ML19261A095

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NRC-2019-000288 - Resp 1 - Final
ML19261A095
Person / Time
Site: Palo Verde, San Onofre  Southern California Edison icon.png
Issue date: 09/12/2019
From: Stephanie Blaney
Information Services Branch
To: Akerson S
Public Watchdogs
Shared Package
ML19261A098 List:
References
FOIA, NRC-2019-000288
Download: ML19261A095 (2)


Text

NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER (06-2019)

RESPONSE TO FREEDOM OF 2019-000288 1 INFORMATION ACT (FOIA) REQUEST RESPONSE TYPE INTERIM FINAL REQUESTER: DATE:

Sarah Akerson 09/12/2019 DESCRIPTION OF REQUESTED RECORDS:

Any and all financial audits performed on the San Onofre Nuclear Generating Station (SONGS) Decommissioning Trust Fund (DTF). This DTF includes two separate DTFs, a Qualified Trust Fund and a Non-Qualified Trust fund, both of which include decommissioning funds for SONGS and for the Palo Verde Nuclear Generating Station (PVNGS).

PART I. -- INFORMATION RELEASED The NRC has made some, or all, of the requested records publicly available through one or more of the following means: (1) https://

www.nrc.gov ; (2) public ADAMS, https://www.nrc.gov/reading-rm/adams.html; (3) microfiche available in the NRC Public Document Room; or FOIA Online, https://foiaonline.gov/foiaonline/action/public/home.

Agency records subject to the request are enclosed.

Records subject to the request that contain information originated by or of interest to another Federal agency have been referred to that agency (See Part I.D -- Comments) for a disclosure determination and direct response to you.

We are continuing to process your request.

See Part I.D -- Comments.

PART I.A -- FEES You will be billed by NRC for the amount indicated. Since the minimum fee threshold was not met, AMOUNT you will not be charged fees.

You will receive a refund for the amount indicated.

Due to our delayed response, you will not be Fees waived. charged search and/or duplication fees that would otherwise be applicable to your request.

PART I.B -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE We did not locate any agency records responsive to your request. Note: Agencies may treat three discrete categories of law enforcement and national security records as not subject to the FOIA ("exclusions"). See 5 U.S.C. 552(c). This is a standard notification given to all requesters; it should not be taken to mean that any excluded records do, or do not, exist.

We have withheld certain information pursuant to the FOIA exemptions described, and for the reasons stated, in Part II.

Because this is an interim response to your request, you may not appeal at this time. We will notify you of your right to appeal any of the responses we have issued in response to your request when we issue our final determination.

You may appeal this final determination within 90 calendar days of the date of this response. If you submit an appeal by mail, address it to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Mail Stop T-6 A60M, Washington, D.C. 20555-0001. You may submit an appeal by e-mail to FOIA.resource@nrc.gov. You may fax an appeal to (301) 415-5130. Please be sure to include on your submission that it is a FOIA Appeal. Only a pre-registered user may file an appeal through FOIA Online, https://

foiaonline.gov/foiaonline/action/public/home. A user who has not registered an account prior to filing the initial FOIA request may still submit their appeal by one of the above mentioned options.

PART I.C -- REFERENCES AND POINTS OF CONTACT You have the right to seek assistance from the NRC's FOIA Public Liaison by submitting your inquiry at https://www.nrc.gov/reading-rm/

foia/contact-foia.html, or by calling the FOIA Public Liaison at (301) 415-1276.

If we have denied your request, you have the right to seek dispute resolution services from the NRC's Public Liaison or the Office of Government Information Services (OGIS). To seek dispute resolution services from OGIS, you may e-mail OGIS at ogis@nara.gov, send a fax to (202) 741-5789, or send a letter to: Office of Government Information Services, National Archives and Records Administration, 8601 Adelphi Road, College Park, MD 20740-6001. For additional information about OGIS, please visit the OGIS website at https://www.archives.gov/ogis.

NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION NRC RESPONSE NUMBER (06-2019)

RESPONSE TO FREEDOM OF 2019-000288 1 INFORMATION ACT (FOIA) REQUEST RESPONSE TYPE INTERIM FINAL PART I.D -- COMMENTS We reached out to the offices of Nuclear Reactor Regulation (NRR), Region IV (RIV), and Nuclear Material Safety &

Safeguards (NMSS) to search for any records responsive to your request. While NRC does not conduct financial audits of licensees, the NRC does conduct timely and independent analyses of reports required by 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning, and 10 CFR 50.82, Termination of license, on the status of decommissioning funding for each power reactor (operating or in decommissioning). Enclosed is a listing of all the reports and related records that are maintained in NRC's Agency-wide Documents Access and Management System (ADAMS). We have also enclosed additional records that are not maintained in ADAMS.

You may wish to refer to the above-referenced regulations, as well as LIC-205 Revision 6 (April 10, 2017) (ML17075A086),

which describes the financial assurance process that licensees and NRC staff undertake. NRR staff also provided us with the following summary of this process:

NRC regulations require a licensee to submit a site-specific decommissioning cost estimate (SSCE),

which encompasses all estimated costs required for decommissioning. When determining the reasonableness of the SSCE, the NRC typically relies on cost comparisons to projects of similar scope, both completed and proposed, and to the NRC minimum for radiological decommissioning.

After permanent cessation of operations and until radiological decommissioning is complete, licensees are required to submit decommissioning funding status reports on an annual basis and certify to the decommissioning cost estimate. Ultimately, through its independent review of this information, the NRC seeks to find that licensees have provided reasonable assurance that they have or will have funding greater than or equal to the certified amount estimated to be needed for radiological decommissioning.

As part of the decommissioning funding status oversight, staff reviews prior-year and cumulative decommissioning expenditures, as well as the remaining estimated decommissioning cost, reflecting any differences between actual and estimated costs for the prior year. As appropriate, the staff has the ability to request additional information to clarify the data provided in the report. Ultimately, it is the licensees responsibility to complete the decommissioning process in accordance with NRC regulations.

Signature - Freedom of Information Act Officer or Designee Stephanie A. Blaney Digitally signed by Stephanie A. Blaney Date: 2019.09.12 13:13:37 -04'00'