ML22214A097
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| ML22214A097 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/02/2022 |
| From: | Brost W South Texas |
| To: | Office of Nuclear Reactor Regulation |
| Tyree, Christopher | |
| Shared Package | |
| ML22214A095 | List: |
| References | |
| Download: ML22214A097 (6) | |
Text
Risk-Informing License Renewal -
Other Possibilities and Continued Discussion Wendy Brost, Licensing Supervisor STP Nuclear Operating Company
Recap of RIC Presentation & Background
- STP was proof-of-concept pilot for risk significance categorization, 50.69 predecessor
- STP has categorized over 100 plant systems in terms of nuclear safety risk (GQA) and plant generation risk (PGR)
- Component risk categorization provides a technical basis for treatment of components commensurate with their safety and operational significance
- STP plans to apply alternative treatment for GQA Low and Non-Risk Significant components (RISC-3 and RISC-4),
engineering evaluations would be performed for RISC-2 components
- Each AMP will be evaluated for risk-informed potential
Goals and Benefits
- Goal: apply the appropriate resources to components commensurate with their nuclear safety significance
- Benefits:
- Focus resources on items with the most safety significant components
- Increased availability of SSCs due to removal of prescriptive special treatment requirements in lieu of adequate and more efficient alternative treatments and a reduction in outage time during the performance of AMP requirements
- Improved ALARA performance
- Reduced station burden for AMPs
Next Actions - Preparing for the Change
- Creating procedure for performing AMP evaluations
- Guidance for tracking, implementation, and documentation of alternate treatment actions and activities
- Ensures industry and station OE pertaining to age-related degradation reviewed and factored into evaluations
- Guidance and responsibilities for AMP-specific alternate treatment implementation and maintenance
Next Actions - Preparing for the Change
- Documented position in internal white paper
- Comparative evaluation assessing applicability of the STP exemption from special treatment requirements to risk-informing aging management programs
- License renewal and aging management are special treatment requirements
- Risk insights can be used to evaluate aging management programs
Conclusion:
STP can risk-inform procedures and processes to implement Exemption allowances for all station programs, as applicable and appropriate.
Other Potential Applications and Issues
- Applying risk insights to additional parts of License renewal
- Equipment Qualification mentioned in License Renewal correspondence RAI response
- Lack of exact/specific guidance or clear precedence - justifiable, but different
- Want to be transparent in our actions - what is the appropriate vehicle for communicating this change?
- 50.59 evaluation - would be subject to inspection, reported in biennial update
- Future discussion in public forum?