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, 2014Received:

December 22, 2014PUBLIC SUBMISSIONenmg_ost PUBLC S BMISIONTracking No. ljy-8g7e-s48p Comments Due: December 22, 20Submission Type: WebDocket: NRC-2014-0223 Southern California Edison Company; San Onofre Nuclear Generating

Station, Units 2 and 3Comment On: NRC-2014-0223-0001 Southern California Edison Company; San Onofre Nuclear Generating

Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report14Document:

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

76) Fp- 6t66"t00Submitter Information Name: Ray LutzAddress:771 Jamacha Rd. #148El Cajon, 92019Email: raylutz@citizensoversight.org General Comment7 7The following comment is provided by CitizensOversight.

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

,- "Thank you -'--Ray LutzCitzensOversight.org i-] -oSee attached file(s)Attachments COPSQuestions on SONGS2&3_PSDAR&DCE SUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add= .x) ev-- ( Tuo,ý.)

Citizens' Oversight Projects (COPs)771 Jamacha Rd #148El Cajon, CA 92019CitizensOversight.org 619-447-3246 August 26, 2014NS' OVERSIGHT PROJEUCitizensOversightorg REVIEW OF POST-SHUTDOWN ACTIVITIES REPORT (PSDAR) AND OTHER DOCUMENTS RELATED TO THE DECOMMISSIONING OF SAN ONOFRE1. 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 isnow 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 stepstaken during SONGS 1 and the plans for SONGS 2 & 3. How is SCE safeguarding thisinformation 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 I4. 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 "SiteRestoration" tasks, which comprise seven more years. Together, these five line items compriseabout $2.4 billion.

These tasks should be broken down much further to allow the project to betracked 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 totalproposed to be spent each year.PERIODDESCRIPTION PERIODYRSCOST(lO00s)+/- + I-Decon Pd 3Decommissioning 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 andImplementation

• Purchase Dry Storage Canisters for GTCCWaste* Segment and Package Reactor Internals forStorage in the ISFSI6/30/2015 to6/1/20193.92$539,009I _ _ _ _ _ _ I I _ _ _ _ _ _

Decon Pd 4Plant Systems and Large Component Removal -"decontamination and dismantlement of SSCs knownto be substantially contaminated and the removal ofthe components from both Periods 3 and 4. "* Upgrade Rail Spur in Owner Controlled Area* Install Large Array Radiation Detection Systemto 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 FuelPool Island Equipment, and Bridge Crane* Remove and Dispose of Legacy Class B and CWastes* Remove, Package, and Dispose of Essential Systems" Removal and Disposal of Spent Resins, FilterMedia, and Tank Sludge" Large Component Removal" Prepare License Termination Plan6/1/2019to9/24/2022 3.31 1 $804,504-I ______ 4 ____________

Decon Pd 5Building Decontamination

-"decontamination of thevarious buildings.

As noted elsewhere it may be moreappropriate to simply proceed with dismantlement if itis more timely and cost-effective to simply dispose ofbuilding 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 MainSteam Isolation Valve (MSIV) Buildings

" Radiological Survey of Structures DuringDecontamination 9/24/2022 to7/13/2024 1.80 $429,106*1 i -iSiteRestoration Pd 4Building Demolition to Three Feet Below-Grade

• Demolition Preparations

• De-tension and Remove Containment BuildingTendons* Demolish Diesel Generator Buildings

• Demolish Condensate Buildings andTransformer Pads" Demolish Full Flow Areas and TurbineBuildings

" Demolish Auxiliary Rad-waste Building* Demolish Auxiliary Control Building* Remove Systems and Demolish Make-upDemineralizer Structures 7/13/2024 to10/14/2028 4.25 $259,066 000SSDemolish Penetration Buildings Demolish Safety Equipment and MSIVBuildings Demolish Fuel Handling Buildings Demolish Containment Buildings Demolish Intake and Discharge Structures SiteRestoration Pd 5Subgrade 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 InsideSeawall* Remove Off-shore Intake and Outfall Conduits" Remove Sheet Piling and Excavation Shoring,and Perform Dewatering and EffluentTreatment

• Finish Grading and Re-vegetate Site AsNeeded/Required 10/14/2028 to12/5/2031 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 notplanning on comparing the detailed cost estimate with the actual spending levels. Do you still planto 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, toaccommodate all the waste other than the high-level waste stored in the dry-cask storage facilityon 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 withall the reactor pressure vessels?9. Why is the transmission line switchyard not included in the decommissioning project?Sincerely, Raymond LutzNational Coordinator, Citizens' Oversight Projects As of: December 24, 2014Received:

December 22, 2014PUBLIC SUBMISSIONenmg_ost PUBLC S BMISIONTracking No. ljy-8g7e-s48p Comments Due: December 22, 20Submission Type: WebDocket: NRC-2014-0223 Southern California Edison Company; San Onofre Nuclear Generating

Station, Units 2 and 3Comment On: NRC-2014-0223-0001 Southern California Edison Company; San Onofre Nuclear Generating

Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report14Document:

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

76) Fp- 6t66"t00Submitter Information Name: Ray LutzAddress:771 Jamacha Rd. #148El Cajon, 92019Email: raylutz@citizensoversight.org General Comment7 7The following comment is provided by CitizensOversight.

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

,- "Thank you -'--Ray LutzCitzensOversight.org i-] -oSee attached file(s)Attachments COPSQuestions on SONGS2&3_PSDAR&DCE SUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add= .x) ev-- ( Tuo,ý.)

Citizens' Oversight Projects (COPs)771 Jamacha Rd #148El Cajon, CA 92019CitizensOversight.org 619-447-3246 August 26, 2014NS' OVERSIGHT PROJEUCitizensOversightorg REVIEW OF POST-SHUTDOWN ACTIVITIES REPORT (PSDAR) AND OTHER DOCUMENTS RELATED TO THE DECOMMISSIONING OF SAN ONOFRE1. 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 isnow 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 stepstaken during SONGS 1 and the plans for SONGS 2 & 3. How is SCE safeguarding thisinformation 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 I4. 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 "SiteRestoration" tasks, which comprise seven more years. Together, these five line items compriseabout $2.4 billion.

These tasks should be broken down much further to allow the project to betracked 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 totalproposed to be spent each year.PERIODDESCRIPTION PERIODYRSCOST(lO00s)+/- + I-Decon Pd 3Decommissioning 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 andImplementation

• Purchase Dry Storage Canisters for GTCCWaste* Segment and Package Reactor Internals forStorage in the ISFSI6/30/2015 to6/1/20193.92$539,009I _ _ _ _ _ _ I I _ _ _ _ _ _

Decon Pd 4Plant Systems and Large Component Removal -"decontamination and dismantlement of SSCs knownto be substantially contaminated and the removal ofthe components from both Periods 3 and 4. "* Upgrade Rail Spur in Owner Controlled Area* Install Large Array Radiation Detection Systemto 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 FuelPool Island Equipment, and Bridge Crane* Remove and Dispose of Legacy Class B and CWastes* Remove, Package, and Dispose of Essential Systems" Removal and Disposal of Spent Resins, FilterMedia, and Tank Sludge" Large Component Removal" Prepare License Termination Plan6/1/2019to9/24/2022 3.31 1 $804,504-I ______ 4 ____________

Decon Pd 5Building Decontamination

-"decontamination of thevarious buildings.

As noted elsewhere it may be moreappropriate to simply proceed with dismantlement if itis more timely and cost-effective to simply dispose ofbuilding 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 MainSteam Isolation Valve (MSIV) Buildings

" Radiological Survey of Structures DuringDecontamination 9/24/2022 to7/13/2024 1.80 $429,106*1 i -iSiteRestoration Pd 4Building Demolition to Three Feet Below-Grade

• Demolition Preparations

• De-tension and Remove Containment BuildingTendons* Demolish Diesel Generator Buildings

• Demolish Condensate Buildings andTransformer Pads" Demolish Full Flow Areas and TurbineBuildings

" Demolish Auxiliary Rad-waste Building* Demolish Auxiliary Control Building* Remove Systems and Demolish Make-upDemineralizer Structures 7/13/2024 to10/14/2028 4.25 $259,066 000SSDemolish Penetration Buildings Demolish Safety Equipment and MSIVBuildings Demolish Fuel Handling Buildings Demolish Containment Buildings Demolish Intake and Discharge Structures SiteRestoration Pd 5Subgrade 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 InsideSeawall* Remove Off-shore Intake and Outfall Conduits" Remove Sheet Piling and Excavation Shoring,and Perform Dewatering and EffluentTreatment

• Finish Grading and Re-vegetate Site AsNeeded/Required 10/14/2028 to12/5/2031 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 notplanning on comparing the detailed cost estimate with the actual spending levels. Do you still planto 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, toaccommodate all the waste other than the high-level waste stored in the dry-cask storage facilityon 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 withall the reactor pressure vessels?9. Why is the transmission line switchyard not included in the decommissioning project?Sincerely, Raymond LutzNational Coordinator, Citizens' Oversight Projects