Delivering Risk Informed Engineering Programs (50.69) The OG Plan RMSC / SEE December 2016

Purpose of Presentation Understand PWROG efforts in place for 50.69 Understand PWROG plan to deliver 50.69 to members Members should be able to communicate this presentation to their sites – and help incorporate PWROG effort into their own plans

What is 10 CFR 50.69? 50.69 provides an option to reduce regulatory burden via risk-informing to make plants more cost-effective and provide flexibility to refocus resources on areas that matter.   NEI 00-04 provides the guidance.

How is the PWROG Involved? Delivering the Nuclear Promise Risk Informed Operations NEI 50.69 Task Force The PWROG’s Top Priority Moving into 2017+ is to align to Deliver the Nuclear Promise. PWROG Generic Implementation via RMSC/SEE

How is the PWROG Involved? OG’s provided support for the NEI LAR Template OG’s helping craft NEI 16-09 (50.69 Guidance) Overall OG program being designed to accommodate industry effort The OG’s have been working in the background since early 2016 to ensure coordinated, industry effort

Annual Expected Savings for 1 Unit for 1 system – Justify Industry Costs and Savings to Sites Cost Range to Implement 50.69 for 1 System - $50,000 - $300,000 Total Cost Range to Generically Categorize a System (~40% of effort generic + site costs) - $21,000 - $124,000 Annual Expected Savings for 1 Unit for 1 system – $29,000 - $176,000 $ based on APS estimates

Why is the PWROG the Best Route for 50.69? Network to Ensure Consistency – Improves Efficiency Categorization Alternate Treatments Common Industry databases Cost Savings Beyond 50.69 Itself Generic categorization via OG avoids duplicate individual site work Each system ~650 hours Strength in numbers to support licensees during inspections The PWROG removes the duplicative nature of the work – doing it once for all

Suggested Industry Group Swim Lanes Industry Guidance Industry Coordination Resolution of Generic Issues NEI Detailed Implementation Guidance Implementation Tools (Categorization Database, Dissemination of OE OG Alternate Treatments New Categorization Approaches (e.g. passive cat.) EPRI Time

PWROG Generic Implementation Identification of Low Risk Systems (PA-RMSC-1477) Pilot Generic Categorization of Containment Spray (PA-RMSC-1516) Generic Categorization for Industry Site Implementation / Incorporation Coordinate between PWROG (RMSC, SEE), NEI, BWROG

Incorporating PWROG 50.69 Work Containment Spray (pilot) Radiation Monitor NSSS What Systems Can Sites Plan OG to Cover? Plant Specific Systems Cooling Water BOP What Systems Should Sites Factor into their Workload Start Planning Now

Efforts Combine for Efficient 50.69 Implementation PWROG Effort Complements and Plugs Into Ongoing Work at Site Site 50.69 Work OG 50.69 Work Efforts Combine for Efficient 50.69 Implementation OG work does not duplicate site work…

RMSC/SEE Project Authorization Plan Overview

Technical Inputs Risk Characterization System Functions Definition PRA model required for Internal Events (including Internal Flood) PRA or Qualitative Assessment for remaining hazard groups System Functions Definition UFSAR Design Basis Documents Master Equipment List Maintenance Rule Program System Functions Categorization PRA model driven – from mapped components Qualitative Assessment

1 Industry Tool (PA-RMSC-1515) Vendor Tools Utility Tools 1 Industry Tool (PA-RMSC-1515) The Industry is Best Served with 1 Tool for Generic Categorization Multiple categorization databases are in progress…we need to combine efforts For a 50.69 WIN. The PWROG (in coordination with the BWROG)has the infrastructure to coordinate 1 tool for the industry.

The Next Steps for 50.69 in the PWROG OG Steps PAs for generic cat. Expected in Winter 2016/2017 Continued coordination with NEI Maintain timeline for sites to implement OG 50.69 products Member’s Steps Members need to reinforce this info packet to site management Coordinate site 50.69 effort with PWROG effort Prepare to approve 50.69 PAs in Winter 2016/2017 Ready teams at site to respond to PA-RMSC-1477 surveys in Winter/Spring 2017