L-04-003, Independent Spent Fuel Storage Installation Supplemental General and Financial Information - 10 CFR 72.22

Independent Spent Fuel Storage Installation Supplemental General and Financial Information - 10 CFR 72.22

ML041240046
Person / Time
Site:	Humboldt Bay
Issue date:	04/23/2004
From:	Womack L Pacific Gas & Electric Co
To:	Document Control Desk, NRC/FSME
References
+sisprbs20051109, -RFPFR, HIL-04-003
Download: ML041240046 (8)

Text

W Pacific Gas and Electric Company Lawrence F. Womack Diablo Canyon Power Plant Vice President PO. Box 56 Nuclear Services Avila Beach. CA 93424 805.545.4600 April 23, 2004 Fax: 805.545.4234 PG&E Letter HIL-04-003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 72-27 Humboldt Bay Independent Spent Fuel Storage Installation Supplemental General and Financial Information - 10 CFR 72.22

Dear Commissioners and Staff:

By Pacific Gas and Electric Company (PG&E) Letter HIL-03-001, dated December 15, 2003, PG&E submitted an application to the Nuclear Regulatory Commission (NRC) requesting a site-specific license for an Independent Spent Fuel Storage Installation (ISFSI) at the Humboldt Bay Power Plant. The application included a Safety Analysis Report, Environmental Report, and other required documents in accordance with 10 CFR 72. to this letter provides supplemental general and financial information regarding 10 CFR 72.22, as requested by Mr. S. O'Connor and Mr. L. Pittiglio of the NRC staff, during a April 13, 2004, telephone conference call in support of the December 15, 2003, Humboldt Bay ISFSI license application.

Reference material, in support of the Humboldt Bay ISFSI License Application, Attachment F, "Preliminary Decommissioning Plan," is transmitted in Enclosure 2.

If you have any questions about this matter, please contact Mr. Terence Grebel at (805) 545-4160.

Sincerely, Lawrence F. Womack gwh Enclosures cc:

William C. Huffman Larry Pittiglio PG Fossil Gen HBPP Humboldt Distribution cc/enc:

Stephen C. O'Connor

/jmsOI PG&E Letter HIL-04-003 Sheet 1 of 5 10 CFR 72.22 Contents of Application: General and Financial Information 10 CFR 72.22 Section PG&E Response References Each application must state:

(a) Full name of applicant; Pacific Gas and Electric Company Application Section 1.2 (b) Address of applicant; Humboldt Bay Power Plant Application Sections 1.2 1000 King Salmon Avenue and 1.3 Eureka, CA 95503 Executive Offices 77 Beale Street P.O. Box 770000 San Francisco, CA 94177 (c) Description of business or Pacific Gas and Electric Company, including its subsidiaries, Application Section 1.3 occupation of applicant; is a wholly owned subsidiary of PG&E Corporation. PG&E Corporation is a holding company based in San Francisco, California, which provides energy services throughout North America.

(d) If applicant is:

(1) An individual: Citizenship and age; Not applicable (2) A partnership: Name, citizenship, Not applicable and address of each partner and the principal location at which the partnership does business; (3) A corporation or an unincorporated association:

(i) The State in which it is incorporated PG&E is a corporation organized and existing under the Application Section 1.4 or organized and the principal laws of the State of California and its principal office is location at which it does business; located in San Francisco, California.

and (ii) The names, addresses, and A list of officers is provided in the PG&E Corporation 2002 Application Section 1.4 citizenship of its directors and Annual Report, which is included as Attachment A to the and Attachment A pages principal officers.

Application. All directors and principal officers are United 185-186.

States citizens.

PG&E Letter HIL-04-003 Sheet 2 of 5 10 CFR 72.22 Contents of Application: General and Financial Information 10 CFR 72.22 Section PG&E Response References (4) Acting as an agent or Gregory M. Rueger representative of another person in Senior Vice President, Generation and filing the application. The Chief Nuclear Officer identification of the principal and 77 Beale Street, MC B32 the information required under this San Francisco, CA 94105 paragraph with respect to such principal.

(5) The Department of Energy:

Not applicable (i) The identification of the DOE Not applicable organization responsible for the construction and operation of the ISFSI or MRS, including a description of any delegations of authority and assignments of responsibilities.

(ii) For each application for a license Not applicable for an MRS, the provisions of the public law authorizing the construction and operation of the MRS.

PG&E Letter HIL-04-003 Sheet 3 of 5 10 CFR 72.22 Contents of Application: General and Financial Information 10 CFR 72.22 Section J

PG&E Response I

References (e) Except for DOE, information sufficient to demonstrate to the Commission the financial qualifications of the applicant to carry out, in accordance with the regulations in this chapter, the activities for which the license is sought. The information must state the place at which the activity is to be performed the general plan for carrying out the activity, and the period of time for which the license is requested. The information must show that the applicant either possesses the necessary funds, or that the applicant has reasonable assurance of obtaining the necessary funds; or that by a combination of the two, the applicant will have the necessary funds available to cover the following:

PG&E will have the financial qualifications to construct and operate the Humboldt Bay ISFSI. PG&E is an electric utility subject to rates established by the California Public Utilities Commission (CPUC). The funds necessary to cover the costs of constructing and operating the ISFSI will be paid from the Humboldt Nuclear Decommissioning Trusts as approved by the CPUC.

Application Sections 1.3 and 1.5.

Enclosure I PG&E Letter HIL-04-003 Sheet 4 of 5 10 CFR 72.22 Contents of Application: General and Financial Information 10 CFR 72.22 Section I

PG&E Response I

References (1) Estimated construction costs; PG&E Letter HBL-03-002, Decommissioning Funding Report for Humboldt Bay Power Plant Unit 3, dated March 27, 2003, was based on HBPP fuel remaining in the spent fuel pool until the DOE took possession after the opening of their Nuclear Fuel Repository in 2010.

Subsequent to the submittal of the Humboldt Bay ISFSI License Application on December 15, 2003, PG&E submitted, in PG&E Letter HBL-04-007, dated March 31, 2004, its Decommissioning Funding Report for Humboldt Bay Power Plant Unit 3, which reflects the cost estimates prepared by TLG Services, Inc. and adjustments as a result of the Nuclear Decommissioning Cost Triennial Proceeding (Decision 03-10-014 from the CPUC, dated October 2, 2003).

Costs for the Humboldt Bay ISFSI construction (including engineering and licensing) is $41.8 million (2004 dollars).

The operating costs of the ISFSI are estimated to be

$22.2 million, and an additional $3.0 million to transfer the fuel to DOE (in 2004 dollars). Operating costs are based on DOE opening a Fuel Repository in 2010 and taking possession of HBPP fuel by 2015.

The funds necessary for decommissioning of the proposed ISFSI are estimated to be approximately $0.9 million (2004 dollars). The detailed cost estimate was reflected in PG&E's March 2004 Decommissioning Funding Report to the Nuclear Regulatory Commission (PG&E Letter HBL-04-007) as required by 10 CFR 50.75 (f)(1). PG&E has established an external sinking fund account for decommissioning HBPP Unit 3, as discussed in the March 2004 Decommissioning Funding Report to the NRC.

This account includes monies for licensing, constructing, operating, and decommissioning the ISFSI.

Application Section 1.5 PG&E Letter HBL-03-002 PG&E Letter HBL-04-007 TLG Services, Inc.

Decommissioning Cost

Study, dated February 2002 J _________________________________________________________________

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PG&E Letter HIL-04-003 Sheet 5of5 10 CFR 72.22 Contents of Application: General and Financial Information 10 CFR 72.22 Section PG&E Response References (2) Estimated operating costs over See above.

the planned life of the ISFSI; and (3) Estimated decommissioning costs, As discussed in the HB ISFSI License Application, Application Section 1.5; and the necessary financial Attachment F, 'Preliminary Decommissioning Plan" Chapter Application Section 10.0; arrangements to provide 4, it is estimated that decommissioning for the Humboldt Application Attachment F, reasonable assurance before Bay ISFSI will cost approximately $ 0.9 million in 2002 Chapter 4 and 5.

licensing, that decommissioning will dollars and is also $0.9 million in 2004 dollars as stated in PG&E Letter HBL-03-002 be carried out after the removal of PG&E Letter HBL-04-007. This cost is a small fraction of the dated March 31, 2003; spent fuel, high-level radioactive entire decommissioning cost of Humboldt Bay Unit 3 as PG&E Letter HBL-04-007 waste, and/or reactor-related demonstrated below.

dated March 30, 2004 GTCC waste from storage.

Based on site-specific cost estimates prepared by TLG TLG Services, Inc.

Services, Inc. dated February 2002, and adjustments as a Decommissioning Cost result of the Nuclear Decommissioning Cost Triennial

Study, Proceeding (Decision 03-10-014 from the CPUC, dated dated February 2002 October 2, 2003), PG&E has estimated that the 2002 Nuclear decommissioning costs per 10 CFR 50.75 (c) are Decommissioning Cost approximately $284.3 million (including $16.6 million Triennial Proceeding, disbursed from the trusts through December 2003 and Decision 03-10-014,

$267.7 million future radiological removal costs) for HBPP dated October 2, 2003.

Unit 3 in 2004 dollars. These costs do not include the dismantling or demolishing the non-radiological nuclear portions of the facilities ($3.4 million in 2004 dollars), nor the licensing, construction, operation, and decommissioning of the ISFSI through 2015 ($68.0 million in 2004 dollars). The detailed decommissioning cost estimates were submitted to the NRC in the March 2003 Decommissioning Funding Report (PG&E Letter HBL-03-002) and in the March 2004 Decommissioning Funding Report (PG&E Letter HBL-04-007) required by 10 CFR 50.75(0(1). The 2004 report references the cost estimates prepared by TLG Services, Inc. and the Nuclear Decommissioning Cost Triennial Proceeding Decision 03-10-014.

PG&E Letter HIL-04-003 Sheet I of 1 Humboldt Bay ISFSI License Application Attachment F, Preliminary Decommissioning Plan Reference Material

1. TLG Services, Inc., Decommissioning Cost Study for the Humboldt Bay Power Plant Unit 3 2006 SAFSTOR, February 2002

2.

California Public Utilities Commission Decision 03-10-014, dated October 2, 2003, Application of the Pacific Gas and Electric Company in its 2002 Nuclear Decommissioning Cost Triennial Proceeding (Application 02-03-020, Filed March 15, 2002)

TLG Services, Inc., Decommissioning Cost Study for the Humboldt Bay Power Plant Unit 3 2006 SAFSTOR