Letter Sequence RAI |
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MONTHYEARML1109503932011-03-30030 March 2011
Decommissioning Funding Status Report - 2010
Project stage: Request
ML1115302142011-06-0202 June 2011
Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
Project stage: RAI
ML1115301992011-06-0202 June 2011
Email, Request for Additional Information, Review of Biennial Decommissioning Funding Status Report
Project stage: RAI
ML1116721852011-06-16016 June 2011
Email Regarding Extension on Response Time for Request for Additional Information on Decommissioning Funds Status Report
Project stage: RAI
2011-06-16
[Table View] |
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Category:Request for Additional Information (RAI)
MONTHYEARML24011A1002024-01-10010 January 2024
March 2024 Emergency Preparedness Program Inspection - Request for Information
ML23334A1612023-11-30030 November 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - RAIs Associated with License Renewal Commitment for Pressurizer Surge Line Welds Inspection Program to Manage Environmentally Assisted Fatigue
ML23334A0072023-11-29029 November 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAIs for LAR That Revises TSs 3.5.1, SITs - Operating; 3.5.2, SIT Shutdown; 3.6.5, Containment Air Temperature; and SRs for TS 3.5.1, SITs Operating
ML23298A1232023-10-25025 October 2023
NRR E-mail Capture - Palo Verde, Unit 1 - RAIs for Relief Request 70, Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle
ML23031A3392023-01-31031 January 2023
In-service Inspection Request for Information
ML23013A0632023-01-13013 January 2023
NRR E-mail Capture - Palo Verde Unit 1 -Request for Additional Information - U1R23 Inspection Summary Report for Steam Generator Tubing
ML22348A1672022-12-14014 December 2022
March 2023 Emergency Preparedness Exercise Inspection - Request for Information
ML22339A2372022-12-0505 December 2022
NRR E-mail Capture - Palo Verde Unit 1 Request for Additional Information - U1R23 Inspection Summary Report for Steam Generator Tubing
ML22272A3252022-09-29029 September 2022
Licensed Operator Positive Fitness-For-Duty Test Request for Additional Information
ML22209A1752022-07-28028 July 2022
Inservice Inspection Request for Information
ML22187A2632022-07-0606 July 2022
Notification of Inspection (NRC IR 05000528/2022004, 05000529/2022004 and 05000530/2022004) and Request for Information
ML22067A2292022-03-0202 March 2022
Inservice Inspection Inspection PWR Request for Information
ML22055A5842022-02-24024 February 2022
NRR E-mail Capture - Palo Verde, Unit 3 - Final RAIs for 22nd Refueling Outage (Spring 2021) Steam Generator Tube Inservice Inspection Report
ML22035A3302022-02-10010 February 2022
Requests for Confirmation of Information for Exemption to Delete Diverse Auxiliary Feedwater Actuation System Based on Risk-Informed Process for Evaluations
ML22025A4012022-01-0303 January 2022
March 2022 Emergency Preparedness Program Inspection - Request for Information
ML21245A2222021-09-0101 September 2021
Request for Information
ML21200A2392021-07-20020 July 2021
Docs Request AC - AA August 2021
ML21154A0082021-05-26026 May 2021
NRR E-mail Capture - Palo Verde 1, 2 and 3 - Official RAIs for LAR Associated with Permanent Extension of Containment ILRT Frequency to 15 Years (Type a) and CIV Leak Rate Test Frequency to 75 Months (Type C)
ML21064A2372021-03-0303 March 2021
ISI Request for Information Rls
ML21042B9692021-02-18018 February 2021
Notification of NRC Design Bases Assurance Inspection and Initial Request for Information
ML21043A1462021-02-11011 February 2021
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAI for an Order Associated with Indirect License Transfer from Public Service Company of New Mexico to Avangrid, Inc
ML21023A0212021-01-13013 January 2021
PVNGS PI&R Request for Information RA
ML21011A1972021-01-12012 January 2021
Unit 2, and Unit 3 - Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000528/2021012, 05000529/2021012 and 05000530/2021012) and Request for Information
ML20227A0992020-08-14014 August 2020
Licensed Operator Positive Fitness-For-Duty Test Request for Additional Information
ML20118D1362020-04-28028 April 2020
Licensed Operator Positive Fitness-For-Duty Test Request for Additional Information
ML20049A0992020-02-14014 February 2020
Notification of Cyber Security Inspection (NRC Inspection Report 05000528/2020401; 05000529/2020401; and 05000530/2020401) and Request for Information
ML20049A0252020-02-12012 February 2020
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Unit 1 - Official RAIs for License Amendment Request Associated with Changes to Emergency Plan Staffing Requirements
ML20021A3172020-01-21021 January 2020
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Unit 1 - Official RAIs for Relief Request 64, Impractical Examinations for the Third 10-Year ISI Interval
ML19317D0782019-11-13013 November 2019
NRR E-mail Capture - Palo Verde 1 - Requests for Additional Information on Unit 1 21st Refueling Outage Steam Generator Tube Inspection Report
ML19234A3202019-08-29029 August 2019
Redacted - Request for Additional Information for Amendment and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel (EPID L-2018-LLA-0194; EPID L-2018-LLE-0010)
ML19155A1842019-05-30030 May 2019
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Unit 3 - Mvib Official RAIs for RR-63, Impractical Examinations for the Third 10-Year ISI Interval
ML19095A6552019-04-0404 April 2019
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Unit 3 - Mphb Official RAIs for RR-63, Impractical Examinations for the Third 10-Year ISI Interval
ML19044A7342019-02-13013 February 2019
NRR E-mail Capture - Palo Verde1, 2, and 3 - Official Requests for Additional Information for RR 62, Third and Fourth 10-Year ISI Intervals, Proposed Alternative - Pressurizer Heat Sleeve Repairs
ML19008A3612019-01-0808 January 2019
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAIs for LAR Associated with Response Time Testing of Pressure Transmitters
ML18341A0252018-12-0303 December 2018
Notification of NRC Design Bases Assurance Inspection (Teams)(05000528/2019011, 05000529/2019011, and 05000530/2019011) and Initial Request for Information
ML18271A0392018-10-0202 October 2018
Non Proprietary - Supplemental Information Needed for Acceptance of Requested License Amendments and Exemptions Implementation of Framatome High Thermal Performance Fuel (Epids L-2018-LLA-0194 and L-2018-LLE-0010)
ML18221A5102018-08-23023 August 2018
Request for Additional Information License Amendment Request to Adopt Risk-Informed Completion Times (CAC Nos. MF6576, MF6577, and MF6578; EPID: L-2015-LLA-0001)
ML18229A3132018-08-17017 August 2018
NRR E-mail Capture - Request for Additional Information Relief Request 58: Impractical Examinations for the Third 10-Year Inservice Inspection Interval Arizona Public Service Company Palo Verde Nuclear Generation Station, Unit 2 - Second Se
ML18227A8672018-08-15015 August 2018
NRR E-mail Capture - Request for Additional Information Relief Request 58: Impractical Examinations for the Third 10-Year Inservice Inspection Interval Arizona Public Service Company Palo Verde Nuclear Generation Station, Unit 2
ML18124A0112018-05-0303 May 2018
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official Eeob RAIs for TSTF-505 (4b) LAR (CAC Nos. MF6576, MF6577, and MF6578; EPID L-2015-LLA-0001)
ML18099A0072018-04-0606 April 2018
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAIs for 10 CFR 50.69 LAR (CAC Nos. MF9971, MF9972, and MF9973; EPID L-2017-LLA-0276)
ML18094B1122018-04-0404 April 2018
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Final RAIs for TSTF-505 (Initiative 4b) LAR (CAC Nos. MF6576, MF6577, and MF6578: EPID L-2015-LLA-0001)
ML18066A7032018-03-0707 March 2018
Notification of Nrc Design Bases Assurance Inspection (Programs) 05000528/2018011, 05000529/2018011, and 05000530/2018011 Initial Request for Information
ML17248A0162017-08-31031 August 2017
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Final RAI for RRs PRR-03, PRR-04 and PRR-05, Pump Testing
ML17107A0052017-04-14014 April 2017
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Ngf LAR and Exemption RAIs (CAC Nos. MF8076 to MF8081)
ML17082A4462017-03-28028 March 2017
PVNGS Units 1, 2, and 3 Transition to CE 16x16 Ngf - Draft RAIs Rev 3
ML17003A0182017-01-0202 January 2017
NRR E-mail Capture - Palo Verde, Unit 3 - Draft RAIs for the Second Emergency LAR Associated with EDG 3B Failure
ML16258A0312016-09-14014 September 2016
PVNGS Units 1-3 - Notif of NRC Insp of the Implementation of Mitigation Strategies and Spent Fuel Pool Instr. Orders and Emer. Prep. Comm./Staffing/Multi-Unit Dose Assessment Plns(05000528/ 2016009;05000529/2016009;and 05000530/2016009) and
ML16111B3312016-04-20020 April 2016
Notification of NRC Component Design Bases Inspection (05000528/2016007; 05000529/2016007; 05000530/2016007) and Initial Request for Information
ML16083A2502016-03-23023 March 2016
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Official RAIs for EAL LAR
2024-01-10
[Table view] |
Text
DRAFT REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 By letter dated March 30, 2011, APS submitted to the U.S. Nuclear Regulatory Commission (NRC) the 2011 Decommissioning Funding Status (DFS) report for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (PVNGS 1, 2, and 3), as required under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.75(f)(1) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110950393).
The NRC staff has reviewed the information provided by the licensee and determined that the following additional information is needed to complete the review:
RAI #1: Minimum DFA calculation:
Provide an explanation for the adjustment factors used in the DFS report. If necessary, provide a corrected submittal for that part of the report.
On March 30, 2011, APS 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.
Within its DFS report submittal, APS used an energy factor different than indicated by the BLS and used the burial factor from Example 1 (the Washington Site PWR Direct Disposal burial factor) in NUREG-1307, Rev. 14, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities.
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).
Also, as stated under 10 CFR 50.75(c)(2):
[e]scalation factors for labor and energy [. . .] are to be taken from regional data of U.S. Department of Labor Bureau of Labor Statistics and [. . .] escalation factor for waste burial and is to be taken from NRC report NUREG-1307, Report on Waste Burial Charges.
NUREG-1307 states that:
[f]or plants that have no disposal site available for LLW (e.g., plants not located within the Atlantic, Northwest, and Rocky Mountain Compacts), NUREG-1307, Rev. 14 assumes the costs for disposal is the same as that provided for the Atlantic Compact for lack of a better alternative at this time. . .
ENCLOSURE
RAI #2: 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 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, APS reported the following for the licensees of PVNGS 1, 2, and 3:
APS:
5 percent rate of escalation in decommissioning costs, and 6.75 percent rate of earnings on decommissioning funds.
Salt River Project Agricultural Improvement and Power District (SRP):
5.92 percent rate of escalation in decommissioning costs, and 7.65 percent rate of earnings on decommissioning funds.
El Paso Electric Company (EPE):
5.2925 percent rate of escalation in decommissioning costs, and 7.3310 percent rate of earnings on decommissioning funds.
Southern California Edison Company (SCE):
7.2 percent rate of escalation in decommissioning costs, and 5.25 percent rate of earnings on decommissioning funds.
Public Service Company of New Mexico (PNM):
5 percent rate of escalation in decommissioning costs, and 9.5 percent rate of earnings on decommissioning funds.
Southern California Public Power Authority (SCPPA):
6 percent rate of escalation in decommissioning costs, and 6.83 percent rate of earnings on decommissioning funds.
Los Angeles Department of Water and Power (LADWP):
5 percent rate of escalation in decommissioning costs, and 7 percent rate of earnings on decommissioning funds.
As stated in 10 CFR 50.75(f)(1),
the 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 #3: Escalation of costs to 2010 for site-specific study:
Provide the site specific cost estimate in 2010 dollars and describe the cost escalation factor(s) used to escalate the cost estimate to 2010 dollars in a total and year-to-year format. If applicable, provide an updated site-specific cost estimate that takes into account license renewal of PVNGS 1, 2, 3 on April 21, 2011.
On March 30, 2011, APS provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required. The cost estimate also had year-to-year expenses but was in 2007 dollars. Also, APS indicated that the 2010 cost estimate had not been approved yet by the time of the submittal of the DFS report.
As required under 10 CFR 50.75(e)(1)(i) and (ii), while providing the site-specific cost estimate in relation to the costs, the licensee must provide the site-specific cost estimate in current year dollars of the most current year.
RAI 4: Decommissioning costs timeframe inconsistencies:
Clarify the inconsistencies in decommissioning costs timeframes presented by each of the licensees.
On March 30, 2011, APS provided a site-specific cost estimate for the decommissioning of PVNGS 1, 2, and 3 for immediate decommissioning. In the DFS report, each licensee provided the following timeframes for expected costs during decommissioning.
APS:
Decommissioning costs until 2037 for PVNGS 1, 2, and 3.
SRP:
Decommissioning costs until 2037 for PVNGS 1, 2, and 3.
EPE:
Decommissioning costs until 2031 for PVNGS 1, 2033 for PVNGS 2, and 2035 for PVNGS 3.
SCE:
Decommissioning costs until 2031 for PVNGS 1, 2033 for PVNGS 2, and 2034 for PVNGS 3.
PNM:
Decommissioning costs until 2037 for PVNGS 1, 2, and 3.
SCPPA:
Decommissioning costs until 2025 for PVNGS 1, 2026 for PVNGS 2, and 2027 for PVNGS 3.
LADWP:
Decommissioning costs until 2025 for PVNGS 1, 2026 for PVNGS 2, and 2027 for PVNGS 3.
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.
RAI #5: Contributions to trust funds:
Provide clarification in relation to the annual contributions of SCPPA and LADWP decommissioning trust funds.
On March 30, 2011, APS provided the PVNGS 1, 2, 3, DFS report where each licensee listed their annual contributions to their respective trust funds. However, SCPPA indicated negative contributions of $4,046,138 per year until 2020, $2,475,754 in 2021, and $1,176,842 in 2022.
Also, LADWP indicated negative contributions of $1,368,422 per year until 2020, $450,596 in 2021, and $76,366 in 2022.
As stated under 10 CFR 50.75(h)(1)(iv):
Except for withdrawals being made under §50.82(a)(8) or for payments of ordinary administrative costs (including taxes) and other incidental expenses of the fund [. . .] in connection with operation of the fund, no disbursement or payment may be made from the trust. . .
