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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

tr.kim@kings.ac.kr

Prof. Hwang, IL-Soon

Seoul National University

hisline@snu.ac.kr

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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