ML24094A064
| ML24094A064 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/27/2024 |
| From: | Morgan M Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24094A064 (1) | |
Text
~YIEDiSON*
An P.DISOW INTERNATIONALitJ Company ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 March 27, 2024
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 2023 San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation
Dear Sir or Madam:
Mark Morgan Manager Nuclear 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 d_ecomr'nissioning funding for San Onofre Nuclear Generating Station\\\\
(San Onofre) Units 1, 2, ang 3 and the San Onofre Independent Spent Fuel Storage Installation,
(ISFSI) as of December 31, 2023.
\\
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.
None of the events listed in the provisions of 10 CFR 72.30(c)(1-4) have been experienced for the current reporting period, and there were no resulting impacts on the decommissioning costs.
During 2023, SCE made the decision to defer submittal of a License Termination Plan (LTP}
from 2024 until a desired end-state for the land is determined by the landowner, the Department of the Navy. This is not expected to occur until there is a viable path for removal of spent fuel and Greater Than Class C waste from the -site. At that time, SCE will submit an L TP for NRC review. SCE has reviewed the Post-Shutdown Decommissioning Activities Report (PSDAR) and determined that there is no revision necessary as a result of this decision. In addition, there is no significant change to the Decommissioning Cost Estimate as a result of this decision.
There are no commitments contained in.this letter or its enclosure.
NfVl.SSO f t/\\J u'V\\S S 2 £ NIV'iS5>
N (<-fl.
I \\
If you have any questions regarding this matter, please contact me at (949) 368-6274.
Enclosure:
Sincerely, San Onofre Nuclear Generating Station Units 1, 2, and 3 and ISFSI Decommissioning Funding Status Report for Calendar Year 2023 cc: J. D. Monninger, 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 2023
San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)
Decommissioning Funding Status Report For Calendar Year 2023 San Onofre Unit 1 was a pressurized water reactor (PWR) rated at 1347 MWt. San Onofre Units 2 and 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 1 O CFR 72 General License issued to the holders of a 1 O 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 Unit 3 Owner Decommissioning Decommissioning Decommissioning Liability Liabilitv 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, 2023 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 2016-2023 "To Go" License Termination Costs Estimate of Fuel Storage Costs Less: Fuel Star. Costs during 2016-2023 "To Go" Fuel Storage Costs Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs Less: Site Restor. Costs during 2016-2023
To Go" Site Restoration Costs Total Unit 1 "To Go" Costs as of 1/1/2024 Estimate of License Termination Costs Less: Lie. Term. Costs through 12/31/2023 "To Go" License Termination Costs Estimate of Fuel Storage Costs Less: Fuel Star. Costs through 12/31/2023 "To Go" Fuel Storage Costs Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs Less: Site Restor. Costs through 12/31/2023 "To Go" Site Restoration Costs Total Unit 2 "To Go" Costs as of 1/1/2024 2
San Onofre Unit 1 (1l 92.6 million 55.4 million 37.2 million 57.1 million 9.0 million 48.1 million 6.9 million 139.6 million 0.3 million 139.3 million 231.5 million San Onofre Unit 2<2>
$ 1,352.3 million 897.0 million 455.3 million 943.0 million 539. 7 million 403.3 million 23.8 million 631.8 million 188.4 million 443.4 million
$ 1,325.8 million
Estimate of License Termination Costs Less: Lie. Term. Costs through 12/31/2023
'To Go" License Termination Costs San Onofre Unit 3(2>
$1,341.7 million
$ 886.3 million 455.4 million Estimate of Fuel Storage Costs 972.0 million Less: Fuel Star. Costs through 12/31/2023 "To Go" Fuel Storage Costs 538.8 million 433.2 million Estimate of ISFSI Decommissioning Costs Estimate of Site Restoration Costs 25.3 million 908.2 million Less: Site Restor. Costs through 12/31/2023 "To Go" Site Restoration Costs 230.9 million 677.3 million Total Unit 3 "To Go" Costs as of 1/1/2024
$ 1,591.2 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 2023 (net of pending Trust Fund withdrawals and estimated capital gains taxes) are:(3)(4>
Co-Owner SCE SDG&E Anaheim Riverside TOTAL San Onofre Unit 1
$ 323.0 million
$ 144.9 million N/A N/A
$ 467.9 million San Onofre Unit 2 870.6 million 300.9 million 40.7 million 20.7 million
$ 1,232.9 million San Onofre Unit 3
$ 1,108.6 million 367.1 million 40.7 million 25.2 million
$ 1,541.6 million
- 3)
Each San Onofre co-owner deposits its decommissioning fund contributions into their respective external sinking fund accounts as provided in 10 CFR 50.75(e)(1)(ii). The annual amounts projected to be collected in 2024 are:(4>
Co-Owner SCE SDG&E Anaheim Riverside 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 ~n San Onofre Units 1; 2, a~d 3 decommissioning work performed during 2023 are summarized below:
Cost Category
, San Onofre Unit 1 San Onofre Unit 2 99.4 million San Onofre Unit 3 98.3 million License Term.
1.1 million Spent Fuel Storage $
2.0 million 19.6 million 20.7 million ISFSI Decom.
0.0 million 0.0 million 0.0 million Site Restoration
~
0.6 million
~
35.1 million
~
25.1 million TOTAL 3.7 million
$ 154.1 million 144.1 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 4.28%
2.31%
1.97%
San Onofre Unit 2 4.39%
2.43%
1.96%
San Onofre Unit 3 4.39%
2.43%
1.96%
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, 2023 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:<3>
Estimated San Onofre Unit 1 "To Go" 12/31/2023 Decommissioning Net Trust Balance Cost License Termination Costs 37.2 million 37.2 million Spent Fuel Management Costs 48.1 million 48.1 million ISFSI Decommissioning Costs
~
6.9 million
~
6.9 million Subtotal: NRG-Required Costs 92.2 million 92.2 million Site Restoration Costs
~ 139.3 million
~ 375. 7 million TOTAL 231.5 million 467.9 million 4
San Onofre Unit 2 License Termination Costs Spent Fuel Management Costs ISFSI Decommissioning Costs Subtotal: NRG-Required Costs Site Restoration Costs TOTAL<6>
San Onofre Unit 3 License Termination Costs Spent Fuel Management Costs ISFSI Decommissioning Costs Subtotal: NRG-Required Costs Site Restoration Costs TOTAU6>
Estimated
To Go" 12/31/2023 Decommissioning Net Trust Balance Cost 455.3 million 403.3 million 23.8 million 882.4 million 443.4 million
$ 1,325.8 million Estimated "To Go" Decommissioning Cost 455.4 million
$
- 433.2 million 25.3 million 913.9 million 677.3 million
$ 1,591.2 million 455.3 million 403.3 million 23.8 million 882.4 million
$ 350.5 million
$ 1,232.9 million 12/31/2023 Net Trust Balance 455.4 million 433.2 million 25.3 million 913.9 million 627.7 million
$1,541.6 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 One canister of Greater Than Class C (GTCC) waste from Unit 1 is,,
located in the ISFSI The U.S. Department of Energy (DOE) will commence transporting spent fuel assemblies in 2031 <5>
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 Five canisters of Greater than Class C (GTCC) waste from-Unit 2 have been placed in the SONGS ISFSI. The sixth and final Unit 2 GTCC canister is currently forecast to be transferred to the ISFSI in May of 2024.
DOE will commence transporting spent fuel assemblies in 2031 <5>
DOE will remove last SONGS Units 2&3 fuel from the ISFSI by 2051 5
Notes:
San Onofre Unit 3:
1,734 fuel assemblies in 53 canisters are located in the ISFSI Five.. canisters of Greater than Class C (GTCC) waste from Unit 3 have been placed in the SONGS ISFSI. The sixth and final Unit 3 GTCC canister is currently forecast to be transferred to the ISFSI in May of 2024.
DOE will commence transporting spent fuel assemblies in 2031<5)
) 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)
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 1 O CFR 50.75(e)(1)(ii). To the extent the 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 terminate the NRC licenses, (2) spent fuel storage (including ISFSI decommissioning), and (3) site restoration as required to terminate the 6
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.
{4)
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.
(5)
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.
(6)
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 12/31/2023 Net Trust Balances. The Estimated "To Go" costs for SONGS 2&3 Site Restoration activities (non NRG-Required Costs) exceeded the remaining 12/31/2023 Net Trust Balances based on this method of calculating funding assurance.
This is because in 2022 there was significant decline in the equity markets and a rise in interest and escalation rates. 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 SONGS co-owners believe when future projected returns and escalation forecasts are included in analysis there are sufficient trust funds to complete all decommissioning activities, including site restoration. SCE and the other co-owners are continuing to monitor this situation, and intend to take appropriate actions, as needed, to ensure the ability to cover the full project costs until the project is completed.
7