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

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

Risk Characterization - Vogtle submittal 3 5 Risk Contributors NEI-00-04 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

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

Is a standard needed for characterization? At least three utilities have used NEI-00-04/RG 1.201 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)

NEI-00-04 Categorization TOC

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 50.49 (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 50.65 (Maintenance Rule) 10CFR50.72 (notification requirements) 10CFR50.73 (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)

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 37060 (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, 50.55a, 50.65 (Maintenance Rule)

Summary PRA Models have a Standard Categorization process in NEI-00-04 for 50.69 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”