Lessons Learned While Pursuing the 10 CFR 50.69 Project at Vogtle Electric Generating Plant

10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, is a voluntary regulation that allows nuclear power plants to categorize structures, systems and components (SSCs) according to their risk-informed safety significance and then adjust the treatment applied to these SSCs commensurate with their safety significance. 10 CFR 50.69 allows the reduction of many special treatment requirements for safety related SSCs that have been categorized as low safety significant in accordance with an approved methodology. Conversely, SSCs that are non safety related but categorized as safety significant are required to be evaluated for additional controls to ensure that they can perform their safety significant functions. 10CFR 50.69 does not alter the design requirements and safety classification of any categorized component. The intent of 50.69 is to allow increased focus and resources to be applied to safety significant SSCs while allowing increased flexibility for items with low safety significance. The expected result of applying this methodology is that nuclear safety is increased while allowing the reliable and cost-effective operation of the power plant. To date, none of the utilities in the USA have fully implemented 10 CFR 50.69 since it became effective. Two plants, Wolf Creek and Surry, completed categorization of select systems. However, they never submitted a License Amendment Request (LAR). With increased focus on risk-informed regulation, NRC is interested in seeing to see a utility implement 50.69. The Vogtle Electric Generating Plant (VEGP) initiated the “50.69 Project” at the beginning of 2011. The ultimate goal is to seek approval from NRC (via license amendment) to fully implement 10 CFR 50.69. The project has three high level milestones — prepare and submit LAR; NRC review and approval; and implement 10 CFR 50.69. VEGP applied for the pilot status on December 6, 2010, and received it on June 17, 2011. This paper outlines lessons learned and challenges faced year-to-date while performing engineering work to achieve the first milestone. The lessons learned can be used by any licensees interested in pursuing 10 CFR 50.69 at their sites before starting the 50.69 project.