ML20065T539
| ML20065T539 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/17/1990 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| P-90343, NUDOCS 9012280186 | |
| Download: ML20065T539 (33) | |
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Comparty of Colorado P.o Box 84o Denver co 80201 0840 December 17, 1990 fort St. Vrain Unit No. 1 A. Clegg Crawford va P,woeni d
P-90343 Nuclear Operstions U.S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C.
20555 ATIN: Mr. Seymour H. Weiss, Director Non-Power Reacto% Decommissioning and Environmental Projeci Oirectorate Docket No. 50 267
SUBJECT:
FORT ST. VRAIN DECOMMISSIONING FINANCIAL ASSURANCE
REFERENCE:
PSC letter, Crawford to Weiss, dated November 5, 1990 (P 90318)
Dear Mr. Weiss:
PSC submitted the Proposed Decommissioning Plan for fort St. Vrain Nuclear Generatir.g Station in the letter referenced above.
In preliminary evaluation of this submittal, the NRC has expressed concern over the level of detail provided for site specific decommissioning costs and for the lack of a funding plan to accumulate funds for those identified _ decommissioning costs.
4 Therefore, the purpose of this letter is to further address these NRC concerns regarding the cost of decommissioning, as understood by PSC, and to provide further clarification of PSC's position as presented in Section 5 of the Proposed Decommissioning Plan.
As identified in the referenced letter and Section 5 of the plan, PSC fully recognizes its responsibility to provide additional cost information (proprietary Tables 5-1, 5-2 and 5-3) and the decommissioning funding plan.
PSC plans to provide the proprietary tables by the end of 1990 and will provide a copy of the PSC/ Westinghouse contract and the decommissioning funding plan by or before mid-1991.
As noted in the referenced lett0r, PSC reaffirms its commitment to provide a copy of the final contract to perform decommissioning activities that is now being negotiued between PSC and Westinghouse.
Attachments to this letter, which are summarized bel ow, provide further PSC evaluations related to the acceptability of a firm fixed price contract in lieu of detailed decommissioning cost estimates.
PSC remains convinced that use of a competitive bid process involving four major decommissioning contractors, and a subsequent firm fixed price contract represents
- accuracy, commitment and f p{\\
provides a level of financial assurance significantly beyond that presented by a single detailed cost estimate.
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I P-90343 December 17,-1990 Page 2 Attachment 1,
Decommissioning Financial Assurance for fort St.
- Vrain, provides supplemental justification related to the acceptability of PSC's use of its decommissioning cost estimate based on the competitive bid process and award of a firm fixed price contract.
', PSC Competitive Bid Process and Award of fixed Price Contract, provides a detailed summary of the process used by PSC to fully define the secpe of the decommissioning effort and to select its decommissioning contractor, i, Comparison of PSC Decommissioning Cost Breakdown with Regulatory Requirements and Guidelines, contains a
detailed comparison of the contents of the Fort St.
Vrain Proposed Decommissioning - Plan with existing regulatory requirements and guidance.,
Proposed Work Breakdown Structure for the Fort St.
Vrain Decommissioning Project, provides the proposed Level IV project breakdown.
PSC and the Westinghouse team propose to provide a cost for each of the items listed in this proposed outline.
PSC is extremely proud of the innovative, thorough process that it has undertaken to identify the workscope and cost for decommissioning and to select the decommissioning contractor.
PSC firmly believes that this process is the most thorough used in the industry and that this approach will lead the nuclear industry in the use and selection of firm fixed price contracts for decommissioning.
PSC would welcome the opportunity to make a presentation to the NRC on PSC's competitive bid process, in order to demonstrate that the entire scope.of decommissioning activities has been identified, as well as share more specific information on the evaluation of the qualified decommissioning proposals.
If you have any further questions related to the Proposed Decommissioning Plan or would like to arrange a presentation on PSC's con.petitive bid process, please contact Mr. M. H. Holmes at (303) 480 6960.
Very truly yours,
/l hff s-A. Clegg Crawford Vice President Nuclear Operations ACC:CRB/cb Attachments
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P 90343 December 17, 1990 Page 3 cc:
Regional Administrator, Region IV ATIN: Mr. G.L. Constable, Chief Technical Support Section Division of Reactor Projects Mr. J.B. Baird Senior Resident-Inspector Fort St. Vrain Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health 4210 East lith Avenue Denver, CO 80220 l
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ATTACHMENT 1 TO P 90343 l
DECOMMISSIONING FINANCIAL ASSURANCE FOR FORT ST. VRAIN i'
I.
INTRODUCTION Decommissioning costs and the proposed schedule for submittal of the decommissioning funding plan to support the DECON alternative for Fort St. Vrain were provided in the Proposad Decommissioning Plan, forwarded to the NRC in Reference 1.
In Section 5 of the Propcsed Decommissioning Pl an, Public Service Company of Colorado (PSC) provided justification-that use of a competitive bid process and subsequent award of a firm fixed price contract will provide the requisite level of cost and funding assurance desired by 10 CFR 50.82(b)(4) and NRC Regulatory Guide 1.159
" Assuring the Availability _ of Funds for Decommissioning Nuclear Reactors" (Ref.
^
2).
However, followint preliminary evaluation of the Reference 1 cost-and ' funding p'an information, the NRC has expressed
-reservations over the -level of detail provided to support the
~ decommissioning cost. -Therefore, supplemental information in this attachment is provided to further amplify PSC's position that the competitive bid = process being used by PSC and a firm fixed price contract represent a significantly higher level of assurance in determining the cost of decommissioning than that provided by a p
-single cost estimate.
It:is PSC's opinion that over-reliance is placed on " detailed" cost estimates in which the site specific work sco)e has not been adequately identified, and that inadequate consiceration has been given to-other methods that will provide equiT; lent or greater assurances of~ identifying decommissioning cosis.
The NRC is requested to evaluate PSC's approach to determine if this-approach satisfies 'the ultimate intent of the rule, i.e., to adequately define the cost to decommission Fort St. Vrain.
The NRC -requirement' for detailed cost estimates is intended to provide assurance that realistic costs' have been identified for all anticipated activities proposed to be conducted under the purview of the--decommissioning -dismantlement plan.
However, PSC is convinced that the information provided in PSC's current cost breakdown (Ref.
1), together with the detailed description of associated activities,-
provide a significant level of assurance of the adequacy of the cost F
to' decommission Fort St. Vrain.
In that the proposed cost for the decommissioning is based on a firm fixed price, and the price has been independently verified by a competitive bid process, the focus of the NRC review, in PSC's opinion, should be on-the adequacy of the proposed dismantlement plan to fully define the scope of work to l
be performed during decommissioning.
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Attachment I to P-90343 December 17, 1990 Page 2 11.
UNCERTAINTIES IN DETAILED DECOMMISSIONING COST ESTIMATES During decommissioning planning efforts, some uncertainty existed on the part of PSC concerning the feasibility of dismantling and decontaminating the PCRV.
Therefore, PSC commissioned an outside third party consultant (Bechtel) to determine the technical feasibility of dismantling and decontaminating the PCRV using existing technology, or whether PSC should wait until more advanced techniques were available in the future.
This evaluation was particularly important since PSC did not have the benefit of generic evaluations of decommissioning techniques and costs, as commissioned by the NRC for PWRs and BWRs in NUREG/CR-0130 and NUREG/CR-0672.
The results of this independent evaluation were provided to the NRC in Reference 3.
The independent study clearly indicated that the technology now exists to dismantle the PCRV, and dismantlement can be performed at a reasonable cost.
This study, which included the technical approach and cost estimate, was evaluated by PSC, who deterained that the study fully evaluated the scope of work for PCRV dismantlement.
This study then served as a partial basis for the Request for Proposal that was sent to major bidders for competitive bid.
Bechtel was one of the four major bidders evaluated by PSC to be the potential decommissioning contractor for Fort St. Vrain.
- However, when evaluating a comparable scope of we * (PCRV dismantlement only, which is the significant portion of the decommissioning cost),
Bechtel's fixed price contract proposal was nearly double their original cost study.
The implications of this major difference between the fully dntailed cost. study and the actual firm fixed price proposal for a major contractor are significant.
The cost estimate for the original study was performed at a level of detail consistent with previous NUREGs and previously accepted decommissioning cost. estimates.
There were no significant changes in project scope (for PCRV dismantlement) contained in the RFP beyond those identified in the original cost study.
Howaver, this inconsistency represented a major contractor unwilling to use their own cost study in a fixed price arena without allowance for substantial margin for uncertainty, risk and profit, i
This difference leads PSC to question the reliance on a detailed cost estimate as the singular basis for assuring that the actual cost of deconnissioning nas been accurately identified.
PSC believes that the competitive bid process provides assurances beyond reliance on a single detailed cost estimate, in PSC's experience, each of the four qualified bidders performed detailed internal cost evaluations.
The four qualified bidders were willing to assume some of the risk inherent in their cost estimates by submitting firm l
fixed price proposals.
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o Attachment I to P-90343-December 17, 1990 Page 3 Based on the competitive bid process, the previous Bechtel study, and PSC's own engineering analysis, PSC is confident that the scope of work has been fully identified and was included in the firm fixed price proposals.
Secondly, based on these proposals, PSC is equally confident that the cost of decommissioning has been accurately identified.
Thirdly, based on an award of the firm fixed price contract together with PSC established contingencies, PSC is confident.that an upper limit has been placed on the maximum cost of decommissioning to PSC.. This is critical to PSC shareholders and any future negotiations with the Colorado Public Utilities Commission- (CPUC).
Lastly, based on PSC's own experience with a
" fully detailed cost estimate" and its relationship with the actual contract proposal, PSC is convinced that the "real" cost of
~ decommissioning has been identified, which is the ultimate intent of
~
the Decommissioning _ Rule and Reg. Guide 1.159.
Ill.
INHERENT PROBLEMS IN " CANNED" COST ESTIMATES Over reliance on detailed cost estimates can also lead to other potential problems.
Plants that select the SAFSTOR decommissioning alternative are allowed by 10 CFR 50.82(d) to submit proposed
- decommissioning L plans that.do not fully identify detailed dismantlement plans.
However, these same plants are also required to submit detailed cost estimates to " identify" the full cost of decommissioning.
This approach may result in submittal of. a-detailed cost estimate based on a. " canned" cost estimating. methodology, that will generate an acceptably detailed cost estimate. This. cost estimate implicitly generatess a "de facto" dismantlement plan,. although the - licensee
.will not prepare.their actual dismantlement plan until many years in
- the future. -Whene the-licenses's dismantlement plan is eventually -
prepared and submitted, the identified ' work scope may be substantially different from the -"de facto" dismantlement - pin on which the. cost estimate was based.
However, the NRC wor nave
- received a
" fully detailed" cost estimate with the proposed decommissioning plan on-which to base the NRC conclusion that the cost of decommissioning has been accurately estimated.
Therefore, a detailed cost estimate does not necessarily provide the necessary -assurance sought by the NRC to ensure that the cost of
--decommissioning is accurately identified.
If the licensee has not submitted a detailed dismantlement plan on which the cost estimate is based.. no such-assurance is available.
In PSC's case, a detailed dismantlement plan was submitted in Reference 1
that fully identifies-the tcchnology and costs of
_ dismantlement and decommissioning, and PSC.has selected a contractor willing to legally obligate itself to a contract and assume _ responsibility for satisfactory completion of the decommissioning project, as well as assume responsibility. for certain project cost overruns.
To PSC, this process assures that the intent of the Decommissioning Rule and Reg. Guide 1.159 are satisfied.
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Attachment I to P 90343 December 17, 1990 Page 4 IV.
CPUC PREFERENCE FOR FIRM FIXED MICE CONTRACTS In preliminary meetings to inform the Colorado _ Public Utilities Commission (CPVC) of its intentions, PSC approached each of the CPUC commissioners and identified options currently being evaluated for the-repowering of Fort St. Vrain.
Repowering is necessary to provide the funding to perform immediate dismantlement and decommissioning of Fort St. Vrain. These options were identified in Reference 1.. - Since Fort St. Vrain has been removed from the rate base, PSC must obtain CPVC agreement with the selected option prior to proceeding with repowering Fort St. - Vrain.
These repowering efforts will allow restart of the plant as a-fossil powered unit and, in turn, will-generate the necessary revenues (either directly from the rate base or indirectly from a power-purchase agreement) to fund the decommissioning of the radioactive ' portions of Fort St.
Vrain.
Therefore, PSC has a significant financial interest, in addition to its regulatory interest, in accurately representing the cost of decommissioning.
PSC also presented each CPUC commissioner with proposed plans for decommissioning Fort St. Vrain under the DECON decommissioning alternative, and identified the proposed terms. of the contract be' ween PSC and 'the -Westinghouse team to decommission the plant.
Based on these conversations, PSC believes the CPUC commissioners -
would have a preference that options to repower and to decommission Fort St. Vrain should be based on fixed price contracts.
The CPVC commissioners do not desire further financial exposure of ratepayers
'as a result of Fort St. Vrain.
As 'noted inl the Reference 1, without decommissioning funding from revenues generated-from a repowered Fort St. Vrain, PSC will be unable to finance the DECON alternative and it will be necessary to select the SAFSTOR decommissioning alternative for Fort'St. Vrain.
V.
USE OF PREFERRED INDUSTRY AND GOVERNMENT CONTRACTING PRACTICE It is also important to note that the PSC approach to awarding the decommissioning contract is no different than the approach typically used-by both private industry and Federal government contract administrators. J-The agency or _ firm desiring a contract for a product or service identifies its need and prepares a work scope specification and_ an internal cost estimate on which to evaluate the validity and reasonableness of contract _ proposals.
The agency or L_
firm-then advertises its-RFP and specifies its contractual a'rrangements, such' as the following common contract types: firm fixed price, time and material (T&M), or cost plus fixed fee (CPFF).
Of these contract types, there is a distinct buyer preference for a firm fixed price contract over either T&M or CPFF contracts.
Major government agencies (e.g.,
000 and DOE) are under strong congressional pressure to restructure major contracts to be firm fixed price contracts, in order to limit future government contract p
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, to P-90343 December 17, 1990 Page S
-liabilities and prevent contract overruns.
With a firm fixed price contract, responsibility for satisfactory completion of the contract is shared between the contractor and the contracting agency:
the contracting agency is responsible for ensuring that the scope of work is accurately and completely defined, and the contractor is responsible for ensuring that all costs have been properly estimated and are included m the proposal.
Once the internal cost estimate has been completed and proposals have been received from qualified bidders, the proposal prices are compared with the internal cost estimate.
Proposals that are either too high or too low may be determined to be unresponsive to the contract,- and disqualified at that point.
Typically the remaining bidders ("short" list) may be asked to present their proposals to the contracting authority, and - may_ be offered an opportunity to refine and resubmit their proposed price.
The government contracting authority will then award the contract to.the successful low bidder.
In private industry, there is no requirement to award the contract-to the lowest bidder, and in fact PSC did not award the contract to the lowest bidder.
Since--the contrntor assumes more risk in a firm fixed price contract, an appropriate risk premium is sually included in the contractor's-proposed price.
Therefore, assuming the project scope has been properly evaluated and included in the awarded contract, the contracting authority has greater confidence that the product or service will be performed for' the proposed price under a firm fixed price contract than for other. contract types.
This fact became readily apparent-during PSC negotiations with bidders who ' submitted proposals-f r decommissioning of Fort St. Vrain. -As part of the Request for. Proposal, PSC requested that each proposal be basea on a
' firm fixed price contract.
However, due to the bidder's reluctance-to commit to a firm fixed price, only one of the four qualified proposals was originally submitted on a firm fixed price basis.
Subsequently, PSC restated--its request ar.J received a firm fixed price quote from each of the three remainir.g qualified bidders.
It-is significant to note that when required to submit their firm fixed price bids, the bid price for two of the tnree bidders increased an average of 37% to compansate them for the added risk and increased responsibility to properly complete the project.
In the spacific case of Fort St. Vrain, the Westinghouse team was selected over other' qualified bidders, despite submitting a proposal with a proposal price in excess of other competitors.
The Westinghouse team was selected since their method 'of dismantlement was least sensitive to' errors in the activation analysis and radiation levels, and the Westinghouse team was the most willing to share the risks involved with decommissioning and repowering of fort St. Vrain.
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, -to P 90343 December'17, 1990 Page 6 VI.
DISCLOSURE OF DETAILED CONTRACTOR PRICING INFORMATION PSC is concerned about submission of more detailed pricing information for three important reasons-
- 1. Disclosure of detailed aricing data, even though submitted on' a confidential bas's, could represent a significant competitive advantage if it were disclosed to other competitors.
2.' Fixed orice bids are, by their very nature, based on a definec' and comprehensive work scope.' If this work scope is correct (and PSC-hcs spent months with different, independent contractors defining this ' work scope), this process is a-substantial improvement over oetailed cost estimates that are computer generated and frequently based on -inadequate work scopo definition.
Moreover, assuming the-. defined work scope is correct, Westinghouse has the contractual liability for all cost overruns.
- 3. PSC ' believes' that to now submit an estimate in a format akin to that-prepared fcr Pathfinder cannot realistically provide any further assurance to the NRC regarding the-decomissioning costs for fort St. Vrain that approaches
-the process followed in the competitive bidding on a firm fixed price basis.
PSC _ recognizes __ that, at:this time, the NRC does 'not have the level of. detail necessary.to evaluate th'e fixed price contract.
PSC has committed to_ provide the contractual details as soon as the contract negotiations-can be culminated.
Contract negotiations ~- between PSC and the Westinghouse. team to finalize terms of the decommissioning are still in progress.
Disclosure among the parties of such pricing data, _ which would be necessary in order to provide.the needed breakdown to thet NRC, could create significant barriers to
-succersful: conclusion of 'the contract negotiations as described above.- Once the contract has been finalized, PSC will forward
. additional-cost information in a level of detail comparable. to the most recent -Westinghouse _ team proposed work breakdown structure, contained in__
Attachment:
4.
'VII..
USE OF ALTERNATIVE COST ESTIMATING METHODOLOGIES
.Another area of PSC concern is the NRC's insistence on the form and contents-of a detailed decommissioning cost estimate.
NRC's own guidance in Reg. Guide 1.159 clearly states that - "(s)tudies other than the PNL or ORNL studies may be used to estimate decommissioning costs.
-The reasonableness of the estimate should be shown by indicating the bases used, and the principal assumptions used in the estimate...".
l to P-90343 December 17, 1990 Page 7 Contrary to the above, to date only one cost estimating methodology, based on computer generated estimates prepared by one decommissioning contractor, has been accepted by the NRC which is inconsistent with the guidance provided in Reg. Guide 1.159.
As an aside, this decommissioning contractor was also heavily involved in the preparation of the PNL studies in which the NRC established their preferred methodology and level of detail for cost estimates.
Vill. CONCLUSION The use of the competitive bid process and award of a firm fixed price contract is not a new approach, but rather is an acceptable and proven industry contracting approach, although it is somewhat dif ferent from the customary cost information and the prescriptive methodology typically received by the NRC to document cost estimates for decommissioning.
The NRC appears to be overly focussed on one detailed cost estimating methodology rather than the overall intent of the rule, which is to ensure that decommissioning costs are fully identified and funds will be available to meet these decommissioning costs.
PSC believes that regulatory requirements and guidance provided by the Decommissioning Rule. NRC regulatory guides, and NRC staff interpretation of this guidance should not be so restrictive as to preclude licensees from alternative approaches es allowed by Reg.
Guide 1.159, thereby effectively pre 1uding licensees from the same options available to the NRC in the NRC's own contract proceedings.
It appears that the NRL's position is that a licensee cannot be assured of identifying all decommissioning costs unless a specific type of cost estimate has been prepared.
This specific type of cost estimate is "not" endorsed in any published regulatory guidance.
The original Bechtel study, in conjunction with PSC's own studies, provided PSC with a basis for evaluating submittals provided during the competitive bid process.
The full project scope was determined in the RFP and during the research period prior to the contract award.
PSC has complete confidence that-all required decommissioning actions were adequately identified and will be included in the final Westinghouse contract.
Use of the competitive bid process requires bidders to be responsible for estimating costs to support this scope of work. The Bechtel study and cost estimate, along with four fixed price bids, provide PSC with assurance that the successful bidder did not underestimate decommissioning costs.
It is important to note that the NRC review and concurrence with a detailed cost estimate does not automatically infer that a
contractor can or will be found that will perform the decommissioning for the estimated amount.
To the contrary, PSC has found that even if a detailed cost estimate is available, there exists in the decommissioning scenario sufficient uncertainty, risk and profit consideratim: to increase the actual decommissioning cost above the v> L of a detailed cost estimate.
Attachment I to P 90343 December ll, 1990 Page 8 PSC recognized, when filing the Proposed Decommissioning Plan, that a level of cost detail beyond that presented would be required for both the
't estimate and the funding plan.
In this respect, PSC committc-crovide additional information as soon as it became availabh
~C commits to provide the following information:
- 1. A copy of the final negotiated contract between PSC and the Westinghouse team for decommissioning containing the contractual provisions, the work specification, and the work breakdown schedule.
- 2. Contract costs consistent with the work breakdown schedule (see Attachment IV), with supporting assumptions.
- 3. The detailed funding alan as soon as possibic after selection of one of tie four options outlined in the Proposed Decommissioning Plan for the repowering and decommissioning of Fort St. Vrain.
PSC submitted the Proposed Decommissioning Plan with full awareness of the above commitments, based on a high level of confidence in the cost -information provided during the fixed price proposal process.
In PSC's opinion, there is more than sufficient information available to the NRC to continue -its review of the Proposed Decommissioning Plan while awaiting the additional information identified above.
PSC is _ also concerned that the mandatory disclosure of detailed confidential pricing information to licensees and others will make it extremely difficult for other utilities in the future to obtain firm fixed price proposals for decommissioning, once bidders realize that detailed costing data must be released.
Moreover, in PSC's opinion, firm fixed price contracts are preferable to CPFF or T&M contracts, in which all or nearly all of the financial exposure is retained by the utility or federal government and is not contractually shared by the contractor.
CPFF contracts will tend to push utilities into SAFSTOR, and the cost exposure in 50 years is potentially many hundreds of times greater than for immediate dismantlement (DECON).
In summary, PSC reiterates its position that the use of the competitive bid approach has fully defined the scope of work to be-accomplished during the decommissioning effort, and use of a firm fixed price contract has placed an upper bound on the cost of decommissioning to PSC.
Such an approach provides financial assurance beyond those assurances provided by a single detailed cost estimate without either a defined workscope or a contractor's obligation to meet that estimate.
Therefore, it -is PSC's position that preparation of a detailed cost estimate is not necessary to meet the underlying intent of the regulation.
The approach
-.=
Attachment I to P 90343 December 17, 1990 Page 9 identified in the Fort St. Vrain Proposed Decommissioning Plan, use of the competitive bid process and award of a firm fixed price contract, achieves the underlying purpose of the rule, i.e.,
to identify the real cost of decommissioning and provide financial assurances that funds will be available to pay for the decommissioning costs, j
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Attachment I to P-90343 December 17, 1990 i
Page 10 REFERENCES 1.
PSC letter, Crawford to Weiss, dated November 5,
1990 (P90318) 2.
NRC Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors", August 1990.
3.
PSC letter, Crawford to Weiss, dated May 1, 1990 (P 90124) i i
a
2 ATTACllMENT 2 TO P 90343 PSC COMPETITIVE HID PROCESS AND 1
AWARD OF FIXED PRICE CONTRACT 1.
Introduction
'PSC firmly believes that it has undertaken one of the most innovative and thorough processes -to define the scope of decommissioning for Fort St.
- Vrain, and to select its decommissioning contractor.
This process took approximately 12 4
months to prepare -and validate the Request for Proposal, allowed four months for contractors to respond, and took an additional three months for PSC to evaluate the proposals and select its decommissioning contractor.
The following were key steps involved in the competitive bid process which will be' described in further detail in the following paragraphs:
't 1.
Preliminary Technical feasibility Studies
_2.
Development of the Decommissioning Request for Proposal 3.
Proposal Solicitation and Bidder Onsite Visits 4.-
Formal Bidder Presentations 5.
Proposal Evaluation 6.
PSC Corporate Evaluation and Decommissioning Contractor l
Selection PSC believes that the process that was used is the most thorough that has been used in the industry.
In PSC's opinion, use of the
- t competitive bid process will establish an indv*try precedent to allow use of firm fixed price contracts for dec W m ioning.
11.
Preliminary Technical Feasibility Studies During exploratory decommissioning planning efforts, PSC initiated a decommissioning study for the dismantlement of the Prestressed Concrete-Reactor Vessel: (PCRV) with the assistance of the Bechtel Corporation.
- This study was necessary since some uncertainty existed on the part of-PSC concerning the feasibility o f-dismantlement' and decontamination of the PCRV.
In parallel, PSC-internally evaluated decontamination and dismantlement of other contaminated systems external to the PCRV.
The Bechtel-study was initiated in August 1988 ard was completed in January 1989.
Results of the. associated Bechtel cost estimate included identification of estimated costs and work scope to dismantle the PCRV, as' well as costs to remove major-PCRV internal o
components, including the core barrel, core support floor, and steam l'
generator modules, for PSC, the study results affirmed that the technology was now available to dismantle the PCRV, and that dismantlement could be performed at a reasonable cost, p
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. to P-90343 December 17, 1990 Page 2 111. Development of the Decommissionina Recuest for Proposal At this time, other significant events were occurring with respect to the future of Fort St. Vrain.
In December 1988, based on economic considerations, PSC informed NRC that it was PSC's decision to permanently shutdown and decommission Fort St. Vrain, and that power operations would be be terminated not later than June 30, 1990.
Therefore, once the Bechtel study was received in January 1989, PSC began planning efforts for eventual decommissioning of Fort St.
- Vrain, and a decision was made to begin preparation of a
comprehensive Request for Proposal (RFP).
The quantities and types of material involved were estimated for the PCRV, PCRV internals, and each radioactive system for inclusion in the RFP.
Detailed radiation survey data was included, as well as a detailed listing of system piping and components (quantitles and related information, such as pipe and valve sizes and pipe lengths were included).
The RFP also presented detailed requirements regarding use of existing plant equipment and services, regulatory guidance, responsibilities for PSC and the contractor, programmatic requirements (quality assurar n, radiation protection, waste e nsa m nt, ranfiguration control, etc.), and project management requirements (work breakdown structure, scheioling, change control, cost control, etc,),
i.e.,
the RFP ident ified the complete work scope.
In thc Bechtel study, several methods were evaluated for removal of the PCRV internal components and for dismantlement of contaminated portions of the vessel i tsel f.
Although the Bechtel study was utilized as a major source of input data, the RFP did not specify a preferred method to dismantle the PCRV and the RFP allowed bidders to evaluate the best methods available.
This data was then utilized in the development and preparation of the RFP for the dismantlement, decontamination and decommissioning af Fort St. Vrain.
in addition to the decision to permanently shutdown Fort St. Vrain, other significant decommissioning milestones occurred during this period:
June 30, 1989:
PSC submitted the Preliminary Decommissioning Plan to the NRC based on the SAFSTOR alternative.
August 29, 1989: The PSC Board of Directors af firmed the PSC management decision to permanently shutdown Fort St. Vrain following a malfunctioning control rod incident and identification of significant cracking in the steam generator ring headers.
i
. to P 90343 December 17, 1990 Page 3 IV.
proposal Solicitation and Bidder Onsite Visits During preparation of the decommissioning RFP, PSC preselected nine potential contractors who possessed the technical qualifications, experience, and financial resources necessary to dismantle and decommission Fort St. Vrain.
By letter dated October 20, 1989, PSC notified each of these companies of the upcoming RFP, and solicited a statement of technical qualifications if the prospective bidder was interested in bidding on the decommissioning effort, so that PSC could pre-qualify each of the bidders.
Based on the statements of qualification received from these companies, PSC eliminated two of the nine potential bidders, resulting in a bidders list of seven qualified bidders.
PSC completed and issued the formal Request for Proposal to these seven qualified bidders on Dember 8, 1989.
Issuance of the RFP followed _ an exhaustive effort to define the scope of the decommissioning effort.
Bidders were requested to provide proposals by April 2,1990, to respond to the qllowing six decommissioning and conversion options:
- 1) dismantlement / decommissioning (D&D) of the PCRV only; D&D of radioactive systems only; D&D of site environs only; combined D&D of
- PCRV, radioactive systems and site environs; (5) combined D&D of PCRV, systems and site, and conversion of balance of plant to fossil fuel; and (6) anv entrepreneurial approach the bidder might desire to precent.
Of these initial seven qualified bidders, one withdrew from further consideration and two bidders chose a teaming arrangement, resulting in five remaining qualified bidders.
In order to support the bidders during preparation of their proposals, PSC established an extensive reference library, complete with all available plant drawings, system descriptions and construction specifications for use by the bidders.
This was in addition to detailec drae.ings provided in the RFP.
Additionally, PSC scheduled a one-week visit at PSC offices and the fort St. Vrain site, to allow each bidder to individually review information in the reference library, ask specific detailed technical and financial questions, and to conduct site walk downs. Each of the five bidder teams participated in these visits, and each bidder typically sent an average of 8 to 10 technical and management individuals.
During these visits to PSC offices and the Fort St. Vrain site, PSC provided senior PSC plant personnel whose time was dedicated to assist the bidders during plant walk-downs, answer technical questions, and locate information or drawings requested by the bidders to support their bid proposals.
Additionally, during follow-on preparation of the bidder proposals, PSC responded to
1 I
3 to P-90343 December 17, 1990 Page 4 subsequent written requests for additional information for each bidder.
PSC continued to track the progress of each bidder to ensure that the proposals would be complete and rer onsive to the entire scope of work.
Since the RFP had specified firm fixed price bids, the bidders requested and were provided a significant level of detail regarding the plant
- design, physical layout and radiation /
contamination history.. As a result of the ' site visits and requests for supporting information from five independent bidders, PSC is 1
- extremely confidu c that the entire-scope of work was identified and included in each of the bidder's proposals.
.V.
Formal Bidder Presentations I
Proposals were received from each of the five remaining qualified firms in response to the RFP. -In each case, the bidder presented detailed descriptions of the approach and techniques which would be utilized for decommissioning of the PCRV and contaminated systems and descriptions of the specific programmatic systems that would be instituted for quality assurance, radiation protection, waste management,. waste shipping and disposal, work control, personnel health _ and safety, configuration control, and purchasing.
c L Each of the proposals.~ involved teaming arrangements between major companies based on specific areas.of expertise.-
It is significant to note, that these teaming arrangements included two major British firms and the. Central Electric Generating Board ~ (CEGB) from-Great 1
Britain.- These British firms are currently involved.in planning for the decommissioning of 14 gas cooled reactors in the United Kingdom.
Therefore.. the competitive bid process has allowed PSC. to benefit
.from their experience in identifying and resolving problems identified 1n their decommissioning planning process.
A11'five proposals were responsive in detail descEibing the methods of-achievingL _ compliance- - with-federal -regulations and the requirements to be implemented in the various programs _ and project
- j.
controls.
Each 3roposal contained, in response to 'the RFP l
requirements, a-celineation of any significant assumptions or (qualifying conditions made in establishment of the fixed price.
l Proposals were received from each of the five--qualified bidders on-the bid -deadline of April 2,
1990.
Following receipt of the proposals, the proposals were issued to internal-PSC review groups to begin prelim _inary review of each of-the proposals.
A-formal -PSC bid evaluation--team - was established to -evaluate each of the proposals, comprised'of technical, licensing, radiation protection, q
.. transportation, and financial experts 'within PSC.-
To familiarize the bid evaluation team and PSC management with l
- contents of 'the-proposals, each of the five bidders were requested Lto _make a formal-presentation of their proposal to these key PSC
~... -
- to P 90343 i
December 17, 1990 Page 5 i
personnel, and allow PSC to ask direct questions in any area related
- to' the bidder's proposal or qualifications to perform the decommissioning effort.
Each of these presentations lasted approximately eight hours.
During the formal bidder presentation, each bidder outlined the principal elements of their proposal, including the decommissioning approach, methodology and equipment, to ensure that the evaluation team. fully understood the scope, assumptions and pricing of the proposal.
To support them during the presentation, each of the bidders typically brought in its proposed management
- team, representatives from other joint venture companies, and technical experts who could address specific details of their decommissioning
. plans.
Each bidder also brought in financial experts to address the-proposed methods to finance the decommissioning and repowering efforts.
4 To indicate the. high. level of attention these evaluations received
- within PSC, W.tl of the presentations was attended by PSC's Senior Vice President of Electric Operations,_ the Vice President of Nuclear Operations, and the Vice President for Engineering and Planning, as
- well as approximately 40 other PSC nuclear operations management and technical staf f.
VI.
Proposal Evaluation a
Of. the five proposals that were received, one. bidder was immediately determined :to be non responsive toi the RFP and was notifled that their proposal would no longer be considered, leaving four qualified i
- proposals that were carried through-to final evaluation.
Of the
- four remaining proposals, only one proposal (the original Westinghouse - team-proposal) was responsive to the RFP _ request to submit a. firm fixed price bid.
l Therefore, PSC requested - that-each of the remaining three bidders submit a-firm fixed price bid for their-proposal or be dropped from further consideration.
Each of these three bidders' then provided.a firm fixed _ price - proposal.
It is significant to note that when 1
required to submit firm fixed price bids, the outcome cannot be
=
predicted.-
In = PSC's - case, the bid orice for two of' the three bidders increased an averaae -cf 37L while the third bid price remained the samellt:
Following the presentation and responses to-PSC questions on each r
proposal, PSC's ' bid evaluation team proceeded -to breakd',wn-and i
evaluate each of the-four remaining proposals.
The bid evaluation team. evaluated each proposal with respect to the-scope of work, methodology' and approach, compliance with regulatory requirements, project = management and: controls systems to be utilized, proposed terms and conditions, pricing basis and associated assumptions, and any unique qualifying conditions.- Each proposal was individually evaluated, and then cross-comparisons were made with other proposals
. to P 90343 December 17, 1990 i
Page 6 in the above evaluation areas.
Comparisons were also made with the original feasibility study and other estimates developed as a precurser to the RFP.
Proposals were technically evaluated in the following areas: (1) overall decommissioning approach; (2) PCRV concrete, liner and insulation removal; (3) PCRV core barrel removal; (4) core support floor removal; (5) removal of core region components; (6) removal of v
lower pienum elements; (7) radioactive waste handling and i
processing; (8) contaminated system plans; and (9) site cicanup plan.
1 Following technical evaluation, other non-technical issues were also evaluated, including corporate commitment, experience, proposed project management, and completertess and quality of the proposals.
Each of these factors were weighted, with technical approach and experience receiving 70% of the final weighted value.
As questions arose during the bid evaluation, formal letters were sent to the bidder; requesting additional clarification or information.
During the evaluation period, the sensitivity of assumptions regarding the amount of material or components to be removed, the waste volomos and contamination or radiation levels were discussed with the bidders.
These discussions and the evaluation of the response to the formal questions were an important final step in the bid evaluation process to ensure that the proposed fixed prices fully covered the decommissioning work te be accomplished.
The remaining four proposals were evaluated in detail over a two month period in the above areas.
Each of these four proposals were also normalized or levelized to the extent possible, in order to base evaluations and decisions on comparable waste
- volumes, transportation distances and other key assumptions, such as taxes, insurance costs, and PSC performed activities.
The bid evaluation team prepared a detailed assessment of the four
' i remaining proposals, and forwarded the results of this evaluation to t
a PSC management team.
The bid evaluation team recommended two vendors as being essentially equal in the overall evaluation.
Of the two recommended proposals, one utilized a dry method for PCRV dismantlement and the other utilized a wet method (PCRV filled with water).
The proposals were compared after the total fixed price for each proposal had been adjusted and levelized in those areas identified above.
Although a variation of 31% existed in the total evaluation of the final four bidders, a variation of only 5.5% existed for
?
three of the four proposals.
Between the top two proposals, u variation of only 3% was present.
Additionally, there was only a variation of 2.25% in the top three proposals based on levelized net present value of the proposals.
These variations were determined I.
. to P 90'43 December 17, 1990 Page 7 using the total fixed price of each proposal, which included both the cost of decommissioning and of conversion.
The small variation in the overall project costs may be attributable to minor differences in assumptions and allocation of costs between decommissioning and conversion portions of each proposal, and serves to reinforce PSC's confidence in the validity of the decommissioning cost.
Vll. ESC Coroprate Evaluation and Decommissionina Contract 2r Selection This PSC corporate management team consisted of high icvel corporate officers, including the Senior Vice President of Electric Operations and the Vice President for Nuclear Operations.
This management team further evaluated the proposals on additional factors, such as conversion, financing and willingness to share risk or risk aversion on the part of the bidder.
Of the two vendors recommended by the bid evaluation team, the PSC management team selected one of the two remaining bidders and made a final recommendation to PSC's President and Chief Executivr Officer and to the PSC Board of Directors.
s The PSC Board of Directors affirmed the recommendation to proceed with early dis 9antlement (DECON), and the Westinghouse team was notified of their winning proposal on July 2,1990.
Additionally, it is noted 'Aat the winning Westinghouse proposal price was not the lowest fira fixed price proposD.
Vill.
Summarv of Contractor Selection Praten As demonstrated in the previous paragraphs, PSC employed a
multi step process to select a qualified bidder and establish a firm fixed price for the decommissioning effort.
Based upon this process, PSC is convinced that the decommissioning work scope, compliance with regulatory requirements and costs associated with labor, equipment, materials, permits / fees and administration, and the technical support necessary to complete the work have been adequately captured by the bidders in their firm fixed price proposals.
Clearly, with a project of this magnitude and its potential liabilities, the bidders have taken extraordinary care in the development of the proposed work and associated internal cost estimates to ensure that the resultant firm fixed price proposal adequately covers their exposure.
The process of competitively bidding on a firm fixed price basis, together with the detailed pre-bid preparations and post-bid evaluations to ensure that the bidder has adequately captured and responded to the scope of work, represents a comprehensive and thorough method of assuring PSC and the NRC that the decommissioning costs have been completely identified.
.+
NITACIIMENT 3 TO P 90343 COMPARISON OF PSC DECOMMISSIONING COST HREAKDOWN WITH REGULATORY REQUIREMENTS AND GUIDELINES 1.
REGULATORY REQUIREMENTS:
The. requirement for an updated decommissioning cost estimate is identified in 10 CFR 50.82(b)(4), which specifies the following:
"The proposed decommissioning plan must include -
d(4) An Updated cost estimate for the chosen alternative for ecommissioning, comparison of that estimate with present funds set aside for decommissioning, and plan for assuring the availability of adequate funds for completion of decommissioning."
PSC Resoonse:
An updated cost estimate was prepared by PSC.
Use of the competitive bid process and subsequent award of a firm fixed price contract for decommissioning provides assurance that the scope of-docommissioning activities has been completely identified and that the real cost of decommissioning has been identified.
Additionally, by receiving four fixed price bids and awarding a firm fixed price contract, PSC has proceeded further than performance of a single detailed cost estimate.
Moreover,_
selecting-and contractually obligating a
decommissioning contractor. to perform the specified scope of work is in the best interests of PSC, the State of. Colorado, and the NRC.
-II.
DRAFT REGULATORY GUIDE DG-1005 GUIDANCE:
Additional guidance contained in NRC Regulatory Guide DG-1005
" Standard Format and Content for Decommissioning Plans for Nuclear Reactors", Section 5, is' limited to the-following guidance on cost information to be, submitted with the Proposed Decommissioning Plan:
'the' licensee should present an updated cost estimate as l
required by paragraph 50.82(b)(4) based on the detailed information submitted in this plan."
ESC Response:
As noted-above, a cost estimate has been performed.
- Moreover, a suitably detailed dismantlement plan for Fort St. Vrain has been prepared and was included in Reference 1 of Attachment 1.
..-r
-.m 9
-e--
w-
+
e
. to P-90343 December 17, 1990 Page 2 Additionally, a proposed scope of work was identified in Appendix 1 of t ie Proposed Decommissioning Pl an, and PSC committed to provide the NRC with a signed contract when contract negotiations have been completed.
Therefore, although a " detailed" cost estimate is not available, the detailed dismantlement plan and completed contract will provide 1
sufficient assurance that the entire scope of decommissioning efforts are Mentified.
111. Reaulatory Guide 1.159 Guidance further guidance regarding decommissioning costs is provided in NRC Regulatory Guide 1.159, " Assuring the Availability of funds for Decommissioning Nuclear Reactors" (Attachment 1, Ref. 2).
In its
" Introduction", Reg. Guide 1.159 states:
"As a guidance document, this regulatory guide and its provisions are not designed to be restrictive or to represant binding requirements.
The guide presents methods acceptabic to the NRC staff for complying with the decommissioning regulations.
The NRC staff recognizes that in certain circumstances (e.g.,
to meet requirements estabitsbed by Federal or State economic regulatory agencies or to comply with other applicable laws) other approaches may be necessary."
PSC Response:
The contents of the Proposed Decommissioning Plan have also been compared to the guidance contained in Reg. Guido 1.159, which clearly states that its provisions are not designed to be restrictive or to represent binding requirements.
Due to the premature shutdown of Fort St. Vrain, and the fact that all i
delays and resultIng costs are borne by the PSC shareholders, PSC has expedited the process to select a contr, 'or to decommission Fort St. Vrain.
PSC designed a process, consistent with standard industry and government contracting practices, which it felt would define the complete scope of decommissioning and dismantlement activities and provide both PSC and the NRC with sufficient assurances that the associated costs of decommissioning would be accurately defined.
This process was more detailed than a single detailed cost estimate through involvement of five major contractors bidding on the proposal.
Knowledge that their internal cost estimates would be used as the basis for the firm fixed price contract on a specific decommissioning scope of work provided PSC with firm assurances that the cost of decommissioning was adequately defined.
l~
4 4 =,:
i to P-90343 December 17,-1990 Page 3:
-A-Determination of Reasonableness of the Estiptn Section C,
1.4.1, of Reg. Guide 1.159 ("Regalatory Position")
specifies that:
' cost estimates for specific reactors may be developed using, as a
- basis, the studies perfcrmed by Battelle PNL and ORNL."
Reg. Guide 1.159 further specifies-that:
- studies'other than the PNL and 0RNL studies may be used to estimate decomissioning costs.. The reasonableness of the estimate:should be shown by ^indicaling/ the bases used (e.g., NUMARC -(formerly Alf) studies,' other generic studies, ifcensee model, -recent experience),
and the principal assumptions used in the estimate..."
PSC Response:
Contrary::to the-above, to date only one cost estimating methodology, based on computer generated estimates preparedlby one! decommissioning contractor, has been accepted by-the NRC which:is inconsistent with the guidence provided in Reg. Guide 1.15g.
it is PSC's. ' opinion that inadequate consideration Sas been given to other methods -that will provide. equivalent or greater assurances Lof identifying decommissioning - costs.
Il e NRC is requested to evaluate PSC's: approach, as PSC is-cony'nced that its- _ approach satisfies the; ultimate intent of the r ale, i.e.,
~ toldequately define the cost to decommission fort S'. Vrain.
B.
General Cost Estimate Considerations:
-In1 preparing cost estimates _ for decommissioning, Reg. Guide :1.159 directs that:the following general considerations be evaluated:-
L1.-
Estimates should.be-based on: technology current at the time the-
- estimate is' prepared.-
L2, The estimate should-indicate. the year's ~ dollars on which the costs are basedt 3 '. -
Estimates should-beibassd on existing guidance and criteria on p
tresidual radioactivity and occupational exposure, PSC Respons e y
The Proposed Decommissioning Plan is fully responsive to the
. general considerations identified in Reg
Guide 1.159,,
-paragraph-l.4.3 specifically:
3 L
(1)
PDP Section 2.3 demonstrates that all proposed activities-F rely on generally accepted industry practices.
All m
+--~4
-v n
er w'y<d
3p y :to P-90343 December 17, l e n Page_4 practices and techniques proposed for use are being used and have received extensive experience in the U.S. nuclear industry and in the United Kingdom.
(2) The basis-(year) for the costs is appropriately identified to be based on future value dollars in the year in which the expenditure is made; and (3).PDP Sections 2.3.6-and 4 clearly identify the criteria for residual: radioactivity-and occupational exposure.
C.
Snm ific Cost Estimate Considerations:
-1 In addition-to-the general considerations identified above, Reg.-
Guide 1.159 - specifies _that cost estimates should' consider the following:-
4 1.-
1 Planning; and: preparation o f.
the facility and site for decommissioning.
2.
Decontamination-and dismantling of radioactive facility structures, systems, and components.
7 3-Packaging,L shipment,. and burial of radioactive wastis.
4 '.
The final radiation survey.
PSC Response:
The Proposed Decommissioning Plan is also folly responsive to
- the description' of cost 1 estimate details (-
- . Guide 1.159, 1.4.4;-
1(1) Activities related to the planning.and preparation /
the facility and site'are identified in-PDP Section 2.
and i
Appendix _I.-
Further breakdown' of the costs for.nese
-activities; a ill' be provided
-in-PDP.
Table: 2-w (proprietary).-
(2)- A; detailed dismantlement plan is provided in PDP--Sections y.
2.3.3: and 2.3.4. L Activities related to< decontamination of the ' radioactive-facility to ' levels _ which = will allow release for~ unrestricted.use lin accordance' with NRC interim guidance _are identified in PDP Sections 2,3 and 4'.
Costs for these activities-'wili -be provided in PDP Table:
.5.-2 (proprietary).
-(3).- Activities' related to packaging, shipment and bJrial ' of g
radioactiveEwastes are identified-in PDP Ser ion 3.3.3.
+
Costs-for -these activities will be :provided iv PDP Tables 5-2.and'5-3,(proprietary).
-(4)1' ActivitiesL related to the final radiation survey are identified 'in PDP Section 4 and associated costs.will be J
provided in~PDP Table 5-2-(proprietary).
A i
N
-=
9 6 i
l to P-90343 December 17, 1990 Page 5 D.
Principal Cost Estimate Factors:
If studies other than those performed by PNL and ORNL are used in developing costs for the above activities, Reg. Guide 1.159 directs that a summary be included that indicates the principal factors used in the estimates.
The following principal factors should be included:
1.
Estimated radiological conditions at the time of facility shutdown, including radionuclide inventories and component and surface dose rates.
2.
Inflation between the time the studies were completed and the time the facility-specific cost estimate is made...
O.
Major facility design and layout differences from the studies that could significantly influence decommissioning costs.
4.
The cost of labor: estimated staff-years and bases; unit costa of labor specific to local n use af contractors and effect on labor costs.
5.
The cost of energy: estimated energy usage and bases; unit
. costs of energy for electricity and fuel oil specific to locale.
6.
Waste disposal costs: estimated number af containers and casks; shipments to be made; burial volumes; special charges; differences in transport distances from those indicated in the PNL study and effects of escalation.
7.
Estimated costs of major items: special tools, supplies, specialty contractors, nuclear insurance."
PSC Response:
PSC has identified those princh al factors that werc used as the basis for the decommissionin cost in PDP Section 5.3 (Reg.
Guide 1.159, 1.4.4.2).
Hownver, detailed information rclated to labor and energy costs art not available due to the proprietary nature of the contractor's firm fixed price proposal.
The following are evaluations of PSC responsiveness to principal factors identified in Reg. Guide 1.159:
(1) Estimated radiological conditions, including detailed site surveys and results of the PCRV activation analysis, are identified in PDP Sections 3.1, 3.3, and Appendix 11.
(2)
Inflation effects are represented in the fixed price and will be included in the decommissioning funding plan to be submitted at a later date.
(3) Facility design and layout have been fully evaluated in the detailed dismantlement plan (PDP Section 2.3), and fully accounted for in the Westinghouse team scope of work and decommissioning cos't.
(4) Waste disposal quantitles have been fully identified in PDP Section 3.1 and 3.3, and disposal costs have been evaluated in PUP Tables 5-2 and 5-3.
Appropriate
[
s l to P 90343 December 17, 1990 Pag? 6 adjustments have been made to account for an anticipated c
change in burial site from Beatty NV to Richland WA after 1992.
(5)
Estimated costs of major
- items, including spec' al ty contractors, have been incorporated into the PSC decommissioning costs presented in PDP Table 5-2.
Nuclear insurance costs have been sionificantly reduced to reflect the permanent shutdown condition and reduced value of Fort St. Vrain nuclear assets, and are no longer a major consideration.
A detailed breakdown of the cost of labor and the cost of energy has not been provided, since this contract will be awarded on the basis of a
firm fixed
... i c e contr;;t.
Disclosure of detailed information relet., to the bidder's proposal for estimated staff-years and energy costs could represent a significant competitive disadvantage for the Westinghouse team if this information were to become available to competitors of the Westinghouse team.
PSC's confidence in the proposed cost, including costs for staffing and energy, is based on comparison with an independent cost estimate performed and used as a basis for the Request for Proposal submitted to pre-selected qualified bidders.
Comparison of the proposals that were received with this preliminary cost estimate provided PSC with a sufficient level of confidence that each of the bidders had not underbid the decommissioning cost, it is also important to note that although cost was an important element of the evaluation process, the contract was not awarded to the low bidder,
_____m__._
i u
e 2
ATI'ACHMENT 4 TO P 90343 s
PROPOSED WORK IIREAKDOWN STRUCTURE FOR THE FORT ST. VRAIN DECOMMISSIONING PROJECT in order to provide the NRC with a degree of confidence in the level
~
of cost detail that will be provided once the firm fixed price contract has been signed between PSC and Westinghouse, a breakdown of detailed cost items is provided in this attachment.
PSC and the Westinghouse team will provide a
detailed identification of decommissioning costs consistent with the Level IV detail contained in the Wcstinghouse Project Work Breakdown Structure.
Specific items to be identified in this Level IV detail are identified in the following outline.
A cost will be provided for each of the Level IV cost items identified in this outline.
Although the final terms of the contract are still under negotiation, the work breakdown structure associated with the final contract should vary only slightly from g
the outline presented below.
1.0 PHASE 1 ACTIVITIES
-1.1 Project Management and Sumort 1.1.1.
Project Control 1.1.1.1 Project Management 1.1.1.2 Cost control 1.1.1.3 Plaming and Scheduling 1.1.1.4 Contract Adninistration 1.1.1.5 Reporting 1.1.1.6 Records Management and Docurent Control 1.1.1.7 ProjectControlManual 1.1.2 Cenerat Adniniatration 1.1.2.1 General Adninistration Services 1.1.2.2
- Personrel Relocation Planning 1.1.3
-Quality Assurance Plaming 1.1.3.1 QA Plan Developunt 1.1.3.2 Engineering Audit ard Surveillance 1.1.4 Licensing and Permitting 1.144.1 NRC Licensing and Permitting 1.1.4.2 EPA Licensing ard Permitting 1.1.4.3 State and Local Licensing and Permitting 1.1.4.4 Licensing and Permitting Plan 1.1.4.5 Decomissioning Plan Defense 1.1.5 Procurement 1.1.5.1 Develcpuent of Procuranent Management System 1.1.6
- Health, Safety nd Envirorsnental Management 1.1.6.1 Radiological Protection Plan Developnent 1.1.6.2 Ocetpational Safety Plan 1.1.6.3 Site Release Celteria ard laptementation Plan 1.1.6.4 Environmental Licensing S @ port
.i.6.5 Decontamination Spect fication Develegnent
3 I to P-90343 December 17, 1990 Page 2 1.2 Engineering
- 2.1 Initial Site Characterizatico 1.2.1.1 Radiological Characterization 1.2.1.2 Asbestos identification 1.2.1.3 Facility Equipment Status 1.2.1.4 Chemical Characterization 1.2.2 Decommissioning Plan Developnent 1.2.2.1 Radiological Status = PDP 1.2.2.2 Radiation Protection
- PDP 1.2.2.3' Radioactive Waste Management PDP 1.2.2.4 Accident Analysis 1.2.2.5 Final Radiation Survey Plan PDP 1.2.2.6 Technical Specifications 1.2.2.7 Quality Assurance 1.2.2.8 Security 1.2.2.9 Transportation Plan 1.2.2.10 Integration 1.2.3 Project Manuals 1.2.3.1 Configuration Control Plan 1.2.3.2 Emergency Plan 1.2.3.3 Fire Protection Plan 1.2.3.4 Training Maruet 1.2.3.5 Safety Marual (Intiastry) 1.2.3.6 Hatards Comu11 cation Program 1.2.4 Site Preparation Speciff.stione 1.2.4.1 Tenrocary FaclLities, irrtuding Fire Protection 1.2.4.2 Warehousing 1.2.4 3 Utilities 1.2.4.4 Leydown 1.2.4.5 Contaminated Segnentation and Repair Work Area 1.2.4.6 Decontamination / Repackaging Work Areas 1.2.4.7 Shipping Area 1.2.5 Asbestos Removat Specificotton 1.2.5.1 PCRV Asbestos 1.2.5.2 c mteminated System Asbestos 1.2.5.3 Conversion Ashestos 1.2.6 Persomet Test and Training Programs 1.2.6.1 Asbestos 1.2.6.2 Radiation Worker Training 1.2.6.3 Safety Training 1.2.6.4 Speelfic Job Training 1.2.6.5 Fitness for Duty 1.2.6.6 Site Orientation Training 1.2.7 Liquid Waste Disposal Specifications and Procedures 1.2.7.1 Installation of Liquid Waste Systan 1.2.7.2 Disposat ot Liquid Waste 1.2.7.3 Removal of Liquid Waste System 1.3 PCRV D/D Design, Specifications and Procedares 1.3.1 Initial Preparations, Disassect)(y Planning and Engineering 1.3.1.1 Design and Specify PCRV D/D Tools 1.3.1.2 Design and Specify underwater Tools 1.3.1.3 Plan D/D Preparatf ms 1.3.1.4 Spect fy Main Crane L.difications 1.3.1.5 Spect fy Handling Equipnent Refurbishment 1.3.1.6 Tendon Renovat 1.3.1.7 Remove RCDs, CRDs and Reflectors Blocks 1.3.1.8 Hellun Purification Well Equipnent Removal 1.3.2 Shletded Access to PCRV Plaming and Engineerthg 1.3.2.1 Specify Concrete Rennwal Tools 1.3.2.2 Specify Urtierwater Light aM Rennte Cameras 1.3.2.3 Seat PCRV Cooling Tthr, Removat 1.3.2.4 Center Access Penetration 1.3.2.5 PCRV Shielding Water System 1.3.2.6 Cmtomination Control EqCpnent and Facility 1.3.2.7 PCRV Top Head Cutting 1.3.2.6 PCRV Flooding 1.3.2.9 PCRV Cavity Work Platform l
y u
1 to P-90343 December. 17, 1990 Page 3 1.3.3 PCRV Core Dismantlement Planning and Engineering 1.3.3.1 GraMite Grappling Tool Design and Specification 1.3.3.2 PCRV Tooting Mockup Design and Specification 1.3.3.3 Defuettre Element Removat 1.3.3.4 Removal of Replaceable and Permanent Hexagonal Reflectors 1.3.3.5 Large side Reflector Element Removat 1.3.3.6 Boronated Spacer Element :lemoval 1.3.3.7 Hastelloy can Hexagonal Reflector Block Removat 1.3.3.5 Nee Sumort Block and Post Removat 1.3.4 CSF, Core Barret and Insulation Removat Plaming and Engrg 1.3.4.1 CSF Toottre Design and Specification 1.3.4.2 CSF Colum and Hettun Ductwork Tooting 1.3.4.3 Core Barrel and Key Removat 1.3.4.4 CSF Renovat 1.3.4.5 Top CSF Insulation Renovat 1.3.5 PCRV Lower Plenum Plaming and Engineering 1.3.5.1 Steam Generator Removat Tot Design Specification 1.3.5.2 Steam Generator Mockup Design and Specification 1.3.5.3 Steam Generator Module (12) Removat 1.3..'.4 Hellun Dif fuser (4) and S.O. Velve Assenbly removat 1.3.5.5 CSF Columns, Lower Floor, wd Flexible Colum Removal 1.3.5.6 PCRV Lower Flenun insulation and Cover Plate Renovat 1.3.6 Finst PCRV D&D, Cleanto Plaming and Engineering 1.3.6.1 Bettline Activated Concrete, Liner & Insulation Removat 1.3.6.2 Lower PCRV Liner Decontamination 1.3.6.3 PCRV Wetts, Penetrations, Piping, instrunentation Decon 1.3.6.4 Area clearup and DecobUlration 1.3.6.5 Ptav t,econtaminat)on Procedure for Final Relecto Survey 1.4 Contaminated System D&D Design, specifications and Procedurt:s 1.4.1 Disassenbty Tools 1.4.1.1 Mechanical Cutting Tool Specifications
- 1. 4.1.2.
Miscellaneous Tool Specification 1.4.2 BCP Systens Dismantiltw Plaming and Engineering 1.4.2.1 Preparation Activities 1.4.2.2 System 13 fuel Handling System 1.4.2.3 System 14 Fuel Storage facility 1.4.2.4 System 16 HSF, Atc, ard ESWs 1.4.2.5 System 23 Hetlun Purification System 1.4.2.6 System 46 Reactor Plant Cooling Water System 1.4.2.7 System 47 Purification Cooling Water System 1.4.2.8 System 61 Decontamination System 1.4.2.9 System 62 Radioactive Liquid Waste System 1.4.2.1D System 63 Radioactive Gas Waste System 1.4.2.11 System 72 Reactor Building Drain System 1.4.2.12 System 73 Reactor Plant Ventilaticri system 1.4.2.13 System 93 Instrunentation ard Controln System 1.4.2.14 Cont.minated Lamdry and Redwaste Ccapaalon Facilities 1.4.2.15 Demobilize and Cleamp Area 1.5 Site clearup Specifications and Detailed Procedures 1.5.1 Tools and Equipnent Specifications 1.5.2 Site Cleanup Specificattors and Detailed Procedures 1.5.2.1 Evaporation Ponds (4) 1.5.2.2 Sewage Lagoons (2) 1.5.2.3 Diesel Storage Tanks (3) 1.5.2.4 Effluent Ditches (2) 1.5.2.5 Farm Pond 1.5.3 Demobl1iaation l
1.6 Radioactive Waste Manace' </, an 1.6.1 Waste Processing Methc.so' my M Facilities 1.6.1.1 Concrete Segmentation i
1.6.1.2 Metal segmentat W 1.6.1.3 Gra$lte Segmenw 1 1.6.1.4 Water Management 1.6.1.5 Segmentation Acu 1
-4 a..
i to P-90343 December 17, 1990 Pa9e 4 1.6.2 Weste Packagire 1.6.2.1 Standard LSA Containers 1.6.2.2 Non Standard LSA Containers 1.6.2.3 High Integrity Contelner Packaging 1.6.2.4 shielded Container Packaging 1.6.3 Weste Shipping 1.6.3.1 Stagirg Area 1.6.3.2 Highway shipments 1.6.3.3 Rail Shipnents 1.6.3.4 Mlacellaneous shipnents 1.6.4 Weste Burial 1.6.4.1 Burlet 1.6.4.2 Westirghouse Scientific Ecology Grom 1.6.4.3 Other 1.6.5 Weste Program Managenent 1.6.5.1 Training 1.6.5.2 Weste Classification Conpliance Program 1.6.5.3 Saipling and Analysis 1.6.5.4 Waste Management Precedures Manual 2.0 PHASE II ACTIVITIES 2.1 Project Managemerit and Suport 2.1.1 Project Control 2.1.1.1 Project Management 2.1.1.2 Cost control 2.1.1.3 Plaming and Scheduling 2.1.1.4 Contract Adninistr6 tion 2.1.1.5 Reporting 2.1.1.6 Records Management and Document control 2.1.2 General Achinistration 2.1.2.1 Ceneral Actninletration Services 2.1.2.2 Persomel Relocetton.
2.1.2.3 Procurement Services 2.1.2.4 Facility Services (Snow Removal Equip. Maint., Janitorial, Security) 2.1.3 Quality Assurance 2.1.3.1 Quality Assurance
'2.1.3.2 Quality controt 2.1.4 Licensing and Persiitting 2.1.4.1 NRC Licensing and Permitting 2.1.4.2 EPA Licensing and Permitting 2.1.4.3 State and Local Licensing and Permitting
~ 2.1.4.4
. Decamissioning Plan Maintenance 2.1.4.5 Final Decanissionirg Report and Defense 2.1.5 Site Engineering 2.1.5.1 Detailed Procedure Revisions 2.1.5.2 Ercineering docwent Revisions 2.1.5.3 Decamissioning Plan Update $toport 2.1.5.4 General Site Enginevring Services 2.1.5.5 Firel Deconnissioning Report Support 2.1.6 Health, safety ard Enviromental Managenent 2.1.6.1 Radiological Engineering Services 2.1.6.2 Radiation Centrota 2.1.6.3 Laboratory Sumort (orsite, contract, Asbestos) 2.1.6.4 Independent verification Contractor interf ace 2.1.6.5 Industrial Safety Management 2.1.6.6 First Aid 2.1.6.7 Endremental docunent Sumort 2.1.6.8 finat Release Survey Documentation 2.1.6.9 Contaminated La,rdry and Radwaste Compaction f acilities 2.1.7 -
Project Clon out 2.1.7.1 Remove Teamrary Structures and Site Restoration 2.1.7.2 D&D Demobittretion 2.1.7.3 Docurent Turnover to PSC 2.1.7.4 FaclLity and Materlats Relcention 1
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p.'t l Attachment-4 to P 90343 December.17, 1990 Page 5
' 2.2 Cc m on Facilities and Services
-2.2.1 Site Preparations 2.2.1.1 Temporary facilities 2.2.l.2 Warehoustry
'2.2.1.3 Utilities
.L 2.2.1.4-Leydown-2.2.1.5 Contaminated Seynentation and Ewipnent Repair 2.2.1.6 Decontamination and Repackaging Work Area 2.2.1.7 Shipping Area -
2.2.1.8 Dther E@lpment Modifications 2.2.2 -
Peram ' Testing and Training 2.2.2.1 Asbestos Training 2.2.2.2 Radiation Worker Training i
2.2.2.3 Safety Training 2.2.2.4 Spectfic Job Training 2.2.2.5 Waste Packaging Training 2.2.2.6 :
'2.2.2.7-Site Drientation/ Security Trair.g 2.2.3 Liquid Weste Disposat 2.2.3.1 Install / Modify Licpid Weste System 2.2.3.2 Dispose of Licpid Wastes 2.2.3.3.
Dismantis and Package the Liquid Weste System 2.2.4 DeconteminetIon 2.2.4.1 Decontaminate Materials for Unrestei m o Release 2.2.4.23
- eminate for Releaae ey a
a.
- 2.2.5 -
C'
.ons Support fra.e
.2.2.6' 8r cents 2.2.6.1'-
Cer. i Tooting (Concrete Rmvt,' Metal t'etting, Rigging, Holsting) 2.2.6.2 Fan sity Related Procurements (Furniture, Vehicles, Utilities, Dther) 2;2.6.3 Envirormental Safety and Health Procurement 2.2.7 Radiological Surveys and Assessments 2.2.7.1 System Radiological Assessments 2.2.7.2" 51nal Release Surveys t
2.3 '.
PCR Diamantling and Decontamination 2.3.1 -
Initial Preparations, Disassenbty -
2.3.1.1
-PCKY D/D Tools 2.3.1.2
'Undercater Tools 2.3.1.3
-PCRV Attestos Removal (Preparations, Packaging, Cleanup, Inspectims) 2.3.1.4
_ Preparations :
'2.3.1.5 Modify Reactor Building Crane.
' 2.3.1.6
- Refurbish Hellun Circulator /Ccurponent Handling 2.3.1.7-Tencbn Detensiontre and Removal 2.3.-1.8
- Remove RCDs and Reflector Blocks-2.3.1.9
- Remove Hettun Purification Well Ecpipment 2.3.2
. Shielded Access to PCRV-2.3.2.1
'Conert i Re m val Tools 2.3.2.2
-Jnderwater Lighting ard Remote Cameras 2.3.2.3 seat PCRV Cooling itbes 2.3.2.4 Center Access Penetratico 2.3.2.5 PCRV Shielding Water System 2.3.2.6:
-Contamiretion Control Tent (Refueling Floor) 2.3.2.7-
. Cut PCRV fop Head 2.3.2.8 Flood the PCRV 2.3.2.9 Install'the PCRV Cavity Work Platform d.3.3 Dissentle the PCRV Core 2.3.3.1
. Grarbite Crnppling Tools 2.3.3.2 PCRV Tooting Mockup 2.3.3.3 Remove Defueling Elements
'2.3.3.4' Remove Replaceable and Permanent Hexagonal Reflectors 2.3.3.5 Remove Large-Side Reflector Elements 2.3.3.6 Remove Boronated Spacer Elements 2.3.3.7 Remove Hastelloy can Hexagoral Reflector Blocks 2.3.3.8~
Remove Core S @ port Blocks and Posts 2.3.4 CSF, Core Barret and Insulation Removal 2.3.4.1 CSF Tooting 2.3.4.2 CSF Colum and Hellun Ductwork Hock @
2.3.4.3 Rem ve Core Barret and Keys 2.3.4.4 Remove core S@ port Floor 2.3.4.5 Remove Top CSF Insulation r
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k i to P-90343 December 17e 1990 Page:6-r 2.3.5 =
PCRV Lower Plenun 2.3.5.1 Steen Generator Removal tools 2.3.5.2.
Steam Gs erator Full Scale MockLps 2.3.5.3 Remove Steam Generator Moeles (12)-
'2.3.5.4L Remove Hellun Dif fusers (4) and Shutof f Valve Assembly 2.3.5.5 Remove CSF Colums, Lower Floor, and FleFible Colunna 2.3.5.6 Remove PCRV Lower Plerun Insulation and Cover Plates
,2.3.6 Flnet PCRV D&D, Cleanup 2.3.6.1 Remove Bettline Activated concrete, Liner & Insulation 2.3.6.2 Decontaminate Lower PCRV Liner 2.3.6.3 Decontaminate PCRV Wells, Penetrations, Piping, Instrunentation 2.3.6.4 Area Cleanup and Donobilization 2.3,6.5 Decontaminate PCRV for Final.Releose Survey I
2.3.7 PCRV Optione 2.3.7.1 Control Rod Drive Orlfice Assemblies 2.3.7.2 Lower Portion of Hellun Circulators 2.4
' contaminated Systun D8D 2.4.1 :
Initial Preparations and Disassembly 2.4.1.1 Mechanical Cutting Tools 2.4.1.2--
Miscellaneous Tools 2.4.1.3 BOP Asbestos Removal 2.4.2 ; -
Dismantling operations 2.4.2.1 Preparation Activities-2.4.2.2_-
System 13 Fuel Handling System -
2.4.2.3 System 14 Fuel Storage Facility _
2.4.2.4
. System 16 Mff,- ATC, and ESWs
-2.4.2.5-System 23 Hellunt Purf fication System 2.4.2.6 System 46 Reactor Plant Cooling Water Systein 2.4.2.7-System 47 Purification Cooling Water System
.2.4.2.8-System 61 Decontamination System 2.4'.2.9 '
$ystem 62 Radioactive Liquid Weste System 22.4.2.10~
System 63 Radioactive cas Waste System 2.4.2.11
--System 72 Reactor Building Drain System 2.4.2.12-
' system 73 Peactor Plant Ventitation System 2.4.2.13 System 93 Instrunentation and Controls System =.--
2.4.2.14 Contaminated Lauxfry and Ra&aste.Ccnpoetion Facilities
- 2.4.2.15
-Damchtlize and Cleanup Area
-2.5
. Site Cleorg.
-2.5.1
. Tools and Emipment Acquisition 2.5.2'
= Site Clearm (perations E 2.5.2.1 Evaporetlon Ponds (4)'
- 2.5.2.2
- Sewage Lagoons (2)-
?.5.2.3'
.-Diesel Storage Tanks (3) 2,5.2.4' Effluent Ditches (2)
'2.5.2.5 '
Farm Pond 2.5.3 -
' Demobilization 2.5.4 Backfitl Option -
i f2.6:
- Radioactive Waste Management 2.6.1 Rad Waste Processing 2.6.1.1
- Concrete Seg'ientation 2.6.1.2 -
Metal Segmentatton
- 2.6.1.3 Graphite Segnentatico 2.6.1.4 Water Management 2.6.2.
-Red Waste Packagtho
=2.6.2.1
-Standard LSA Containera-2.6.2.2 Non Startfard LSA Containers
'2.6.2.3
- High Integrity Contalner Pa:.kaging 2.6.2.4' Shtelded T.ontairer Packaging-2.6.3 Red Waste Shipping L
2.6.3.1-Staging Area 2.6.3.2 Highway Shipnents 2.6.3.3 Rail Shipments 2.6.3.4~
Miscellaneous Shipnents I
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. to P-90343 December 17, 1990 Page 7 l
2.6.4 Waste Burial 2.6.4.1 Rad Weste Burial 2.6.4.2 Westinghouse scientific Ecology Crow 2.6.4.3 Other 2.6.5 Red Waste Program Management 2.6.5.1 Training 2.6.5.2 Weste Classification Conpliance Prograrn 2.6.5.3 Sanpling and Analysis 2.6.5.4 Waste hanagement Procedures Manual Mainterance l
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