ML23276A594

And Independent Spent Fuel Storage Installation - Supplement to Decommissioning Funding Status Reports

ML23276A594
Person / Time
Site:	San Onofre
Issue date:	09/28/2023
From:	Madigan J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML23276A594 (1)

Text

SOUTHERN CALIFORNIA James Madigan EDISON~ Manager - Oversight, Regulatory An EDISON INTERNATIONAL'~ Company Affairs, and Nuclear Safety Concerns San Onofre Nuclear Generating Station

September 28, 2023

10 CFR 72.30

A TIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Subject:

Docket No. 72-41 Supplement to Decommissioning Funding Status Reports San Onofre Nuclear Generating Station and Independent Spent Fuel Storage Installation

Dear Sir or Madam:

This letter provides a Supplement to various decommissioning funding reports for the San Onofre Nuclear Generation Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) required by 10 CFR 72.30(c). By References 1 through 5 (below), Southern California Edison (SCE) submitted five decommissioning funding reports for both SONGS Units 1, 2 and 3 and the ISFSI. These reports provided the overall status of funding assurance for future decommissioning of the SONGS ISFSI and are responsive to multiple regulations, including 10 CFR 72.30.

In general, these regulations require reporting of the overall status of decommissioning funding and an estimate of decommissioning costs. 10 CFR 72.30(c)(1-4) provide specific elements to be addressed in ISFSI decommissioning funding reports. These include the following events which may have an effect on decommissioning cost estimates:

(1) Spills of radioactive material producing additional residual radioactivity in onsite subsurface material.

(2) Facility modifications.

(3) Changes in authorized possession limits.

(4) Actual remediation costs that exceed the previous cost estimate.

SCE's approach to addressing these specific requirements has been to describe the resulting impacts to decommissioning cost estimates if and when they occur. For those reporting years when none of these four events have been applicable, SCE has not discussed any resulting effect on decommissioning costs in the funding reports.

During a phone call with an NRC reviewer for the various decommissioning funding plans, it was recognized that 10 CFR 72.30(c) requires specifically addressing these events, whether they were relevant in a particular reporting year or not. The purpose of this Supplement is to provide that specific statement for References 1 through 5.

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rvnsf Document Control Desk 2

For the rep.orting years in question, the only change driven by the events listed in 10 CFR 72.30(c)(1-4) was the expansion of the SONGS ISFSI. This was a facility modification (event 2) that affected remediation costs (event 4). The associated cost effects were summarized in a response to a request for additional information submitted to the NRC on April 11, 2018 (Reference 6). Other than this, none of the events listed in the provisions of 10 CFR 72.30(c)(1-

4) have been experienced for the reporting years in question and as a result there have been no effects on decommissioning costs driven by any of these events.

References:

1) Letter from J. Kay (SCE) to Document Control Desk (NRC) dated March 28, 2017: Subject; Docket Nos. 50-206, 50-361 and 50-362, 72-41, 10 CFR 50.75(1)(1), 10 CFR 50.82(a)(8)(v), 10 CFR 50.82(a)(8)(vii), and 10 CFR 72.30(c) Decommissioning Funding Status Report San Onofre Nuclear Generating Station Units 1, 2 and 3 and ISFSI (ADAMS Accession No.

ML17090A152)

2} Letter from A. Bates (SCE) to Document Control Desk (NRC) dated March 17, 2020: Subject; Docket Nos. 50-206, 50-361 and 50-362, 72-41, 10 CFR 50.82(a)(8)(v-vii), and 10 CFR 72.30(c) Decommissioning Funding Status Report 2019; San Onofre Nuclear Generating Station Units 1, 2 and 3 and ISFSI (ADAMS Accession No. ML20079J032)

3) Letter from A. Bates (SCE} to Document Control Desk (NRC) dated March 24, 2021: Subject; Docket Nos. 50-206, 50-361 and 50-362, 72-41, 10 CFR 50.82(a)(8)(v and vii}, and 10 CFR 72.30(c) Decommissioning Funding Status Report 2020, San Onofre Nuclear Generating Station Units 1, 2 and 3 and ISFSI (ADAMS Accession No. ML21091A037)

4) Letter from A. Bates (SCE) to Document Control Desk: (NRC) dated March 23, 2022: Subject; Docket Nos. 50-206, 50-361 and 50-362, 72-41, 1 O 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 ISFSI (ADAMS Accession No. ML22084A055)

5} Letter from A. Bates (SCE) to Document Control Desk (NRC) dated March 29, 2023: Subject; Docket Nos. 50-206, 50-361, 50-362, and 72-41, 1 O CFR 50.82(a)(8)(v and vii), and 1 O CFR 72.30(c) Decommissioning Funding Status Report 2021 (sic), San Onofre Nuclear Generating Station Units 1, 2 and 3 and ISFSI (ADAMS Accession No. ML23094A127)

6) Letter from T. J. Palmisano (SCE) to Document Control Desk (NRC) dated April 11, 2018: Subject; Docket No. 72-41, Response to Request for Additional Information - Southern California Edison's Decommissioning Funding Plan Update for San Onofre Nuclear Generating Station Independent Spent Fuel Storage Installation (ADAMS Accession No. ML18106A042)

There are no commitments contained in this letter.

Document Control Desk 3

If you have any questions regarding this matter, please contact me at (949) 368-7024.

Sincerely,

Enclosure:

San Onofre Nuclear Generating Station Units 1, 2, and 3 and ISFSI Decommissioning Funding Status Report for Calendar Year 2022

cc: J. D. Monninger, Regional Administrator, NRC Region IV A. M. Snyder, NRC Project Manager, San Onofre Units 1, 2, and 3