Letter Sequence Draft RAI |
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MONTHYEARML1109006602011-03-30030 March 2011
Decommissioning Funding Report as of December 31, 2010
Project stage: Request
ML1113004002011-05-10010 May 2011
Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
Project stage: Draft RAI
ML1113003952011-05-10010 May 2011
Email, Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
Project stage: Draft RAI
2011-03-30
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Category:Request for Additional Information (RAI)
MONTHYEARML21117A3492021-03-30030 March 2021
March 30, 2021, Email from Public Watchdogs on Providing New Information to Its October 13, 2020, 2.206 Petition
ML21068A2722021-03-0909 March 2021
SONGS Endangered Species Act Additional Information Request
ML20343A1292020-12-0808 December 2020
NRR E-mail Capture - Request for Additional Information
ML18193A2002018-07-19019 July 2018
SONGS ISFSI Only Dqap RAI
ML15083A4552015-03-27027 March 2015
and Independent Spent Fuel Storage Installation - Request for Additional Information Decommissioning Quality Assurance Program Review
ML15071A1842015-03-19019 March 2015
Independent Spent Fuel Storage Installation - Request for Additional Information Regarding the 10 CFR 50.54(p) Changes to the Security Plans
ML15042A3942015-01-23023 January 2015
NRR E-mail Capture - SONGS - Draft RAI Permanently Defueled Technical Specifications License Amendment Request
ML15033A0522014-12-11011 December 2014
NRR E-mail Capture - SONGS - Draft RAI Permanently Defueled Technical Specifications License Amendment Request
ML14248A5902014-09-18018 September 2014
Independent Spent Fuel Storage Installation - Request for Additional Information, Amendment Request to Revise Emergency Plan to Support Permanently Defueled Condition
ML14248A5602014-09-18018 September 2014
Independent Spent Fuel Storage Installation - Request for Additional Information, Amendment Request to Revise Emergency Action Level Scheme to Support Permanently Defueled Condition
ML14258A0172014-09-11011 September 2014
NRR E-mail Capture - SONGS - Revised Draft RAI Concerning TS Section 5 Administrative Controls License Amendment Request (TACs MF2954 and MF2955)
ML14209A0052014-08-27027 August 2014
Request for Additional Information, Exemption Request from 10 CFR 50.47 and 10 CFR Part 50 Appendix E, Discontinue Offsite Emergency Planning Activities and Reduce Scope of Onsite Emergency Planning (TAC MF3835-MF3837)
ML14139A4782014-06-0505 June 2014
Request for Additional Information, License Amendment Request to Revise Technical Specifications 5.1, 5.2, and 5.3 to Reflect Reduced Staffing/Training in Permanently Shutdown and Defueled Condition
ML14093A6772014-05-0101 May 2014
SONGS - Request for Additional Information Concerning Pre-Emption Authority
ML13352A0912013-12-30030 December 2013
Decommissioning Funding Status Report - Request for Additional Information
ML13191A8372013-09-12012 September 2013
Request for Additional Information, Review of Decommissioning Funding Status Report
ML13154A4312013-06-0404 June 2013
Rai'S Following Ifib Analysis of Edison'S 2013 Decommissioning Funding Status Report for San Onofre Units 2 and 3
ML13113A2562013-05-10010 May 2013
Request for Additional Information No. 73 Regarding Response to Confirmatory Action Letter
ML13072A0542013-03-18018 March 2013
Redacted, Request for Additional Information, Nos. 33-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
ML13074A6872013-03-15015 March 2013
Email, Draft Request for Additional Information, Nos. 68-72, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
ML13053A1842013-02-21021 February 2013
Draft Request for Additional Information, Nos. 53-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
ML13056A0922013-02-20020 February 2013
Email, Draft Request for Additional Information Nos. 38-52, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
ML13053A3672013-02-0101 February 2013
E-mail, Draft Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
ML12356A1982012-12-20020 December 2012
Email, Request for Additional Information, Round 3, Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report
ML12345A4272012-12-10010 December 2012
Revised Email, Request for Additional Information Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report
ML12338A1102012-11-30030 November 2012
Email, Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter (CAL) 4-12-001 Dated March 27, 2012
ML12313A4752012-11-0808 November 2012
Request for Additional Information Email, Relief Request IST-4-P-2, ASME OM Code Requirements for Testing CSS and LPSI Pumps, Fourth 10-Year Inservice Inspection Interval
ML12297A3972012-10-23023 October 2012
Request for Additional Information Email, Relief Request ISI-3-36, Reactor Coolant Pressure Boundary Testing, Third 10-Year Inservice Inspection Interval
ML12283A2302012-10-0909 October 2012
Request for Additional Information Email, Round 3 W/Corrected Due Date, Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel
ML12283A2252012-10-0909 October 2012
Request for Additional Information Email, Round 3, Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel
ML12220A0492012-08-0707 August 2012
Request for Additional Information Email, Round 2, License Amendment Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel
ML12207A2612012-08-0101 August 2012
Redacted, Request for Additional Information, License Amendment Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel
ML12201A1552012-07-19019 July 2012
R. Onge Ltr Request for Additional Information Decommissioning Funding
ML12056A0502012-03-12012 March 2012
Enclosure 4 - Recommendation 2.3: Flooding
ML12056A0512012-03-12012 March 2012
Enclosure 5 - Recommendation 9.3: Emergency Preparedness
ML12056A0482012-03-12012 March 2012
Enclosure 2 - Recommendation 2.1: Flooding
ML12056A0472012-03-12012 March 2012
Enclosure 1 - Recommendation 2.1: Seismic
ML12056A0492012-03-12012 March 2012
Enclosure 3 - Recommendation 2.3: Seismic
ML1200603242012-01-19019 January 2012
Fleet, RAI, Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-789 (N-789)
ML1126604602011-10-14014 October 2011
Request for Additional Information Regarding Use of American Concrete Institute Reports for Restoration of Unit 3 Containment
ML11182C0322011-06-30030 June 2011
Notification of Inspection (Inspection Report 05000361; 05000362/2011004) and Request for Information
ML1113003952011-05-10010 May 2011
Email, Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
ML1113004002011-05-10010 May 2011
Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
ML1112307842011-05-0303 May 2011
Draft Request for Additional Information, Relief Requests ISI-3-32 Through ISI-3-34, Alternative to Requirements for Examinations of Welds and Core Support Structure Surfaces, Third 10-Year Inservice Inspection
ML1106006612011-03-0101 March 2011
Draft Generic Request for Additional Information, License Amendment Request to Revise License Condition and Approve Cyber Security Plan
ML1024301262010-08-31031 August 2010
Request for Additional Information Relief Request ISI-3-31
ML1022404532010-08-11011 August 2010
Draft Request for Additional Information LAR on Fuel Assembly Movement
ML0933601212009-12-0202 December 2009
Request for Additional Information Relief Request ISI-3-30
ML0831705532008-12-0808 December 2008
Request for Additional Information, License Amendment Request to Support Replacement Steam Generators
ML0831901202008-11-26026 November 2008
Request for Additional Information Test Protocol Used in the Testing at Vuez
2021-03-09
[Table view] |
Text
REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 This Request for Additional Information (RAI) is in response to Southern California Edisons (SCEs) 2011 Decommissioning Funding Status (DFS) report for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. On March 30, 2011, SCE submitted to the Nuclear Regulatory Commission (NRC) the 2011 DFS report for SONGS Units 2 and 3, as required under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, paragraph 50.75(f)(1)
(Agencywide Documents Access and Management System (ADAMS) Accession No. ML110900660). The NRC staff has reviewed SCEs DFS report and requests responses to the following questions in order to complete its review.
RAI No. 1: Minimum DFA calculation:
Provide the labor, energy, and burial factors used in the calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS report.
On March 30, 2011, SCE reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) less than the amount calculated by the NRC staff.
According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c).
The formulas for the factors used by the staff can be found using NUREG-1307, Rev. 14, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities. For example, the calculations for the Labor and Energy Adjustment Factors can be found on pages 7 and 8 of NUREG-1307, Rev. 14.
RAI No. 2: Reporting requirements:
SCE should indicate whether there are any material changes to the trust agreements from the last submittal.
On March 30, 2011, SCE reported that none of the licensees were relying on any contracts pursuant to 10 CFR 50.75(e)(1)(v) and that there were no modifications to their method of providing financial assurance. However, SCE did not indicate if there were any material changes to the trust agreements from the last submittal.
As stated under 10 CFR 50.75(f)(1):
ENCLOSURE
[T]he information in [the DFS] report must include [. . .] any contracts upon which the licensee is relying under paragraph (e)(1)(v) of this section; any modifications occurring to a licensees current method of providing financial assurance since the last submitted report; and any material changes to trust agreements. . .
RAI No. 3: Citation for real rate of returns:
Provide the citation(s) (e.g, an Order by the rate-regulatory authority) by the regulatory entity that allows for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors assumed in your DFS report.
On March 30, 2011, SCE reported the following for the joint owners of SONGS 2 and 3:
SCE:
6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.46 percent rate of earnings on decommissioning funds.
San Diego Gas & Electric (SDG&E):
6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.14 percent rate of earnings on decommissioning funds.
City of Anaheim (Anaheim):
4 percent rate of escalation in decommissioning costs, 4 percent rate of earnings on decommissioning funds.
City of Riverside (Riverside):
4 percent rate of escalation in decommissioning costs, 3.87 percent rate of earnings on decommissioning funds.
As stated in 10 CFR 50.75(f)(1),
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .
RAI No. 4: Rate of escalation clarification:
Clarify which escalation costs are attributable to radiological costs associated for radiological decommissioning. Define what other costs imply and why Riverside and Anaheim do not have
such a breakdown. Also, clarify for the NRC staffs review, why Riverside has an escalation factor higher than its rate of earnings.
On March 30, 2011, SCE provided the escalation decommissioning costs for site specific decommissioning and the rate of earnings for each joint owner of SONGS 2 and 3.
As stated in 10 CFR 50.75(f)(1):
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .
RAI No. 5: Annual collections:
Indicate whether SCE and its joint owners will have future collections into the trust funds. If so, provide a breakdown of the annual decommissioning contributions that will be accumulated for only radiological decommissioning costs.
Within the March 30, 2011, DFS report, SCE included the contributions for the year 2011, but does not indicate if there are future contributions.
As stated under 10 CFR 50.75(f)(1):
[T]he information in [the DFS] report must include [. . .] a schedule of the annual amounts remaining to be collected. . .
RAI No. 6: Citation for Site-Specific Study:
Provide the site-specific cost estimate for SONGS 2 and 3, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars.
On March 30, 2011, SCE provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required in 2009 dollars, but did not include the cost escalation factor(s) that would be used to escalate the site-specific cost estimate to 2010 dollars.
Per 10 CFR 50.75(e)(1)(i) and (ii), the licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.
