ML032540418

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Request for Additional Information (RAI) on the Spent Fuel Management and Funding Plan for Humboldt Bay Unit 3
ML032540418
Person / Time
Site: Humboldt Bay
Issue date: 10/06/2003
From: Bernard Thomas
NRC/NRR/DRIP/RPRP
To: Rueger G
Pacific Gas & Electric Co
Pittiglio C, DRIP/RPRP, 301-415-1435
References
+sisprbs20051109, -RFPFR
Download: ML032540418 (5)


Text

October 6, 2003 Mr. Gregory M. Rueger Senior Vice President - Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant P. O. Box 3 Avila Beach, CA 94177

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) ON THE SPENT FUEL MANAGEMENT AND FUNDING PLAN FOR HUMBOLDT BAY, UNIT 3 In accordance with the provisions of 10 CFR 50.54(bb), reactor licensees that have permanently shutdown are required to submit for U.S. Nuclear Regulatory Commission (NRC) approval a program for the management and funding of spent fuel. Pursuant to 10 CFR 50.54(bb), you submitted a letter to the NRC dated September 26, 2000, addressing the spent fuel management and funding plans for Humboldt Bay Nuclear Power Plant, Unit 3.

The staff has reviewed your 50.54(bb) submittal and requests additional information in support of the Humboldt Bay spent fuel management and funding plan. Specifically:

1)

Your September 26, 2000, letter stated that costs associated with SAFSTOR (which includes costs associated with spent fuel management including such activities as operation, maintenance, security, and similar expenses associated with storage of the fuel while stored in a spent fuel pool) are recovered on an annual basis via Pacific Gas and Electrics (PG&Es) base rates as authorized by the California Public Utilities Commission (CPUC). It is reasonable to expect that the 50.54(bb) plan would include consideration of the design, licensing, construction, operation, and decommissioning of an ISFSI dry cask storage system, if it is anticipated that this option is likely to be chosen. Based on the significant expenditures to date related to ISFSI design and licensing for Humboldt Bay, the staff finds that you have made a sufficient commitment to the dry cask storage option such that you should address ISFSI funding in your 50.54(bb) plan. Please provide estimates of ISFSI related expenditures to date and future cost estimates. Commensurate with the ISFSI cost estimates, please discuss the arrangements and provisions that will ensure that adequate funds will be available to pay for the projected ISFSI expenses and what impact these costs have had on your decommissioning fund to date.

2)

It is the staffs understanding that the Humboldt Bay decommissioning fund contains monies for spent fuel management in support of 10 CFR 50.54 (bb) and non-radiological decommissioning activities, in addition to the radiological decommissioning funds in support of 10 CFR 50.82 activities. Consistent with regulatory Statements of

Mr. Gregory M. Rueger Consideration (e.g., 67 FR 78340, or 61 FR 39285), the decommissioning regulations do not prohibit co-mingling of decommissioning funds with spent fuel management (ISFSI) funds and other non-radiological decommissioning funds, provided that accounting mechanisms are employed to ensure that funds for each type of activity are appropriately identified. Please provide a description of the accounting mechanism used to segregate the different cost centers in the decommissioning fund.

3)

In a letter from PG&E to the NRC dated March 27, 2003, (PG&E letter HBL-03-002), it was stated that the Humboldt Bay decommissioning fund is approximately $167 million dollars short of being fully funded. This shortfall estimate does not appear to include any ISFSI related construction, operation, or decommissioning costs (as requested in question 1 above). Please provide the staff more detail on the anticipated funding mechanism for this decommissioning fund shortfall and why PG&E is confident that these funds will be authorized.

Your staff may contact the NRC project manager, Bill Huffman, at (301) 415-1141, or Larry Pittiglio at (301) 415-1435, if you have any questions concerning the requested information.

Sincerely,

/RA/

Brian Thomas, Section Chief Reactor Policy and Rulemaking Program Division of Regulatory Improvements Program Office of Nuclear Reactor Regulation License No. DPR-7 Docket No. 50-133 Docket No. 72-27 CC: PG&E List

ML032540418 OFFICE RPRP NMSS NMSS:SL NMSS:BC RPRP:SC NAME CPittiglio*

BHuffman*

SMoore*

DGillen*

BEThomas DATE 9/11/2003 09/11/2003 09/11/2003 09/24/2003 10/06/2003

Pacific Gas and Electric Company cc:

Mr. Lawrence F. Womack, Vice President Power Generation & Nuclear Services Diablo Canyon Power Plant P. O. Box 56 Avila Beach, CA 93424 Mr. Roy Willis, Plant Manager Humboldt Bay Nuclear Power Plant Pacific Gas & Electric Company 1000 King Salmon Avenue Eureka, CA 95503 R. Terry Nelson, Director Fossil Generation Mail Code N11E Pacific Gas & Electric Company P.O.Box 770000 San Francisco, California 94177-0001 Christopher J. Warner, Esq.

Law Department Pacific Gas & Electric Company Post Office Box 7442 San Francisco, CA 94120 Chairman, Humboldt County Board of Supervisors County Courthouse 825 Fifth Street Eureka, CA 95501 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, CA 94327-7320 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102 Redwood Alliance P.O. Box 293 Arcata, CA 95521 Dr. Rich Ferguson, Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, CA 94814 Mr. Ed Bailey, Radiation Program Director Radiologic Health Branch State Department of Health Services P.O. Box 942732 (MS 178)

Sacramento, CA 94327-7320 Commissioner California Energy Commission 1516 Ninth Street Sacramento, CA 95814 Deputy Attorney General State of California 110 West A Street, Suite 700 San Diego, CA 92101