Review & Comment on Regulatory Analysis for USI A-46, 'Seismic Qualification of Equipment in Operating Plants.'| ML20136D045 |
| Person / Time |
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| Issue date: |
07/31/1984 |
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| From: |
NRC OFFICE OF RESOURCE MANAGEMENT (ORM) |
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| To: |
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| Shared Package |
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| ML20136C160 |
List: |
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| References |
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| FOIA-85-361, REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8511210214 |
| Download: ML20136D045 (3) |
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Category:NRC TECHNICAL REPORT
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Category:TEXT-SAFETY REPORT
MONTHYEARML20209H5911987-01-31031 January 1987
Budget Estimates.Fiscal Years 1988-1989
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Licensed Operating Reactors Status Summary Report.Data as of May 31,1986.(Gray Book I)
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Cost Analysis Group Review of Regulatory Impact Analyses of Proposed Insider Rulemaking
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Cost Analysis Group (Cag) Comments on Regulatory Impact Analysis of Proposed Revs to 10CFR73.71, 'Reporting of Safeguards Events.'
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Plant-Specific Replacement Energy Cost Estimates for Reg Guide 1.99,Rev 2 Value-Impact Analysis
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1987-01-31
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Text
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. 1 REVIEW AND COMMENT ON REGULATORY ANALYSIS FOR USI,A-46 SEISMIC QUALIFICATION OF EQUIPMENT IN OPERATING PLANTS
-i- JULY, 1984 i
4 ed by:
COST ANALYSIS GROUP DIVISION OF BUDGET AND ANALYSIS OFFICE OF RESOURCE MANAGEMENT
'ucicar Regulatory ,
ission b
i1 -
.,/ .E 4
B511210214 851022 '
PDR FOIA 4 g DELL 85-361 PDH fO
- _ .. o . _ . _ . . . _ , -
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.USI A-46 SEISMIC QUALIFICATION OF EQUIPMENT IN OPERATING PLANTS This report is in response to a request from the Division of Safety Technology to review the cost analysis contained in the Regulatory Analysis for USI A-46 Soismic Qualification of Equipment in Operating Reactors. The following comments are offered. i i
- 1. Cost of Re' placing Eouipment i In the current regulatory analysis, cost estimates for impactej equipment and its installation are based on 1975 and 1981 editions of " Process Plant Construction Estimating Standards," by Richardson Engineering
. Services, Inc. Estimates taken from the 1975 edition were increased by 30% to account for inflation and presumably, no adjustments were made to estimates available from the 1981 edition.
These adjustments are simply not in tune with the actual escalation in construction costs (equipment and installation) in the 1975 - 1981 -
1 1984 timeframe. Based on the Handy-Whitman Index of Public Utility 1
Construction Costs (Bulletin #119 January 1984) construction costs of
- this nature have, on average, increased almost 100% between 1975 and 1984 (on a regional basis the percantage increase ranges from about 90% to
- 106%). Thus, the 30% adjustment for inflation applied to the 1975 data
"! appears totally inadequate. Similarly, between 1981 and 1984 construction escalation has actually been about 15% (on a regional basis the percentage increase has ranged from about 14% to 20%) versus the zero inflation implicitly assumed in the regulatory analysis.
Other concerns with the estimated cost of replacing equipment also exist:
'The data source used in the regulatory analysis assumes equipment is being installed in a new construction environment. However, these modifications constitute replacements to operating reactors where possible congestion, radiation, safety requirements, etc. could substantially limit workers' productivity and thus raise the installation cost. There will also be a need to remove and dispose of the existing piece of equipment which is not reflected in the current cost estimate.
Finally, the likelihood of hav*ng to incur an incremental outage to the plant while replacing equipment should be explicitly discussed. If plant unavailability is likely, significant replacement energy costs must be included in the cost analysis.
1 I
l L -
, . - - . . - _ . . =_, .-. .- . _ _ _ - _ ._
L
- 2. Average Plant Cost l
4 The following data
- are provided in the current regulatory analysis as the j typical plant cost associated with the proposed new requirement.
1 Item Estimated Cost (Dollars) i Define scope of systems, subsystems and $1,000 - $ 5,000
, components required -
Compare data base spectra with site spectra 5 500 - 5 1,000 Conduct plant walk-through $5,000 - $ 10,000 Repairs to anchorage and supports $2,500 - $ 35,000
., Qualification or replacement of relays at $6,000 - $ 10,000
, $500/ relay '
Miscellaneous modifications to components $5,000 - $ 10,000 to fit experience data h, Procurement of additional experience data $10,000 - 3 50,000 l' or test data
- Preparation and submission of report to NRC
$3,000 - $ -5,000 i -
TOTAL
$33,000 - $126,000
- SOURCE: Page 13, Enclosure 1, Regulatory Analysis for USI A-46 The report, however, is basically silent on how or why this particular mix of activities was arrived at as the typical response to satisfy this new requirement. The regulatory analysis' Table 1 identifies four specific i
alternative responses a utility may take to satisfy the requirement. For each alternative, detailed cost data on an equipment basis are offered. It would l appear that some discernible relationship between that data and the results reported above should be provided. Most of the items identified above are
, costed-out without any supporting documentation. The CAG questions whether it 1
' is possibly for the regulatory analysis to contain a likely scenario which identifies how many pieces of equipment would be subject to just " comparison",
4 i
how many to " replacement", how many to " test and analysis", and how many to
" analysis", and then, the cost data in Table 1 could be utilized as the basis r 4
for a typical utility cost estimate. For those specific items that transcend i the table 1 alternatives, e.g. plant walk-through, preparation and submission of report, etc., explicit assumptions could be presented concerning man hours of i
effort and labor rates, etc. to provide a basis for the dollar estimates i reported there. ,
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