ML030830095

Staff Comments to Industry Guidance on Revised 54.4 (a)(2) Scoping Criterion (Non-Safety Affecting Safety) for License Renewal

ML030830095
Person / Time
Site:	PROJ0690
Issue date:	03/21/2003
From:	Kuo P Division of Regulatory Improvement Programs
To:	Alexis Nelson Nuclear Energy Institute
Kang P, NRR/DRIP/RLEP, 415-2779
References
Download: ML030830095 (7)

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March 21, 2003Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708

SUBJECT:

STAFF COMMENTS TO "INDUSTRY GUIDANCE ON REVISED 54.4 (a)(2)SCOPING CRITERION (NON-SAFETY AFFECTING SAFETY)" FOR LICENSE RENEWAL

Dear Mr. Nelson:

By letter dated February 24, 2003, the Nuclear Energy Institute (NEI) provided industryguidance in response to the proposed staff's interim staff guidance (ISG) letters dated December 3, 2001, and March 15, 2002, on the identification and treatment of structures, systems, and components (SSCs) consistent with the scoping criterion specified in 10 CFR 54.4(a)(2) for license renewal. The industry has developed this guidance to ensure that the scoping of non-safety related SSCs is conducted in a consistent manner by applicants requesting a renewed license in accordance with the requirements of 10 CFR 54.4(a)(2).

Based on the staff's review of the draft guidance, we are providing the enclosed comments.

We would like to schedule a public meeting to discuss these comments for a timely resolution of this ISG.For the resolved ISGs, it is also possible that comparable changes might need to be made toNEI 95-10, Revision 3, "Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.Sincerely, /RAPao-Tsin Kuo, Program DirectorLicense Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690

Enclosure:

As stated cc w/encl: See next page Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708

SUBJECT:

STAFF COMMENTS TO "INDUSTRY GUIDANCE ON REVISED 54.4 (a)(2)SCOPING CRITERION (NON-SAFETY AFFECTING SAFETY)

" FOR LICENSERENEWAL

Dear Mr. Nelson:

By letter dated February 24, 2003, the Nuclear Energy Institute (NEI) provided industryguidance in response to the proposed staff

's interim staff guidance (ISG) letters datedDecember 3, 2001, and March 15, 2002, on the identification and treatment of structures, systems, and components (SSCs) consistent with the scoping criterion specified in 10 CFR 54.4(a)(2) for license renewal. The industry has developed this guidance to ensure that the scoping of non-safety related SSCs is conducted in a consistent manner by applicants requesting a renewed license in accordance with the requirements of 10 CFR 54.4(a)(2).

Based on the staff

's review of the draft guidance, we are providing the enclosed comments.We would like to schedule a public meeting to discuss these comments for a timely resolution of this ISG.For the resolved ISGs, it is also possible that comparable changes might need to be made toNEI 95-10, Revision 3, "Industry Guidance for Implementing the Requirements of 10 CFRPart 54 - The License Renewal Rule.

" If you have any questions regarding this matter, pleasecontact Peter Kang at 301-415-2779.Sincerely, /RA/Pao-Tsin Kuo, Program DirectorLicense Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690

Enclosure:

As stated cc w/encl: See next page Distribution: See next pageC:\ORPCheckout\FileNET\ML030830095.wpd OFFICELA: RLEP:DRIPPM:RLEP:DRIPSC:RLEP:DRIPPD:RLEP:DRIPNAMEYEdmondsPKangSLeePTKuo DATE3/20/033/20/033/20/033/21/03OFFICIAL RECORD COPY DISTRIBUTION: Dated: March 21, 2003 HARD COPY RLEP RFProject ManagerE-MAIL:PUBLICW. Borchardt D. Matthews F. Gillespie RidsNrrDe E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden H. Nieh G. Holahan H. Walker S. Black B. Boger D. Thatcher R. Pettis G. Galletti C. Li J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Smith (srs3)

T. Kobetz R. Assa C. Munson RLEP Staff

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A. Thadani C. Julian R. Gardner M. Farber M. Modes J. Vora STAFF COMMENTS ON INDUSTRY GUIDANCE ON 54.4(a)(2) SCOPING CRITERION1.The position paper should state the staff

's evaluations have indicated that a combinationof a desk-top review of structures, systems, and components (SSCs) and a plant walkdown of areas containing a combination of safety-related and non-safety-related SSCs is the most effective means of identifying SSCs which meet the criterion, and that the results of these activities should be maintained in a retrievable and auditable form.2.Section 5.2, Preventive OptionThe Nuclear Energy Institute (NEI) position states that pipe whip, jet impingement, sprayor flooding from non-safety-related (NSR) systems could create additional failures of safety-related (SR) SSCs. The staff believes that this sentence should be revised as follow: "Physical impacts, such as pipe contact (pipe falling such that it physicallycontacts safety-related equipment), pipe whip, jet impingement, spray or flooding, etc.,

from NSR SSCs could create additional failures of SR SSCs.

"This revision specifically identifies the need to consider the potential for structures andcomponents (SCs) falling onto SR SCs and is consistent with industry operating experience with identified failures.3.Section 5.2.1.1, Loss of a Safety-Related Component vs Loss of a Safety-RelatedFunctionThe NEI position implies that a NSR SSC need not come into scope if its failure will notadversely impact on a safety-related function. The staff does not agree. This issue has been the topic of discussion during all license renewal application (LRA) audit review activities, and to date applicant

's have not implemented such an approach. The Commission in the Statement of Consideration (SOC) for the Rule clearlyarticulated that the applicant should consider the potential for failure of safety-related systems, structures, or components from performing their intended function(s) and did not limit the scope to that of system intended function(s) solely.Specifically, the SOC states, in part: "The first two categories of systems, structures,and components discussed in the new scope section (Sec. 54.4(a)(1) and (a)(2)) are the same categories defined in the previous definition of systems, structures, and components important to license renewal. These scoping categories concern (1) all safety-related systems, structures, and components, and (2) all non-safety related systems, structures, and components that support the function of a safety-related system, structure, or component or whose failure could prevent a safety-related system, structure, or component from satisfactorily fulfilling its intended function(s)."Enclosure 2The staff has therefore taken the position that all non-safety-related systems, structures,and components that support the function of a safety-related system, structure, or component or whose failure could prevent a safety-related system, structure, or component from satisfactorily fulfilling its intended function(s), should be initially included in scope.4.Section 5.2.1.2, Equipment Used to Establish Initial ConditionsThe NEI position states that the function of NSR equipment to establish initial conditionsfor equipment operation or accident assumptions does not constitute the basis for inclusion within the scope. The staff does not agree. The determination to include SSCs are needed to ensure initial conditions is plant-specific, and has been addressed this way in previous license renewal application (LRA) reviews. The applicant should identify design basis events (DBE) and whether the NSR SSCs are needed to ensure the initial plant conditions assumed in addressing the DBE5.Section 5.2.2.1, Systems and Components Containing Air/GasThe NEI position states that operating experience for systems containing air/gas hasshown no failures due to aging that have adversely impacted the accomplishment of a safety function, and that a review of site-specific operating experience should be performed to verify this assumption. This implies that the basis for exclusion from scope is plant-specific. The staff agrees and requests that NEI revise the guidance to state that the applicant should include the references to industry and plant-specific operating experience credited for establishing this position. The review results should be maintained in a retrievable and auditable form. 6.Section 5.2.2.2.1, High-Energy SystemsThe staff needs clarification about what is being addressed in this section. Specifically,does the discussion of physical impact of high-energy systems include seismic and non-seismic components, or is this addressed in Subsection 5.2.2.3 (see below)? Also, is pipe failure/separation considered a credible source of physical impact?7.Section 5.2.2.2.2, Moderate-/Low-Energy SystemsThe staff needs clarification about what is being addressed in this section. Specifically,does the discussion of spatial interactions of moderate- and low-energy systems include seismic and non-seismic components, or is this addressed in Subsection 5.2.2.3 (see below)? Also, is pipe failure/separation considered credible source of physical impact?8.Section 5.2.2.3, Non-seismic and Seismic II/I Piping and SupportsThe NEI paper states that this section is intended to describe the potential spatialinteraction of NSR piping systems that may fall on or otherwise physically impact SR SSCs. It states that operating experience confirms that pipe segments do not fall during seismic events. The staff agrees, but requests that the first sentence be revised to read 3"This section is intended to describe the potential spatial interaction of non-safety-related piping systems that may fall on or otherwise physically impact safety-related SSCs during a seimic event.

" Given this clarification, the staff believes that the discussion of the impacts of the failureof high-, moderate, and low-energy system components described in Sections 5.2.2.2.1 and 5.2.2.2.2 could be revised to clarify that failure of pipe segments due to non-seismic events can and do occur, and because of this, the physical impact of falling pipes should be considered when determining whether NSR piping should be brought into scope.9.Section 5.2.3.1, Exposure DurationThe NEI position states that only NSR SSCs whose failure could result in short-termfailure of a SR SSC need not be included within scope. The staff does not agree.

Neither the Rule, nor the SOC, considers duration of the failure of a SR SSC or function due to the failure of a NSR as a factor in determining whether a NSR SSC should be in scope. Further, this position has not been taken by previous applicants.10.Section 5.2.3.2, Fail-Safe ComponentsThe NEI position states that NSR SSCs that could only cause a failure of a fail-safecomponent, would not be considered in scope. The staff disagrees. It is not clear from the position taken by industry why a failure of a NSR SSC cannot impact the ability of a SR SSC from attaining it

's fail-safe state. The staff requests further dialog with theindustry on this issue to specifically confirm that a NSR SSC cannot impact a fail-safe SR SSC in such a manner as to preclude the SR SSC from fulfilling it

's intendedfunction(s).11.Section 6.0, Industry Guidance - Preventive OptionIn Item F, the NEI position states that the 54.4(a)(2) scoping methodology should bedocumented, along with the bases for the engineering judgements. The staff agrees.

However, in addition, the staff believes that to ensure that actions have been identified and have been or will be taken such that there is reasonable assurance that the SSCs that meet the 54.4(a)(2) criterion are adequately managed during the period of extended operation, the applicant will need to identify for the staff the components which meet 54.4(a)(2) and are subject to an aging management review, along with the associated aging management information (material, environment, aging effect(s), and aging management program/activity). We suggest the following revision:

"Document the plant-specific 54.4(a)(2) scoping methodology. The results from theapplication of this methodology will be plant-specific (commodity lists, component lists, or boundary drawings, etc.) and should be documented, including the bases for the engineering judgements made during this review.

"

NUCLEAR ENERGY INSTITUTE Project No. 690

cc:Mr. Joe BartellU.S. Department of Energy NE-42 Washington, DC 20585Ms. Christine S. SalembierCommissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. Alan P. NelsonNuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708 APN@NEI.ORGMr. Stephen T. HaleFlorida Power & Light Company 9760 S.W. 344 St.

Florida City, FL 33035Mr. William CorbinVirginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348George WrobelManager, License Renewal R.E. Ginna Nuclear Power Plant 1503 Lake Rd.

Ontario, NY 14519Mr. David LochbaumUnion of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919Ronald B. ClaryManager, Plant Life Extension V.C. Summer Nuclear Station Bradham Blvd.

P.O. Box 88 Jenkinsville, SC 29065Mr. John B. HermanManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

Post Office Box 550 Fort Calhoun, NE 68023-0550Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service

1424 16 th St., NW, Suite 404Washington, DC 20036Mr. Hugh JacksonPublic Citizen

's Critical Mass Energy & Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003Mary OlsonNuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Talmage B. ClementsManager - License Renewal Nuclear Engineering Services

CP&L 410 South Wilmington St.

Raleigh, NC 27602