ML13093A028
| ML13093A028 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 04/01/2013 |
| From: | Halpin E D Pacific Gas & Electric Co |
| To: | NRC/FSME, Document Control Desk |
| Shared Package | |
| ML130930039 | List: |
| References | |
| HBL-13-003 | |
| Download: ML13093A028 (70) | |
Text
m Pacific Gas and _E_le_c_t"_ic_C_o_m_'P_an_y April 1, 2013 PG&E Letter HBL-13-003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-133, License No. DPR-7 Humboldt Bay Power Plant, Unit 3 Edward D. Halpin Senior Vice President Oia'blo Canyon Power Plant Mail Code 104/6 Nuclear Generation
& Chief Nuclear Officer P. O. Box 56 Avila Beach, CA 93424 805.545.4100 E-Mail: E1H8@pge.com 10 CFR 50.75(f) 10 CFR 50.82(8)(v) 10 CFR 50.82(8)(vii)
Decommissioning Funding Report for Humboldt Bay Power Plant. Unit 3 Dear Commissioners and Staff: Pacific Gas and Electric Company (PG&E) is submitting its decommissioning funding report for Humboldt Bay Power Plant (HBPP), Unit 3, pursuant to the requirements of 10 CFR 50.75(f), 10 CFR 50.82(8)(v), and 10 CFR 50.82(8)(vii).
Humboldt Bay, Unit 3 At the end of calendar year 2012, the market value of the HBPP, Unit 3 (220 MWt) decommissioning trust funds was $272.0 million. PG&E estimates it will need to collect an additional
$474.4 million (future nominal dollars) over 4 years, beginning in 2014, based on a site-specific decommissioning cost estimate prepared by PG&E staff and submitted to the California Public Utilities Commission's Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) on December 21, 2012. The NDCTP application is based on actual bids for remaining HBPP civil work scope, costs for removal of underground reactor caisson, cost associated with a delay in the Department of Energy's acceptance of site-stored spent fuel, cost to remediate site radioactivity to nuclear resident farmer criteria, and updated remaining decommissioning costs based on actual past HBPP decommissioning data versus industry estimates.
The market value of the HBPP trust is lower than the minimum amount of the NRC decommissioning estimate of $687.2 million (2013 dollars) that was calculated pursuant to the requirements of 10 CFR 50.75(c), which is based on a minimum 1200 MWt plant. This is due to $268.5 million having been spent on decommissioning activities through December 2012, and an estimate to complete of $618.1 million for the NRC radiological scope. PG&E is confident the HBPP trust, with the noted additional contributions, will be sufficient to ensure successful decommissioning and maintaining the spent fuel in an independent spent fuel storage installation (ISFSI) at HBPP until 2025, based on the December 2012 site-specific decommissioning cost estimate prepared by PG&E staff.
m Document Control Desk April 1 ,2013 I & Page 2 of 3 Supporting Cost Estimates PG&E Letter HBL-13-003 Based on a December 2012 site-specific cost estimate prepared by PG&E staff, PG&E estimates that the decommissioning costs are about $888.9 million (including
$268.5 million disbursed from the trust(s) through December 2012 and $618.1 million future radiological removal costs) for HBPP, Unit 3, in 2013 dollars. These costs do not include site restoration of the facilities
($.9 million), or spent fuel management until 2025 ($139.5 million).
To assure that sufficient funds will be available for decommissioning, PG&E established external sinking trust fund accounts for HBPP, Unit 3. Supporting Enclosures Enclosures 1-4 provide supporting documentation for this report. Enclosure 1 provides decommissioning funding status information in a format suggested by Nuclear Energy Institute (NEI) and the NRC. Enclosure 2 provides information on the escalation of the required decommissioning funding amounts to 2013 dollars. As required by 10 CFR 50.75(c)(2), and using NUREG-1577, "Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance," Revision 1, and NUREG-1307, "Report on Waste Burial Charges," Revision 15, the information includes escalation factors for energy, labor, and waste burial costs. Enclosure 3 is a cash flow of the total decommissioning of HBPP that identifies the monies for NRC scope (removal of radiological contamination), site restoration (including the non-radiological work) and the spent fuel management.
Enclosure 4 contains the PG&E decommissioning cost estimate report prepared in December 2012 for HBPP, Unit 3. The report provides cost estimates for the decommissioning of the nuclear, non-nuclear facilities, and spent fuel management, including operation of the ISFSI in 2011 dollars PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter. Should you have any questions, please contact Mr. Bob Kapus at (707) 444-0810.
m Document Control Desk April 1,2013 * & Page 3 of 3 Sincerely, Edward D. Halpin Senior Vice President
-Chief Nuclear Officer Enclosures PG&E Letter HBL-13-003 cc/enc: John B. Hickman, NRC/FSME/DWMEP Project Manager Arthur T. Howell, III, NRC Region IV HBPP Humboldt Distribution INPO PG&E Letter HBL-13-003 Enclosure 1 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant Unit 3 (2 pages)
Enclosure 1 PG&E Letter HBL-13-003 NRC Decommissioning Funding Status Report Humboldt Bay Power Plant -Unit 3 (220 MWt) As provided in 10 CFR 50.75(f)(1), each power reactor licensee is required to report to the NRC on a calendar year basis, beginning March 31, 1999, and annually thereafter, on the status of its decommissioning funding for each reactor that it owns and has already closed. Note that Items 3, 4, and 8 are data included in PG&E's Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) filed with the California Public Utilities Commission (CPUC) on December 12, 2012. PG&E does not anticipate a decision on this filing until late 2013 or early 2014. 1. The minimum decommissioning fund estimate, pursuant to 10 CFR 50.75 (b) and (C).1 January 2013 dollars $ in Millions $ 687.2 (HBPP is a shutdown unit with a Site Specific Cost Study; therefore, the minimum decommissioning fund estimate is based on the Site Specific Cost Study shown in item 8 of this enclosure.)
- 2. The amount accumulated at the end of the calendar year preceding the date of the report for items included in 10 CFR 50.75 (b) and (c). (Alternatively, the total amount accumulated at the end of the calendar year preceding the date of the report can be reported here if the cover letter transmitting the report provides the total estimate and indicates what portion of that estimate is for items not included in 10 CFR 50.75 (b) and (c)). Market Value (December 2012 dollars) $ 272.0 3. A schedule of the annual amounts remaining to be collected; for items in 10 CFR 50.75 (b) and (c). (Alternatively, the annual amounts remaining to be collected can include items beyond those required in 10 CFR 50.75 (b) and (c) if the cover letter transmitting the report provides a total cost estimate and indicates what portion of that estimate is for items that are not included in 10 CFR 50.75 (b) and (c). 1
- The NRC formulas in section 10 CFR 50.75(c) include only those decommissioning costs incurred by licensees to remove a facility or site safely from service and reduce residual radioactivity to levels that permit: (1) release of the property for unrestricted use and termination of the license; or (2) release of the property under restricted conditions and termination of the license. The cost of dismantling or demolishing non-radiological systems and structures is not included in the NRC decommissioning cost estimates.
The costs of managing and storing spent fuel on site until transfers to DOE are not included in the cost formulas.
Page 1 of 2 Amount remaining Number of years to collect 2014-2017 Annual amount to be collected Enclosure 1 PG&E Letter HBL-13-003
$ 474.4 4 years $ 118.6 4. The assumptions used regarding escalation in decommissioning cost, rates of earnings on decommissioning funds (assumes trust will be gradually converted to a more conservative, all fixed income portfolio after 2010), and rates of other factors used in funding projections (all values below are from the 2012 NDCTP filing). Escalation in decommissioning costs Rate of Retu rn 2.6 percent 5. Any contracts upon which the licensee is relying pursuant to 10 CFR 50.75(e)(1)(v).
None 6. Any modifications to a licensee's current method providing financial assurance occurring since the last submitted report. None 7. Any material changes to trust agreements.
- 8. CPUC Submittal in 2012 Dollars in Millions:
Total Project (Decommission 2012) Scope Excluded from NRC calculations Scope of ISFSI from Licensing to Decommissioning in 2025 Scope Decommissioned and disbursed from Trust(s) Total NRC Decommissioning Remaining Scope Page 2 of 2 None $ 1,027.0 $ 0.9 $ 139.5 $ 268.5 $ 618.1 2013 Decommissioning Estimate (1 page) Composite Escalation (1 page) Development of E Component (4 pages) Development of L Component (2 pages) Development of B Component (1 page) PG&E Letter HBL-13-003 Enclosure 2
2013 Decommissioning Estimate Nuclear Regulatory Commission Estimate of Decommission Costs for Boiling Water Reactor (BWR) In 2012 HBPP BWR ($ in millions)
Jan 1986 Estimate $114.80 (Table 2.1 in NUREG 1307 Rev 14 Escalated to 1999 128.9 has no value for 1999 Burial) Escalated to 2000 400.2 ($360.9 in 2000 Submittal)
Escalated to 2001 354.1 ($425.3 in 2001 Submittal)
Escalated to 2002 357.4 ($445.6 in 2002 Submittal)
Escalated to 2003 373.8 ($430.1 in 2003 Submittal)
Escalated to 2004 388.0 ($439.6 in 2004 Submittal)
Escalated to 2005 416.8 ($453.2 in 2005 Submittal)
Escalated to 2006 519.2 ($494.3 in 2006 Submittal)
Escalated to 2007 538.3 ($548.6 in 2007 Submittal)
Escalated to 2008 564.4 ($590.9 in 2008 Submittal)
Escalated to 2009 574.6 ($573.8 in 2009 Submittal)
Escalated to 2010 594.5 ($596.6 in 2010 Submittal)
Escalated to 2011 626.5 ($619.0 in 2011 Submittal)
Escalated to 2012 659.9 ($645.4 in 2012 Submittal)
Escalated to 2013 687.2 Jan 1986 based on 10 CFR 50.75 (c) Table of minimum amounts BWR based on minimum 1200 MWt = ($104 + (.009xMWt))
million per unit where BWR less than 1200 MWt use P=1200 MWt, HBPP 220 MWt NUREG-1307 Rev 15 has a revision of Values for Burial Function impacting back to 2008 Page 1 of 1 Enclosure 2 PG&E Letter HBL-13-003 Composite Escalation Calculating Overall Escalation Rate BWR Dec-05 Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-11 Dec-12 Weight (1) L (Labor) 2.0600 2.1218 2.1939 2.2536 2.2784 2.3175 2.3711 2.4081 0.65 E (Energy) 1.9106 1.9808 2.4513 1.8323 2.0402 2.3945 2.7719 2.8187 0.13 B (Burial) 13.3331 13.8744 14.4164 15.0096 15.6028 16.5439 17.4856 18.4273 0.22 (1) from NUREG 1307 Revision 15, Report on Waste Burial Charges, Section 2 Summary, Page 3 ... where A, B, and C are the fractions of the total 1986 dollar costs that are attributable to labor (0.65), energy (0.13), and burial (0.22), respectively, and sum to 1.0. BWR Combined Escalation Rate for:
Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-11 Dec-12 4.6891 4.9163 5.0052 5.1788 5.4573 5.7484 5.9857 Page 1 of 1 Enclosure 2 PG&E Letter HBL-13-003 Development of E Component Calculation of Energy Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 03/14/13) and WPU0543 Industrial Electric Power (as of 03/14/13)
REBASED TO 1986 = 100 Dec-99 Jan-OO Feb-OO Mar-OO Apr-OO May-OO Jun-OO Jul-OO Aug-OO Sep-OO Oct-OO Nov-OO Dec-OO Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 Aug-01 Sep-01 Oct-01 Nov-01 Dec-01 Jan-02 Feb-02 Mar-02 Apr-02 May-02 Jun-02 Jul-02 Aug-02 Sep-02 Oct-02 Nov-02 Dec-02 Jan-03 Feb-03 Mar-03 Apr-03 May-03 Jun-03 Jul-03 Aug-03 Sep-03 Oct-03 Nov-03 Dec-03 PPI for Fuels & Related Products (2000 = 100) (P) =Industrial Energy Power 126.5 126.8 126.7 126.7 126.8 128.6 133.6 136.2 137.4 137.8 134.1 130.9 132.7 136.4 136.4 136.5 135.1 136.2 148.4 149.5 148.9 148.2 143.8 137.3 136.9 136.3 135.4 135.7 135.4 137.9 143.6 144.9 145.0 145.8 140.0 139.5 139.6 140.3 140.6 143.3 144.3 145.1 148.3 151.6 151.3 152.0 147.4 142.7 142.9 PPI for Light Fuel Oils (2000=100) (F) = Light Fuel Oils 72.9 75.3 87.9 89.7 83.1 82.9 86.2 88.7 91.6 110.1 108.6 108.4 100.6 96.1 91.6 83.1 86.2 94.2 90.2 81.3 83.2 93 76.8 70.5 56.6 58.3 59.6 69.1 76.4 75 71.4 75.5 77.9 89.5 95.1 82.8 84.6 95.7 120.4 128.9 98.3 85.5 87.2 90.1 94.1 88.2 97.8 93.0 95.8 PPI for Fuels & PPI for Light Related Products Fuel Oils (2000 = 100) (2000=100) (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wi = 0.54 BWR wt = 0.46 1.0000 1.0000 1.0024 1.0329 1.0016 1.2058 1.0016 1.2305 1.0024 1.1399 1.0166 1.1372 1.0561 1.1824 1.0767 1.2167 1.0862 1.2565 1.0893 1.5103 1.0601 1.4897 1.0348 1.4870 1.0490 1.3800 1.0783 1.3182 1.0783 1.2565 1.0791 1.1399 1.0680 1.1824 1.0767 1.2922 1.1731 1.2373 1.1818 1.1152 1.1771 1.1413 1.1715 1.2757 1.1368 1.0535 1.0854 0.9671 1.0822 0.7764 1.0775 0.7997 1.0704 0.8176 1.0727 0.9479 1.0704 1.0480 1.0901 1.0288 1.1352 0.9794 1.1455 1.0357 1.1462 1.0686 1.1526 1.2277 1.1067 1.3045 1.1028 1.1358 1.1036 1.1605 1.1091 1.3128 1.1115 1.6516 1.1328 1.7682 1.1407 1.3484 1.1470 1.1728 1.1723 1.1962 1.1984 1.2359 1.1960 1.2908 1.2016 1.2099 1.1652 1.3416 1.1281 1.2757 1.1296 1.3141 Page 1 of 4 Energy Escalation Factor (E) forBWR (Humboldt) 1.0000 1.0164 1.0955 1.1069 1.0656 1.0721 1.1142 1.1411 1.1645 1.2830 1.2577 1.2428 1.2013 1.1887 1.1603 1.1070 1.1206 1.1758 1.2026 1.1512 1.1606 1.2195 1.0985 1.0310 0.9415 0.9497 0.9541 1.0153 1.0601 1.0619 1.0635 1.0950 1.1105 1.1871 1.1977 1.1180 1.1297 1.2028 1.3599 1.4251 1.2363 1.1589 1.1833 1.2157 1.2396 1.2054 1.2463 1.1960 1.2145 Enclosure 2 PG&E Letter HBL-13-003 Development of E Component Calculation of Energy Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 03/14/13) and WPU0543 Industrial Electric Power (as of 03/14/13)
REBASED TO 1986 = 100 PPI for Fuels & PPI for Light PPI for Fuels & PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100) (2000=100)
(2000 = 100) (2000=100) (P) =Industrial Energy Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWRwt= 0.54 BWRwt= 0.46 Jan-04 143.1 106.8 1.1312 1.4650 Feb-04 143.1 100.8 1.1312 1.3827 Mar-04 143.1 107.8 1.1312 1.4787 Apr-04 143.1 115.2 1.1312 1.5802 May-04 144.2 116 1.1399 1.5912 Jun-04 152.4 111.5 1.2047 1.5295 Jul-04 152.2 119.3 1.2032 1.6365 Aug-04 154.0 131.1 1.2174 1.7984 Sep-04 154.0 136.8 1.2174 1.8765 Oct-04 145.8 161.7 1.1526 2.2181 Nov-04 144.9 153.6 1.1455 2.1070 Dec-04 146.2 133.8 1.1557 1.8354 Jan-05 148.9 138.5 1.1771 1.8999 Feb-05 148.0 146 1.1700 2.0027 Mar-05 148.1 169.4 1.1708 2.3237 Apr-05 148.7 170.9 1.1755 2.3443 May-05 151.1 165.3 1.1945 2.2675 Jun-05 159.7 180.6 1.2625 2.4774 Jul-05 162.1 186.2 1.2814 2.5542 Aug-05 162.5 194.5 1.2846 2.6680 Sep-05 162.8 209.9 1.2870 2.8793 Oct-05 159.5 252.0 1.2609 3.4568 Nov-05 161.1 199.1 1.2735 2.7311 Dec-05 161.4 193.6 1.2759 2.6557 Jan-06 167.0 191.8 1.3202 2.6310 Feb-06 168.6 190.0 1.3328 2.6063 Mar-06 167.4 199.2 1.3233 2.7325 Apr-06 169.6 221.9 1.3407 3.0439 May-06 170.8 231.4 1.3502 3.1742 Jun-06 181.2 238.1 1.4324 3.2661 Jul-06 181.9 231.6 1.4379 3.1770 Aug-06 180.2 241.4 1.4245 3.3114 Sep-06 181.0 203.1 1.4308 2.7860 Oct-06 171.2 198.1 1.3534 2.7174 Nov-06 167.2 198.2 1.3217 2.7188 Dec-06 167.8 200.4 1.3265 2.7490 Jan-07 171.9 180.0 1.3589 2.4691 Feb-07 175.7 191.5 1.3889 2.6269 Mar-07 172.1 215.1 1.3605 2.9506 Apr-07 173.1 231.8 1.3684 3.1797 May-07 179.2 225.3 1.4166 3.0905 Jun-07 186.7 222.4 1.4759 3.0508 Jul-07 187.0 237.8 1.4783 3.2620 Aug-07 187.6 225.5 1.4830 3.0933 Sep-07 188.4 238.9 1.4893 3.2771 Oct-07 182.7 243.3 1.4443 3.3374 Nov-07 180.3 288.2 1.4253 3.9534 Dec-07 180.0 266.7 1.4229 3.6584 Jan-08 181.9 273.8 1.4379 3.7558 Feb-08 180.0 280.2 1.4229 3.8436 Page 2 of 4 Energy Escalation Factor (E) forBWR (Humboldt) 1.2848 1.2469 1.2911 1.3378 1.3475 1.3541 1.4025 1.4846 1.5206 1.6427 1.5878 1.4684 1.5096 1.5530 1.7011 1.7131 1.6881 1.8213 1.8669 1.9210 2.0194 2.2710 1.9440 1.9106 1.9231 1.9186 1.9715 2.1242 2.1892 2.2759 2.2379 2.2925 2.0542 1.9808 1.9644 1.9808 1.8696 1.9584 2.0919 2.2016 2.1866 2.2003 2.2988 2.2237 2.3117 2.3151 2.5882 2.4513 2.5042 2.5364 Enclosure 2 PG&E Letter HBL-13-003 Development of E Component Calculation of Energy Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 03/14/13) and WPU0543 Industrial Electric Power (as of 03/14/13)
REBASED TO 1986 = 100 PPI for Fuels & PPI for Light PPI for Fuels & PPI for Light Related Products Fuel Oils Related Products Fuel Oils (2000 = 100) (2000=100)
(2000 = 100) (2000=100) (P) =Industrial Energy Power (F) = Light Fuel Oils (P) =Industrial Energy Power (F) = Light Fuel Oils BWRwt= 0.54 BWRwt= 0.46 Mar-08 183.1 339.6 1.4474 4.6584 Apr-08 185.2 352.5 1.4640 4.8354 May-08 189.5 384.9 1.4980 5.2798 Jun-08 191.9 410.5 1.5170 5.6310 Jul-08 196.1 423.8 1.5502 5.8134 Aug-08 197.1 343.9 1.5581 4.7174 Sep-08 195.9 335.1 1.5486 4.5967 Oct-08 193.0 279.0 1.5257 3.8272 Nov-08 187.7 218.2 1.4838 2.9931 Dec-08 188.3 163.0 1.4885 2.2359 Jan-09 190.3 159.8 1.5043 2.1920 Feb-09 190.3 145.6 1.5043 1.9973 Mar-09 187.6 136.8 1.4830 1.8765 Apr-09 186.9 159.9 1.4775 2.1934 May-09 190.5 158.6 1.5059 2.1756 Jun-09 193.3 183.7 1.5281 2.5199 Jul-09 196.2 165.2 1.5510 2.2661 Aug-09 194.7 196.1 1.5391 2.6900 Sep-09 194.9 186.6 1.5407 2.5597 Oct-09 189.9 193.3 1.5012 2.6516 Nov-09 186.0 207.8 1.4704 2.8505 Dec-09 186.0 197.5 1.4704 2.7092 Jan-10 186.3 220.7 1.4727 3.0274 Feb-10 186.1 200.2 1.4711 2.7462 Mar-10 189.0 217.0 1.4941 2.9767 Apr-10 188.8 231.5 1.4925 3.1756 May-10 192.0 226.0 1.5178 3.1001 Jun-10 197.8 212.4 1.5636 2.9136 Jul-10 199.8 209.3 1.5794 2.8711 Aug-10 200.8 221.4 1.5874 3.0370 Sep-10 200.0 220.0 1.5810 3.0178 Oct-10 194.6 235.8 1.5383 3.2346 Nov-10 190.9 245.3 1.5091 3.3649 Dec-10 191.4 250.0 1.5130 3.4294 Jan-11 193.1 260.4 1.5265 3.5720 Feb-11 194.4 278.8 1.5368 3.8244 Mar-11 195.0 307.5 1.5415 4.2181 Apr-11 194.1 325.1 1.5344 4.4595 May-11 196.9 315.1 1.5565 4.3224 Jun-11 205.7 316.9 1.6261 4.3471 Jul-11 215.3 311.5 1.7020 4.2730 Aug-11 216.6 296.9 1.7123 4.0727 Sep-11 215.8 306.5 1.7059 4.2044 Oct-11 206.6 299.6 1.6332 4.1097 Nov-11 204.0 322.7 1.6126 4.4266 Dec-11 204.4 301.0 1.6158 4.1289 Jan-12 201.1 308.8 1.5897 4.2359 Feb-12 200.3 316.5 1.5834 4.3416 Mar-12 199.8 330.8 1.5794 4.5377 Apr-12 198.1 327.1 1.5660 4.4870 Page 3 of 4 Energy Escalation Factor (E) forBWR (Humboldt) 2.9245 3.0149 3.2377 3.4094 3.5113 3.0114 2.9507 2.5844 2.1781 1.8323 1.8207 1.7311 1.6640 1.8068 1.8140 1.9843 1.8799 2.0685 2.0094 2.0304 2.1052 2.0402 2.1879 2.0577 2.1761 2.2667 2.2457 2.1846 2.1736 2.2542 2.2420 2.3186 2.3628 2.3945 2.4674 2.5891 2.7727 2.8800 2.8288 2.8777 2.8846 2.7981 2.8552 2.7724 2.9071 2.7719 2.8070 2.8522 2.9403 2.9096 Enclosure 2 PG&E Letter HBL-13-003 Development of E Component Calculation of Energy Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.2 Using Regional Indices SERIES ID: WPU0573 Light Fuel Oils (as of 03/14/13) and WPU0543 Industrial Electric Power (as of 03/14/13)
REBASED TO 1986 = 100 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 PPI for Fuels & Related Products (2000 = 100) (P) =Industrial Energy Power 201.5 207.7 221.5 222.1 222.8 214.1 210.9 213.0 PPI for Light Fuel Oils (2000=100) (F) = Light Fuel Oils 315.6 284.6 287.9 313.4 330.4 334.1 311.6 302.6 Nov 12 through Dec 12 are Preliminary Values from PPI Indices PPI for Fuels & PPI for Light Related Products Fuel Oils (2000 = 100) (2000=100) (P) =Industrial Energy Power (F) = Light Fuel Oils BWR wt = 0.54 BWR wt = 0.46 1.5929 4.3292 1.6419 3.9040 1.7510 3.9492 1.7557 4.2990 1.7613 4.5322 1.6925 4.5830 1.6672 4.2743 1.6838 4.1509 Based on Base Year 2000 being the indice values Dec 1999, Jan 2013 base will be Dec 2012 Page 4 of 4 Energy Escalation Factor (E) forBWR (Humboldt) 2.8516 2.6825 2.7622 2.9257 3.0359 3.0221 2.8665 2.8187 Enclosure 2 PG&E Letter HBL-13-003 Development of L Component Calculation of Labor Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.1 Using Regional Indices SERIES ID: CIU20100000002401 (as of 03/14/13)
Enclosure 2 PG&E Letter HBL-13-003 Note 1: The Base Labor factor was re-indexed in December 2005, at which time the index was reset to 100. Employment Cost Indust West Region Labor Private Industry Escalation (2005=100)
Factor Dec-05 100 2.06000 Jan-06 Feb-06 Mar-06 100.6 2.07236 Apr-06 May-06 Jun-06 101.B 2.0970B Jul-06 Aug-06 Sep-06 102.5 2.11150 Oct-06 Nov-06 Dec-06 103 2.121BO Jan-07 Feb-07 Mar-07 104.2 2.14652 Apr-07 May-07 Jun-07 104.9 2.16094 Jul-07 Aug-07 Sep-07 105.7 2.17742 Oct-07 Nov-07 Dec-07 106.5 2.19390 Jan-OB Feb-OB Mar-OB 107.B 2.2206B Apr-OB May-OB Jun-OB 10B.4 2.23304 Jul-OB Aug-OB Sep-OB 109.3 2.2515B Oct-OB Nov-OB Dec-OB 109.4 2.25364 Jan-09 Feb-09 Mar-09 109.9 2.26394 Apr-09 May-09 Jun-09 110 2.26600 Jul-09 Aug-09 Sep-09 110.3 2.2721B Oct-09 Nov-09 Page 1 of 2 Development of L Component Calculation of Labor Escalation Factor -Reference NUREG-1307, Revision 15, Section 3.1 Using Regional Indices SERIES ID: CIU20100000002401 (as of 03/14/13)
Enclosure 2 PG&E Letter HBL-13-003 Note 1: The Base Labor factor was re-indexed in December 2005, at which time the index was reset to 100. Employment Cost Indust West Region Labor Private Industry Escalation (2005=100)
Factor Dec-05 100 2.06000 Dec-09 110.6 2.27836 Jan-10 Feb-10 Mar-10 111.3 2.29278 Apr-10 May-10 Jun-10 111.7 2.30102 Jul-10 Aug-10 Sep-10 112.3 2.31338 Oct-10 Nov-10 Dec-10 112.5 2.31750 Jan-11 Feb-11 Mar-11 113.5 2.33810 Apr-11 May-11 Jun-11 114.3 2.35458 Jul-11 Aug-11 Sep-11 114.6 2.36076 Oct-11 Nov-11 Dec-11 115.1 2.37106 Jan-12 Feb-12 Mar-12 115.7 2.38342 Apr-12 May-12 Jun-12 116.3 2.39578 Jul-12 Aug-12 Sep-12 116.9 2.40814 Oct-12 Nov-12 Dec-12 116.9 2.40814 Page 2 of 2 Development of Burial Escalation Developed from NUREG-1307 Revision 15 Development of B Component Enclosure 2 PG&E Letter HBL-13-003 Table 2.1 "VALUES OF B SUB-X AS A FUNCTION OF LLW BURIAL SITE, WASTE VENDOR, AND YEAR" (Summary for non-Atlantic Compact) Revised to Bx Values for Generic LLW Disposal Site are assumed to be the same as that provided for the Atlantic Compact, for lack of a better alternative at this time 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Revised to Bx Values for Generic LLW Disposal Site are assumed to be Combination of Compact-Affliated and Compact Facility for HBPP BWR BWR Burial Costs Restated to (South Carolina) 1986 = 100 1.561 1.0000 1.831 1.1730 2.361 1.5125 9.434 6.0436 9.794 6.2742 10.42 6.6752 10.379 6.6489 13.837 8.8642 13.948 8.9353 16.244 10.4061 16.474 10.5535 16.705 10.7015 17.337 11.1063 17.970 11.5119 19.391 12.4222 20.813 13.3331 21.658 13.8744 22.504 14.4164 23.430 15.0096 24.356 15.6028 25.825 16.5439 27.295 17.4856 28.765 18.4273 Table 2.1 Note (e) Bx values for the generic site are assumed to be the same as that provided for the Atlantic Compact for lack of a better alternative at this time Note (f) Effective with NUREG-1307, Revision 8 (Ref.3) an alternative disposal option was introduced in which the bulk of the LLW is assumed to be dispositioned by waste vendors and/or disposed of at a non-compact disposal facility Note (g) Effective with NUREG1307, Revision 15, the nomenclature for the two disposal options, referred to as "Direct Disposal" and "Direct Disposal with Vendors" in previous revisions of NUREG-1307, is changed to "Compact-Affiliated Disposal Facility Only" and "Combination of Comapct-Affiliated and Non-Compact Disposal Facilities" to better describe the options. 2013 has no information in NUREG-1307 Rev 15. 2013 is an estimate that is calculated by by applying the average % change between 2010 and 2012 and adding to the 2012 base Page 1 of 1 PG&E Letter HBL-13-003 Enclosure 3 Nuclear Decommissioning Cash Flow for Assurance Funding (1 page)
Year 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 TOTAL 1) 2) NRC $1,678,452
$8,663,216
$5,573,757
$723,490 $85,241
$89,543 $994,127 $494,838 $491,070 $161,506 $1,073,612
$4,474,247
$12,590,383
$32,901,391
$56,957,494
$60,585,531
$80,966,451
$159,567,437
$178,650,426
$98,292,470
$87,902,768
$54,044,696
$32,096,192
$5,797,186
$839,389 $420,574 $420,574 $439,198 $550,712 $1,295,619
$888,821,591 Humboldt Bay Power Plant Decommissioning Cash Flow (Note 1) 2013 Dollars SPENT FUEL NON -NRC MANAGEMENT TOTAL $1,678,452
$8,663,216
$344,408 $5,918,165
$2,281,454
$3,004,944
$2,736,091
$2,821,332
$398,012 $487,555 $113,704 $1,107,831
$2,539,476
$3,034,314
$1,444,628
$1,935,698 $1,671,769 $1,833,275
$3,546,617
$4,620,229
$9,240,172
$13,714,419
$28,485,988
$41,076,371
$3,179,956
$36,081,347
$5,734,776
$62,692,270
$5,495,157
$66,080,688
$0 $5,120,117
$86,086,569
$380,160 $4,950,314
$164,897,911
$380,160 $4,810,683
$183,841,269
$126,720 $4,810,683
$103,229,873
$0 $5,081,813
$92,984,581
$0 $4,874,885
$58,919,581
$0 $4,874,885
$36,971,077
$0 $4,595,622
$10,392,808
$0 $4,799,354
$5,638,743
$0 $4,595,622
$5,016,196
$0 $4,595,622
$5,016,196
$0 $4,595,622 $5,034,820
$0 $5,194,254 $5,744,966
$0 $9,384,682
$10,680,301
$887,040 $139,496,366
$1,029,204,997 Cummulative Decommission Estimate $1,678,452
$10,341,668
$16,259,833
$19,264,777
$22,086,109
$22,573,664
$23,681,495
$26,715,809
$28,651,507
$30,484,782
$35,105,011
$48,819,430
$89,895,801
$125,977,148
$188,669,418
$254,750,106
$340,836,675
$505,734,586
$689,575,855
$792,805,728
$885,790,309
$944,709,890
$981,680,967
$992,073,775
$997,712,518
$1,002,728,714
$1,007,744,910
$1,012,779,730
$1,018,524,696
$1,029,204,997 Cash Flow is based on construction of ISFSI and Fuel removed from HBPP in 2025 (Assumes DOE Used Fuel Repository opens 2024 allowing HBPP Fuel to be shipped during 2024-2025)
Trust Account Value of $267.3 million is Expense Equivalent Liquidation Value (Includes Tax Break) Market Value of Trust as of 12/12 was $272.0 million, actual expended as of 12/12 was $340.8 million Page 1 of 1 $340,836,675 Actual $612,788,405 Actual + Market Value Enclosure 3 PG&E Letter HBL-13-003
$608,101,808 Actual + Equivalent Liquidation Decommissioning Project Report for the Humboldt Bay Power Plant Unit 3 (121 pages) PG&E Letter HBL-13-003 Enclosure 4
Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 DECOMMISSIONING PROJECT REPORT FOR THE HUMBOLDT BAY POWER PLANT UNIT 3 2012 -2024 December 2012 Rev. 0 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 STUDY REVISION PAGE Title: Decommissioning Project Report for the Humboldt Bay Power Plant Unit 3, 2012-2024 Steve Shelanskey Robert Kapus Prepared by Brooke Winterton Checked by Status Rev. # Date Revision Signatures 12/20/2012 Date 12/20/2012 Date Kerry Rod Approved by 12/20/2012 Date Prepared By Pages Description of Changes Issued 0 12/20/12 R. Kapus All New S. K. Shelanskey Rev. 0 Page i of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 TABLE OF CONTENTS Rev. 0 EXECUTIVE SUMMARy ..............................................................................................................
4 1 INTRODUCTION
...............................................................
- ...................................................
7 1.1 OBJECTiVE
....................................................................................................................
7 1.2 PRIOR HiSTORy ...........................................................................................................
7 1.3 PLANT DESCRIPTION
...................................................................................................
7 1.4 NRC LICENSE TERMINATION
........................................................................................
8 1.5 STATE AND LOCAL APPROVALS
..............................................................................
10 1.6 ISFSI OPERATIONS AND DEMOLITION
.....................................................................
12 2 DECOMMISSIONING PLANNING AND ACTIVITIES
.........................................................
15 2.1 INITIAL PLANNING ......................................................................................................
15 2.2 COMPLETED ACTiViTIES
...........................................................................................
21 2.3 TRANSITIONING TO CIVIL WORKS PROJECTS .......................................................
24 2.4 MAJOR CIVIL WORK PROJECTS ...............................................................................
25 2.5 BID SPECiFiCATIONS
.................................................................................................
26 3 COST ESTIMATE ................................................................................................................
32 3.1 BASIS OF ESTIMATE ...................................................................................................
35 3.2 REMAINING MAJOR DECOMMISSIONING COST DRIVERS ....................................
35 3.3 REACTOR VESSEL CAISSON REMOVAL .................................................................
39 3.4 CIVIL WORKS PROJECTS ..........................................................................................
41 3.5 Intake and Discharge Canal Remediation
....................................................................
45 3.6 STAFFING PLAN .........................................................................................................
48 3.7 Staffing Costs ...............................................................................................................
53 3.8 SMALL VALUE CONTRACTS
......................................................................................
55 3.9 Project Tools and Equipment
.......................................................................................
56 3.10 Health Physics Supplies/RP Tools and Equipment
......................................................
57 3.11 Spent Fuel Manage.ment
..............................................................................................
59 3.12 Removal of Plant Systems, Site Infrastructure, Reactor Vessel Removal ....................
61 3.13 Contingency
... , ..............................................................................................................
61 SCHEDULE ESTIMATE .............................................................................................................
63 3.14 HBPP
SUMMARY
SCHEDULE WITH KEY MILESTONES
.........................................
63 3.15 CRITICAL PATH
SUMMARY
.......................................................................................
65 Page ii of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 3.16 SELF PERFORM SCHEDULE .....................................................................................
70 4 RADIOACTIVE WASTE .......................................................................................................
72 5 REFERENCES
....................................................................................................................
92 Page iii of 120 EXECUTIVE
SUMMARY
Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Pacific Gas and Electric Company (PG&E) has prepared this site-specific Decommissioning Project Report (DPR) for decommissioning the Humboldt Bay Power Plant Unit 3 (HBPP Unit 3) to identify the cost and schedule to complete decommissioning and license termination of HBPP Unit 3. This DPR incorporates the site specific decommissioning tasks and detailed plans which have been identified as a result of the ongoing implementation of the decommissioning effort. The projected total cost to decommission HBPP Unit 3, including costs spent to date and a 10% to 25% line item contingency applied to remaining work depending on the degree of difficulty, is estimated to be approximately
$982.4 million (2011 dollars).
The DPR assumes the removal of identified contaminated and activated plant components and structural materials, and that decommissioning will be accomplished within the 60-year period required by current Nuclear Regulatory Commission (NRC) regulations.
The DPR assumes that the spent fuel remains in storage at the site until such time that the transfer to a United States Department of Energy (DOE) facility can be completed.
Once the spent fuel transfer is complete, the storage facility will be decommissioned.
The major cost contributors to the remaining decommissioning cost are (1) changes to the scope of the planned decommissioning work, including removal of the reactor caisson, intake and discharge canal remediation and an assumed four year extension of the time spent fuel will be stored on site, and (2) higher pricing from competitive bids received from the industry, staffing (labor plus per diem), safety and field oversight of removal of alpha contaminated plant systems and components, spent fuel storage, final site surveys, tools and equipment, and the disposition of waste generated in the decontamination and demolition of HBPP Unit 3. The estimate is based on several key assumptions, including regulatory requirements, estimating methodology, contingency requirements, and site restoration requirements.
A complete discussion of the assumptions used in this estimate is presented in Section 3. Methodology In March, 2009, PG&E authorized the preparation by TLG Services, Inc. of a cost study for decommissioning HBPP Unit 3 (2009 Cost Study).The methodology used to develop the 2009 decommissioning cost estimates for HBPP Unit 3 followed the basic approach originally presented in the "Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates," (T.S. LaGuardia et aI., AIF/NESP-036, May 1986.) This reference describes a unit factor method for determining decommissioning activity costs. This DPR uses a different methodology:
specific bid pricing and experience gained by PG&E after four years of full-scale decommissioning.
Over the past four years, the majority of decommissioning work has been installation of site infrastructure and removal of systems and components, known as the Plant System Removal Phase. In this phase, PG&E established a self-perform arrangement in which PG&E provided direct supervision of a contracted work force performing work on a Time-And-Material basis or on a Cost-Plus basis. This type of contracting arrangement was optimal, due to several factors Page 4 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 including the dynamics of maintaining specific plant systems in service while others were removed from service and the configuration control that must be maintained; removal of large components with known high levels of radiation that required slow and methodical disassembly; and removal of contaminated systems under special engineering controls and requirements.
Careful planning and special measures were taken to accomplish this work with maximum safety to the workers and the public. A work scope of this nature, wherein uncertainty exists as to the exact effort that is required to perform all tasks, lends itself to Time-And-Material or Plus contracting.
This phase is now largely completed.
PG&E is currently transitioning from self-perform to lump sum fixed cost contracting, commensurate with the change in nature of the work. As HBPP Unit 3 Decommissioning transitions from the Plant System Removal Phase, where work scope was dynamic with significant uncertainty, to the Civil Works Projects Phase, where work scope is well defined, the remaining decommissioning work has been analyzed and then described in major, well defined Civil Works Projects.
These Civil Works Projects include Turbine Building Demolition, Nuclear Facilities Demolition and Excavation, Intake and Discharge Canal Remediation, Office Facility Demobilization, and Final Site Restoration.
Detailed bid specifications were developed for each project and then bids were solicited from multiple vendors. The use of competitively bid, fixed price contracts assures PG&E that the costs are fully understood and provides for some financial risk mitigation.
Remaining Costs The cost estimate for the remaining work at HBPP Unit 3 is based on industry pricing in lieu of a budgetary cost estimate.
This cost estimate is backed by competitive bids and four years of successful decommissioning.
A detailed breakdown of these major cost contributors to the decommissioning cost estimate is reported in the table below and in Section 3 of this document.
Page 5 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3
SUMMARY
OF DECOMMISSIONING COST CONTRIBUTORS (Thousands, 2011 Dollars) Rev. 0 Cost Category Percentage I Amount Page 6 of 120 1 INTRODUCTION
1.1 OBJECTIVE
Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 The objective of this Decommissioning Project Report (DPR) is to provide an updated, comprehensive evaluation of the remaining activities, costs, and schedule to decommission HBPP Unit 3 as well as to provide a status of the work completed to date. 1.2 PRIOR HISTORY The site on which HBPP Unit 3 is located was initially developed in around 1950 by PG&E as a fossil based electrical generating station. Attachment A, Site History of Humboldt Bay Power Plant Unit 3, provides a photographic history of the site beginning in the mid-1940s.
HBPP Unit 3 is a 65-megawatt (MW) nuclear reactor that began commercial operation in 1963 and was taken off-line in 1976 to refuel and to make seismic modifications.
In 1979, prior to the completion and acceptance of the seismic modifications, the nuclear incident at Three-Mile Island occurred and, as a result, the Nuclear Regulatory Commission (NRC) mandated a comprehensive series of other modifications that would have required additional investment.
The California Public Utilities Commission (CPUC) approved an early decommissioning plan for HBPP Unit 3 because the additional investments required by the NRC made restarting the plant uneconomic.
Pacific Gas and Electric Company (PG&E) placed the plant in a long term storage and monitoring condition known as SAFSTOR. During this period, the plant was maintained to ensure the integrity of its safety systems and to ensure that the health and safety of the public, environment, and work force were protected.
Several cost studies were performed between 1978 and 2009. PG&E hired a specialty consultant, TLG Services, Inc., to prepare the 2001 SAFSTOR Decommissioning Study that was issued in 1997. The decommissioning cost study and subsequent studies by TLG provided PG&E with sufficient information to prepare the financial planning documents for decommissioning, as required by the Nuclear Regulatory Commission (NRC). The cost studies provided estimates that were based on detailed studies of the unique features of the facility and accounted for lessons learned at other facilities that had undergone similar decommissionings.
These estimates were not detailed engineering documents, but were financial analyses prepared in advance of the detailed engineering that would be required to carry out the decommissioning.
The latest cost study (2009 Cost Study) was approved by the CPUC in the 2009 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP). While in SAFSTOR, PG&E planned and constructed an Independent Spent Fuel Storage Installation (ISFSI). Once construction and testing were completed, PG&E transferred the spent nuclear fuel from the spent fuel pool to the ISFSI, finishing in 2008. The CPUC found PG&E's costs incurred in connection with construction of the ISFSI reasonable in the 2009 NDCTP. 1.3 PLANT DESCRIPTION HBPP Unit 3 is located approximately four miles southwest of Eureka, California.
The site consists of approximately 143 acres located on the mainland shore of Humboldt Bay. Figure 1.1 shows the layout of the site and the surrounding area. The most current aerial view of the site is shown in Attachment A, Site History of HBPP Unit 3. Page 7 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 The Nuclear Steam Supply System (NSSS) for HBPP Unit 3 consisted of a single cycle, natural circulation, boiling water reactor and the associated control and support systems. The generating unit had a rated core thermal power of 220 MWth (thermal) with a corresponding net electrical output of 65 MWe (electric).
The NSSS is located within the "primary containment structure." The primary containment is located mostly below grade and consists of a drywell vessel and a suppression chamber. Both the drywell and the suppression chamber area are located within a reinforced concrete caisson. The drywell vessel is centrally' located in the caisson and serves as the primary containment vessel. The suppression chamber is constructed of reinforced concrete and lined with carbon steel plate. Six vent pipes connect the drywell to a common ring header at the top of the suppression chamber. Downcomers drop from the ring header and terminate below the normal water level of the suppression pool. As a system, the drywell, suppression chamber, and interconnecting piping were designed to reduce the pressure increase in the event of a local process system piping failure. Other supporting systems included the turbine-generator system that converted heat produced in the reactor to electrical energy; a closed feedwater cycle whereby steam was condensed and the condensate/feedwater was returned to the reactor vessel; and a Circulating Water System (CWS) that delivered the water required to remove the heat load from the main condenser and other auxiliary equipment and returns it to the bay through the discharge pipes and a canal. At the time that HBPP Unit 3 entered commercial service in 1963, the nuclear fuel assemblies utilized stainless steel as the fuel rod cladding.
The stainless steel-clad fuel experienced gross cladding failures during operation.
These failures were severe enough that radioactive fuel was released from the cladding and dispersed throughout numerous plant systems, contaminating these systems with alpha emitting radionuclides (i.e., transuranic elements).
HBPP Unit 3 completed the transition from stainless steel to zircaloy assemblies in 1969. Over the SAFSTOR period, as beta and gamma emitting radionuclides have decayed, alpha has become a more dominant factor in dose contribution.
Because alpha causes more severe biological damage when internal exposure occurs, the potential radiological dose consequences are likewise more severe. This issue leads to a unique, plant-specific concern for HBPP Unit 3 decommissioning.
The extent of the alpha contamination requires additional radiological controls and will reduce the efficiency of component removal activities.
1.4 NRC LICENSE TERMINATION
1.4.1 License
Termination Plan There are two NRC-issued licenses that pertain to HBPP Unit 3: one issued under 10 CFR §50 pertaining to operation of the plant and the other issued under 10 CFR §72 pertaining to the storage of spent nuclear fuel and operation of the ISFSI. Once the decommissioning effort is complete, PG&E will petition the NRC to terminate the 10 CFR §50 license. At least two years prior to the anticipated date of license termination, a License Termination Plan (L TP) is required.
Submitted as a supplement to the Final Safety Analysis Report (FSAR) or its equivalent, the plan must include: a site characterization, description of the remaining dismantling activities, plans for Page 8 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 site remediation, procedures for the final radiation survey, designation of the end use of the site, an updated cost estimate to complete the decommissioning, and any associated environmental concerns.
The NRC will notice the receipt of the plan in the Federal Register, make the plan available for public comment, and schedule a local hearing. L TP approval will be subject to any conditions and limitations as deemed appropriate by the NRC. Incorporated into the L TP is the Final Survey Plan. This plan identifies the radiological surveys to be performed once the decontamination activities are completed and is developed using the guidance provided in the "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)." This document incorporates the statistical approaches to survey design and data interpretation used by the Environmental Protection Agency (EPA). It also identifies the-art, commercially available instrumentation and procedures for conducting radiological surveys. Use of this guidance ensures that the surveys are conducted in a manner that provides a high degree of confidence that applicable NRC criteria are satisfied.
Once the survey is complete, the results are provided to the NRC in a format that can be verified.
The NRC then reviews and evaluates the information, performs an independent confirmation of radiological site conditions, and makes a determination on final termination of the license. The NRC will terminate the 10 CFR §50 operating license if it determines that site remediation has been performed in accordance with the L TP and that the terminal radiation survey and associated documentation demonstrate that the facility is suitable for release. 1.4.2 Radiological Criteria for License Termination In 1997, the NRC published Subpart E, "Radiological Criteria for License Termination," amending 10 CFR §20. This subpart provides radiological criteria for releasing a facility for unrestricted use. The regulation states that the site can be released for unrestricted use if radioactivity levels are such that the average member of a critical group would not receive a Total Effective Dose Equivalent (TEDE) in excess of 25 millirem (mR) per year, and provided that residual radioactivity has been reduced to levels that are As Low as Reasonably Achievable (ALARA). The NRC and the EPA differ on the amount of residual radioactivity considered acceptable in site remediation.
The EPA has two limits that apply to radioactive materials.
An EPA limit of 15 m R per year is derived from criteria established by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).
An additional limit of 4 mR per year, as defined in 40 CFR §141.16, is applied to the drinking water exposure pathway. On October 9, 2002, the NRC signed an agreement with the EPA on the radiological decommissioning and decontamination of NRC-licensed sites. The Memorandum of Understanding (MOU) provides that EPA will defer exercise of authority under CERCLA for the majority of facilities decommissioned under NRC authority.
The MOU also includes provisions for NRC and EPA consultation for certain sites when, at the time of license termination, (1) groundwater contamination exceeds EPA-permitted levels; (2) NRC contemplates restricted release of the site; and/or (3) residual radioactive soil concentrations exceed levels defined in the MOU. The MOU does not impose any new requirements on NRC licensees and should reduce the involvement of the EPA with NRC licensees who are decommissioning.
Most sites are Page 9 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 expected to meet the NRC criteria for unrestricted use, and the NRC believes that only a few sites will have groundwater or soil contamination in excess of the levels specified in the MOU that trigger consultation with the EPA. However, if there are other hazardous materials on the site, the EPA may be involved in the cleanup. As such, the possibility of dual regulation remains for certain licensees.
The present study does not include any costs for this occurrence.
Early in the decommissioning process, PG&E conducted extensive studies on projected use of the land upon which HBPP was constructed.
The purpose of the studies was, in part, to evaluate the radiological impact on people who would work or inhabit the land after the operating license for the plant was terminated.
By determining the land use, PG&E could calculate the residual radioactive contamination levels below which the radiation doses from the ground would meet the criteria from the NRC and EPA. The 2009 Cost Study estimate for remediation of soils and structures was based on the NRC limit of 25 mR per year and a land use that included control of the site for at least an additional 30 years beyond license termination.
Subsequent to the 2009 Cost Study, PG&E has engaged stakeholders and reviewed the lessons learned for remediation of radioactivity at other facilities.
Although NRC regulations and the MOU between the NRC and EPA would allow for a license termination once the 25 mR per year criteria was met, PG&E decided that a more prudent criteria was the lower EPA limit and a land use that would allow for immediate release of the property for unrestricted public habitation.
This cost study is based on the lower limits. 1.5 STATE AND LOCAL APPROVALS While the NRC has the authority to terminate the 10 CFR §50 license, State and local authorities and the public also have input into decommissioning activities.
For example, the NRC provides opportunities for public involvement during its decommissioning determinations.
State agencies such as the California Coastal Commission, the California Environmental Protection Agency Department of Toxic Substance Control, and the State Water Control Board also have the opportunity to address end-state site conditions.
To better anticipate the direction expected to be provided by State and local sources, PG&E established communications directly with the governmental entities and helped form a Citizens' Advisory Board (CAB). Page 10 of 120 Meeting Date 3/6/2012 4/5/2012 7/12/2012 8/3/2012 9/4/2012 Meeting Date 9/6/2012 HBPP site Decommissioning Project Report for Humboldt Bay Power Plant Rev. 0 Unit 3 Agency Summary Joint meeting with Department Provided overview of of Toxic Substances Control decommissioning project and (DTSC) and North Coast DTSC-Iead remediation project to Regional Water Quality Control NCRWQCB staff and discussed Board (NCRWQCB) (Cleanup agency coordination requirements Section) to be considered during project planning.
NCRWQCB Discussed approach to permitting of planned Ground Water Treatment System (GWTS) to treat stormwater and water from construction dewatering, and status of Liquid Radwaste (LRW) system NPDES discharge.
US Army Corps of Engineers Discussed permitting issues related to the dredging of the I ntake/Discharge canals and Fisherman's Channel California Coastal Commission Meeting to discuss overall (CCC) permitting approach and schedule for necessary permits for decommissioning, and to discuss application for immaterial Coastal Development Permit (CDP) amendment for construction of Ground Water Treatment System (GWTS) and establish schedule for CCC approval.
DTSC Provided overview of decommissioning project, and key issues, including slurry wall installation, canal remediation and final site restoration; discussed planned permitting activities and relationship to DTSC remediation planning process. Agency Summary CCC Provided overview of Page 11 of 120 visit 11/8/2012 11/29/2012 12/11/2012 Decommissioning Project Report for Humboldt Bay Power Plant Rev. 0 Unit 3 decommissioning project and key issues, including slurry wall installation, canal remediation and final site restoration; discussed planned permitting activities.
CCC Discussed change in decommissioning project plan to include removal of reactor caisson and discussed status and schedule for developing the CDP application for the spent fuel pool/caisson removal. Joint meeting with CCC & Joint meeting to discuss DTSC decommissioning permitting activities and coordination of DTSC remediation planning process with CCC permitting process; pre-application meeting regarding CDP amendment for Caisson and spent fuel pool removal. NCRWQCB Provided overview of decommissioning project, and key issues, including slurry wall installation, canal remediation, final site restoration and planned permitting activities; discussed status of NPDES permit and planned termination of LRW discharge, and status of construction general stormwater permit and associated construction ofGWTS. 1.6 ISFSI OPERATIONS AND DEMOLITION The ISFSI will continue to operate under a separate and independent license (10 CFR §72) following the termination of the §50 operating license. The ISFSI will continue to operate until all spent fuel and Greater Than Class C (GTCC) material has been transferred to the DOE. This study assumes that the DOE will commence transferring all spent fuel from HBPP Unit 3 in the year 2024. Page 12 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 At the conclusion of the transfer process, the ISFSI will be decommissioned.
The storage modules are not assumed to be activated from the storage of fuel, due to the age of the fuel when placed in the modules and the relatively short residence time. Consequently, this estimate does not include the cost of any significant decontamination of the ISFSI facility.
Confirmation of the radiological status will be obtained through surveys and sampling of the modules. The NRC will terminate the ISFSI 10 CFR §72 license when it determines that site remediation has been performed in accordance with a license termination plan and the terminal radiation survey and associated documentation demonstrate that the structure is suitable for release. Once the requirements are satisfied, the NRC will be in a position to terminate the license for the ISFSI. Page 13 of 120 J Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 FI G URE 1.1 LAYOUT OF THE NUCLEAR PLANT SITE AND SURROUNDING AREA N umbe r !i ;; I i} I (I..\. De!.crip t ion liNlt III i HOTS>tQP
'( UV I WII.J!Z FIlII E;$F Q RDut y lR.\I\.f'l
- II lITlo\l l ISFSl LFO'TANI<.'ARElI l
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0--.. . DRAWING SK-C M L-D01 SHEET 6 of REV o Page 14 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 2 DECOMMISSIONING PLANNING AND ACTIVITIES
2.1 INITIAL
PLANNING Rev. 0 In 2008 and 2009, PG&E began an intensive planning and preparation phase in advance of beginning the decommissioning process. This phase included engineering; work planning; financial planning; and initial stakeholder outreach; performance of a radiological characterization survey of work areas, major components, and structures (including the drywell);
sampling of internal piping and primary shield cores; development of cost and work control program; development of detailed work plans and schedules; development of a radioactive waste processing and disposal plan; and the development of the engineering decommissioning licensing basis. PG&E was committed to completing this phase completely in order to better assure itself, its regulators, and the public that decommissioning could be started and completed both safely and cost effectively.
The initial approach to determining the cost of decommissioning HBPP Unit 3 was to breakdown the entire effort into four periods (note that the numbering starts with Period 2 to maintain numbering conventions with previous cost studies):
- Period 2: Safe Storage and Decommissioning Preparations
- Period 3: Preparations
- Period 4: Decommissioning Operations and License Termination
- Period 5: ISFSI Operations and Demolition
2.1.1 Periods
2 and 3 Periods 2 and 3 have been completed.
PG&E did extensive pre-project planning in preparation for decommissioning of the nuclear plant. The company bench marked against completed decommissioning projects and compared budgets and schedules across the industry.
A high degree of uncertainty and risk was identified with the initial phases of decommissioning due to the elevated alpha hazard, limited footprint within which activities would occur, and the sheer quantity of work that needed to be performed.
The planning focused on self-performed decontamination and removal of radioactive and hazardous waste, and removal of installed equipment from HBPP Unit 3. PG&E also needed to implement other projects at the site simultaneously; i.e., construct a new generating facility (Humboldt Bay Generating Station (HBGS>>, decommission fossil units, construct an ISFSI, and perform other required site modifications and 60kv switchyard upgrade. Due to the technical and regulatory nature of decommissioning a nuclear facility, the work associated with this plan affected the other work performed at the site. Thus the various projects were planned to closely coordinate activities to avoid space conflicts and related adverse impacts. The initial planning process accounted for the various technical, regulatory, and coordination challenges to successful decommissioning of Unit 3 including topics such as System and Area Closure, Decontamination, Transportation and Waste Disposal.
Planning also accounted for: Page 15 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 .. Permitting and Regulations Rev. 0 Governmental agencies from local boards to the State of California approve and issue permits to perform specific activities during decommissioning.
The Decommissioning organization expects only minor changes to permits, once issued. Several governmental agencies at the State and federal level promulgate regulations that affect various activities associated with decommissioning.
The Decommissioning organization anticipates only minor changes to the pertinent regulations that would affect decommissioning.
PG&E will make significant changes to the License Bases Documents (LBDs) during the course of the decommissioning.
The changes to LBDs revolve around the changes made to the site and plant configurations.
PG&E has anticipated the need to change LBDs and has planned and staffed to make the changes. .. Low-Level Radioactive Waste Disposal The contaminated and activated material generated in the decontamination and dismantling of a commercial nuclear reactor is classified as low-level (radioactive) waste (LLRW), although not all of the material is suitable for "shallow-land" disposal.
With the passage of the Level Radioactive Waste Policy Act" in 1980, and its Amendments of 1985, the states became ultimately responsible for the disposition of low-level radioactive waste generated within their own borders. Until recently, there were two facilities available to PG&E for the disposal of low-level radioactive waste generated by Humboldt.
As of July 1, 2008, however, the facility in Barnwell, South Carolina was closed to generators outside the Atlantic Compact (comprised of thestates of Connecticut, New Jersey and South Carolina).
This left the facility in Clive, Utah, operated by Energy Solutions, as the only available destination for level radioactive waste requiring controlled disposal.
This facility is not licensed to accept Class Band C radioactive wastes (B&C LLRW). Since the closure of Barnwell, SC, to Compact states, a new facility was licensed for receipt and storage of B&C LLRW; Waste Control Specialist (WCS) in Texas. HBPP shipped its first container in October 2012 using an 8-120 A Cask containing Reactor Pressure Vessel (RPV) internals.
HBPP worked closely with the disposal site to obtain timely State approval of import petitions, waste profiles, certifications, procedures, etc. Anticipating the very strong industry demand for access to WCS, PG&E proactively managed the process so that HBPP was at the top of the queue for the facility's acceptance of out-of-state waste. This success eliminated the need to construct and operate an on-site interim Class Band C waste storage facility.
The dismantling of the components residing closest to the reactor core generates radioactive waste considered unsuitable for shallow-land disposal.
These materials contain concentrations of radionuclides that exceed the limits established by the NRC for Class C radioactive waste and are classified as Greater Than Class C (GTCC). The Low-Level Radioactive Waste Policy Amendments Act of 1985 assigned the federal government the responsibility for the disposal of this material.
The Act also stated that the beneficiaries of the activities resulting in the generation of such radioactive waste bear all reasonable costs Page 16 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 of disposing of such waste. However, to date, the federal government has not identified a cost for disposing of GTCC or a schedule for acceptance.
As such, the GTCC radioactive waste will be packaged and stored at the ISFSI until such time that the DOE can accept shipment of those materials.
The GTCC wastes will be processed, packaged in the same type of container as for spent nuclear fuel, and transferred to the ISFSI in 2013. GTCC will be stored at the ISFSI at a cost equivalent to that envisioned for the spent fuel.
- Schedule PG&E established the work sequence and duration based upon ongoing planning efforts. The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security.
This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.
PG&E has scheduled decommissioning of the HBPP site over a period of approximately ten years finishing in June 2018. Site restoration will be complete in 2018. An additional year of administrative closeout is included in the estimate.
Schedule duration is sufficient for the activities to be completed.
The ISFSI will continue in operation until the DOE takes custody of the fuel and GTCC waste.
- Stakeholder Involvement Stakeholders have a vested interest in the safe, effective, and efficient completion of all decommissioning activities.
Stakeholders include PG&E, employees, local community members, local government, State regulators and federal regulators.
Stakeholder interests range from continued employment opportunities to the radiological consequences of decommissioning activities to environmental impacts of previous plant operations and the site environmental end state condition.
PG&E has actively sought out the inputs from the local stakeholders through sponsorship of a Citizens Advisory Board (CAB). PG&E continues to engage governmental agencies and regulators at all levels to ensure that they are informed of the ongoing and anticipated activities.
2.1.2 Schedule
Impacts on Staffing Needs Scheduled work drives the need for personnel.
As the work load increases, the staffing to successfully complete pre-project planning as well as the implementation of the plans increases.
As the work is completed, the need for staffing begins to decrease as well. PG&E established the work sequence and duration based upon ongoing planning efforts and PG&E's forecast schedule.
The schedule is relied upon in calculating the carrying costs, which include program management, administration, field engineering, equipment rental, and support services such as quality control and security in addition to the staffing ramp-up/ramp-down.
This systematic approach for assembling decommissioning estimates ensures a high degree of confidence in the reliability of the resulting cost estimate.
In the initial phases of the HBPP Unit 3 decommissioning, PG&E self-performed all the work including planning, engineering, large component removal, and systems removal. The self-performed work Page 17 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 included those activities where there was a high degree of uncertainty or risks involved.
As the decommissioning transitions to work where the scope is well defined and uncertainty is minimal, PG&E is shifting from self-performed work to fixed price contracts.
The staffing costs for the on fixed price contracts are borne by the successful bidder. However, the continuing costs associated with overhead staffing will persist. Those costs include the personnel who are part of management, engineering, safety, and Radiation Protection.
- 2005 Staffing Bases: The peak staffing to support the 2005 schedule was estimated to be approximately 121 utility, Decommissioning Oversight Contractor (DOC), and Security personnel.
The peak period for staffing was anticipated to last for nine months. The estimate assumed that a DOC would manage, plan, and perform all of the physical decommissioning activities.
The DOC would be responsible for recruiting, acquiring, hiring and supervision of the staff. PG&E would have a limited number of personnel to oversee the activities of the DOC. A separate Radwaste contractor would be commissioned to manage processing and disposal of decommissioning wastes. The 2005 estimate assumed that the fossil units would continue to operate which was expected to result in the site being less congested, having less people on site, and having more available laydown space and work area.
- 2009 Staffing Bases Changes: Several assumptions were changed between the 2005 and 2009 estimates.
First, PG&E commissioned a project to construct the HBGS on the site to replace the aging fossil units. Second, PG&E decided to demolish Units 1 and 2 and sell the two combustion jet engine generating units. The sequence includes construction of HBGS followed by removal of the fossil units. Limited Unit 3 decommissioning was scheduled to proceed until demolition of Units 1 and 2 had been completed.
This sequence allowed for continued reliable generation of electricity for the local area; expanding laydown areas for Unit 3 demolition onto the removed Units 1 and 2 footprint; and providing time to prepare Unit 3 with a Radwaste processing area. After demolition of Units 1 and 2, preparation of Unit 3, and full decommissioning of Unit 3 was undertaken.
Recent industry decommissioning experience indicated that use of a DOC has resulted in unanticipated expense, schedule extension, and other issues. Therefore, PG&E decided to self-perform the decommissioning activities of high uncertainty and risk and manage the processing and disposal of waste with internal resources.
Use of a DOC did provide two advantages that PG&E wished to retain. First, a DOC could efficiently identify, screen and select augmented staff with minimal impact on PG&E Management's time. Second, a DOC could provide clear delineation between full-time PG&E employees and the augmented staff provided by the DOC. To retain these two desired features, PG&E selected a staffing company to provide augmented staff. The staffing company was contracted to help recruit, acquire, and manage augmented staff. The staffing company will relieve site management of the burden of soliciting, screening, and identifying potential staff augmentation candidates.
The use of the staffing company resulted in cost and manager labor savings. PG&E retains Page 18 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 the responsibility for oversight of decommissioning activities and augmented staff; and, therefore will keep full-time PG&E employees in key positions to assure that the decommissioning is performed safely, effectively, and efficiently.
- 2012 Staffing Bases Changes: The self-performed work conducted from 2009 through 2012 was performed well. During this same period, PG&E separately decommissioned Units 1 and 2 using a fixed price contract.
The scope of the Unit 1 and 2 decommissioning was well defined with little uncertainty.
The total costs for that decommissioning were under budget and the work completed ahead of schedule.
Based on this experience, PG&E decided to identify those remaining scopes of work for HBPP Unit 3 that could be easily and well defined with little or no uncertainty.
Shifting major pieces of work scope to a fixed-price contract has the effect of reducing the PG&E staff that is required.
The residual staff that remains with PG&E is considered overhead and is comprised mainly of management, engineering, oversight, safety, and RP. The duration that the overhead is required will be extended based upon adding the reactor caisson removal as a new scope of work. That scope will add about 2 % years to the duration of the decommissioning and, therefore, the same amount of time added to the need to retain the overhead staffing.
2.1.3 Impact
of Alpha Contamination The extremely high levels of alpha contamination present in the plant makes HBPP Unit 3 unique in the realm of decommissioning of commercial nuclear plants. This results in:
- lower productivity associated with greater use of protective clothing and respiratory protection;
- significantly greater efforts to avoid generating airborne releases due to decontamination efforts, which constrains options as to techniques that can be used and results in more time and fiscal resources being consumed; and
- significantly increases the demand on Radiation Protection resources to provide sampling, survey, job coverage, and respiratory protection support for work. The net effect of these is to increase the duration, staffing and consumables needed to complete the work. 2.1.4 Transition Special Projects PG&E identified several special projects.
Special projects are those activities that do not provide direct progress on the schedule but do support scheduled activities.
As such, the special projects were incorporated into the planning and cost estimate processes.
Examples of special projects include: Page 19 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3
- Re-Locate Access Control: Rev. 0 The rad-waste transportation plan calls for the enlargement of the area surrounding Gate 13, where the current alternate access control is located. To support that change in plant design, a new alternate access will need to be constructed and installed.
This project includes the engineering to support the movement and modification of the plant, implementation of the new alternate access and to move the current equipment, and re-calibrate and test the equipment prior to opening the new access control.
- Restore 75 Ton Refueling Building Crane: The 75 ton main hoist, which was originally built in 1947 for a substation in San Francisco, has not been used in the last 20 years. Due to the age of this equipment, replacement parts are no longer available and any required replacement will result in extensive evaluations of parts equivalency.
To improve the safety of the operation of the 75 Ton main hoist new electrical and control components including refurbished or new motors are required.
This equipment is needed for access to the reactor vessel for characterization.
- Temporary Utilities for Decommissioning:
Temporary utilities are needed in most areas to prepare for decommissioning, such as electrical power, service air, water, lighting, ventilation, and communications.
Existing utilities, designed for routine operations and maintenance, are typically inadequate or unavailable to meet the needs of decommissioning.
For example, power tools often require higher voltage and/or amperage to operate, additional lighting is typically needed in most rooms, and ventilation systems need to be modified.
These temporary utilities need to be planned, designed, purchased, and made operational prior to starting decommissioning activities.
- Additional Infrastructure:
Increased staffing required for the decommissioning of Humboldt Bay Power Plant results in the need for additional office space, including facilities for breaks, restrooms, storage of records, records management, and the construction of a second access road that connects the main access road to PG&E facilities north of the parking lot. This work includes the engineering, surveying, geotechnical, permitting, materials testing, and inspection needed to complete design of the access road and monitor construction.
The increased staffing to support the decommissioning activities requires the purchase/leasing of additional trailers and installation of services such as telephone, computer, water, and electrical.
2.1.5 Periods
4 and 5 Period 4, Decommissioning Operations, is ongoing and Period 5, ISFSI, is in operations.
Over the past four years, the majority of decommissioning work has been installation of new site infrastructures and removal of systems and components, otherwise known as the Plant System Removal Phase. In this phase, PG&E established a self-perform arrangement in which PG&E provided direct supervision of a contracted work force performing work on a Time-And-Material basis or on a Cost-Plus basis. This type of contracting arrangement was necessary, and optimum, due to several factors including Page 20 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 the dynamics of maintaining specific plant systems in service while others were removed from service and the configuration control that must be maintained; removal of large components with known high levels of radiation that required slow and methodical disassembly; and removal of contaminated systems under special engineering controls and requirements.
Careful planning and special measures were taken to accomplish this work with maximum safety to the workers and the public. Work scope of this nature, wherein uncertainty exists as to the exact effort that will be required to perform all tasks, lends itself to Time-And-Material or Cost-Plus contracting.
This phase has been undertaken by PG&E and is near completion.
During this period to support full decommissioning a significant number of required plant modifications, site improvements and infrastructure were put in place. At the same time PG&E was commencing decommissioning of HBPP Unit 3, it also was decommissioning fossil plants located on site to provide access and lay-down for the Unit 3 nuclear decommissioning.
PG&E evaluated the management options for decommissioning and removal of out-of-service electrical production units. Fossil decommissioning included demolition of Units 1 and 2 with a capacity of 53 MW(e) each and removal of the two 15 Mw(e) combustion turbine units that have been used as peaking and emergency (MEPPS) units. The work scope was well defined with little uncertainty associated with system and component removal requirements.
A single demolition/decommissioning organization, led by the HBPP Director and Nuclear Plant Manager was chosen. It provided a better means to plan work activities, coordinate space usage, levelize staffing needs, and control and monitor costs. From the early planning efforts of defining the project scope to development of the technical and administrative specifications to obtaining competitive bids and managing the execution of the project, the project team successfully managed this project within budget and seven months ahead of schedule.
The model established for the Fossil Decommissioning is being adopted for the well-defined scopes of work for decommissioning HBPP Unit 3. 2.2 COMPLETED ACTIVITIES HBPP Unit 3 successfully completed the transfer of spent nuclear fuel assemblies from the spent fuel pool in five casks to the independent spent fuel storage installation (ISFSI) in December 2008. Since the 2009 NDCTP, the site has fully transitioned into full scale decommissioning.
During this period, PG&E took on some of the most challenging and laborious projects involving significant risk and radiologically significant work activities.
To support full scale-decommissioning, a significant number of required plant modifications, site improvements and infrastructure were put in place. The changes to the site and facilities included:
a new 2,000 ft2 radiological control access; 4,000 ft2 environmental count room facility; truck portal monitors and scale; 5,000 ft2 tented enclosure for radwaste handling; and 25,000 ft2 of office space constructed from ten new trailers, nine re-powered trailers and six re-used trailers from Humboldt Bay Generating Station (HBGS); re-powering and implementing cold and dark program on all three units fossil and nuclear and to mitigate the environmental challenges with provisions of the new construction storm water general permit, a significant upgrade and paving project was completed to the main road. Page 21 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Decommissioning activities to date have resulted in the removal and disposal of all large components outside of the NSSS, the reactor vessel head, and most of the supporting systems outside of the NSSS. PG&E completed removal of most large nuclear components, excluding the reactor vessel, and safely transported these oversized, overweight shipments to distant radiological disposal sites without incident.
These large nuclear components included spent fuel pool racks, high and low pressure turbines, turbine crossover, main condenser halves, reactor head, heat exchangers and low and intermediate heaters. The project received PG&E's Sibley award for excellence in health and safety performance in 2008,2009, and 2010. The 2009 Cost Study estimated a 34 month schedule for removal of the Turbine Building systems. Even though PG&E faced difficult challenges such as dealing with alpha contaminated plant systems, PG&E successfully completed component removal from the Turbine Building within the planned 34 months. This work involved removal of many different systems and components, each presenting different challenges.
By February 2012, the main steam piping, feed water piping and other plant systems had been removed from the turbine building.
To add a margin of radiological safety, a multiple barrier approach was used to protect the workers and minimize the potential for spread of contamination.
Multiple layers of protective clothing and respiratory protection were provided for personnel in the work area, and multiple containment boundaries such as sleeves, fixatives, and glove bags were used on the components.
The concentrations and quantities of alpha contamination were of such concern to HBPP Unit 3 management that they felt compelled to inform the NRC due to associated risks. The alpha contamination levels have been compared to high levels found at DOE nuclear weapons sites. An NRC Commissioner visited the site in early 2010 and had very positive comments about the controls implemented to address the contamination.
As a follow-up, the NRC Chairman, visited the site in August, 2010, in part to review the activities pertaining to the control of the alpha contamination.
The Chairman was favorably impressed with the professional attitudes of personnel and high quality of work being performed at the site. He noted that HBPP had received PG&E's Sibley award three years in a row and stated that it was justified and reflective of the performance of the site staff. A testament to the rigor of the processes implemented to control the extreme levels of alpha contamination was that the entire Turbine Building Preparation project was completed without a single incident of a worker becoming contaminated; there were no significant radiation exposures; there were no unplanned exposures; and there were no releases of contamination to the environment.
Staying on schedule has enabled PG&E to plan to demolish the turbine building one year ahead of schedule.
Through a thorough competitive bid process based on technical merit and commercial terms, the demolition contractor is now mobilized, trained and preparation activities are underway to start decontamination and physical turbine building demolition work in December 2012. Other accomplishments include:
- A reactor vessel removal contract is in place to remove the internals and a separate contract to segment the shell has been awarded. Removal of more than 65% of the reactor internals has been achieved to date. After twenty five years, the drywell was re-opened and the reactor Page 22 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 head removed. The vessel was flooded, water filtered, an extension tank installed and two control rods removed. Surveys and characterization of the reactor vessel were completed.
To date, the internals removea from the reactor include the chimney and chimney clamps, upper core guide, fuel hold downs, core support plate, and specimen baskets.
- Since the closure of Barnwell, SC, to non-Compact states, HBPP Unit 3 commenced its first shipment of B&C LLRW to Waste Control Specialist (WCS) in Texas, in October 2012 using an 8-120 A Cask containing RPV internals.
HBPP Unit 3 worked closely with the disposal site to obtain timely State approval of import petitions, waste profiles, certifications, procedures, etc. Anticipating the very strong industry demand for access to WCS, PG&E proactively managed the process so that HBPP Unit 3 was at the top of the queue for the facility's acceptance of out-of-state waste. This success eliminated the need to construct and operate an on-site interim Class Band C waste storage facility that was applied for as a contingency plan and approved by the California Coastal Commission in October 2011.
- HBPP Unit 3 successfully completed its fourth designated "Radiological Significant Decommissioning Activity" (RSDA) by transferring the contents of ISC-18 (remnants of spent nuclear material) into a shipping cask and shipped it to Barnwell, SC for processing in October 2012. This process waste container was vacuum dried, helium leaked tested and delivered back to PG&E where the package will be placed in the Greater Than Class C (GTCC) cask. This final sixth cask will be loaded in 2013 with this process waste container and highly radioactive internal components from the reactor vessel, and moved to the ISFSI for storage.
- PG&E executed a contract in 2011 to remove the abandoned, out-of-service liquid radwaste tanks. To date, three of the four tanks have been removed and this resulted in a significant reduction of high-risk alpha contaminated system tanks. The remaining spent resin tank is expected to be removed early in 2013.
- Systems removal from the Turbine Building has been completed and the building prepared for turnover to a prime contractor, for decontamination and demolition (0&0). This 0&0 work is about to begin and is scheduled for completion by mid-2013.
- In the Valve Gallery, significant progress was made removing main steam line piping and other systems outside the reactor vessel dry well. This work will resume following Turbine Building demolition.
- In the Refueling Building, the Cleanup and Shutdown Heat Exchanger systems have been removed.
- In the Suppression Chamber, preparatory work for systems removal has been established including safety improvements to the man-lift (conveyor belt) access, emergency egress, scaffolding, lighting, and ventilation.
Systems removal will begin in December 2012. Page 23 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. a
- In the Off-gas Tunnel, significant systems removal progress has been made after establishing . access, erecting material handling and packaging containment structure, and other special setups.
- PG&E completed a major effort to consolidate about 10,000 cubic yards of soil generated from numerous site improvements required to support decommissioning since it began. The management of this soil as fill for a material handling area, avoided the need for expensive storage or disposal off site, and opened valuable laydown areas on the congested site for other uses.
- The HBPP Unit 3 Decommissioning Project has been successfully coordinating work with another major project on site, the Humboldt Bay Switchyard GIS Replacement Project. The on time completion of this project is required to bringing the new equipment on-line during a critical transmission outage schedule period.
- Exemption requests were approved by the NRC for waste material disposal at US Ecology, Idaho, enabling PG&E to significantly reduce its waste disposal costs.
- A Request for Proposal (RFP) bid package was completed and issued to perform the major civil works scope for decommissioning.
The RFP process is still in progress.
- An evaluation of the need to remove the deep reactor vessel caisson structure, and a feasibility study for its removal, were completed.
The conclusion of this evaluation and study was to recommend removal of the caisson. The major civil works RFP is currently being updated to include this new scope of work. Actual decommissioning costs to date are very close to forecasted amounts from previously approved cost studies. 2.3 TRANSITIONING TO CIVIL WORKS PROJECTS PG&E is transitioning from plant systems removal activities to civil works execution projects performed similarly to the demolition of two retired fossil units adjacent to the nuclear unit. . The nuclear decommissioning effort incorporates lessons learned from the recently completed fossil decommissioning project. The remaining nuclear building demolition work or civil works effort is similar in nature to the fossil decommissioning project with scope-specific work, proven methodologies, and predefined boundaries.
The strategy is to transition from self-perform to more lump sum fix cost contracting, commensurate with the change in nature of the work. As HBPP Unit 3 Decommissioning transitions from the Plant System Removal Phase, where work scope was dynamic with significant uncertainty, to the Civil Works Projects Phase, where work scope is well defined, a contracting plan similar to that used for Fossil Decommissioning will be implemented.
Award of five major work scopes in various stages of development are planned as five separate contracts to five or fewer Contractors.
These include Turbine Building Demolition, Nuclear Facilities Demolition and Excavation, Intake and Discharge Canal Remediation, Office Facility Page 24 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Demobilization, and Final Site Restoration, as described in the following section. Each work scope is supported by detailed and high quality bid specifications with a clear and concise description of work, which enables PG&E to solicit RFPs that are competitively bid and awarded as Firm Fixed-Price or Fixed Unit Price contracts.
PG&E formed an interdisciplinary and broad-based subject matter expert team to develop and vet fifteen technical specifications accompanied by ten administrative specifications.
The specifications developed by this technically focused group will define the requirements and criteria to complete the remainder of the decommissioning at HBPP Unit 3, including a plan for final site restoration.
The Specifications Development Team met every week for twelve months and a Long Term Strategy Team met every week for seven months developing the Level 1 Long Term Schedule and Exit Strategy.
This effort resulted in issuance of the HBPP Unit 3 Decommissioning Capstone Document to the 0&0 industry.
The Capstone Document was provided to the Bidders to facilitate transfer of knowledge from these teams to the qualified Bidders. The insights, challenges, and expectations these teams achieved during development of the civil works projects will help the Bidders create responsive, well-thought-out bids to complete this complex undertaking safely and successfully.
2.4 MAJOR
CIVIL WORK PROJECTS Removal of the boiling water reactor steam and condensate systems from the Turbine Building was completed in early 2012. The contract for asbestos abatement and surface decontamination and demolition (0&0) of the Turbine Building was awarded in 2012 with the work scope planned for completion in mid 2013. The following five major civil work projects will span the next five years at HBPP Unit 3: 2.4.1 Turbine Building Demolition:
The scope of work includes asbestos abatement (primarily of the Reactor Feed Pump raceways and penetrations), open air demolition of a concrete structure.
2.4.2 Intake
and Discharge Canal Remediation:
This scope of work includes mechanical removal of radiologically and chemically contaminated sediment from the Intake and Discharge Canals, demolition of the discharge outfall and levee to Humboldt Bay, demolition of the intake and discharge structures, restoration of levee and coastal trail along the Bay, management and dewatering of contaminated sediments, and water treatment to meet discharge permit requirements.
2.4.3 Nuclear
Facilities Demolition and Excavations:
This scope of work includes decommissioning and demolition of all remaining permanent plant structures and facilities identified for demolition.
Additionally, this scope of work includes installation of a slurry bentonite wall to the Unit F clay layer that will encompass the Reactor Building Caisson, Turbine Building foundation, and other deep structures in the Unit 3 area to provide groundwater control and isolation.
Note that this scope of work will include removal of the Reactor Caisson and Foundation Piles. The Nuclear Facilities Demolition and Excavations, including the removal of the Page 25 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Spent Fuel Pool, is a significant and diverse scope of work representing the principal contract of HBPP Decommissioning.
2.4.4 Office
Facility Demobilization This scope of work includes removal and/or demolition of office facilities, including buildings and structures owned and leased by PG&E. Most of buildings and structures to be removed are modular or trailer type construction.
Leased trailers and structures are to be isolated, disconnected, removed from HBPP Unit 3, and returned to the owner. Buildings and structures owned by PG&E are to be isolated, disconnected, demolished, and disposed as waste, unless released for salvage or recycle. This scope of work includes an estimated 32 building units comprising approximately 40,000 square feet. 2.4.5 Final Site Restoration This scope of work includes development of site grading and drainage, placement of ground cover including vegetation and other surfacing, road construction and repairs, installation of fencing and site lighting, and other final site development work to achieve the required end state condition for PG&E's future industrial use. It includes demolition of remaining miscellaneous structures to support final site restoration plans. The parcel containing the restoration area is approximately 102 acres. Main features of this scope of work include removal of buried asbestos containing materials; demolition of reinforced concrete settling basins, truck ramp, and associated piping; soil excavation, backfilling, and compaction; wetlands construction; finish grading; storm drain system installation; topsoil placement; vegetation establishment; installation of erosion control features; ground cover installation; final surfacing; and removal of portal monitors and truck scales. Benefits realized by transitioning to the Civil Works Projects Phase with predominant firm price/fixed unit price contracting include single or multiple D&D contractors who can coordinate concrete shaving, liner removal, structural removal, and other demolition activities; streamline financial control; reduce PG&E overhead staffing; and provide a specialized Bidder Team with experience from other similar projects.
The overall approach PG&E has taken to complete HBPP Unit 3 Decommissioning has produced proven and successful results at other D&D projects and programs throughout the U.S. 2.5 BID SPECIFICATIONS In 2011 and 2012, as the self-performed portions of the decommissioning were well underway, PG&E identified scopes of work that were well understood with minimal risk. PG&E decided that competitively bid, fixed price contracts for the work would be the most cost effective, efficient, and safest way to complete the work. In order to assure itself and its stakeholders that the contractors would meet all expectations, PG&E developed a set of bid specifications.
The specifications contain the requirements that successful bidders must meet and PG&E's commitments to those bidders. The topics contained in the specifications include (partial list):
- Health and Safety Requirements;
- Project Coordination and Meeting Requirements;
- Quality Programs; Page 26 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3
- Temporary Facilities and Utilities;
- Environmental Protection;
- Waste Management;
- Decontamination Processes; and
- Final Site Restoration Rev. 0 PG&E commissioned publication of a Decommissioning Capstone Document that summarizes the expectations, goals, processes, and projects that will be performed under fixed-price contracts.
The Decommissioning Capstone Document will help all parties, including HBPP Unit 3 staff, bidders, and stakeholders, understand the approach and final outcomes of this phase of the decommissioning.
PG&E developed several bid specifications to identify and control important aspects of the bidding, award, and implementation of fixed price contracts.
Both clear direction to the bidders and clear commitments for support and oversight by PG&E will result in consistent and reliable bids on the front side and work that meets PG&E's expectation after implementation.
The bid specifications include (partial list): 2.5.1 Health and Safety Requirements (01-11-01)
PG&E fosters a safety culture and expectation of exemplary safety performance.
Protection of personnel and the environment while providing a safe work place are the number one priorities at PG&E. The purpose of this specification is to outline the health and safety requirements for the performance of all work identified in the Specifications for decontamination, demolition and/or remediation activities at the former HBPP Unit 3. This specification includes requirements for training, radiation protection, monitoring and control, site security, as well as PG&E's expectations and codes of conduct. 2.5.2 Project Coordination (01-31-13)
PG&E will continue to self-perform some minor activities after awarding of fixed-price contracts.
Those activities include operations, maintenance, and some decommissioning.
The purpose of this specification is to outline the coordination requirements for the performance of all work identified in the Specifications for decontamination, demolition, and/or remediation activities at HBPP Unit 3. Defined in this specification are operations performed by PG&E, procedure identification and compliance, work sequencing and constraints, work planning, environmental quality, radiation protection and final status survey requirements, and expected responses to emergencies.
2.5.3 Submittal
Procedures (01-33-00)
PG&E considers development of accurate and timely submittals for project planning, and during demolition, to be extremely important.
Proper, complete, and appropriate documentation is necessary to record project decisions, the basis for planned activities, execution of the Work, and conformity with project plans and specifications.
PG&E also recognizes that submittal and review is a two-way street. The purpose of this specification is to clearly define the expectations and processes for submittal and review of all project documentation including drawings, calculations, design data, test and inspection reports, procedures, and plans. Included in this specification are the requirements to be followed by both the contractor and by PG&E. Page 27 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 2.5.4 Contractor Quality Control (01-45-16)
Rev. 0 Contractor Quality Control (CQC) is the means by which a contractor ensures that the work, including that performed by subcontractors and suppliers, complies with the requirements of the Contract.
This specification defines the requirement for a contractor to have, maintain, and implement a CQC Plan. It further defines the content requirements for the CQC Program and for the CQC organization.
To assure PG&E of proper and compliant implementation of this specification, the specification also includes requirements and methods that PG&E will implement to verify Quality. 2.5.5 Temporary Facilities and Controls (01-50-00)
The purpose of this specification is to provide the contractors with information about regulatory community and PG&E requirements for permits and approvals for facilities, structures, and engineered solutions necessary to support the Decommissioning effort. Because of the dynamic nature of the work, a variety of temporary systems will be necessary, including utilities, laydown areas and structures, and protective systems and barriers.
In addition, the Civil Works contractors must develop plans addressing a variety of temporary and changing situations, particularly with respect to noise and dust control, traffic and pedestrian routing, and other field logistics as work amongst the various Civil Works contracts progresses around the site. This specification provides the expectations and direction to assist with successful completion of work while accounting for the requirements for temporary facilities and controls.
2.5.6 Stormwater
Pollution Prevention Plan (SWPPP) Implementation (01-57-13)
All stormwater collected and discharged from the HBPP Unit 3 is subject to regulation under a NPDES permit. PG&E and its contractors are responsible for maintaining stormwater collection and discharge systems, and preventing pollution from entering stormwater flow into Humboldt Bay, including through the Intake and Discharge Canals. PG&E accomplishes this through a system of drain inlets, underground piping, and BMP that control erosion, minimize sediment loss, and prevent or limit exposure of potential contaminants to precipitation during routine plant operations.
This specification defines the requirements for both PG&E and contractors to comply with the requirements of the NPDES permit and the SWPPP including control of materials, required staffing, inspections, maintenance of control and monitoring systems, and responses to hazardous wastes. 2.5.7 Supplemental Environmental Protection Requirements (01-57-19)
In addition to PG&E's commitment to the health and safety of personnel and the environment as noted in Specification 01-11-01, PG&E is committed to demonstrating environmental leadership through its actions. This specification defines the general environmental requirements and expectations that PG&E intends to impose on contractors performing work at HBPP Unit 3. Included in the specification are quality requirements, accountabilities, and training.
Specific requirements are defined for hazardous materials, biological resource preservation, cultural resource preservation, air quality, noise and vibration, water quality, vehicular traffic, and aesthetics and visual resource preservation.
Page 28 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 2.5.8 Waste Management (01-74-01)
Rev. a The HBPP Unit 3 Decommissioning and Demolition Civil Works Projects will involve several discrete processes generating waste that must be managed for offsite disposal onsite reuse, or in limited cases, offsite reuse. PG&E currently conducts its own waste management operations in accordance with a Site-wide Waste Management Plan addressing contaminated soil, demolition debris, and radiological waste. The plan is robust and addresses regulatory background and requirements; provides information on site-specific waste management practices, policy, and procedure; and serves to meet a requirement of the California Coastal Commission for compliance with permitting, documents, and agreements.
This specification requires the contractor to develop a plan and to manage wastes in accordance with PG&E's established waste management and radiological protection programs.
The specification provides direction on scheduling, waste acceptance criteria, waste accumulation, packaging, loading, shipping, and decontamination.
2.5.9 Building
Decontamination (02-51-00)
HBPP Unit 3 interior concrete surfaces were painted with Carboline lead based paint after construction.
During plant operation and SAFSTOR, the concrete surfaces were subjected to liquid and gaseous contamination, which resulted in loose and fixed contamination of the concrete surfaces with alpha and beta-gamma emitting radionuclides.
The contamination was often fixed in place by repeatedly painting the floors, walls, and ceilings.
This specification covers decontamination of the surfaces to contamination levels that are low enough to allow open air demolition.
This specification includes allowable decontamination methods, sequencing and schedules, plan development, plan evaluation, personnel and environmental safety requirements, debris and material controls, and final acceptance criteria.
2.5.10 Above Ground Demolition
-RCA Structures (02-41-16.02)
This Specification Section describes the expectations of PG&E in demolishing the above ground portions of the buildings located inside the HBPP Unit 3 Radiologically Controlled Area (RCA) ("RCA Structures").
In developing these Specifications, PG&E separated the Work of this Section from the Work of Specification Section 02 61 00, "Removal of Subgrade Structures and Contaminated Soil" because several of the deeper subgrade features must be protected until they are ready for removal. Specifically, the Refueling Building at EI.+12 is located atop the Reactor Caisson and Caisson Access Shaft that extend down to EI.-66, the Spent Fuel Pool at EI.-14, and the Cask Pit inside the Spent Fuel Pool at EI.-24. The RCA structures included in this specification include:
- Solid Rad Waste Building (Building
- 14)
- Low Level Rad Waste Building (Building
- 15)
- Liquid Rad Waste Building (Building
- 16)
- Hot Machine Shop (Building
- 4)
- SAS Building/Recombiner/lnstrument Building (Building
- 17)
- Plant Ventilation Stack Base
- Refueling Building (Building
- 3)
- Various miscellaneous RCA structures Page 29 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 2.5.11 Non RCA Ancillary Buildings Demolition (02-41-16.09)
Rev. 0 This Specification Section describes the expectations of PG&E in demolishing buildings and structures located outside the HBPP Unit 3 Radiologically Controlled Area (RCA). These structures are removed after or in conjunction with demolition of the RCA structures and include a mix of permanent and temporary facilities.
The end state of the Non RCA Ancillary Buildings Demolition is all identified Buildings and Structures have been demolished or removed from the HBPP site and the site is stabilized and turned over for Final Site Restoration.
2.5.12 Removal of Subgrade Structures, Contaminated Soil (02-61-00.01)
This specification describes the work involved in removal of hazardous, nonhazardous, and radiological contaminated materials, which include paving, concrete slabs, subgrade structures, embedded pipe, soils, and debris. The contractor's work plans shall include a description on how the contractor will keep dose As Low As Reasonably Achievable (ALARA) and minimize the generation of wastes. In addition to licensed nuclear material, other environmental contaminants that may be encountered include total petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), and metals, including chromium, lead, copper, and molybdenum.
Removal of subgrade structures and contaminated soils includes the following:
- Condensate Pump Pit and four (4) Casings
- Unit 3 Turbine Building slabs, embedded piping and subgrade structure and removal of the Condensate Pump Pit and two (2) Pit Casings
- Liquid RadWaste Handling Building slabs and subgrade structures
- Sump and trenches
- Hot Machine Shop slab and sub grade structures and the pit casing
- High Level Storage Vault
- North and South Yard Drainage Stormwater drain system
- Underground Radwaste and utility piping
- Off Gas Tunnel
- Circulation cooling water intake and discharge water piping up to the canals
- Firewater protection pipe on the north and east side of Unit 3.
- All buried and embedded piping within the RCA boundary shall be removed. 2.5.13 Removal of Subgrade Structures and Contaminated Soil -Spent Fuel Pool (02-61-00.01)
This specification is for the demolition of the Spent Fuel Pool sub-grade structure to the minus twenty-nine
(-29) foot elevation to remove three Spent Fuel Pool concrete walls (one must be retained to support the Suppression Pool), remove contaminated soil around the pool cell after the walls has been removed, and also includes removal of the tremie concrete below the SPF floor. The Fuel Pool was a poured-in-place concrete vault approximately twenty-six (26) feet by twenty (20) feet high with a deeper cask pit that extends from EI. -14 to -24 foot elevation and is ten (10) by twelve (12) feet, six (6) inches. The spent fuel pool stainless steel liner was installed due to cracks that formed in the structural walls as a result of seismic activity.
It is known that water leaked from the Page 30 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Spent Fuel Pool into the sub-grade soil. There is evidence of water intrusion behind the liner. It is anticipated that fifty (50) to two hundred fifty (250) gallons per day of in-leakage of groundwater into the pool can be expected when the SPF is drained, in the absence of mitigation measures.
The liner will have been removed by others when this work scope is initiated.
2.5.14 Intake and Discharge Canal (02-60-00)
This specification describes the requirements for setup and mechanical removal of contaminated sediment from the Intake and Discharge Canals, demolition of discharge outfall structure that is within existing levee, removal of the intake/discharge structures and isolation and severing the circulation water piping, restoration of levee, management and dewatering of sediments.
Remediation, removal or isolation of the Intake and discharge circulation cooling water piping is coordinated with canal remediation.
This specification further stipulates sequencing and scheduling requirements, planning and evaluation requirements, safety requirements, excavation methods and surveys, demolition controls and debris management, water management, and other safety and environmental requirements.
2.5.15 Final Site Restoration (32-71-00.00)
This specification is for completing the final restoration Work to fulfill the requirements of the various permits covering HBPP Unit 3 and to assist with obtaining the NRC's release of the Part 50 license. Included in this Work are demolition of the Assembly building (10); removal of asbestos containing materials; demolition of reinforced concrete settling basins, truck ramp and associated piping; soil excavation, backfilling, and compaction; wetlands construction; finish grading; storm drain system installation; topsoil placement; vegetation establishment; installation of erosion control features; ground cover installation; final surfacing; removal of portal monitors and truck scales; fencing and gate installation; lighting installation; and construction of new roads or repairs to existing roads. Page 31 of120 3 COST ESTIMATE Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Site-specific cost estimates were prepared for PG&E prior to commencing decommissioning of the HBPP unit 3 facility.
The estimates were based on the unique features of the facility, previous studies and accounted for lessons learned at other facilities that had undergone similar decommissionings.
As PG&E identified efficiencies and discovered issues that affected work processes, and therefore costs, changes to implementation methodologies were researched, planned, and reviewed by management.
With system dismantling work underway, PG&E has not updated the previous cost studies; rather this current estimate reflects forecasts which have been developed from engineering studies, and/or or actual contractor bids. This estimate update incorporates the site specific and special tasks that have been prescribed or implemented as a result of the ongoing decommissioning planning.
The basis of the estimate and the sources of information, methodology, site-specific considerations, assumptions, and total costs are described in this section. PG&E currently estimates that the cost to complete remaining decommissioning work at HBPP Unit 3 is $727.6 million including contingency.
1 The total cost of decommissioning Humboldt Unit 3 is $982.4 million. This represents an increase from the forecast approved in the 2009 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) of $499.9 million (in 2008 dollars) for decommissioning HBPP Unit 3. The principal drivers of the projected cost increase are unforeseen changes in the scope of work to be performed.
In its previous cost studies, PG&E had specifically assumed that the reactor caisson and associated structures three feet and more below grade level would remain in place. In late 2011, PG&E was able to obtain access to one portion of the bioshield wall surrounding the reactor vessel. Laboratory testing revealed that there was greater neutron activation than had been predicted.
PG&E now believes that it has no viable alternative but to remove the entire reactor caisson containment structure.
After a detailed feasibility study, PG&E has determined that this new scope of work will be approximately
$192 million, including contingency.
Additionally, given political realities within Humboldt County, and state and local regulatory requirements, the probability is high that PG&E will ultimately be required to mitigate the final restoration state of the project to a more stringent standard than previously assumed under NRC regulations.
PG&E has changed its previous assumption and assumed lower values of residual radioactive material.
This change in scope particularly impacts the remediation of the intake and discharge canals which, with associated soil removal and disposal, is estimated to be approximately
$47 million, including contingency.
It is PG&E's judgment that moving to the more rigorous standard now will not only result in more complete remediation, but will also result in lower costs than the costs associated with regulatory uncertainty, delay and potential litigation.
Joint site support and groundwater treatment costs for the caisson and canal are $6.2 million, Costs for spent fuel management have increased because four additional years are assumed to be required to store high level radioactive waste (spent nuclear fuel) on site until a federal repository or suitable facility is established by the DOE. The cost of this changed assumption is approximately
$20 million, including contingency.
1 Unless specifically stated otherwise, dollars used herein are in 2011 $. Page 32 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Collectively, these three items constitute
$265.2 million, about 55% of the total increase.
Page 33 of 120 Decommissioning Project Report for Humboldt Ba y Pow e r P lant Unit 3 Cost Category I G e n e r a l S t a ffing (Exc lud es C a i sso n) Overall Project License Termination Survey (Excludes Caisson) Remainder of Plant Systems Direct Labor Craft Radiation Protection Liquid Radwaste System Tools & Equipment
- Common Tools Rad Protection Glove Bags Site Infrastructure Specific Project Costs (Excludes Disposal!
Caisson! Canal) Reactor Vessel Removal Turbine Bldg Demolition Other Civil Works Waste Disposal (Excludes Caisson! Canals) \. Labor (Packaging and Handling)
Third Party Disposal Sites Waste Handling Building Small Value Contracts Small Dollar Vendors Specialty Contracts Spent Fuel Management Security ISFSIO&M ISFSI Removal NRC Fees Transfer to DOE Contingency (Excludes Caisson I Canals) Subtotal Base Caisson Fie l d Work Packaging I Material Handling Project Staffing Waste Disposal License Termination Survey Tools and Supplies Other Caisson Contingency Canal Remediation Removal Disposal Canal Contingency Common Site Support -Caisson and Canals Relocation of Trailer City Groundwater Treatment Groundwater Treatment System Operation Subtotal Caisson! Canal! GWTS TOTAL I Re v. a Amount 100,167 87,002 13,166 56,693 32,814 17,748 15,066 6,659 17 , 220 3,771 12 , 628 821 2,074 104,254 15,368 14,307 74,579 74,011 18,994 52,315 2,701 36,042 10,751 25,291 62,608 47,243 7,925 2,000 2,940 2 , 500 46,552 482,402 191,627 78,000 12,932 22,126 24,037 6,168 2 , 346 4,238 41,780 47,408 21 , 000 20,224 6,184 6,196 2,542 2 , 893 761 245,230 727,633 Page 34 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Finally, PG&E now has several years of actual decommissioning experience as the site transitioned from SAFSTOR to full scale decommissioning.
The prior study was based on time estimates developed in the industry, adjusted for expectations regarding the difficulty of the work to be performed at Humboldt.
The current cost DPR reflects additional experience with safely managing alpha contamination and the constrained working environment (in the case of projects performed on a time and material basis) as well as actual contract values and competitive bid pricing in lieu of budgetary estimates.
In particular, experience has shown that additional attention to safety and other work requirements has led to additional labor hours, beyond levels anticipated in removing plant systems and Humboldt specific costs (reflected in third party bids) higher than forecast.
3.1 BASIS
OF ESTIMATE PG&E formed an interdisciplinary and broad-based subject matter expert team to develop and vet fifteen technical specifications accompanied by ten administrative specifications.
The specifications developed by this technically focused group defined the requirements and criteria to complete the remainder of the decommissioning at HBPP Unit 3, including a plan for final site restoration.
The Specifications Development Team met every week for twelve months and a Long Term Strategy Team met every week for seven months developing the Level 1 Long Term Schedule and Exit Strategy.
The effort resulted in a document known as the Decommissioning Capstone Document.
Three bids were received from leading industry/reputable companies for all four discrete civil works projects.
One additional bid was received for canal remediation only. The four projects are: Intake and Discharge Canal Remediation; Nuclear Facilities Demolition and Excavations; Office Facility Demobilization; and Final Site Restoration.
PG&E identified potential issues associated with the reactor caisson. To better understand the alternatives to resolve radiological issues associated with the caisson, PG&E commissioned an engineering feasibility study. The study, known as the Kiewit HBPP Caisson Feasibility Study, evaluated methods, risks, schedules, and costs for removal of the caisson. After PG&E evaluated the technical issues associated with remediation and in-place abandonment versus removal, management determined that the only viable solution was complete excavation and removal of the caisson. In addition to the cost of civil works, PG&E will incur overhead costs associated with oversight of the civil works projects, safety monitoring, ongoing engineering work, and control of the site. Those costs are captured in the staffing plan. 3.2 REMAINING MAJOR DECOMMISSIONING COST DRIVERS The significant cost drivers for completing decommissioning of HBPP Unit 3 have been identified and analyzed, and implementation strategies developed.
They include: 3.2.1 Changes in Scope of Work. Changes in the scope of work which was previously assumed are as follows: Changes to Final-State Land Use. The 2009 Cost Study assumed that the land that the facility occupied would remain under the control of PG&E for an extended period of time and, Page 35 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 be used only for industrial purposes, and identified a specific value of radioactive material to be left at the site. After consultations with stakeholders and a re-evaluation of this assumption, PG&E decided to assume the lower values of residual radioactive material associated with greater public uses of the site.
- Reactor Vessel Caisson Removal Project. The 2009 Cost Study assumed that the reactor caisson would be decontaminated and structures greater than three feet below grade would be left in place. Testing resulted in the discovery of greater than forecast nuclear activation in the concrete bioshield walls surrounding the reactor vessel. After evaluating alternatives, PG&E determined that the only viable solution is to entirely remove the reactor vessel caisson. This new project is estimated to be approximately
$192 million. This project is discussed in Section 3.3.
- Intake and Discharge Canal Remediation.
The 2009 Cost Study assumed that the intake and discharge canals were to be back-filled with clean fill brought in from off-site, at an estimated cost of $3 million. The scope of this project has been significantly modified, and the additional cost to demolish the intake and discharge canal concrete structures, remove silt/sediment and excavate six inches into the walls and bottom of the canal is estimated at $47 million. This project is discussed in Section 3.5.
- ISFSI. Costs for spent fuel management have increased because four additional years are assumed to be required to store high level radioactive waste (spent nuclear fuel) on site until a federal repository or suitable facility is established by the DOE. This change in scope increases decommissioning cost estimates by roughly $20 million including contingency.
The additional cost is primarily related to the additional time that security personnel will be at the site. 3.2.2 Civil Works Projects.
In addition to changes in scope, the Civil Works Projects effort marks a transition from performance of decommissioning activities to competitively-bid, fixed cost completion of major remaining decommissioning activities.
The details are discussed in Section 3.4. 3.2.3 Updates to 2009 Cost Study Estimated Costs. After the full decommissioning effort for HBPP Unit 3 started, PG&E identified several cost items that were accruing costs at a faster rate than was predicted by the 2009 Cost Study. PG&E undertook several studies of the individual parameters to better quantify the costs. Most of the cost increase has been determined to be attributable to the encounter during the course of decommissioning of more unfavorable work conditions than anticipated, including higher levels of alpha contamination and a more physically constrained working environment.
- Labor -Remainder of Plant Systems Removal. Labor costs to remove plant systems have been higher than anticipated.
Most of this is attributable to enhanced emphasis on safety, on account of the higher than anticipated levels of alpha contamination, a more constrained than anticipated work environment, and associated work rules, that limit the time workers can Page 36 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 physically engage in their craft. For example, work preparation time including activities such as pre-job tailboards, and equipment and work site inspections were increased to avoid injury or exposures.
Break times were enhanced beyond expectations to ensure worker focus. These precautions increased safety margins against injuries and accidents for employees working in the field. The first three years of decommissioning from 2009 to 2011 had planned 122,000 craft hours (Le., hours engaged in the physical process of decommissioning), with a downward adjustment of 8% to reflect labor hours for these kinds of activities not engaged in physical processes.
The actual adjustment for these safety-related labor rules, however, was much greater. To ensure worker focus, safety tailboards and other pre-planning activities were strengthened and adequately conducted with the work force prior to, during and after the completion of each task. Non-production times including breaks were enhanced beyond expectations on account of radiological conditions and associated work requirements.
Break times and tailboards are required by regulations and labor agreements.
In addition, PG&E's safety program requires activities such as personnel stretching, work site inspections, and equipment pre-use inspections.
These precautions increase safety margins against injuries and accidents for employees working in the field. Personnel must leave the Radiologically Control Area (RCA) for breaks because no eating, drinking, or smoking is allowed in the .RCA. The process of leaving and re-entering the RCA takes at least 30 minutes, allowing time for logging into the area, radiological screening upon exit, and logging back into the area. Personnel working in Surface Contaminated Areas (SCA) require additional time to don and doff protective clothing for area entry and exit respectively.
Transit time through the RCA Access Point adds 30 minutes round trip for each break. PG&E's updated estimates of labor expenses for remaining work were developed based on actual experience to date, anticipated decommissioning methods, radiological conditions expected, safety requirements and other factors. Based on this information, crew sizes for each resource were estimated and applied to the duration of each major activity to calculate a total man-hour estimate.
These estimates together with anticipated billing rates, were used to estimate the labor cost to perform the remaining decommissioning work. PG&E has increased the 2009 estimate of $23 million by an additional
$32.8 million. Staffing is discussed further in section 3.7.
- Tools and Eguipment/RP Supplies.
HBPP Unit 3 has significant alpha radiological hazards which must be carefully handled. Experience to date has shown that the consumption rate for tools and equipment and radiation protection supplies is much higher than initially forecast.
Addressing high alpha radiological contamination involves the controlled cutting and disassembly of each system, which requires extensive scaffolding and man lifts to access the work locations.
To facilitate radiological safety, and enhance personnel safety scaffolding is erected multiple times in any given area. Various other tools and equipment, including one-of-a-kind specialty devices, are needed for rigging components out from their installed locations, and replacing permanently installed utilities with temporary utilities to perform the work. Once contaminated, tools and equipment often need to be disposed of as waste to protect workers, and to avoid the spread of contamination.
The 2009 estimate of Page 37 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 $9.3 million has been spent and an additional
$19.3 million is required to complete decommissioning.
Rev. 0 .. License Termination Survey. The 2009 Cost Study included $4 million for a final site survey. Using industry benchmarking, including the estimated costs for DCPP Unit 1 and Unit 2, PG&E now estimates that the cost of the survey, including professional staff, radiation protection technicians and per diem expenses will be $19 million, which is an increase of $15 million. .. Turbine Building Demolition.
The 2009 estimate for the turbine building decontamination and demolition was $4 million. After an evaluation of the two competitive bids received, a specialty contractor has been awarded $14 million to demolish the building, which is an increase of $10 million. .. Site Infrastructure and Plant Modifications.
Prior to beginning decommissioning of (HBPP Unit 3, the site was configured to safely monitor and store the hazards associated with operating and maintaining the plant. To prepare for and sustain the decommissioning effort, major new infrastructure and some site modifications were needed. Certain activities planned for in the 2009 Cost Study were completed, and others were determined to be not needed. The additional costs for Infrastructure for Facility Modifications were driven primarily by the unexpected costs associated with providing access to the site and providing work space for personnel once on site. The Radiological Protection (RP) facilities have required additional staffing and testing to control the extreme alpha contamination on site. The large number of samples needed to adequately assess the extent and concentration of alpha contamination combined with the requirement to achieve very low background radiation levels in the resulted in the decision to construct a new counting facility rather than attempting to salvage existing facilities.
Additional RP facilities included an enclosure
("RUBB Tent") for packaging radioactive materials for shipment and a new access control facility for personnel and material access and egress to and from the radiologically controlled areas of the facility.
The RUBB Tent was constructed to facilitate packaging in inclement weather and to control potential airborne releases during packaging.
The access control facility was expanded to more efficiently accommodate large numbers of workers during peak transit times to and from their work areas. The 2009 estimate of $8.6 million for facility upgrades to support full scale-decommissioning has been expended.
An additional
$8.2 million in infrastructure improvements and installations are needed to facilitate the shutdown of the liquid radwaste system, including an alternate liquid radwaste system, groundwater treatment system, waste packaging storage facility and to relocate certain facilities (office trailers).
.. Small Value Contracts.
The 2009 estimate did not take into account certain smaller value contracts, which are critical to the decommissioning work. Services include infrastructure support such as janitorial, water, garbage disposal, trailer rental, maintenance of office facilities, membership fees, California Coastal Commission fees, and office supplies.
The Page 38 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 current estimate of $10.8 million is based on the expected spend rate of existing contracts and meeting project milestones.
- Contingency. The current estimate includes $94.5 million in contingency, an increase of $40.5 million from the 2009 estimate.
The project has used $36 million of the 2009 contingency.
Contingency on the remaining scope of work ranges from 10 percent to 25 percent applied to various decommissioning activities.
3.3 REACTOR
VESSEL CAISSON REMOVAL The industry standard for planning and executing nuclear facility decommissionings is to decontaminate structures that are greater than three feet below grade and leave them in place. A previous cost studies for HBPP Unit 3 assumed that structures more than three feet below grade, with the exception of the spent fuel pool, would be left in place. PG&E had previously decided on complete removal of the spent fuel pool due to previously identified leakage and the contamination levels of the leaked water. A caisson is a water tight structure used as a foundation or to carry out work under water. Caissons have been used for centuries as building foundations and, occasionally, as structures housing activities such as garages and pump stations.
In the case of HBPP Unit 3, the caisson was a first of its kind to house a nuclear containment structure, pressure suppression chamber, bioshield wall surrounding a reactor vessel; and nuclear steam supply system below grade. The advantages of this approach included additional shielding provided by the soils and external pressure to assist with pressure suppression in the event of an accident.
The caisson was constructed by forming 13 foot sections above ground and then excavating and water jetting the ground from underneath the structure thus allowing it to "sink" into the earth. This technique allowed the work force to remain above ground. The construction of the caisson ultimately placed the lowest floor at approximately 66 feet below sea level, the bottom of the structure about 80 feet below grade, and most of the structure below the water table. PG&E first obtained access to the interior of the bioshield wall surrounding the reactor vessel in late 2011. When a portion of the caisson structure was sampled in the spring of 2012, quantities of neutron activation products significantly higher than forecast were discovered.
The newly discovered technical issues that have a significant impact on in-place disposal of the caisson include the additional quantities of neutron activation products within the caisson structure and uncertainty of survey methodologies to verify that residual radioactive contamination levels would meet the release criteria.
.. The activation product identified in the concrete bioshield wall is a long-lived radioisotope known as Carbon-14 (C-14). C-14 has a half-life of 5730 years, is considered biologically important, and was identified in portions of the concrete that were exposed to the neutron flux from the operating reactor. Remediating the C-14 would require removal of well over 21 inches from the supporting walls. PG&E has determined that removal of this quantity of material could result in an unstable structure leading to a significant safety risk to personnel performing the removal and final status surveys. Additionally, removal of only the activated concrete would cause schedule delays and additional disposal fees. Recommendations from the Electric Power Research Page 39 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Institute (EPRI) and several facilities that have encountered C-14 activated concrete are to remove and dispose of the entire structure.
- The interior walls within the caisson contain many small diameter electrical conduits and small bore piping. Verification of contamination levels within these smaller diameter tubes is problematic.
- In addition to the smaller tubing, larger contaminated embedded piping is also present within the caisson. Experience in the turbine building has been that the ability to clean the piping to clearance levels has been very difficult and resulted in large quantities of secondary waste for disposal.
- Cracks in the caisson walls, particularly adjacent to the spent fuel pool, contain radioactive contamination that must either be removed by "chasing cracks" or otherwise accounted for in dose modeling.
Other sites have found it most economical to simply remove those structures where contaminated cracks in the concrete affect the dose modeling.
- The radiological dose modeling required for a structure the size of the caisson containing uncertain levels of contamination due to both embedded contaminated piping and levels of neutron activation products presented an additional challenge.
- Removal of activated concrete, and contaminated conduit and small bore piping would result in an unstable structure that would pose a significant risk of collapse while workers are below grade removing those materials.
PG&E commissioned an engineering feasibility study to identify alternatives to resolve radiological issues associated with the caisson. The study evaluated methods, risks, schedules, and costs for removal of the caisson. After PG&E evaluated the technical issues associated with remediation and in-place abandonment versus removal, it determined that the only viable solution was complete excavation and removal of the caisson. PG&E also engaged the CAB in evaluating the options for the caisson. The CAB has expressed desires to have the site returned to that state to the extent that is reasonable, including removal of subgrade structures.
The technical, safety, regulatory and public perception challenges associated with leaving the caisson in place appear insurmountable.
The challenges posed by caisson removal include groundwater control, large volumes of soil requiring removal, and ground (stability) control around the work area. To adequately and safely control ground water intrusion, from the investigative work completed to date, it appears that a slurry wall to approximately one hundred and seventy (170) feet below grade to the Unit F clay layer will be required.
The slurry wall will be used for the removal of both the concrete caisson and the spent fuel pool. The cost to the decommissioning project of removing the caisson is significantly more than the original cost estimate for decontamination and place disposal.
The cost increases are comprised of the costs to construct ground water controls, increased material packaged and sent for disposal, and the additional schedule time to complete the removal. The feasibility study identified the following cost contributors:
Page 40 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 I Total I $191-6 M Field Work $78.0 M* Packaging/Material
$12.9 M Handling Project Staffing $22.1 M Waste Disposal $24.0 M License Termination
$6.2 M Survey Tools and Supplies $2.3 M Other $4.2 M Contingency
$41.8M Rev. 0 Additionally, the feasibility study estimated that removal of the caisson will add two and one half years to the schedule.
The benefits of removing the caisson include enhanced personnel safety during the project, mitigation of the concerns pertaining to surveying in situ materials, removal of the entire source term, elimination of the risk associated with legal or regulatory challenges, and resolution of the concerns of the CAB. 3.4 CIVIL WORKS PROJECTS After a successful asbestos abatement and demolition of the above grade demolition of the fossil units 1 and 2 (adjoining the nuclear unit 3) seven months ahead of schedule and without injury, PG&E made a significant effort to develop similar bid specifications that were thorough and complete with clear definition of scope and strong emphasis on safety and environmental compliance for nuclear unit 3. As discussed above in Section 2,3, PG&E is now transitioning to a Civil Works Projects Phase, PG&E's bid specifications include all HBPP Unit 3 safety and environmental expectations and specific requirements so bidders clearly understand the culture that is paramount to successfully performing work at the HBPP Site. PG&E expects that all work is performed with. safety at the forefront and built into every aspect of work execution, and that all work is accomplished in a manner that will protect the environment and assure the local community that the HBPP Site will be left in a condition that at least meets, if not exceeds all requirements.
3.4.1 Nuclear
Facilities Demolition and Excavations:
The scope of work includes decommissioning and demolition of all remaining permanent plant structures and facilities identified for demolition.
Additionally, this scope of work includes installation of a slurry bentonite wall to the Unit F clay layer that will encompass the Reactor Building Caisson, Turbine Building foundation, and other deep structures in the Unit Page 41 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 3 area to provide groundwater control and isolation.
Note that this scope of work will potentially include removal of the Reactor Caisson and Foundation Piles. The Nuclear Facilities Demolition and Excavations, including the removal of the Spent Fuel Pool, is a significant and diverse scope of work representing the principal contract of HBPP Unit 3 Decommissioning.
3.4.2 Office
Facility Demobilization The scope of work includes removal and/or demolition of office facilities, including buildings and structures owned and leased by PG&E. Most of buildings and structures to be removed are modular or trailer type construction.
Leased trailers and structures are to be isolated, disconnected, removed from HBPP Unit 3, and returned to the owner. Buildings and structures owned by PG&E are to be isolated, disconnected, demolished, and disposed as waste, unless released for salvage or recycle. This scope of work includes an estimated
-32 building units comprising approximately 40,000 square feet. 3.4.3 Final Site Restoration The scope of work includes development of site grading and drainage, placement of ground cover including vegetation and other surfacing, road construction and repairs, installation of fencing and site lighting, and other final site development work to achieve the required end state condition for PG&E's future industrial use. It includes demolition of remaining miscellaneous structures to support final site restoration plans. The parcel containing the restoration area is approximately 102 acres. Main features of this scope of work include removal of buried asbestos containing materials; demolition of reinforced concrete settling basins, truck ramp, and associated piping; soil excavation, backfilling, and compaction; wetlands construction; finish grading; storm drain system installation; topsoil placement; vegetation establishment; installation of erosion control features; ground cover installation; final surfacing; and removal of portal monitors and truck scales. 3.4.4 Known Challenges The HBPP Unit 3 nuclear decommissioning project has unique challenges due to its specific design features, highly congested facilities and underground systems/utilities, contamination issues, limited access, high water table, etc. Furthermore, multiple operations conducted by separate entities (PG&E, various contractors, etc.) are and will continue to occur simultaneously throughout the course of the decommissioning, requiring close coordination, communication, and interface between the parties. Known challenges at HBPP Unit 3 that support an understanding of the significant increase in the value to perform the work at HBPP Unit 3 from the competitive bids and as shown in the above graph are:
- Weather: Eureka receives about 75 percent of its average annual rainfall during the rainy season, generally October through April, with greatest monthly totals in December and January. Eureka's average annual rainfall over the 11 O-year period is 38.87 inches. The area available for staging empty and filled intermodals and the ability for PG&E to ship intermodals during the rainy season may affect the rate at which the structures can be demolished.
Page 42 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0
- Site Coordination and Congestion:
The site footprint is extremely small and constricted.
Coordination among all parties performing work onsite is critical for success. Very little space is available onsite for laydown areas, soil stockpiling, demolition debris, and equipment operation, including demolition machines and truck traffic. Significant delays or inefficiencies may be unavoidable due to interference and coordination with other site activities.
The constricted space may limit the pace of demolition and excavation.
Personnel access to the below grade areas of the reactor caisson (suppression cells, drywell, access shaft, etc.), is restricted (confined space and radiation area) and requires detailed planning to ensure optimal time on tools. Additionally, the number of personnel working below EI. -14 in the RFB must be minimized due to space restrictions and limited egress / ingress.
- Below Grade Obstructions:
Underground utilities and other underground commodities that have not been appropriately documented may be encountered during installation of a support of excavation system or during open-cut excavation.
Original plant design drawings of underground utilities and commodities may not match the installed configurations in the field. Systems may have been added or altered without corresponding as-built documentation.
Obstructions are anticipated and contingency plans are needed for unexpected obstructions in the excavations.
Previously unidentified areas of radiological or non-radiological contamination associated with unidentified underground commodities may also be encountered during excavations.
This may require additional measures, including soil sampling and segregation of soil stockpiles, to be applied to appropriately manage potentially contaminated soil that was unexpected.
Increased coordination with PG&E will be required in responding to such discoveries.
- Deep Excavations:
Excavations deeper than (+) 8-foot elevation (approximately four feet below grade) will require water control. Numerous excavations will be deeper than four feet and will require the need to collect and pump the water into holding tanks. Due to the depth of these excavations, shoring may be required for water intrusion and for stabilization of trenches.
Excavation spoils have to be sampled for hazardous constituents before disposition for reuse or offsite disposal.
Spoils are required to be stockpiled until sample results are received, generally a 14-day turnaround.
Soil piles are required to be maintained and managed to prevent water runoff and potential contamination.
Due to the small footprint of the Site, there is limited space for stockpiling soils. Soil stockpiles may accumulate faster than PG&E can package and ship the soil offsite. Page 43 of 120 Decommissioning Project Report for Humboldt Bay P ower P lant Unit 3 3.4.5 B I D RES U LTS Soil Remediation" Building Demo, and Site Restoration CPuc NDCTP Filing: 2012 VS. 2009 1 80,000 , 000 -g i. 1 00,000,000
.5 ! fa ' 140,000,000 llO,ooo,O(lO 60 , 000,000 40,000.000 10,000,000 [toIt<<>ln,d
'll f os s il Uni ts 1 & 2 Abov e G rO!Jnd Demo InduWialW o ,K., .
"\fam $lI mi!1iQn W a$te Disp o sa l Cost t o Perfor n F i eld Work .---... ---.... -...... --....... ............ : . l ._ _ .... _. : S i d , r eceiVed ... -_ ......... :--_ ... -... -_ ... _-: ... ,. ..........
-_ ...... -: : ' : , l.. I : R.s i dentfal Fllr",., :
- s : S ot n a.r i c ! , A.' : : V : , , ' .... t :: : : x 1 : ; : : \ ! Cl v ll V o I.Ume! and D l$posal E$tlmate Rev. 0 A key input that is being used for the current cost estimate include the three competitive bids received to perform the remainder of the Civil Works projects at HBPP. Adjustments were made where there existed overlap between the feasibility study to remove the caisson and bids and overlaps the NDCTP and Fossil Decommissioning.
Adjustments/Reductions:
The Work Breakdown Structure (WBS) in the feasibility study delineates four key breakdown areas amounting to a cost estimate of $83M. Within this scope and cost estimate are areas that overlap with the Civil Works bids. The Kiewit feasibility study includes a cost of $17.8M for installation of the slurry wall. This cost is also provided in the Civil Works bids and it will have to be reduced from Nuclear Facilities Demolition and Excavations cost work breakdown structure which includes installation of a slurry wall. Also, the removal of the refueling building slab from +12 EI. to +9 EI., the concrete spent fuel pool/soils are part of the two inputs. From the caisson feasibility study the unit rates are: concrete removal $1,773 per cu. yd.; soil $265 per cu. yd.; and structure backfill $192 per cu, yd , The RFB concrete slab is 306 cu, yd. and concrete SFP is 471 cu. yd. Accounting for dewatering costs, concrete and soil removal and backfill costs apply a $4M reduction.
Therefore, a reduction of $21.8M or $22M is applied to the civil works bids because of these overlaps.
The caisson feasibility scope of work includes:
demolition of Units 1 and 2 foundation slabs and pile caps; removal of foundation piles; and backfilling voids generated from the demolition and pile removal. The feasibility for this scope of work includes:
Project Management; Office/Staff Expenses; Page 44 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Operational
& Compliance Support; Design and Engineering; Temporary Work; Unit 1 and 2 demolition, excavation and backfill.
The total cost for this effort is estimated at $5M. Rev. 0 Therefore, a reduction of $5M is applied to the caisson feasibility study because this subgrade demolition and removal of the piles is part of the Fossil Decommissioning.
Three bids were received from leading industry/reputable companies for all four discrete civil works projects.
The four projects are: Intake and Discharge Canal Remediation; Nuclear Facilities Demolition and Excavations; Office Facility Demobilization; and Final Site Restoration.
A fourth bid was received from another well qualified company, but it only applied to performing the remediation of the intake and discharge canals. Pricing was received for each discrete project. Inputs from Sourcing, Finance and Decommissioning Project Manager were sought to develop a composite pricing from the bids received to estimate the contract value for the CPUC filing. 3.5 Intake and Discharge Canal Remediation The 2009 Cost Study assumed that minimal amount of soil and no sediment was to be removed from the intake canal to meet the land use release criteria associated with the Industr O ial Use Scenario.
However, to meet the more stringent release that PG&E is now assuming, impacted soils and sediment will need to be removed. The Discharge Canal was likely impacted from historical discharges from various pipes; most notably the Abandoned Radwaste Discharge Line via Unit 3 Discharge Tube and the Radwaste Discharge Line. The area and depth of impacted soil for this case was based on analytical data collected in 1998. Most of the data indicates that the bottom of the Discharge Canal was impacted above background.
The greatest impact was a sample point at 42 pCi/g of Cs-137 at a depth interval of 1 to 2 ft. The sample collected from 2-3 ft. sample interval showed impacts above background at this depth. In the 2009 Cost Study, an estimated area of 233 ff and 3 feet in depth was estimated to be excavated from the discharge canal and with an assumed bulking factor of 1.35 resulted in a volume of 945 fe. HBPP Intake Canal HBPP Discharge Canal Page 45 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 In order to fully evaluate the needs for remediating the intake and discharge canals and associated structures, HBPP Unit 3 management evaluated the final status survey methods and rigor, desires of the local community, and the experiences at other decommissionings.
A postulated risk of identifying additional remediation needs at the end of the decommissioning long after completion of the canal remediation project was identified.
Three approaches to address the risk are to:
- Begin the remediation early with the established radiological limits;
- Perform the remediation at the end of the decommissioning; or
- Remediate to the lower radiological limits (0.5 pCi/g). The risk associated with starting early with the established radiological limits are that additional remediation needs will be identified at the end of the decommissioning during the final status survey process. Additional remediation will require the duplicate costs of establishing ground water controls, permitting, excavation, disposal, additional fill material, and re-performance of the final status surveys. The risk associated with performing the remediation at the end of the decommissioning is the potential for overwhelming the transportation processes.
The managing the volume of soil that would be transported during the same time frame the final soils removal for the site and the caisson would become impractical and may pose an unacceptable burden on the local roads and other infrastructure.
The risk associated with early remediation to lower radiological limits is the cost of disposal for the larger volume of material removed. When the pros and cons of each approach were compared, PG&E decided that the financial risks associated with remediating early to the lower radiological limit were the prudent course of action. The 2012 cost estimate assumes dose limits commensurate with EPA limits and ALARA (As Low As Reasonably Achievable).
This conservative approach requires that 24,000 ft3 of soil be removed from the Intake Canal, and 120,000 ft3 of soil be removed from the Discharge Canal. Over the past year, the Discharge Canal has filled with accumulated silt depositing a volume of 20,000 fe which must be removed. The material contains biological material and is not suitable as site backfill due to the non-compatibility of the silt material.
PG&E prepared civil works bid specifications in June 2012. The scope of work to remediate the Intake and Discharge Canals included:
mechanical removal of radiologically and chemically contaminated sediment; demolition of the discharge outfall and levee to Humboldt Bay; demolition of the intake and discharge structures; restoration of levee and coastal trail along the Bay; management of and dewatering of contaminated sediments, and water treatment to meet discharge permit requirements.
Four bids were received in September of 2012. The estimates to perform this work are proprietary information as bids are being technically evaluated, however, they are of a substantial cost. The recommendation is to follow the conservative approach because there may be a potential to incur these significant costs if final site surveys at the end of the project require additional remediation.
Page 46 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Delaying the project to the end of the project is not practical.
Permitting for the remediation of the canals is expected to be in-place early 2014 and the estimated 1,000 shipments of intermodals to remove the sediment from the canal should start in 2014. ;100.000 ! I l5II.ooo l t ! f 1 1SO,ooo! 1 XXl,OOci! !
1 !
1 I I ptf)eif '''''
... 9IHlOO I\' Canal Remediation 47,408 Removal 21,000 Disposal 20,224 Canal Contingency
.6,184 Intake-and Discha r ge Canal Remediation CPU.C-NDCTP Filin, ,, 2011 vs. roto! lit",", Cem'" S l Mf lOO9).!ld $lM(lOOS l CO" t o P. ."" flfld Wor!< *....................... *. ..... : . _. 6>d *** <., .... d tr.n.:an,f r'" ..... --_._ ..... -..... --.... -i ":14.000 11' !r,Q>,Jo,t n.u W or bot: ! . ..... _"'"' ..
.. rV.,MWfIf.b.1c.tf'
-wd t
, ,,wo.ron-,,,,,,,,,,,,,,, $8 tM!Jc.n u_ tOO?t F<< lM!ltl'lJ( Intake and DIscharge Canal sediment Volum es and Disposal Estimates Remed i atio n Est.lmates
'Cos t t o perfOflTf WO<k In 2 0 11 1ndud .. c...,.;r.lOn of tM m t.o .nd e.lim a , td d i$P O Jai CQ$\ <If $0.$ miII'.n .pplicd. . SI O \ $5 0<<"" S I7 H II_I $1.971 k hdca i f na $4'lk Tr&M1'Oft S l6l)t DI1po Ja l SUb k $l.mIt Tot<t l $8,101k Page 47 of 120
3.6 STAFFING
PLAN Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Successful management of the cost of the decommissioning is contingent on control of Lqbor costs. To that end, the first priority is to manage the headcount for the entire duration of the decommissioning.
PG&E developed a staffing plan specific to the headcount for each period that runs to the end of 2019. The HBPP Unit 3 staffing plan is connected to the working schedule to ensure that the necessary staff will be available to complete the decommissioning in a safe, cost effective, and timely manner. PG&E assessed the staffing needs based on the work and project plans, complexity of the work, hazards associated with the work (alpha contamination in particular), potential conflicts with other projects on site, and the schedule to complete the work. PG&E sought the help of highly experienced staff and consultants to assist in developing detailed plans and schedules.
Four major companies supplied personnel with previous experience in decommissioning at 24 sites throughout the United States, who were also able to draw upon many years of personal experience when drafting their work plans and technical work papers. PG&E was thus able to benefit from the collective lessons learned at other commercial nuclear and Department of Energy/Department of Defense facilities that have undergone decommissioning.
The table below summarizes the experience base used to provide planning, briefing, and field walk-downs:
Assignment Number Sites Worked assigned PG&E Fulltime 1 CYAPC La Crosse Employee Brookhaven National Lab MYAPC Staffing Augment 9 BRP NASA Plumbrook DOE Fuel Processing Rocky Flats Planning & 14 Ft Calhoun Rancho Seco Special Projects Ft Greely Saxton Site 7 Hanford SONGS Decommissioning Honeywell Fuel Processing Trojan INEL UW Test Reactor Debriefs JACADS TOCDF Westinghouse Test Reactor K25 Oakridge YAEC KAPL Zion Attachment B, Subject Matter Experts, contains a detailed list of the positions and companies that supplied SMEs. The Plant Director and the Department Managers responsible for the various aspects of the decommissioning met off-site several times in 2012 to develop and refine the staffing plan. The staffing plan includes ramp-up, ramp-down, durations, funding sources, and number of staff needed to complete each function associated with the decommissioning.
The staffing plan starts in 2012 and continues through the caisson removal project, restoration and administrative close-out in about 2019. Page 48 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 Rev. 0 Scheduled work drives the need for personnel.
As the work load increases, the staffing to successfully complete project planning as well as the implementation of the plans increases.
As the work is completed, the need for staffing begins l to decrease as well. The prediction of staffing needs, staffing increases, and staff lay-o ffs is referred to as staffing ramp-up/ramp-down or simply as that "Staffing Plan" herein. 35,000 30,000 -\I) "tJ 25,000 c ctl \I) :::J 0 20,000 .c .... g 15,000 .... c :::J 0 10,000 E <C 5,000 Staffing CPUC NDCTP Filin s: 2012 vs 2009 Removal 1 2016-June 2018 & y Year -2009CPUC -2012CPUC PG&E has scheduled the remainder of the decommissioning of the HBPP site over a period of approximately eight years finishing in 2019. Schedule duration is sufficient for the decommissioning activities including the caisson removal project that spans 2 % years. The ISFSI will continue in operation until the DOE takes custody of the fuel and GTCC waste, expected to commence at the end of 2024. These ISFSI costs are discussed in a separate work break down structure
-Spent Fuel Management, and they are not included in the staffing plan. The staffing plan for this cost estimate update starts in January 2012 and ends in 2019. The staffing ramp-downs in 2013 as the decommissioning complete removal of plant systems and transitions to civil works projects.
The staffing plan continues to ramp down during the caisson removal project starting 2016 and into the latter part of 2018 during final site restoration.
During close-out of the project in 2019, the staffing plan is at a minimum headcount as it submits its license termination request, completes its invoicing and closes out its records. In order to better track and quantify costs for staffing, a work breakdown structure was developed.
The "Staffing Plan" work breakdown structure consists of the following departments:
- Site Management
- Decommissioning including Finance and Sourcing Page 49 of 120 Decommissioning Project Report for Humboldt Bay Power Plant Unit 3 48 Projects 48 Engineering, Safety and Administration and Engineering Contracts 48 Radiation Protection 48 Radiological Materials Control and Count Room 48 Environmental and Environmental Contracts including Permitting 48 Site Services 48 Final Status Survey Rev. 0 The staffing plan includes fixed overhead which are those costs incurred for maintaining staff that is assigned to management, safety, facility maintenance, licensing support, and procurement and finance. Fixed overhead are job functions that are needed regardless of the status and progress of the decommissioning.
Because the job functions are independent of the scheduled demolition of the plant, the functions and associated positions are considered as fixed overhead.
It also includes direct and discrete labor that are staffing costs for personnel who are directly supporting schedule progress such as engineered plans, development of work packages, and permits. 3.6.1 Site Management:
The Site Management structure is depicted in Attachment C. 3.6.2 Decommissioning:
The Decommissioning organization is responsible for oversight, identification, and controlling the execution of project transition and work. The Support Services group performs cost and budget control, procurement, and warehousemen functions.
The Decommissioning organization structure is depicted in Attachment D. 3.6.3 Projects:
The Projects organization is responsible for implementing self-performed projects and oversight of civil works projects.
The Projects organization structure is depicted in Attachment E. 3.6.4 3.6.4 Engineering:
The Engineering organization structure is depicted in Attachment F, and it includes a broader base of functions such as engineering, work control, safety, plant operations and plant administration.
The engineering functional area is responsible for: developing, reviewing, and approving drawings, calculations, work packages, and other documents; evaluating non-conformances of licensed components for engineering implications; assisting with development of work flow plans; revising Engineering procedures and programs; field engineering; and developing rigging and heavy lift plans. The work control group prepares work packages, cost and time estimates, drafts clearance orders, and revises procedures during the planning phase. Page 50 of 120