ML061240369
| ML061240369 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Palo Verde, South Texas  |
| Issue date: | 04/03/2006 |
| From: | Christian D, Floyd S, Jordan T, James M. Levine Arizona Public Service Co, Dominion, Nuclear Energy Institute, South Texas |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML061240369 (15) | |
Text
Risk-Informed, Performance-Based Regulation Jim Levine, Arizona Public Service David Christian, Dominion Tom Jordan, South Texas Project Steve Floyd, NEI May 3, 2006 ats I
Prog ress to Date
- Risk-informed, performance-based approaches have been demonstrated to be effective
- Successful applications have included
- Revised reactor oversight process
- Maintenance rule
- Mitigating Systems Performance Index
- Plant safety, reliability, and economic performance have been sustained at high levels 2
Current Situation
- Momentum for progress of important risk-informed rulemakings has slowed significantly
- Implementation of the direction provided by the Commission in response to SECY-98-300 is taking far too long
- Safety and efficiency enhancements desired by both the NRC and industry are impacted
- Purpose of briefing is to provide examples and identify success oath 3
1995 NRC PRA Policy Statement
- PRA methods should complement the NRC's deterministic approach
- Focus attention and resource allocation to areas of true safety significance
- Implement in a manner that promotes regulatory stability and enhances safety 4
Key Points
- Risk-informed, performance-based regulation cannot be another layer
- Strong change management needed to regain momentum
Implementation of §50.69 Special Treatment Requirements
- Concept began as graded quality assurance
- Initial industry/NRC meeting in August 1998
- Industry guidance and pilot of categorization process began in 2000
- South Texas exemption approved in August 2001
- Final rule approved in November 2004
- Regulatory Guidance issued in January 2006 -
revision expected in May 2006 NtK I 6
Regulatory Guide 1.201 (50.69 implementation guidance)
- Use of risk-informed process for categorization has been demonstrated X Majority of NRC staff discussion focused on treatment of safety related, low safety significant equipment (RISC-3 SSCs)
- Recent revision to regulatory guide appears to resolve industry concerns NeE I 7.
§50.69 Implementation
- Industry intends to submit a pilot application this year
- This is a strategic investment that should provide long term value
- Broader industry implementation is expected to follow
- Timely NRC review of industry submittals is needed to progress with implementation of 50.69 rISE I 8
STP Exemption Implementation Summary
- STP Exemption proof-tested 50.69 concept
- Categorization completed on 94 systems
- Number of systems driven by Station users
- For safety-related SSCs, 75% determined to be Low Safety Significant (RISC-3)
- Categorization results enhance our focus on safety and support better-informed decisions
- Treatment proceeding in deliberate manner 9iE I
§50.46a - LOCA Requirements
- Research effort began in 1999
- Industry petitioned NRC for enabling rule in 2002
- Proposed rule deferred several times from March 2004 to November 2005 E I 4k,.-
10
Proposed §50.46a Significant concerns
- New operational restrictions for old design basis events
- New change control requirements focused on residual risk
- Lack of stakeholder participation Not a viable option for licensees in its current form Nie, I 11v
§50.46a Going Forward v Huge potential for safety enhancements and operational flexibility mImplementation must be practical and consistent with policy direction mStakeholder participation would help support viability of final rule and guidance development .
r*1 I 12
Future Risk-Informed Applications
- Fire Protection - Transition to NFPA-805
- Many plants have expressed intent
- Significant Fire PRA effort
- Part 52 Rulemaking
- Earlier version had full scope PRA requirement i These initiatives should incorporate lessons learned from prior efforts 13
PRA Tools
- Current and envisioned applications all need acceptable at-power, internal event PRA models
- Industry will focus on the development and peer review of these PRAs 14,E I 14
Conclusions E Industry agrees with the Commission's policy direction
- Industry will support applications that add value e Safety enhancements and cost benefits
- Strong leadership and change management is needed by all parties to support implementation
- Need to ensure focus is on matters of high safety significance I Lessons learned from §50.69 and §50.46 rulemakings should be incorporated in future risk-informed initiatives _
rats d
_,"a. I 15