K. McElroy Presentation on Vogtle 10 CFR 50_69 Pilot Program

Report
PLANT VOGTLE 1&2
10 CFR 50.69 PILOT PROGRAM
NESCC MEETING
NOVEMBER 3, 2014
AGENDA
• Vogtle Risk Categorization
• 50.69 Discussion Topics
• Why haven’t more utilities submitted 50.69?
• Is a Standard needed for the Categorization Process?
• Is a Standard needed for the Special Treatment Process?
• Summary/Questions
RISK CHARACTERIZATION VOGTLE SUBMITTAL
3
• 5 Risk Contributors
• NEI-00-04 requires peer-reviewed IE PRA
Internal
Events Risk
Fire
Risk
Internal Events
(including
Internal
Flooding)
Fire
PRA
PRA
FIVE
Seismic
Risk
Seismic
PRA
Updated
Seismic
Margin
Analysis
Other
External
Events Risk
Other
External
Events PRA
Updated
IPEEE
Screening
Shutdown
Risk
Shutdown
PRA
S/D DID
Model via
EOOS
WHY HAVEN’T OTHER UTILITIES
SUBMITTED?
• Utilities did not have infrastructure when rule made
effective (November 2004)
• Significant investment required for risk models and
characterization
• Industry concerned NRC would regulate Special
Treatment through inspection
SNC believes this will change with a successful pilot
4
IS A STANDARD NEEDED FOR
CHARACTERIZATION?
• At least three utilities have used NEI-00-04/RG 1.201
to categorize
•
•
•
•
Guidance turned into detailed process & procedures
NRC has reviewed procedures and witnessed IDP meetings
STP has categorized over 100 systems
NRC SER expected soon for Vogtle pilot
• Model adequacy
• Characterization process
• Extensive industry experience categorizing components
• Maintenance Rule
• AP-913 (Equipment Reliability)
5
NEI-00-04 CATEGORIZATION TOC
6
REGULATORY REQUIREMENTS THAT
NO LONGER APPLY PER 10CFR50.69
10CFR50.69 eliminates the following requirements for
components designated as RISC-3 (low risk, safety-related):





10CFR50, Appendix B (quality
requirements)
10CFR Part 21
(deficiency reporting
requirements)
10CFR 50.49
(Testing, documentation, and
margin requirements for EQ
purposes)
10CFR50.55(e)
(event reporting)
10CFR 50.55a(f), (g) & (h)
(Applicable portions of ASME &
IEEE codes and standards)





10CFR 50.65
(Maintenance Rule)
10CFR50.72
(notification requirements)
10CFR50.73
(licensee event reports)
Portions of 10CFR50, Appendix J
(primary reactor containment
leakage testing)
Portions of Appendix A to 10CFR
Part 100
(Seismic qualification with respect
to extent of testing and types of
analyses)
IS A STANDARD NEEDED FOR SPECIAL
TREATMENT?
• Rule does not prescribe special treatments
• Rule is performance-based
• Reasonable assurance vs. reasonable confidence
• Extensive industry comments on IP 37060 (draft)
• Inspections should be performance-based, not prescriptive
• Draft IP in 2012 incorporated many industry comments
• Industry has developed guidance on treatment
• EPRI Special Treatment Guidance (2007), plus Environmental
Qualification & Seismic
• SNC developing treatment procedures for 10 CFR 50 App. B,
App. J, 50.55a, 50.65 (Maintenance Rule)
8
SUMMARY
• PRA Models have a Standard
• Categorization process in NEI-00-04 for 50.69 is
similar to other risk-informed initiatives
•
•
•
•
Maintenance Rule
RI In-Service Inspection
Surveillance Frequency Control Program
Risk Prioritization – Cumulative Impacts
• Guidance available for Special Treatments
• Performance-based rule
• Flexibility desired to define “reasonable assurance”
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