Appendix J Program Initiatives

NEI 94-01 Revision 3-A of the Nuclear Energy Institute’s “Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J”, specifically allows the utility to submit a License Amendment Request to adopt the following initiatives:

  • Permanent Extension of the Type A (ILRT) Test Interval to 15 years
  • Targeted Type C (LLRT) Test Scope Reduction / Interval Optimization

Why True North?

TNC’s direct involvement in the development and review/approval process of NEI 94-01, Revision 3-A, acting as a partner alongside EPRI and NEI representatives and interfacing directly with the Nuclear Regulatory Commission (NRC) during numerous teleconferences and requests for additional information, has provided us unique insights that will assist licensees in obtaining approval for use of Revision 3-A in a timely and fully compliant manner. Our involvement in every phase of the development, regulatory negotiations, and approval process of Revision 3-A of the NEI 94-01 guideline, uniquely qualifies True North to assist licensees with the development of their License Amendment Requests.

Potential Utility Benefits

Permanent Extension of the Type A (ILRT) Test Interval to 15 years

  • Reduce outage critical path duration by deferring the ILRT to a 15-year interval
  • Depending on current operational license, may be able to eliminate one ILRT completely
  • Defer cost of test implementation / vendor costs
  • Defer dose associated with conducting the ILRT

Targeted Type C (LLRT) Test Scope Reduction / Interval Optimization

  • Reduce cost of the LLRT tests through a reduction in scope and the elimination of unwarranted tests
  • Reduced scheduled outage duration for accomplishing the LLRT test scope
  • Reduce creation of radioactive/chemically-treated waste water from pre-test drain down
  • Reduced accumulated dose rate for LLRT crews and operations personnel
  • Reduced test configuration alignment time and test volume drain-down time
  • Reduced LLRT conduct test time, reduced penetration refill time and realignment of affected Type C penetrations
  • Increased system availability associated with those Type C penetrations now on a 25% longer LLRT interval (75 months versus previous 60 months extended interval).

Cost Benefit Analysis

The cost of doing business without implementation of these initiatives is estimated to be:

  • Estimated cost of ILRT Test = $1.5-2.5M per test
  • Estimated cost of LLRT Test = $5-10k per test

The cost for implementation of these initiatives is estimated to be:

  • ILRT Permanent 15 Year Interval Extension = $185-200k (one-time cost)
  • LLRT Test Scope Reduction / Optimization = $60-75k (one-time cost)

The estimated savings to the utility is:

  • ILRT Permanent 15 Year Interval Extension = $800k (or $1.5-2.5M if eliminated)
  • LLRT Test Scope Reduction / Optimization = $100-$300k per outage

For more information, see our brochure.

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