ML20105B780

Comparison of Licensing Activities for Operating Plants Designed by Babcock & Wilcox

ML20105B780
Person / Time
Issue date:	01/31/1985
From:	Thoma J Office of Nuclear Reactor Regulation
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NUREG-1110, NUDOCS 8502070590
Download: ML20105B780 (29)

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NUREG-1110 Comparison of Licensing Activities for Operating Plants Designed by Babcock & Wilcox 1

U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation J.O.Thoma

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NOTICE j

Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

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Washington, DC 20555 l

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NUREG-1110 Comparison of Licensing Activities for Operating Plants Designed by Babcock & Wilcox a0eYuished au 1

J. O. Thoma Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20565 p+"*%,

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ABSTRACT This report provides a comparison of a number of licensing activities for the operating Babcock & Wilcox (B&W) plants with emphasis on Rancho Sece The factors selected were a comparison of staff resources expended in I.84, active licensing action reviews, implementation of NUREG-0737 modifications, exemptions to regulations, SALP reports, enforcement actions, and Licensee Event Reports (LERs). The eight licensed operating plants examined are as follows: Arkansas Nuclear One Unit 1 (AN0-1), Crystal River Unit 3, Davis Besse, Oconee Units 1, 2, and 3, Rancho Seco, and Three Mile Island Unit 1 (TMI-1).

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l TABLE OF CONTENTS Page Executive Summary 1

1.0 Introduction 2

2.0 Status and Comparisons 2

Staff Resources 2

Licensing Action Backlog 3

MPA Review Status 3

NUREG-0737 Review Status 3

Plant Specific Review Status 3

Implementation of NUREG-0737 Modifications 4

Exemptions to Regulations 4

SALP Reports 4

Enforcement Actions 4

LERs 5

3.0 Conclusions 5

4.0 Figures 6

Figure 1 Staff Hours Expended in FY84 Through 06/30/84 7

Figure 2 Average Staff Hours Expended per Completed Action 8

in FY84 Through 06/30/84 Figure 3 Total Active Issues for B&W Plants as of 07/31/84 9

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Figure 4 Active MPA Issues for B&W Plants as of 07/31/84 10 Figure 5 Active 0737 Issues for B&W Plants as of 07/31/84 11 Figure 6 Active Plant Specifics for B&W Plants as of 07/31/84 12 Figure 7 NUREG-0737 Plant Modifications Required 13 Figure 8 Exemptions Issued and Still Effective 14 Figure 9 Specific Major Regulations 16 Figure 10 Last SALP Ratings for B&W Plants 19 Figure 11 Violations Issued in Last SALP Period 20 Figure 12 LERs Listed at Last SALP 21 A

v

'Z Executive Summary This report provides a comparison of a number of licensing activities for the operating Babcock & Wilcox (B&W) plants with emphasis on Rancho Seco. The factors selected were a comparison of staff resources expended in FY84, active licensing action reviews, implementation of NUREG-0737 modifications, exemptions to regulations, SALP reports, enforcement actions, and Licensee Event Reports (LERs).

Information used in this report was primarily obtained from the most recent SALP report for each B&W licensee and NUREG-0748, Vol. 4, Nos. 6 and 7, " Operating Reactors Licensing Actions Summary" (ORLAS).

ORLAS is published monthly.

It is not the intent of this report to rank the licensees in any fashion.

Rather the objective is to review basic licensing information and determine if generalized conclusions can be reached.

Plants are listed in order of the date of their operating license. This procedure was chosen to determine if an age correlation existed for any data. However, no significant differences

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were noted based on plant age.

The conclusion of the report is that the eight operating B&W plants, as a class, require above average NRC staff attention.

It takes longer to complete a review on these plants and they have more open licensing issues on the average than the other operating plants.

Because of the relatively small number and unique design of the B&W reactors, they do not experience fully the benefits of " generic resolution" that can be spread over large numbers of plants as can be done with General Electric or Westinghouse designs. Also, the B&W operating plants, with the exception of Oconee, are single unit sites.

It is not directly appropriate to compare a single Oconee unit with the other plants. Neither is it appropriate to simply add the three Oconee units and call it one site and use that for comparison. This statistical variation will explain to some degree, but not fully, the higher than average staff rescurce expendi-ture on these B&W plants.

Other factors which must be considered include the difficulty of individual reviews or the quality (or lack thereof) of the licensee's submittals or responses to staff questions.

TMI-1 has required significant staff resources.

However, in reviewing the seven remaining B&W plants, Rancho Seco also is high-lighted in that it was number one or two in five of the categories reviewed. Specifically, Rancho Seco has the most active licensing issues overall, requires a long time on the average to complete an issue with the staff, has required a significant amount of staff resources to conduct reviews, has eight NUREG-0737 items remaining to be physically implemented, and was the only operating B&W plant to receive a Category "3" SALP rating for both Plant Operations and Licensing Activities.

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OPERATING PLANTS DESIGNED BY B&W

1.0 INTRODUCTION

The following is a comparison of ten licensing activity factors for the eight operating plants designed by B&W. The tables and charts, on which the following discussion is based, were derived from readily obtainable data as of August 22, 1984. The data base includes the status of active multi-plant, NUREG-0737, and plant specific issues as well as inputs from SALP reports, other plant records, and discussions with the assigned Project Manager.

The primary sources of information were NUREG-0748, Vol. 4, Nos. 6 and 7, " Operating Reactors Licensing Actions Sumary" (CRLAS) and the most recent SALP report for s-each B&W licensee. Particular emphasis has been placed on Rancho Seco in each section. However, it is not the intent of this report to rank the licensees in any fashion. Rather the objective is to review basic licensing information and determine if generalized conclusions can be reached.

The eight plants received their operating license in a four year time

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frame starting in 1973. Therefore they are, on the average, seven to eleven years old. Throughout the report, the plants are listed in accordance with their relative age as follows: Oconee-1 (0-1), Oconee-2 (0-2), Three Mile Island-1 (TMI-1), Arkansas Nuclear One Unit 1 (ANO-1),

c Oconee-3 (0-3), Rancho Seco (RS), Crystal River 3 (CR-3), and Davis Besse (08). This procedure was chosen to determine if an age correlation factor existed for any data. However, no significant differences were noted based on plant age.

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2.0 STATUS AND COMPARIS0NS

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m Staff Resources Figure 1 provides the NRR staff hours expended in FY84 per plant through June 30, 1984. As expected, the staff has spent considerable time

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reviewingTMI-1(9014.9 staffhours). However, the staff has also devoted more time to Rancho Seco (2786.3 staff hours) compared to the average of approximately 1700 staff hours expended per licensee for the remaining B&W t

plants. Although the numbers are different, the relative positions are j

the same (i.e., TMI number one and Rancho Seco definitely number 2) for NRR staff hours expended on the respective plants in FY83.

Another indication of licensee / staff inter-relations is the average number of NRR staff hours necessary to complete a review in FY84, which is provided in Figure 2.

The average time for all operating plants is 70.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but the B&W plants as a class average 103 hours0.00119 days <br />0.0286 hours <br />1.703042e-4 weeks <br />3.91915e-5 months <br /> expended per completion.

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TMI-1 averaging 306 hours0.00354 days <br />0.085 hours <br />5.059524e-4 weeks <br />1.16433e-4 months <br /> / completion, Rancho Seco averaging 147.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> / completion, and AN0-1 averaging 121.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / completion are significantly above average even for the B&W units.

Excluding TMI-1, the average staff i

hours expended per completed action for the B&W units would be 74.2 and the overall average for all plants would be 67.5.

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Because of the relatively small number and unique design of B&W reactors, they do not experience fully the benefits of " generic resolution" that can be spread over larger numbers of plants as can be done with General Electric or Westinghouse designs. Also, the B&W operating plants, with the exception of Oconee, are single unit sites.

It is not directly appropriate to compare a 1

single Oconee unit with the other plants. Neither is it appropriate to simply add the three Oconee units and call it one site and use that for comparison.

This statistical variation will explain to some degree, but not fully, the higher than average staff resource expenditure on these B&W plants. Other factors which must be considered include the difficulty of individual

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reviews or the quality (or lack thereof) of the licensee's submittals or responses to staff questions.

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Licensing Action Backlog i

Figure 3 provides the total number of active licensing issues on each B&W plant. The overall average for all operating plants is 43 items per plant; but the B&W units average 52 open items per plant. Rancho Seco, with 60 issues, has the largest number of active licensing reviews among the eight B&W plants and TMI-1 is second with 56 issues.

This is consistent with Figure 2 which reveals that it takes longer or more staff effort to complete a review on TMI-1 and Rancho Seco. This indicates that TMI-1 and Rancho Seco will require a significant portion of the limited NRC staff resources in the future.

MPA Review Status Multiplant Activities (MPAs) are licensing actions which are comon to a given class of reactors (i.e., Control of Heavy Loads).

There are 25 MPAs which are still under review on at least one B&W plant. Of these 25 issues, ten are open on all eight B&W units and two are open on only one plant each.

Figure 4 provides the number of active MPA issues per plant. The B&W units with an average of 16 open MPAs per plant are above the overall average of 13 open MPAs per plant. However, the B&W units as a class are reasonably close to each other for total number of active MPAs. Davis Besse has the highest number of active MPAs with a total of 19.

Rancho Seco has 17 open MPAs.

NUREG-0737 Review Status (TMI Action Plan)

There are 16 NUREG-0737 issues which are still active on at least one B&W plant.

Of these 16 issues, eight are active on all eight plants.

Figure 5 provides the number of active NUREG-0737 issues per plant.

The B&W units with 12 issues open per plant are slightly above the overall average of 10 issues per plant.

But again the B&W plants are very close to each other as a class.

Rancho Seco has 12 open issues.

Plant Specific Review Status Figure 6 provides the total number of plant specific active issues for each plant.

The B&W units with an average of 24 issues per plant are above the overall average of 20 open issues per plant. So in all three licensing action categories, the B&W plants average more open issues than the average of all plants combined.

Rancho Seco with 31 open plant specific items and TMI-1 with 29 issues are significantly above average even for the B&W units.

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Y Implementation of NUREG-0737 Modifications

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-5 Figure 7 provides the number of NUREG-0737 items per plant q"

where physical modifications are still required.

It is based on updating information from NUREG-1066.

Oconee with nine items per plant and Rancho h.

Seco with eight items have more modifications than the remaining B&W units j

which have six or less items to complete per plant, m

2 Exemptions to Regulations

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Figure 8 lists exemptions approved and still effective on each y

plant. The older plants have almost twice as many exemptions still active j*

as the newer plants with the maximum number for a single plant being six exemptions.

Rancho Seco has active exemptions on four regulations.

"2 Figure 9 provides a breakdown of two major regulations, fire

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protection and equipment qualification. As far as technical exemptions to the fire protection rule are concerned, TMI-1 has 13 technical exemptions 1

approved, ANO-1 has 12, and Rancho Seco has six. All the remaining licensees average one technical exemption to the fire protection rule per unit. However, the licensees for Rancho o and Davis Besse have

-i indicated that they will shortly request more s inical exemptions to a

the fire protection rule. To date, no B&W licensee has requested a

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time extension to the Equipment Qualification rule to correct known deficiencies. The Crystal River 3 licensee on July 6,1983 reque:ted a time extension for any unspecified new items identified in meeting the requirements of Regulatory Guide 1.97.

This was just a precautionary

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request in case they identified any new items requiring environmental e

qualification.

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SALP Reports

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red Figure 10 contains data obtained from the most recent SALP for 9

each plant. Ten functional areas used in the SALP rating were common to

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a majority of the plants and are listed in the attachment.

Occasionally there were some unique plant specific ratings listed in the individual 3

SALPs but they are not provided in this chart. The SALP reports evaluate e

each plant for a given period of time ranging from 11 to 16 months. A y

category 3 rating in an individual area indicates that more emphasis is y

v.9eded in this area by both the licensee and the staff. Rancho Seco and 7

ANO-1 were rated in category 3 or 2 in more functional areas than any of M

the other B&W units.

Rancho Seco was the only B&W licensee to receive a 3

category 3 under Licensing Activities and Plant Operations. Based on ratings in the ten functional areas of the SALP report, Rancho Seco and 4

AN0-1 require more future emphasis by the starf than the other plants.

-5 Enforcement Actions Figure 11 provides, a summary of the violations issued on each plant in the last SALP period.

Davis Besse with 26, Crystal River 3 with 26, and TMI-1 with 22 had significantly more violations during their respective i

SALP periods than the other B&W licensees.

Rancho Seco had 17 violations.

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LERs Figure 12 provides a summary of LERs issued per plant during the last SALP period.

The dominant classification of cause for each plant is component failure. However, a larger percentage of Rancho Seco's LERs are classified as personnel errors (13 out of 43 or 30%) than for any other B&W unit. This may be significant as Rancho Seco is the only B&W plant experiencing staffing problems.

3.0 CONCLUSION

S The eight operating B&W plants, as a class, require above average NRC staff attention.

It takes longer to complete a review on these plants and they have more open licensing issues than other operating plants. To some degree, this can be explained due to the unique design of the plants and the fact that they are generally single unit sites.

However, there are other factors involved.

TMI-1 has required significant staff resources.

However, in reviewing the seven remaining B&W plants, Rancho Seco also is high-lighted in that it was number one or two in five of the categories reviewed.

Specifically, Rancho Seco has the most active licensing issues overall, requires a long time on the average to complete an issue with the staff, has required a significant amount of staff resources to conduct reviews, has eight NUREG-0737 items remaining to be physically implemented, and was the only operating B&W plant to receive a Category "3" SALP rating for both Plant Operations and Licensing Activities.

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Exemptions !ssued and Still Effective ^!' . - -(, e.-; ? Plant Date S/T Topic Rule C '.2. Oconee 1/2/3 07/14/77 T Operation for 5 Years Appendix H U with Reactor Vessel l Surveillance Speci-C r.. ments at CR-3 7 q Oconee 1/2/3 10/23/78 T ECCS Small Breaks 10 CFR 50.46 l '.~. r l Oconee 1/2/3 02/02/82 T/S Fire Protection 10 CFR 50 App. R r,b-

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Oconee 1/2/3-06/16/82 S Extension of 07/14/77 Appendix H 'C- [ Exemption .7.p j-Oconee 1/2/3 08/31/83 T Fire Protection Appendix R Oconee 1/2/3 01/06/84 T Emergency Exercises Appendix E 0 o ,} [ TMI-1 04/27/78 T ECCS Performance 10 CFR 50.46 f'q l and Appendix r. g,,.. I TMI-1 05/18/78 T ECCS Performance 10 CFR 50.46 k l (modification of and Appendix K [ 04/27/78 Exemption) .;p w a THI-1 03/16/79 T ECCS Performance 10 CFR 50.46 Y.? '* ' (modification of and Appendix K g 04/27/78 exemption) gg.Q g TMI-1 05/10/82 S Fire Protection 10 CFR 50 and h I Appendix R be v TMI-1 09/14/82 T Emergency Exercises Appendix E

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[ TMI-1 06/04/84 T Fire Protection 10 CFR 50 App. R ? p_ t ANO-1 04/01/77 T Operation for 5 years Appendix H with Reactor Vessel <y = C-4 i Surveillance Speci- ,f.; '.t ments at DB ,g v AN0-1 04/30/82 S Extension of 4/1/77 Appendix H -N >;g.f Exemption 7 ANO-1 05/10/82 5 Fire Protection 10 CFR 50 f,b,. m 'l AN0-1 03/22/83 T Fire Protection Appendix R y ; ". Q. ' 14 i ;,u f ~ ~ -

FIGURE 8 page 2 Plant Date S/T Topic Rule ANO-1 05/11/83 T Fire Protection Appendix R ANO-1 03/22/84 T Emergency Exercise Appendix E RS 07/13/77 S Air Lock Doors Appendix J RS 01/10/83 T Fire Protection Appandix R RS 01/10/83 T Allows Reactor Vessel Appendix H Surveillance Specimens to be irradiated at DB RS 07/25/83 S Reactor Vessel Head 10 CFR 50.44 Vents CR-3 09/01/78 T ECCS 10 CFR 50.46 CR-3 05/04/82 S Fire Protection Appendix R CR-3 02/07/83 T Fire Protection Appendix R CR-3 07/21/83 S Reactor Vessel Head 10 CFR 50.44 Vents DB 01/23/82 T Fire Protection Appendix R DB 08/20/84 T Fire Protection Appendix R OB 09/07/83 S Reactor Vessel Head 10 CFR 50.46 Vents 15

FIGURE 9 i L p i b R f ?r SPECIFIC MAJOR f,EGULATIONS g k I c I-k E: f 'r I b E [' E E 6 16 PF

FIGURE 9 page 2 FIRE PROTECTION EXEMPTION RE00ESTS Oconee 1/2/3 TMI-1 ANO-1 RS CR-3 DB TECHNICAL Requested 9 18 13 9 1 2 Approved 3 13 12 6 1 2 Denied 0 0 0 2 0 0 Withdrawn 0 2 0 1 0 0 Not Needed 6 3 1 0 0 0 SCHEDULAR Requested 0 9 7 0 6 0 Approved 0 6 6 0 5 0 Denied 0 1 0 0 0 0 Withdrawn 0 0 0 0 0 0 Not Needed 0 2 1 0 1 0 TOTAL Requested 9 27 20 9 7 2 Approved 3 19 18 6 6 2 AVERAGE FOR THE 8 PLANTS Technical Requested 7 Technical Approved 5 Schedular Requested 3 Schedular Approved 2 Total Requested 9 Total Approved 7 17

k.a. FIGURE 9 page 3 .y -9 ., h EQ RULE i' ..]. c Schedular Exemptions ~9 l 4 Oconee - None as of yet c-None as of yet '. 1. TMI-1 None as of yet .h ~ ANO-1 '.gy;; None as of yet i.; l RS On July 6, 1983 the licensee fer CR-3 requested a N.l : CR-3 schedular exemption from the EQ rule for any new items '.; 4 identified during the review for requirements of fx Regulatory Guide 1.97. The schedule.to meet Regulatory .fg~ Guide 1.97 is a separate issue from the EQ rule. .; g 3q None as of yet

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FIGURE 10 LAST SALP RATINGS FOR B&W PLANTS 0-1/2/3 TMI-l ANO-1 RS CR-3 DB Functional Area ** Plant Operations 2 2 2 3 2 2 Radiological Controls 2 1 2 2 1 1 Maintenance 1 1 3 2 2 3 Surveillance 3 1 3 3 2 3 1 2 2 2 2 Fire Protection Emergency Preparedness 2 1 2 2 2 2 Security & Safeguards 1 1 1 1 2 2 y Refueling / Design 1 2 1 1 1 1 Licensing 2 2 1 3 2 2 2 QA 2 1 3

• Not rated in the SALP
  • These ten functional areas were selected as they were comon to a majority of the plants reviewed. There were other plant specific functional areas listed in individual SALPs for(example, ANO-1 was also rated for training and management controls). However, these ratings were unique to a particular plant and are not listed.

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.= a NRC PORM 335 U S NUCLt An AEGULATOmV COMMISSIOg i mtPOmf Novst m # Am,aea e, reoC eaa ve< No,,e say, ] y (2 Sei ac,",'#t BIBLIOGRAPHIC DATA SHEET $18 INSTRUCT #ONS ON t=t pivEnst i h 1110 2 feTLt AND SveTsTL4 J LEAv sNu 2 Cmparison of ensing Activities for Operating z Plants Design by R'Wk and Wilcox j/ . o An ac,Oa r COu,u no = j ,EA. .O 1-Decarber 1984 j a Avt,.Oaisi John O. 'Ihma ,0,,,,, l January 1985 7 PtmtomwsNG ORGANt2 AllON N AME AND W LING ADDRES$ ttara or te Coe, s PROJECT T ASK WORK LNif NvwstR = w 2 Division of Licensing ,,,s.,0,,A,,,,,,t,, Office of Nuclear Peac Regulation f U.S. Nuclear Regulatorf 'ssion s Washington, DC 20555 j 10 SPONSORING ORGANi2 AilON NAWt AND MAILING ADL 53 ifachede if Cope, tlaYvPEOFMEPOmY Same as 7. above 'Ibchnical Report .,t ,Oo cOv t a t o,, -m 12 SUPPLEMENT ARY NOf ts 2, j 3 A.sra AC, an e, o, 'Ihis report provides a camparison a of licensing activities for the ) operating R,Wk & Wilcox (B&W) p ts 'th sphasis on Rancho Seco. 'Ihe factors selected were a cmpariso of sta resources expended in FY84, active licensing action reviews, impl tation o; NURE-0737 modifications, exmptions to regulations, SALP reports, orement a 'ons, and Licensee Event Reports (LERs). The eight licensed ating plants . ned are as follows: Arkansas Nuclear One Unit 1 (ANO-1), tal River Uni , Davis Besse, Oconee Units 1, 2, and 3, Rancho Seco, and e Mile Island Un 1 ('IMI-1). E 9 = l 14 DOCUWENT AN ALYSes - e ut vwOaD5 0t5-PTO*45 it AvaitatiLif v s "A"* BaMock & Wilcox (B&W Oconee 1, 2, 3 ANO-l Rancho Seco Unlimited Crystal River 3 'IMI-l Davis Besse Licensing Actions 's secua>Tv eta 55icatiom ? = , rm,,e,,, Unclassified ..ot v.itasetN E oto naws iVme reeertl Unclassified 17 NvWetR OF PAGES 1 14 PmtCE 3 -i- --

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