Westinghouse Owners Group Risk-Informed Repair and Replacement Implementation of 10 CFR 50.69 Twelfth International

1. Westinghouse Owners Group Risk-Informed Repair and Replacement – Implementation of 10 CFR 50.69Twelfth International Conference on Nuclear EngineeringArlington, Virginia, USA 26 April 2004 Jason BrownWestinghouse Electric Company LLC

2. 2 Presentation Outline What is 10 CFR 50.69? What is the Westinghouse Owners Group §50.69 Program? What are the program benefits? What are the lessons learned?

3. 3 Proposed 10 CFR 50.69 Rule Title 10 of The Code of Federal Regulations, Part 50, Section 69 Permits licensees to reduce special treatment requirements for safety related components that are determined to be low safety significant Provides high level requirements for categorization process (details on next slide) Provides high level treatment requirements for low safety significant, safety-related components Design control, procurement, corrective action, and maintenance, inspection, testing, and surveillance Requires final categorization to be approved by plant-appointed Integrated Decision-making Panel

4. 4 NRC Proposed §50.69 Risk-Informed Safety Classifications (RISC)

5. 5 Overview of Categorization Process Robust categorization process outlined in NEI 00-04, Final Draft, “10 CFR 50.69 SSC Categorization Guideline”, April 2004 PRA screening for risk insights Fire/Seismic/Shutdown/Other External Events Defense in Depth Safety Margins Other plant operations related deterministic considerations Categorization results verified by plant personnel as part of Integrated Decision-making Panel

6. 6 Westinghouse Owners Group (WOG) §50.69 Program Use the industry guidance and proposed §50.69 rule to categorize two systems for two WOG pilot plants (Wolf Creek and Surry Unit 1) Support NRC review of WOG Topical Report for each pilot plant related to the use of the new §50.69 process Develop high level treatment requirements related to the use of the new §50.69 process Develop WOG submittal template and implementation guidance for use by WOG members in plant-specific applications of §50.69 Support industry activities to influence §50.69 rule language development, regulatory guidance and standard review plans

7. 7 Status of WOG §50.69 Program First Wolf Creek Integrated Decision-making Panel (IDP) – December 2003 Second Wolf Creek IDP – May 2004 Surry IDP – July 2004 Wolf Creek Regulatory Submittal – June 2004 Surry Regulatory Submittal – October 2004

8. 8 Benefits of WOG §50.69 Program Resolution of generic regulatory issues related to the use of NEI 00-04 and ASME Code Case N-660 October 2003 version of NEI 00-04 revised and resubmitted to NRC in April 2004 based on trial use at one plant ASME Code Case N-660 being revised based on trial use at one plant Development of guidance for defining treatment changes Equipment qualification, seismic, etc. Definition of required submittal content for using §50.69 Development of an implementation guide (including training) to assure consistency for WOG member implementation of §50.69

9. 9 Benefits of WOG §50.69 Program, continued Demonstration of the plant benefits associated with implementation of §50.69 Procurement, repair & replacement, inservice inspection/testing, equipment qualification, quality assurance, Maintenance Rule, etc. Generic cost-benefit performed for 2002 WOG §50.69 demonstration program - ~$1.5 Million annual savings per plant Generic cost-benefit validated at another plant – similar findings

10. 10 Lessons Learned from WOG §50.69 Program Importance of a robust categorization process, culminating with the Integrated Decision-making Panel Documentation, guidance, and training Expectations and requirements of NRC submittal Encouraged by NRC comment resolution as reported at February meeting with the Advisory Committee on Reactor Safeguards Good reason to proceed with pilot plant effort Cost-benefit of §50.69 implementation remains intact Still more benefits to be achieved through continuation of WOG program