ML20056E612

Forwards Request for Addl Info Re B&Wog 930505 Submittal of Rept Entitled, Integrated Plant Assessment Component Screening Methodology. Response Requested by 930903

ML20056E612
Person / Time
Issue date:	07/23/1993
From:	Hiltz T Office of Nuclear Reactor Regulation
To:	Mcconnell T BABCOCK & WILCOX CO.
References
PROJECT-683A NUDOCS 9308240334
Download: ML20056E612 (6)

Text

July 23, 1993 h

Project No. 683 Mr. Tony L. McConnell a

Program Director Generic License Renewal Program B&W Nuclear Service Company i

P.O. Box 10935 Lynchburg, Virginia 24506-0935

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE BABC0CK AND WILCOX OWNERS GROUP SUBMITTAL ENTITLED " INTEGRATED PLANT ASSESSMENT COMPONENT SCREENING METHODOLOGY" By letter of May 5, 1993, the Babcock and Wilcox Owners Group (BWOG) submitted to the U.S. Nuclear Regulatory Commission (NRC) a report entitled " Integrated Plant Assessment Component Screening Methodology." The NRC staff has reviewed this document and identified several areas where the staff requires additional information before concluding whether the component screening approach is acceptable.

These requests for additional information (RAls) are enclosed.

The staff is continuing its review of the proposed component screening methodology and may develop additional RAls.

The NRC staff will consider your responses to these RAls before developing a draft safety evaluation report on the BWOG component screening methodology submittal.

In order to maintain the proposed review schedule, the staff requests that you respond, in writing, to the enclosed RAls by September 3, 1993. Please contact me if you require clarification on any of the RAls or have questions or comments relating to this request.

This requirement affects less than ten (10) respondents, and therefore, is not subject to Office of Management and Budget review under Public Law 96-511.

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Original signed by:

Thomas G. Hiltz, Senior Project Manager License Renewal and Environmental Review 4

Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation

Enclosures:

RAls cc:

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Enclosure Requests for Additional Information Regarding the BWOG Generic License Renewal Program Submittal Entitled, " Integrated Plant Assessment Component Screening Methodology," dated April 28, 1993 l

RAI 2.1.1 As with the preceding document in this series, "... System /

Structure Screening Methodology," the limited level-of-detail in this component screening methodology document appears to be consistent with a high-level, top-tier approach.

The staff appears to be reviewing a methodology " concept" and the lack of detail may lead to inefficiencies in resolving license renewal issues.

Explain your intentions, if any, for integrating the-methodology reports and incorporating additional details into the documents.

(General)

RAI 2.1.2 In Section 3.1, " acceptance" criteria are defined for classifying components as important to license renewal (ITLR).

lhese criteria may be of little value to an applicant or to the staff in evtluating this component screening approach.

Explain, in more detail, how and when these criteria will be applied.

RAI 2.1.3 In Section 3.1, the first criteria states' that a component will be l

classified as ITLR if that component is required to function for the achievement of a system / structure ITLR function.

However, failure of one component (a single failure) in a safety system i

should not result in the loss of the systems safety function. How I

will your methodology consider a component regarding " contribution to the performance of a required function" as specified in 10 CFR Part 54? How will diversity and redundancy of ITLR functions be considered in your component screening methodology?

I RAI 2.1.4 In Section 3.1, " acceptance" criteria 2.b indicates that if a component failure results in the failure of structural support of an ITLR portion of a system, then the component is ITLR.

Why are structural supports singled out? Explain how other components, such as electrical power, which contribute to the performance of a required function or whose failure could directly prevent accomplishment of any of the required functions of an ITLR portion of a system, will be considered in your methodology.

RAI 2.1.5 In Section '3.1, you list three strategies for identifying components as ITLR.

l (A) How will Strategy I be integrated with the system / structure I

screening methodology?

It appears that this strategy is a stand-alone type approach, eliminating the need for a system / structure screening approach.

(B)

For Strategy 2, explain how system ITLR boundaries will be established. What' criteria will be used to establish system ITLR boundaries?

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(C)

For Strategy 3, how will.this process be integrated with the concept of an iterative approach for determining systems that j

are ITLR, where the identification of supporting functions for an ITLR component may lead to determination that a previously screened 'not-ITLR system' has some ITLR functions?

(D) How will these strategies be implemented?

RAI 2.1.6 In Section 3.1, Footnote 8 states that the criteria listed above reasonably define the information needed to comply with Sec -

tion 54.21 (a)(4) of the license renewal rule. The conclusion that addressing the criteria is sufficient to meet the intent of

" describe and justify" appears unfounded.

Explain the basis for this conclusion.

For example, consider Strategy 1.

What criteria 1

will be used to perform a " logical sort of the plant databases"?

RAI 2.1.7 Provide a list of generic ITLR functions-expected to be evaluated for each component.

(Section 3.2)

RAI 2.1.8 In Section 3.3, you indicate that aging evaluations are the third

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and final step of the integrated plant assessment. This appears inconsistent with the steps outlined in the license renewal rule.

Explain.

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Project No. 683 Babcock & Wilcox Owners Group Generic 6

License Renewal Program cc:

Mr. Robert B. Borsum Regional Administrator, Region II B&W Nuclear Technologies U.S. Nuclear Regulatory Commission 1700 Rockville Pike 1010 Marietta St., N.W. Suite 2900 Suite 525 Atlanta, Georgia 30323 Rockville, Maryl and 20852 Mr. M. E. Patrick Mary E. O'Reilly Compliance Centerior Energy Corporation Duke Power Company 300 Madison Avenue Oconee Nuclear Site Toledo, Ohio 43652 P.O. Box 1439 Seneca, South Carolina 29679 Michael Laggart Mr. R. L. Gill Manager, Corporate Licensing GLRP Licensing Coordinator GPU Nuclear Corporation c/o Duke Power Company One Upper Pond Road EC-09M Parsippany, New Jersey 07054 P.O. Box 1006 Charlotte, NC 28201-1006 Chairman Regional Administrator, Region IV Board of County Commissioners U.S. Nuclear Regulatory Commission of Dauphin County 611 Ryan Plaza Drive, Suite 1000 Daughin County Courthouse Arlington, Texas 76011 Harrisburg, Pennsylvarila 17120 Mr. Percy M. Beard, Sr.

Mr. James J. Fisicaro Vice President Director, Licensing Nuclear Operations Entergy Operations, Inc.

ATTN: Manager, Nuclear Operations Route 3, Box 137G Licensing Russelville, Arkansas 72801 P.O. Box 219-NA-21 Crystal River, Florida 34423-0219 Mr. John R. McGaha Earnest L. Blake, Jr., Esq.

Vice President, Operations Support Shaw, Pittman, Potts Entergy Operations, Inc.

and Trowbridge P.O. Box 31995 2300 N. Street H.W.

Jacksonville, Mississippi 39286 Washington, D.C.

20037 Mr. Robert W. Schrauder Regional Administrator, Region I Manager, Nuclear Licensing U.S. Nuclear Regulatory Commission Toledo Edison Company 475 Allendale Road 300 Madison Avenue King of Prussia, Pennsylvania 19406 Toledo, Ohio 43652 Regiond Administrator, Region 111 Mr. Donald C. Shelton U.S. Nuclear Regulatory Commission Vice President, Nuclear -

4 799 Roosevelt Road Davis-Besse Glen Ellyn, Illinois 60137 Centerior Service Company c/o Toledo Edison Company 300 Madison Avenue Toledo, Ohio 43652

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Project No. 683 Babcock & Wilcox Owners Group Generic License Renewal Program William Dornsife, Acting Director Chairman Bureau of Radiation Protection Board of Supervisors Pennsylvania Department of of Londonderry Township Environmental Resources R.D. #1 Geyers Church Road i

P.O. Box 2063 Middletown, Pennsylvania 17057 t

Harrisburg, Pennsylvania 17120 l

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