ML11304A261

Audit of the Southern Nuclear Operating Company Categorization Process Being Developed to Support a Request for a License Amendment to Implement 10 CFR 50.69

ML11304A261
Person / Time
Site:	Vogtle
Issue date:	11/07/2011
From:	Harrison D NRC/NRR/DRA/APLA
To:	Kulesa G Plant Licensing Branch II
Dinsmore S, NRR/DRA/APLA, 415-8482
References
Download: ML11304A261 (5)

Text

November 7, 2011 MEMORANDUM TO: Gloria Kulesa, Chief Plant Licensing Branch Division of Operating Reactor Licensing II-1 Office of Nuclear Reactor Regulation FROM: Donnie Harrison, Chief /RA/

Probabilistic Risk Assessment Licensing Branch A Division of Risk Assessment Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT OF THE SOUTHERN NUCLEAR OPERATING COMPANY CATEGORIZATION PROCESS BEING DEVELOPED TO SUPPORT A REQUEST FOR A LICENSE AMENDMENT TO IMPLEMENT TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50.69 By letter dated December 6, 2010, Southern Nuclear Operating Company (SNC) stated that they planned to submit a request for a license amendment for the SNC Vogtle Electric Generating Plant (VEGP) to implement 10 CFR 50.69 in 2012. The licensee requested pilot status and a waiver of licensing review fees. By letter dated June 17, 2011, the Nuclear Regulatory Commission (NRC) granted pilot status and the fee waiver request.

A principle step in implementing 10 CFR 50.69 is a meeting of the licensees integrated decision-making panel (IDP) where the final safety-significant categories for components are chosen. SNC informed the NRC that its IDP will meet in November 2011, and January 20012, and invited the NRC to observe one of the meetings. The NRC has informed SNC that it would like to observe the November 29, 2011, IDP meeting. In order to most effectively gain insights from observing the IDP meeting, VEGP and NRC staff will meet the afternoon of November 28, 2011, to discuss the draft categorization procedures and any other issues related to the categorization process.

This memo provides the audit plan for the NRC Staffs observation visit.

Docket No.: 50-424 and 50-425

Enclosure:

1. .Audit Plan CONTACT: Stephen Dinsmore, NRR/DRA/APLA 301-415-8482

ML11304A261 OFFICE DRA/APLA DRA/APLA NAME SDinsmore DHarrison DATE 11 / 03 / 11 11 / 07 / 11 Audit of the Southern Nuclear Operating Company categorization process being developed to support a request for a license amendment to implement 10 CFR 50.69

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Background===

By letter dated December 6, 2010, Southern Nuclear Operating Company (SNC) requested pilot status and a waiver of review fees for the planned SNC Vogtle Electric Generating Plant (VEGP) 10 CFR 50.69 license amendment request which will be submitted in 2012. By letter dated June 17, 2011, the NRC granted the request for pilot status and fee waiver.

On March 29, 2011, NRC and SNC met to review SNC's planned approach for implementation of 10 CFR 50.69, risk-informed categorization and treatment of structures, systems, and components (SSCs) for nuclear power reactors. SNC informed the NRC about its ongoing trial categorization of three VEGP systems. By letter dated August 17, 2011, SNC provided the draft categorization procedures to the NRC.

A principle step in the categorization is a meeting of the licensees integrated decision-making panel (IDP) where the final safety-significant categories for SSCs are chosen.

SNC informed the NRC that the IDP will meet in November 2011, and January 20012, and invited the NRC to observe one of the meetings. The NRC has informed Vogtle that it would like to observe the November 29, 2011, IDP meeting. In order to most effectively gain insights from observing the IDP meeting, Vogtle and NRC staff will meet the afternoon of November 28, 2011, to discuss the draft categorization procedures and any other issues related to the categorization process.

APLA has concluded that the audit which includes the observation of the IDP process at the licensees site would allow the staff to:

• Gain a better understanding of the detailed process used by the licensee to demonstrate compliance with the risk informed categorization process,

• Identify additional information that might be needed to document the staffs conclusions regarding the adequacy, or lack of adequacy, of the risk assessments to support the submittal, and

• Establish an understanding of potential concerns to inform future regulatory actions associated with adoption of 10 CFR 50.69.

Regulatory Basis The audit will be conducted to clarify the acceptability of the licensee risk-informed evaluations based on the following regulatory documents.

10 CFR Part 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors provides an alternative approach for establishing the requirements for treatment of structures, systems and components ENCLOSURE

(SSCs) for nuclear power reactors using a risk-informed method of categorizing SSCs according to their safety significance .

Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, describes an acceptable risk assessment method for the licensee and NRC staff to use in assessing the nature and impact of changes to a plants licensing basis.

RG 1.201 Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance describes methods the staff considers acceptable for use in implementing a performance-based risk-informed program that meets the requirements of 10 CFR 50.69.

Regulatory Audit Methodology The audit will begin on November 28, 2011, with a discussion of the categorization process as described in the SNC draft 50.69 procedures and other SNC 50.69 process items.

The audit will conclude on November 29, 2011, with the observation of the IDP discussions.

Information and Other Material Necessary for the Regulatory Audit The NRC staff will bring the regulatory documents described above. SNC should have the following documents available for the overview of process on November 28th.

1) The version of the industry developed guidance document NEI 00-04, 10 CFR 50.69 SSC Categorization Guideline that the licensee will use.

2) The document that describes the process that the licensee will use to categorize the safety significant of the passive functions and SSCs that support these passive functions.

The licensee should provide personnel that are intimately familiar with the risk-informed categorization process on November 28, 2011.

Team Assignment Donnie Harrison, Chief, Probabilistic Risk Assessment Licensing Branch (APLA)

Stephen Dinsmore, Senior Reliability and Risk Analyst (APLA)

Dan ONeal, Reliability and Risk Analyst (APLA)

Logistics

• November 28: Pre-Audit Team Meeting - 9:30 - 11:30

• Review Audit Plan

• Review 10 CFR 50.69 IDP

• Discuss specific regional areas of focus

• November 28: Pre-IDP Meeting - 2 PM - 5 PM

• Review IDP process

• Review SNC draft 50.69 procedures

• Review select SNC 50.69 process items

• November 29: IDP Meeting - 8:30 AM - 3:30 PM

• The NRC staff will only observe and will not participate in the IDP discussions Deliverable The NRC staff will provide feedback on November 28 and after the IDP meeting on November 29. No conclusions or findings will be made based in the observations during the audit.

An audit report will be developed within 60 days of completion of the audit. The report will describe the process as observed and any observations regarding the consistency of the process with regulatory guidance.

The information in the audit reports may be used to identify information that should be placed on the docket in support of the up-coming license amendment request.