NLS2008106, Submittal of Program for Maintenance of Irradiated Fuel

Submittal of Program for Maintenance of Irradiated Fuel

ML083650343
Person / Time
Site:	Cooper
Issue date:	12/23/2008
From:	Vanderkamp D Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2008106
Download: ML083650343 (18)

Text

N Nebraska Public Power District "Always there when you need us" NLS2008106 December 23, 2008 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Program for Maintenance of Irradiated Fuel Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

1. Letter from Stewart B. Minahan (Nebraska Public Power District) to the U.S.

Nuclear Regulatory Commission dated September 24, 2008, "License Renewal Application" (NLS2008071)

2. Letter from David W. Van Der Kamp (Nebraska Public Power District) to the U.S. Nuclear Regulatory Commission dated December 15, 2008, "Decommissioning Cost Analysis" (NLS2008098)

Dear Sir or Madam:

The purpose of this correspondence is to submit the Nebraska Public Power District's (NPPD)

Program for Maintenance of Irradiated Fuel. The report provides NPPD's intentions to manage and provide funding for the management of all irradiated fuel until title to the irradiated fuel is transferred to the Secretary of Energy. This report is pursuant to the requirements of 10 CFR 50.54(bb), "Conditions of Licenses."

NPPD submitted a License Renewal Application for Cooper Nuclear Station (CNS) (Reference 1). Although NPPD is seeking license renewal, the subject report is submitted based on the current operating license expiration date of January 18, 2014.

In addition, it should be noted that NPPD submitted, in accordance with 10 CFR 50.75(f)(3), the Decommissioning Cost Analysis (Reference 2) for CNS.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 AD I Telephone: (402) 825-3871 / Fax: (402) 825-5211 www.nppd.com

NLS2008106 Page 2 of 2 Should you have any questions concerning this matter, please contact me at (402) 825-2904.

Sincerely, David W. Van Der Kamp Licensing Manager

/jo Attachment cc: Regional Administrator w/attachment USNRC - Region IV Cooper Project Manager w/attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/attachment USNRC - CNS NPG Distribution w/attachment CNS Records w/attachment

NLS2008106 Attachment Page 1 of 15 10 CFR 50.54(bb) Program for Maintenance of Irradiated Fuel

1. Background and Introduction The Nebraska Public Power District (the "District") has applied for renewal of the operating license for the Cooper Nuclear Station,[1] currently set to expire on January 18, 2014. It is expected that the Nuclear Regulatory Commission's staff would complete its review of the application within 30 months from receipt if a hearing is required or within 22 months from receipt if no hearing is required. As such, action on the request would be within the five year period prior to the expiration of the current license. Pursuant to 10 CFR 50.54(bb), licensees of nuclear power plants that are within five years of the expiration of the reactor operating license shall submit written notification to the Nuclear Regulatory Commission (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 fuel at the reactor following permanent cessation of operation of the reactor until title to the irradiated fuel and possession of the fuel is transferred to the U.S.

Department of Energy (DOE) for ultimate disposal.

Since the District has submitted an application for License Renewal pursuant to 10 CFR 54, the District requests that the NRC schedule the review of this information following a final decision on the License Renewal application.

The District is submitting this plan to comply with the requirements of 10 CFR 50.54(bb). The District has not determined or committed to a specific decommissioning approach for Cooper at this time. However, it is the District's current plan for purposes of demonstrating the adequacy of funding to meet regulatory requirements to use the SAFSTOR decommissioning option based on the current license expiration date, employing a SAFSTOR period as permitted in 10 CFR §50.82(a)(3) such that decommissioning is completed within 60 years of permanent cessation of operations.

License renewal is likely to require a need to revise this preliminary plan.

2. Spent Fuel Management Strategy Completion of the decommissioning process is. highly dependent upon the DOE's ability to remove spent fuel from the site in a timely manner. DOE's repository program assumes that spent fuel will be accepted for disposal from the nation's commercial nuclear plants, with limited exceptions,- in the order (the "queue") in which it was removed from service. The District's current spent fuel management plan is based in general upon: 1) a 2020 start date for repository operations and 2) the DOE's expectations for spent fuel receipt as delineated in the "Acceptance Priority Ranking &

Annual Capacity Report," DOE/RW-0567, last updated in July 2004. The District projects that fuel could be removed from the site as early as 2046, if the oldest fuel allocation receives the highest priority and the geologic repository is able to achieve the DOE's stated annual rate of transfer (3,000 metric tons of uranium per year).

NLS2008106 Attachment Page 2 of 15 The District has 1,054 spent fuel assemblies from Cooper in storage at General Electric's wet-pool Independent Spent Fuel Storage Installation (ISFSI) in Morris, Illinois. This analysis assumes that this inventory is preferentially transferred to the DOE, starting in 2022. The first assemblies removed from the Cooper site would then be in 2027. Interim storage of the spent fuel, until the DOE has completed the transfer, will be in the reactor building's storage pool and/or at an ISFSI located on the Cooper site.

The NRC requires (in 10 CFR 50.54(bb)) that licensees establish a program to manage and provide funding for the caretaking of all irradiated fuel at the reactor site until title of the fuel is transferred to the DOE. An ISFSI, which can be operated under a separate and independent license, is being constructed to support continued plant operations and future decommissioning. The facility is designed to accommodate the dry storage modules needed to off-load the wet storage pool at the end of currently scheduled plant operations so that decommissioning activities can proceed. Once the pool is emptied, the reactor building can be either decontaminated and dismantled or prepared for long-term storage.

Cooper is projected to generate 4,098 assemblies through the end of its currently licensed operations in 2014. Included within this total are the 1,054 assemblies in storage at Morris. The assemblies stored in the reactor building's spent fuel storage pool at the time of shutdown are assumed to be loaded into Multi-Purpose Canisters (MPCs) and moved into the concrete storage modules on the ISFSI pad by 2019.

Starting in 2022, the spent fuel is off-loaded from the Morris facility and transported to a DOE facility. This process is expected to be completed by 2027 at which time the fuel in storage in the Cooper ISFSI is off-loaded. The MPCs are assumed to be compatible with the DOE transport cask with no additional packaging or repackaging required. Based upon current projections, all fuel is expected to be removed from the Cooper site by the year 2046. The District's analysis conservatively assumes, for purposes only of this report, that it does not employ the DOE spent fuel disposal contract's allowances for up to 20% additional fuel designation for shipment to DOE each year. [2]

In the event that Cooper does cease operations in 2014, the District will continue to comply with existing NRC licensing requirements, including the operation and maintenance of the systems and structures needed to support continued operation of the spent fuel pool and ISFSI, as necessary, under the decommissioning scenario ultimately selected. In addition, the District will also comply with applicable license termination requirements in accordance with 10 CFR 50.82 with respect to plant shutdown and post-shutdown activities including seeking such NRC approvals and on such schedules as necessary to satisfy these requirements consistent with the continued storage of irradiated fuel.

NLS2008106 Attachment Page 3 of 15

3. Cost Considerations The costs estimated to decommission Cooper under various scenarios are identified in the "Decommissioning Cost Analysis."' 3ý The spent fuel management plan presented herein is based upon Scenario 3 in the referenced document. In this scenario, the nuclear unit is placed into safe-storage at the expiration of its current operating license in 2014.

Decommissioning is deferred such that termination of the license would occur within the required sixty-year period. Decommissioning costs for this scenario are allocated into the three major categories of license termination, spent fuel management, and site restoration.

The allocations are reproduced in Table 1. Costs are reported in 2008 nominal dollars.

The timing of the spent fuel management expenditures ($195.398 million) is shown in Table 2. The expenditures include direct costs (e.g., for handling, packaging, storing and transferring the spent fuel) as well as indirect cost such as program management and oversight, security, pool and ISFSI operating costs, fees, insurance, etc., projected to be incurred over the post-operations storage period.

The significant contributors to the direct cost of managing the spent fuel at the Cooper site are identified in Table 3. As shown, costs are included for the procurement of multi-purpose storage canisters as well as the loading and transfer costs associated with relocating the spent fuel from the pool to the ISFSI pad and the eventual transfer of the fuel at the ISFSI to the DOE. The direct cost of $66.619 million is a subset of the

$195.398 million shown in Tables 1 and 2.

It must also be noted that these figures will vary based on actual DOE performance, including the actual cask provisions and requirements that DOE settles upon. At this time, DOE has not identified any transport casks or requirements. Therefore, there is considerable uncertainty as to the actual costs that may have to be incurred; and uncertainty as to whether the DOE will agree to bear certain of those costs. Major scheduling milestones are identified in Table 4.

At shutdown, the Cooper spent fuel pool is expected to contain freshly discharged assemblies from the most recent refueling cycles. Over the next five years the assemblies are packaged into MPCs for transfer to the ISFSI. It is assumed that this time period is sufficient to meet the decay heat requirements for dry storage.

The decommissioning scenario assumes that the existing ISFSI can accommodate the spent fuel remaining in the reactor building's storage pool at shutdown. To support decommissioning operations, the District anticipates loading 34 MPCs with the assemblies stored in the spent fuel pool. The MPCs will then be placed in storage modules on the ISFSI along with the 16 projected to be placed prior to shutdown.

In the absence of identifiable DOE cask requirements, the design and capacity of the MPCs is based upon a commercial dry cask storage system (the Transnuclear NUHOMS system). The NUHOMS multi-purpose canister has a capacity of 61 fuel assemblies at a

NLS2008106 Attachment Page 4 of 15 unit cost of approximately $900,000, including the cost of the concrete storage module. It should be noted that the District's contract with the DOE requires DOE to provide shipping containers to the District, but for present purposes, this estimate includes those costs.

An average unit cost of $500,000 was estimated for the labor and equipment to load, seal, and transfer each MPC from the storage pool to the ISFSI. A unit cost of $250,000 was estimated for the final transfer of the MPC at the ISFSI into a DOE transport cask (50%

of the cost incurred for transferring the spent fuel from the pool). This cost was also used for estimating the cost to unload the spent fuel from the Morris pool.

Operation of the reactor building's spent fuel storage pool is discontinued in 2019 once the fuel has been transferred~to dry storage. ISFSI operations continue until such time that the DOE is able to complete the transfer of the fuel to a federal repository (currently anticipated to be in 2046).

4. ISFSI Decommissioning With the spent fuel removed from the site, the ISFSI is available for decommissioning. It is assumed that once the MPCs containing the spent fuel assemblies have been removed, any required decontamination performed on the storage modules and the license for the facility terminated, the modules can be dismantled using conventional techniques for the demolition of reinforced concrete. The concrete storage pad can then be removed and the area regraded. The cost to decontaminate the ISFSI to the extent necessary to release the facilities for conventional demolition is estimated at $2.29 million. Conventional demolition of the remaining overpacks and pads and restoration of the affected area of the site is estimated at $0.611 million.

5. Financial Assurance The District is a public corporation and political subdivision of the state of Nebraska. The District has the authority and is required to fix, establish, and collect adequate rates and other charges for electrical energy and any and all commodities or services sold or furnished by it. The District is accordingly authorized to establish its own rates and other charges through which it can recover its cost of service. The District is governed by an 11-member Board of Directors who are popularly elected from the District's chartered territory. The Board of Directors is the rate making authority for the District.

The District's financial statements indicate an external trust balance of $403.437 million as of December 31, 2007.J'4 In addition, the District will file its NRC Decommissioning funding status report in March 2009, in accordance with 10 CFR 50.75(f)(1).

As shown in Reference 3, the cost to decommission Cooper is estimated at approximately

$907.708 million (in 2008 dollars). The estimate is based upon a scenario under which the plant would be placed into safe-storage for a period such that decommissioning is

NLS2008106 Attachment Page 5 of 15 completed no later than 60 years after cessation of permanent operations. Approximately 74% of the total or $674.964 million is estimated to be required for radiological decommissioning necessary to terminate the operating license and 22% of the total or

$195.398 million to manage the spent fuel until such time that it can be transferred to the DOE (the remaining 4% is associated with site restoration activities; the costs for which are excluded from the financial assurance calculation which addresses only NRC decommissioning and spent fuel-management obligations).

The decommissioning funding plan is shown in Table 5. It uses a 2.5% real growth, as authorized by Board of Directors of the District, [5] in the trust fund over time to demonstrate that the identified scenario is financially viable (i.e., that a surplus is shown in the fund at the completion of decommissioning). Although the decommissioning trust fund is for radiological decommissioning cost only, to the extent that the trust fund balance exceeds costs required for radiological decommissioning, these funds would be available to address costs incurred by the licensee including spent fuel management costs.

It should be noted that the projected expenditures for spent fuel management identified in the decommissioning cost analysis do not consider the outcome of the litigation (including compensation for damages) with the DOE with regards to the delays incurred by the District in the timely removal of the spent fuel from the site. The District views the extended spent fuel management costs to be damages that should be paid by the government because of the DOE's breach of the spent fuel disposal contract.

In the event that the expected surplus funds from the decommissioning trust are insufficient to provide for fuel management costs and subject to application of funds realized from any spent fuel litigation settlement realized from the DOE; the District, would use other remaining reserve funds derived from the ownership and prior operation of Cooper Nuclear Station or utilize additional borrowings of the District to pay for any possible funding shortfalls to fulfill this obligation.

6. NRC Approvals This spent fuel management plan assumes withdrawals from the decommissioning trust for spent fuel management purposes. The District will make appropriate submittals for an exemption in accordance with 10 CFR §50.12 from the requirements of 10 CFR

§50.82(a)(8)(i)(A) in order to use the decommissioning trust fund(s) for spent fuel management expenses. In the event of a permanent plant shutdown on January 18, 2014, the District will revalidate the status of the Decommissioning Trust to make certain that sufficient funds exist for decommissioning as required under 10 CFR 50.75. If deemed sufficient, the District will then periodically revisit the spent fuel management plan to ensure that withdrawals for spent fuel management do not inhibit the ability of the licensee to complete radiological decommissioning.

NLS2008106 Attachment Page 6 of 15

7. References

1. "License Renewal Application," Cooper Nuclear Station, NRC Docket 50-298, DPR-46, NLS2008071, September 24, 2008

2. "Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste,"

Contract No. BE-CRO1-83NE44397, dated June 24, 1983

3. "Decommissioning Cost Analysis for the Cooper Nuclear Station," Document No.

NO1-1590-002, Rev.1, TLG Services, Inc., December 2008

4. U.S. Bank Statement, Nebraska Public Power District Decommissioning Account, Market and Cost Reconciliation, Balance for Period Ending December 31, 2007

5. "Resolution of Nebraska Public Power District," No. 08-70, adopted June 13, 2008

NLS2008106 Attachment Page 7 of 15 TABLE 1 Cooper Nuclear Station Summary of Major Cost Contributors (Thousands, 2008 dollars)

License Spent Fuel Site Termination Management Restoration Total Decontamination 18,399 0 0 18,399 Removal 57,353 1,380 16,613 75,346 Packaging 9,572 4 0 9,577 Transportation 6,319 27 0 6,346 Waste Disposal 44,192 68 0 44,260 Off-site Waste Processing 42,743 0 0 42,743 Program Management [1 383,951 85,578 20,525 490,053 Corporate A&G 10,100 0 0 10,100 Spent Fuel Management [2] 0 69,839 0 69,839 Insurance and Regulatory Fees 44,974 31,941 0 76,914 Energy 12,022 427 192 12,641 Characterization and Licensing Surveys 16,568 0 0 16,568 Miscellaneous Equipment 28,770 6,136 17 34,923 Total [3] 674,964 195,398 37,347 907,708

[ll Includes security and engineering

[21 Does not include costs spent to date and through the remaining years of operation

[31 May not add due to rounding

NLS2008 106 Attachment Page 8 of 15 TABLE 2 Cooper Nuclear Station Schedule of Annual Expenditures Spent Fuel Management Allocation (Thousands, 2008 dollars)

Equip & Yearly Year Labor Materials Energy Burial -Other Totals 2014 2,833 8,499 0 0 2,153 13,485 2015 5,289 5,644 49 0 2,122 13,104 2016 9,375 *5,718 107 0 1,965 17,165 2017 9,349 5,703 107 0 1,960 17,118 2018 9,349 5,703 107 0 1,960 17,118 2019 6,087 3,353 58 0 1,540 11,038 2020 2,225 570 .0 0 1,046 3,840 2021 2,219 568 0 0 1,043 3,830 2022 2,219 568 0 0 1,043 3,830 2023 2,219 568 0 0 1,043 3,830 2024 2,225 570 0 0 1,046 3,840 2025 2,219 568 0 0 1,043 3,830 2026 2, 219 568 0 0 1,043 3,830 2027 2,219 568 0 0 1,043 3,830 2028 2,225 570 0 0 1,046 3,840 2029 2,219 568 0 0 1,043 3,830 2030 2,219 568 0 0 1,043 3,830 2031 2,219 568 0 0 1,043 3,830 2032 2,225 570 0 0 1,046 3,840 2033 2,219 568 0 0 1,043 3,830 2034 2,219 568 0 0 1,043 3,830 2035 2,219 568 0 0 1,043 3,830 2036 2,225 570 0 0 1,046 3,840 2037 2,219 568 0 0 1,043 3,830 2038 2,219 568 0 0 1,043 3,830 2039 2,219 568 0 0 1,043 3,830 2040 2,225 570 0 0 1,046 3,840 2041 2,219 568 0 0 1,043 3,830 2042 2,219 568 0 0 1,043 3,830 2043 2,219 568 0 0 1,043 3,830 2044 2,225 570 0 0 1,046 3,840

NLS2008 106 Attachment Page 9 of 15 TABLE 2 (continued)

Cooper Nuclear Station Schedule of Annual Expenditures Spent Fuel Management Allocation (Thousands, 2008 dollars)

Equip & Yearly Year Labor Materials EnryBurial Other Totals 2045 2,219 568 0 0 1,043 3,830 2046 2,213 566 0 0 1,040 3,819 2047 0 0 0 0 0 0 2048 0 0 0 0 0 0 2049 0 0 0 0 0 0 2050 0 0 0 0 0 0 2051 0 0 0 0 0 0 2052 0 0 0 0 0 0 2053 0 0 0 0 0. 0 2054 0 0 0 0 0 0 2055 0 0 0 0 0 0 2056 0 0 0 0 0 0 2057 0 0 0 0 0 0 2058 0 0 0 0 0 0 2059 0 0 0 0 0 0 2060 0 0 0 0 0 0 2061 0 0 0 0 0 0 2062 0 0 0 0 0 0 2063 0 0 0 0 0 0 2064 0 0 0 0 0 0 2065 0 0 0 0 0 0 2066 0 0 0 0 0 0 2067 0 0 0 0 0 0 2068 0 0 0 0 0 0 2069 0 0 0 0 0 0 2070 43 7 0 4 85 138 2071 293 44 0 28 571 936 2072 294 44 0 28 573 939 2073 87 13 0 18, 169 277 2074 91 206 0 101 27 324

NLS2008106 Attachment Page 10 of 15 TABLE 2 (continued)

Cooper Nuclear Station Schedule of Annual Expenditures Spent Fuel Management Allocation (Thousands, 2008 dollars)

Equip & Yearly Year Labor Materials Energy Burial Other Totals 2075 81 183 0 0 24 287 Total 103,120 50,461 427 68 41,322 195,398

NLS2008106 Attachment Page 11 of 15 TABLE 3 Cooper Nuclear Station Significant Cost Contributors Spent Fuel Management - Direct Expenditures (2008 dollars)*

Morris to DOE Loading and Transfer 6,072,000 Capital Costs of ISFSI MPCs and Storage Modules 30,693,500 MPC Loading and Transfer to the ISFSI 17,204,000 MPC Transfer from ISFSI to DOE 12,650,000 Total 66,619,500

• Contingency has been added to all costs (15%)

NLS2008106 Attachment Page 12 of 15 TABLE 4 Cooper Nuclear Station Projected Schedule and Milestones Major Milestones and Fuel-Related Events Currently scheduled cessation of plant operations January 2014 ISFSI available Pre-shutdown First MPC transferred post-shutdown from pool to ISFSI 2014 Last MPC transferred post-shutdown from pool to ISFSI 2019 End of wet storage pool operations 2019 DOE begins to receive commercial spent fuel 2020 1 st fuel assembly removed from Cooper ISFSI LJ 2027 Last fuel assembly leaves Cooper ISFSI 2046 ISFSI decommissioned [2J 2070 - 2073 ISFSI demolition [3J 2074 - 2075

ý13 Assemblies stored at Morris are shipped first, beginning in 2022

[2] ISFSI decontaminated during this time period, in conjunction with the contaminated power block structures

[3] ISFSI demolished during this time period along with the other structures on site

NLS2008 106 Attachment Page 13 of 15 TABLE 5 Cooper Nuclear Station Decommissioning Funding Plan Scenario 3: 2014 Shutdown, SAFSTOR Alternative (Thousands of dollars)

Basis Year 2008 Beginning Fund Balance $403 .437 Annual Escalation 0.00%

Annual Earig 2.50% _____

A B C D E 50.75 Decommissioning License 50.54(bb) Total Cost Trust Fund Termination Spent Fuel Escalated Escalated at 2.5%

Cost Management Total Cost at 0% (minus expenses)

Year (millions) Cost (millions) (millions) -(millions) (millions) 2007 403.437 2008 413.523 2009 ______423.861 2010 434.457 2011 ______445.319 2012 456.452 2013 467.863 2014 43.626 13.485 57.111 57.111 422.449 2015 50.453 13.104 63.557 63.557 369.453 2016 5.399 1715 22.564 22.564 356.125 2017 5.385 17.118 22.503 22.503 342.526 2018 5.385 17.118 22.503 22.503 328.586 2019 4.830 11.038 15.869 15.869 320.932 2020 4.185 3.840 8.025 8.025 320.930 2021 4.174 3.830 8.003 8.003 320.950 2022 4.174 3.830 8.003 8.003 320.970 2023 4.174 3.830 8.003 8.003 320.991 2024 4.185 3.840 8.025 8.025 320.991 2025 4.174 3.830 8.003 8.003 321.012 2026 4.174 3.830 8.003 8.003 321.034 2027 4.174 3.830 8.003 8.003 321 .056 2028 4.185 3.840 8.025 8.025 321.057 2029 4.174 3.830 8.003 8.003 321.080 2030 4.174 3.830 8.003 8.003 321.104 2031 4.174 3.830 8.003 8.003 321.128 12032 1 4.185 3.840 1 8.025 1 8.025 1321.131

NLS2008106 Attachment Page 14 of 15 TABLE 5 (continued)

Cooper Nuclear Station Decommissioning Funding Plan Scenario 3: 2014 Shutdown, SAFSTOR Alternative (Thousands of dollars)

Basis Year 2008 Beginning Fund Balance $403.437 Annual Escalation 0.00%

Annual Earnings 2.50%

A B C D E 50.75 Decommissioning License 50.54(bb) Total Cost Trust Fund Termination Spent Fuel Escalated Escalated at 2.5%

Cost Management Total Cost at 0% (minus expenses)

Year (millions) Cost (millions) (millions) (millions) (millions) 2033 4.174 3.830 8.003 8.003 321.156 2034 4.174 3.830 8.003 8.003 321.181 2035 4.174 3.830 8.003 8.003 321.207 2036 4.185 3.840 8.025 8.025 321.212 2037 4.174 3.830 8.003 8.003 321.239 2038 4.174 3.830 8.003 8.003 321.267 2039 4.174 3.830 8.003 8.003 321.295 2040 4.185 3.840 8.025 8.025 321.302 2041 4.174 3.830 8.003 8.003 321.331 2042 4.174 3.830 8.003 8.003 321.361 2043 4.174 3.830 8.003 8.003 321.392 2044 4.185 3.840 8.025 8.025 321.401 2045 4.174 3.830 8.003 8.003 321.433 2046 4.173 3.819 7.993 7.993 321.476 2047 4.146 0.000 4.146 4.146 325.367 2048 4.157 0.000 4.157 4.157 329.344 2049 4.146 0.000 4.146 4.146 333.431 2050 4.146 0.000 4.146 4.146 337.621 2051 4.146 0.000 4.146 4.146 341.916 2052 4.157 0.000 4.157 4.157 346.307 2053 4.146 0.000 4.146 4.146 350.819 2054 4.146 0.000 4.146 4.146 355.443 2055 4.146 0.000 4.146 4.146 360.184 2056 4.157 0.000 4.157 4.157 365.031 2057 4.146 0.000 4.146 4.146 370.011 2058 4.146 0.000 4.146 4.146 375.115

NLS2008106 Attachment Page 15 of 15 TABLE 5 (continued)

Cooper Nuclear Station Decommissioning Funding Plan Scenario 3: 2014 Shutdown, SAFSTOR Alternative (Thousands of dollars)

Basis Year 2008 Beginning Fund Balance $403.437 Annual Escalation 0.00%

Annual Earnings 2.50%

A B C D E 50.75 Decommissioning License 50.54(bb) Total Cost Trust Fund Termination Spent Fuel Escalated Escalated at 2.5%

Cost Management Total Cost at 0% (minus expenses)

Year (millions) Cost (millions) (millions) (millions) millions) 2059 4.146 0.000 4.146 4.146 380.347 2060 4.157 0.000 4.157 4.157 385.699 2061 4.146 0.000 4.146 4.146 391.195 2062 4.146 0.000 4.146 4.146 396.830 2063 4.146 0.000 4.146 4.146 402.604 2064 4.157 0.000 4.157 4.157 408.512 2065 4.146 0.000 4.146 4.146 414.579 2066 4.146 0.000 4.146 4.146 420.798 2067 4.146 0.000. 4.146 4.146 427.172 2068 27.415 0.000 27.415 27.415 410.436 2069 63.494 0.000 63.494 63.494 357.203 2070 100.380 0.138 100.518 100.518 265.615 2071 63.571 0.936 64.507 64.507 207.748 2072 63.745 0.939 64.683 64.683 148.259 2073 39.826 0.277 40.103 40.103 111.862 2074 1.485 0.324 1.809 1.809 112.850 2075 0.084 0.287 0.372 0.372 115.299 674.963 195.398 870.362 870.362 Calculations:

Column C = A + B Column D = (C)*(l+.00)A(current year - 2008)

Column E = Column E = (Previous year's fund balance) * (1 + .025) - D (current year's decommissioning expenditures)

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@

Correspondence Number: NLS2008106 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None 4 +

4 +

4 +

-t *1-4 +

PROCEDURE 0.42 REVISION 22 PAGE 18 OF 25