ML112070175
| ML112070175 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 07/22/2011 |
| From: | Xcel Energy, Northern States Power Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML112070189 | List: |
| References | |
| L-XE-11-011 | |
| Download: ML112070175 (5) | |
Text
ENCLOSURE 1 RAI#1: Minimum Decommissioning Funding Assurance Calculation Provide the labor, energy, and burial factors used in your calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS [Decommissioning Funding Status] report.
In its March 28, 2011, submittal, for PINGP [Prairie Island Nuclear Generating Plant] Unit 1 Xcel Energy 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.
In its March 28, 2011, submittal for PINGP Unit 2 Xcel Energy reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) greater than the amount calculated by the NRC staff.
In its March 28, 2011, submittal for Monticello, Xcel Energy 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)".
NSPM Response:
The following table provides the corrected minimum decommissioning fund estimates, pursuant to 10CFR 50.75 (b) and (c) in 2010 dollars in Enclosure 1, 2, and 3 for the respective item 1 of the March 28, 2011 submittal.
Plant 1986 Minimum Escalation 2010 Minimum Calculation Calculation Rate Using Blended Burial for Item 1 Prairie Island 1 89,757,600 4.4998 403,893,103 Prairie Island 2 89,757,600 4.4998 403,893,103 Monticello 119,975,000 4.5643 547,601,510 See Enclosure 2 of this letter for the specific factors that were input to derive the calculations. The calculations presented in Enclosure 2 are based on the guidance in NUREG-1307 Rev.14.
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RAI#2: Amount Accumulated
- a. Provide an explanation of the external qualified, external escrow, and internal accumulations of funds identified in Enclosures 1, 2, and 3 of the submittal. The explanation should include a discussion of how each accumulation meets the methods of 10 CFR 50. 75(e)(1). The explanation should include relevant information of how your rate-regulator authorizes their use in your cost recovery authorization.
- b. Provide whether the "External Escrow" is a modification in the method of providing decommissioning funding assurance since the last report.
- c. On page 3 of the 2009 submittal, it is stated, "The internal fund is being transferred to the external fund on a prescribed schedule." Your 2011 submittal does not include a similar statement. Explain whether a prescribed schedule is still in use and identify whether the schedule is required by your rate-regulatory authority.
- d. Provide the actual dates of the account balances in Enclosure 4 of the submittal. Provide an explanation for the difference in terminology between and Enclosure 4.
On March 28, 2011, Xcel Energy reported three separate accumulations of funds for the amount accumulated at the end of the calendar year preceding the date of the report for PINGP Units 1 and 2 and MNGP. Xcel Energy provided the amounts held in the external qualified, external escrow, and internal accumulation of funds for each plant.
According to 10 CFR 50. 75(f)(1),
The information in this report must include ... the amount accumulated to the end of the calendar year preceding the date of the report.
According to 10 CFR 50.75(e)(1)(ii), "External sinking fund",
An external sinking fund is a fund established and maintained by setting funds aside periodically in an account segregated from licensee assets and outside the administrative control of the licensee and its subsidiaries or affiliates in which the total amount of funds would be sufficient to pay decommissioning costs at the time permanent termination of operations is expected. An external sinking fund may be in the form of a trust, escrow account, or Government fund, with payment by certificate of deposit, deposit of Government or other securities, or other method acceptable to the NRC.
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NSPM Response:
- a. The external qualified fund is a trust fund established by Northern States Power Company - a Minnesota corporation (NSPM), d/b/a Xcel Energy to meet the requirements of 10 CFR 50.75 (e)(1), which requires NSPM to set aside funds, segregated from NSPM assets, in order to meet future decommissioning cost needs. This fund is a standard NRC structured trust fund, as the funds are reserved exclusively for decommissioning related costs and cannot be withdrawn for any other purposes until all decommissioning activities are completed. The external qualified trust fund has been authorized by the Minnesota Public Utilities Commission (MPUC) for use in collecting decommissioning funds since Docket No. E002/D-90-184 was issued in 1991. Any required funding into the external qualified fund occurs through general rates from customers.
The external escrow fund (described in Enclosure 3 of this letter) is a trust fund established by NSPM to supplement the external qualified fund in order to meet the funding requirements of 10 CFR 50.75 (e)(1). As with the external qualified fund, the monies in the external escrow fund have been set aside, separate from NSPM assets, in order to meet future decommissioning cost needs. The difference in this fund is that if it is determined by the MPUC that the funds are no longer needed to cover costs in the future, then the funds can be withdrawn to be refunded to customers. The external escrow fund was created in 2006 and was authorized by the MPUC under Docket No. E002/M-05-1648. From 2006 until 2010, all funding for decommissioning activities received from customers through general rates were paid into the external escrow fund. We have enclosed a copy of the Custody and Escrow Agreement (Enclosure 5), which regulates the relationship between NSPM and Mellon Bank, the bank serving as a custodian for the funds.
The internal fund is the remnant of the NSPMs internal decommissioning accruals, which was accumulated since 1983. The amount represents funds internally collected for a jurisdiction that no longer exists. The next triennial nuclear decommissioning filing is due to be filed with the MPUC in October 2011.
The end result for these funds will be determined after that filing is complete and it will be either transferred into one of the external funds or the accrual will be reversed.
- b. The external escrow fund is not a modification in NSPMs method of providing funding assurance. The external escrow fund has been used by the NSPM since 2006. NSPM presented the Escrow fund amount separately in the 2011 submittal in order to fully disclose the amount which is subject to possible refund to customers in the future should there be an excess of funds or will be poured over to the external qualified fund if there is no excess. Previously the external escrow amount was shown commingled with the external qualified amount.
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- c. See part a. The internal fund is related to a wholesale jurisdiction that no longer exists. The triennial nuclear decommissioning filing will determine what needs to be done with this wholesale jurisdiction internal fund.
- d. The trust fund balances shown in Enclosure 4 in NSPMs March 28, 2011 submittal are as of December 31, 2009 and December 31, 2010 respectively.
The balances shown in Enclosure 1 are a breakdown of the Radiological Decommissioning portion of all decommissioning funding into external qualified, external escrow, and internal components. Enclosure 4 shows the trust fund balances broken out into the three decommissioning components, and includes funds contained in the external qualified, external escrow, and internal fund.
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RAI #3: Amounts Accumulated Provide the after-tax amount of decommissioning funds accumulated through December 31, 2010. Verify whether the dollar amounts Xcel Energy provided were pre-tax or after-tax amounts of funds accumulated through December 31, 2010, for PINGP Units 1 and 2 and Monticello.
The provisions of 10 CFR 50 75(f)(1) and (2) require the licensee to report the amount of funds accumulated to the end of the calendar year preceding the report.
NSPM Response:
A Mellon Bank report is included (Enclosure 4 of this submittal) that shows tax payments that were made in 2010. A summary worksheet has been provided to sum up the cash payments for taxes for the total qualified fund that were withdrawn from accounts within the fund. Taxes are calculated for the qualified fund as a whole and the tax payment is made from whatever accounts had generated cash proceeds to cover the payment. Thus not all accounts will show cash outlays for taxes paid during the year.
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