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Westinghouse Owners Group Risk-Informed Repair and Replacement – Implementation of 10 CFR 50.69 Twelfth International Conference on Nuclear Engineering Arlington, Virginia, USA 26 April 2004 Jason Brown Westinghouse Electric Company LLC. Presentation Outline. What is 10 CFR 50.69?

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  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. 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. 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. NRC Proposed §50.69 Risk-Informed Safety Classifications (RISC) Safety-Related Nonsafety-Related Robust Categorization Process Safety Significant RISC-1 RISC-2 Not Categorized as Safety Significant RISC-3 RISC-4

  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. 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. 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. 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. 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. 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

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