1. Westinghouse Owners Group Risk-Informed Repair and Replacement – Implementation of 10 CFR Twelfth International Conference on Nuclear Engineering Arlington, Virginia, USA 26 April Jason Brown Westinghouse Electric Company LLC

2. Presentation Outline What is 10 CFR 50.69?
What is the Westinghouse Owners Group §50.69 Program?
What are the program benefits?
What are the lessons learned?

3. Proposed 10 CFR Rule
Title 10 of The Code of Federal Regulations, Part 50, Section 69
Permits licensees to reduce special treatment requirements for safety related components that are determined to be low safety significant
Provides high level requirements for categorization process (details on next slide)
Provides high level treatment requirements for low safety significant, safety-related components
Design control, procurement, corrective action, and maintenance, inspection, testing, and surveillance
Requires final categorization to be approved by plant-appointed Integrated Decision-making Panel

4. NRC Proposed §50.69 Risk-Informed Safety Classifications (RISC)
Safety-Related
Nonsafety-Related
Robust Categorization Process
Safety
Significant
RISC-1
RISC-2
Not Categorized
as Safety
Significant
RISC-3
RISC-4

5. Overview of Categorization Process
Robust categorization process outlined in NEI 00-04, Final Draft, “10 CFR SSC Categorization Guideline”, April 2004
PRA screening for risk insights
Fire/Seismic/Shutdown/Other External Events
Defense in Depth
Safety Margins
Other plant operations related deterministic considerations
Categorization results verified by plant personnel as part of Integrated Decision-making Panel

6. Westinghouse Owners Group (WOG) §50.69 Program
Use the industry guidance and proposed §50.69 rule to categorize two systems for two WOG pilot plants (Wolf Creek and Surry Unit 1)
Support NRC review of WOG Topical Report for each pilot plant related to the use of the new §50.69 process
Develop high level treatment requirements related to the use of the new §50.69 process
Develop WOG submittal template and implementation guidance for use by WOG members in plant-specific applications of §50.69
Support industry activities to influence §50.69 rule language development, regulatory guidance and standard review plans

7. Status of WOG §50.69 Program
First Wolf Creek Integrated Decision-making Panel (IDP) – December 2003
Second Wolf Creek IDP – May 2004
Surry IDP – July 2004
Wolf Creek Regulatory Submittal – June 2004
Surry Regulatory Submittal – October 2004

8. Benefits of WOG §50.69 Program
Resolution of generic regulatory issues related to the use of NEI and ASME Code Case N-660
October 2003 version of NEI revised and resubmitted to NRC in April 2004 based on trial use at one plant
ASME Code Case N-660 being revised based on trial use at one plant
Development of guidance for defining treatment changes
Equipment qualification, seismic, etc.
Definition of required submittal content for using §50.69
Development of an implementation guide (including training) to assure consistency for WOG member implementation of §50.69

9. Benefits of WOG §50.69 Program, continued
Demonstration of the plant benefits associated with implementation of §50.69
Procurement, repair & replacement, inservice inspection/testing, equipment qualification, quality assurance, Maintenance Rule, etc.
Generic cost-benefit performed for 2002 WOG §50.69 demonstration program - ~$1.5 Million annual savings per plant
Generic cost-benefit validated at another plant – similar findings

10. Lessons Learned from WOG §50.69 Program
Importance of a robust categorization process, culminating with the Integrated Decision-making Panel
Documentation, guidance, and training
Expectations and requirements of NRC submittal
Encouraged by NRC comment resolution as reported at February meeting with the Advisory Committee on Reactor Safeguards
Good reason to proceed with pilot plant effort
Cost-benefit of §50.69 implementation remains intact
Still more benefits to be achieved through continuation of WOG program