Comparison of PSR and LR for LTO regulatory process of PSR and LR for LTO regulatory process 2017....
Transcript of Comparison of PSR and LR for LTO regulatory process of PSR and LR for LTO regulatory process 2017....
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KINGS
Comparison of PSR and LR
for LTO regulatory process
Comparison of PSR and LR
for LTO regulatory process
2017. 10.
Prof. Kim, Tae-Ryong
KEPCO International Nuclear Graduate School
Prof. Hwang, IL-Soon
Seoul National University
4th International Conference on NPP Life Management 2017.10.23~27, Lyon, France
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• Periodic Safety Review (PSR) - Primary purpose : to check plant safety at 10 years interval in EU and Korea
� Can be used as a useful tool for decision of LTO
- Indefinite O/L term → regulators require PSR to continue the operation
- Basic guideline: IAEA safety standards series
• Licensing Renewal (LR)- Definite O/L term (e.g. 40 years in USA) → needs to renew
- Renewed term : usually 20 years in USA – No limitation to # of LR
- Basic guideline: 10CFR54
Two Approaches for LTO
LTOOriginal Operating License
(10 years)
LR
LTO
PSR PSR PSR
PSR+
LER+
RER
LTO LTO LTO LTO
PSR+
LER+
RER
PSR+
LER+
RER
SLR
PSR+
LER+
RER
DesignLife
LER: Life Evaluation Report for main components
RER: Radiological impact on Environments Report
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IAEA Nuclear Safety Convention (1996)
- Recommend MS to adopt PSR
- Develop SSG-25 (2013)
• Korea promised to
adopt PSR
• AEC* announced PSR
policy (1999)
• First PSR started
Kori-1 (2000),
Wolsong-1 (2001),
Kori-2 (2001), ······
• Rule-making for PSR
completed (2001)
• Rules for LTO
established (2005)
• International standard
- Common and general requirements applicable to all MS.
- Each MS should establish its own specific requirements.
PSR Approach for LTO in Korea (1/4)
* Atomic Energy Commission
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PSR Approach for LTO in Korea (2/4)
• Regulatory requirements for PSR and LTO in Korea
Article 37
(Submittals for LTO)
a. PSR report
including 14 safety
factors
b. Life evaluation
report (LER) of key
components
considering
extended period
c. Radiological impact
on environments
report (RER)
* NSSC: Nuclear Safety and Security Commission
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Safety Factors in PSR
SF Title
SF 1 Plant Design
SF 2 Actual Condition of SSCs
SF 3 Equipment Qualification
SF 4 Aging
SF 5 Deterministic Safety Analysis
SF 6 Probabilistic Safety Analysis
SF 7 Hazard Analysis
SF 8 Safety Performance
SF 9 Use of Experience from Other
Plants and Research Findings
SF 10 Organization and
Administration
SF 11 Procedures
SF 12 Human Factors
SF 13 Emergency Planning
SF 14 Radiological Impact on
Environment
Plant Design
Safety
Analysis
Plant
Performance
Management
Environment
Global Assessment
Specific review elements
a. Program policy, organization and
resources.
b. Methods and criteria for
identifying SSCs covered by the
AMP.
c. A list of SSCs covered by the
AMP
d. Evaluation of potential aging
degradation.
e. ….
f. ….
g. ….
h. ….
i. Acceptance criteria for SSCs
j. Awareness of physical condition
of SSCs
Codified into Ministerial Decree
PSR Approach for LTO in Korea (3/4)
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Article 38 (Technical criteria for LTO)
a. Current licensing basis (CLB)
b. For evaluation of SSCs, technical criteria
considering the recent operational
experience and R&D results shall be
used
c. For radiological impact on environments,
the latest technical criteria shall be used.
PSR Approach for LTO in Korea (4/4)
• Regulatory requirements for PSR and LTO in Korea
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LTO based on PSR (Korea) LTO based on LR (USA)
Technical
Information
PSR report
(Review on 14 safety factors)
Integrated Plant Assessment
including AMP
CLB Changes CLB Changes
Life evaluation report (AMP + TLAA) TLAA
FSAR Supplement FSAR Supplement
Tech. Spec. Changes Tech. Spec. Changes
Environmental
Information
Radiological Impact on Environment
report
Environmental Impact
Statement
• Similarity : Information to be Submitted
PSR vs. LR_Similarity (1/3)
AMP: Aging Management Program
CLB: Current Licensing Basis
TLAA: Time Limited Aging Analysis
FSAR: Final Safety Analysis Report
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AMP required for PWR in PSR
Items No. of AMPs
- Mechanical Components
- Structural Components
- Electrical Components
Total 39 AMPs
LR
Items No. of AMPs
- Mechanical
- Structural
- Electrical
38 AMPs
8 AMPs
6 AMPs
Technical Criteria
NUREG-1800
NUREG-1801
• Similarity : Ageing Management Programs
AMP to be submitted in Korea AMP in NUREG-1801
1. In-service inspection of safety class 1,2,3 XI.M1
4. Reactor Vessel Surveillance XI.M31
8. Boric acid corrosion XI.M10
11. Flow-accelerated corrosion XI.M17
27. Steel liners for concrete containments, steel containments XI.S1
39. Electrical cable connections not subject to 10CFR50.49 EQ req’ments XI.E6
PSR vs. LR_Similarity (2/3)
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TLAA required for PWR in PSR Technical guideline from LR
- Identification of TLAA
- Reactor Vessel Embrittlement
- Metal Fatigue
- Environmental Qualification
- Containment Building Tendon Prestress
- Containment Building Penetration Fatigue
- Plant Specific
- 10CFR54.21
- 10CFR50 Appendix G
- 10CFR54.21
- 10CFR50.49
- 10CFR54.21
- 10CFR54.21
- 10CFR54.21
• Similarity : Time Limited Ageing Analysis
- Generic TLAA
- Plant Specific TLAA
Used for 20 years, 84 units Used for 10 years, 2 reactors
Both approaches approve LTO based on the submitted documents.
Technical information is good enough for confirming the safety of LTO.
PSR vs. LR_Similarity (3/3)
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• Nuclear Industries Lost Public Confidence- Forgery of quality documents
- Hiding some incidents
- Using unqualified components
Public Acceptance on LTO in Korea
• Much efforts done for LTO in Korea- Post-Fukushima actions items fully implemented
- Stress tests for LTO completed
- Severe accident fast response expert team launched (SAFE-T)
• Public fear against NPP accident expanded- Fukushima earthquake and tsunami
- Gyeongju Earthquake (2016.9.12)
� Magnitude (5.8) : the biggest one in Korean history
� Very near to Wolsong nuclear site (28km)
• Long term operation of aged plants is not allowed.
[President Moon Jae-In’s speech in the ceremony of
Kori Unit 1 permanent shutdown in July 19, 2017]
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• Strong Support to Nuclear Industries
- Favorability to nuclear energy still high enough
- Almost all reactors expected to operate for 60 years.
(Mar. 2015, NEI)
What’s the difference ?
- particularly in LTO
FukushimaChernobyl
(as of Dec. 2016)
Public Acceptance on LTO in USA
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• Differences in Regulation System
- Openness in regulatory activities
� Somewhat closed to public (Korea) vs. Openness and transparency (USNRC)
� No public hearing (PSR in Korea) vs. Formal public hearing (LR)
PSR vs. LR_Difference (1/3)
USA
Formal public participation channels exist
Korea
CO Process
No Formal public participation channels
(KHNP Homepage) (USNRC Homepage)
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• Nuclear Safety Policy Statement in Korea(1994)
- IAEA Nuclear Safety Convention → Government announced the Policy Statement
- The Statement declare 5 Regulatory Principles
� Independence, Openness, Clarity, Efficiency, Reliability
( Mar. 2016, NEI)
Fewer words and more action is important !
PSR vs. LR_Difference (2/3)
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• Differences in Regulatory System
- Extended operation period
� 10 years (PSR in Korea) vs. 20 years (USNRC)
� PSR approach gives two-fold burden to operator.
- Docketing date for LTO application
� 5~2 years (PSR in Korea) vs. 20~5 years before the expiration (USNRC)
� Insufficient time to debate for decision of LTO
� Insufficient time for operator to refurbish plant
LTO based on PSR (Korea) LTO based on LR (USA)
Extended Period 10 years 20 years
Docketing Date 5~2 years before expiration 20 ~ 5 years before expiration
PSR at 10 years
+
LR of 20 years
20~5 years before expiration
recommended
PSR vs. LR_Difference (3/3)
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Concluding Remarks
• Both approaches, PSR and LR, are good enough for technically
confirming plant safety in LTO.
• LTO process in Korea based on PSR is recommended to improve.
� Formal public hearing process is recommended for decision making of LTO.
� Extension of 20 years is recommended while performing PSR at every 10 years.
� 20~5 years before expiration is recommended for thorough discussion and
refurbishment plan for LTO.
• To recover the public confidence for nuclear industry in Korea, safety
culture shall be changed.
� Much more openness is required to both regulatory body and NPP operator.
“They always say time changes things, but
you actually have to change them yourself.”
- The Philosophy of Andy Warhol (1977, Mariner Books) -
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