ML063350515

NFPA-805 Transition Pilot Plant FAQ-06-0002, Revision 2

ML063350515
Person / Time
Site:	Harris
Issue date:	10/26/2006
From:	Ertman J Carolina Power & Light Co
To:	Office of Nuclear Reactor Regulation
References
FAQ-06-0002, NEI 04-02
Download: ML063350515 (14)

Text

FAQ Number 06-0002 Revision 2.Plant: Harris Nuclear Plant Submittal Date:. 10/26/06 Submitter Contact: Jeff Ertman Phone: 919.546.2662 Submitter Email: ieffrey.ertman,,pnmail.com Distribution: (NEI Internal Use)E 805 TF ] FPWG E] RATF L] RIRWG [] BWROG [] PWROG Subiect: Interpretation of guidance?

es / No Proposed new guidance not in NEI 04-02? / No Details: NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

NEI 04-02, Section 5.3 and Appendix I.Circumstances requiring guidance interpretation or new guidance: Recommend making nuclear safety and radioactive release questions first in screening reviews in order to determine necessity for Chapter 3 features and systems.Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

N/A Potentially relevant existing FAQ numbers: Related to FAQ 06-0003 and FAQ 06-0004 Response Section: Proposed resolution of FAQ and the basis for the proposal: Page 1 of 11 faq 06-0002 -chap 4 questions first -rev lc.doc FAQ Number 06-0002 Revision 1 Revise NEI 04-02 Section 5.3 and Appendix I, to reflect the revised order of questions.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision: See attached revision.Page 2 of 11 faq 06-0002 -chap 4.questions first -rev lc.doc FAQ Number 06°0002 Revision 1 5.3.2 Defining the Change Changes can involve either physical components of the plant or specific details of the fire protection program. The need to perform a Change Evaluation can arise through a number of events or conditions.

I. An in-situ condition could be discovered that is inconsistent with the NFPA 805 Licensing Basis. A Change Evaluation can be performed to determine if the in-situ condition can remain and be treated as an acceptable change to the fire protection program.2. A plant modification could be proposed that requires altering the fire protection program features in order to implement the modification in a cost-effective manner. A Change Evaluation can be performed to examine a number of proposed alternatives to develop a configuration that provides adequate protection at acceptable cost.Page 3 of 11 faq 06-0002 -chap 4 questions first -rev 1 c.doc FAQ Number 06-0002 Revision 1 Defining the Change (5.3.2)Complies Ye: License No wip Cha or Amendment pt a Amendmnt preiously approved Request Alterative?

T Yes License Amendment

-Request NOT Required R 're Pr-eliiminary Risk Screening (5.3.3)----Evaluat-on (5.3.4)SCcOeptance TrMtea----

---

---(5.3.5)Defining the Change License Amendment Request Preliminary Risk Scrn Risk Evaluation (5.3..Acceptance Criteria Deleted: Page 4 of 11 faq 06-0002 -chap 4 questions first -rev 1 c.doc FAQ Number 06-0002 Revision 1 Figure 5-1 -Plant Change Evaluation

3. A programmatic change in the fire protection program may alter a feature that has been explicitly or implicitly incorporated into the Licensing Basis (pre-transition or NFPA 805 Licensing).

A feature that forms the basis for the acceptance of an exemption or deviation (e.g., specific reference to a response by the fire brigade) would represent implicit incorporation into the Licensing Basis. A Change Evaluation is required in this case to determine if this modification is acceptable.

4. A change to administrative controls or organization, such as a change to surveillance frequencies.

The Change Evaluation process begins by defining the change or altered condition to be examined and the baseline configuration as defined by the Licensing Basis (CLB pre-transition or NFPA 805 Licensing Basis post-transition)'.

1. The baseline is defined as that plant condition or configuration that is consistent with the Licensing Basis (CLB pre-transition or NFPA 805 Licensing Basis post-transition).

2. The changed or altered condition or configuration that is not consistent with the Licensing Basis is defined as the proposed alternative.

In some instances, the Change Evaluation focuses on the presence of plant system(s) that would typically have been located in separate fire areas or would have otherwise been provided with features or characteristics that would have minimized their concurrent failure given a postulated fire. The presence of these redundant features creates the potential for a single postulated fire to disable both. As such, combination of targets within the fire area represents the interactions that require evaluation in the Change Evaluation process. These interactions or target set(s) are an important consideration in the Change Evaluation process.Additional consideration should be given to changes to Fundamental Program Elements and Minimum Design Requirements.

Since many of the fire protection systems/features in NFPA 805 Chapter 3 are the result of meetine the Chapter 4 performance criteria, the change review process should determine the Chapter 4 requirements first in the change identification process.10 CFR 50.48(c)(2)(vii) allows licensees to use performance-based methods to demonstrate compliance with NFPA 805 Chapter 3 requirements.

However, these alternate methods must be approved via the license amendment process (10 CFR 50.48(c)(4)).

In some instances where the existing licensing basis is unclear the 'Deterministic Approach' may form the baseline for the Change Evaluation.

Page 5'of 11 faq 06-0002 -chap 4 questions first -rev 1 c.doc FAQ Number 06-0002 Revision I Page 1 of_4 A lCFNSFE NAME --------UNIT(S)0l SITEA 0 SITEB 0 SITEC i.it I Unit2 0 Unit3 ACTIVITY TITLE/DOCUMIENT/REVISION Complete each section and summarize results below.CONCLUSIONS CIIANGE EVALUATION

SUMMARY

RISK EVALUATION SUNlMMARY O The change is editorial or trivial in nature. El The change can be evaluated using a PRELIMINARY (Screening per Section L.a, 2.a, or 3.a) RISK SCREEN (Section 4)fl The channe affect, compliance ivith the .Nuclear El Yes El No Safety Criteria of NFPA 805 ai defined in linsert reference to the uppropriate (houmenttl E The RISK EVALUATION demonstrates that A (Section 1). CDF/LERF are acceptable and defense-in-depth

/ safety 17 Yes No margin are maintained.

Therefore, the change is acceptable.

l The chiange siffects compliance with che Radioactive Release Criteria of N FPA 805 as defined in limert reference to the nappropriate El The RISK EVALUATION demonstrates that either the A documenti (Section 2). CDF/LERF are unacceptable and/or defense-in-depth

/safety margin are not maintained.

Therefore, the change[71 Ye' [ No is NOT acceptable.

E) The change affects compliance with a renuired Fundamental Elements / Minimum Design Requirements of NFPA 805 Chapter3 (Section License Amendment Required?Yl yes No --- -----------------------

SIGNOFFS Print Name Signature DATE SCREEN PREPARER2 Print Name Signature DATE SCREEN REVIEWER I CHANGE DESCRIPTION Provide a brief description of what is being changed and why.I" I -I I REFERENCES I Deleted: UTILITY I Deleted: I Deleted: ¶0l The change affects compliance with the Nuclear Safety Criteria of NFPA 805 as defined in linsert reference to the appropriate document](Section 2).¶0l Yes El No0 Dl The change affects compliance with the Radioactive Release Criteria of NFPA 805 as defined in linsert reference to the appropriate documenti (Section 3).¶[I Yes [I No List applicable references.

Include sufficient identifying detail to facilitate independent revievýand retrieval.

2 Signoffs should be consistent with the Licensee's processes.

For example it may be necessary for a fire protection engineer, PRA engineer, or safe shutdown engineer to have signature authority on the Plant Change Evaluation.

Page 6 of 11 faq 06-0002 -chap 4 questions first -rev 1 c.doc FAQ Number 06-0002 Revision 1 NUCLEAR SAFETY COMPLIANCE STRATEGY CHANGE QUESTIONS Considering the proposed change, answer the following questions.

including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a hrief description of why the proposed chanec does or does not satisfy the referenced document s).I. Does the proposed chanle involve a Nuclear Safetv Compliance Strategy rcquirement as defined in linsert appropriate document refereneel?

• FA Yes -Proceed to Question L.a.* F"1 No -Document basis and nrocecd to Oucstion 2.a. Is the change editorial or trivial in nature? (See Attachment 1)o Fl Yes Document basis and stop.o Fl No Proceed to Question I.b.b. Does the change meet the deterministic requirements ofChapteri4 of NFPA 805?o Ml Yes Document basis and complete remaining sections.o Fl No Proceed to Ouestion L.c.c. Is the change equivalent to the NFPA 805 Chapter 4 compliance strategy as dcfined in [Insert appropriate document referencel?

Ensure documentation for determination of equivaleney is included and meets NEI 04-02 requirements for documentation o Fl Yes Document basis and complete remaining sections.o Fl No Perform a Risk Evaluation.

_ ---1 Deleted: (See Attachment 2)I Changes to Fire Protection Program Fundamental element / minimum ldesign requirements that are required for compliance with NFPA 805 Chapter 3 or to meet the Nuclear Safety Performance Criteria must be evaluated in Section 3.-[Comment [EK1]: Added based on NRC Comments I Page 7 of 11 faq 06-0002 -chap 4 questions first -rev lc.doc FAQ Number 06-0002 Revision 1 I RADIOACTIVE RELEASE CHANGE QUESTIONS Considering the proposed chanue, answer the following questions, including, a reference to the applicable recmlatory, licensing basis, or NFPA document(s), and a brief description of why the proposed chance does or does not satisfy the referenced document(s).

2. Does the proposed change involve a Radioactive Release requirement as defined in lInsert appropriate document referencel?

M "' Yes -Proceed to Question 2.a.F -l No -foncirnnt hbak and nrnceod to risk ,creeninf, a. Is the change editorial or trivial in nature? (See Attachment I)o Fl Yes Document basis and stop.o Fl No Proceed to Question 2.b.b. Does the change meet thc requiremcnts of the Radioactive Release criteria?o F" Yes Document conclusions and proceed to risk screening.

o F" No Proceed to'Question 2.c.c. Is the change equivalent to the Radioactive Release compliance strategy as defitied in [Insert appropriate document referencel?

Ensure documentation for determination of equivalency is included and meets NET 04-02 requirements for documentation.

o Fl Yes Document conclusions and proceed to risk screcning o Fl No Perform a Risk Evaluation.

_ --( Deleted: (See Attachment

2) 1 CIhanges to Fire Protection Procram Fundamental element / minimum design requirements that are required !for compliance with NFPA 805 Chapter 3 or to meet the Radioactive Release Performance Criteria must be evaluated in Section 3.-Comment [EK2]: Added based on NRC Comments j Page 8 of 11 faq 06-0002 -chap 4 questions first -rev Ic.doc FAQ Number 06-0002 Revision 1 I FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT I MINIMUM DESIGN REQUIREMENT CHANGE QUESTIONS

--... ( Formatted Table.I Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

_ Does the proposeqdchange involve an NFPA 805 Chapter 3 requirement as defined in [Insert appropriate document reference]?

For those fire protection program changes that involve a Nuclear Safety Compliance Strategy requirement or a Radioactive Release requirement, ensure the effect of the change is evaluated in Appendix I, Sections 1.0 and 2.0. respectively.

• LI Yes -Proceed to Question Ia.F -1 No -Document basis and proceed to Question 2--'tDeleted:

I.Deleted: I iIzIIIIzIJ

a. Is the change editorial or trivial in nature? (See Attachment 1)o LI Yes Document basis and stop.o E) No Proceed to Question 13,b.b. Does the change meet NFPA 805 Chapter 3 requirements or the previously approved alternative as defined in [Insert appropriate document reference]?

Changes that deviate from the NFPA standards referenced in NFPA 805 Chapter 3 can be made without NRC approval if allowed by the code of record (so long as the evaluated condition is in accordance with the terms of the code of record) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection systems).

Ensure documentation for determination of acceptability is included and meets NEI 04-02 requirements for documentation. (See Attachment 2)o LI Yes Document conclusions, complete remaining sections.o El No License Amendment Request must be processed for NRC approval., "1 Deleted: I I Complete remaining sections.Page 9 of 11 faq 06-0002 -chap 4 questions first -rev lc.doc FAQ Number 06-0002 Revision 1 PRELIMINARY RISK SCREENING Considering the proposed change, answer the following questions.

The nature of the change should enable you to choose among the three categories.

Refer to the IPEEE, a plant-specific fire PRA, or other documents to determine whether the change could have "no", "minimal" or "greater than minimal" impact. Document the basis for the conclusion.

The potential for common cause effects of a given plant change on the above factors should be considered.

For example, an increase in combustible loading in an area can impact all of the factors. See Attachment 3 for examples.4.0 Can the change be evaluated using a preliminary risk screen?a. Does the proposed change impact the FIRE FREQUENCY of any fire scenarios affected by the change?o El No Impact o E] Minimal Impact o El Greater than minimal b. Does the proposed change impact the MAGNITUDE OF THE EXPECTED FIRES for any fire scenarios affected by the change?o E1 No Impact o El Minimal Impact o Ml Greater than minimal c. Does the proposed change impact the DETECTION CAPABILITY for any fire scenarios affected by the change?o [E No Impact o El Minimal Impact o El Greater than minimal d. Does the proposed change impact the SUPPRESSION CAPABILITY for any fire scenarios affected by the change?o El No Impact o El Minimal Impact o El Greater than minimal...IDe~leted:

• NUCLEAR SAFETY COMPLIANCE

!STRATEGY CHANGE QUES ni Page 10 of 11 faq 06-0002 -chap 4 questions first -rev Ic.doc FAQ Number 06-0002 Revision 1 e. Does the proposed change impact the POST-FIRE CAPABILITY OF PLANT SYSTEMS TO PREVENT CORE DAMAGE (including fire affected human actions) during any mode of operation for any fire scenarios affected by the change?o El No Impact o El Minimal Impact o El Greater than minimal f, Do any of the risk screening questions have "Greater than minimal" impact, then a detailed quantitative risk evaluation may be required.o El No. The Fire Protection Program Plant change meets the risk-informed acceptance criteria of NFPA 805 Section 2.4.4.o El Yes, a detailed quantitative risk evaluation is required.Page 11 of 11 faq 06-0002 -chap 4 questions first -rev lc.doc Page 10: [1] Deleted Liz Kleinsorg 10/23/2006 9:04:00 AM Page 10: [1] Deleted Liz Kleinsorg 10/23/2006 9:04:00 AM NUCLEAR SAFETY COMPLIANCE STRATEGY CHANGE QUESTIONS Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

2. Does the proposed change involve a Nuclear Safety Compliance Strategy requirement as defined in lInsert appropriate document reference]?

[D Yes -Proceed to Question 2.a.ID No -Document basis and proceed to Question 3.a. Is the change editorial or trivial in nature? (See Attachment 1)[ Yes Document basis and stop.[ No Proceed to Question 2.b.b. Does the change meet the deterministic requirements of Chapter 4 of NFPA 805?D Yes Document basis and complete remaining sections.E3 No Proceed to Question 2.c.c. Is the change equivalent to the NFPA 805 Chapter 4 compliance strategy as defined in [Insert appropriate document reference]?

Ensure documentation for determination of equivalency is included and meets NEI 04-02 requirements for documentation.(See Attachment 2)[ Yes Document basis and complete remaining sections.[ No Perform a Risk Evaluation.

-Page Break RADIOACTIVE RELEASE CHANGE QUESTIONS Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

3. Does the proposed change involve a Radioactive Release requirement as defined in[Insert appropriate document reference]?

l Yes -Proceed to Question 3.a.[ No -Document basis and proceed to risk screening.

a. Is the change editorial or trivial in nature? (See Attachment 1)[ Yes Document basis and stop.[ No Proceed to Question 3.b.b. Does the change meet the requirements of the Radioactive Release criteria?[ Yes Document conclusions and proceed to risk screening.

[ No Proceed to Question 3.c.c. Is the change equivalent to the Radioactive Release compliance strategy as defined in[Insert appropriate document reference]?

Ensure documentation for determination of equivalency is included and meets NEI 04-02 requirements for documentation. (See Attachment 2)P Yes Document conclusions and proceed to risk screening 19 No Perform a Risk Evaluation.

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