Enabling Safety Upgrades That Reduce Risk David Lochbaum Director, - PowerPoint PPT Presentation

Enabling Safety Upgrades That Reduce Risk David Lochbaum Director, Nuclear Safety Project www.ucsusa.org May 11, 2017 1

Newton’s Third Law For e or ever ery action, y action, ther there is an e is an equal and equa l and oppo opposite r site react eaction. ion. Action: Quantity and Reaction: Properly quality of operating applied do’s and don’ts experience increases decrease risks 2

Goal To pr o provide incen vide incentiv tives f es for or licensees to implement licensee s to implement saf safety up ety upgrades ades o over and er and abo bove minim e minimal r al regula gulator tory y requir equirement ements s suc such tha h that t safety ca saf ety can impr n improve during e during react eactor or oper operating ting lif lifetimes. etimes. 3

Real Goal To o pr provide incen vide incentiv tives f es for or licensees to licensee s to implement implement saf safety up ety upgrades ades o over and er and abo bove minim e minimal r al regula gulator tory y requir equirement ements s suc such tha h that t saf safety ca ety can impr n improve during e during react eactor or oper operating ting lif lifetimes. etimes. 4

What to Avoid Non Non-vette etted an d and/or d/or unr unregula gulated ted volunta oluntary saf y safety ety mar margin gin in investme estments must n nts must not ot subs substitute titute for or complianc compliance e with with regula gulator tory y requir equirement ements. s. The NR he NRC, its l , its license icensees and t es and the he public all ha public a ll have a stak e a stake in e in nuc nuclear lear saf safety ety. No stak . No stakeholde eholder r should be e shou ld be excluded. luded. 5

Safety Margin Bank Safety Margin Balance 3 Reactor Y 2 Margin Provided by Voluntary Safety Margin Investments 1 Reactor X Margin Established by Regulatory Requirements Operating Lifetime 6

Safety Margin Investments Examp Examples of les of v volunta oluntary saf y safety ety mar margins in gins investme estments inc nts include: lude: • installing installing flood flood alar alarms ms in s in switc witchge hgear ar rooms ooms at t Indian Indian Point oint • ins installing talling auto automa matic tic react eactor or trip w trip when hen ground ound motion motion near nears s SSE SSE le level el • installing installing filter filter on on BWR BWR Mar Mark k I/I I/II I containment containment vent ent pa path th • replacing eplacing ECCS ECCS pumps pumps with ones with ones ha having ving lo lower er NPSH NPSH R , , elimina eliminating ting need need for co or containment ntainment over erpr pres essur sure e cr credit edit • pr providing viding N+3 N+3 ca capa pabilities bilities in F in FLEX LEX • adopting adopting 50.69 50.69 risk ca risk cate tegoriza gorizatio tion 7

Potential Incentives It c It could b ould be ea e easier f sier for or React eactor or Y than than React eactor or X to: to: • get get mor more e time to time to implement implement measur measures es manda mandate ted d by NR by NRC • get get license license amendme amendment nt requests equests appr pproved ed for or longer LCOs longer COs and and sur surveillan eillance ce test r test reductions eductions • receiv eceive e grea eater ter discr discretion etion in NOE in NOED D space space • have quicker “reset” of greater -th than an-gree een n findings findings in R in ROP space OP space • obtain obtain an e an exemptio emption/w n/wai aiver er fr from a new om a new regula gulator tory y requir equirement ement 8

Questions Ho How a w are values e values of of v volunta oluntary y safety mar saf ety margin gin in investme estments nts appr ppraised? aised? W When? hen? By By whom? hom? Wha hat r t regula gulator tory y over ersight sight applies during “loans” from the saf safety mar ety margin gin bank bank? Wha hat pr t protec otects a ts against gainst saf safety ety mar margin ba gin bank being nk being over erdr drawn? awn? 9

Safety Margin Investment Appraisals Value c alue could b ould be dete e determined mined (SAMA (SAMA pr proces ocess templa s template?) te?) when “loan” is arranged. Licensee could identify “extra” margin mar gin to b to be used e used as colla as collater teral. al. NRC could verify that “extra” margin mar gin exists and t xists and tha hat t it it offsets of fsets requeste equested need d need. 10

Regulatory Oversight May a May alr lready eady be esta be established blished (e.g., 50.69 ame (e.g., 50 .69 amendmen ndment) t) and and thus thus mer merel ely susta y sustained ined Otherwise, c Other wise, could b ould be se e set by the t by the terms of “loan” (i.e., NRC inspec inspection p tion proced ocedur ures x es x, y , y, , and and z and/or commitmen z and/or commitments) ts) 11

Regulatory Oversight Supp Suppose ose Plant Y Plant Y has insta has installed lled seismic automa seismic automatic tic react eactor or trip trip and wants and ants to to rel ely on tha y on that t in investme estment to nt to obta obtain lon in longer ger time to e time to evalua valuate a te a new new seismic seismic hazar hazard. d. Licens Licensee c ee could c ould commit ommit to L to LCO CO, , Action Actions, sur s, surveillances, etc eillances, etc. . compa comparable ble to o to other ther t trip rip functions. function s. 12

Overdraft Protection Each “loan” application could identify identify all cur all current ent outs outstand tanding ing “loans.” Before approving the “loan,” NR NRC could v C could verify tha erify that it will t it will n not ot mor more th e than e an empty mpty the the saf safety ety mar margin gin bank bank. 13

Safety Margin Banking Decades of Decades of ope operating ting exper xperience ience and and alr already eady pr proven en proces pr ocesses ( ses (e.g., e.g., NOEDs, NOEDs, SDP SDP , , SAMA, etc SAMA, etc.) co .) could uld supp suppor ort the t the means to ince means to incentiviz ntivize licens e licensees ees to mak to make saf e safety mar ety margin gin in investme estments o nts over and er and a abo bove e thos those need e needed ed for or regula gulator tory y compliance. complianc e. 14

Subsequent Safety Margin Banking After After the the saf safety ety mar margin gin bank banking ing pr process has been de ocess has been developed eloped and and road oad-teste tested d a f a few ew year ears, s, it it might might be time t be time to e o examine xamine whether “loans” could also be used used to of to offset fset non non-co complian mpliance ces s with with regula gulator tory y requir equirement ements. s. 15