ML23109A143
| ML23109A143 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 04/18/2023 |
| From: | Halliburton B, Lux J Environmental Properties Management |
| To: | Office of Nuclear Material Safety and Safeguards, NRC/OCFO, Document Control Desk |
| References | |
| Download: ML23109A143 (1) | |
Text
April 18, 2023 U.S. Nuclear Regulatory Commission Chief Financial Officer 11555 Rockville Pike Rockville, MD 20852-2738 Re: Application for Exemption of Fees Pursuant to 10 CFR 170.12 Docket No. 07000925; License No. SNM-928
Dear Sirs:
Solely as Trustee for the Cimarron Environmental Response Trust (CERT), Environmental Properties Management LLC (EPM) is advising the U. S. Nuclear Regulatory Commission (NRC), as a beneficiary of the CERT, that its beneficial interest in recovery of oversight fees conflicts with its beneficial interest in the decommissioning of the Cimarron site and termination of special nuclear materials license SNM-928.
The February 14, 2011, Environmental Response Trust Agreement (Cimarron) provides for recovery of NRC fees from CERT accounts. Paragraph 2.2.1 states that one of the objectives of the CERT is to perform all activities pursuant to the terms and conditions of the Cimarron License, including the preparation and implementation of an NRC-approved decommissioning plan and groundwater remediation plan, and all Environmental Actions required under federal or state law .
Unfortunately, based on current remediation cost estimates, the CERT accounts do not provide sufficient funding to achieve compliance with all federal and state requirements. The State of Oklahoma has agreed to defer actions that would complete remediation to State cleanup criteria for the sole purpose of achieving termination of license SNM-928.
All that remains to achieve license termination is the removal of uranium from groundwater. It is not possible to achieve this goal if the NRC continues to recover oversight fees, which have constituted nearly one fourth of all decommissioning expenditures since 2011. Consequently, EPM is requesting exemption of NRC from pursuant to 10 CFR 170.12.
10 CFR 170.11(b) states, The Commission may, upon application by an interested person, or upon its own initiative, grant such exemptions from the requirements of this part as it determines are authorized by law and are otherwise in the public interest. Applications for exemption under this paragraph may include activities such as, but not limited to, the use of licensed materials for educational or noncommercial public displays or scientific collections.
EPM believes it is clearly in the public interest to reduce the concentration of enriched uranium in groundwater at the Cimarron site to concentrations that are less than the NRC Criterion 9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
stipulated in NRC license SNM-928, and to the extent achievable if not less than the NRC Criterion.
Prior to the full funding of the Trust accounts, the NRC deferred recovery of costs, with the intent that when the Trust accounts received additional funding from ongoing litigation, the deferred costs would be recovered. When additional funding was received, the NRC invoiced the Trust for all deferred fees. At a minimum, EPM requests that the NRC resume the policy of deferring all fees until the decommissioning of the site is complete.
The CERT is not an operating business that can generate additional funds to address an anticipated shortfall in funding. As both regulator and beneficiary of the CERT, the NRC has a unique role; as beneficiary, the NRC can decide whether to utilize Trust funds to recover fees or to complete the decommissioning of the site. provides background information which describes the formation of the CERT, the impact of NRC fee recovery on expenditures, and the basis for EPMs assertion that exemption or deferral of NRC fees is necessary for EPM to complete the decommissioning of the site.
If you have any questions or desire clarification, please contact me at jlux@envpm.com or (405) 642-5152.
Sincerely, Bill Halliburton Trust Administrator Jeff Lux Project Manager cc: Jane Marshall, NRC Pamela Dizikes, Office of General Counsel, DEQ NRC Public Document Room DEQ vcpsubmittals@deq.ok.gov 9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
ATTACHMENT 1 APPLICATION FOR EXEMPTION FROM NRC FEES SUPPORTING INFORMATION 9400 Ward Parkway
- Kansas City, MO 64114 Tel: 405-642-5152
- jlux@envpm.com
ATTACHMENT 1 Application for Exemption from Fees Pursuant to 10 CFR 170.12 Supporting Information The Formation of the Cimarron Environmental Response Trust The previous licensee, Cimarron Corporation, a subsidiary of Tronox Incorporated (Tronox),
notified the NRC that it had filed for relief under Chapter 11 of the U.S. Bankruptcy Code in a letter dated January 12, 2009.
Approximately two years later, on February 14, 2011, Tronox and its subsidiaries, numerous federal and state agencies, and the Navajo Nation executed a Consent Decree and Environmental Settlement Agreement (the Agreement). The Agreement created six Trusts, including the Cimarron Environmental Response Trust (the CERT). NRC License SNM-928 was transferred from Cimarron Corporation to the CERT.
For the remediation of the Cimarron Site, the Agreement established four accounts, initially funded by Tronox and subsequently by a settlement agreement with the Kerr-McGee Corporation and certain of its affiliates (New Kerr-McGee), and their parent Anadarko Petroleum Corporation, in a fraudulent conveyance case brought by the United States and co-plaintiff Anadarko Litigation Trust (the Trust) in the bankruptcy of Tronox Inc. and its subsidiaries (Tronox).
The NRC (on behalf of the United States) and the Oklahoma Department of Environmental Quality (DEQ) (on behalf of the State of Oklahoma) are the primary beneficiaries of the CERT.
The Agreement established the following three Trust accounts for which the NRC and the DEQ are both beneficiaries:
Cimarron Trust Administrative Account (Administrative Account)
Cimarron Trust Federal Environmental Cost Account (herein, State Account)
Cimarron Trust State Environmental Cost Account (herein, Federal Account)
A Letter of Credit held by the previous licensee was called in to create a Cimarron Standby Trust Fund, for which the NRC is the sole beneficiary.
Decommissioning/remediation costs are to be funded by the Federal Account and the State Account. Theoretically, State Account funds are to be used to achieve State criteria and Federal Account funds are to be used to achieve Federal criteria. Because reducing the concentration of uranium in groundwater represents progress toward achieving both Federal and State criteria, the NRC and the DEQ have agreed that both accounts will fund the decommissioning of the site.
The DEQ has agreed to defer remediation of other contaminants for now to preserve as much funding as possible to achieve termination of special nuclear materials license SNM-928.
The purpose for the Standby Trust Fund was not specifically defined, and EPM has included that account in the available funding for decommissioning.
Decommissioning Expenditures and the Impact of NRC Fee Recovery As of the end of 2022, the CERT costs have totaled over $27,000,000 for regulatory oversight fees, site characterization, remedial alternative evaluation, and preparation of decommissioning plans to achieve license termination. Specifically, NRC fees for that time period exceed
$6,200,000, or 23% of the total decommissioning costs. Exhibit A provides a tabulation of decommissioning costs and NRC fees from the time the CERT was created through the end of 2022.
Although EPM does not assume that NRC fees will continue to represent such a significant portion of decommissioning costs, projected NRC fees represent the greatest single factor that jeopardizes the likelihood of completing the decommissioning of the site.
Basis for Asserting that Decommissioning Could be Completed with NRC Fee Exemption or Deferral EPM submitted a decommissioning plan for the Cimarron site in November 2022. The decommissioning plan included a decommissioning cost estimate in accordance with NUREG-1757, Consolidated Decommissioning Guidance. EPM believes the decommissioning plan can be approved by the end of 2024 and construction can be completed by the end of 2025.
Calculation of the rate of decline of concentrations, based on groundwater flow models which have been reviewed by NRC personnel, provided the basis for a groundwater remediation schedule. Exhibit B presents four schedules from the decommissioning plan:
Figure 9-1, Pre-Construction Schedule Figure 9-2, Construction Schedule Figure 9-3, Remediation Schedule Figure 9-4, Post-Remediation Schedule Figure 9-3 shows that the license criteria for groundwater (the NRC Criterion) is projected to be achieved in the second quarter of 2038.
Exhibit C presents two tables based on Table 16-5 of the decommissioning plan, Cost Summary
- Rev 0. Both tables present the anticipated cost for pre-construction and construction activities, groundwater remediation, and post-remediation activities. The tables show the funds available when the decommissioning plan was submitted, the annual cost in 2022 dollars, and the anticipated depletion of available funds based on a 1% return on invested funds and a 3%
escalation rate.
The first table in Exhibit C, Decommissioning Cost Estimate Including NRC Fees shows that the impact of NRC fees results in the exhaustion of funds approximately two years before the NRC Criterion is achieved. The second table in Exhibit C, Decommissioning Cost Estimate Eliminating NRC Fees, shows that exemption from NRC fees indicates that funding may be sufficient to achieve the NRC Criterion.
EXHIBIT A NRC FEES AS A PERCENTAGE OF DECOMMISSIONING EXPENDITURES
CIMARRON ENVIRONMENTAL RESPONSE TRUST NRC FEES AS A PERCENTAGE OF DECOMMISSIONING EXPENDITURES Federal Account State Account Total Year NRC Fees % of Total Expenditures Expenditures Expenditures Expenditures 2011 $502,052 $30,845 $532,897 $190,071 35.7 2012 $655,531 $57,842 $713,373 $63,497 8.9 2013 $987,572 $86,190 $1,073,762 $1,781 0.2 2014 $1,186,605 $72,953 $1,259,558 $17,438 1.4 2015 $1,833,234 $191,027 $2,024,260 $173,131 8.6 2016 $1,550,242 $84,100 $1,634,342 $701,640 42.9 2017 $3,915,437 $251,299 $4,166,736 $2,565,927 61.6 2018 $5,306,841 $173,162 $5,480,003 $497,906 9.1 2019 $3,531,033 $209,350 $3,740,383 $777,280 20.8 2020 $2,581,705 $131,995 $2,713,700 $605,374 22.3 2021 $1,835,848 $82,759 $1,918,607 $339,903 17.7 2022 $1,660,489 $114,774 $1,775,262 $274,315 15.5 Cumulative $25,546,588 $1,486,296 $27,032,884 $6,208,261 23.0 Note: Beginning Q3 2012, the NRC did not charge the Trust for recovery of all fees.
In 2018, the NRC billed the Trust for $2,168,844.50 to recover fees not previously charged.
EXHIBIT B FROM FACILITY DECOMMISSIONING PLAN - REV 3 Figure 9-1, Pre-Construction Schedule Figure 9-2, Construction Schedule Figure 9-3, Remediation Schedule Figure 9-4, Post-Remediation Schedule
Figure 9-1 Revision 0 Preparer: E. Dulle; Date: 08/31/22 Pre-Construction Schedule Reviewer: J. Hesemann; Date: 08/31/22 ID Task Name Duration Start Finish Qtr 3, 2022 Qtr 4, 2022 Qtr 1, 2023 Qtr 2, 2023 Qtr 3, 2023 Qtr 4, 2023 Qtr 1, 2024 Qtr 2, 2024 Qtr 3, 2024 Qtr 4, 2024 Qtr 1, 2025 Qtr 2, 2 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr 1 Decom. Plan-Rev3 386 days Fri 9/30/22 Fri 3/22/24 2 EPM submits formal D-Plan 0 days Fri 9/30/22 Fri 9/30/22 9/30 3 NRC Accepts D-Plan for Technical 65 days Fri 9/30/22 Thu 12/29/22 Review 4 NRC Reviews D-Plan 86 days Fri 12/30/22 Fri 4/28/23 5 NRCs Issues RAIs 0 days Fri 4/28/23 Fri 4/28/23 4/28 6 EPM Prepares & Issues RAI 45 days Mon 5/1/23 Fri 6/30/23 Responses 7 NRC Drafts SER, EA, License 190 days Mon 7/3/23 Fri 3/22/24 Amendment 8 License Amendment 153 days Mon 3/25/24 Wed 10/23/24 9 NRC and EPM Reach Concurrence on 43 days Mon 3/25/24 Wed 5/22/24 Draft License Amendment 10 License Amendment Issued 110 days Thu 5/23/24 Wed 10/23/24 11 Design, Bidding, and Contracting 458 days Mon 5/1/23 Wed 1/29/25 12 Prepare remediation infrastructure 170 days Mon 5/1/23 Fri 12/22/23 and facilities bid packages 13 Bidders to prepare and submit bids 70 days Mon 12/25/23 Fri 3/29/24 14 Request and Obtain Construction 148 days Mon 4/1/24 Wed 10/23/24 Funding Approval 15 Execute Contracts 70 days Thu 10/24/24 Wed 1/29/25 16 Pre-Mobilization 14 days Thu 1/30/25 Tue 2/18/25 Page 1 of 1
Figure 9-2 Revision 0 Preparer: E. Dulle; Date: 08/31/22 Construction Schedule Reviewer: J. Hesemann; Date: 08/31/22 ID Task Name Duration Start 2026 2nd Quarter 3rd Quarter 4th Quarter 1st Quarter Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb 1 Remediation Well Field Infrastructure 132 days Tue 2/18/25 2 Mobilization and Site Preparation 35 days Tue 2/18/25 3 Equipment Mobilization 15 days Tue 2/18/25 4 BMPs, Road Installation, and Site Work 20 days Tue 3/11/25 5 Extraction and Injection Infrastructure 117 days Tue 3/11/25 6 Extraction Well Installation 15 days Tue 3/11/25 7 Extraction Trench Installation 43 days Tue 4/8/25 8 Injection Trench Installation 60 days Tue 4/8/25 9 Utilities and Outfall Installation 37 days Tue 7/1/25 10 1206 Drainage 15 days Fri 6/6/25 11 Facilities Infrastructure 132 days Tue 4/8/25 12 WATF Facility Infrastructure 132 days Tue 4/8/25 13 WATF Grading and Foundations 45 days Tue 4/8/25 14 Building Construction and Fit-out 87 days Tue 6/10/25 15 BA1 Facility Infrastructure 25 days Tue 6/10/25 16 BA1 Grading and Foundations 10 days Tue 6/10/25 17 Construction and Fit-out 15 days Tue 6/24/25 18 Startup and Commissioning 60 days Thu 10/9/25 19 Startup and Commissioning 30 days Thu 10/9/25 11/19 20 Weather Delays 30 days Thu 11/20/25 Page 1 of 1
Figure 9 Revision 0 Preparer: E. Dulle; Date: 09/16/22 Reviewer: J. Hesemann; Date: 09/23/22 Remediation Schedule Time 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 Remediation Area (Months) Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 BA1-A 150 Time to Reduce Uranium to < NRC Criterion BA1-B 62 Time to Reduce Uranium to < NRC Criterion Water Treatment 126 Time Uranium Treatment System Operates1 Water Pumping & Injection 150 Time Pumping & Injection Continues WAA U>DCGL 135 Time to Reduce Uranium to < NRC Criterion 1206 North 5 Time to Reduce Uranium to < NRC Criterion WU-BA3 48 Time to Reduce Uranium to < NRC Criterion Water Pumping & Treatment 135 Time Pumping & Uranium Treatment System Operates1 WU-BA3 Injection 48 Treated Water Injection Notes:
1 Either treatment system may be bypassed if the concentration of uranium in the influent is less than 30 µg/L.
Facility Decommissioning Plan - Rev 3 Page 1 of 1
Figure 9 Revision 0 Preparer: E. Dulle; Date: 09/29/22 Post-Remediation Schedule Reviewer: J. Hesemann; Date: 09/30/22 2038 2039 2040 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D PostRemediation Monitoring 1st Quarter Sample, Analyze, QReview nd 2 Quarter Sample, Analyze, QReview 3rd Quarter Sample, Analyze, QReview 4th Quarter Sample, Analyze, QReview 5th Quarter Sample, Analyze, QReview th 6 Quarter Sample, Analyze, QReview 7th Quarter Sample, Analyze, QReview 8th Quarter Sample, Analyze, QReview Dismantle & Dispose of Material Sample & Analyze Resin & Filter Media Demobilize/Ship Filter Systems P Dispose/Ship Resin Note: the "P" designates a month spent planning the D&D. P Demobilize/Ship Resin Processing System P Demobilize/Ship Ion Exchange Systems P Demobilize/Ship Pumps, Tanks, Etc.
Remove/Ship Wells, Piping, Utilities Final Status Survey Draft & Submit Final Status Survey Plan NRC Review Finalize Final Status Survey Plan Conduct Final Status Survey Prepare Final Status Survey Report NRC Review Finalize Final Status Survey Report License Termination Process Prepare Dose Model NRC Review Finalize Dose Model Apply for License Termination Terminate SNM928 Facility Decommissioning Plan Rev 3 Page 1 of 2
Figure 9 Revision 0 Preparer: E. Dulle; Date: 09/29/22 Post-Remediation Schedule Reviewer: J. Hesemann; Date: 09/30/22 2041 2042 2043 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J PostRemediation Monitoring st 1 Quarter Sample, Analyze, QReview nd 2 Quarter Sample, Analyze, QReview 3rd Quarter Sample, Analyze, QReview 4th Quarter Sample, Analyze, QReview 5th Quarter Sample, Analyze, QReview th 6 Quarter Sample, Analyze, QReview 7th Quarter Sample, Analyze, QReview 8th Quarter Sample, Analyze, QReview Dismantle & Dispose of Material Sample & Analyze Resin & Filter Media Demobilize/Ship Filter Systems Dispose/Ship Resin Demobilize/Ship Resin Processing System Demobilize/Ship Ion Exchange Systems Demobilize/Ship Pumps, Tanks, Etc. P Remove/Ship Wells, Piping, Utilities P Final Status Survey Draft & Submit Final Status Survey Plan NRC Review Finalize Final Status Survey Plan Conduct Final Status Survey Prepare Final Status Survey Report NRC Review Finalize Final Status Survey Report License Termination Process Prepare Dose Model NRC Review Finalize Dose Model Apply for License Termination Terminate SNM928 Facility Decommissioning Plan Rev 3 Page 2 of 2
EXHIBIT C DECOMMISSIONING COST ESTIMATE Decommissioning Cost Estimate Including NRC Fees Decommissioning Cost Estimate Eliminating NRC Fees
CIMARRON ENVIRONMENTAL RESPONSE TRUST DECOMMISSIONING COST ESTIMATE INCLUDING NRC FEES Table 165a Costs in 2022 Dollars Description 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 License Compliance $378,000 $765,000 $765,000 $730,000 $880,000 $850,000 $840,000 $840,000 $840,000 $840,000 $840,000 NRC Fees $400,000 $800,000 $800,000 $400,000 $400,000 $280,000 $240,000 $240,000 $240,000 $240,000 $240,000 Decomissioning $583,000 $2,446,000 $1,384,000 $24,038,750 $1,850,000 $1,785,000 $1,680,000 $1,680,000 $1,680,000 $1,680,000 $1,680,000 ODEQ Fees $15,000 $30,000 $30,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 Total Annual Cost $1,376,000 $4,041,000 $2,979,000 $25,204,750 $3,166,000 $2,951,000 $2,796,000 $2,796,000 $2,796,000 $2,796,000 $2,796,000 Table 165b 3% Annum Escalation Description Year > 1 2 3 4 5 6 7 8 9 10 License Compliance $378,000 $787,950 $811,589 $797,691 $990,448 $985,383 $1,003,004 $1,033,094 $1,064,087 $1,096,009 $1,128,890 NRC Fees $400,000 $824,000 $848,720 $437,091 $450,204 $324,597 $286,573 $295,170 $304,025 $313,146 $322,540 Decomissioning $583,000 $2,519,380 $1,468,286 $26,267,791 $2,082,191 $2,069,304 $2,006,008 $2,066,188 $2,128,174 $2,192,019 $2,257,780 ODEQ Fees $15,000 $30,900 $31,827 $39,338 $40,518 $41,734 $42,986 $44,275 $45,604 $46,972 $48,381 Total Annual Cost $1,376,000 $4,162,230 $3,160,421 $27,541,911 $3,563,361 $3,421,018 $3,338,570 $3,438,727 $3,541,889 $3,648,146 $3,757,590 Initial Available Funds (7/1/2022) $71,462,410 YearEnd Available Funds $70,443,722 $66,985,929 $64,495,367 $37,598,410 $34,411,033 $31,334,126 $28,308,897 $25,153,259 $21,862,902 $18,433,385 $14,860,129 Table 165a Costs in 2022 Dollars Description 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 License Compliance $840,000 $840,000 $840,000 $840,000 $840,000 $703,962 $567,924 $567,924 $467,924 $253,962 $126,981 NRC Fees $240,000 $240,000 $240,000 $240,000 $240,000 $220,000 $200,000 $200,000 $200,000 $200,000 $100,000 Decomissioning $1,680,000 $1,680,000 $1,680,000 $1,680,000 $1,180,000 $1,040,550 $241,100 $940,550 $1,380,000 $205,000 $115,000 ODEQ Fees $36,000 $36,000 $36,000 $36,000 $36,000 $33,000 $30,000 $30,000 $30,000 $30,000 $15,000 Total Annual Cost $2,796,000 $2,796,000 $2,796,000 $2,796,000 $2,296,000 $1,997,512 $1,039,024 $1,738,474 $2,077,924 $688,962 $356,981 Table 165b 3% Annum Escalation Description 11 12 13 14 15 16 17 18 19 20 21 License Compliance $1,162,756 $1,197,639 $1,233,568 $1,270,575 $1,308,693 $1,129,652 $938,692 $966,853 $820,508 $458,684 $236,222 NRC Fees $332,216 $342,183 $352,448 $363,022 $373,912 $353,035 $330,570 $340,487 $350,701 $361,222 $186,029 Decomissioning $2,325,513 $2,395,278 $2,467,137 $2,541,151 $1,838,402 $1,669,777 $398,502 $1,601,223 $2,419,838 $370,253 $213,934 ODEQ Fees $49,832 $51,327 $52,867 $54,453 $56,087 $52,955 $49,585 $51,073 $52,605 $54,183 $27,904 Total Annual Cost $3,870,318 $3,986,427 $4,106,020 $4,229,201 $3,577,093 $3,205,420 $1,717,348 $2,959,636 $3,643,652 $1,244,342 $664,090 Initial Available Funds (7/1/2022)
YearEnd Available Funds $11,138,412 $7,263,369 $3,229,983 ($966,919) ($4,553,681) ($7,804,638) ($9,600,033) ($12,655,669) ($16,425,878) ($17,834,479) ($18,676,913)
Notes:
$71,189,722 is the funding available in the Federal, State and Standby Trust Accounts as of 9/30/2022.
Table 165a was created by taking the costs from Tables 164 through 164 (adjusting the values for a portion of 2022).
For all tables, YearEnd Available Funds were calculated by adding 1% to the previous year's YearEnd Available Funds and subtracting the year's Total Annual Cost.
For Table 165b, the Total Annual Cost in 2022 dollars is escalated by 3% per annum by (1.03^n, where "n" is the number of years).
CIMARRON ENVIRONMENTAL RESPONSE TRUST DECOMMISSIONING COST ESTIMATE ELIMINATING NRC FEES Table 165a Costs in 2022 Dollars Description 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 License Compliance $378,000 $765,000 $765,000 $730,000 $880,000 $850,000 $840,000 $840,000 $840,000 $840,000 $840,000 NRC Fees $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Decomissioning $583,000 $2,446,000 $1,384,000 $24,038,750 $1,850,000 $1,785,000 $1,680,000 $1,680,000 $1,680,000 $1,680,000 $1,680,000 ODEQ Fees $15,000 $30,000 $30,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 $36,000 Total Annual Cost $1,376,000 $4,041,000 $2,979,000 $25,204,750 $3,166,000 $2,951,000 $2,796,000 $2,796,000 $2,796,000 $2,796,000 $2,796,000 Table 165b 3% Annum Escalation Description Year > 1 2 3 4 5 6 7 8 9 10 License Compliance $378,000 $787,950 $811,589 $797,691 $990,448 $985,383 $1,003,004 $1,033,094 $1,064,087 $1,096,009 $1,128,890 NRC Fees $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Decomissioning $583,000 $2,519,380 $1,468,286 $26,267,791 $2,082,191 $2,069,304 $2,006,008 $2,066,188 $2,128,174 $2,192,019 $2,257,780 ODEQ Fees $15,000 $30,900 $31,827 $39,338 $40,518 $41,734 $42,986 $44,275 $45,604 $46,972 $48,381 Total Annual Cost $976,000 $3,338,230 $2,311,701 $27,104,820 $3,113,157 $3,096,421 $3,051,998 $3,143,558 $3,237,864 $3,335,000 $3,435,050 Initial Available Funds (7/1/2022) $71,462,410 YearEnd Available Funds $70,843,722 $68,213,929 $66,584,367 $40,145,391 $37,433,688 $34,711,603 $32,006,722 $29,183,231 $26,237,199 $23,164,571 $19,961,167 Table 165a Costs in 2022 Dollars Description 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 License Compliance $840,000 $840,000 $840,000 $840,000 $840,000 $703,962 $567,924 $567,924 $467,924 $253,962 $126,981 NRC Fees $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Decomissioning $1,680,000 $1,680,000 $1,680,000 $1,680,000 $1,180,000 $1,040,550 $241,100 $940,550 $1,380,000 $205,000 $115,000 ODEQ Fees $36,000 $36,000 $36,000 $36,000 $36,000 $33,000 $30,000 $30,000 $30,000 $30,000 $15,000 Total Annual Cost $2,796,000 $2,796,000 $2,796,000 $2,796,000 $2,296,000 $1,997,512 $1,039,024 $1,738,474 $2,077,924 $688,962 $356,981 Table 165b 3% Annum Escalation Description 11 12 13 14 15 16 17 18 19 20 21 License Compliance $1,162,756 $1,197,639 $1,233,568 $1,270,575 $1,308,693 $1,129,652 $938,692 $966,853 $820,508 $458,684 $236,222 NRC Fees $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Decomissioning $2,325,513 $2,395,278 $2,467,137 $2,541,151 $1,838,402 $1,669,777 $398,502 $1,601,223 $2,419,838 $370,253 $213,934 ODEQ Fees $49,832 $51,327 $52,867 $54,453 $56,087 $52,955 $49,585 $51,073 $52,605 $54,183 $27,904 Total Annual Cost $3,538,102 $3,644,245 $3,753,572 $3,866,179 $3,203,181 $2,852,385 $1,386,779 $2,619,149 $3,292,951 $883,120 $478,060 Initial Available Funds (7/1/2022)
YearEnd Available Funds $16,622,676 $13,144,658 $9,522,533 $5,751,579 $2,605,914 ($220,412) ($1,609,395) ($4,244,638) ($7,580,036) ($8,538,956) ($9,102,406)
Notes:
$71,189,722 is the funding available in the Federal, State and Standby Trust Accounts as of 9/30/2023.
Table 165a was created by taking the costs from Tables 164 through 164 (adjusting the values for a portion of 2022).
For all tables, YearEnd Available Funds were calculated by adding 1% to the previous year's YearEnd Available Funds and subtracting the year's Total Annual Cost.
For Table 165b, the Total Annual Cost in 2022 dollars is escalated by 3% per annum by (1.03^n, where "n" is the number of years).