The Purpose Improving Operational Efficiency by Focusing  Resources on Areas of Safety Significance  (10CFR50.69)

Improving Operational Efficiency by Focusing Resources on Areas of Safety Significance (10CFR50.69)
Thomas Zachariah
Project Manager, Risk Assessment
NRC 2016 RIC
March 9, 2016 • Bethesda North Marriott
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The Purpose
Provide Flexibility to Reduce Cost and Improve Plant Operations & Safety Margins
High Safety Significant Areas
Reduce Burden
Increase
Focus
Low Safety Significant Areas
This is a Key to the Cost Effectiveness of Nuclear Power
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Categorization
Safety Related
Low Risk
50.69
High Risk
Non Safety Related
RISC 1
RISC 2
Safety Related
Non Safety Related
High Safety Significance
High Safety
Significance
Safety Related
Non Safety Related
Low Safety Significance
Low Safety
Significance
RISC 3
RISC 4
RISC = Risk Informed Safety Class
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Categorization Experience
Averages for Component Categorization
RISC 1
RISC 2
13‐25%
of Safety Related SSCs
1‐3% of Non‐Safety Related SSCs
75‐87%
of Safety Related SSCs
97‐99%
of Non‐Safety Related SSCs
RISC 3
RISC 4
Exempted Special Treatment Requirements
RISC‐3 Components Can Be Scoped Out of These Safety Related Regulations
Local Leak Rate Testing [10 CFR 50 Appendix J]
Quality Requirements [10 CFR 50 Appendix B]
In‐service Inspection
[10 CFR 50.55a(g)] Deficiency Reporting [10 CFR Part 21]
Maintenance Rule [10 CFR 50.65]
In‐service Testing [10 CFR 50.55a(f)]
Environmental Qualification [10 CFR 50.49]
Event Reporting [10 CFR 50.55(e)]
Seismic Qualification [Portions of Appendix A to 10 CFR Part 100]
ASME XI repair & replacements, applicable portions, with limitations [10 CFR 50.55a(g)]
Applicable Portions of IEEE standards [10 CFR 50.55a(h)]
Notification Requirements [10 CFR 50.72, 50.73]
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Alternate Treatments for RISC‐3
Components Can Be Moved from Special Treatments to Alternate Treatments
NRC Special Treatment Requirements (Current)
Alternate Treatment Requirements (New)
Requirements Defined by NRC
Requirements Defined by Licensee with No NRC approval
Needs to Provide Assurance –
More Rigor
Needs to Provide Confidence –
Less Rigor
Results of SDPs are based on NRC Requirements SDP Results on RISC‐3 Components Should Be Green by Definition
Still needs to show that component is capable of meeting safety related function
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2
The Benefits
Alternate Treatment Requirements
Reduction in Procurement Costs
Reduction of Onsite Surveillances
Reduction in Vendor Testing Frequency
Increased Flexibility of Addressing Obsolescence
Decrease Frequency of Replacing Components
Reallocation of Resources
Example Benefits
Improve Safety and Reduce Operational Cost
Improved Equipment Reliability
Increased Equipment Availability
Reduction in Outage Duration
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Phased Approach
Designed to be Methodical and at the Licensee’s Pace
Phase 1: Submittal
Phase 2: Categorization
Phase 3: Alternate Treatment
System 2
System 3
Choose a Program
Application to Implement 10 CFR 50.69 for NRC Approval
Choose a System
Choose to Submit
System 1
Maintenance Rule
ASME XI repair & replacements
Environmental Qualification In‐service Inspection
Applicable Portions of IEEE standards
Seismic Qualification
In‐service Testing
Event Reporting
System 5
Local Leak Rate Testing Notification Requirements System 6
Deficiency Reporting Quality Requirements System 4
Licensee choice on when to enter each phase and choose the most beneficial path
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Forming a More Cost Effective Industry
Piloted guidance has been established and is continually being improved
Nuclear
Cost‐Effectiveness
Site Specific 50.69 Process Implementation
NEI Guidance
Categorization
EPRI Guidance
Alternate Treatment Requirements
Industry Experience
Increased implementation will identify new applications and make the industry more cost effective as a whole
Cost‐Effective Improvements
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3
Summary
Not Implementing 50.69 Leaves Significant Operational Savings on the Table Every Year
The Submittal is a Low Risk Investment
The road has been paved
Implement Everything or Nothing…or anything in‐between
The rule was designed to be implemented strategically
Much of the work completed
Potential for great benefits
Your implementation plans should reflect that strategy
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