ML063170362
| ML063170362 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/26/2006 |
| From: | Kleinsorg E Carolina Power & Light Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| 06-0012 Rev. 1 | |
| Download: ML063170362 (7) | |
Text
FAQ Number 06-0012 Rev I
- Plant: *
- Harris Nuclear
- a Submittal
- 10/26/06 Plant Date:
- U
- U Submitter *
- Elizabeth
- Phone .*
- 704.651.5548
Contact:
Kleinsorq
- S W U U U
- Submitter
- M Insert email Email:
Distribution: (NEI Internal Use)
ED805TF ] FPWG EIRATF ElRIRWG ElBWROG ElPWROG
Subject:
Interpretation of guidance? F / No Proposed new guidance not in NEI 04-02? Fe / No Details:
NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers 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:
0 2006-05 Public Meeting Notice 20060609 on Manual Action Clarifications ML061390156 E 2006-05 Draft NRC Response to 05-03-06 NEI letter - ML061440251 a 2006-05 Draft NRC Response to 03-29-06 EPM letter - ML061440237.
N 2006-06 RIS 2006-10 Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions - ML061650389 M 2006-07 NRC Meeting Summary of 06-09-06 OMA Meeting ML061950327 Deleted: faq templatedoc I Page I of 7 faq 06-0012 - manual actions - rev la.doc. /
FAQ Number 06-0012 Rev I 0 2006-07 NRC Revision to Draft Response to EPM March 2006 letter -
ML061980016 a 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 consensus on the facts and circumstances:
None.
Potentially relevant existing FAQ numbers:
This FAQ supersedes FAQ 06-0001.
Response Section:
Proposed resolution of FAQ and the 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 paragraphIll.G. 2, then the use of operatormanual actions, or other means necessary, to mitigate fire-inducedoperation or maloperation to the second train may be considered in accordance with the licensee's fire protection program and license condition since paragraph lL/ 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.
"Paragraph111'G.2 allows the licensee to use the alternative shutdown method describedin paragraphIll. G.3 of Appendix R if the licensee cannot meet the requirementsof paragraph/II.G.2. "(RIS 2006-10)
" Exemptions from Paragraph III.G.2 for Plants Licensed to Operate Before January 1, 1979 "The regulationsin 10 CFR Part 50.48(b) impose the requirements of paragraph
///.G.2 of Appendix R on plants licensed to operate before January 1, 1979 (pre-1979 licensees). As originally issued, 10 CFR 50.48, "FireProtection,"allowed licensees to request an exemption from compliance with one or more of the Deleted: faq templatedoc I Page 2 of 7 fag 06-0012 - manual actions - rev la.doc,
FAQNumber 06-0012 Rev 1 provisions of Appendix R if the licensee justified the exemption on the basis that the requiredmodifications would not enhance fire protection safety in the facility or that the modifications might be detrimentalto overall facility safety.
The staff's 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 operatormanual 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 separationcriteria of paragraph/II.G.2 where the exemption criteriawere met. These exemptions are specific to the licensee and the situation discussed in the exemption. Exemptions grantedfor specific conditions cannot be applied under other conditions.Although the rationale for an exemption may appearto be applicable to a similarsituation for a second licensee, the staff cautions that NRC review and approvalby issuance of an exemption would be necessary for the second licensee.
The appropriateregulatoryvehicle (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.
Forpre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operatormanual actions, in lieu of one of the means specified in paragraphIll. G.2, does not eliminate the need for an exemption.
Pre-1979 licensees who have SERs, but not a correspondingexemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstancesof 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 "Sinceplants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraphIll. G.2, a staff decision in an SER that approves the use of manual operatoractions does not require exemption under 10 CFR 50.12. Post-1979 licensees may be requested to demonstrate, as part of the NRC ReactorOversight Process,that the use of an operatormanual action would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire consistent with their license." (RIS 2006-10)
If appropriate, provide proposed rewording of guidance for inclusion in the next Deleted: faq template.doc I Page 3 of 7 fag 06-0012 -manual actions -.rev la.doc, 7
FAQ Number 06-0012 Rev 1 Revision:
. Revise NEI 04-02 as shown in attachment.
,f Deleted: faq template.doc I Page 4 of 7 fag 06-0012 - manual actions - rev la.doc,
Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision I with changes tracked 2,2.4 RecoveryAct//on7s Operator .anual actions will be transitioned as "recovery_actions" in the new NFPA 805 - jDeleted: 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 NRC's 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. In some cases the previous approval may not be obvious, yet should be allowed.
E x amples imclu d e: ----------------------------------------- ----------- Deleted: are
" .Qperation of fire affected equipment for fire areas that meet the separation Deleted: <#>The operator manual action is currently credited in the requirements of Section III.G. lof 10 CFR Part 50, Appendix R (or applicable sections Alternate Shutdown Procedure. Although this manual action was NOT specifically of NUREG-0800). See Figure B-4 mentioned in the SER, the licensee submittal specifically discussed the
- Operation of fire affected equipment for fire areas that meet the protection operator action. This can be considered requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of previously approved¶
<#>The operator manual action is NUREG-0800) for redundant trains. See.Figure B-5. currently credited in Non-Alternate Shutdown Procedure. The manual action
" Manual operation of normally operated manual switches and valves (valves de- was specifically discussed as acceptable energized during normal operation can be considered manual valves) where in the SER however the NRC did not grant an exemption/deviation. This can separation/protection is provided for redundant safe-shutdown trains in accordance be considered previously approved.¶ with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of <#>Operation of equipment for which cables and equipment for the redundant NUREG-0800). safe shutdown train are located in separate fire areas thus meeting Section
" Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, III.G. lof Appendix R to 10 CFR Part 50,¶ Appendix R (or applicable sections of NUREG-0800). <#>Manual operation of normally operated manual switches and valves "
" Operator manual actions to address spurious actuations in the credited safe shutdown where IIIG. 1 separation is provided for reduidant safe-shutdown trains¶ success path are allowed, as long as the spurious actuation does not disable the Formatted: Bullets and Numbering credited function during the time it takes to perform the operator manual action 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 IlI.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.
Attachment Page 5 of 7
Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision I with changes tracked Repairs or operator manual actions credited either for transitioning to or maintaininpecold fDeleted: for shutdown equipment will also be transitioned on a fire area basis and do not require a change evaluation. Information that should be summarized includes reference to documentation 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.
,_perator P manual actions ýre not allowed or"have not been reviousl 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 IV 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 lIl.G.2 and III.G.3)
Deleted: that Attachment Page 6 of 7
Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Train A Train B Pump Pump I Train B Power Train A Power Cable Train B Contro Cable Train A Control Cable Cable Train A Train B' Power Supply Power Supply Fire Area A Fire Area B a
Fire Area A and B meet the separation criteria of 10 CFR 50 Appendix R Section II.G. 1 A postulated fire in Fire Area A could result in the spurious starting of the Train A pump, which can be mitigated by a manual operator action to de-energize the Train A Power Supply to stop Pump A.
Figure B-4 Acceptable Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section 111.1.1 Separation Criteria 3 - hour Rated
- Raceway Fire Barrier Fire Area B meets the separation criteria of 10 CFR 50 Appendix R Section II.G.2.a A postulated fire in Fire Area A could result in the spurious starting of the non-credited Train A pump, which can be mitigated by a manual operator action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-1.
Figure B-5 Acceptable Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Manual Action for Fire Affected Train Attachment Page 7 of 7