ML23094A127
| ML23094A127 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/29/2023 |
| From: | Bates A Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML23094A127 (1) | |
Text
SOUTHERN CALIFORNIA EDISON~
An RDISON INTERNATIONAi, Company ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 March 29, 2023
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 10 CFR 50.82(a)(8}(v and vii) and 10 CFR 72.30(c)
Decommissioning Funding Status Report 2021 San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation
Dear Sir or Madam:
Al Bates Manager, Regulatory Affairs 10 CFR 50.82 10 CFR 72.30 As required by 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vii), and 10 CFR 72.30(c), this letter provides the status of the decommissioning funding for San Onofre Nuclear Generating Station (San Onofre) Units 1, 2, and 3 and the San Onofre Independent Spent Fuel Storage Installation (ISFSI) as of December 31, 2022.
Based on the requirements in 10 CFR 50.82(a)(8)(v) and 10 CFR 50.82(a)(8)(vii), this information is reported on an annual basis for SONGS Units 1, 2, and 3 because the units were permanently shut down and site-specific decommissioning cost estimates (DCEs) have been submitted for each of these units. In addition, based on the requirements in 10 CFR 72.30(c),
information demonstrating the adequacy of funding for the San Onofre ISFSI is reported at intervals not to exceed three years, and is included. The required information for Southern California Edison, San Diego Gas & Electric, the City of Anaheim, and the City of Riverside is provided in the Enclosure.
There are no commitments contained in this letter or its enclosure.
If you have any questions regarding this matter, please contact me at (949) 368-7024.
Enclosure:
San Onofre Nuclear Generating Station Units 1, 2, and 3 and ISFSI Decommissioning Funding Status Report for Calendar Year 2022 cc: R. J. Lewis, Regional Administrator, NRC Region IV A. M. Snyder, NRC Project Manager, San Onofre Units 1, 2, and 3
Enclosure San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)
Decommissioning Funding Status Report for Calendar Year 2022
San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)
Decommissioning Funding Status Report For Calendar Year 2022 San Onofre Unit 1 was a pressurized water reactor (PWR) rated at 1347 MWt. San Onofre Units 2and 3 were PWRs rated at 3438 MWt. Provided below is the information required by 10 CFR 50.82(a)(8)(v) and (vii) for San Onofre Units 1, 2, and 3; and the information required by 10 CFR 72.30(b) for the San Onofre ISFSI. This information is reported every year for San Onofre Units 1, 2, and 3 because they are permanently shut down and site-specific decommissioning cost estimates (DCEs) have been submitted for them.
The San Onofre ISFSI is located on the partially decommissioned site of San Onofre Unit 1 and is operated under a 10 CFR 72 General License issued to the holders of a 10 CFR 50 license.
The decommissioning liability is shared between the current owners and former owner, Anaheim, as set forth below for each unit:
Unit 1 Unit2 Unit3 Owner Decommissioning Decommissioning Decommissioning Liability Liability Liability SCE 80.00%
75.7363%
75.7475%
SDG&E 20.00%
20.0000%
20.0000%
Anaheim 0.00%
2.4737%
2.4625%
Riverside 0.00%
1.7900%
1.7900%
All dollar amounts are in 100% share, 2022 dollars.
- 1)
The estimated costs to decommission San Onofre Units 1, 2, and 3, and the San Onofre ISFSI, including all decommissioning and spent fuel storage costs estimated to be required pursuant to 10 CFR 50.75(b) and (c); 10 CFR 50.54(bb);
and 10 CFR 72.30(b) are shown below:
1
The site-specific estimates for decommissioning include the following radiological decommissioning costs associated with terminating the site license pursuant to 10 CFR 50.75(b); non-radiological site restoration costs; spent fuel storage costs pursuant to 10 CFR 50.54(bb); and ISFSI decommissioning costs pursuant to 10 CFR 72.30(b):
Estimate of License Termination Costs Less: Lie. Term. Costs during 2016-2022 "To Go" License Termination Costs Estimate of Fuel Storage Costs Less: Fuel Stor. Costs during 2016-2022 "To Go" Fuel Storage Costs Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs Less: Site Restor. Costs during 2016-2022 "To Go" Site Restoration Costs Total Unit 1 "To Go" Costs as of 1/1/2023 Estimate of License Termination Costs Less: Lie. Term. Costs through 12/31/2022 "To Go" License Termination Costs Estimate of Fuel Storage Costs Less: Fuel Stor. Costs through 12/31/2022 "To Go" Fuel Storage Costs Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs Less: Site Restor. Costs through 12/31/2022 "To Go" Site Restoration Costs Total Unit 2 "To Go" Costs as of 1/1/2023 2
San Onofre Unit 1 <1>
88.1 million 52.0 million 36.1 million 54.3 million 6.8 million 47.5 million 6.6 million 131.0 million (0.3} million<6>
131.3 million 221.5 million San Onofre Unit 2<2>
$ 1,290.9 million
$ 762.8 million 528.1 million 898.6 million
$ 497. 7 million 400.9 million 22.5 million 599.8 million 146.7 million 453.1 million
$ 1,404.6 million
Estimate of License Termination Costs Less: Lie. Term. Costs through 12/31/2022 "To Go" License Termination Costs San Onofre Unit 3(2)
$ 1,280.7 million 753. 7 million 527.0 million Estimate of Fuel Storage Costs 925.2 million Less: Fuel Stor. Costs through 12/31/2022 "To Go" Fuel Storage Costs 495.4 million 429.8 million Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs 23.9 million 860.6 million 196.8 million 663.8 million Less: Site Restor. Costs through 12/31/2022 "To Go" Site Restoration Costs Total Unit 3 'To Go" Costs as of 1/1/2023
$ 1,644.5 million The site-specific decommissioning cost estimates for San Onofre Units 1, 2, and 3 and the San Onofre ISFSI include: (1) the cost to perform all decommissioning activities; (2) the cost of meeting the 10 CFR 20.1402 radiological criteria for unrestricted site use; and (3) adequate contingency factors for all costs.
- 2)
Each San Onofre co-owner has established one or more external sinking trust fund accounts as provided in 10 CFR 50.75(e)(1)(ii) for their respective shares of the San Onofre Units 1, 2, and 3 decommissioning obligation, which also includes the San Onofre ISFSI. The Decommissioning Trust Fund amounts remaining at the end of calendar year 2022 (net of pending Trust Fund withdrawals and estimated capital gains taxes) are:(3)(4)(5)
Co-Owner SCE SDG&E (5>
Anaheim (5>
Riverside (5)
TOTAL San Onofre Unit 1
$ 294.3 million
$ 139.1 million N/A NIA
$ 433.4 million San Onofre Unit 2 886.8 million
$
- 300.9 million 41.8 million 22.4 million
$ 1,251.9 million San Onofre Unit 3
$ 1,098.1 million 359.3 million 42.3 million 26.4 million
$ 1,526.1 million
- 3)
Each San Onofre co-owner deposits its decommissioning fund contributions into their respective external sinking fund accounts as provided in 1 O CFR 50.75(e)(1)(ii). The annual amounts projected to be collected in 2023 are:
Co-Owner SCE SDG&E (5l Anaheim (5)
Riverside (5)
TOTAL San Onofre Unit 1
$ 0.0 million
$ 0.0 million N/A N/A
$ 0.0 million 3
San Onofre Unit 2 San Onofre Unit 3 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million 0.0 million
- 4)
The amounts spent on San Onofre Units 1, 2, and 3 decommissioning work performed during 2022 are summarized below:
Cost Category San Onofre Unit 1 San Onofre Unit 2 94.8 million San Onofre Unit 3 96.4 million License Term.
Spent Fuel Storage$
ISFSI Decom.
Site Restoration TOTAL 0.8 million<6>
1.5 million 0.0 million 0.2 million<6>
2.5 million 17.8 million 14.7 million 0.0 million 0.0 million 9.7 million 12.4 million
$ 122.3 million
$ 123.5 million
- 5)
The composite escalation rate and after-tax investment rates of return for San Onofre Units 1, 2, and 3 Decommissioning are summarized below:
Composite Rate Rate of Return Escalation Real Earnings Rate San Onofre Unit 1 4.25%
2.46%
1.79%
San Onofre Unit 2 4.49%
2.62%
1.87%
San Onofre Unit 3 4.49%
2.62%
1.87%
The composite investment rates of return less the composite escalation rates yield composite real earnings rates less than the 2% real rate of return allowed under 10 CFR 50.75{e){1){ii).
- 6)
None of the co-owners of San Onofre Units 1, 2, and 3 or the San Onofre ISFSI is relying on any contracts for the purposes of providing decommissioning funding pursuant to 10 CFR 50.75{e)(1)(v). There have been no modifications to the method of providing financial assurance.
- 7)
The amounts of decommissioning funds available as of December 31, 2022 for San Onofre Units 1, 2, and 3 License Termination, Site Restoration, Spent Fuel Management, and ISFSI Decommissioning costs are shown in the tables below:<4>
Estimated San Onofre Unit 1 aTo Go" 12/31/2022 Decommissioning Net Trust Balance Cost License Termination Costs 36.1 million 36.1 million Spent Fuel Management Costs 47.5 million 47.5 million ISFSI Decommissioning Costs I
6.6 million I
6.6 million Subtotal: NRC-Required Costs 90.2 million 90.2 million Site Restoration Costs i
131.3 million i
343.2 million TOTAL 221.5 million 433.4 million 4
San Onofre Unit 2 License Termination Costs Spent Fuel Management Costs ISFSI Decommissioning Costs Subtotal: NRG-Required Costs Site Restoration Costs TOTAL(8>
San Onofre Unit 3 License Termination Costs Spent Fuel Management Costs ISFSI Decommissioning Costs Subtotal: NRG-Required ~osts Site Restoration Costs TOTAL(8>
Estimated "To Go" Decommissioning Cost 528.1 million 400.9 million 22.5 million 951.5 million 453.1 million
$ 1,404.6 million Estimated "To Go" Decommissioning Cost 527.0 million 429.8 million 23.9 million 980. 7 million 663.8 million
$ 1,644.5 million 12/31/2022 Net Trust Balance 528.1 million 400.9 million 22.5 million 951.5 million 300.4 million
$ 1,251.9 million 12/31/2022 Net Trust Balance 527.0 million 429.8 million 23.9 million 980. 7 million 545.4 million
$ 1,526.1 million
- 8)
. Key assumptions pertaining to spent fuel storage and ISFSI decommissioning:
San Onofre Unit 1:
395 fuel assemblies in 17 canisters are located in the SONGS ISFSI 1 canister of Greater Than Class C (GTCC) waste is located in the ISFSI*
The U.S. Department of Energy (DOE) will commence transporting spent fuel assemblies in 2031(7>
DOE will remove last SONGS Unit 1 fuel from the ISFSI by 2037 San Onofre Unit 2:
1,726 fuel assemblies in 53 canisters are located in the ISFSI Greater than Class C (GTCC) waste is scheduled to be placed in the SONGS ISFSI during 2023 DOE will commence transporting spent fuel assemblies in 2031(7)
DOE will remove last SONGS Units 2&3 fuel from the ISFSI by 2051 5
San Onofre Unit 3:
1,734 fuel assemblies in 53 canisters are located in the ISFSI Greater than Class C (GTCC) waste is scheduled to be placed in the Notes:
SONGS ISFSI during 2023 DOE will commence transporting spent fuel assemblies in 2031(7)
DOE will remove last SONGS Units 2&3 fuel from the ISFSI by 2051 San Onofre ISFSI:
The San Onofre ISFSI will be decommissioned and the remaining plant and ISFSI site will be decontaminated to meet 10 CFR 20.1402 site release criteria for unrestricted use as required to terminate the Part 50 General License by 2053.
(1)
The current site-specific decommissioning cost estimate for San Onofre Unit 1 (SCE 2020 SONGS 1 DCE) that was submitted to the California Public Utilities Commission (CPUC) on February 28, 2022, includes the radiological costs associated with terminating the site license, site restoration costs, and fuel storage costs.
(2)
The current site-specific decommissioning cost estimate for San Onofre Units 2 and 3 (2020 SONGS 2&3 DCE) that was submitted to the CPUC on February 28, 2022 includes the radiological costs associated with terminating the site license, site restoration costs, and fuel storage costs.
(3)
During the period between June 7, 2013 and December 31, 2022, SCE incurred costs of $1,407.2 million for San Onofre Unit 2 and
$1,445.9 million for San Onofre Unit 3 (100% share, 2022 $).
(4)
Pursuant to 10 CFR 72.30(e)(5), power reactor licensees are authorized to use the financial assurance methods provided for in 10 CFR 50.75(e).
All four San Onofre co-owners recover the cost of decommissioning pursuant to cost-of-service rate regulation and, therefore, are eligible to provide assurance using the external sinking fund method provided for in 10 CFR 50.75(e)(1)(ii). To the extentthe decommissioning costs are fully funded and annual deposits are no longer required, the Co-Participants provide assurance using the prepayment method provided for in 10 CFR 50.75(e)(1)(i).
SCE and SDG&E are also required to accumulate sufficient funds to decommission the SONGS facility under the California Nuclear Facilities Decommissioning Act, CA Public Utilities Code Section 8321, et seq. The CPUC has construed the SONGS decommissioning obligation to include: (1) radiological decommissioning as required to 6
terminate the NRC licenses, (2) spent fuel storage (including ISFSI decommissioning), and (3) site restoration as required to terminate the SONGS site lease contracts granted by the U.S. Department of the Navy and the California State Lands Commission.
Under CA Public Utilities Code Section 8326(a)(2), SCE and SDG&E are required to update their site-specific nuclear facility decommissioning cost estimates periodically to reflect changes in decommissioning regulation, technology, and economics, for the purpose of adjusting contribution levels to their decommissioning trust.
Under CA Public Utilities Code Sections 8326(b), 8327, 8328, and 8329, the CPUC periodically reviews SCE and SDG&E's site-specific decommissioning cost estimates for the purpose of considering changes in electrical rates to ensure that sufficient funds will be available for payment of all decommissioning costs. The Cities of Anaheim and Riverside are not under the jurisdiction of the CPUC.
(5)
SCE is submitting information with respect to the San Onofre co-owners, SDG&E, Anaheim, and Riverside, on their behalf, and they are responsible for the completeness and accuracy of their respective information.
(6)
The credits recorded in 2022 for San Onofre Unit 1 occurred due to accounting corrections.
(7)
The current site-specific decommissioning cost estimates for San Onofre Unit 1 and for San Onofre Units 2 and 3 assume that the DOE will commence transporting spent fuel assemblies in 2031. This assumption may be updated periodically due to the ongoing uncertainties regarding the availability of a permanent repository for spent fuel.
(8)
The Estimated 'To Go" costs for SONGS 2&3 License Termination, Spent Fuel Management, and ISFSI decommissioning (NRG-Required Costs) are fully funded by the 12/31/2022 Net Trust Balances. The Estimated "To Go" costs for SONGS 2&3 Site Restoration activities (non NRG-Required Costs) exceeded the remaining 12/31/2022 Net Trust Balances. This is because the escalation rates applied to all the Estimated "To Go" costs reflected the increased inflation experienced throughout the global economy since 2021. SCE and the other SONGS co-owners believe this unusual reversal (of Net Trust Balances versus Estimated "To-Go" costs) is temporary. The SONGS nuclear decommissioning trusts rely on future projected returns, in excess of escalation, to have sufficient funds to complete decommissioning activities. SCE and the other co-owners are continuing to monitor this 7
situation, and intend to take appropriate actions, as needed, to ensure the ability to cover the full project costs until the project is completed.
8