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

1

May 11, 2017

2

Newton’s Third Law

For e

• r ever

ery action, y action, ther there is an e is an equa equal and l and oppo

• pposite r

site react eaction. ion.

Action: Quantity and quality of operating experience increases Reaction: Properly applied do’s and don’ts decrease risks

3

Goal

To pr

• provide incen

vide incentiv tives f es for

• r

licensee licensees to implement s to implement saf safety up ety upgrades ades o

• ver 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

• r oper
• perating

ting lif lifetimes. etimes.

4

Real Goal

To

• pr

provide incen vide incentiv tives f es for

• r

licensee licensees to s to implement implement saf safety up ety upgrades ades o

• ver 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

• r oper
• perating

ting lif lifetimes. etimes.

5

What to Avoid

Non Non-vette etted an d and/or d/or unr unregula gulated ted volunta

• luntary saf

y safety ety mar margin gin in investme estments must n nts must not

• t

subs substitute titute for

• r 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 a public all ha ll have a stak e a stake in e in nuc nuclear lear saf safety

• ety. No stak

. No stakeholde eholder r shou should be e ld be excluded. luded.

6

Safety Margin Bank

Safety Margin Balance Operating Lifetime

1 2 3

Margin Established by Regulatory Requirements Margin Provided by Voluntary Safety Margin Investments

Reactor Y Reactor X

7

Safety Margin Investments

Examp Examples of les of v volunta

• luntary 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

• oms at

t Indian Indian Point

• int
• ins

installing talling auto automa matic tic react eactor

• r trip w

trip when hen ground

• und

motion motion near nears s SSE SSE le level el

• installing

installing filter filter on

• n 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 NPSHR, , elimina eliminating ting need need for co

• r containment

ntainment

• ver

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

8

Potential Incentives

It c It could b

• uld be ea

e easier f sier for

• r React

eactor

• r Y

than than React eactor

• r 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

• r

longer longer LCOs 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
• btain an e

an exemptio emption/w n/wai aiver er fr from a new

• m a new

regula gulator tory y requir equirement ement

9

Questions

Ho How a w are values e values of

• f v

volunta

• luntary

y saf safety mar 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

• tects a

ts against gainst saf safety ety mar margin ba gin bank being nk being over erdr drawn? awn?

10

Safety Margin Investment Appraisals

Value c alue could b

• uld be dete

e determined mined (SAMA (SAMA pr proces

• cess templa

s template?) te?) when “loan” is arranged. Licensee could identify “extra” mar margin gin to b to be used e used as colla as collater teral. al. NRC could verify that “extra” mar margin gin exists and t xists and tha hat t it it

• f
• ffsets

fsets requeste equested need d need.

11

Regulatory Oversight

May a May alr lready eady be esta be established blished (e.g., 50 (e.g., 50.69 ame .69 amendmen ndment) t) and and thus thus mer merel ely susta y sustained ined Other Otherwise, c wise, could b

• uld be se

e set by the t by the terms of “loan” (i.e., NRC inspec inspection p tion proced

• cedur

ures x es x, y , y, , and and z and/or z and/or commitmen commitments) ts)

12

Regulatory Oversight

Supp Suppose

• se Plant Y

Plant Y has insta has installed lled seismic automa seismic automatic tic react eactor

• r trip

trip and and wants ants to to rel ely on tha y on that t in investme estment to nt to obta

• btain lon

in longer ger time to time to e evalua valuate a te a new new seismic seismic hazar hazard. d. Licens Licensee c ee could c

• uld commit
• mmit to L

to LCO CO, , Action Actions, sur s, surveillances, etc eillances, etc. . compa comparable ble to o to other ther t trip rip function functions. s.

13

Overdraft Protection

Each “loan” application could identify identify all cur all current ent outs

• utstand

tanding ing “loans.” Before approving the “loan,” NR NRC could v C could verify tha erify that it will t it will n not

• t

mor more th e than e an empty mpty the the saf safety ety mar margin gin bank bank.

14

Safety Margin Banking

Decades of Decades of ope

• perating

ting exper xperience ience and and alr already eady pr proven en pr proces

• cesses (

ses (e.g., e.g., NOEDs, NOEDs, SDP SDP , , SAMA, etc SAMA, etc.) co .) could uld supp suppor

• rt the

t the means means to ince 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

• r regula

gulator tory y complianc compliance. e.

15

Subsequent Safety Margin Banking

After After the the saf safety ety mar margin gin bank banking ing pr process has been de

• cess has been developed

eloped and and road

• ad-teste

tested d a f a few ew year ears, s, it it might might be time t be time to e

• 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.