ML062130056

Email: (PA) Non-Safety Related Scs

ML062130056
Person / Time
Site:	Pilgrim
Issue date:	06/29/2006
From:	Jennifer Davis Division of Regulatory Improvement Programs
To:	Ellis D, Ford B Entergy Nuclear Operations
References
%dam200612, TAC MC9669
Download: ML062130056 (1)

Text

avs-No-aeRelated S~s Jae Pagej1 From: James Davis To: Bford@entergy.com; Dellisl @entergy.com Date: 06/29/2006 3:40:55 PM

Subject:

Non-Safety Related SCs Here is the question I discussed with you on the phone, Brian. How are non-safety related SCs handled in terms of elements 7, 8, and 9? Will there be a committment and an FSAR writeup to handle non-safety related SCs? I have attached the writeup from the Browns Ferry SER for information.

Jim CC: Kenneth Chang ; Peter Wen; Ram Subbaratnam

[,p,:\Tep)GW}oO.M M A2F 2 3534 Iae1 Mail Envelope Properties (44A42CC7.9CF : 22 : 35346)

Subject:

Non-Safety Related SCs Creation Date 06/29/2006 3:40:55 PM From: James Davis Created By: JAD@nrc.gov Recipients Action Date & Time entergy.com Transferred 06/29/2006 3:41:43 PM BFord (Bford@entergy.com) dellisl (Dellis 1@entergy.com) nrc.gov OWGWPO03.HQGWDOO1 Delivered 06/29/2006 3:40:55 PM KXC2 CC (Kenneth Chang) nrc.gov TWGWPO02.HQGWDOO1 Delivered 06/29/2006 3:41:00 PM RXS2 CC (Ram Subbaratnam) Opened 06/30/2006 10:08:57 AM nrc.gov TWGWPOO4.HQGWDO01 Delivered 06/29/2006 3:41:00 PM PXW CC (Peter Wen) Opened 07/05/2006 9:16:41 AM Post Office Delivered Route entergy.com OWGWPOO3.HQGWDOO1 06/29/2006 3:40:55 P]M nrc.gov TWGWPOO2.HQGWDO01 06/29/2006 3:41:00 P] nrc.gov TWGWPO04.HQGWDO01 06/29/2006 3:41:00 PIMt nrc.gov Files Size Date & Time MESSAGE 605 06/29/2006 3:40:55 PM Element 7, 8, and 9.wpd 11296 06/29/2006 11:08:20 AM Options Auto Delete: No Expiration Date: None

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Notify Recipients: Yes Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened

I James Davis - Element 7. 8. and 9.WDd Pane 11 1

[James Davis Element 7. 8. and 9.wDd

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3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on SCs subject to an AMR will be adequately managed so that their intended functions will be maintained consistent with the CLB for the period of extended operation.

SRP-LR, Branch Technical Position RLSB-1, "Aging Management Review - Generic," describes ten attributes of an acceptable AMP. Three of these ten attributes are associated with the quality assurance activities of corrective action, confirmation processes, and administrative controls. Table A.1 -1, "Elements of an Aging Management Program for License Renewal," of Branch Technical Position RLSB-1 provides the following description of these quality attributes:

• Corrective actions, including root cause determination and prevention of recurrence, should be timely.

• The confirmation process should ensure that preventive actions are adequate and that appropriate corrective actions have been completed and are effective.

a Administrative controls should provide a formal review and approval process.

SRP-LR, Branch Technical Position IOMB-1, "Quality Assurance For Aging Management Programs," noted that those aspects of the AMP that affect quality of SR SSCs are subject to the quality assurance (QA) requirements of 10 CFR Part 50, Appendix B. Additionally, for NSR SCs subject to an AMR, the existing 10 CFR Part 50, Appendix B, QA program may be used by the applicant to address the elements of corrective action, the confirmation process, and administrative controls. Branch Technical Position IQMB-1 provides the following guidance with regard to the QA attributes of AMPs:

• SR structures and components are subject to 10 CFR Part 50, Appendix B, requirements, which are adequate to address all quality-related aspects of an AMP consistent with the CLB of the facility for the period of extended operation.

For NSR SCs that are subject to an AMR for license renewal, an applicant has an option to expand the scope of its 10 CFR Part 50 Appendix B program to include these structures and components to address corrective actions, the confirmation process, and administrative controls for aging management during the period of extended operation.

In this case, the applicant should document such a commitment in the FSAR supplement in accordance with 10 CFR 54.21 (d).