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RESOLUTION OF GENERIC SAFETY ISSUE 191

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Presentation on theme: "RESOLUTION OF GENERIC SAFETY ISSUE 191"— Presentation transcript:

1 RESOLUTION OF GENERIC SAFETY ISSUE 191
NRC Perspectives on GSI 191 Closure Process Jack R. Davis Deputy Director, Division of Safety Systems U.S. Nuclear Regulatory Commission NEI PWR Sump Performance Workshop, October 18-19, 2012

2 RESOLUTION OF GENERIC SAFETY ISSUE 191
BASES FOR CLOSEOUT PROCESS SECY Reflects Industry commitments Considers availability of guidance Considers final licensing basis LICENSEE 12/31/12 LETTERS TO THE NRC NEI 5/4/12 letter on recommended actions for closure NEI 3/5/12 letter on Defense-in-Depth ESTABLISHED NRC PROCESSES

3 RESOLUTION OF GENERIC SAFETY ISSUE 191
EXPECTATIONS FOR 12/31/12 LICENSEES LETTERS TO THE NRC DISCUSS CLOSEOUT PLANS Which option from SECY will be pursued Schedule for completion DISCUSS SAFETY CASE Completed modifications that improve plant performance Mitigative measures that will be in place until all analyses, modifications, and regulatory issues have been completed DISCUSS COMMITMENTS Previous commitments New commitments

4 RESOLUTION OF GENERIC SAFETY ISSUE 191
ESTABLISHED NRC PROCESSES NRC GENERIC LETTER PROCESS NRC standard docketing process Open and frequent communication NRC REGULATORY GUIDES/INDUSTRY GUIDANCE NRC RG 1.174, 1.82, etc. NEI 04-07, WCAP (in-vessel), March 08’ strainer testing guidance, etc. GUIDANCE STILL IN DEVELOPMENT By-pass testing Boron precipitation? Water quality? Review process?

5 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 1 RESOLUTION PATH “CLEAN PLANT CRITERIA” CLOSEOUT PLANT SPECIFIC TESTING CLOSEOUT Licensees complete strainer evaluation Respond to any outstanding RAIs on strainer Complete testing if necessary Licensees complete in-vessel evaluation Staff issues safety evaluation on WCAP-16793 Licensees demonstrate compliance with WCAP

6 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 1 RESOLUTION PATH AND SCHEDULE LICENSEE PATH FORWARD SUBMITTAL: 12/31/12 LICENSEE DETAILED SUBMITTAL 6/30/13 (NO TESTING) 9/30/13 (ADDITIONAL TESTING) STAFF CLOSEOUT LETTER (ASSUMING NO RAIs) 12/2013 PLANT MODIFICATIONS First RFO after 1/1/13, complete planning and scoping Second RFO after 1/1/13, complete modifications INSPECTION AND CLOSEOUT UFSAR UPDATE 10 CFR 50.71(e) defines schedule

7 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 1 ADDITIONAL CONSIDERATIONS (OPTIONAL) LICENSEE IMPLEMENTS TS PROGRAM Program developed through TSTF process Licensee adopt via license amendment, 10 CFR 50.90 (OPTIONAL) LICENSEE ADOPTS FUTURE DEVELOPMENTS Margin improvement 10 CFR 50.59

8 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 2 RESOLUTION PATH DETERMINISTIC CLOSEOUT RISK-INFORMED CLOSEOUT MITIGATIVE MEASURES Staff reviews plant-specific measures for acceptability NEI letter dated March 5, 2012 RAIs if necessary Acknowledgement letter June 2013 (no RAIs) Staff informs Commission of results of review

9 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 2 DETERMINISTIC PATH REFINEMENTS TO GSI-191 METHODS Strainer evaluation refinements In-Vessel refinements PWROG program RE: August 22, 2012, meeting Schedule for completion summer 2014 STAFF REVIEWS REFINEMENTS In-vessel review scheduled for summer 2015 If found acceptable, licensees perform any needed plant-specific analyses and testing INSPECTION AND CLOSEOUT UFSAR UPDATE

10 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 2 DETERMINISTIC PATH SCHEDULE LICENSEE PATH FORWARD SUBMITTAL: 12/31/12 STAFF EVALUATES MEASURES: 6/30/13 LICENSEE FINAL SUBMITTAL: SUMMER 2015 STAFF CLOSEOUT LETTER (ASSUMING NO RAIs) 12/2015 PLANT MODIFICATIONS First RFO after 1/1/13, complete measurements to support analyses and modification planning Third RFO after 1/1/13, complete modifications INSPECTION UFSAR UPDATE 10 CFR 50.71(e) defines schedule

11 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 2 RISK-INFORMED PATH SOUTH TEXAS RISK-INFORMED SUBMITTAL 12/2012 License Amendment Request Exemption from 10 CFR based on RG 1.174 STAFF REVIEW SUBMITTAL 12/2014 OTHER INTERESTED LICENSEES Meet with Staff to discuss plans for testing and analyses to support risk-informed approach, 2013 Perform testing and analyses by 2nd RFO after 1/1/2013 Submit within 1 year of South Texas review, 2015 STAFF REVIEW (1 YEAR) STAFF ISSUES CLOSEOUT LETTER LICENSEE UPDATES UFSAR

12 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 2 RISK-INFORMED PATH SCHEDULE LICENSEE PATH FORWARD SUBMITTAL: 12/31/12 STAFF EVALUATES MEASURES: 6/30/13 SOUTH TEXAS Risk-informed submittal: 12/2012 Staff review: 12/2014 Plant modifications: 1st RFO after approval OTHER LICENSEES 1st RFO after 1/1/13, complete measurements to support analyses and modification planning 2nd RFO after 1/1/13, complete testing and analyses 1st RFO after approval, complete modifications INSPECTION UFSAR UPDATE

13 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 3 PATH LICENSEE ADOPT MITIGATIVE MEASURES (AS OPTION 2) For in-vessel LICENSEE COMPLETE DETERMINISTIC STRAINER EVALUATION (AS OPTION 1) “Clean Plant” or plant-specific testing Licensee submit strainer evaluation information Staff evaluate strainer evaluation information Schedule consistent with Option 1 OR Refer to Staff “No Further Questions” letter

14 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 3 PATH (CONTINUED) PILOT APPLICATION Industry and Staff identify pilot application(s), 12/2013 Develop pilot application(s), 6/2015 Review pilot application(s), 6/2016 OTHER INTERESTED LICENSEES DEVELOP RISK-INFORMED IN-VESSEL EVALUATION Meet with Staff to discuss plans for testing and analyses to support risk-informed approach, 12/2015 Perform testing and analyses to support approach Submit within 1 year of pilot review, 6/2017 STAFF REVIEW (1 YEAR) STAFF ISSUES CLOSEOUT LETTER LICENSEE UPDATES UFSAR

15 RESOLUTION OF GENERIC SAFETY ISSUE 191
OPTION 3 PATH SCHEDULE LICENSEE PATH FORWARD SUBMITTAL: 12/31/12 STAFF EVALUATES MEASURES: 6/30/13 PILOT PLANTS Submittal: 6/2015 Staff review: 6/2016 Plant modifications: 1st RFO after approval OTHER LICENSEES Submittal Staff review 1st RFO after approval, complete modifications INSPECTION UFSAR UPDATE

16 RESOLUTION OF GENERIC SAFETY ISSUE 191
SUMMARY SECY PROVIDES SIGNIFICANT FLEXIBILITY PARALLEL NRC REVIEWS LIMITED RESOURCES COMMUNICATIONS AND INTERACTIONS ESSENTIAL

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