ML15349A942

San Onofre, Units 1, 2, and 3 - Submittal of 10 CFR 72.30 ISFSI Decommissioning Funding Plan

ML15349A942
Person / Time
Site:	San Onofre
Issue date:	12/14/2015
From:	Palmisano T J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML15349A942 (8)

Text

2, OTENCALIFORNIAl-- EDISONAn EDISON INTERNATIONAL CompanyThomas 1. PalmisanoVice President Decommissioning &Chief Nuclear OfficerDecember 14, 201510 CFR 72.30ATTN: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, D. C. 20555-0001

Subject:

Docket No. 50-206, 50-361, 50-362, and 72-4110 CFR 72.30 ISFSI Decommissioning Funding PlanSan Onofre Nuclear Generating Station Units 1, 2, & 3

Dear Sir or Madam:

As required by 10 CFR 72.30, this letter provides the decommissioning funding plan for the SanOnofre Nuclear Generating Station Units 1, 2, and 3 shares of the SONGS Independent SpentFuel Storage Installation. The required information is provided for Southern California Edison,San Diego Gas & Electric, the City of Anaheim, and the City of Riverside.There are no new commitments contained in this letter or its enclosure.If you have any questions regarding this matter, please contact Mr. Jim Kay, Manager, NuclearRegulatory Affairs, at (949) 368-7418.I declare under penalty of perjury that the foregoing is true and correct.Executed on / ,/,,-,.-Sincerely,

Enclosure:

San Onofre Nuclear Generating Station ISFSI Decommissioning FundingPlancc: M. Dapas, Regional Administrator, NRC Region IVM. G. Vaaler, NRC Project Manager, San Onofre Units 1, 2 and 3W. C. Allen, NRC Project Manager, San Onofre ISFSIj~>S2~QP.O. Box 128San Clemente, CA 92674(949) 368-6575Fax: (949) 368-6183tom~palmisano@sce.com EnclosureSan Onofre Nuclear Generating StationISFSI Decommissioning Funding Plan San Onofre Nuclear Generating Station ISFSIDecommissioning Funding PlanThe Independent Spent Fuel Storage Facility (ISFSI) at the San Onofre Nuclear GeneratingStation (SONGS) is located on the partially decommissioned site of SONGS Unit 1, and isoperated under a 10 CFR 72 General License issued to holders of a 10 CFR 50 license.The decommissioning funding requirements for the San Onofre Nuclear Generating Station(SONGS) Independent Spent Fuel Storage Installation (ISFSI) are currently addressed in theSONGS Unit I site-specific decommissioning cost estimate and the SONGS Units 2 and 3 site-specific decommissioning cost estimate.Provided below is the information required by 10 CFR 72.30(b) for the SONGS Units 1, 2, and 3ISFSI Decommissioning Funding Plan.The SONGS Unit 1 co-owners are reported as follows:Southern California Edison (SCE)San Diego Gas & Electric (SDG&E)80.00 %20.00 %100.00 %The SONGS Units 2 and 3 co-owners and former co-owner, Anaheim, are reported as follows:Southern California Edison (SCE)San Diego Gas & Electric (SDG&E)City of Anaheim (Anaheim)City of Riverside (Riverside)78.21 %20.00 %0.00 %1.79 %100.00 %The decommissioning liability is shared between the current co-owners and former co-owner,Anaheim, as set forth below for each unit:Owner Unit 1 Unit 2 Unit 3Decommissioning Decommissioning DecommissioningLiability Liability LiabilitySCE 80.00% 75.7363% 75.7475%SDG&E 20.00% 20.00% 20.00%Anaheim 0.00% 2.4737% 2.4625%Riverside 0.00% 1.7900% 1.7900%1) Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI or MRS:All costs associated with the decommissioning of the SONGS ISFSI are included in thesite-specific decommissioning cost estimates for SONGS Units 1, 2, and 3. SCE'scurrent site-specific decommissioning cost estimates (100% share, 2014 dollars)are as1 SONGS Unit 1"To Go" Radiological Costs*"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (cinc. ISFSI Decom.)Total "To Go" Costs as of 1/112015SONGS Unit 2"To Go" Radiological Costs"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (inc. ISFSI Decom.)Total "To Go" Costs as of 1/1/2015SONGS Unit 3"To Go" Radiological Costs"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (inc. ISFSI Decom.)Total "To Go" Costs as of 1/1/2015$115.5 million$ 77.2 million$ 6.5 million$ 199.2 million$ 939.4 million$ 369.6 million$ 545.5 million$1,854.5 million$ 983.5 million$ 545.7 million$ 576.1 million$ 2,105.3 millionThe Decommissioning Trust Fund balances (2014 dollars) for SONGS Units 1, 2, and 3,as of December 31, 2014, (net of estimated capital gains taxes) were:(3)Co-ParticipantsSCESDG&ETOTALCo-ParticipantsSCESDG&EAnaheimRiversideTOTALLess: 2013-2014 CostsNet BalancesCo-ParticipantsSCESDG&EAnaheimRiversideTOTALLess: 2013-2014 CostsNet BalancesSONGS Unit 1$ 230.1 million$ 131.4 million$ 361.5 millionSONGS Unit 2$1,465.4 million$ 410.9 million$ 61.8 million$ 37.7 million$1,975.8 million$ 226.2 million$1,749.6 millionSONGS Unit 3$1,641.3 million$ 465.3 million$ 67.2 million$ 40.6 million$2,214.4 million$ 225.2 million$1,989.2 million2 Each Co-owner's current annual contribution amounts (2014 dollars) to SONGS Units 2and 3 decommissioning trusts are as follows:Co-ParticipantSCESDG&EAnaheimRiversideSONGS Unit 1$ 0.0 million$ 0.0 millionNot ApplicableNot Applicable$ 0.0 millionSONGS Unit 2$ 0.0 million$ 5.8 million$ 0.0 million$ 0.0 million$ 5.8 millionSONGS Unit 3$ 0.0 million$ 2.2 million$ 0.0 million$ 0.0 million$ 2.2 million2) A detailed cost estimate for ISFSI decommissioning, in an amountreflecting:(i) The cost of an independent contractor to perform alldecommissioning activities;(ii) An adequate contingency factor; and(iii) The cost of meeting the 20.1402 of this chapter criteria forunrestricted use, provided that, if the applicant or licensee candemonstrate its ability to meet the provisions of 20.1403 of thischapter, the cost estimate may be based on meeting the 20.1403criteria.SCE's site-specific decommissioning cost estimates for SONGS Units 1, 2, and 3 weredeveloped under the assumption that SCE would be the decommissioning agent anddirect all ISESI decommissioning work. The site-specific estimates for ISESIdecommissioning, and decommissioning trust funds currently allocated to ISESIdecommissioning, (100% share, 2014 dollars) are as follows:SONGS Unit 1SONGS Unit 2SONGS Unit 3TOTALISFSI Decom Cost Funds Allocated to ISESI Decom$ 4.8 million $ 8.7 million$ 15.3 million $ 15.7 million$ 15.3 million $ 15.7 million$ 35.4 million $ 40.1 millionThese site-specific ISESI decommissioning estimates include a 25% contingency factor.The site-specific decommissioning cost estimates for SONGS Units 1, 2, and 3 includethe cost of meeting the 10 CER 20.1402 radiological criteria for unrestricted site use.3) Identification of and justification for using the key assumptions containedin the decommissioning cost estimate.The SONGS Units 1, 2, and 3 site-specific decommissioning cost estimates contain thefollowing key assumptions that pertain to spent fuel storage and ISESI decommissioning:3 SONGS Unit 1:* Permanently retired on November 30, 1992* 395 fuel assemblies in 17 canisters are located in the SONGS ISFSI* 1 canister of Greater Than Class C (GTCC) waste is located in the SONGSISFSI* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Unit 1 fuel from the ISFSI by 2036SONGS Unit 2:* Permanently ceased operations on June 7, 2013* 408 fuel assemblies in 17 canisters are currently located in the SONGS ISESI* 1,318 fuel assemblies are scheduled to be placed in canisters in the SONGSISESI by 2019* Greater Than Class C (GTCC) waste will be placed in the SONGS ISFSI perschedule to be developed by future Decommissioning General Contractor* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Units 2 & 3 fuel from the ISESI by 2049SONGS Unit 3:* Permanently ceased operations on June 7, 2013* 384 fuel assemblies in 16 canisters are currently located in the SONGS ISESI* 1,350 fuel assemblies are scheduled to be placed in canisters in the SONGSISESI by 2019* Greater Than Class C (GTCC) waste will be placed in the SONGS ISFSI perschedule to be developed by future Decommissioning General Contractor* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Units 2 & 3 fuel from the ISESI by 2049SONGS ISFSI* The SONGS ISESI will be decommissioned and the plant and ISFSI site will bedecontaminated to meet 10 CFR 20.1402 site release criteria for unrestricteduse as required to terminate the 10 CER 50 licenses and the 10 CFR 72General License by 2051.These assumptions will be updated periodically due to the ongoing uncertaintiesregarding the availability of a permanent repository for spent fuel.The assumption above regarding DOE commencing the transport of spent fuelassemblies to an offsite repository in 2024 is consistent with the most recentassumptions approved in proceedings before the California Public Utilities Commission(CPUC). This assumption will be updated periodically due to the ongoing uncertaintiesregarding the availability of a permanent repository for spent fuel.4

4) A description of the method of assuring funds for decommissioning fromparagraph (e) of this section, including means for adjusting cost estimatesand associated funding levels periodically over the life of the facility.Pursuant to 10 CER 72.30(e)(5), power reactor licensees are authorized to use thefinancial assurance methods provided for in 10 CER 50.75(e). All four Co-Participantsrecover the cost of decommissioning pursuant to cost-of-service rate regulation and,therefore, are eligible to provide assurance using the external sinking fund methodprovided for in 10 CFR 50.75(e)(1)(ii). To the extent the decommissioning costs are fullyfunded and annual deposits are no longer required, the Co-Participants provideassurance 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 theSONGS facility under the California Nuclear Facilities Decommissioning Act, CA PublicUtilities Code Section 8321, et seq. The California Public Utilities Commission (CPUC)has construed the SONGS decommissioning obligation to include: (1) radiologicaldecommissioning as required to terminate the NRC licenses, (2) spent fuel storage(including ISFSI decommissioning), and (3) site restoration as required to terminate theSONGS site lease contracts granted by the U.S. Department of the Navy and theCalifornia State Lands Commission.Under CA Public Utilities Code Section 8326(a)(2), SCE and SDG&E are required toupdate their site-specific nuclear facility decommissioning cost estimates periodically toreflect changes in decommissioning regulation, technology, and economics, for thepurpose of adjusting contribution levels to their decommissioning trust.Under CA Public Utilities Code Sections 8326(b), 8327, 8328, and 8329, the CPUCperiodically reviews SCE and SDG&E's site-specific decommissioning cost estimates forthe purpose of considering changes in electrical rates to ensure that sufficient funds willbe available for payment of all decommissioning costs.The Cities of Anaheim and Riverside are not under the jurisdiction of the CPUC.Each Co-Participant deposits its decommissioning fund contributions into one or moreexternal sinking funds as provided in 10 CFR 50.75(e)(1)(ii). The Co-Participants'decommissioning fund accumulations and annual contribution rates are provided in theresponse to Question 1, above.5) The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination.The ISFSI does not contribute to subsurface material containing residual radioactivitybecause the dry shielded canisters are double seal welded and designed to meet thecriteria of Interim Staff Guidance-I18, Revision 1, "The Design and Testing of Lid Weldson Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent FuelStorage." This prevents the release of radionuclides in liquid or gaseous effluents fromthe SONGS ISFSI to the environment.5 The SONGS ISFSI is located on the partially decommissioned site of SONGS Unit 1.The SONGS Unit 1 site-specific decommissioning cost estimate includes a volume ofonsite subsurface material requiring some residual remediation to meet the criteria forlicense termination for the entire SONGS Unit 1 site.6) A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning.Financial assurance for ISESI decommissioning funding is provided through the processused to fund the decommissioning cost estimates of SONGS Units 1, 2, and 3 asdescribed in the responses to Questions 1 and 4 above.Notes: (1) The site-specific decommissioning cost estimate for SONGS Unit 1 that wasprovided to the California Public Utilities Commission (CPUC) on December 21,2012, includes the SONGS Unit 1 share of: (1) spent fuel storage and ISESIdecommissioning costs; (2) the remaining radiological costs associated withterminating the site license for SONGS Unit 1; (3) non-radiological costs,including the costs to excavate and dispose of all remaining structures,appurtenances, and foundations from the SONGS Unit 1 onshore site, to performfinal site restoration; and to disposition the SONGS Unit 1 offshore circulatingwater conduits. The CPUC approved the SONGS Unit 1 decommissioning costestimate on December 18, 2014.(2) The site-specific decommissioning cost estimate for SONGS Units 2 and 3 thatwere provided to the CPUC on December 10, 2014, include the SONGS Units 2and 3 shares of: (1) spent fuel storage and ISESI decommissioning costs; (2)radiological costs associated with terminating the site licenses for SONGS Units2 and 3; (3) non-radiological costs, including the costs to excavate and disposeof all remaining structures, appurtenances, and foundations from the SONGSUnits 2 and 3 onshore site, and to perform final site restoration; and the costs todisposition the SONGS Units 2 and 3 offshore circulating water conduits. Thisdecommissioning cost estimate is currently pending before the CPUC.(3) SCE is submitting information with respect to the SONGS decommissioning co-participants, SDG&E, Anaheim, and Riverside. SDG&E, Anaheim, and Riversideare each responsible for the completeness and accuracy of their information.6 2, OTENCALIFORNIAl-- EDISONAn EDISON INTERNATIONAL CompanyThomas 1. PalmisanoVice President Decommissioning &Chief Nuclear OfficerDecember 14, 201510 CFR 72.30ATTN: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, D. C. 20555-0001

Subject:

Docket No. 50-206, 50-361, 50-362, and 72-4110 CFR 72.30 ISFSI Decommissioning Funding PlanSan Onofre Nuclear Generating Station Units 1, 2, & 3

Dear Sir or Madam:

As required by 10 CFR 72.30, this letter provides the decommissioning funding plan for the SanOnofre Nuclear Generating Station Units 1, 2, and 3 shares of the SONGS Independent SpentFuel Storage Installation. The required information is provided for Southern California Edison,San Diego Gas & Electric, the City of Anaheim, and the City of Riverside.There are no new commitments contained in this letter or its enclosure.If you have any questions regarding this matter, please contact Mr. Jim Kay, Manager, NuclearRegulatory Affairs, at (949) 368-7418.I declare under penalty of perjury that the foregoing is true and correct.Executed on / ,/,,-,.-Sincerely,

Enclosure:

San Onofre Nuclear Generating Station ISFSI Decommissioning FundingPlancc: M. Dapas, Regional Administrator, NRC Region IVM. G. Vaaler, NRC Project Manager, San Onofre Units 1, 2 and 3W. C. Allen, NRC Project Manager, San Onofre ISFSIj~>S2~QP.O. Box 128San Clemente, CA 92674(949) 368-6575Fax: (949) 368-6183tom~palmisano@sce.com EnclosureSan Onofre Nuclear Generating StationISFSI Decommissioning Funding Plan San Onofre Nuclear Generating Station ISFSIDecommissioning Funding PlanThe Independent Spent Fuel Storage Facility (ISFSI) at the San Onofre Nuclear GeneratingStation (SONGS) is located on the partially decommissioned site of SONGS Unit 1, and isoperated under a 10 CFR 72 General License issued to holders of a 10 CFR 50 license.The decommissioning funding requirements for the San Onofre Nuclear Generating Station(SONGS) Independent Spent Fuel Storage Installation (ISFSI) are currently addressed in theSONGS Unit I site-specific decommissioning cost estimate and the SONGS Units 2 and 3 site-specific decommissioning cost estimate.Provided below is the information required by 10 CFR 72.30(b) for the SONGS Units 1, 2, and 3ISFSI Decommissioning Funding Plan.The SONGS Unit 1 co-owners are reported as follows:Southern California Edison (SCE)San Diego Gas & Electric (SDG&E)80.00 %20.00 %100.00 %The SONGS Units 2 and 3 co-owners and former co-owner, Anaheim, are reported as follows:Southern California Edison (SCE)San Diego Gas & Electric (SDG&E)City of Anaheim (Anaheim)City of Riverside (Riverside)78.21 %20.00 %0.00 %1.79 %100.00 %The decommissioning liability is shared between the current co-owners and former co-owner,Anaheim, as set forth below for each unit:Owner Unit 1 Unit 2 Unit 3Decommissioning Decommissioning DecommissioningLiability Liability LiabilitySCE 80.00% 75.7363% 75.7475%SDG&E 20.00% 20.00% 20.00%Anaheim 0.00% 2.4737% 2.4625%Riverside 0.00% 1.7900% 1.7900%1) Information on how reasonable assurance will be provided that funds willbe available to decommission the ISFSI or MRS:All costs associated with the decommissioning of the SONGS ISFSI are included in thesite-specific decommissioning cost estimates for SONGS Units 1, 2, and 3. SCE'scurrent site-specific decommissioning cost estimates (100% share, 2014 dollars)are as1 SONGS Unit 1"To Go" Radiological Costs*"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (cinc. ISFSI Decom.)Total "To Go" Costs as of 1/112015SONGS Unit 2"To Go" Radiological Costs"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (inc. ISFSI Decom.)Total "To Go" Costs as of 1/1/2015SONGS Unit 3"To Go" Radiological Costs"To Go" Site Restoration Costs"To Go" Fuel Storage Costs (inc. ISFSI Decom.)Total "To Go" Costs as of 1/1/2015$115.5 million$ 77.2 million$ 6.5 million$ 199.2 million$ 939.4 million$ 369.6 million$ 545.5 million$1,854.5 million$ 983.5 million$ 545.7 million$ 576.1 million$ 2,105.3 millionThe Decommissioning Trust Fund balances (2014 dollars) for SONGS Units 1, 2, and 3,as of December 31, 2014, (net of estimated capital gains taxes) were:(3)Co-ParticipantsSCESDG&ETOTALCo-ParticipantsSCESDG&EAnaheimRiversideTOTALLess: 2013-2014 CostsNet BalancesCo-ParticipantsSCESDG&EAnaheimRiversideTOTALLess: 2013-2014 CostsNet BalancesSONGS Unit 1$ 230.1 million$ 131.4 million$ 361.5 millionSONGS Unit 2$1,465.4 million$ 410.9 million$ 61.8 million$ 37.7 million$1,975.8 million$ 226.2 million$1,749.6 millionSONGS Unit 3$1,641.3 million$ 465.3 million$ 67.2 million$ 40.6 million$2,214.4 million$ 225.2 million$1,989.2 million2 Each Co-owner's current annual contribution amounts (2014 dollars) to SONGS Units 2and 3 decommissioning trusts are as follows:Co-ParticipantSCESDG&EAnaheimRiversideSONGS Unit 1$ 0.0 million$ 0.0 millionNot ApplicableNot Applicable$ 0.0 millionSONGS Unit 2$ 0.0 million$ 5.8 million$ 0.0 million$ 0.0 million$ 5.8 millionSONGS Unit 3$ 0.0 million$ 2.2 million$ 0.0 million$ 0.0 million$ 2.2 million2) A detailed cost estimate for ISFSI decommissioning, in an amountreflecting:(i) The cost of an independent contractor to perform alldecommissioning activities;(ii) An adequate contingency factor; and(iii) The cost of meeting the 20.1402 of this chapter criteria forunrestricted use, provided that, if the applicant or licensee candemonstrate its ability to meet the provisions of 20.1403 of thischapter, the cost estimate may be based on meeting the 20.1403criteria.SCE's site-specific decommissioning cost estimates for SONGS Units 1, 2, and 3 weredeveloped under the assumption that SCE would be the decommissioning agent anddirect all ISESI decommissioning work. The site-specific estimates for ISESIdecommissioning, and decommissioning trust funds currently allocated to ISESIdecommissioning, (100% share, 2014 dollars) are as follows:SONGS Unit 1SONGS Unit 2SONGS Unit 3TOTALISFSI Decom Cost Funds Allocated to ISESI Decom$ 4.8 million $ 8.7 million$ 15.3 million $ 15.7 million$ 15.3 million $ 15.7 million$ 35.4 million $ 40.1 millionThese site-specific ISESI decommissioning estimates include a 25% contingency factor.The site-specific decommissioning cost estimates for SONGS Units 1, 2, and 3 includethe cost of meeting the 10 CER 20.1402 radiological criteria for unrestricted site use.3) Identification of and justification for using the key assumptions containedin the decommissioning cost estimate.The SONGS Units 1, 2, and 3 site-specific decommissioning cost estimates contain thefollowing key assumptions that pertain to spent fuel storage and ISESI decommissioning:3 SONGS Unit 1:* Permanently retired on November 30, 1992* 395 fuel assemblies in 17 canisters are located in the SONGS ISFSI* 1 canister of Greater Than Class C (GTCC) waste is located in the SONGSISFSI* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Unit 1 fuel from the ISFSI by 2036SONGS Unit 2:* Permanently ceased operations on June 7, 2013* 408 fuel assemblies in 17 canisters are currently located in the SONGS ISESI* 1,318 fuel assemblies are scheduled to be placed in canisters in the SONGSISESI by 2019* Greater Than Class C (GTCC) waste will be placed in the SONGS ISFSI perschedule to be developed by future Decommissioning General Contractor* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Units 2 & 3 fuel from the ISESI by 2049SONGS Unit 3:* Permanently ceased operations on June 7, 2013* 384 fuel assemblies in 16 canisters are currently located in the SONGS ISESI* 1,350 fuel assemblies are scheduled to be placed in canisters in the SONGSISESI by 2019* Greater Than Class C (GTCC) waste will be placed in the SONGS ISFSI perschedule to be developed by future Decommissioning General Contractor* DOE will commence transporting spent fuel assemblies to an offsiterepository in 2024* DOE will remove last SONGS Units 2 & 3 fuel from the ISESI by 2049SONGS ISFSI* The SONGS ISESI will be decommissioned and the plant and ISFSI site will bedecontaminated to meet 10 CFR 20.1402 site release criteria for unrestricteduse as required to terminate the 10 CER 50 licenses and the 10 CFR 72General License by 2051.These assumptions will be updated periodically due to the ongoing uncertaintiesregarding the availability of a permanent repository for spent fuel.The assumption above regarding DOE commencing the transport of spent fuelassemblies to an offsite repository in 2024 is consistent with the most recentassumptions approved in proceedings before the California Public Utilities Commission(CPUC). This assumption will be updated periodically due to the ongoing uncertaintiesregarding the availability of a permanent repository for spent fuel.4

4) A description of the method of assuring funds for decommissioning fromparagraph (e) of this section, including means for adjusting cost estimatesand associated funding levels periodically over the life of the facility.Pursuant to 10 CER 72.30(e)(5), power reactor licensees are authorized to use thefinancial assurance methods provided for in 10 CER 50.75(e). All four Co-Participantsrecover the cost of decommissioning pursuant to cost-of-service rate regulation and,therefore, are eligible to provide assurance using the external sinking fund methodprovided for in 10 CFR 50.75(e)(1)(ii). To the extent the decommissioning costs are fullyfunded and annual deposits are no longer required, the Co-Participants provideassurance 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 theSONGS facility under the California Nuclear Facilities Decommissioning Act, CA PublicUtilities Code Section 8321, et seq. The California Public Utilities Commission (CPUC)has construed the SONGS decommissioning obligation to include: (1) radiologicaldecommissioning as required to terminate the NRC licenses, (2) spent fuel storage(including ISFSI decommissioning), and (3) site restoration as required to terminate theSONGS site lease contracts granted by the U.S. Department of the Navy and theCalifornia State Lands Commission.Under CA Public Utilities Code Section 8326(a)(2), SCE and SDG&E are required toupdate their site-specific nuclear facility decommissioning cost estimates periodically toreflect changes in decommissioning regulation, technology, and economics, for thepurpose of adjusting contribution levels to their decommissioning trust.Under CA Public Utilities Code Sections 8326(b), 8327, 8328, and 8329, the CPUCperiodically reviews SCE and SDG&E's site-specific decommissioning cost estimates forthe purpose of considering changes in electrical rates to ensure that sufficient funds willbe available for payment of all decommissioning costs.The Cities of Anaheim and Riverside are not under the jurisdiction of the CPUC.Each Co-Participant deposits its decommissioning fund contributions into one or moreexternal sinking funds as provided in 10 CFR 50.75(e)(1)(ii). The Co-Participants'decommissioning fund accumulations and annual contribution rates are provided in theresponse to Question 1, above.5) The volume of onsite subsurface material containing residual radioactivitythat will require remediation to meet the criteria for license termination.The ISFSI does not contribute to subsurface material containing residual radioactivitybecause the dry shielded canisters are double seal welded and designed to meet thecriteria of Interim Staff Guidance-I18, Revision 1, "The Design and Testing of Lid Weldson Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent FuelStorage." This prevents the release of radionuclides in liquid or gaseous effluents fromthe SONGS ISFSI to the environment.5 The SONGS ISFSI is located on the partially decommissioned site of SONGS Unit 1.The SONGS Unit 1 site-specific decommissioning cost estimate includes a volume ofonsite subsurface material requiring some residual remediation to meet the criteria forlicense termination for the entire SONGS Unit 1 site.6) A certification that financial assurance for decommissioning has beenprovided in the amount of the cost estimate for decommissioning.Financial assurance for ISESI decommissioning funding is provided through the processused to fund the decommissioning cost estimates of SONGS Units 1, 2, and 3 asdescribed in the responses to Questions 1 and 4 above.Notes: (1) The site-specific decommissioning cost estimate for SONGS Unit 1 that wasprovided to the California Public Utilities Commission (CPUC) on December 21,2012, includes the SONGS Unit 1 share of: (1) spent fuel storage and ISESIdecommissioning costs; (2) the remaining radiological costs associated withterminating the site license for SONGS Unit 1; (3) non-radiological costs,including the costs to excavate and dispose of all remaining structures,appurtenances, and foundations from the SONGS Unit 1 onshore site, to performfinal site restoration; and to disposition the SONGS Unit 1 offshore circulatingwater conduits. The CPUC approved the SONGS Unit 1 decommissioning costestimate on December 18, 2014.(2) The site-specific decommissioning cost estimate for SONGS Units 2 and 3 thatwere provided to the CPUC on December 10, 2014, include the SONGS Units 2and 3 shares of: (1) spent fuel storage and ISESI decommissioning costs; (2)radiological costs associated with terminating the site licenses for SONGS Units2 and 3; (3) non-radiological costs, including the costs to excavate and disposeof all remaining structures, appurtenances, and foundations from the SONGSUnits 2 and 3 onshore site, and to perform final site restoration; and the costs todisposition the SONGS Units 2 and 3 offshore circulating water conduits. Thisdecommissioning cost estimate is currently pending before the CPUC.(3) SCE is submitting information with respect to the SONGS decommissioning co-participants, SDG&E, Anaheim, and Riverside. SDG&E, Anaheim, and Riversideare each responsible for the completeness and accuracy of their information.6