ML17136A169

NRR E-mail Capture - (External_Sender) OPPD FCS Decommissioning Financial Reports

ML17136A169
Person / Time
Site:	Fort Calhoun
Issue date:	05/16/2017
From:	Blome B Omaha Public Power District
To:	Dusaniwskyj M, James Kim Division of Inspection and Regional Support, Division of Operating Reactor Licensing
References
MF9536
Download: ML17136A169 (5)

Text

NRR-PMDAPEm Resource From: BLOME, BRADLEY H <bblome@oppd.com>

Sent: Tuesday, May 16, 2017 11:18 AM To: Kim, James; Dusaniwskyj, Michael Cc: MATZKE, ERICK P

Subject:

[External_Sender] OPPD FCS decommissioning financial reports Attachments: NRC clarification.pdf

References:

1. Letter from OPPD (M. J. Fisher) to US NRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, 2017 Biennial Decommissioning Funding Status Report," Dated March 24, 2017 (LIC-17-0021) (ML17083B297)

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) (ML17089A759)

3. Letter from OPPD (M. J. Fisher) to US NRC (Document Control Desk), "Fort Calhoun Station Irradiated Fuel Management Plan," Dated March 31, 2017 (LIC-17-0031) (ML17093A594)

Based on information from the recent NRC public meeting to Discuss New Potential Regulations for Power Reactor Decommissioning, Omaha Public Power District (OPPD) is providing the following clarifications in support of the Fort Calhoun Station (FCS) Biennial Decommissioning Funding Status Report (Reference 1), Post-Shutdown Decommissioning Activities Report (PSDAR) and Decommissioning Cost Estimate (DCE) (Reference 2), and Irradiated Fuel Management Plan (IFMP) (Reference 3).

Clarification 1 The cash flows reported in the Biennial Funding Report and in the PSDAR/DCE and IFMP appear to be different but are not. The cash flows included in the PSDAR/DCE and IFMP are based on 2016 dollars as noted in the various table headings (e.g. Table 2 on Page xx of xxii of the DCE) and the dollars in the Biennial Funding Report were adjusted for inflation as noted on page 2, section D of the report. The inflation rates used to convert the cash flows are included in Attachment D of Biennial Funding Report.

Clarification 2 Page 2, section C, and Attachment C of Biennial Funding Report and Table 4 of the IFMP contain information on Annual Decommissioning Fund Collections. The reports note the collections are a combination of District Funds (cost of service electric rates) and Department of Energy (DOE) reimbursement of spent fuel costs. It is OPPDs intention to fund the collections from District Funds. If OPPD would receive any DOE reimbursements, those amounts would be used by OPPD to supplement the District funds. The DCE clearly delineates this basis as stated in Footnote 4 on page viii of xxii as follows:

Projected expenditures for spent fuel management identified in the cost analyses do not consider the outcome of the litigation (including compensation for damages) with the DOE with regard to the delays incurred by the OPPD in the timely removal of spent fuel from the site. As such, this analysis takes no credit for collection of damages, even though utilities are now routinely being awarded such damages in the courts. Collection of spent fuel damages from the DOE is expected to provide the majority of funds needed for spent fuel management.

The above clarifications should resolve any potential confusion between the three referenced submittals.

Brad Blome Director - Licensing & Regulatory Assurance 1

Fort Calhoun Station (FC-2-4)

Omaha Public Power District 9610 Power Lane, Blair, NE 68008 402-533-7270 bblome@oppd.com This e-mail contains Omaha Public Power District's confidential and proprietary information and is for use only by the intended recipient. Unless explicitly stated otherwise, this e-mail is not a contract offer, amendment, or acceptance. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

2

Hearing Identifier: NRR_PMDA Email Number: 3516 Mail Envelope Properties (DCBA4D5BE93A1E4CA8E806D1BDF8829CCF838DF8)

Subject:

[External_Sender] OPPD FCS decommissioning financial reports Sent Date: 5/16/2017 11:17:55 AM Received Date: 5/16/2017 11:20:20 AM From: BLOME, BRADLEY H Created By: bblome@oppd.com Recipients:

"MATZKE, ERICK P" <ematzke@oppd.com>

Tracking Status: None "Kim, James" <James.Kim@nrc.gov>

Tracking Status: None "Dusaniwskyj, Michael" <Michael.Dusaniwskyj@nrc.gov>

Tracking Status: None Post Office: SEPEX731.oppd.oppd-ds.com Files Size Date & Time MESSAGE 3561 5/16/2017 11:20:20 AM Picture (Device Independent Bitmap) 1.jpg 1030 NRC clarification.pdf 259674 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

References:

1. Letter from OPPD (M. J. Fisher) to US NRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, 2017 Biennial Decommissioning Funding Status Report," Dated March 24, 2017 (LIC 0021) (ML17083B297)

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)

(ML17089A759)

3. Letter from OPPD (M. J. Fisher) to US NRC (Document Control Desk), "Fort Calhoun Station Irradiated Fuel Management Plan," Dated March 31, 2017 (LIC-17-0031) (ML17093A594)

Based on information from the recent NRC public meeting to Discuss New Potential Regulations for Power Reactor Decommissioning, Omaha Public Power District (OPPD) is providing the following clarifications in support of the Fort Calhoun Station (FCS) Biennial Decommissioning Funding Status Report (Reference 1), Post-Shutdown Decommissioning Activities Report (PSDAR) and Decommissioning Cost Estimate (DCE) (Reference 2), and Irradiated Fuel Management Plan (IFMP) (Reference 3).

Clarification 1 The cash flows reported in the Biennial Funding Report and in the PSDAR/DCE and IFMP appear to be different but are not. The cash flows included in the PSDAR/DCE and IFMP are based on 2016 dollars as noted in the various table headings (e.g. Table 2 on Page xx of xxii of the DCE) and the dollars in the Biennial Funding Report were adjusted for inflation as noted on page 2, section D of the report. The inflation rates used to convert the cash flows are included in Attachment D of Biennial Funding Report.

Clarification 2 Page 2, section C, and Attachment C of Biennial Funding Report and Table 4 of the IFMP contain information on Annual Decommissioning Fund Collections. The reports note the collections are a combination of District Funds (cost of service electric rates) and Department of Energy (DOE) reimbursement of spent fuel costs. It is OPPDs intention to fund the collections from District Funds. If OPPD would receive any DOE reimbursements, those amounts would be used by OPPD to supplement the District funds. The DCE clearly delineates this basis as stated in Footnote 4 on page viii of xxii as follows:

Projected expenditures for spent fuel management identified in the cost analyses do not consider the outcome of the litigation (including compensation for damages) with the DOE with regard to the delays incurred by the OPPD in the timely removal of spent fuel from the site. As such, this analysis takes no credit for collection of damages, even though utilities are now routinely being awarded such damages in the courts. Collection of spent fuel damages from the DOE is expected to provide the majority of funds needed for spent fuel management.

The above clarifications should resolve any potential confusion between the three referenced submittals.