ML23243A944
| ML23243A944 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/29/2023 |
| From: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| To: | Madigan J Southern California Edison Co |
| References | |
| EPID L-2017-FPR-0062 | |
| Download: ML23243A944 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 29, 2023 James Madigan Manager - Oversight, Regulatory Affairs, and Nuclear Safety Concerns Southern California Edison San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
THE U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF SOUTHERN CALIFORNIA EDISONS 2017, 2020, 2021, 2022, AND 2023 UPDATED DECOMMISSIONING FUNDING PLANS FOR SAN ONOFRE NUCLEAR GENERATING STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS
Dear James Madigan:
By letters dated March 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17090A152), March 17, 2020 (ML20079J032),
March 24, 2021 (ML21091A037), March 23, 2022 (ML22084A055), March 29, 2023 (ML23094A127), and as supplemented by letter dated September 28, 2023 (ML23276A594),
Southern California Edison (SCE), on behalf of itself, San Diego Gas & Electric, the City of Anaheim, and the City of Riverside (co-owners), submitted updated decommissioning funding plans (DFPs) for 2016, 2019, 2020, 2021 and 2022 calendar years, respectively, for the San Onofre Nuclear Generating Station (San Onofre), Units 1, 2, and 3, Independent Spent Fuel Storage Installation (ISFSI) located in San Clemente, California, for U.S. Nuclear Regulatory Commission (NRC) staff review and approval.
Previously, by letter dated December 14, 2012 (ML130420384), SCE submitted, on behalf of itself, San Diego Gas & Electric, former co-owner the City of Anaheim, and the City of Riverside, an initial DFP for the San Onofre ISFSI for NRC staff review and approval. By letter dated December 14, 2015 (ML15349A942), as supplemented by letter dated April 11, 2018 (ML18106A042), SCE submitted, on behalf of itself, San Diego Gas & Electric, former co-owner the City of Anaheim, and the City of Riverside, an updated DFP for San Onofre ISFSI for NRC staff review and approval. The NRC staff reviewed the initial and updated DFP submittals for San Onofre ISFSI and documented its findings in its letter dated April 7, 2021 (ML21061A231).
In support of its approval of the initial 2012 and updated 2015 DFPs, the NRC issued an environmental assessment and its associated finding of no significant impact on April 7, 2021 (ML21061A230), which was published in the Federal Register (FR) on April 14, 2021 (86 FR 19644).
Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 72.30(b), each holder of, or applicant for, a license under 10 CFR Part 72 must submit for NRC review and approval a DFP containing information on how reasonable assurance will be provided that funds will be available to decommission its ISFSIs. The DFP must contain a detailed decommissioning cost
J. Madigan estimate (DCE) in an amount reflecting: (1) the cost of an independent contractor to perform all decommissioning activities, (2) an adequate contingency factor, and (3) the cost of meeting the 10 CFR 20.1402 unrestricted use criteria (or the cost of meeting the 10 CFR 20.1403 restricted use criteria, provided the licensee can demonstrate its ability to meet these criteria). The licensees DFP must also identify and justify using the key assumptions contained in the DCE.
Further, the DFP must describe the method of assuring funds for ISFSI decommissioning, including means for adjusting cost estimates and associated funding levels periodically over the life of the ISFSI. Additionally, the DFP must specify the volume of onsite subsurface material containing residual radioactivity that will require remediation to meet the criteria for license termination and contain a certification that financial assurance for ISFSI decommissioning has been provided in the amount of the DCE.
Pursuant to 10 CFR 72.30(c), at the time of license renewal and at intervals not to exceed 3 years, the initial DFP required to be submitted by 10 CFR 72.30(b) must be resubmitted with adjustments as necessary to account for changes in costs and the extent of contamination in an updated DFP. The updated DFP must update the information submitted with the original or prior approved plan. In addition, the updated DFP must also specifically consider the effect of the following events on decommissioning costs, as required by 10 CFR 72.30(c)(1)-(4): (1) spills of radioactive material producing additional residual radioactivity in onsite subsurface material, (2) facility modifications, (3) changes in authorized possession limits, and (4) actual remediation costs that exceed the previous cost estimate.
In accordance with 10 CFR 72.30(c), and using NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance, dated February 2012, the NRC staff reviewed the following updated DFPs submitted by SCE, including the updated DCEs and the method of assuring funds for decommissioning.
2017 Updated DFP In its 2017 updated DFP, SCE estimated that the total cost to decommission the ISFSI at San Onofre to be $39.8 million, for unrestricted use, in 2016 dollars.
SCEs 2017 updated DCE, as supplemented by letter dated September 28, 2023, provided narratives on each of the requirements of 10 CFR 72.30(c)(1)-(4). Specifically, the licensee explained that there were no changes in the factors listed in 10 CFR 72.30(c)(1)-(4). Based on its review of the SCEs 2017 updated DCE, the NRC staff finds that the updated DCE: was based on reasonable costs of a third-party contractor; included an adequate contingency factor; reflected the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and was based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2017 updated DCE adequately estimated the cost, at the time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE acceptable.
In the 2017 updated DFP, SCE and other co-owners reported that they had previously fully funded the estimated costs of decommissioning into an external sinking fund pursuant to 10 CFR 50.75(e)(1)(ii). SCE and other co-owners are allowed to provide financial assurance using 10 CFR 50.75(e)(1)(ii) pursuant to 10 CFR 72.30(e)(5) because the SONGS ISFSI belongs to a licensee with a power reactor license under 10 CFR Part 50. To the extent the decommissioning costs have been fully funded by the co-owners, annual deposits are no longer necessary. In the 2017 updated DFP, SCE and other co-owners reported that the external sinking funds remain sufficiently funded to decommission the SONGS ISFSI. In the 2017 updated DFP SCE and its co-owners reported that all four San Onofre co-owners recover the
J. Madigan cost of decommissioning pursuant to cost-of-service rate regulation. Therefore, the NRC finds that SCE and its co-owners are eligible to use an external sinking fund as the exclusive mechanism to provide financial assurance consistent with 10 CFR 50.75(e)(ii)(A). The NRC staff reviewed the licensees 2017 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments and the licensees recovery of the cost of decommissioning through cost-of-service ratemaking regulation provide adequate financial assurance to cover its cost estimates. Therefore, the NRC staff finds this financial instrument acceptable.
2020 Updated DFP In its 2020 updated DFP, SCE estimated that the total cost to decommission the ISFSI at San Onofre to be $45.2 million, for unrestricted use, in 2019 dollars.
SCEs 2020 DCE, as supplemented by letter dated September 28, 2023, provided narratives on each of the requirements of 10 CFR 72.30(c)(1)-(4). Specifically, the licensee explained that there were no changes in the factors listed in 10 CFR 72.30(c)(1)-(4). Based on its review of the SCEs 2020 updated DCE, the NRC staff finds that the updated DCE: was based on reasonable costs of a third-party contractor; included an adequate contingency factor; reflected the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and was based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2020 updated DCE adequately estimated the cost, at the time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE acceptable.
In the 2020 updated DFP, SCE and other co-owners reported that they had previously fully funded the estimated costs of decommissioning into an external sinking fund pursuant to 10 CFR 50.75(e)(1)(ii). SCE and other co-owners are allowed to provide financial assurance using 10 CFR 50.75(e)(1)(ii) pursuant to 10 CFR 72.30(e)(5) because the SONGS ISFSI belongs to a licensee with a power reactor license under 10 CFR Part 50. To the extent the decommissioning costs have been fully funded by the co-owners, annual deposits are no longer necessary. In the 2020 updated DFP, SCE and other co-owners reported that the external sinking funds remain sufficiently funded to decommission the SONGS ISFSI. In the 2020 updated DFP SCE and its co-owners reported that all four San Onofre co-owners recover the cost of decommissioning pursuant to cost-of-service rate regulation. Therefore, the NRC finds that SCE and its co-owners are eligible to use an external sinking fund as the exclusive mechanism to provide financial assurance consistent with 10 CFR 50.75(e)(ii)(A). The NRC staff reviewed the licensees 2020 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments and the licensees recovery of the cost of decommissioning through cost-of-service ratemaking regulation provide adequate financial assurance to cover its cost estimates. Therefore, the NRC staff finds this financial instrument acceptable.
2021 Updated DFP In its 2021 updated DFP, SCE estimated that the total cost to decommission the ISFSI at San Onofre to be $46.3 million, for unrestricted use, in 2020 dollars.
SCEs 2021 DCE, as supplemented by letter dated September 28, 2023, provided narratives on each of the requirements of 10 CFR 72.30(c)(1)-(4). Specifically, the licensee explained that there were no changes in the factors listed in 10 CFR 72.30(c)(1)-(4). Based on its review of the SCEs 2021 updated DCE, the NRC staff finds that the updated DCE: was based on reasonable costs of a third-party contractor; included an adequate contingency factor; reflected the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and was based on reasonable and
J. Madigan documented assumptions. Therefore, the NRC staff finds that the 2021 updated DCE adequately estimated the cost, at the time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE acceptable.
In the 2021 updated DFP, SCE and other co-owners reported that they had previously fully funded the estimated costs of decommissioning into an external sinking fund pursuant to 10 CFR 50.75(e)(1)(ii). SCE and other co-owners are allowed to provide financial assurance using 10 CFR 50.75(e)(1)(ii) pursuant to 10 CFR 72.30(e)(5) because the SONGS ISFSI belongs to a licensee with a power reactor license under 10 CFR Part 50. To the extent the decommissioning costs have been fully funded by the co-owners, annual deposits are no longer necessary. In the 2021 updated DFP, SCE and other co-owners reported that the external sinking funds remain sufficiently funded to decommission the SONGS ISFSI. In the 2021 updated DFP SCE and its co-owners reported that all four San Onofre co-owners recover the cost of decommissioning pursuant to cost-of-service rate regulation. Therefore, the NRC finds that SCE and its co-owners are eligible to use an external sinking fund as the exclusive mechanism to provide financial assurance consistent with 10 CFR 50.75(e)(ii)(A). The NRC staff reviewed the licensees 2021 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments and the licensees recovery of the cost of decommissioning through cost-of-service ratemaking regulation provide adequate financial assurance to cover its cost estimates. Therefore, the NRC staff finds this financial instrument acceptable.
2022 Updated DFP In its 2022 updated DFP, SCE estimated that the total cost to decommission the ISFSI at San Onofre to be $49.7 million, for unrestricted use, in 2021 dollars.
The SCEs 2022 DCE, as supplemented by letter dated September 28, 2023, provided narratives on each of the requirements of 10 CFR 72.30(c)(1)-(4). Specifically, the licensee explained that there were no changes in the factors listed in 10 CFR 72.30(c)(1)-(4). Based on its review of the SCEs 2022 updated DCE, the NRC staff finds that the updated DCE: was based on reasonable costs of a third-party contractor; included an adequate contingency factor; reflected the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and was based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2022 updated DCE adequately estimated the cost, at the time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE acceptable.
In the 2022 updated DFP, SCE and other co-owners reported that they had previously fully funded the estimated costs of decommissioning into an external sinking fund pursuant to 10 CFR 50.75(e)(1)(ii). SCE and other co-owners are allowed to provide financial assurance using 10 CFR 50.75(e)(1)(ii) pursuant to 10 CFR 72.30(e)(5) because the SONGS ISFSI belongs to a licensee with a power reactor license under 10 CFR Part 50. To the extent the decommissioning costs have been fully funded by the co-owners, annual deposits are no longer necessary. In the 2022 updated DFP, SCE and other co-owners reported that the external sinking funds remain sufficiently funded to decommission the SONGS ISFSI. In the 2022 updated DFP SCE and its co-owners reported that all four San Onofre co-owners recover the cost of decommissioning pursuant to cost-of-service rate regulation. Therefore, the NRC finds that SCE and its co-owners are eligible to use an external sinking fund as the exclusive mechanism to provide financial assurance consistent with 10 CFR 50.75(e)(ii)(A). The NRC staff reviewed the licensees 2022 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments and the licensees recovery of the cost of decommissioning
J. Madigan through cost-of-service ratemaking regulation provide adequate financial assurance to cover its cost estimates. Therefore, the NRC staff finds this financial instrument acceptable.
2023 Updated DFP In its 2023 updated DFP, SCE estimated that the total cost to decommission the ISFSI at San Onofre to be $53 million, for unrestricted use, in 2022 dollars.
SCEs 2023 DCE, as supplemented by letter dated September 28, 2023, provided narratives on each of the requirements of 10 CFR 72.30(c)(1)-(4). Specifically, the licensee explained that there were no changes in the factors listed in 10 CFR 72.30(c)(1)-(4). Based on its review of the SCEs 2023 updated DCE, the NRC staff finds that the updated DCE: is based on reasonable costs of a third-party contractor; includes an adequate contingency factor; reflects the cost of meeting the 10 CFR 20.1402 criteria for unrestricted use; and is based on reasonable and documented assumptions. Therefore, the NRC staff finds that the 2023 updated DCE adequately estimate the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the updated DCE acceptable.
In the 2023 updated DFP, SCE and other co-owners reported that they had previously fully funded the estimated costs of decommissioning into an external sinking fund pursuant to 10 CFR 50.75(e)(1)(ii). SCE and other co-owners are allowed to provide financial assurance using 10 CFR 50.75(e)(1)(ii) pursuant to 10 CFR 72.30(e)(5) because the SONGS ISFSI belongs to a licensee with a power reactor license under 10 CFR Part 50. To the extent the decommissioning costs have been fully funded by the co-owners, annual deposits are no longer necessary. In the 2023 updated DFP, SCE and other co-owners reported that the external sinking funds remain sufficiently funded to decommission the SONGS ISFSI. In the 2023 updated DFP SCE and its co-owners reported that all four San Onofre co-owners recover the cost of decommissioning pursuant to cost-of-service rate regulation. Therefore, the NRC finds that SCE and its co-owners are eligible to use an external sinking fund as the exclusive mechanism to provide financial assurance consistent with 10 CFR 50.75(e)(ii)(A). The NRC staff reviewed the licensees 2023 updated DFP and finds that the aggregate dollar amount of the licensees financial instruments and the licensees recovery of the cost of decommissioning through cost-of-service ratemaking regulation provide adequate financial assurance to cover its cost estimates. Therefore, the NRC staff finds this financial instrument acceptable.
Conclusion The NRC staff reviewed the SCE and other co-owners 2017, 2020, 2021, 2022, and 2023 updated DFPs, as supplemented by letter dated September 28, 2023, including the updated DCEs and the method of assuring funds for decommissioning, in accordance with 10 CFR 72.30(c) and NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance. Based on its review, the NRC staff finds that the updated DFPs contain the information required by 10 CFR 72.30(c) and that SCE and other co-owners have provided reasonable assurance by which funds will be available to decommission the ISFSI at San Onofre. Therefore, the NRC staff finds that the DCEs adequately estimated the cost, at this time, to carry out required ISFSI decommissioning activities prior to license termination, and that the DCEs are reasonable.
In addition to the NRC staffs review of the above updated DFPs, the NRC staff completed an environmental review. The NRC staff published a summary of the results of the environmental review in the Federal Register (88 FR 58320) on August 25, 2023, for the SCEs ISFSIs. The environmental assessment and findings of no significant impact for SCEs ISFSIs is available in
J. Madigan https://www.regulations.gov under the Docket ID: NRC-2023-0135. The NRC staff determined that there was no environmental impact from the NRC staffs review and approval of SCEs updated DFPs.
In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS.
ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m.
eastern time (ET), Monday through Friday, except Federal holidays.
If you have any questions regarding this matter, please contact me at (301) 415-8064 or via email at yoira.diaz-sanabria@nrc.gov.
Sincerely, Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-41 License No.: SFGL-19 EPID No.: L-2017-FPR-0062 Signed by Diaz-Sanabria, Yoira on 10/29/23
J. Madigan
SUBJECT:
THE U.S. NUCLEAR REGULATORY COMMISSIONS ANALYSIS OF SOUTHERN CALIFORNIA EDISONS 2017, 2020, 2021, 2022, AND 2023 UPDATED DECOMMISSIONING FUNDING PLANS FOR SAN ONOFRE NUCLEAR GENERATING STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS DOCUMENT DATED:
DISTRIBUTION:
PUBLIC DFM r/f FMiller, NMSS SMcCarthy, NMSS TWertz, NMSS RidsNmssRefsFab ASnyder, NMSS DAtkinson, NMSS KBanovac, NMSS ADAMS Accession Number: ML23243A944 OFFICE DFM/STLB:PM DFM/STLB:LA OGC (NLO)
NMSS/STLB:BC NAME TLiu WWheatley KBernstein YDiaz-Sanabria DATE 8/25/2023 9/5/2023 10/26/2023 10/29/2023 OFFICIAL RECORD COPY October 29, 2023