ML13154A483

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Rai'S Following Ifib Analysis of Ap'S 2013 Decommissioning Funding Status Report for Palo Verde Units 1, 2 and 3
ML13154A483
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 06/04/2013
From: Christopher Regan
Division of Inspection and Regional Support
To: Markley M
Plant Licensing Branch IV
Richard Turtil
References
Download: ML13154A483 (4)


Text

June 4, 2013 MEMORANDUM TO: Michael Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Christopher M. Regan, Chief /RA/

Financial Analysis and International Projects Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation

SUBJECT:

ARIZONA PUBLIC SERVICE COMPANY - 2013 DECOMMISSIONING FUNDING STATUS REPORTS - REQUEST FOR ADDITIONAL INFORMATION Enclosed is the subject Request for Additional Information (RAI) for Arizona Public Service Company (APS) for Palo Verde Nuclear Generating Station Units 1, 2, and 3, 2013 Decommissioning Funding Status (DFS) reports, from the Financial Analysis and International Projects Branch (IFIB). IFIB staff requests that the RAI be issued to the licensee with a response to be provided 30 days from issuance.

Enclosure:

As stated CONTACT: Richard H. Turtil, NRR/DIRS 301-415-2308

ML13154A483 OFFICE: NRR/DIRS/IFIB NRR/DIRS/IFIB: BC NAME: RTurtil CRegan DATE: 6/3/13 6/4/13 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2013 DECOMMISSIONING FUNDING STATUS REPORT FOR ARIZONA PUBLIC SERVICE COMPANY (APS) PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2, AND 3 (PVNGS 1, 2 and 3)

The requests for additional information (RAIs) provided are in response to APSs 2013 Decommissioning Funding Status (DFS) report. On March 29, 2013, APS submitted to the Nuclear Regulatory Commission (NRC) the 2013 Decommissioning Funding Status (DFS) report for PVNGS 1, 2, and 3 (see ML13098A033) as required under 10 CFR 50.75(f)(1). The NRC staff has reviewed the information provided in the submittal and determined that the following additional information is required in order to complete its review. APS should provide a response within 30 days from the date of this letter.

RAI #1 for PVNGS 1, 2, and 3: Amounts accumulated Indicate if the amount of decommissioning funds identified in the March 29, 2013, submittal are for the after-tax amounts of decommissioning funds accumulated through December 31, 2012.

If not, please provide the after-tax amounts of decommissioning funds accumulated through December 31, 2012, for PVNGS 1, 2, and 3.

On March 29, 2013, APS reported the amounts of decommissioning funds accumulated as of December 31, 2012, for PVNGS Units 1, 2, and 3, but did not indicate if the amounts stated were the before or after-tax balances.

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.

RAI #2 for PVNGS 1, 2, and 3: Citation for Site-Specific Study Provide the site-specific decommissioning cost estimate for PVNGS 1, 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 decommissioning cost estimate should include a summary schedule of annual expenses, projected earnings, end-of-year fund balances, expressed in 2012 dollars, and cost escalation factors with associated basis for the factors. Pursuant to 10 CFR 50.75(b), the cost estimate shall be in an amount that may be more, but not less, than the amount estimated to be required under 10 CFR 50.75(b) and (c).

On March 29, 2013, APS provided to the NRC site-specific decommissioning cost estimate values for the amount of decommissioning funds, in 2010 dollars, that it states, come from the

2010 Decommissioning Cost Study, Appendix C. APS did not include the cost escalation factor(s) that would be used to escalate the site-specific cost estimate to 2012 dollars.

Per 10 CFR 50.75(d)(2)(iii), the licensee is to provide a description of the means of adjusting the cost estimate and associated funding level over the life of the facility. And 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.