ML023190049
| ML023190049 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Oconee, Arkansas Nuclear, Crystal River, PROJ0693, Crane  |
| Issue date: | 11/11/2002 |
| From: | Mallay J B & W Owners Group, Framatome ANP |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BAW-2374, NRC:02:052, OG:02:1826 | |
| Download: ML023190049 (2) | |
Text
Duke Energy Compay Oconee 1, 2,3 A-erGen Energy Company. LLC mi-I Entergy Operations, Inc.
ANO-1 The B&W FirstEnergy Nuclear Operating Company D-B Florida Power Corporation Crystal River 3 Owners Gr Up Framatome ANP Working Together to Economically Provide Reliable and Safe Electrical Power November 11, 2002 NRC:02:052 OG:02:1826 Document Control Desk ATTN: Chief, Planning, Program and Management Support Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Credit for Inappropriate Review Time on BAW-2374 On September 25, the B&WOG Executive Committee held a meeting with senior NRC management. One of the subjects discussed was the ongoing review of BAW-2374, Revision 1, "Risk-Informed Assessment of OTSG Tube Thermal Loads Due to Breaks in RCS Upper Hot Leg Large Bore Piping." The B&WOG requested that NRC management provide the attention needed to conclude the review of this report in an expeditious manner, and that this review concentrate on the risk-informed approach suggested by the NRC in January 2001 and fully addressed in this revision of the report. In addition, the B&WOG requested that the NRC provide financial credit for portions of the review that appear to be misdirected and have not addressed the subject of the report This letter summarizes the basis for B&WOG's request for financial credit.
This report has been under NRC review since March 2001. The focus of the review has changed on several occasions, with the initial review concentrating on the risk-informed nature of the report, as intended by the B&WOG, followed by two different, deterministic-based evaluations.
The purpose of this topical report is to justify not modifying the original design basis for the thermal loads on the steam generator tubes. This justification is based on a risk-informed demonstration that the probability of scenarios other than the original design basis, Along with the associated core damage frequency and large early release fraction, is exceedingly small compared to the criteria provided in Regulatory Guide 1.174.
In contrast to the approach taken in the topical report, and as suggested by the NRC, recent reviews have concentrated on establishing a new design basis without regard for the original design basis or the risk-informed arguments presented in the topical report. These reviews, initiated sometime prior to July 2001 and continuing at least through June 2002, should not have been conducted. Therefore, the B&WOG should not be held accountable for the expenditures associated with these reviews.
Framatome ANP B&W Owners Group 3315 Old Forest Road Lynchburg, VA 24501 Phone: 434-832-3635 Iax: 434-832-4121
Document Control Desk NRC:02:052 November 11, 2002 OG:02:1826 Page 2 A detailed review of the invoices issued to the B&WOG during this 12-month period shows NRC expenditures of $106,234. Therefore, the B&WOG requests that credit be provided for these Very truly yours, James F. Mallay, Director Regulatory Affairs cc:
J. Colaccino D. G. Holland Project 693