ML033290170
| ML033290170 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/2003 |
| From: | Sunil Weerakkody Plant Systems Branch |
| To: | Emerson F Nuclear Energy Institute |
| Iqbal, N 415-3346 | |
| References | |
| Download: ML033290170 (5) | |
Text
November 25, 2003 Mr. Fred Emerson Senior Project Manager Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
RESPONSE TO EMAIL DATED NOVEMBER 5, 2003
Dear Mr. Emerson:
By an Email dated November 5, 2003, you asked me to provide the status of nine items of interest. I have listed these items and our responses in the Attachment.
A number of your requests require us to contact our internal stakeholders and receive their views. As the attachment indicates, we have shared all of your requests and the Fire Protection Programs (FPP) views on your requests with the internal stakeholders and we are awaiting their responses.
As mentioned before, a number of issues and requests such as your proposal on self-assessment of associated circuits and the proposed incentives to adopt National Fire Protection Association (NFPA) 805 require consideration of changes to our current processes and policy.
As such, I am having discussions with my management about the possibility of forming a steering committee on fire protection issues to enhance our effectiveness in responding to your requests.
As you already know, the regulatory framework on the FPP is undergoing a number of major changes. This is reflected by the two ongoing rule making activities pertaining to manual actions and NFPA 805, as well as our efforts in the area of associated circuit analysis. These major changes and other emerging issues require us to frequently communicate with all of our major internal and external stakeholders in the appropriate forums. To ensure effective communications with the appropriate burden to my staff, and after discussions with my management, I have decided to hold two meetings per year with each of our major stakeholders (the regions, the Nuclear Energy Institute, the Advisory Committee on Reactor Safeguards (ACRS) sub committee).
In addition to the above, our periodic update of the Fire Protection Implementation Plan (FPIP) will keep you and all other stakeholders apprized of the status of ongoing issues. In this context, I have asked my staff to include key milestones on all issues of interest to you in the FPIP. In the future, please contact Alex Klein of my staff in order to include all issues of interest in the FPIP.
2 I appreciate your time and patience while we revise our internal processes to cater to the unique needs of the FPP. If you have any questions regarding this letter, please contact me at (301) 415-2870.
Sincerely, Sunil Weerakkody, Chief //RA//
Fire Protection Engineering and Special Projects Section Plant Systems Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation
2 I appreciate your time and patience while we revise our internal processes to cater to the unique needs of the FPP. If you have any questions regarding this letter, please contact me at (301) 415-2870.
Sincerely, Sunil Weerakkody, Chief Fire Protection Engineering and Special Projects Section Plant Systems Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation DISTRIBUTION:
ADAMS SPLB R/A SBlack MJohnson JHannon PLain EBrown DFrumkin RGallucci RPerch MSalley NIqbal JBirmingham AKlein RDudley CHaney PQualls DOCUMENT NAME: Email_Response_Letter.wpd OFFICE NRR/DSSA/SPLB SC:NRR/DSSA/SPLB NAME SWeerakkody JHannon DATE 11/ 25/03 11/25/03 Official Copy
Response to Email Dated November 5, 2003 Status of the Fire Protection Related Issues (1) Time frame for detailed NRC comments on NEI 00-01, based on our October 17 meeting.
Response
We will send you additional observations and comments discussed on October 17, 2003 with specific actions (if relevant) by December 15, 2003.
Lead staff contact: Ray Gallucci (RHG ) (301 415-1255).
As we indicated in our previous letter, the staff is reviewing NEI 00-01 in the context of 10 CFR Part 50.48, which will incorporate NFPA 805. The staffs vision for NEI 00-01 is to possibly endorse portions its circuit analysis methodology in the planned Regulatory Guide to accompany the rule.
Also, in light of the historical issues that led to NEI-00-01, we emphasize that the NRC cannot endorse several key issues in the overall approach in NEI-00-01. As we stated during our last and previous communications to you, staff does not plan to endorse the implicit changes to the licensing basis via NEI-00-01 deterministic methods. Rather, our approach is to combine the industry findings on hot-short probabilities and the current licensing basis of plants to risk-inform associated circuit analysis. To this extent, I have directed my staff to examine the risk screening tool that you provided in Chapter 4.0 of NEI-00-01 to develop a risk-screening tool to process findings in the area of associated circuits. At the present time, the staff is examining how this can be accomplished within the overall risk assessments principles in the revised Fire Protection Significance Determination Process. As demonstrated in my answers to another question in your list, we are also examining the Appendix B-2 of NEI-00-01 for possible endorsement, if we can substantiate your postulation that multiple high impedance failures are not credible.
(2) Time frame for the circuit failures workshop postponed from October 13-14.
Response
Our current plans are to hold this workshop in the first quarter of 2004. Please call Mark Salley during the last week of December to receive the planned date for this workshop.
Lead staff contact: Mark Salley (MXS3) (301 415-2840).
(3) Time frame for an NRC response to our 805 incentives letters (you responded in a general way to the first one, indicating that you were considering our proposals).
Response
We have already disseminated your request to the responsible NRC offices and divisions and we are awaiting their input. We will update you on the status of these proposed incentives during our next periodic meeting (March, 04).
Lead staff contact: Paul Lain (PWL) (301 415-2346).
ATTACHMENT
2 (4) Time frame for a response to our circuit failure self-assessment proposal.
Response
We have already disseminated your request to other NRC offices and divisions and we are awaiting their input. We will update you on the status of these proposed incentives before December 31, 2003. Given the extensive changes that you had asked us to consider, it will take additional time for us to provide feedback, even though you indicated that you would wish to hear our feedback in early December.
Lead staff contact: Mark Salley (MXS3) (301 415-2840).
(5) Status of staff consideration of the industry request (from our SDP meeting on October
- 30) for participation in the SDP tabletops. You will be getting a letter in the next day or so with our detailed comments on the SDP as a follow-up to the October 30 meeting.
Response
We have communicated your request to the responsible branch. Please contact them directly.
Lead staff contact: Robert Perch (RLP) (301 415-1422).
(6) Status of NRC consideration of our comments on the RIS.
Response
We have received your comments. We plan to disposition them and issue the final Regulatory Information Summary (RIS) by end of December 2003.
Lead staff contact: Mark Salley (MXS3) (301 415-2840).
(7) Status of NRC consideration of our comments on NUREG-1805 (we just sent them in).
Response
We have received your comments. We plan to disposition them and issue the final NUREG-1805 by January 2004.
Lead staff contact: Naeem Iqbal (NXI) (301 415-3346).
(8) Status of the response to the anonymous utility question we sent in on Multiple High Impedance Faults.
Response
I have asked Dan Frumkin of my staff to investigate this issue. He has started evaluating the proposal. We will update you on the status of these proposed incentives during our next periodic meeting (March, 2004).
Lead staff contact: Daniel Frumkin (DXF1) (301 415-2280).
(9) Time frame for issuing NUREG-1778 for comment.
Response
We plan to issue draft NUREG-1778 in December 2003.
Lead staff contact: Mark Salley (MXS3) (301 415-2840).