ML20196G152

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Forwards Draft Outline to NRC to Facilitate Discussions Between Util & NRC Re Actions Believed Needed to Address Restraints to Implementation of Graded QA
ML20196G152
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 12/03/1998
From: Alexion T
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9812070263
Download: ML20196G152 (4)


Text

,

i MEMORANDUM TO: PD IV-1 File December 3, 1998 FROM:

Thomas W. Alexion, Project Manager ORIG SIGNED BY:

Project Directorate IV-1 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation l

SUBJECT:

DRAFT OUTLINE FROM STP NUCLEAR OPERATING COMPANY REGARDING ACTIONS TO ADDRESS RESTRAINTS TO IMPLEMENTATION OF GRADED QUALITY ASSURANCE (GQA)

On September 23,1998, STP Nuclear Operating Company (STPNOC) provided the l

attached draft outline to the Nuclear Regulatory Commission (NRC) on the above subject.

l STPNOC provided the outline to the NRC to facilitate discussions between STPNOC and NRC l

l regarding actions STPNOC believed are needed to address restraints to implementation of GQA The purpose of this memorandum is to place the attachment in the public document room.

i l

l Docket Nos. 50-498 and 50-499

Attachment:

Actions to Address Restraints DISTRIBUTION:

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  • Docket File (50-498 & 50-499)~

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%;M,,,,,J December 3, 1998 MEMORANDUM TO: PD IV-1 File FROM:

homas W. Alexion, Project Manager Project Directorate IV-1 Division of Reactor Projects -lil/IV Office of Nuclear Reactor Regulation i

SUBJECT:

DRAFT OUTLINE FROM STP NUCLEAR OPERATING COMPANY REGARDING ACTIONS TO ADDRESS RESTRAINTS TO IMPLEMENTATION OF GRADED QUALITY ASSURANCE (GQA)

On September 23,1998, STP Nuclear Operating Company (STPNOC) provided the attached draft outline to the Nuclear Regulatory Commission (NRC) on the above subject.

STPNOC provided the outline to the NRC to facilitate discussions between STPNOC and NRC regarding actions STPNOC believed are needed to address restraints to implementation of GQA. The purpose of this memorandum is to place the attachment in the public document room.

Docket Nos. 50-498 and 50-499

Attachment:

Actions to Address Restraints I

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20*a w ol Actions to address restraints to implementation of GQA Basis:

STP has an NRC approved PRA (SER issued) that establishes the fundamental analytical tool determining the risk significance of structures, systems and components.

STP has an NRC approved Graded Quality Assurance risk ranking process that establishes a methodology.to determine which structures, systems and components have a significant impact on plant safety.

STP has completed review of 7 systems under the Graded Quality Assurance risk ranking process to date and determined that a majority of the components reviewed are not risk significant.

Proposed Action:

Provide an exemption for STP to appropriate regulations to allow STP to downgrade components identified by the risk ranking tool to non safety related or not important to safety thereby removing these components from the scope of various deterministic regulations.

This effort is proposed as a pilot activity that would support the ongoing risk based changes to regulations and can be approved and implemented in the shoit term. As a pilot some limitations on the overall scope of the effort and NRC participation in the process are appropriate. Specifically:

The systems to which this exemption will be specifically identified.

(e.g. to include systems reviewed to date plus some of the systems to be reviewed next year)

The applicable exemptions are expected to focus on 50.59 and j

50.2 and removing components from the scope of the seismic, EQ and ASME rules such that the complexity of routine maintenance and replacement can be reduced. (Additional research and review is needed to ensure that any roadblocks created by tha interrelationship of the regulations are identified and resolved)

A process for_ NRC participation can be established to include for example: site visits, presentations, reports and audits.

STP would enter into this pilot with the expectation that NRC would approve expanding the scope at the successful conclusion of the pilot.

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