ML22153A294

richardsd-hv-th28

ML22153A294
Person / Time
Site:	South Texas
Issue date:	06/17/2022
From:	Richards D South Texas
To:	Office of Nuclear Reactor Regulation
References
Download: ML22153A294 (6)

Text

Risk-Informed Approach for Aging Management Programs Session: Risk-Informing License Renewal - Exploring the Potential Presented by:

Drew Richards, Regulatory Affairs Manager STP Nuclear Operating Company

Key Regulatory Considerations

• 10 CFR 50.69 Statement of Considerations,Section II.4.10.8

• 10 CFR Part 54 was identified as a candidate special treatment requirement

• Part 54 aging management requirements are special treatment requirements in that they provide assurance that SSCs [Systems, Structures, and Components] will continue to meet their licensing basis requirements during the renewed license period.

• that licensees can renew their licenses in accordance with Part 54 by demonstrating that the

§ 50.69 treatment provides adequate aging management in accordance with § 54.21. The NRC staff suggested that no changes are necessary to Part 54 to implement § 50.69 either before renewing a licensing or after license renewal.

• South Texas Project (STP) Exemption from Special Treatment Requirements (precursor to 10 CFR 50.69) has been confirmed to be valid through the period of extended operation (PEO)

Key Station Considerations

• Significant advantage for risk-informing Aging Management Programs (AMPs) based on number of systems categorized by STP

• Over 100 plant systems categorized

• Two types of categorization: Graded Quality Assurance (GQA) Risk (nuclear safety);

PGR (plant generation risk)

• Categorization data and supporting information incorporated into station information databases and software programs

• STP categorization: key to optimizing operational effectiveness and efficiency now and during PEO

Key Station Considerations (continued)

• The original License Renewal Implementation (LRI) AMP scope remains the same; however, an alternative treatment will be applied to components that are GQA Low and Non-risk Significant (NRS) (i.e.,

RISC3 and RISC4)

• Many Low/NRS components can be alternatively treated with existing station processes (e.g., Preventive Maintenance, opportunistic inspections, Corrective Action Program)

• Project plan is for each AMP to be evaluated for risk-informed potential, as practical and appropriate

Benefits

• Safety Benefits: AMP focus is on items of nuclear safety significance

• Operational Benefits: reduction in SSC outage time to perform AMP requirements and improved ALARA [As Low As Reasonably Achievable]

performance

• Program effectiveness: reduced station burden for the following AMPs (all AMPs to be evaluated):

• One-time Inspections

• Aluminum-Bronze Selective Seaching

• Internal Surfaces Inspection

• Open-Cycle Cooling Water