PRA and Its Role in U'S' Regulation: Status, Trends and Prospects

1
PRA and Its Role in U.S. RegulationStatus,
Trends and Prospects

• Tony Pietrangelo
• Senior Director, Risk Regulation
• October 28, 2003

2
Overview

• Guiding Principles
• Successful Voluntary Applications
• Involuntary Applications
• Current Initiatives
• Purpose, Schedule, Cost/Benefit
• Challenges
• Conclusions

3
Guiding Principles

• Use risk insights to
• Improve the safety focus of the regulatory
  process
• Reduce unnecessary regulatory burden
• Use performance-based approaches to
• Provide more objective regulatory oversight
• Provide licensees with greater flexibility to
  determine how to implement requirements

4
Successful Voluntary Applications

• Containment integrated leak rate testing
• Appendix J, Option B (industry-wide, 1995)
• One time extension to 15 years (30 units, 2002)
• In-Service Inspection (Over 80 units, 1998)
• Reduced RCS weld exams and person-rem exposure
• Technical Specifications
• Individual AOT extensions (industry-wide, 1998)
• No shutdown for missed surveillance (85 units,
  2001)
• Increased startup flexibility (expect wide
  adoption, 2003)

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Involuntary Applications

• Maintenance Rule
• Categorization (1996)
• Configuration risk management (1999)
• Reactor Oversight Program
• Significance determination process (2000)
• Future performance indicators (MSPI - 2004/5)
• License Amendments
• NRC staff may raise risk issues (2001)
• e.g., license renewal (SAMA), power uprates

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Current Initiatives

• Proposed 10 CFR 50.69, Scope of Special Treatment
  Requirements
• 10 CFR 50 Technical Requirements
• 10 CFR 50.46 ECCS Requirements
• Redefinition of LBLOCA
• Uncoupling LOOP/LOCA
• Technical Specifications

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10 CFR 50.69Purpose/Schedule

• Purpose
• Categorize SSCs using risk-informed process
• Improve safety focus and reduce burden with
  implementation of special treatment requirements
• Schedule
• Proposed rule comment period complete
• Final rule in mid to late 2004

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10 CFR 50.69Cost/Benefit

• Costs
• Demonstrate PRA technical adequacy to ASME
  standard
• Implementation Categorization/Programs
• Benefits
• QA, EQ, Seismic Qualification, Maintenance Rule,
  Reporting, ISI/IST, Type B/C Leakage Testing
• Reduction in green inspection findings
• Basis for future application to scope reductions
  in tech specs, license renewal, and new plants

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10 CFR 50 Technical RequirementsPurpose/Schedule

• Purpose
• Enhance safety focus and reduce compliance burden
  with extreme design basis assumptions
• Schedule
• Proposed rule redefining LBLOCA due March 04
• Proposed rule uncoupling LOOP/LOCA due July 04
• Final rules two years from now

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10 CFR 50 Technical RequirementsCost/Benefits

• Costs
• Develop technical bases
• PRA Adequacy (need for full scope model?)
• Plant and program changes
• Benefits
• Greater operational flexibility/margin
• Reduced compliance costs (e.g., PWR sumps)
• Fuel and power performance enhancements

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Technical SpecificationsPurpose/Schedule

• Purpose
• Harmonize tech specs with risk management program
• Attain greater operational flexibility
• Schedule
• Initiatives on end states and support system
  impacts complete within 1 year
• Risk-informed surveillance within 2 years
• Broad risk-informed allowed outage times in 2 to
  3 years

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Technical SpecificationsCost/Benefits

• Costs
• PRA technical adequacy (probably most challenging
  application)
• Benefits
• Comprehensive, integrated risk management
• Eliminate need for most NOEDs
• Fewer forced shutdowns
• Reduced outage durations

13
Challenges

• Demonstration of PRA technical adequacy
• ASME Level I PRA standard
• Industry peer review process
• NRC Regulatory Guide
• Need for full scope PRA model?
• Cost/Benefit of applications
• Change management

14
Conclusions

• Successful completion of 10 CFR 50.69 rulemaking
  is critical to future risk initiatives
• Involuntary applications will drive need to
  maintain and improve risk analyses
• Marginal additional investment in PRA needed to
  pursue voluntary initiatives
• Useful tool for enhancing plant safety and safety
  culture
• Risk-informed, performance-based regulation may
  be critical to viability of new plants