I nis form Is to be tilled out (typed or hand-printed) by the person who announced the meeting (i.e., the person who issued the meeting notice). The completed form, and the attached copy of meeting handout materials, will be sent to the Document Control Desk on the same day of the meeting; under no circumstances will this be done later than the working day after the meeting. Do not include proprietary materials.
The attached document(s), which was/were handed out in this meeting, is/are to be placed in the public domain as soon as possible. The minutes of the meeting will be issued in the near future. Following are administrative details regarding this meeting:
Docket Number(s)
Plant/Facility Name-50 - 2Z5
TAC Number(s) (if available)
Reference Meeting Notice
Purpose of Meeting (copy from meeting notice)
~~A~fl-j[ I"LY1V S&oOAL A
NAME OF PERSON WHO ISSUED MEETING NOTICE TITLE
OFFICE
DIVISION
BRANCH
Distribution of this form and attachments: Docket File/Central File PUBLIC D 6o
NRC FORM 658 (9-1999) PRINTED ON RECYCLED PAPER This form was designed using InForms
NRC&ARM 658 -U.S. NUCLEAR REGULATORY COMMISSION 1 UNITED STATES
0• NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
• '- TRANSMITTAL OF MEETING HANDOUT MATERIALS FOR "IMMEDIATE PLACEMENT IN THE PUBLIC DOMAIN
50( - IA )-so
-( K ý -~ ~ ~ ~ • N I C , r P - oTHJo N c _ p ? f l --ý
AGENDA
SNC Licensing Workshop
November 3-4, 1999
Birmingham, AL
November 3rd
8:00 - 8:30
8:30 - 9:00
9:00 - 9:45
9:45 - 10:00
10:00- 11:30
11:30 - 12:30
12:30 - 1:00
1:00- 1:45
1:45 - 2:30
2:30 - 3:00
3:00 - 3:15
3:15 - 4:15
4:15 - 4:30
Introduction/Orientation
Deregulation Impact on SNC
NOEDs : Y2K and Weather Related
Break
Regulatory Issues: Design Bases (SNC), 10 CFR 50.59 (NRC), and FSAR (SNC)
Lunch
ADAMS
Licensing Processes -NRC Perspective - Office Letter 803 - RAI's
Licensing Processes - SNC Perspective
Attributes of a Good Relief Request
Break
Attributes of a Good Submittal Breakout
Summary/Conclusions Breakout
Jack Woodard Herb Berkow
Louis Long
Herb Berkow
All
Ben George Lenny Olshan Don Crowe
Ramin Assa
Ramin Assa
Mark Ajluni Jim Bailey Don Crowe
Mark Padovan
All
All
NRC-NRR-SNC Licensing Workshop11/02/99
AGENDA (Continued)
SNC Licensing Workshop
November 3-4, 1999
Birmingham, AL
November 4th
8:00 - 9:15
9:15 - 9:30
9:30- 10:00
10:00 - 10:30
10:30- 11:00
11:00
Critique Licensing Submittals Breakout
Summary/Conclusions from Breakout
PRA Models and Applications
Reinvention (Role of Project Manager)
Workshop Conclusions and Closing Comments
End of Workshop
All
All
Bill Bums
Rich Emch
Herb Berkow Don Crowe
NRC-NRR-SNC Licensing Workshop 11/02/99
SNC Licensing Workshop
November 3-4, 1999
Birmingham, AL
List of Attendees
NRC
Herb Berkow, NRR Ramin Assa Rich Emch Lenny Olshan Mark Padovan Len Wiens
MEAG
Cole Lindell
SNC
Jack Woodard'1)
Farley
Mark Ajluni Ed Carmack Phil Crone Mike Eidson Bonnie Goodwin Richard Hill(2) Howard Mahan Doug McKinney Wes Sparkman
Hatch
Lewis Sumner(2) Jeff Branum(3 ) Don Crowe Dean Drinkard') Mark Friedman John Lontine Ira Luker Les Mikulecky°
1 )
Sharon Palm Cindy Tully Ozzie Vidal(3) Jim Wade(') Glenn Warren Dennis Zabala°')
Bamie Beasley(2) Jim Bailey Skip Kitchens(2) Joe Leamon Medhi Sheibani Jack Stringfellow Lewis Ward Brian Whitley
Technical Services
Louis Long(3) Bill Bums(3) Ben George John Giddens(3) Ken McCracken(]) Tom Milton
Notes: ( Part time attendance including lunch. (2) Lunch only. (3) Part time no lunch.
NRCNRR and SNC Licensing Workshop
November 3 - 4, 1999
DeregulationImpact on SNC
SOUTHERN o COMPANY
Energy to Serve Your World"
NRCNRR & SNC Licensing Workshop
41 SOUTHERNAM
COMPANY Energy to Serve Your Werid"
• Introduction Second level
Third level - Fourth level
») Fifth level
NRCNRR & SNC Workshop 2
SOUTHERNA4 COMPANY
NRCNRR & SNC Licensing Workshop 'Yor! d
Deregulation Impact on SNC Characteristics of a Traditional Utility
"* Monopolies in their service territory
"* Captive customers
"* Regulated profits (price)
"* Capital intensive
"* Long life assets
NRCNRR & SNC Workshop 3
NRCNRR & SNC Licensing Workshop
SOUTHERN k COMPANY
Enerp to Serve Your Wr/t
* Deregulation Impact on SNC * Traditional Utility Process
GROWTHE..ORECAST
NEW CONSTRfUCTION PI LANS
RAISE Th-PITAL
_AR ADJUST RATES
NRCNRR & SNC Workshop 4
SOUTHERNAM'k COMPANY
NRCNRR & SNC Licensing Workshop ""'emr' to Srv
"* Deregulation Impact on SNC
"* Characteristics of a Competitive Utility "* No service territory
"* No captive customers-free to shop around
* No regulation
"* Market driven price
"* Capital intensive
"* Long life assets
NRCNRR & SNC Workshop 5
NRCNRR & SNC Licensing Workshop
SOUTHERN'.I4 COMPANY
Energy to Serve Your World
• Deregulation Impact on SNC
* Cost of Service
NRCNRR & SNC Workshop 6
NRCNRR & SNC Licensing Workshop
SOUTHERN £k COMPANY
Energy to Serve Your Wkrld
* Deregulation Impact on SNC
* New Utility Model•Main Driver-Maximizing the Wealth of the Stockholder
Earnings Per Share
NRCNRR & SNC Workshop
m
7
SOUTHERN',A COMPANY
NRCNRR & SNC Licensing Workshop nerg7 to Serve Your Work
* Deregulation Impact on SNC * Typical Deregulation Scenario14
12
10
8
6
4
2
0
�1
IMPrice]
1 2 3 4 5 6 7 NRCNRR & SNC Workshop
m
9
NRCNRR & SNC Licensing Workshop
SOUTHERN 54 COMPANY
Energy to Serve Your World
• Deregulation Impact on SNC • Southern Cost Goal
1994 Cents/kwh
2003 Cents/kwh
Capital O&M Fuel
NRCNRR & SNC Workshop
2.46 1.77 1.48
5.71 5.41
9
NRCNRR & SNC Licensing Workshop I
SOUTHERN A COMFPNY
Energy to Serv eYor W'orkt
* Deregulation Impact on SNC * How Do Get There?
"* Increase off-peak sales
"* Cut fuel costs
"* Cut O&M- $550M
"* Cut capital - Write off assets
- Accelerate depreciation
- Refinance debt - Purchase power capacity if cheaper than building
NRCNRR & SNC Workshop
m
10
NRCNRR & SNC Licensing Workshop
k SOUTHERNAU£ COMPANY
Enherg to Serve IYur World'
* Deregulation Impact on SNC Southern Company Strategy
"* BAG-Best utility investment
"* Major issues - Growth
- Maximizing value of regulated business
- Natural gas business
- International business
NRCNRR & SNC \;Workshop
m
I1I
NRCNRR & SNC Licensing Workshop
SOUTHERNAZL COMPANY
Energy to Serve Your ,rI'r
• Deregulation Impact on SNC "* Strategy Review
" Core returns of14% vs 11%
"* Top 10 in electric and gas marketing
"* Expanded internationally-30% of earnings by 2000
"* Why Review?
NRCNRR & SNC Workshop
I
12
NRCNRR & SNC Licensing Workshop
SOUTHERNA COMPANY
Energy to Serve Your World
• Deregulation Impact on SNC BAG Vs Performance
* Best Investment TSR= g + d
* 64 of 84 Utilities in TSR for 1995-97
* 35 of 88 Utilities in TSR for 1998
NRCNRR & SNC Workshop
r-
13
NRCNRR & SNC Licensing Workshop
SOUTHERNA.a COMPANY
Energy to Serve Your W•rd'T
* Deregulation Impact on SNC Expand Growth
m Southeast (Now 32,000MW) - Add 5600MW by 2002 for wholesale and retail mkts.
m North America- Add 20,000MW in next 5 years serving the wholesale market
- Northeast
- Midwest
- Texas/Louisiana
- California
NRCNRR & SNC Workshop 14
NRCNRR & SNC Licensing Workshop
k SOUTHERNA COMPANY
Energy to Serve Your ,Wrl/t
* Deregulation Impact on SNC* Sharpen International Focus
m Asia
m Europe
m Brazil
NRCNRR & SNC Workshop
m
15
SOUTHERN Z COMPANY
NRCNRR & SNC Licensing Workshop Env,,,to Srme Y Pr Wo rld
Deregulation Impact on SNC Anticipated Impact of Strategy Shift
"* EPS of 1.85 in 1999 EPS of 2.00 in 2000
" Beyond 2000 EPS growth of 6-8% to achieve the BAG as Best Utility Investment
"* Double the generation in the Southern Company over the next 5-6 years
NRCNRR & SNC Workshop 16
SOUTHERNA L COMPANY
NRCNRR & SNC Licensing Workshop Efl°rA*Y to
• Deregulation Impact on SNC
• SNC Response * Contractor & Overtime Reductione Attrition: 3530-3064 (92-98)
o Outage Length Reduction
o Capacity Factor Improvements
o Power Uprates
o Process Improvements
o Human Performance FocusNRCNRR & SNC Workshop 17
NRCNRR & SNC LicensingWorkshop
SOUTHERN 'I COMPANY
Energy to Serve Your WorIdF
• Deregulation Impact on SNC * Impact of $20 Unplanned Outage
Net Income Shares
EPS
$977M 697M
$1.40
$957M 697M
$1.37
NRCNRR & SNC Workshop
m
18
NRCNRR & SNC Licensing Workshop
SOUTHERN R,4 COMPANY
Energyro Serve IY'urWorldc
• Deregulation Impact on SNC
* SNC Response * Contractor & Overtime Reductione Attrition: 3530-3064 (92-98)
"* Outage Length Reduction
"* Capacity Factor Improvements
"* Power Uprates
"* Process Improvements
"* Human Performance FocusNRCNRR & SNC Workshop 19
NRCNRR & SNC Licensing Workshop
SOUTHERN A COMPANY
Energy to Serve Your World'
. Deregulation Impact on * SNC Production Costs
SNC
1998 1.7Cents/kwh
FI Other
0 Fuel MO&MI
1994 1995 1996 1997 1998
NRCNRR & SNC Workshop 20
NRCNRR & SNC Licensing Workshop
SOUTHERN COMPANY
Energy o Serve Your World'
* Deregulation Impact on SNC* SNC Total Costs
Add Capital Cost .5-3 Cents/kwh
Market Price= 2.7 Cents/kwh
NRCNRR & SNC Workshop 21
NRCNRR & SNC Licensing Workshop
SOUTHERN A4 COMPANY
Energy to Serve Your W•rld-
• Deregulation Impact on SNC Impact of Increased O&M on Earnings
N Fuel E] Taxes
EM Depr.
IM Cost of Debt
* O&M
M] Profit
NRCNRR & SNC Workshop
m
22
I
I
i
I
NRCNRR & SNC Licensing Workshop
4A SOUTHERNSLia COMPANY
Fnerg to Serept You r •Rrl
• Deregulation Impact on SNC * Continuous Improvement
" Safety
"* Cost
"* Reliability
NRCNRR & SNC Workshop 23
Y2K-RELATED NOED CONTINGENCIES
Herb Berkow, Project Director Division of Licensing Project
Management
POLICY
* NRC HAS AMENDED ITS ENFORCEMENT POLICY - APPENDIX E
*THE INTERIM POLICY IS EFFECTIVE AUG. 30, 1999 UNTIL JAN. 1, 2001.
BASIS FOR THE INTERIM ENFORCEMENT POLICY
* DESPITE LICENSEES' EFFORTS, NUCLEAR FACILITIES MAY BE SUSCEPTIBLE TO Y2K-RELATED EVENTS NECESSITATING EITHER SHUTDOWN OR GRANTING OF AN NOED
* CASCADING, OR EVEN LOCALIZED POWER OUTAGES COULD HAVE SERIOUS SHORT-AND LONG-TERM CONSEQUENCES.
*CONTINUED SAFE OPERATION OF NUCLEAR PLANTS DURING Y2K KEY DATES MAY BE NECESSARY FOR MAINTAINING GRID STABILITY
CRITERIA FOR EXERCISE OF ENFORCEMENT DISCRETION:
-(A) COMPLYING WITH LICENSE CONDITIONS WOULD REQUIRE A PLANT SHUTDOWN, AND
-(B) CONTINUED PLANT OPERATION IS NEEDED TO MAINTAIN A RELIABLE AND STABLE GRID; AND
* (C) ANY DECREASE IN PLANT SAFETY IS ACCEPTABLY SMALL, AND
*(D) REASONABLE ASSURANCE OF PUBLIC HEALTH AND SAFETY IS MAINTAINED WITH THE GRANTING OF AN NOED
NRC Y2K NOED CONTINGENCY PLAN
" THE HEADQUARTERS EMERGENCY OPERATIONS CENTER WILL BE ACTIVATED
"* REGION IV INCIDENT RESPONSE CENTER WILL SERVE AS BACK UP
m*AUGMENTED STAFF DURING Y2K ROLLOVER PERIOD
-AT THE NRC HEADQUARTERS OPERATIONS CENTER AND REGIONAL INCIDENT RESPONSE CENTERS
* NOED TEAM STAFFING
-APPROPRIATE SENIOR LEVEL MANAGERS AND TECHNICAL STAFF WITH AUTHORITY TO GRANT VERBAL NOED APPROVAL.
PROCESS
"* FOLLOW THE EXISTING NOED GUIDANCE TO THE MAXIMUM EXTENT PRACTICABLE, AND
"* CONTACT NRC EARLY, EVEN IF COMPLETE INFORMATION IS NOT AVAILABLE.
" CONTACT, IN ORDER OF PREFERENCE:
-THE NRC HEADQUARTERS OPERATIONS CENTER
- REGION IV INCIDENT RESPONSE CENTER - OTHER REGIONAL INCIDENT RESPONSE
CENTERS.
* PROVIDE WRITTEN, OR ORAL JUSTIFICATION FOLLOWED BY WRITTEN JUSTIFICATION.
* PROVIDE A FACSIMILE OF APPLICABLE TS PAGES
SOME IMPORTANT POINTS
"* PLAN AHEAD. COMPLETE ALL SCHEDULED ACTIVITIES WELL AHEAD OF Y2K ROLLOVER DATES.
"* ENGAGE NRC EARLY IF NOED IS REQUIRED.
"* PRIOR COMMUNICATION WITH NRC AND STAFF APPROVAL ARE REQUIRED FOR CONTINUED PLANT OPERATION.
"* WITHOUT NRC APPROVAL, TAKE ACTIONS IN CONFORMANCE WITH TS AND REGULATIONS [E.G., 10 CFR 50.54(X), IF NECESSARY].
"* ON HIGH VOLUME OF REQUESTS, THE NRC MAY PERFORM ONLY AN INITIAL SAFETY ASSESSMENT. UNLESS ASSESSMENT IS UNFAVORABLE, PROCEED WITH THE PLANNED COURSE OF ACTION.
"* NOED REQUESTS WILL BE PRIORITIZED BASED ON SAFETY SIGNIFICANCE , AOT, OPERABILITY OF OTHER SYSTEMS, COMPENSATORY MEASURES, GRID STABILITY AND RELIABILITY.
SEVERE WEATHER/NATURAL EVENT NOEDS
* HISTORY & EVOLUTION
CURRENT GUIDANCE & PRACTICE
government or responsible independent entity makes assessment that need for power and overall public health & safety considerations constitute an emergency situation
staff must balance public health & safety implications with potential radiological risks
risks must be acceptably small
EXAMPLES 4 granted
WEATHER-RELATED VS. "REGULAR" NOED compliance issue vs. degraded or inoperable component/system
NRCNRR and SNC Licensing Workshop
November 3 -.4, 1999
10 CFR50.2 DesignBases
SOUTH ERN .rq COMPANYEneriy to Serve 'i~ur World'm
SOUTHERN A5 COMPANY
NRCNRR & SNC Licensing Workshop Fner*v to Serve
10 CFR 50.2 Design Bases e Objective
" Common understanding of "design bases" that: - Provides a definitive scope of the 10 CFR 50.2 definition
- Provides proper characterization of design issues that may arise in the field
- Supports UFSAR updates [IOCFR50.34(b)]
- Supports 10 CFR 50.59 implementation (Criterion vii & viii)
"* Reportability issue resolved with prop6sed rule changes to 1OCFR50.72 and 50.73
- Design defect or deviation reportable only if safety function of SSC compromised
NRCNRR & SNC Workshop 2
SOUTHERNA A COMPANY
NRCNRR & SNC Licensing Workshop F,.,,, Seroe •* ur Wor
10 CFR 50.2 Design Bases 10 CFR 50.2 Definition
n Design bases means that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design.
m These values may be (1) restraints derived from generally accepted "state of the art" practices for achieving functional goals, or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals.
NRCNRR & SNC Workshop
3
SOUTHERN A£ COMPANY
NRCNRR & SNC Licensing Workshop o . '•u Wrk
10 CFR 50.2 Design Bases Final Safety Analysis Report
10 CFR 50.34(b) - "The FSAR shall include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole."
NRCNRR & SNC Workshop
4
Page 5
Relationship of Licensing Basis,. Design Basis
and Operating Basis
Current Licensing
Basis
Original Licensing
BasisrC
Ope~r~atin --- .6 is
8urrent Lic. di~rginal Lic. V e.Dein i IBasis I Basis 11 Bases
1Orig. LB +- O.L.ISRefct I- Updated FSAR 'I - Tech Specs ' Functional Crit. 'II
I II I -Iomtens -FIIFntonlRq *Letters ii - QA-Plan Controlling 11 I* GL, Bulein - E-Plan If Parameters 11
I * NV, LE 'I -S-Pla - Bounding Valus - New 1 OCFR (1QOCFR5O.34) i -SERs II (1 OCFR5O.2) 'I
- -II - - - IL - - - - 1- - - - - -II
OpEraigW niern Bai ' e. ai
Re'd I Basiseerin Oprtn R..133 11 upotn
- Proc D e'sign Info - Surv I11 - Testing I - Etc.
- ---- - - - - - - - -- - - - ---I
I
I
Regulatory Engineering Design Design Basis Bases
1* 1
i
p-, I ý ý %ý ý.,% % %Iklýi " - - - - - I -- -U-
i
- - - - - - - - - -- ý I - - - - - - - - - - *
-IBM-
I
SOUTHERNAM' COMPANY
NRCNRR & SNC Licensing"Workshop R "'e Your % ro'
10 CFR 50.2 Design Bases Design Bases Interpretation Background * NUMARC 90-12 (Design Bases Program Guidelines) * NUREG-1397 (Assessment of Design Control
Practices and Design Reconstitution Programs) * 1992 Commission Policy Statement (Availability
and Adequacy of Design Bases Information) * Millstone Lessons Learned
- NRC A/E inspections - October 1996 10 CFR 50.54(f) letter
NRCNRR & SNC Workshop 6
SOUTHERNAI, COMPANY NRCNRR & SNC Licensing Workshop CMFPANYvr ,o,,
10 CFR 50.2 Design Bases Industry Guidance
"* November 1997 submittal of NEI 97-04, Design Bases Program Guidelines (update of NUMARC 90-12), sought NRC focus on interpretation issue
"* Revised Appendix B of NEI 97-04 to provide framework guidance
"* Formatted to highlight the basis in the regulations for 10 CFR 50.2 design bases functional requirements
"* Examples of supporting design information provided to highlight distinction from 10 CFR 50.2 design bases
NRCNRR & SNC Workshop 7
SOUTHERNA COMPANY NRCNRR & SNC Licensing Workshop Energy"o Srve
10 CFR 50.2 Design Bases Basic Principles (NEI 97-04, Appendix B)
General guidance: - Design bases functions: (1) Functions required to meet
regulations, license conditions, orders or technical specification, or (2) functions credited in safety analyses to meet NRC requirements
- Design bases values: Values or ranges of values of controlling parameters established by NRC requirement, established or confirmed by safety analyses, or chosen by the licensee from an applicable code, standard or guidance document as reference bounds for design to meet design bases functions requirements
NRCNRR & SNC Workshop 8
w4 SOUTHERNAL COMPANY
NRCNRR & SNC Licensing Workshop 1,,r 1,o Serve T d'
10 CFR 50.2 Design Bases Basic Principles (NEI 97-04, Appendix B)
Specific guidance: - 10 CFR 50.2 design bases include the bounding
conditions for which SSCs are required to function - The 10 CFR 50.2 design bases of a facility are a subset
of the licensing basis and are required to be included in the updated FSAR
- Underlying 10 CFR 50.2 design bases is substantial supporting design information
NRCNRR & SNC Workshop 9
NRCNRR & SNC Licensing Workshop
SOUTHERNAA£. COMPANY
Energy to Serve Your Wrld'
• 10 CFR 50.2 Design Bases Relationships (NEI 97-04, Appendix B)
"• -art 5 requirements "* Appendix B " 10 CFR 50.59 "- UFSAR "* NRC Commitments
and licensing basis
m Design Basis Documents s Topical Requirements (e.g., m SSC Design Requirements m Individual SSC functions m Design Inputs
NRCNRR & SNC Workshop
EQ, seismic)
m
10
SOUTHERN L' COMPANY
NRCNRR & SNC Licensing Workshop nergy to ServeYr'
10 CFR 50.2 Design Bases Examples (NEI 97-04, Appendix B)
" BWR Containment
"* Auxiliary Feedwater System "* Emergency Diesel Generator "* Containment Isolation MOV "* Turbine Generator
"* Topical Design Bases - Single failure criterion
- Seismic & Tornado
NRCNRR & SNC Workshop
SOUTHERNAM COMPANY
NRCNRR & SNC Licensing Workshop gv to Serve Your Worl,
10 CFR 50.2 Design Bases Status " Revised NEI 97-04, Appendix B, provided to NRC
week of October 25th - Reflects significant interactions with NRC - Developed with NEI task force assistance
"* NRC on a course to endorse the industry guidance - Working to resolve remaining few issues - Draft regulatory guide due to Commission mid November
NRCNRR & SNC Workshop 12
Schedule * Final Rule issued in Federal Register on
October 4, 1999 * NEI will submit NEI 96-07, Rev. I "Guidelines
for 10 CFR 50.59 Evaluations" to the NRC by the end of the year
* NRC Regulatory Guide to be issued in the later Summer of 2000
* Implementation is 90 days after issuance of Regulatory Guide
I
2
Major Changes
"* Removal of reference to "Unreviewed Safety Question"
"* Term "Safety Evaluation" is changed to "10 CFR 50.59 Evaluation"
"* Added Definitions of "change" and "facility as described in the final safety analysis (as updated)"
Major Changes (continued)
"* Will allow for minimal changes, without requiring prior NRC approval
"* Changed "Probability" statement to "Increase in frequency" or "likelihood of occurrence"
"* Malfunction of a different type is being replaced with "malfunction with a different result"
i
I
3
Major Changes (continued)
Margin of Safety Evaluation Criteria is being replaced with 2 new criteria. "* Criteria (vii) - Evaluation of integrity of
fission product barriers "* Criteria (viii) - Changes to approved
evaluation methods
TImpacts and Benefits " Impacts:
"* Will require major revision to 50.59 procedure
"* Will require new training standards to be developed
" Benefits: m Overall improvement over previous rule
language m Agreed upon Industry/NRC Guidance
I
NRCNRR and SNC Licensing Workshop
November 3 - 4, 1999
UFSAR
SOUTHERN
gOMPAiN Entergy to Se'rve Yiour MCortd'°
IMPORTANT UFSAR DATES
SOUTHERN 'A4 COMPANY
Fnergy to Serve Your WorliF
March 30, 2000 - Exercise of discretions for violations involving
risk significant items of UFSAR
March 30, 2001 - Exercise of discretions for violations involving all
other items concerning UFSAR ACCURACY
and COMPLETENESS
NRCNRR & SNC Workshop 2
SOUTHERN k COMPANY
SOME BASIC UFSAR ISSUES Etr t eveYu Wrd
Purpose of UFSAR Definition of Design Basis (Scope of 50.59) Content of UFSAR
* Level of detail
* Removal of information * Format
* Accuracy * "Historical" information * Addressing generic letters and bulletins
Descriptive material
CLB versus UFSAR Limits of operations Temporary modifications
* Incorporation by reference
NRCNRR & SNC Porkshop 3
w4 SOUTHERNA5 COMPANY
MODIFYING THE UPDATED UFSAR EnServeSYoeiuirýorldf
"o Historical information
"o Removing excessive detail
"o Referencing
NRCNRR & SNC Workshop 4
DEFINITION OF ADAMS
The policies, processes, and software tools to manage unclassified, official program and administrative records of lasting business value to the NRC in an electronic rather than paper based environment.
ADAMS will not contain historical documents.
2
A GENCYWIDE DOCUMENT MANA GEMENT & A CCESS SYSTEM
(ADAMS) EL ECTR ONIC INFORMA TION
EXCHANGE (EIE)
NRC/SNC WORKSHOP November 1999 Ramin Assa, PE
IMPORTANCE OF ADAMS (CONT.)
* Will make public documents available to the public via the Internet
* Submittals to the NRC can be in Electronic form via the Internet (in lieu of paper)
IMPORTANCE OF ADAMS
* the NRC will achieve productivity gains with its use
* It will improve communication within the NRC and with licensees and other stakeholders
3
I
WHAT WILL ADAMS •.. ;::(CONT.)
Searching through reams of paper
o NRC's public information dissemination program as we know it today
Retrieve full text and images of documents from electronic repository
LPDR's will eventually be replaced by the NRC website
7
S
BENEFITS OF ADAMS
"o Opportunity to re-engineer work "o Improved integrity of information "[ Faster, broader access to documents at every
employee's desktop o] Streamlined concurrence; improved tracking o Security/access control down to the
document level
CHANGE
I IMPLEMENTATION STRATEGY
ol There will be a phased deployment of users and system capabilities that has begun and will continue through the early part of 2000
10
BENEFITS OF ADAMS (CONT.)
"E Eventual elimination of hard copy requirements
"i Documents available much faster
"El Reduced Information Management costs
EIE WILL BE ACCOMPLISHED IN 4. VARIOUS WAYS
"* Web based forms for submittals (if less than 2 MB)
"* CD's or other media "* Preferred forms and formats will be
PDF normal PDF Word perfect MS Word
12
ELECTRONIC SUBMITTALS
ELECTRONIC INFORMATION EXCHANGE (EIE)
11
CONCEPT OF OPERATIONS "FOR EIE
"[ Submitter to the NRC Will register to become an electronic trading partner with the NRC
"c After acceptance as an EIE trading partner "* Will contact the NRC Web site
"* Pull up the NRC submittal form "* Fill out the header information as required by
the form
" Attach the submittal 4
ELECTRONIC INFORMATION _________EXCHANGE
EIE WILL BE
VOLUNTARY
13
Electronic Information Exchange
CONCEPT OF OPERATIONS FOR EIE (CONT.)
o Digitally sign the document, if necessary, by ". clicking on the prompt
". entering his or her identifier
"* completing a notification E-mail address if other than central processing
* And clicking on the submit button
16
'D =act
4.. IMPACT OF EIE (CONT.) [ The impact on NRC staff will be
minimal. The only requirement will be the use of an additional passcode to digitally sign documents.
18
I IMPACT OF EIF o The impact on the licensees should be
minimal as the NRC will provide the software and instructions for the EIE process. The only requirement will be for each submitter to register to receive a digital signature passcode.
17
SIGNIFICANT DATES
El Fall 99 • Administrative letter issued to allow Part
50 c!Cctronic submiddis and the reduction of required hard copy submittals to 1 copy
El Fall 99 * Final process and procedures developed for
agency wide implementation of EIE
20
IMPLEMENTATION OF EIE
El Implement 10 CFR Part 50 electronic submittal process with reduced hard copy requirement through the issuance of an administrative letter.
El Implement agency wide electronic submittal process in lieu of hard copy through a rulemaking process
19
4/ SIGNIFICANT EIE DATES (CONT.) oApril/July 2000
- Rule Change to allow Agency wide electronic submittals in lieu of hard copy
21
FY 1999 NRR PERFORMANCE STATISTICS
LICENSING ACTIONS (TACS)
Inventory:
Completions:
EOFY98 - 1113 EOFY99 - 857 (goal 1000) EOFYOO - -750
1727 vs. FY 99 goal of 1670 1465 incoming vs. 1400 goal
FY99 Actual FY99 Goal
86% < 1 yr., 80% < 1 yr.,
100% < 2 yrs. 95% < 2 yrs., 100% < 3 yrs.
OTHER LICENSING ACTIVITIES (TACS)
Inventory:
Completions:
Age:
EOFY99 - 1044 (no goal)
939 vs. FY 99 goal of 800
FY 99 Actual (No Goal)
40.7% < 1 yr., 58% < 2 yrs. 85.7% < 3 yrs., 14.3% > 3 yrs.
TIAs (TACS)
Inventory: EOFY 98 EOFY 99
87 32
3 > 2 yrs. 4> 1 yr.
75% < 6 mos. (goal not met)
Age:
Age Goal
Office Letter 803
Ramin Assa, PE
NRC/SNC Licensing Workshop
November 1999
11/3/99
4
Amendment Process Start
I
11/3/99
2
Initial Processing
* Amendments "* Acceptance review "* Work planning "* Prioritization
Acceptance Review .~ ... ......
"* Oath & affirmation, State copy "* Clear description of change "* Safety analysis and justification "* NSHC and EA (or exclusion) "* Approval and implementation schedules "* Is it risk-informed?
3
11/3/99
3
Work Planning
PM (and technical staff) "* Search for precedents "* Review method (PM, tech staff, etc.) "* Scope & depth of review "* Resource planning and schedule "* Priority
Priority
* Priority 1 "* Highly risk-significant safety concern
"* Issue involving plant shutdown, derate, or restart
* Priority 2 "* Significant safety issue "* Support continued safe plant operations
"* Risk-informed licensing action "* Topical report with near-term or significant safety
benefit
5
11/3/99
4
Priority (continued)
* Priority 3 "* Moderate to low safety significance "* Cost beneficial licensing actions "* Generic issue or multi-plant action "* Topical report with limited benefit
NSHC Determination
" NSHC Based on 50.92 (51 FR 7751) "* Significant increase in probability or
consequences of an accident "* Possible new or different accident "* Significant reduction in margin of safety
"* If proposed NSHC, hearing can be after amendment
"* If SHC or no determination, any hearing would precede amendment
11/3/99
5
* Environmental Impact Statements (EISs) and EAs based on 51.20 to 51.22 "* EISs very rare "* Amendment EA exclusions in 51.22 "* Most amendments meet the exclusions
"* EA must be published in the Federal Register before the amendment is issued
Noticing
"* "Normal" amendments, 50.91(a)(2) "* Bi-weekly or individual Federal Register notices
30 day comment period
"* Notice of proposed amendment, proposed NSHC, hearing opportunity
"* Notice of issuance
* If a proposed NSHC determination is not made, use individual notices * Can't be handled as an exigent or emergency
9
11/3/99
6
Noticing - Exigent amendment
* Notice in Federal Register (FR) if amendment is to be issued after 15 days but before 30 days "* Individual FR notice "* Repeat in bi-weekly FR notice
"- Notice in local media if amendment is to be issued after 6 days but before 15 days - Repeat in bi-weekly FR notice
"* Amendments require a final NSHC determination
10
Noticing - emergency amendment
* Emergency amendments noticed after issuance for comment and an opportunity for hearing
11
Review Process And Documents Preparation "* Review process
"* Precedents "* Requests for additional information (RAIs) "* Regulatory commitments
"* Document preparation "* Safety evaluation "* Concurrence review "* Amendment issuance
13
11/3/99
4 Reviewer Assignments * Reviews can be performed by PM or
technical staff, considerations include: " Technical complexity & risk significance "* PM technical expertise "* Conformance to improved Standard
Technical Specifications (iSTS) guidance "* Conformance to precedents "* Resource availability & schedule needs
12
7
11/3/99
8
Review Process And ,,,ocuments Preparation
Precedents Ensure request meets current expectations "* Format "* Guidance to industry
"* Technical content
14
Review Process And Documents Preparation
* Requests for additional information "* Staff goal: 1 RAI per reviewing technical
branch "* Notify the licensee
"* Discuss questions "* Resolve minor issues "* Establish reasonable response date "* Document conversation on cover letter
"* Questions should state Regulatory Basis
'5
11/3/99
9
\ Commitments
* Regulatory commitments are information relied on by the staff in making its conclusion but are not included in the technical specifications.
* Current staff practice outlined in SECY-98224, NRC guidance on commitment management
16
Commitments
Hierarchy of licensing-basis information SObligations - license, TS, rules, orders
, Mandated Licensing-Basis Information - UFSAR, QA/security/emergency plans
SRegulatory Commitments - docketed statements agreeing or volunteering to take specific actions Non-Licensing-Basis Information
17
11/3/99
10
Commitments • !! o m i tm ~e~ ts...................................... . " Commitments stated in the safety
evaluation are considered part of the licensing basis but not are legally binding requirements
"* Safety evaluation should clearly state what actions are considered regulatory commitments
"* Control of commitments is in accordance with licensees' programs
18
Commitments * Escalation to license conditions reserved
for safety-significant matters (e.g., those that meet 10 CFR 50.36 criteria for inclusion)
* Staff is continuing to include license conditions for relocation of information to UFSAR or other controlled documents in amendment implementation condition
19
11/3/99
II
Commitments * Office Letter 900 to be issued spring
2000 "* will address NEI's revised guidance "* will include "audits" of licensee's
Commitment Management Program performed by PMs 1/3 of plants per year
20
Safety Evaluation :2!!~i, ii•.S a f . .. E v .!. .aio ......... .... .......-.............
" Routinely included "* Staff evaluation - why the request satisfies
regulatory requirements "* State consultation "* Environmental considerations
"* As needed "* Regulatory commitments "* Emergency/exigent provisions "* Final NSHC determination
21
11/3/99
12
Concurrence .... .... ... .... ... .. ...
"* Licensing Assistant - format and revised TS pages
"* Technical Branch - technical adequacy
" Technical Specifications Branch "* Significant deviations from iSTS guidance or changes
consistent with iSTS "* Use of 10 CFR 50.36 criteria
"- Office of the General Counsel * Legal defensibility and completeness
22
Amendment Issuance * Ensure that we've addressed all comments
from public and state * Transmitted to licensee via letter
- Issued after associated EA * Standard distribution (cc) list
* Notify NRC staff of licensee's organization changes to list via docketed letter
* Federal Register notice of issuance
23
Submitting Relief Requests to the NRC
Mark Padovan, NRC Farley Project Manager
10 CFR 50.55a Subjects
Subjects 10 CFR 50.55a Paragraph
Reactor Coolant Pressure 50.55a(c) Boundary
Quality Group B Components 50.55a(d)
Quality Group C Components 50.55a(e)
Inservice Testing Items 50.55a(f)
Inservice Inspection 50.55a(g) (examination) Items
Protection Systems 50.55a(h)
Methods to Use to Ask for Relief)
3.. Propose an alternative to the code requirement and show that:
the alternative provides an acceptable level of quality and safety
pursuant to 10 CFR 50.55a(a)(3)(i), or
complying with the code requirement would result in hardship or
unusual difficulty without a compensating increase in quality or
safety pursuant to 10 CFR 50.55a(a)(3)(ii).
=, Show that the code requirement is impractical (not just inconvenient)
pursuant to 10 CFR 50.55a(f)(6)(i) for inservice testing items or
50.55a(g)(6)(i) for inservice inspection (examination) items.
Note: Seeking relief from augmented reactor vessel shell weld examination specified in
10 CFR 50.55a(g)(6)(ii) is an exception to this. Utilities must propose an alternative
that would provide an acceptable level of quality and safety pursuant to 10 CFR
50.55a(g)(6)(ii)(A)(5) (rather than show that the requirement is impractical).
Methods the NRC Can Use to Authorize an Alternative orGrant Relief
" Authorize a licensee-proposed alternative in accordance with
10 CFR 50.55a(a)(3)(i) if NRC determines that the alternative
provides an acceptable level of quality and safety, or
" Authorize a licensee-proposed alternative (if any) in accordance with
10 CFR 50.55a(a)(3)(ii) if NRC determines that complying with the
specified requirement would result in hardship or unusual difficulty
without a compensating increase in the level of quality and safety, or
" Grant relief and impose alternative requirements in accordance with
10 CFR 50.55a(f)(6)(i) for inservice testing items if NRC determines
that the code requirement is impractical, or
" Grant relief and impose alternative requirements in accordance with
10 CFR 50.55a(g)(6)(i) for inservice inspection (examination) items if
NRC determines that the code requirement is impractical.
Table 1 - Relief Request Guidance
10 CFR 50.55a Section Applicable Table
S10 CFR 50.55a(a)(3)(i)
10 CFR 50.55a(a)(3)(ii)
10 CFR 50.55a(f)(6)(i)
see Table 2
see Table 3
see Table 4
10 CFR 50.55a(g)(6)(i) see Table 5
A10 CFR 50.55a(g)(6)(ii) see Table 5 iilii (A)(5) ;:•:
Pick the single, most applicable 10 CFR 50.55a section to address.
The NRC can only authorize an alternative that the utility proposes in
their written submittal. The utility must prepare another written submittal
proposing (other) alternatives if they decide or agree with the NRC to
use (other) alternatives.
ze Note:
Ew Note:
Table 2 - Authorizing a Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
Purpose Authorize a utility-proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i).
Necessary Determine if the utility-proposed alternative provides an -etermination acceptable level of quality and safety.
SIndicate the applicable Code edition and addenda, and describe the Code requirement.
SDescribe the proposed alternative and bases.
Guidance * Discuss why the proposed alternative provides an
acceptable level of quality and safety.
Specify the duration of the proposed alternative.
SDo not mention impracticality, burden, unusual difficulty or hardship.
Note: ASME Code Cases listed in the following documents are suitable for use without prior NRC approval:
+ NRC Regulatory Guide (RG) 1.84, "Design and Code Case Acceptability - ASME Section III Division 1"
* NRC RG 1.85, "Materials Code Case Acceptability - ASME Section III Division 1,"
v ,ikRCk RG 1.147, "Inservice Inspection Code Case Acceptability - ASME Section Xl Division 1"
NRC can also authorize utilities to use other Code Cases if they request this pursuant to 10 CFR 50.55a(a)(3)(i) or (a)(3)(ii).
Table 3 Authorizing a Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
Purpose
E
Guidance
Authorize a utility's proposed alternative in accordance with 10 CFR 50.55a(a)(3)(ii).
Determine if complying with the specified requirement would result in hardship or unusual difficulty (rather thai being impractical) without a compensating increase in the level of quality and safety.
For ISI items - Determine if the proposed alternative provides reasonable assurance of pressure boundary integrity.
For IST items - Determine if the proposed alternative provides reasonable assurance that the component or system is operationally ready (capable of performing its intended function).
SIndicate the applicable Code edition and addenda, and describe the Code requirement.
SDescribe the utility-proposed alternative and bases.
Discuss why complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level o quality and safety.
For IST items: Discuss why the proposed alternative provides reasonable assurance that the component or system is operationally ready.
SFor ISl items: Discuss why the proposed alternative provides reasonable assurance of pressure boundary integrity.
2& Specify the duration of the proposed alternative.
Do not mention impracticality.
Necessary )eterminations
Table 4 Inservice Testing - Granting Relief in Accordance with 10 CFR 50.55a(f)(6)(i)
Purpose Grant relief and impose alternative requirements in accordance with 10 CFR 50.55a(f)(6)(i) for inservice testing items.
Guidance
Specify the duratin, of the alterrat",.'
SD o not m e ntio n ha rdshio o r unusual difficulty .
Indicate the applicable Code edition and addenda.
SDescribe the utility's proposed alternative (if any) and bases.
2 Describe why it is impractical for the utility to comply with the specified requirement.
B- Describe the burden on the utility created by imposing the requirement (e.g., having to replace a component, redesign the system or shutdown the plant'
B Discuss why the proposed testing provides reasonable assurance that the component is operationally ready.
ew Note: 10 CFR 50.55a(f)(6)(i) allows the NRC to impose additional requirements without having the utility first commit to them. 10 CFR 50.55a(a)(3) does not allow this.
Determine if the code requirement is impractical.
Necessary Determine if the proposed testing provides reasonable )eterminations assurance that the component is operationally ready
(capable of performing its intended function).
Table 5 Inservice Inspection - Granting Relief in Accordance with 10 CFR 50.55a(g)(6)(i)
Grant relief and impose alternative requirements in Purpose accordance with 10 CFR 50.55a(g)(6)(i) for inservice
inspection (examination).
Determine if the code requirement is impractical.
Necessary Determine if the proposed inservice inspection Determinations (examination) provides reasonable assurance of
component or structure pressure boundary integrity.
SAdditional guidance in Generic Letter 90-05 "Guidance for Performing Temporary Non-code Repair of ASME Code Class 1, 2, and 3 Piping."
a Indicate the applicable Code edition and addenda, and describe the Code requirement.
SDescribe the proposed alternative (if any) and bases
, Describe why it is impractical to comply with the specified requirement.
SDescribe the burden created by imposing the requirement (e.g., having to replace a component, redesign the system or shutdown the plant).
SDescribe why the proposed inspection (examination) provides reasonable assurance of component or structure pressure boundary integrity.
SSpecify the duration of the alternative.
SDo not mention hardship or unusual difficulty.L J
Guidance
SNote: 10 CFR 50.55a(f)(6)(i) allows the NRC to impose additional requirements without having the utility first commit to them. 10 CFR 50.55a(a)(3) does not allow this.
Notes
NRCNRR and SNC Licensing Workshop
November 4, 1999
PROBABALISTIC RISK ASSESSMENT AND RISK INFORMED APPLICATIONS
SOUTHERN "
COMPANY Eneigy to Serve Your WMortd"
SOUTHERN L4 COMPANY
DISCUSSION TOPICS Ernergy torSerYur Mrld"
PRA ORGANIZATION
PRA MODELS - Evolution of methodology - Capabilities - Maintenance - Future Developments
APPLICATIONS OF PRA - Potential Applications - Experience With Applications - Potential Impediments to Risk Informed Regulation
NRCNRR & SNC Workshop 2
RISK ANALYSIS ORGANIZATIONSOUTHERN 'A4
COMPANY Energy to Srve Your World'
Numb Mr of Personnel
8 Engineers, 1 Secretary, and 1 Manager
Professional Qualifications
3 Registered Professional Engineers 3 Former Senior Reactor Operators 2 Former Nuclear Navy Qualified Persons
NRCNRR & SNC Workshop 3
SOUTHERNAM COMPANY RISK ANALYSIS ORGANIZATION Energy to ev orMrd
Educational Achievements
10 Bachelors of Science Degrees (5 Mechanical, 2 Nuclear, 1 Civil, 1 Chemical, 1 Physics)
5 Masters of Science Degrees in Nuclear Engineering 1 Masters of Business Administration 1 Doctorate Degree in Mechanical Engineering
Engineering Experience
Engineering Experience in Nuclear Field 19 years average (28 years high; 13 years low)
Experience in PRA 9 years average (18 years high; 3 years low)
NRCNRR & SNC Workshop 4
SOUTHERN RMik COMPANY
Participation in Industry Efforts ro,,•
Active Member of:
BWROG Integrated Risk Based Regulation Subcommittee
WOG Risk-Based Technology Working Group
EPRI Risk and Reliability Workstation Working Group
Chair the EPRI Modular Accident Analysis Program Users Group(MAAP)
NRCNRR ý I SNC Workshop 5
SOUTHERN A COMPANY
Energy to Serve our World"INITIAL PRA MODELS
PRAs submitted pursuant to GL 88-20 were linked event tree models
HNP-- PLG "Riskman" FNP-- Westinghouse software VNP -- Westinghouse software
Models were highly complex with numerous conditional split fractions and dependency rules
Manipulation was difficult because software was cumbersome and required a high degree of model-specific manipulation
NRCNRR & SNC Workshop 6
NEED FOR MODIFICATIONSOUTHERNZa4
COMPANY Energy to Serve our •WrWd'
A need was recognized for common software to provide for flexibility of resource utilization and depth of expertise
Much of industry product development was based on large fault tree methodology -- "Betamax in a VHS world"
Linked fault tree models are generally more readily understood by non-PRA engineers and operators
NRCNRR & SNC Workshop 7
SOUTHERN ',4 COMPANY
Energy to Serve Your Wor/ldMODEL CONVERSION
Models were converted to CAFTA Linked Fault Tree Methodology (FNP '97 VNP '98 HNP '99)
Equipment Out Of Service (EOOS) tool for monitoring plant safety has been developed for two of three plants, third is near completion
Data /IDesign updates for two of three models have been completed; update for third model is in progress
Calculational software upgraded to FORTE to increase model speed and depth of cutset capabilities
NRCNRR & SNC Workshop 8
SOUTHERN ,.k COMPANY
CAFTA Energy to Serve Your Morld
CAFTA is a PC-based fault tree analysis workstation which provides:
- A fault tree editor for building, updating and printing fault tree models;
- Reliability databases for storing basic event, failure rate and gate information used in the models;
- A choice of fault tree evaluating processors to be used to obtain model cutsets; and
- A cutset editor for reviewing and editing cutset results.
Calculates Core Damage Frequencies (CDF) and Large Early Release Frequencies (LERF)
NRCNRR & SNC Workshop 9
SOUTHERN A COMPANY
Eterg• to Serve Your horld"
EOOS is a PC-based tool for evaluating the impact of changing the plant configuration on CDF and LERF
EOOS analyzes the cutsets generated by the PRA model using either pre-generated cutsets or a direct re-quantification method
EO0S can serve personnel concerned with scheduling future
equip-Ient outages (work planning / outage planning)
EOOS can also serve personnel interested in the impact on relative risk of changes to the current plant configuration (such as operators,
engineers, and management)
NRCNRR & SNC Workshop
EOOS
10
SOUTHERNAM COMPANY EOOS CAPABILITIES E he rgy toSevYour%/4
Plant Safety Index indicates the impact of out-of-service equipment on calculated CDF / LERF
Has "What If?." capability to analyze risk significant impacts of emergent maintenance work
Can import a maintenance schedule and determine status of systems and risk significance of scheduled itemns
Can simultaneously display work activities, system status, and risk profile in the scheduler's application
Interrogative feature allows determination of cause of system unavailability, the shifting of planned work to another time period, and re-calculation of system status and risk profile
NRCNRR & SNC Workshop I1I
EOOS CAPABILITIES (continued)
SOUTHERN'A4 COMPANY
Energy to Serve Your Wr/t
Can support the development of maintenance schedule
Can support the management of emergent work with "real time" PRA calculations
Can graphically identify the status of mitigating trains, systems, and components
Can provide information to assist in prioritizing restoration of most significant out-of-service equipment
Can be tied to other plant information systems (e.g., tagging, computerized logs, etc.) through a supporting system
NRCNRR & SNC Workshop 12
SOUTHERNAM COMPANY
EOOS CAPABILITIES (continued) Etergy
Components OOS can be selected from drop down equipment tag lists, procedure lists, or simplified P&ID
Can display and report instantaneous risk as well as integrated risk over time
Can display the risk importance of items removed from service
Can display the time for which a configuration can exist prior to exceeding specified risk threshold
NRCNRR & SNC Workshop 13
SOUTHERNAL COMPANY
Energy to Serve Your World"MODEL MAINTENANCE
Routine plant modifications are reviewed for incorporation into the models after refueling outages
Significant plant modifications are incorporated into the models as soon as practical
Data related to equipment reliability, initiating events, etc. are updated approximately every three years
Model revisions are controlled by a calculation procedure
PRA software enhancements are incorporated as appropriate
NRCNRR & SNC Workshop 14
SOUTHERNAL COMPANY
FUTURE MODEL DEVELOPMENTS Eoevor•orF
Sponsoring the development of a 32-bit version of EOOS software to
enhance the speed of EOOS and a 32-bit version of SYSIMP to
enhance the performance of importance evaluations
Currently upgrading to FORTE Version 2.2 (d) quantification code
Planning, development, and implementation of a PRA model of
shutdown operation
NRCNRR & SNC Workshop 15
SOUTHERNL COMPANY POTENTIAL PRA APPLICATIONS CoMSANY
CONFIGURATION MANAGEMENT
Risk-informed "equipment-out-of-service" planning and scheduling Support maintenance rule implementation Outage risk assessment On-line maintenance support
REGULATORY AND LICENSING
Risk-informed support of technical specification amendments Risk-informed support of 10CFR50.59 Enhancement of allowed outage times and surveillance test frequencies Assess impact of findings and violations (i.e., SDPs) Assess safety significance of significant events (i.e., LERs) Assess safety significance of operability concerns including support of JCOs Identify risk significant systems for inspections and audits Support for the possibility of future risk-based technical specification
NRCNRR & SNC Workshop 16
POTENTIAL PRA APPLICATIONSSOUTHERN A',
COMPANY Enirgy to Serve Yo. ur 11r/d
TRAINING AND PROCEDURES
Provide focus on safety significant issues for training and plant drills Provide input and focus for EOPs and severe accident procedures
TESTING / SURVEILLANCE PROGRAMS
Risk-informed Risk-informed Risk-informed Risk-informed
ISI IST Appendix J testing focus for MOV and AOV testing
QUALITY AND DESIGN ISSUES
Risk-i iformed graded quality assurance Risk-iLkAiformed graded procurement Risk-i-iformed fire protection programs Priorirtze and identify safety impact of design changes
NRCNRR & SNC Workshop 17
SOUTHERNA LM COMPANY SNC APPLICATION EXPERIENCE CoMPANY
Risk analyses for initial power uprates for Plants Farley, Hatch, and Vogtle
Risk analysis for revision of Plant Vogtle's Emergency diesel
generator AOT to 14 days
Risk analysis in support of Plant Hatch's extended power uprate
Risk analysis in support of Plant Farley's appeal to eliminate the mid-cycle inspection of steam generator tubes
Risk analyses in support of maintenance rule implementation
Risk analyses in support of on-line maintenance activities
Evaluation of vulnerabilities to internal and external sources of risk
Evaluation of abnormal conditions, out of service equipment, etc
NRCNRR & SNC Workshop 18
SOUTHERN ta COMPANY
POTENTIAL IMPEDIMENTS TO RIR C5MPAd
Will a voluntary approach to RIR have a complicating impact on developing consensus positions? How will the NRC regulate under probabilistic and deterministic systems concurrently?
What's required scope, level, depth, and quality of a PRA used for RIR?
Certification?
Measures and standards for risk importance of SSCs?
SSCs not currently "safety-related" but determined to be risk significant?
How will PRA's inherent uncertainties be accommodated in RIR? Will PRA (practitioner art as well as science) stand up to uninformed public's scrutiny?
Can NRC / Industry staffs effectively and efficiently adapt to RIR?
NRCNRR & SNC Workshop 19
DIVISION OF LICENSING PROJECT MANAGEMENT
REDEFINITION PROJECT
BACKGROUND
* EMPHASIS ON LICENSING ACTIONS
* NRR REORGANIZATION OF 3/99
* OIG AUDIT, JOB TASK ANAL YSIS, ARTHUR ANDERSEN ASSESSMENT
* NEED FOR CLEAR MANAGEMENT EXPECTATIONS RE: PM FUNCTIONS! RESPONSIBILITIES
strategic plans operating plans declining resources
v DLPM IS PILOT FOR OTHER NRR DIVISIONS AND NRC OFFICES
DLPM FUNCTIONS
* LICENSING AUTHORITY
Licensing Actions Mandated Controls Other Licensing -Tasks
* INTERFACES
0 ,Licensees/Owners Groups o ,Regions • ,Headquarters o ,Public
* REGULA TORY IMPROVEMENTS
* TOTAL OF 74 SPECIFIC TASKS
EXAMPLES OF LICENSING AUTHORITY TASKS
MA NDA TED CONTROLS
* Amendments (TS & USQ)
# Exemptions # Reliefs # License Transfers # NOEDs * Lead Plant Reviews
* Bases Changes # UFSA R Reviews * 50.59 Reviews # QA, Security,
EP Reviews
OTHER
* TIAs 0 2.206s # Backfits * Plant-Specific MPAs * Commitment Management v Hearing Support
LICENSING ACTIONS
EXAMPLES OF INTERFACE TASKS
NRC REGIONS
* ROUTINE COMMUNICATIONS v SITE VISITS/DROP-INS v LEAD ON TECH ISSUES
(MPAs, GSIs, USIs)
NRC HO
* MORNING CALLS v MGMT. OVERSIGHT PANELS * ROUTINE COMMUNICATIONS * TS INTERPRETATIONS v ENFORCEMENT SUPPORT * EVENT FOLLOWUP
PUBLIC
* MGT. INFO. & STATUS REPORTS * MISC. LICENSEE REPORTS # INCIDENT RESPONSE v LIC. RENEWAL SUPPORT v GENERAL SUPPORT TO OTHER
OFFICES * SURVEYS
a CONTROLLED CORRESPONDENCE * ALLEGATIONS v FOIAs # PLANT INFO WEB PAGE SUPPORT
LICENSEES/ OWNERS GROUPS
EXAMPLES OF REGULA TOR Y IMPRO VEMENTS TASKS
s LATF * OWNERS GROUP INTERACTIONS * NRR OFFICE LETTERS * REDEFINITION EFFORT * DLPM HANDBOOK * RULEMAKING a RISK INFORMED EFFORTS * LICENSING WORKSHOPS
TASK EVALUATION
* PERFORMANCE MEASURES INCL UDE:
Timeliness Effectiveness Efficiency Quality Quantity
* TASKS PRIORITIZED WITH RESPECT TO STRATEGIC OUTCOME GOALS
00 Maintain Safety 0* Reduce Unnecessary Regulatory Burden of Increase Public Confidence of Increase Internal Efficiency &
Effectiveness
# RESOURCE ESTIMATES
STAKEHOLDER INPUT
.* PUBLIC MEETING - 7/99 Industry & Interested Members of Public
* REGIONS Meetings With Each Region
# NRR Other 4 NRR Divisions & NRR Senior Management
# NRC Cognizant Offices & NRC Senior Management