ML051710609
| ML051710609 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/2005 |
| From: | Lyons J Division of Systems Safety and Analysis |
| To: | Marion A Nuclear Energy Institute |
| Frumkin, d., NRR/DSSA/SPLB, 415-2280 | |
| References | |
| RIS-04-003, Rev. 1 | |
| Download: ML051710609 (4) | |
See also: RIS 2004-03
Text
September 2, 2005
Mr. Alexander Marion
Senior Director, Engineering
Nuclear Generation Division
Nuclear Energy Institute
1776 I Street, NW, Suite 400
Washington, D.C. 20006-3708
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION RESPONSE REGARDING
NUCLEAR ENERGY INSTITUTE 04-06, GUIDANCE FOR SELF-ASSESSMENT
OF CIRCUIT FAILURE ISSUES
Dear Mr. Marion:
On March 16, 2005, you submitted Revision L of Nuclear Energy Institute (NEI) 04-06,
Guidance for Self-Assessment of Circuit Failure Issues (ADAMS Accession No. ML050760219).
The staff supports the industry's efforts to standardize the self-evaluations related to circuit
failure issues.
The enclosure to this letter provides our specific comments to NEI 04-06. In particular,
licensees that perform NEI 04-06 may identify non risk-significant configurations which are not
in compliance with their plant licensing basis. Such non-compliances must be resolved in a
timely fashion and in accordance with NRC regulations. Also, we would like to reiterate that
Regulatory Issue Summary (RIS) 2004-003, Revision 1, does not differentiate between required
and associated circuits.
We thank you for your assistance in improving licensees understanding of the need for circuit
failure evaluation. Please contact Dr. Sunil Weerakkody or Mr. Daniel Frumkin of my staff if
you have additional questions on this matter.
Sincerely,
/RA/
James E. Lyons, Director
Division of Systems Safety and Analysis
Office of Nuclear Reactor Regulation
Enclosure: As stated
The staff supports the industry's efforts to standardize the self-evaluations related to circuit
failure issues.
The enclosure to this letter provides our specific comments to NEI 04-06. In particular,
licensees that perform NEI 04-06 may identify non risk-significant configurations which are not
in compliance with their plant licensing basis. Such non-compliances must be resolved in a
timely fashion and in accordance with NRC regulations. Also, we would like to reiterate that
Regulatory Issue Summary (RIS) 2004-003, Revision 1, does not differentiate between required
and associated circuits.
We thank you for your assistance in improving licensees understanding of the need for circuit
failure evaluation. Please contact Dr. Sunil Weerakkody or Mr. Daniel Frumkin of my staff if
you have additional questions on this matter.
Sincerely,
/RA/
James E. Lyons, Director
Division of Systems Safety and Analysis
Office of Nuclear Reactor Regulation
Enclosure: As stated
DISTRIBUTION:
SPLB R/A
TMartin
JHannon
SWeerakkody
DFruchter
PKoltay
PQualls
RGallucci
DFrumkin
STreby
RGibbs
CPatel
ADAMS Accession # ML051710609
NRR-106
OFFICE
SPLB/DSSA/NRR
SC:SPLB/DSSA/NRR
BC:SPLB/DSSA/NRR
SC:IIPB/DIPM/NRR
NAME
DFrumkin
SWeerakkody
JHannon
RGibbs
DATE
06 / 27 /05
07 / 03 /05
07 / 07 /05
07 / 29 /05
OFFICE
D:DSSA/NRR
NAME
STreby
JLyons
DATE
08 / 17 /05
09 / 02 /05
ENCLOSURE
NRC COMMENTS REGARDING THE NEI 04-06, GUIDANCE FOR SELF-ASSESSMENT FOR
CIRCUIT FAILURE ISSUES
NRC staff comments are provided below.
1. Page 1, fourth paragraph. The guidance in NEI 04-06 does not assess compliance with a
plant's licensing basis and applicable rules. Licensing bases are plant specific and must be
assessed against plant specific license basis documents.
2. Page 1, fourth paragraph states, As an example, providing 20' of separation between
redundant trains with no intervening combustibles is an acceptable method for
compliance . . .. Twenty feet of separation without intervening combustibles also requires
detection and automatic suppression.
3. Page 3, first paragraph. Delete required and associated since Regulatory Issue Summary
(RIS) 2004-03, Rev. 1 does not use these terms. Make this change throughout the
document.
4. Page 3, second paragraph, Section 2.2. Note that although the assumption of the
consideration of a maximum of two concurrently damaged cables is consistent with RIS 2004-03, Rev. 1, it may not be consistent with a plants specific licensing basis. The NRC
will use the plants licensing basis for determining compliance.
5. Page 3, Intent of Screening process. The intent must comply with the licensing bases of
the facility. Even violations that are screened to green or are minor that are identified
through this process are violations and must be identified and addressed.
6.
Page 5, Section 3.2 paragraph 1. Identify the . . . that could significantly impact. Delete
the word significantly, since limiting identification findings to a judgement of what are
significant does not comply with the regulation.
7. Figure A-1 (on page 25) allows screening with 20' separation. It should also mention
detection and automatic suppression.
8. Figure A-1 (on page 56) Should not allow screening low risk issues without compliance
with regulations.
9. Appendix B. This appendix is devoted to required and associated circuits. The RIS that
this document implements does not use these terms. Rather the RIS relates only to failures
that could adversely affect safe shutdown, regardless of how they are classified. Therefore,
the judgments in this appendix are not consistent with the RIS and should be deleted. Also,
based on the technical basis of the appendix, the staff has issues with the determinations
(see NRC comments dated 4/27/2004, ADAMS Accession No. ML042270373).
10. Appendix C, Template. This template makes a distinction between required and associated
circuits. RIS 2004-03, Rev. 1, does not make this distinction.