ML20210L474
| ML20210L474 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-180, SECY-97-180-01, SECY-97-180-1, SECY-97-180-R, NUDOCS 9708210175 | |
| Download: ML20210L474 (16) | |
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l POLICY ISSUE 1
Auoust 6. 1997 (Information) sEcr-97-180 f_QB: The Commissioners ff_011: L. Joseph Callan Executive Director for Operations SU3 JECT: RESPONSE TO STAFF REQUIREMENTS MEMORANDUM OF MAY 28, 1997.
CONCERNING BRIEFING ON IPE INSIGHT REPORT PURPOSE:
To inform the Commission of the planned followup activities that are based on IPE results and on the industry's average cost per person-rem averted in satisfying Station Blackout requirements.
SUMMARY
Based on IPE results, the staff is planning followup activities, which will be detailed in a alan that will be final in December 1997. Further, in response to this SRM tie staff has performed a gross scoping analysis of the costs and benefits associated with the Station Blackout rule. The staff's analysis concludes that. on average, the industry's response to the Station Blackout rule results in costs of slightly less than $5000 per person-rem averted.
Given that the value or benefit of averting a person-rem is in excess of $5000 (averted health effects plus averted offsite and onsite property effects) the staff's analysis suggests that, on average, the Station Blackout costs and benefits were essentially the same. Furthermore, the overall average cost per person-rem averted is heavily skewed by a relatively few plants that spent $5 to $10 million 3er reactor. Most reactors were estimated to have incurred costs of less tlan $1 million, and thus, their corresponding cost to avert a person-rem was considerably less. For example, the staff's analysis concludes that more than 70 percent of the reactors incurred costs of less than $1000 per >erson-rem averted. In addition, a number of plants have received, or are in t1e process of receiving, credit for Station Blackout nodifications in terms of extensions in allowed outage times for diesel generators. These CONTACT: NOTE: To BE MADE PUBLICLY AVAILABLE IN Joseph A. Murphy RES 5 WORKING DAYS FRoM THE DATE OF THIS PAPER
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The Commissioners 2-credits represent an economic benefit to the licensee because they reduce the need to shut down the plant to Jerform maintenance on the diesels and they aromote a maintenance process tlat is more cost effective. These benefits lave only the staff' partially been factored into our cost benefit analysis, and thus. !
s estimate tends to overestimate the true cost of averting a person- ;
rem.
BACKGROUND:
In the staff requirements memorandum (SRM) of May 28. 1997, concerning briefing
" on IPE insight report. the Commission directed the staff to
... provide the scope and schedule of activities related to using IPE results to assess regulatory effectiveness in resolving major safety issues. The Commission specifically requested that the staff provide an estimate of the average cost to respond to the Station Blackout rule per person rem averted in achieving an average reduction in core damage frequency of 2E-5/RY." .
DISCUSSION:
Follow Vo Activities Based Voon IPE Results As reported in the PRA Implementation Plan, the staff is planning folluwup activities based on IPE results (item 1.7 of the plan). These followup activities will include assessing the effectiveness of the resolution of major safety issues (e.g., reactor coolant pump seal integrity. Station Blackout .
rule. ATWS) to see whether additional generic action is warranted, assessing whether any new generic safety issues warrant investigation or research, and assessing the need for plant-saecific actions based on IPE results. Criteria are being developed to guide tie identification of those plant-specific items -
to be included in the followup activities. The criteria would include factors such as whether any event sequences exceed the criteria for cost benefit analyses-contained in the Regulatory Analysis Guidelines how close the plants are to the Safet/ Goal Quantitative Health Objectises and why, and whether licensee actions discussed in the IPE submittal were in fact completed. NRR and RES are also working on defining their res)ective roles in implementing the IPE followup activities. The scope and scledule of these activities will be detailed in a plan that will be final in December 1997.
I Station Blackout Rule Averaae Cost An NRR Station Blackout tracking system was used to identify the plant-specific requirements and modifications performed by industry to satisfy the Station Blackout rule. This data base includes results for 74 nuclear power plants representing 108 active power reactors. For this analysis, the
, requirements and modifications were judged to include one or more of seven cost elements, for which generic or average cost estimates were developed.
Attachment 1 identifies the cost elements, corresponding dollar estimates, and the basis for e3th of the cost estimates. Appendix 1 provides more detailed
, plant specific data.
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s l* The Commissioners 3-Based on this analysis. the staff estimates an average cost of about $2.2 million per reactor. The staff assumes that, in general, Station Blackout requirements were completed in 1993. This translates to an average remaining useful life per reactor of 24 years. Ifoneassumedthatthe$2.2million average reactor cost were evenly distributed over the reactor's remaining life, the 24 year levelized annual cost per reactor, based on a 7 percent real discount rate, would be equivalent to about $190,000 per reactor year. For sensitivity analysis purposes, if one assumed that half the reactor population opted for an additional 20-year license renewal term, the average remaining reactor life would be approximately 34 years, and the level 12ed annual cost would be about $170.000 W reactor year, Benefit - Averted Perseg In NUREG 1109, "Re Safety Issue A 44 gulatory/Backfit Analysis Station Blackout," for the the average Resolution population doseof associated Unresolved with a severe accident caused by a Station Blackout event is estimated at about 2 million person rem per reactor (within a 50 mile radius of the site).
Based on the Commission's assumption that the Station Blackout rule achieved an " average reduction in core damage frequency of 2E-5/RY," the average benefit per reactor year would be approximately 40 person rem averted (2 million person rem x 2E-5/RY),
Dollars ner Person-Rem Averted The average cost per person rem averted on an annual per reactor basis is
$190,000/40 person rem averted = $4.750 per person rem averted.
This result, however, does not fully attribute other values or benefits to the Station Blackout requirements: actuall benefits being realized by licensees. y,As there are substantial a result economic of installing alternate power (e.g., additional diesel generators), licensees have been granted relaxations in their limiting condition of operation (LCO), which affects the allowed outage time on their diesels. With these relaxations, plants can remove their diesels from operation for an additional 4 to 11 days without having to shut down the plant. Since a t overhaul every 5 to 10 years on average, ypical diesel requires a majora licensee c year of incremental downtime. Given that the average replacement energy costs for a typical reactor are $500,000 per day, the economic savings per reactor-year are $0.5 to $1.0 million. To date, 4 plants have received such LC0 extensions, and another 20 are currently under review.
The foregoing analysis is based on a number of simplifying assumptions and conditions: therefore, the relevance and perspective of these results need to be considered in the context of these limiting factors, The staff acknow-ledges that its cost estimates are only gross approximations, For example, no attempt was made to survey the industry. . In certain instances, individual plants were contacted and single point estimates were assumed re)resentative for all reactors that had committed to similar fixes, even thougl plant-specific conditions could result in significant cost variability. The cost estimates are also somewhat subjective because certain modifications probably satisfied joint objectives and requirements, and these modifications should
The Connissioners not necessarily be totally ascribed to the Station Blackout rule. The staff l
attempted to partially address this concern in costing the emergency (safety-grade) diesel generators. As for benefits, average values were used for the population dose and the reduction in core damage frequency even though the regulatory analysis suggests that the eactor specific variability for each cf these terms is a factor of 4 from th average value. This suggests that a good deal of caution should be attached to the differences reported between reactors as depicted in Attachment 2.
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Staff analyses on the value of averting an accident sug cumulative benefits are approximately $U ner person rem gestinthat theof averted terms health effects and averted off-site ano :a. property effects.
This estimate is based on the following ., factors: First, in 1995. the Commission adopted a conversior, factor of 1000 as the monetary value of the health consequences associate 0 with radiological exposure (see NUREG/BR 0053.
" Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission,"
November 1995. p. 22). Second, the mean offsite pro >erty damage costs are estimated to be $3000 per person-rem averted (see NU1EG/CR 6349, " Cost Benefit Considerations in Regulatory Analysis." October 1995. Table 5-4. pp. 5 7). '
lastly, based on estimates developed in the " Regulatory Analysis Technical Evaluation Handbook." onsite property costs are $500 per person-rem averted for a generic reactor with a remaining life of 24 years (see NUREG/BR-0184.
" Regulatory Analysis Technical Evaluation Handbook." January 1997, pp. 5.40 5.49).
By contrast, the Station Blackout rule is averting a person-rem at a cost of about $4.750. This result, however does not give full credit for other sizable economic benefits and it is heavily influenced by a relatively few reactors whose cost to satisfy the Station Blackout requirements exceeded $10 million per reactor. Most reactors were estimated to have incurred costs of less than $1 million, and the corresponding cost to avert a person rem was considerably less.
Attachment 2 shows the distribution of reactors by the average cost per reactor, the average cost aer person-rem averted, and the cumulative percentage of reactors wit 1 costs equal or less than the corresponding reference cost estimate. This calculation suggests that about 70 percent of the reactors incurred costs of less than $1000 per person-rem averted, and 75 percent incurred costs of less than $2000 per person-rem averted.
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4 The Commissioners 5-1 C00R0ltMT10N:
The Office of the General Counsel has reviewed this paper and has no legal objection. This paper has been coordinated with the Office of the Chief Financial Officer and the Chief Information Officer for information.
JL or,eph Callan Exec tive Director for Operations Attachments:
- 1. Cost Elements for Station Blackout Requirements
- 2. Distribution of Reactors by Cost
- 3. SRM dtd. 5/28/97
- 4. Ap>endix 1 - Plant Specific Jata DISTRIBUT1oN Commissioners oGC oCAA oIG oPA oCA ACRS Clo CFo EDo SECY
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i ATTACHMENT 1 COST ELEMENTS FOR STATION BLACKOUT REQUIREMENTS
i ATTACHMENT 1 - COST ELEMENTS FOR STATION BLACK 0UT REQUIREMENTS COST ELEMENT COST ESTIMATE ($THOUSAND)
A. Assess plant's capability to cope with $350 per reactor' station blackout and develop procedures '
and training B. Add Non-class IE diesel generator $10,000 per site' C. Add emergency diesel generator $10,000 per site' D. New batteries $650 per site' E. Add Non-class-lE gas turbine $7,000 per site d F. Battery charger $850 per site 6 G. Minor modifications (e.g. crosstie, valve $100 per site 6 modifications, circuit breakers) 3 " Regulatory /Backfit Analysis for the Resolution of Unresolved Safety Issue A-44, Station Blackout," NUREG 1109. Table 10, p. 20 June 1988.
Based on costs incurred at Dresden and Quad City Plants. Estimate reflects informal discussion between the NRC project manager and licensee.
3 Engineering judgment suggests that a safety-grade diesel generator would cost two to three times the $10 million cost of a non-class diesel (i.e., about
$25 million). However, the addition of a safety-grade generator was well beyond the station blackout requirements. Licensees who added safety-grade generators most likely did so to jointly satisfy other recuirements or objectives (e.g., to reduce the likelihood of costly shutdowns). ~hus, it appears inappropriate to fully charge this cost against the station blackout requirements as the rule could have been satisfied with the addition of a non class-lE diesel generator at a cost of $10 million.
- Based on costs incurred at Palo Verde. Estimate reflects informal discussion between the NRC project manager and licensee.
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" Response to Industry Coments on Station Blackout Cost Analysis "
NUREG/CR-3840. Table 4 November 1986.
6 Covers a wide array of modifications that were judged minor by NRR. The
$100,000 estimate is somewhat arbitrary.
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ATTACHMENT 2 DISTRIBUTION OF REACTORS BY COST
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4 ATTACHMENT 2 DISTRIBUTION OF REACTORS BY COST TO RESPOND TO STATION BLACK 0UT RULE iumber of IIMULA"lVE Averaae Cost Ayeraae Cost Per a
Reactors iRCEN AGE Per Reactor Person Rem Averted 38 35% $350.000 $760 16 50% $400,000 $870 23 71% $450.000 $980 2 73% $675,000 $1470 2 75% $775,000 $1690 1 76% $1,000,000 $2180 1 77% $1,200,000 $2620 3 80% $5,015.000 $10,930 4 83% $5.350,000 $11.660
! 4 87% $5,400.000 $11,7'O 10 96% $10,350,000 $22,560 4 100% $10,400,000 $22,670 TOTAL 108 WEIGHTED AVERAGE $2.206,000 $4750 l
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A~ TAC- V ENT 3 SP 0 VAY 28, 1997
Action: Morrison, RES/
Collins. NRR 6
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/***% UNfftD STMS / Cys: Callan g
- NUCLEAR REQULATORY COMMISSION Jordan g manwoton.or seeneeet Thompson
\ May 28, 1997 IN RESPONSE, PLEASE M970507
##"* REFERTOgfahB .
Ross, AEOD )
MEMORANDUM TO: L. Joseph Callan Exe ivj Di ector for Operations FROM: Jo M
. Hoy k
e, Secretary l
SUBJECT:
STAFF REQUIREMENTS - BRIEFING ON IPE INSIGHT REPORT, 2:00 P.M., WEDNESDAY, MAY 7, 1997, COMMISSIONERS # CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO
. PUBLIC ATTENDANCE)
The Commission was briefed by the NRC staff on the Individual Plant Examination (IPE) insight report. The Commission asked the staff to expedite activities in the following areas (1) using IPE results to prioritize inspection activities; (2) improving regional capabilities for the use of PRA and risk insights; and (3) providing related inspector training.
4EDO) (RES) (SECY Suspense: TBD) 9700206 The Commission asked the staff to provide the scope and schedule of activities related to using IPE results to assess regulatory effectiveness in resolving major safety issues. The Commission specifically requested that the staff provide an estimate of the average cost to respond to the Station Blackout rule per person-rem averted in achieving an average reduction in core damage frequency of 2E-5/RY. These activities should be coordinated with the regulato effectiveness organization.
4EDO) (NRR) RES/NRR) (SECY Suspense 6/27/97) 9700207 After the IPE database has been placed on the Internet, the staff should consider allowing licensees to update their IPEs voluntarily to reflect changes in plant configuration.
(RES)
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i ATTACFMENT 4 APPENDIX 1 -
PLANT-SPECIFIC DATA
APPENDIX 1 - PLANT-SPECIFIC DATA:
PLANTS: [QST ELEMENTS:' COST ESTIMATE (PER REACTOR-51HOUSAND)
ARKANSAS 1, 2 A, B, G 5,400 BEAVER VALLEY 1, 2 A. G 400 BIG ROCK P0lNT A 350 BRAIDWOOD 1, 2 A 350 BROWNS FERRY 2 A 350 BROWNS FERRY ], 3 A 350 BRUNSWICK 1, 2 A, G 400 BYRON 1, 2 A 350 CALLOWAY A 350 CALVERT CLIFFS 1, 2 A,B C 10,350 CATAWBA 1, 2 A 350 CLINTON A 350 COMANCHE PEAK 1, 2 A 350 COOK 1, 2 A 350 COOPER A 350 CRYSTAL RIVER 3 A, G 450 DAVIS BESSE A, B 10,350 DIABLO CANYDN 1, 2 A, C 5,350 DRESDEN 2,3 A, B(2) 10,350 DUANE ARNOLD A. G 450 FARLEY 1, 2 A. G 400
PLANTS: COSTELEMENTS3 COST ES":H E" (PER REACTOR-V HD_ USAND)
FERMI 2 A 350 FITZPATRICK A, G 450 FORT CALHOUN A 350 GINNA A 350 l GRAND GULF A 350 l HADDAM NECK A, G 450 1
l HARRIS A. G 450 HATCH 1, 2 A, F 775 HOPE CREEK AG 450 INDIAN POINT 2 A, G 450 INDIAN POINT 3 A 350 KEWAUNEE A, G 450 LASALLE 1, 2 AD 675 LIMERICK 1, 2 A 350 MAINE YANKEE A 350 MCGUIRE 1, 2 A 350 MILLSTONE 1 A. G 450 MILLSTONE 2 A, G 450 MILLSTONE 3 A, B 10,350 MONTICELLO A, G 450 NINE MILE POINT 1 A, D 1,000 NINE MILE POINT 2 A 350 NOR1H ANNA 1, 2 A,B,G 5,400 OCONEE 1, 2, 3 A 350 OYSTER CREEK A, G 450
4 PLANTS: COST ELEMENTS: 3 COST ESTLMATE (PER RfAC10R $ HOUSAND)
PALISADES AG 450 PALO VERDE 1, 2, 3 A E(2) 5.015 PEACH BOTTOM 2, 3 A. G 400 PERRY A, G 450 PILGRIM A. G 450 POINT BEACH 1, 2 A. C(2), G 10,400 PRAIRIE ISLAND 1, 2 A. C(2) 10.350 OUAD CITY 1, 2 A, B(2) 10,350 RIVER BEND AG 450 ROBINSON 2 AG 450 SALEM 1, 2 A. G 400 SAN ONOFRE 2, 3 A 350 SEABROOK 1 A 350 SEQUOYAH 1, 2 A, G 400 SOUTH TEXAS 1, 2 A 350 ST, LUCIE 1 A, G 450 SUMMER A, F 1,200 SURRY 1, 2 A, B 5,350 SUSOUEHANNA 1, 2 A 350 THREE MILE ISLAND 1 A, G 450 TURKEY POINT 3, 4 A C(2), G 10,400 VERMONT YANKEE A. G 450 V0GTLE 1, 2 A, G 400 WATERFORD 3 AG 450 0
PLANTS: COST ELEMENTS: 1 COS" ES"1 MATE (PER REAC"0R-51HOUSAND)
WATTS BAR 1 A 350 WNP 2 A, G 450 WOLF CREEK A 350 ZION A, G 450 NOTE 1 Cost Element A Assess plant's capability to cope with station blackout and develop procedures and training Cost Element B Add Non class-lE diesel generator Cost Element C Add emergency diesel generator Cost Element D Add New batteries Cost Element E Add Non class lE gas turbine Cost Element F Battery charger Cost Element G Minor modifications (e,g, crosstie, valve modifications, circuit brea',ers)
B(2), C(2), or E(2) indicates that two diesels or turbines were added at the site..
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