1. Plant Vogtle 1&2 10 CFR 50.69 Pilot Program NESCC Meeting
November 3, 2014

2. Agenda Vogtle Risk Categorization 50.69 Discussion Topics
Why haven’t more utilities submitted 50.69?
Is a Standard needed for the Categorization Process?
Is a Standard needed for the Special Treatment Process?
Summary/Questions

3. Risk Characterization - Vogtle submittal3
5 Risk Contributors
NEI requires peer-reviewed IE PRA
Internal
Events Risk
Fire
Risk
Seismic
Risk
Other External Events Risk
Shutdown
Risk
Internal Events (including Internal Flooding)
PRA
Fire
PRA
Seismic PRA
Other External Events PRA
Shutdown PRA
Updated Seismic Margin Analysis
Updated IPEEE Screening
S/D DID Model via EOOS
FIVE

4. Why haven’t other utilities submitted?
Utilities did not have infrastructure when rule made effective (November 2004)
Significant investment required for risk models and characterization
Industry concerned NRC would regulate Special Treatment through inspection
SNC believes this will change with a successful pilot

5. Is a standard needed for characterization?
At least three utilities have used NEI-00-04/RG to categorize
Guidance turned into detailed process & procedures
NRC has reviewed procedures and witnessed IDP meetings
STP has categorized over 100 systems
NRC SER expected soon for Vogtle pilot
Model adequacy
Characterization process
Extensive industry experience categorizing components
Maintenance Rule
AP-913 (Equipment Reliability)

6. NEI-00-04 Categorization TOC

7. Regulatory Requirements that No Longer Apply per 10CFR50.69
10CFR50.69 eliminates the following requirements for components designated as RISC-3 (low risk, safety-related):
10CFR50, Appendix B (quality requirements)
10CFR Part 21 (deficiency reporting requirements)
10CFR (Testing, documentation, and margin requirements for EQ purposes)
10CFR50.55(e) (event reporting)
10CFR 50.55a(f), (g) & (h) (Applicable portions of ASME & IEEE codes and standards)
10CFR (Maintenance Rule)
10CFR (notification requirements)
10CFR (licensee event reports)
Portions of 10CFR50, Appendix J (primary reactor containment leakage testing)
Portions of Appendix A to 10CFR Part 100 (Seismic qualification with respect to extent of testing and types of analyses)

8. Is a standard needed for Special treatment?
Rule does not prescribe special treatments
Rule is performance-based
Reasonable assurance vs. reasonable confidence
Extensive industry comments on IP (draft)
Inspections should be performance-based, not prescriptive
Draft IP in 2012 incorporated many industry comments
Industry has developed guidance on treatment
EPRI Special Treatment Guidance (2007), plus Environmental Qualification & Seismic
SNC developing treatment procedures for 10 CFR 50 App. B, App. J, a, (Maintenance Rule)

9. Summary PRA Models have a Standard
Categorization process in NEI for is similar to other risk-informed initiatives
Maintenance Rule
RI In-Service Inspection
Surveillance Frequency Control Program
Risk Prioritization – Cumulative Impacts
Guidance available for Special Treatments
Performance-based rule
Flexibility desired to define “reasonable assurance”