ML041550038

License Renewal Application - Response to Requests for Additional Information on Scoping & Screening Results

ML041550038
Person / Time
Site:	Cook
Issue date:	05/20/2004
From:	Nazar M Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4034-05, TAC MC1202, TAC MC1203
Download: ML041550038 (36)

Text

Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1373 INDIANA MICHIGAN POWER May 20, 2004 AEP:NRC:4034-05 10 CFR 54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001

SUBJECT:

Donald C. Cook Nuclear Plant, Units I and 2 Docket Nos. 50-315 and 50-316 License Renewal Application -

Response to Requests for Additional Information on Scoping and Screening Results (TAC Nos. MC 1202 and MC 1203)

Dear Sir or Madam:

By letter dated October 31, 2003, Indiana Michigan Power Company (I&M) submitted an application to renexv the operating licenses for Donald C. Cook Nuclear Plant (CNP), Units 1 and 2.

In the course of the Nuclear Regulatory Commission (NRC) review process, the NRC staff transmitted a number of draft requests for additional information (RAIs) to I&M. In a public meeting held on April 13, 2004, the Staff instructed I&M to consider these draft RAls final, and provide responses as required to support NRC review of the license renewal application (LRA).

This letter provides I&M's responses to LRA Section 2 draft RAIs received between April 1 and April 15, 2004.

The enclosure to this letter provides an affirmation pertaining to the statements made in this letter.

Attachment I provides I&M's responses to the RAIs; provides a copy of the CNP Unit I and Unit 2 feedwater system flow diagrams, as required to facilitate the review of the response to RAI 2.3.4.1-2. There are no new commitments contained in this submittal.

Should you have any questions, please contact Mr. Richard J. Grumbir, Project Manager, License Renewal, at (269) 697-5141.

Sincerely, M. K. Nazar Senior Vice Pre ent and Chief Nuclear Officer aO '

NH/rdw

U. S. Nuclear Regulatory Commission AEP:NRC:4034-05 Page 2

Enclosure:

Affirmation Attachments:

1. Response to Requests for Additional Information for the Donald C. Cook Nuclear Plant License Renewal Application - Scoping and Screening Results

2. Flow Diagrams for the Donald C. Cook Nuclear Plant, Units I and 2, Feedwater System (OP-1 -5106-49 and OP-2-5106-44) c:

J. L. Caldwell, NRC Region III K. D. Curry, AEP Ft. Wayne, w/o attachments J. T. King, MPSC, w/o attachments J. G. Lamb, NRC Washington DC J. G. Rowley, NRC Washington DC MDEQ - WHMD/HWRPS, w/o attachments NRC Resident Inspector

Enclosure to AEP:NRC:4034-05 AFFIRMATION I, Mano K. Nazar, being duly sworn, state that I am Senior Vice President and Chief Nuclear Officer of American Electric Power Service Corporation and Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

American Electric Power Service Corporation M. K. Nazar Senior Vice Presi nt and Chief Nuclear Officer SWORN TO AND SUBSCRIBED BEFORE ME THIS 20 DAY OF 2004 I

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My Commission Expires (U

-0 12ClZ07 BRIDGET TAYLOR Notary Public, Berrien County, m~l My Commission Expires jun. 10,2007

Attachment I to AEP:NRC:4034-05 Page I Response to Requests for Additional Information for the Donald C. Cook Nuclear Plant License Renewal Application - Scoping and Screening Results This attachment provides Indiana Michigan Power Company's (I&M's) responses to the Donald C. Cook Nuclear Plant (CNP) License Renewal Application (LRA), Section 2, Requests for Additional Information (RAls) received between April 1 and April 15, 2004.

RAI 2.3.1.2-1:

In Table 2.3.1.2-1 of the LRA, ANote 1, it was stated that although the vessel lifting tugs do not directly support any intendedfiunction, they are includedfor completeness. The staff, however, believes that the subject component should be in scope in accordance with JO CFR 54.4(a)(2),

because its failure may prevent some of the safety related components from performing their intendedfiunctions if the RPV [reactor pressure vessel] head drops while being lifted. Please state the trite basis, consistent with the rule, for which components are determined to be in scope requiring aging management.

I&M Response to RAI 2.3.1.2-1:

Although the safety-related reactor vessel head is credited for performing a pressure boundary intended function, the reactor vessel head lifting lugs are not relied on to support this license renewal intended function.

The reactor vessel head lifting lugs are not relied on to remain functional during and following design basis events (DBEs) to ensure the 10 CFR 54.4(a)(1) functions are satisfied. Notwithstanding their safety classification, operating procedures limit the load path and elevation of the head while suspended from the lifting lugs such that failure of the lifting lugs could not prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (a)(l)(ii), or (a)(l)(iii) of 10 CFR 54.4. Since the lifting lugs are part of the reactor vessel head, they are safety-related and hence do not meet the criterion of 10 CFR 54.4(a)(2). The lifting lugs are not relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations listed in 10 CFR 54.4(a)(3).

RAI 2.3.1.3-1:

In page 11, Chap. 3, of the UFSAR [Updated Final Safety Analysis Report] for Unit I (and page 29 for Unit 2), it is stated that a small amount of inlet water is directed into the vessel head plenum to provide cooling of the vessel head. According to TWCAP-14577-A, the components associated with this cooling system should be in scope of license renewal requiring aging management. Since it appears that the subject components were not identified in Table 2.3.1-2 of the LRA, please confirm whether the components associated with RPV head cooling system are within the scope requiring aging management.

to AEP:NRC:4034-05 Page 2 I&M Response to RAI 2.3.1.3-1:

To provide vessel head plenum cooling, a small amount of bypass flow is directed from the inlet downcomer into the upper head. The flow path for this bypass flow consists of 16 spray holes located in the flange of the core barrel. Similar spray holes are provided at corresponding locations in the upper support plate. These spray holes are located outside the outer diameter of the holddown spring, allowing a small, unimpeded bypass flow from the inlet downcomer below the core barrel flange, through the annulus outside of the holddown spring, and up through the upper support plate into the upper head plenum. The spray holes are integral with the component types "Core barrel" and "Upper support plate," listed as subject to aging management review in LRA Tables 2.3.1-2 and 3.1.2-2.

RAI 2.3.1.4-1:

Staffposition on reactor vessel flange leak-off lines is that unless a plant specificjiistification is provided, the components should be in scope requiring aging management. Please confirm whether any of the component type listed in Table 2.3.1-3 of the LRA includes the subject components. If not, then the subject components should be identified as within scope requiring aging management, or provide a plant specificjustification.

I&M Response to RAI 2.3.1.4-1:

The flange leak-off lines are included within the scope of license renewal and are identified as requiring aging management review. The flow path from the O-ring groove to the outer surface of the reactor vessel flange is included in the component type "Flange leak tubes" listed in LRA Table 2.3.1-1. Downstream of the outer surface of the reactor vessel, the flange leak-off lines are shown at location G5 on license renewal drawings LRA-1-5128 and LRA-2-5128, and are included as the following component types listed in Table 2.3.1-3:

• Piping and fittings (including blind flanges) [Nominal Pipe Size] NPS <4-inches

• Class I valve bodies and/or bonnets < 2-inches

Attachment I to AEP:NRC:4034-05 Page 3 RAI 2.3.1.4-2:

Pursuant to 10 CFR 50, App. R, Sec.III 0, the reactor coolant pump (RCP) lube oil collection subsjystem is designed to collect oilfrom the RCPs and drain it to a collection lank to prevent a fire in the Containment Building during normal plant operations. The staff believes that the subsystem and the tank should be within scope requiring aging management. Houwever, it appears that the subject components there not identified in the LRA (Tables 2.3.1-3); and therefore, the staff requests the applicant to provide an explanation.

I&M Response to RAI 2.3.1.4-2:

The lube oil collection system is a non-Class I system with an intended function of meeting fire protection requirements; therefore, the lube oil collection system was included in the fire protection system aging management review.

System component types "Fittings," "Piping,"

"Tank," and "Valve" are subject to aging management review and are listed in LRA Table 2.3.3-7 for the fire protection system. Components in the lube oil collection system are included in LRA Table 3.3.2-7 with the external and internal environments "Lube oil and borated water leakage," which is identified in LRA Table 3.0-1 as an environment specific to the lube oil collection system.

RAI 2.3.1.5-1:

Intergranular and transgranular type stress corrosion cracking *tere observed in the past in the i'elded section ofpressurizer instrumentation nozzles in Westinghouse P JRs [pressurized wsater reactors]. Please confirm whether an aging management reviewv (AMR) ii'as performedfor the iuselded portion of instrumentation nozzles.

I&M Response to RAI 2.3.1.5-1:

An aging management review for the attachment welds of the pressurizer instrument nozzles was performed at CNP. Similar to other pressurizer nozzles such as the spray, surge, and relief nozzles, the instrument nozzle attachment welds were reviewed with the welded item itself, and are included in the component type "Instrument nozzles and couplings" listed in LRA Table 2.3.1-4. The aging management review results for pressurizer instrument nozzles and couplings, as listed in LRA Table 3.1.2-4 (page 3.1-76), include the attachment welds.

Attachment I to AEP:NRC:4034-05 Page 4 RAI 2.3.1.5-2:

LRA Drawing 5128A and Table 2.3.1-4 did not include the pressurizer relief/quench tank within the scope. In orderfor the staff to make a determination whether the exclusion wasjustified, the staff requests the applicant to provide the following additional information:

a) Does the failure of pressurizer relief tank prevent effective pressure control or prevent depressurization through the relief/safety valves?

b) In the event the relief tank is not finctional, and as a result, high pressure and high velocity steam need to be discharged into the containment, what are the consequences? The response should include discussions on potential offailure of other safety related components by the discharging steam.

I&M Response to RAI 2.3.1.5-2:

a)

The function of the pressurizer relief tank (PRT), as described in UFSAR Section 4.2.2.3, is to condense and cool the discharge from the pressurizer safety and relief valves, as well as several smaller relief valves. By means of its connection to the waste disposal system, the PRT also provides a means for removing any non-condensable gases, which might collect in the pressurizer, from the reactor coolant system. The PRT does not serve a pressurizer pressure control or depressurization prevention function.

b)

The consequences of a steam discharge from the PRT to the containment atmosphere are enveloped by various safety analyses described in detail in each unit's UFSAR Chapter 14.

UFSAR Section 14.2.5 discusses the analysis of a steam pipe rupture.

UFSAR Section 14.3.1 describes the analysis for a large break loss of coolant accident.

Unit 2 UFSAR Section 14.4.11, which includes the Unit I analysis, states that equipment inside containment must be qualified to demonstrate that it can perform its safety-related function following a high-energy line break (HELB).

Unit 2 UFSAR Tables 14.4.2.1 and 14.4.2.1A include pressurizer safety and relief valves, and supporting components, in the equipment required for shutdown following a HELB. The PRT is not included in the lists of equipment in UFSAR Tables 14.4.2.1 or 14.4.2.1A.

RAI 2.3.1.5-3:

In Table 2.3. 1-4 of the LRA, spray head it'as listed as a component type subject to an AAIR having an intendedfiunction of pressure control; and in page 2.3-10 of the LRA, it is stated that the spray head and heaters provide pressure control during certain design basis events (DBE).

But the LRA drawving # 5128A showls the component not in scope. Please clarify If the spray head ws as excludedfronm the scope, then the following additional information is requested:

Attachment I to AEP:NRC:4034-05 Page 5 a) How do you reconcile the fact that the component is relied upon for pressure controlfiunction during certain DBE, but the same component does not require any aging management?

b) The staff requests the applicant to clarify if the current licensing basis (CLB) for fire protection (FP) complies with certain sections of Appendix R, particularly Section III. G, wthich provides the requirementsfor the fire protection safe shutdoit'n capability Discuss if the pressurizer spray head and associated piping are credited and relied upon in the fire protection safe shutdown analysis to bring the plant to cold shutdol'n conditions within a given time for compliance with Appendix R.

If it is credited in the fire protection safe shutdown analysis, the pressurizer spray head and associated piping would satisfy IO CFR 50.48, Appendix R requirements; and therefore, should be included within the scope of license renewal. The specific intendedfitnction of the subject components which meets the 10 CFR 54.4(a)(3) requirements is the spray finction, and the particular components which help perform this finction are the section of piping and the spray head located inside the pressurizer. Note that the subject components do not have pressure boundary function. The staff requests the applicant to describe whether the loss of spray finction can make it impossible to bring the plant to cold shutdou'n conditions within the given time for compliance wiith Appendix R.

If so, then the staff requests that the spray head and the associated piping inside pressurizer having the spray finction be included within the scope requiring aging management so that it should provide a reasonable assurance that an adequate spray finction will be maintained inside the pressurizer during the extended period of operation.

1&M Responsc to RAI 2.3.1.5-3:

The pressurizer spray head is in scope and an aging management review was performed on this item. This review resulted in the component types "Spray head," "Spray head locking bar," and "Spray head coupling" being listed in LRA Tables 2.3.1-4 and 3.1.2-4. Highlighting of the spray head was inadvertently omitted on license renewal drawings LRA-1-5128A and LRA-2-5128A.

RAI 2.3.1.6-1:

In Table 2.3. 1-5 of the LRA, the staff notes that the SG [steam generator] partition plate has been identified as within the scope of license renewal requiring aging management. Hout'ever, one of the most significant intended functions of the component, namely the floatw distribution, was not identified in the table. The SG partition plate is located in the loiter head of each SG and separates the hot leg primary fluid from the cold leg primary fluid. Reactor coolant is located on both sides of the SG partition plate. The staffs Understanding is that the intended function of SG partition plates is flow distribution, i e., forcing the hot leg primalyflow through the SG tribes, and thereby enabling the SG to perform its primary finction of heat transfer. As a r esult, failure ofpartition plate itill degrade the heat transferfitnction of the SG. Degradation of the heat transfer fimction of SG has several safety consequences such as, inability of the reactor

Attachment I to AEP:NRC:4034-05 Page 6 to safely shutdown, loss of natural circulation heat removal through the SG which may be creditedfor prevention or mitigation of design-basis events, accidents, and/or the Commission's regulated events. In addition, the staff believes that there are potential for loose parts being originatedfrom a degraded partition plate due to aging, which may lead toflolw blockage of the SG tutbes, and thus causing degradation of SG heat transfer finction. The staff therefore, requests the applicant to specify 'flow distribution" as one of the intended finctions of SG partition plates, and to prescribe an aging management program (AMUP) that provide a reasonable assurance that the plates will not fail in a manner which can result in the primary coolant bypassing the SG tubes, and/or generate loose parts.

I&M Response to RAI 2.3.1.6-1:

The steam generator partition plate is a pressure boundary between the reactor coolant system (RCS) inlet and outlet areas of the lower head. This partition plate separates the primary coolant inlet chamber from the outlet chamber. Failures that bypass the steam generator tubes and loose parts that could cause flow blockage of the steam generator tubes would be readily apparent due to the impact on steam generator performance during normal power operation.

Aging effects associated with the component type "Partition plate" listed in LRA Table 3.1.2-5 include loss of material and cracking. These aging effects are managed by the Water Chemistry Program, the Alloy 600 Aging Management Program, and the Inservice Inspection Program.

These programs provide reasonable assurance that the steam generator partition plate will not fail in a manner that could result in reactor coolant bypassing the steam generator tubes or generating loose parts. The addition of "flow distribution" as an intended function for the partition plate would have no effect on the CNP aging management review results.

RAI 2.3.1.6-2:

The staff notes that SGfeedwvater ring and "J" tribes -were not identifed in Table 2.3.1-5 of the LRA as within the scope of license renewal requiring aging management. The staff requests the applicant to provide the following additional information in order to conclude w'hether the exclusion of subject components from scope was justified:

a) In page 19 (Chap. 4) of the UFSAR, it is stated that the J" tlubes prevent rapid drainage of the feediiater ring due to a drop in steam generator weater level and thus eliminate or reduce the possibility of wtater hammer in the feedwvater line. On the basis of the above statement made in the UFSAR, it appears that the subject components are needed to prevent or mitigate accidents; and therefore, should be in scope in accordance with 10 CFR 54.4(a)(7)(Iii).

b) Explain, if the components were relied Upon to demonstrate compliance during a design basis event, such asfeedit'ater line break accident, and/or Commission 's regulated events.

Attachment I to AEP:NRC:4034-05 Page 7 c) Explain, wrhyfailure of the components will not prevent in-scope components within the SG from performing their intendedfunclions.

d) Explain, whether the subject components are covered under any existing inspection and/or monitoring programs, such as SG Integrity program.

I&M Response to RAI 2.3.1.6-2:

a) The steam generator feedwater ring and "J" tubes are not subject to aging management review because they do not directly support the steam generator pressure boundary function.

Prevention of conditions that may result in water or steam hammer is sound engineering practice exercised throughout the entire CNP plant design. Water hammer is not a DBE; the text in the UFSAR only identifies a design feature of the feedwater ring and "J" tubes that may reduce the potential for water hammer in the event of a reduction in steam generator water level below the feedwater ring.

b) There are no DBEs or regulated events at CNP that rely upon the steam generator feedwater ring or "J" tubes to demonstrate successful mitigation and recovery from the event.

c) As stated by the Commission in the Statement of Considerations for the Final Part 54 Rule, "Consideration of hypothetical failures that could result from system interdependencies that are not part of the CLB and that have not been previously experienced is not required." CNP has not experienced any water hammer events in the feedwater rings that led to a line failure or DBE. Pressure boundary would be maintained in the event of failure of the "J" tubes and feedwater ring.

d) The steam generator feedwater ring and "J" tubes are monitored as part of the Steam Generator Monitoring Program, which implements the Steam Generator Integrity Program described in LRA Section B. 1.31. The chemistry of the feedwater and the secondary fluid within the steam generators is controlled by the Primary and Secondary Water Chemistry Control Program, which is described in LRA Section B.1.40.1, to mitigate corrosion and stress corrosion cracking. No new AMPs are required for these items.

RAI 2.3.2.3-1:

In page II (Chapter 6) of the UESAR, it wtas stated that screen assemblies and vortex suppressors are used in the containment sump which provides itater for the ECCS [emergency, core cooling system] recirculation phase, and one of the intended finctions is to protect the ECCS pumps from debris and cavitation due to harmfil vortex following an LOCA [loss of coolant accident]. Although, the LRA (Table 2.4-1) listed the screens (fine and coarse) as subject to AMR, the vortex suppressors and their intended function, w'hich also should require an AMR, w;'as not identified. Please explain

Attachment I to AEP:NRC:4034-05 Page 8 I&M Response to RAI 2.3.2.3-1:

The CNP containment recirculation sump design does not employ vortex suppressors to prevent cavitation due to vortexing. The fine and coarse screens listed in LRA Table 2.4-1 serve as flow strainers and mitigate vortex formation by equalizing local velocity differences.

The containment recirculation sump design provides sufficient flow area over the trash curb ahead of the sump and adequate net positive suction head for the residual heat removal and containment spray pumps to operate in the recirculation mode. The water level in the sump at the time of switchover from the injection phase to the recirculation phase has been established to ensure sufficient submergence to preclude vortexing or air entrainment.

Additionally, CNP analyses demonstrate that water inventory delivered or released to the containment from the refueling water storage tank, ice melt, RCS, and safety injection accumulators is sufficient to ensure that the minimum containment recirculation sump level is sufficient to preclude vortex formation in the suction flow to the ECCS and containment spray system pumps.

RAI 2.3.3.1-2:

For those systems, structures, and components (SSCs) ~within the scope of license renewal in accordance with 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structures and components subject to an AMR. The staff wtas unable to decide whether the applicant has considered all the SSGs within the scope of license renewal in accordance it'ith 10 CFR 54.4 in order to satisfy, this requirement.

LRA Section 2.1.2. 11 states the follois'ing:

The identification of components subject to aging management reviell' began with the determination of the system evaluation boundary. T/ie systeni evaluation boundary includes those portions of the systeni that are necessary to ensure that the intendedfiunctions of the system *till be performed Components needed to support each of the system-level intended functions identified in the scoping process are included within the system evaluation boundary However, the staff is unable to v'erifj5 whether the applicant has identified all the components that perform an intendedfitnction because in its LRA the applicant has not identified the components within the system evaluation boundary. The staff needs to verifv this information in order to effectively review the LRA using the Standard Review Plan for Review of License Renewal Applications for Nuclear Poui er Plants (ANUREG-1800), dated Julyj 2001, of it'hich Section 2.3. 1 gives /he followt ing guidance:

For a mechanical system that is within the scope of license renew'al, the applicant should identify the portions of the system that performn an intended finction, as

Attachment I to AEP:NRC:4034-05 Page 9 defined in 10 CFR 54.4(b). The applicant mall identify these particular portions of the system in mnarked-up piping anl instrument diagrams (P&IDs) or other

,ncdia. This is 'scoping" of mechanical components in a systeni to identifj those that are within the scope of license reneualfor a system.

LRA Section 2. 1.2. 1.2 states that "licensing reneit'al drawings were created bya marking mechanical floit' diagrams to indicate only those components within the systeni evaluation boundaries that require an aging management review.

The information provided in the LRA is not siaficient for the staff to complete its review of the scoping of components *within mechanical systems because licensing reneit'al drawtings marked only those portions of the mechanical systems that require an AMR.

Confirm that the systenm components marked on licensing renewal drawring LRA-12-5136 depict all the components within the spent fiuel pool (SFP) system that perform an intended finction (i.e., within the systemi evaluation boundarj). If not, provide a list of those components that petform an intendedfiunction but are not marked on licensing renewal drawing LRA 5136 or provide revised drawtings as needed to include the additional components.

I&M Response to RAI 2.3.3.1-2:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2).

Structures depicted on license renewal drawing LRA-12-5 136 that perform an intended function are discussed in LRA Section 2.4.2 and included in the structure / component / commodity types "Spent fuel pit steel (including swing gate, attachments, liner, and fuel racks)," "Spent fuel pit walls and slab," and "Fuel transfer canal" listed in LRA Table 2.4-2.

Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.21(a)(1)(i) criteria, as identified in the Nuclear Energy Institute (NEI) document, NEI 95-10, Appendix B.

This includes items such as instrumentation, motors and valve operators. License renewal drawing LRA-12-5136 does not depict any short-lived components that perform a 10 CFR 54.4 intended function.

Marking up the license renewal drawings to show components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams.

I&M's response to RAI2.3.3.11-1 (Reference I) provides a list of SFP component types that perform a 10 CFR 54.4(a)(2) intended function.

Attachment I to AEP:NRC:4034-05 Page I10 RAI 2.3.3.2-4:

For those systems, structures, and components (SSCs) within the scope of license renewal in accordance wiith 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structures and components subject to an AIR. The staff wtas unable to decide thether the applicant has considered all the SSCs within the scope of license renewal in accordance with 10 CFR 54.4 in order to satisfy this requirement.

LRA Section 2.1.2. 11 states the following:

The identification of components subject to aging management review began ii'ith the dletermination of the system evaluation boundary The system evaluation boundary, includes those portions of the system that are necessary to ensure that the intendedfinctions of the system wtrill be performed. Components needed to support each of the system-level intended finctions identified in the scoping process are included within the system evaluation boundary HIowt'ever, the staff is unable to verify whether the applicant has identified all the components that perform an intendedfinction because in its LRA the applicant has not identified the components within the system evaluation boundary The staff needs to verif1/4 this information in order to effectively reviewi' the LRA rising the Standard Revie' Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800), dated July 2001, of uswhich Section 2.3.1 gives the following guidance:

For a mechanical system that is within the scope of license renewal, the applicant should identify the portions of the system that perform an intended finction, as defined in 10 CFR 54. 4(b). Tiec applicant majy icentifj these particular portions of the system in marked-up piping and instrument diagrams (P&IDs) or other media. This is "scoping" of mechanical components in a system to identiqfj those that are within the scope of license renewvalfor a system.

LRA Section 2.1.2.1.2 states that "licensing renewal drantwings were created by marking mechanical flow diagrams to indicate only those components within the system evaluation boundaries that require an aging management review. "

The information provided in the LRA is not sufficient for the staff to complete its review of the scoping of components within mechanical systems because licensing renewal drawings marked only those portions ofthe mechanical systems that require an AMR.

Confirmn that the system components marked on licensing renewal drawtings LRA-1-5113, LRA-1-5113A, LRA-1-5113B, LRA-1-5113C, LRA-1-5149, LRA-1-5151B, LRA-1-5151D, LRA-2-5113, LRA-2-5113A, LRA-2-5113B, LRA-2-5113C', LRA-2-5149, LRA-2-5151B, and LRA-2-5151D, depict all the components 'ithin the essential service water (ES f'9 systemn thiat

Attachment I to AEP:NRC:4034-05 Pag~e I11 perform an intendedfiunction (i.e., within the system evaluation boundar)). If not, provide a list of those components that perform an intendedfuinction hut are not marked on licensing renewal drawiings or provide revised draws ings as needed to include the additional components.

I&M Response to RAI 2.3.3.2-4:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.21(a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators. No short-lived components that perform an 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5113, 5113A, 5113B, 5113C, 5149, 5151B, 5151D, LRA-2-5113, 5113A, 5113B, 51 13C, 5149, 5151B, or 5151D.

Marking up the license renewal drawings to show components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams.

I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a list of ESW component types that perform a 10 CFR 54.4(a)(2) intended function.

RAI 2.3.3.3-6:

For those systems, structures, and components (SSCs) within the scope of license renewal in accordance with 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structures and components subject to an AAIR. The staff was unable to decide wt'hether the applicant has considered all the SSCs within the scope of license renewal in accordance with 10 CFR 54.4 in order to satisfy this requirement.

LRA Section 2.1.2.1. states the following:

The identification of components subject to aging management revieit began with the determination of the system evaluation boundary. The system evaluation boundary includes those portions of the system that are necessary to ensure that the intendedffunctions of the system ithill be petformed. Components needed to support each of the system-level intended fiunctions identified in the scoping process are included wt'ithin the system ev aluation boundary.

Howrevber, the staff is unable to verify wthether the applicant has identified all the components that petform1 an intendedfiunction because in its LRA the applicant has not identified the components

Attachment I to AEP:NRC:4034-05 Page 12 wt'ithin the systeim evcaluation bounldar-.

The staff needs to verifj' this information in order to effectively review the LRA uising the Stanclard ReWiewt Plan for Reviewe of License Reneiral Applications for Nuclear Powter Plants (NUREG-J 800), dated Jill) 2001, of which Section 2.3.1 gives the folloinsig guidlance:

For a mechanical system that is within the scope of license renelfal, the applicant should i(lenqif the portions of the systemn that perform an intendledfiunction, as defined in 10 CFR 54.4(b). The applicant may identify these particular portions of the syswtem in marked-up piping and instrument diagranms (P&IDs) or other media. This is "scoping" of mechanical components in a system to identify' those that are uithin the scope of license reneitalfor a system.

LRA Section 2.1.2.1.2 states that "licensing renewal dlrawrings were created by marking mechanical flowr diagrams to indicate only those components within the systenl evaluation bounclaries that require an aging mnanagement revwiew.

The information pro'idced in the LRA is not stfficient for the staff to complete its retient' of the scoping of components within mechanical systems because licensing renewal drawtings marked only those portions of the mechanical systems that require an AMliR.

Confirm that the systenl components marked on licensing renewal cdrawings LRA-1-5113, LRA-1-5129A, LRA-1-5135A, LRA-1-5135B, LRA-J1-5135C, LRA-1-5135D, LRA-1-5135E, LRA-1-5135F, LRA-1-5135G, LRA-1-5143, LRA-2-5113, LRA-2-5129A, LRA-2-5135A, LRA-2-5135B, LRA-2-5135C, LRA 5135D, LRA-2-5135E, LRA-2-5135F, LRA-2-5135G, and LRA-2-5143 depict all the components within the component cooling ierater (CCIV) system that perform an intendledfiunction (i.e., within the system evaluation boundlamy). If not, proidle a list of those components that perform an intendedfiunction but are not marked on licensing reneiwal dlraanings or provwicle revised drawings as needed to include the adclitional components.

I&M Response to RAI 2.3.3.3-6:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2).

The aging management review for the structural elements of the CCW containment penetrations, shown on license renewal drawings LRA-1-5135F, LRA-1-5135G, LRA-2-5135F, and LRA-2-5135G, are grouped with the structural review in LRA Section 2.4.1. The CCW system includes components with a potential for 10 CFR 54.4(a)(2) functional failure, as well as components with a 10 CFR 54.4(a)(2) spatial interaction concern.

Since potential for a 10 CFR 54.4(a)(2) functional failure exists, clarification of the CCW system drawings for the CCW miscellaneous services header components that are within the scope of

Attachment I to AEP:NRC:4034-05 Page 13 license renewal and subject to aging management review is warranted.

This additional clarification is provided in I&M's response to RAI 2.3.3.3-5 (Reference 1).

Marking up the license renewal drawings to show components that are in scope and subject to aging management reviewv based solely on the spatial interaction aspects of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams. I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a list of CCW component types that perform a 10 CFR 54.4(a)(2) intended function.

Active components that were screened out and not highlighted on flow diagrams are those that do not meet the 10 CFR 54.21(a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

No short-lived components that perform an 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5113, 5129A, 5135A, 5135B, 5135C, 5135D, 5135E, 5135F, 5135G, 5143; LRA-2-51 13, 5129A, 5135A, 5135B, 5135C, 5135D, 5135E, 5135F, 5135G, or 5143; or flow diagrams OP-1-5141B, OP-1-5141G, and OP-2-5141G, which were provided in I&M's response to RAI 2.3.3.3-5 (Reference 1).

RAI 2.3.3.3-7:

LRA Section 2.1.2.1.2 states the follo1t'ing:

Licensing renewal drawt ings were created bar marking mechanical flow diagrams to indicate only! those components within the system evaluation boundaries that require an aging management review. Components that are within the scope of license renewal based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the drawings but are described in Section 2.3 and listed in Table 3.3.2-11.

10 CFR 54.21(a)(l) requires tie applicant to identify and list those structures and components subject to an AMWR.

The staff does not believe the applicant met this requirement because the components of the component cooling water (CCI1') sjslten meeting 10 CFR 54.4(a)(2) are neither identified on draitwings, nor listed.

The applicant included these components as "component types" in LRA Table 2.3.3-2 instead of as individually listed components.

The CCJV systein is identifed in LRA Section 2.3.3.11 as containing components that meet criteria 10 CFR 54.4(a)(2). Confirm that the systenm comlponents larked on licensing renet'al drawings LRA-1-5113, LRA-1-5129A, LRA-1-5135A, LRA-1-5135B, LRA-1-5135C, LRA-1-5135D, LRA-1-5135E, LRA-1-5135F, LRA-1-5135G, LRA-1-5143, LRA-2-5113, LRA-2-5129A, LRA-2-5135A, LRA-2-5135B, LRA-2-5135C, LRA-2-5135D, LRA-2-5135E, LRA-2-5135F, LRA-2-5135G, and LRA-2-5143 depict all the components within the CCII'sywtem

Attachment I to AEP:NRC:4034-05 Page 14 that meet criteria of 10 CFR 54. 4(a)(2). If not, provile a list of these components that are not marked on licensing renewal (drawrings or provide revised cdraw'ings as neecled to inclutle the adlditional components.

I&M Response to RAI 2.3.3.3-7:

Since potential for a 10 CFR 54.4(a)(2) functional failure concern exists, clarification of the license renewal drawings for the CCW miscellaneous services header components that are within the scope of license renewal and subject to aging management review is warranted.

This additional clarification is provided in I&M's responses to RAI 2.3.3.3-5 and RAI 2.3.3.11-1 (Reference 1).

Marking up the license renewal drawings to show components that are in scope and subject to aging management review based solely on the spatial interaction criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included in scope if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams.

I&M's "spaces" approach to identifying 10 CFR 54.4(a)(2) components with a potential for spatial interaction, which is based upon the physical location of safety-related SSCs (targets) that could be adversely affected by nonsafety-related components, results in a more functional and conservative accounting of the 10 CFR 54.4(a)(2) component types than could be provided by marked-up flow diagrams, which provide no physical location information.

As stated in the staffs request, components meeting 10 CFR 54.4(a)(2) are listed as "component types" in the LRA tables instead of as individual components. With few, if any, exceptions this is the practice followed by previous license renewal applicants, including those who have been granted a renewed license.

This is true for components meeting 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(3), as well as those meeting 10 CFR 54.4(a)(2).

As stated in LRA Section 2.1.2.1.2, components within the scope of license renewal based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the license renewal drawings, but are described in LRA Section 2.3 and listed in LRA Table 3.3.2-11.

These components are listed as component types, as stated in the above paragraph. The description and table listing meet the 10 CFR 54.21(a)(1) requirement to identify and list those structures and components subject to an aging management review, and is consistent with previously approved LRAs. As a reviewer's aid, I&M's response to RAI 2.3.3.11-1 (Reference I) provides a matrix of systems and component types that perform a 10 CFR 54.4(a)(2) intended function.

RAI 2.3.3.4-3:

For those sjstems, str-uchtres, anl components (SCscs) Xw'ithin the scopne of license renew ial in accordlance lwith 10 CFR 54. 4, 10 CFR 54.21(a)(I) requires the applicant to ilentf/5' and list

Attachment I to AEP:NRC:4034-05 Page 1 S those structures and components subject to an AIMR.

The staff was unable to decide whether the applicant has considered all the SSCs ii'ithin the scope of license renewal in accordanice Itith 10 CFR 54.4 in order to satisfj this requiremlen7t.

LRA Section 2.1.2.1.1 states thefollow ing:

The identification of components subject to aging management review began wi'ith the determination of the systemn evaluation boundary.

The system evaluation boundary includes those portions of the system1 that are necessary to ensure that the intendedafunctions of the system will be performed. Components needed to support each of the system-level intendel fiunctions identifled in the scoping process are included within the system evaluation bounlary.

However, the staff is unable to verify whether the applicant has identified all the components that performn an intendedfuvnction because in its LRA the applicant has not identified the components wtithin the system evaluation boundary. Tlhe staff needs to verify this information in order to effectively review the LRA uising the Standard Review Plan for Review of License Renewtal Applicationsfor Nuclear Power Plants (ANUREG-1800), dated July 2001, of which Section 2.3.1 gives thefollowing guidance:

For a mechanical systemn that is within the scope of license renewal, the applicant should identify the portions of the system that performn all intended futnction, as definled in 10 CFR 54.4(b). The applicant may identify these particular portions of the system in marked-up piping and instrulment diagranms (P&ID.s) or other media. This is "scoping" of mechanical components in a system to identify those that are It'ithin the scope of license renewalfor a system.

LRA Section 2.1.2.1.2 states that "licensing renewal drawsings wtere created by marking mechanical flowt diagrams to indicate only those components within the system evaluation boundaries that require an aging management review.

The information prov ided in the LRA is not slfficientfor the staff to complete its review of the scoping of conlponents wtithin mechanical systems because licensing renewal drawings marked only those portions of the mechanical systems that require an AMR.

Confirm that the systeml components marked on licensing renewal drawings LRA-1-5120D, LRA-1-5120E, LRA-1-512ONN, LRA-1-5120R, LRA-1-5120S, LRA-1-5128A, LRA-2-5120D, LRA 5120E, LRA-2-5120KK, LRA-2-5120R, LRA-2-51208, LRA-2-5128A, LRA-12-5118B, and LRA-12-5120B depict all the components within the compressed air (CA)syswtem that pemform amn intendedfunction (i.e., within the systeml evaluation boundarl). If not, provide a list of those comlponents that perform an intended function but are not mnarked on licensing renewal drawit'ngs or provide revised draltvings as needed to include the additional components.

Attachment I to AEP:NRC:4034-05 Page 16 I&A Response to RAI 2.3.3.4-3:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.21(a)(1)(i) criteria, as identified in NEI 95-10 Appendix B. This includes items such as instrumentation, motors and valve operators.

In the compressed air system, a number of relief valves on nonsafety-related piping are identified as safety-related on license renewal drawings (e.g., LRA-1-5120D at locations 17 and E9; LRA-2-5120D at locations C6 and F8; LRA-1-5120E at locations C9 and F7; and LRA-2-5120E at locations C8, C9, G6, and G7). These relief valves perform the active function of providing overpressure protection of fail-safe, air-operated valves in the event of a regulator failure. The pressure boundary function is not required to be maintained for these components because they are not in a safety-related containment isolation boundary or in a portion of the system with a required backup accumulator. Therefore, an aging management review is not required for these relief valves.

Mechanical components in the back-up compressed air supply to the pressurizer power-operated relief valves are highlighted on license renewal drawings LRA-1-5120D and LRA-2-5120D.

The reserve control air tanks, TK-253-1 and TK-253-2, are subject to aging management review.

The air bottles, TK-253-3 through TK-253-8, are frequently replaced with new bottles; therefore, these air bottles are not long-lived components, and do not require aging management review.

Mechanical components in the back-up air supply for the post-accident containment hydrogen monitoring system are shown on license renewal drawings LRA-1-51 2ONN, and LRA-2-512OKK. The backup air tanks, TK-400-1 through TK-400-4, are frequently replaced with new tanks; therefore, these tanks are not long-lived components, and are not subject to aging management review.

Nonsafety-related air components do not pose a hazard to other plant equipment, and cannot adversely affect safety-related components due to leakage or spray. This has been confirmed by an operating experience review. As a result, nonsafety-related components in the compressed air system that contain only dry air or gas have been determined to not meet the 10 CFR 54.4(a)(2) criterion, and are not in the scope of license renewal.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5120E, 5120R, 5120S, 5128A; LRA-2-5120E, 5120R, 5120S, 5128A; LRA-12-5118B, or 5120B.

Attachment I to AEP:NRC:4034-05 Page 17 RAI 2.3.3.8-5:

For those systems, structures, and components (SSCs) iwithin the scope of license renewt'al in accordance with 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structures and components subject to an AIMR. The staff iwas Unable to decide whether the applicant has considered all t(le SSCs within the scope of license renewal in accordance with 10 CFR 54.4 in order to satisfy this requirement.

LRA Section 2.1.2. 1I states the follow ing:

Tue identi/ication of components subject to aging management review began wi'ith the determination of the system evaluation boundcuy The system evaluation boundary includes those portions of the system that are necessar)y to ensire that the intendedfiunctions of the system Hrill be performed. Components needed to support each of the system-level intended finctions identified in the scoping process aire included wi'ithin the system evaluation boundary.

However, the staff is unable to verify ithether the applicant has identified all the components tihat perform an intendedfiunction because in its LRA the applicant has not identified the components wtithin the system evaluation boundary The staff needs to verify this information in order to effectively review the LRA lusing the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800), drted July 2001, of which Section 2.3. 1 gives thefollowing guidance:

For a mechanical systen thiat is *tithin the scope of license renewtal, the applicant should identify the portions of the system that perform an intendedfiunction, as defined in 10 CFR 54.4(b). The applicant mray identify these particular portions of the systenm in nuarked-uip piping and instrument diagrams (P&IDs) or other nmedia. This is "scoping" of mechanical components in a system to identify those that are within tlie scope of license renewt'alfor a systen.

LRA Section 2. 1.2 1.2 states that "licensing renewal derawings Hsere created by marking mechanical flow diagrams to indlicate only those components iwithin the system evaluation boundaries that require an aging managenment reviei.

The information prov ided in the LRA is not sufficient for the staff to complete its review of the scoping of comnponents within mechanical systems because licensing renewal drawings marked only those portions of he mrechanical systenms that require an AMR.

Confirn that the systemr components marked on licensing renewval cdrawings LRA-1-5151A, LRA-1-5151B, LRA-1-5151C, LRA-1-5151D, LRA-1-5120Y, LRA-2-5151A, LRA-2-51513, LRA-2-5151C, LRA-2-5151D, anrd LRA-2-5120Y dcepict all the components ws'ithin the emergency diesel generator (EDG) system thiat perfornm an intended function (i.e.,

'ithin the systemu

Attachment I to AEP:NRC:4034-05 Page I 8 evaluation bounclalj). If not. providle a list of those componenls that peiforJin an intendled function buitJ are not markedl on licensing renewal dcraiiings or provicle revisedl dIrawi-ings as needed to inclucle the addclitional components.

I&M Response to RAI 2.3.3.8-5:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet 10 CFR 54.21 (a)(1)(i) as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

The "Diesel Fuel Oil Equipment Location Plan" sketches included on license renewal drawings LRA-1-5151A, LRA-I-5151C. LRA-2-5151A, and LRA-2-5151C depict equipment layout, rather than process flow information. This information is duplicative of that shown elsewhere on the license renewal drawings for the EDGs; consequently, these equipment location plans are not highlighted.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5151A, 5151B, 5151C, 5151D, 5120Y, LRA-2-5151A, 5151B, 5151C, 5151 D, or 5120Y. No EDG system components are in scope for the 10 CER 54.4(a)(2) criterion.

RAI 2.3.3.9-4:

For those systems, structures, and components (SSCs) wiithin the scope of license renewal in accorclance wiith 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structu eres and compone)ets suibject to an AMfR. The staff was unmhabclto decicle whtherthe applicant has consiclered all the SSCs wiithin the scope of license renewal in accorlance wtith 10 CFR 54.4 in order to satisfi' this requirement.

LRA Section 2.1.2. 11 states the follow ing:

The idlentification of components subject to aging management reviewt began wt'ith the determination of the system evaluation boutndlary The sstenm evaluation boudmyr includes those portions of the sylstemn that are necessal)m to ensure that the intencledfiunctions of the system wtill be peiformel. Components needled to support each of the system-level intended finctions iclentiJied in the scoping process are inchulecl within the system evaluation bounolarj

Attachment I to AEP:NRC:4034-05 Page 1 9 Hoit evere the staff is unable to v'erif' it-hether thde applicant has idlentified all the components dhal perform an intendledfiunction because in its LRA the applicant has not idlentified tile comiponents uitlin thle systen evaluation boundaiy. The staff needs to verifj, this information in ordler to effectiveely revieu, thde LRA uising the aStanclard Revieiw Plan for Review of License Renewt(al Applications for Aluclear Poii'er Plants (NUREG-J800), dated.Iul 2001, of wihich Section 2.3.1 gives the followt-ing guilance:

For a mnechanical.9stem that is ii'itlin the scope of license renew al, the applicant shoulld identif' the portions of the system that pemform an intended filnction, as defined in 10 CFR 54. 4(b). Tle applicant mznay identif' Ithese particuilar pordions of the systenm in markecl-ip piping and instrument diagramns (P&IDs) or other media. This is "scoping" of mechanical components in a system to ilentif' those that are wi'ithin the scope of license renew alfor a system.

LRA Section 2.1.2.1.2 states that "licensing renewral drait'ings it'ere created by marking mechanical flhow diagramns to indicate only those components within the.system evaluation bounclaries that require an aging management review. "

The information provlided in the LRA is not sifficient for the staff to complete its review, of tie scoping of components wiithin mechanical systenms because licensing reneital ltrauwings inarked only those portions of the mechanical sstemns that require an) AAIR.

Confirni that the system components marked on licensing reneii'al draw-ing LRA-12-5150B dlepict all the components ii'ithin the security system that petforni an intendledfiunction (ie., within the systenm evaluation boindaaj.). If not, provide a list of those components that pem form an intenlded fiuction but are not marked on licensing reneiial drauiings or provlide revised draii'ings as neeted to inclulde the addlitional components.

I&M Response to RAI 2.3.3.9-4:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.21 (a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawing LRA-12-5150B. No security diesel system components are in scope for the 10 CFR 54.4(a)(2) criterion.

Attachment I to AEP:NRC:4034-05 Page 20 RAI 2.3.4.1-2:

For those sYstems, structures, and components (SSCs) wiithin 11e scope of license renewi'al in accordance wvith 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identify and list those structlurl-es and components subject to n AMAIR.

The stacff wzas unable to cdecidle ihlhlr the applicant has considered all the SSCs within the scope of license renewal in accordance with 10 CFR 54.4 in order to satisfy this req uirement.

LRA Section 2.1.2.1. 1 states the follow ing:

The identification of components subject to aging m(anagemnent review began with the determination of the system evaluation boundcay.

The system evaluation boundary includes those portions of the systeml that are necessaty to ensure that the intendedfiunctions of the systemn will be peiformned. Components needed to support each of the system-level intended finictions identified in the scoping process are included within the system evaluation boundaty.

However, the staff is unable to verify whether the applicant has identified all the components that perform an intended fimnction because in its LRA the applicant has not identifed the components within the system evaluation boundacy. The staff needs to verify this information in order to effectively review the LRA lusing the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800), cated July 2001, of which Section 2.3.1 gives thefollowing guidance:

For a niechanical systemn that is within the scope of license renew'al, the applicant should identify the portions of the system that perform an intendedfunction, as defined in 10 CFR 54.4(b). The applicant may identify' these particular portions of the system in marked-up piping and instrument diagrams (P&ID.V) or other media. This is "scoping" of mechanical components in a systent to identify those that are within the scope of license renewtalfor a systemn.

LRA Section 2.1.2.1.2 states that "licensing reneital drawi'ings itere created by marking mechanical floit' diagrams to indicate only those components within the system evaluation boundaries that require an aging management review. "

The information provided in the LRA is not suifficient for the staff to complete its reviewt of the scoping of components within mechanical systems because licensing renewal drawings mnarked only those portions of the mechanical systenms that require an AM11R.

Confirm that the system components marked on licensing renewal dlrawings LRA-1-5105D and LRA-2-51 O5D depict all the components within the main feedwater (F 11) system that peiformi an intendedfiunction (i.e., within the system evaluation boundar3). If not, provide a list of those

Attachment I to AEP:NRC:4034-05 Page 21 components that perform an intendledfunction but are not marked on licensing renew'al cIrawl'ings or providle revised dhraings as needledl to inclucle the acdclitional components.

I&M Rcsponse to RAI 2.3.4.1-2:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of feedwater regulating and isolation valves, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2).

Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.2 1(a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

Flowv diagrams OP-1-5106 and OP-2-5106 (Attachment 2 to this letter) are provided to show the feedwater regulating valves (FRVs) and the feedwater isolation valves, which have an active function of feedwater isolation upon receipt of an engineered safety feature actuation system (ESFAS) signal. The ESFAS functions of feedwater isolation and FRV closure rely on the active function of closure of the motor-operated feedwater isolation valves or the pneumatically-operated FRVs.

Both sets of valves function to prevent feedwater from being supplied to the steam generators and do not require pressure boundary integrity of this portion of the system. If pressure boundary is lost in this portion of the system (including these valves),

interruption of feedwater flow to the steam generator would occur (i.e., fail to the safe state).

Therefore, these feedwater valves and this portion of the system do not require aging management review.

Marking up the license renewal drawings to show components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams. I&M's response to RAI 2.3.3.11-1 (Reference I) provides a list of feedwater system component types that perform a 10 CFR 54.4(a)(2) intended function.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5105D and LRA-2-5 05D.

RAI 2.3.4.1-3:

LRA.Section 2.1.2.1.2 states the following:

Licensing renewtal drcawings Mrere created by marking mnechanical flow liagramis to inclicate only those components wtithin the systenl evaluation bounclaries that require an aging management ievi 'eii'. Components that are wiithin the scope of

Attachment I to AEP:NRC:4034-05 Page 22 license reneiral based solely on the criter ion of 10 CFR 54.4('a)(2) care not gener afclly indicated on the crbalmings but Care descriibed in Section 2.3 and listed in Table 3.3.2-11.

10 CFR 54.21('a)(1) requir es the applicant to identi'i, and list those strluctuares and components subject to an AMRIR.

The staff does not believe the applicant nmet this requiremeent because the components of the feedii'ater (F 119 systemn mneeting IO CFR 54.4(a) (2) are neither identified onl lrmawings, noor listed.

The applicant included these components as component topes" in LRA Table 2.3.4-1 instead of is individualtly listed components.

The Fff'systenm is identified in LRA Section 2.3.3. 11 as containing components that meet criteria 10 CFR 54. 4(a)(2). Confirm that the system components nmalrked on licensing renewl al dIrawings LRA-1-5105D aEd LRA-2-5105D, depict all the components within the FJV system that meet criteria of 10 CFR 54.4('a)(2). If not, provide a list of these components that aire not marked on licensing renewal drawsings or provile revised dirawings (is needled to include the additional components.

I&M Response to RAI 2.3.4.1-3:

The RAI correctly states that the components meeting 10 CFR 54.4(a)(2) are grouped as

"~component types" in the LRA tables instead of as individual components. With few, if any, exceptions this approach was followed by previous license renewal applicants, including those who have been granted a renewed license.

This is true for components meeting 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(3), as well as those meeting 10 CFR 54.4(a)(2).

As stated in LRA Section 2.1.2.1.2, components within the scope of license renewal based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the license renewal drawings but are described in LRA Section 2.3 and listed in LRA Table 3.3.2-11. These components are grouped as component types, as stated in the above paragraph. The description and table listing meet the 10 CFR 54.4(a)(1) requirement to identify and list those structures and components subject to an aging management review, and is consistent with previously approved LRAs.

Showing components on the license renewal drawings that are within the scope of license renewal and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) wvould be of minimal, if any, value since such components are typically included based on proximity to safety-related SSCs. I&M's "spaces" approach to identifying 10 CFR 54.4(a)(2) components, which is based upon the physical location of safety-related SSCs (targets) that could be adversely affected by nonsafety-related components, results in a more functional and conservative accounting of the 10 CFR 54.4(a)(2) component types than could be provided by marked-up flow diagrams, which provide no physical location information. As a reviewer's aid, I&M's response to RAI 2.3.3.11-1 (Reference I) provides a matrix of systems and component types that perform a 10 CFR 54.4(a)(2) intended function.

Attachment I to AEP:NRC:4034-05 P'age 23 RAI 2.3.4.2-3:

For those systems, struclures, and components (SSCs) within the scope of license reneital in accordance with fO CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identifj' and list those structures and components subject to an AAMR. The staff was unable to decide wi'hether the applicant has considered all the SSCs 'within the scope of license renewal in accordance with 10 CFR 54.4 in order to satisfy this requirement.

LRA Section 2.1.2. 1.I states thefollowiing:

The identification of components subject to aging management review began wt'ith the determination of the.system evaluation boundaly. The systeym evaluation hounldar' includes those portions of the system that are necessaty to ensure that the intendedfiunctions of the system will be peiformed. Components needed to support each of the system-level intended finctions identified in the scoping process are included within the systemn evalhation bounldary.

However, the staff is unable to verifsy whether the applicant has identified all the components that perform an intendedfunction because in its LRA the applicant has not identified the components within the systemn evalucation boundaly. The staff needs to verify this information in order to effectively review the LRA using the Standard Review Plan for Reviewt of License Renei'al Applications for Nuclear Power Plants (ANUREG-1800), dated.July 2001, of w hich Section 2.3.1 gives the followting guidance:

For a mechanical system that is within the scope of license renewal, the applicant should identify the portions of the system that perform an intended function, as defined in 10 CFR 54.4(h). Thle applicant may identifl these particutlar portions of the system in marked-zup piping and instrument diagrams (P&IDs) or other media. This is 'scoping" of mechanical components in a.system to identify those that are 'within the scope of license renewvalfor a system.

LRA Section 2.1.2.1.2 states that "licensing renewval drawings were created by marking mechanical flow diagrams to indicate only those components within the system evaluation boundaries that require an aging management review.

The information provided in the LRA is not sufficient for the staff to complete its reviewi of the scoping of components 'within Mechanical systems because licensing renewal drawings marked onl' those portions of the mechanical systems that require an AMA-R.

Confirm that the system components mnarked on licensing renewal drawi'ings LRA-1-5105D, LRA-1-5141A, LRA-2-5105D, and LRA-2-5141A depict all the components within the mecain steam (AfIS) system that perform an intended function (i.e., iithin the systenm evalualtion

Attachment I to AEP:NRC:4034-05 Page 24 boundalr). If not, provide a list of those conmponents that petform a(n intendedfiniction but are not miarked on licensing renetwal drai'iings or provide revised dhraitings as needed to include the additional components.

I&M Response to RAI 2.3.4.2-3:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 1O CER 54.21 (a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

Markingt up the license renewal drawings to show components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams. I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a list of main steam system component types that perform a 10 CFR 54.4(a)(2) intended function.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-51 05D, LRA-1-5141A, LRA-2-5 05D, or LRA-2-5141A.

RAI 2.3.4.2-4:

LRAI Section 2.1.2.1.2 states the follou hing:

Licensing reneu'al drawibings Were created bya marking mnechanicalflows, diagrams to indicate only' those conmponents ii'ithin the systeln evaluation boundaries that require an aging managenment revie1'. Componenlts tiht (re it'ithin the scope of license reneirlt based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the d/rawings but are described in Section 2.3 (1and listed in Table 3.3.2-1 1.

10 CFR 54.21(a)(1) requires the applicant to identif' and list those structures and components subject to an AHIR. The staff does not believe the applicant mnet this requiremnent because the components of the main steam (MS) systemn meeting 10 CER 54.4(a)(2) are neither identified on draiyiings, nor listed The applicant included these conponents as "component tly)es in LRA Table 2.3.4-2 instead of as individuallyj listed components.

Attachment I to AEP:NRC:4034-05 Page 25 The AIS system is identmiied in LRA Section 2.3.3. 11 as containing components that meet criteria 10 CFR 54. 4(a)(2). Confirm-that tie system coinponents omarked on licensing reneitial draii'ings LRA-1-5105D, LRA-1-5141A, LRA-2-5105D, and LRA-2-5141A dlepicl all the components wl'ithin the IMS system twhat meet criteria of 10 CFR 54. 4(a)(2). If not, provide a list of these comnp)onents that are not markedl on licensing renewral dlrawings or provlide revised cdrawings as needled' to include the adclitional coumponents.

I&M Response to RAI 2.3.4.2-4:

As correctly stated in the RAI, components meeting 10 CFR 54.4(a)(2) are grouped as "component types" in the LRA tables instead of as individual components. With few, if any, exceptions this is the approach followed by previous license renewal applicants, including those who have been granted a renewed license.

This is true for components meeting 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(3), as well as those meeting 10 CFR 54.4(a)(2).

As stated in LRA Section 2.1.2.1.2, components within the scope of license renewal based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the license renewal drawings, but are described in LRA Section 2.3 and listed in LRA Table 3.3.2-11.

These components are grouped as component types, as stated in the above paragraph. The description and table listing meet the 10 CFR 54.4(a)(1) requirement to identify and list those structures and components subject to an aging management review, and is consistent with previously approved LRAs.

Showing components on the license renewal drawings that are within the scope of license renewal, and subject to aging management review, based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are typically included based on proximity to safety-related SSCs. I&M's "spaces" approach to identifying 10 CFR 54.4(a)(2) components, which is based upon the physical location of safety-related SSCs (targets) that could be adversely affected by nonsafety-related components, results in a more functional and conservative accounting of the 10 CFR 54.4(a)(2) component types than could be provided by marked-up flow diagrams, which provide no physical location information. As a reviewer's aid, I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a matrix of systems and component types that perform a 10 CFR 54.4(a)(2) intended function.

RAI 2.3.4.3-4:

For those s stems, structures, and components (SScs) wiithin the scope of license renewi'al in accordlance wiith 10 CFR 54.4, 10 CFR 54.21('a)(1) requires the applicant to identifr and list those structures and components subject to an AIMR. The staff it-as utnale to dlecidle wthelther the applicant has consilered all the SSC's within time scope of license renewi'al in accordance l'ith 10 CFR 54.4 in order to sati.sy this requirement.

Attachment I to AEP:NRC:4034-05 Pag~e 26 LRA Section 2.1.2. 1. I states the followring:

The idlentification of coniponents subject to aging management review began wtith the dceternination of thie system evalulfation boundcai The sysftem evaluation boundawy inchicles those portions of the systeni that are necessary to ens ure tf/at tf/e intendcedfinctions of tfie system is-ill be performcd. Coniponents needcd to support each of the system-level intendced fiuetions idcentifiecd in ihe scoping process are included w,'ithin the systen evaluation boundcay However, the staff is unable to verify w/fhether the applicant has identified all the coniponents that peformn an intendedfilnction because in its LRA tf/e applicant has not identifiecd the coniponents wtithin the system evaluation boundary. The staff needs to verify tfis information in order to effect ively review thfe LRA ursing the Standard Review Plan for Review of License Renewt'al Applicationsfor Nuclear Powter Plants (ANUREG-1800), dated.Iuly 2001, of w'hich Section 2.3. 1 gives he following guidance:

For a niechanical system that is within the scope of license renewal, the applicant sholdt idcentify the portions of the systeni that peiforrin an intended finction, as defined in 10 CFR 54.4(b). The applicant may identifjv these particular portions of the sysfent in marked-up piping and instrument diagramls (P&IDs) or other niedia. This is "scoping" of mechanical components in ac sstemn to identifq those that are within the scope of license renewalfor a system.

LRA Section 2. 1.2. 1.2 states that "licensing renewal cdrawiings were created by mnarking mechanical flo1' diagrams to indicate only thiose components within ihe sysfeni evaluation bounlaries that require an aging nianagenient review.

The inforniation provided in the LRA is not sufficient for tf/e staff to coniplete its review of the scoping of components wt'itf/in mnechanical systenis because licensing renewral drawings marked only those portions of the mechanical systems that require an A AIR.

Confirn that thie systenm components niarked on licensing renewtal drawings LRA-1-5105D LRA-1-5105E, LRA-1-5106A, LRA-I-51IA, LRA-1-S1IOB, LRA-1-5113, LRA-2-5105D, LRA-2-5105E, LRA-2-5106A, LRA-2-5110B, and LRA-1-5113 depict all the components wititin the auxiliaijfeedwater (AFW,) system that perforni an intended finction (ie., within the systemn evaluation bounidaty). If not, provide a list of those conponents that performi an intended finction but are not niarked on licensing renewal drawiings or provide revised drawtings as needed to include the additional components.

I&M Response to RAI 2.3.4.3-4:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures. active and short-lived

Attachment I to At l':NRC:4034-05 Page 27 components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CER 54.4(a)(2). Active components that were screened out, and not highlighted on flow diagrams, are those that do not meet the 1O CER 54.21(a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

No short-lived components that perform an IO CFR 54.4 intended function are depicted on license renewal drawings LRA-1 -5105D, 5105E, 5106A, 511 OA, 511 OB, 5113, LRA-2-5105D, 5105E, 5106A, 51 10B, or 5113.

No AFW system components are in scope for the 10 CFR 54.4(a)(2) criterion.

RAI 2.3.4.4-2:

For those systems, structures, and components (SSC's) ii'ithin the scope of license rene'al in accordance with 10 CFR 54.4, 10 CFR 54.21(a)(1) requires the applicant to identif' andl list those strucltures and components subject to an AAIR.

The staff iaias unable to decide ii'hether the applicant has considered all the SSCs wecithin the scope of license renewral in accordance wtith 10 CER 54.4 in order to satisfy' this requirement.

LRA Section 2.1.2. 1. 1 states the follow-ing:

The identification of components subject to aging managemnent reviei11 began is'ith the letermination of the system evaluation houndary.

The systeln evaluation bounlary incitles those portions of the s'stemn that are necessary to ensure that the intendedfuncltions of the system nt'ill be performnedI. Components needlel to support each of the system-level intended functions identified in the scoping process are included wt ithin the system evaluation houndlamy lon'euver, the staff is unable to verifj, ithether the applicant has identified all the components that perform all intendedfiunction because in its LRA the applicant has not identified the components within the systein evaluation bounclar).

The staff neetds to verify this information in order to effectively review the LRA uIsing the Standard Review, Plan for Review of License Renew~al Applications for Nuclear Powrer Plants (ANUREG-] 800), dated Jully 2001, of which Section 2.3.1 gives thefolloit'ing guidance:

For a mechanical system that is within the scope of license renewal, the applicant should idlentifr the portions of the s.jwteni that performn an intendedfinction, as defineLd in 10 CFR 54.4(b). The applicant may identify these particular portions of the.sstem in,narked-up piping and instrument diagrams (P&ID.s) or other mnedia. This is 'scoping" of mechanical components in a cS)Wtem to itlentif3' those that are ii'ithin the scope of license renemwal for a systen.

Attachment I to AEP:NRC:4034-05 P'age 28 LRA Section 2.1.2.1.2 states that "licensing renewal dirawings were created by marking mechanical flow diagramns to indicate on1b' those components within the systemi evaluation boundaries that require an aging management review.

The information provided in the LRA is not sufficient for the staff to complete its review of the scoping of components within mnechanical sstenms because licensing renewal drawings marked only those portions of i/ie nechanical systems that require an A AIR.

Confirm that 11e systemmi comnponents marked on) licensing renewtal drawrings LRA-1-5105, LRA-1-5105B, LRA-1-5105D, LRA-1-5141A, LRA-2-5105B, LRA-2-5105D, and LRA-2-5141A depict all the components wtithin the steam generator bloit'doit'n (BD) systemz that petform an intendedfiunction (i.e., within the systent evaluation boundar;). If not, provide a list of those components that perform an intended funclion but are not marked on licensing renewal b drawings or provide revised drawings as needed to include the additional components.

I&M Response to RAI 2.3.4.4-2:

The system components highlighted on the license renewal drawings indicate all components that perform an intended function with the exception of structures, active and short-lived components, and those components that are in scope and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2). Active components that 'were screened out, and not highlighted on flow diagrams, are those that do not meet the 10 CFR 54.21(a)(1)(i) criteria, as identified in NEI 95-10, Appendix B. This includes items such as instrumentation, motors and valve operators.

Marking up the license renewal drawings to show components that are in scope, and subject to aging management review, based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are included if they are installed in the area of safety-related SSCs, and proximity to safety-related SSCs cannot be determined from functional flow diagrams. I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a list of BD system component types that perform a 10 CFR 54.4(a)(2) intended function.

No short-lived components that perform a 10 CFR 54.4 intended function are depicted on license renewal drawings LRA-1-5105, 5105B, 5105D, 5141A, LRA-2-5105B, 5105D, or 5141A.

Attachment I to Al l':NRC:4034-05 Page 29 RAI 2.3.4.4-3:

LRA Section 2.1.2.1.2 states the following:

Licensing renewal d~raniings were createl bya marking mechanicalflois' diagrams to indicate only those components within the system evaluation boundlaries that require an aging mianagemnent review. Comnponents that are wtithin the scope of license renewal based solely on tile criterion of 10 CFR 54.4(a) (2) are not generally indicated on ti/e drawmings but are described in Section 2.3 annd listed in Table 3.3.2-11.

10 CFR 54.21(a) (1) requires the applicant to ilentifj and list those structures and comnpoinents subject to an IAMR.

T/ie staff dloes not believe t/he applicant met this requirement because ti/e components the bloitdo~tn (BD) systeni meeting 10 CFR 54.4(a) (2) are neither ilentliiel on d~rawcings, nor listed. The applicant inchled these conm)onents as component tyipes in LRA Table 2.3.4-4 instead of as indivicldually listed components.

The BD system is identified in LRA Section 2.3.3. 11 as containing components that meet criteria 10 CFR 54.4(a)(2). Confirnm that the systeme comiponents niarked on licensing renetwal drawt ings LRAt-1-5105, LRA-1-51051, LRA-1-5105D, LRA-1-5141A, LRA-2-5105B, LRA-2-510)5D, and LRA-2-5141A depict all t/e components wcithin the BD s5stenz that mfeet criteria of 10 CFR 54.4(a)(2). If not, providle a list of these components t/hat are not narked on licensing renewt'al dirate'ings or prov idle revised drawsings as needled to inclule the adlditional conh/)onents.

I&M Response to RAI 2.3.4.4-3:

The RAI correctly states that the components meeting 10 CFR 54.4(a)(2) are grouped as "component types" in the LRA tables instead of as individual components. With few, if any, exceptions this is the approach followed by previous license renewal applicants, including those who have been granted a renewed license.

This is true for components meeting 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(3), as wvell as those meeting 10 CFR 54.4(a)(2).

As stated in LRA Section 2.1.2.1.2, components within the scope of license renewal based solely on the criterion of 10 CFR 54.4(a)(2) are not generally indicated on the license renewal drawings but are described in LRA Section 2.3 and listed in LRA Table 3.3.2-11. These components are grouped as component types, as stated in the above paragraph. The description and table listing meet the 10 CFR 54.4(a)(1) requirement to identify and list those structures and components subject to an aging management reviewv, and is consistent with previously approved LRAs.

Showing components on the license renewal drawings that are within the scope of license renewal and subject to aging management review based solely on the criterion of 10 CFR 54.4(a)(2) would be of minimal, if any, value since such components are typically included based on proximity to safety-related SSCs. I&M's "spaces" approach to identifying

Attachment I to AEP:NRC:4034-05 Page 30 10 CFR 54.4(a)(2) components, which is based upon the physical location of safety-related SSCs (targets) that could be adversely affected by nonsafety-related components, results in a more functional and conservative accounting of the 10 CER 54.4(a)(2) component types than could be provided by marked-up flow diagrams, which provide no physical location information. As a reviewer's aid, I&M's response to RAI 2.3.3.11-1 (Reference 1) provides a matrix of systems and component types that perform a 10 CER 54.4(a)(2) intended function.

References

1. Letter from M. K. Nazar, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant, Units I and 2, License Renewal Application - Response to Requests for Additional Information on Scoping and Screening Results," AEP:NRC:4034-01, dated May 7, 2004.

to AEP:NRC:4034-05 Floxv Diagrams for the Donald C. Cook Nuclear Plant, Units I and 2, Feedwater System (OP-1-5106-49 and OP-2-5106-44)

THIS PAGE IS AN OVERSIZED DRAWING OR

FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:

DWG. NO. OP-i -5106-49 "FLOW DIAGRAM FEEDWATER" WITHIN THIS PACKAGE..

OR BY SEARCHING USING DWG. NO. OP-il-5106-49 D-O1

THIS PAGE IS AN OVERSIZED DRAWING OR

FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:

DWG. NO. OP-2-5106-44 "FLOW DIAGRAM FEEDWATER UNIT NO. 2" WITHIN THIS PACKAGE..

OR BY SEARCHING USING DWG. NO. OP-2-5106m44 D-02