HBL-21-003, Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3
| ML21088A435 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 03/29/2021 |
| From: | Zawalick M Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| HBL-21-003 | |
| Download: ML21088A435 (10) | |
Text
Maureen R. Zawalick Vice President Generation Business and Technical Services Diablo Canyon Power Plant Mail code 104/6/608 P.O. Box 56 Avila Beach, CA 93424 805.545.4242 Internal: 691.4242 10 CFR 50.75(f) 10 CFR 50.82(a)(8)(v) 10 CFR 50.82(a)(8)(vii)
March 29, 2021 PG&E Letter HBL-21-003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-133, DPR-7 Humboldt Bay Power Plant, Unit 3 Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3
References:
- 1. PG&E Letter HBL-20-006, Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3, dated March 30, 2020 (ML20090E248)
- 2. PG&E Letter HBL-19-007, Decommissioning Funding Report for Humboldt Bay Power Plant, Unit 3, dated March 28, 2019 (ML19087A094)
Dear Commissioners and Staff:
Pacific Gas and Electric Company (PG&E) is submitting the decommissioning funding report for Humboldt Bay Power Plant (HBPP), Unit 3, pursuant to the requirements of 10 CFR 50.75(f), 10 CFR 50.82(a)(8)(v), and 10 CFR 50.82(a)(8)(vii).
Humboldt Bay Power Plant, Unit 3 PG&E has spent $802.8 million on NRC radiological decommissioning activities through December 2020. At the end of calendar year 2020, the market value of the HBPP Unit 3 (220 MWt) decommissioning trust fund was $170.1 million. PG&E estimates that $4.0 million will be needed to complete the NRC radiological scope.
PG&E estimates it will need to collect an additional $11.4 million over two years, beginning in 2021, based on a site-specific decommissioning cost estimate prepared by PG&E staff and submitted to the California Public Utilities Commission's (CPUC)
Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) on December 13, 2018 for radiological decommissioning, site restoration, and spent fuel management.
The cost estimate in the 2018 NDCTP application is based on actual bids for remaining HBPP civil work scope and includes final site restoration, final site m
PacHic Gas and Electric Company*
PG&E Letter HBL-21-003 Document Control Desk March 29, 2021 Page 2 surveys, and spent fuel management costs associated with the delay in the Department of Energy's acceptance of site-stored spent fuel, cost to remediate site radioactivity to resident farmer criteria, and updated remaining decommissioning costs based on actual past HBPP decommissioning data versus industry estimates.
The NRC minimum decommissioning estimate is $465.3 million (2021 dollars) that was calculated pursuant to the requirements specified in 10 CFR 50.75(c), which is based on a minimum 1200 MWt plant that has not started decommissioning activities. HBPP is approximately 99.5 percent complete with the radiological decommissioning scope of work and has withdrawn funds through 2020 from the HBPP trust resulting in a current market value lower than the NRC minimum estimate.
The HBPP trust has sufficient funds to complete radiological decommissioning.
PG&E is confident that the HBPP trust, with the noted additional contributions, will be sufficient to maintain the spent fuel in an independent spent fuel storage installation at HBPP until 2033, based on the December 2018 site-specific decommissioning cost estimate prepared by PG&E staff.
Supporting Cost Estimates Based on a December 2018 site-specific cost estimate prepared by PG&E staff and submitted to the NRC in Enclosure 5 of Reference 2, PG&E estimates that the total HBPP decommissioning costs are approximately $1,141.1 million (including
$802.8 million disbursed from the Trust(s) for radiological decommissioning costs through December 2020 and $4.0 million future radiological decommissioning costs) for HBPP, Unit 3, in 2021 dollars. These NRC decommissioning costs do not include Non-NRC site restoration ($68.2 million) or spent fuel management until 2033 ($266.2 million). To assure that sufficient funds will be available for decommissioning, PG&E established external sinking trust fund accounts for HBPP, Unit 3.
Supporting Enclosures provides decommissioning funding status information in a format suggested by Nuclear Energy Institute (NEI) and the NRC. is a cash flow of the total decommissioning of HBPP that identifies the monies for NRC scope (removal of radiological contamination), site restoration (including the non-radiological work), and the spent fuel management. contains the variance of the 2020 forecast of $24.5 million, as submitted in Enclosure 3 of Reference 1.
PG&E Letter HBL-21-003 Document Control Desk March 29, 2021 Page 3 PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.
Should you have any questions, please contact Mr. Philippe Soenen at (805) 459-3701.
Sincerely, Maureen R. Zawalick Vice President Generation, Business and Technical Services Enclosures cc: HBPP Humboldt Distribution cc/enc: Amy M. Snyder, NRC Project Manager Scott A. Morris, NRC Region IV Administrator INPO PG&E Letter HBL-21-003 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant - Unit 3 (220 MWt)
PG&E Letter HBL-21-003 Page 1 of 2 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant - Unit 3 (220 MWt)
As provided in 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning March 31, 1999, and annually thereafter, on the status of its decommissioning funding for each reactor that it owns and has already closed.
Note that Items 3 and 8 are data included in PG&Es Nuclear Decommissioning Cost Triennial Proceeding filed with the California Public Utilities Commission (CPUC) on December 13, 2018, which includes radiological decommissioning, site restoration and spent fuel management costs. The CPUC has extended the deadline for a decision to September 13, 2021.
- 1. The minimum decommissioning fund estimate,
$ in Millions pursuant to 10 CFR 50.75(b) and (c).1 January 2021 dollars
$ 465.3 (Humboldt Bay Power Plant is a shutdown unit with a Site-Specific Cost Study; therefore, the minimum decommissioning fund estimate is based on the Site-Specific Cost Study shown in Item 8 of this enclosure.)
- 2. The amount accumulated at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75(b) and (c). (Alternatively, the total amount accumulated at the end of the calendar year preceding the date of the report can be reported here if the cover letter transmitting the report provides the total estimate and indicates what portion of that estimate is for items not included in 10 CFR 50.75(b) and (c)).
Market Value (December 2020 dollars)
$ 170.1
- 3. A schedule of the annual amounts remaining to be collected; for items in 10 CFR 50.75(b) and (c). (Alternatively, the annual amounts remaining to be collected can include items beyond those required in 10 CFR 50.75(b) and (c) if the cover letter transmitting the report provides a total cost estimate and indicates what portion of that estimate is for items that are not included in 10 CFR 50.75(b) and (c).
Amount remaining
$ 11.4 2 Number of years to collect 2021-2022 2 years 2020-2022 Annual amount to be collected
$ 3.791 1 The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in the NRC decommissioning cost estimates. The costs of managing and storing spent fuel on site until transfers to Department of Energy are not included in the cost formulas.
2
- As a result of the pending CPUC decision, no contributions were made in 2020. After a CPUC decision, a true-up contribution for the 2020 approved amount plus the 2021 amount will be made.
PG&E Letter HBL-21-003 Page 2 of 2
- 4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds (assumes trust will be gradually converted to a more conservative, all fixed income portfolio over time), and rates of other factors used in funding projections.
Escalation in decommissioning costs Rate of Return 2021 2.96 percent Escalation in decommissioning costs Rate of Return 2022 2.77 percent Escalation in decommissioning costs Rate of Return 2023 2.59 percent Escalation in decommissioning costs Rate of Return 2024 2.28 percent Escalation in decommissioning costs Rate of Return 2025 2.03 percent Escalation in decommissioning costs Rate of Return 2026 1.72 percent Escalation in decommissioning costs Rate of Return 2027 1.48 percent Escalation in decommissioning costs Rate of Return 2028 1.23 percent Escalation in decommissioning costs Rate of Return 2029 0.98 percent Escalation in decommissioning costs Rate of Return 2030 0.86 percent Escalation in decommissioning costs Rate of Return 2031-2033 0.74 percent
- 5. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).
None
- 6. Any modifications to a licensees current method providing financial assurance occurring since the last submitted report.
None
- 7. Any material changes to trust agreements.
None
- 8. CPUC Submittal in 2021 Dollars in Millions:
Total Project (Decommission $2021)
$ 1,141.1 Scope Excluded from NRC calculations
$ 68.2 Scope of Independent Spent Fuel Storage Installation from Licensing to Decommissioning in 2033
$ 266.2 NRC Scope Decommissioned and disbursed from Trust(s)
$ 802.8 Total NRC Decommissioning Remaining Scope
$ 4.0 PG&E Letter HBL-21-003 Humboldt Bay Power Plant Decommissioning Cash Flow (1 page)
PG&E Letter HBL-21-003 Nominal/2021$ Dollars Year NRC NON - NRC SPENT FUEL MANAGEMENT TOTAL Cumulative Decommission Estimate 1996
$1,678,452
$1,678,452
$1,678,452 1997
$8,663,216
$8,663,216
$10,341,668 1998
$5,573,757
$344,408
$5,918,165
$16,259,833 1999
$723,490
$2,281,454
$3,004,944
$19,264,777 2000
$85,241
$2,736,091
$2,821,332
$22,086,109 2001
$89,543
$398,012
$487,555
$22,573,664 2002
$994,127
$113,704
$1,107,831
$23,681,495 2003
$494,838
$2,539,476
$3,034,314
$26,715,809 2004
$491,070
$1,444,628
$1,935,698
$28,651,507 2005
$161,506
$1,671,769
$1,833,275
$30,484,782 2006
$1,073,612
$3,546,617
$4,620,229
$35,105,011 2007
$4,474,247
$9,240,172
$13,714,419
$48,819,430 2008
$12,590,383
$28,485,988
$41,076,371
$89,895,801 2009
$32,901,391
$3,179,956
$36,081,347
$125,977,148 2010
$56,957,494
$5,734,776
$62,692,270
$188,669,418 2011
$60,585,531
$5,495,157
$66,080,688
$254,750,106 2012
$81,577,560
$4,509,009
$86,086,569
$340,836,675 2013
$93,946,862
$4,668,626
$98,615,488
$439,452,163 2014
$79,506,972
$5,085,456
$84,592,428
$524,044,590 2015
$106,846,880
$5,853,718
$112,700,598
$636,745,188 2016
$106,532,076
$619,888
$5,768,725
$112,920,689
$749,665,877 2017
$89,781,415
$7,100,443
$7,141,755
$104,023,613
$853,689,490 2018
$41,848,597
$24,115,759
$7,606,854
$73,571,210
$927,260,701 2019
$8,106,458
$13,642,923
$7,291,458
$29,040,838
$956,301,539 2020
$7,073,340
$9,236,127
$16,309,468
$972,611,006
$972,611,006 Actual 2021
$3,988,464
$10,018,605
$14,007,070
$986,618,076 170,095,127 2020 Marker Value 2022
$0
$17,473,019
$17,473,019
$1,004,091,095 2023
$0
$17,280,561
$17,280,561
$1,021,371,656 2024
$0
$15,749,683
$15,749,683
$1,037,121,339 2025
$0
$15,749,683
$15,749,683
$1,052,871,022 2026
$0
$10,771,813
$10,771,813
$1,063,642,835 2027
$0
$9,230,968
$9,230,968
$1,072,873,803 2028
$0
$9,190,741
$9,190,741
$1,082,064,545 2029
$0
$9,190,741
$9,190,741
$1,091,255,286 2030
$0
$9,190,741
$9,190,741
$1,100,446,027 2031
$0
$836,272
$8,392,540
$9,228,812
$1,109,674,839 2032
$0 5,203,482
$8,236,093
$13,439,575
$1,123,114,414 2033
$0
$16,698,513
$1,321,021
$18,019,535
$1,141,133,949
$1,142,706,133 Actual + Market Value TOTAL
$806,746,522
$68,217,281
$266,170,146
$1,141,133,949 1) 2)
3)
Totals may not balance due to rounding.
Humboldt Bay Power Plant Decommissioning Cash Flow1 Cash Flow is based on construction of ISFSI and Fuel removed from HBPP in 2033 (Assumes DOE Used Fuel Repository opens in 2031 allowing for HBPP Fuel to be shipped during 2031-2032 and Final Site Restoration in 2033).
Market Value of Trust as of 12/2020 was $170.1 million, actual expended as of 12/2020 was $972.6 Million 1 of 1 PG&E Letter HBL-21-003 Variance of the 2020 Forecast PG&E Letter HBL-21-003 Page 1 of 1 Estimated Costs:
Forecast of 2020 per PG&E Letter HBL-20-006, Enclosure 3, dated March 30, 2020, in 2020 dollars:
NRC Scope (Radiological)
$ 10,155,794 Non-NRC Scope
$ 0 Spent Fuel Management
$ 14,399,155 Actual Costs:
Actual 2020 Incurred Costs, provided in Enclosure 3 of this letter, reflects the actuals for 2020 in nominal dollars.
NRC Scope (Radiological)
$ 7,073,340 Non-NRC Scope
$ 0 Spent Fuel Management
$ 9,236,127 Variance: (Favorable)
NRC Scope (Radiological)
$ 3,082,454 Non-NRC Scope
$ 0 Spent Fuel Management
$ 5,163,028 Decommissioning costs were underspent in 2020 primarily due to some of the Final Site Survey reports to the NRC pushing into 2021. Spent Fuel Management also delayed work on infrastructure upgrades that were planned in 2020 due to Covid-19 response.