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1 UNITED STATES NUCLEAR REGULATORY COMMISSION … · MEAG Cole Lindell SNC Jack Woodard'1) Farley...

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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
Transcript
  • 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


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