ML19311C710
| ML19311C710 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/23/2014 |
| From: | Public Watchdogs |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| Cruz Z | |
| Shared Package | |
| ML19311C699 | List:
|
| References | |
| Download: ML19311C710 (56) | |
Text
Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1084 Page 2 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1085 Page 3 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1086 Page 4 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1087 Page 5 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1088 Page 6 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1089 Page 7 of 8 Case 3:19-cv-01635-JM-MSB Document 1-35 Filed 08/29/19 PageID.1090 Page 8 of 8
August 17, 2018 MEMORANDUM TO: Eric J. Simpson, CHP, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety W. Chris Smith, Reactor Inspector Engineering Branch 1 Division of Reactor Safety Marlone X. Davis, Transportation & Storage Safety Inspector Inspections & Operations Branch Division of Spent Fuel Management THROUGH: Janine F. Katanic, PhD, CHP, Chief /RA/ LLH for Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety FROM: Troy W. Pruett, Director /RA/
Division of Nuclear Materials Safety
SUBJECT:
INSPECTION CHARTER TO EVALUATE THE NEAR-MISS LOAD DROP EVENT AT SAN ONOFRE NUCLEAR GENERATING STATION A special inspection has been chartered to review the licensees follow-up investigation, causal evaluation, and planned corrective actions regarding the near-miss drop event involving a loaded spent fuel storage canister at the San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) on Friday, August 3, 2018.
(License Nos. NPF-10 and NPF-15, Docket Nos. 50-361, 50-362 and 72-41).
CONTACT: Janine F. Katanic, PhD, CHP, FCDB/DNMS (817) 200-1151
E. Simpson 2 BACKGROUND AND BASIS On Friday, August 3, 2018, at approximately 1:30 pm (PST), SONGS was engaged in operations involving movement of a loaded spent fuel storage canister into its underground ISFSI storage vault (HI-STORM UMAX storage system). As the loaded spent fuel canister was being lowered into the storage vault using lifting and rigging equipment, the licensees personnel failed to notice that the canister was misaligned and was not being properly lowered. The licensee continued to lower the rigging and lifting equipment until it believed that the canister had been fully lowered to the bottom of the storage vault. However, a radiation protection technician identified elevated radiation readings that were not consistent with a fully lowered canister. The licensee then identified that the loaded spent fuel canister was hung up on a metal flange near the top of the storage vault, preventing it from being lowered, and that the rigging and lifting equipment was slack and no longer bearing the load of the canister.
In this circumstance, with the important to safety (ITS) rigging and lifting equipment completely down in the lowest position, the ITS equipment was disabled from performing its designed safety function of holding and controlling the loaded canister from a potential canister drop condition. The licensee reported that the canister was resting on a metal flange within the storage vault. It was estimated that the canister could have experienced an approximately 17-18 foot drop into the storage vault if the canister had slipped off the metal flange or if the metal flange failed. This load drop accident is not a condition analyzed in the dry fuel storage systems Final Safety Analysis Report (FSAR).
In response to the discovery that the canister was not fully lowered, the licensee took immediate actions to restore control of the load to the rigging and lifting devices. The estimated time the canister was in an unanalyzed credible drop condition was approximately 45 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in duration. The licensee regained control of the load, repositioned the canister, and lowered the canister into the storage vault. The licensee halted all dry fuel storage movement operations in order to fully investigate the incident and develop corrective actions to prevent a recurrence. In addition, the licensee has shared the operational experience with another site with a similar dry fuel storage system.
Region IV became aware of the SONGS near-miss incident on Monday, August 6, 2018, when the licensee provided a courtesy notification and described it as a near-miss or near-hit event. The reporting requirements of the incident are still being evaluated by the Region and discussed with the licensee.
On August 7 and 16, 2018, Region IV and NMSS representatives participated in conference calls with licensee representatives in order to gather additional facts regarding the circumstances of the incident and the licensees investigation. Region IV is evaluating the information provided by the licensee and is coordinating with the Division of Spent Fuel Management, NMSS.
The NRC is chartering this special inspection pursuant to Management Directive 8.3, NRC Incident Investigation Program, and NRC Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors.
The purpose of the inspection is to investigate the occurrence; interview personnel; observe equipment; and review relevant documentation, including the results of the licensees investigation and causal analysis, and development and implementation of actions to prevent
E. Simpson 3 recurrence. The licensee has committed to not resume fuel loading operations until after this special inspection and associated reviews are complete. Once the licensee has confirmed its plans to resume fuel loading operations, inspectors will also observe the loading operations to ensure that the corrective actions are adequate. These observations may be conducted as part of this special inspection or as an independent inspection activity, as directed by regional management.
SCOPE The inspection should seek to address the following items at a minimum:
- 1. Identify and review all pertinent records, documents, and procedures related to the licensees downloading operations at the ISFSI pad including but not limited to: worker training and qualifications; rigging equipment qualification, testing, and preventative maintenance; and lifting equipment qualification, testing, and preventative maintenance.
Evaluate the adequacy of the above noted procedures, worker training and equipment testing and preparation.
- 2. Evaluate the adequacy of the loading procedure(s) with respect to verification of MPC movement, centering the MPC over the ISFSI vault, lowering the MPC, and positioning the MPC within the ISFSI vault. Interviews with personnel involved in the ISFSI loading operations should be conducted to evaluate licensee and contractor communications between crane/VCT operators, rigging and spotting staff, cask loading supervisors, radiation protection staff, and licensee oversight personnel. Evaluate the adequacy of pre-job briefings that may have taken place prior to fuel loading operations.
- 3. Review and evaluate the licensees immediate corrective actions taken after the event for adequacy of notifications to the licensee and safety assessments performed immediately following the event. Review the licensees inspection documentation and/or analysis to determine whether the vaults divider shell experienced any damage that would inhibit the component from performing its designed safety function.
- 4. Based on the review of procedures and interviews of personnel involved with loading operations, evaluate the adequacy of procedure adherence.
- 5. Interview personnel associated with the event to develop a timeline to ensure the licensees investigation contained all necessary information to identify all contributing factors and develop adequate corrective actions.
- 6. Review the licensees root cause investigation results, to determine whether the review thoroughly identified all contributing factors and that final corrective actions will be adequate to prevent reoccurrence. Evaluate whether prior operational experience relating to complications or issues associated with canister downloading operations was identified and considered as part of the licensees root cause investigation and corrective action development.
- 7. Review the licensees planned actions that will address the point loading condition that was experienced by the affected canister. If applicable, review the licensees analysis that demonstrated the canister will continue to perform as designed for continued storage OR review licensees inspection plan to safely remove or lift the canister from the vault to support inspection of the bottom of the canister to demonstrate the canister did not
E. Simpson 4 receive any damage that would inhibit the component from continuing to perform as designed.
- 8. Investigate the licensees procedures for reportability to the NRC and determine if the licensee made the correct decision regarding notifications made to the NRC for this event.
- 9. As directed by regional management, observe resumption of fuel loading operations to verify that corrective actions were effective in addressing deficiencies that contributed to the event. This should include evaluation of procedure and/or equipment enhancements; review or observation of training and briefings provided to riggers, crane operators, spotters and observers, supervisors and other personnel involved in fuel loading operations.
- 10. Determine if the inspection should be elevated to an AIT and promptly notify regional management of any recommendation to escalate the special inspection to an AIT.
GUIDANCE The NRC is chartering this special inspection pursuant to Management Directive 8.3, NRC Incident Investigation Program, and NRC Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors. The Manual Chapter and Management Directive identify Inspection Procedure 93812, Special Inspection, for specific use in reviewing events. Planned Dates of Inspection are September 10-14, 2018.
This inspection should emphasize fact-finding in its review of the circumstances surrounding the near-miss canister drop event. Safety concerns identified that are not directly related to near-miss drop event should be reported to NRC management for appropriate action.
Daily briefings with NRC management should occur to discuss the teams progress and preliminary observations.
In accordance with Manual Chapter 0610, a report documenting the results of the inspection should be issued within 30-45 days of the completion of the inspection.
This Charter may be modified should NRC inspectors find significant new information that warrants review. Should you have any questions concerning this charter, please contact Janine F. Katanic at 817-200-1151.
INSPECTION CHARTER TO EVALUATE THE NEAR-MISS LOAD DROP EVENT AT SAN ONOFRE NUCLEAR GENERATING STATION - DATED AUGUST 17, 2018 DISTRIBUTION:
KKennedy, ORA SMorris, ORA TPruett, DNMS LHowell, DNMS JKatanic, DNMS LBrookhart, DNMS MLayton, NMSS ARivera-Varona, NMSS VDricks, ORA BMaier, ORA CLipa, DNMS/RIII JTrapp, DNMS/RI TInverso, OEDO AMoreno, OCA JWeil, OCA ADAMS ACCESSION NUMBER: ML18229A203 SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: LLH Yes No Publicly Available Sensitive NRC-002 OFFICE DNMS:FCDB DNMS:DD DNMS:D NAME JFKatanic LLHowell TWPruett SIGNATURE /RA/ LLH for /RA/ /RA/
DATE 8/17/18 8/17/18 8/17/18 OFFICAL RECORD COPY
Case 3:19-cv-01635-JM-MSB Document 1-30 Filed 08/29/19 PageID.893 Page 2 of 5 1 SAN ONOFRE DECOMMISSIONING 2 COMMUNITY ENGAGEMENT PANEL MEETING 3 STATE OF CALIFORNIA, COUNTY OF ORANGE 4
5 6
7 8
9 10 11 12 TRANSCRIPT OF VIDEOTAPED PROCEEDINGS 13 LAGUNA HILLS, CALIFORNIA 14 THURSDAY, MARCH 22ND, 2018 15 16 17 18 19 20 21 22 Reported by:
Katherine Magner 23 CSR No. 14083 Job No. 2846039 24 25 Page 1 Veritext Legal Solutions 866 299-5127
Case 3:19-cv-01635-JM-MSB Document 1-30 Filed 08/29/19 PageID.894 Page 3 of 5 1 COMMUNITY ENGAGEMENT PANEL MEMBERS:
2 DR. DAVID G. VICTOR CEP CHAIRMAN 3
JERRY KERN 4 CEP SECRETARY 5 DAN STETSON VICE CHAIRMAN 6
BILL HORN 7 SAN DIEGO COUNTY SUPERVISOR (Not Present) 8 9 TOM CAUGHLAN CAMP PENDLETON 10 MARNI MAGDA 11 SIERRA CLUB, ANGELES CHAPTER 12 TED QUINN AMERICAN NUCLEAR SOCIETY 13 STEVE SWARTZ 14 CITY OF SAN CLEMENTE 15 GARRY BROWN ORANGE COUNTY COASTKEEPER 16 MARTHA MCNICHOLAS 17 CAPISTRANO UNIFIED SCHOOL DISTRICT 18 CAPTAIN MEL VERNON SAN LUIS REY BAND OF MISSION INDIANS 19 SERGIO FARIAS 20 MAYOR, SAN JUAN CAPISTRANO 21 DONNA BOSTON ORANGE COUNTY SHERIFF'S DEPARTMENT 22 TOM PALMISANO 23 VICE PRESIDENT, DECOMMISSION CHIEF NUCLEAR OFFICER AT SONGS 24 RICH HAYDEN 25 CALIFORNIA STATE PARKS Page 3 Veritext Legal Solutions 866 299-5127
Case 3:19-cv-01635-JM-MSB Document 1-30 Filed 08/29/19 PageID.895 Page 4 of 5 1 them you need to tell me how you're going to remediate 2 this, and they came back and said we want to go back to 3 the older design.
4 CHAIRMAN DR. VICTOR: People are going to want 5 to know about these four canisters. Why not take eight 19:05:32 6 or ten days and move them back into the pool, and unload 7 them and reload them? Help us understand. I know, it's 8 early days.
9 MR. PALMISANO: Sure.
10 CHAIRMAN DR. VICTOR: Help us understand what 19:05:45 11 the logic process is going to be there.
12 MR. PALMISANO: Yeah. And let me just --
13 because I faced this issue back in the mid '90s at the 14 Palisades Nuclear Plant with a loaded canister that had a 15 potential weld defect and got into this very discussion. 19:05:58 16 So nobody has unloaded a commercial canister, 17 either a bolted cask or a welded cask or canister. Okay.
18 It is possible. What you would do is basically have a 19 mechanism, either to do it in a fuel pool or do it in a 20 dry transfer facility. It's possible either way. 19:06:15 21 You would take the canister back in. And the 22 first thing you would do is reconnect the valves and find 23 a way to purge the helium and refill its hole with water.
24 Okay.
25 The biggest technical issue that we've looked at 19:06:29 Page 85 Veritext Legal Solutions 866 299-5127
Case 3:19-cv-01635-JM-MSB Document 1-30 Filed 08/29/19 PageID.896 Page 5 of 5 1 in the industry over the many years -- not just related 2 to SONGS -- is the thermal transient to actually 3 reintroduce water into a -- let's say a canister with hot 4 fuel, 200-300 degrees C. And the thermal transient that 5 you put the fuel through. Okay. 19:06:44 6 So once you get it reflooded, cooled down, you 7 would then put that similar machine on, grind out the 8 weld, take the lid off. That's just the mechanics.
9 That's certainly doable.
10 The real challenge as we would understand it 19:06:54 11 today, and nobody has had to do it yet, is the reflood.
12 Certainly, technically possible. What I would tell you 13 is just I was back in Washington with the NRC last week, 14 if you were just to brainstorm, this would probably be a 15 two- to three-year project to develop the techniques, 19:07:09 16 pile up the techniques. The NRC would want to have 17 explicit approval on this because of the radiological 18 hazards.
19 CHAIRMAN DR. VICTOR: To the workers?
20 MR. PALMISANO: Well, to the workers, yeah. 19:07:20 21 So when you think about this, you have a 22 canister that has intact fuel rods inside of a sealed 23 canister. This pin problem doesn't affect the canister 24 itself. Okay. So you've got that condition.
25 You've got to weigh that condition -- if this 19:07:34 Page 86 Veritext Legal Solutions 866 299-5127
Application No.: 18-03-XXX Exhibit No.: SCE-03 Witnesses: Jose L. Perez Nicholas Capik (U 338-E)
Testimony On The 2017 Decommissioning Cost Estimate for SONGS 2&3 PUBLIC VERSION Before the Public Utilities Commission of the State of California Rosemead, California March 15, 2018
SCE-03: Testimony On The 2017 Decommissioning Cost Estimate for SONGS 2&3 Table Of Contents Section Page Witness I. INTRODUCTION .............................................................................................1 J. Perez II.
SUMMARY
OF 2017 SONGS 2&3 DECOMMISSIONING COST ESTIMATE.............................................................................................2 A. Methodology and Description................................................................2 B. 2017 DCE Assumptions.........................................................................4 C. Contingency ...........................................................................................5 III. INDEPENDENT REVIEW OF 2017 SONGS 2&3 DCE .................................9 N. Capik A. Introduction ............................................................................................9 B. ABZ Background And Experience ........................................................9 C. ABZ Independent Review....................................................................10
- 1. Scope ........................................................................................10
- 2. Review Process ........................................................................10 D. ABZ Findings.......................................................................................11
- 1. Key Facts And Assumptions....................................................11
- 2. Scope ........................................................................................11
- 3. Schedule ...................................................................................11
- 4. Risk Mitigation ........................................................................12 E. Conclusion ...........................................................................................12 IV. RECONCILIATION OF THE 2017 DCE TO THE 2014 DCE ......................13 J. Perez A. Overview ..............................................................................................13 B. Distributed Projects..............................................................................14
- 1. ISFSI & Fuel Transfer Operations ...........................................14
- 2. Final Site Restoration...............................................................16
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SCE-03: Testimony On The 2017 Decommissioning Cost Estimate for SONGS 2&3 Table Of Contents (Continued)
Section Page Witness
- 3. ISFSI Aging Management .......................................................16
- 4. Decontamination, Demolition, and Disposal ...........................17
- 5. Substructure Removal ..............................................................21
- 6. Other Distributed Projects........................................................21
- 7. Greater Than Class C (GTCC) Waste Storage ........................28
- 8. Plant Easement/Lease Renewals ..............................................29
- 9. Offshore Conduits Removal ....................................................31
- 10. ISFSI Demolition .....................................................................31
- 11. Completed Projects ..................................................................31 C. Undistributed Activities .......................................................................33
- 1. Contracted Services .................................................................33
- 2. Service Level Agreements/A&G .............................................36
- 3. DGC Staffing ...........................................................................37
- 4. Labor-Staffing ..........................................................................38
- 5. All Other Non-Labor................................................................38 V. CONCLUSION ................................................................................................47 Appendix A Witness Qualifications Appendix B Decommissioning Cost Estimate - Confidential Appendix C Reconciliation - Confidential Appendix D Declaration of Todd R. Adler Regarding the Confidentiality of Certain Data Appendix E SONGS Mesa Lease and Station Easement Boundaries
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SCE-03: Testimony On The 2017 Decommissioning Cost Estimate for SONGS 2&3 List Of Tables Table Page Table II-1 Contingency Factors Applied in 2017 DCE ...............................................................................8 Table IV-2 Reconciliation of 2017 DCE to 2014 DCE (100% Share, Millions of 2014 $) ......................14 Table IV-3 2017 SONGS 2&3 DCE Decontamination, Demolition, and Disposal Costs (100% Share, Millions of 2014 $)........................................................................................................20 Table IV-4 Reconciliation of 2017 DCE to 2014 DCE Other Distributed Projects (100%
Share, Millions of 2014 $) ...................................................................................................................24 Table IV-5 Reconciliation of 2017 DCE to 2014 DCE Completed Projects (100% Share, Millions of 2014 $) ..............................................................................................................................33 Table IV-6 Contracted Services (100% Share, Millions of 2014 $) ..........................................................34 Table IV-7 Reconciliation of 2017 DCE to 2014 DCE All Other Non-Labor (100%
Share, Millions of 2014 $) ...................................................................................................................42
-iii-
1 I.
2 INTRODUCTION 3 The purpose of this testimony is to demonstrate the reasonableness of the 2017 4 Decommissioning Cost Estimate for San Onofre Nuclear Generating Station Unit Nos. 2&3 (2017 5 SONGS 2&3 DCE). The 2017 DCE estimates that the total cost to decommission SONGS 2&3 will be 6 $4,479 million (100% share, 2014 $), an increase of approximately 1.5% over the 2014 SONGS 2&3 7 DCE. The Commission-approved 2014 DCE estimated that the total cost to decommission SONGS 2&3 8 would be $4,411 million (100% share, 2014 dollars).
9 Chapter II of this testimony provides a summary of the 2017 DCE. Chapter III provides 10 testimony from ABZ Incorporated (ABZ), a third-party consultant who performed an independent 11 review of the 2017 DCE. Chapter IV provides a detailed reconciliation of the 2017 DCE to the 2014 12 DCE. Chapter V concludes SCEs testimony.
1
1 II.
2
SUMMARY
OF 2017 SONGS 2&3 DECOMMISSIONING COST ESTIMATE 3 A. Methodology and Description 4 SCE and the other SONGS participants1 began accumulating funds for the eventual 5 decommissioning of SONGS 2&3 early in the units operating lives. Because the units were licensed to 6 operate for several decades,2 decommissioning fund accumulations were based on conceptual cost 7 estimates.3 These conceptual DCEs were developed by third-party vendors using proprietary estimating 8 algorithms consistent with recognized industry guidelines such as AIF/NESP-036, Guideline for 9 Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates and the Department of 10 Energy (DOE) Decommissioning Handbook.4 These estimates were updated periodically to reflect 11 changes in regulations, technology, and economics; additions and deletions to the nuclear facilities; 1 San Diego Gas & Electric Company and the City of Riverside own 20% and 1.79% shares of SONGS 2&3, respectively. On December 29, 2006, SCE acquired the City of Anaheims ownership share of SONGS 2&3.
Under the Anaheim Settlement Agreement adopted by the Commission in D.06-11-025, however, the City of Anaheim retained a pro-rata share of the SONGS 2&3 decommissioning obligation as shown approximately in the table below:
Decommissioning Obligation SONGS 2 SONGS 3 SCE 75.7363% 75.7475%
SDG&E 20.0000% 20.0000%
Anaheim 2.4737% 2.4625%
Riverside 1.7900% 1.7900%
100.00% 100.00%
2 On March 9, 2000, the U.S. Nuclear Regulatory Commission issued Amendment No. 166 to Facility Operating License No. NPF-10 and Amendment No. 157 to Facility Operating License No. NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively. These amendments revised the expiration dates of the SONGS 2 and SONGS 3 operating licenses from October 18, 2013, to February 16, 2022 and November 15, 2022, respectively.
3 In this context, conceptual means that the decommissioning cost estimates were developed based on Unit Cost Factors coupled with the Critical Path Method, using the best-available current information, for projects that were not expected to commence until several years or decades into the future. These conceptual cost estimates were not intended to be executable decommissioning project plans or schedules.
4 See Decommissioning Cost Estimate for SONGS 2&3 Prepared for SCE by ABZ Incorporated, dated December 14, 2012, page 5. From 2001 to 2013, SCE utilized ABZ, Incorporated to develop the decommissioning cost estimates for SONGS 2&3. Prior to 2001, SCE utilized TLG Services, Incorporated to develop the decommissioning cost estimates for SONGS 1 and for SONGS 2&3.
2
1 updated site radiological assumptions; lessons-learned from other nuclear decommissioning projects; 2 and other related information necessary to complete accurate cost estimates.
3 On July 22, 2013, after SCE announced its decision to permanently retire SONGS 2&3, SCE 4 notified the Commission that it intended to prepare a new DCE for SONGS 2&3 after the development 5 of a site-specific decommissioning plan.5 SCE informed the Commission that this new estimate would 6 be included in the Post Shutdown Decommissioning Activities Report (PSDAR) that SCE was required 7 to submit to the NRC.6 8 SCE retained the consortium of EnergySolutions and Chicago Bridge & Iron Company (ES/CBI) 9 to develop the 2014 SONGS 2&3 DCE, which included the total estimated cost for the decommissioning 10 project. SCE and SDG&E submitted the 2014 DCE to the Commission in Application (A.) 14-12-007.
11 The Commission adopted the 2014 SONGS 2&3 DCE in Decision (D.) 16-04-019.
12 As required by the California Nuclear Facilities Decommissioning Act of 19857 13 (Decommissioning Act), SCE is required to periodically update the SONGS 2&3 DCE. Therefore, in 14 2017, SCE engaged The Kenrich Group (Kenrich)8 to prepare the 2017 SONGS 2&3 DCE. This DCE is 15 consistent with the guidance provided in NRC Regulatory Guide 1.202, Standard Format and content of 16 Decommissioning Cost Estimates for Nuclear Power Reactors. The 2017 DCE presents the total 17 estimated project cost, including recorded costs to date, to allow for comparisons to the 2014 DCE.
18 That is, the 2017 DCE includes recorded costs from project inception through September 30, 2017, and 19 estimated costs from October 1, 2017 through assumed project completion in 2051. The 2017 DCE 20 estimates that the total cost to decommission SONGS 2&3 will be $4,479 million (100% share, 2014 $).
21 The 2017 DCE uses the same Work Breakdown Structure (WBS) that was used in the 2014 DCE, and 22 includes the following new and updated information:
23
- The pricing for the contract awarded to Holtec International, Inc., (Holtec) for the 24 Independent Spent Fuel Storage Installation (ISFSI) expansion and the transfer of spent fuel 25 from the SONGS 2&3 spent fuel pools to the ISFSI; 5 A.12-12-013, Exhibit SCE-06, page 1.
6 Id.
7 Pub. Utilities Code § 8321 et. seq.
8 See Exhibit SCE-01, pages 17-18.
3
1 2
- The pricing for the contract awarded to SONGS DecommissioningSolutions (SDS) for the 3 decontamination and dismantlement (D&D) of SONGS 2&3, and the removal and disposal 4 of radiological, hazardous, and non-hazardous waste; 5
6
- Recorded costs through September 30, 2017; 7
8
- Revised DOE spent fuel acceptance date to reflect DOEs continued failure to perform its 9 contractual obligations to pick up fuel from commercial nuclear reactors during the four 10 years since the 2014 DCE was completed; 11 12
- Revised environmental review costs and approval dates based on the current permitting 13 strategy and the requirements of the California State Lands Commission (CSLC), the 14 California Coastal Commission (CCC), and the U.S. Department of the Navy (Navy);
15 16
- Revised project execution strategy, including the deferral of the start of substructure removal 17 until 2046; 18 19
- Updated undistributed cost projections based on historical recorded costs and revised 20 projections; 21 22
- Other project costs not previously identified.
25 Significant components of the 2017 DCE are now based on competitively bid contracts, as well 26 as three additional years of experience managing a decommissioning plant and overseeing 27 decommissioning personnel. Where new information was not available, Kenrich worked with third-28 party consultants and SCE personnel to validate and refine the cost and schedule assumptions for 2017 29 SONGS 2&3 DCE.
30 B. 2017 DCE Assumptions 31 The 2017 DCE includes the following assumptions that have not changed from the 2014 SONGS 32 2&3 DCE:
33 34
- SONGS 2&3 will be decommissioned using the prompt DECON decommissioning 35 methodology; 36
- All fuel assemblies will be transferred from the SONGS 2&3 spent fuel pools to the ISFSI by 37 mid-2019; 38 4
1
- A dry transfer facility will not be necessary to transfer the spent fuel canisters to DOE 2 transport canisters; 3
4
- Decommissioning will be performed by a decommissioning general contractor (DGC) with 5 oversight by the SONGS Participants; 6
7
- SONGS 2&3 major D&D activities will be completed by the end of 2028; 8
9
- All onshore substructures and offshore conduits will be removed; and 10 11
- ISFSI decommissioning, NRC license termination, and site lease termination will be 12 completed by the end of 2051.
13 14 In addition, the 2017 DCE is based on the following updated assumptions:
15 16
- SONGS 2&3 D&D will commence in January 2019 based on expected completion dates of 17 environmental reviews and approvals; and 18 19
- The DOE will commence accepting spent fuel from U.S. commercial nuclear facilities in 20 2028, which results in the DOE removing the last spent fuel from the SONGS ISFSI in 2049.
21 22 C. Contingency 23 Contingency is applied to cost estimates to account for unknown or unplanned occurrences 24 during the performance of a project. Contingency is defined in the American Association of Cost 25 Engineers Project and Cost Engineers Handbook as, specific provision for unforeseeable elements of 26 cost within the defined project scope; particularly important where previous experience relating to 27 estimates and actual costs has shown that unforeseeable events which will increase costs are likely to 28 occur. The consensus in the industry literature, including sources from the DOE9 and the Association 29 for the Advancement of Cost Engineering International,10 is that a contingency factor for cost estimates 30 in this stage of development should fall within a range of 15% to 30%.
31 In its decision for the 2005 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP), the 32 Commission ordered the Utilities (SCE, SDG&E, and PG&E) to serve testimony in the next NDCTP 9 Chapter 11 of U.S. Department of Energy (DOE) Decommissioning Implementation Guide DOE, G 430.1-1, March 28, 1997.
10 Association for the Advancement of Cost Engineering International, Recommended Practice No. 18R-97, at page 2 of 9.
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1 that demonstrates they have made all reasonable efforts to conservatively establish an appropriate 2 contingency factor for inclusion in the decommissioning revenue requirements.11 3 To comply with this Commission order, in the 2009 NDCTP,12 which occurred at a time when 4 the Utilities still believed that decommissioning would not begin until decades in the future, PG&E 5 prepared a paper titled, Technical Position Paper for Establishing an Appropriate Contingency Factor 6 for Inclusion in the Decommissioning Revenue Requirements. Based on industry and regulatory 7 documents, the position paper concluded that it is appropriate to add a 25% contingency factor to 8 estimated decommissioning costs because it provides reasonable assurance for unforeseen 9 circumstances13 that could increase decommissioning costs, and should not be reduced or eliminated 10 simply because foreseeable costs are low. In that proceeding, SCE agreed based on its own independent 11 research that the 25% contingency factor was conservative and appropriate.14 Consistent with this 12 assumption, each of the DCEs submitted by the Utilities in that proceeding contained a 25% contingency 13 factor. The Commission found that each such DCE was reasonable.15 14 Later, an Independent Review Panel (Panel) examined the definition and role of contingency 15 factors in DCEs.16 The Panel identified that DCEs should consider four types of risk or uncertainty, 16 including: (1) performance risk; (2) scope risk; (3) regulatory risk; and (4) financial risk.17 The Panel 17 found that the DCEs prepared by third-party vendors on behalf of the Utilities typically only addressed 18 performance risks by including 17%-22% contingency, and that the Utilities adjustments to target their 19 DCEs overall contingency to 25% was intended to capture all risks, and was consistent with the 11 D.07-01-003, Ordering Paragraph 8.
12 A.09-04-007 and A.09-04-009.
13 For example, some activities in the remaining decommissioning work are less familiar activities in the industry. To terminate the easement with the Navy, SCE may be required to perform extensive site restoration work that is unique to the SONGS site.
14 D.10-07-047, page 23.
15 Id., Conclusions of Law 4, 5, 6, 7, 13, and 14. Also see D.11-07-003 at page 25.
16 Report on Nuclear Decommissioning, February 28, 2011, For The California Public Utilities Commission, Prepared by Nicholas Capik, Geoffrey Griffiths, and Bruce Lacy, at pages 40-42.
17 Id., at page 40. Financial risk is typically addressed through conservative assumptions for cost escalation and fund earnings rates.
6
1 contingency value normally used by the NRC.18 The Commission also approved SCEs 2 decommissioning cost estimates in the 2012 NDCTP and SCEs 2014 SONGS 2&3 DCE, each of which 3 also included a 25% contingency factor.19 4 In the 2017 SONGS 2&3 DCE, SCE did not apply contingency to the $1,156 million (100%
5 share, 2014 $) of SONGS 2&3 decommissioning costs that were recorded between June 2013 and 6 September 2017. For work scopes that have been contracted or are well defined in the 2017 DCE, SCE 7 applied lower contingency factors. Kenrich and knowledgeable SCE personnel reviewed each DCE line 8 item, giving consideration to the technical complexity, contracting status, estimating approach, and 9 timing of each work scope, and applied an appropriate contingency factor. For decommissioning 10 activities in the 2017 DCE that will not be performed until decades in the future when their scopes 11 become better defined, SCE applied a 25% contingency factor as approved by the Commission in the 12 past several NDCTPs.
18 Id., see Footnote 37.
19 See D.14-12-082 at page 38, Findings of Fact 13, and Conclusions of Law 17, 22, 23, and 24; and D.16-04-019 Conclusion of Law 1.
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1 Table II-1 below identifies the range of contingency factors utilized for each 2017 DCE cost 2 category:
Table II-1 Contingency Factors Applied in 2017 DCE Contingency 2017 DCE Category Factor Recorded Costs Through September 2017 0%
Service Level Agreements 10%
Undistributed Labor 10%
ISFSI & Fuel Transfer Operations Undistributed Non-Labor 15%
Plant Easement/Lease Renewals 20%
Other Projects 15-20%
GTCC Waste Storage 25%
Offshore Conduit Removal 25%
Substructure Removal 25%
ISFSI Demolition 25%
Final Site Restoration 25%
3 The composite contingency factor included in the 2017 DCE is approximately of the base 4 costs.
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1 III.
2 INDEPENDENT REVIEW OF 2017 SONGS 2&3 DCE 3 A. Introduction 4 This testimony describes ABZ, Incorporateds (ABZ) independent review of the 2017 San 5 Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Decommissioning Cost Estimate (DCE),
6 and the conclusions reached by ABZ in that review.
7 Nick Capik was the project manager and principal author of the ABZ review of the 2017 8 SONGS 2&3 DCE. In this testimony, he describes the scope of ABZs review and the conclusions 9 reached during that review.
10 B. ABZ Background And Experience 11 ABZ was founded in 1986 to provide consulting and engineering services to the nuclear power 12 industry. ABZ supports nuclear decommissioning projects in a number of ways including cost 13 estimating, licensing, project management, due diligence, and litigation. ABZ has been engaged from 14 conceptual design of decommissioning through implementation and site restoration.
15 ABZ has also prepared or reviewed 43 decommissioning cost estimates covering 63 nuclear 16 plants. This includes preparing DCEs for SONGS 2 & 3 from 2001 through 2014. These SONGS cost 17 estimates were accepted by the California Public Utilities Commission (CPUC) as reasonable and 18 formed the basis for ratemaking for decommissioning collections. In addition, I participated as the ABZ 19 representative in an Independent Review Panel established by the CPUC to examine decommissioning 20 cost issues as part of Decision (D.) 10-07-047. As part of this work, ABZ evaluated the 2008 21 SONGS 2&3 DCE in comparison to Pacific Gas and Electrics Diablo Canyon estimate, the Palo Verde 22 Nuclear Generating Station estimate, and the estimates for four other similar nuclear power plant sites.
23 Significant areas of focus included cost and financial assumptions, waste management approaches, state 24 requirements for site restoration, severance costs, and use of actual industry performance and cost data.
25 In addition to cost estimating, ABZ has performed direct oversight of decommissioning activities 26 for several nuclear power plant decommissioning projects, including Zion, Trojan, and Shoreham. ABZ 9
1 staff has provided additional support for decommissioning at Connecticut Yankee, Maine Yankee, 2 Yankee Rowe, Fort St. Vrain, Millstone, and others.
3 ABZ has participated in litigation associated with decommissioning in several venues, including 4 the U.S. Court of Claims, U.S. Tax Court, and State proceedings. Finally, ABZ has performed due 5 diligence reviews of decommissioning plans, efforts, and costs as part of two nuclear plant sales.
6 C. ABZ Independent Review 7 1. Scope 8 ABZ performed an independent review of the 2017 SONGS 2&3 DCE. This review was 9 conducted in several phases as the DCE was being developed such that responses to ABZ comments and 10 questions could be evaluated and incorporated into the final DCE. ABZs review focused on key 11 assumptions, scope and cost of decommissioning projects, project schedules, and undistributed costs, 12 including staffing, and contingency.
13 2. Review Process 14 ABZ reviewed the draft DCE and supporting information over a seven-month period in 15 2017. ABZ performed distinct reviews at 60 percent complete, 90 percent complete, and just prior to 16 issuance of the final DCE. ABZs intent was to assess the reasonableness of the DCE assumptions, 17 project scopes, costs, and schedule. ABZ provided comments addressing the scope of the estimate 18 compared to previous SONGS estimates and industry experience, estimated costs, work completed to 19 date, and assumptions used in preparing the estimate.
20 ABZ started by reviewing the key assumptions of the DCE for reasonableness. ABZ 21 evaluated these assumptions in light of similar assumptions made at other decommissioning projects.
22 ABZ then evaluated the projects included in the DCE to ensure that the collective scope 23 of activities was sufficient to terminate the NRC license and restore the SONGS site. ABZ evaluated the 24 costs of these projects against previous estimates and with comparable industry costs. In parallel with 25 its review of projects, ABZ evaluated the schedule for these projects to ensure that sufficient time was 26 allocated for successful performance, and to evaluate the ability to adjust the planned schedule to 27 accommodate potential delays.
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1 Separate from its review of decommissioning projects, ABZ evaluated undistributed costs 2 in the DCE, including both staff costs as well as non-staff costs to ensure that all such costs were 3 included and that the estimated costs were reasonable.
4 Finally, ABZ reviewed the contingency included in the DCE and the basis used to 5 allocate contingency. ABZ evaluated the change in contingency from previous DCEs as well as the 6 basis for such changes.
7 D. ABZ Findings 8 1. Key Facts And Assumptions 9 The 2017 SONGS 2&3 DCE contains a number of key facts and assumptions. ABZ 10 reviewed these key facts and assumptions and concluded that the facts represent known conditions and 11 that the assumptions are reasonable.
12 2. Scope 13 The SONGS DCE includes two major fixed-price contracts that cover a large portion of 14 the work to remediate radiological hazards and reduce the footprint of the NRC license to that required 15 to store spent fuel, and to transfer spent fuel on-site to a dry storage facility. Beyond these two major 16 contracts, the DCE includes continued management of spent fuel until accepted by DOE, demolition of 17 uncontaminated structures, and restoration of the site. ABZ reviewed this scope of work against 18 previous SONGS DCEs including the 2014 DCE performed by EnergySolutions as well as previous 19 ABZ estimates.
20 ABZ verified that the 2017 DCE included all identified activities needed to terminate the 21 NRC operating license and restore the site consistent with the end-state assumptions.
22 3. Schedule 23 ABZ reviewed the schedule for decommissioning activities, identified critical path 24 activities, and ability to manage delays in performance of major activities. ABZ compared this schedule 25 to previous SONGS schedules and evaluated the proposed activity lengths to relative to recent 26 decommissioning projects. ABZ concluded that the schedule allowed adequate time to complete 27 required activities.
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1 4. Risk Mitigation 2 ABZ reviewed both the contingency included in the 2017 SONGS 2&3 DCE as well as 3 the schedule to determine whether and how uncertainties could be accommodated without an increase in 4 project cost or duration. ABZ concluded that the schedule provided sufficient flexibility to allow for a 5 delay in completing critical path activities while still maintaining the overall project schedule and 6 keeping costs within the estimate total. Further, ABZ evaluated the overall contingency compared to the 7 current state of the SONGS decommissioning project and concludes that the contingency is reasonable 8 for the current project state.
9 E. Conclusion 10 ABZ concludes that the scope of the 2017 SONGS DCE is sufficient to terminate the NRC 11 license and restore the site; that the projected schedule allows sufficient time for completion of all 12 required activities; that the cost is reasonable for performance of those activities; and that sufficient risk 13 mitigation has been included.
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1 IV.
2 RECONCILIATION OF THE 2017 DCE TO THE 2014 DCE 3 A. Overview 4 In D.16-04-019, the Commission found reasonable the 2014 SONGS 2&3 DCE of 5 $4,411 million (100% level, 2014 $). The 2017 SONGS 2&3 DCE estimates the total cost to 6 decommission SONGS 2&3 will be $4,479 million (100% share, 2014 $). There are several variances 7 between the 2014 and 2017 DCEs that net to small 1.5% increase in the 2017 DCE, as shown in Table 8 IV-2 below.20 At a high level, the increase is due to new scope not included in the 2014 DCE including 9 ISFSI Aging Management Project and GTCC waste storage; the remaining variances essentially net to a 10 zero change.
20 Appendix C provides a table which shows the differences between Table 2 of the 2017 SONGS 2&3 DCE and this Table IV-2. SCE made these changes to be able to provide better description of the activities and variances.
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Table IV-2 Reconciliation of 2017 DCE to 2014 DCE (100% Share, Millions of 2014 $)
2017 DCE 2014 DCE Total Total Description (2014 $) (2014 $) Variance 1 Distributed Projects 2 ISFSI & Fuel Transfer Operations $ 270.2 $ 405.1 $ (134.9) 3 Final Site Restoration 6.9 57.4 (50.5) 4 ISFSI Aging Management 36.5 - 36.5 5 Decontamination, Demolition, and Disposal 1,208.2 6 Substructure Removal 273.0 303.8 (30.8) 7 Other Projects 99.6 72.9 26.7 8 GTCC Waste Storage 26.6 - 26.6 9 Plant Easement/Lease Renewals 27.1 1.4 25.7 10 Offshore Conduit Removal 91.6 96.0 (4.4) 11 ISFSI Demolition 19.2 21.1 (1.9) 12 Completed Projects 123.3 98.1 25.2 13 Distributed Subtotal $ $ 2,264.0 $
14 15 Undistributed Activities 16 Contracted Services $ 225.2 $ 34.6 $ 190.6 17 Service Level Agreements 168.2 - 168.2 18 DGC Staffing 423.6 19 Labor-Staffing 986.2 1,029.4 (43.2) 20 All Other Non-Labor 623.6 659.6 (36.0) 21 Undistributed Subtotal $ $ 2,147.2 $
22 23 Total $ 4,478.6 $ 4,411.2 $ 67.4 1 B. Distributed Projects 2 1. ISFSI & Fuel Transfer Operations 3 SCE retained Holtec as the vendor to construct sufficient additional dry spent fuel storage 4 capacity for the fuel currently stored in the SONGS 2&3 spent fuel pools, and to transfer the fuel to dry 5 storage. Holtecs ISFSI & Fuel Transfer Operations work scope includes the following activities:
6
- Design and license a seismically designed dry storage system for the 2,668 fuel 7 assemblies that remain in the SONGS 2&3 spent fuel pools 8
- Excavate and install the foundation base mat 9
- Fabricate, transport, and install the 75 vertical canister enclosure containers (CECs) 14
1
- Install a perimeter form surrounding the CECs and backfill with concrete 2
- Install a protected area security perimeter around the new ISFSI 3
- Fabricate and transport 75 multi-purpose canisters (MPCs) and seal lids, two shielded 4 transfer casks, canister sealing equipment, and cask transfer equipment to the SONGS 5 site 6
- Re-certify the spent fuel pool cranes to ensure safe lifting of the fully loaded MPCs 7 and transfer casks 8
- Perform dry-run testing of fuel loading, canister sealing, and canister drying in the 9 spent fuel pools 10
- Perform dry-run testing of fully loaded MPCs/transfer casks from the SONGS 2&3 11 spent fuel pools to the ISFSI 12
- Remove each fully loaded MPC/transfer cask from spent fuel pool, decontaminate, 15 weld MPC lid and leak test, dehydrate MPC interior and fill with helium, weld vent 16 and drain ports and closure ring 17
- Transfer each fully loaded MPC/transfer cask from the spent fuel pool to the ISFSI 18
- Install the closure lid on each CEC 20
- Construct stand-alone ISFSI security building 21 Based on SCEs contract with Holtec,21 the cost to complete the ISFSI and Fuel Transfer 22 Operations project is estimated in the 2017 DCE to be $270.2 million22 (100% share, 2014 $). In the 23 2014 DCE, SCE estimated that the cost to expand the SONGS ISFSI and transfer all remaining fuel 24 from the SONGS 2&3 spent fuel pools to the ISFSI was $405.1 million (100% share, 2014 $). Thus, the 25 2017 DCE reflects a decrease of $134.9 million. This decrease is attributable to the lower cost of the 21 SCE selected Holtec after a competitive procurement process.
22 See 2017 DCE, Appendix C, Table 2, line 37.
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1 competitively bid Holtec contract relative to the 2014 DCE. Because SCE negotiated a substantial 2 reduction relative to the previously estimated ISFSI and Fuel Transfer Operations costs, the Commission 3 should find that the estimated cost is reasonable.
4 2. Final Site Restoration 5 The 2017 DCE includes the following scope for Final Site Restoration: (1) remove 6 railroad tracks, gunite slope protection, site access roads, and parking lots; (2) perform final site grading 7 and re-vegetation; and (3) perform any other work required by the Navy real estate authorization, which 8 is expected to include end state requirements for the SONGS site.
9 The estimated cost for Final Site Restoration work in the 2017 DCE is $6.9 million23 10 (100% share, 2014 $). The estimated cost for Final Site Restoration in the 2014 DCE was $57.4 million 11 (100% share, 2014 $). This resulted in a cost decrease of $50.5 million (100% share, 2014 $). This cost 12 decrease occurred because SCE consolidated two previously planned dewatering campaigns that would 13 have been separated by nearly two decades into a single campaign that will occur near the end of the 14 decommissioning schedule after SCE will have secured the final real estate authorization from the Navy 15 and will know the Navys final site restoration requirements. Final site restoration is a necessary part of 16 the decommissioning process, and therefore, the Commission should find that these estimated costs are 17 reasonable.
18 3. ISFSI Aging Management 19 The ISFSI Aging Management Program (AMP) project was established to develop 20 inspection and maintenance programs for both the Areva and Holtec spent fuel dry storage systems.24 21 The project also includes the cost to renew the NRC Certificates of Compliance (CoCs) for the storage 22 systems. Areva and Holtec currently hold 20-year CoCs for their spent fuel dry storage systems used at 23 SONGS. The Areva and Holtec CoCs will expire in 2023 and 2035, respectively. Under 10 C.F.R. 24 § 72.240, the CoC holder may apply for renewal of the CoC for a term not to exceed 40 years. The CoC 25 renewal applications must include Safety Analysis Reports (SARs) that provide descriptions of the 23 See 2017 DCE, Appendix C, Table 2, line 251.
24 In September 2014, NEI 14-03 [Revision 0], Guidance for Operations-Based Aging Management of Dry Cask Storage was issued.
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1 AMPs and time-limited aging analyses demonstrating that the structures, systems, and components 2 important to safety will continue to perform their intended functions for the requested period of 3 extended operation.
4 The estimated cost for the ISFSI Aging Management Program in the 2017 DCE is $36.5 5 million25 (100% share, 2014 $). The 2014 DCE did not include a specific line item for the ISFSI Aging 6 Management Program. This resulted in a cost increase of $36.5 million (100% share, 2014 $).
7 As discussed above, these costs include initial cask testing, inspection equipment and licensing costs for 8 dry cask CoC renewals and SAR updates for the Holtec and Areva AMPs.26 These estimated costs are 9 necessary to renew NRC required CoCs and therefore should be deemed reasonable by the Commission.
10 4. Decontamination, Demolition, and Disposal 11 The Decontamination, Demolition, and Disposal cost category includes many activities 12 that will be performed by the DGC. As such, the pricing of these activities is primarily based on the 13 executed SDS contract, which was achieved through a competitive procurement process that included 14 multiple experienced contractors.27 The work included in this category encompasses the removal and 15 disposal of the necessary structures, systems, and components, as well as the removal of radiological and 16 non-radiological contaminants necessary to meet the approved license termination plan. This category 17 has been subdivided into the following major projects, consistent with the Milestone Framework:
18
- Initial D&D Activities - includes modifying the units containment access to support 19 future decommissioning activities; removing the missile shields and reactor heads; 20 constructing an electrical ring bus for the site; and executing the necessary waste 21 disposal contracts 22
- Reactor Vessel Internals (RVI) Segmentation and Disposal - includes designing and 23 procuring the necessary RVI segmentation equipment; testing the specially 25 See 2017 DCE, Appendix C, Table 2, line 163.
26 SCE will also incur undistributed non-labor costs for the ISFSI Aging Management Program for periodic maintenance and inspections of the spent fuel dry storage systems. Those costs are discussed in Section IV.C.5 below.
27 See Exhibit SCE-05 for additional information regarding the DGC selection process.
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1 engineered equipment and installing the equipment within containment; performing 2 RVI segmentation; packaging GTCC waste; and disposing non-GTCC waste 3
- Spent Fuel Systems and Equipment Removal and Disposal - includes removing the 4 spent fuel pool racks; installing a water processing system; and draining the spent fuel 5 pools 6
- Steam Generator Removal and Disposal - includes removing the steam generators 7 (two per unit); and segmenting, packaging, and disposing of the steam generators 8
- Non-Essential Systems Removal and Disposal - includes removing systems in 9 multiple maintenance buildings, administration buildings, and warehouse buildings; 10 and removing injection systems, condenser tubes, and auxiliary transformers 11
- Large Components Removal and Disposal - includes removing and disposing of 12 reactor vessel insulation; and segmenting, packaging, and disposing of the reactor 13 vessels, pressurizers, and turbine gantry cranes 14
- Initial Plant Buildings Demolition and Disposal - includes procuring building 15 demolition equipment; and then demolishing the auxiliary control/radwaste building, 16 full flow condensate polishing demineralizer and turbine buildings, emergency diesel 17 generator buildings; transformer pads, administration/warehouse/shop (AWS) 18 building, and numerous other support structures 19
- Buildings Decontamination - includes removing the remaining radioactive materials 20 embedded within the concrete and steel surfaces, walls, and floors of the buildings in 21 the SONGS radiological control area; and performing decontamination verification 22 surveys to validate the effectiveness of the decontamination work performed 23
- Final Plant Buildings Demolition and Disposal - includes demolishing the buildings 24 in the central area of the plant, (i.e., the fuel handling and penetration buildings); and 25 removing the protective area pavement 18
1
- Offshore Conduits Diffusers and Risers Removal - includes preparing hydro-2 geological analysis; and removing specified vertical diffusers and risers from the two 3 offshore intake conduits and the two offshore discharge conduits 4
- Containment Buildings Demolition and Disposal - includes de-tensioning and 5 removing the containment building post-tensioning cables; and demolishing the 6 containment and safety equipment buildings 7
- Site Backfill, Compaction, etc. - following the demolition of structures, systems, and 8 components, backfilling and compacting the site to a specified grade to meet the 9 interim end-state 10
- Final Site Radiological Survey and NRC License Termination (for Partial Site 11 Release of SONGS 2&3 Site) - includes performing the final radiological site status 12 survey in accordance with NRC guidelines; and developing and supporting the 13 License Termination Plan 14
- Waste Taxes (pass-through)28 - per the DGC contract, the SONGS Participants are 15 responsible to pay the DGC for the actual waste taxes and fees invoiced to SDS based 16 on the actual waste disposed 17 The estimated costs for Decontamination, Demolition, and Disposal activities are shown 18 in Table IV-3 below:
28 These costs are not included in the SDS contract, but have been estimated in the 2017 DCE. In the 2014 DCE, applicable waste taxes were included with the estimated costs for each distributed project.
19
Table IV-3 2017 SONGS 2&3 DCE Decontamination, Demolition, and Disposal Costs (100% Share, Millions of 2014 $)
2017 DCE Total Description (2014 $)
1 Decontamination, Demolition, and Disposal 2 Initial D&D Activities $
3 Reactor Vessel Internals Segmentation and Disposal 4 Spent Fuel Systems/Equipment Removal and Disposal 5 Steam Generator Removal and Disposal 6 Non-Essential Systems Removal and Disposal 7 Large Components Removal and Disposal 8 Initial Plant Buildings Demolition and Disposal 9 Building Decontamination 10 Final Plant Buildings Demolition and Disposal 11 Offshore Conduit Diffusers/Risers Removal 12 Containment Buildings Demolition and Disposal 13 Site Backfill, Compaction, etc.
14 Final Site Radiological Survey and NRC License Termination 15 Waste Taxes (pass-through) 16 Decontamination, Demolition, and Disposal Total $
1 In the 2017 DCE, the estimated cost for Decontamination, Demolition, and Dismantling 2 activities is $ 29 (100% share, 2014 $). In the 2014 DCE, the estimated cost for these 3 activities was $1,208.2 million (100% share, 2014 $), resulting in an increase of $ .30 4 The primary reason for the increased cost is the addition of activities expected to be performed that are 5 currently outside the scope of the SDS contract.
29 See 2017 DCE, Appendix C, Table 2, lines 8 and 50, 57, 66, 70, 75, 86, 108, 121, 130, 132, 134, 144, 149, and 153.
30 SCE is not providing a line-by-line comparison and variance analysis of DGC contract values to the 2014 DCE, because such an analysis would not provide meaningful information given how the DGC contract values were determined. The SDS contract reflects negotiated terms and conditions regarding the contract pricing and timing of payments agreed to between SCE and SDS. The SDS contract also assumes a grouping and sequencing of work different than assumed in the 2014 DCE. Although a line-by-line variance analysis is not possible given these issues, SCE is able to compare the total costs of the scope included in the SDS contract to the same scope of work included in the DCE.
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