ML070030457

NFPA 805 Transition Pilot Plant FAQ 06-0021

ML070030457
Person / Time
Site:	Harris
Issue date:	12/19/2006
From:	Holder A Progress Energy Co
To:	Office of Nuclear Reactor Regulation
References
NEI 04-02 FAQ 06-0021, Rev 0
Download: ML070030457 (2)

Text

1 of 2 NFPA-805 Transition Pilot Plant Frequently Asked Questions

Plant: Harris Nuclear Plant (HNP) FAQ # 06-0021 Rev. 0 Submittal Date: 11-30-06 Licensee Contact: A.L. Holder Tele/email 919-546-3372 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 interp retation (include section, paragraph number, and line number as applicable):

NEI 04-02, Section 4.3.1, Fundamental Fire Pr otection Program and Design Elements Transition Review, appendices to list acceptable interpretations to the NFPA 805 standard (future).

Circumstances requiring guidance in terpretation or new guidance:

Clarification of NFPA-805, Standard for Fi re Protection for Light Water Reactor Electric Generating Plants (2001 Edition), Chapter 3, Section 3.3.5.2, "Only metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components."

Specifically, this FAQ asks to clarify that air drops are acceptable. Pilot Plant HNP has exposed cable drops ~ 3' in length, which are a previously approved configuration.

Detail contentious points if licensee and NRC have not reached agreement:

NA Potentially relevant existing FAQ numbers:

FAQ 06-0007 2 of 2 Response Section Proposed Resolution of FAQ and basis for the proposal:

This FAQ asks to clarifying that air drops are acceptable. "HNP has exposed cable drops ~ 3' in length." Because air drops are a typical industry configuration, and for the most part have been identifi ed and approved in facility CLBs there is no need to burden staff or licensees with the need for additional justif ication or review of such configurations. Likewise, based on the widespread application of airdrops in the industry there is no reason to include submittal of these airdrops as items previously approved when a bounding interpretation will address the configuration.

If appropriate, provide proposed rewording of guidance for inclusion in next revision.

As follows; Clarification NFPA 805 specific sections as may be applied under NEI 04-02, to be included in (New) Appendix K, to NEI 04-02 upon approval of specific clarification (final formatting to be provided by NEI contract writers).

Specific clarification for NFPA 805 section 3.3.5.2, from FAQ 06-0021, Where used in section 3.3.5.2, the term, "Flexible metallic co nduits shall only be used in short lengths to connect components", shall be considered to be equi valent to "cable air drops of limited length, or as may have been previously approved in the CLB."