ML25091A067
| ML25091A067 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/27/2025 |
| 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: ML25091A067 (1) | |
Text
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An EDISON INTERNATIONAL Company ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 March 27, 2025
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 Financial Assurance Status Report 2024 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 decommissioning financial assurance status report 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, 2024.
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 San Onofre 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.
There are no commitments contained in this letter or its enclosure.
If you have any questions regarding this matter, please contact me at (949) 368-6274.
Sincerely, A,~
Enclosure:
San Onofre Nuclear Generating Station Units 1, 2, and 3 and ISFSI Decommissioning Financial Assurance Status Report for Calendar Year 2024 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 Financial Assurance Status Report for Calendar Year 2024
San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)
Decommissioning Financial Assurance Status Report For Calendar Year 2024 The decommissioning liability for San Onofre Units 1, 2, and 3 is shared between Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and the City of Riverside (Riverside), and former owner, the City of Anaheim (Anaheim), (collectively, the Decommissioning Participants), as set forth below for each unit:<1l Unit 1 Unit 2 Unit 3 Participant 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%
The financial assurance information required by 10 CFR 50.82(a)(8)(v) and (vii) is provided in the bullet points below.
10 CFR 50.82(a)(8)(v)(A) - The amount spent on decommissioning (cumulative),
(100% Share, 2024 $)
Cost Category San Onofre Unit 1 <2l San Onofre Unit 2 (2016-2024)
License Termination 59.5 million Spent Fuel Management $
4.9 million ISFSI Decommissioning 0.0 million Site Restoration
~$ __
0.......
6_m_i""'"lli""'"o-""'n TOTAL 65.0 million (2013-2024)
$ 1,040.1 million 571.6 million 0.0 million 214.4 million
$ 1,826.1 million San Onofre Unit 3 (2013-2024)
$ 1,041.0 million 570.8 million 0.0 million 264.1 million
$ 1,875.9 million 10 CFR 50.82(a)(8)(v)(A) - The amount spent on decommissioning (calendar year 2024) (100% Share, 2024 $)
Cost Category License Termination Spent Fuel Management ISFSI Decommissioning Site Restoration TOTAL San Onofre Unit 1 2.6 million 1.7 million 0.0 million 0.4 million 4.7 million 1
San Onofre Unit 2 San Onofre Unit 3
$ 106.7 million
$ 118.8 million 10.0 million 10.0 million 0.0 million 0.0 million 18.3 million 23.8 million
$ 135.0 million
$ 152.6 million
Major decommissioning activities during 2024 included:
Greater Than Class C (GTCC) Waste transfer to ISFSI Large component removal and disposal Auxiliary Control Building demolition Radwaste shipped offsite 10 CFR 50.82(a)(8)(v)(A) - Remaining balance of decommissioning funds Each San Onofre Decommissioning Participant 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 (in 2024 $) remaining at the end of calendar year 2024 (net of pending Trust Fund withdrawals and estimated capital gains taxes) are:<3)
Partici~ant San Onofre Unit 1 San Onofre Unit 2 San Onofre Unit 3 SCE
$ 343.5 million 860.0 million
$ 1,110.0 million SDG&E
$ 145.8 million 302.6 million 370.7 million Anaheim N/A 39.3 million 39.3 million Riverside N/A 19.3 million 23.6 million TOTAL
$ 489.3 million
$ 1,221.2 million
$ 1,543.6 million 10 CFR 50.82(a)(8)(v)(A) - The amount provided by other financial assurance methods being relied upon None 10 CFR 50.82(a)(8)(v)(B) -An estimate of the costs to complete decommissioning as of December 31, 2024, reflecting any difference between actual and estimated costs for work performed during the year and the decommissioning criteria upon which the estimate is based (100% Share, 2024 $)
Cost Category License Termination Spent Fuel Management ISFSI Decommissioning Site Restoration TOTAL San Onofre Unit 1 <4) San Onofre Unit 2<4) San Onofre Unit 3<4) 36.5 million 53.4 million 6.3 million
$ 133.3 million
$ 229.5 million 273. 7 million 453.3 million 22.0 million 499.0 million
$ 1,248.0 million 267.3 million 494.8 million 23.5 million 717.3 million
$ 1,502.9 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 required for NRC license termination and final site restoration as determined by the site landowners; (2) the cost to meet the 10 CFR 20.1402 radiological criteria for unrestricted site use; and (3) adequate contingency for all such decommissioning-related costs.
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The estimated costs to complete the decommissioning of San Onofre Units 1, 2, and 3 that are presented in this report were derived from the 2024 San Onofre Unit 1 and 2024 San Onofre Units 2&3 Decommissioning Cost Estimates.(4) The estimated cost to complete decommissioning in last year's Annual Decommissioning Funding Status Report were based on the 2020 San Onofre Unit 1 and 2020 San Onofre Units 2&3 Decommissioning Cost Estimates.
SCE underran the 2024 budget due to timing shifts in physical work performed by the Decommissioning General Contractor and unused contingency included in 2024 to cover project risks. This underrun has been incorporated into the "costs to complete decommissioning" estimate above.
There were no other material changes to the decommissioning criteria upon which the 2024 San Onofre Unit 1 and San Onofre Units 2&3 Decommissioning Cost Estimates were based.
1 O CFR 50.82(a)(8)(v)(C) - Any modifications to licensee's current method of providing financial assurance since the last submitted report None 10 CFR 50.82(a)(8)(v)(D) - Any material changes to trust agreements or financial assurance contracts None 10 CFR 50.82(a)(8)(vii)(A) - Amounts of funds accumulated to cover the cost of managing the irradiated fuel The San Onofre Decommissioning Participants do not segregate their decommissioning trust funds by decommissioning cost category. However, the Estimated "To Go" costs for San Onofre Units 2&3 License Termination, Spent Fuel (i.e., Irradiated Fuel)
Management, and ISFSI Decommissioning (NRG-Required Costs) are fully funded by the 12/31/2024 Net Trust Balances. See the "Subtotal: NRG-Required Costs" row for each unit in the Financial Assurances Summary below.
10 CFR 50.82(a)(8)(vii)(B) - Projected cost of managing irradiated fuel until title to the fuel and possession of the fuel are transferred to the Secretary of Energy The projected cost of managing irradiated fuel until title to the fuel and possession of the fuel are transferred to the Secretary of Energy is shown in the "Spent Fuel Management" rows in the table provided above for 10 CFR 50.82(a)(8)(v)(B). Also, the Estimated "To Go" costs for Spent Fuel Management and the corresponding Net Trust Balances for each San Onofre unit are provided in the Financial Assurance Summary below.
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10 CFR 50.82(a)(8)(vii)(C) - If the funds do not cover the projected cost, a plan to obtain additional funds to cover the cost Not applicable 10 CFR 72.30(c) - Funding plan for ISFSI decommissioning The funding plan (estimated cost) for ISFSI decommissioning is shown in the "ISFSI Decommissioning" rows in the table provided above for 10 CFR 50.82(a)(8)(v)(B). Also, the Estimated "To Go" costs for ISFSI Decommissioning and the corresponding Net Trust Balances for each San Onofre unit are provided in the Financial Assurance Summary below.
Financial Assurance Summary The amounts of decommissioning funds available as of December 31, 2024 for San Onofre Units 1, 2, and 3 License Termination, Site Restoration, Spent Fuel Management, and ISFSI Decommissioning costs (100% Share, 2024 $) are shown in the tables below:(3)
San Onofre Unit 1 License Termination Spent Fuel Management ISFSI Decommissioning Subtotal: NRG-Required Costs Site Restoration TOTAL San Onofre Unit 2 License Termination Spent Fuel Management ISFSI Decommissioning Subtotal: NRG-Required Costs Site Restoration TOTAU6l Estimated "To Go" Decommissioning Cost 36.5 million 53.4 million i
6.3 million 96.2 million i
133.3 million 229.5 million Estimated "To Go" Decommissioning Cost 273. 7 million 453.3 million i
22.0 million 749.0 million i
499.0 million
$ 1,248.0 million 4
12/31/2024 Net Trust Balance 36.5 million 53.4 million i
6.3 million 96.2 million i
393.1 million 489.3 million 12/31/2024 Net Trust Balance 273. 7 million 453.3 million i
22.0 million 749.0 million i
472.2 million
$ 1,221.2 million
San Onofre Unit 3 License Termination Spent Fuel Management ISFSI Decommissioning Subtotal: NRG-Required Costs Site Restoration TOTAL Estimated "To Go" Decommissioning Cost 267.3 million
$ 494.8 million 23.5 million 785.6 million 717.3 million
$ 1,502.9 million 12/31/2024 Net Trust Balance 267.3 million 494.8 million 23.5 million 785.6 million
$ 758.0 million
$ 1,543.6 million Key assumptions pertaining to San Onofre spent fuel management and ISFSI decommissioning:
San Onofre Unit 1:
395 fuel assemblies in 17 canisters are stored in the San Onofre ISFSI One canister of Greater Than Class C (GTCC) waste from Unit 1 is stored in the San Onofre ISFSI The U.S. Department of Energy (DOE) will commence transporting spent fuel assemblies in 2034<5)
DOE will remove last San Onofre Unit 1 fuel from the San Onofre ISFSI by 2040<5) 270 fuel assemblies are stored at the GE-Hitachi facility in Morris, IL. The storage costs for these assemblies were paid in 2024 with utility operating funds from the Unit 1 Decommissioning Participants, not from their nuclear decommissioning trusts.
San Onofre Unit 2:
1,726 fuel assemblies in 53 canisters are stored in the San Onofre ISFSI Six canisters of Greater than Class C (GTCC) waste from Unit 2 are stored in the San Onofre ISFSI DOE will commence transporting spent fuel assemblies in 2034<5)
DOE will remove last San Onofre Units 2&3 fuel from the San Onofre ISFSI by 2054(5)
San Onofre Unit 3:
1,734 fuel assemblies in 53 canisters are stored in the San Onofre ISFSI Six canisters of Greater than Class C (GTCC) waste from Unit 3 are stored in the San Onofre ISFSI DOE will commence transporting spent fuel assemblies in 2034<5)
DOE will remove last San Onofre Units 2&3 fuel from the San Onofre ISFSI by 2054(5) 5
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 2056(5)
Notes:
(1)
SCE is submitting information with respect to the San Onofre Decommissioning Participants on their behalf. They are responsible for the completeness and accuracy of their respective information.
(2)
The "cumulative" amount spent for San Onofre Unit 1 decommissioning, as provided for 10 CFR 50.82(a)(8)(v)(A) above, represents 100% of the decommissioning costs incurred for San Onofre Unit 1 during 2016-2024 and are expressed in 2024 dollars.
(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 Decommissioning Participants 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 extent the decommissioning costs are fully funded and annual deposits are no longer required, the 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 San Onofre facility under the California Nuclear Facilities Decommissioning Act, CA Public Utilities Code Section 8321, et seq. The California Public Utilities Commission (CPUC) has construed the San Onofre decommissioning obligation to include: (1) radiological decommissioning as required to terminate the NRG licenses, (2) spent fuel management (including ISFSI decommissioning), and (3) site restoration as required to terminate the San Onofre site lease and easement contracts with 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.
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(4)
The current site-specific decommissioning cost estimates for San Onofre Unit 1 (SCE 2024 San Onofre 1 DCE) and for San Onofre Units 2&3 (SCE 2024 San Onofre 2&3 DCE) that were submitted to the CPUC on December 6, 2024, include the radiological costs associated with terminating the site license, site restoration costs, and spent fuel management costs.
(5)
The SCE 2024 San Onofre Unit 1 and Units 2&3 DCEs assume that: (1) the DOE will commence transporting spent fuel assemblies in 2034; (2) all San Onofre Unit 1 spent fuel will be removed from the San Onofre ISFSI by 2040; (3) all San Onofre Units 2&3 spent fuel will be removed from the San Onofre ISFSI by 2054; and (4) the remaining San Onofre plant and ISFSI site will be decontaminated to meet 1 O CFR 20.1402 site release criteria for unrestricted use as required to terminate the Part 50 General License by 2056. These assumptions 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 (NRC-Required Costs) are fully funded by the 12/31/2024 Net Trust Balances. The Estimated "To Go" costs for San Onofre Units 2 Site Restoration activities (non NRC-Required Costs) exceeded the remaining 12/31/2024 Net Trust Balances based on this method of calculating financial assurance. This is because in 2022 there was significant decline in the equity markets and a rise in interest and escalation rates. The San Onofre nuclear decommissioning trusts rely on future projected returns, in excess of escalation, to have sufficient funds to complete decommissioning activities. SCE believes 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 is continuing to monitor this situation and intends to take appropriate actions, as needed, to ensure the ability to cover the full project costs until the project is completed.
Because the Estimated "To Go" costs for San Onofre Units 2&3 License Termination, Spent Fuel (i.e., Irradiated Fuel) Management, and ISFSI Decommissioning (NRC-Required Costs) are fully funded by the 12/31/2024 Net Trust Balance, the temporary shortfall for San Onofre Units 2 Site Restoration costs (non NRC-Required Costs) does not trigger the requirement in 10 CFR 50.82(vi) that this report must include additional financial assurance to cover the estimated cost of completion.
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