ML22153A294
| 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