View source for LIC-17-0031, Irradiated Fuel Management Plan

{{Adams
| number = ML17093A594
| issue date = 03/31/2017
| title = Irradiated Fuel Management Plan
| author name = Fisher M
| author affiliation = Omaha Public Power District
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000285, 07200054
| license number = DPR-040
| contact person = 
| case reference number = LIC-17-0031
| document type = Letter type:LIC
| page count = 13
}}

=Text=
{{#Wiki_filter:10 CFR 50.82(a)(4) 10 CFR 50.54(bb)
LIC-17-0031 March 31, 2017 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Fort Calhoun Station, Unit No. 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:==
Fort Calhoun Station Irradiated Fuel Management Plan

==References:==
: 1.      Letter from OPPD (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067) (ML16242A127)
: 2.       Letter from OPPD (M. J. Fisher) to USNRC (Document Control Desk}, "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report,"
dated March 30, 2017 (LIC-17-0033)
On August 25, 2016, Omaha Public Power District (OPPD) submitted Reference 1 to the U.S.
Nuclear Regulatory Commission (NRC) certifying permanent cessation of operations at the Fort Calhoun Station (FCS). In accordance with 10 CFR 50.54(bb) and 10 CFR 50.82(a)(4)(i), OPPD is required to submit an Irradiated Fuel Management Plan (IFMP), Site Specific Decommissioning Cost Estimate (DCE), and Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of permanent cessation of operations.
The FCS IFMP is attached. The DCE and PSDAR were submitted on March 30, 2017 (Reference 2). The IFMP represents OPPD's current plans and is subject to change as the project progresses. In particular, the Independent Spent Fuel Storage Installation vendor(s) have not been selected. The decision making and procurement activities are underway but have not been finalized.
444 South 161h Street Mall Omaha, NE 68102-2247
                                                                        -  *f    I          *    - *--=--

U.S. Nuclear Regulatory Commission LIC-17-0031 Page 2 Any changes to significant details wiH be included in subsequent revisions to the IFMP as required by 10 CFR 50.54(bb ). Financial assurance information will be provided on an annual basis as required by 10 CFR 50. 75(f)( 1).
There are no regulatory commitments contained within this letter.
If you should have further questions, please contact Mr. Bradley H. Blome, Director Licensing &
Regulatory Assurance, at 402-533-7270.
Mary J. Fisher Senior Director - FCS Decommissioning MJF/TJH/epm

==Enclosure:==
Fort Calhoun Station Irradiated Fuel Management Plan c:     K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

Enclosure LIC-17-0031 Page 1 of 11 Fort Calhoun Station Irradiated Fuel Management Plan I. Background and Introduction On August 25, 2016, Omaha Public Power District (OPPD) submitted a letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference 1) certifying the permanent cessation of operations at the Fort Calhoun Station (FCS) effective October 24, 2016, in accordance with 10 CFR 50.82(a)(1 )(i). All fuel was removed from the FCS reactor vessel and placed in the spent fuel pool as certified in accordance with 10 CFR 50.82(a)(1)(ii) (Reference 2).
Pursuant to 10 CFR 50.54(bb), licensees are required to submit a plan for the management of irradiated fuel until title and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. The Irradiated Fuel Management Plan (IFMP) is required to be submitted to the Commission either five years before expiration of the Operating License or within two years following permanent cessation of operations, whichever occurs first. Therefore, the FCS IFMP is required to be submitted prior to October 24, 2018, two years following cessation of operations.
Post-Shutdown Decommissioning Activities Report (PSDAR) and Decommissioning Cost Estimate (DCE) have been prepared and submitted (Reference 3). The DCE identifies the details, schedules, and costs of spent fuel management activities associated with the IFMP, along with license termination and site restoration activities and costs. The assumptions regarding the United States Department of Energy (US DOE) acceptance of irradiated fuel are consistent with the DCE. The FCS DCE and this IFMP are based on commencement of industry-wide acceptance of spent fuel by US DOE in 2030.
II. Irradiated Fuel Management Strategy The safe initial interim storage of FCS irradiated fuel will be a combination of "wet storage" in the FCS spent fuel pool and "dry storage" in the FCS Independent Spent Fuel Storage Installation (ISFSI). While spent fuel is stored in the spent fuel pool, spent fuel storage and handling systems will be maintained in operation. Following transfer of all spent fuel from the spent fuel pool to the FCS ISFSI, spent fuel storage and handling systems will be removed from operation.
A total of 1,264 irradiated fuel assemblies have been generated at FCS. At present, 320 irradiated fuel assemblies have already been transferred to the FCS ISFSI. The remaining 944 irradiated fuel assemblies will be loaded in dry fuel canisters and transferred to the ISFSI.
The current ISFSI is located inside the Owner Controlled Area. It was designed and constructed to accommodate all FCS irradiated fuel. The ISFSI currently contains 10 dry fuel canisters storing FCS fuel. All of the fuel on the ISFSI is stored in Trans nuclear NUHOMS Model Number-32PT Dry Shielded Canisters.
The major IFMP activity phases, including start dates, end dates and associated costs for each period are identified in Table 1. The identified Decommissioning Periods are developed in and align with the site-specific DCE.

Enclosure LIC-17-0031 Page 2 of 11 The current plan is to commence the movement of the irradiated fuel from the FCS spent fuel pool to the FCS ISFSI in 2021. OPPD expects to complete the transfer in 2022. Additional dry fuel canisters will be procured from one or more of the available dry storage system suppliers beginning in 2018. It is anticipated that an additional30 dry fuel canisters will be required for the remaining FCS irradiated fuel (dependent on the capacity of the selected system).
The US DOE Standard Contracts for acceptance and disposal of nuclear fuel and high level waste contain the basis for initial ranking of industry-wide spent fuel acceptance obligations based upon the date of permanent removal of the spent nuclear fuel from service ("oldest fuel first" allocation). Those Standard Contracts also contain provisions allowing for "exchanges" of acceptance obligations, and priority for retired units. Given the US DOE's lack of a performance plan, a common assumption for purposes of this fuel management plan is to base acceptance projections upon application of an "oldest fuel first" allocation scheme to a projected start date for repository operations. This plan is based upon a 2030 start date for US DOE acceptance of spent fuel from the industry and the FCS position in the queue. As indicated in Table 2, OPPD is therefore assuming all spent fuel will be removed from the FCS site as of 2058. Based on this information, the ISFSI will be subsequently decommissioned by the 2065 final license termination date.
Ill. Financial Assurance The site-specific decommissioning cost analysis prepared by TLG Services, Inc. projects the total cost of Spent Fuel Management activities to be $405.5 million in 2016 dollars as shown in Table 3. The FCS DCE contains an estimate of the costs of license termination, spent fuel management, and site restoration. Tables 3.2a, 3.2b, and 3.2c in the DCE delineate the annual expenditures for license termination, spent fuel management, and site restoration respectively.
This annual expenditure information is used in the cash flow analysis. The purpose of the cash flow analysis (Table 4) is to demonstrate that the balance in the FCS Decommissioning Trust Fund (DTF) is sufficient to cover license termination expenses.
Under NRC regulations (1 0 CFR 50.82(a)(8)), a licensee must provide reasonable assurance that funds will be available (or "financial assurance") for decommissioning (i.e., license termination) costs. The regulations also describe the acceptable methods a licensee can use to demonstrate financial assurance. Most licensees do this by funding a nuclear decommissioning trust (NDT). Nebraska State Statues provides the regulatory authority that allows OPPD's Board of Directors to establish the inflation rates and earning rates of OPPD.
OPPD maintains two separate trust accounts for this purpose, one for the License Termination Expenditures (NRC minimum decommissioning amount) and another for the Spent Fuel Management and Site Restoration Expenditures. As of December 31, 2016, the License Termination Expenditures trust had a balance of $285,838,000 and the Spent Fuel Management and Site Restoration Expenditures trust had a balance of $96,296,000.
The two trust funds are not commingled and the funds accumulated for the additional decommissioning cost are not included as funds for the NRC minimum decommissioning amount. The funds accumulated for the additional decommissioning costs including additional radiological, site restoration and spent fuel management are available for radiological decommissioning without prior approval by a State regulatory authority and are not subject to disapproval for radiological decommissioning by a State regulatory authority.

Enclosure LIC-17-0031 Page 3 of 11 Costs are inflated using a blending of the IHS Global Insight's forecasts for Consumer Price Index, All-Urban and Employment Cost Index, Total Private Compensation. The indices are blended based on the ratio of labor and all other costs to the total DCE. For the years beyond the available forecast, the final forecast rate available is held constant for the duration of the analysis.
Consistent with Regulatory Guide 1.159, OPPD will update the FCS DCE as required. In calculating projected earnings, OPPD uses the IHS Global Insight's forecast for the yield on 5-year Treasury Notes which is within a two percent (2%) annual real rate of return. The rates used for the escalation of the site-specific decommissioning cost estimate and earnings rates on the Decommissioning Fund through the completion of decommissioning are shown in Table 5.
OPPD intends to fund the cost of decommissioning (license termination, spent fuel management and site restoration) out of existing operations until the DTF is funded in the 2022 timeframe, as currently forecasted. When the remaining cost of decommissioning matches the funding in the DTF then OPPD will withdraw any decommissioning expenses from the DTF.
In the event that additional financial assurance beyond the amounts contained in the remaining trust fund for FCS is required pursuant to NRC regulations to complete radiological decommissioning and spent fuel management at FCS, OPPD will augment the NDTs with annual contributions to the NDTs.
As conditions may change, OPPD will adjust the funding, as appropriate, using alternative funding mechanisms acceptable to the NRC.
IV. Regulatory Activities This spent fuel management plan assumes withdrawals from the supplemental decommissioning trust for spent fuel management purposes.
In accordance with 10 CFR 50.82(a)(8)(vii), OPPD will annually submit to the NRC by March 31 51 a report on the status of the funding for managing spent fuel. The report will include, current through the end of the previous calendar year, the amount of funds accumulated to cover the cost of managing the spent fuel, the projected cost of managing spent fuel until title to the fuel possession is transferred to the Secretary of Energy, and a plan to provide additional funding assurance using one of the methods allowed by the NRC regulations.
V. Summary The spent fuel management activities described in this Irradiated Fuel Management Plan must be performed in conjunction with license termination activities. The cash flow analysis demonstrates that the FCS DTF and the supplemental fund with projected earnings augmented by funding from operations is sufficient to cover the estimated costs of Licensing Termination Expenses, Spent Fuel Management, and Site Restoration.

Enclosure LIC-17-0031 Page 4 of 11 References
: 1. Letter from OPPD (T. Burke) to USNRC (Document Control Desk}, "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067)
(ML16242A127)
: 2. Letter from OPPD (T. Burke) to NRC (Document Control Desk}, "Certification of Permanent Removal of Fuel from the Reactor Vessel," dated November 13, 2016 (LIC-16-0074)
(ML16319A254)
: 3. Letter from OPPD (M. J. Fisher) to US NRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated March 30, 2017 (LIC-17-0033)

Enclosure LIC-17-0031 Page 5 of 11 Table 1 Irradiated Fuel Management Plan Summary Schedule and Costs Fuel Management Cost Approximate (Thousands of    Duration Decommissioning Periods            Start     End      2016 dollars)   (yearsJ Period 1: Preparations and Planning     2016       2018         38,401        1.68 Period 2a: Dormancy with Wet Fuel       2018      2022         175,296        4.51 Storage Period 2b: Dormancy with Dry Fuel       2023       2058        191,846       36.02 Storag_e Total                                                          405,543       42.21

Enclosure LIC-17-0031 Page 6 of 11 Table 2 Spent Fuel Management Schedule (Fuel Assembly Totals by Location)
ISFSI          DOE Year    Pool Inventory I   Inventory     Acceptance[11 2016              944 !            320 2017              944              320 i 2018              944              320 2019 I            944              320                 I
             ! 2020              944              320 2021 I I            784              480 2022                 0           1,264 2023                   I         1,264 2024                             1,264 2025                             1,264 2026 I                           1,264 2027                             1,264 2028                             1,264 2029                             1,264 2030                             1,264 2031                             1,264 2032                             1,203             61 2033                             1,107             96 2034                             1,067             40 2035                             1,007             60 2036                               917             90 2037                               871             46 2038                               827             44 2039                               790             37 2040                               757             33 2041                               732             25 2042                               704             28 2043                               652             52 2044                               603             49 2045                               558             45 I
I 2046                               465             93 2047                   1I          425             40 2048                               384.            41 2049 ''                            353             31 2050                               327             26 2051                               327               0 2052                               290             37 2053 I                             233              57

Enclosure LIC-17-0031 Page 7 of 11 Table 2 (continued)
Spent Fuel Management Schedule (Fuel Assembly Totals by Location)
Year       Pool Inventory          ISFSI           DOE Inventory       Acceptance 2054                                     173               60
                '      2055                        I            173                o, 2056                                     173 l              0 !
2057                                     133               40 2058                                       0              133 Total                                                    1,264
[1]   DOE acceptance schedule assuming industry acceptance begins in year 2030 and Fort Calhoun acceptance begins in year 2032. The schedule is provided for illustrative purposes only. It is expected that OPPD will seek to accelerate acceptance based on shutdown reactor priority, exchanges of acceptance allocations and other contractual provisions.

Enclosure LIC-17-0031 Page 8 of 11 Table 3 Spent Fuel Management Expenditures (thousands, 2016 dollars)
Equipment                                              '
Year    Labor   & Materials    Energy        Burial    Other   Total I
2016          0           0           0             0      806     806 2017          0           0           0             0'  25,132  25,132 2018     13,628           0           0             0   18,443  32,070 2019     27,033           0           0             0   11,863  38,895 2020     27,107           0           0             0   11,895  39,002 2021     27,033           0           0             0   11,863  38,895 2022     27,033           0           0             0   11,863  38,895 2023      4,869           0           0             0      137   5,006 2024      4,882           0           0             0      137   5,020 2025      4,869           0           0             0      137   5,006 2026      4,869           0           0             0      137   5,006 2027      4,869           0           0             0      137   5,006 2028      4,882           0           0             0      137   5,020 2029      4,869           0           0             0      137   5,006 2030      4,869           0           0             0      137   5,006 2031      4,869           0           0             0      137   5,006 2032      5,026        431            0             0      137   5,595 2033      5,085        647            0             0      137   5,869 2034      4,941        216            0             0      137   5,294 2035      5,013        431            0             0      137   5,581 2036      5,098        647            0             0      137   5,882 2037      4,941        216            0             0      137   5,294 2038      4,941        216            0             0      137   5,294 2039      4,941        216            0             0      137   5,294 2040      4,954        216            0             0      137   5,307 2041      4,941        216            0             0      137   5,294 2042      4,941        216            0             0      137   5,294 2043      5,013        431            0             0      137   5,581 2044      5,026        431            0             0      137   5,595 2045      4,941        216            0             0      137   5,294 2046      5,085        647            0             0      137   5,869 2047      4,941        216            0             0\     137   5,294 2048      4,882           0            0            0      137   5,020

Enclosure LIC-17-0031 Page 9 of 11 Table 3 (continued)
Spent Fuel Management Expenditures (thousands, 2016 dollars)
Year    Labor   Equipment j     Energy         Burial   Other   Total
                     & Materials 2049      4,941        216               0            0     137   5,294 2050      4,941        216              0             0     137   5,294
 !   2051      5,013        431              0             0     137   5,581 2052      4,954        216               0            0     137   5,307 2053      4,941        216  I           0             0     137   5,294 2054      5,013        431               0            0     137   5,581 2055      4,941        216              0             0     137   5,294 2056      4,954        216              0             0     137   5,307 2057      5,013        431              0             0     137   5,581 2058      5,013        431              0             0     137   5,581 Total   300,115      8,625              0             0  96,802 405,543

Enclosure LIC-17-0031 Page 10 of 11 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 Table 4 Decommissioning Fund Annual Collections, Expenditures and Balances
                                                                          $ in thousands Total Annual                License            Spent Fuel             Site        Decommissioning             Supplemental Decommissioning             Termination          Management          Restoration          Trust Fund           Decommission ing Year          Fund Collections'           Expenditures         Expenditures       Expenditu res          Balance'          Trust Fund Balance' 2016                             $0                    $23                $272               $279              $285,838                 $96,296 2017                     $147,459                $135,676              $26,312                 so              $289,391                 $84,334 2018                     S135,054                  $66,060             $33,812                 $0              $295,108                S122,526 2019                     $156,262                  $24,535             $42,180                 $0              $303,537                $217,424 2020                     $134,762                  $25,311             $43,515                 $0              $313,049                $291,962 2021                     $188,436                  $25,971             $44,649                 $0              $662,261                 $82,276 2022                     $108,703                  $26,719             $45,935                 so              $656,761                $148,760 2023                     $132,370                   $8,462              $6,082                 $0              $669,637                $281,978 2024                        $9,187                 $13,980              $6,273                 $0              $677,326                $294,160 2025                        $1,216                  $6,647              $6,435                 $0              $692,719                $298,475 2026                        S1,255                  $6,835              $6,617                 $0             $708,424                 $302,786 2027                        S1,287                  $7,028              $6,804                 $0             $724,446                 $307,079 2028                        $1,323                  S7,243              $7,013                 $0              S740,774                $311,339 2029                        $1,361                  $7,424              $7,187                 $0              S757,452                $315,598 2030                        S1.403                  $7,629              $7,386                 so              $774,467                $319,837 2031                        S1,437                  S7,841              $7,591                 $0              $791,822                $324,041 2032                        $1,477                  S8,081              $8,719                 $0              $809,502                $327,276 2033                        $1,518                  $8,281              $9,399                 $0              $827,556                S329,969 2034                        S1,744                  $8,509              $8,711                 $0              $845,969                $333,678 2035                        $1,880                  $8,742              $9,435                 $0              $864,748                $336,910 2036                        $1,742                  S9,005             $10,215                 $0              $883,873                $339,315 2037                        $1,887                  $9,225              $9,444                 $0              $903,400                $342,730 2038                        $2,043                  $9,476              $9,701                 $0              $923,310                $346,154 2039                        $1,889                  $9,734              $9,965                 $0              $943,610                $349,265 2040                        $1,940                 $10,024             $10,260                 $0              $964,277                S352,230 2041                       $1,993                 $10,267             S10,512                 $0              $985,374                S355,090 2042                       $2,052                 $10,544             $10,795                 $0            $1,006,879                S357,815 2043                        $2,102                 $10,829             $11,688                 $0            $1,028,798                $359,773 2044                        $2,159                 $11,153             $12,035                 so            $1,051,104                $361,501 2045                        $2,338                 $11,424             $11,696                 so            S1,073,864                $363,811 2046                        $2,407                 $11,734             $13,318                 so            $1,097,054                $364,618 2047                       S2,339                 $12,052             S12,338                 $0            $1,120,679                S366,379 2048                       $2,664                 $12,412             S12,017                 $0            $1,144,711                $368,853 2049                       $2,468                 S12,714             $13,016                 $0            $1,169,221                $370,194 2050                       $2,403                 $13,058             $13,369                 $0            $1,194,183                $371,154 2051                       S2,603                 $13,412             S14,476                 $0            $1,219,601                $371,224 2052                       $2,674                 $13,813             $14,138                 $0            $1,245,443                $371,712 2053                       $2,895                 S14,149             S14.485                 $0            $1,271,789                S372,087 2054                       $2,828                 S14,532             $15,685                 $0            $1,298,607                $371,187 2055                       S2,897                 $14,926             $15,281                 $0            S1,325,901                $370,738 2056                       S3,137                 $15,372             $15,734                 $0            $1,353,634                $370,058 2057                       $3,056                 $15,745             $16,995                 $0            $1,381,894                $367,993 2058                       $3,147                 $16,173             S17.458                 $0            $1,410,645                $365,481 2059                       $3,399               $160,859                   $0             $1,115            $1,293,284                $379,754 2060                       $3,492                S303,834                  so             $4,293            S1,026,772                $391,358 2061                            so               S350,342                  $0             $5,283              S704,278                S398,785 2062                            so               $233,487                  so             $8,545              $490,003                $403,141 2063                            $0               $239,815                  so             $8,777              $262,290                $407,403 2064                            $0               $210,069                  $0             $6,349               $57,364                $414,273 2065                            $0                $57,589                  $0           S48,938                   S709                $378,082 2066                            so                   $507                  so           S88,148                   S217                $300,857
                                   $1,090,698             $2,249,273             $628,948          S171,727 1
Collections are a combination of District Funds and DOE reimbursements for spent fuel costs.
       ' In 2021, a lump sum of $339,400,000 will be tra nsferred from the Decommissioning Supplemental Trust to fu nd the Decommissioning Trust
       'All collections and expenditures flow through the Decommissioning Su pplemental Tru st through 2021.

Enclosure LIC-17 -0031 Page 11 of 11 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 Table 5 Decommissioning Fund Annual Inflation Rates and Earnings Rates Inflation     Earnings Year           Rate          Rate 2017          2.52%         1.63%
2018          2.84%         2.23%
2019          2.86%         2.98%
2020          2.88%         3.27%
2021          2.89%         3.27%
2022          2.88%         3.27%
2Q23          2.87%         3.27%
2024          2.86%         3.27%
2025          2.86%         3.27%
2026          2.83%         3.27%
2027          2.83%         3.27%
2028          2.78%         3.27%
2029          2.77%         3.27%
2030          2.77%         3.27%
2031          2.78%         3.27%
2032          2.77%         3.27%
2033          2.76%         3.27%
2034          2.75%         3.27%
2035          2.74%         3.27%
2036          2.73%         3.27%
2037          2.72%         3.27%
2038          2.72%         3.27%
2039          2.72%         3.27%
2040          2.71%         3.27%
2041          2.70%         3.27%
2042          2.70%         3.27%
2043          2.70%         3.27%
2044 - 2066      2.71%         3.27%}}