ML052290388

Summary of July 2005 Conference Call with Nuclear Energy Institute to Discuss Status of Fire Protection Issues

ML052290388
Person / Time
Issue date:	08/15/2005
From:	Sunil Weerakkody Plant Systems Branch
To:	Nuclear Energy Institute
Frumkin, d., NRR/DSSA/SPLB, 415-2280
References
Download: ML052290388 (15)

Text

August 15, 2005 STAKEHOLDERS: Nuclear Energy Institute, and Industry Representatives FROM: Sunil Weerakkody, Chief /RA/

Fire Protection and Special Projects Section Division of Systems Safety and Analysis

SUMMARY

OF JULY 2005 CONFERENCE CALL WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS STATUS OF FIRE PROTECTION ISSUES In 2003, the U. S. Nuclear Regulatory Commission (NRC) staff, Nuclear Energy Institute (NEI),

and industry representatives developed fire protection issue management protocol (IMP)

[ADAMS Accession No. ML031210232] to define a process for identifying, tracking, and resolving issues that may arise during NRC or industry review of guideline documents, plant-specific events, generic trends, and NRC research findings. The IMP does not displace any regulatory processes, but the IMP may supplement the regulatory process for issues that arise that do not yet meet the threshold of requiring regulatory action. On January 28, 2004, a suggestion was made to hold monthly calls between members of the NRC and NEI to determine the status of the items, provide any additions or updates, and review/revise priorities.

NEI took the action to take the lead to maintain the list of issues and add priority and status information. Public meetings would be held at regular intervals to discuss the specifics or resolve any concerns.

On July 25, 2005, the NRC staff conducted a conference call with representatives of the NEI and members of industry. This call was intended to determine the status of those items on the Issue Management Tracking List, provide any additions or updates, and review/revise priorities.

Prior to the phone call, NRC staff provided NEI and industry representatives a draft version of the tracking list (Attachment 1- Draft 4). During the meeting changes were made to the tracking list, and the final version of the tracking list is included as Attachment 2, Draft 5. includes two tables, Active Items and Completed Items. The Active Items will be used as talking points for the next meeting. The completed items will be available as a resource if needed. Following the next meeting, the completed items will not longer be included in the tracking list.

CONTACT: Daniel Frumkin, NRR/DSSA/SPLB 301-415-2280

2 Below is a list of the issues that were added to Issues Management Tracking List (ML041480161), since the NRC published the last list. These issues are as follows:

NFPA 805 - 10CFR50.48(c) Fire Protection Rule - Reg Guide - Item 805-8 Circuit Failure

- Clarification RIS - Item CF-8

- Generic Letter - Item CF-9 Other Fire Protection

- Containment Oil Misting - Item FP-7

- Mrule Consideration of Fire - Item FP-8

- Fire Hydrant (Grease Problem) - Item FP-9 The participants on the conference call are listed below:

NRC Participants NEI and Industry Participants R. Dipert A. Marion D. Frumkin C. Pragman S. Weerakkody D. Brandes P. Lain K. Singer P. Qualls R. Richter A. Klein F. Garret N. Iqbal Attachments: 1. Draft 4 - Issue Management Tracking List

2. Draft 5 - Issue Management Tracking List

ML052290388 NRC-001 OFFICE SPLB SPLB\SC NAME DFrumkin SWeerakkody DATE 08 / 15 / 05 08 / 15 / 05 INDUSTRY/NRC FIRE PROTECTION ISSUE MANAGEMENT TRACKING LIST Draft 4 - July 2005 Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility NFPA 805/10 CFR 50.48(c) 805-3 Processing of licensing basis issues N - High Addressed in 69 FR 33685 Addressed in public comments To be included in NEI 04- N, I DG-1139, NFPA 805, 69 (how issues are to be handled I - High and DG-1139 on DG-1139 (NEI #4). More 02 and NRC R.G. FR 33685, NEI 04-02 during transition) for licensees details required in DG-1139 adopting NFPA 805 (issue needs and/or NEI 04-02 more definition) 805-4 NFPA Implementing Guidance, NEI N - High Complete NEI 04-02 Will address NRC comments Submit Rev. 0 Complete ML051430568 04-02, Rev 0 (specific issues are I - High expeditiously to support on Rev F of NEI 04-02; tracked individually) industry adoption of NFPA Maximize content of NEI 04-805 licensing basis 02, minimize DG-1139 content 805-6 Consider adding guidance to the N/A SECY 04-0050 issued Complete SECY 04-0050 Rule Statements of Consideration regarding the Rules place in the regulatory hierarchy (10/15/03 mtg) 805-7 NRC response to public comments N -High Staff preparing response; Formally issue responses Complete?  ??? Comment/Response on DG-1139 I - High public meeting to discuss (SOC) handout for 1/26/05 mtg draft responses on 1/26/05 ML050480240 805-8 NRC issue final reg guide for N - High Minimize RG content - Agree with NRC position; RG NRC to Complete R.G. N DG-1139, NEI 04-02 adoption of NFPA 805 licensing I - High include guidance in NEI 04- should fully endorse NEI 04-02 basis (specific issues are tracked 02 individually) 805-9 Additional 805 Actions Circuit Failure ATTACHMENT 1

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility CF-2 NEI 00-01 full response/ (integrated N - High Developing. Letter at Requested Response to NEI letters N NEI letters 4/09/03 &

closure plan for circuit failure I - High Division Director level, 5/22/03 issues) expected out shortly. SW email 2/11/04 (specific issues below from 10/17/03 mtg) CF workshop expected Schedule July meeting to N, I September 8-9 discuss issue prior to Review the treatment of model and workshop in September parameter uncertainty with regards to sensitivity.

Provide NEI with some comments to N return the tone of NEI 00-01 to guidance versus a policy document and provide comments regarding changes needed in NEI 00-01 to conform to regulatory policy.

Review how the implementation guide will be treated should the N,I NRC decide to endorse its use.

CF-4a Circuit inspections N - High Preparing for resumption of Must have appropriate SDP in Develop inspection Complete Guidance in IP 71111.05 I - High inspections place guidance before SDP in IMC 0609, associated circuit Appendix F inspections resume CF-4b Circuit inspections N- High Preparing for resumption of Conduct preparatory self- Provide Rev L of NEI 04- Complete Sent March 16, 2005 I - High inspections assessments 06 CF-4c Circuit inspections N - High Inspections have resumed NRC accept self-assessment Response to Rev L of N I - High guidance NEI 04-06 06/30/05 CF-6 NUREG-1778 N -Low Feedback No action Complete NUREG-1778 deferred I - High requestedComments provided CF-7 Release report on NEI 00-01 pilots N - Med Determine if summary of I I - Low report can be provided in the near future CF-8 RIS for clarification of circuit N - High Positions stated in RIS Varies Incorporate stakeholder N Draft RIS ML051110160 analysis terms I - Low comments and finalize RIS CF-9 Additional clarification of circuit N-High Additional issues may NRC to determine if N analysis terms I-low require clarification additional clarifications are needed 2

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility Fire Barrier Issues FB - 1 Hemyc test plan N - High Complete testing Observe/participate in tests. Complete test plan Complete NRC test plan I - Low arrangements expeditiously. Provide comments on test ML051040193 No plans for soliciting further setup prior to tests.

comments on test plan.

FB-2 Hemyc Testing N-High Complete testing Complete Testing Complete ML051190046 - Hemyc I-Low ML051430409 - MT FB-3 Information Notice on Hemyc N-High Inform Industry of Issues IN Complete ML050890089 Results I-? unexpected test results FB-4 Generic communication on N- High NRC will collect information NRC to issue draft N July 2005 Fire protection web site has Hemyc/MT test results I-? regarding Hemyc/MT and generic communication been updated with licensees will act to ensure on Hemyc/MT applicable references.

compliance is met Other Fire Protection Issues FP-1 CO2 system lockouts - determine if N - Med Provided basis. Relatively Develop white paper Develop white paper for Complete White paper submitted Jan.

generic issue (call 10-10-03) - I - Low high risk issue. NRC concurrence before 31, 2005 address risk significance sending to industry FP -1a CO2 System Lockouts N-Med NRC to respond to NEI N July 05 I-Low white paper FP-2 Industry response to NRC position N - Med Preparing Complete and submit I July 15 NEI 02-03, Rev 0 on NEI 02-03 I - Med FP-3 Use of fire watches for non-safety N - Low Determine if compensatory None Issue position in final Complete RIS 2005 issued compliance issues (mtg 8-21-03) I - Med measure white paper will be form issued as generic communication FP-4 Epoxy coatings/flame spread N - Med Provided basis Preparing summary Provide letter to NRC Complete (10/10/03 call) I - Low with recommendations on issue resolution FP-4a Epoxy coating/flame spread N-Low NRC to respond to NEI N June 30 I-Low white paper FP-5 2003 National Regional Utility N - Low Obtain industry I Group action item on NRC regional I - Low feedback (industry public workshops (mtg 8/21/03) concerns/recommendatio ns)

FP-6 RCP seals (mtg 6-22-04) N-? Information required to Generic treatment of issue; Staff will consider request Complete IN 2005-14 I-H develop position delay regulatory action on for generic treatment inspection findings 3

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility FP-7 Containment Oil Misting N - Med Potential non-compliance Industry to survey and I  ?

I-? with III.O, if from RCPs. report Two plants Ginna and Waterford affected as RCPs.

Two plants Ft. Calhoun and San Onofre may be other oil source FP-8 Mrule consideration of fire N-High Maintenance Rule Prepare industry position I  ?

I-? evaluations should consider fire risk Inspections and Self-Assessments I/SA-1a FP self-assessments - NRC N-? Will consider when Develop self-assessment Complete engineering N consider fast track for implementing I - Med engineering self-assessment guidance self-assessment activity complete I/SA-1b FP self-assessments - NRC N-? Will consider when Develop self-assessment Complete and implement I consider fast track for implementing I - Med engineering self-assessment guidance revised self-assessment activity complete guidelines I/SA-3 Information Notice on triennial N - High Preparing None Complete IN N results I - Low I/SA-4 Determine feasibility of developing N - Low NRC Considering SDP N Performance Indicator for Fire I - Low Brigades Manual Actions MA-1 Draft feasibility criteria handed out N - High Complete October 17 NRC handout at October 17 meeting I - High on manual actions feasibility criteria FR 66501 NEI ltr 1/27/04 SECY 03-100 and corresponding SRM MA-2 Enforcement discretion for manual N - High Complete SECY 04-0233 and actions inspection findings I - High corresponding SRM FRN Vol. 70 No. 43 pg 10901 MA-3 Alternate shutdown manual actions N - High Proposed rule issued; public Same feasibility criteria as IP Proposed rule issued; N 2006 FRN Vol. 70 No. 43 pg I - Med comment received. NRC will 71111.05T (March 2003) public comment received. 10901 evaluate and provide should apply Final rule in development NEI ltr 5/23/05 position in final rule 4

NOTES:

Definitions 805 - issue related to NFPA 805 rulemaking or implementation CF - issue related to circuit failure issue closure, NEI 00-01, or associated circuit inspections FB - issue related to fire barriers FP - general fire protection issue INPO - issue related to INPO I/SA - issue related to fire protection inspections or self-assessments MA - issue related to manual actions 5

INDUSTRY/NRC FIRE PROTECTION ISSUE MANAGEMENT TRACKING LIST Active Items - Draft 5 - July 25, 2005 Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility NFPA 805/10 CFR 50.48(c) 805-3 Processing of licensing basis issues N - High Addressed in 69 FR 33685 Addressed in public comments To be included in NEI 04- N, I Nov 2005 DG-1139, NFPA 805, 69 (how issues are to be handled I - High and DG-1139 on DG-1139 (NEI #4). More 02 and NRC R.G. FR 33685, NEI 04-02 during transition) for licensees details required in DG-1139 adopting NFPA 805 (issue needs and/or NEI 04-02 more definition) 805-8 NRC issue final reg guide for N - High Minimize RG content - Agree with NRC position; RG NRC to Complete RG N Nov 2005 DG-1139, NEI 04-02 adoption of NFPA 805 licensing I - High include guidance in NEI 04- should fully endorse NEI 04-02 Address ACRS basis (specific issues are tracked 02 Comments individually)

Circuit Failure CF-7 Release report on NEI 00-01 pilots N - Med Determine if summary of I NEI follow up.

to NRC I - Low report can be provided in the near future CF-8 RIS for clarification of circuit N - High Positions stated in RIS Varies Incorporate stakeholder N Draft RIS ML051110160 analysis terms I - Low comments and finalize RIS NRC proposed RIS to address endorsement of NEI 00-01 for non-805 plants. RIS 2005-03 provides endorsement for 805 plants. RG to address.

Public meeting planned.

CF-9 Additional clarification of circuit N-High Additional issues may NRC to determine if N Fall 2005 Porposed genric analysis terms I-low require clarification additional clarifications communication to address are needed one-at-a-time.

Fire Barrier Issues ATTACHMENT 2

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility FB-4 Generic communication on N- High NRC will collect information NRC to issue draft N July 2005 Fire protection web site has Hemyc/MT test results I-? regarding Hemyc/MT and generic communication been updated with licensees will act to ensure on Hemyc/MT applicable references.

compliance is met FRN published July 25 for public comment - due Sept 23 ML051990212 Other Fire Protection Issues FP -1a CO2 System Lockouts N-Med NRC to respond to NEI I Fall 2005 NRC comment issued July I-Low white paper 20 ML05174005 Review NRC comments and determine if further action is warranted FP-2 Industry response to NRC position N - Med Preparing Complete and submit I Fall 2005 NEI 02-03, Rev 0 on NEI 02-03 I - Med NEI to follow up.

FP-4a Epoxy coating/flame spread N-Low NRC to respond to NEI N June 30 I-Low white paper FP-7 Containment Oil Misting N - Med Potential non-compliance Industry to survey and I Fall 2005 I-? with III.O, if from RCPs. report Two plants Ginna and Waterford affected as RCPs. NRC to provide specifics Two plants Ft. Calhoun and San Onofre may be other oil I - Review RIV white source paper FP-8 Mrule consideration of fire N-High Maintenance Rule NRC to provide specifics I Fall 2005 I-? evaluations should consider fire risk FP-9 Fire hydrants grease may cause NRC to issue IN N Winter .

corrosion 2005/

2006 Inspections and Self-Assessments I/SA-4 Develop SDP for Fire Brigades N - MED Preparing Complete draft and N I - Low provide to industry for comment Manual Actions MA-3 Alternate shutdown manual actions N - High Proposed rule issued; public Same feasibility criteria as IP Proposed rule issued; N Winter FRN Vol. 70 No. 43 pg I - Med comment received. NRC will 71111.05T (March 2003) public comment received. 2005/ 10901 evaluate and provide should apply Final rule in development 2006 NEI ltr 5/23/05 position in final rule 2

NOTES:

Definitions 805 - issue related to NFPA 805 rulemaking or implementation CF - issue related to circuit failure issue closure, NEI 00-01, or associated circuit inspections FB - issue related to fire barriers FP - general fire protection issue INPO - issue related to INPO I/SA - issue related to fire protection inspections or self-assessments MA - issue related to manual actions 3

Completed Items - These items will be deleted at the next revision of the tracking list.

INDUSTRY/NRC FIRE PROTECTION ISSUE MANAGEMENT TRACKING LIST Completed Items - Draft 5 - July 25, 2005 Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility NFPA 805/10 CFR 50.48(c) 805-4 NFPA Implementing Guidance, NEI N - High Complete NEI 04-02 Will address NRC comments Submit Rev. 0 Complete ML051430568 04-02, Rev 0 (specific issues are I - High expeditiously to support on Rev F of NEI 04-02; tracked individually) industry adoption of NFPA Maximize content of NEI 04-805 licensing basis 02, minimize DG-1139 content 805-6 Consider adding guidance to the N/A SECY 04-0050 issued Complete SECY 04-0050 Rule Statements of Consideration regarding the Rules place in the regulatory hierarchy (10/15/03 mtg) 805-7 NRC response to public comments N -High Staff preparing response; Formally issue responses Complete?  ??? Comment/Response on DG-1139 I - High public meeting to discuss (SOC) handout for 1/26/05 mtg draft responses on 1/26/05 ML050480240 Circuit Failure 4

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility CF-2 NEI 00-01 full response/ (integrated N - High Developing. Letter at Requested Response to NEI letters complete NEI letters 4/09/03 &

closure plan for circuit failure I - High Division Director level, 5/22/03 issues) expected out shortly. SW email 2/11/04 (specific issues below from 10/17/03 mtg) CF workshop expected Schedule July meeting to September 8-9 discuss issue prior to Review the treatment of model and workshop in September parameter uncertainty with regards to sensitivity. NEI 001-01, Rev. 1 finalized and sent to Provide NEI with some comments to NRC Jan 2005.

return the tone of NEI 00-01 to guidance versus a policy document and provide comments regarding changes needed in NEI 00-01 to conform to regulatory policy.

Review how the implementation guide will be treated should the NRC decide to endorse its use.

CF-4a Circuit inspections N - High Preparing for resumption of Must have appropriate SDP in Develop inspection Complete Guidance in IP 71111.05 I - High inspections place guidance before SDP in IMC 0609, associated circuit Appendix F inspections resume CF-4b Circuit inspections N- High Preparing for resumption of Conduct preparatory self- Provide Rev L of NEI 04- Complete Sent March 16, 2005 I - High inspections assessments 06 CF-4c Circuit inspections N - High Inspections have resumed NRC accept self-assessment Response to Rev L of complete I - High guidance NEI 04-06 CF-6 NUREG-1778 N -Low Feedback No action Complete NUREG-1778 deferred I - High requestedComments provided Fire Barrier Issues FB - 1 Hemyc test plan N - High Complete testing Observe/participate in tests. Complete test plan Complete NRC test plan I - Low arrangements expeditiously. Provide comments on test ML051040193 No plans for soliciting further setup prior to tests.

comments on test plan.

FB-2 Hemyc Testing N-High Complete testing Complete Testing Complete ML051190046 - Hemyc I-Low ML051430409 - MT 5

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility FB-3 Information Notice on Hemyc N-High Inform Industry of Issues IN Complete ML050890089 Results I-? unexpected test results Other Fire Protection Issues FP-1 CO2 system lockouts - determine if N - Med Provided basis. Relatively Develop white paper Develop white paper for Complete White paper submitted Jan.

generic issue (call 10-10-03) - I - Low high risk issue. NRC concurrence before 31, 2005 address risk significance sending to industry FP-3 Use of fire watches for non-safety N - Low Determine if compensatory None Issue position in final Complete RIS 2005 issued compliance issues (mtg 8-21-03) I - Med measure white paper will be form issued as generic communication FP-4 Epoxy coatings/flame spread N - Med Provided basis Preparing summary Provide letter to NRC Complete Aug 2005 (10/10/03 call) I - Low with recommendations on issue resolution FP-5 2003 National Regional Utility N - Low Obtain industry Complete Delete since no on recalls Group action item on NRC regional I - Low feedback (industry what hti sis about.

public workshops (mtg 8/21/03) concerns/recommendatio ns)

FP-6 RCP seals (mtg 6-22-04) N-? Information required to Generic treatment of issue; Staff will consider request Complete IN 2005-14 I-H develop position delay regulatory action on for generic treatment inspection findings WOG issue a tech bulletin Inspections and Self-Assessments I/SA-1a FP self-assessments - NRC N-? Will consider when Develop self-assessment Complete engineering Complete Overcome by events -

consider fast track for implementing I - Med engineering self-assessment guidance self-assessment delete activity complete I/SA-1b FP self-assessments - NRC N-? Will consider when Develop self-assessment Complete and implement Complete Overcome by event - delete consider fast track for implementing I - Med engineering self-assessment guidance revised self-assessment activity complete guidelines I/SA-3 Information Notice on triennial N - Low Preparing None Complete IN Complete results I - Low Manual Actions 6

Track-ing Action Action

1. Issue/origin Priority NRC Position Industry Position Next Action Responsi- Due Date Applicable References bility MA-1 Draft feasibility criteria handed out N - High Complete October 17 NRC handout at October 17 meeting I - High on manual actions feasibility criteria FR 66501 NEI ltr 1/27/04 SECY 03-100 and corresponding SRM MA-2 Enforcement discretion for manual N - High Complete SECY 04-0233 and actions inspection findings I - High corresponding SRM FRN Vol. 70 No. 43 pg 10901 NOTES:

Definitions 805 - issue related to NFPA 805 rulemaking or implementation CF - issue related to circuit failure issue closure, NEI 00-01, or associated circuit inspections FB - issue related to fire barriers FP - general fire protection issue INPO - issue related to INPO I/SA - issue related to fire protection inspections or self-assessments MA - issue related to manual actions 7