ML22214A097

Presentation by South Texas Project

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: ML22214A096 ML22214A097 ML22216A115
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?