ML20081B551

Forwards Applicant Responses to Commission 811224 Order,On Behalf of Project Mgt Corp & TVA

ML20081B551
Person / Time
Site:	Clinch River
Issue date:	01/18/1982
From:	Chipman G ENERGY, DEPT. OF
To:	Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM)
References
NUDOCS 8403090219
Download: ML20081B551 (101)

Text

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Department of Energy I

Washington, D.C. 20545 .

January 18, 1982 d .

The Honorable Nunzio J. Palladino The Honorable Peter Bradford Chainnan Connissioner U.S. Nuclear Regulatory Coonission U.S. Nuclear Regulatory Connission Washington, DC 20555 Washington, DC 20555 The Honorable Victor Gilinsky The Honorable John F. Ahearne Connissioner Connissioner U.S. Nuclear Regulatory Connission U.S. Nuclear Regulatory Connission Washington, DC 20555 Washington, DC 20555 The Honorable Thomas F. Roberts Connissioner U.S. Nuclear Regulatory Connission Washington, DC 20555 Re: Clinch River Breeder Reactor Plant Docket No. 50-537 (Section 50.12 Request)

Gentlemen:

The Department of Energy, on behalf of its coapplicants, Project Management Corporation and the Tennessee Valley Authority, hereby files the attached Answers to the Questions Set Forth in Attachment A to the Connission's December 24, 1981, Order.

Sincerely, G rdon L. an, Jr. '

Deputy Assistant Secretary for Nuclear Reactor Programs Office of Nuclear Energy Attachment cc w/ attachment:

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APPLICANTS' ANSWERS TO .

' - -- QUESTIONS SET,FORTH IN ATTACHMENT A -

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QUESTION 1:

( Is there any indication in acts providing for

}

" CRBRP authorizations or appropriations or other applicable ,

statutes that NRC licensing of the CRBRP could, 'or could f not, include use of 10 C.F.R. 5 50.12 as proposed by the applicants?

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4

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QUESTION 2:

i Is there any indication in the acts providing for CRBRP authorizations or appropriations, associated committee or conference reports, or legislative history that speaks to the licensing procedures to be used by the NRC?

ANSWER:

The-CRSRP authorization and appropriation acts, .

t along with other applicable statutes, and the associated legislative history, indicate that there definitely is no prohibition on the Commission's use of Section 50.12 as part of the CRBRP licensing procedures. Indeed, the combined thrust of this authority clearly militates in favor of the Commission's use of Section 50.12. The bases for these conclusions are as follows:

[a] _ The procedures which NRC must use for the CRBRP ar.e chase contemplated by the Energy Reorganization Act-(42 U.S.C. S 5801 et. seq.), the CRBRP authorization acts (Pub. L. No'.91-273, as amended), and the Atomic Energy

l. . .

Act (42 U.S.C. 5 2011 et_. seq.). Section 202(1) of the f

Energy Reorganization Act provides that NRC shall have licensing and regulatory authority as to the following ERDA facilities:

(1) Demonstration Liquid Metal Fast Breeder reactors when operated as part of the power

F generation facilities of an electric utility system, or when operated in any other manner for

r the purpose of demonstrating the suitability for

L commercial application of such a reactor.

I-1 As presently. defined in the authorizing legislation, Pub. L. No.91-273, as amended, the CRBRP

, . proj ect is subject to NRC licensing and regulatory jurisdiction. The statutory criteria and program justification data which were approved by the authorizing legislation, contemplate operation of the facility as part

• V of the power generation facilit'ies of a utility systemi-l< Consequently, the project falls within the ambit of Section

,- 202(1) of the Energy Reorganization Act. Further, since the c'

project ic authorized as the fourth round of the Co-operative

(

t I, *j Under the Department of Energy Reorganization Act of 1977, 42 U.S.C. 7101, et. seq., DOE assumed all rights ,

j responsibilities, obligations, and interests of ERDA.

t*] See Pub. L. No.94-187; ERDA Authorizing Legislation for TTscal Year 1976: Hearings on Fission Power Reactor Develop =cnt Before the Subcomm. on Legislation of the i

Joint Comm. on Atomic Energy, 94th Cong. ,1st Sess. ,

Part 4 at .2280-87 (1975) (letter of Robert C. Seamans, Jr., Administrator, ERDA) [ hereinafter "JCAE Hearings"].

L l . _ _ _ _ . _ _ _ ._ __. __ _ _.

')

-Power Reactor Demonstration Program, any license applied for would be issued under Section 104b. of the Atomic Energy Act.3

'l

[b] The Commission must apply the same procedures for Section 104b. licenses as are available for Section 103 commercial nuclear power plant ifcenses. Section 104b.

l .l provides that:

1 ij [1]n issuing licenses under this subsection,

the Commission shall impose the minimum amount

, of such regulations and terms of license as

will permit the Commission to fulfill its obligations under this chapter. 42 U.S.C.

i' 5 2134b.

Senate Report No. 1699, 83d Cong., 2d. Sess. (1954), which accompanied this legislation, explained that the Commission -

should apply this provision so as to impose only those regu-

.lations on demonstration plants that would be' compatible with those later imposed on a commercial plant of the same it l type if the technology were later to prove commercially feasible. S.R. No. 1699 as reprinted in U.S. CODE CONG. &

AD. NEWS 3475 (1954). In other words, the regulatory requirements for Section 103 commercial nuclear power plant licenses form a ceiling for the requirements imposed upon

(

Section 104b. licenses. Thus, the Commission cannot impose

• / See Section 106 of Pub. L. No.91-273, as amended; see

'JCR Hearings at 2280.

ty See 42 U.S.C. 5 2134b. ; 42 U.S .C. 5 2132c.

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more stringent procedures on Section 104b. reactors than it I

imposes on Section 103 reactors. Similarly, whatever procedures are generally available to commercial ' applicants must be available to Section 104b. applicants. Inasmuch as Section 50.12 makes no distinction between classes of reactors, it must be applicable to Section 104b. as well as Section 103 commercial reactors.

[c] The President and the Congress have directed the expeditious completion of the project, and the Commis-sion should use its authority under Section 50.12 in fur-therance of that direction.

The President's direction is clear:

I am directing that government' agencies proceed with the demonstration of breeder

- reactor. technology, including completion of the Clinch River Breeder Reactor. This is

' essential to ensure our preparedness for longer-term nuclear power needs.*/ ._

The Congress' direction is equally clear:

1. From the inception of the project through 1977, when the previous Administration decided to cancel the project, the. Congress: (a) approved priority pursuit of the LMFBR program and CRBRP project; and (b) expressly rejected a stretch-outlaf the schedule for the program and project. (Applicants' November 30, 1981 j!/ October 8,1981, President Reagan's Nuclear Energy Policy' Statement.

t I

Legal Memorandum [ hereinafter, "L.M."] at 15-16; Appendix A at 1-9).

2. Ln the face of active efforts by the h

i previous Administration to cancel the project

t 3 in each of the past four years, the Congress I has acted to preserve the project's authori-zation, provide adequate funding, and urge its Q..-

) expeditious completion. (L.M. at 17-18; Appendix A-at 9-25).

.. 3. The Omnibus Budget Reconciliation Act of 1981, Pub. L. No.' 97-35, includes a Congres-

, sional, mandate for expeditious project com-1' ~ */

pletion. The Conference Report- accompanying ,

this legislation and the contemporaneous statements of the floor managers at the time

• W' of enactwentr conclusively demonstrate the n

[

Y jf/ " Ordinarily the most persuasive element of legislative i history is the report of the legislative committee recommending its enactment," G. Folsom, Legislative History 33 (1972). The Supreme Court views the com-mittee reports as representing "the considered and col-lective understanding of those Congressmen involved in drafting and studying proposed legislation." Zuber v.

JAllen , 396 U.S . 168, 186 (1969) . See also, United

~ States v. Wrightwood Dairy Co., 313 IT.C T10,125

- (1941 ) .

• 1 Statements made in the course of floor debate are i

considered part of the legislative history of a '

s ta tute . See, Bindczyck v. Finucane, 342 U.S. 76, 83 (1951); Epstein v. Resor, 296 F. Supp. 214, 216 (N.D.

Calif .' 1969). The weight to be given such statements (Continued)'

[.

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following elements of Congress Lor.al

\

i intent:

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> a. The plant must be constructed in a

. timely and expeditious manner; construc-tion must be undertaken as expeditiously as possible; the cooperation of all agencies is required.

b. Unrecoverable delays resulting from the 1977 decision to stop the project must be minimized; construction must be undertaken with as little delay as dis-cretion will allow.*]

depends upon the status of the speaker. See, G. Folsom, Legislative History 34 (1972). Statements made by the

_ sponsors of the legislation are viewed as persuasive of the congressional intent. See, Ae.., Mitchell v Kentucky Finance Co., 359 U.S. 290, 295 (1959); United States v. International Union, UAW, 352 U.S. 567, 585-87 (1957); United States v. Wrightwood Dairy Co. , 315 U.S.

110, 125 (1942). On the other hand, post-enactment statements.of individual Congressnen and Senators who are not sponsors, are not considered partoof the legis-lative history of a statute. Schiaffo v. Helstoski, 350 F. Supp . 1076, 1091, . (D.N.J . 1972) , rev' d. in part ,

aff'd. in part, 492 F.2d 413 (3rd Cir. 1974). Such statements are not given effect, Committee for Humane Legislation, Inc. v. Richardson, 414 F. Supp. 297, 309 (D.D.C. 1976), aff'd., 540 F.2d 1141, and will not be relied upon by the courts, United States v. United Mine Workers of America, 330 U.S. 259, 281-2 (1947); Epstein

v. Resor, 296 F. Supp. 214, 216 (N.D. Calif.1969);

Allyn v. United States, 461 F.2d 810, 811 (Ct. C1.

1972), since they represent no more than the personal views of an individual legislator. National Woodwork Mfrs . As s 'n. v. NLRB, 386 U.S. 612, 639 n.34 (1967);

Shiaffo v. Helstoski, supra. Thus, the statements cited by the' Applicants (L.M. at 19-22) are controlling, and the statements relied upon by NRDC (e. ., NRDC Legal Memorandum, December 16, 1981, at 13, , 37 note 28) are not.

• / L.M. at 19-22.

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On the basis of the foregoing it is clear that there is an executive and legislative mandate concerning the need for and urgency of project completion. The Commission j should accord this mandate controlling weight and apply that I procedure -- Section 50.12 -- which will result in as little

) delay as discretion will allow.

In addition, at the very least chie executive and

.;- legislative mandate is entitled to substantial deference.

a i The Commission has previously addressed the question of deference to the executive and the Congress for the CRBRP project as follows:

" we believe'that the ERDA impact state-ment and associated processes, in light of the Energy Reorganization Act, and as confirmed by Congressional consideration of both the LMFBR

-, program and the Clinch River project, must be taken as establishing the need for a demon-1 stration-scale facility to test the feasibil-I: icy of liquid metal fast breeder reactors when

! operated as part of the power generation facilities of an electric utility system, and that that need is a present one.jy (Emphasis added.)

Where, as in this case, NRC licensing of

- a demonstration breeder reactor is mandated, deference to this basic objective of the

[ Energy Reorganization] Act--separation of responsibilities--compels a careful delineation of our role so as to avoid undue

> interference with ERDA's overall planning i

• / United States Energy Research and Development Adminis-tration, et al. (Clinch River Breeder Reactor Plant),

Docket No. 53!537, 4 NRC at 79.

i . .

J functions. If nothing else, the Act makes clear that we must not decide the present issue so as to put the Nuclear Regulatory .

Commission in the position of scrutinizing

.i afresh the judgments on long-range energy

, research and development issues made by the agency to which such judgments were primarily <

confided . */ (Emphasis added.)

'. In the present case, Congress has repeatedly recognized the requirement for a demonstration project to help in predicting the safety, practicality and environmental acceptability of commercial breeder reactors. Year after year, the cognizant committee, the Joint Committee on Atomic Energy, has urged rapid progress on the demonstration reactor. Year after year, Congress as a body has enacted the authorization legislation recommended by the l Joint Committee. This history supports our conclusion that the need for this facility, as we have defined it above, need not be reviewed j,

in this proceeding.*y (Emphasis added.)

The Applicants thus submit that, in light of the statutory

' basic for and/or legislative history of: 1) the CRBRP pro-ject, 2) and the-licensing procedures contemplated for that project, the Commission can and should employ its established Section 50.12 procedure.

QUESTION 3:

(a) Under what conditions would grant of an exemption be authorized by law? [b ] Would grant of an

• / United States Energy Research and Developcent Administration, aupra, 4 NRC at 83.

• !/ United States Energy Research and Development Administration, supra, 4 NRC at 88.

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.7 exemption endanger life or property or the common defense and security? [c] Would grant of this exemption be in the public interest? If not, why not? [d] With regard to the

f.

public interest criteria in Section 50.12(a) and (b)(4),

what interpretation and weight should be given to

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Presidential and Congressional statements pertaining to the

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q-timing 'of construction of the CRBRP?

! ~ ANSWER:

f

[a] Approval of the Applicants' Section 50.12

. request under.the conditions obtaining here is clearly authorized by law. The Applicants' November 30, 1981 L.e gal

- Memorandum (L.M.) identifies those conditions, as follows:

. 1. In light of the existing environmental and

' f ..

safety reviews fo the project, the Commission has the li L discretion to autho'. .ze site preparation activities pursuant

'i. to Section 50.12. (L.M. at 5-13) . -Prior NRC reviews for

'the project have satisfied all relevant. requirements arising out of NERA. .(L.M. at 5-9). Hearings are not required by I NEPA or the AEA prior to commencement of site preparation '

i (L.M. at 10-11; See Commission Order, December acutvities.

h1 l 24, 2981 at 4-7). The Commission has the discretion to grant an exemption from its hearing regulations and authorize commencement of site preparation pursuant to Section 50.12. (L.M. at 12-13).

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j 2. In view of the exigent and exceptional b circumstances of this request, the Commission should exercise its discretion to exercise its Section 50.12 authority to-grant the request. (L.M. at 14-26). Congress has mandated expeditious completion of the project. (L.M.

at 14-22). The project is in an advanced stage of development and unless relief is granted, undue hardship will inevitably result. (L.M. at 23-25). In light of the project's unique characteristics, the grant of relief would be entirely consistent with the Commission's sparing use of its Section 50.12 authority. (L.M. at 26) .

3. There is'a compelling case for a favorable determination under the Section 50.12- factors. (L.M. at 27-36).

[b]- Approval of the Appiicants' Section 50.12 l

request would not, from either a factual or legal stand-point, endanger life or property or the common defense and l

security. From a factual standpoint, grant of the request u

cannot in any way endanger life or property or the common

defense and security, since the scope of proposed activities does.not include any safety-related work. From a legal standpoint, grant of the request will not endanger life or l property or the common defense and security, since

(1) l this str.ndard derives from the Atomic Energy Act (See, e.g.,

4 2 U . S . 'J . $2012 d.-e. ; 42 U.S .C. 52134 b.; 10 C.F.R.

i f

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550.12(a)); and (2) the Atomic Energy Act permits the

< conduct of site preparation activities without prior NRC l approval. (L.M. at 10-11).

[c] The Applicants' November 30,1981 Legal Memorandum demonstrates that grant of the Section 50.12 request would be in the public interest. (See L.M. at 14-i 36). The bases for this conclusion are set forth in the Legal Memorandum, as follows:-

1. In view of the exigent and exceptional circum-stances of this request, the Commission should exercise its discretion to exercise its Section 50.12 authority to grant the request. (L.M. at 14-26). Congress has mandated expe-l ditious completion of the project. (L.M. at 14-22). The F

project is in an advanced stage of development and unless t

[. relief is granted, undue hardshi~p will inevitably result.

(L.M. at 23-25). In light of the project's unique charac-l.

teristics, the grant of relief would be entirely consistent p

j with the Commission's sparing use of its Section 50.12

. authority. ',L.M. at 26).

l L 2. There is a compelling case for a favorable L determination under the Section 50.12 factors. (L.M. at 27-l 36). The proposed activities will not give rise to signifi-cant adverse environmental impacts. (L.M. at 28-30). The impacts of the proposed activities are easily edressable, l

and the Applicants are committed to redress if a l

id

! l Construction Permit is not granted. (L.M. at 31-32). No reasonable alternatives will be foreclosed by conduct of the q

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proposed activities. (L.M. at 33-34). On balance, the public interest will be best served by the grant of the request. (L.M. at 35-36).

d. [d] With regard to the public interest criteria a

ci - in Sections 50.12(a) and (b)(4), the Commission should give controlling weight to Presidential and Congressional

! statements pertaining to the timing of construction of the

.i CRBRP. Sections 50.12(a) and (b)(4) contemplate the grant of requests to conduct site preparation activities as "are otherwise in the public interest", and upon consideration of j the "effect of delay in conducting such activities on the

!i public interest." As indicated in the answer to Questions 1

! and 2 above, subpart d, the President and the Congress, ll speaking as the elected representatives of the people, have urged that all responsible federal agencies work to complete the project with minimal delay. These expressions of intent are entitled to controlling weight, or at the verv least entitled to substantial deference by the Commission.

QUESTION 4:

Is the available documentation adequate for the Commission to base its decision on the exemption request to authorize site preparation activitie's? The documentation l{

includes the Applicants' Preliminary Safety Analysis Report t

ir.

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13 -

1  !

ti .

t (PSAR), Environmental Report (ER), Schedule for and Description of Site Preparation Activities to be conducted

} pursuant to 10 CFR 50.10(e)(1) (received April 11, 1975),

1

. and Site Preparation Activities Report (SPAR)- (November 30, a]

d 1981) as well as the staff's Site Suitability Report (SSR) and Final Environmental Statement (FES).

q-

'I ANSWER:

3]. The Applicants believe that.the documentation 1

+

presented in the November 30 request, as supplemented by the i

Applicants' December 31, 1981 submission and this submis-sion, and as supported by pertinent portions of the documen-

. cati on. listed in the NRC question, provides a substantial basis for the Commission to make a final decision.

4 The primary documentation for the Section 50.12 l.f request consists of the Site Preparation Activities Report (SPAR) . of November 1981, as supported by the CRBRP Environ-

.; mental Report through Amendment XI, and the NRC Final l Environmental Statement of 1977. A cross-reference of the pertinent sections of each of these documents supporting the Applicants' SPAR is shown in Table 1.

^

The Applicants' documentation is addressed directly to the relevant Section 50.12 factors, as follows:

• / Such documentation will also include the DOE documen-tation supplied in response to thic Order (See, e.g.,

Order supra at 10.) (This footnote appears in the text of Attachment A of the Commission's December 24, 1981 Order as a footnote to question 4).

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s  :

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a. Impacts of the proposed activities - 10 C.F.R. 50.12(b)(1); SPAR Sections 2, 3, and 4; L.M. at 28-30.

h b. Redress - 10 C.F.R. 550.12(b)(2); SPAR Section 5; L.M. at 31-32.

! c. Foreclosure of alternatives - 10 C.F.R.

i j $50.12(b)(3); SPAR Section 6; L.M. at 33-34.

l' d. Effect of delay /public interest C.F.R.

550.12(b)(4); SPAR Sections 1 and 7; L.M. at 14-36. -

Others - 10 C.F.R. 550.12(a); See those

f. e.

portions of Applicants ' Legal Memorandum identified in the j Answer to Question 3 above.

e The Applicants note that the Schedule for and

! Description of Site Preparation Activities to be Conducted i pursuant to 10 C.F.R. 50.10(e)(1) (received April 11, 1975)

[

wes amended by the Applicants' April 1,1977 submission (A.

R. Buhl (ERDA) to R. S. Boyd (NRC)) . With regard to the PSAR and SSR, it should also be noted that those documents deal with watters of radiological safety and site suita-bility, which will be fully considered in subsequent licensing proceedings, but which are not necessary conditions for approval of the Section 50.12 request.

QUESTION 5:

Identify areas, if any, in various licensing documents (PSAR, ER, FES, SSR, etc.) that need to be updated, which would have a bearing on this exemption decision.

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. TABLE 1 -

CROSS REFERENCE'OF SPAR, ER AND FES SPAR ER Section/Page ,

Iten Section/Page through AMERMI. XI FES Section Site location and layout

- Population Center Distances p2.1 p2.1, 2.2-2~ sec. 2.1

- Area Inpact p2.1-4 p2.2-1, 2.1-3 local Q M y

- Transient Population p2-8 p2.2-5 through sec. 2.2

- Recreational Facilities p2-8 p2.2-5

- Industrial Activity p2 p2.2-4, 5, 8, 9, 10

Incal Land / Water Use in - Eagle Picher p2-10 p2.2-9 sec. 2.1 M - Meltant. Hill Com. Operation p2-10 p2.2-11 s - Public h ter Supplies p2-10 p2.2-12

- Indivichl hter Supplies p2-11 p2.2-14 Historical and Archeological Featurea

- Historical Features p2-11, 12, 13 p2.3-2, 3, 4 sec. 2.3

- Archaeol<= pal Features p2-13, 14 p2.3-4 'arcugh 2.3-10 .

Site Geology and Hydrology p2-14, 15 pi 2.4-6, 2.4-9 sec. 2.4

- Hydrology p2-15, 16 t 1, 2.5-18, 18a, 19 sec. 2.5 Ecology sec.2.6.1.1,p2-16,17 p2.7-lb, 2.7-8 sec. 2.7.1

- Terrestrial Ecology, Flora p2-18, 19, 20, 21 p. 2.7-5%, 507, 508, 509 sec. 2.7.1

- p2-22 p2.7-381, 38m i

_ _ . _ .. . . . _ . _ . _ . .._m... . . . . . ......m. . _. _. . ,

4 SPAR ER Section/Page Section/Page through Amend. XI -

FES Section Itan

• 1hreatened or Ehdsngered Fama ,

- Mammm1m p2-22, 23 p2.7-38ff, 38ff(1)

- Avifauna -

p2-23, 24 .p2.7-38gg

- Herpe'tofauna p2-24 , p2.7-38hh Recommissance Survey Aug.1980 p2-25, 26 p2.7-38w sec 2.7.2 Aquatic Ecology _

TVA Study pgs 142-145)

Fish Classification p2-27 p2.7-87d Ehdangered Species p2-30 p2.7-87g Reconnaissance Survey, Aug.1980 p2-30, 31 p2.7-87h, 871 i

Site Investig* inn p2-31, 32, 33, 34, 35 sec. 2.4 i

p2-35 sec. 6.1-3 - sec. 2.6 Meteorology  :

p3-1 p4.1-1, 2, 3 sec. 4.2.1 i

Site Clearing and Grading p3-2 p4.1-2, 3 sec. 4.2.1 Excavation  ! .

sec. 2.5.2 1

Groundwater p3-8 p2.5-13, 14, sec. 2.5.2.2 Geology Investigation p3-8 sec. 2.4 j

i p3-9, sec. 3.3 sec. 4.1.1.2 (p4.1-4)

Temporary Facilities l

Terway Roads p3-9 Construction Electric Power p3-10, 15 ,

i

! Concrete Bacching & Mixing Plant p3-10 i

i

. _ _ . . _ . . . . . . - . . . ~ ,.. .,. , -. .,, .

]

SPAR ER Section/Page Itesa Section/Page_ through Amend. XI EES Section Quarry p3-11, 17, 18 sec. 4.1.1 (p4.1-3) sec. 4.1, 4.2.1 Semge Treatment p3-11, 16,.17 sec. 3.7.1 (p.3.7-1,-2) sec. 4.1.1.5 (p.4.1-6,-7)

Fire Protection p3-11, 16 Stona Drainage p3-11,.12 p4.1-12 Off Site Warehouse p3-12 Pennenent Access Roads p3-12 Railroad Spur p3-14 sec. 4.1.1.3(p4.1-5)

Construction Parking p3-14

, Temporary Roads p3-14 sec. 4.1.1.3 N Contractor Work & Storage Areas p3-15 ,

i

, Electric Power p3-15 i Compressed Air p3-15 l Water Systein p3-15 Raw Water p3-16 sec. 4.1.2.1 sec. 4.3 i Survey Control Lines p3-17 4

Cost of Site Preparation p3-18, 19 i

Enviraranental Effects Section 4.0 sec. 4.0 sec. 4.0 i land Use p4-2 sec. 4.1 sec.~4.2.1

' and 4.4.1 i,

j; * ~

ji

SPAR ER Section/Pags

' Item Section/Page throtuh Amend. XI FES Section f

-Plant Connunity Types p4-2, Table 4-1 sec. 4.1.1.6, (p4.1-7 sec. 4.4, 4.2 thru 4.1-9), Table 4.1-2 Wildlife p4-2,.4-6, 4-7 pr. 1-8, 4-1-8a, 8b p4-5 Aquatic Ecology- p4-7 sec. 4.1.2.3, p4.1-5, 14, 15 sec. 4.4.2

. Land Use Inpact p4-8, 9 p4.1-3 sec. 4.2.1 Soil T= =ct p4-10 sec. 4.2.1 and 4.3 hter Resource Inpact p4-11, 14 sec. 4.1.2.1,4.1.2.2, 4.1.2.3 p4.1-13, 14 4.2-1, 4.4 Solid and Liquid W ate

- Open burning p4-15 p4.1-2 i i . - Non-conbustibles p4.1-2, 7

! . - Wesnicals/ oil p4.1-6 i ,-4

Sanitary W ate p4-16 sec. 4.1.1.5, p4.1-6, sec. 4.6.1 l

3.7.1, p3.7-1 Wstewater/ Dewatering p4-16 p4.1-12 sec. 4.6.1 Garbage p4-17 p4.1-6 sec. 4.6.1 l Inpact of Historical and Archaeological Features p4-17 sec. 2.3 sec. 2.3, 4.6.1 j

Aesthetic Inpact p4-18 sec. 4.1.1.7, p4.1-9, 10 4.5.5, 4.5.6 l (inise)

), thique/Special Hamrds p4-20 Socioeconomic p4-20 thru 26 sec. 2.2.8.1, 8.2, 8.3 ch. 4 Inpact Control Measures p4-26, 27, 28 sec. 4 sec. 4.6 l

4 .

.. - - - . e,-~..- . . . . , , , . .

'i 9 ANSWER:

- All of the Applicants' documents pertinent to the 50.12 request have been updated in pertinent sections to

)

j -reflect current site and environnental conditions. The ER now includes Amendment XI, ! while the PSAR now includes Amendment 63.

j QUESTION 6:

What, if any, further exemptions from regulatory 1 requirements does the applicant plan to request if this 10 CFR 50.12 request is granted? If this exemption is granted, does the applicant plan also to request a Limited Work

, Authorization?

,' ANSWER:

q.

] At this time the Applicants do not intend to j request additional authorization under Section 50.12. The

! Applicants do intend to request permission to initiate

limited construction activities in mid-1983 under a limited m

a work authorization (1:WA-2) pursuant to 10 C.F.R. 550.10 (e) (3) (i)-(ii) .

l ii -

h

• j ER amendment XI has been approved and will be promptly served upon all parties to the suspended proceedings.

o

[. _ . :. g - .._ . . _ . _ . . - . . _

l 20 -

I QUESTION 7:

Provide the updated overall CRBRP schedule, including (a) current estimate of when applicant expects to request resumption of ASLB proceeding, (b) key milestones of f

constructing and licensing the plant, (showing DOE assump-

. tions regarding date, for NRC licensing action) and (c) current expected date of operation. The schedule should indicate points at which a negative NRC action could adversely affect'the overall CRBRP schedule.

ANSWER:

(a) The request for resumption of ASLB proceedings was made by the Applicants on January 11, 1982; (b) The ten 9

- key milestones for the project, including key licensing actions are shown in Table 2; and (c) As indicated in Table

2, this schedule would provide for initial criticality of i

l the CRBRP in late 1988. In regard to points at which

[ negative NRC action could affect the overall CRBRP schedule, f- - delays'in initiation of site preparation activities or plant l

construction will translate into delays in initial criticality.

9

, _ . . _ _ _ _ - _ __. _ _ . _ _ _ - , _ _ . , . _ . . . _ . . . . . , _ ~ , _ _ _ _ _ _ ,._.. _

t l

. t TABLE 2 4

1 CRBRP KEY MILESTONES NRC Commission grant Section 50.12 request- March, 1982 Start Site Preparation March, 1982 NRC Grant an LWA under 10 CFR 50.10(e) (3) (1)-(11) June, 1983

. Start Nuclear Island Hat June, 1983 NRC grant of CP ,

June, 1984 4

Submit FSAR to NRC . June, 1985 St. art Na System Testing December, 1987 NRC grant of OL April, 1988 Start Fuel Loading May, 1.988 Initial Criticality September, 1988 l

l' l:

I t

f i

l I .

1 .

QUESTION 8: ,

t

. Identify and discuss any changes in the project scope from the scope originally evaluated (staff FES Chapter t

T' 4 - Environmental Impacts Due to Construction) that may have if

.; contributed to the changes in proposed site preparation

! activities (page 3-1 of the Site Preparation Activities Report, November 1981), particularly the substantial W

ji' increase in the amount of excavation.

l ANSWER:

The proposed scope of site-preparation activities for the CRBRP Project, as set forth in the SPAR, differ from those activities discussed in NRC's 1977 FES (Chapter 4) in the amount of acreage to be cleared and grubbed and in the II amount of excavation required. The factors which contri-e buted to these changes are discussed below in regard to: (a)

I, acreage; and (b) excavation. It should be noted that the l:

l}

resulting environmental impacts of the proposed site preparation activities will not differ significantly from

- those originally evaluated in the NRC FES Chapter 4, and that the conclusions of the FES remain valid. This is l

discussed in, detail in the Answer to 9(a) (Environmental

( impact' estimates) below.

A. Acreage to Be Cleared and Grubbed

\

The proposed scope of site preparation activities l

includes the clearing and grubbing of a portion of the site

. . _ . _ . . ~ - . . . , _ _ _ . . , .

~ ~ '

i, 1

i s to allow excavation of the plant foundation, openin's of a

] site quarry, installation of temporary buildings and

'i j

installation of roads, railroads and other required site

i facilities as described in the SPAR Section 3. In its 1977 Final Environmental Statement (FES), NRC estimated that 195 acres of the CRBRP site would have to be cleared and grubbed l,I during site preparation.

' In the SPAR, the. Applicants revised this estimate to 260 acres. The differences between the FES and the SPAR li -

are attributable to the following factors:

SCOPE DIFFERENCES Acres Increased estimate for quarry / crusher area e

20 Borrow pit eliminated (32)

Increase in spoil area due to spoil overburden being more moist or higher in fine materials than indicated by original samples 37.5 Meteorological tower area not included in original estimate 10 Concrete -batch plant relocation 3 Grading to improve line of sight for new 10 security requirements Increased utility corridors for intake and discharge lines to reflect final design 5 Increase in barge area to reflect final design 0.5 Increase in impounding pond area to reflect detailed construction planning 1.0

i j A d

4 1 Increased parking area to reflect detailed construction planning 10 l '

Total Difference 65 acres h- FES Estimate 195 acres i

11/81 SPAR Estimate 260 acres In addition, detailed calculations conducted since

[ the SPAR was prepared indicate that an additional 11 acres

': would be cleared and grubbed to provide wider rights-of-way for the site roadways. This additional area was not included in the SPAR and results in a total of approximately 271 acres that would be cleared and grubbed during site preparation.

B. Site Excavation The proposed scope of site preparation activities includes the excavation, backfill, and grading of portions l of the site for the main plant,. roads and railroads, con-I-

l, crete plant, parking lots, storage areas, etc., as described

[ in the SPAR Section 3. In the Feburary 1977 FES, NRC does not state a specific quantity for the amount of excavation to be performed during site preparation-activities. The P

data available to NRC at that time was a 1974 estimate by the Applicants that approximately 1,445,000 cubic yards (cy.) of excavation would be required during site prepara-tion. In addition, 570,500 cy. of excavation were estimated to be required from an offsite borrow pit for a total of

l_._...__ . . . .

C 2,015,500 cy. These data are found in the Applicants' Schedule for and Description of Site Preparation Activities to be Conducted Pursuant to 10 C.F.R. 50.10(e)(1) (received

. by NRC in April, 1975). The November 1981 SPAR estimate of excavation is a value of 2,790,000 cy. This estimate reflects the current project plan to obtain borrow material onsite rather than having it trucked in from an offsite location.

A comparison of the excavation quantities is shown in Table 3.

TABLE 3 COMPARISON OF EARTHWORK ACTIVITIES 1974 Estimate 1981 Estimate (cy) (cy)

Balance of Plant 697,000 1,976,000 l Road, Railroad and Batch Plant 85,000 70,000 Kuclear Island 663,000 744,000 L

L

! */ Detailed engineering calculations performed in connec-tion with the site preparation procurement process (see i Answer to Question 11 below), indicate that the 2,790,000 cy. value. overestimates the actual quanti-Thus, this value represents an upper bound on l ties.

l excavation quantities. To assure a conservative i analysis, the Applicants will continue to use the l 2,790,000 cy value.

g .

~~

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h y

!'n a . ,

[

f. Total Onsite Excavation. 1,445,000 2,790,000 e r offsice Borrcw 570,500 0

]

- 2,015,500 2,790,000

1. Changes in the excavation quantities are chiefly due to the 6

3_ following:

r i il . Nuclear Island -

As the plant design was detailed between 1974 and 1981, various dimensions of the nuclear island foundation v n ,,

have increased. Specifically, the basemat width and length i were increased by 18 feet as a result of the decision to add Yb the confinement" building around reactor containment.

~ '

This

~

decision, in sturn, resulted from project /NRC Staff interac-tiens in the~

1 technical review' process. - 'Similarly, changes 3 '

~

'o in'ch' e .basemat design increased its thickness by nine (9) feet. In addition, design evolution resulted in increases of -the foundation sizes of the diesel generator, reactor

- service, and steam generator buildings. Finally, detailed construction planning indicated that a vertical cut, rather than' sloped sides could be used in some areas of the nuclear

,g ,

island. foundation, thus sl;ightly decreasing the amount of

- excavation required.. These changes result in a net increase c of 81,000 cycin the excavation required for the nuclear

.< island as shown' in Table 3.

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2. Roads. Railroad and Batch Plant -

As the plant design has proceeded, che location of i

l n roadways and'various support facilities, such as the batch 1

l[ plant, have been optimized. These optimizations generally 2 As a provide for easier flow of materials and equipment.

result of these studies, final lengths and location of the l roadways and railroad and the location and size of the batch

-i

]' ; .

plant were determined. The net result of optimizing the l location of these facilities is an estimated decrease o'f approximately 15,000 cy in the required excavation.

3. Balance of Plant -

As the plant design has evolved, refinements have

- occurred in the size and location of certain portions of the balance-of-plant. Also, as the project has proceeded- to deta'iled construction planning, certain temporary facilities

., and work areas that were not anticipated at the preliminary j;x design stage have been identified. The principle refine-if ments to the preliminary design include a change in the i

normal" cooling tower foundation requiring deeper excavation, an increase in the size of the turbine generator building, increased excavation and grading of the area surrounding the plant to meet security requirements (increased line of

<1 sight), the additionHof an Emergency Cooling Tower (with water line tranching required), and an increase in the size of the parking area. Items requiring excavation that were 1- ...-. _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ - . _ _ _ _ , _ . -

. - . . - ~ , . - - . - - . - - -- - - - . , .__-

.. . . ~ . _

- 28 - ,

? >

l i

\

I I

> not anticipated in the project's 1974 planning include addi-l[ tional work-areas on the west side of the site to enhance the efficiency of project construction activities, addi- i

.i-

< tional laydown areas, and the addition of some temporary

. facilities to support tbn craft labor. Finally, the deci-sion wasemade-to obtain fill and construction materials for

), -

1 ~the . plant. from an onsite quarry rather than from an offsite

) ~ borrow-ares. The.. net result of these changes is an esti-insted incr1ase< in the excavation for the balance of. plant portion of the' project as showa in Table 3.

' :In summary, the. total amount of onsite excavation

.will'be increased by no.more than 1,344,500 cy. However, this reflects the previously noted decision to obtain/ borrow

- . materials onsite during the site preparation activities and

.. avoid. trucking-in 570,509 cy of borrow material. Thus, the 4 tocal estimated amount of the excavation during site

?-

'\- 1, preparation has; increased by no more than 774,500 cy.

jj, It

- should be noted, however, that the project has eliminated theredirementthatsubstantialquantitiesofborrow C material be transported to the site,.and has thus eliminated C the' adverse environt. ental impacts associated with these e

- ,' activities. It should.be also noted that development of the Jiu sensite quarry /ci: usher complex to ; furnish aggregate for concrete will also eliminate the'need to haul more than 1,000,000 tons of aggregate from commercial sources over w

J publice roads,to.the sice.

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29 -

I l ,

4 QUESTION 9(a) [ Environmental impact estimates):

O, Provide the documentation which forr.s the basis for projected . .. environmental impact estimates referred to j in the Site Preparation Activities Report and Secretary Edwards' letter. j j ANSWER 9(a) [ Environmental impset estimates]:

1

'! The Applicants' December 31, 1981 submission, i;

3

' Attachme7t A, at pages 5-10, identifies supporting documen-tation which forms the basis for the environmental impact estimates of the proposed site preparation activities con-I tained in Section 4 of the SPAk. ' Supporting documentation was identified for each subsection of Section 4 of the SPAR, including detailed cross-references to the Applicants' ER, updated through Amendment X, and the NRC's 197'i FES (the Answer to Question 4 above provides the corresponding cross-4

! reference for Sections 2, 3 and 4 of the SPAR). Copies of  :

] . specific reference documents for the SPAR were also provided

. by the Applicants' December 31, 1981 submission. Alto-gether, this material clearly demonstrates that the NRC 1977 FES conclusion - namely, that the environmental impacts of CRBRP site _ preparation activities would not he significant (FES at page 9-23) - remains valid today. For summary

. purposes, we.here identify the 1977 FES conclusion per-taining to each specific element of environmental impact, 1

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- 30 -

i and the corresponding reasoning in the SPAR, to demonstrate

that each of ene 1977 conclusions remains valid today.

f 5 4.1.1 Impact on Terrestrial Ecology On the bacis of the CRBRP construction plans and the site characteristics defined at the time of the FES assessment, the NRC staff concluded (FES, Section 4.4.1, page 4-5) that "the impact on terrestrial biota would be

[ minimal in view of the fact that the amount of land affected would be less than 1% of similar available land onsite and on the Oak Ridge reservation. The staff's opinion is that the applicant's comm'itments to restrict erosion and chemical releases would be adequate to protect the terrestrial eco-system from significantly adverse effects from those sources."

'The impact assessment of the proposed site preparation activities reflects: (1) the increase in land

' area to be disturbed (271 acres compared to the 195 acres

• /

planned at the time of the NRC staff reviewT; and (2) updated ecological data from an August 1980 reconnaissance survey which confirmed that no significant changes to the ecology of the site had occurred since the FES was issued.

On the basis that no threatened or endangered fauna is expected to be affected by CRBRP site preparation accivities, that the various site flora also exist on the Oak Ridge reservation, Tennessee and the Appalachian region,

• / . 271 acres still represents about 1% of sbnilar available Yand onsite and on the Oak Ridge reservation.

~

. i

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)

[ I F

that site preparation activities have been planned to avoid

some rare plant species that occur on the site, and that I

control measures endorsed or recommended by the NRC staff to limit construction impacts will be implemented, the previous t

- NRC conclusion that "the impact on terrestrial biota would

be minimal" remains valid.

4

?

i 4.1.2 Impact on Aquatic Ecolony I,

1 On the basis of the CRBRP construction plan and f the site characteristics defined at the time of the FES

) effort, the NRC staff concluded (FES, Section 4.4.2, page 4-6) that "the aquatic ecosystem is expected to sustain no

- significant impact from constructing the plant and trans-mission lines. 'To measure impacts, the staff would require

} monitoring during construction, as specified in-Section 6,1.4."

i' The impact assessment of the proposed site i

preparation activities reflects the fact that construction i

of a river pump house and intake / discharge pipes included by the NRC in its FES assessment would not be involved in the proposed site preparation effort. Only the construction of i

j: a barge unloading facility would remain as a river-front construction effort, thereby reducing tne river dredging volume to.11,000 cubic yards, which is substantially smaller than the 19,000 cubic yards assumed in the FES. Updated

il . .

L I

't h ecological data confirmed the absence of endangered or threatened aquatic species in the vicinity of the site. On the basis that the dredging volume is smaller than that used l

in the NRC assessment, that benthic species disturbed by dredging activities are expected te recover rapidly, that fish species will be able to avoid armas of high turbidity,

'I and that control measures and a monitoring program

.1

] recommended by the NRC staff will be implemented, the i

i previous NRC conclusion thac "the aquatic ecosystem is i

expected to sustain no significant impact" remains valid.

3

4.1.3 Impact on Land Use

- On the basis of the CRBRP construction plan and 4

the site characteristics defined at-the time of the FES i effort, the NRC staff concluded that "the loss, for the life

[ of the plant, of 73 acres for production of biota would not constitute a significant impact since there are thousands of similarly forested acres in the vicinity" (FES, Section

'4 f 4.2.1, page 4-3) and also that "the extent of such effects

[resulting from moving construction equipment and disturbing land] would be at a practicable minimum during the brief li. periods of their.occu;;rences. The long-term effects would not lue significer.c" (FES, Section 4.2.1, page 4-4).

The impact assessment of proposed site preparation activities is based on current plans for a 45-acre on-site quarry and stockpile' area, whereas the NRC staff analysis in

r, q *

, 33 -

the FES assumed a 32-acre borrow pit for structural fill and did not include consideration of a quarry (since its use was speculative at that time) . The use of an on-site quarry and j

. stockpile area would eliminate the need for a borrow pit and

l. substantially reduce off-site trucking for construction j materials. Further, the totsl area of permanently disturbed

l land and specific land-use allocations are essentially i similar to that used in the FES (73 acres in FES versus 84

. . acres based on current estimates). On these bases, the previous NRC conclusions regarding land-use impact remain

valid.

4.1.4. Impact on Soils 9- ,

On the basis of the CRBRP construction plan and m

the site characteristics defined at the time of the FES

}

] effort, the NRC staff concluded in FES Section 4.2.1 (page j 4-4) that "

... temporary adverse effects such as erosion, o siltation ... would be at practicable minimum during the J1 brief periods of their occurrences. The long-term effects p would not be significant".

The impact assessment of the planned site preparation activities reflects the proposed method for

j. quarry operation and reclamation. The proposed site preparation activities have comparable erosion potential to the construction plans evaluated in the FES. Further, the same extensive erosion control measures required as

?

4' 1

l J .

l- conditions by the NRC staff in the FES will be used in the proposed site preparation activities. On these bases, the i previous NRC conclusion in the FES regarding soil erosion i and siltation impacts remains valid.

4.1.5 Impact on Water Resources i On the basis of a maximum river water consumption I' requirement of 190,000 gallona per day, the NRC staff con-d cluded- (FES Section 4.3, page 4-4) that "this small with-

]

drawal [of river water] is expected to hava no significant

effect on navigational and recreational uses of the river or on any downctream uses." With regard to construction of a river pump house, intake / discharge pipes and a barge unload-ing facility that was evaluated in the FES, the NRC staff 9 . .

d. Judged (FES Section 4.3, page 4 ,5) that " protective measures a

and the plan to do major construction elements in sequence would give protection sufficient to insure only temporary ,

minor adverse impacts upon the aesthetic quality and naviga-tional and recreational uses of the river". The NRC staff considered the use of the barge unloading facility for the j delivery ~of construction materials and plant components and L.

j. concluded (FES Section 4.3, page 4-4) that "the overall impact [on other river shipping]'would be very small because

- of the. limited number of shipments over the several year construction period".

l'

. . 7. _ __ .

I I

5 f, .

The impact assessment of water resources during proposed site preparation activities considers the facts I that river withdrawal requirements of these limited activities will be much smaller (60,000 gallons per day) 3 l

than the value used by the NRC for the FES (190,000 gallons i-i per day), that the site preparation activities do not i include construction of the river pump house and intake /

i discharge pipes, and that.use of the barge unloading facility will involve only construction equipment and materials, and not plant components. On these bases the NRC staff conclusions on the impact of site preparation activi-ties on water resources remain valid.

, 4.2 Solid and Liquid Waste Disposal j Based on the nature of plant construction activi-t I ties and proposed practices for the disposal of solid'and 1

L chemical wastes, the NRC staff concluded in the FES (FES j Section 4.2.1, page 4-4) that " surrounding forested areas J >

would sustain no significantly adverse effects in view of the applicant's plans for ... limited onsite burning in con-l formance with State and Federal air pollution require-1 i ments". The NRC staff also judged (FES Section 4.4.1, page 4-5) that "the applicant's commitments to restrict ...

chemical releases would be adequate to protect the terres-trial ecosystem from significantly adverse effects from h those sources". On the basis of its evaluation of the p

,, _,. . . _ . . . . _ . , _ , _ . , . , , . . . , . . _ _ . _ ~ . , _ . . . . _ _ _ . . . , , , . . . , - - - _ .

L.

l E.

Applicants' plans for mitigating the effects of disposing of ,

chemicals and solid waste, the NRC staff concluded (FES .

l" Section 4.4.2, page 4-6) that " disposal of those materials would have insignificant, effects upon the aquatic ,

ecosystem".

The impact assessment of solid and liquid waste disposal on the environment during site preparation f.

activities is bas'ed on the Applicants' . commitment to the same waste disposal practices judged to be adequate by the NRC in its FES.' Accordingly, the NRC conclusions on the

~

-disposal of solid and liquid wastes remain valid.

4.3 Sanitary and Other Waste Treatment and Processing Based on the nature of plant construction activi-ties and proposed practices for the disposal of conventional o garbage and sanitary wastes, the NRC endorsed in the FES (Section' 4.2.1, pages 4-3 and 4-4) the Applicants ' proposed practice that " conventional garbage would not be incinerated on the site but collected and disposed of offsite by a licensed contractor, or onsite near the borrow pit in compliance with applicable requirem2nts". The NRC staff L also evaluated the Applicants' plans for mitigating the l-effects of disposing of sanitary wastewater and concluded (Section 4.4.2, page 4-6) that " disposal of those materials would have insignificant effects-upon the aquatic ecosysten".

a ... .- .. . .- . - . . . .

o .

1 1 'i.

il The Applicants remain committed to process and

. dispose of conventional garbage and sanitary wastes during l site preparation activities using the same practices that

)

Li .

were judged acceptable by the NRC staff in their FES assess- '

i.

'j- ment. Therefore, the NRC conclusion on the environmental

~t j impact from disposal of garbage and sanitary wastes remains

+

li  : valid.

1 4.4 Impact on Historical and Archaeological Features The NRC staff judged in the FES (Sectio'n 4.2.1,

{

page 4-4) that borrow-pit activity during construction would r be sufficiently restricted so as not to interfere with near-j by historical (Hensley cemetery) and archaeological (Indian 4-i Mound) sites and ccncluded that "they would be unaffected".

i j

The NRC staff also' acknowledged the opinions of: ,

(1) the

} State archaeologist that "the applicant has given adequate i~

-i consideration to archaeological resources" on the site, and (2) the State Historic Officer who concurred that '.'no

).

. structures of historic interest remain in the are'".

.i On the basis that proposed construction activities

.l no longer include che use of a borrow pit, that all archaeo-5 logical field work was completed in 1975 and that the

[-

Hensley-cemetery will be preserved, the conclusions of the

'I FES regarding the protection of historical and archaeo-logical values remain valid.

I 4.5 Impact on Aesthetic Values

.t t on the basis of the physical location of proposed i '

construction activities relative to various natural and ,

, l demographic features, the NRC staff concluded (FES Section 4.5.5, page 4-16) that "the CRBRP would not form an objectionable visual intrusion on the landscape". The staff also reviewed the Applicants' plans for dust and noise control, concluding that " dust and noise and other potentially' adverse effects from blasting and heavy equipment would have minor adverse effects and they would be experienced only by the few residents-immediately south of the river". (FES Section 4.5.6, page 4-17)

'On the basis that construction activities would be limited to site clearing and excavation rather than the total plant construction effort, that the construction noise levels would have the same maximum values judged acceptable by the NRC staff, and that dust would be controlled by the

. same mitigating measures evaluated in the FES, the conclu-sion of the FES 'regarding construction impact on aesthetic values remains valid.

" 4. 6' Identification of Unique or Special Hazards l

On the basis of its evaluation of the Applicants' l

fire control plan, the NRC staff concluded that " surrounding forested areas would sustain no significantly adverse-l i effects in view of the Applicants' plans for fire prevention V <

- ' ~

..) - -

1 39 -

t I control procedures...." (FES Section 4.2.1, page 4-4) The i

Applicants remain committed to implement those s.ame procedures during the proposed site preparation activities f

l and, hence, the NRC staff conclusion on the absence of

significant fire hazards remains valid.

1 1

4.7 Economic and Social Effects of Proposed Activities See SPAR Section 4.7 and Applicants' December 31,

$ '1981 submission at page 10.

,6 l5 o

l l

L

.~..__ . .. _ .. . _ . . . . . . . . .

l

( t QUESTION 9(a) AND (b) (COSTS):

(a) Provide the documentation which forms the basis for projected cost of delay .. . referred to in the

l. Site Preparation Activities Report and Secretary Edwards' letter. (b) Demonstrate the validity of the cost estimate.

ANSWER:~

{ Applicants estimate that, absent authorization I

, pursuant to Section 50.12 to begin site preparation activities the Project will incur (1) additional delays of

[ one-to-two years duration and (2) corresponding increased costs . in the amount of $120-240 million.

In estimating the duration of delay, three cases were compared: (a) approval of the Section 50.12 request to permit site preparation activities; (b) the NRC Staff's

[ schedule which estimated the issuance of a TWA I by August-I September, 1983; and (c) the Staff's estimate for an LWA E

increased by an assumed additional delay of one year.

Comparing Case _ (a) to Case (b) indicates that approval of the Section 50.12 request would avoid or save roughly fifteen (15) months on the Project schedule. Comparing Case (a) to Case (c) results in an expected savings of approximately twenty-seven (27) months. Based on these t

l

• J The Energy Daily, December 2,1981 at 2.

1

1 g -.7. -

o.

t .

[ comparisons, the SPAR estimated a duration of delay in the l'

range of twelve (12) to twenty-four (24) months.

The range of delay costs can be conservatively

[ estimated on the basis of: 1) an estimate of cost increases-for certain unavoidable management activities which are l particularly sensitive to delay; 2) an estimate of the effects of inflation assuming a delay in initial criticality from September 1988 to February 199(T; and 3) an estimate of the cost of capital expended on hardware for the period of delay. Each of these estimates are more fully described below; they show that the cost estimate of $120 - 240 million in the SPAR is clearly conservative.

1. Cost Increases For Certain Unavoidable Management Activities An analysis was made of the current Project acti-

~

vities which are particularly cost sensitive to delay. In particular, the Applicants estimated the cost of management activities which are necessary to maintain.the Project on a current status'during the period of delay.

At the present time Project management functions

! are being performed by the Department of Energy, Project Management Corporation, Westinghouse Lead Reactor Manufacturer (LRM), and Stone & Webster Engineering Corpora-

. tion. Although these management groups have separate responsibilities, because they provide overall management

• / Tha September 1988 initial criticality date assumes a start of site preparation in November 1981 while the Section 50.12 (continued)

); - -

h .

for the entire Project and their responsibilities continue

until Project completion, they must be maintained intact 1 M  !

during any period of delay. An extension in the Project f

schedule of one-to-two years, therefore, necessarily results

'l' in additional costs for these management groups without

}

1 advancing progress toward completion. Simply stated, unless l'

the Applicants' Section 50.12 request is granted the ,

various management groups will be required to perform their i ' duties for an additional one-to-two year period creating i substantially greater costs to the Project.

4

't In addition, the design and engineering con-tractors (the Architect / Engineer - Burns and Roe, and the Reactor Manufacturers - Westinghouse, General Electric, and Atomics International) also perform management and ,

administrative duties which are keyed to project comple-I tion. The managerial functions performed by these groups i-d j must continue during any period of delay through Project completion.

j The Aanlicants' estimate that the cost of

!, maintaining the various management groups for an additional one-to-two year period is $42.3 million per year. A

' description of the Project management activities and the

! calculation of increased costs due to delay is included in Appendix A.

i 1

f

,,n,+,.,-,.,-----,,,- --,,--,--,--.n, ,n~, , , , , --,-,-..---.-~,.----wn.,n, ,

~~ ~~ - ~ ~~ ~ ~ - '""

_ _ _ -.. .. 1. .- .._

t i

2. Inflation In estimating the effects of inflation, a compari-son was made of the cost of certain activities assuming a delay in initial criticality from Saptember 1988 to February 1990. The difference in cost between these two periods (17 1

-months) represents escalation due to inflation at the rate of eight (8) percent per year. In making this comparison I

only those costs which were cons-idered particularly sensitive to schedule delay were escalated over the i seventeen month period. The schedule sensitive costs included construction, Project Office, Operations and Main-tenance, fuel costs and offsetting revenues.

The Commission h~as recognized the necessity of considering the cost impact of inflation when balancing the Section 50.12 factors. In Carolina Power & Light Co.,

(Shearon-Harris Nuclear Power Plant, Units 1, 2, 3 and 4)

LBP 74-18, 7 AEC 538,. (1974) the applicant estimated that, i

absent authorization to immediately begin site preparation, the total project cost of $1.6 billion would increase at the

! rate of 5 per cent per year due to inflation. Based on the applicant's estimate, the Licensing . Board found that the public interest would be served by granting the Section 50.12 request on the ground, among others, that in permit-ting site preparation to begin immediately the project would i

save six months of delay and the consuming public would not

. _ . =_ - _ , _ _ _

_......-7._.._.._...__._

1 l

)

+

1 .

ll .

be forced to pay an additional $42 million for increased construction costs due to- inflation. On appeal, the Com -

21 mission noted the applicant's cost estimate and agreed with the Licensing Board that a grant of the Section 50.12 request was in the public interest in light of the cost savings which would result. Carolina Power & Light Co.,

3 I (Shearon-Harris Nuclear Power Plant, Units 1, 2, 3 and 4)

i

] CLI 74-18, 7 AEC 939, 941, 944 (1974) .

In light of the economic circumstances of the CRBRP Project, the necessity for considering the cost impact of inflation is even greater in this case than in Shearon-Harris. Unlike Shearon-Harris, the CRBRP Project is funded through Congressional appropriations and thus operates with, and all costs are estimated based upon, year of expenditure dollars. Total project costs are estimated using a standard 3

8% escalation value. Any increased costs due to delay in

[

,i this case will be borne by the nation's taxpayers, and the l> Commission should not ignore the adverse effects of inflation upon the taxpayer.

The Applicants estimate that the impact of a one-

. to-two year delay amounts to $88.8 million per year or $7.4 million por month. The calculation of the effects of in-flation on the selected cost items is included in Appendix B.

l l

T i

j

3. Interest on Capital 1 -

Whenever an organization, including the United 1

States Government dedicates funds to a capital project, it 1 . foregoes the opportunity to invest those funds in alterna-u tive projects which will earn an equal or greater return on 4

' investment or to pay off debt on which the capien1 costs are i '

being incurred. In short, the organization " ties-up" capital i

F and incurs an opportunity cost. Although certain components of the cost may be difficult to measure, it is, in an l economic sense, a real cost and is included as a cost in an investor owned utilit'ys. accounting and racemaking.

The Federal Government has explicitly recognized  :

interest on' expended capital'as a construction cost. Cost Accounting Standard 417, Cost of Monev as'an' Element of the

,! Cost of Capital Assets Under Construction provides:

ll The cost of money applicable to the inves tment in tangible and intangible

capital assets being constructed, fabri-

+

cated or developed for a contractor's

} own use shall be included in the i capitalized acquisition cost of such

'; assets.

{'

[j See also Cost Accounting Standard 414.

l' A one-to-two year delay in the Project schedule will result La additional cost on expended capital during the delay period. In order to arrive at a conservative i

estimate of the cost of capital during the delay period, a l

f' l 6

1 u.

I: 9

'l 1,

)

rate of 10 percent */ was applied only to the capital costs 1

for hardware.**f The delay costs amount to $43.9 million on i a yearly basis or $3.7 million per month for every month of dela . The calculation of capital costs is included in d ***/

! Appendix C.

ii '

il j conclusion l A period of delay of one-to-two years beginning in -

l March,1982 will result in (1) cost increases attributable

t 1

5 to certain unavoidable management activities of $42.3

' million per' year, or $3.5 million per month; (2) an infla-

tionary impact on cost prorated on a yearly basis of $88.8 million or $7.4 million per month; and (3) increased q

interest on expended capital for hardware alone of $43.9 million per year or $3 7 million .per month. As these q

it estimates demonstrate, for schedule delays in the range of d

il 1-2 years, grant of the Section 50.12 request would, on a 1

i

[

• / The interest rate applied is substantially less than that established by the Secretary of Treasury pursuant to Public Law 92-41. See CAS 417.50. As of January.1, l- 1982, the rate established by the Secretary of Treasury was 14 3/4 percent. 47 Fed. Reg. 366 (Jan. 5,1982)

• • / . Applied to total capital costs the yearly cost of capital attributable to delay amounts to approximately

$110 million per year

• • • / The applicants have not included in their cost calculation any amount resulting from the deferral of revenues for the period of delay upon completion of the Project.

J t

e

$ conservative basis, save or avoid-increased Project costs of l $120-240 million. -

1 a

7 t

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le If II r

l.

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. - , , _ . . . . _ , . __ . . . . , _ . _ , . . ~ . _ - , , . . . _ . . . _ . . . . _ _ . _ . . _ , , , . . _ _ , . _ _ , . _ _ _ - . _ . _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ . _ . . , . _ _ _ _ , _ _ _ .

. . _ . _ ~. . _ . _ _ . - . . _ . ._ . . . . . . . .

i I

F APPENDIX A PROJECT MANAGEMENT ACTIVITIES Overall project management is the responsibility l- of DOE's integrated project office, which includes Project Management Corporation.- Within that framework, major ele-ments of the management functions for the Project are per-L formed by the Project's principal contracters which are I

j Stone and Webster Engineering Corp. for construction,

! Westinghouse (LRM), lead reactor manufacturer, and Burns and l Roe as Architect-Engineer. Additional management functions L are.perforned by the three reactor manufacturers, Westing-j house RM, Atomics International and General Electric. A

! description of the management activities performed by these

• /

l organizations to establish the basis for the costs- of -

j maintaining each of these organizations at irreducible man-1 power levels during a period of delay is as follows:

1. CRBRP Project Office - DOE and PMC j The CRBRP Project Offics is responsible for the overall management of the CRBRP Project, including the direc-tion of all Project activities to accomplish the design, l

i

• ] The cost calculations are based on an assumed one year delay period which is somewhat less than the delay

which corresponds to the NRC Staff's estimated LWA schedule. If the delay should extend beyond one year, costs.would be increased in approximate proportion to the additional delay. .

'l 4

d .

1. manufacturing, licensing, construction, testing, and opera-tion on a utility system, of the liquid metal fast breeder reactor demonstration plant. At the present time, the Pro-ject Office is comprised of an integrated staff of Depart-5

,j ment of Energy, Project Management Corporation and utility industry employees. The major functional responsibilities ,

of the Project Office organization include: Engineering and

'i design, plant licensing and public safety, construction l

i operations, procurement, quality assurance, project control, financial management,-legal support, labor relations and i

i public information.

The following chart shows the major organizational

'l elements of the Project <0ffice and the designation of the i

'l employer of the manager of each element.

)

1 i

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O

, z-- ------------_:-- . _

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1

- l:

CRBRP FROJECT OFF. ICE

! IDENTIFICATION OF KEY POSITIONS 1

[ ME MC X Director -

X Deputy Director -

i X Assistant Director -

X Executive Assistant -

l 4

X Assistant Director for Construction -

4 X Chief, Construction Management Branch -

I X Chief, Cost and Schedule Branch -

j X Chief, Inspeccion and Test Branch -

X Assistant Director for Operations X Assistant Director for Procurement -

4 X Deputy Assistant Director -

k I Assistant Director for Public Safety -

8 X Chief, Licensing Branch -

.. X Chief, Safety & Environmental Branch -

X Chief, Reliability Branch -

X Assistant Director for Engineering -

j.  ; X Deputy Assistant Director -

4 X Chief, Civil, Structural &

i Mechanical Branch -

X Chief, Reactor and Plant Systems Branch -

l} Chief, Reactor and Plant Components X

Branch -

X Chief, Instrumentation, Control &

Electrical - Technology Branch -

X Chief, Engineering Support Branch -

X Chief, Engineering Management Branch -

X Chief, Configuration Management Branch -

X Chief, Information Division -

- X Chief, Project Control Division -

• X Chief, Counsel Division -

+ X' Chief, Administrative Services Division -

X Chief, Automatic Data Processing Division -

X Chief, Labor Relations Division -

4 9

___._._.m._.-______.__

1. _  ;

4

-i

j. .!'

i d

X Chief, Quality Assurance Division -

X Chief, Quality Verification Branch -

X. Chief, Quality Engineering Branch -

X Chief, Quality Improvement Branch - l 1

X . Chief, Financial Management Division -

~,

X Chief, Accounting Branch - ,

s X' Chief, Budget Branch -

d

}. X Chief, Audit Division -

.. a The Project management activities performed by PMC and DOE must continue during any period of delay. The 3

design, planning, scheduling, licensing and procurement activities will, continue during any delay period and through ,

Project completion. -It is essential that the Project Office

[ . ensure that those activities and the resultant expenditure

1 of funds be performed in a cost effective manner. This l requires that a substantial level of program management 2

staff be maintained during the delay period. In addition, l the Project Office mitst also maintain sufficient staff in f

] order to manage properly and efficiently the construction

- activities that will take place following the delay period.

In calculating the increased cost associated with i continued management during the delay period, the Project Office (i.e., PMC and DOE) staffing levels were reduced to i.

the minimum number of personnel necessary to maintain the Project during the delay period. Reductions below those'

-L 4 shown on the following graph are not possible because the delay period of one-to-two years is of sufficiently

l l

! l l

l short duration to make th,e expenditure and effort to V, terminate and rehire impracticable.

i l'

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=

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8 DOE E iTIMATE I ITH AND W/0 DEL & -

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t . 48 - _ __f.9*=*sswg 4p i ,# 48 1 $%g

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3/82 3/83 3/84 3/85 3/86 .

3/87 3/88 3/89 3/90 ,

! - ESTIMATE W/0 DEALY

! " ESTIMATE WITH DELAY

- - ' - - ~ ~ ~

55 -

.4

.. i Based on the projected staffing levels during the

.4 period of delay, the Project Office will incur additional costs attributable to delay as follows:

PMC Li l' Average

}

j Staffing Level Rate *f Cost /Yr.

1 i 170 $36.6K $6.2M

?

DOE Average

, Staffing **/

Level Rate Cost /Yr.

30 $53.8K $1.6M a

' .j i

1

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.)

"j .

h

• / The rate per man year was based on actual PMC costs i- incurred in 1981. Costs are expected to. increase during fiscal years 1982 and 1983 and, therefore, the L

use of the actual fiscal year 1981 rate is clearly

' conservative.

• • / The rate per man year was based on actual DOE costs for fiscal year 1981. Costs are expected to increase during fiscal years 1982 and 1983 and, therefore, the use of the actual fiscal year 1981 rate is clearly

. conservative.

, . - , , - - - ,- . .,-~,,-,-.----,e g-. -

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'2 . 'destinahouse LRM h v

' The primary function of Westinghouse LRM is to ,

i: s ,

}.

,, ' prov[de the CRBRP Nuclear Steam Supply System. In fulfill-w ing this function, Westinghouse LRM's activities must con-

! tinue through constructf on and until project completion.

l l ,, Specific functions which will continue at or near the pre-jL sent level of effort are:

4

i. - , A. Provide guidance.for the planning and imple-mentation of the reactor manufacturers' work in the design, . quality assurance, procurement, manufacture, assembly and operation of the Nuclear Steam Supply System p (NSSS) of the CRERP. -

3 i B. Integration of the NSSS through top level I -. design guidance (OPDD 10), preparation of overall systems l studies in order to interface the several systems and

i i; contractors; review of designs in order to assure appro-

=-

i -

priate design consistency.,among the three reactor manufac-

• turersi establish and control NSSS interfaces; participate in

} aystem design. reviews and manage the resolution of key i ff system review actions.,

i C. Assist in licensing activities and coordinate

[ " (

t the , reactor manrfacturers input into the licensing process.

, ,f. .

D.. - Continuing coordination with the Architect-y 7 Engineer, including review of designs' relating to the

, nuclear island. .

a .

4

'l . . -

~

^

__.-______f -

_.q . . : . _ . - _. __ . . .

i E. Negotiation of scope of work, budgets and schedules with the three reactor manufacturers and the Project Office.

F. Continuing coordination with Stone and Webster to establish the construction schedule assuring ,

proper integration of the NSSS schedules with the develop-ment of a more detailed construction schedule.

As the above described activities demonstrate, Westinghouse LRM's activities continue throughout the period of design, manufacture,' construction and operation of the ,

CRBRP. Reductions in the planned Uestinghouse LRM staffing levels in the event of a one-to-two year delay in starting site preparation activities would not be practicable or cose effective for the following reasons:

A. The majority of the planned activities after the period of delay are tied directly to the support of con-struction and licensing efforts. The present staffing levels are not only necessary to maintain the Project during the delay period, but are also necessary to provide the required level of assistance during construction and licensing. The construction schedule would be disrupted if Westinghouse LRM did not have intact the experienced technical and managerial personnel necessary to begin construction and licensing activities.

' ' ~ ~ ~ ~

. - - = - - __. _ _ _ . ~_.... -. .._ .__. _ _ .

1 ._

-- 58 -

B. During the period of delay, a substantial level of effort must be maintained in the overall management of the NSSS program. This management function will continue 1 until Project completion.

"- C. Even if some minor reduction in personnel I were possible, the delay period of one-to-two years is suf-a ficiently short that the time periods to renove staff and 5 the lead time to add staff will overlap, making the expen- .

diture of effort to terminate and rehire staff impractica-ble. More. importantly, the loss of continuity and resultant inefficiencies in the event that a portion of the assembled i '.

LRM staff is disbanded, will have a significant, adverse a

imp ~act on the remainder of the Project.

1 The effect of a one year delay on the LRM 1taffing .

I level is demonstrated by the following graph:

5 i:-

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-*- - , . , ~ , , - ..e._,, . . - , - - . . ,.-,,-.-y,-.- ewe.,e-.._n..-,. -

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TA  % 3 T SE g R EY  % U C

SE C MN g O EO T 0 7 S ST 0 ,% 3 8 YU 1

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E NW g G A .

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A 1*g 6 S 8 E c

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$] 632k t$ gg Prw  ;

? : !l r8 i l 1' i i j!!j1

If the Project is delayed by only a one year

• period, Westinghouse LRM and, therefore, the Project will incur increased costs for approximately 101 additional man I

i years of effort.1] Expressed in dollars, the cost impact of I a one year delay will be $11.2 million.

i Westinghouse LRM (Non-Systems)

[ Staff Rate **/_ Cost /Yr.

i 101 5110.5K 511.ZH

'! In calculating the cost impact of delay, it was assumed that

-o Westinghouse LRM would maintain its staff at current levels

- during the period of delay, i

1 h

1 i

t l */ The staffing levels include only LRM non-systems personnel who are not performing discrete systems work. LRM systems staffing levels are as follows:

l 3/82 3/83 Average Increased Cost

! 24.7 23 23.9  !-

• • / The charging race is based on actual historical

--~

data and includes direct labor charges, overhead, G&A, associated ' materiala and services and R&D costs totalling $110.5K per equivalent direct man year. The FY 82 rate was applied to both FY 82 and FY 83 but does not include an increase due to inflation or increased costs for FY 1983.

l ......... _. .

1

$i

3. Stone & Webster Enaineerina Corp.

Stone & Webster's primary function is construction of the Clinch-River Breeder Reactor Plant. In fulfilling

[.

i this function, Stone & Webster is responsible for providing Y

construction management,-labor, materials, related construc-e tion equipment, construction facilities, certain plant equipment and project quality records management. In order i

merely to maintain the Project during a period of delay of t

one-t'o-two years, Stone & Webster's activities would include

. the following:

I A. Continued supervision of the overall con-A struction planning; B. Preparation of various studies related to a revised construction schedule and levels of funding;

! C. Revision of the present construction

engineering plan in light of the delay; n

j. D. Maintenance of Project-wide automated equip-

'I yment, document systems as well as cost and scheduling inputs to internal Stone & Webster automated control systems; E. The solicitation process for for site pre-f paration activities. will be . undertaken a second time;

F. Quality control planning for site preparation activities will be undertaken a second time.

Stone & Webster's staffing level can be slightly reduced during a period cf delay through normal attrition. ,

_ _ _ _ _ _ _ _ _ - - _ _ - - - _- __.--_-__m-__ _ _ _ ._ . _ _ - _ _ . _

7 4 -_. -

7....

1; i

f

- Substantial reductions, however,-are not possible for a number of reasons. .

First, ~t he planned activities during the period of h . ,

delay are predicated on the planning, scheduling, estimating i

systems and procedures being maintained on a current status

. in order to prevent disruption.of the construction schedule 1

j at the end of the delay period. Second, key management h- staff must be in place during the build-up of staff to sup-port construction in order to provide continuity in carrying out Project goals and activities. Third, during a delay of

. one-to-two years, the time periods to remove staff and the i lead time to add staff overlap making the expenditure of effort to terminate and rehire staff unjustified. More importantly, the loss of continuity in management and the resultant inefficiencies in the event a portion of the

- assembled managers is disbanded, will have a significant adverse impact on the start of construction. Finally, dur-ing the delay period, Stone & Webster must continue to ,

!' coordinate with the architect-engineer and the reactor manu- ,

facturers in order to ensure that the design as evolving can in - fact be ~ constructed.

It-is estimated that approximately 20 percent of the Stone & Webster effort during the delay period will

.further schedule progress. The remaining 80 percent level 9-of effort will be needed to maintain the Project

l1 1 . .

I 4

construction program without appreciably furthering the Project schedule.

The following graph demonstrates the effects of 4

delay on the Stone & Webster staffing schedule.

4 i

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e 4

I 4

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E T N I

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OW T

S

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6 PR AA RF 6 GY m 8 (

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5

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9 1 2 8

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4 1

5 o 5 0 5 0 2 5 2 o s

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7 6 i

- ' 5g3 t$o bih i w . ~

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, i1 ' i1l i ii bii  ;  ;

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A one year delay in the Project schedule will have the following cost impact:

Stone & Webster l Average *j 80%

! Staff Rate Cost /Yr.

140 13HT8K 56.6M (l

i. In addition to performing various management acti-vities, Stone & Webster also provides interim storage for the Project which will continue during any period of delay.

Interim storage includes'not only the physical warehousing of equipment, but also continuing inspection and maintenance.

Inspections are performed at the time each item is received

~

and periodically as scheduled by the particular supplier's shipping plan. The inspection schedules range from twice monthly to yearly and are primarily visual inspections and, ,

Il on occasion, electrical tests. The shipping plans also

!a it l

o-

• ] The rate waa derived from an estimate of the Stone j & Webster costs for the last six months of fiscal

4 year 1982. The rate includes salaries, overhead,

,! payroll taxes, salary related expenses and office LL material expenses. The total cost for the second tj half of fiscal year 1982 was calculated by applying i

average salaries per man month for the six month

!j . period to the average man months expected to be

.needed during the second half of fiscal year 1982 E and applying overhead and payroll taxes at current l

rates and adding allowances for computer and office expenses based on per month current expenditures.

A second total cost for fiscal year 1983 was also ll- calculated resulting in a significantly higher rate due to anticipated-cost increases. In order to

-l 2 ensure a conservative estimate, the lower fiscal

• year 1982 rate was applied for the entire one year during this period.

1:

i i - require certain maintenance including rotation of motor .

shafts, filling with oil, maintaining a nitrogen or dry air j purge and lining containers with disiccant for humidity

control.

Stone & Webster's storage areas run the full 4 spectrum of classifications including Level A (heated, air li e

{ conditioning, and humidity control), Level B (heated), Level

~

C (unheated building) and Level D (outdoors). At the present time, . Stone & Websters storage facilities are broken into two major areas, Oak Ridge and Memphis. The Memphis facilities which were developed for barge delivered components include two warehouse areas of approximately 42,000 sq. ft.

~

The major components stored in Memphis include:

NAME ,

SIZE WEIGHT (in ft.)

. Sodium Dump Tanks (3) 30W x 30L x 27H 150,000 lbs each

, Primary Sodium Overflow 22L x 18W x 18H 107,000 lbs li Vessell (1) l; Sodium Pump Guard Vessel'(3) 33L x 20W x 25H 57,300 lbs each l' Reactor Guard Vessel (1) 71L x 24W x 27H 46L x 18W x 19H 480,000 lbs li' Intermediate Heat Exchanger 111,468 lbs each l Guard Vessel (3) l Ex-Containment Tanks (2) 32L x 19W x 18H 114,000 lbs each l Reaction Products Separator 17W x 17L x 24H 77,000 lbs each Tanks (6)

L i- - In-Containment Tank (1) 23L x 18W x 18H 98,000 lbs The Oak Ridge facilities, used for truck and rail deli-

! veries, presently consist of three areas of various levels Lc totaling 96,470 sq. ft.

l-l, 2,900 sq. ft. of Level A l

l' __

~ ~ ~ ' ~'

... ._. . .. .. . e _.

- 67 -

U .

19,860 sq. ft. of Level B 5,460 sq. ft. of Level C

't 68,250 sq. ft. of Level D 3

ji Soar of the major components stored at the Oak Ridge facili-

-i i ties include:

NAME SIZE WEIGHT q

(in f t.)

il Intermediate Heat Exchangers (3) 60L x 14W x 14H 405,000 lbs each Steam Drums (3). 42L x 9W x 9H 200,000 lbs each-Demerator 100L x 12W x 12H 187,075 lbs each Feedwater Heaters (11) Varies Varies Sodium Pump Drive Motors (5) 10L x 14W x 17H 90,000 lbs each Protected Water Storage Tank (1) 69L x 13W x 13H 93,000 lbs-each Primary Sodium Check Valves (3) 12L x 8W x 8H 18,200 lbs each Condensate Pumps (3) 4L x 4W x 18H 6,400 lbs each Condensate Pump Motors (3) 5L x 6W x 7H 6,000 lbs each Recirculation Pump Cogonents Varies 6,200 lbs each-Recirculation Pumps (3) .

7L x 7W x 13H Varies.

Recirculation Pump Motors (3) 8L x 8W x 9H 10,000 lbs each In-Vessel Transfer Nkchine Varies s.. Varies Components Sodium' Pump Drive System (4) Varies Varies Plant Protection System Cabinets Varies Varies t' Control Rod Drive Mechanism Varies Varies Components Head Heating System Components Varies Varies

^

Desuperheaters (4) 5L x 4W x 4H 1,925 lbs each Hoke Valves Varies Varies O Yarway Valves Varies Varies Condenser Shells (2) 60L x 10R x 9H 160,000 lbs each Condenser Hoewell Components (2)- 58L x 3W x 9H 22,000 lbs each 1

Condenser Water Boxes (8) 10L x 6W x 8H 10,000 lbs each f

9

• + r -a w ee, -em.--.-g.--9.,-- ., w. p+c+e - - -%

1. e- ee-w wmw w--*-veer- w-,we 4 ** vow-s w vei c ew+,- - - --.e--ww.w-w--ew-'rw e

L f During fiscal year 1982, (March-Sept.) the interim storage costs are expected to total $266,000 as follows:

l- Memphis Oak Ridge Monthly Cost March-Mo. Cost ~ Mo. Cost Cost Sept. 1982

~

525K $13K 538K . 5266K During fiscal year 1983, (October-March 1983) the

interim storage costs are expected to total $240,000 as follows:

Memphis */ Oak Ridge Monthly Cost October Mo . Cos t -- Mo. Cost Cost March 1983 V35K 513K 548K 5240K Thus, the total cost impact.on the Project due to Stone & Webster's (1) continued management activities and (2) continued interim storage during the period of delay amounts to $7.i million on a yearly basis.

4. Westinghouse RM, AI and GE The three reactor manufacturers perform a substantial amount of management activities (non-systems) which continue throughout the construction program. A delay

t. of one-to-two years at the beginning of the Project, while the Project seeks a LWA 1, will require the reactor

• / The Memphis subcontract for storage provides for escalation. In addition, the monthly charge will

' increase in FY 1983 by $8000 per month due to storage of EVST equipment and increased maintenance costs.

I

f i

i .

manufacturers (RM) to perform their non-systems work for an

. additional one-to-two years.

i-j- The non-systems work being performed by the RM's which must be " carried" during the delay period includes the following:

A. Quality Assurance ! - Direct and manage the

- Quality Assurance Programs; conduct the Audit and Vendor

. Surveillance Program; manage and oversee the Corrective Action Program -for (1) Unusual Occurrence Reports, (2)

. material non-conformances, (3') audit and surveillance defi-ciencies and requests for corrective action; assure imple-

- mentation of the established requirements for shipping and i storage of components (hurdware and software.)

i. B. Program Control - Provide scheduling cost and budget planning and data management and administration;

~

l continue to implement the performance meansurement system

('

(PMS); maintain all PMS documentation; maintain cost control lj - pregram; maintain quality records management system.

,y h~

• f Approximately one-half of the Quality Assurance staff will perform work which will further schedule progress. The cost for the QA staff performing this work has been excluded from the cost computation.

• • / Approximately one-half of the Program Control staff at the three RM's are involved in activities which will

! further schedule progress. The cost of the Program Control staff involved in such activities has been excluded from the calculation of delay costs.

u

P.i - _ _ _ _ _ _ . . _. ..

. o. s C. Systems integration and Construction Support -

. Continue to obtain and factor-in results of on-going develop-i ment programs: issue impacts to proposed changes to NSSS and

~t BOP de' sign for hardware and software in order to maintain the design currents provide input for Plant Operation and Start-up it f procedures, and perform OM&T and ALARA reviews to maintain the 1 procedures currents update and ensure proper schedular integra-

)

tion of design interfaces between systems, the AE and construc-tors provide liaison information to the constructor and the AE in support of their activities: maintain and update the details of the construction cost estimate.

D. Licensing Support - Preparation of materials 5 in support of licensing reviews: provide technical and design expertise to support Project licensing review $ maintain the t

. PSAR and FSAR.

The above described non-systems activities are required to provide continued (1) management of the cost and I - schedule baseline, (2) administration of component con-

.i.

tracts, (3) maintenance of an effective quality assurance f

program, (4) support of activities to license the plant and

_( 5) integration of the design as it finally evolves. These activities must continue through the period of plant con-struction and in certain instances until project completion.

Accordingly, a delay of one-to-two years in the start of

j. .

1

I .

construction will require the RMs' to perform these activities for an additional one-to-two year period of time.

.j- As the following graph demonstrates, the non-

-i .

systems staffing levels for the three reactor manufacturers will average approximately 100 man years during a one year 4

- period of delay.

1 .

i 4 '

I

. i.

9 4

0

%$ 9 / )

% 3 R

% A

% E 4  % Y 3 _

g 0 9 L

A b 8 C

/ S

% 4 3 I F

% D

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g I H' .N 4 M T

4 3 IY  % T A

WA g -

L 3 EE 8 E R TD 4 / M UC I

A ,7 3 MR 4 6 T C IA O TE g S SY  %

E E 'M D

EN LO g 7 E E

TT i m  %

% 8

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%7 Y0 1 6 R S1 E NI OW N

MN T

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S E

RA M 0 -

1 6 t S

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- 0 l

i 1

P A

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5 8

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== 1 0

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== 4 A

L E Y D A L 8 E

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W W EE

++

TT AA 3 MM

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i 8 0 5 0 5 0 7 5 2 ~

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1!  : !  : , : -! ;iil lllli j!l! l;ii!! < I f!

~i I

.a Although it is anticipated that the RM staffing levels will increase during the assumed one year delay

period in order to provide the appropriate level of con-i struction support and systems integration following the period of delay, the calculation of cost assumes no staff

[ increase.

The cost of maintaining the RMs' non-systems staff

on a yearly basis is as follows

Staff Rate Cost /Yr.

100 $101.6K $10.1M I

t

• /

~~

The rate is a composite for the three reactor manu-facturers and is expressed in equivalent direct man-years. The~ rate includes direct labor charges, over-head, G&A, associated materials and services and R&D costs. The rate of $101.6K is for FY 1982 and does not i include any increase due to inflation or increased costs for FY 1983.

_ - - - - _ - - - - - - - - - - _ _ - - - - - - . - _ - - - - - - - - - - - - - - - - )

L,

^

b C. Project Operations - Provides for administra-tive services in areas of planning and scheduling, cost con-

. trol, financial management, plant cost estimating, data con-trol, development and maintenance of plans and procedures and document control.

d, D. Licensing and Environmental - Provides for the ongoing preparation of input to licensing documents such as i the PSAR, FSAR and ER, and permit acquisition assistance.

E. Project Office - Provides direct liaison with

Project Office.

The anticipated staffing levels for Burns & Roe during the delay period are shown on the following graph:

?

- l-I i

l i

A I

4

, , _ _ , ~- , , _ _ , _ - -

. 0 )

9 R

% / A s) 3 E Y

L

_-  % A C

Y

% S EA . 2%

6 4

4 9 I

F _

TL 8 -

I AE . / D ND  %

b 3 I I

% M TR g SA T EE  % A _

- Y S g R ME U EN 7%' 2 C I

TO S a. 6 8 E O C

YT = 8 M -

SU O * /

3 I

T S

'M NH OT NI

• D E

E 0D RN H

• 7 A

E G

A 7 R 1 & 8 E H / V ST 3 A .

NI g

. RW S U  % E -

B M 4  % U 0 g S 1 ' S A

I

% 6 8 H g ' / P

% 3 A R

% (

G 9 % 4 0

1%

1 i

i% M 5 8

/

% 3 Y

g A

, L 2%

3 t 9 1

EY DA TE L

4 l

~

1 8

l 0 D.

m

/

3 HH, TT I I

%p WW 1 2 E E.

T T f 0 A A MM.

2 3

1 r# f1 3 8

I I T T, S

S_

Y

/ E E

,a 3 m .

m u

m 2 8 ._

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2 3 0

1 6 _

0 5 0 5 5 - '

7 2 5

1 2

1

,0

.;i

. .' , , , ~ i i . !;!

j' l

l As the staffing levels on the graph demonstrate, Burns & Roe must maintain a staffing level of 102 during the

• /

period of delay.- The costs associated wich this staffing

-level are ,

! Burns and Roe

.i~ Average

• • /

j. Staff Rate Cost /Yr.

t

. 102 $60.2K $6.lM 1

. CONCLUSION In the event of a one year delay, the Project will incur increased management costs as follows:

Cost /Yr.

Project Office $ 7.8M

. . Westinghouse LRM 11.2M Stone & Webster 7.lM j RM 10.lM

. Burns & Roe 6'.lM i ' Total $42.3M i

'l 4 '.;

~/ The staffing level excludes approximately one-half of the Quality Assurance personnel who will engage in

i<

activities in which further schedule progress.

• • / The rate is for FY 1982 and is applied to FY 1983. The

. rate does not include any amount to account for inflation or increased costs in FY 1983.

~

1 i= .

APPENDIX B, IMPACT OF INFLATION ON PROJECT COSTS In estimating the impact of inflation on Project costs, only those cos'es which were considered particularly sensitive to delay were escalated to account for inflation.

s j' The cost of engineering and hardware were not escalated on the assumption that both procurement of hardware and design

[

l- work could continue during the period of delay.

In estimating the' effects of inflation the base l

Y

j. data used were cost estimates of various cost sensitive

] items assuming an. initial criticality of September 15, 1988. 'The cost of these items was then escalated at 8% per year in order to approximate the cost of these same items o assuming an initial criticality of February 15, 1990 as follows: ,

.i 1roject Expenditures Project Expenditure 9 it Assuming a 9/15/88 Assuming a-2/15/80

q. Work Categories Criticality *_/ Criticality J

! Construction $890.5M $993.5M ll Construction Contingency 113.3 126.4 W Fuel /SNM 264.6 295.2 P Fuel Contingency 16.8 18.7 B Project Office 105.1 117.3 Operations and Maintenance 306.5 342.

! Revenue (611.2) (682.1) l _. Total Cost $1085.6M $1211.0M i

m Difference in Cost $125.4M Monthly Impact of Inflation $7.4M ($125.4M t 17)

I ll */

Actual expenditures through FY 1981 have been excluded.

Il n

l :'

Y

~~

s. . .

I

' 6

) .

! APPENDIX C i .

j INTEREST ON EXPENDED CAPITAL FOR HARDWARE i,

In calculating the cost of expended capital, a rate of 10 percent was applied to Project hardware costs which is significantly less than the rate published by the Secretary of the Treasury. In addition, the rate was applied only to the cost of hardware expected to be expended

!- as of October 1982 l

Actual Hardware Costo Through FY 1981 - $371.2M Estimated Hardware Costs Through FY 1982 - 67.3M Total Hardware Costs Through FY 1982 - $438.5M Cost of Expended Capital per year (at 10%) $ 43.9M

~

• / October 1982 represents the approximate mid-point cf a one year delay beginning in March !982. Additional expenditures during the last six months of the delay period are expected to at least equal the expenditures during the first six months. .

4 .

( *.  !

QUESTION 10:

Provide the documented basis, criteria and the project scope to support the cost estimates for redressing i' the site, should the project be terminated, f

[ ANSWER:

The SPAR, as restated in the Applicants' December

31, 1981 submission (See Table 2 at p.12), estimates a cost of $6.8 million for redres.s of the site in the event that i

the project is not completed. In addition, the salvage value of construction equipment and temporary plant facili-ties would provide revenues of some $13 million. This estimate' assumed a scope of redress activities consisting of backfill of excavations for major plant buildings and the

'$ quarry; regrading, reseeding and landscaping of the general

ette'and quarry areas; and removal of the. crushing facility i

and temporary plant facilities. The construction utilities, l-access road and railroad and barge facilities were assumed to be left intact in view of the fact that the site is dedicated to future industrial use. This analysis will pro-vide additional detail concerning the bases, criteria, and scope'for redress activities and the cost estimated therefor. /

• /

~~

All costs estimated in the SPAR and herein are calculated on the' assumption that all site preparation

- activities are completed before redress is conducted.

Of course, if site preparation activities are not com-(Continued)

The scope of site preparation activities and the corresponding scope of redress activities proposed in the Applicants' SPAR, along with the corresponding sections of the ER and FES addressing each category of site preparation

,a y activities, are correlated as follows:

REDRESS SITE PREPARATION ACTIVITIES j (SPAR) (ER) (FES) 1 1 1. General Site Clearing, 5.1, 5.2 4.1, 4.1.1, 4.2.1 Excavation and Grading ,

4.1.1.6 j 2. -Temporary Plant 5.3 4.1, 4.1.1. 3 4.1 Facilities 4.1.1.5

3. Access Roads, 5.4 4.1. 2. 3 4.2.1, Railroad Spur 4.4.2, 4.6.1.1

4. Construction 5.5 4.1.1.3 4.3, Utilities 4.6.1.1

5. Permanent Main 5.6 none none

-] Control

.i 6. Quarry and Crushing 5.7 4.1.1.8 4.1 Facility 4.2.1, l 4.4.1 i

The bases, criteria, scope of redress activities,

]

j- and costs for each of the above six categories of redress activities are described in the following discussion.

,i A. General Site Clearing, Grading and Excavation.

a The redress plan contemplates backfilling the excavations made for the foundations of the permanent plant

' pleted, costs of redress are likely to be less than the 6

amounts estimated herein.

i

.g.

l4 j ..

1-;

facilities and backfilling other depressions within the q ,

construction area. / Subsequently, the area would be graded j to facilitate drainage, topsoil stockpiled during site clearing would be replaced, and the redressed construction area would be reseeded.and landscaped. These activities are addressed in Section 5.1 and 5.2 of the SPAR, as well as of that portion of Section 5.3 associated with parking areas, il temporary roads, and work and storage areas.

The costs associated with these activities are estimated at .appro'ximately $5,470,000. The bases for this estimate are as follows:

1. Backfill - 1,000,000-cubic yards at $4.50/yd. $4.500M

2. Grading, dressing - 484,000 square yards at

.048

$.10/sy.

3. Topsoil - 823,000 sy at S.81/sy. .667 i

4. Landscape - 170 acres at $1500/ acre .255 E 5.4 70R One million cubic yards (cy) of backfill would be required to fill in the facility excavation up to a finished grade of 812-814 feet MSL, sloped for drainage. The unit ,

cost of $4.50/cy was a composite value calculated by Stone &

L Webster (S&W) based on recent work completed by S&W, adjusted for site conditions and local area labor costs. .

l i

l *f The impounding ponds would remain in place.

,7

! .m

-^w

. .- x

+.

]

j ,,

83 -

)

c

] { g The S&W cost estimate-for backfilling is higher because -

f the backfill nrast be compacted (up to 100 ft.) in order 1 '

i to prevent later' settling of earth within the excavation, w

and to make the ice compatible fur industrial use.

The. area graded, approximately 100 acres, would be that in the immediate area of the backfill work. The cost of $.10/ square yard for simple grading and leveling.was.

- based on recent work by S&W. The value was compared to

- values for similar work contained in Building Construction y Cost' Data,_ edited and published by Robert Snow Means, in order to benchmark the estimate.

~

The amount of topcoil replaced (823,000 sy) would cover the 170 acres of the $(pdral site area at an average s ..

N' 5 depth of six inches. The unit cost of $.81/ square yard is the estimate for hauling the topsoil from its stockpile area

W

\'

and spreading it over the backfill. The estimate was bench-c s marked against the Means' publication described above.

3  %

\'

' The landscaping entails seeding, fertilizing and maintaining the area until the grass becomes established.

The 170 acres to be landscaped represeiits the general site

~

s y area. The unit cost per acre of $1500 for landscaping was i

F T h 'iased on' information obtained from the Office of Surface

x. -

Mining, Knoxville, which estimated landscaping at $1000 per c .

.p .7

- acre and from a ~ local strip mine operator, who reported such

^

(4,_

y%x,

~ R  %-

~ ~

i costs at from $300 to $1000 per acre. The value was conser-vatively increased for this calculation to $1500 per acre.

Grading to facilitate drainage would leave the

site in a condition most compatible with its intended future LJ

!; use for industrial purpoces. Restoration of the site to its

i

original contours (with two ridges straddling the area where

.t.

( the main excavation will be located) would be entirely

'I inconsistent with future industrial use. If recontouring were required, however, total restoration costs (in millions of dollars) are estimated as follows:

1. Backfill - 900,000 cy at $4.50/yd. S4.050M

2. . Grading - 1,500,000 cy at $1.75/yd. 2.625

3. Topsoil - 1,050,000 sy at S.81/sy .851

4. Landscape - 217 acres at $1,500/ acre .325 -

S7.851M In order to carry out-redress to original l- contours, a two-step process would be contemplated. First, l

' the facility excavations would have to be backfilled and

brought to the original elevation without regard for the ridges now located on either side of the excavation area.

1}ue backfill would require closely controlled compaction of 900,000 cubic yards (cy).- This amount is less than the

'I preceding estimate since portions of the existing area for, the excavation are below elevation 812-814 MSL.

The unit

< cost of $4.50 per cy has the same basis as the preceding 3, .

e 1

- ,,. , - , , - - _ - .,,,n..

-..n, --,,- -- -- , , - , - , _ . , , - - - - - - - , . - - , - - . - - - - -

• ~

, . . r .

s t l

Second, grading 1 ] would be undertaken to restore j estimate.

the ridges to their original contours. The amount to be graded is approximately 1,500,000 cy at a unit cost of

$1.75/cy. The unit cost was based on estimates received from the Office of Surface Mining in Knoxville, which t  !

q reported gradiag costs for strip nining operations in East Tennessee'at from S.75 to $1.25 per cy. The cost was increased to $1.75 per ey in order to provide a conservative 3t .

f estimate.

r The area requiring topsoil and landscaping, 217 acres (1.05 million sq), increased from the 170 acres found in the preceding case since restoration df the ridges increases the area to be landscaped. The unit cost

? ,7;;;I s estimates of $.81/sy for topsoil and $1500 per acre for

> } ---

.Y landscaping are as discussed above.

'l'

~

The total cot for redressing to original contours t- -

increases-general site redress and backfill costs by

-;; approximately $2.4 million.

m On the-basis oc the foregotna, the costs of redress for the general site and excavation are estimated to

.< jf The grading required for this phase would differ from that discussed previously. The grading for the planned redre'ss work is limited to general grading and leveling. The grading required for restoring original contours entails grading, dumping, scooping .and

.[ ,

g

- compaction to restore the two ridges on either side of r rf ~ -_. .the planc location to original contours.

m .. .

/

Y

.) Q.

range between $5.47 million (redress for industrial purposes) and $7.85 million (redress to original concour). ,

B. Temoorary Plant Facilities.

The redress of temporary plant facilities is dis-cussed in Section 5.3 of the SPAR. Such facilities as the

~

concrete batch plant, administration building, on-site ware-house, TVA substation and other miscellaneous buildings can be dismantled and removed, if required, or can remain in place to support other work at the Clinch River site.1) The costs to dismantle and remove all temporary plant facilities total approximately $490,000. A breakdown of these costs (in millions of dollars) is as follows:

Concrete Batch Plant $ .030M

, TVA Substation- .100

.; Temporary Services .050

- Administration Building .150

On-Site Warehouse .080

-i Craft Change House .030 Other Misc. Buildings .050

- 5 490M The cost estimates for removal of the temporary plant facilities are based on historical experience con-sidering the cost in man-hours and equipment rental to remove non-salvageable building superstructures and founda-tions to-belou grade. Concrete pads would be removed, as 2/ Current plans call for the administration building and warehouse to be part of the permanent facility. The other structures would be removed at the completion of the construction phase of the project.

i

would any pipes or other protrusions out of the ground. The cost estimate assumes that all salvageable material would be

, removed beforehand (see section G).

! C. Access Road, Railroad Spur Line, and Barge Unloading l Facility

'lf Redress of the railroad spur line is discussed in

Section 5.4aof the SPAR. It is likely in the event of pro-I j, jact termination that the railroad spur would remain intact

since it enhances the value of the site for alternative industrial uses. If required, however, the railroad ties, rails and accessories could be disassembled and removed, fill material and topsoil replaced and the area of the spur line reseeded. It is estimated that the Applicants could receive approximately $439,000 in salvage value from a cen-tractor for allowing the removal of the ties, rails, and accessories. The cost to the Applicants for other redress work, which includes spreading 2 feet of backfill and landscaping and saeding, would be approximately S74,000, broken down as follows:

i

1. Spread 2 ft. backfill

• 11,600 cy at $4.50 per cy S52,200

2. Haul and Spread Topsoil i 19,360 sy at S.81 per sy 15,700

! 3. Landscape / seed 4 acres at $1500 per acre 6,000 S73,900 The 11,600 cy is the amount required to cover the area of the railroad spur with 2 feet of backfill. This backfill would require compaction to prevent erosion. The

1 I

unit cost of $4.50/cy, which reflects this compaction requirement, is as previously discussed in section A above.

I p The four acres requiring topsoil and landscaping i

corresponds to the area of the railroad spur. The basis for r

the unit costs are as discussed in section A above.

The permanent paved access road will be con-t structed for the most part on an already existing dirt and

! gravel access road. Since no purpose would be served by degrading a paved road to a gravel road, no redress of the access rcad is contemplated by the Applicants. If such work were required,.however, the estimated cost of such work would be approximately $94.,000. This figure is based on:

1. Remove and dispose of asphalt binder course 37,000 sy at $.65 per sy $24,050

2. Surface with 6" gravel

. 37,000 sy at $1.90 per sy 70,300 594,350 The amount of asphalt removed, 37,000 sy, repre-sents the entire area of the paved road on the site. The L

i F unit cost estimates for removal and resurfacing with gravel were based on quotes by a local contractor.

! Redress of the barge unloading facility would

[

require spreading backfill over the facility and reseed-ing. Estimated cost of such redress work is $88,000, broken down as follows:

4 i

i s s

'l - -

39 - .

1. Spread backfill

$6 4, .':50 14,300 cy at $4.50 per cy t 2. Spread Topsoil 1 21,296 sy at S.81 per sy 17,250 l< 3. Landscape.

4.4 acres at $1500 per acre 6,600 588,200 The 14,300 cy of backfill would cover the area of the barge facility with 2 feet of fill. Compaction of the backfill would be required to prevent erosion. The bases t- for the unit costs for backfilling, topsoil, and landscaping are as discussed in .Section A above. .

D. Construction Utilities.

Redress of construction utilities, i.e., potable water, electric and sewer,'is di.scussed in Section 5.5 of '

the SPAR. In all likelihood, such utilities would remain intact in the event of project cancellation since they would

~

be required for any subsequent development of the site as an industrial park. . If directed to do so, however, the Appli-c' anes will remove all' above-ground appurtenances associated with the utilities, such as cables, hydrants, pumps and tanks, including diemantling and removing the sewage treatment plants.

The cost associated with such redress is estimated at'$25,000, for removal of the following:

i

1. . , -. -. -..+ ,w .-- --, - ,.--. ,, - - , , - , . - , . , . . _ . _ _ , , -,, ,, . . , - . , ,,

t 90 -

Cost Salvane Value Pumps, Tanks, Hydrants $5,000 $15,000 Sewage Treatment Plants $20,000 $180,000

$25,000 The costs were based on the estimated can-hours and equipment required to demolish and dispose of the non-i

, salvageable material. The salvage values for the equipment t -l and facilities are in addition to those set forth in section F

G below. A net salvage value of $20,000 for the fencing was also calculated' based on an est'imate from a local contractor 4 as to the amount he would be willing to pay for the oppor-tunity to remove the fencing and keep all nacerial.

E. Main Control Devices and Benchmarks.

Redress of main' control lines and benchmarks is

discussed in Section 5.6 of the~ SPAR. The horizontal i n ' control devices such as targets, concrete monuments, markers ,

I and similar devices would be removed. Benchmarks and vertical control devices would probably be left in place for t

future survey reference but could be removed, if required.

- .The cost of this activity is relatively insignificant and is included in the overall scope of work and cost for general ,

site redress.

- 91*-

F. Quarry and Crushinz Facility. ,

- Redress of the on-site quarry to approximately orig 1nal contours and removal of the crushing facilities are

discussed in Sections 3.7 and 5.7 of the SPAR. The redress .

j' plan calls for removal of the crushers and backfill of the 1 quarry area with aggregate and spoil material stocepiled on-site during the quarry operation. The Applicants would then

complete redress by returning the topsoil removed during the initial site work at the quarry, by grading to restore to original drainage lines, and by reseeding the area.

The cost of redressing the_ quarry area at the and of site preparation is estimated at $1,057,000, broken down .

as follows:

1. Backfill and grade 400,000 cy

- at $1.75/cy. $ .700 l 2. Remove crushers .114 j 3. Spread Topsoil 217,800 at $.81/sy .176

4. Landscape 45 acres at $1500/ acre .067

{

$1.057ti

{

The basis for the unit price of $1.75/cy is j discussed in section A above. The 400,000 cy for backfill and grade represents the volume of material required to fill i the quarry and grade to approximately original contours at the time that site preparation work is completed. The cost for removal of the crushers was based on the estimated man-

, hours and equipment required for the work. The costs for i

f 9

s .

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topsoil and landscaping are based on the estima es discussed in section A above.

rI G. Salvane Value

i The salvage values calculated at the end of site preparation can be' broken down as follows

Salvage Value L 1. Concrete Batch Plant $ 2.347M

,, 2. Quarry Equipment 2.381

3. Heavy Equipment, Light 4.690 Equip., Small Tools

4. Administration Building 1.100

5. TVA Substation .450

6. On-Site Warehouse 1.050

7. Other Misc. Facilities / 1.408 Materials Delivered but not yet incorporated Total $13.426M j The salvags values for categories 1-3 were based

't on standard references such as the Green Guide -- The

'l Handbook of New and Used Construction Equipment Values ,

! published by Nielsen na taquest.. The values for categories 4-7 were based on S&W data on the historic salvage cost for similar types of equipment.

1 H. Recapitulation and Summary.

4

. The estimated costs of redress are summarized on

- Table 5 attached. The cost of redress will range from $7 i

• / Table 2 of the Applicants' December 31, 1981 submission incorrectly states this total as $13.326M.

i L.

l

[ -

I million to $9.5 million. In the base case presented in the SPAR, the site will be redressed to a state which is most l compatible with future industrial use at a cost of $7 i million. Additional redress can be effected to a state

• /

which removes all improvements at an additional cost of less than S.2 million ($7.204 million total). Restoration of the general site area to original contours can be effected for some $2.4 million of additional cost,.but as with the removal of improvenents, the site would be less suitable for industrial use. Revenues from salvage of construction equipment, materials, and facilities would range between $13 and $14 million.

• / Does not include redress of access road at a cost of $94,350.

TABLE 5 REDRESS COSTS (Cost in $ Million)

SPAR (Case 1) Case 2 Improvements Removed Redress Salvage Redress Salvage Cost Value Cost Value General Site Redress and Backfill 5.470 5.470 Quarry and Crushing Facility 1.057 1.057

.490 3.558 .490 3.558

g Temporary Plant Facilities Construction Equipment ( p",e atch 9.418 9.418 Construction Utilities .450 .025 .665 n 5.ng'and .

! TVA Substatioi t)

Railroad and Barge Facilities .162 .439 TOTAL 7.017 13.426 1.204 14.08 Net Cost (Revenue) (6.409) (6.876) 4 I

l- _ .- ---- , . . - - _ _ _ . . . . . . __ _

l e e QUESTION 11:

At the December 16th meeting, Mr. Silverstrom stated that if the Commission does not approve the request, then the proj.ect will be dead in the water in March.

1 (a) Please explain, including showing what activities will

- be completed by March and what activities will be ready for the first time in March that were not previously ready.

(b) Why is March, 1982 to commence the site preparation activities so crucial to the whole project? Identify any special reasons (either of a technical or an economical nature) why this date is selected.

ANSWER:

(a) By March of 1982, the CRBRP Project will have completed all the necessary planning and procurement activi-ties to allow site preparation to begin. The principal activities that will be completed for the first time in late 6

March that were not previously ready are contractor selec-

' tion and contract award for the site clearing and excavation activities described in the SPAR. A schedule of the criti-cal milestones which lead to selection and contract award is shown in Table 4.

e r- r ' ' - '

TABLE 4 SCHEDULE FOR SITE CLEARING AND EXCAVATION CONTRACTOR SELECTION Activity Date

Mailing of Prequalification Invitations

! November 30, 1981 to Selected Firms 1

l Commerce Business Daily Announcement 4 with Prequalification Requirements December 2, 1981 RFP's Mailed to Prequali ?ied Firms and Joint Ventures January 11, 1982 Prebid Conference January 25, 1982

' Proposals Received March 2, 1982 Contract Award March 29, 1982 (b) In general, the Applicants need to begin site preparation activities for the CRBRP Project at the . earliest possible date so as to obtain the maximum possible savings in project costs. A timely approval to commence site preparation is crucial to meeting these cost saving objec-ll tives.

l The design work and advanced planning necessary to i

i i initiate site preparation work have been completed. As l

l indicated above, however, the schedule limiting item is the award of a contract fors performing the site preparation activities under Section 50.12. This, in turn, was limited by the project's inability to initiate the selection of a contractor for site preparation until project funding for FY 1982 was secured from the Congress. This occurred on November 20 and 21, 1981 when the conference report on Pub.

I

l I

L. No. 97-88 was passed by the House and Senate, respec-tively. Once project funding was secured, the procurement process was initiated, and the schedule set forth in Table 5 was developed. This schedule defines March of 1982 as the 1*

date that a contractor will be selected and be on board to j begin work.

I

)

By the end of March of 1982, the project will be f ready to begin site preparation activities. If approval of

. the Section 50.12 request is delayed, progress towards completion of the project and realization of the cost savings estimated in the SPAR will be lost. If this occurred, the project would indeed be dead in the water as it would have attained a complete state of readiness to

! begin site preparation, but could not do so.

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, DISTRIBUTION LIST

4. *The Honorable Nunzio J. Palladino i Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555

.- *The Honorable Peter Bradford a

Comissioner

] U. S. Nuclear Regulatory Commission

t Washington, D. C. 20555 a

'*The Honorable Victor Gilinsky Commissioner U. S. Nucisar Regulatory Commission Washington, D. C. 20555

• The Honorable John F. Ahearne Commissioner:

1 U. S. Nuclear Regulatory Commission Washington, D. C. _

20555 l

• The-Honorable Thomas F. Roberts I- Commissioner R

.U. S. Nuclear Regulatory Commission Washington,-D. C. 20555 I'm

• Marshall E. Miller, Esquire 1 -

. Chairman

~ Atomic Safety &' Licensing Board U. S. Nuclear' Regulatory Commission Washington, D. C. 20545 L Dr. Cadet H. Hand, Jr.

H Director Bodega Marine Laboratory l University of California P. O. Box 247

' Bodega. Bay, California 94923 i

6 l

.(

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• Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, 3. C. 20545

• Daniel Swanson, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545

[ *Stuart Treby, Esquire Office of Executive Legal Director i

U. S. Nuclear Regulatory Commission i; Washington, D. C. 20545

• Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545

• Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20545

• Docketing & Service Section i Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (3 copies)

William B. Hubbard, Esquire Assistant Attorney General h- State of Tennessee Office of the Attorney General 422 Supreme Court Building Nashville, Tennessee 37219

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! Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 l-l' Lewis E. Wallace, Esquire Division of Law Tennessee Valley Authority Knoxville, Tennessee 37902

• Dr. Thomas Cochran l Natural Resources Defense Council

) 1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 l

c . - . .

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• W l 4

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Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss

] ,

1725 Eye Street, N. W., Suite 506

Washington, D. C. 20006 a

j Lawson McGhee Public Library i 500 West Church Street j Knoxville, Tennessee 37902 Luther M. Reed, Esquire

Attorney for the City of Oak Ridge j 253 Main Street, East t Oak Ridge, Tennessee 37830 Herbert S. Sanger,'Jr., Esquire General Counsel

, Tennessee Valley Authority Knoxville, Tennessee 37902

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Wa hing o D b.'2bb6

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, 1901 L Street, N. W., Suite 805 Washington, D. C. 20036 i

'l Commissioner James Catham 1 Tennesse.e Department of Economic i- and Community Development

!l l Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 l

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