ML052140326

RIC 2005 Presentation - A3 - Glen E. Schinzel - 50.69

ML052140326
Person / Time
Site:	South Texas
Issue date:	03/09/2005
From:	Schinzel G South Texas
To:	Office of Nuclear Reactor Regulation
References
Download: ML052140326 (8)

Text

RIC 2005 Session WA3 Risk-Informing Special Treatment Requirements 10 CFR 50.69 Insights from the 50.69 Proto-type Pilot Plant Glen Schinzel, Project Manager Risk Implementation, STPNOC - South Texas Project March 9, 2005 361-972-7854 geschinzel@stpegs.com

2 Background of STPs Status

• STP pursued and received an Exemption from certain Special Treatment Requirements in August 2001 - viewed as proto-type pilot for 10 CFR 50.69

• STP categorization process and implementation allowances closely align with the processes approved in 10 CFR 50.69

• As of 12/31/04, STP completed categorization of 85 different system designators (about 80,000 components)

3 Categorization Lessons Learned Positives noted:

• Consensus decision-making process has been effective in promoting critical discussion and consensus resolutions

• Excellent categorization stability has been noted throughout process

• Good consistency noted between probabilistic and deterministic results

• Dissenting Opinion process has worked well -

differences of technical opinions effectively addressed

• Management involvement adds value to the process

4 Categorization Lessons Learned Challenges seen:

• Proper identification of all system functions is necessary for effective categorization results

• Electrical components (breakers, MCCs, etc) pose unique categorization challenges when determining importance

• If a certain number of components are not specifically tagged, need to develop methodology on how to address these in both categorization and implementation

5 Categorization Lessons Learned Hazards to be Avoided:

• Begin with a well-reviewed, well-supported PRA Model

• Recognize that some SSCs will periodically change categorization - prepare a methodology to restore full regulatory controls to SSCs that were previously RISC-3

• Documentation of categorization basis must be detailed, clear, and retrievable

• Categorization and treatment must be addressed separately

• Must prepare the organizational culture to understand and use the categorization results

6 Implementation Lessons Learned

• Communicate, communicate, communicate

• Focus on a few programmatic areas of implementation initially - when these areas show positive feedback with controlled results, move on to other areas

• Focus on programmatic areas that have a willing owner

• Determine how to define implementation success -

could be defined through reduced burden, parts savings, better focus on safety significant activities, etc.

7 Implementation Lessons Learned

• STP is expending considerable effort to document a basis of reasonable confidence when reducing treatment for RISC-3 SSCs - question as to whether 50.69 requires this same degree of effort

• There remains uncertainty about NRC expectations for industry RISC-3 treatments - when will the industry feel comfortable with what constitutes reasonable confidence, and who will define it?

8 Going Forward

• STP efforts to date have demonstrated the value of a sound categorization approach

• Implementation results in both nuclear safety and economic benefits - not all can be measured via bottom-line, hard-dollar savings

• Categorization and treatment are different aspects and must be kept separate

• Industry is poised to move forward, but uncertainties still exist that could keep many industry players on the sidelines