ML14364A016

Comment (15) of Ray Lutz, on Behalf of Citizens' Oversight Projects, on Southern California Edison Company; San Onofre Nuclear Generating Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report

ML14364A016
Person / Time
Site:	San Onofre
Issue date:	12/22/2014
From:	Lutz R Citizens Oversight Projects (COPS)
To:	Rules, Announcements, and Directives Branch
References
79FR61668 00015, NRC-2014-0223
Download: ML14364A016 (4)

Text

As of: December 24, 2014 Received:

December 22, 2014 PUBLIC SUBMISSIONenmg_ost PUBLC S BMISIONTracking No. ljy-8g7e-s48p Comments Due: December 22, 20 Submission Type: Web Docket: NRC-2014-0223 Southern California Edison Company; San Onofre Nuclear Generating Station, Units 2 and 3 Comment On: NRC-2014-0223-0001 Southern California Edison Company; San Onofre Nuclear Generating Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report 14 Document:

NRC-2014-0223-DRAFT-001 1 Comment on FR Doc # 2014-24356

76) Fp- 6t66"t00 Submitter Information Name: Ray Lutz Address: 771 Jamacha Rd. #148 El Cajon, 92019 Email: raylutz@citizensoversight.org General Comment 7 7 The following comment is provided by CitizensOversight.

,-I The questions provided are not clearly answered by the PSDAR and Detailed Cost Estiirate.

,- " Thank you -'--Ray Lutz CitzensOversight.org i-] -o See attached file(s)Attachments COPSQuestions on SONGS2&3_PSDAR&DCE SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= .x) ev-- ( Tuo,ý.)

Citizens' Oversight Projects (COPs)771 Jamacha Rd #148 El Cajon, CA 92019 CitizensOversight.org 619-447-3246 August 26, 2014 NS' OVERSIGHT PROJEU CitizensOversightorg REVIEW OF POST-SHUTDOWN ACTIVITIES REPORT (PSDAR) AND OTHER DOCUMENTS RELATED TO THE DECOMMISSIONING OF SAN ONOFRE 1. What system is being used to track the spending and work performed during the decommissioning process?2. In the SONGS 1 decommissioning, SCE used a home-brew tracking system "CARS" which is now impossible to use, meaning we have lost that historical record. Essentially all information about SONGS 1 spending has been lost. Thus we have no means to reflect and compare the steps taken during SONGS 1 and the plans for SONGS 2 & 3. How is SCE safeguarding this information so it will not be lost this time, and so it can be used to inform other decommissioning projects, such as the inevitable decommissioning of the PG&E plant at Diablo Canyon?3. Does SCE nevertheless have any other record of detailed spending for SONGS I 4. The major portions of the decommissioning process occur in three of the "decon" group of tasks, for a total of nearly half the total budget and encompassing over nine years, followed by two "Site Restoration" tasks, which comprise seven more years. Together, these five line items comprise about $2.4 billion. These tasks should be broken down much further to allow the project to be tracked by oversight groups. -- Please provide more detail on these line items on a year-by-year and subproject-by-subproject basis, including cost estimates for each subproject, and total proposed to be spent each year.PERIOD DESCRIPTION PERIOD YRS COST (lO00s)+/- + I-Decon Pd 3 Decommissioning Preparations and Reactor Internals Segmentation

-"decontamination and dismantlement of the major components in the containment building (RV internals, vessel, head, steam generators, pressurizer, and main piping)."* DGC Mobilization and Planning* System Decontamination

• Reactor Internals Removal Preparations

• Reactor Internals Segmentation Planning and Implementation

• Purchase Dry Storage Canisters for GTCC Waste* Segment and Package Reactor Internals for Storage in the ISFSI 6/30/2015 to 6/1/2019 3.92$539,009 I _ _ _ _ _ _ I I _ _ _ _ _ _

Decon Pd 4 Plant Systems and Large Component Removal -"decontamination and dismantlement of SSCs known to be substantially contaminated and the removal of the components from both Periods 3 and 4. "* Upgrade Rail Spur in Owner Controlled Area* Install Large Array Radiation Detection System to Monitor Shipments In/Out of Site" Remove, Package, and Dispose of Non-Essential Systems" Asbestos and Lead Abatement* Spent Fuel Pool Closure* Remove Spent Fuel Pool Racks, Spent Fuel Pool Island Equipment, and Bridge Crane* Remove and Dispose of Legacy Class B and C Wastes* Remove, Package, and Dispose of Essential Systems" Removal and Disposal of Spent Resins, Filter Media, and Tank Sludge" Large Component Removal" Prepare License Termination Plan 6/1/2019 to 9/24/2022 3.31 1 $804,504-I ______ 4 ____________

Decon Pd 5 Building Decontamination

-"decontamination of the various buildings.

As noted elsewhere it may be more appropriate to simply proceed with dismantlement if it is more timely and cost-effective to simply dispose of building material as radioactive waste."* Decontaminate Containment Buildings* Decontaminate Turbine Buildings* Decontaminate Fuel Handling Buildings* Decontaminate Auxiliary Rad-waste Building* Decontaminate Auxiliary Control Building" Decontaminate Penetration Buildings" Decontaminate Safety Equipment and Main Steam Isolation Valve (MSIV) Buildings" Radiological Survey of Structures During Decontamination 9/24/2022 to 7/13/2024 1.80 $429,106*1 i -i Site Restoration Pd 4 Building Demolition to Three Feet Below-Grade

• Demolition Preparations

• De-tension and Remove Containment Building Tendons* Demolish Diesel Generator Buildings* Demolish Condensate Buildings and Transformer Pads" Demolish Full Flow Areas and Turbine Buildings" Demolish Auxiliary Rad-waste Building* Demolish Auxiliary Control Building* Remove Systems and Demolish Make-up Demineralizer Structures 7/13/2024 to 10/14/2028 4.25 $259,066 0 0 0 S S Demolish Penetration Buildings Demolish Safety Equipment and MSIV Buildings Demolish Fuel Handling Buildings Demolish Containment Buildings Demolish Intake and Discharge Structures Site Restoration Pd 5 Subgrade Structure Removal Below Three Feet* Install Sheet Piling and Excavation Shoring, Dewatering System, and Effluent Treatment and Discharge Controls* Demolish and Backfill Subsurface Structures

• Demolish and Backfill Intake Structure Inside Seawall* Remove Off-shore Intake and Outfall Conduits" Remove Sheet Piling and Excavation Shoring, and Perform Dewatering and Effluent Treatment* Finish Grading and Re-vegetate Site As Needed/Required 10/14/2028 to 12/5/2031 3.14$441,547 (TOTAL)$2,473,232

5. When and how much money does SCE plan to request to be provided from the decommissioning project using the Advice Letter process.6. In the Nuclear Decommissioning Cost Triennial Proceeding, SCE testified that you were not planning on comparing the detailed cost estimate with the actual spending levels. Do you still plan to try to avoid this level of reasonable oversight in the spending of ratepayer monies?7. Does SCE already have a contract with Waste Control Specialists in Andrews, Texas, to accommodate all the waste other than the high-level waste stored in the dry-cask storage facility on site?8. The SONGS I Reactor Pressure Vessel still exists on site and there have been serious technical problems associated with "segmentation" and transportation.

What are the exact plans to deal with all the reactor pressure vessels?9. Why is the transmission line switchyard not included in the decommissioning project?Sincerely, Raymond Lutz National Coordinator, Citizens' Oversight Projects As of: December 24, 2014 Received:

December 22, 2014 PUBLIC SUBMISSIONenmg_ost PUBLC S BMISIONTracking No. ljy-8g7e-s48p Comments Due: December 22, 20 Submission Type: Web Docket: NRC-2014-0223 Southern California Edison Company; San Onofre Nuclear Generating Station, Units 2 and 3 Comment On: NRC-2014-0223-0001 Southern California Edison Company; San Onofre Nuclear Generating Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report 14 Document:

NRC-2014-0223-DRAFT-001 1 Comment on FR Doc # 2014-24356

76) Fp- 6t66"t00 Submitter Information Name: Ray Lutz Address: 771 Jamacha Rd. #148 El Cajon, 92019 Email: raylutz@citizensoversight.org General Comment 7 7 The following comment is provided by CitizensOversight.

,-I The questions provided are not clearly answered by the PSDAR and Detailed Cost Estiirate.

,- " Thank you -'--Ray Lutz CitzensOversight.org i-] -o See attached file(s)Attachments COPSQuestions on SONGS2&3_PSDAR&DCE SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= .x) ev-- ( Tuo,ý.)

Citizens' Oversight Projects (COPs)771 Jamacha Rd #148 El Cajon, CA 92019 CitizensOversight.org 619-447-3246 August 26, 2014 NS' OVERSIGHT PROJEU CitizensOversightorg REVIEW OF POST-SHUTDOWN ACTIVITIES REPORT (PSDAR) AND OTHER DOCUMENTS RELATED TO THE DECOMMISSIONING OF SAN ONOFRE 1. What system is being used to track the spending and work performed during the decommissioning process?2. In the SONGS 1 decommissioning, SCE used a home-brew tracking system "CARS" which is now impossible to use, meaning we have lost that historical record. Essentially all information about SONGS 1 spending has been lost. Thus we have no means to reflect and compare the steps taken during SONGS 1 and the plans for SONGS 2 & 3. How is SCE safeguarding this information so it will not be lost this time, and so it can be used to inform other decommissioning projects, such as the inevitable decommissioning of the PG&E plant at Diablo Canyon?3. Does SCE nevertheless have any other record of detailed spending for SONGS I 4. The major portions of the decommissioning process occur in three of the "decon" group of tasks, for a total of nearly half the total budget and encompassing over nine years, followed by two "Site Restoration" tasks, which comprise seven more years. Together, these five line items comprise about $2.4 billion. These tasks should be broken down much further to allow the project to be tracked by oversight groups. -- Please provide more detail on these line items on a year-by-year and subproject-by-subproject basis, including cost estimates for each subproject, and total proposed to be spent each year.PERIOD DESCRIPTION PERIOD YRS COST (lO00s)+/- + I-Decon Pd 3 Decommissioning Preparations and Reactor Internals Segmentation

-"decontamination and dismantlement of the major components in the containment building (RV internals, vessel, head, steam generators, pressurizer, and main piping)."* DGC Mobilization and Planning* System Decontamination

• Reactor Internals Removal Preparations

• Reactor Internals Segmentation Planning and Implementation

• Purchase Dry Storage Canisters for GTCC Waste* Segment and Package Reactor Internals for Storage in the ISFSI 6/30/2015 to 6/1/2019 3.92$539,009 I _ _ _ _ _ _ I I _ _ _ _ _ _

Decon Pd 4 Plant Systems and Large Component Removal -"decontamination and dismantlement of SSCs known to be substantially contaminated and the removal of the components from both Periods 3 and 4. "* Upgrade Rail Spur in Owner Controlled Area* Install Large Array Radiation Detection System to Monitor Shipments In/Out of Site" Remove, Package, and Dispose of Non-Essential Systems" Asbestos and Lead Abatement* Spent Fuel Pool Closure* Remove Spent Fuel Pool Racks, Spent Fuel Pool Island Equipment, and Bridge Crane* Remove and Dispose of Legacy Class B and C Wastes* Remove, Package, and Dispose of Essential Systems" Removal and Disposal of Spent Resins, Filter Media, and Tank Sludge" Large Component Removal" Prepare License Termination Plan 6/1/2019 to 9/24/2022 3.31 1 $804,504-I ______ 4 ____________

Decon Pd 5 Building Decontamination

-"decontamination of the various buildings.

As noted elsewhere it may be more appropriate to simply proceed with dismantlement if it is more timely and cost-effective to simply dispose of building material as radioactive waste."* Decontaminate Containment Buildings* Decontaminate Turbine Buildings* Decontaminate Fuel Handling Buildings* Decontaminate Auxiliary Rad-waste Building* Decontaminate Auxiliary Control Building" Decontaminate Penetration Buildings" Decontaminate Safety Equipment and Main Steam Isolation Valve (MSIV) Buildings" Radiological Survey of Structures During Decontamination 9/24/2022 to 7/13/2024 1.80 $429,106*1 i -i Site Restoration Pd 4 Building Demolition to Three Feet Below-Grade

• Demolition Preparations

• De-tension and Remove Containment Building Tendons* Demolish Diesel Generator Buildings* Demolish Condensate Buildings and Transformer Pads" Demolish Full Flow Areas and Turbine Buildings" Demolish Auxiliary Rad-waste Building* Demolish Auxiliary Control Building* Remove Systems and Demolish Make-up Demineralizer Structures 7/13/2024 to 10/14/2028 4.25 $259,066 0 0 0 S S Demolish Penetration Buildings Demolish Safety Equipment and MSIV Buildings Demolish Fuel Handling Buildings Demolish Containment Buildings Demolish Intake and Discharge Structures Site Restoration Pd 5 Subgrade Structure Removal Below Three Feet* Install Sheet Piling and Excavation Shoring, Dewatering System, and Effluent Treatment and Discharge Controls* Demolish and Backfill Subsurface Structures

• Demolish and Backfill Intake Structure Inside Seawall* Remove Off-shore Intake and Outfall Conduits" Remove Sheet Piling and Excavation Shoring, and Perform Dewatering and Effluent Treatment* Finish Grading and Re-vegetate Site As Needed/Required 10/14/2028 to 12/5/2031 3.14$441,547 (TOTAL)$2,473,232

5. When and how much money does SCE plan to request to be provided from the decommissioning project using the Advice Letter process.6. In the Nuclear Decommissioning Cost Triennial Proceeding, SCE testified that you were not planning on comparing the detailed cost estimate with the actual spending levels. Do you still plan to try to avoid this level of reasonable oversight in the spending of ratepayer monies?7. Does SCE already have a contract with Waste Control Specialists in Andrews, Texas, to accommodate all the waste other than the high-level waste stored in the dry-cask storage facility on site?8. The SONGS I Reactor Pressure Vessel still exists on site and there have been serious technical problems associated with "segmentation" and transportation.

What are the exact plans to deal with all the reactor pressure vessels?9. Why is the transmission line switchyard not included in the decommissioning project?Sincerely, Raymond Lutz National Coordinator, Citizens' Oversight Projects