ML062890271
| ML062890271 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/28/2006 |
| From: | - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FAQ 06-00011, NEI-04-02, NFPA-805 | |
| Download: ML062890271 (3) | |
Text
FAQ TEMPLATE Plant: D. C. Cook FAQ # 06-0011 Rev. 0 Submittal Date: 09-28-06 Licensee
Contact:
Thomas Jutras (EPM) Tele/email 508-875-2121 x 215 NRC
Contact:
Tele/email Distribution: Check all that apply (NEI Internal Use) o FPWG o RIRWG o NSSS OG X NFPA 805 TF Subiect:
Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:
NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):
NEI 04-02, Appendix B, Section B.2.2., (Page B-7, last paragraph)
Circumstances requiring guidance interpretation or new guidance:
The subject of transitioning Appendix R III.G.3/III.L areas is discussed in Section B.2.2 of NEI 04-02. However, the wording is not entirely clear. Clarification is requested regarding the deterministic transition of areas that currently comply with Section III.G.3 of Appendix R (with or without associated engineering evaluations and exemptions) to NFPA 805 without the need for a change evaluation.
The original intent (based on input from NFPA 805 Committee Members) was that III.G.3 compliant areas could be transitioned as "in compliance with existing plant license basis." This is completely in agreement with the philosophy of safe-today, safe-tomorrow. Per NFPA 805 Figure 2.2 this is considered the "deterministic approach". However, the deterministic approach sections of NPFA 805 Chapter 4, do not appear to specifically address the III.G.3 compliance option. According to NFPA 805 committee members, alternate shutdown was just considered another success path and that was the reason a specific paragraph was not included for III.G.3 in the deterministic approach.
The suggested clarifications to NEI 04-02 are also in line with other parts of NEI 04-02 and Reg. Guide 1.205.
Examples:
From Section 4.3.2 of NEI 04-02, "The deterministic branch ofFigure 2.2 of NFPA 805 recognizes the newfire protection licensing basis mnay include components of the existingplant FireProtectionProgram(includingapproved ereteptions/ deviations, and correctly implemented 10 CFR 50.59 and FireProtectionRegulator), reviews) that can be shown to comply with Chapters 1, 2 and 4. This would be consideredcompliance with deterministiccompliance in NFPA 805 Chapter4. Otherwise, additionalFire ProtectionRegulatory reviews may be used to demonstrate equivalence."
From RG 1.205 Section 2.3, "Section 2.2.7 of NFPA 805 describes the applicationof existing engineeringequivalency evaluations (EEEEs) when using a deterministic approachduring the transitionto an NFPA 805 FPP."
Detail contentious points if licensee and NRC have not reached agreement:
N/A Potentially relevant existing FAQ numbers:
FAQ 06-008 states that alternative shutdown areas transition deterministically in accordance with NEI 04-02 and would not need prior approval.
Response Section Proposed Resolution of FAQ and the basis for the proposal:
Revise NEI 04-02, Section B.2.2 to address the transition of III.G.3 areas deterministically.
Previous analysis has demonstrated the ability to achieve the safe shutdown performance criteria for these areas. Maintaining the philosophy of safe-today, safe-tomorrow, further evaluation is not necessary and a change evaluation should not be required until post-transition changes occur.
If appropriate, provide proposed rewording of guidance for inclusion in next revision.
Revise NEI 04-02, Section B.2.2 (second paragraph) to state the following:
"'Transitionof afire areathat is governedby Sections II.G.3/Il.L of 10 CFR 50 Appendix R is not treated differently than other plantfire areas. While alternativeor dedicatedshutdown capabilitywas omittedfrom the deterministicrequirements in Chapter4 of NFPA 805, the transitionoft a L G.3 11re area can be completed deterministicalligiven the recovery actions are [iasibleand the sak shutdown compliance strateg)' is clearly docunmented. A change evahtation to address the transition would, therefore not he necessarv. This is consistent with the deterministicapproach as dehicted in Fietre2.2 ofNFPA 805 and is consistent with the safe-today, safe-tomorrow
lhilosoplhv. Fowever, the current licensing basisforan alternative/dedicatedshutdownfire area may_ -(Deleted: fire area isnot different.
be more explicit than otherfire areas,since many licensees have detailedalternative/dedicated shutdown Safety EvahlationReports. It may require more detailed documentation to ensurefitture change evaluations accuratelycapture the baseline configuration.Forexample, a dedicatedshutdown methodology may credit a unique power source orpump that is not part of the plant 's safety systems or post-fire safe shutdown program.Post-transitionchanges to this equipment or methodology would need to be accuratelycapturedforassessment ofrisk impact."