoheatbuildings,powersteamboats,andforotherpurposesas well.ItisnotpossibletoconclusivelyattributethesesfragmentstoDeSotoascoalwouldhavebeen usedintheareawellafterthetownhadbeenabandoned.Alsointhislevelwasoneprehistoricflake madeofchert.InTestUnit4,Level34060cmwasaferrousmetallumpweighing3.9g.Alsointhislevel weretwowirenails.Becausethenails,whichpostdateDeSoto,werefoundatthisdepthitislesslikely thatthecoalfoundhigherintheunitdatestotheoccupationofDeSoto.

InTestUnit5,Level22040cmwasonewhitewaresherd.Thesherdwassmallweighing.8g,but wasfairlythickat6.3mm.Thepasteisfineandwhite,andtheglazeisalsowhite.Thesmallpiecehasno decoration.WhitewarewouldhavebeenavailableduringtheoccupationofDeSotoandremainsavery commontypeofceramictoday.Consequentlytheundecoratedwhitewaresherdisofunknownage.

InTestUnit7,Level1020cmweretwoclearcontainerglassfragments.Thefragmentsweighed 2.4gcombined.Theyarethickandoneispartofthelipofabottleorjar.Thefragmentshaveno distinguishingmarksandcannotbeattributedtoaspecifictimeperiod.

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Theartifactsrecoveredfromthetestunitswerefewinnumberandsmallinsize.Noneofthe artifactshaveanymarkingsorotherdistinctivecharacteristics.Nothingfoundcanpositivelybe attributedtohistoricDeSoto.Nofeaturesorintactculturallayerswereencounteredinanyofthetest units.Thislackofmaterialandfeaturesisverydifferentfromthe1976excavation.Infieldnotesandthe fieldreportthearcheologistsdescribeartifactsreadilyvisibleonthesurface.Awealthofartifactswas excavatedduringthesummerfieldseason.Moreimportantly11featuresrelatedtobuildingswere excavatedand17otherfeatureswereleftinplace(Steinacher1976).Nothingapproachingthatdensity wasseeninthe2013testing.

Conclusions

The2013testingdidnotdiscoverintactfeaturesorothersignificantsurfaceorsubsurface deposits.AlsonoartifactsthatcouldbepositivelyattributedtoDeSotowereuncovered.Documents fromthe1976excavationfoundinthe25WN16sitefiledetailextensiveartifactsandstructuralremains.

The2013testingwaslocatedinareasthathadbeenpreviouslydisturbedornevercontainedsubstantial remainsfromthesite.The1976fieldreportdescribesmanyfeaturesleftinplace.Theexactlocationof theseisunclearbuttheyareinbetweenthe2013constructionareas(Figure9)(Steinacher2013).This locationisoutsideofAPEforNH753(116).

Recommendation

Theproposedproject,NH753(116),willtakeplacewithinthesiteboundaryof25WN16.The siteiseligiblefortheNRHPunderCriteriaDforhavingsignificantresearchpotential.Theprojectwillnot affectsignificantarcheologicaldeposits,whichgivethesiteitsresearchpotential.Afindingofno historicpropertiesaffectedisrecommended.

References Steinacher,Terry

1976NebraskaStateHistoricalSocietyHighwaySalvageFieldReportNumber8.Onfile, NebraskaStateHistoricalSocietyArcheologicalCollections.

2013PersonalCommunication

Wells,Tom

1998NailChronology:TheUseofTechnologicallyDerivedFeaturesHistoricalArcheology, 32(2):7899.

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Table1:MaterialRecovered Provenience Depth Name Description

1. Weight(g)

Notes TU1Level1 020cm glass fragment lightbrowncontainerglass fragment 1

1.0 25.7mmx13.7mmx2.6mm TU1Level1 020cm wire ferrouswirefragments,bent 2

4.8 2.8mmdiameter,45mm&50mmlong TU1Level2 2030cm metal fragment flatferrousmetalfragment 1

10.3 irregularshape TU1Level2 2030cm ceramic sherd tansaltglazedstoneware sherd 1

1.3 17.5mmx13.8mmx4.6mmnotcompletethickness TU1Level3 3040cm glass fragment darkbrowncontainerglass fragment 1

0.6 9.4mmx9.5mmx4.5mm TU2Level1 020cm glass fragment blackcontainerglassfragment 1

0.2 9.6mmx7.7mmx4.4mm TU2Level2 2030cm glass fragment clearcontainerglassfragment 1

0.3 9.8mmx7.9mmx4.1mm TU3Level1 020cm wire ferrouswirefragment,straight 1

1.2 2.8mmdiameter,40.6mmlong TU4Level2 2040cm coal coalfragments 5

0.8 blackcoalfragments TU4Level2 2040cm CSD brokenflake 1

0.9 prehistoric TU4Level3 4060cm metal fragment ferrousmetallump 1

3.9 irregularshape TU5Level2 2040cm ceramic sherd whiteware,plain,whiteglaze 1

0.8 15.2mmx9.7mmx6.3mm,offwhitefinepaste TU7Level1 020cm glass fragment clearcontainerglassfragments 2

2.4 13mmx10mmx9mm,13.5mmx10mmx5.7mm

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Figure1:25WN16Location

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Figure2:OPPDPowerPlantinRelationtoDeSoto,MissouriRiverca.1860inblue

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Figure3:ConstructionAreas(inyellowandred)Testedin2013at25WN16 ConstructionAreaA ConstructionAreaB

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Figure4:ConstructionAreaA;TestUnits(inpink),AdditionalSurveyLocation(inblue),and25WN16Boundary(inred)

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Figure5:ConstructionAreaB;TestUnits(inpink)

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Figure6:TestUnit2

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Figure7:TestUnit2SoilProfile 015cm,10YR4/4Silt 1532cm,10YR5/8ClayeySilt 3250cm,10YR6/8ClayeySilt

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Figure8:Artifacts

Ferrous Metal Fragments Container Glass Fragments Historic Ceramic Sherds CoalFragments Ferrous Wire Fragments

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Figure9:25WN16(inred)ConstructionAreas(inyellowandred),

ProbableLocationofIntactFeatures(inpurple)

LIC-22-0010 ATTACHMENT 6 OMAHA PUBLIC POWER DISTRICT PAYMENTS IN LIEU OF TAXES (PILOT)

SUMMARY

2017 - 2021 APRIL1,2022 PAYMENT APRIL1,2021 PAYMENT APRIL1,2020 PAYMENT APRIL1,2019 PAYMENT APRIL1,2018 PAYMENT COUNTY 2021 2020 2019 2018 2017 BURT

$49.08

$49.08

$49.08

$49.08

$49.08 CASS

$294,285.87

$285,420.69

$288,076.61

$296,242.93

$276,510.68 COLFAX

$4,131.65

$4,212.38

$4,626.45

$4,438.01

$4,257.61 DODGE

$147,617.21

$149,980.48

$148,249.17

$147,123.39

$142,749.81 DOUGLAS

$27,823,830.13

$27,305,442.72

$27,920,586.09

$28,205,205.39

$27,601,636.52 JOHNSON

$14,483.13

$14,045.13

$15,022.87

$15,239.59

$14,336.73 NEMAHA

$40,363.90

$40,131.60

$41,881.29

$41,757.37

$39,764.80 OTOE

$4,945.00

$5,055.04

$5,223.33

$5,506.98

$5,312.61 RICHARDSON

$15,048.08

$15,008.84

$15,105.95

$15,937.26

$14,979.92 SARPY

$9,209,063.83

$6,641,735.89

$5,557,183.77

$5,129,697.64

$4,874,001.33 SAUNDERS

$330,669.61

$323,300.81

$326,163.28

$331,118.25

$316,002.12 WASHINGTON

$669,041.56

$651,679.12

$655,674.35

$672,597.89

$651,261.11 NE OCC

$1,500.00

$1,500.00

$1,500.00

$1,500.00

$1,500.00 Total

$38,555,029.05

$35,437,561.78

$34,979,342.24

$34,866,413.78

$33,942,362.32