ML19352A415
| ML19352A415 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 02/13/1979 |
| From: | Cockrell R WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Mattson R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18025B195 | List:
|
| References | |
| FOIA-80-587 GO3-79-230, NUDOCS 8104170049 | |
| Download: ML19352A415 (7) | |
Text
O ROUTING AND TRANSMI1TAL SUP I initials Date TO: (Name, o# ice symbol, room number, butidsng, Agency / Post) 2.
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Action Fue Note and Retum Approval For Cleerence Per Conversation As Requested For Correction Propero Reply Circulate For Your Information See Me Comment investigate Signature C =d; nation Justify REMARKS When responses to these Ticket items are submitted for typing, please be sure the original yellow ticket & attachments are attached so that we will know that the memo / letter being typed is in response to a controlled yellow ticket.
Thanks.
DO NoT use this form as a RECORD of approvels, concurrences, disposals, clearances, and similar actions FROM: (Name, org. symbol, Agency / Post)
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W PP W shington Public Power Supply System A JOINT OPERATING AGENCY SS February 13, 1979 G03-79-230 Dr. R. J. Mattson, Director Division of Systems Safety U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
ATW5 COST WPPSS NUCLEAR PROJECTS NO. 3 AND 5
Reference:
letter, R. J. Mattson to J. Ward, ATWS Cost Estimates, dated November 15, 1978
Dear Dr. Mattson:
As a result of discussions during the meeting which you held with industry representatives on December 6,1978, we have generated order of raagnitude cost estimates for the ATWS fixes describec in the referenced letter for our Nuclear Projects No. 3/5 (Combustion Engineering Pressur-ized Water Reactors).
As I noted in my December 18, 1978 letter to you concerning ATWS costs for our Nuclear Project No. 2, we consider ATWS to be a licensing issue and not a plant safety issue. Therefore, our response regarding fixes should be interpreted only as providing ir. formation and not as an indi-cation of our agreement that these fixes are necessary.
l The following listed assumptions were made in preparing the attached I
cost estimates:
1.
All costs are in 1978 dollars.
2.
The requirement to backfit is imposed in December 1979.
3.
The cost estimates incluoe only direct costs, i.e., design, procurement and installation of eouipment and do not take into account other Owner's costs such as replacement fuel costs, testing and start-up, radiation exposure, etc. These indirect costs in most cases outweigh direct costs.
The estimates for l
Items 9 and 10 do include estimates for extended outage and l
delay in fuel load, respectively, since these items represent l
significant cost item:.
Our willingness to provide the requested information does not indicate an agreement with the need or practicality of any of the suggested back-fits.
In fact, we disagree with the need to treat ATWS as a real event.
However, if required to do so, we believe preventative modifications using a diverse trip system would be the most cost effective.
Dr. R. J. ;bttson G03-79-230 Page 2 2/13/79 Should you have any comments or questions, please feel free to call me (509/375-5221).
Very truly yours, dbexJ,dt R. G. C0CKRELL Manager, Engineering RGC: RCD:ds Attachments cc: GW e'. err, ACRS J Ward, AIF l
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ATTACHMENT A ATWS BACKFITTING COSTS FOR WNP-3/5 RESPONSE TO R. J. MATTSON'S LETTER OF 11/15/78 The following order of magnitude cost estimates are in 1978 dollars and are based on the assumption that the NRC backfit requirement is imposed in December 1979.
'1 Item 1:
Estimated costs of a Supplementary Protection System which satisfies IEEE-279,1971.
I Item WNP-3
,NP-5 W
AE engineering 73,000 73,000 NSSS suppif:d equipment 200,000 200,000 (sensors, trar...aitters, logic assemblies, engineering and circuit breakers)
Electrical, I&C installation 52,000 52,000 (cable, terminations, equipment pads, instrument racks, tubing, i
field fabrication, installation, contract administration and construction management)
Total Direct Costs 325,000 325,000 Sales Tax 18,000 18,000 Financing 60,000 78,000 Total Costs 403,000 421,000 Schedule Impacts Provided tne backfit effort begins no later than December 1979, this fix could be incorporated prior to fuel load for WNP-3 and WNP-5 with a low probability of schedule delay.
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Item 2:
Estimated cost of diverse actuation circuitry for auxiliary feedwater systems satisfying the criteria in Section IV.4 of Appendix IV of NUREG-0460.
Item WNP-3 WNP-5 AE design 147,000 147,000 NSSS supplied equipment 353,000 353,000 (sensors, transmitters, logic assemblies, circuit breakers and engineering)
Electrical, I&C installation 102.000 102,000 (cable, terminations, equipment pads, instrument racks, tubing, field fabrication, installation, contract administration and i
construction mangement)
Total Direct Costs 602,000 602,000 Sales Tax 32,000 32,000 Financing 110,000 143,000 Total Costs 744,000
000 Schedule Impacts Provided tne backfit effort begins no later than December 1979, this fix can be incorporated prior to fuel load for WNP-3 and WNP-5 with a low probability of schedule delay.
Items 3-6, BWR's only Items 7 or 8 Estimated cost of denonstrating the functionability of reactor coolant pressure boundary valves following two different events (see Mattson to Ward letter for details).
Item WNP-3 WNP-5 NSSS analysis (total direct cost) 57,000 57,000 Sales Tax 3,000 3,000 Financing 10,000 14,000 Total Cost 70,000 74,000 l
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Item 9:
Estimated costs of replacement of those valves discussed in questions 7 and 8 if their functionability cannot be demonstrated.
Assumptions:
A.
NRC requirement imposed December 1979.
B.
NSSS analysis and NRC disposition by June 1981.
C.
Analysis is unable to demonstrate functionability.
D.
WNP-3 will be permitted to operate until the valves are replaced during a 30 day extended refueling outage.
Defueling, removal of existing valves, preparation, installation, NDT, hydrotesting and refueling may realistically require a 1 to 4 month extended outage for the number of valves contemplated. A one month extended outage is assumed for this estimate.
E.
Replacement valves are manufactured, procured and installed prior to WNP-5 fuel load.
Estimate:
Item WNP-3 WNP-5 NSSS analysis 57,000 57,000 Engineering 15,000 15,000 Replacement valves listed in 650,000 650,000 Attachment B Installation 50,000 50,000 RCS hydrotest 50,000 50,000 Pertannel exposures 200,000 N/A (HP services, training, practice sessions, admin.
costs,etc.)
Total Direct Costs 1,022,000 822,000 Sales Tax 55,000 44,000 Financing 188,000 197,000 Cost of 30 day outage 12,900,000 N/A l
(not including cost of replacement power *)
Total Costs 14,200,000 1,060,000
- WPPSS is a power generating agency, and as such cannot estimate the costs of replacement power. However, replacement power costs must be borne by the WPPSS participants and owners, whose costs must ultimately be borne by the consumer.
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Item 10:
Estimated cost of the addition of three pressurizer safety valves.
Assumotions:
A.
NRC requirement imposed December 1979.
B.
Both units will be subjected to this' modification prior to fuel load since the pressurizer compartment must be expanded by approximately three feet radius to accommo-date the additional lines, valves, laydown areas and maintenance areas.
C.
Additional relief valves will be branched off the existing pressurizer penetration.
D.
Rupture disks are provided in the pressurizer compartment and normal bleed line routing to the reactor drain tank is unchanged.
Estimate:
Item WNP-3 WNP-5 Engineering 125,000 125,000 Additional safety valves 400,000 400,000 Installation and hardware 100,000 100,000 (associated piping, rupture disks and civil work)
Total Direct Cost of Fix 625,000 625,000 Sales Tax 34,000 34,000 Financing 114,000 150,000 Total Cost of Fix 773,000 809,000 Cost of delay 120,000,000*
l Total Cost 121,000,000 809,000+
- Schedule Imoacts WNP-3 fuel load delayed eight months primarily due to engineering, rebar fabrication and delivery.
WNP-5 delay :annot be quantified at this time but will probably be similar to the WNP-3 delay.
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ATTACHMENT B REACTOR COOLANT PRESSURE BOUNDARY VALVES POTENTIALLY REQUIRING REPLACEMcE Valve Tyoe Location Quantity 16" Gate SDCS Suction 2
14" Check SIS Inlet to Coldleg 4
3" Check HPSI Flushing Connection 2
2h" Check CVCS Charging 1
j 2" Check RCP Controlled Bleedoff 1
1" Check RCP Seals 4
1" Check Auxiliary Pressurizer Spray 1
2" Globe CVCS Letdown 3
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..,... 2s p.~. i s e,.... i. n Docket flos. 50-508, 50-509, 50-513 February 13, 1979 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comf ssion Washington D. C.
20555
Subject:
Dear Mr. Denton:
At the January 4,1979 meeting of the Advisory Committee on Reactor Safeguards, the NRC Staff provided its recomendations for meeting certain ATWS design requirements. At that time it was stated by the Staff that those plants which received Construction Permits after January 1,1978 were to be considered in the same category with new plants and thus must include modifications required to mitigate an ATWS event. The Staff also noted during this discussion that those plants which would be affected by this implementation date were on notice at the time their construction permits were issued that mod-ifications would be required.
Three (3) of our nuclear projects (WNP-3, -4 and -5) received Construction Permits after January 1,1978. Therefore, we have reviewed our docket files with respect to these three projects and are unable to find information therein which would have given us notice that the modifications being discussed would be required.
Two of these three plants (WNP-3 and UNP-5) are Combustion Engineering).
Reactors which were licensed under the reference plant concept (CESSAR The third (WNP-4) is a Babcock and Wilcox reactor which was licensed simultaneously with a duplicate plant (WNP-1) which is not impacted by the January 1 implementation date. We consider that the effective date of this regulation strikes a severe blow to the Commission's standardization program. One of the principle goals of standardization as espoused by the Commission was to introduce a degree of stability and predictability into the regulatory process, necessary to eliminate uncertainty. This can only be accomplished by both industry and reg-ulator forgoing introduction of changes having only marginal public benefi t.
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- k. R. Denton page 2 We view the decision that is to be made regarding implementation of ATWS modifications on standard plants to be of utmost importance to the future of standardization.
The summary of the January 2,1979 Regulatory Requirements Review Comittee (R C) meeting noted that R3C was evenly divided on the 3
question of what ATWS requirement should apply to standard plants re-ceiving construction permits after January 1,1978.
3 Since the R C has recomended that this question be decided by you, we would appreciate the opportunity to discuss this item with you before that dec;sion is made.
Dr. R. G. Cockrell of my staff contacted you on February 13, 1979, to arrange a meeting with you to discuss the concerns expressed in this letter, and to provide additional information that might assist in gaining a favorable decision.
It is our under-standing you would prefer to have such a meeting after receipt of all coments from industry, due on or before March 2,1979. This is accep-table to the Supply System as we continue to cooperate with your staff in arriving at a rational resolution of the ATWS issue. As this matter is of extreme importance to the Supply System, Dr. Cockrell will contact you shortly after March 2,1979, to arrange the meeting.
Very truly yours, Ye &, f D. L. RENBERGER Assistant Director, Technology DLR:GCS:ds/Im cc: RJ Mattson, NRC A Bournia, NRC GW Kerr, ACRS MW Carbon, ACRS 0
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