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{{Adams
#REDIRECT [[NLS2015141, ISFSI Decommissioning Funding Plan]]
| number = ML16014A382
| issue date = 12/17/2015
| title = Cooper Nuclear Station - ISFSI Decommissioning Funding Plan
| author name = Shaw J
| author affiliation = Nebraska Public Power District (NPPD)
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS
| docket = 05000298, 07200066
| license number = DPR-046
| contact person =
| case reference number = NLS2015141
| document type = Decommissioning Funding Plan DKTs 30, 40, 50, 70, Letter
| page count = 16
}}
 
=Text=
{{#Wiki_filter:N!Nebraska Public Power DistrictAlways there when you need usNLS2015 141December 17, 2015ATTN: Document Control DeskDirector, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
 
==Subject:==
 
Independent Spent Fuel Storage Installation Decommissioning Funding PlanCooper Nuclear Station, Docket No. 50-298, DPR-46Cooper Nuclear Station ISFSI, Docket No. 72-66
 
==Dear Sir or Madam:==
The purpose of this correspondence is to provide Nebraska Public Power District's Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Cooper NuclearStation (CNS) in accordance with 10 CFR 72.30, Financial Assurance and Recordkeeping forDecommissioning.
The enclosure to this letter provides a detailed cost estimate fordecommissioning the ISFSI at CNS in an amount reflecting the work is performed by anindependent contractor, an adequate contingency factor, and release of the facility and the drystorage system for unrestricted use, as specified in 10 CFR Part 20.1402.Additionally, the enclosure provides identification of the key assumptions contained in the costestimate and also the volume of onsite subsurface material containing residual radioactivity, ifany, that will require remediation to meet the criteria for license termination.
The enclosure also presents information related to demonstrating the adequacy ofdecommissioning funding for ultimate ISFSI decommissioning.
: Finally, attached is the certification required pursuant to 10 CFR 72.30(b)(6) that financial assurance for decommissioning has been provided in the amount of the cost estimate fordecommissioning.
This letter contains no new regulatory commitments.
P.O. Box 98 / Brownville, NE 68321-0098 Telephone:
(402) 825-3811
/ Fax: (402) 825-5211
"
NLS2015141 Page 2 of 2Should you have any questions concerning this matter, please contact me at (402) 825-2788.
Sincerely,ShawLicensing Manager/ho
 
==Attachment:==
 
Certification of Financial Assurance
 
==Enclosure:==
 
10 CFR 72.30 ISFSI Decommissioning Cost Estimatecc: Regional Administrator w/ attachment and enclosure USNRC -Region IVCooper Project Manager w/ attachment and enclosure USNRC -NRR Project Directorate IV-1Senior Resident Inspector w/ attachment and enclosure USNRC -CNSNPG Distribution w/o attachment and enclosure CNS Records wh/attachment and enclosure NLS2015 141Attachment Page 1 of 2Attachment Certification of Financial Assurance CERTIFICATION OF FINANCIAL ASSURANCE NRC License:
DPR-46Nebraska Public Power DistrictCooper Nuclear StationP.O. Box 9872676 648 ABrownville NE 68321Issued to: U.S. Nuclear Regulatory Commission
 
==Subject:==
 
Independent Spent Fuel Storage Installation Certification:
I hereby certify that Nebraska Public Power District is the licensee for the Cooper Nuclear StationIndependent Spent Fuel Storage Installation (Cooper ISFSI), and that the undersigned is authorized toprovide this Certification of Financial Assurance with respect to the decommissioning of the CooperISFSI.During the operation of this ISFSI spent nuclear fuel will be stored in storage casks licensed under 10CFR Part 72. Pursuant to contracts with the Department of Energy the spent fuel and casks willultimately be removed from the ISFSI location, at which time the ISFSI will be decommissioned inaccordance with NRC regulations.
I further certify that financial assurance in an amount sufficient to fund ISFSI decommissioning at thetime of such decommissioning exists, as described in the Enclosure to the letter to which this Certification is attached.
That amount is premised on a site-specific decommissioning cost estimate provided in thatEnclosure.
Cooper Nuclear Station ISFSI$ 6,104,000 (inclusive of contingency)
Title: Vice President
& Chief Financial OfficerDate zCorporate Seal -- -
NLS2015 141Enclosure Page 1 ofl12Enclosure Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding PlanCooper Nuclear Station, Docket No. 50-298, DPR-46Cooper Nuclear Station ISFSI, Docket No. 72-6610 CFR 72.30 ISFSI Decommissioning Cost Estimate 10 CFR 72.30 ISFSI Decommissioning Funding Plan1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011 ,E with the rule becoming effective on December 17, 2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning,"
requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).Correspondingly Nebraska Public Power District (NPPD) submitted the requisite plan tothe NRC on or about December 17, 2012. This is the second submittal to the NRC onthis same topic.In accordance with the rule, this enclosure provides a detailed cost estimate fordecommissioning the ISFSI at Cooper Nuclear Station (CNS) in an amount reflecting:
: 1. The work is performed by an independent contractor;
: 2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This enclosure also provides:
: 1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity, if any,that will require remediation to meet the criteria for license termination.
: Finally, in Section 7 of this enclosure, Nebraska Public Power District (NPPD) provides adescription of the method of assuring funds for decommissioning the ISFSI, including means for adjusting the cost estimate and associated funding levels over the life of theplant.The material in Sections 1 -6, and Tables 1 and 2, herein, were prepared based onevaluations conducted by TLG Services, Inc. Section 7, containing the financial assurance information, was prepared by NPPD.U.s. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"
Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011
: 2. Spent Fuel Management StrategyThe operating license for CNS is currently set to expire on January 18, 2034.Approximately 5,927 spent fuel assemblies are currently projected to be generated overthe life of the plant. Because of the breach by the Department of Energy (DOE) of itscontract to remove fuel from the site, an ISFSI has been constructed and spent fueltransferred to dry storage modules located on the ISFSI, to support continued plantoperations.
Based upon the current projection of the DOE's ability to remove spent fuelfrom the site, this estimate assumes that the current ISFSI will be expanded after shutdownto store the used fuel that remained in the spent fuel pool in order to support plantdecommissioning.
The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2]).Because of the DOE's breach, it is envisioned that the spent fuel pooi will contain asignificant number of spent fuel assemblies at the time of expiration of the currentoperating license in 2034, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations orsafe-storage operations, the fuel that cannot be transferred directly to the DOE from thepool is assumed to be packaged in dry storage modules for interim storage at the ISFSI.Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas canbe either decontaminated and dismantled or prepared for long-term storage.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations will be accepted for disposal from the nation's commercial nuclear plants,with limited exceptions, in the order (the "queue")
in which it was discharged from thereactor.C 31 NIPPD's current spent fuel management plan for the CNS spent fuel is based ingeneral upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel toa federal facility (not necessarily a final repository),
and 2) expectations for spent fuelreceipt by the DOE for the CNS fuel. The DOE's generator allocation/receipt schedules arebased upon the oldest fuel receiving the highest priority.
Assuming a maximum rate oftransfer of 3,000 metric tons of uranium/year,[
41 the spent fuel is projected to be fullyremoved from the CNS site in 2072. This also assumes that the 1,054 spent fuel assemblies NPPD has in storage at General Electric's wet-pool JSFSI in Morris, illinois are shippedfirst, starting in 2032.NPPD believes that one or more monitored retrievable storage facilities could be put intoplace within a reasonable time. In January 2013, the DOE issued the "Strategy for theU.S. Code ofFdrlRegulations, Tte10, Pat72, Subpart K, "GnrlLcnefrStorage ofSpentFula Power Reactor Sites."U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV -Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNE and/or HLWat the DOE repository.
This priority ranking shall be based on the age of SNF and/or HLW as calculated fromthe date of discharge of such materials from the civilian nuclear power reactor.
The oldest fuel or waste willhave the highest priority for acceptance, except as ..""Acceptance Priority Ranking & Annual Capacity Report,"
DOE/RW-0567, July 20042 Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," inresponse to the recommendations made by the current administration' s Blue RibbonCommission and as "a framework for moving toward a sustainable program to deploy anintegrated system capable of transporting,
: storing, and disposing of used nuclear fuel..."[
5]The report stated that "[W]ith the appropriate authorizations from Congress, theAdministration currently plans to implement a program over the next 10 years that:... [Aidvances toward the siting and licensing of a larger interim storage facility to beavailable by 2025 that will have sufficient capacity to provide flexibility in the wastemanagement system and allows for acceptance of enough used nuclear fuel to reduceexpected government liabilities; and..."For purposes of this estimate, NPPD is using a more conservative 2030 start date forDOE.NPPD's position is that the DOE has a contractual obligation to accept the spent fuelearlier than the projections set out above consistent with its contract commitments.
Noassumption made in this study should be interpreted to be inconsistent with this claim.3. ISFSI Decommissioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI will be promptlydecommissioned (similar to the power reactor DECON altemnative).
For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario.
In this estimatethe ISFSI decommissioning is considered an independent
: project, regardless of thedecommissioning alternative identified for the nuclear power plant.4. ISFSI Description The design and capacity of the CNS ISFSI is based upon a NUHOMS-61BT drystorage system. The NUHOMS system is comprised of a dry storage canister (DSC)with 61 spent fuel assembly capacity and a horizontal storage module (HSM), Model202. The DSCs are assumed to be transferred directly to the DOE and not returned to thestation.
Some of the remaining HSMs are assumed to have residual radioactivity due tosome minor level of neutron-induced activation as a result of the long-term storage of thespent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established forunrestricted use, form the basis of the ISFSI decommissioning estimate.
NPPD's current spent fuel management plan for the CNS spent fuel would result in 73HSMs being placed on an expanded storage pad at the site. This represents 75% of thetotal spent fuel projected to be generated during the currently licensed operating period."Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.DOE, January 11, 2013 This projected configuration is based upon the 2030 DOE spent fuel program start with a2037 DOE start date for the fuel at the CNS site, a 3,000 MTU / year pickup rate, and a52 module capacity for the ISFSI pad built to support plant operations.
This scenariowould allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.
Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.
: 5. Key Assumptions
/ Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI expected afterall spent fuel and GTCC material has been removed from the site. The configuration ofthe ISFSI is based on the station operating until the end of its current license (2034) andthe DOE's spent fuel acceptance assumptions, as previously described.
For purposes ofthis analysis the current pad (265 feet by 42 feet) will be expanded to accommodate the73 modules.The dry storage vendor, Transnuclear, Inc., does not expect the horizontal storagemodules to have any interior or exterior radioactive surface contamination.[
61 It isexpected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign.
Any neutron activation of the steel and concrete is expected to be extremely 71This assumption is adopted for this analysis.
The decommissioning estimate is based on the premise that the DSC support structure within some of the HSMs and surrounding HSM concrete will contain low levels ofneutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning.
As an allowance, nine of the 73 HSMs are assumed to be affected, i.e.,contain residual radioactivity.
The allowance quantity is based upon the number of DSCsrequired for the final core off-load (i.e., 548 offloaded assemblies/unit, 61 assemblies perDSC) which results in a total of nine HSMs that contain residual radioactivity.
It isassumed that these are the final USMs offloaded; consequently they have the least timefor radioactive decay of the neutron activation products.
It is not expected that there will be any concrete activation of, and/or residualcontamination left on the concrete ISFSI pad. It is expected that this assumption would beconfirmed as a result of good radiological practice of surveying potentially impactedareas after each spent fuel transfer campaign.
Therefore, it is assumed for this analysisthat the ISFSI pad will not be contaminated.
As such, only verification surveys areincluded for the pad in the decommissioning estimate.
6Updated Final Safety Analysis Report for the Standardized NUJHOMS Horizontal Modular Storage Systemfor Irradiated Nuclear Fuel, Transnuclear Inc., NUJI-003, Rev. 12, at page 3.5-1 dated February 1, 2012,[ML12037A013]
Ibid. at page 9.6-14 There is no known subsurface material in the proximity of the ISFSI containing residualradioactivity that will require remediation to meet the criteria for license termination.
Decommissioning is assumed to be performed by an independent contractor.
As such,essentially all labor, equipment, and material costs are based on national
: averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations),
and laboratory service costs are based on vendor pricelists. Those craft labor positions that are expected to be provided
: locally, are consistent with fully burdened contractor labor rates used in the most recently developed CNSdecommissioning cost estimate.
NPPD, as licensee, will oversee the site activities; theestimate includes NPPD's labor and overhead costs.Low-level radioactive waste packaging, transport and disposal costs are based on ratesconsistent with the most recently developed decommissioning cost estimate (year 2015dollars).
Contingency has been added at an overall rate of 25%. This is consistent with thecontingency evaluation criteria referenced by the NRC in NUREG-1757.
t81Costs are reported in 2015 dollars and based upon a decommissioning analysis preparedfor CNS in 2015.The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meetthe 10 CFR §20.1402 criteria for unrestricted use. Disposition of released material andstructures is outside the scope of the estimate.
: 6. Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2. The cost has been organized into three phases, including:
*An initial planning phase -empty HSMs are characterized and the specifications andwork procedures for the decontamination (DSC support structure removal) developed.
*The remediation phase -residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of at low-level waste.*The final phase -license termination
: surveys, independent surveys are completed, andan application for license termination submitted.
In addition to the direct costs associated with a contractor providing the decommissioning
: services, the estimate also contains costs for the NRC (and NRC contractor to performthe verification survey),
NPPD's oversight staff, site security (industrial),
and other siteoperating costs."Consolidated Deconmmissioning
: Guidance, Financial Assurance, Recordkeeping, and Timeliness,"
U.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUJREG-1757, Volume3, Revision 1, February 20125 For estimating purposes it should be conservatively assumed that all expenditures will beincurred following plant decommissioning and all spent fuel removal.
Based on bestavailable information, NPPD expects that the DOE will complete the pickup of spent fuelat CNS by 2072.7. Financial Assurance ISFSI operations at CNS are in response to the DOE's failure to remove spent nuclearfuel from the site in a timely manner. The costs for management of the spent fuel arecosts for which the DOE is responsible under federal law and the Standard Contract.
It istherefore expected that, once the ISFSI is no longer needed, the cost to decommission theISFSI would be a DOE-reimbursable expense.
Until such time that the costs can berecovered from the DOE, NPPD will rely upon the money available in itsdecommissioning trust fund to terminate the ISF SI license and release the facility forunrestricted use.Using the decommissioning trust fund is reasonable based on the following:
*Although the decommissioning trust fund is for radiological decommissioning (i.e.,post-shutdown) costs only, the ISFSI decommissioning is a radiological cost. Also,to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by NPPD,including ISFSI decommissioning costs.*The projected minimum certification amount, calculated pursuant to 10 CFR 50.75(c)required to demonstrate reasonable assurance of funds for decommissioning CNS is$633,277,000 (2014 dollars),
based upon the NRC's latest figures for calculating thatvalue. [9]*Based upon CNS's decommissioning trust fund balance as of December 31, 2014 asreported in Nebraska Public Power District's March 30, 2015 Decommissioning Funding Ninth Biennial Report and considering a 2.5% real rate of return~l0l on thefund between December 31, 2014 and the start of CNS decommissioning the trustfund would contain a $374,826,405 surplus (refer to Table 3) beyond the NRCminimum funding formula provided in 10CFR50.75(c).
This surplus is more thansufficient to complete the future decommissioning of the ISFSI (estimated costprovided in Table 2).* NPPD will continue to assess the decommissioning fund status in accordance with theNRC requirements (e.g. 10CFR 50.75(b)(2),
10CFR 50.75(f)(1),
10CFR72.30(c))
and"Report on Waste Burial Charges,"
U.S. Nuclear Regulatory Commission's Office of Nuclear ReactorRegulation, NIJREG-1307, Rev. 15, January 2013t0The assumed annual real rate of return is 2.50 percent.
The District's Board of Directors (as the licensee's ratesetting authority) has approved this assumption for the decommissioning funding plan for Cooper NuclearStation through the adoption of a Board Resolution, dated June 13, 2008, as part of its official business.
6 projected
: surplus, to account for the continued assurance of adequate funds for ISFSIdecommissioning.
Any adjustments to the cost estimate and funding levels will bemade in connection with the triennial filing required pursuant to 1OCFR72.30(c).
Tothe extent any specific regulatory actions are necessary at the time of withdrawal from the trust fund of the amount necessary for ISFSI decommissioning, NPPD willpursue such actions.* In addition to the projected excess in decommissioning funds that would be available for the diminimus level of funding required for ISFSI decommissioning, NPPD couldadditionally rely on its available cash and investments that total over $1.2 billion(including
$478.4 million in liquid assets).
This information was provided to theNRC with NPPD's guarantee of deferred
: premiums, pursuant to 10 CER 140.21,submitted by letter dated June 30, 2015, "Licensee Guarantees of Payment ofDeferred Premiums",
Cooper Nuclear Station, Docket No. 50.298, DPR-46.*NPPD provides this information because it further demonstrates the availability offunding to pay for ISFSI decommissioning.
NPPD is not here submitting thisinformation in the form of a guarantee under 10 CFR 72.30(e)(2),
but may do so inthe future.7 Table 1Significant Quantities and Physical Dimensions ISFSI PadItem Length (ft) Width (if) Residual Radioactivity Current 1SF SI Pad 265 42 NoISFSI Horizontal Storage Module -Model 202Item Value Notes (all dimensions are nominal)Outside Height (inches) 222 Without vent coverOutside Length (inches) 248 Without shield wallsOutside Width (inches) 116 Without shield wallsQuantity (total) 73 Spent Fuel (excluding GTCC modules)Equivalent to the number of HSMs used to storeQuantity (with residual radioactivity) 9 last complete core offload)HSM Low-Level Radioactive Waste (pounds) 2,808,891 Concrete and steelOther Low-Level Radioactive Waste (pounds) 1,562 DAW, filters and other secondary wasteLow-Level Radioactive Waste (packaged density) 146 Average weight density8 Table 2ISFSI Decommissioning Costs and Waste VolumesWaste________________(thousands, 2015 dollars)
Volume HoursI Oversight Removal Packaging Transport Disposal Other Total (cubic feet) Craft and Contractor Decommissioning Contractor Planning (characterization, specs and procedures)
---- 219 219 --1,096Remediation (HSM disposition) 406 4795 1,303 -2,508 19,245 3,757 -License Termination (radiological surveys)
---- 967 967 -8,164-Suttl406 4795 1,303 1,186 3,694 19,245 11,921 1,096Fees and Costs ---- 405 405 --776Insurance
---- 110 110---Energy ---- 43 43---Non-Labor Overhead
---- 26 26---Security (industrial)
---- 327 327 --5,013NPPD Oversight Staff ---- 278 278 --3,803Subtotal
---- 1,189 1,189 -- 9,592Total (w/o contingency) 406 4 795 1,303 2,375 4,883 19,245 11,921 10,688Total (w125% contingency) 508 5 994 1,628 2,969 6,1049 Table 3Financial Assurance' 10 CFR 50.75(b)
& (c) Decommissioning Estimate (2014 Dollars):
$633,277,0002 Decommnissioning Fund3 Total as of 12/31/2014:
$565,543,636 Schedule of Future Annual Fund Earnings and Decommissioning Cost in Constant 2014Dollars4Projected Earnings CreditFunding Applying NRCBeginning Funding Requirement Approved Real Ending MinimumYear Balance Contribution Year-Beginning Rate of Return Balance 2014 Dollars2015 $565,543,636
-0 $14,138,591
$579,682,227
$633,277,000 2016 $579,682,227
-0 $14,492,056
$594,174,283
$633,277,000 2017 $594,174,283
-0 $14,854,357
$609,028,640
$633,277,000 2018 $609,028,640
-0 $15,225,716
$624,254,356
$633,277,000 2019 $624,254,356
-0 $15,606,359
$639,860,715
$633,277,000 2020 $639,860,715
-0 $15,996,518
$655,857,232
$633,277,000 2021 $655,857,232
-0 $16,396,431
$672,253,663
$633,277,000 2022 $672,253,663
-0 $16,806,342
$689,060,005
$633,277,000 2023 $689,060,005
-0 $17,226,500
$706,286,505
$633,277,000 2024 $706,286,505
-0 $17,657,163
$723,943,668
$633,277,000 2025 $723,943,668
-0 $18,098,592
$742,042,259
$633,277,000 2026 $742,042,259
-0 $18,551,056
$760,593,316
$633,277,000 1 The following table is excerpted from Nebraska Public Power District's March 30, 2015 ninth Biennial Report onFinancial Assurance for Cooper Nuclear Station in accordance with 10 CFR 50.75(D(1)
Reporting and Recordkeeping forDecommissioning Planning and is provided for illustrative purposes.
Please also reference related NPPD correspondence to theNRC (NLS2008098 dated December 15, 2008) that provided various decommissioning planning scenarios for Cooper NuclearStation that considered both delayed DECON and SAFSTOR alternatives.
Either of those scenarios provides deferred dates forthe decommissioning of Cooper Nuclear Station.
With those later dates, NPPD would expect to accrue additional earningsconsistent with the assumed real rate of return for the decommissioning trust fund.2 This estimate is based upon NRC decommissioning minimum certification escalation requirements in 10 CFR50.75(c)(l) and (2) and guidance per NUREG 1307 for a BWR the size of Cooper Nuclear Station.
The calculation utilizes thevendor waste burial factor in Revision 15 of NUREG 1307 and Labor and Energy escalation factors derived from December2014 Midwest regional data of the U.S. Department of Labor Bureau of Labor Statistics.
3 This is the total amount (market value) in the external sinking fund (as described in 10 CFR 50.75) to cover the costsof NRC-defined decommissioning.
The current (November 30, 2015) Market Value of the external sinking fund is$569,468,385.
4 These figures will be recalculated on an annual basis in accordance with 10 CFR 50.75 (b) and (c). The aboveamounts reflect the anticipated annual contributions (none currently scheduled),
and annual fund earnings that demonstrate fullfunding of the decommissioning trust by the end of the operating license (license expiration January 18, 2034), and taking intoaccount a pro rata credit during the dismantlement period (recognizing both cash expenditures and earnings) over the first sevenyears after shutdown on a constant dollar basis (see 10 CFR 50.75(e)(
1)(ii)).
Please note that all prior submissions by the Districtin accordance with 10 CFR 50.75()(
: 1) have been provided on a nominal dollar basis. This change is responsive to RAL #3included in a May 23, 2013 email from Lynnea Wilkins, NRC Project Manager.10 Beginning BalanceFundingFunding Requirement Contribution Year-Beginning Year20272028202920302031203220332034203520362037203820392040$760,593,316
$779,608,149
$799,098,352
$819,075,811
$839,552,706
$860,541,524
$882,055,062
$904,106,439
$833,979,254
$762,098,889
$688,421,515
$612,902,206
$535,494,914
$456.152.441 Projected Earnings CreditApplyingApproved RealRate of Return0 $19,014,833 0 $19,490,204 0 $19,977,459 0 $20,476,895 0 $20,988,818 0 $21,513,538 0 $22,051,377 42 $20,340,957 43 $18,587,778 43 $16,790,769 43 $14,948,834 43 $13,060,852 43 $11,125,669 43 $9,142,107 EndingBalance$779,608,149
$799,098,352
$819,075,811
$839,552,706
$860,541,524
$882,055,062
$904,106,439
$833,979,254
$762,098,889
$688,421,515
$612,902,206
$535,494,914
$456,152,441
$374,826,405 NRCMinimum2014 Dollars$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$90,468, 1$90,468, 1$90,468, 14$90,468, 1$90,468, 1$90,468, 1.$90,468,1.
11 N!Nebraska Public Power DistrictAlways there when you need usNLS2015 141December 17, 2015ATTN: Document Control DeskDirector, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
 
==Subject:==
 
Independent Spent Fuel Storage Installation Decommissioning Funding PlanCooper Nuclear Station, Docket No. 50-298, DPR-46Cooper Nuclear Station ISFSI, Docket No. 72-66
 
==Dear Sir or Madam:==
The purpose of this correspondence is to provide Nebraska Public Power District's Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding Plan for Cooper NuclearStation (CNS) in accordance with 10 CFR 72.30, Financial Assurance and Recordkeeping forDecommissioning.
The enclosure to this letter provides a detailed cost estimate fordecommissioning the ISFSI at CNS in an amount reflecting the work is performed by anindependent contractor, an adequate contingency factor, and release of the facility and the drystorage system for unrestricted use, as specified in 10 CFR Part 20.1402.Additionally, the enclosure provides identification of the key assumptions contained in the costestimate and also the volume of onsite subsurface material containing residual radioactivity, ifany, that will require remediation to meet the criteria for license termination.
The enclosure also presents information related to demonstrating the adequacy ofdecommissioning funding for ultimate ISFSI decommissioning.
: Finally, attached is the certification required pursuant to 10 CFR 72.30(b)(6) that financial assurance for decommissioning has been provided in the amount of the cost estimate fordecommissioning.
This letter contains no new regulatory commitments.
P.O. Box 98 / Brownville, NE 68321-0098 Telephone:
(402) 825-3811
/ Fax: (402) 825-5211
"
NLS2015141 Page 2 of 2Should you have any questions concerning this matter, please contact me at (402) 825-2788.
Sincerely,ShawLicensing Manager/ho
 
==Attachment:==
 
Certification of Financial Assurance
 
==Enclosure:==
 
10 CFR 72.30 ISFSI Decommissioning Cost Estimatecc: Regional Administrator w/ attachment and enclosure USNRC -Region IVCooper Project Manager w/ attachment and enclosure USNRC -NRR Project Directorate IV-1Senior Resident Inspector w/ attachment and enclosure USNRC -CNSNPG Distribution w/o attachment and enclosure CNS Records wh/attachment and enclosure NLS2015 141Attachment Page 1 of 2Attachment Certification of Financial Assurance CERTIFICATION OF FINANCIAL ASSURANCE NRC License:
DPR-46Nebraska Public Power DistrictCooper Nuclear StationP.O. Box 9872676 648 ABrownville NE 68321Issued to: U.S. Nuclear Regulatory Commission
 
==Subject:==
 
Independent Spent Fuel Storage Installation Certification:
I hereby certify that Nebraska Public Power District is the licensee for the Cooper Nuclear StationIndependent Spent Fuel Storage Installation (Cooper ISFSI), and that the undersigned is authorized toprovide this Certification of Financial Assurance with respect to the decommissioning of the CooperISFSI.During the operation of this ISFSI spent nuclear fuel will be stored in storage casks licensed under 10CFR Part 72. Pursuant to contracts with the Department of Energy the spent fuel and casks willultimately be removed from the ISFSI location, at which time the ISFSI will be decommissioned inaccordance with NRC regulations.
I further certify that financial assurance in an amount sufficient to fund ISFSI decommissioning at thetime of such decommissioning exists, as described in the Enclosure to the letter to which this Certification is attached.
That amount is premised on a site-specific decommissioning cost estimate provided in thatEnclosure.
Cooper Nuclear Station ISFSI$ 6,104,000 (inclusive of contingency)
Title: Vice President
& Chief Financial OfficerDate zCorporate Seal -- -
NLS2015 141Enclosure Page 1 ofl12Enclosure Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Funding PlanCooper Nuclear Station, Docket No. 50-298, DPR-46Cooper Nuclear Station ISFSI, Docket No. 72-6610 CFR 72.30 ISFSI Decommissioning Cost Estimate 10 CFR 72.30 ISFSI Decommissioning Funding Plan1. Background and Introduction The Nuclear Regulatory Commission (NRC) issued its final rule on Decommissioning Planning on June 17, 2011 ,E with the rule becoming effective on December 17, 2012.Subpart 72.30, "Financial assurance and recordkeeping for decommissioning,"
requiresthat each holder of, or applicant for, a license under this part must submit for NRC reviewand approval a decommissioning funding plan that contains information on howreasonable assurance will be provided that funds will be available to decommission theIndependent Spent Fuel Storage Installation (ISFSI).Correspondingly Nebraska Public Power District (NPPD) submitted the requisite plan tothe NRC on or about December 17, 2012. This is the second submittal to the NRC onthis same topic.In accordance with the rule, this enclosure provides a detailed cost estimate fordecommissioning the ISFSI at Cooper Nuclear Station (CNS) in an amount reflecting:
: 1. The work is performed by an independent contractor;
: 2. An adequate contingency factor; and3. Release of the facility and dry storage systems for unrestricted use, as specified in 10CFR Part 20.1402This enclosure also provides:
: 1. Identification of the key assumptions contained in the cost estimate; and2. The volume of onsite subsurface material containing residual radioactivity, if any,that will require remediation to meet the criteria for license termination.
: Finally, in Section 7 of this enclosure, Nebraska Public Power District (NPPD) provides adescription of the method of assuring funds for decommissioning the ISFSI, including means for adjusting the cost estimate and associated funding levels over the life of theplant.The material in Sections 1 -6, and Tables 1 and 2, herein, were prepared based onevaluations conducted by TLG Services, Inc. Section 7, containing the financial assurance information, was prepared by NPPD.U.s. Code of Federal Regulations, Title 10, Parts 20, 30, 40, 50, 70 and 72 "Decommissioning Planning,"
Nuclear Regulatory Commission, Federal Register Volume 76, Number 117 (p 35512 et seq.), June 17, 2011
: 2. Spent Fuel Management StrategyThe operating license for CNS is currently set to expire on January 18, 2034.Approximately 5,927 spent fuel assemblies are currently projected to be generated overthe life of the plant. Because of the breach by the Department of Energy (DOE) of itscontract to remove fuel from the site, an ISFSI has been constructed and spent fueltransferred to dry storage modules located on the ISFSI, to support continued plantoperations.
Based upon the current projection of the DOE's ability to remove spent fuelfrom the site, this estimate assumes that the current ISFSI will be expanded after shutdownto store the used fuel that remained in the spent fuel pool in order to support plantdecommissioning.
The ISFSI is operated under a Part 50 General License (in accordance with 10 CFR 72, Subpart K[2]).Because of the DOE's breach, it is envisioned that the spent fuel pooi will contain asignificant number of spent fuel assemblies at the time of expiration of the currentoperating license in 2034, assuming the plant operates to that date, including assemblies off-loaded from the reactor vessel. To facilitate immediate dismantling operations orsafe-storage operations, the fuel that cannot be transferred directly to the DOE from thepool is assumed to be packaged in dry storage modules for interim storage at the ISFSI.Once the spent fuel pool is emptied, the spent fuel pool systems and fuel pool areas canbe either decontaminated and dismantled or prepared for long-term storage.Completion of the ISFSI decommissioning process is dependent upon the DOE's abilityto remove spent fuel from the site. DOE's repository program assumes that spent fuelallocations will be accepted for disposal from the nation's commercial nuclear plants,with limited exceptions, in the order (the "queue")
in which it was discharged from thereactor.C 31 NIPPD's current spent fuel management plan for the CNS spent fuel is based ingeneral upon: 1) a 2030 start date for DOE initiating transfer of commercial spent fuel toa federal facility (not necessarily a final repository),
and 2) expectations for spent fuelreceipt by the DOE for the CNS fuel. The DOE's generator allocation/receipt schedules arebased upon the oldest fuel receiving the highest priority.
Assuming a maximum rate oftransfer of 3,000 metric tons of uranium/year,[
41 the spent fuel is projected to be fullyremoved from the CNS site in 2072. This also assumes that the 1,054 spent fuel assemblies NPPD has in storage at General Electric's wet-pool JSFSI in Morris, illinois are shippedfirst, starting in 2032.NPPD believes that one or more monitored retrievable storage facilities could be put intoplace within a reasonable time. In January 2013, the DOE issued the "Strategy for theU.S. Code ofFdrlRegulations, Tte10, Pat72, Subpart K, "GnrlLcnefrStorage ofSpentFula Power Reactor Sites."U.S. Code of Federal Regulations, Title 10, Part 961.11, Article IV -Responsibilities of the Parties, B. DOEResponsibilities, 5.(a) ... DOE shall issue an annual acceptance priority ranking for receipt of SNE and/or HLWat the DOE repository.
This priority ranking shall be based on the age of SNF and/or HLW as calculated fromthe date of discharge of such materials from the civilian nuclear power reactor.
The oldest fuel or waste willhave the highest priority for acceptance, except as ..""Acceptance Priority Ranking & Annual Capacity Report,"
DOE/RW-0567, July 20042 Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," inresponse to the recommendations made by the current administration' s Blue RibbonCommission and as "a framework for moving toward a sustainable program to deploy anintegrated system capable of transporting,
: storing, and disposing of used nuclear fuel..."[
5]The report stated that "[W]ith the appropriate authorizations from Congress, theAdministration currently plans to implement a program over the next 10 years that:... [Aidvances toward the siting and licensing of a larger interim storage facility to beavailable by 2025 that will have sufficient capacity to provide flexibility in the wastemanagement system and allows for acceptance of enough used nuclear fuel to reduceexpected government liabilities; and..."For purposes of this estimate, NPPD is using a more conservative 2030 start date forDOE.NPPD's position is that the DOE has a contractual obligation to accept the spent fuelearlier than the projections set out above consistent with its contract commitments.
Noassumption made in this study should be interpreted to be inconsistent with this claim.3. ISFSI Decommissioning StrategyAt the conclusion of the spent fuel transfer process the ISFSI will be promptlydecommissioned (similar to the power reactor DECON altemnative).
For purposes of providing an estimate for a funding plan, financial assurance is expectedto be provided on the basis of a prompt ISFSI decommissioning scenario.
In this estimatethe ISFSI decommissioning is considered an independent
: project, regardless of thedecommissioning alternative identified for the nuclear power plant.4. ISFSI Description The design and capacity of the CNS ISFSI is based upon a NUHOMS-61BT drystorage system. The NUHOMS system is comprised of a dry storage canister (DSC)with 61 spent fuel assembly capacity and a horizontal storage module (HSM), Model202. The DSCs are assumed to be transferred directly to the DOE and not returned to thestation.
Some of the remaining HSMs are assumed to have residual radioactivity due tosome minor level of neutron-induced activation as a result of the long-term storage of thespent fuel. The cost to dispose of residual radioactivity, and verify that the remaining facility and surrounding environs meet the NRC's radiological limits established forunrestricted use, form the basis of the ISFSI decommissioning estimate.
NPPD's current spent fuel management plan for the CNS spent fuel would result in 73HSMs being placed on an expanded storage pad at the site. This represents 75% of thetotal spent fuel projected to be generated during the currently licensed operating period."Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste," U.S.DOE, January 11, 2013 This projected configuration is based upon the 2030 DOE spent fuel program start with a2037 DOE start date for the fuel at the CNS site, a 3,000 MTU / year pickup rate, and a52 module capacity for the ISFSI pad built to support plant operations.
This scenariowould allow the spent fuel storage pool to be emptied within approximately five and one-half years following the permanent cessation of operations.
Table 1 provides the significant quantities and physical dimensions used as the basis indeveloping the ISFSI decommissioning estimate.
: 5. Key Assumptions
/ Estimating ApproachThe decommissioning estimate is based on the configuration of the ISFSI expected afterall spent fuel and GTCC material has been removed from the site. The configuration ofthe ISFSI is based on the station operating until the end of its current license (2034) andthe DOE's spent fuel acceptance assumptions, as previously described.
For purposes ofthis analysis the current pad (265 feet by 42 feet) will be expanded to accommodate the73 modules.The dry storage vendor, Transnuclear, Inc., does not expect the horizontal storagemodules to have any interior or exterior radioactive surface contamination.[
61 It isexpected that this assumption would be confirmed as a result of good radiological practice of surveying potentially impacted areas after each spent fuel transfer campaign.
Any neutron activation of the steel and concrete is expected to be extremely 71This assumption is adopted for this analysis.
The decommissioning estimate is based on the premise that the DSC support structure within some of the HSMs and surrounding HSM concrete will contain low levels ofneutron-induced residual radioactivity that would necessitate remediation at the time ofdecommissioning.
As an allowance, nine of the 73 HSMs are assumed to be affected, i.e.,contain residual radioactivity.
The allowance quantity is based upon the number of DSCsrequired for the final core off-load (i.e., 548 offloaded assemblies/unit, 61 assemblies perDSC) which results in a total of nine HSMs that contain residual radioactivity.
It isassumed that these are the final USMs offloaded; consequently they have the least timefor radioactive decay of the neutron activation products.
It is not expected that there will be any concrete activation of, and/or residualcontamination left on the concrete ISFSI pad. It is expected that this assumption would beconfirmed as a result of good radiological practice of surveying potentially impactedareas after each spent fuel transfer campaign.
Therefore, it is assumed for this analysisthat the ISFSI pad will not be contaminated.
As such, only verification surveys areincluded for the pad in the decommissioning estimate.
6Updated Final Safety Analysis Report for the Standardized NUJHOMS Horizontal Modular Storage Systemfor Irradiated Nuclear Fuel, Transnuclear Inc., NUJI-003, Rev. 12, at page 3.5-1 dated February 1, 2012,[ML12037A013]
Ibid. at page 9.6-14 There is no known subsurface material in the proximity of the ISFSI containing residualradioactivity that will require remediation to meet the criteria for license termination.
Decommissioning is assumed to be performed by an independent contractor.
As such,essentially all labor, equipment, and material costs are based on national
: averages, i.e.,costs from national publications such as R.S. Means' Building Construction Cost Data(adjusted for regional variations),
and laboratory service costs are based on vendor pricelists. Those craft labor positions that are expected to be provided
: locally, are consistent with fully burdened contractor labor rates used in the most recently developed CNSdecommissioning cost estimate.
NPPD, as licensee, will oversee the site activities; theestimate includes NPPD's labor and overhead costs.Low-level radioactive waste packaging, transport and disposal costs are based on ratesconsistent with the most recently developed decommissioning cost estimate (year 2015dollars).
Contingency has been added at an overall rate of 25%. This is consistent with thecontingency evaluation criteria referenced by the NRC in NUREG-1757.
t81Costs are reported in 2015 dollars and based upon a decommissioning analysis preparedfor CNS in 2015.The estimate is limited to costs necessary to terminate the ISFSI' s NRC license and meetthe 10 CFR §20.1402 criteria for unrestricted use. Disposition of released material andstructures is outside the scope of the estimate.
: 6. Cost EstimateThe estimated cost to decommission the ISFSI and release the facility for unrestricted useis provided in Table 2. The cost has been organized into three phases, including:
*An initial planning phase -empty HSMs are characterized and the specifications andwork procedures for the decontamination (DSC support structure removal) developed.
*The remediation phase -residual radioactivity is removed, packaged in certified wastecontainers, transported to the low-level waste site, and disposed of at low-level waste.*The final phase -license termination
: surveys, independent surveys are completed, andan application for license termination submitted.
In addition to the direct costs associated with a contractor providing the decommissioning
: services, the estimate also contains costs for the NRC (and NRC contractor to performthe verification survey),
NPPD's oversight staff, site security (industrial),
and other siteoperating costs."Consolidated Deconmmissioning
: Guidance, Financial Assurance, Recordkeeping, and Timeliness,"
U.S.Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards, NUJREG-1757, Volume3, Revision 1, February 20125 For estimating purposes it should be conservatively assumed that all expenditures will beincurred following plant decommissioning and all spent fuel removal.
Based on bestavailable information, NPPD expects that the DOE will complete the pickup of spent fuelat CNS by 2072.7. Financial Assurance ISFSI operations at CNS are in response to the DOE's failure to remove spent nuclearfuel from the site in a timely manner. The costs for management of the spent fuel arecosts for which the DOE is responsible under federal law and the Standard Contract.
It istherefore expected that, once the ISFSI is no longer needed, the cost to decommission theISFSI would be a DOE-reimbursable expense.
Until such time that the costs can berecovered from the DOE, NPPD will rely upon the money available in itsdecommissioning trust fund to terminate the ISF SI license and release the facility forunrestricted use.Using the decommissioning trust fund is reasonable based on the following:
*Although the decommissioning trust fund is for radiological decommissioning (i.e.,post-shutdown) costs only, the ISFSI decommissioning is a radiological cost. Also,to the extent that the trust fund balance exceeds costs required for Part 50 radiological decommissioning, these funds would be available to address costs incurred by NPPD,including ISFSI decommissioning costs.*The projected minimum certification amount, calculated pursuant to 10 CFR 50.75(c)required to demonstrate reasonable assurance of funds for decommissioning CNS is$633,277,000 (2014 dollars),
based upon the NRC's latest figures for calculating thatvalue. [9]*Based upon CNS's decommissioning trust fund balance as of December 31, 2014 asreported in Nebraska Public Power District's March 30, 2015 Decommissioning Funding Ninth Biennial Report and considering a 2.5% real rate of return~l0l on thefund between December 31, 2014 and the start of CNS decommissioning the trustfund would contain a $374,826,405 surplus (refer to Table 3) beyond the NRCminimum funding formula provided in 10CFR50.75(c).
This surplus is more thansufficient to complete the future decommissioning of the ISFSI (estimated costprovided in Table 2).* NPPD will continue to assess the decommissioning fund status in accordance with theNRC requirements (e.g. 10CFR 50.75(b)(2),
10CFR 50.75(f)(1),
10CFR72.30(c))
and"Report on Waste Burial Charges,"
U.S. Nuclear Regulatory Commission's Office of Nuclear ReactorRegulation, NIJREG-1307, Rev. 15, January 2013t0The assumed annual real rate of return is 2.50 percent.
The District's Board of Directors (as the licensee's ratesetting authority) has approved this assumption for the decommissioning funding plan for Cooper NuclearStation through the adoption of a Board Resolution, dated June 13, 2008, as part of its official business.
6 projected
: surplus, to account for the continued assurance of adequate funds for ISFSIdecommissioning.
Any adjustments to the cost estimate and funding levels will bemade in connection with the triennial filing required pursuant to 1OCFR72.30(c).
Tothe extent any specific regulatory actions are necessary at the time of withdrawal from the trust fund of the amount necessary for ISFSI decommissioning, NPPD willpursue such actions.* In addition to the projected excess in decommissioning funds that would be available for the diminimus level of funding required for ISFSI decommissioning, NPPD couldadditionally rely on its available cash and investments that total over $1.2 billion(including
$478.4 million in liquid assets).
This information was provided to theNRC with NPPD's guarantee of deferred
: premiums, pursuant to 10 CER 140.21,submitted by letter dated June 30, 2015, "Licensee Guarantees of Payment ofDeferred Premiums",
Cooper Nuclear Station, Docket No. 50.298, DPR-46.*NPPD provides this information because it further demonstrates the availability offunding to pay for ISFSI decommissioning.
NPPD is not here submitting thisinformation in the form of a guarantee under 10 CFR 72.30(e)(2),
but may do so inthe future.7 Table 1Significant Quantities and Physical Dimensions ISFSI PadItem Length (ft) Width (if) Residual Radioactivity Current 1SF SI Pad 265 42 NoISFSI Horizontal Storage Module -Model 202Item Value Notes (all dimensions are nominal)Outside Height (inches) 222 Without vent coverOutside Length (inches) 248 Without shield wallsOutside Width (inches) 116 Without shield wallsQuantity (total) 73 Spent Fuel (excluding GTCC modules)Equivalent to the number of HSMs used to storeQuantity (with residual radioactivity) 9 last complete core offload)HSM Low-Level Radioactive Waste (pounds) 2,808,891 Concrete and steelOther Low-Level Radioactive Waste (pounds) 1,562 DAW, filters and other secondary wasteLow-Level Radioactive Waste (packaged density) 146 Average weight density8 Table 2ISFSI Decommissioning Costs and Waste VolumesWaste________________(thousands, 2015 dollars)
Volume HoursI Oversight Removal Packaging Transport Disposal Other Total (cubic feet) Craft and Contractor Decommissioning Contractor Planning (characterization, specs and procedures)
---- 219 219 --1,096Remediation (HSM disposition) 406 4795 1,303 -2,508 19,245 3,757 -License Termination (radiological surveys)
---- 967 967 -8,164-Suttl406 4795 1,303 1,186 3,694 19,245 11,921 1,096Fees and Costs ---- 405 405 --776Insurance
---- 110 110---Energy ---- 43 43---Non-Labor Overhead
---- 26 26---Security (industrial)
---- 327 327 --5,013NPPD Oversight Staff ---- 278 278 --3,803Subtotal
---- 1,189 1,189 -- 9,592Total (w/o contingency) 406 4 795 1,303 2,375 4,883 19,245 11,921 10,688Total (w125% contingency) 508 5 994 1,628 2,969 6,1049 Table 3Financial Assurance' 10 CFR 50.75(b)
& (c) Decommissioning Estimate (2014 Dollars):
$633,277,0002 Decommnissioning Fund3 Total as of 12/31/2014:
$565,543,636 Schedule of Future Annual Fund Earnings and Decommissioning Cost in Constant 2014Dollars4Projected Earnings CreditFunding Applying NRCBeginning Funding Requirement Approved Real Ending MinimumYear Balance Contribution Year-Beginning Rate of Return Balance 2014 Dollars2015 $565,543,636
-0 $14,138,591
$579,682,227
$633,277,000 2016 $579,682,227
-0 $14,492,056
$594,174,283
$633,277,000 2017 $594,174,283
-0 $14,854,357
$609,028,640
$633,277,000 2018 $609,028,640
-0 $15,225,716
$624,254,356
$633,277,000 2019 $624,254,356
-0 $15,606,359
$639,860,715
$633,277,000 2020 $639,860,715
-0 $15,996,518
$655,857,232
$633,277,000 2021 $655,857,232
-0 $16,396,431
$672,253,663
$633,277,000 2022 $672,253,663
-0 $16,806,342
$689,060,005
$633,277,000 2023 $689,060,005
-0 $17,226,500
$706,286,505
$633,277,000 2024 $706,286,505
-0 $17,657,163
$723,943,668
$633,277,000 2025 $723,943,668
-0 $18,098,592
$742,042,259
$633,277,000 2026 $742,042,259
-0 $18,551,056
$760,593,316
$633,277,000 1 The following table is excerpted from Nebraska Public Power District's March 30, 2015 ninth Biennial Report onFinancial Assurance for Cooper Nuclear Station in accordance with 10 CFR 50.75(D(1)
Reporting and Recordkeeping forDecommissioning Planning and is provided for illustrative purposes.
Please also reference related NPPD correspondence to theNRC (NLS2008098 dated December 15, 2008) that provided various decommissioning planning scenarios for Cooper NuclearStation that considered both delayed DECON and SAFSTOR alternatives.
Either of those scenarios provides deferred dates forthe decommissioning of Cooper Nuclear Station.
With those later dates, NPPD would expect to accrue additional earningsconsistent with the assumed real rate of return for the decommissioning trust fund.2 This estimate is based upon NRC decommissioning minimum certification escalation requirements in 10 CFR50.75(c)(l) and (2) and guidance per NUREG 1307 for a BWR the size of Cooper Nuclear Station.
The calculation utilizes thevendor waste burial factor in Revision 15 of NUREG 1307 and Labor and Energy escalation factors derived from December2014 Midwest regional data of the U.S. Department of Labor Bureau of Labor Statistics.
3 This is the total amount (market value) in the external sinking fund (as described in 10 CFR 50.75) to cover the costsof NRC-defined decommissioning.
The current (November 30, 2015) Market Value of the external sinking fund is$569,468,385.
4 These figures will be recalculated on an annual basis in accordance with 10 CFR 50.75 (b) and (c). The aboveamounts reflect the anticipated annual contributions (none currently scheduled),
and annual fund earnings that demonstrate fullfunding of the decommissioning trust by the end of the operating license (license expiration January 18, 2034), and taking intoaccount a pro rata credit during the dismantlement period (recognizing both cash expenditures and earnings) over the first sevenyears after shutdown on a constant dollar basis (see 10 CFR 50.75(e)(
1)(ii)).
Please note that all prior submissions by the Districtin accordance with 10 CFR 50.75()(
: 1) have been provided on a nominal dollar basis. This change is responsive to RAL #3included in a May 23, 2013 email from Lynnea Wilkins, NRC Project Manager.10 Beginning BalanceFundingFunding Requirement Contribution Year-Beginning Year20272028202920302031203220332034203520362037203820392040$760,593,316
$779,608,149
$799,098,352
$819,075,811
$839,552,706
$860,541,524
$882,055,062
$904,106,439
$833,979,254
$762,098,889
$688,421,515
$612,902,206
$535,494,914
$456.152.441 Projected Earnings CreditApplyingApproved RealRate of Return0 $19,014,833 0 $19,490,204 0 $19,977,459 0 $20,476,895 0 $20,988,818 0 $21,513,538 0 $22,051,377 42 $20,340,957 43 $18,587,778 43 $16,790,769 43 $14,948,834 43 $13,060,852 43 $11,125,669 43 $9,142,107 EndingBalance$779,608,149
$799,098,352
$819,075,811
$839,552,706
$860,541,524
$882,055,062
$904,106,439
$833,979,254
$762,098,889
$688,421,515
$612,902,206
$535,494,914
$456,152,441
$374,826,405 NRCMinimum2014 Dollars$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$633,277,000
$90,468, 1$90,468, 1$90,468, 14$90,468, 1$90,468, 1$90,468, 1.$90,468,1.
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