ML20141F035
| ML20141F035 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1997 |
| From: | Shapaker J NRC (Affiliation Not Assigned) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-97-02, GL-97-2, TAC-M91544, NUDOCS 9705210188 | |
| Download: ML20141F035 (1) | |
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON D.C. 2065FA001
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May 20. 1997 MEMORANDUM TO:
Document Control Desk Document Management Branch Division of Information Support Services J
Office of Information Resources Managen FROM:
James W. Shapaker. Technical Assistant 1 ;
Events Assessment and Generic Communica foT1 Bran Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
DOCUMENTS ASSOCIATED WITH NRC GENERIC LETTER 97-02.
REVISED CONTENTS OF THE MONTHLY OPERATING REPORT (TAC No. M91544)
The Events Assessment and Generic Communications Branch (PECB) in the Divisison of Reactor Program Managment (DRPM) prepared the subject generic letter, which was issued on May 15, 1997, and given accession number 9705020260. There is material related to the subject generic letter that should be ) laced in the NRC Public Document Room and made available to the public. Tierefore, by copy of this memorandum. I am providing the following documents to the NRC Public Document Room:
(1) a copy of the published version of the subject generic letter. (2) a copy of the information paper (SECY-97-092) that was sent to the Commission. (3) a co)y of each letter received in response to the notice of o)ortunity for pualic comment on the proposed generic letter that was publisled in the Federal Register on August 18, 1995. (4) a copy of the summary and resolution of public comments that were received. and (5) a copy of the CRGR review package.
I request that you provide me with the Nuclear Documents System accession number for this memorandum. This information may be provided by telephone (415-1151) or by e-mail (JWS).
In addition, please modify the appropriate NUDOCS entries to reflect the fact that the documents identified herein are related to Generic Letter 97-02.
Attachments:
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i As stated
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION l
WASHINGTON, D.C. 20555-0001 May 15,' 1997
' NRC GENERIC LETTER 97-02: REVISED CONTENTS OF THE MONTHLY OPERATING f
REPORT Addressees All holders of operating licenses for nuclear power reactors, except those who have -
permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.
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Purpose The' purpose of this generic letter is to inform licensees that the NRC is requesting the sub-i mittal of less information in the monthly operating report. This generic letter requires no specific action or written response.
Discussion OVERVIEW The assessment of NRC information gathering needs has been the' subject of several staff
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reviews. These reviews have focused on identifying duplicative reporting, determining whether some reports could be reduced in scope or eliminated, and determining whether -
the frequency of reporting could be reduced. In this regard, the NRC staff concludes that
. l the scope of the information requested in the monthly operating report, which is called for in the Technical Specifications, may be reduced.
NEED FOR THE MONTHLY. OPERATING REPORT l
The impetus for the monthly operating report came from the 1973-1974 oil embargo. Draft Regulatory Guide 1.16, Revision 4," Reporting of Operating Information - Appendix A Technical Specifications," published for comment in August 1975, identifies operating statistics and shutdown experience information then desired in the operating report.
l Licensees have generally followed the guidance of the draft Regulatory Guide. The NRC y
initially compiled this information on.a monthly basis and published it in hard copy form as NUREG-0020, " Licensed Operating Reactors - Status Summary Report" (referred to as the
" Gray Book"). Beginning in 1990, this information was published on an annual basis in hard.
copy form and was also made available on diskette monthly. NUREG-0020 was discontinued after the December 1995 report.
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GL 97-02 May 15,1997 Page 2 of 4 The NRC staff assessed the information that is submitted in the monthly operating report and determined that it is a unique source of information for two of the eight performance indi-cators approved by the Commission for the NRC Performance Indicator (PI) Program.
Performance indicator data are fundamental tools used by the NRC staff to independently analyze nuclear power plant safety performance trends. The performance indicator data provided in the monthly operating report include the number of reactor critical hours for the equipment forced outage indicator, the forced outage hours and generator on-line hours for the forced outage rate indicator, the number of forced outages for the equipment forced outage indicator, and the outage type (whether forced or scheduled) for the forced outage rate and equipment forced outage indicators. NRC will retain the monthly operating report because the agency has a continuing need to receive this performance indicator data, and at the same frequency. Attachment 1 to this generic letter delineates the information that is needed for the Pl Program.
The NRC also has a need to provide operating factor (availability and capacity factors) data to Congress and other govemment agencies on a regular basis. This information is useful as an indicator of the ability of a plant to perform its design function, and provides insights into the safety performance of a plant. In general, a plant with high availability and capacity factors is less likely to experience transients which challenge safety systems.
These data are often used by senior NRC managers in meetings and presentations. The monthly operating report is a unique source of reliable and timely operating factor data for all commercial nuclear power plants to support the information needs of senior NRC managers. Attachment 1 also delineates the operating factor data that is needed.
Voluntary Response Reauested Effective immediately, licensees of operating nuclear power plants submitting monthly operating reports called for in the Technical Specifications may do so in accordance with the guidance provided in Attachment 1 to this generic letter. Implementation of this option by licensees is voluntary. However, licensees will have to take whatever means are appro-priate to negate any prior commitments or requirements to provide monthly operating reports which contain the information identified in Draft Regulatory Guide 1.16, Revision 4, Section C.1.c; this may include an amendment to the facility operating license to l
remove a license condition. Licensees who choose not to implement this option may continue to submit monthly operating reports as they have in the past.
Backfit Discussion The NRC staff has determined that the backfit rule, Section 50.109 of Title 10 of the Code of Federal Regulations (10 CFR 50.109), does not apply to this generic letter because the reduction by licensees of the scope of the monthly operating report to that described in j is strictly voluntary.
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Gl 97-02 May 15,1997 Page 3 of 4 Federal Reaister Notification A notice of opportunity for public comment was published in the Federal Register (60 FR 43174) on August 18,1995. Comments were received from 6 utilities, 2 private industries,1 university,'1 industry organization,1 govemment agency, 3 public interest groups, and 2 individuals (no affiliation). Copies of the staff evaluation of these comments are available from the NRC Public Document Room.
Paperwork Reduction Act Statement i
. This generic letter contains voluntary reductions in'the public reporting burden. The l
resultant information collections are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget, approval number 3150-0011, which expires July 31,1997.
The public reporting burden for this collection of information is estimated to average 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The U.S. Nuclear Regulatory Commission is seeking public comment on the potential impact of the collection of infom1ation contained in the generic letter and on the following issues:
1.
Is the proposed collection of information necessary for the proper performance of the functions of the NRC, including whether the information will have practical
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utility?
2.
Is the estimate of burden accurate?
3.
Is there a way to enhance the quality, utility, and clarity of the information to be collected?
- 4.. How can the burden of the collection of information be minimized,- including the use of automated collection techniques?
Send comments on any aspect of this collection ofinformation, including suggestions for reducing this burden, to the Information and Records Management Branch, T-6 F33, i
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Desk Officer, Office of information and Regulatory Affairs, NEOB-10202 (3150-0011), Office of Management and Budget, Washington, DC 20503.
The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
GL 97-02 May 15,1997 Page 4 of 4 If you have any questions about this matter, please contact one of the technical contacts listed below, signed by Marylee M. Slosson, Acting Director '
Division of Reactor Program Management Office of Nuclear Reactor Regulation Technical contacts:
Marcel R. Harper, AEOD (301) 415-6344 E-mail: mrhi@nrc. gov James W. Shapaker, NRR (301) 415-1151 E-mail: jws@nrc. gov Attachments:
- 1. Monthly Operating Report Contents
- 2. List of Recently issued NRC Generic Letters e
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i GL 97-02 May 15,1997 Page 4 of 4 If you have any questions about this matter, please contact one of the technical contacts listed below.
original signed by Marylee M. Slosson, Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation j
i Technical contacts:
Marcel R. Harper, AEOD (301) 415-6344 E-mail: mrhi@nrc. gov James W. Shapaker, NRR (301) 415-1151 E-mail: jws@nrc. gov Attachments:
- 1. Monthly Operating Report Contents
- 2. List of Recently issued NRC Generic Letters l
l Tech Editor has reviewed and concurred on 03/20/97 l-DOCUMENT NAME: 97-02.GL
- SEE PREVIOUS CONCURRENCES Ta receive a copy of this document. Indicate in the boa: 'C' = Copy w/o attachment /enctosure 'E' = Copy w/sttachment/ enclosure "N' = No copy 0FFICE TECH CONTS l
OGC C:PECB:DRPM AD:DRPM l
l NAME MRHarper*
RKHoefling*
AEChaffee*
MMSlosson i
JWShapaker*
DATE 03/19/97 03/31/97 03/20/97 05/14/97 0FFICIAL RECORD COPY c
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1 Attachmsnt 1
-l GL 97-02 4
May 15,1997 Page 1 of 8 MONTHLY OPERATING REPORT CONTENTS Backaround As part of its mission to protect public health and safety, the NRC monitors the performance of licensees that operate the commercial nuclear power plants in the United States. This monitoring effort aleds the NRC to the necessity of adjusting plant-specific regulatory programs. One monitoring tool being used is a set of eight performance indicators (Pis).
l The Pls provide information about plant performance trends and assist NRC management
- to identify poor and/or declining safety performance, as well as good and/or improving performance. PI reports are provided to the Commission, NRC senior managers, licensee senior managers, and to the public through the NRC Public Document Rooms. Other tools j
include availability and capacity factors, which are provided to NRC senior managers, other i
govemment agencies, and Congress on a regular basis.
Contents of the Monthly Operatina Report Routine reports of operating statistics and shutdown experience are needed to support the NRC Performance Indicator Program, and availability and capacity statistics. Therefore, tt.e following information should continue to be provided in the monthly operating report:
Docket Number, Unit Name, Date, Name and Telephone Number of Preparer, and
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Reporting Month This information is needed for administrative, tracking, and data entry purposes for the Pl Program.
Unit Shutdowns, including:
Sequential number of shutdown for calendar year Date of start of shutdown Type (Forced or Scheduled)
Duration (hours).- to the nearest tenth of an hour Reason for shutdown Method of shutting down the reactor Corrective actions / comments Narrative summary of monthly operating experience.
i This information is needed to calculate the following performance indicators in the Pi report; forced outage rate and equipment-forced outages per 1000 commercial critical hours. The information is also used to confirm the operational phase of each event. The operational phase is identified in the PI report for various initiators: automatic trip while critical, safety system actuation, significant event, safety system failure, and cause codes.
Att chm:nt 1 GL 97-02 May 15,1997 Page 2 of 8 Number of Hours the Reactor Was Critical This information is needed to calculate the equipment forced outage indicator and to tabulate critical hours in the PI report.
Number of Hours the Generator Was On Line (Service Hours)
This information is needed to calculate the forced outage rate indicator in the Pl report.
Unit Reserve Shutdown Hours This information is needed to calculate the unit availability factor.
Design Electrical Rating Maximum Dependable Capacity Net Electrical Energy This information is needed to calculate the unit capacity factor.
Appendices A and B of this attachment provide further guidance conceming the information that should continue to be submitted. Appendices A and B may also be used as a guide for the format of the information submitted in the monthly operating report. The completed monthly operating report should be submitted by the 15th of the month following the calendar month covered by the report to Document Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.
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Att: chm:nt 1 GL 97-02 May 15,1997 Page 3 of 8 APPENDIX A OPERATING DATA REPORT DOCKET NO.
UNIT NAME DATE COMPLETED BY TELEPHONE (This report should continue to be furnished on a monthly basis by licensees.)
REPORTING PERIOD (Month / Year)
YEAR IO MONTH DATE CUMULATIVE
- 1. Design Electrical Rating (MWe-Net).
The nominal net electrical output of the unit specified by the utility and used for the purpose of plant design.
- 2. Maximum Dependable Capacity (MWe-Net).
The gross electrical output as measured at the output terminals of the turbine-generator during the most restrictive seasonal conditions minus the normal station service loads.
- 3. Number of Hours the Reactor Was Critical.
The total number of hours during the gross hours of the reporting period that the reactor was critical.
- 4. Number of Hours the Generator Was On Line.
(Also called Service Hours). The total number of hours during the grocs hours of the reporting period that the unit operated with breakers closed to the station bus.
)
The sum of the hours the generator was on line plus the total outage hours should equal the gross hours in the reporting i
period.
Attachm nt 1 GL 97-02 May 15,1997 Page 4 of 8 APPENDIX A OPERATING DATA REPORT DOCKET NO.
UNIT NAME DATE COMPLETED BY TELEPHONE (This report should continue to be furnished on a monthly basis by licensees.)
REPORTING PERIOD (MonthlYear)
YEAR IO MONTH DATE LATIVE
- 5. Unit Reserve Shutdown Hours.
The total number of hours during the gross hours of the reporting period that the unit was removed from service for economic or similar reasons but was available for operation.
- 6. Net Electrical Energy (MWH).
The gross electrical output of the unit measured at the output terminals of the turbine-generator minus the normal station service loads during the gross hours of the reporting period, expressed in mega-watt hours. Negative quantities should not be used.
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GL-97-02 May 15, 1997 Page 6 of 8 SlM ERY:
t (1) Reason A - Equipment Failure (Explain)
B - Maintenance or Test C - Refueling D. Regulatory Restriction E - Operator Training / License Examination F - Administrative G - Operational Error (Explain)
H - Other (Explain)
(2) Method l'
1 - Manual 2 - Manual Trip / Scram j
3 - Automatic Trip / Scram 4 - Continuation 5 - Other (Explain) i I
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I GL 97-02 May 15,1997 Page 7 of 8 UNIT SHUTDOWNS INSTRUCTIONS -
All plant shutdowns that have occurred during the report period should be identified. The
. COMMENTS column should be used to provide edditional information when the coded columns are not sufficiently descriptive. Please do not add to the list of codes or legends now fumished. Similarly, do not add additional columns.
NUMBER - This column should indicate the sequential number assigned to each shutdown for the calendar year. When a shutdown begins in one report period and ends in.another, an entry should be made for both report periods to ensure that all shutdowns are reported, j
Until a unit has achieved its first power generation, no number should be assigned to each entry.
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DATE - This column should indicate the date of the start of each shutdown, in the following numerical format: YYMMDD, where YY is the year, MM is the month and DD is the day.
When a shutdown begins in one report period and ends in another, an entry should be made for bdh report periods to ensure that all shutdowns are reported.
TYPE - Use "F" or "S" in this column to indicate either a " Forced" or " Scheduled" shutdown,
. respectively, for each shutdown. Forced shutdowns include those required to be initiated by no later than the weekend following the discovery of an off-normal condition. It is recognized that som.e judgment is required in categorizing shutdowns in this way. In general, a forced shutdown is one that would not have been completed in the absence of the condition for which corrective action was taken.
DURATION (HoursI - Self explanatory. When a shutdown extends beyond the end of a l-report period, count only the time to the end of the report period and pick up the ensuing downtime in the following report period. Report duration of outages rounded to the nearest tenth of an hour to facilitate summation. The sum of the total outage hours plus the hours l
the generator was on line should equal the gross hours in the reporting period.
4 REASON - Categorize by letter designation from the table appearing on the report form. If category H (Other) must be used, provide brief, supplementary comments.
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GL 97-02 4
May 15,1997 l-Page 8 of 8 i
METHOD OF SHUTTING DOWN THE REACTOR - Categorize by number designation from the table appearing on the report form. If Category 5 (Other) must be used, provide brief, 2
supplementary comments.
J CAUSE/ CORRECTIVE ACTIONS / COMMENTS - Use this column to amplify or explain the -
reasons for each shutdown, with the corrective action taken, if appropriate. The Comments i
column entries should provide identification of each shutdown that occurs as a direct result l
of an event for which a licensee event report has been or will be submitted.' (This information may not be immediately evident for all such shutdowns, of course, since further investigation may be required to ascertain whether or not a licensee event report was i
1 involved.) When a direct correlation can be made between a given shutdown and a specific
~ licensee event report, the Comments column entry should state the licensee event report number and date.
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SUMMARY
- - Write a brief summary description (3 to 4 sentences) of the highlights of operation of the unit for the reporting month.
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Att chm:nt 2 4
GL 97-02 i
May 15,1997 j
Page 1 of 1 l
l LIST OF RECENTLY ISSUED GENERIC LETTERS Generic Date of l
Letter Sublect issuance issued To
- l 97-01 DEGRADATION OF CONTROL 04/01/97 ALL HOLDERS OF OLs
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ROD DRIVE MECHANISM '
FOR PRESSURlZED WATER 1
NOZZLE AND OTHER VESSEL REACTORS,EXCEPT CLOSURE HEAD PENETRATIONS THOSE WHO HAVE PER-
' l MANENTLY CEASED OPERATIONS AND HAVE CERTIFIED THAT FUEL HAS BEEN PERMANENTLY 4-REMOVED FROM THE REACTOR VESSEL 95-06, CHANGES IN THE OPERATOR 02/31/97 ALL HOLDERS OF OLs SUPP.1 LICENSING PROGRAM (EXCEPT THOSE LICENSEES OF PERMANENTLY SHUTDOWN I
REACTORS WHO ARE NO I
LONGER REQUIRED TO UTILIZE LICENSED REACTOR OPERATORS) FOR NPRs 96-07 INTERIM GUIDANCE ON 12/05/96 ALL HOLDERS OF OLs i
TRANSPORTATION OF AND DECOMMISSIONING STEAM GENERATORS FACILITIES WITH POSSESSION-ONLY LICENSES FOR PRESSURIZED-WATER NPRs 96-06 ASSURANCE OF EQUIPMENT 11/13/96 ALL HOLDERS OF OLs OPERABILITY AND CONTAIN-FOR NPRs, EXCEPT FOR MENT INTEGRITY DURING THOSE LICENSES THAT DESIGN-BASIS ACCIDENT HAVE BEEN AMENDED TO CONDITIONS POSSESSION-ONLY STATUS 1
i.
OL = OPERATING LICENSE
CP = CONSTRUCTION PERMIT NPR = NUCLEAR POWER REACTORS t
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POLICY ISSUE (Information)
April 29,1997 SECY-97-092 FOR:
The Commissioners e
FROM:
L. Joseph Callan Executive Director for Operations
SUBJECT:
PROPOSED NRC GENERIC LETTER TITLED " REVISED CONTENTS OF THE i
MONTHLY OPERATING REPORT" PURPOSE:
To inform the Commission, in accordance with the guidance in the December 20, 1991. memorandum from Samuel J. Chilk to James M. Taylor regarding SECY-91-172 " Regulatory Impact Survey Report-Final." of the staff's intent to issue the attached generic letter (Attachment 1)~.
The generic letter notifies addressees that the NRC is requesting the submittal of less information in a i
modified version of the monthly operating report, and provides for voluntary conformance on the part of addressees.
l DISCUSSION:
The assessment of NRC information-gathering needs has been the subject of several staff reviews.
These reviews have focused on identifying duplicative reporting, determining whether some reports could be reduced in scope or eliminated, and determining whether the frequency of reporting could be j
reduced.
In this regard, the NRC staff concluded that the scope of the information requested in the monthly operating report, which is required in Technical Specifications, could be reduced.
NRC initiated the monthly operating report in response to the 1973-1974 oil embargo. Draft Regulatory Guide 1.16. Revision 4. " Reporting of Operating Information - Appendix A. Technical Specifications." published for comment in August 1975, identifies operating statistics and shutdown experience information then desired in the operating report.
The NRC initially compiled this information and published it monthly in hard copy form. Although NRC
Contact:
James W. Shapaker. NRR SECY NOTE TO BE MADE PUBLICLY AVAILABLE (301) 415-1151 IN 5 WORKING DAYS FROM THE DATE OF THIS
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Marcel R. Harper. AEOD (301) 415-6344 Y
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The Commissioners ;
continued to comaile this information monthly, beginning in 1990. the agency published.it in lard copy form annually and made the data available on diskette monthly.
NRC stopped publishing the information in hard copy form
.after the December 1995 report.
The NRC staff determined that the information submitted in the monthly operating report is a unique source of' data for two of the eight performance.
indicators approved by the Commission for the NRC Performance Indicator.(PI)
Program.
Performance indicator data are fundamental tools used by the NRC staff to independently analyze trends in nuclear power plant safety performance.
NRC will retain the monthly operating report because the agency las a continuing need to receive these performance indicator data, and at the same frequency. Attachment 1 to the generic letter delineates the information that is needed for the PI Program.
The NRC also needs to provide data on operating factors to Congress and other government agencies on a regular basis.
This information serves as an indicator of the ability of a plant to perform its design function, and provides insights into a plant's safety performance.
In addition, senior NRC managers frequently use operating factor data in meetings and presentations.
The monthly operating report is a unique source of reliable and timely operating factor data for all commercial nuclear power plants to support the information needs of senior NRC managers. Attachment 1 to the generic letter L
delineates the operating factor data that are needed.
A notice of opportunity for public comment was published in the Federal Register on August 18. 1995. Comments were received from 6 utilities.
2 private industries.1 university 1 industry organization.1 government agency. 3 public interest groups, and 2 individuals (no affiliation).
Based on the comments received. it appears that licensees will stand to benefit from the proposed generic letter by not having to devote as many resources to the preparation of the monthly operating report.
Nevertheless, the information that the public may need to monitor operational safety at nuclear power plants will..still be provided.
In this regard, many commenters recommended that availability and capacity factor data should continue to be re)orted in the monthly operating report since, over the years. a correlation aetween safety and productive efficiency has been observed. Consequently, availability and capacity factor data will continue to be called for.
It is noted that the information on power reductions that is to be deleted from the monthly I
operating report is not useful to the public for assessing o]erational safety since, by the time this information appears in the report. tne event will have passed and already been assessed for potential safety significance by the licensee and NRC.
However, any power reduction initiated because a shutdown is required by a plant's technical s)ecifications, even if the shutdown is not completed, is reportable within one lour under 10 CFR 50.72, and this information is also made publicly available.
Some commenters questioned the need for the present frequency of the report.
Although the Performance Indicator (PI) Report, which the monthly operating report will primarily support, will be published annually (this began with the l
The Commissioners Fiscal Year 1996 report). the Commission has directed the staff to collect PI data on a continuing basis.
This is because PI data is also needed to support seml annual Senior Management Meetings. program office and agency annual reports, and special requests by the Commission for current PI information.
Therefore, the information will continue to be ' collected on a monthly basis.
The suggestion was also made that NRC consider collecting the data electronically: this aspect is currently being assessed by the agency.
The staff believes that the monthly operating report as currently constituted in Attachment 1 provides an acceptable balance between (1) satisfying the information needs of the agency, the Congress. other government agencies, and the public, and (2) accommodating those commenters that felt reduced reporting would be better. Attachment 2 lists the data that will no longer be requested.
Copies of the comment letters that were received are available in the Public Document Room (PDR). A copy of the staff's evaluation of the comments is available in the NRC Central Files and will be made available in the PDR after the generic letter is issued.
The proposed generic letter was endorsed by the Committee to Review Generic Requirements (CRGR) on March 18. 1997.
The'0ffice of the General Counsel (OGC) has reviewed the proposed generic letter and has no legal objection to it.
Furthermore. the Office of Management and Budget (OMB) has confirmed that the proposed generic letter is not a major " rule" under the provisions of the Small Business Regulatory Enforcement Fairness Act (see 5 U.S.C.. Chapter 8), enacted on March 29. 1996.
The Chief Information Officer has no objection to the issuance of the proposed generic letter.
The staff intends to issue this generic letter approximately 5 working days after the date of this information paper.
L. J eph Callan Exec tive Director for Operations l
Attachments:
DISTRIBUTION:
1.
Proposed Generic Letter Titled " Revised Commissioners Contents of the Monthly Operating Report" OGC 2.
Monthly Operating Report Data Being Deleted OCAA l
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EDO REGIONS SECY
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PUBLIC COMMENT LETTERS ATTACHMENT 10
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September 4, 1995 Chief Rules Review and Directives Branch US Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20555 To Whom it Concerns:
This is a comment on the proposed change in reporting requirements for nuclear utilities.
We strongly disagree that the reporting of such data as availability and capacity factor have no bearing on nuclear plant safety.
While at any given moment this may be true, this data is a strong ladicator over time of the level of safe operation of a nuclear facility.
If reporting of this data were eliminated, the public would be deprived of data which does indeed give indication of safety of operation.
Thus, we do not agree with the elimination of reporting of the monthly data as is being considered by the NRC.
We therefore request that you do not eliminate this requirement.
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Sincerely,
!d7tt Tom Clements Greenpeace i
Nuclear Campaign l
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1436 U Street. NW
- Washington. DC 20009
- Tel (202) 1621' '
- Fax (202) 462-4507
- Tlx 89-2359 w,
Argentina
- Austraha
- Austna
- Belgium Brazd
- Canada
- Chde
- Czech Repuchc
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- Finlana
- France
- Germany
- Greece a Guatemala Ireland
- Italy Japan
- Luxembourg 0%uco *The Netherlands
- New Zealand
- Norway a Russia
- opain
- Sweoen
- Setzerland
- Tunisia
- Ukraine
- Unned Kingdom
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.A September 11,1995
- / Chief, Rules Review and Directives Branch S Nuclear Regulatory Commission 2
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Dear Chief of Rules Review and Directive Branch,
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In response to your Press Release of August 29,1995, "NRC Staff Asks Pub-
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r lic Comment on Proposal to Reduce Amount of Operational Data Reported by 3
O" in the collection and publicatsn of nuclear power plant operations data, so-called Nuclear Power Plant Licensus,' I strongly urge you to reconsider the reduction "Graybook" data. During the last ten years, I have relied extensively on these data. Attached is a partial list of my papers that have analyzed these data.
I realize that some of these data do not appear to be directly related to the NRC's safety mission. IIowever, as nuclear power plants age and as these plants face increased competition from other sources of power, the operations data point toward possible safety problems.
For example, I have decomposed the capacity factor into the service factor I
and the capacity utilization rate. See my paper attached, " Utilization and i
Service: Decomposing Nuclear Reactor Capacity Factors," Resources and Energy (1990). The service factor is the percentage time that the plant is up and run-ning. The capacity utilization rate is the plant's capacity factor when it is up and running. As I show (see page 227), aging in plants of different vendors
' effects the capacity utilization rate and the service factor differently. Changes in the underlying operations data point to aging effects.
Also, the Graybook data allow for the analysis of duration between shut-downs of all lengths. I have shown that there is a relationship between plant organizational structure and the probability of shutting down and the probability of coming back up after a shutdown. See " Organization Structure and Expected Output at Nuclear Power Plants," forthcoming in Revieu of Economics and Statistics.
I believe that the NRC can understand aging effects from these operational data. As the nuclear power plant fleet ages, a consistent set of these data will become increasingly important.
I would be happy to talk with you about my work. I would be willing to work with the NRC to provide these data to the public at lower cost. Please let me knowyf I ca help you further in any way.
jred yours4 c
m 9
{
Geoffrey Rothwell, Ph.D.
(415) 725-3456 Enclosures
~ /5 0'lf h Q{J g) ~
Corner of Gahez & Serra. Stanford. Cahfortua 44V5-6als I.n (415) 72Mn11 icierone < 415) 725-1974
~
t Dr. Geoffrey Rothwell Senior Research Associate Center for Economic Policy Research Stanford University Stanford, California 94305 (415) 725-3458 Publications using the Graybook Data:
"A Dynamic Programming Model of Nuclear Power Plant Fuel Cycles,' with John Rust, Journal of Business and Economic Statistice (forthcoming).
" Organizational Structure and Expected Output for Nuclear Power Plants,"
Revieto of Economics and Statistics (forthcoming).
?
" Measuring Standardi ation: An Application to the American and French Nuclear Power Industries' with Paul David, European Journal of Political Economy (forthcoming).
" Comparing Boiling and Pressurized Water Reactor Productivity in the United States: 1975-1990,' in J. Szargut, et al, eds, Energy Systems and Ecology:
Proceedings of an International Conference. (Krakov, Poland: Ameri::an Society of Mechanical Engineers, July 5-9,1993). Also available as Center for Economic Policy Research Working Paper No. 333.
" Performance and Reliability at U.S. Nuclear Power Plants," Public Utilities Fortnightly (July 1,1993).
" Utilization and Service: Decomposing Nuclear Reactor Capacity Factors,"
Resources and Energy 12 (1990) pp. 215-229.
" Risk and Reactor Safety Systems Adoption' with Jeffrey Dubin, Journal of Econometrics,42,2 (October 1989) pp. 201-218.
" Stock Market Reaction to Nuclear Reactor Failures,' Contemporary Policy Issues (July 1989) pp.96-106.
"Stop and Start: A Duration Analysis of Nuclear Reactor Operations,"
Proceedings of the International Association of Energy Economists' Annual North American Conference (October 1989) pp. 309-17.
Working Papers using the Graybook data:
" Learning by Accident?: Reductions in the Risk of Unplanned Outages in U.S.
Nuclear Power Plants After Three Mile Island,' with Paul David and Roland Maude-Griffin, revision of CEPR Working Paper No. 248 (September l
1994).
" Contracting Out for Services: An Empirical Examination of Practices at Nuclear Power Plants," with J. Bradford Jensen, Center for Economic Policy Research Working Paper 280 (May 1992).
1 Contact me at the above address for any or all of these papers.
l l
l
4 Resources and Energy 12 tivvin 215-229 North Itolland i
I i
E UTILIZATION AND SERVICE Decomposing Nuclear Reactor Capacity Factors
- i GeofTrey ROTilWELL Stanford Unn ersary, Stanford, CA 94303-6072, USA Received May 1989, final version received February 1990 Statistical analyses of electricity generation productivity have focused on the capacity factor,i.e.,
the ratio of reahied to potential output. Here, the capacity factor is decompowd into the capacity utilization rate (output when the reactor is operating) and the service factor (the percent of operating time). Elasticities of capacity factor, utdization rate, service factor, and the forced outage rate with respect to reactor size and age are estimated for fuel cycles of four reactor manufacturers, controlling for changes in the industry after the accident at Three Mdc i
Island in 1979. Whde the service factor decreases with size for all reactor makes, the increase in the capacity utshzation rate yields a positive relationship between size and the capacity factor for i
boiling water reactors Age has no consistent influence. Only Babcock & Wilcon (the 2
manufacturcr of TMI) reactors experienced a sigmficant decrease in productivity after 1979 I.' Introduction The most popular measure of productivity in the electric utility industry is
)
the capacity factor (i.e., the ratio of net annual electric megawatthours generated and the net annual generator rating times the number of hours).
Capacity factofs for conimercial nuclear power reactors were initially pro-i w f j, co,,
jected at 75-80%, similar to coal-fired power plants. Unfortunately, reactors experienced an average 63% capacity factor from 1975-85, This can be decomposed into. a 90% capacity utilization rate (i.e., the ' capacity factor giu that the plant is operating) and a 70*/, service factor (i.e., the ratio of ope eing time to total time). Further, the capacity utilization rate can be decomposed into average output per unit of capacity and the number of hours operating. The service factor can be decomposed into the scheduled i
l-operating time and the forced outage rate. This paper explores the relation-
- I acknowledge the aid of Tim Bresnahan, Paul David, W. Edward Steinmueller, Lewis Perl' Frank Wotak, and the participants of the lechnology and Productivity Semi.st, Stanford j
University and the Industrial Organization Seminar University of Cahfornia, Berkeley. Research j
was funded by the Center for Economic Pohey Research, liigh Technology impact Program, l
under grants from the National Science Foundation (IRI 8814179) and the Center for Economic l
Policy Research, Technology and Growth Program. An earlier version of this paper.was presented to the American Economics Association New York, December 1988.
l l
OltiS4572,90$03.50 01990-Elsevier Science Pubhshers DN.(North-Holland) i i
I'
2t6 G. Ro% ell. Decomposmg capacuy factors ships among these measures of productivity and the independent variables of interest in previous studies.
- 2. Nuclear reactor performance The analysis of reactor performance has taken three directions: (1) engineering case studies of individual plants addressing specific operating problems, (2) descriptive statistics for various samples of total performance sneasures, such as the capacity factor, and (3) regression estimation of equations relating capacity factors to plant characteristics. The engineering studies provide a rich understanding of the technical aspects of reactor operation, but do not address industry performance. (See publications by the Nuclear Reactor Division of the Electric Power Research Institute.) Descrip-tive statistics allow a broader view by giving industry-wide averages for many categories, e.g., by vendor, by age, by year, by size, or by country. But these comparisons rarely discuss the interactions between these characteris-tics. Sophisticated analyses of this type are available in Stoller Corporation (1986).
The regression literature is represented by Komanoff (1978), Joskow and Rozanski (1979), Easterling (1982), and Krautmann and Solow (1988). Table I compares these studies. I focus on Joskow and Rozanski (1979) because their results are similar in the other studies, but their model is more general.
Joskow and Rozanski fm' d that (1) larger plants have lower asymptotic capacity factors; (2) later plants have higher capacity factors than earlier plants: 'an additional year of design and construction experience increases the asymptotic capacity factor by about 3 percentage points'(p.165); and (3) learning by-doing effects are significant and substantial with the reactor j
wh t ;.y m.a.; ~,'
perating at 90*, ofits asymptotic output after three years.
~
Although Joskow and Rozanski advanced both the analysis of capacity factors and learning, their
.o rical measure of learning is equal to ' lifetime cumulative plant output, esed by gross plant capacity', i.e., it is the lifetime sum of the capacity factors. The observed capacity factor will be correlated with the cumuiative capacity factor, and both will be correlated j
with the error term in the regression. Hence, their estimates may be biased by simultaneity.
Also, their dependent variable depends on an arbitrarily selected time period, i.e., a calendar year (December 1975 to November 1976). This is particularly troublesome in cross-section samples under the assumption that a reactor must refuel during a one year period. But reactors need not operate on twelve-month cycles. For example, because of uranium-fuel dynamics, the first and second fuel cycles will be longer than all others. [See Stoller Corporation (1987) on the changing length of reactor fuel cycles.] Because they will not be down for refueling, capacity factors for plants in their first
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Tabk 1-l
-. Stude of nuclear reactor performance.*
i Dependent study vanabic Constant Stre Time -
Lagged Type ist year R8 Komanolf CF(PWR)
CAP /ICO LAGE I
NEWPWR n25 I
(1978) thru-1977 67 7
-3#
24 9*
CAP /IO0 (1978) thru 1977 72 2
-3F NA 9
- o R
Joskos InCF InCAP V tjx PWR/x NEWPWR 0.10 5
i
=-
Rozanski 12/75-11/76 1.3'
-07 0 04t*
- 7966* 1745' 3879*.
F P
(1979) i D
CAP /IGO YEARS.
t (1982) thru 1979 75 7(NA) - 3.5*
34' NA Delete obs.-
CAP /IDO YEARS
+
(1982) thru 1979 41.3(N A)
-09 7.1
- NA Delete obs.
k R
I Krautmann and lagit CF
' CAP AGE
-CFLAG BWR NA N
l Solow (19NM) 19 W l978
.- 1.0
~.-0 00l*
0 052' 15
- 0.2*
Delete obs.
AGE - months since first commercial operation; BWR - binary variable indicating Boiling Water Reactor, CAP -"
Y
- Description of variables:
i t
gross plant capacity in Mw(e); CF - capacity factor; CFLAG - capacity factor legged I year. LAGE - losanthm I
I'
' (base 10) of age in year of observation; Logit CF -logistic transformation of capacity factor, NEWPWR - binary i
variable for PWR with reant commercial operation: PWR - binary variable indsating Pressurized Water Reactor; V i
- vintage, number of months since November 1%2; X - cumulative output divided by gross plant capacity; YEARS.
- discrete number of years of operation to date of observation; NA - not available,
- Confidence at 90% level.
i
- Confidence at 95% level.
~ t
>4
,m3 i
_ _ _ _. _ ~ _.. _ _, _ _...,.... _... -..
.. _.. -.... _. _.... _..... ~.. _.... _. _ -, -.,.... _.
... _, _ _ -. _ _ -... - _... -, _. -. _ - ~. _
. - ~, _ _ _. -.. _._ -
- i 2I8
' G. Rothwell. Decomposmg capaceryfactors i
fuel cycle during the sample period will be higher. This is probably why-Joskow and-Rozanski find that reactors that began commercial operation -
after April.1,1975, had higher capacity factors, not necessarily because these reactors were better performers. I avoid many of these problems by using the length of the fuel cycle, i.e., the period between reactor starts after refueling.
To examine the capacity factor in more detail, the next section proposes a method to analyze nuclear reactor performance over the fuel cycle.
i 4
- 3. A decomposition of the capacity factor l
The future of the commercial nuclear power industry depends critically on
[
the performance of reactors now in operation. Rc31ized capacity factors have been far less than envisioned by electric utilities when they placed orders in i
L the late 1960s and early 1970s. To examine reactor productivity, I decompose l
the capacity factor, enabling the calculation of performance clasticities.'
The unit ' capacity factor *, CF, is equal to the megawatthours of electricity,
+
Q, divided by the product of the potential capacity of the reactor, SZ, and j
the number of hours in the period of observation, 7'i.e.,
CFaQ/SZ*T (la) i This expression can be modified to introduce the amount of time during which the reactor is generating electricity, i.e.,' hours generator on-line,' UP:
l l
CFu(Q/SZ UP)-(UP/T),
-(Ib)
- [
i Let Q/(S2 UP) be the capacity utilization rate, CU, and (UP/T) be the unit j
- service factor', SF, i.e., CU is a measure of how close the reactor is to 4A-4 p -u:r ::*, N potential output when it is running and SF is the percentage of the time the reactor is running. The capacity utilization rate can be decomposed into 1/
UP and Q/SZ, average output or ' equivalent full power hours' from Stoller l
(1987).
l Further, T is equal to UP plus two types of downtime: scheduled outage I
time, RAf (refueling and maintenance), plus forced outage time, FORCED.
Then, Tn UP + R Af + FORCED, or
?
l UP u T-R Af - FORCED i
a ( T - R Af) -(1 - FOR CED/( T-R Af )) s (T - R M) -( 1 - FOR),
(2a) j
'For the defimtion of the capacity factor and other definitions (in quotes) given here, see the Glossary of the Nuclear llegulatory Commission's Licensed Operating Reactors. This pubhcation i
is dncussed more fully m section 3 l
8 6
e k
4 4
[
t
G. Rothm ell. Decompostng capaat v factors 219 where [ FORCED /(T-R Af)] is the unit ' forced outage rate,' FOR,2 (T-RAf) is the scheduled generation time, and [(T-RAf)/T] is the percent of scheduled generation time.
The forced outage rate can be decomposed as FORs ORCED S.
FORCED F
s (2b)
T-RAf T-- R Af S
where S is the number of ' scrams'.31.et SCRA AfS=[S/[T-RAf)], i.e., the average number of scrams during the scheduled generation period, and SCR A Af T-(FORCED /S), i.e., the average time spent in each forced outage.
To summarize, CF s CU Sf a: k E ~ ^O (1 - FOR),
(3)
SZ uf 1
where FORsSCR AbfS 3CRAAIT (4)
By taking the natural logarithm of both sides of eqs. (3) and (4):
In CF s in CU + 1n SF e in (Q/SZ)-in UP + 1n (T-R Af/T) i
+ 1n ( I - FO R),
(Sa) in FOR sin SCR A AfS +1n SCR A AfI
($b)
&~ h.19. Abr ::,., ig The capacity factor can b: modeled as a function of those variables found l
significant in earlier studies, while controlling for changes in the operating j
environment following the accident at Three Mile Island. CF is a logarithmic function of the size of the generator, SZ, its age, AGE, and whether the observation period was after March 28,1979, TAf f = l:
i l
In CF = a i + aii n SZ +a i n AGE +a3 In TAfl + ei, (6) l al l
o where ei is a normally distributed error term. To control for differences 1 arn using regulatory conventions in defining TOR. A raore appropriate probabilistic 3
dcIimt on of FOR would focus on the number of outages, ie., how many outages per unit of time For an analysis of this probabiht), see Rothwell(1989b).
'A scram is a manual or automatic actuation of the reactor protection system resulting in the i
j most rapid possible insertion of the control rods', Nuclear Energy Agency (1987, p. 4).
i i
s
I 220 G Rothuell. Decomposmg capacayfacwrs between reactor manufacturers, i.e., Babcock & Wilcox, Combustion Engi.
neering, General Electric (GE), and Westinghouse, I divide the observations into four samples. (Note Babcock & Wilcox, Combustion Engineering, and Westinghouse produce pressurized water reactors, PWP.s, and GE produces boiling water reactors, BWRs.) Similarly, CU, SF, Q/S2, DP, (T-RM)/T (1-FOR), FOR, SCRA AfS, and SCRA Af T can be represented with logarith-mic functions of SZ, AGE, and TAf t:
r in CF "y
~
In C U y2 InSF 13 In Q/SZ 14 i-InUP ys
= a,+ a, ln SZ + a2,-In AGE + ag Tall + e,
=
o s
in l.- R hi/T b,e j
in 1 -- FOR y,
inFOR ye in SCR A AfS y,
in SCR A Af T, y
_ s o_
(7) where the a,j are parameters to be estimated and e are error terms, assumed j
to be independent across observations and normally distributed. Note that a,, = aa + a,3 = a,, + a,3 + a,. + a,, and a = a,, + a
.3 for i = 0,1,2,3.
n Parameters are estimated with observations on commercial nuclear reactor fuel cycles during the late 1970s and early 1980s.
- ,;. ~
- w.
p ~;e,si,as
- 4. Data The data required to estimate this model is available in the Nuclear Regulatory Commission's Licensed Operating Reactors - Status Summary Report (NUREG-0020), commonly known as the 'Graybook', from the color of its early cover. This section describes the 'Graybook' data and how I constructed the sample from IMm.*
The Graybook data contain the following information: (1) the unit name; (2) the outage date; (3) the outage length in hours; (4) whether the outage
'For other uses of these data, see Dubin and Rothwell (1989) and Rothwell (1989a). For a more detailed discussion of these data, see Rothwell. Appendit l',in David et al. (1988).
w
_ -. _ _ _ ~
G Rothwell, Decomposms capacutyfactors 228 type was forced or scheduled; (5) the reason for the outage; and (6) the method of shutting down. There are eight reasons for ou: age:(A) equipment failure; (B) maintenance or test; (C) refueling; (D) regulatory restriction; (E) operator training or licensing examination; (F) administrative, including decisions to reduce output because of demand conditions;(G) operator error; i
and (H) other. There are live methods of shutting down the reactor: (1) manual; (2) manual scram; (3) automatic scram; (4) continuation, implying a continued outage ' rom the previous ' month; and (9) other, including cases where the reactor is 'still operating, but the turbine-generator is not functioning.
The length of the fuel cycle,7,is the number of hours between the starts of operation after refueling. The refueling and maintenance period, RM, includes all hours from the start of refueling to operation for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 'All outages during the fuel cycle that started with a scram constitute FORCED; if there were no scrams during an observation period, SCRAMS.
was set to 0.001/(T-RM) and SCRAMT was set to 0.01. RM includes all scheduled outages. Total output was determined by matching fuel cycles with information in Stollet (1987). The size of the plant is the name plate rating of the generator. Its age is the difference between the date at the start of operating after a refueling and the commercial operation date. To avoid problems with uranium fuel dynamics, the first two cycles have been deleted.
Table 2 presents the means of the dependent variables for each reactor make.
Notice that while all the PWRs experienced capacity factors above 65%,
the average capacity factor for BWRs was below 55%. Although all reactors
(
were running about 70% of the fuel cycle, BWRs achieved only 75% of their potential output, compared to 90% for PWRs. Also, while the number of scrams (normalized by the number of hours in a year) were generally the
that averages for all the independent variables are similar across all reactors.
i
- 5. Estimation results Tables 3.1 through 3.4 present parameter estimates for eq. (7).S According
'The robustness of thes* results was tested by the inclusion of interaction and quadratic terms, as well as a senes of binary vanables The interaction terms, e g., InSZ in AGE, were insigmficant individually and as a group. I tested the hypothesis that therc was no difference between the partial derivative of each dependent variable with respect to size and age, with and without a senes of escluded vanables. This senes included binary variables representing (1) the manufacturer of the nucicar steam supply system, (2) the architect engineer who designed the reactor, (3) the general contractor who built the reactor,(4) the manufacturer of the turbine-generator, and (5) the region. I could not reject the null hypothesis for any series. I did find, however, that the inclusion of bmary variables representing the electric utility operating the reactor did change coefficients on size, but because so few firms operate reactors of different sizes, the inclusion of these variables confuses the mterpretation of the influence of size. For this reason, I did not include firm vanables.
222 G. Rothwell, Decomposmg capaaty factors Table 2 Means.'
B&W COMB GE WEST NSSS Umts All PWR PWR BWR PWR Obs N
256 30 33 74 119 Cr 63.0 63.4 67.9 53.7 67.3 CU 88.6 92.9 93.9 75.8 92.4 ST 71.2 68.0 72.4 69.2 72.8 Q/SZ Hours 7826 8152 8812 7939 7400 UP Hours 8969 8785 9394 10324 8055
( T.RM)/ T
?;
75 6 71.7 75 1 75.0 77.1 (1.TUR) 5, 94.1 94 9 96.3 92.3 94.4 T
Hours 13022 13196 13284 15352 11457 RM Hours 3414 3912 3499 4081 2849 TORCED Hours 640 498 391 947 553 SCR A MS N/ Year 8.2 8.8 6.3 8.9 8.2 SCRAMT llours 64 2 53.7 48.2 81.7 60 4 AGE Years 6.8 56 6.3 6.9 7.2 SIZE M wtel 818 891 789 843 799 TMI 74.2 70 0
$1.8 74.3 73.1
- B&W - Babcock & Wilcos; COMB - Combusuon Engmeenng; GE -
General Electric; WEST - Wesunghouse; PWR - Pressurued Water Reactor; BWR - Bosimg Water Reacto.
to the earlier studies, decreases in size and increases in age are associated with increases in the capacity factor. Focusing on the first column of each table, these earlier findings are not jointly supported in any sample. Although the coefficient on size is negative for the PWRs, this coefficient is only 45W4,o Atweb.ig significant for Westinghouse reactors. The capacity factor for GE reactors increases with size. The coefficient on age is significantly positive for Babcock
& Wilcox reactors, significantly negative for Combustion Engineering -
reactors, and insignificant for both GE and Westinghouse reactors. Statistical analyses of annual capacity factors before 1979 do not explain industry performance after that time.
Can these results be reconciled with the earlier literature by examining the decomposition of the capacity factor? (Note that parameters in columns labeled CU and SF add to those in the CF column and that CU=G/
SZ-UP, SF =(T-R A1)/T +(1 - FOR), and FOR = SCR AMS + SCRAMT).
First, consider the influence of size on the capacity utilization rate (CU) and the service factor (SF). For Westinghouse reactors, the influence of size on SF dominates its influence on Cd. For example, 95% (-0.300/- 0.317) of the negative impact of size at these reactors is through SF, i.e., larger reactors are running less often than smaller reactors. Although size is not significant in explaining performance for the other PWRs, the same pattern i
1 1
i
f l-1 Yf g
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) ^.
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Table 3.1 Ordinary least squares estunates: Babcock & Wikon (PWR); N=30.
Model CF CU QiSZ UP SF (T-RM)lF (1-FOR) FOR SCRAMS SCRA MT f
2 R
0.208 0.135 0 604 0.560 0.192 ul48 0 084 0.069 0.176 0105 S
C 6.379 0.558 20 653 20.095 5.821 4.933 0.888
- 22.130 2.151
- 24.281 9
(5.110)
(1.271)
(4 666)* (4 976)*
(4 420)
(4.451)
(1.264)
(37.134) (15.532)
(29 658) j inSZ
-1.056 o 102
-1.827
- 1.725
- 0.954
- 0 813
- 0.141 2.933 -1205 4 138 I
(0.754)
(0.188)
(0 689)' (0.735)"
(0.653)
(0.657)
(0.187)
(5.512) (2.293)
(4.383) 5 inAGE 0.271 0.053 0.425 0 371 0 218 0.192 0.026
- 1.096 - 0.593
- 0.503 (0.118)'
(0.029)* (0 108)' (0.115)*
(0.102)* (0.103)*
(0.029)
(0.863) (0.3591*
(0.686) g j
TMl
- 0.193
- 0.044 0.029 0.073
- 0.149
- 0.116
- 0.033 0.840 0.009 0.831 4
(0 095)'
(0.024)* (0.087)
(0.093)
(0.083)* (0 083)
(0.024)
(0.698) (0.290)
(0.555) t
- Confidence at 90% level-
' Confidence at 95% level.
k u
A-s{
l.
4, a
Yl aQ s.$
E N
Table 3.2 Ordmary least squares estimater rombuuion Enginecting (PWR); N = 33.
Model CF CU Q!SZ UP SF (T-R%f)lT (1-FOR) FOR SCRA%f5 SCR A %f T 5-@
2 R
0113 0.109 0383 0 286 0 110 0 074 0.175 0.055 0 023 0.131
.b c
0.184
- 0.224 7.414 7.638 0 409 - 0 036 0.445
- 16.429 -11.530
- 4.900
?
(0.799)
(0.240) (0.620)* (0 666)*
(0.795)
(0 690)
(0.247f (9.58 t f (8 492)
(4 618) j InSZ
- 0 068 0.019 0.209 0190
- 0 087 - 0 018
-0069 1.737 0 693 1.044 1
(0 119)
(0.036) (0 0934' (0099f (O. I18)
(O.103)
(0.037f (l.425)
{l.263)
(0 687) s inAGE
- 0.127 0 003 0 095 0 093
-0130 - 0.094
- 0 036 0.502 -03W 0.841 E
(0072r (0.022) (0.057f (0 060)
(0.072r (0062)
(0.022)
(0.864)
(0.7t>6)
(0.417)'
j TAff 0.110 0.037 0.130 0.093 0 073 0.031 0 042
- 0.341
- 0.210
- 0.130 (0.082)
(0 025) (0 065)' (0.068)
(0 082)
(0.071)
(0.025r (0.984)
(0.873)
(0 474)
S
- Confidence at 90*; level.
- Confidence at 95% level.
{*
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= - -.
.~-
.~
~
-N
['
ir Nh x.
b L
+
l Table 3.3 Ordmary least squares estimatts: General Electnc (BWRh N= 74.
en
?
Model CF CU Ql5Z UP SF (T-RM)lT (1-Fon)_
R3 0 072 0292 0.280 P229 0.167 0.148 0.160 0.181 0.173 0 09 5,
}
c
- 2.709
- 2.757 3471 E.22R 0 048 O hn)
- 0.835 0.071
- 7.841 7.912
(,
(I.168)*
G%*f iLo40)*
(0.887 *
(0.751)
(0.672)
(0 423)*
(3 %9)
(2.4356' (3.t(e*
1 In SZ 0.292 0.363 0 440 0.078
- 0.071
- 0.158 0 087
- 0.277 0.247
- 0.524 3
g (0.166r (0.137)* (0.148)*
(0.I26)
(0.107)
(0.096f (0 060)
(0.564)
(0,346)
(0.449) inAGE 0 017
- 0 082 0 230
_ 0.3 t 2 0 099 - 0 023 0.122
-1.098
-0617
- 0.480 4
(0.093)
(0.077) (0 083)*
(0.071)*
(0.060)
(0 054)
(0.034)*
(0.317)* (0.1951' (Ol53r E
TAff 0 077 0268 0.121
- 0.147
- 0.191
- 0.111
- 0.080 0.968 0.333 0 635 (0.091p (0 076)* (0.081)
(0.069)*
(0 059)* (0.053)*
(0 033)*
(0.311)* (0.1917 (0.2471*
4
- Confidence at 90*; level.
- Confidence at 95*.; level.
D2 3
w t.A
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4 n
n v
(
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~
r
.+.
6c w
Table 3 4 Ordinary least squares eshmates: Westinghouse (PWRL N = 119.
- c.
Model CF CU QlSZ UP SF 3
(T-Rht)lT (1-FOR) FOR SCRAkt5 SCRAntT
-?
2 E
R 0 168 0 012 0 009 0.014 0.222 0 085 0.209 0.387 0.242 0.178 c
I.746 0.079 9 403 9.324 1.667 0.821 0.846
- 34478 - 25 675
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- 0.317
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-0 078 - 0 061
-0 300 - 0162
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- 0 014
- 0.022 - 0.011 0 011 0 008 -0005 0.013
- 0.243 - 0 650 0 407 (0.062)
(0 036)
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(0 025)
(0 505)
(0.503)
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- 0 038 - 0 016
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(0.058)
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(0 642)
(0 023)
(0.470)
(0.469) -
(0.299)
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G. Rothwell. Decomposme capacuty fxtors 227 can be seen. However, at GE reactors much of the positive influence of size is through CU, i.e., larger reactors run closer to potential capacity when they are running. A closer examination of the influence of size shows that for PWRs, the clasticities of (Q/SZ) and UP with respect to size are significant for Babcock & Wilcox and Combur..o Engineering reactors and almost equal. These clasticities offset each other in :he influence of size on CU. In contrast, for BWRs, the elasticity of average output, Q/S2, with respect to size, c(Q/SZ,SZ), dominates c(UP,SZ). In fact, it is c(Q/S2,SZ) that domi-nates c(CF,SZ), accounting for much of the influence of size on the capacity factor. Further, for all PWRs increases in size are associated with decreases in tne scheduled generation time, i.e., c(T-R Af/7;SZ)<0, and increases in the forced outage rate, i.e., a decrease in (1 -FOR). Finally, size is strongly correlated with forced outages at Westinghouse reactors. Larger reactors experience more scrams and these reactors require longer periods of down-time to recover. In summary, the influence of size on the capacity factor varies with reactor make. Therefore, one cannot reach general conclusions regarding the relationship between size and the capacity factor for all reactors, as previous papers have done.
This is also true of age. When significant, the influence of age on the service factor dominates its influence on capacity utilization: age has a positive influence at Babcock & Wilcox reactors and a negative influence at Combustion Engineering reactors. ( Age is insignificant in the GE and Westinghouse samples.) Generally c(Q/S2, AGE) offsets c(UP. AGE), i.e.,
c(Q/SZ, AGE)-c(UP, AGE)=c(CU. AGE), leaving c(CU, AGE) small and/or insignificant in every estimation, Age has no consistent influence on the service factor, scheduled generation time, or the forced outage rate. However, the number of scrams per scheduled generation time (SCRA AfS) decreases with age for all reactors. Also, the operators of older Combustion Engineer.
g w:. 3;- em.,,. %
ing (and, insigniGcantly, Westinghouse) reactors spend more time recovering from a scram, but the operators of older GE reactors (and, insignificantly, Babcock & Wilcox) spend less time. Because there is no consistent relation-ship between age and these measures of performance, age should not be used as proxy for learning.
Finally, consider the influence of the Three Mile Island accident (and everything else after 1979) as represented by the binary variable TAfl. We can interpret the coefTicient on TAff as the percentage change in the dependent variable after 1979. As one would expect, the capacity factor of Babcock & Wilcox (the manufacturer of TAfl) reactors declined by an average 19% after 1979. This is equal to a decline of 4% in capacity l
utilization and a decline of 15"; in the service factor But the coefficient on TAfl is insignificant in the CF regressions in all other samples. For Combustion Engineering reactors, the average output, (Q/SZ), increased by 13*;. For GE reactors, the capacity utilization increased by 27%, but this l
228 G. Rothell, Decomposing capacityfactors was offset by a fall in the service factor of 19%. For Westinghouse reactors, there were no significant difierences before and after 1979. Therefore, much of what has been interpreted as a decline in productivity at all reactors from an increase in regulation after the TMI accident can be attributed to the decrease in productivity at Babcock & Wilcox reactors.
- 6. Summary and conclusions Econometric studies of nuclear power plant performance have focused on the relationships between annual capacity factors and the' size and age of the reactor. However, much misinterpretation of the data has occurred because of the assumption of (and availability of data for) annual periods; reactors are not brought up on January ist and brought down ia anticipation of a December 31st deadline. A more appropriate period is the refueling cycle.
Without an appreciation for the dynamics of this cycle, an understanding of reactor performance is not possible. Further, analyses that associate learning with cumulative output gloss over the complexities of this industry. We need to carefully examine how reactors change over time and how reactor operators adjust to these changes.
To analyze the influence of' size, age, time, and make, I inave examined the capacity factor, decomposed into its components: average output, generation time, the scheduled generation period, and the forced outage rate. Previous literature has suggested that smaller and older reactors are associated with increases in performance for both pressurized and boiling water reactors.
This study has shown that the influences of size, age, and tilne vary across make and across measures of performance, While this framework gives many insights, it does not provide a structural analysis of reactor operations.
c W M w oe.vepiwi Future work will propose and estimate structural models based on the objectives of the nuclear electric utility.
References Daud, Paul, Takeshi Amemiya, Kenneth Arrow. Timothy Bresnahan, Thomas Connolly, Elisabeth Pate Cornell, Geoffrey Rothwell and W. Edward Steinmueller,1988, Information and organizational impacts on productivity: The economics of control and reliability in comples production processes, Proposal to the National Sciena Foundation (Center for Economic Pokey Research, Stanfo.J University, Stanford, cal.
Dubin, Jeffrey and Geoffrey Rothwell,1989, Risk and reactor safety systems adoption, Journal of Econometrics 42,201-218.
Easterling, Robert G.,1982, Statistical analysis of U.S. power plant capacity factors through 1979, Energy 7,253-258.
Joskow, Paul and George A. Rozanski,1979, The effects of learning by doing on nuclear plant operating rehabihty, Review of Economics and Statistics 61,161-168.
Komanoff, Charles,1978 Nuclear plant performana update 2 (Komanoff Energy Associates, New York).
3 G. Rathmell, Decompcmng capacityfactors 229 Krautmann, Anthony C. and John Solow,1988. Economies of scale in nuclear power generation.
Southern Economic Journal,7485.
Nuclear Energy Agency,1987 Reducing the frequency of nuclear reactor scr.ms (Organization for Economic Co-operation and Development, Parts).
Nuclear Regulatory Commission, sarious months Licensed operating reactors - summary status report (NUREG@201(Nuclear Regulatory Commission. Washington, DCL Rothwell, Geoffrey,1989a, Stock market reactior to nuclear reactor failures, Contemporary Pohey issues 7,96-106.
Rothwell, Geoffrey,1989b, Stop and start. A duration analysis of nuclear reactor operations.
Proceedings of the International Association of Energy Economists
- annual North American conference, 309-317.
S.M. Stoller Corp.,1986, Nuclear unit operstmg esperience - 1983 and 1984 update EPRI NP-4368 (Stoller Corp., Boulder, CO).
S M. Stoller Corp.,1987. The influence of fuel-cycle duration on nuclear umt performance EPRI NP-56:2 (Stoller Corp., Boulder, COL
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" 13 Mr. David Myers Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Docketing and Services Branch
Subject:
Commonwealth Edison (Comed) Comments pertaining to the Proposed Generic Letter, " Revised Contents of the Monthly Operating Report"
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Reference:
60 Federal Register 43174 dated August 18,1995, Notice of Opportunity for Public Comment, " Revised Contents of the Monthly Operating Report" The purpose of this letter is to provide comments in support of the subject proposed generic letter. Comed believes that the proposed changes both focus the monthly report on data important to the Commission in evaluating plant performance, and improve the efficiency in preparing it for the utility.
Comed would also like to take this opportunity to support the on-going NRC staff review or reporting requirements and supporting documentation designed to reduce reporting burdens placed on licensees without reducing the protection of public health and safety.
Sincerely, bf/
C-Martin'J. Vonk Licensing Administrator Nuclear Regulatory Services cc:
G. Dick, Comed Generic Issues Project Administrator, NRR k i daVG. NW)Cprpt. wpf :1
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9'D{M kgQ L-95-261 m&peR Chief, Rules Review and Directives Hranch U. S. Nuclear llegulatory Conunission Washington, DC 20$55-0001
Subject:
Proposed Generic Letter; Rmsed Contents of the Monthly Opemtmg Repon (60 FR 43174, August 18, 1995)
Rea-for Cnmments On August 18, 1993, the Nuclear Regulatory Commission published for public conunent,
- Proposed Generic lener: Revised Contents of the Monthly Operating Repon."
'Ibese comments are subrnitted on behalf of Florida Power & Light (FPL), a licensed operator of two nuclear power plant units in Dade County, Florida and two units in St. Lucie County, Florida.
l FPL suppons the NRC's efforts to review and propose changes to the Monthly Operating Report (MOR) contents. The version of the report described in the Federal Register notice would greatly reduce FPL's reponing btuden. FPL provides the following additional conurents.
Curready, the Tcht Specifications for FPL's four nuclear units require that the MOR be submitted by the fifteenth of each snonth following the calendar month covered by the report.
The requested submittal date in the draft Generic Ixtrer (GT.) and DraA Regulatory Guide 1.16, Revision 4. dated August 1975, ' Reporting of Operadog Information - Appendix A Tedmis 21 Specifications.' is by the tenth of the month following the calendar mouth covered by the repon.
The Impmved Standard Technical Specifications for Westinghouse and Cornbustion Rr.cir--xing requhe that the repon be submitted no later than the fifteenth of each month following the catesviar month covered by the repon. FPL sequests that the subminal date be erre~N to the thinicth of each month. FPL does not receive any questions from the NRC's contractor until several months (as much as 6 months) after the report is submitted. 'therefore, the request for 30 days should not hinder the NRC or its contractor and is more in line with other NRC j%ile8 tequirements, such as Licensee Event Reports (LERs). The Improved Starrinrd Technical Specifications would need revision to support an extension of the due date to 30 days.
FPL recommends that the NRC perform a review and revision of the reporting acquirements y associated with the Annual Operating Report, as well. Coupled with this review and the proposal to revisc the MOR will be the need to Itvise or delete Draft Reg. Guide 1.16 (tercreuced above). The draft guxic is outdated and is no longer needed.
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l FPL rceonunends that tla: proposed OL be considered as an Adrnimstrative letter in acenrdance with NRC Admimstranve letter (AL) 93-01: " Announcing a New Type of NRC Generic Communication." The AL woted b: Isened to request the submittal of voluntary information of an administrative nature that will assist the NRC in the performance of hs Annetton, Even though the MOR is required by the technical specifications, what the NRC is proposing is more 4
of an administrative change to submit, on a voluntaty basis, less information in a modified version of the MOR.
The collection of performance indicator data has increased dramatically over the last five to ten years and requires both plant and corporate resources for collection and reporting.
FPL is monitoring the discussions between the Omce for Analysts & Evaluation of Operation Data e
j (AEOD) and the instim!: cf Mticlear Power Operations (INPO) regarding the use ofINPO data as part of the agency's revamped hrfennance Indicator (PD program. FPL is unoicar as to the final outcome of these discussion and urges the agency to establish a goal of cumuzing that the net. data collection burden is not increased. Since _thete in a possibility the agency will be requesting new types of data, it is imperative that efforts continue toward elimmating redimdant and mummary data subenistals.
We appreciate the opportumty to comment on this proposed generic letter.
Very truly yours, f
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E'k W. H. Bohlke Vics president Nuclear Engluecaius and Licensing WHB/spt i
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r Nuclear Information and Resource Service 142416th Street NW, Suite 601. Washington, DC 20036 202 328-0002; fax: 202-467-2183; e-mail. nirsnetrgaol com September 14,1995 Chief Rules Review and Directives 13 ranch U.S. Nuclear Regulatory Commission Washington, DC 20555 Comments Pertaining to the Proposed Reduction of Data liMonthly Oncrating Reports To whom it may concern:
Nuclear Information and Resource Service (NIRS) is submitting comments in reference to the proposed generic letter to reduce the amount of monthly operating data nuclear power plant licensees now reported to the Nuclear Regulatory Commission (NRC), as posted in the Federal Register on August 18,1995.
NIRS is opposed to the reduction in reporting of operational data submitted by nuclear power reactor licensees to the NRC.
Under the proposed generic letter, licensees would no longer be required to report information pertaining to the amount of power generated or the reactor service, availability and capacity factors, which NRC staff consider to have no direct bearing on nuclear safety.
NIRS disagrees with the NRC analysis that the above mentioned data on generated power and capacity factors has no bearing on nuclear safety. To the contrary, NIRS contends that a number oflicensees already have displayed a predilection to prioritize electrical production over safety I
that the NRC has documented as performance deficiencies jeopardizing safe operation.
Consequently, there exists a distinct lack of public trust that industry, once given a reduction in performance reporting requirements, will place public safety above electrical production.
NIRS contends that a reduction in operational data reporting requirements will contribute to performance deficiencies through management complacency and deviation / deterioration of reporting procedures. The reduction of monthly operating data will additionally contribute to management complacency by allowing the licensees to be less accountable to public safety-oriented scrutiny. NIRS contends that given these factors, a relaxation of reporting requirements constitutes an erosion of the NRC's commitment to a defense-in-depth strategy and lends towards W: Dl'-
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further subordinating public health and safety to the economic benefits of the nuclear power licensee.
In reference to information contrarv to the staff position that the affected data relating to power production, availability and capacity factors has no bearing on safety, NiRS specifically cites the Systematic Assessment of Licensee Performance (SALP) Report Nos. 50-317/88-99 and 50-318/88-99 for Calvert Cliffs operated by Baltimore Gas and Electric. The SALP report states in Section til Performance Analysis of Plant Operations that "The licensee was slow to recognize and acknowledge that operations performance had declined over the past few years. At the beginning of the period, licensee management's operating style appeared to unduly focus on power production, thereby contributing to performance deficiencies at the facility "
A NRC special inspection team subsequently reported on May 18,1989 that BG&E's management's "orimary emohasis on oower production with less attention to safety" was in evidence of an overall lack of control of operations and maintenance, leading to NRC imposing nearly $500,000 in fines for federal regulatory violations and placing the Calvert Cliffs nuclear power plants repeatedly on the NRC's watch list.
NIRS regularly monitors monthly operating reports for capacity factars. SIRS uses the capacity factors to monitor which reactors are poor performers and trending towards poor performance.
NIRS contends that poor performance indicators constitute a " red flag" on reactors that warrant scrutiny for contributing factors that directly relate to public safety. Such factors include problems with plant systems issues as in design deficiencies, age-related deterioration, and maintenance and surveillance problems. Similarly, serious management issues that jeopardize safe operation manifest in low performance indicators as evidenced by Tennessee Valley Authority's Browns Ferry I and 3 nuclear power reactors' long standing presence on the NRC Problem Plants List in Category 3 as " Shutdown Plants Requiring NRC Authorization To Operate and Which the NRC Will Monitor Closely." NIRS contends that a reduction in the reporting of performance indicators in monthly operating reports will hinder the public effort to monitor nuclear power plants with performance deficiencies and reactors trending toward poor performance and the associated safety-related issues..
NIRS further contends that the proposed reduction in operational data weakens any argument by NRC and industry for moving towards a more performance-based regulation by reducing the frequency and quality of performance-based data provided by the licensee. NIRS contends that in order to justify any performance-based regulation, the performance component must be clearly demonstrable and measurable. NIRS contends that the NRC proposal to diminish reporting information would have a corresponding effect to diminish measurable data used as part of the documentation for a defense-in-depth strategy component of performance-based regulation.
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Paul Gtmter, irector Reactor Watchdog Project
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m September 18,1995 Mr. David L. Meyers Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Docketing and Service Branch
SUBJECT:
Proposed Generic Letter - Revised Contents of the Monthly Operating Report (60 Federal Register 43174 - August 18, 1995)
Notice of Opportunity for Public Comment j
Dear Mr. Meyers:
These comments are submitted on behalf of the nuclear power industry by the Nuclear Energy Institute (NEI)'in response to the August 18,1995, Federal Register Notice of Opportunity for Public Comment concerning the proposed generic 1
. letter, Revised Contents of the Monthly Operating Report.
NEI supports the proposed changes to the Monthly Operating Report (MOR) j requirements. By focusing the data collection activity on those items necessary to support the NRC Performance Indicator Program, the NRC staff has appropriately deleted unnecessary information previously requested in Draft Regulatory Guide 1.16/ Revision 4, " Reporting of Operating Information Appendix A Technical Specifications.
Please note that the Summary of Unit Shutdowns request remaining in the revised
/ MOR is redundant to the Annual Operating Report requirements contained in the technical specifications. Therefore, we recommend that the NRC staff conduct a parallel review and revision of the reporting requirements contained in the Annual INEI is the organization responsible for establishing unified nuclear industry policy on matters
. affecting the nuclear energy industry, including regulatory aspects of generic operational and technicalissues. NEI's members include all utilities licensed to operate commercial nuclear power plants in the Umted States, nuclear plant designers, major architect / engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy issue.
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n Mr. David L. Meyers September 18,1995 Page 2 Operating Report. The requirements of both reports need to be assessed concurrently such that the revised reports are complementary, not redundant.
In addition, Attachment 1 to the proposed generic letter requires the completed
' operating report submitted by the tenth of the month following the calendar month covered. This is inconsistent with the current requirement in many technical specifications that requires the report be submitted by the 15th of the month following the calendar month covered. Also, the requirement of the Improved Standard Technical Specifications allow up to 15 days. We strongly recommend that the wording of the proposed generic letter be changed to "The completed operating report shall be submitted no later than the 15th of the month following the 1
calendar month covered by the report to Document Control Desk, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 0001."
NEI supports the ongoing NRC staff review of reporting requirements and associated guidance documents to identify areas for reducing or eliminating reporting burdens placed on power reactor licensces without reducing the protection of public health a'nd safety.
Sincerely, 46 &
Thomas E. Tipwo JHE/rs c:
Brian K. Grimes, NRC l
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Department of Energy Washington, DC 20585 Sept.ecber 18, 1995 A
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[h, Hctqxr Chief Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Washington,DC 20555
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Dear Sir / Madam:
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ne U.S. Department of Energy (DOE), Office of Civilian Radioactive Waste Management (OCRWM), submits conunents on the Proposed Generic Letter relating to Revised Contents of the Monthly Operating Report. The OCRWM has responsibility for the Nuclear Waste Fund and the management of Federal programs for recommending, constmeting, and operating repositories i
for disposal of high level radioactive' waste (HLW) and spent nuclear fuel (SNF).
ne OCRWM, with the Energy Information Administration (EIA), has assessed the proposed revisions to the contents ofthe Monthly Operating Report and believes that such changes will
. adversely impact various utivides currently perfbrmed by the OCRWM. Specifically, the.
revisions to the form will impact the ability to the OCRWM to effectively manage the Nuclear l
Waste Fund (NWF). nc OCRWM must ensure that the NWF cash flow is managed such that 4
l funds are invested to maximize returns and NWF receivabte projections are WM monthly.
]
I Comments are presented below:
Effects of Operating Report Revisions on NWF Fee Estimation and Verification j
l Net Electrical Energy Gervrated (Mwh)
A. The generation data reported under the operating status are used for preparing a monthly fee Estimation Report. Each month, for the previous three months, the monthly Net Electrical l
Energy Oenerated (Mwh) data are extracted from both Form EIA-759, Monthly Power Plant j
Report, and the Openting Data Report (ODR), an appendix to the current NRC Operating Report, for each nuclear reactor reporting generation data. Appropriate transmission and l
distribution loss factors am applied and the product for each reactor is then summed to yi, eld an i
approximation of the quarterly NWF fees to be collected on the last working day ofeach mon J.
1
)
. Also included on the Fee Estimation report are the reason (s) for reactor shutdown as reported l
the ODR Appendix D - Unit Shutdowns and Power Reductions.
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Using the Form EIA 759 as the sole verifying source of data will be less precise and could j
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potentially have an adverse effect upon the NWF.
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2 B. Internal EI A survey data, such as those data collected o 3 the Form EIA-759, may suffice as the sole data source. However, definitionaldifferences of the term " net electricity generated" exist across the remittance advice Form NWPA-830G, ODR and Form EIA-759.
Elimination of the ODR would mean elimination of a major ' heck on the net generation data c
reported on fee remittances, and significant modification to NWF fee verification procedures would be required.
1 Gross Electric Energy Generated (Mwh)
Gross generation data reported on the remittance advice are currently compared directly to the ODR gross generation. Gross generation is used as another measure to verify the accuracy ofnet electrical energy generated.
/
For NWF fee estimation and verification, the OCRWM recommends that the NRC retain the Gross Electric Enecy Generated and Net Electrical Energy Generated data on the Operating Report, as separate line items or as a footnote to the report Effects of Operating Report Revisions on Compliation and Publication of Generation Data EIA monitoc *uclear power performance, such as capacity factors and outage rates, and publishes statistics, historical performance and analyses of trends. These data are used i
extensively by OCRWM, the public and private sectors. Electricity forecasts are used to support the funding projections for the OCRWM. Listed below are the data elements required by OCRWM to meet their requirements.
Rated Capacities, Both Thermal and Electric Any changes in rated capacities should be reponed. Capacity levels are necessary to compute capacity factors.
j Monthly Generation Data Monthly data for electric and thermal generation and reactor reserve shutdown hours should be reported. "Ihe DOE publishes the generation data and uses it to compute capacity factor, performance statistics, and electric heat rates.
Projected Ourage Data lhese data are critical for projecting short term nuclear-p>wered electricity generation and thus estimated revenues paid into the NWF.
3 For the compilation, projection and publication of generation data, OCRWM recommends that the NRC continue to collect data on rated capacities, monthly generation, and projected outages.
This is a small amount of data and should represent a minimal additional burden to the utilities.
y Continued collection of these data on the Monthly Operating Reports would be pref
(
implementing a new and separate data collection initiative.
The OCRWM hopes that these comments will be of use to the Commission in its final evaluation of the Proposed Generic Letter.
Sincerelyi,'/
l lpf
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amuel Rousso, Director
/ Office of Waste Acceptance, Storage and Transportation Office of Civilian Radioactive Waste Management O
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Omaha Public Power District 444 Sc r TEt-Street Ma.
J'n serrasr a 681C2-224' J02 '636 200C September 18, 1995 LIC-95-0173 Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Conr'ission Washington, DC 20555 Re'erences:
Docket No. 50-285 2.
Federal Register 'iolume 60. No. 160. dated August 18
'.995
SUBJECT:
Conr'ents fro, Omaha Public Power District on Proposed Generic
- ter Regarding Resised Monthly Operating Report Contents In Reference 2. the NRC so'1 cited ccmr'ents on a proposed generic letter regarding revised onthly operatirg report (MOR) contents.
The Omaha Dublic Power District (OFD) of fers the follo ving comments on the proposed generic letter:
(1)
Reference 2. Attachment 1. " Contents of the Monthly Operating Report." lists in#ormation that should be included in the Unit Shutdown and Power Reduction Form.
This list includes a "Varrat 7 t e sumr'ary o f ~cntnly operat 'ng experience. "
- However, i
the Unit Shutdowns Form in Attachment 1. Appendix B does not ir.clude an area #c-providing a narrative su~ nary of monthly operatirg experlerce.
TFere# ore. *his item should not ce irc'uded 1r the '1s*
(2)
The "rarrative sunnary of operating experience" requirement is vague. OPPD reconnends that this particular item be clarifled to more explicitly define the information that should be included in the narratise sumnary in order to provide for consistency a,ongst utilities.
1 1, A; pend 1x A " Operating Data Report" contents will (3) at'achment t
be greatly reduced to the extent that only six numbers will be requested or this 0r~ (ru-ber of rours reactcr critical -
orth... ear-tc-date. 3 r.o : ;-f a *. ', e ; aro number o# hours Jerer3t:r or- 're onth's year-t: 1 ate. ard cumulative).
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The proposed generic letter should address an option :to electronically transmit the MOR data forms.
i In conclusion, OPPD supports the intent of the proposed generic letter fer-i reducing the amount of information required in the MORs.
t If you should have any questions, please contact me.
i Sincerely, 3
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L'. Patterson i
Division Manager Nuclear Operations l
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Winston & Strawn L.-J. Callan, NRC Regional Administrator, Region IV l
S. D. Bloom, NRC Project Manager l
W. C. Walker, NRC Senior Resident Inspector
. Document 'ontrol Desk l
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TO ur. o vid L. Meyer < chief, nuie. nevi.w and oirectivo, 1
Branch /U.S. NRC)
FROM:
ur. eric oison (s.u. stoirer corp.)
DATET 19 September 1995 SUBJECTt comn ents negarding tne eroposed seneric tetter: Revised Contents of the Monthly Operating Report
Dear Mr. Meyer:
I have attached a letter with my comments regarding this proposed generic letter.
I apomgize for sending these after the end of the comment period, htet I would appreciate if they could be given due conside.ation.
Please contact rne if you have any questforis.
Very truly yours bt%
i Eric Olson n
The S.M. Stoller Corporation s'oe natiro Put,33 souwer. Cuorado 60el.5:ss M m 9-m e r4 x u w tises
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Mr. David L Meyer Chief, Rules Review and Diracavec Branch U.S. Nuclear Reguistory Commission WaeNngton, DC 20555 l
Subject:
Comments ReGarding the Proposed Genanc 1.ettec Revisari coritenes of the Monthly Operedng Report 1
Deer Mr. Meyer:
i have been involved with the reporang and using of Grey Book (NUREG 00201 informerinn minee the 1970s. In the past 15 years, I have used the Grey Book infoonstion in a large venoty of ways en investigate and understand the reasons why nuclear power plants perform as they do. This information has been used to help the nucieer Iridustry imswove both tne performance and asfoty of the nucient i
power pients. Certainly perfomience and safety are closely linked. Furthermore, the leeue of unit performance and safety is becoming even rnere important as utsties are required to become more cost 1
ceT+.ee<e.
The Grey llock informetson that would no longer be required to be reported with the proposed change inciooes very important operational and esfety data. Specificany, the information regarding the thermal and electric generamon is neceanary to determine the overal unit onpocity factors. These dets are not easdy available from any other source.
1 Inerefore, I would recommend that the reporting requirements of Regulatory Guide 1.16 Dg1 be 5
enenges for tne tonowing reasons.
l Ine unit capacity factors provide an important aspect in the understanding of a unit's operating and safety performance.
The forced oute0e rate is only part of this understanding.
These cepecity factor data are not emelly avaanble from another souros for utdities or for tnew supportmo comrectors.
lhe overen performance dets has been used in the past to s@ port a large nueveer of j
performance and setety related studies for individual utiBties, for EPRI. for DeO, etc.
1 Please CettlaCl rDe if you have any quettions-j l
m ol_t O
ne S.M. Stoller Corporation
$760 Flanroe Parkwe, soukter. Colorado 803015718 343449-7220 FAX 34MI40s A(89MdYf
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- TOTAL Pact.003 *+
Di o ptA.v r vi lU, McGraw-HHI,Inc.
[
1200 G Street. N.W., Suite 1100 a
Washington. D. C.20005-3802 l
Date: September 15,1995 Submitted to: U.S. Nuclear Regulatory Commission Chief, Rules Review & Directives Branch Washington, DC 20555 Submitted by: Margaret L. Ryan, Chief Editor, Nuclear Publications for The Nuclear Publications, The McGraw-Hill Companies. Inc.
& McGraw-Hill's Utility Data Institute 1200 G Sreet NW, Suite 1100 Washington, DC 20005 Re: Federal Register notice of August 18,1995: " Proposed Generic Letter; Revised Contents of Monthly Operating Report" These comments are in response to the above-referenced Federal Register notice, which proposes i
to alter NRC's 21-year-old practice in collecting monthly operating data from operating U.S. nuclear power plants.
l The proposed generic letter would allow utilities to stop reporting to the U.S. Nuclear Regulatory Commission (NRC) all monthly data on actual thermal, gross electric, and net electric generation, as l
well as power reductions, and would restrict reporting, essentially, to what happened to actually bring a unit off-line. The given reason is that the U.S. NRC does not need any other data to
/
determine whether a plant is safe.
/
'l McGraw-Hill's Nuclear Publications have been covering the news of nuclear power for nearly 50
)
years and, through our newsletter inside N.R.C., nuclear regulation for nearly 20. We and McGraw-
. Hill's Utility Data Institute collect independently and publish some of the same monthly data NRC collects. NRC's decision to stop publishing could leave us the sole national source of this data, a
,/
commercially attractive idea.
But we, as citizens, are appalled at NRC's assertions in this notice that our safety regulators need not track the actual productive activity of nuclear plants. Over the years, NRC officials have over the years found high correlations between safety and productive efficiency-the most productive plants
- have been, concurrently, the safest. To have NRC now assert that it doesn't need to know what a plant is producing seems to us incomprehensibly contradictory. With NRC's proposed cutback, citizens will be deprived of a quick and non-technical tool to see that plants are operating smoothly.
Moreover, we have seen some of the most dangerous situations develop when plants were operating at reduced or fluctuating power levels. The statistics WRC proposes to continue collecting would not let citizens see whether their neighboring nuclear plant is often encountering such d situations-only whether the situations forced downtime. It would take away one measure citizens now have of assuring themselves of safety.
I Page 1 of 2 flui se eh'f i
Ryan/McGraw-Hill - Comments on Aug. 18,1995 FR Notice, Proposed Generic Letter, MORs The Federal Register notice says the NRC no longer wishes to produce a compilation of these statistics. That, in and of itself, is no reason not to collect them. The NRC collects a great deal of information which is simply filed for the public record, as do other federal agencies.
This proposal can produce no discernible benefit to utilities (and if the NRC expects a benefit, the agency has failed to identify it in the Federal Register notice). The basic performance measures that the NRC says it doesn't need are in fact needed by the utilities themselves for their own assurances of productivity and safety. Moreover, the same data are reported to multiple other places such as
/ power pools, state regulators, other federal regulators, vendors, etc. The outage data-the information the NRC wants to continue receiving-is probably the portion of the agency's reports that consumes the most utility staff time to report.
Though there is no identified benefit, there is hann to be done by this proposal: to the public. It is the public that will not have a place to access the most basic operating data about nuclear power plants and their safety. Arcane-and annual-NRC " performance indicators" are no substitute for basic data that can show good-and bad-performers to non-technical people. Moreover, we simply do not believe that regulators can fulfill their public duties and assess safety without knowing at what levels of efficiency plants are operating.
We do not know the motivation behind this proposal. but we hope that common sense and the NRC's commitment to its public duty will prevail, and that this draft generic letter will NOT be
- issued.
Thank you for this opportunity to comment.
1 Page 2 of 2 i
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' September 15, 1995 p
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WRGINIA POWEN uw.
Chief Serial No. GL 95-055 Rules Review and Directives Branch NL/RPC United States Nuclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
COMMENTS ON PROPOSED GENERIC LETTER REVISED CONTENTS OF THE MONTHLY OPERATING REPORT Virginia Power has reviewed the proposed generic communication, Revised Contents of the Monthly Operating Report (60 FR 43174), dated August 18,1995. We concur with the commerts separately submitted by the Nuclear Energy Institute (NEI). In j
addition, we submit the following comment concerning the proposed generic letter for
)
your consideration.
We propose that the generic letter provide the option of submitting a Quarterly J
Operating Report in lieu of the monthly report. This option would be subject to licensees modifying related prior commitments for monthly reporting through the appropriate license amendment process. In the discussion section of the proposed generic letter, retention of the monthly operating report is based on the NRC's continuing need to receive performance indicator (PI) data at the same frequency.
However, in the background section of Attachment 1, it is noted that Pl reports were produced quarterly from 1987 to June 1993, then semiannually until June 1995, and annually thereafter. Virginia Power perceives that this reduction in PI reporting frequency by the NRC warrants similar consideration for a reduction in the frequency imposed on licensees for the submittal of operating reports.
In addition to the proposed reduction in content, a quarterly requirement for reporting would also represent a reduction in regulatory burden without any significant impact on the Pl reporting program.
Should you have any questions, please contact us.
Very truly yours, 4
i M. L. Bowling, Manager Nuclear Licensing and Operations Support cc:
Mr. Thomas E. Tiptor.
Nuclear Energy Institute 1776 i Street, N. W.
Suite 400 Washington, D. C. 20006-3708 A r o A n n i n n_
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PECO ENERGY 7
ecco am c-em, Nuclear Group Headquarters 965 Chestertwook Boulevard s
3 5 Wayne, PA 19087-5691
..,j September 13,1995 l
Mr. David L Meyer, Chief Rules Review and Directives Branch Division of Freedom of Information and Publication Services Office of Administration U.S. Nuclear Regulatory Commission Washingtort DC 20555
Subject:
PECO Energy Company Comments Ccnceming the Proposed Generic Letter on
" Revised Contents of the Monthly Operating Report" (60FR43174, dated August 18, 1995)
Dear Mr. Meyer:
This letter is being submitted in response to the NRC's request for comments concerning a proposed Generic Letter (GL) 95 XX, " Revised Contents of the Monthly Operating Report,"
published in the Federal Register (i.e.,60FR43174, dated August 18,1995). The purpose of this proposed GL is to inform licensees of nuclear power reactors that the NRC is requesting the submittal, on a voluntary basis, of less information in a modified version of the monthly operating report.
PECO Energy Company appreciates the opportunity to comment on this proposed GL and recommends that the content of the monthly operating report be modified to eliminate the need to track load reductions that do not result in plant shutdowns, or limit the reporting of load reductions to only those resulting in a power reduction of greater than 50%, or those associated with significant circumstances. In addition, we endorse the comments submitted by the Nuclear Energy Institute (NEl) on behalf of the nuclear power industry concerning this proposed GL If you have any questions, please do not hesitate to contact us.
Very truly yours,
.h-G. A. Hunger, Director - Licensing l
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i P O BOX 53999. PHOENIX, AAl2ONA 85072-3999 -
J' WILLIAM L STEWART SE5N
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102-03473-WLS/AKK/ACR I
September 17,1995 Mr. David L. Meyer i
Chief, Rules Review and Directives Branch ~
U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Mr. Meyer:
i
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
)
. Units 1,2, and 3 i
Dockets Nos. STN 50-528/529/530 Proposed Generic Letter--Revised Contents of the Monthly i
Operating Report, 60 Federal Register 43174 (August 18,1995)
On August 18,1995, the Nuclear Regulatory Commission (NRC) published in the Federal Register a request for public comment on a proposed Generic Letter, Revised Contents of the Monthly Operating Repnrt. Arizona Public Service Company (APS) hc.ewith submits a response to the request.
APS believes that the proposed change represents an improvement. This change will save resources used currently for the sole purpose of preparing the report to the NRC.
The only concem is that the proposed change provides that the report be submitted by the 10th of the month following the calendar month covered by the report. Currently, the Palo Verde Tech Specs allow the report to be submitted no later than the 15th of each month following the ' calendar month covered' by the report.
Submittal by.the 15th has occasionally been a problem when holidays fall during the first weeks of a month.
Operating logs must be retrieved from the control rooms, and information extracted from them. This effort must be done correctly. Thus it might not be possible for APS to consider using the provisions of the new Generic Letter if the NRC insists on submittal by j
. the 10th of the month. For that reason, it is requested that the Generic Letter be issued in j
a manner that will permit retention of the current submittal date.
As an attemative to the proposed requirements it is suggested that the NRC consider an annual report for those plants that produce a comprehensive intemal monthly performance indicator report and include resident inspectors on distribution. This would retain the ability of the.NRC to identify degrading performance, yet provide the NRC with generic specific information for the NRC's annual industry performance report.
9 ( M @ ?d6fD j
l Mr. David L. Meyer Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission Proposed Generic Letter-Revised Contents of the Monthly Operating Report Page 2 Thank you for the opportunity to comment on the Proposed Generic Letter.
l Should you have any questions about these comments, please call Angela Krainik at (602) 393-5421.
Sincerely, I
wa l
/
WLS/AKK/ACR/dpr 1
I cc:
Brian K. Grimes. NRC i
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September 19, 1995 Chief Rulas Review and Directives Branch U.S. Nuclear Regulatory Commissien Washington, DC 20555-Comments on Proposed GL Regarding Monthly Operating Reports Public Citizen's Critical Mass Energy Project is opposed to NRC's proposed reducti:n ir the am^unt of monthly ;perating data nuclear p wer plant licensees now report to NRC.
l The propcsed chance woula mea.n that nuclear utilities would no longer report sucn information as the amount tf pcwer l generated er the reactor service, availability and capacity factors.
Although the NRC staff considers this data to have no direct bearing on nuclear safety, the staff's view is myopic.
l Capacity factors and availability cata provide a means to assess the relative ef ficiency of nuclear reactors.
The proposed reduction in reporting requirements seems to run counter to the NRC's new performance-based regulatcry philosophy.
If the NRC is going to regulate nuclear reactors based upon performance, then capacity factors and availability data would seem to be appropriate tools for any assessment.
Furthermore, as the nuclear industry enters an era of competition in the electricity market, economic competitiveness will impact on safety. As former NRC Chairman Selin indicated, economic pressures may force utilities to cut corners on safety.
Data, such as reactor availability and capacity factors, can help reveal declining trends in reactor performance that may not be captured in the NRC's performance indicator program or its systematic assessment of licensee performance.
Finally, the NRC has indicated that two of the performance l
indicators captured in the monthly operating reports are unique to that report.
Therefore, the NRC will still require monthly submittals from its licensees.
Since the licensee will still be submitting a monthly report, the inclusion of capacity factors ana availability data hardly represents an undue burden on alcensees.
l Sincerc'y, 5ll?Nd?&
i
James P.
Riccio Staff Attorney Critical Mass Energy Proj ect
-. ~. _ -
s 3
8ricwt N
RD 2, Box 132
~ ' 7 0*
~
Clearville, PA 15535 October 26, 1995
.;." 9:53
~~
In the matter of:
a,
~
' CD FR 'W Health Effects Valuation, letter from T. S. Kress, Chairman ACRS,74to James R.
/ 1.
/ Taylor, EDO NRC, dated September 13, 1995.
l 2.
Nuclear Energy Institute petitions NRC for "reducticn in commitment," Federal l
Register Notice dated September 14, 1995.
3.
Petition for Rulemaking to Amend 10 CFR 50.48 from W. Rasin, NEI, to J. C.
Hoyle, Secretary NRC, dated February 2, 1995.
4.
NRC considers one-time 5-year automatic extension of certain materials licenses.
EG/BR 0032 Vol 15 No. 33 News Releases dated September 15, 1995.
5.
C asks public comment on propose 1 to reduce amount of operational data (rep ted by nuclear power plants licensees.
NUREG/BR 0032 Vol 15 No. 31, dated
\\'
ember 1, 1995.
6.
Compatibility with the International Atomic Energy Agency, Final Rule, FR dated September 28, 1995 at Page 50248 and Re8ulations on the Transportation of Radioactive Material published in the Federal Register September 28, 1995.
7.
Three related NUREGs issued together for comment in August 1995:
NUREG 1505 A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys.
NUREG 1506 Measurement Methods for Radiological Surveys...
NUREG 1507 Minimum Detectable Concentrations with Typical Radiation Survey Instruments...
Dear Commissioners:
This comment letter contains comments on an entire group of recent rule-makings and other actions for which the NRC has invited or allowed comment.
I have chosen this unusual approach to demonstrate a pattern in the recent rule-makings and other actions which place the public in a very unsafe regulatory milieu.
1.
Health Effects Valuation i
Presently, the NRC staff is reconsidering the ancient $1000/ person rem avoided health effects valuation used in the GDCs and elsewhere. This calculates into a human life being worth about $1.5 million.
The ACRS has suggested that
$3 million/ human life would be more consistent with the valuation of human life in other Federal agencies. The staff has suggested reducing the valuation of human life by discounting the $1000/ person rem. This attitude on the part of the staff and NRC to discount human life is part of the NRC's arrogant, deficient attitude towards safety.
(ACRS letter to James Taylor dated 7-20-95.)
ar*~;.
Q
_2-2.
NEI Petitions for " Reduction in Commitment" What a novel concept!
A true bonus to the nuclear industry enabling them to make a contract and if they don't want to fulfill that contract, they can give themselves a " reduction in commitment." I wish I had the option to give myself a " reduction in connitment" from my home mortgage by self determination.
This is a completely parallel situation:
- 1) The nuclear industry makes a commitment.
- 2) The NRC "would permit a licensee (nuclear industry) to change (reduction in commitment) its quality control pro 8 ram if it could show by analysis (esoteric paperwork) that the chan8e does not involve an unreviewed safety question.
(Safety questions remain after they are reviewed!)..."
Again, the public safety is subjected to an arrogant, deficient attitude, but this time the attitude arises from the nuclear industry in petitioning for these changes.
- 3) The Thermolag Debacle continues.
A fire retardant material failed to provide fire protection again and again in testin8 One person went to jail, fines were levied and the Thermolag remains in place performing most deficiently. The result is the nuclear industry petitions for a " reduction in commitment" and other relief through rulemaking of 10 CFR 50.48.
Again, the nuclear industry shows its arrogant, deficient attitude where safety is concerned.
- 4) Forget safety; just change the rules.
With 10 CFR 30, 40 and 70, the NRC plans to extend licenses for 5 years.
Many small users oring their records up to date and do essential maintenance at license renewal time just as many people change their smcke alarm batteries on their birthdays.
Small users need the shock of filling out license forms and paying a fee to focus their attention on their radioactive sources.
This is one small way that the NRC demonstrates its blase and deficient attitude towards safety.
- 5) Throw away the data before somebody finds it.
The NRC is proposing to reduce the amount of operational data reported by nuclear plant licensees.
TMI 2 would have liked this rule. Think how little of the shoddy workmanship and arrogant attitude would have been reported during the accident if the licensee did not have to report his operational data.
With nuclear power plants aging, deficiencies will be hidden by this rule.
Errors of judgment and sins of commission need never reach the light of day.
By reducing the amount of data reported sufficiently, the dying need never know the source of the radiation that caused their cancer.
- 6) Lowest common denominator:
domestic and foreign.
The Uruguay Round of GATT requires that "Each member shall ensure the con-formity of its laws, regulations and administrative procedures with its obliga-tions as provided in the annexed Agreements." (GATT WTO Marrakesh, Morocco, dated 4/15/94.)
i I
The Annexed Agreements are tens of thousands of pages. The NRC responded to these annexed Agreements by a rule which promotes the transportation by air of plutonium and other radionuclides. The NRC again presents its arrogant, inhumane attitude towards safety by promoting the air transportation of plutonium and other radionuclides while the country is in the throes of reeling from major terrorist acts -- Arizona train derailment, Oklahoma Federal Building bombing and New York City building bombing.
- 7) The Devil is in the details.
Commissioner F. Gail Deplanque said in a speech on November 29, 1994 "The Devil is in the details." The Commissioner is correct.
By manipulating details as described in KUREGs 1505, 1506 and 1507 an investigator could come up with any interpretation he wished. The recent Thermolag criminal case against a Thermo-lag principle demonstrated that manipulation of technical data is impossible for a jury of good citizens to overcome.
The same night, he said for NRC staff or just about anyone -- Our Nation has entered an era of technolo8y where a half dozen reprobates can derail a train with crowbars, where a "unabomber" can kill for two decades, where a former foe sells bomb grade material on the black market.
The NRC must wake up to the realities of today and understand that its primary agenda is safety instead of licensing at any cost.
An effective, all-inclusive public safety policy must always be incorporated in all regulations promulgated by the NRC.
To do less than this sows massive j
seeds of public distrust and disgust.
I find all of the above regulations abhorrent to the public at large and heartily recommend that they be removed from any further consideration.
Do what is torally right.
Sincerely, l
N Karl J. Novak j
cc - Senator Arlen Specter Senator Rick Santorum Congressman Bud Shuster
9
- e t
RESOLUTION OF PUBLIC COMMENTS i
1 i
l ATTACHMENT 9 I
r
A 4
)
COMMENT RESOLUTION - PROPOSED GENERIC LETTER REVISED CONTENTS OF THE MONTHLY OPERATING REPORT j
On August 18. 1995, the NRC published a notice of opportunity for public comment in the Federal Regfster (60 FR 43174) on a proposed generic letter that addresses revised contents of the monthly operating report.
The purpose
.of the proposed generic letter is to recuest the submiM r., on a voluntary basis, of less information in a modifiec version of the monthly operating report. The information to be deleted from the monthly operating report is not considered essential to the safety mission of the agency.
Comments were due on September 18, 1995.
Sixteen letters were received in response to the notice. Commenters included 6 utilities. 2 private industries.1 university.1 industry organization.
I government agency. 3 public interest groups, and 2 individuals (no
~
a f filiation). Comments were aggregated into major issues: staff responses to these issues are presented below.
The letters that were received are attached.
1.
MONTHLY OPERATING REPORT DATA PROPOSED FOR DELETION RELATED TO SAFETY Comments:
About half of the commenters disagreed that the information )roposed for deletion is not an essential part of the safety mission of t1e agency.
Examples of such comments include: "We strongly disagree that the reporting of such data as availability and capacity factor have no bearing on nuclear plant safety": "As nuclear power plants age and as these plants face increased competition from other sources of power. the operations _ data point toward possible safety problems"; "Certainly performance and safety are closely linked....
The unit capacity factors provide an important aspect in the 3
understanding of a unit's operating and safety performance"; and "NRC officials have over the years found high correlations between safety and productive efficiency."
In contrast with commenters who believe the most productive plants (high capacity factor and high availability) are the safest, two commenters were concerned that a primary emphasis on power production would result in less attention to safety, and that economic pressures may force utilities to cut corners on safety.
Response
The NRC has determined that availability and capacity factor data should continue to be reported in the monthly operating report.
4 i
ATTACHMENT 9 i -
- -.-, 2.
PUBLIC NEED FOR MONTHLY OPERATING REPORT DATA PROPOSED FOR DELETION Comments:
Several commenters stated that there is a public need for the information being proposed for deletion from the Monthly Operating Report since it provides a way for the public to monitor nuclear power plant safety. Examples of such comments are:
....a reduction in the reporting of performance indicators-in the Monthly Operating Reports will hinder the public effort to monitor nuclear power plants with performance deficiencies and reactors trending toward poor performance and the associated safety-related issues."
and "With NRC's proposed cutback, citizens will be deprived of a quick and non-technical tool to see that plants are operating smoothly."
One commenter was also concerned that the NRC would no longer collect data on nuclear power plants operating at reduced or fluctuating power.
The commenter felt that citizens would no longer be able to see whether neighboring plants are operating in a condition that could lead to dangerous situations.
Response
With respect to the information that the public may need to monitor operational safety at nuclear power plants, all plant outage information will continue to be provided in the Monthly Operating Report and the critical hours and generator on-line hours during the month will still be provided so that the public can tell at a glance whether a unit was operating smoothly.
The reasons for, and Jurations of, both scheduled and forced outages will still be presented in the reports.
In addition. the NRC has determined that availability and' capacity factor data should continue to be reported in the monthly operating report.
Also, any power reduction initiated because a shutdown is required by a plant's Technical Specifications, even if the shutdown is not completed, will still be reportable within one hour under 10 CFR 50.72, and this information will continue to be made publicly available.
The information on power reductions that is to be deleted from the Monthly Operating Report is not useful to the public for assessing current plant operational safety since by the time this information a) pears in the Monthly Operating Report, the circumstances surrounding tie operation at reduced or fluctuating power will have passed and already been assessed for potential safety significance by the licensee and NRC.
3.
DOES PROPOSED GENERIC LETTER BENEFIT LICENSEES BY REDUCING THEIR BURDEN?
l Comments:
Several commenters stated that the reduced reporting offers utilities little i
or no benefit in reduced burden.
For example, one commenter stated that "This proposal can produce no discernible benefit to utilities." Another commenter stated that "Since licensees will still be submitting a monthly report, the
0 t inclusion of capacity factors and availability data hardly represents an undue burden on licensees." However, the licensees who actually prepare these reports do not agree.
One utility stated that the proposed changes to the monthly operating report would substantially reduce their reporting burden.
Another utility stated that "This change will save resources used currently for the sole purpose of preparing the report to the NRC."
Response
Several utilities have declared that reduced reporting will save resources.
No utility stated that reduced reporting will not reduce their burden.
Since adoption of the proposed changes in re)orting is voluntary, utilities that believe the proposal will not reduce t1eir burden may continue to report as in the past.
From the letters received, though, it a) pears that licensees will stand to benefit from tN proposed generic letter )y not having to devote as many resources to the preparation of the Monthly Operating Report.
4.
OTHER USES OF MONTHLY OPERATING REPORT DATA PROPOSED FOR DELETION Comments:
Several commenters discussed the usefulness of the Monthly Operating Report data for other than direct safety applications, and the difficulty of getting this data from other sources. A government agency that commented on the 1
proposal uses gross and net electrical energy generated, thermal and electric rated capacities, monthly generation data, and projected outage data to carry out its mission of managing the Nuclear Waste Fund.
They argue that the elimination of this data from the NRC Monthly Operating Report will eliminate an independent means of verifying the data reported directly to them.
Response
The NRC has determined that availability and capacity factor data should continue to be reported in the monthly operating report.
5.
ISSUES OF SUBMITTAL DATE AND FREQUENCY Comments:
Several of the commenters who favored the proposed generic letter questioned the need for the present frequency and submittal date of the report. There were suggestions to change the frequency of the report from monthly to quarterly or annually, and to change the submittal date from the 10th day of the month following the report period (month) to the 15th or 30th of the following month.
Several letters also noted that some plant Technical Specifications. including the Standard Technical Specifications. require such reports on the 15th of the l
month following the report month.
Response
Although the Performance Indicator (PI) Report will be published annually starting in Fiscal Year 1996, the Commission has directed the staff to collect PI data on a continuing basis.
In addition to an annual PI Report. PI data is also needed to support semiannual Senior Management Meetings, program office and agency annual reports, and special requests by the Commission for current PI information.
Data is, therefore, still needed on a monthly basis, i
Since many plant Technical Saecifications, including the Standard Technical S)ecifications state that t1e Monthly Operating Report is due on the 15th of tie month following the report month. this comment is acceated, and the due date will be changed from the 10th to the 15th of the monti in the generic letter.
6.
FORM OF SUBMITTAL Comments:
One commenter provided several comments on the form of the report. One comment was that there is not enough space in the unit shutdown form (Appendix B) for a narrative summary. The commenter also stated that instructions for this summary are vague. Another comment stated that instead of a form for the operating data report (Appendix A), a narrative summary of monthly operational experience would be sufficient.
Finally, it was suggested that the generic letter should address _an option to transmit the data electronically.
Response
Appendices A and 8 are not official NRC forms, such as the forms used for Licensee Event Reports (Form 366). but rather are suggested layouts for presenting the information.
Nevertheless. Appendix B (Unit Shutdowns) in the generic. letter will include space for a narrative summary.
Instructions for the summary were inadvertently left out of the Federal Reaister notice: they will be included in the final generic letter.
The instructions will be essentially the same as were provided in Regulatory Guide 1.16. but with references to load reductions removed.
In the Operating Data Report (Appendix A). use of the form is not required, but the data should be clearly identified, and a standard layout would help prevent errors in entering the data into databases.
The suggestion that the data be transmitted electronically is an excellent one that could significantly speed up the process of submitting data, and may 1
prevent human errors in the Performance Indicator Program data entry. The NRC is currently assessing various means for transmitting data electronically.
I l
7.
REVIEW ANNUAL' OPERATING REPORT REQUIREMENT FOR REDUCED REPORTING Comments:
. Two commenters' recommended that the NRC perform a parallel review of reporting requirements for.the Annual Operating Report to avoid potential redundant
. reporting requirements.
i
Response
This' generic letter only addresses ti;c Monthly Operating Report.
The NRC Ll intends to review Annual Operating Report requirements, also discussed in Regulatory Guide 1.16..for potential reductions'in re3orting, in the future.
The Annual Operating Report will be addressed by the 9RC Reporting Requirements Review. Panel. This group is fully aware of the activities associated with potential revisions in the Monthly Operating Report requirements, and will address any potential redundancy in the Annual Operating Report reporting requirements.
1 e
i COMMENT RESOLUTION ISSUES - PROPOSED GENERIC LETTER REVISED CONTENTS OF THE MONTHLY OPERATING REPORT Org.
Opposes Supports Is MOR Benefits Submittal Other Form of Review MOR GL MOR GL Data Licensees Date/
Uses of Submittal Annual Related
/ Reduces Frequency MOR Data Issues Oper to Safety Burden?
Report ?
Greenpeace X
X Dr. Geoffrey X
X Rothwell Commonwealth X
X i
Edison Florida Pwr X
X X
I
& Light Nuc Info and X
X Res Serv Nuclear X
X X
Energy Inst Dept. of X
X X
Energy Omaha Pub X
X Pwr Dist Stoller Corp X
X X
McGraw Hill X
X X
X Virginia X
X Power PECO Energy X
Arizona Pub.
X X
X Serv Co
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CRGR REVIEW PACKAGE I
PROPOSED ACTION:
Issue a draft generic letter notifying licensees that the NRC is requesting the submittal of less information in a modified version of the monthly operating report (MOR).
A notice of opportunity for public comment on the draft generic letter was published in the Federal Register and l
comments have been incorporated into the draft generic letter.
No licensee action or written response is required.
CATEGORY:
2 RESPONSE TO REQUIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW (1)
The proposed generic requirement or staff position as it is proposed to be sent out to licensees. Where the objective or intended result of a proposed generic requirement or staff position can be achieved by setting a readily cuantifiable standard that has an unambiguous relationship to a reacily measurable quantity and is enforceable the 3roposed requirement should merely specify the objective or result to
)e attained, rather than prescribing to the licensee how the objective or result is to be attained.
See the proposed generic letter. " Revised Contents of the Monthly Operating Report" (Attachment 1).
(ii)
Draft staff papers or other underlying staff documents supporting the requirements or staff )ositions.
(A copy of all materials referenced in the document shall se made available upon request to the CRGR staff. Any Committee member may request the CRGR staff to obtain a copy of any reference material for his or her use.)
The purpose of this generic letter is to notify licensees that the NRC is requesting the submittal of less information in a modified version of the monthly operating report. The following documents support this staff action:
SECY-94-093. "NRC Staff Assessment of Reporting Requirements for Power Reactor Licensees." April 1. 1994.
Staff requirements memorandum (SRM) dated April 26, 1994, endorsing staff plans to assess reporting requirements for power reactor licensees and initiate rulemaking or other appropriate actions consistent with the recommendations in SECY-94-003. " Plan for Implementing Regulatory Review Group Recommendations." January 7.
1994.
Draft Regulatory Guide 1.16. Revision 4. " Reporting of Operating Information - Appendix A. Technical Specifications." August 1975.
ATTACHMENT 2
2-(iii)
Each proposed requirement or staff position shall contain the sponsoring office's position as to whether the proposal would increase requirements or staff positions, implement existing requirements or staff positions, or would relax or reduce existing requirements or staff positions.
The prcposed generic letter identifies the information needed by the staff to support the NRC Performance Indicator Program, the Office for Analysis and Evaluation of Operational Data (AE00) Annual Repart (NUREG-1272), and regular information requests from the Congress, other government agencies and the Commission: this information represents a reduction in scope over the information previously requested. Acceptance by the licensees of the reduced scope of repcrting is voluntary.
(iv)
The proposed method of implementation with the concurrence (and any comments) of OGC on the method proposed. The concurrence of affected program offices or an explanation of any nonconcurrences.
The method of implementation will be the proposed generic letter; licensees may provide the reduced scope of information being requested on a voluntary basis.
Both AE00 and tne Office of the General Counsel (OGC) have reviewed the nroposed generic letter: AEOD concurs with the reduced scope of infonnation being requested and OGC expressed no legal objection to the method.
(v)
Regulatory analyses conforming to the directives and guidance of NUREG/BR 0058 and NUREG/CR 3568.
(This does not apply for backfits that ensure compliance or ensure, define, or redefine adequate protection.
In these cases a documented evaluation is required as discussed in IV.B.(ix).)
A regulatory analysis is not required because, as stated above, the generic letter is requesting the submittal of less information than previously requested in Draft Regulatory Guide 1.16. Revision 4. and provides for voluntary compliance on the part of licensees.
(vi)
Identification of the category of reactor plants to which the generic requirement or staff position is to apply (that is, whether it is to apply to new plants only, new OLs only, OLs after a certain date, OLs before a certain date, all Ols, all plants under construction, all plants, all water reactors, all PWRs only, some vendor types, some vintage types such as BWR 6 and 4, jet pump and nonjet pump plants, etc.).
The proposed generic letter would apply to all operating nuclear power reactors.
3-(vii)
For backfits other than compliance or adequate protection backfits, a backfit analysis as defined in 10 CFR 50.109. The backfit analysis shall include, for each category of reactor plants, an evaluation
{
which demonstrates how the action should be prioritized and scheduled in light of other ongoing regulatory activities. The backfit analysis shall document for consideration information available concerning any of the following factors as may be appropriate and any other information relevant and material to the proposed action:
(a)
Statement of the specific objectives that the proposed action is designed to achieve:
(b)
General description of the activity that would be required by the licensee or applicant in order to complete the action:
(c)
Potential change in the risk to the public from the accidental release of radioactive material:
(d)
Potential impact on radiological exposure of facility employees and other onsite workers:
(e)
Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delay:
(f)
The potential safety im)act of changes in plant or operational complexity, including t1e relationship of proposed and existing regulatory requirements and staff positions:
(g)
The estimated resource burden on the NRC associated with the proposed action and the availability of resources:
(h)
The potential impact of differences in facility type, design, or age on the relevancy and practicality of the proposed action:
(1)
Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis:
(j)
How the action should be priorit.2ed and scheduled in light of other ongoing regulatory activities. The following information may be appropriate in this regard:
1.
The proposed priority or schedule, 2.
A summary of the current backlog of existing requirements avaiting implementation, 3.
An assessment of whether implementation of existing requirements should be deferred as a result, and x
\\
4 s
4.
Any other information that may be considered appropriate with regard to priority, schedule, or cumulative impact.
For example, could implementation be delayed pending public comment?
Backfit considerations do not apply because acceptance of the reduced scope of reporting is voluntary.
(viii)
For each backfit analyzed pursuant to 10 CFR 50.109(a)(2) (i.e., not adequate protection backfits and not compliance backfits), the proposing Office Director's determination, together with the rationale for the determination based on the consideration of paragraph (1) and (vii) above, that:
(a)
There is a substantial increase in the overall protectica of aublic health and safety or the common defense and security to
)e derived from the proposal: and-(b)
The direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
l Backfit considerations do not apply because acceptance of the reduced scope of reporting is voluntary.
1 (ix)
For adequate protection or compliance backfits evaluated pursuant to i
(a) a docunented evaluation consisting of:
1 (1) the objectives of the modification (2) the reasons for the modification (3) the basis for invoking the compliance or adequate protection exemption.
'.5) in addition, for actions that were immediately effective (and therefore issued without prior CRGR review as discussed in III.C) the evaluation shall document the safety significance and appropriateness of the action taken and (if applicable) consideration of how costs contributed to selecting the solution among various acceptable alternatives.
Backfit considerations do not apply because acceptance of the reduced scope of reporting is voluntary.
(x)
For each evaluation conducted for proposed relaxations or decreases
)
in current requirements or staff positions, the proposing Office j
Director's determination, together with the rationale for the j
determination based on the considerations or paragraphs (1) through (vii) abcVe, that:
i l
l s
.s.
i (a)
The public health and safety and the common defense and i
security would be adequately protected if the proposed reduction in requirements or positions were implemented, and (b)
The cost savings attributed to the action would be substantial l
enough to justify taking the action.
Public health and safety and the common defense and security would continue to be adequately protected if the proposed reduction in the scope of information requested was implemented.
The staff has eliminated the submittal of unnecessary information because it has no impact on the regulatory activities of the agency.
Some cost savings would accrue from having to compile and submit less information.
(xi)
For each request for information under 10 CFR 50.54(f) (which is not subject to exception as discussed in III.A) an evaluation that includes at least the following elements:
(a)
A problem statement that describes the need for the information in terms of potential safety benefit.
(b)
The licensee actions required and the cost to develop a response to the information request.
(c)
An anticipated schedule for NRC use of the information.
(d)
A statement affirming that the request does not impose new requirements on the licensee, other than for the requested information.
This generic letter does not request information under 10 CFR 50.54(f).
(xii)
An assessment of how the proposed action relates to the Commission's Safety Goal Policy Statement.
Although not quantifiable, it is recognized that how well a plant is t
operated is a vital component of plant safety. Therefore, it is essential that the staff continue to gather information for its independent analysis of nuclear power reactor safety performance trends.
l I
l l
i
April 1, 1994 SECY-94-093 EQB:
The Commissioners i
ERGE:
James M. Taylor Executive Director for Operations
SUBJECT:
NRC STAFF ASSESSMENT OF REPORTING REQUIREMENTS FOR POWER REACTOR LICENSEES PURP0$E:
To inform the Commission about the activities of the task force formed to l
assess reporting requirements for power reactor licensees, including plans for evaluating the need or frequency for reporting requirements contained in the regulations, technical specifications or industry codes and standards, t
commensurate with the implementation plan for the Regulatory Review Group recommendations (SECY-94-003).
SUMMARY
This paper describes the activities of a task force to determine if some reporting requirements imposed on power reactor licensees can be reduced in l
scope or eliminated.
As part of this effort, the task force selected a test l
group of 11 reporting requirements for review to develop a means for documenting staff rationale when assessing reporting requirements.
The I
approach for continuing the effort to assess reporting requirements that the 1
industry and the NRC staff identified for possible deletion or revision is discussed; the schedule for accomplishing this is compatible with Topic Area l
No. 59 (Reporting Requirements) of the implementation plan for the Regulatory I
Review Group recommendations. Also, the staff will jnitiate rulemaking or take other appropriate regulatory actions based on the recommendations of the Regulatory Review Group and the Reporting Requirements Task Force, and will investigate the efficacy of applying electronic transmission techniques for data, reports and test results.
l NOTE:
TO BE MADE PUBLICLY AVAILABLE Cantact:
Brian K. Grimes, NRR WHEN THE FINAL SRM IS MADE i
504-1163 AVAILABLE I
I James W. Shapaker, NRR 504-1151 l
I 1
l f '~'0 " 2 Y y - L & y l.
The Commissioners,
BACKGROWW:
In mid-January 1992, the Chairman asked the staff to review the reporting requirements imposed on power reactor licensees to determine if some requirements could be reduced in scope or eliminated.
Shortly thereafter, two Presidential directives, dated January 28, 1992, requested that the Comission and other energy and environmental agencies work together to streamline regulatory requirements and set aside a 90-day period for the evaluation of existing regulations.
The Comission directed the Committee to Review Generic Requirements (CRGR) to use appropriate inputs from the public, the NRC staff
- and other Federal agencies to conduct a special regulatory review addressing the spirit of the concerns raised by the President.
After completing its i
review, the CRGR recommended revising the regulations in eight areas (SECY '
141, dated Aprf) 17, 1992) for which the CRGR could clearly make a determination in the allotted 90 days that a reduction in the regulatory burden could be achieved without in any way reducing the public health and safety or comon defense and security, j
In conducting its review, the CRGR issued a Federal Reaister notice on February 24, 1992 (57 FR 6299), seeking p W 'c comment, and also sought coments from the NRC staff; the CRGR heh public meeting to discuss the comments that were received.
Among other ancerns, the industry considered the magnitude of reporting requirements to be burdensome and some reporting j
requirements to be unnecessary.
In addition, the industry expressed concern over NRC guidance documents issued to provide interpretations of reporting requirements in the regulations and over reporting requirements contained in license documents such as the technical specifications.
Because many of the comments received were outside the scope or criteria of the special CRGR review, their reso16 tion was deferred to other agency initiatives for evaluating reportirg requirements.
Therefore, the staff decided to expand the scope of this effort, and consider the potential for reducing reporting requirements in a comprehensive and integrated manner.
In a memorandum from the Executive Director for Operations, dated May 7,1992, the staff described plans for (1) soliciting the views of the nuclear power industry and other interested parties on reducing reporting requirements and (2) issuing a report with staff recommendations on modifying certain reporting requirements and conducting an expanded review of the reporting requirements for power reactor licensees.
Public comment was obtained through the issuance of a Federal Reatster notice (57 FR 27394, dated June 19,1992); the comment period expired September 30, 1992. identifies those who commented and characterizes the comments that were received.
A multi-office task force was established to support this effort.
The members of the task force are given in Enclosure 2.
To facilitate staff involvement, the task force developed a User Need Statement form for the staff 'to use in developing the justification for reporting requirements.
To affirm the utility of the User Need Statement, the task force identified a test group of 11 reporting requirements for evaluation by the staff. includes (1) a list of the 11 reporting requirements that comprise the test group,
Ji.
1 7
The Commissioners l l
along with the User Need Statements prepared by the cognizant-line organizations, (2) a compilation of the results from the User Need Statements 3
and (3) comment resolution statements for those public consents received in response to the Egignl Reafster notice that are related to the test group of
?
reporting requirements.
The task force met in January 1993 to discuss various approaches for continuing the review of the reporting requirements and to evaluate the need to modify the User Need Statements.
In January 1993, the Executive Director for Operations established the Regulatory Review Group-(ARG).
The RRG conducted a disciplined review of power reactor regulations and related processes, programs and practices.
The findings and reconnendations of the RRG focused on identifying specific l
problems, their cause, and. achievable solutions.
In August 1993, the RRG issued its final report containing recommendations aimed at reducing the i
regulatory burden on power reactor licensees and strengthening NRC i
administrative practices...The RRG report discussed several key areas in which changes in-the way NRC conducts business could significantly reduce industry and NRC staff costs < without adversely affecting the level of safety at-operating plants.
In examining agency administrative practices, one of the i
areas proposed by the RRG for possible efficiencies was the area of reporting requirements.
3 The staff prepared an implementation plan for the recommendations of the RRG (SECY-94-003, dated January 7,1994).
The plan contains general implementation strategies, priorities, major milestones and target schedules
.[
for the timely resolution of the recommendations.
In this regard, the i
resolution approach being recommended by this task force for the review of the i
reporting requirements-for power reactor licensees is compatible with the implementation plan for the RRG recommendations.
.[
DISCUSSION:
{
Public comments that'have been received in response to Federal Reaister i
notices soliciting the views of the nuclear power industry and other i
interested parties on reducing regulatory burdens and reporting requirements l
suggest a need for the NRC staff to look at power reactor reporting requirements.
The comments stated that the NRC staff is in a better position than the industry to judge whether certain reporting requirements are still j
needed.
If the NRC is.to conduct a comprehensive review of its reporting requirements, which would involve substantial resources from the line j
organizations, the NRC must' adopt an efficient and effective approach.
' Irrespective of the approach that is adopted to reassess reporting 4
i requirements, the staff will need to document the rationale for the j'
conclusions it reaches.
This will help ensure that safety objectives are j
adequrtely addressed and that consistent decisions are made.
Therefore, a j
User Need Statement was prepared for use in documenting the justification for reporting requirements and recommendations for change.
The utility of the User Need Statement was affirmed by having the task force members apply it to
]
a test group of 11' reporting requirements.
The User Need Statements were then i
j
i 4
1 The Commissioners !
l sent to the appropriate line organizations for further development.
If the views of the task force differed from those expressed by the responsible line 4
i organization, the task force discussed them with the line organization, and the User Need Statement was revised to reflect a staff concensus.
The User Need Statement is considered to be an effective tool for use by the staff to document, in a consistent manner, the rationale for retaining reporting requirements or recommending changes, including the deletion of i
reporting requirements. However, in applying the User Need Statement to the test group, the task force noted that there were various interpretations of j
the infonsation requests. As a result, the User Need Statement was revised to enhance its usability; the revised form is provided in Enclosure 4.
I The reporting requirements comprisin
-(1) they came from several sources (g the test group were selected because namely, the regulations, the technical specificatluns, and Section XI of the ASME Code, which is incorporated by reference into 10 CFR Part 50); (2) ' hey were addressed by the Nuclear Management and Resources Council (NUMARC) in their response to the June 19, 1992 Federal Reaister notice; (3) they involve several NRC line organizations; (4) a spectrum of recommendations concerning the disposition of the reporting requirements would likely result; and (5) they would give an indication of the level of effort needed to prepare User Need Statements for other reporting requirements.
The results of the task force review of the test group of reporting requirements are presented in Enclosure 3.
The line organizations or the task force recommended that four of the reporting requirements be eliminated (Items 1, 4, 5, and 7 in Table 1 of Enclosure 3), that five of the reporting requirements be revised or further explained to reduce their scope (Items 2, 8, 9, 10 and 11), and that two of the reporting requirements be retained as currently stated (Items 3 and 6).
Several insights were gained from the evaluation of the 11 test case reporting requirements that will be factored into the follow-on effort addressed in this paper to reduce regulatory burden; for example:
1.
The line organizations are best qualified to prepare the justification for the retention, elimination, or revision of reporting requirements; they can provide a safety perspective that is essential to sound decisionmaking.
2.
There is frequently more than one organization using the information being reported, and it is not always obvious which line organization should be asked to exercise control over the destiny of a reporting requirement.
Therefore, the use of a short term task group to assign organizational ownership for each reporting requirement is desirable.
3.
The NRC should investigate the application of electronic transmission techniques for data, reports, and test results as part of its strategic information technology planning process.
s
i The Commissioners 5-i Following is a discussion of the approach and schedule for continuing the-effort to assess reporting requirements for power reactor licensees which the industry and the NRC staff identified for possible deletion or revision.
The i
line organizations will be required to allocate resources to conduct detailed
}
reviews of the reporting requirements within their purview and proceed with 4
rulemaking or other appropriate licensing actions (e.g., generic letters for
.line item improvements to the Standard Technical Specifications that pertain to reporting requirements) to reduce reporting burdens.
1 No oversight group will be associated with this approach, although an initial effort by a small task group will be necessary to (a) compile _ the reporting 1
requirements identified by the Regulatory Review Group and the respondents to l
the aforementioned Federal Reaf ster notices as being unduly burdensome, I
duplicative, or otherwise unnecessary and in need of revision, (b) assign office / division ownership to the reporting requirements contained in the regulations, the Technical Specifications, generic communications, plant l
operating licenses and licensee controlled documents, and (c) prioritize 3
office / division assignments and propose interim milestones for assignments that are compatible with the overall schedule (discussed below) to permit 4
periodic assessments of progress.
The overall schedule for the effort will be in keeping with the implementation 4
i plan for the Regulatory Review Group recommendations.
The line organizations j
will complete the assessment of the body of reporting requirements identified
)
in the public comments and in the Regulatory Review Group implementation plan (SECY-94-003) by December 1995.
The Office of Nuclear Regulatory Research i
(RES) will prepare draft rule changes for presentation to the Commission prior to the end of June 1996, and will publish final versions prior to the end of December 1996. The line organizations will undertake other appropriate j
licensing actions to address changes in the reporting requirements that do not involve rule changes prior to the end of December 1996.
In parallel with the effort to continue the review of NRC reporting requirements to eliminate duplicate requirements and information/ data requirements without a clear nexus to safety, NRC staff will take the following actions based on the recommendations of the Regulatory Review Group and the Reporting Requirements Task Force:
The Office of Nuclear Regulatory Research (RES) will be requested to initiate rulemaking to address the following matters:
1.
Eliminate 10 CFR 73.71(c)(2), which requires the quarterly submittal of safeguards event logs.
2.
Revise 10 CFR 55.25 to eliminate the notification.of operator incapacity due to a disability or illness and refer to a similar reporting requirement under 10 CFR 50.74(c) for this requirement.
m
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n o
a
/
The Commissioners i i
3.
Revise 10 CFR 50, Appendix J to eliminate the requirement to submit the summary technical reports of preoperational and periodic leakage i
rate tests; rather, require the reports to be made available at the plant sites for NRC review.
The proposed schedule'for accomplishing the above rulemaking actions is compatible with the plan for ispirmenting the RRG recommendations (SECY-i 94-003), namely, the staff will provide draft rule changes to the
{
Commission prior to the end of September 1994 and will publish final j
rule changes prior to the end of February 1995.
t Since the ASME Code is endorsed by NRC regulations (see 10 CFR 50.55a),
the NRC will take a proactive role through its representatives on the ASME Code committee to modify code reporting requirements to reduce l
licensee burden; in particular, the NRC will propose to eliminate the need to submit inservice inspection (ISI) reports to the NRC following i
each refueling outage (ASME Code Section XI, Article IWA-6000).
RES will be requested to revise the monthly operating report (Regulatory Guide 1.16), which plant Technical Specifications require licensees to
)
i submit, to eliminate currently reportable information that is not essential to the Performance Indicator Program or that may be e.ulable i
from another source.
J The proposed schedule for accomplishing this will be in keeping with the implementation plan in SECY-94-003; the staff will publish a draft of the revised regulatory guide prior to the end of June 1994, and the final ' regulatory guide will be published prior to the end of January 1995.
This review of the reporting requirements for power reactor licer. sees is in keeping with the expectations of the industry, as expressed in the letters received in response to Federal Reaister notices.
These letters contain a e
recurring theme, namely, that while the nuclear power industry can provide its views on the impact of certain reporting requirements, it is up to the NRC to i
properly identify the information that is required to fulfill its obligation
.to protect the health and safety of the public and to propose appropriate changes.
Therefore, the expectation of the industry is that the NRC will j
continue to conduct reviews of its reporting requirements and evaluate the need for prescribed reports and the information they contain.
C0 ORDINATION:
The Office of General Counsel has reviewed this paper and has no legal objections.
RECOMMENDATIONS:
That the Commission ngig that, absent other directions after 10 working days:
- ~.
The Commissioners 1.
The line organizations will proceed to assess the reporting requirements for power reactor licensees which th: industry and the NRC staff have identified for possible deletion or revision, and to initiate proposed rulemaking or other appropriate regulatory actions on a schedule that is compatible with SECY-94-003 recommendations for Topic Area No. 59.
2.
RES will be requested to initiate a combined rulemaking, and cognizant line organizations will initiate appropriate generic comunications based on the initial recommendations of the Regulatory Review Group and the Reporting Requirements Task Force.
3.
NRC staff will investigate the efficacy of applying electronic transmission techniques for data, reports, and test results.
This will be done in conjunction with the development of the information technology plan for the agency.
/
Y T JglD M. T or Edecutive irector for Operations i
Enclosures:
1.
Respondents to Federal Reaister Notice Solicitation for Public Comment j
2.
Task Force to Review Reporting Requirements j
for Power Reactor Licensees 3.
Test Group of Reporting Requirements Selected for Evaluation 4.
User Need Statement for NRC Power Reactor Reporting Requirenients SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Monday, April 18, 1994, that the Commission, by negative consent, assents to the action proposed in this paper.
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DISTRIBUTION:
I Commissioners OGC OCAA OIG OPA OCA OPP REGIONAL OFFICES EDO ACRS SECY
TEST GROUP 0F REPORTING REQUIRENENTS SELECTED FOR EVALUATION I.
ASME Code Inservice Inspection sunnary report, required by IWA-6220 to be submitted within 90 days of the i
completion of each refueling outage (DE/NRR) 2.
Annual reports of facility changes, tests, and experiments (recently changed to refueling j
basis) (ADPR/NAR)
{
l 3.
Notification within two working days of information having significant implication for public health and safety or common defense and security (FCSS/ MSS)
J 4.
Quarterly safeguards event log entries report (DRSS/NRA and FCSS/ MSS) 5.
10 CFR 50.74 Notification of change of operator status due to i
transfer, termination or disability (DRCH/NRR) 6.
10 CFR 50, Appendix I, Report on higher than normal release ratesSection IV.A.3 (DRSS/N.iR) 7.
10 CFR 50, Appendix J, Containment Integrated Leak Rate Test summary Section V.B technical report (DSSA/NRR) 8.
TS 4.4.5.5(a)
Summary report of SG tubes plugged (DE/NRR)
TS 4.4.5.5(b)
Results of SG tube inservice inspection
]
(DE/NRR)
TS 4.4.5.5(c)
Special Report of SG tube inspection results that fall in Category C-3 (DE/NRR) l TS 4.4.5.5(d)
Results of SG tube inspection for which alternate tube plugging criteria were used (DE/NRR) 9.
TS 6.9.1.3 Cycle Startup Report (DSSA/NRR) j 10.
TS 6.9.1.4 Annual Operating Report (DRSS/NRR) 11.
TS 6.9.1.8 Monthly Operating Report (including refueling i
data and PORV/ safety valve challenges)
(DSP/AE00) 4 ENCLOSURE 3
i 4
TEST CASE 11 USER NEED STATEMENT FOR NRC POWER REACTOR REPORTING REQUIREMENTS 1.
Identification / Statement of reporting requirement TS 6.9.1.5 - Monthly Operating Reports (NOR)
The licensee NOR contains operating statistics with data listed for the month being reported, the year-to-date and cumulative.
It also includes details of unit outages and power reductions, as well as other i
information such as planned outages and changes in unit capacity and restrictions limiting power generation.
2.
Type of report a.
Routine report (Operating statistics and outage description for nuclear power plants)
(i)
Frequency (monthly)
J (ii)
Timeliness of submittal (By the 15th of the month following the month of operation)
)
3.
Purpose The original impetus for the monthly operating report came as a result of the Arab 011 Embargo of 1973-74.
Prior to that time the licensees were asked to provide some of the kinds of information requested in the monthly report, but it was reported typically on a 6 month basis.
The information previously requested also was not so detailed and without the specificity of the MOR requirements.
For example, the licensee was asked to provide a system and component code for each outage that corresponded to the Licensee Event Report codes.
The safety objective for the MOR was not clearly stated, but it was felt that analysis of the data would allow the agency to identify common problems or trends.
NRC publication of the data received from licensees and from the regional offices was made on a monthly basis in a document that was referred to as the Gray Book (USNRC, NUREG-0020, " Licensed Operating Reactors: Status Summary Report").
It rapidly became an authoritative source on the performance of nuclear power plants.
Computerization of the data allowed searches that enabled the NRC staff to obtain information on which systems and components were tevolved in causing automatic scrams and what corrective actions were taken.
Other uses included attempting to analyze what factors impacted on plant performance.
The data was also used by members of the nuclear industry and other interested parties.
Other objectives included being able to compare nuclear plant performance with fossil plant performance utilizing the same definitions of capacity factor and forced outage rate, etc.
4
.~
i t
The current purpose is similar to the origiaal purpose, but there are i
alternate sources for some of the information, such as 10 CFR 50.72 and j
50.73 reports for scrams and information on the systems and components involved in scrams.
However, the bulk of the information included in i
the NOR is not duplicated in other reports required by the NRC.
4.
Organizations receiving the report l
NRR, AE00, Regions, ACRS, PDR and LPDRs, and IRM receive the report L
(RIDS distribution code: IE240).
NRC contractors such as INEL (EGAG) and Oak Ridge get the NORs as well as monthly diskettes including MOR data for all units.
These diskettes have been issued by IRM covering data since January I,1990.
Other NRC organizations get just the monthly diskettes.
The data is also entered into major NRC databases such as. the Shared Information Network (SINET) and EXSIS on a monthly basis.
5.
Organizations using the reports NRR/ Project Managers use the MORs for general information.
IRM uses the monthly reports to provide information to a variety of IRM has INEL prtparing monthly diskettes and one annual report.
users.
The diskettes are distributed to many NRC offices and are also sent to licensees.
t Other non-NRC users can.obtain a subscription for the diskettes from the Government Printing Office.
IRM also makes the HORS available to DOE for use in the Waste Fund program.
As. indicated t
earlier, the data is also entered into SINET and EXSIS.
In response to a Commission directive to develop the Performance.
Indicator (PI) program, AEOD uses data that is reported solely in the licensee MORs to develop PIs.
The data is needed to develop these meaningful and consistent measures of plant performance and their inherent safety relationships.
I 6.
Plant specific / generic actions taken upon receiving the report IRM does not issue any of the subject actions.
AE00 has not taken any i
plant specific or generic actions directly upon receiving the report.
7.
Identify routine analyses / staff reports generated based on the report received IRM issues the compilation of MORs on diskette and publishes the December data in hard copy because it contains calendar year data.
NRR/ Projects may use the MOR information directly for performance evaluation (Senior Management Meeting discussion, SALP preparation;, but the information is usually obtained indirectly through the P1 Reports.
AE0D uses data that is reported solely in the MORs to develop Pls.
Of the present eight Pls, two depend on the data reported in the MORs.
This data includes the number of reactor critical hours for the e
- ~. _ _ _
- l 4
I equiprent forced outage indicator; the forced outage hours for the equipment forccd outage and forced outage rate indicators; and the outage type, whether forced or scheduled, for the forced outage rate and equipment forced outage indicators.
Presently, these indicators are published formally once every quarter as the PI report (USNRC, Office for Analysis and Evaluation of Operational Data, " Performance Indicators for Operating Commercial Nuclear Power Reactors").
8.
Resources (staff hours / contract dollars) expended per report NRR/ Projects expends about one hour per report.
l IRM contractors spend about $60,000 a year maintaining a database and i
issuing diskettes.
IRM enters the data into SINET and EXSIS utilizing i
about 0.1 FTE.
9.
Identify similar/related reporting requirements While 10 CFR Part 50.72 and 50.73 are similar for the items discussed under section 3 above, the bulk of the information included in the MOR l
is not duplicated in other reports required by the NRC.
l 10.
Discuss the potential reduction in public health and safety that would result if the reporting requirement was eliminated.
f Part of the NRC's mission is to provide information to the public about the performance of nuclear power plants.
The MORs, the diskettes, and printed reports meet part of that mission.
1 l
Elimination of the requirement to provide the data in MORs would l
eliminate two of the present eight Pls that were approved by the i
Commission.
This would eliminate two meaningful and consistent measures
)
of plant performance and their inherent safety relationships.
Elimination of the MOR requirement would therefore require the consent of the Commission.
I 11.
Discuss and justify proposed modifications to the reporting requirement that could reduce impact while at the same time continue to meet the i
safety objective; note differing views of other users; conversely justify retaining the reporting requirement, without modification Since IRM is not really a user of the NOR data no proposals on i
modifications are made.
IRM feels that the public information aspect of the MOR justifies its retention.
I Performance Indicator data is one of the fundamental tools used on a i
l continuing basis by AE00 in our independent analysis of nuclear power i
plant safety performance trends.
The results of such analyses are j
necessary for our support of various NRC tasks, such as input to the semi-annual Senior Management Meeting plant selection process.
I w.
Presently, PIs are published formally once every quarter, thus making it appear that the data is needed only quarterly. Therefore, it may appear that the operating report frequency could be changed from monthly to quarterly.
However, this is not the case.
PIs are constantly updated to reflect the latest performance trends.
Thus, decreasing the frequency of reporting to quarterly would greatly hinder the fulfillment of our mission, since the most current data used in developing our concerns may be as much as 6 months old.
Additionally, modifications to the analysis methods used in determining the Pls are being considered by the Commisston for adoptton (see SECY-92-425).
These modifications change the analysis from a quarterly-based system to one that is based on actual operating cycles. Accurate and continuous monthly updates of plant operational data are critical for the success of these enhanced Pls.
j I2.
NRC resource or cost savings based on modifying the requirement A modest reduction in contractor resources would result if reporting frequency was changed from monthly to quarterly, and a further reduction would result if the data was electronically submitted.
Data quality j
assurance checks and reviews would remain at about the same level.
AE00 is working with IRN to eliminate delays in receiving reports by making electronic data interchange the preferred method of submittal.
13.
Management recommendations IRM recommends not changing reporting frequency since that would limit the usefulness of the information to many users and would not result in a significant resource or cost saving.
AEOD also recommends not changing the reporting frequency for licensee
{
MORs since a reduced frequency would limit the usefulness of the information to AE00 and would not result in a significant resource or cost saving.
AE00 continues to need the reactor critical hours and outage data in the NOR in its present form and frequency.
Because of our reliance on and requirement for accurate monthly operating history information, we strongly recommend not changing the frequency of the MORs to quarterly.
In fact, our need for this information is so critical that we are experiencing difficulties in timely analysis due to the inherent slowness in the present reporting method.
By the time the licensee reports are received through the mail by us and are available in database format, nearly 2 months have passed.
We are working with Information Resource Management (IRM) to eliminate much of this delay by making electronic data interchange (EDI) of this information the preferred method of submittal.
Date:
/
Division Director Division / Office:
OSP/AE00
I ADDITIONAL TAEK FORCE COP #iENTS The task force to review the reporting requirements for power reactor licensees has the following additional comments to make concerning the recommendations of the line organization that prepared the User Need Statement for the subject reporting requirement:
SUBJECT:
Technical Specification 6.9.1.5 - Monthly Operating Reports ORGANIZATION:
Division of Safety Programs, AE00 1.
The Division of Safety Programs (DSP) notes in the User Need Statement that information reported in the Monthly Operating Reports (NORs) is used to develop 2 of the 8 Performance Indicators for commercial nuclear power reactors.
DSP further notes that this information is currently only available through the MORs. As a result, the task force agrees that the NORs should be retained.
However, since no safety argument has been presented to justify continuing to receive and compile all of the information now provided, the information reported in the MORs should be reduced to that which is needed to support the Performance Indicator program.
This could be implemented by a line-item improvement to the new Standard Technical Specifications and a generic letter, allowing licensees to adopt the technical specification change through the license amendment process.
l I
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ACTION - Russell, NRR
/
UNITED STATES Cys:
Taylor
'o NUCLEAR REGULATORY COMMISSION Milhoan
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I wAsuncrow,oc asses P50"
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Beckjord, RES Bernero, NMSS ones or rus Jordan, AE00 sacarrany April 26, 1994 BGrimes, NRR JShapaker, NRRp 4
i.
MEMORANDUM TO:
James M. Taylor Executi Dir ctor for Operations FRON:
John C o
, Assistant Secretary
SUBJECT:
SECY 4-093 - NRC STAFF ASSESSMENT OF REPORTING REQUIREMENTS FOR POWER REACTOR LICENSEES This is to advise you that the Commission has not objected to:
I 1) the staff proceeding to assess the reporting requirements for power reactor licensees and initiating rulemaking or other appropriate actions consistent with the recommendations in SECY-94-003, 2) initiation of a combined rulemaking and appropriate generic communications based on the recommendations of the Regulatory Review Group and the Reporting Requirements Task Force, and 3) the staff plans to investigate the efficacy of applying electronic transmission techniques for data, reports, and test results in conjunction with the development of j
the information technology plan for the agency.
The staff should remain aware that there is more to be considered than the burden on licensees and the NRC's need to have the information in deciding to eliminate a reporting requirement.
Each time the NRC decides that a report no longer must be submitted, it reduces the amount of information to which the public has access.
This is particularly important if it is decided that the licensee must have the information available fck review on-site, but is no longer required to submit the information.
SECY NOTE:
THIS SRM AND SECY-94-093 WILL BE MADE PUBLICLY AVAILABLE 10 WORKING DAYS FROM THE DATE OF THIS SRM 4
ATTACHENT 7
o, The staff should consider the public's need for the information in assessing the body of reporting requirements.
In cases where the staff concludes that the reporting requirements being eliminated will significantly affect the ability of the public to participate in the regulatory process, the staff should provide the results of their assessment and their recommendations to the Commission prior to initiating action to eliminate any reporting requirements.
cc:
The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque OGC OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail) i
/pa asog'o,,
t, POLICY ISSUE (Information) 1
]
January 7, 1994 SECY-94-003 fQB:
The Commissioners E806:
James M. Taylor Executive Girector for Operations
SUBJECT:
PLAN FOR IMPLEMENTING REGULATORY REVIEW GROUP RECOMMENDATIONS PURPOSE:
To submit the staff's implementation plan for the Regulatory Review Group recommer.dations described in the final report.
BACKGROUND:
On January 4, 1993, the Executive Director for Operations established the Regulatory Review Group (RRG).
The RRG conducted a disciplined review of power reactor regulations and related procest.es, programs, and practices, placing special attention on the potential for using performance-based requirements and guidance in place of prescriptive requirements and guidance.
The RRG reviewed the regulations of 10 CFR Part 50 affecting operating reactors, the contents of four power reactor licenses, regulatory guidance supporting selected technical areas, public comments related to the Marginal-to-Safety Program, the 1992 review by the Committee to Review Generic Requirements, and recent, related industry correspondence.
In August 1993, the RRG issued its final report containing recommendations aimed at reducing the regulatory burden on power reactor licensees and strengthening NRC administrative practices.
The RRG report discussed several key areas in which changes in the way NRC conducts business could CONTACT:
NOTE:
TO BE MADE PUBLICLY AVAILABLE Roy Zinumerman, EDO IN 10 WORKING DAYS FROM THE 504-2969 DATE OF THIS PAPER l
ATTACHMENT 5 gg73
The Commissioners i i
significantly reduce industry and NRC staff costs without adversely affecting the level of safety at operating plants.
For example, the RRG suggested using more performance-based and risk-based approaches in such areas as quality assurance, security, fire protection, and inservice inspection and testing.
Additionally, the RRG examined agency administrative practices and proposed possible efficiencies in the areas of commitment management, reporting requirements, and relemaking practices.
DISCUSSION:
The staff has prepared an implementation plan for the RRG recommendations.
This plan (see Enclosure 1) contains general implementation strategies, priorities, major milestones and target schedules for the timely resolution of each RRG recommendation.
The activities associated with the development of the implementation plan resulted in some instances in which the planned actions differ from those recommended by the RRG. In each of these cases, the merits of the RRG recommendation were carefully considered.
In completing the RRG effort and preparing the implementation plan, the staff identified several key areas in which substantive burden could be reduced for licensees, staff, or both, without adversely impacting safety at currently operating plants. These areas include: enhancing and expanding the uses of probabilistic risk assessments to improve the regulation of operating reactors, revising existing quality assurance program guidance to encourage a more graded approach, and revising existing prescriptive regulations in security and fire protection to be more performance-based.
Staff and industry initiatives in these and other burden-reducing areas (such as cost-beneficial licensing actions, developing a risk-based approach to inservice inspection and testing, and rulemaking considerations in the security, fitness-for-duty, I
and containment testing areas) are under way and can lead to significant improvements in our regulation of the nuclear industry without adversely affecting plant safety.
The staff constructed the implementation plan by dividing the RRG recommendations into specific topic areas such as quality assurance and security.
Each topic area of the implementation plan contains:
(1) the specific issues (the numbers beneath each issue correspond to the appropriate sections in the RRG report), (2) the RRG recommendations for each issue, (3) an action plan for implementing individual RRil recomineiidatT6ns~,7 the priorTty assigned by the task ~ group', ^oised_primarily 'on burden re u)~ction, (5 i
the lead office for the resolution of each RRG recommendation, and (6) the tarSHed. complition dates for each item, recognizing that the staff is still reviewing integrated resource loading.
l Although not specifically stated in the action plan, completion of a number of the items will necessitate training of headquarters and regional staff, and will require ongoing dialogue with industry in order to achieve a smooth transition from action plan to actual practice.
i
=
The Commissioners The NRC ' Principles of Good Regulation" are the foundation for many of the specific recommendations of the RRG and the enclosed implementation plan.
The plan, including the completion schedule, has been endorsed by the regional administrators and appropriate office direuors.
The staff is implementing the agreed upon actions.
I intend to monitor the steady progress toward completion of the implementation plan by receiving periodic updates from the office directors and will act to ensure that the action plan is implemented.
/
s M. Ta r, Executive Director or Operations
Enclosure:
RRG Implementation Plan l
DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA OPP REGIONAL OFFICES EDO ACRS ASLBP SECY
~..
t l
TOPIC-ISSUE
- RRG REC 0fMENDATION ACTION PLAN?
PRI-LEM :
TMGET AREA 0FFICE SCHED'AE Allow line item Penmit lisuHeems improvemunes in Policy Sa=aa==* on Teciumed NA COMPRETE improveensees for accordance with the TM Specifications dated 7/22/93 sensed limproved Standard Specificassoas insprovesment pohey for line itese improvensmen would be Techascal all individual licensees in adentsam ao accepted by NRC Specifications lead plant liceneses 3.3.4j i
f
.. mm REronTING Delete m I=======d="a= to delete Pohey Seneermet on aaeh=e=I REQUIRE
- NA NA COMFIETE reportgag reportag requirennets for ryorts lhet specificatsers allows line items rapnireussets are "not requned* in the new improvemusas (see itsen # 56)
Standard Tech-e=1 Specifications 2.3.16e IMahamid be acted upon by she staff i
I 2.3.18 I
Revise Pg '- =y Revise Pg
- M-j Gunde 1.16,
- 1. Revise and publie dran 2
RES 6/94 Gede 1.16
==ahly operating report, to ehmaanes regulatory guide 1.16 to reduce W 85 porting rapartenues scope of smostl@ operatana report 2.3.15c accordagly (see seemt # 59) 2.3.16
' JS
- 2. Pubhsh final regulatory guide I/95
/
Evaluate need or
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llie KR O., G W a amajor
- 1. Provide draR rule changes to the 2
RES 9/94 frequency for all sanff effort so review all *=ch===8
/
('a====== an items decided by reporteg specificateca reportug requeusemes RRG. and P, _=Q P,
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- 2. Puldish final rule changes to 2/95 i
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- 3. Assoas additional reporting NRR 12/95 standards Lequ'r=="a=_ identified in pubhc consumes so desarmine wh=st-ihey
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- 5. Pubhsh final rule dr ges 12/96
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i 15
t Revision 4 U.S. NUCLEAR REGULATORY COMMISSION Auguet 1975 REGULATORYGUIDE l
OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 1.16 a
REPORTING OF OPERATING INFORMATION-APPENDIX A i
TECHNICAL SPECIFICATIONS l
A. INTRODUCTION of Reporting Requirements sSub to NRC Regulations," and is not pre i
Section 50.36.
- Technical Specifications," of 10 CFR Part 50, " Licensing of Production and Utilization s.
Facilities," requires that each applicant for a license authorizing operation of a nuclear power plant include lii Septem oenic Energy Commis-in its apphcation proposed technical specifications.
sion' Re ed Revision 2 of Regula-These technical specifications, as issued by the NRC, are tory Gui sion reflected results of a. staff i
i incorporated into the facility bcense and are conduions revie f
information needed to permit 1
of the beense. Technical specifications are now included assess y
ommission of safety related activities I
as two appendices to the beense: Appendix A technical ra ing phase of plant life. Significant specifications relate to health and safety, and Appendix tsson 2 were:
B technical specifications relate to environmental im-porting requirements were updated to reflect pact.8 Each of these appendices includes a section in reports required by Appendix A technical reporting requirements. The reporting program descri e cations. In general, these changes involved:
in this regulatory guide involves the reporti u
a.
a change in frequency of submittal of j
ments of Arpendtx A technical specificatio outine operating reports; j
some cases, Ns program may r.ced to be su emen b.
elimination of the first year operating or modified because of unique plant design r
report; j
other factors. The need for a supplemental or ed c.
formalization of reporting of operating j
program Mll be determined on a case by. case basis.
information on a monthly frequency; Reporting of informati ceming radioactive d.
deletion of certain items ofinformation r.o discharges, radiological en monitonng, and longer required to be submitted on a routine basis; g
l nonra&ological environ t
e urke and environ-e.
changes in the format and imracciacy of
}
rnental trnpact is latory Guide 4.8 reporting required for certain types of ab.tormal occur-
- Environmental Te ical e cations for Nuclear rences (now called reportable occurrences);and Power Plants."
f.
improved guidance concerning deftnitions Irt additi ng requirements necessary and categories of significance of abnormal occurrences, for compliance i technical specifications, specific re-
?.
s.ppendices were added to provide the desired porting require are included in Part 50, as well as fonaat for radiation exposure reports and monthly in other Parts of tle 10, Chapter I, Code of Federal operating reoorts Regulations. A cornpilation of all reporting requirernents 3.
A hating of reports other than those required appbcable to the various types of NRC licensees,includ-by Appendix A technical specifications was elimmated.
ang identification of the proper NRC addressee or ad (See introduction above.)
dressees and designation of the number of copier requir-2 ed,is included in Regulatory Guide 10.1. Compilation ne Atomic Energy Commnuon was aboluhed by the Energy 2
Reorgannation Act of 1974, whkh also created the Nuclear aA few facihtses have a angle appendix that contams the Regulatory Commason and save it the lacensing and rotated cornbined sapect of Appendices A and B.
regulatory functions of the AEC.
4 USNRC REGULATORY GUIDES C.'".*..~,'c..8***~'**S".'~.c".'.".C****.'**W8"".'".".
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ATTACHMENT 3
Comments were invited within 60 days of publica-1.
Routine Repoets tion of Revision 2 for use in con.lunction with early revision of the guide. As a result of comments received a.
Startup Repoet on the guide and additional staff review, the staff developed Revision 3. Significant changes in Revision 3 A summary report of plant startup and power v re:
escalation testing should be submitted following (1) 1.
The startup report was revised to be more receipt of an operating license, (2) amendment to the specific as to the test results to be reported.
License involving a planned increase in power level, (3) 2.
The annua! report section was revised to (1) installation of fuel that has a different design or has been further quantify the term " reduction in power," (2) manufactured by a different fuel supplier, and (4) provide further guidance on reporting of occupational modifications that may have significantly altered the radiation exposures, and (3) revise the information to be nuclear, thermal, or hydraulic performance of the plant.
submitted on fuel performance.
The report should addren each of the tests identified in 3.
The abnormal occurrence report section was the FSAR and should in generalinclude a description of revised to (1) provide for prompt notification by the measured valaes of the operating conditions or telephone and confirmation of such notification by characteristics obtained during the test program and a telegraph, mai! gram, or facsimile transtmssion of the comparison of these values with design predictions and types of abnormal occurrences listed under Section 2.a, specifications. Any corrective actions that were required (2) be more specific on the types of abnormal occur.
to obtain satisfactory operation should also be de.
rences reported, (3) delete radiological effluent releases scribed. Additional specific details may be fx!uded in from Appendix A technical specification reporting license conditions based on the applicant's commitment requirements, (4) provide for reporting of the types of to applicsble regulatory guides and should be included in abnormal occurrences listed under Section 2.b within 30 this report.
days of occurrence of the event, and (5) make Section Startup reports should be submitted within (1) 2.c of Revision 2 of the guide a separate section (Section 90 days following completion of the startup test 4).
program, (2) 90 days following resumption or com.
In previous revisions of Regulatory Guide 1.16,the mencement of commercial power operation, or (3) 9 o
term " abnormal occurrence" was used to designate any months following initial criticality, whichever is earliest, unscheduled or unanticipated operational event reported if the Startup Report does not cover all three events to the Commission. Included in these reported events (i.e., initial criticality, completion of startup test pro.
were (1) events that could or did have significance from gram, and resumption or commencement of commercial the standpoint of public health or safety and (2) events power operation), supplementary reports should be reported to NRC for performance evaluation and trend submitted at least every three months until all three determinations. In Section 208 of the Energy Reorgani.
events have been completed.
zation Act of 1974 (Pub. L 93 438), an " abnormal occurrence"is dermed for the purposes of the reporting b.
Annual Operating Repoet 8 requirements of the Act as an unscheduled incident or event which the Commission determines is significam Routine operating reports covering the opera.
from the standpoint of public health or safety. In order tion of the unit during the previous calendar year should to be consistent with this definition, the events desig.
be submitted prior to March I of each year. The initial nated in previous revisions of this guide as " abnormal report should be submitted prior to March I of the year occurrences" are designated " reportable occurrences" following initial criticality.
in Revision 4. Any " reportable occurrences" that are The primary purpose of annual operstmg reports determined by the Commission to be significant from the isto permit annualevaluationby the NRC staff of operat.
standpoint of pubbc health or safety will be further ing and maintenar.ce experience throughout the nuclear designated " abnormal occurrences."
power industry. Tlw annual operating reports niade by licensees should provide a comprehensive summsry of
- I E
C. REGULATORY POSITION though some repetition of previously reported informa.
In addition to the applicable reporting requirements tion may be involved. References in the annus) operating of Title 10, Code of Federal Regulations, the following report to previously submitted ieports should be clear.
Each annual operating :eport should melude:
1 program for reporting of operatinginformation provides (1) A narrative summary of operaiing experi.
an acceptable basis to the NRC staff for meeting the ence during the report period relating to safe operation reporting requirements of Appendix A techmcal specifi.
of the facility, indudmg safety.related maintenance not cations. Reports submitted in accordance with this guide covered in item 1.b.(2)(c) belaw.
should be addiesaed to the Director of the appropnate NRC Regional Office unless otherwise noted.
3A sms:e subnuttal may be rnade for a multiple unit station.The subrmstal should combnie those sections that are comtr.oa to
- tines indicate substanuve changa from prenous issue.
all units at the ststion.
1.16 2
(Q '
(2) For each outap or forced reduction in tests, ultrasonic tests, or visual examinations completed power
- of over 20 percent of design power level where during the report period.
the reduction extends for more than four hours:
(a) the proximate cause and the system /
c.
MostWy Operating Report and major component inwived (if the outage or forced reduction in power involved equipment malfunction);
Routine reports of operating statistics and (b) a brief discusion of (or teference to shutdown experience should be subrnitted on a monthly reports of) any reportable occurrences pertaining to the basis. The report fon.'ats set forth in Appendices B, C, outage or power reduction; and D to this guide should be completed in accordana (c) corrective action taken to reduce the with the instructions provided. 'Ihe completed forms probability of recurrence,1(appropriate; should be submitted by the tenth of the month (d) operating time lost as a restJt of the following the calendar month covered by the report to outap or power reduction (for scheduled or forced out-the Director, Office of Manapment Information and ages,s use the generator-off.line hours; for forced re-Program Control, U.S. Nuclear Regulatory Commission, ductions in power, use the approx 1rnate duration of op-Ms%ngton, D.C. 20555, with a copy to the appropriate cration at reduced power);
NRC Regional Office.
(e) a description of major safety-related corrective maintenance performed dunng the outage or 2.
ReponsWe Occumaces power reduction, including the system and component involved and identification of the entical path activity CuidanC8 C "Cerning reportable occurrences that dictating the length of the outage or power reduction; should be reported in different time frames is provided and (0 -s report of any single release of radio-below. Supplemental reports may be required to fuuy desenbe final resolution of the occurrence. In cases of lsted with the outage which accounts for more than 10 activity or single radiation exposure specificaUy associ.
c nected or supplemental reports, a licensee event percent of the aUowable annual values.
report should be completed and reference should be (3) A tabulation on an annual basis of the inade to the onginal report date.
' [N number of station, utility, and other personnel (in-(
ciuding contractors) receiving exposures greater than a.
Prompt Notification With Written Fogowup.
100 mrem /yr and their associated man. rem exposure according to work and job functions,* e g., reactor The types of events listed below should be operations and surveillance, inservice inspection, routme reported as expeditiously as possible, but within 24 maintenance, special maintenance (desenbe mamte.
hours by telephone and confirmed by telegraph, mail.
nance), waste processing, and refuelmg. The dose assign.
gram, or facsimile transmission to the Director of the ments to vanous duty functions may be estimates based appmpriate NRC Regional Office, or his designee, no on pocket dosimeter,TI.D,or film badge measurements.
later than the first working day following the event, with Small exposures totalling less than 20 percent of the a wntten followup report within two weeks. A copy of individual total dose need not be accounted for. In the the confirmation and the written followup report shot 'd aggregate, at least 80 percent of the total whole body also be sent to the Director Office of Management dose received from external sources should be assigned Information and Program Control, USNRC. The wntten to specific major work functions. See Appendix A to follom2p report should include, as a minimum, a this guide for a standard format for providing this completed copy of the licensee event report form (see information.
Appendix E to this guide) used for entering data into the (4) Indications of failed fuel resulting from NRC's computer. based file of information concerning irradiated fuel exammations, including eddy current licensee events. (Instructions for completing these licensee event report forms 7 are issued individually to each licensee.) Information provided on the licensee "The term " forced reduction m power" as uved in this guide and event report form should be supplemented, as needed, as normally defined in the electne power industry means the occunence of a component failure or other condition that by additional narrative material to provide complete
- requses thet the load on the urut be reduced for cornetsve explanation of the circumstances surrounding the event, action anunedannely or up to and includmg the very next (1) Failure of the reactor protection system or
" j*[','*nd actEtEs l
other systems subject to limiting safety system settings requ to initiate the required protective function by the time a reductions are not covered by this sectaon.
'The term " forced outage" as used in this guide and as normally monitored parameter teaches the setpoint specified as def'ined in the electne power industry means the occurrence of the limiting safety-system setting in the technical specifi.
a component failure or other condition that requires that the unit be removed from service for conectrve action immedutely or up to and includans the very next weekend.
finstruction Manual, Licensee Event Report File. Omce of
- nis tabuintion sapplements the requirements of 6 20.407 of Management Information and Program Control, U.S. Nuclear b
10 CFR Part 20 Resulatory Comnussion, Washington, D.C. 20555.
1.16-3
cations or failure to complete the required protectiw (4) Reactivity anomahes involving diangreement function. De foGowing are examples:'
with the predicted value of reactivity balanz under (a) Reactor pressure exceeds limiting steady 4 tate conditbns during power operation greater safety 4ystern setting value without automatic pip.
than or equal to 1% Ak/k; a calculated reactivity balance *
(b) Inability to trip and insert suffident indicating a shutdown mars a less conservatiw than control rods to achiew the technical specification shut.
specified in the technical specifications; short term react-down margin.
Ivity increases that correspond to a reactor period ofless (c) FaGure of the reactor proteedve system than 5 seconds or, if suberitical, an unplanned reactivity to complete the required protective action once initi.
insertion of more than 0.5% Ak/k;or occurrence of any ated.
unplaaned criticality.
(5) FaGure or malfunction of one or rnore com.
Note: Instrument drift discowred as a result of testing Ponents which prevents or could prevent, by itself, the need not be reported under this item but may be report.
fulfillment of the functional requirements of system (s) able under items 2.a(5),2.a(6), or 2.b(1) below.
used to cope with accidents analyzed in the SAR.The following are examples:
(2) Operation of the unit or affected systems (a) Clogged fuel line(s) resulting in failure when any parameter or operation subject to a limiting to supply fuel to the emergency ymerators.
condition for operation is less conservatiw than the least (b) Multiple inetrument drift resulting in conservatiw aspect of the limiting condition for opers, loss of protectiw function.
tion established in the technical specifications. De foj.
(c) HPCI faBure to start or failure to con-lowing are examples:
tinue running once initiated.
(a) Shutdown not begun within the speci.
(6) Personnel error or procedural inadequacy fled tirne when unidentified reactor coolant leakage ex, which prewnts or could prewnt, by itself, the fulfill-ceeds the technical specifications hmit, ment of the functional requirernents of systerns required (b) Failure of a system other than the tu cope with accidents analyzed in the SAR. De foDow-rystems subject to limiting safety 4ystem settings (see ing are examples:
2J(1) abow) to actuate, or actuation of such a system (a) Failure to restore a safety rystem to at a monitored parameter value less conservative than operabihty fc!)owing test or maintenance.
that listed in the technical specifications for the system.
(b) Improper procedure leading to in-(c) Operation with unacceptable cx>ntain.
correct valve lineup which iesulted in closure of one ment leak rate type B or C test results.
manual valve in each of two redundant safety injection (d) System cooldown at a rate exceeding subsystems and would have prevented injection on the technical specifications Linut.
demand.
Note: If specified action is taken when a system is found Note: For items 2.n(5) and 2.a(6) reduced redundancy g
,g g ;
,g ggg to be operating between the most conservative and the least conservatiw aspecu of a limiting condition for g
g g
g g
operation listed m, the technical sr:cifications, the under items 2.b(2) and 2.b(3) below.-
limiting condition for operation is not considered to have been violated and need not be reported under this item, but it may be reportable under item 2.b(2) below.
(7) Conditions ansing from natural or man-made events that, as a direct result of the event, require (3) Abnormal degradation discovered in fuel
-: nt shutdown, operation of safety systems, or other cladding, reactor coolant pressure boundary, or pnmary tective measures required by technical specifications.
containment,he following are examples:
g r llowing are examples:
o (a) Rrough wall failure of piping or con" (a) Threatened civil disturbances requiring ponents of the reactor coolant pressure boundary.
pla i mutdown.
(b) Steam generator tube thuuung in excess (b) Damage to the facuity caused by fire, of acceptance limits in Regulatory Guide 1.83, flood, earthquake, or other similar occurrences.
"Intervice Inspection of, Pressunzed Water Reactor (8) Errors discowred in the transient or Steam Generator Tubes."
acc dent analyses or in the methods used for such (c) Weldmg or material defects greater than analyses as described in the safety analysis report or in those allowable by applicable codes.
the bases for the technical specifications that haw or could have permitted reactor operation in a mannerless Note: Leakage of valve packing or gaskets within the conservatiw than assumed in the analyses. He following i
limits for identified leakage set forth in technical specifi.
,,,,,,,p;,,.
cations need not be reported under this item.
(a) Loss of condenser vacuum resulting in reactor pressure and Dux transients that peak at values Eumpi.,. ine.nd.d to be asustr.tiv. onny.
higher than analyzed.
a 1.16-4
(b) Reactivity insertion delay times by of the functional requirements of affected systems.The reactor protection system lonpr than those used in the following are examples:
technical specification bases.
(a) One of the four scram dump volume (9) Pbrformance of structures, systems, or com-level switches failed to operate during surveillance test.
ponents that requires remedial action or correctim (b) One of four reactor low-pressure ne:asums to prewet operation in a manner less conserva-switches operated at 885 peig instead of LSSS value of tlw than that assumed in the accident analyses in the 900 psig.
anfety analysis report or technical specifications bases; or (c) During tett, one out of four under-discowry during plant life of conditions not specifically voltage relays failed to perform its function of tripping a canadered in the safety analysss report or technical spe-reactor trip breaker.
cifications that require remedial action or correctiw (2) Conditions leading to operation in a de-measures to prewnt the existence or dewlopment of an graded mode permitted by a lirniting condition for unaafe condition. De following are examples:
operation, or plant shutdown required by a limiting condition for operation he following an examples:
(a) Axial flux ratios less conseryw nan (a) Con spray pump breaker tripped after those for which cormlations with owrpower As were 20 minutes during test Trip unit was found to be based on core bumup projections.
(b) Failure of a safety injection pump to defactive, declared inoperable, and repaired.
deliver the flow rates assumed in the FSAR.
(b) Safety injection pump failed to start (c) Degradation of hydraulic shock sup.
followmg system initiation. Required surveillance en pressors to the extent that they could not perform their redundant components was successfully completed.
required safety function.
(c) One of the two centrifugal charging (d) Failure of magnetic trip mechanisms Pumps became inoperable because of a faulty bearing.
on a safety related circuit breaker to provide trip on Redundant pump operability >vas canfirmed.
instantaneous overcurrent as indicated on the manufac-turer's tirrocurrent characteristic curve.
Note: Routine surveillance testing, instrument cabbra.
(e) Failure of a safety / relief valve to close tion, or preventive maintenance which require system after pressure has reduced below the required rescat configurations as described in items 2.b(1) and 2.b(2)
- valve, need not be reported except where test results them-(f) Dermal shock to the reactor coolant selves reveal a degraded mode as described above.
system resulting from inadvertent safety injection actua-tion.
(3) Observed inadequacies in the implementa-tion of administrative or procedural controls which Note: This item is intended to provide for reporting of threaten to cause reduction of degree of sedundancy potentially generic problems.
provided in reactor protection systems or engineered safety feature systems. The following are examples:
b.
Birty-Day Written Reporta (a) One of the three diesel generators tripped from high temperature because cooling water ne reportable occurrences dis issed below valves were lined up incorrectly, should be the subject of written reports to the Director (b) Isolation valve for a low pressure trip of the appropriate NRC Regional Office within 30 days switch was found closed with system pressure locked in.
of occurance of the event. A copy of the written report Tnp of switch would not occur at low pressure.
should also be sent to the Director, Office of Manage-Improper retum to operation following maintenance was ment Information and Program Control. ne wrttten the cause.
report should include, as a minimum, a completed copy (c) Failure to perform surveillance tests at of the licensee ewnt report form (see Appendix E to the required frequency, this guide) used for entering data into the NRC's computer based file of information concerning licensee (4) Abnormal degradation of systems other events. (Instructions for completing these licensee event than those specified'in item 2.a(3) abou designed to report forms? are issued individually to each licensee.)
contain cedioactive material resulting from tb fission Information provided on the licensee event report form process. Fu example, a through-wall leak in a liquid l
should be supplemented, as needed,by additional narra-waste storage tank.
tive material to provide complete explanation of the cir.
I l
cumstances surrounding the ewnt.
Note: Scaled. sources or calibration sources are not l
(1) Reactor protection system or engineered included under this item. leakage of valve packing or saf 'y feature instrument settings which are found to be gaskets within the 14 nits for identified leakage set forth 9
less conservative than those established by the technical in technical specifications need not be reported under specifications but which do not prevent the fulfillment this item.
1.16 5 4
(
Unscheduled shutdowns expected to last for 3.
Unique Reporting Requiressants e.
more than one week, regardless of cause.
The above reporting program will in general satisfy f.
Unusual releases of radioactive material from the reporting requirements necessary for compliance the site boundary not reportable under other require-with Appendix A technkal specifications. His program ments.
may need to be supplemented or modified becauw of g.
Failure of or damage to safety-related equip.
unique plant design features or other factors. The need ment which need not be reported under item 2.s above, for a supplemental or modified program will be deter.
if the time for repair is likely to exceed the time allowed mined on a case by case basis and so designated in by the technical specifications.
individual operating licenws.
4.
Events of Potential Public Interest D. IMPi.EMENTATION "he types of events listed below are freque.tly of ne purpose of this section is to provide informa-hi h public interest. While some of the events may not tion to applicants ar.d licensees regarding the NRC staff's 4
be srportable by regulation or defined in other parts of plans for utilizing this regulatory guide.
thu pide, the Director of the appropriate NRC Regional Except in those cases in which the appucant Office, or lus designee, should be informed of such proposes an acceptable alternative method, the reporting events by telephone as soon as possible after the event program described herein is being used by the NRC staff has been discovered.
in order to standardize the reporting requiremer.s section of Appendix A technical specifications of all a.
An event that causes damage to property or operating licenses.
equipment when such damage affects the powe' pro.
For licensees holding operating licenses without duction capability of the facibty.
Appendix k environmental technical specifications, it b.
Radiation exposure to licensee personnel or may be neces ary to include those reports identified in memWrs of the pubhc in excess of spplicable exposure Regulatory Guide 1.21, " Measuring, Evaluating, and limits set forth in 10 CFR Part 20.
Reporting Radioactivity in Solid Wastes and Releases of c.
Natural or man made conditions that may Radioactive Materials in Liquid and Gaseous Effluents require actior! which need not be reported under item from Light Water Cooled Nuclear Power Planu," and 2.a(7) above.
Regulatory Guide 4.1," Programs for Monitoring Radio-d.
Discovery of significant radiological event oft.
setivity in the Environs of Nuclear Power Plants,"in the c'te occurring during transport of material for which the technical specifications under the unique reporting licensee was either shipper or consignee.
requirement; section of the technical specifications.
0
- 1. I 6-6 w __-
v\\
APPENDlX A STANDARD FORMAT FOR REPORTING NUMBER OF PERSONNEL AND MAN-REM BY WORK AN Number of Personnel (> 100 awesa)
Total Maa-Reca Contract Workers l
-- ~
Worg & Job Function St. tion Employees Utdaty EmP oyees sad Others Station Einployees Utilsty Einployees h*'
Ranctor Operatioe s & Servestlance Maintenance Penonnel Operating Personnel Health Physacs Personnel Supervisory Personnel Engineering Personnel I
Routine Meantenmace Meantenance Personnel Operating Personnel Health Physscs Personnel Supervisory Personnel Engincenns Personnel Inservice lampection Maintenance Perwnnel Operating Personnel Health Physics Personnel Supervisory Personnel Engneenns Personnel Specal Maintenance 6
Maintenance Personnel
/
7 Operating Personnel
}
4 IIcalth Physica Personnel Suparisory Personnel Engneering Personnel Weste Proceannag Mainicame rersonnel Gperating Personnel Health Physacs Personnel Supervisory Personnel Engineering Personnel Refuelang Maintenance Personnel Operating Personnel Health Physics Personnel Supervtsory Personnel Engincedg Personnel TOTAL Maintenance Personnel Operatir:g Personnel Health Physacs Personnel Supervisory Personnel Engineenns Personnel Grand Total
APP 5 NDIX B AVERAGE DAILY IJNIT POWER LEVEL DOCKET NO.
UNIT DATE COMPLETED BY TELEPHONE MONTH DAY AVERAGE DAILY POWER LEVEL DAY AVERAGE DAILY POWER LEVEL (MWe-Net)
(MWe-Net) 1 l
17
]
l 2
18 3
19 l
4 m
5 21 8
22 7
23 8
24 9
25 l
10 26
(
11 27 12 28 13 29 14 30 15 31 i
16 INSTRUCTIONS On this form, list the average daily unit power level m MWe-Net for each day in the reporting month. Compute to the nearest whole megawatt.
These figures wHl be used to plot a graph for each reporting month. Note that when maximum dependable capacity is used for the net electrical rsting of the unit, then' may be occasions when the daily average power level exceeds the 10Crk hne (or the restricted power level line). E. such cases, the average daily unit power output sheet should be footnoted to explain the apparent anomaly.
1.16-8
~~ -
t k
APPENDIX C OPERATING DATA REPORT i
i DOCKET NO.
i e
UNIT DATE COMPLETED BY l
TELEPHONE OPER ATING STATUS
- 1. REPORTING PERIOD:
GROSS HOURS IN REPORTING PERIOD:
- 2. CURRENTLY AUTHORIZED POWER LEVEL (MWt):
MAX. DEPEND. CAPACITY (MWe-Ned:
DESIGN ELECTRICAL RATING (MWe Net):
l
- 3. POWER LEVEL TO WHICH RESTRICTED (IF ANY) (MWe Not):
l i
- 4. REASONS FOR RESTRICTION!(IF ANY):
I THIS MONTee YR TO DATA CUMULATIVE
- 5. NUM8ER OF HOURS REACTOR WAS CRITICAL
- 6. REACTOR RESERVE SHUTDOWN HOURS
- 7. HOURS GENERATOR ON LINE
- 8. UNIT RESERVE EHUTDOWN HOURS
- 9. G3OSS THENMAL ENERGY GENERATED (MWH)
- 10. GROSS ELECTRICAL ENERGY GENERATED (MWH).
II. NET ELECTRICAL ENERGY GENERATED (MWHI
- 12. REACTOR SERVICE FACTOR l
- 13. REACTOR AVAILABILITY F ACTOR
- 14. UNIT SERVICE FACTOR
- 15. UNIT AVAILASILITY FACTOR
- 16. UNIT CAPACITY FACTOR (Uning MDC)
- 17. UNIT CAPACITY FACTOR (Using Dessen MWel
- 18. UNIT FORCED OUTAGE RATE
- 19. SHUTDOWNS SCHEDULED OVER NEXT 6 MONTHS (TYPE DATE, AND DURATION OF EACH):
- 20. IF SHUT DOWN AT END OF REPORT PERT 00. ESTIMATED DATE OF STARTUP:
- 21. UNITS IN TEST STATUS (PRIOR TO COMMERCIAL OPERATION):
FORECAST ACellEVED INITI AL CRITIC ALITY INITI AL ELECTRICITY COMMERCI AL OPERATION 1.16 9
l 4
i D
INSTRUCTIONg FOR CORFl.ETING OPERATING DATA REPORT ij' nis report should be furnshed each month by as specific as possible within space limitations. Plants in licensees, ne name and telephone number of the startup and power ascension,est phase should be i
f Preparer should be provided in the designated spaces. identified here.
The instructions below are provided to assist licensees in j
reporting the data consistently. The number of the
- 5. Show the total number of houn the reactor was instruction corresponds to the item number of the critiW during the poss hours of the reporting period.
report form.
- l. Reportang Period. Demgnete the month for which
- 6. Reactor Rearew Shutdown Hours. The totd '
the data are presented. The Gross Hours are normally number of hours during the poes hours of reporting l
from 0001 of the Arst day through 2400 of the last day period that the reactor was removed from service for i
of the calendar month, with appropriate adjustments for admmistrative or other reasons but was available for any month in which a chany from standard to operation.
daylight-saving time (or vice verse) is made. The only two shorter reporting periods are (1) the one in which
- 7. Hours Generator On use. Also called Service the initial electrical generation occurs and (2) the one in Hours. The total number of hours during the pom hours 1
which the reactor is shut down for decommissioning. In of the reporting period that the unit operated with the former, the poes hours, expremed to the nearest breakers closed to the station bus. These hours, plus 1
tenth of an hour, are those from the time of initial those listed in Appendix D for the generator outage power pneration to 2400 of the last day of the calendar houn, should equal the poss hours in the reporting i
month, in the latter case, the poes hours, expremed to period.
)
the nearest tenth of an hour, are those from 0001 of the calendar month to the specific time of final shutdown.
- 8. Unit Reserve Shutdown Hours. The total number of hours dunng the poss hours of the reporting period
- 2. lhe Authortrad Power Level is the maximum that the unit was removed from service for economic or O
thermal power, expressed in messwatts, currently similar reasons but was available for operation.
authorized by the Nuclear Regulatory Commission.
i
- 9. Gross Thermal Energy Generated. The thermal De net Maximum Dependable Capacity is the pom output of the nuclear steam supply system during the
(
electrical output as measured at the output terminals of poss hours of the reporting period, expressed in the turbine.pnerator during the most restrictive seasonal megawatt hours.
conditions less the normal station service loads.
- 10. Gross Electrical Energy Generated. The electrical ne net Desen Electrical Rating is the nominal net output of the vrut measured at the output terminals of electrical output of the unit specified by the utility and used for the purpose of plant design.
the turbine generator during the pom hours of the reporting period, expressed in megawatt hours.
- 3. Note that this item is applicable only if restric-tions on the power level are in effect. Short. term (less
- 11. Net Electrical Energy Generated. The poe elec-j than one month) limitations on power level need not be trical output of the unit measured at the output presented in this item, ance one of the important terminals of the turbine-pnerator minus the normal purposes of the item is to determine if, and at what station service loads during the poss hours of the power level, a restricted power level line should be reporting period, expressed in megawatt hours. Negative drawn on the chart of averap daily reactor power.
quantities should not be used. If there is no net postive value for the period, enter zero.
1 Since this information is used to develop figures on 0
capacity lost due to restnctions and because most users 1218. For units still in the startup and power of the " Operating Plant Status Report" are pnmarily ascension test phase, items 1218 should not be com-
)
interested in energy actually fed to the distribution puted. Instead, enter N/A in the current month column.
system, it is requested that this figure be expressed in These seven factors should be computed starting at the MWe Net in spite of the fact that the figure must be tirne the unit is declared to be in commercial operation, derived from MWt or percent power.
The cumulative figures in the second and third columns should be based on commercial operation as a starting
.(
- 4. Reasons for Restriction (if Any). If item 3 is date. However, units alrear'y in commercial operation, f
used, item 4 explains why. Brief narrative is acceptable.
for which cumulative figures have been based on i
\\
Cite references u appropriate. Indicate whether restric.
different starting dates, need not recalculate the cumu tions are self-imposed or are regulatory requirements. Be tive figures.
1.16 11
O1
- 12. Reactae Servke Factoe. Compute by dividing
- 18. Unit Foeced Outap Rate. Compute by dividing hours reactor was critical (item 5) by the poes hours in the total forced outage hours (from the table in the reporting period (item 1). Express as percent to the Appendix D) by the sum of hours generator on line nearest tenth of a percent During months when the unit (item 7) plus total forced outay hours (from the table i
is shut down for the entire period because of nonreactor in Appendix D). Express as percent to the nearest tenth problems, enter "Not Applicable" and explain in the of a percent.
)
Summary of Appendix D. Do not include reserve
. shutdown hours in the cakulation.
- 19. Shutdowns Scheduled to Begin la Next 6 i
Months. Include type (refueling, maintenance, other),
j
- 13. Reactee Availabaity Factee. Compute by divid.
proposed date of start of shutdown, and proposed length ing the reactor available hours (iterns 5 plus 6) by the of shutdown. It is recognized that shutdowns may bc
)
pose hours in the reporting period (item 1). Express as scheduled between reports and that this item may not be j
percent to the nearest tenth of a percent.
all inclusne. Be as accurate as possible as of the date the I
report is prepared.
{
- 14. Unk Seevice Factor. Compute by dividing hours the pnerator was on line (item 7) by the poss hours in
- 20. Self<xplanatory.
j the reporting period (item I). Express as percent to the nearest tenth of a percent. Do not include reserw 2). Self. explanatory. Note, however, that this infor.
shutdown hours in the calculation.
mation is requested for all units in startup and power ascension test status and is not required for units already i
c mme peradon.
- 15. Unit Avagability Factor. Compute by dividing the unit svallable hc rs (item 7 plus item 8) by the gross Test Status is dermed as that period followmg initial hours in the reporting period (item 1). Express as enticality during which the unit is tested at successively percent to the nearest tenth of a percent.
higher outputs, culminating with operation at full power for a sustained period and completion of warranty runs.
- 16. Unit Capacity Factoe (Using MDC). Compute by Following this phase, the unit is generally canadered by dividing net electrical energy generated (item ll} by the the utility to be available for commercial operation.
product of maximum dependable capacity (item 2) times the gross hours in the reporting period (item 1).
Date of Commercial Operation is dermed as the date Express as percent to the nearest tenth of a percent.
that the unit was declared by the utility owner to be j
available for the regular production of electricity, j
17, Unit Capacity Factor (Using Desgn Electrial usually related to the satisfactory completion of qualifi.
Rating). Compute as in item 16, substituting duign cation tests as specified in the purchase contract and to electrics! rating for nuxirnum dependable capacity, the accounting policies and practices of the utility.
O 1.1612
APPENDIX D DOCKET NO.
UNIT SHUTDOWNS AND POWER REDUCTIONS UNIT NAME DATE COMPLETED BY REPORT MONTH METHOD OF TYPE SHUTTING DOWN F: FORCED DURATION THE REACTOR OR NO.
DATE S: SCHEDULED (HOURS)
REASON (H REDUCING POWER (2)
CORRECTIVE ACTIONSWENTS (I) REASON A: EQUIPMENT FAILURE (EXFUdN)
R: M41NT.ORTEST C: REFUE13NG D. REGULATORY RESTRICTION 2: OPERATORTRAINING AND 1
13 CENSE EXAMINATION I: ADMINISTR GVE w
G: OPERA 110NAL ERROR (EXFLAIM)
H: UrHER (EXPLAIN)
(2) METHOD 1: MANUAL 2: MANUALSCRAM 3: AUIT)MATICSCRAM 4: OTHER (EXFIAIN)
SUhESARY:
UNIT SHUTDOWNS AND POWER REDUCTIONS INSTRUCMONS required to be initiated by no later than the weekend I
following Oscovery of an off-normal condition. It i i
This report should describe all plant shutdowns dur.
recognized that some judgment is recuired in categori s
ing the report period. In addition, it should be the zing shutdowns in tius way. In general, a forced shut source of explanation of significant dips in average down is one that would not have been completed in the power levels (Appendix B). Each signiDeant reduction in absence of the condition for which corrective action was Power level (greater than 20% reduction in average daily taken.
Power level for the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) should be noted, ewn though the urut inay not have been shut down Duration. Self explanatory. When a shutdown extends completely.8 For such reductiom in powei lev:', the beyond the end of a report period, count only the tirne duration should be listed as zero, the method of reduc.
tion should be listed as 4 (Other), and the Comm nts to the end of the report period and pick up the ensuing 4
column should explain. The Comrnents column should down time in the following report periods. Report dura.
tion of outages rounded to the nearest tenth of an hour be used to provide any needed explanation not ade.
to facilitate summation. The sum of the total outage quately described by the coded columns. Please do not hours plus the hours the generator was on line (item 7 of add to the list of codes or legends now fumished. Simi.
larly, do r.ot add additional columns.
Appendix C) should equal the gross hoursin the report.
ing period (item I of Appendix C).
Reason. Categorize by let'" derignation in accordance Number. This column should indicate the sequential with the table appearing on the report form. If category number stigned to each shutdown or significant reduc.
H must be useJ, supply bnef comments.
tion in power for that calendar year. When a shutdown or significant power reduction begms in one report Method of Shutting Down the Reactor or Reducing
, period and ends in another,an entry should be made for Power. Categorize by number designation in accordance both report periods to be sure all shutdowns or signin.
with the table appearing on the report form. If categery cant power reductiom are reported. Until a urut has 4 must be used, supply bnef cornments.
achieved its first power Jeneration,no number should be assigned to each entry.
Corrective Actiom/ Comments. Use this column to am.
plify or explain the reasons for each shutdown or signifi.
Date. His column should mdicate the date of the start cant power reduction, with the correctiw action taken, of each shutdown or significant power reduction. Report if appropriate. De Comments column entries should as year, month, and day. August 14,1975 would be provide identification of each shutdown or significant reported as 750814. When a shutdown or significant power reduction that occurs as a direct result of a re.
power reduction begins in one report period and ends in portable occurrence on which a report has been or will another, an entry should be made for both report be subnutted. (This mformation may not beimmediately periods to be sure all shutdowns or sigruficant power evident for all such shutdowns, of course. since further reductions are reported.
investigation may be required to ascertain whether or not a reportable occurrence was involved.) When a direct Type. Use "F" or "S" to indicate either " Forced" or correlation can be made between a given shutdown and a
" Scheduled," respectively, for each shutdown or sigrufi.
specific reportabic occurrence report, the Comments cant pawer reducuon. Forced shutdowns include those column entry should state the reportable occurrence report number and date, 8 Note that than dJfers f c.rn the Edison Electne insutute (EEt) defu'stions of "Ic. aced Partial Outage" and " Scheduled Partial Summary. Wrne a brief summary description (3 to 4 Ou'aae " For these terms, eel uses a change of 30 MW u the sentences) of th @gMs of operation of the uM for break point. For isrser power reactors, 30 MW u too small a the reporting month. Include any cornments required by chamse to warrant explanation.
item 12 of Appendix C.
9 1.1614
f%
+\\-Q APPENDlX E LICENSEE EVENT REPORT LONTROL SLOCK l I l l l l l LICE N8 E E LICENSE EVENT NAME LICENSE NUMBER TYPE TYPE 1
@l I l I I l l l l 1-1 I I I l ll I l Ill l Ll L_.L.J 9
14 IS 28 28 20 31 32 REPORT REPORT CATEGORY TYPE SOURCE DOCKET NUM8ER EVENT DATE REPORT DATE MON t_L_l U l_) l l I l -I I I I l 1 l 1 1 I I I I I I I I I I 7 e si es se so si se se 74 7s so EVENT DESCRIPTION 9
80 I
l eo L
l r
e
,a 9
si i
m i
I 8
- SYSTEM CAUSE F
yy COMPONENT 80 Chy C R
E!BLbOnt LfE I I i i i I I y
CO COMPONENT CODE MANUPACTERlR u VIOLATION
! l 7 89 10-11 12 17 43e 44 47 as CAUSE DESCRIPTION 1
1 (3
i
\\
u)
DG I I
i ee no F ACILIT Y METHOD OF STATUS
% POWER OTH E R ST ATUS DISCOV E R Y DISCOVERY DESCRIPTION U
l l l l 1 i U l
I 7 8 9
10 12 13 44 45 de 90 IN CONTENT RE E ASED OF M LEASE AMOUNT OF ACTIVITY LOCATION OF RELE ASE l
1 PERSONNEL EXPOSURES NUMSER TYPE DESCRtPTION 81 I I I LJ l
I 7 89 11 12 13 SO PE RSONNE L INJUmlES NUMSER DESCRIPYlON l l l l l 7..
,E PRCSASLE CONSFOUENCES 8,. L.
_J LOSS OR DAM AGE TO P ACILIT Y TYPE DESCRIPTION U !
7 Es i,
ao PUSLIC TY l
7 39 g
80 ADOtTIONAL P ACTORS rr [
7 ee l
so Q
mc L 1
7 f9 80 N AM E :
PHONE:
.u. s.cc4 anet ea *r t c arr ect ii,es.rar.re r,sm, 1.16 15
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