ML20213E756
| ML20213E756 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1984 |
| From: | Speis T Office of Nuclear Reactor Regulation |
| To: | Triner E NRC OFFICE OF RESOURCE MANAGEMENT (ORM) |
| Shared Package | |
| ML20213E759 | List: |
| References | |
| FOIA-87-181, REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8403210190 | |
| Download: ML20213E756 (4) | |
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March 7,1984 MEMORANDUti FOR:
Edwin Triner, Director Division of Budget and Analysis Office of Resource Management FROM:
Themis P. Speis, Director Division of Safety Technology Office of Nuclear Reactor Regulation
SUBJECT:
REQUEST FOR PEVIEW OF REGULATORY AtlALYSIS FOR USI A-46, " SEISMIC QUALIFICATI0fi 0F EQUIPMENT Ifl
-OPERATING PLANTS" BY-THE COST AflALYSIS GROUP The Division of Safety Technology has completed the technical resolution of USI A-46 and has prepared a Regulatory Analysis to support _the proposed implementation reautrements.
It is requested that the cost analysis group review the cost aspects of the regulatory analysis, The enclosed package which has been prepared for review by the CPGR was issued on March 6 for review by the NRR Divisions.
You are requested to provide any coments or suggestions you may have by fia rch 15, 1984.
We would welcone the opportunity to discuss the regulatory analysis with you ar.c will provide er.y backup material you need.
DST contact for this package is Newton Anderson, x27476 or T. Y. Chang, x27486.
u G.L -l Themis P. Speis, Director Division of Safety Technology Office of fluclear Reactor Regulation
Enclosure:
A-46 CRGR Package cc:
F. Schroeder J. Clark W. Minners O
N. Anderson
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REVIEW AND COMMENT ON REGULATORY ANALYSIS FOR USI A-46 SEISMIC QUALIFICATION OF EQUIPMENT IN OPERATING PLANTS JULY, 1984 repered by COST ANALYSIS GROUP DIVISION OF BUDGET AND ANALYSIS OFFICE OF RESOURCE MANAGEMENT
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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 Seismic Qualification of Equipment in Operating Reactors. The following comments are offered.
1.
Cost of Replacing Equipment In the current regulatory analysis, cost estimates for impacted 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 -
1984 timeframe.
Based on the Handy-Whitman Index of Public Utility Construction Costs (Bulletin #119 January 1984) construction costs of thisnaturehave,onaverage,incraasedalmost100_%;bitweeWJ975and1984 (on a regional basis the percentage increase ranges from about 90% to 106%). Thus, the 30% adjusbnent 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.
4 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, thes~e 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 having to incur an incremental outage to the 7 ej/ q plant while replacing equipment should be explicitly discussed.
If g 7-4 plant unavailability is likely, significant replacement energy costs must be included in the cost analysis.
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Average Plant Cost The following data
- are provided in the current regulatory analysis as the typical plant cost associated with the proposed new requirement.
Item Estimated Cost (Dollars)-
Define scope of systems, subsystems and
$1,000 - $ 5,000 components required
. Compare data base spectra with site spectra
$ 500 - $ 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 Mis.celtaneous modifications to components
$5,000 - $ 10,000
.to fit experience data Procurement of additional ex'perience data
$10,000 - $ 50,000 or test data Preparation and submission of report to
$3,000 - $ 5,000 NRC 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 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 is possibly for the regulatory analysis to contain a likely scenario which identifies how many pieces of equipment would be subject to just " comparison",
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 for a typical utility cost estimate.
For those specific items that transcend the table 1 alternatives, e.g. plant walk-through, preparation and submission of report, etc., explicit assumptions could be presented concerning man hours of effort and labor rates, etc. to provide a basis for the dollar estimates reported there.
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