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| number = ML111300400 | | number = ML111300400 | ||
| issue date = 05/10/2011 | | issue date = 05/10/2011 | ||
| title = | | title = Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report | ||
| author name = Hall J | | author name = Hall J | ||
| author affiliation = NRC/NRR/DORL/LPLIV | | author affiliation = NRC/NRR/DORL/LPLIV | ||
| addressee name = Conklin L | | addressee name = Conklin L | ||
Line 19: | Line 19: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 This Request for Additional Information (RAI) is in response to Southern California Edisons (SCEs) 2011 Decommissioning Funding Status (DFS) report for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. On March 30, 2011, SCE submitted to the Nuclear Regulatory Commission (NRC) the 2011 DFS report for SONGS Units 2 and 3, as required under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, paragraph 50.75(f)(1) | ||
RAI No. 1: | (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110900660). The NRC staff has reviewed SCEs DFS report and requests responses to the following questions in order to complete its review. | ||
RAI No. 1: Minimum DFA calculation: | |||
Provide the labor, energy, and burial factors used in the calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS report. | Provide the labor, energy, and burial factors used in the calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS report. | ||
On March 30, 2011, SCE reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) less than the amount calculated by the NRC staff. | On March 30, 2011, SCE reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) less than the amount calculated by the NRC staff. | ||
According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c). | |||
According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be | The formulas for the factors used by the staff can be found using NUREG-1307, Rev. 14, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities. For example, the calculations for the Labor and Energy Adjustment Factors can be found on pages 7 and 8 of NUREG-1307, Rev. 14. | ||
The formulas for the factors used by the staff can be found using NUREG-1307, Rev. 14, | RAI No. 2: Reporting requirements: | ||
RAI No. 2: | |||
SCE should indicate whether there are any material changes to the trust agreements from the last submittal. | SCE should indicate whether there are any material changes to the trust agreements from the last submittal. | ||
On March 30, 2011, SCE reported that none of the licensees were relying on any contracts pursuant to 10 CFR 50.75(e)(1)(v) and that there were no modifications to their method of providing financial assurance. However, SCE did not indicate if there were any material changes to the trust agreements from the last submittal. | On March 30, 2011, SCE reported that none of the licensees were relying on any contracts pursuant to 10 CFR 50.75(e)(1)(v) and that there were no modifications to their method of providing financial assurance. However, SCE did not indicate if there were any material changes to the trust agreements from the last submittal. | ||
As stated under 10 CFR 50.75(f)(1): | As stated under 10 CFR 50.75(f)(1): | ||
ENCLOSURE | |||
[T]he information in [the DFS] report must include [. . .] any contracts upon which the licensee is relying under paragraph (e)(1)(v) of this section; any modifications occurring to a licensees current method of providing financial assurance since the last submitted report; and any material changes to trust agreements. . . | |||
RAI No. 3: Citation for real rate of returns: | |||
Provide the citation(s) (e.g, an Order by the rate-regulatory authority) by the regulatory entity that allows for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors assumed in your DFS report. | |||
On March 30, 2011, SCE reported the following for the joint owners of SONGS 2 and 3: | |||
SCE: | |||
6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.46 percent rate of earnings on decommissioning funds. | |||
San Diego Gas & Electric (SDG&E): | San Diego Gas & Electric (SDG&E): | ||
6.93 percent rate of escalation in burial costs, | 6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.14 percent rate of earnings on decommissioning funds. | ||
City of Anaheim (Anaheim): | City of Anaheim (Anaheim): | ||
4 percent rate of escalation in decommissioning costs, | 4 percent rate of escalation in decommissioning costs, 4 percent rate of earnings on decommissioning funds. | ||
City of Riverside (Riverside): | City of Riverside (Riverside): | ||
4 percent rate of escalation in decommissioning costs, | 4 percent rate of escalation in decommissioning costs, 3.87 percent rate of earnings on decommissioning funds. | ||
As stated in 10 CFR 50.75(f)(1), | |||
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . . | |||
RAI No. 4: Rate of escalation clarification: | |||
Clarify which escalation costs are attributable to radiological costs associated for radiological decommissioning. Define what other costs imply and why Riverside and Anaheim do not have | |||
such a breakdown. Also, clarify for the NRC staffs review, why Riverside has an escalation factor higher than its rate of earnings. | |||
On March 30, 2011, SCE provided the escalation decommissioning costs for site specific decommissioning and the rate of earnings for each joint owner of SONGS 2 and 3. | |||
As stated in 10 CFR 50.75(f)(1): | |||
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . . | |||
RAI No. 5: Annual collections: | |||
As stated in 10 CFR 50.75(f)(1): | |||
RAI No. 5: | |||
Indicate whether SCE and its joint owners will have future collections into the trust funds. If so, provide a breakdown of the annual decommissioning contributions that will be accumulated for only radiological decommissioning costs. | Indicate whether SCE and its joint owners will have future collections into the trust funds. If so, provide a breakdown of the annual decommissioning contributions that will be accumulated for only radiological decommissioning costs. | ||
Within the March 30, 2011, DFS report, SCE included the contributions for the year 2011, but does not indicate if there are future contributions. | Within the March 30, 2011, DFS report, SCE included the contributions for the year 2011, but does not indicate if there are future contributions. | ||
As stated under 10 CFR 50.75(f)(1): | |||
As stated under 10 CFR 50.75(f)(1): | [T]he information in [the DFS] report must include [. . .] a schedule of the annual amounts remaining to be collected. . . | ||
RAI No. 6: Citation for Site-Specific Study: | |||
RAI No. 6: | |||
Provide the site-specific cost estimate for SONGS 2 and 3, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars. | Provide the site-specific cost estimate for SONGS 2 and 3, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars. | ||
On March 30, 2011, SCE provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required in 2009 dollars, but did not include the cost escalation factor(s) that would be used to escalate the site-specific cost estimate to 2010 dollars. | On March 30, 2011, SCE provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required in 2009 dollars, but did not include the cost escalation factor(s) that would be used to escalate the site-specific cost estimate to 2010 dollars. | ||
Per 10 CFR 50.75(e)(1)(i) and (ii), the licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.}} | Per 10 CFR 50.75(e)(1)(i) and (ii), the licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.}} |
Latest revision as of 03:22, 11 March 2020
ML111300400 | |
Person / Time | |
---|---|
Site: | San Onofre ![]() |
Issue date: | 05/10/2011 |
From: | Hall J Plant Licensing Branch IV |
To: | Conklin L Southern California Edison Co |
Hall, J R, NRR/DORL/LPL4,301-415-4032 | |
Shared Package | |
ML11130094 | List: |
References | |
TAC ME5532, TAC ME5533 | |
Download: ML111300400 (3) | |
Text
REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2011 DECOMMISSIONING FUNDING STATUS REPORT FOR SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 This Request for Additional Information (RAI) is in response to Southern California Edisons (SCEs) 2011 Decommissioning Funding Status (DFS) report for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. On March 30, 2011, SCE submitted to the Nuclear Regulatory Commission (NRC) the 2011 DFS report for SONGS Units 2 and 3, as required under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, paragraph 50.75(f)(1)
(Agencywide Documents Access and Management System (ADAMS) Accession No. ML110900660). The NRC staff has reviewed SCEs DFS report and requests responses to the following questions in order to complete its review.
RAI No. 1: Minimum DFA calculation:
Provide the labor, energy, and burial factors used in the calculation of the minimum requirement for decommissioning financial assurance and, if necessary, a corrected submittal for that part of the DFS report.
On March 30, 2011, SCE reported an amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c) less than the amount calculated by the NRC staff.
According to 10 CFR 50.75(f)(1), the amount provided in the DFS report should be the amount of decommissioning funds estimated to be required under 10 CFR 50.75(b) and (c).
The formulas for the factors used by the staff can be found using NUREG-1307, Rev. 14, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities. For example, the calculations for the Labor and Energy Adjustment Factors can be found on pages 7 and 8 of NUREG-1307, Rev. 14.
RAI No. 2: Reporting requirements:
SCE should indicate whether there are any material changes to the trust agreements from the last submittal.
On March 30, 2011, SCE reported that none of the licensees were relying on any contracts pursuant to 10 CFR 50.75(e)(1)(v) and that there were no modifications to their method of providing financial assurance. However, SCE did not indicate if there were any material changes to the trust agreements from the last submittal.
As stated under 10 CFR 50.75(f)(1):
ENCLOSURE
[T]he information in [the DFS] report must include [. . .] any contracts upon which the licensee is relying under paragraph (e)(1)(v) of this section; any modifications occurring to a licensees current method of providing financial assurance since the last submitted report; and any material changes to trust agreements. . .
RAI No. 3: Citation for real rate of returns:
Provide the citation(s) (e.g, an Order by the rate-regulatory authority) by the regulatory entity that allows for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other factors assumed in your DFS report.
On March 30, 2011, SCE reported the following for the joint owners of SONGS 2 and 3:
SCE:
6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.46 percent rate of earnings on decommissioning funds.
San Diego Gas & Electric (SDG&E):
6.93 percent rate of escalation in burial costs, 2.32 percent rate of escalation in other costs, and 4.14 percent rate of earnings on decommissioning funds.
City of Anaheim (Anaheim):
4 percent rate of escalation in decommissioning costs, 4 percent rate of earnings on decommissioning funds.
City of Riverside (Riverside):
4 percent rate of escalation in decommissioning costs, 3.87 percent rate of earnings on decommissioning funds.
As stated in 10 CFR 50.75(f)(1),
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .
RAI No. 4: Rate of escalation clarification:
Clarify which escalation costs are attributable to radiological costs associated for radiological decommissioning. Define what other costs imply and why Riverside and Anaheim do not have
such a breakdown. Also, clarify for the NRC staffs review, why Riverside has an escalation factor higher than its rate of earnings.
On March 30, 2011, SCE provided the escalation decommissioning costs for site specific decommissioning and the rate of earnings for each joint owner of SONGS 2 and 3.
As stated in 10 CFR 50.75(f)(1):
[T]he information in [the DFS] report must include [. . .] the assumptions used regarding rates of escalation in decommissioning costs, rates of earnings on decommissioning funds, and rates of other factors used in funding projections. . .
RAI No. 5: Annual collections:
Indicate whether SCE and its joint owners will have future collections into the trust funds. If so, provide a breakdown of the annual decommissioning contributions that will be accumulated for only radiological decommissioning costs.
Within the March 30, 2011, DFS report, SCE included the contributions for the year 2011, but does not indicate if there are future contributions.
As stated under 10 CFR 50.75(f)(1):
[T]he information in [the DFS] report must include [. . .] a schedule of the annual amounts remaining to be collected. . .
RAI No. 6: Citation for Site-Specific Study:
Provide the site-specific cost estimate for SONGS 2 and 3, unless it was previously submitted to NRC. If the cost estimate was previously submitted to NRC, then provide a reference to its submittal. The site-specific cost estimate should include a summary schedule of annual expenses, projected earnings, and end-of-year fund balances, expressed in 2010 dollars.
On March 30, 2011, SCE provided a site-specific cost estimate for the amount of decommissioning funds estimated to be required in 2009 dollars, but did not include the cost escalation factor(s) that would be used to escalate the site-specific cost estimate to 2010 dollars.
Per 10 CFR 50.75(e)(1)(i) and (ii), the licensee must specifically describe the safe storage period in order to take credit for projected future earnings when it uses a site-specific estimate as the basis for using the prepayment or external sinking fund methods of financial assurance.