ML14078A028

Access to Nuclear Decommissioning Trust Funds

ML14078A028
Person / Time
Site:	San Onofre
Issue date:	03/12/2014
From:	Brabec R Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14078A028 (6)

Text

ISOUTHERN EDISON" CALIFORNIA An EDISON INTERNATIONAL" Company Richard C. Brabec Principal Manger, Nuclear Regulatory Affairs and Emergency Planning March 12, 2014 10 CFR 50.82(a)(8)(i)(A) 10 CFR 50.75(h)(2) 10 CFR 50.12 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362, San Onofre Nuclear Generating Station, Units 2 and 3 Access to Nuclear Decommissioning Trust Funds

Reference:

Letter from Thomas J. Palmisano, Southern California Edison to U. S.

Nuclear Regulatory Commission, Access to Nuclear Decommissioning Trust Funds, dated February 13, 2014

Dear Sir or Madam:

SCE and the NRC staff have discussed whether or not exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(2) are required to support access to the Decommissioning Trust Funds set aside by the San Onofre participants in support of various activities required to decommission the site and to meet various regulatory and statutory obligations. The path forward agreed upon was a dual track submittal. The next step was the referenced letter which requested that the NRC either agree that such exemptions are not necessary or grant appropriate exemption(s) to clearly allow use of all the NDTs for their intended purposes.

It was our understanding that the staff would begin with a review to determine whether or not the NRC staff agreed that exemptions are not required. If such a conclusion appeared unlikely in a timely manner, the NRC staff was to notify SCE that the exemption is the best path forward and promptly begin its review. The content of Enclosure 2 to that letter was an exemption request similar to equivalent submittals on other dockets thereby facilitating the NRC's review.

P. O. Box 128 San Clemente, CA 92672 ýCc9

Document Control Desk March 12, 2014 On March 5, 2014 SCE and NRC staff discussed the progress on the review of the dual purpose letter. The NRC staff indicated that the most timely path would be to pursue the exemption(s). The staff further indicated that the technical/financial aspects of the review could be completed very promptly and that issuance could follow soon thereafter and in no case later than the end of the second quarter which was consistent with our previous request.

As previously noted we will work closely with the NRC to avoid any adverse financial impact or delays in the decommissioning of SONGS Units 2 and 3. It remains imperative that access to these funds not be delayed significantly beyond the time-frame expected to set up appropriate processes for CPUC oversight and authorization to access the funds in the NDTs.

SCE does understand that the limitations on use of the radiological decommissioning (also referred to as license termination) funds remain in effect thus partially limiting our access to those portions of the trust funds until after the Post Shutdown Decommissioning Activities Report (PSDAR) is filed, a public meeting is held and the report is accepted by the NRC. The requested exemption would confirm unlimited access of the SONGS participants to those portions of the trusts associated with spent fuel management and site restoration.

One request was made of SCE and is provided in the attached cash flow tables. to my February 13, 2014 letter included cash flows combined for both Units 2 and 3. The staff requested that the funds be separated to better correlate the cash flows to the trusts supporting each unit which would allow them to provide continued assurance that there is sufficient funding remaining for radiological decommissioning for each, separate unit. Attachment 1 provides cash flows by unit and includes updated balances as of December 31, 2013 which will be consistent with our annual 10 CFR 50.75(f)(1) reports due later this month.

In deriving the annual cash flows from the July 2013 site specific cost study, SCE refined and improved the method by which some costs were allocated in certain years.

Thus, the total annual cash flows in Attachment 1 vary from the annual cash flows provided in the prior submittal even though they are based upon the same study.

Finally, the July 2013 study provided cash flows in 2011 dollars, but the cash flows in have been escalated to 2013 dollars, so that they can be more accurately compared to the 2013 balances.

If there are any questions or if additional information is needed, please contact Mr. Ken Wilson at (949) 368-9514. ZI Sil

Document Control Desk March 12, 2014 Attachment

1. SONGS Units 2 and 3 Nuclear Decommissioning Trust Funds Annual Cost and Contribution Cash Flows Separated by Unit cc: Mark Dapas, Regional Administrator, NRC Region IV M. H. Chernoff, NRC Project Manager, San Onofre Units 2 and 3 Decommissioning R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3 G. G. Warrick, NRC Senior Resident Inspector, San Onofre Units and 2

Document Control Desk March 12, 2014 ATTACHMENT 1 SONGS UNITS 2 AND 3 NUCLEAR DECOMMISSIONING TRUST FUNDS ANNUAL COST AND CONTRIBUTION CASH FLOWS SEPARATED BY UNIT

March 12, 2014 SONGS Unit 2 Decommissioning Funding Summary Year Radiological Spent Fuel Site Total Contributions Available Funds Decontamination Management Restoration to Trust Fund 2013 36,774 17,022 65,401 119,197 - $ 1,847,000 2014 72,949 33,767 15,104 121,820 23,400 2015 77,044 40,942 10,781 128,767 23,400 2016 81,294 48,132 14,195 143,622 23,400 2017 81,072 48,001 14,157 143,229 23,400 2018 81,072 48,001 14,157 143,229 23,400 2019 81,072 48,001 14,157 143,229 23,400 2020 81,294 48,132 14,195 143,622 23,400 2021 81,072 48,001 14,157 143,229 23,400 2022 81,072 48,001 14,157 143,229 23,400 2023 81,072 48,001 14,157 143,229 2024 26,253 13,032 69,736 109,021 2025 14,659 12,996 69,545 97,201 2026 14,659 12,996 69,545 97,201 2027 7,269 20,327 34,487 62,084 2028 - 7,990 - 7,990 2029 - 7,968 - 7,968 2030 - 7,968 - 7,968 2031 - 7,968 - 7,968 2032 - 7,990 - 7,990 2033 - 7,968 - 7,968 2034 - 7,968 - 7,968 2035 - 7,968 - 7,968 2036 - 7,990 - 7,990 2037 - 7,968 - 7,968 2038 - 7,968 - 7,968 2039 - 7,968 - 7,968 2040 - 7,990 - 7,990 2041 - 7,968 - 7,968 2042 - 7,968 - 7,968 2043 - 7,968 - 7,968 2044 - 7,990 - 7,990 2045 - 7,968 - 7,968 2046 - 7,968 - 7,968 2047 - 7,968 - 7,968 2048 - 7,990 - 7,990 2049 - 7,968 - 7,968 2050 774 8,432 9,741 18,946 2051 774 8,432 5,197 14,403

$900,174 $727,643 $462,867 $2,090,684 $ 210,600 Notes: Costs are in 2013 dollars (in thousands).

Trust fund balance at December 31, 2013 was $1,847,000 (net of estimated taxes)

March 12, 2014 SONGS Unit 3 Decommissioning Funding Summary Radiological Spent Fuel Site Total Contributions Available Year Decontamination Management Restoration to Trust Fund Funds 2013 22,631 20,026 66,872 109,528 - $ 2,079,400 2014 44,892 39,726 19,231 103,848 7,300 2015 64,706 43,719 14,471 122,896 7,300 2016 84,427 47,778 17,384 149,590 7,300 2017 84,197 47,648 17,337 149,181 7,300 2018 84,197 47,648 17,337 149,181 7,300 2019 84,197 47,648 17,337 149,181 7,300 2020 84,427 47,778 17,384 149,590 7,300 2021 84,197 47,648 17,337 149,181 7,300 2022 84,197 47,648 17,337 149,181 7,300 2023 84,197 47,648 17,337 149,181 2024 25,592 13,815 80,398 119,806 2025 14,122 13,778 80,398 108,298 2026 14,122 13,778 80,178 108,078 2027 7,003 21,031 39,760 67,794 2028 - 8,826 - 8,826 2029 - 8,802 - 8,802 2030 - 8,802 - 8,802 2031 - 8,802 - 8,802 2032 - 8,826 - 8,826 2033 - 8,802 - 8,802 2034 - 8,802 - 8,802 2035 - 8,802 - 8,802 2036 - 8,826 - 8,826 2037 8,802 - 8,802 2038 - 8,802 - 8,802 2039 - 8,802 - 8,802 2040 - 8,826 - 8,826 2041 - 8,802 - 8,802 2042 - 8,802 - 8,802 2043 - 8,802 - 8,802 2044 - 8,826 - 8,826 2045 - 8,802 - 8,802 2046 - 8,802 - 8,802 2047 - 8,802 - 8,802 2048 - 8,826 - 8,826 2049 - 8,802 - 8,802 2050 995 9,338 60,218 70,552 2051 995 9,338 55,723 66,056 869,093 759,789 636,038 2,264,920 $ 65,700 Notes: Costs are in 2013 dollars (in thousands).

Trust fund balance at December 31, 2013 was $2,079,000 (net of estimated taxes).