ML26085A231
| ML26085A231 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  (DPR-043) |
| Issue date: | 03/26/2026 |
| From: | Jeffery Lynch Kewaunee Solutions |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| KS-2026-007 | |
| Download: ML26085A231 (0) | |
Text
March 26, 2026 KS-2026-007 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Kewaunee Power Station Facility Operating License No. DPR-43 NRC Docket Nos. 50-305 and 72-64
Subject:
Decommissioning Trust Fund Annual Report for Kewaunee Power Station In accordance with 10 CFR 50.75(f)(1), and 10 CFR 50.82(a)(8)(v) - (vii), Kewaunee Solutions, Inc., (KS) is submitting the annual status of decommissioning funding, status of funding for managing irradiated fuel, and financial assurance report for Kewaunee Power Station (KPS) as of December 31, 2025. The report is provided in Enclosure 1 of this letter.
The estimates provided in Enclosure 1 using December 31, 2025, trust fund balances, indicate that KPS has met the NRCs funding requirements. Accordingly, KS concludes that no further action is currently required to demonstrate adequate funding assurance for decommissioning.
This letter contains no new regulatory commitments. If you have any questions with respect to the contents of this letter, please contact me at 508-728-1421 or jrlynch@energysolutions.com.
Respectfully, Joseph R. Lynch Regulatory Affairs Director (D&D)
EnergySolutions cc:
NRC Regional Administrator - Region III NRC Lead Inspector - Kewaunee Power Station NRC Project Manager - Kewaunee Power Station
- Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report as of December 31, 2025 Joseph R. Lynch Digitally signed by Joseph R. Lynch Date: 2026.03.26 09:48:12 -04'00' Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2025 Page 1 of 3 As required by 10 CFR 50.75(f), and 50.82(a)(8), Kewaunee Solutions, Inc. (KS) reports the following information for Kewaunee Power Station (KPS):
A. Formula Cost Amount per 10 CFR 50.75(c)
KS does not use the calculation in 10 CFR 50.75(c) for any decommissioning cost estimates or evaluations.
B. Current Decommissioning Cost Estimate The required minimum funding assurance amount for KPS, as of December 31, 2025, is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the Post-Shutdown Decommissioning Activities Report (PSDAR) Revision 3 (Reference 1).
Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides the KS revised total estimate information as required by 10 CFR 50.82. The revised total cost estimate to complete decommissioning for the KPS site is $1,211.6M as shown in Tables 1 and 2 and as described below. Of that total cost estimate, the revised estimate includes the following expenses:
- $918.6M for license termination (the cumulative decommissioning expenditures incurred as of December 31, 2025, in the amount of $477.4M and the remaining decommissioning estimated cost of $441.2M). The remaining decommissioning estimated cost of $441.2M was a product of inflation to 2026 dollars, supply chain impacts, procurement cost increases, and actual contract costs versus original estimates in the PSDAR.
- $257.8M for spent fuel management (the cumulative decommissioning expenditures incurred as of December 31, 2025, in the amount of $40.1M and the remaining decommissioning estimated cost of $217.7M). Spent fuel management costs do not reflect DOE reimbursements, which is a change from previous filings and explains in part the difference between PSDAR, Revision 3 (Reference 1) and this report.
- $35.2M for the decommissioning cost estimate for site restoration (the cumulative decommissioning expenditures incurred as of December 31, 2025, in the amount of $16.7M and the remaining decommissioning estimated cost of $18.5M)
C. Current Decommissioning Fund Balance The KPS Decommissioning Trust Fund (DTF) balance as of December 31, 2025, was
$653.2M. This amount represents the market value of the DTF fund, net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. The trust fund amount is the total available for decommissioning including costs of Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2025 Page 2 of 3 license termination, spent fuel management, and site restoration activities. Note that KS received exemptions from 10 CFR 50.82(a)(8)(i)(A) to allow the KPS DTF to be used for site irradiated fuel management and site restoration costs (References 2 and 3, respectively).
D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earnings on Funds, and Other Factors Used in Funding Projections KS has assumed a 2% real rate of return as allowed by 10 CFR 50.75(e)(1)(i).
E. Rates used to Inflate Decommissioning Costs The estimates in the 2025 KPS Revised PSDAR (Reference 1) were provided in 2025 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2026 dollars. The Bureau of Labor Statistics (BLS) data provided the basis for the decommissioning cost estimate inflation rate forecast. Decommissioning costs are inflated using a weighted average of BLS indices for Labor, Energy, Consumer Price Index, Materials, and Equipment. For burial inflation factor, KS utilized NUREG-1307, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities, Revision 20. KS has used a factor of 1.02125 to calculate the inflation to 2026 dollars.
F. Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $18.6M (2026 dollars). The ISFSI estimated costs are based on the estimated costs provided in Reference 1, inflated to 2026 dollars.
G. Decommissioning Financial Assurance Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1) as approved by NRC in their approval of the license transfer to KS.
H. Changes in the Decommissioning Funding Plan Trust Agreement There are no changes to the Decommissioning Funding Plan Trust Agreement.
Refer to Tables 1 and 2 of this Enclosure for additional required reporting data. Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by KS. This cash flow analysis demonstrates that the KPS decommissioning trust fund is sufficiently funded to cover costs as estimated for the license termination, Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2025 Page 3 of 3 spent fuel management and site restoration activities necessary to complete safe and compliant decommissioning of the site.
References
- 1. Letter KS-2025-019 from Joseph R. Lynch, EnergySolutions to Document Control Desk, USNRC, Notification of Amended Post-Shutdown Decommissioning Activities Report (Revision 3) for Kewaunee Power Station, dated October 21, 2025 (ML25294A209)
- 2. Letter from Christopher Gratton, USNRC, to David A. Heacock, Dominion Energy Kewaunee, Inc, Kewaunee Power Station - Exemptions from the Requirements of 10 CFR Part 50, Section 50.82(a)(8)(i)(A) and Section 50.75(h)(1)(iv) (TAC No. MF1438),
dated May 21, 2014 (ML13337A287)
- 3. Letter from Karl Sturzebecher, USNRC, to Amy C. Hazelhoff, EnergySolutions, Kewaunee Power Station - Exemption to Allow Use of Funds from the Nuclear Decommissioning Trust for Site Restoration and to Remove a Notification Requirement for the Disbursal of Funds from the Decommissioning Trust (EPID No. L-2023-LLE-0008), dated January 26, 2024 (ML23339A133)
Page 1 of 2
Page 2 of 2 Note: Summary of License Termination Cost Increases License Termination cost increases are driven by a combination of scope changes, higherthanplanned unit costs, and labor constraints. Escalation costs for 2025 were also materially higher than assumed, adding approximately $8-10M across multiple Work Breakdown Structure (WBS) elements.
Construction and demolition costs also exceeded estimates, particularly for the Phase 3A Auxiliary Building interior and Fuel Handling Building D&D, as well as Phase 3B containment interior demolition. Field execution challenges further increased costs from those previously estimated, including higher waste volumes than planned and the need to source experienced nuclear personnel due to labor availability constraints.
Laborrelated increases reflect both higher craft labor training and greater indirect oversight needs, driven by increased workforce concurrency and higher EnergySolutions field staffing (Supervision, Radiation Protection, Safety, QA, Construction Managers/Project Managers, Operations, and Maintenance). Finally, additional unplanned equipment costs were incurred due to selfperforming work that was not included in the original contract estimate.
Page 1 of 1 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) Net of Taxes on realized gains 2 2026 Beginning of Year NDT Balance is net of realized tax liabilities 3 Columns may not add due to rounding 4 Spent Fuel Management Costs do not reflect DOE reimbursements which is a change from previous filings