ML062860255
| ML062860255 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/17/2006 |
| From: | Lain P Office of Nuclear Reactor Regulation |
| To: | |
| Moulton C, NRR/DRA, 415-2751 | |
| References | |
| FAQ 06-00012, NFPA-805 | |
| Download: ML062860255 (5) | |
Text
NFPA-805 Transition Pilot Plant Frequently Asked Questions (Template)
Plant: Harris Nuclear Plant (HNP) FAQ # 06-00012 Submittal Date: 08-17-06 Licensee
Contact:
Elizabeth Kleinsorg Tele/email 704.651.5548 NRC
Contact:
Tele/email Subject Interpretive Guidance? Yes / No Proposed New Guidance not currently in NEI 04-02? Yes / No Details NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number as applicable):
Section B.2.2.4 Recovery Actions.
Circumstances requiring guidance interpretation or new guidance:
Subsequent to the submittal of FAQ 06-0001, the following documents were issued by the NRC:
2006-05 Public Meeting Notice 20060609 on Manual Action Clarifications ML061390156 2006-05 Draft NRC Response to 05-03-06 NEI letter - ML061440251 2006-05 Draft NRC Response to 03-29-06 EPM letter - ML061440237 2006-06 RIS 2006-10 Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions - ML061650389 2006-07 NRC Meeting Summary of 06-09-06 OMA Meeting ML061950327 2006-07 NRC Revision to Draft Response to EPM March 2006 letter - ML061980016 2006-07 NRC Revision to Draft Response to NEI May 2006 letter - ML061980035 These documents provide additional clarification with respect to the acceptability of existing manual actions.
Detail contentious points if licensee and NRC have not reached agreement:
None.
Potentially relevant existing FAQ numbers:
FAQ 06-0001 Response Section Proposed Resolution of FAQ and basis for the proposal:
Revise Section B.2.2.4, Recovery Actions to clarify the following:
Operator Manual Actions on Fire Affected Train.
As discussed during a March 1, 2006, public meeting, if one of the redundant trains in the same fire area is free of fire damage by one of the specified means in paragraph III.G.2, then the use of operator manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to the second train may be considered in accordance with the licensees fire protection program and license condition since paragraph III.G.2 has been satisfied.(RIS 2006-10)
Additional clarification was provided at the June 9, 2006 Public Meeting and was summarized in a subsequent NRC Internal Memorandum (July, 19, 2006 ML061950327, ML061980016)
Conversion of Compliance Strategy from III.G.2 to III.G.3.
Paragraph III.G.2 allows the licensee to use the alternative shutdown method described in paragraph III.G.3 of Appendix R if the licensee cannot meet the requirements of paragraph III.G.2.(RIS 2006-10)
Exemptions from Paragraph III.G.2 for Plants Licensed to Operate Before January 1, 1979 The regulations in 10 CFR Part 50.48(b) impose the requirements of paragraph III.G.2 of Appendix R on plants licensed to operate before January 1, 1979 (pre-1979 licensees). As originally issued, 10 CFR 50.48, Fire Protection, allowed licensees to request an exemption from compliance with one or more of the provisions of Appendix R if the licensee justified the exemption on the basis that the required modifications would not enhance fire protection safety in the facility or that the modifications might be detrimental to overall facility safety.
The staffs current basis for approving an exemption is provided in 10 CFR 50.12 Specific Exemptions. In order for the NRC to approve such an exemption request, a licensee would have to identify all relevant credited operator manual actions by fire area or fire scenario.
The NRC has reviewed and granted exemption requests for the use of operator manual actions in lieu of the separation criteria of paragraph III.G.2 where the exemption criteria were met.
These exemptions are specific to the licensee and the situation discussed in the exemption.
Exemptions granted for specific conditions cannot be applied under other conditions. Although the rationale for an exemption may appear to be applicable to a similar situation for a second licensee, the staff cautions that NRC review and approval by issuance of an exemption would be necessary for the second licensee.
The appropriate regulatory vehicle (in the absence of a rulemaking or plant-specific Order) to provide dispensation from compliance with fire protection requirements is the issuance of an exemption under 10 CFR Part 50.12. Inspection reports, meeting minutes, and letters from licensees are examples of documents that do not provide dispensation from compliance with applicable fire protection requirements.
For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in paragraph III.G.2, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstances of section 50.12(a)(2)(ii), citing the SER as the safety basis, and confirming that the safety basis established in the SER remains valid. The staff expects to grant the exemption on these bases without further review. (RIS 2006-10)
Plants Licensed to Operate After January 1, 1979 Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraph III.G.2, a staff decision in an SER that approves the use of manual operator actions does not require exemption under 10 CFR 50.12.
Post-1979 licensees may be requested to demonstrate, as part of the NRC Reactor Oversight Process, that the use of an operator manual action would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire consistent with their license.
If appropriate, provide proposed rewording of guidance for inclusion in next revision.
Revise NEI 04-02 as follows:
Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked B.2.2.4 Recovery Actions Operator manual actions will be transitioned as recovery actions in the new NFPA 805 Deleted: M licensing bases. Repairs will also be transitioned as recovery actions.
The information for operator manual actions that should be included in the summary for the fire area is: 1) whether the operator manual actions are currently allowed or were previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR), and 2) reference to documentation that demonstrates prior review and approval by the NRC. Operator manual actions that are currently allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation) can be transitioned without the need to use the change evaluation process. Examples include: Deleted: In some cases the previous approval may not be obvious, yet should Operation of fire affected equipment for fire areas that meet the separation be allowed.
requirements of Section III.G.1of 10 CFR Part 50, Appendix R (or applicable sections Deleted: are of NUREG-0800). See Figure B-4 Deleted: <#>The operator manual action is currently credited in the Operation of fire affected equipment for fire areas that meet the protection Alternate Shutdown Procedure. Although this manual action was NOT specifically requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of mentioned in the SER, the licensee NUREG-0800) for redundant trains. See Figure B-5. submittal specifically discussed the operator action. This can be considered Manual operation of normally operated manual switches and valves (valves de- previously approved¶
<#>The operator manual action is energized during normal operation can be considered manual valves) where currently credited in Non-Alternate separation/protection is provided for redundant safe-shutdown trains in accordance Shutdown Procedure. The manual action was specifically discussed as acceptable with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of in the SER however the NRC did not NUREG-0800). grant an exemption/deviation. This can be considered previously approved.¶ Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Comment [EK1]: Note this assumes Appendix R (or applicable sections of NUREG-0800). FAQ 06-001 approval Comment [EK2]: NRC Comment on Operator manual actions to address spurious actuations in the credited safe shutdown FAQ 06-001 success path are allowed, as long as the spurious actuation does not disable the Comment [EK3]: Note this assumes credited function during the time it takes to perform the operator manual action FAQ 06-001 approval action.
For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in Section III.G.2 of 10 CFR 50, Appendix R, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves manual actions, should verify that the basis for acceptability in the SER is still valid. If the basis for acceptability is still valid, then no change evaluation is required.
Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of Section III.G.2 of 10 CFR 50, Appendix R, a staff decision in an SER that approves the use of manual operator actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.
Additional clarification related to allowed manual actions is provided in an NRC Internal Memorandum issued July 19, 2006 (ML061950327, ML061980016).
Attachment Page 1 of 2
Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Repairs or operator manual actions credited either for transitioning to or maintaining cold Deleted: recovery actions shutdown will also be transitioned on a fire area basis and do not require a change Deleted: for evaluation. Information that should be summarized includes reference to documentation Deleted: equipment that demonstrates the equipment necessary for the repair/action is staged, the repair/action is proceduralized, and the repair/action is achievable in the necessary timeframe.
Operator manual actions that are not allowed or have not been previously reviewed and Deleted: Operator manual actions that have been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation approved by the NRC (as documented in process outlined in Chapter 5.3 of this guidance. The following methodology should be an approved SER) can be transitioned without the need to use the change used to optimize this process: evaluation process. However, licensees may consider use of the change evaluation process for previously reviewed and approved operator manual actions so that the evaluation is consistent with operator manual actions not previously reviewed and approved by the NRC.¶
¶ Deleted: (e.g., those credited for compliance with Appendix R sections III.G.2 and III.G.3)
Attachment Page 2 of 2