ML071630422

NFPA 805 Transition Pilot Plant FAQ Process: Substantive E-Mails; March 2007

ML071630422
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/31/2007
From:	Charles Moulton NRC/NRR/ADRA/DRA/AFPB, Nuclear Energy Institute
To:	Jamar B Nuclear Energy Institute
References
NFPA 805
Download: ML071630422 (168)

Text

Brandon, Attached are advance e-copies of the staff's draft proposal for FAQ 8 and draft responses to FAQs 16 and 18. These documents will be handouts for the 3/22 public meeting.

Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

Mail Envelope Properties (45E882B6.677 : 12 : 9706)

Subject:

NRC staff draft responses for NFPA 805 FAQs 8, 16, and 18 Creation Date 3/2/2007 3:01:58 PM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/2/2007 3:02:20 PM btj (internet:btj@nei.org) nrc.gov TWGWPO04.HQGWDO01 Delivered 3/2/2007 3:02:07 PM SDW1 CC (Sunil Weerakkody)

Opened 3/10/2007 7:05:52 PM Post Office Delivered Route nei.org TWGWPO04.HQGWDO01 3/2/2007 3:02:07 PM nrc.gov Files Size Date & Time MESSAGE 849 3/2/2007 3:01:58 PM FAQ 06-0016 NRC response.pdf 90916 3/2/2007 2:33:40 PM FAQ 06-0018 NRC response.pdf 82553 3/2/2007 2:31:32 PM FAQ 06-0008 NRC proposal.pdf 167676 3/2/2007 2:46:26 PM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate Status Tracking:

Delivered & Opened

NRC Response to FAQ 06-0008 [DMF] {3/2/2007}

FAQ 8 - NRC PROPOSAL PURPOSE A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c),

is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4) to develop a process to maintain the flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.

DESCRIPTION 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendments for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this proposal licensees must send the proposed process/methods outlined in this proposal to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of staff approval of the proposed methods/processes.

The licensees proposal must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(vii) and 10 CFR 50.48(c)(iv) to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make change to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria and satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This proposal would not apply to NFPA 805 Chapter 3 changes that do not relate to NFPA codes or listings. Changes to other portions of Chapter 3 of NFPA 805 would continue to require individual 50.90 amendments addressing the specific deviation.

PROPOSAL License may perform change evaluations for, deviations from the NFPA codes mentioned in NFPA 805, and listings for rated components, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

NRC Response to FAQ 06-0008 [DMF] {3/2/2007}

JUSTIFICATION Since this proposal will be approved by the NRC as part of the 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (nuclear safety requirements, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to protect fire safe shutdown at the plant. By only allowing changes to the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required. Secondary features may be changed based on an evaluation, using the required methods in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

CONCLUSION This proposal will permit, within the bounds of secondary codes and listings, and following NRC approval of a 50.90 amendment, licensees to evaluate fire protection features without prior NRC approval. Other issues not addressed by NFPA codes or listings would have to be submitted for NRC approval on a case by case basis.

NRC Response to FAQ 06-0008 [DMF] {3/2/2007}

EXAMPLE Section 3.6.1 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805, and the NFPA 805 change process is used.

NRC Response to FAQ 06-0008 [DMF] {3/2/2007}

SECTION APPLICATION - FAQs that would benefit from this method are listed.

3.3.1.2(1) - Listing for pressure-impregnated or coated with listed fire-retardant wood. - FAQ 06-0019 3.3.1.2(2) - Fire resistance of plastic sheeting - per NFPA 701 3.3.1.2(5) - Controls on combustible and flammable liquids - per NFPA 30 or other applicable NFPA standards 3.3.1.2(6) - Control on use and storage of flammable gases - per NFPA standards - FAQ 06-0020 3.3.1.3.1 - Hot work procedure - per NFPA 51B, NFPA 241 3.3.2 - Structural integrity - per NFPA 220 3.3.3 - Interior finishes - per NFPA 101 3.3.5.1 - Listing of cable for plenum use - FAQ 06-0022 (Partial) 3.3.6 - Roofs - per NFPA 256 3.3.7.1 - Storage of flammable gas - per NFPA 50A 3.3.8 - Bulk storage of flammable or combustible liquids - per NFPA 30 - FAQ 06-0023 3.4.1(a) - On-site fire brigade capability - per NFPA 600, 1500, and 1582 - FAQ 06-0007 3.4.3(a)(1) - Fire brigade training - per NFPA 600 or 1500 3.4.4 - Fire fighting equipment - per applicable NFPA standards - FAQ 06-0026 3.5.1(b) - Flow rate calculation - per NFPA 13 or 15 3.5.2 - Fire water tanks - per NFPA 22 3.5.3 - Fire pumps - per NFPA 20 3.5.10 - Fire main - per NFPA 24 3.5.15 - Fire hydrants - per NFPA 24 3.6.1 - Standpipes - per NFPA 14 3.7 - Fire Extinguishers - per NFPA 10 3.8.1 - Fire alarm - per NFPA 72

NRC Response to FAQ 06-0008 [DMF] {3/2/2007}

3.8.2 - Fire detection - per NFPA 72 3.9.1 - Water fire suppression - per appropriate NFPA standards including 13, 15, 750, and 16 3.10.1 - Gaseous fire suppression - per NFPA 12, 12A and 2001 3.6.3 - Listing of hose nozzles as electrically safe 3.11.1 - Building separation - per NFPA 80A 3.11.2 - Fire barriers - per NFPA 251 3.11.3 - Listing of fire rated door assemblies, fire dampers.

3.11.3 - Fire barrier penetrations per - NFPA 80, 90A, 101 3.11.4 - Listing of fire rated devices for through penetration fire stops.s

NRC Response to FAQ 06-0016 [RHG] {3/2/2007}

RES & EPRI Team Response to FAQ 06-0016 NUREG/CR-6850, EPRI TR-1011989 Final - 2/7/2007 Prepared by: S. Nowlen, B. Najafi, M. Kazarians, F. Joglar FAQ 06-0016 requests clarification regarding electrical panel / electrical cabinet counting guidance. A copy of the original FAQ as reviewed by the team is attached to the end of this response.

The first point to observe is that panel counting impacts only the fire frequency assigned to an individual panel or group of panels. Hence, the ultimate criterion for partitioning of the fire frequency is the relative number of ignition sources present. The counting guidance does not, in particular, have anything to do with the potential for fire spread between vertical sections or out of a panel, a factor that will impact our response to some of the examples posed in the FAQ.

In practice, it was considered impractical to count ignition sources (e.g., circuit cards, relays, cable terminations and junctions, etc.) directly because (1) the number of ignition sources present in an entire plant is quite large and (2) in most cases the analyst will not be free to open multiple panels for routine inspection of contents. Hence, the guidance was written in such a way that the analyst is not expected to examine the contents of every panel in the plant as a part of the counting process. Examining a sample of representative panels will likely prove useful to the analyst, but the guidance presumes that this will be possible for, at most, a small sample of panels.

As an alternative, the guidance is based on the counting of vertical sections as a surrogate for the counting of ignition sources. The overall objective is to strike a balance such that two banks of panels with a similar number of ignition sources would result in a similar panel count. As a result, the team agrees with some of the examples provided in the FAQ but disagrees with others.

The team agrees in full with the three examples provided on Page 3 of the FAQ and their results (i.e., the switchgear, load center and MCC examples resulting in counts of 9, 4 and 9 vertical sections respectively).

There are then eight examples on page 4 of the FAQ. We will refer to these as examples 1-8 based on numbering from the top to the bottom of page 4. Our assessment of these examples is as follows:

• Examples 1 and 2: The team agrees with these two examples. The distinction between these two examples appears to be that the example 2 panel is a slightly smaller panel than example 1. The team agrees that both examples could be counted as a single panel given that these are not outliers.

1

NRC Response to FAQ 06-0016 [RHG] {3/2/2007}

• Examples 3 and 4: The team disagrees with example 3 but agrees with example

4. The distinction between these two examples is that the dividers are not solid in example 3 but are solid in example 4 (solid is defined in the FAQ). The solidity of the section dividers has absolutely nothing to do with counting for fire frequency purposes. This may be a consideration in fire spread analysis, but given that other factors are similar (i.e., the panel contents are similar) then these two examples should result in the same panel count, namely, six vertical sections.

• Example 5: The team agrees with this example.

• Examples 6 and 7: The team generally agrees with these two examples. The intent of the guidance is to allow analyst judgment in outlier cases. Such cases should be sharply limited in number, but are expected to occur. These are reasonable examples of what might constitute outliers. The judgment used in assigning a panel count to such outliers should be documented. To reiterate, panel counting is ultimately intended to reflect the relative number of ignition sources present. If the density of components, connections, and cable terminations roughly matches that of other panels in the plant, counting based on a representative panel length would be reasonable.

• Example 8: The team disagrees with this example. The number of cables present is not necessarily a good indication of the ignition frequency. If panel contents are considered, then all potential ignition sources should be considered.

In particular, rather than the number of cables present, the relative number of cable junctions, cable terminations and other electrical components would be a better indicator of fire frequency than the simple bulk of cables. Cables that simply pass through a cabinet would not, for example, be significant ignition sources in general compared to cables that terminate at a cabinet. However, the consideration of panel contents might well be legitimate, especially where one encounters a rather large but essentially empty electrical panel.

2

NRC Response to FAQ 06-0016 [RHG] {3/2/2007}

RES & EPRI Team Response to FAQ 06-0018 NUREG/CR-6850, EPRI TR-1011989 Final - 2/7/2007 Prepared by: S. Nowlen, B. Najafi, M. Kazarians, F. Joglar FAQ 06-0018 requests clarification regarding the relationship between Appendix L and Task 6, bin 4, the Main Control Board. It is also the RES & EPRI teams understanding that there was some question as to what should be included in the Main Control Board given the wording provided in Appendix L. The FAQ as presented to the RES & EPRI team is included for reference as an attachment at the end of this response.

On the first point, the teams intent is that there is a one-to-one correspondence between the main control board as discussed in Appendix L and Bin 4 in the fire frequency task.

On the second point, what constitutes the main control board, the intent of the guidance was to sharply limit the scope of the panels to be included in this bin. The main intent was to capture the main horseshoe and little else. For many plants, the main control board will be the main horseshoe and nothing else. This is important given that fires in the main control room that occur outside the main horseshoe were binned with the general electrical panel fires and not with the main control board. Changing the definition of a fire frequency bin (i.e., what goes into a particular bin) creates an inconsistency with the binning of events (in Chapter 6) and the resulting fire frequency estimates.

The additional wording provided in Appendix L (the bullet list on page L-2) was intended to allow for some flexibility given the wide variability among control rooms around the country. The guidance was not intended to open the door to inclusion of more than a small handful of other control room panels. Any panel that is detached from the main horseshoe would generally be excluded from this definition of the main control board with few exceptions.

The joint RES/EPRI efforts included demonstration studies where we exercised the consensus methodology at volunteer pilot plants. To illustrate the intended exception, at one of our pilot plants we encountered two bench-board panels that were detached from, but directly in front of, the main horseshoe. (At some plants such panels are referred to as consoles.) The two panels were an integral part of the main plant monitoring and control functions. They were also in the center of the operators main work area and were manned on a nearly continuous basis. Our intent was to include these two bench-boards as a part of the main control board and the wording of the guidance was intended to allow for this flexibility.

However, this same plant had numerous smaller detached panels housing such things as computers and the event recording equipment and printers. These panels were in full view of the operators (generally behind or to the side of their main work area). None the 1

NRC Response to FAQ 06-0016 [RHG] {3/2/2007}

less, they were not treated as a part of the main control board because they were clearly and distinctly detached from the main control board and served unique functions.

There were also numerous back panels and other detached panels housing items such as balance of plant and offsite power controls and indicators. All of these panels were excluded from the main control board and were treated as general electrical panels.

In general, the definition of the main control board is intended to sharply limit the scope of that bin to the main horseshoe and under certain circumstances a very small number of other detached panels. The intent is to treat the vast majority of the detached panels, and any back panels, as general electrical panels, not as a part of the main control board.

2

A few FAQ meetings ago I gave Chuck a FAQ Log that the task force uses to maintain status of the issues. Based on recent recommended changes to FAQ content for submittals, I thought it appropriate to update our tracking tool as well. I've attached the latest log which will be updated by the task force on 3/22/07. I think our meetings will benefit in efficiency and communication if we utilize this document for status and tracking.

Please let me know if you have any comments or suggestions (this document is considered draft). Please let me know if you intend to publish this in ADAMS and I can provide a cleaner (final) version for periodic submittal.

Thanks, Brandon Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185

E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (46000B7B.169 : 9 : 49513)

Subject:

NEI NFPA 805 Task Force FAQ Log - March 2007 Creation Date 3/20/2007 12:28:51 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1544 3/20/2007 12:28:51 PM TEXT.htm 7131 FAQ LOG - March 07.pdf 24069 Mime.822 45207 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled

Block List is not enabled

Reviewer Submitted Working Plant Licensee Contact NRC NEI TF NRC Submittal Date Tentative Final 06-0001 0

0 Alternate method for Engineering Evaluations Add in clarification that fire affected train manual actions are 'allowed' and therefore do not require evaluation.

NRC rejected the statements regarding SER approval without Exemptions Tentatively approved.

Superceded by FAQ 06-0012.

Closed Harris Nuclear Plant Ertman Submitted to NRC Closed 4/25/2006 Closed ML063480169

Closed ML063480169

06-0002 1c 1c NEI 04-02 Section 5.3.3 and App. I, Order of Questions for Change Analysis Screening Change Figure 5-1, text, and Appendix I to ask the Chapter 4 questions before Chapter 3 questions.

NRC agreed in principle, however wanted wording clarified to "make clear the distinction between Chapter 3 requirements that are subject to Chapter 4 evaluations versus the Chapter 3 requirement that are independent of Chapter 4" added clarification to 'boxes' at end of Questions 1 and 2 in Change Analysis Form NRC added 'included required recovery actions to text of 5.3.3 and added 'including Human actions' to Question 4.e of Change Analysis Form Task Force agrees to first request. Task force is evaluating the addition of NRC rejected the statements regarding SER approval without Exemptions Committed to revise based on RIS 2006-10 and NRC Public Meeting June 9, 2006. See RIS 2006-12 'human actions' to the risk screening questions. - tentatively approved - will resubmit 10/26/06 Closed Harris Nuclear Plant Ertman Gallucci Submited to NRC Closed 4/25/2006 10/26/2006 10/26/2006 Closed 06-0003 1b 1b Change Analysis Screening Change 'greater than minimal' to

'potentially greater than minimal' Closed Harris Nuclear Plant Jeff Ertman Gallucci Submited to NRC Closed 4/25/2006 10/26/2006 10/26/2006 Closed 06-0004 0

1 Clarify NFPA 805 Chapter 4 and 3 relationship for

'required' FP systems/features How fire protection systems and features transition is highly dependent on how they are 'required' to meet the nuclear safety criteria of Chapter 4.

Note NRC was using NEI 04-02 Revision 2H figures and not figures in FAQ 06-0004 NRC to re-review in appropriate context &

provide status on 10/26/06 Received NRC comments 11/29/06.

Resubmitted to NRC and returned with comments. Currently under TF review.

M Harris Nuclear Plant Jeff Ertman Frumkin TF to resubmit May 2007 in conjunction w/ B.III tables Comments provided on R0 5/12/2006 06-0005 1

1 Guidance on FPP-related changes NEI 04-02 does not provide guidance what should be considered a FPP-related change or not. Since failure to obtain NRC pre-approval for using risk reductions from a non-FPP related change would be contrary to the guidance in RG 1.205, additional guidance should be provided to clarify what is considered a FPP-related change once NFPA-805 is implemented FAQ has been revised.

Resubmit to NRC 11/30/06 - waiting for NRC response as of Jan 07 H

Harris Nuclear Plant Ertman TF waiting for NRC comments 8/24/2006 11/30/2006 06-0006 2

2 High-low pressure interface definition and NEI 00-01/NFPA 805 discrepancies Definition of High-Low Pressure interface is not consistent between NFPA 805 and NEI 00-01. Need to provide clarification.

Received NRC comments on R1, R2 Resubmit 12/19/06 - Definition change per NRC request. Closure process has begun. Draft closure letter has content TF is reviewing.

M Duke Barrett Dinh TF reviewing draft closure letter Draft closure letter issued 8/24/2006 12/19/2006 1/18/2007 06-0007 2

2 NFPA 805 Chapter 3 Requirements for Fire Brigades Need clarification on when NFPA 600 or NFPA 1500 apply. Also clarify if requiements apply to interior structural fire fighting brigade.

FAQ to be revised to mark up NEI 04-02 to show the addition of an appendix for NFPA 805 clarifications.

M Harris Nuclear Plant Holder Lain Waiting for NRC comments on R2 Comments provided on R1 2/15/2007 Approval Status Revision FAQ #

Summary Submitter Actions and Notes Name Priority Page1 of 4

06-0008 1i 2b Alternate method for Engineering Evaluations Many Generic Letter 86-10 evaluations exist at facilities today.

Transition of these existing evaluations is essential for the success of the Pilot Plants. In addition the use of engineering evaluations for Chapter 3 issues post transition needs to be clarified.

Presented 9/28/06 Comments received from NRC on 11/29/06.

Clarification call scheduled. Resubmit to NRC by 02/07 H1 NEI Ratchford Frumkin TF revising FAQ 8 R2 Comments provided on R1i 2/15/2007 06-0009 NEI 04-02 Typo Corrections Editorial changes to NEI 04-02 Projected submittal 2Q/07 L

NEI Kleinsorg 06-0010 Incorporate Regulatory Guide 1.205 Baseline concept into NEI 04-02 Based on changes to Regulatory Guide 1.205, NEI 04-02 needs to reflect the baseline risk Projected submittal mid-2007 L

NEI Ertman 06-0011 1b 1b Clarify III.G.3 Compliance Transition Alternative Shutdown is not specifically addressed in NFPA 805.

Approved by Task Force Reviewers. Submitted to NRC 9/28/06. Under NRC review.

Comments received from NRC on 11/29/06.

Need time for TF review. Rewrite w/consideration for NRC comment #2 -

Resubmit Feb. '07 H2 NEI Jutras Lain TF waiting for NRC comments on R1b Comments provided on R0 2/15/2007 06-0012 1a 2b Clarify Manual Action Transition in Appendix B Some manual actions are either allowed by the current regulation or have been Submitted to NRC 9/28/06. Resubmit 10/26/06 as combined with FAQ 06-0001 Comments received from NRC on 11/30/06.

With TF for review. Revision by May '07.

H3 NEI Kleinsorg Barbadaro TF revising FAQ 12 R2 Comments provided on R1a 9/28/2006 10/26/2006 06-0013 Clarify Chapter 4 Methodology Transition Process Bases on Pilot Plant Results Will be presented at 2006 HNP Pilot meeting.

Duke to submit end of first Quarter 2007 L

NEI Barrett 06-0014 0

Cumulative Risk Regulatory Guide 1.205 requires tracking of changes to assess cumulative risk. NEI 04-02 does not provide guidance on this issue With FPRA TF for comment - 12/14/06 L

NEI Rishel FPRA TF has action 06-0015 0

Guidance on not-red determination Process for determining if non-compliances found during the transition process are 'not red' needs to be simplified.

Sent to Task Force for review 11/30/06 With FPRA TF for review-12/14/06 Ken Heffner to provide regulatory input to this FAQ by 12/14/06 Amir Afzali to provide PRA screening criteria for

'not red' determination by 12/14/06 L

NEI Fortman FPRA TF has action 06-0016 0

1 Ignition Source counting guidance for Electrical Cabinets Clarification/enhancement of Ignition Source counting guidance for Electrical Cabinets in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.

Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

Potential disagreement on the examples provided in the FAQ were discussed by Ray Gallucci of the NRC. Kiang Zee provided feedback that the examples were intended to be taken collectively and were intended to be drawn to scale.

H HNP Miskiewicz Gallucci FPRA TF has action Comments provided on R0 12/19/2006 06-0017 0

0c Ignition Source counting guidance for High Energy Arcing Faults (HEAF)

Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.

Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

Preliminary comments indicated a recommending splitting of HEAFs into a low voltage and high voltage bins. In addition, a new frequency is being considered for bus ducts.

H HNP Miskiewicz Gallucci FPRA TF waiting for NRC comments 12/19/2006 Page2 of 4

06-0018 0

0 Ignition Source counting guidance for Main Control Board (MCB)

Clarification/enhancement of Ignition Source counting guidance for Main Control Board (MCB) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.

Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

Preliminary comments indicated more focus on counting just horseshoe cabinets as MCBs.

H HNP Miskiewicz Gallucci FPRA TF has action Comments provided on R0 12/19/2006 06-0019 0

0c Define power block and plant Define where used in Chapter 3, power block and plant are intended to mean areas in which a fire could jeopardize the ability to meet the performance criteria described in section 1.5.

3.3.1.2 Control of Combustible Materials (1)Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Comments to be provided by NRC prior to Feb.

2007 meeting.

H HNP Holder Dinh TF revising FAQ 19 R0c Comments provided on R0 12/19/2006 06-0020 0

0c Definition of applicable (6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

Presented to Task Force 11/30/06 H

HNP Holder Dinh TF revising FAQ 20 R0c Comments provided on R0 12/19/2006 06-0021 0

0 Clarify that air drops are acceptable.

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.

HNP as well as other plants have exposed cable drops ~ 3 in length.

Presented to Task Force 11/30/06 LL HNP Holder Dinh TF reviewing NRC comments on R0 Comments provided on R0 12/19/2006 06-0022 0

0a Identify a list of typical flame propagation tests which are considered acceptable.

3.3.5.3 - Electric cable construction shall comply with a flame propagation test as acceptable to the AHJ.

Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

Additional info on applicability of test requested by NRC.

M ANO Puckett Moulton TF waiting for NRC comments 12/19/2006 06-0023 0

0 Grant exception for Diesel Generator Day Tanks located within Diesel Generator Buildings.

3.3.8 Bulk Storage of Flammable and Combustible Liquids - Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code.

Presented to Task Force 11/30/06 Submitted to NRC 12/19/06 NRC questioned if issue warranted a FAQ since it is part of plant systems LL HNP Holder Lain TF waiting for NRC comments 12/19/2006 06-0024 0

0 Define what adequate clearance is.

3.3.11 Electrical Equipment -

Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment.

Need to provide a clearer definition of

'adequate clearance'. Could be based on OSHA 3ft requirement.

Presented to Task Force 11/30/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

M HNP Holder Oudinot TF waiting for NRC comments 12/19/2006 Page3 of 4

06-0025 0

0 Define minimum acceptable pre-plan scope.

3.4 Industrial Fire Brigade - 3.4.2.1 -

The plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.

Suggest define more clearsly what the minimum acceptable pre-plan scope is. Consider use of existing guidance Presented to Task Force 11/30/06 H

HNP Holder Barbadaro TF reviewing NRC comments on R0 Comments provided on R0 12/19/2006 RESUBMIT March 2007 06-0026 0

0 Clarify NFPA code requirements for gear maintenance 3.4.4 Fire-Fighting Equipment -

Protective clothing, respiratory protective equipment, radiation monitoring equipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrial fire brigade. This equipment shall conform with the applicable NFPA standards.

Clarify that intent is for design and purchase of equipment. NFPA code requirements for gear maintenance is not applicable.

Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.

M HNP Holder Oudinot TF waiting for NRC comments 12/19/2006 06-0027 0a Clarify the where provided statement.

3.7 Fire Extinguishers - Where provided, fire extinguishers of the appropriate number, size, and type shall be provided in accordance with NFPA 10, Standard for Portable Fire Extinguishers. Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.

Part of NFPA 10 is placement / travel distances for extinguishers. The

'where provided' statement needs clarification.

To TF by Feb 07 Not discussed on 1/18/07 M

ANO Puckett 06-0028 0

0 Clarify intent of familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms regarding scope of or depth of the training.

3.3.1.1 General Fire Prevention Activities - (1) Training on fire safety information for all employees and contractors including, as a minimum, familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms Clarify the intent of 'familiarization'.

Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Not discussed on 1/18/07 M

HNP Alan Holder Oudinot TF reviewing NRC comments on R0 Comments provided on R0 12/19/2006 06-0029 0a Clarify zone of influence for NUREG 6850 Task 8.

FDT spreadsheets are used to provide a zone of influence.

Submitted to the task force: 12/19/06 Discuss at January 24, 2007 FPRA meeting Not discussed on 1/18/07 H

HNP Thompson Page4 of 4

Brandon, Attached is an advance copy of a handout for our Thurs. public meeting, so please share it with the taskforce. This is the draft technical content for the closure of FAQ 6.

I don't think there have been any substantive changes. That is, I think that this should be the same technical content that we have presented before.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

Mail Envelope Properties (4600206C.D17 : 12 : 9706)

Subject:

Draft of closure for FAQ 06-0006 Creation Date 3/20/2007 1:57:00 PM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/20/2007 1:57:39 PM btj (internet:btj@nei.org) nrc.gov OWGWPO03.HQGWDO01 Delivered 3/20/2007 1:57:08 PM TQD1 CC (Thinh Dinh)

Opened 3/20/2007 2:04:28 PM nrc.gov TWGWPO01.HQGWDO01 Delivered 3/20/2007 1:57:00 PM PWL CC (Paul Lain)

Opened 4/17/2007 8:22:39 AM nrc.gov TWGWPO04.HQGWDO01 Delivered 3/20/2007 1:57:08 PM SDW1 CC (Sunil Weerakkody)

Opened 3/20/2007 7:56:33 PM Post Office Delivered Route nei.org OWGWPO03.HQGWDO01 3/20/2007 1:57:08 PM nrc.gov TWGWPO01.HQGWDO01 3/20/2007 1:57:00 PM nrc.gov TWGWPO04.HQGWDO01 3/20/2007 1:57:08 PM nrc.gov Files Size Date & Time MESSAGE 1109 3/20/2007 1:57:00 PM FAQ 06-0006 NRC closure.pdf 77896 3/7/2007 8:16:14 AM Options Auto Delete:

No

Expiration Date:

None Notify Recipients:

Yes Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate Status Tracking:

Delivered & Opened

NRC Response to FAQ 06-0006 [TQD] {3/7/2007}

Summary of the Two Issues Raised in FAQ-06-0006 NEI 04-02, Revision 1, which has been endorsed by RG 1.205, references the use of NEI 00-01 methodology as one acceptable method for meeting the requirements of Section 2.4.2, Nuclear Safety Capability Assessment, of NFPA 805. During the pilot plant review of the post-fire safe shutdown methodology, licensee noted that the definition of high-low pressure interface provided in NEI 00-01, Appendix C, and the definition of that term in provided in NFPA 805, Section 1.6.31 are different. Therefore, through FAQ 06-0006, the licensee requested that the NRC staff provide a clarification on the acceptability of the NEI 00-01's definition of the term high-low pressure interface in meeting NFPA 805 requirements.

Section 1.6.31 of NFPA 805 defines High-Low Pressure Interface as follows:

Reactor coolant boundary valves whose spurious opening could potentially rupture downstream piping on an interfacing system or could cause a loss of inventory that could not be mitigated in sufficient time to achieve the nuclear safety performance criteria.

Section C.4 of NEI 00-01, establishes the following criterion for the determination of a high-low pressure interface valve:

A valve whose spurious opening could result in a loss of reactor pressure vessel/reactor coolant system (RPV/RCS) inventory and, due to the lower pressure rating or other breaches such as relief valve operations on the downstream piping, an interfacing loss-of-coolant accident (LOCA) (i.e.,

pipe rupture in the low pressure piping).

Since the above definitions of high-low pressure interface do not match verbatim, the licensee raised two issues using FAQ-06-006. Issue #1 is the determination of which definition for high-low pressure interface boundary valves is to be used in conducting the nuclear safety performance criteria methodology review. Issue #2 is to specify which document takes precedence when inconsistencies or conflicts arise between NFPA 805 and NEI 00-01 when performing the Nuclear Safety Performance Criteria Transition Review.

Resolution of Issues On Issue #1, the staff concluded that the definition provided in NEI-00-01 for the term high-low pressure interface is acceptable. The staff reviewed the above definitions and determined that NEI 00-01 defines high-low pressure interface valves as those that could cause any loss of RPV/RCS inventory due to flow diversion or pipe ruptures in the low pressure piping as the result of spurious valve operations. This definition, therefore, bounded the NFPA 805's definition, which focused on inventory loss that could not be mitigated in sufficient time to achieve the nuclear safety performance criteria. In addition, the staff noted that the use of NEI 00-01 methodology to identify and evaluate high-low pressure interface valves has been previously accepted by the NRC.

Therefore, for the purpose of analyzing high-low pressure boundary valves in conducting the nuclear safety performance criteria methodology review for NFPA 805 transition, the staff agreed that the guidance provided in NEI 00-01 is one acceptable approach.

NRC Response to FAQ 06-0006 [TQD] {3/7/2007}

On Issue #2, it is the staffs position that where definitions or methodologies are not in strict alignment between documents, regulatory requirement documents (e.g., NFPA 805) take precedence over industry guidance (e.g., NEI 00-01), regulatory guides, and all other lower tier documents. As such, the staff recommended that FAQ 06-0006 be revised to delete the text which may be construed as whenever NFPA 805 and NEI 00-01 are not in strict alignment, the methodology in NEI 00-01 would take precedence and should be used as the basis for acceptability. The licensee accepted the staff recommendation and issued FAQ 06-0006, Rev. 2, to emphasize that the acceptance of NEI 00-01 methodology is only applicable to the high-low pressure interface issue. In addition, texts that implied NEI 00-01 methodology may take precedence over a regulatory document is deleted.

Brandon, Please distribute to the Task Force as you see fit.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

Mail Envelope Properties (4600293D.897 : 12 : 9706)

Subject:

Meeting summary for Feb FAQ meeting (contains ADAMS numbers for handouts)

Creation Date 3/20/2007 2:34:37 PM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/20/2007 2:35:26 PM btj (internet:btj@nei.org) nrc.gov TWGWPO01.HQGWDO01 Delivered 3/20/2007 2:34:37 PM PWL CC (Paul Lain)

Opened 4/9/2007 1:22:29 PM nrc.gov TWGWPO04.HQGWDO01 Delivered 3/20/2007 2:34:44 PM SDW1 CC (Sunil Weerakkody)

Opened 3/20/2007 7:55:53 PM tri-en.com Transferred 3/20/2007 2:35:26 PM fleurmeister CC (internet:fleurmeister@tri-en.com)

Post Office Delivered Route nei.org TWGWPO01.HQGWDO01 3/20/2007 2:34:37 PM nrc.gov TWGWPO04.HQGWDO01 3/20/2007 2:34:44 PM nrc.gov tri-en.com Files Size Date & Time MESSAGE 785 3/20/2007 2:34:37 PM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard

ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate Status Tracking:

Delivered & Opened

Did I miss the attachment?

---

Original Message-----

From: Charles Moulton [1]

Sent: Tuesday, March 20, 2007 2:35 PM To: JAMAR, Brandon Cc: Paul Lain; Sunil Weerakkody; fleurmeister@tri-en.com

Subject:

Meeting summary for Feb FAQ meeting (contains ADAMS numbers for handouts)

Brandon, Please distribute to the Task Force as you see fit.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11 This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (46002D8B.566 : 1 : 54630)

Subject:

RE: Meeting summary for Feb FAQ meeting (contains ADAMS numbers for handouts)

Creation Date 3/20/2007 2:54:14 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1067 3/20/2007 2:54:14 PM Mime.822 3496 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled

Brandon, Please distribute to the Task Force as you see fit.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11 Mail Envelope Properties (46002DEB.3C9 : 12 : 9706)

Subject:

Meeting summary for Feb FAQ meeting (contains ADAMS numbers for handouts)[now with attachment]

Creation Date 3/20/2007 2:54:35 PM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/20/2007 2:55:15 PM btj (internet:btj@nei.org) nrc.gov TWGWPO01.HQGWDO01 Delivered 3/20/2007 2:54:35 PM PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 Delivered 3/20/2007 2:54:43 PM SDW1 CC (Sunil Weerakkody)

Opened 3/20/2007 7:55:58 PM tri-en.com Transferred 3/20/2007 2:55:15 PM fleurmeister CC (internet:fleurmeister@tri-en.com)

Post Office Delivered Route nei.org

TWGWPO01.HQGWDO01 3/20/2007 2:54:35 PM nrc.gov TWGWPO04.HQGWDO01 3/20/2007 2:54:43 PM nrc.gov tri-en.com Files Size Date & Time MESSAGE 803 3/20/2007 2:54:35 PM feb meeting summary.pdf 74245 3/20/2007 2:15:02 PM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate Status Tracking:

Delivered & Opened

March 6, 2007 MEMORANDUM TO: Sunil D. Weerakkody, Branch Chief Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM:

Charles Moulton, Fire Protection Engineer /RA/

Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 15, 2007, CATEGORY 2 MEETING ON FREQUENTLY ASKED QUESTION PROCESS REGARDING NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 On February 15, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting, via teleconferencing, with stakeholders and the public to discuss Frequently Asked Questions (FAQs) at plants that are adopting National Fire Protection Association Standard 805.

Licensees introduced and discussed revised versions of three FAQs at this meeting. The staff presented and discussed written responses to four FAQs. Licensees and NRC staff also discussed the remaining open FAQs. The participants determined that both industry stakeholders and the NRC staff needed to continue to work on the remaining open FAQs.

All participants agreed that the next monthly meeting should occur on March 22, 2007, at Nuclear Energy Institute headquarters.

The revised FAQs and written responses introduced at the meeting are available in the Agencywide Documents Access and Management System. The accession numbers for the revised FAQs are ML070510442, ML070510499, and ML070510505. The accession numbers for the responses are ML070510365, ML070510369, ML070510417, and ML070510427.

A list of meeting attendees is enclosed with this memorandum.

Enclosure:

As stated CONTACT: Charles Moulton, NRR/DRA 301-415-2751

ENCLOSURE MEMORANDUM TO: Sunil D. Weerakkody, Branch Chief Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM:

Charles Moulton, Fire Protection Engineer Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 15, 2007, CATEGORY 2 MEETING ON FREQUENTLY ASKED QUESTION PROCESS REGARDING NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 On February 15, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting, via teleconferencing, with stakeholders and the public to discuss Frequently Asked Questions (FAQs) at plants that are adopting National Fire Protection Association Standard 805.

Licensees introduced and discussed revised versions of three FAQs at this meeting. The staff presented and discussed written responses to four FAQs. Licensees and NRC staff also discussed the remaining open FAQs. The participants determined that both industry stakeholders and the NRC staff needed to continue to work on the remaining open FAQs.

All participants agreed that the next monthly meeting should occur on March 22, 2007, at Nuclear Energy Institute headquarters.

The revised FAQs and written responses introduced at the meeting are available in the Agencywide Documents Access and Management System. The accession numbers for the revised FAQs are ML070510442, ML070510499, and ML070510505. The accession numbers for the responses are ML070510365, ML070510369, ML070510417, and ML070510427.

A list of meeting attendees is enclosed with this memorandum.

DISTRIBUTION:

DRA R/F TDinh DFrumkin PLain RRadlinski CMoulton AKlein RGallucci PBarbadoro SWeerakkody ADAMS Accession #: ML070640531 NRC-001 OFFICE AFPB/FPE BC:AFPB/FPE NAME CMoulton SWeerakoddy DATE 3/ 06 /07 3/ 06 /07

ENCLOSURE NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FREQUENTLY ASKED QUESTION PROCESS LIST OF ATTENDEES February 15, 2007 U.S. Nuclear Regulatory Commission Staff C. Moulton D. Andrukat D. Frumkin D. Oudinot J. Circle*

P. Barbadoro P. Lain R. Radlinski S. Dinsmore S. Weerakkody T. Dinh OTHER A. Holder (Progress)*

A. Ratchford (Kleinsorg Group)*

B. Jamar (NEI)*

E. Kleinsorg (Kleinsorg Group)*

F. dePeralta-Meister (Tri-en Corp)*

G. Cooper (Constellation)

G. Harris (AmerenUE)*

H. Barrett (Duke)*

J. Fortman (AmerenUE)*

J. Lattner (Southern Nuclear)*

K. Heffner (Progress)*

M. Yungbluth (AmerenUE)*

R. Dible (AREVA)*

R. Gray (AEP)*

R. Ladd (NMC)*

R. Puckett (Entergy)*

T. Jutras (EPM)*

T. Shudak (NPPD)*

• participated via phone

Please find the attached revision to FAQ 06-0008 (Rev. 2d) for official submittal.

If you have any questions regarding this FAQ and its transmittal please contact me directly.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (460076B6.E25 : 11 : 60965)

Subject:

FAQ 06-0008 Rev. 2d - Submittal Creation Date 3/20/2007 8:06:36 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1055 3/20/2007 8:06:36 PM TEXT.htm 6189 FAQ 06-0008R2d.pdf 38013 Mime.822 62749 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled

Block List is not enabled

FAQ Number 06-0008 FAQ Revision 2d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 5 FAQ 06-0008R2d.doc Plant: Harris Date:

2/15/2007

Contact:

Jeff Ertman Phone:

919-546-3681 Email:

jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

The purpose of FAQ 06-0008 is to provide a process/method for the use of fire protection engineering analyses post-transition to address NFPA 805 Chapter 3 requirements. Currently, licensees may self approve these evaluations under the existing fire protection license conditions.

The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). Post-transition, licensees will use this process/method to self approve acceptable fire protection engineering analyses.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

Sections 2.3, 2.4, 4.3.1, 4.6.1, 5.3.2, Appendix H, and Appendix I of NEI 04-02 Revision 1.

Circumstances requiring guidance interpretation or new guidance:

Risk-informed, performance-based fire protection engineering analyses are an acceptable alternative to the deterministic approaches in NFPA 805 Chapter 4. Some sections of Chapter 3 are conditional based upon Chapter 4 requirements; therefore, risk-informed, performance-based methods are allowed for those sections. Risk-informed, performance-based fire protection engineering analyses may also be needed to document the acceptability of fire protection systems and features addressed in NFPA 805 Chapter 3 sections that are not conditional based upon Chapter 4 requirements. Current licensing basis allows flexibility to use performance-based technical analysis per Generic Letter 86-10. An alternative method (approach) is needed to allow this flexibility following transition to NFPA 805.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

FAQ Number 06-0008 FAQ Revision 2d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 5 FAQ 06-0008R2d.doc 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4) provide for performance-based methods and alternatives to NFPA 805 as a means of meeting fire protection regulations, as long as the appropriate regulatory processes (i.e., a license amendment request) are utilized.

A process for a 10 CFR 50.48(c)(2)(vii)/10 CFR 50.48(c)(4) License Amendment Request has not yet been agreed upon.

Potentially relevant existing FAQ numbers:

FAQ 06-0004 includes a process for defining fire protection systems and features required to meet NFPA 805 Chapter 3 criteria.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c),

is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4) to develop a process to maintain the current flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.

BACKGROUND 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this FAQ to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(vii) and 10 CFR 50.48(c)(iv) to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval

FAQ Number 06-0008 FAQ Revision 2d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 5 FAQ 06-0008R2d.doc by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to NFPA codes or listings. Changes to other portions of Chapter 3 of NFPA 805 would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

PROCESS Licensees may perform change evaluations for deviations from the NFPA codes mentioned in NFPA 805, and listings for rated components, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following provides the sections of NFPA 805 that will utilize this process/method. Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Section Title FAQ 06-008 Process Applicable Chapter 4 Conditional Section FAQ 06-008 Process and Chapter 4 Not Applicable 3.1 General X

3.2 Fire Protection Plan X

3.2.1 Intent X

3.2.2 Management Policy Direction and Responsibility X

3.2.3 Procedures X

3.3 Prevention X

3.3.1 Fire Prevention for Operational Activities X

3.3.2 Structural X

3.3.3 Interior Finishes X

3.3.4 Insulation Materials X

3.3.5 Electrical X

3.3.6 Roofs X

3.3.7 Bulk Flammable Gas Storage X

FAQ Number 06-0008 FAQ Revision 2d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 5 FAQ 06-0008R2d.doc Section Title FAQ 06-008 Process Applicable Chapter 4 Conditional Section FAQ 06-008 Process and Chapter 4 Not Applicable 3.3.8 Bulk Storage of Flammable and Combustible Liquids X

3.3.9 Transformers X

3.3.10 Hot Pipes and Surfaces X

3.3.11 Electrical Equipment X

3.3.12 Reactor Coolant Pumps X

3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X

3.4.2 Pre-Fire Plans X

3.4.3 Training and Drills X

3.4.4 Fire Fighting Equipment X

3.4.5 Off-Site Fire Department Interface X

3.4.6 Communications X

3.5 Water Supply X

3.6 Standpipe and Hose Stations X

3.7 Fire Extinguishers X

3.8 Fire Alarm and Detection Systems X

3.9 Automatic and Manual Water-Based Fire Suppression Systems X

3.10.

Gaseous Fire Suppression Systems X

3.11 Passive Fire Protection Features X

3.11.1 Building Separation X

3.11.2 Fire Barriers X

3.11.3 Fire Barrier Penetrations X

3.11.4 Through Penetration Fire Stops X

3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS)

X

FAQ Number 06-0008 FAQ Revision 2d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 5 FAQ 06-0008R2d.doc EXAMPLE Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

JUSTIFICATION Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals/objectives/criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.

By only allowing changes to the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues not addressed by NFPA codes or listings would have to be submitted for NRC approval on a case by case basis.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

[To be provided following review and discussion on the approach with the NRC.]

A proposed method/process is to include the text from the Process and Example sections above in section 5.3 of NEI 04-02. Note this is similar to guidance from NEI 02-03 Appendix A. The new process/method for changes would be cross-referenced in the other sections of NEI 04-02 (i.e., 2.3, 2.4, 4.3.1, 4.6.1, Appendix H, and Appendix I).

I've attached revision 2 to FAQ 06-0012 for submittal. One version shows changes and the other is clean for use as you see fit.

Please let me know if you have any questions.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (4602B186.92B : 14 : 43307)

Subject:

FAQ 06-0012 Rev. 2 Submittal Creation Date 3/22/2007 12:41:30 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1051 3/22/2007 12:41:30 PM TEXT.htm 6187 FAQ 06-0012 - Manual Actions - Rev 2 - changes accepted.pdf 137844 FAQ 06-0012 - Manual Actions - Rev 2_changes.pdf 151855 Mime.822 407544 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled

Junk Mail using personal address books is not enabled Block List is not enabled

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 1 of 13 faq 06-0012 - manual actions - rev 2 - changes accepted.doc Plant:

Harris Nuclear Plant Date:

03/22/2007

Contact:

Elizabeth Kleinsorg Phone:

704.651.5548 Email:

ekleinsorg@haifire.com Purpose of FAQ:

Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / 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:

Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.

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

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 2 of 13 faq 06-0012 - manual actions - rev 2 - changes accepted.doc 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 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.

These documents provide additional clarification with respect to the acceptability of existing operator 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:

The following information will be used as input for a revision to NEI 04-02:

Allowed Operator Manual Actions With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 3 of 13 faq 06-0012 - manual actions - rev 2 - changes accepted.doc (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)

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.

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 4 of 13 faq 06-0012 - manual actions - rev 2 - changes accepted.doc 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. (RIS 2006-10)

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Revise NEI 04-02 as shown in the attachment.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 5 of 13

[Fifth paragraph on page 29 of NEI 04-02 Revision 1]

4.3.2 Nuclear Safety Performance Criteria Transition Review Operator manual actions being transitioned to recovery actions that are not allowed under the current regulatory framework or do not have previous NRC approval should be evaluated using the change process. See Appendix B-2 of this document for additional guidance.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 6 of 13 B.2.2.4 Recovery Actions Operator manual actions will be transitioned as recovery actions in the new NFPA 805 licensing bases. Repairs will also be transitioned as recovery actions.

The following information for operator manual actions should be included in the fire area summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Worksheet):

Whether the transitioning recovery action is allowed or was previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR). Include reference to documentation that demonstrates prior review and approval by the NRC.

Reference to the feasibility evaluation of the transitioning recovery action. See discussion below.

Reference to the evaluation of additional risk associated with the use of recovery actions. See section discussion below.

Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 7 of 13 Action is taken inside of the Main Control Room?

Action is a Normally Manually Operated Switch/Valve Action taken to Achieve &

Maintain Cold Shutdown?

Action Credited for App.

R Section III.G.3 (NUREG-0800 C.5.c)?

Action is for fire affected train?

(Meets III.G.1 / III.G.2/

NUREG 0800 Separation)

Action Related to Credited Train, but does not disable Function?

Prior NRC Approval Obtained?

Action is Feasible?

Operator Manual Action is ACCEPTABLE For each Operator Manual Action for a Given Fire Area No No No No No No No Yes Yes Yes Yes Yes Yes Yes Yes No Operator Manual Action Not Allowed / Not Approved (Candidate for RI-PB Change Evaluation)

Figure B-4 General Process to Transition Operator Manual Actions Determining If a Transitioning Operator Manual Action requires a Change Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include:

Operator manual operation from the control room or emergency control station(s)

Repairs or operator manual actions credited either for transitioning to or maintaining cold shutdown equipment Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 8 of 13 with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800)

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of normally operated manual switches and valves Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Appendix R (or Section C.5.c of NUREG-0800).

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required RIS 2006-10 states: 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.

Operation of fire affected equipment for fire areas that meet the separation requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800). See Figure B-5.

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

operation of equipment for which cables are located in fire areas that meet Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6.

RIS 2006-10 states: 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.

Operator manual actions to address spurious actuations in the credited safe shutdown success path are allowed, as long as the spurious actuation does not disable the credited function and the credited function does not become disabled during the time it takes to perform the operator manual action. See Figures B-7 and B-8 During the June 9, 2006 public meeting the following example was specifically discussed: Two redundant trains taking suction from a common tank. Provided the

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 9 of 13 manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation. (Figure B-7)

A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path.

Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)

In addition to allowed operator manual actions some manual actions may have been previously reviewed and approved by the NRC (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205.

In some instances the NRC may have reviewed and approved an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance:

For pre-1979 licensees, a staff decision in an 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. RIS 2006-10 directs licensees to submit an exemption request 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. Since the licensee is adopting NFPA 805 as a licensing basis, the submittal of a clarification exemption request is not necessary. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves operator 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.

RIS 2006-10 states: 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.

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 operator manual actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

RIS 2006-10 states: 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

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 10 of 13 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.

Operator manual actions that are not allowed or have not been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation process outlined in Chapter 5.3 of this guidance. Examples of operator manual actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting (ML061950327, ML061980016)

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 11 of 13 Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Train B Pump Fire Area A Fire Area B Train B Power Supply Train B Power Cable Train A Pump Train A Power Supply Train A Power Cable Train A Control Cable Train B Control Cable 3 - hour Rated Raceway Fire Barrier Fire Area B meets the separation criteria of 10 CFR 50 Appendix R Section III.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 an operator manual action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-5.

Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 12 of 13 Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Suction

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 13 of 13 Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Feedwater Flow Diversion

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 1 of 13 faq 06-0012 - manual actions - rev 2 (2).doc Plant:

Harris Nuclear Plant Date:

03/22/2007

Contact:

Elizabeth Kleinsorg Phone:

704.651.5548 Email:

ekleinsorg@haifire.com Purpose of FAQ:

Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / 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:

Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.

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 Deleted: faq 06-0012 - manual actions - rev 2.doc

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 2 of 13 faq 06-0012 - manual actions - rev 2 (2).doc 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 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.

These documents provide additional clarification with respect to the acceptability of existing operator 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:

The following information will be used as input for a revision to NEI 04-02:

Allowed Operator Manual Actions With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required Deleted: faq 06-0012 - manual actions - rev 2.doc

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 3 of 13 faq 06-0012 - manual actions - rev 2 (2).doc (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)

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.

Deleted: faq 06-0012 - manual actions - rev 2.doc

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 4 of 13 faq 06-0012 - manual actions - rev 2 (2).doc 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. (RIS 2006-10)

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Revise NEI 04-02 as shown in the attachment.

Deleted: faq 06-0012 - manual actions - rev 2.doc

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 5 of 13

[Fifth paragraph on page 29 of NEI 04-02 Revision 1]

4.3.2 Nuclear Safety Performance Criteria Transition Review Operator manual actions being transitioned to recovery actions that are not allowed under the current regulatory framework or do not have previous NRC approval should be evaluated using the change process. See Appendix B-2 of this document for additional guidance.

Deleted: M Deleted: (credited for III.G.2 compliance)

Deleted:

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 6 of 13 B.2.2.4 Recovery Actions Operator manual actions will be transitioned as recovery actions in the new NFPA 805 licensing bases. Repairs will also be transitioned as recovery actions.

The following information for operator manual actions should be included in the fire area summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Worksheet):

Whether the transitioning recovery action is allowed or was previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR). Include reference to documentation that demonstrates prior review and approval by the NRC.

Reference to the feasibility evaluation of the transitioning recovery action. See discussion below.

Reference to the evaluation of additional risk associated with the use of recovery actions. See section discussion below.

Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation.

Deleted: M Deleted: that Deleted: y Deleted: for the fire area Deleted: is Deleted: :

Deleted: 1) w Deleted: operator Deleted: manual Deleted: s Deleted: were Deleted:, and 2)

Deleted: R Deleted: A Deleted: s

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 7 of 13 Action is taken inside of the Main Control Room?

Action is a Normally Manually Operated Switch/Valve Action taken to Achieve &

Maintain Cold Shutdown?

Action Credited for App.

R Section III.G.3 (NUREG-0800 C.5.c)?

Action is for fire affected train?

(Meets III.G.1 / III.G.2/

NUREG 0800 Separation)

Action Related to Credited Train, but does not disable Function?

Prior NRC Approval Obtained?

Action is Feasible?

Operator Manual Action is ACCEPTABLE For each Operator Manual Action for a Given Fire Area No No No No No No No Yes Yes Yes Yes Yes Yes Yes Yes No Operator Manual Action Not Allowed / Not Approved (Candidate for RI-PB Change Evaluation)

Figure B-4 General Process to Transition Operator Manual Actions Determining If a Transitioning Operator Manual Action requires a Change Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include:

Operator manual operation from the control room or emergency control station(s)

Repairs or operator manual actions credited either for transitioning to or maintaining cold shutdown equipment Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance Deleted: t Deleted: taion Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

Deleted: are Deleted: M Deleted: is acceptable Deleted: do not require a change evaluation.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 8 of 13 with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800)

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of normally operated manual switches and valves Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Appendix R (or Section C.5.c of NUREG-0800).

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required RIS 2006-10 states: 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.

Operation of fire affected equipment for fire areas that meet the separation requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800). See Figure B-5.

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

operation of equipment for which cables are located in fire areas that meet Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6.

RIS 2006-10 states: 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.

Operator manual actions to address spurious actuations in the credited safe shutdown success path are allowed, as long as the spurious actuation does not disable the credited function and the credited function does not become disabled during the time it takes to perform the operator manual action. See Figures B-7 and B-8 During the June 9, 2006 public meeting the following example was specifically discussed: Two redundant trains taking suction from a common tank. Provided the Deleted: applicable sections Deleted: <#>The operator manual action is currently credited in the Alternate Shutdown Procedure. Although this manual action was NOT specifically mentioned in the SER, the licensee submittal specifically discussed the operator action. This can be considered previously approved¶

<#>The operator manual action is currently credited in Non-Alternate Shutdown Procedure. The manual action was specifically discussed as acceptable in the SER however the NRC did not grant an exemption/deviation. This can be considered previously approved.¶

<#>Operation of equipment for which cables and equipment for the redundant safe shutdown train are located in separate fire areas thus meeting Section III.G.1of Appendix R to 10 CFR Part 50,¶

<#>Manual operation of normally operated manual switches and valves where III.G.1 separation is provided for redundant safe-shutdown trains¶ Deleted: Part Deleted: 6 Deleted: 6 Deleted: 7 Deleted: 7

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 9 of 13 manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation. (Figure B-7)

A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path.

Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)

In addition to allowed operator manual actions some manual actions may have been previously reviewed and approved by the NRC (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205.

In some instances the NRC may have reviewed and approved an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance:

For pre-1979 licensees, a staff decision in an 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. RIS 2006-10 directs licensees to submit an exemption request 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. Since the licensee is adopting NFPA 805 as a licensing basis, the submittal of a clarification exemption request is not necessary. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves operator 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.

RIS 2006-10 states: 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.

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 operator manual actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

RIS 2006-10 states: 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 Deleted: O Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

Deleted: Examples are Deleted: safety evaluation report (SER)

Deleted: paperwork Deleted: operator

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 10 of 13 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.

Operator manual actions that are not allowed or have not been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation process outlined in Chapter 5.3 of this guidance. Examples of operator manual actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting (ML061950327, ML061980016)

Deleted: Repairs credited for cold shutdown equipment will also be transitioned on a fire area basis.

Information that should be summarized includes reference to documentation that demonstrates the equipment necessary for the repair is staged, the repair is proceduralized, and the repair is achievable in the necessary timeframe.¶

¶ Operator manual actions that have been previously reviewed and approved by the NRC (as documented in an approved SER) can be transitioned without the need to use the change 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)

Deleted: that Deleted: July, 19, 2006 Deleted: The following methodology should be used to optimize this process:¶

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 11 of 13 Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Train B Pump Fire Area A Fire Area B Train B Power Supply Train B Power Cable Train A Pump Train A Power Supply Train A Power Cable Train A Control Cable Train B Control Cable 3 - hour Rated Raceway Fire Barrier Fire Area B meets the separation criteria of 10 CFR 50 Appendix R Section III.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 an operator manual action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-5.

Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train Deleted: 4 Deleted: Acceptable Deleted: 5 Deleted: Acceptable

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 12 of 13 Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Suction Deleted: 6

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 13 of 13 Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Feedwater Flow Diversion Deleted: 7

In addition, please find the attached task force responses to NRC comments on revision 1.

Thanks, Brandon From: JAMAR, Brandon Sent: Thursday, March 22, 2007 12:42 PM To: 'Sunil Weerakkody'; Paul Lain; 'Charles Moulton'

Subject:

FAQ 06-0012 Rev. 2 Submittal I've attached revision 2 to FAQ 06-0012 for submittal. One version shows changes and the other is clean for use as you see fit.

Please let me know if you have any questions.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400

Washington, DC 20006 www.nei.org <http://www.nei.org>

P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (4602D864.E04 : 1 : 48644)

Subject:

RE: FAQ 06-0012 Rev. 2 Submittal Creation Date 3/22/2007 3:27:48 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org btj (Brandon JAMAR)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov nei.org Files Size Date & Time MESSAGE 1363 3/22/2007 3:27:48 PM TEXT.htm 8681 TF response to NRC comments - FAQ 06-0012 rev1.pdf 31183 Mime.822 56651 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered

Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 1 of 7 NRC Comment NFPA 805 Task Force Response A

In general, there should be a specific reference provided from the proposed change to the regulatory guidance and technical rational that is the basis for the revision.

See revision to FAQ 06-0012 B

There should be a clear definition and basis of any new terminology or wording. Specifically the proposed wording that manual actions that are currently allowed. This may significantly change the scope of this section and is different from previously approved.

Allowed is not a new term. It was specifically used in NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events. (ML021410026) However, to avoid any confusion the term currently allowed has been revised to allowed.

C. There should be a clear understanding of what documentation will be provided for those conditions / examples that will not require a Change Evaluation. How will the risk be evaluated in these examples and what documentation is to be developed?

This is not the purpose of this FAQ. Feasibility and reliability are addressed in subsequent sections of Appendix B. There is also a parking lot item 39 (FAQ 07-0030) to clarify the evaluation of additional risk D. The overall screening process is not clear and does not lead to a direct interpretation of what does not require an NFPA 805 Change Evaluation. Sections 4.3.2 of NEI 04-02 does not align with this FAQ.

Section 4.3.2 has been revised. See Revision 2 of FAQ 06-0012.

Please explain what is not clear.

E. There was a flow chart provided at the Harris pilot meeting. Is this to be incorporated into this FAQ? If this is the case then the flow chart should assist in this step-by-step screening process.

Incorporated. Note the examples of allowed/approved manual actions has been re-ordered to match the flowchart.

NRC Staff Response to Paragraph # 2:

A. Revise sentence / Para 2 Line 1 : The information for operator manual actions that should be included in the fire area summary (B-3 Worksheet) is:

Incorporated.

NRC Staff Response to Paragraph # 2:

B Explain Para 2 Line 2: Explain the addition of are currently allowed or and provide examples of these MAs. Is this all MAs?

The purpose of this section is to clarify which manual actions will require a change evaluation during the transition. Note Change evaluations are only required for those instances where a compliance strategy is either not allowed under the current regulation or does not have previous NRC approval. The examples that follow this paragraph are examples of allowed (dont have an NRC approval -

bullets 1-5 and 7) and those that have previous approval (bullet 6)

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 2 of 7 NRC Staff Response to Paragraph # 2:

B. Revise sentence / Para 2 Line 5: These operator manual actions identified above in items (1) and (2) as part of the fire area summary may have been reviewed and approved by the NRC in the form of a deviation and or exemption and may not require the need to perform a change evaluation based on demonstrated feasibility.

Comment not incorporated.

Manual actions allowed / previously approved do not require a change evaluation. Manual actions that are not feasible are not allowed (See subsection Criteria for Demonstrating Feasibility).

NRC Staff Response to Paragraph # 2:

C. Delete sentence / Para 2 Line 8: In some cases the previous approval may not be obvious, yet should be allowed. This is not clear on the conditions that may not be obvious. Can this be explained further?

Comment incorporated.

Deleted sentence.

NRC Staff Response to Paragraph # 2:

D. Add / Para 2 Line 9: Examples where manual actions/ recovery actions are required to be demonstrated as feasible however, may not require the use of a Change Evaluation include: If a Change Evaluation is not performed then what is provided as proper consideration?

Comment not incorporated.

The intention of this paragraph is to identify operator manual actions that are not subject to the change evaluation because they are allowed under the current regulatory framework or they have been previously approved.

Section 4.2.4.1.6 of NFPA 805 requires the demonstration of feasibility or all recovery actions (operator manual actions) regardless of whether they are allowed or approved under the currently framework.

Section 4.2.4 of NFPA 805 requires the evaluation of additional risk associated with the use of recovery actions (operator manual actions)

Clarification of these requirements has been added to B.2.2.4 (second paragraph). See revision to FAQ 06-0012.

NRC Staff Response to deleted bullet # 1:

A. Each of these deletions should indicate the rationale and basis for the change and indicate which new example, if any is being proposed that provides clarification and new guidance. This is focused on III.G.3 areas.

This bullet was deleted and the 4th bullet was added to address manual actions taken for III.G.3 areas.

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 3 of 7 NRC Staff Response to deleted bullet #2:

A. Each of these deletions should indicate the rationale and basis for the change and indicate which new example, if any is being proposed that provides clarification and new guidance. This is focused on III.G.2 areas.

Bullets 2 and 3 were deleted at the request of the NRC in their review of FAQ 06-0001. See NRC rationale for the deletion of the bullet.

NRC Staff Response to deleted bullet # 3:

A. Each of these deletions should indicate the rationale and basis for the change and indicate which new example, if any is being proposed that provides clarification and new guidance. This is focused on III.G.1 areas.

Bullets 2 and 3 were deleted at the request of the NRC in their review of FAQ 06-0001. See NRC rationale for the deletion of the bullet.

NRC Staff Response to deleted bullet # 4:

A. Each of these deletions should indicate the rationale and basis for the change and indicate which new example, if any is being proposed that provides clarification and new guidance. This is focused on III.G.1 areas.

This bullet was reworded as new Bullet 1 to make it more consistent with NRC comments on Revision 0 of FAQ 06-0001.

NRC Staff Response to New Bullet # 1 & 2:

A. These new bullets do not capture all the text and or the full intent of the guidance provided in RIS 2006-10 [Ref.1] and within (ML021410026) [Ref.2]. The RIS and the reference state the need for a proper analysis and consideration for the use of manual actions. The proper analysis for performance based should follow the methodology that is identified is a Change Evaluation as per NEI 04-02 Section 4.3.2.

Comment not incorporated.

The intention of these bullets is to identify which manual actions require a change evaluation during the transition.

The change evaluation process identified in NEI 04-02 section 4.3.2 is utilized when a current configuration in the plant js not allowed or has not been previously approved by the NRC. Since these manual action examples are allowed by current regulation they do not require a change evaluation.

Please note that all manual actions require a feasibility evaluation (NFPA 805 Section 4.2.4.1.6). In addition in accordance with section 4.2.4 of NFPA 805, the additional risk presented by their use shall be evaluated. These analyses are considered sufficient to meet the proper analysis and consideration statement in the RIS. Clarification added to B.2.2.4 (see second paragraph).

NRC Staff Response to New Bullet # 1 & 2:

B. These are examples that have not been previously approved by the NRC.

They do not need to be previously approved since they are allowed under the current regulation.

These bullets were originally in FAQ 06-0001. The comments made by the NRC reviewer at the time were incorporated.

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 4 of 7 NRC Staff Response to New Bullet # 1 & 2:

C. The text in Figure B-4 & B-5 should be part of the text in the example, as applicable.

Editorial. Not incorporated NRC Staff Response to New Bullet # 1 & 2:

D. The reference in Figure B-5 to Figure-B-1 should be changed to B-

4.

Incorporated.

NRC Staff Response to New Bullet # 3:

A. This new bullet adds text and may change the intent of the guidance provided in RIS 2006-10 [Ref. 1]and within (ML021410026) [Ref.2]. Define and reference the statement that de-energized valves can be considered manual valves.

This is guidance provided in NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events.

The guidance has been reworded to more accurately reflect the NRC letter.

NRC Staff Response to New Bullet # 3:

B. The generic guidance indicates that for III.G.1 or III.G.2 deterministic approach that recovery actions when used then a proper analysis will be performed to demonstrate feasibility. When transition to NFPA 805 performance-based approach is performed feasibility / reliability should be addressed.

The intention of these bullets is to identify classes of manual actions that do not require a change evaluation. The evaluation of feasibility of manual actions and the additional risk presented by their use is required for all manual actions (those that require and change evaluation as well as those that do not).

No change to this bullet. Clarification added to B.2.2.4 (see second paragraph).

NRC Staff Response to New Bullet # 4:

A. This new bullet does not capture all the text or the full intent of the guidance provided in RIS 2006-10 [Ref. 1] and within (ML021410026) [Ref.2].

The intention of these bullets is to identify classes of manual actions that do not require a change evaluation. The evaluation of feasibility of manual actions and the additional risk presented by their use is required for all manual actions (those that require and change evaluation as well as those that do not)

NRC Staff Response to New Bullet # 4:

B. Specifically the NRR guidance references; the performance criteria of Section III.L as required for III.G.3 when permitting the use of manual actions under certain conditions.

RIS 2006-10 states: 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.

The performance criteria of III.L will no longer be required post-transition. The nuclear safety performance criteria of NFPA 805 Section 1.5 will be applicable.

The required feasibility / additional risk assessment will address achievement of the performance goals.

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 5 of 7 NRC Staff Response to New Bullet # 4:

C. Compliance of III.G.3 areas directly to NFPA 805 would use the performance criteria in III.L of Appendix R as the baseline. The additional risk, if any would be identified in the change evaluation process.

See response above.

NRC Staff Response to New Bullet # 5:

A. There are no references to RIS or other NRC guidance that could be identified that support the example of this condition.

This guidance was provided based on the following example discussed in the June 9, 2006 meeting. Specifically, Two redundant trains taking suction from a common tank. Provided the manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would not require a change evaluation.

NRC Staff Response to New Bullet # 5:

B. This criteria is not consistent with NRR guidance and should be further clarified.

See response above.

NRC Staff Response to New Bullet # 6:

A. This new bullet does not capture all the text or the full intent of the guidance provided in RIS 2006-10 [Ref.1] and within (ML021410026) [Ref.2].

For the referenced paragraph the RIS was written in context of a plant that was not transitioning to NFPA 805. The intent of the RIS was to clean-up a NRC documentation issue (exemption versus SER).

Since the RIS endorses a licensee submitting an exemption under 50.12 citing special circumstances and the SER as the safety basis stating the safety basis established in the SER remains valid we believe that, with validation of the basis, that a change evaluation would not be required.

NRC Staff Response to New Bullet # 6:

B. If a prior exemption is not documented then the noncompliance exists and should be identified in the corrective action program while proceeding to verify the basis for acceptability.

If the manual action is not allowed by the current regulation and previous approval does not exist, then the manual action should be in the corrective action program. See section 3.5 of NEI 04-02.

NRC Staff Response to New Bullet # 6:

C. The basis for acceptability would be demonstrated by meeting the performance-based criteria per NFPA 805 through a change evaluation.

The evaluation of feasibility of manual actions and the additional risk presented by their use is required for all manual actions (those that require and change evaluation as well as those that do not)

Clarification added to B.2.2.4 (see second paragraph).

NRC Staff Response to New Bullet # 7:

A. The example is taken from RIS 2006-10, Section 2.4 Para 1, sentence 1.

No action.

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 6 of 7 NRC Staff Response to New Bullet # 7:

B. Rewrite to include the complete paragraph including the second sentence or explain the deletion. Post-1979 licensees may be requested to demonstrate, as part of the NRC 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.

The purpose of this paragraph is to identify classes of manual actions that require change evaluation. The remainder of the paragraph in the RIS is not germane to that issue.

NRC Staff Response to New Bullet # 7:

C. The RAs in transition should demonstrate proper consideration has been provided and are feasibile.

Clarification added to B.2.2.4 (see second paragraph).

NRC Staff Response to Paragraph # 3:

A. Is the intent of this change to eliminate Change Evaluations for transitioning and post transition? What is the regulatory basis and what are considered credited RAs / MAs?

The intention of the changes to this paragraph is to specifically point out that manual actions and repairs for transitioning to cold shutdown are allowed under the current regulatory framework (Appendix R III.G.1b) and therefore do not require a change evaluation.

NRC Staff Response to paragraph # 4:

A. Please provide examples of MAs that are not allowed that show clear distinction between those examples which would be allowed.

Referenced the NRC summary of the June 9, 2006 public meeting.

Issue 1:

1. Provide a direct reference of the NRR generic communications that were provided in the FAQ Proposal Section that corresponds to the proposed (new examples and changes in text) change in Section B.2.2.4.

Incorporated.

Issue 1:

2. The referenced basis in the FAQ proposal is in some cases is directly quoted from generic NRR communications however, is also paraphrased. Paraphrasing may lead to further interpretation of the guidance and possible difficulty in screening manual actions. Add specific clarification only as necessary and do not change the intent of the guidance.

Incorporated to the extent the reference had impact on the decision to perform a change evaluation.

NEI Task Force Response to NRC Comment on FAQ 06-0012 Page 7 of 7 Issue 1:

3. Some of the examples of recovery actions have detailed Figures.

Some do not have Figures and may be unclear (the text may differ from the Example to the Figure) as to their relationship to a specific NRR generic communication. Review each example to determine the need for figures and revised text.

More examples added.

Issue 1:

4. Consider the use of an algorithm to show the process and the examples step-by-step that represent the examples that do not and those that do require a change evaluation and or another type of analysis.

Added flowchart presented during the pilot process.

Issue 1:

5. As part of Section B.2.2 Fire Area -by-Fire Area Transition these recovery actions and their basis will be captured in the worksheet. A sample should be provided, in detail, of how each of the Examples would apply with reference to the generic guidance and a figure, as necessary.

This will be done during the pilot process.

Issue 1:

6. Any noncompliant MA / RA condition(s) that are identified during the transition of Fire Areas should be documented in the corrective action program.

Yes. See section 3.5 of NEI 04-02.

Issue 2:

A. NEI 04-02 Section 4.3.2 Para 3; Where the changes from the original NRC review and approval have been made appropriately using an approved change process, the changes are considered an acceptable part of the CLB.

No change read the remaining paragraph. Cannot be considered previously approved if changes were made to the original NRC approval.

Issue 2:

B. NEI 04-02 Section 4.3.2 Next to last Para; Manual actions (credited for III.G.2 compliance) being transitioned to recovery actions that do not have previous approval should be evaluated using the change process.

Clarified. See changes to Section 4.3.2 in Revision 2 to FAQ 0-0012

Brandon, Could you send us Word versions of these two files? Something about the images on page 11 (the two figurese B-5 and B-6) kills our printers (causes "printer error"s and forces them to go off-line).

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

>>> "JAMAR, Brandon" <btj@nei.org> 3/22/2007 12:41 PM >>>

I've attached revision 2 to FAQ 06-0012 for submittal. One version shows changes and the other is clean for use as you see fit.

Please let me know if you have any questions.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org

P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (4603F903.43C : 12 : 9706)

Subject:

Re: FAQ 06-0012 Rev. 2 Submittal Creation Date 3/23/2007 11:57:55 AM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/23/2007 11:58:16 AM btj (Brandon JAMAR) nrc.gov TWGWPO01.HQGWDO01 Delivered 3/23/2007 11:57:55 AM PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 Delivered 3/23/2007 11:58:02 AM SDW1 CC (Sunil Weerakkody)

Opened 3/24/2007 11:15:46 AM Post Office Delivered Route nei.org TWGWPO01.HQGWDO01 3/23/2007 11:57:55 AM nrc.gov TWGWPO04.HQGWDO01 3/23/2007 11:58:02 AM nrc.gov Files Size Date & Time MESSAGE 3515 3/23/2007 11:57:55 AM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate

Status Tracking:

Delivered & Opened

Chuck, Per your request the word files have been attached. Please let me know if you continue to have printing issues and I can send you a hard copy.

Thanks, Brandon

---

Original Message-----

From: Charles Moulton [2]

Sent: Friday, March 23, 2007 11:58 AM To: JAMAR, Brandon Cc: Paul Lain; Sunil Weerakkody

Subject:

Re: FAQ 06-0012 Rev. 2 Submittal

Brandon, Could you send us Word versions of these two files? Something about the images on page 11 (the two figurese B-5 and B-6) kills our printers (causes "printer error"s and forces them to go off-line).

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

>>> "JAMAR, Brandon" <btj@nei.org> 3/22/2007 12:41 PM >>>

I've attached revision 2 to FAQ 06-0012 for submittal. One version shows changes and the other is clean for use as you see fit.

Please let me know if you have any questions.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (46041D3E.66E : 2 : 13934)

Subject:

RE: FAQ 06-0012 Rev. 2 Submittal Creation Date 3/23/2007 2:26:51 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 CC (Sunil Weerakkody)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 1803 3/23/2007 2:26:51 PM FAQ 06-0012 - Manual Actions - Rev 2 - changes accepted.doc 540160 FAQ 06-0012 - Manual Actions - Rev 2.doc 552448 Mime.822 1500141 Options Expiration Date:

None Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled

Junk Mail using personal address books is not enabled Block List is not enabled

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 1 of 13 attachment1 for 3-23-07 14.32 email.doc Plant:

Harris Nuclear Plant Date:

03/22/2007

Contact:

Elizabeth Kleinsorg Phone:

704.651.5548 Email:

ekleinsorg@haifire.com Purpose of FAQ:

Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / 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:

Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.

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

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 2 of 13 attachment1 for 3-23-07 14.32 email.doc 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 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.

These documents provide additional clarification with respect to the acceptability of existing operator 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:

The following information will be used as input for a revision to NEI 04-02:

Allowed Operator Manual Actions With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 3 of 13 attachment1 for 3-23-07 14.32 email.doc (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)

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.

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 4 of 13 attachment1 for 3-23-07 14.32 email.doc 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. (RIS 2006-10)

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Revise NEI 04-02 as shown in the attachment.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked

[Fifth paragraph on page 29 of NEI 04-02 Revision 1]

4.3.2 Nuclear Safety Performance Criteria Transition Review Operator manual actions being transitioned to recovery actions that are not allowed under the current regulatory framework or do not have previous NRC approval should be evaluated using the change process. See Appendix B-2 of this document for additional guidance.

Attachment Page 5 of 13

Attachment to FAQ 06-0012 Revision 2 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 licensing bases. Repairs will also be transitioned as recovery actions.

The following information for operator manual actions should be included in the fire area summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Worksheet):

Whether the transitioning recovery action is allowed or was previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR). Include reference to documentation that demonstrates prior review and approval by the NRC.

Reference to the feasibility evaluation of the transitioning recovery action. See discussion below.

Reference to the evaluation of additional risk associated with the use of recovery actions. See section discussion below.

Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation.

Attachment Page 6 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Action is taken inside of the Main Control Room?

Action is a Normally Manually Operated Switch/Valve Action taken to Achieve &

Maintain Cold Shutdown?

Action Credited for App.

R Section III.G.3 (NUREG-0800 C.5.c)?

Action is for fire affected train?

(Meets III.G.1 / III.G.2/

NUREG 0800 Separation)

Action Related to Credited Train, but does not disable Function?

Prior NRC Approval Obtained?

Action is Feasible?

Operator Manual Action is ACCEPTABLE For each Operator Manual Action for a Given Fire Area No No No No No No No Yes Yes Yes Yes Yes Yes Yes Yes No Operator Manual Action Not Allowed / Not Approved (Candidate for RI-PB Change Evaluation)

Figure B-4 General Process to Transition Operator Manual Actions Determining If a Transitioning Operator Manual Action requires a Change Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include:

Operator manual operation from the control room or emergency control station(s)

Repairs or operator manual actions credited either for transitioning to or maintaining cold shutdown equipment Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance Attachment Page 7 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800)

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of normally operated manual switches and valves Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Appendix R (or Section C.5.c of NUREG-0800).

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required RIS 2006-10 states: 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.

Operation of fire affected equipment for fire areas that meet the separation requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800). See Figure B-5.

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

operation of equipment for which cables are located in fire areas that meet Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6.

RIS 2006-10 states: 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.

Operator manual actions to address spurious actuations in the credited safe shutdown success path are allowed, as long as the spurious actuation does not disable the credited function and the credited function does not become disabled during the time it takes to perform the operator manual action. See Figures B-7 and B-8 During the June 9, 2006 public meeting the following example was specifically discussed: Two redundant trains taking suction from a common tank. Provided the Attachment Page 8 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation. (Figure B-7)

A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path.

Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)

In addition to allowed operator manual actions some manual actions may have been previously reviewed and approved by the NRC (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205.

In some instances the NRC may have reviewed and approved an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance:

For pre-1979 licensees, a staff decision in an 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. RIS 2006-10 directs licensees to submit an exemption request 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. Since the licensee is adopting NFPA 805 as a licensing basis, the submittal of a clarification exemption request is not necessary. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves operator 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.

RIS 2006-10 states: 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.

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 operator manual actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

RIS 2006-10 states: 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 Attachment Page 9 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked 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.

Operator manual actions that are not allowed or have not been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation process outlined in Chapter 5.3 of this guidance. Examples of operator manual actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting (ML061950327, ML061980016)

Attachment Page 10 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train Attachment Page 11 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Suction Attachment Page 12 of 13

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Feedwater Flow Diversion Attachment Page 13 of 13

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 1 of 13 attachment2 for 3-23-07 14.32 email.doc Plant:

Harris Nuclear Plant Date:

03/22/2007

Contact:

Elizabeth Kleinsorg Phone:

704.651.5548 Email:

ekleinsorg@haifire.com Purpose of FAQ:

Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / 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:

Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.

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

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 2 of 13 attachment2 for 3-23-07 14.32 email.doc 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 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.

These documents provide additional clarification with respect to the acceptability of existing operator 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:

The following information will be used as input for a revision to NEI 04-02:

Allowed Operator Manual Actions With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 3 of 13 attachment2 for 3-23-07 14.32 email.doc (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)

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.

FAQ Number 06-0012 Revision 2 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 4 of 13 attachment2 for 3-23-07 14.32 email.doc 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. (RIS 2006-10)

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Revise NEI 04-02 as shown in the attachment.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 5 of 13

[Fifth paragraph on page 29 of NEI 04-02 Revision 1]

4.3.2 Nuclear Safety Performance Criteria Transition Review Operator manual actions being transitioned to recovery actions that are not allowed under the current regulatory framework or do not have previous NRC approval should be evaluated using the change process. See Appendix B-2 of this document for additional guidance.

Deleted: M Deleted: (credited for III.G.2 compliance)

Deleted:

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 6 of 13 B.2.2.4 Recovery Actions Operator manual actions will be transitioned as recovery actions in the new NFPA 805 licensing bases. Repairs will also be transitioned as recovery actions.

The following information for operator manual actions should be included in the fire area summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Worksheet):

Whether the transitioning recovery action is allowed or was previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR). Include reference to documentation that demonstrates prior review and approval by the NRC.

Reference to the feasibility evaluation of the transitioning recovery action. See discussion below.

Reference to the evaluation of additional risk associated with the use of recovery actions. See section discussion below.

Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation.

Deleted: M Deleted: that Deleted: y Deleted: for the fire area Deleted: is Deleted: :

Deleted: 1) w Deleted: operator Deleted: manual Deleted: s Deleted: were Deleted:, and 2)

Deleted: R Deleted: A Deleted: s

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 7 of 13 Action is taken inside of the Main Control Room?

Action is a Normally Manually Operated Switch/Valve Action taken to Achieve &

Maintain Cold Shutdown?

Action Credited for App.

R Section III.G.3 (NUREG-0800 C.5.c)?

Action is for fire affected train?

(Meets III.G.1 / III.G.2/

NUREG 0800 Separation)

Action Related to Credited Train, but does not disable Function?

Prior NRC Approval Obtained?

Action is Feasible?

Operator Manual Action is ACCEPTABLE For each Operator Manual Action for a Given Fire Area No No No No No No No Yes Yes Yes Yes Yes Yes Yes Yes No Operator Manual Action Not Allowed / Not Approved (Candidate for RI-PB Change Evaluation)

Figure B-4 General Process to Transition Operator Manual Actions Determining If a Transitioning Operator Manual Action requires a Change Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include:

Operator manual operation from the control room or emergency control station(s)

Repairs or operator manual actions credited either for transitioning to or maintaining cold shutdown equipment Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance Deleted: t Deleted: taion Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

Deleted: are Deleted: M Deleted: is acceptable Deleted: do not require a change evaluation.

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 8 of 13 with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800)

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of normally operated manual switches and valves Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Appendix R (or Section C.5.c of NUREG-0800).

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required RIS 2006-10 states: 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.

Operation of fire affected equipment for fire areas that meet the separation requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800). See Figure B-5.

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

operation of equipment for which cables are located in fire areas that meet Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6.

RIS 2006-10 states: 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.

Operator manual actions to address spurious actuations in the credited safe shutdown success path are allowed, as long as the spurious actuation does not disable the credited function and the credited function does not become disabled during the time it takes to perform the operator manual action. See Figures B-7 and B-8 During the June 9, 2006 public meeting the following example was specifically discussed: Two redundant trains taking suction from a common tank. Provided the Deleted: applicable sections Deleted: <#>The operator manual action is currently credited in the Alternate Shutdown Procedure. Although this manual action was NOT specifically mentioned in the SER, the licensee submittal specifically discussed the operator action. This can be considered previously approved¶

<#>The operator manual action is currently credited in Non-Alternate Shutdown Procedure. The manual action was specifically discussed as acceptable in the SER however the NRC did not grant an exemption/deviation. This can be considered previously approved.¶

<#>Operation of equipment for which cables and equipment for the redundant safe shutdown train are located in separate fire areas thus meeting Section III.G.1of Appendix R to 10 CFR Part 50,¶

<#>Manual operation of normally operated manual switches and valves where III.G.1 separation is provided for redundant safe-shutdown trains¶ Deleted: Part Deleted: 6 Deleted: 6 Deleted: 7 Deleted: 7

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 9 of 13 manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation. (Figure B-7)

A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path.

Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)

In addition to allowed operator manual actions some manual actions may have been previously reviewed and approved by the NRC (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205.

In some instances the NRC may have reviewed and approved an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance:

For pre-1979 licensees, a staff decision in an 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. RIS 2006-10 directs licensees to submit an exemption request 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. Since the licensee is adopting NFPA 805 as a licensing basis, the submittal of a clarification exemption request is not necessary. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves operator 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.

RIS 2006-10 states: 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.

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 operator manual actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

RIS 2006-10 states: 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 Deleted: O Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

Deleted: Examples are Deleted: safety evaluation report (SER)

Deleted: paperwork Deleted: operator

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 10 of 13 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.

Operator manual actions that are not allowed or have not been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation process outlined in Chapter 5.3 of this guidance. Examples of operator manual actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting (ML061950327, ML061980016)

Deleted: Repairs credited for cold shutdown equipment will also be transitioned on a fire area basis.

Information that should be summarized includes reference to documentation that demonstrates the equipment necessary for the repair is staged, the repair is proceduralized, and the repair is achievable in the necessary timeframe.¶

¶ Operator manual actions that have been previously reviewed and approved by the NRC (as documented in an approved SER) can be transitioned without the need to use the change 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)

Deleted: that Deleted: July, 19, 2006 Deleted: The following methodology should be used to optimize this process:¶

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 11 of 13 Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Train B Pump Fire Area A Fire Area B Train B Power Supply Train B Power Cable Train A Pump Train A Power Supply Train A Power Cable Train A Control Cable Train B Control Cable 3 - hour Rated Raceway Fire Barrier Fire Area B meets the separation criteria of 10 CFR 50 Appendix R Section III.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 an operator manual action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-5.

Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train Deleted: 4 Deleted: Acceptable Deleted: 5 Deleted: Acceptable

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 12 of 13 Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Suction Deleted: 6

Attachment to FAQ 06-0012 Revision 2 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 13 of 13 Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Feedwater Flow Diversion Deleted: 7

Brandon, Please send a hard copy of each of these. There seems to be something on that page (11) that our printers (or the printer network) just can't process. Note that this won't affect the original pdf files going into ADAMS and that I am not having this problem with the "comments" file.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

>>> "JAMAR, Brandon" <btj@nei.org> 3/23/2007 2:26 PM >>>

Chuck, Per your request the word files have been attached. Please let me know if you continue to have printing issues and I can send you a hard copy.

Thanks, Brandon

---

Original Message-----

From: Charles Moulton [3]

Sent: Friday, March 23, 2007 11:58 AM To: JAMAR, Brandon Cc: Paul Lain; Sunil Weerakkody

Subject:

Re: FAQ 06-0012 Rev. 2 Submittal

Brandon, Could you send us Word versions of these two files? Something about the images on page 11 (the two figurese B-5 and B-6) kills our printers (causes "printer error"s and forces them to go off-line).

Thanks, Chuck

Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

>>> "JAMAR, Brandon" <btj@nei.org> 3/22/2007 12:41 PM >>>

I've attached revision 2 to FAQ 06-0012 for submittal. One version shows changes and the other is clean for use as you see fit.

Please let me know if you have any questions.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org

nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (46043470.43C : 12 : 9706)

Subject:

RE: FAQ 06-0012 Rev. 2 Submittal Creation Date 3/23/2007 4:11:28 PM From:

Charles Moulton Created By:

CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 3/23/2007 4:11:49 PM btj (Brandon JAMAR) nrc.gov TWGWPO01.HQGWDO01 Delivered 3/23/2007 4:11:29 PM PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 Delivered 3/23/2007 4:11:37 PM SDW1 CC (Sunil Weerakkody)

Opened 3/24/2007 11:15:31 AM Post Office Delivered Route nei.org TWGWPO01.HQGWDO01 3/23/2007 4:11:29 PM nrc.gov TWGWPO04.HQGWDO01 3/23/2007 4:11:37 PM nrc.gov Files Size Date & Time MESSAGE 5554 3/23/2007 4:11:28 PM Options Auto Delete:

No Expiration Date:

None Notify Recipients:

Yes Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard To Be Delivered:

Immediate

Status Tracking:

Delivered & Opened

Correct revision 3d to FAQ 06-0008 is attached. If you have comments you are comfortable sharing please send them via e-mail ahead of the formal feedback so we can work on this as quickly as possible (Dan, this is what I was suggesting - just need them captured somewhere).

Thank you, Brandon From: JAMAR, Brandon Sent: Friday, March 30, 2007 9:38 AM To: 'Charles Moulton'; Sunil Weerakkody; Paul Lain Cc: 'Robert Radlinski'

Subject:

NFPA 805 - FAQ 06-0008 Rev. 3c Sumbittal Please find revision 3c to FAQ 06-0008 attached for submittal.

FAQ 06-0008 Rev. 3c changes are tracked from Rev. 2d sent to NRC on 3/20/07. Two files are attached (changes shown/changes accepted). Also included in this transmittal is a markup to NEI 04-02 Rev. 1 sections (changes are tracked from Rev. 1 of NEI 04-02 with exception of App. I form, which was tracked from FAQ 06-02).

If you have any questions please give me a call.

Thank you,

Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006 www.nei.org <http://www.nei.org>

P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

Mail Envelope Properties (460D3675.014 : 20 : 40980)

Subject:

Resubmit - NFPA 805 - FAQ 06-0008 Rev. 3d Submittal Creation Date 3/30/2007 12:11:47 PM From:

"JAMAR, Brandon" <btj@nei.org>

Created By:

btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)

PWL (Paul Lain) nrc.gov OWGWPO02.HQGWDO01 DXF1 (Daniel Frumkin) nrc.gov TWGWPO03.HQGWDO01 RFR1 CC (Robert Radlinski) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org btj (Brandon JAMAR)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov OWGWPO02.HQGWDO01 nrc.gov TWGWPO03.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov nei.org Files Size Date & Time MESSAGE 1847 3/30/2007 12:11:47 PM TEXT.htm 9607 FAQ 06-0008 rev 3d engineering analyses_changes shown.pdf 68624 FAQ 06-0008 rev 3d nei 04-02 markups.pdf 100159 FAQ 06-0008 rev 3d engineering analyses_changes accepted.pdf 55745 Mime.822 323453 Options Expiration Date:

None

Priority:

Standard ReplyRequested:

No Return Notification:

None Concealed

Subject:

No Security:

Standard Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc Plant: Harris Date:

3/30/07

Contact:

Jeff Ertman Phone:

919-546-3681 Email:

jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

The purpose of FAQ 06-0008 is to provide a process/method for the use of fire protection engineering analyses post-transition to address NFPA 805 Chapter 3 requirements. Currently, licensees may self approve these evaluations under the existing fire protection license conditions.

The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). The process/method to be submitted in the LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Post-transition, licensees will use this process/method to self approve acceptable fire protection engineering analyses.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

Sections 2.3, 2.4, 4.3.1, 4.6.1, 5.3.2, Appendix H, and Appendix I of NEI 04-02 Revision 1.

Circumstances requiring guidance interpretation or new guidance:

Risk-informed, performance-based fire protection engineering analyses are an acceptable alternative to the deterministic approaches in NFPA 805 Chapter 4. Some sections of Chapter 3 are conditional based upon Chapter 4 requirements; therefore, risk-informed, performance-based methods are allowed for those sections under NFPA 805 / 10 CFR 50.48 (c). Risk-informed, performance-based fire protection engineering analyses may also be needed to document the acceptability of fire protection systems and features addressed in NFPA 805 Chapter 3 sections that are not conditional based upon Chapter 4 requirements. Current licensing basis allows flexibility to use performance-based technical analysis per Generic Letter 86-10. An alternative method (approach) is needed to allow this flexibility following transition to NFPA 805.

Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

The fire protection program elements and minimum design requirements of NFPA 805 Chapter 3 may be subject to the performance-based methods permitted elsewhere in NFPA 805 per 10 CFR 50.48(c)(2)(vii), as long as the appropriate regulatory processes (i.e., a license amendment request) are utilized.

A process for a 10 CFR 50.48(c)(2)(vii) License Amendment Request has not yet been agreed upon.

Potentially relevant existing FAQ numbers:

FAQ 06-0004 includes a process for defining fire protection systems and features required to meet NFPA 805 Chapter 3 criteria.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c),

is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) to develop a process to maintain the current flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.

BACKGROUND 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this FAQ to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA Deleted: and 10 CFR 50.48(c)(4) provide for performance-based methods and alternatives to NFPA 805 as a means of meeting fire protection regulations, Deleted: /10 CFR 50.48(c)(4)

Deleted: and 10 CFR 50.48(c)(4)

Deleted: and 10 CFR 50.48(c)(iv)

Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4. These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

PROCESS Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205):

Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.

Licensees may also perform change evaluations for deviations from the NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following provides the sections of NFPA 805 that will utilize this process/method. Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Column Heading Definition:

Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.

Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.

Deleted:.

Deleted: Changes to other portions of Chapter 3 of NFPA 805 Deleted: and listings for rated components, Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this FAQ is not applicable and would be outside the scope of the associated LAR.

Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.1 General X

3.2 Fire Protection Plan X

3.2.1 Intent X

3.2.2 Management Policy Direction and Responsibility X

3.2.3 Procedures X

3.3 Prevention X

3.3.1 Fire Prevention for Operational Activities X

3.3.2 Structural X

3.3.3 Interior Finishes X

3.3.4 Insulation Materials X

3.3.5 Electrical X

3.3.6 Roofs X

3.3.7 Bulk Flammable Gas Storage X

3.3.8 Bulk Storage of Flammable and Combustible Liquids X

3.3.9 Transformers X

3.3.10 Hot Pipes and Surfaces X

3.3.11 Electrical Equipment (Note 1)

X 3.3.12 Reactor Coolant Pumps (Note 1)

X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X

3.4.2 Pre-Fire Plans X

Deleted: FAQ 06-008 Deleted: FAQ 06-008 Deleted: X Deleted: X Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.4.3 Training and Drills X

3.4.4 Fire Fighting Equipment X

3.4.5 Off-Site Fire Department Interface X

3.4.6 Communications X

3.5 Water Supply X

3.6 Standpipe and Hose Stations X

3.7 Fire Extinguishers X

3.8 Fire Alarm and Detection Systems X

3.9 Automatic and Manual Water-Based Fire Suppression Systems X

3.10.

Gaseous Fire Suppression Systems X

3.11 Passive Fire Protection Features X

3.11.1 Building Separation X

3.11.2 Fire Barriers X

3.11.3 Fire Barrier Penetrations X

3.11.4 Through Penetration Fire Stops (Note 2)

X 3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS)

X Note 1 - Separate FAQs will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.

Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)

Deleted: FAQ 06-008 Deleted: FAQ 06-008 Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 6 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc EXAMPLE Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

JUSTIFICATION Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives /

criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to NFPA 805 Chapter 4 conditional sections and the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

The method will ensure that the following requirements are met:

10 CFR 50.48(c) Requirement Method of Accomplishment (a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.

The fire protection engineering analysis process includes the assessment of impact on NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.

(b) Safety margins are maintained.

Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

(c) Fire protection defense-in-depth is maintained.

Maintaining fire protection defense-in-depth will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 7 of 7 FAQ 06-0008 rev 3d engineering analyses_changes shown.doc The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:

RG 1.205 Guidance Method of Accomplishment (a) detailed description of the alternative risk-informed, performance-based method The alternative method will be described in the LAR in detail, or a reference to NEI 04-02 will be provided once the process is added to this document.

(b) description of how the method will be applied, the aspects of the FPP to which it will applied, and the circumstances under which it will be applied Risk-informed, performance based fire protection engineering analyses will be allowed to be applied When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805 (c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when determining whether the results of an evaluation that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria Acceptance criteria for changes will use the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J (and supplemented by RG 1.205 Section 3.2).

(d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy for evaluation of the changes to which it will be applied Technical adequacy of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

(e) for PSA-based methodologies, a description of the peer review and how the review findings have been addressed Peer review of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

[See attached proposed revision to NEI 04-02]

Deleted: addressed by Deleted:

Deleted: To be provided following review and discussion on the approach with the NRC.]

Deleted: ¶ A proposed method/process is to include the text from the Process and Example sections above in section 5.3 of NEI 04-

02. Note this is similar to guidance from NEI 02-03 Appendix A. The new process/method for changes would be cross-referenced in the other sections of NEI 04-02 (i.e., 2.3, 2.4, 4.3.1, 4.6.1, Appendix H, and Appendix I).

Deleted: FAQ 06-0008 rev 3d engineering analyses.doc

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 1 Section 2.2, page 7, 3rd paragraph:

Performance-Based Methods, § 50.48(c)(2)(vii) - The prohibition in Section 3.1 of NFPA 805 that does not permit the use of performance-based methods for the Chapter 3 fundamental fire protection program elements and minimum design criteria is not endorsed. The NRC takes this exception in order to provide licensees greater flexibility in meeting the fire protection program elements and minimum design requirements of Chapter 3 by the use of performance-based methods (including the use of risk-informed methods) described in the NFPA 805 standard. Licensees who wish to deviate from Chapter 3 requirements must submit a license amendment request for NRC approval.

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

o When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and o For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 2.3, page 9, 2nd paragraph:

Compliance with Chapter 3 of NFPA 805 may be demonstrated by showing that the specific requirements are met either directly or by the use of alternative methods and analytical approaches. Alternative methods and analytical approaches must be accepted by the NRC in a license amendment per 10 CFR 50.48(c)(4). Contrary to Section 3.1 of NFPA 805, performance-based methods may be used. (See 10 CFR 50.48(c)(2)(vii)). Note licensees contemplating applying for permission to use an alternative method or analytical approach could pursue a generic approval process with other utilities and/or NEI. See Section 2.4 of this document.

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.1.1, page 21, 1st paragraph:

For areas of the fire protection program that are not in compliance with NFPA 805, Chapter 3, the licensee may utilize the alternate performance-based methods as long as the method is

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 2 approved by the NRC in a License Amendment. The NRC has taken exception to NFPA 805, Section 3.1 (See 10 CFR 50.48.c (2)(vii)).

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.3.1, page 27, add new paragraph to this section at the end Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.6.1, page 34 insert new paragraph before last sentence A sample LAR Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 5.3.1, page 43

.Under the risk-informed, performance-based regulatory framework, Fire Protection Program changes will be made without prior NRC approval, except where required by:

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 3 10 CFR 50.59, Other regulatory processes (i.e., Technical Specifications),

10CFR 50.48(c) (certain changes to Chapter 3 requirements or Nuclear Safety Changes that do not meet the acceptance criteria of NFPA Section 2.4.4.)

Changes that have been evaluated using performance-based methods other than the those acceptable to the AHJ Changes that have been evaluated using performance-based methods other than the approaches in NFPA 805 (i.e., fire modeling and risk evaluation)

Except as noted, in general changes that have been previously approved by the NRC or that do not deviate from a specific NFPA 805 requirement related to systems, methods, or devices need not be submitted for AHJ approval Section 5.3.2, page 46, starting with 7th paragraph:

Additional consideration should be given to changes to Fundamental Program Elements and Minimum Design Requirements. 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)).

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Most changes to the Fundamental Program Elements and Minimum Design Requirements should not require a License Amendment request, since they are evaluations that demonstrate compliance with requirements of Chapter 3 of NFPA 805. Licensees can deviate from the NFPA standards referenced in NFPA 805 Chapter 3 within the bounds discussed in Appendix L.

Examples of changes that would not require a License Amendment are:

Replacing a fire rated component (e.g., penetration seal, door, wrap, etc.) with a different component/material having the same or greater fire rating. This does not require a license amendment because it meets the appropriate code.

Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of NFPA 805 and the referenced code do not dictate where a sprinkler system should be Deleted: NFPA 805 Section 1.7 Equivalency states that Nothing in this standard is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability and safety over those prescribed by this standard. Technical documentation shall be submitted to the authority having jurisdiction to demonstrate equivalency.

Licensees can deviate from the NFPA standards referenced in NFPA 805 Chapter 3 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). In addition to the performance-based methods outlined in NFPA 805, the NRC will provide guidance on Analytical methods and tools and methods acceptable for use in NFPA 805 applications in the Regulatory Guide for the adoption of 10 CFR 50.48. Therefore approval will be required for:¶ Deleted: out 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 (e.g.,

Nothing in this standard is intended to restrict new technologies or alternate arrangements, providing the level of safety prescribed by the standard is not lowered. - Excerpt from 1985 edition of NFPA 13) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection systems).

Deleted: <#>Changing the surveillance frequency of a fire protection feature or system based on NFPA standard as long as the underlying basis for the NFPA standard frequency is the same. This does not require a license amendment because the surveillance frequency would satisfy that specified in the current edition of NFPA codes for providing reasonable assurance that the system or component is maintained in an operable condition.¶

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 4 installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.

Evaluating a broken/missing hanger on a fire suppression system. The acceptability of this deviation can be evaluated to show that the support of the system is still adequate with the broken/missing hanger and is therefore equivalent to a code compliant system as allowed by the code of record.

Conversely, examples of changes that would require a License Amendment are:

Reducing the number of fire brigade members required on-site to below five.

Elimination of the Fire Prevention Program at the plant NFPA 805 Section 4.1, states that, Deterministic requirements shall be deemed to satisfy the performance criteria and require no further engineering analysis. Chapter 4 of NFPA 805 provides the requirements for the baseline evaluation of the fire protection programs ability to achieve the performance criteria outlined in Section 1.5 of NFPA 805. The deemed to satisfy with out additional engineering analysis does not imply that a Plant Change Evaluation would not be performed. For example if a licensee was changing its current licensing basis in a fire area to a deterministic method, that change would require a Plant Change Evaluation. Note the Defense in Depth and Safety Margin portion of the Plant Change Evaluation would be satisfied by the fact that a deterministic option was chosen for compliance (See Sections 2.4.4.2 and 2.4.4.3 of NFPA 805).

Deleted: <#>Revision of concentration of an agent to a value less than that required by the respective code or previously approved value.¶

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 5 Appendix I, page I-2 (note: changes are shown to approved FAQ 06-0002, rather than rev. 1 of NEI 04-02).

FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT / MINIMUM DESIGN REQUIREMENT 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 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.

Yes - Proceed to Question 3.a.

No - Document basis and proceed to Question 2

a. Is the change editorial or trivial in nature? (See Attachment 1) o Yes Document basis and stop.

o No Proceed to Question 3.b.

b. Does the change meet NFPA 805 Chapter 3 requirements or the previously approved alternative as defined in [Insert appropriate document reference]?

Previously approved alternatives include fire protection engineering analyses that are allowed based upon an approved license amendment described in NEI 04-02, Appendix L. (See )

o Yes Document conclusions, complete remaining sections.

o No License Amendment Request must be processed for NRC approval.

Complete remaining sections.

Deleted: 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.

FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 6 Appendix I - Attachment 2, page I-8 Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

The following are examples of changes that do not require NRC approval:

Replacing a fire rated component (e.g., fire rated penetration seal, fire door, fire rated wrap, etc.) with a different component having the same or greater fire rating.

Use of fire hoses manufactured from a different material.

Use of a valve assembly supplied by a different manufacturer for a suppression system.

Changes to Fire Brigade Training requirements that do not affect performance.

Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of NFPA 805 and the referenced code do not dictate where a sprinkler system should be installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.

Deleted: In general, deviations from Chapter 3 must be submitted for NRC approval per the Rule. However, licensees can deviate from the NFPA standards referenced in Chapter 3 without NRC approval if allowed by the code of record and the changed condition is in accordance with the terms of the code of record (e.g., many earlier editions of NFPA Codes included the following statement: Nothing in this standard is intended to restrict new technologies or alternate arrangements, providing the level of safety prescribed by the standard is not lowered. - From 1985 edition of NFPA 13) or if the code (including NFPA 805, Chapter 3) does not dictate the specific issue (e.g., suppression system or detection system coverage).

Deleted: <#>Changing the surveillance frequency for a fire protection feature, as long as the new frequency is bounded by the NFPA code of record (and does not increase CDF or LERF), providing reasonable assurance that the system or component is maintained in an operable condition.¶

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 7 This Appendix is based upon Frequently Asked Question 06-0008, Revision [TBD], approved by the NRC in Closure memo dated [TBD], as documented in Regulatory Issues Summary (RIS) 2007-[TBD], dated [TBD] ADAMS Accession No. [TBD].

L.1 Background 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this Appendix to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4.

These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

L.2 Process Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205:

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 8 Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.

Licensees may also perform change evaluations for deviations from the NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following table provides the sections of NFPA 805 that will utilize this process/method.

Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Column Heading Definition:

Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.

Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.

Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this Appendix is not applicable and would be outside the scope of the associated LAR.

Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.1 General X

3.2 Fire Protection Plan X

3.2.1 Intent X

3.2.2 Management Policy Direction and Responsibility X

3.2.3 Procedures X

3.3 Prevention X

3.3.1 Fire Prevention for Operational Activities X

3.3.2 Structural X

3.3.3 Interior Finishes X

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 9 Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.3.4 Insulation Materials X

3.3.5 Electrical X

3.3.6 Roofs X

3.3.7 Bulk Flammable Gas Storage X

3.3.8 Bulk Storage of Flammable and Combustible Liquids X

3.3.9 Transformers X

3.3.10 Hot Pipes and Surfaces X

3.3.11 Electrical Equipment (Note 1)

X 3.3.12 Reactor Coolant Pumps (Note 1)

X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X

3.4.2 Pre-Fire Plans X

3.4.3 Training and Drills X

3.4.4 Fire Fighting Equipment X

3.4.5 Off-Site Fire Department Interface X

3.4.6 Communications X

3.5 Water Supply X

3.6 Standpipe and Hose Stations X

3.7 Fire Extinguishers X

3.8 Fire Alarm and Detection Systems X

3.9 Automatic and Manual Water-Based Fire Suppression Systems X

3.10.

Gaseous Fire Suppression Systems X

3.11 Passive Fire Protection Features X

3.11.1 Building Separation X

3.11.2 Fire Barriers X

3.11.3 Fire Barrier Penetrations X

3.11.4 Through Penetration Fire Stops (Note 2)

X 3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS)

X Note 1 - Separate clarifications [TBD] will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 10 Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)

L.3 Example Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

L.4 Justification Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives

/criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner that was previously allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

The method will ensure that the following requirements are met:

10 CFR 50.48(c) Requirement Method of Accomplishment (a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.

The fire protection engineering analysis process includes the assessment of impact on NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.

(b) Safety margins are maintained.

Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 11 10 CFR 50.48(c) Requirement Method of Accomplishment (c) Fire protection defense-in-depth is maintained.

Maintaining fire protection defense-in-depth will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 3d - NEI 04-02 markup - Page 12 The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:

RG 1.205 Guidance Method of Accomplishment (a) detailed description of the alternative risk-informed, performance-based method The alternative method will be described in the LAR in detail, or a reference to NEI 04-02 will be provided once the process is added to this document.

(b) description of how the method will be applied, the aspects of the FPP to which it will applied, and the circumstances under which it will be applied Risk-informed, performance based fire protection engineering analyses will be allowed to be applied:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805.

(c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when determining whether the results of an evaluation that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria Acceptance criteria for changes will use the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J (and supplemented by RG 1.205 Section 3.2).

(d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy for evaluation of the changes to which it will be applied Technical adequacy of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

(e) for PSA-based methodologies, a description of the peer review and how the review findings have been addressed Peer review of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

L.5 Conclusion This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues, not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.

Formatted: Bullets and Numbering

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc Plant: Harris Date:

3/30/07

Contact:

Jeff Ertman Phone:

919-546-3681 Email:

jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

The purpose of FAQ 06-0008 is to provide a process/method for the use of fire protection engineering analyses post-transition to address NFPA 805 Chapter 3 requirements. Currently, licensees may self approve these evaluations under the existing fire protection license conditions.

The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). The process/method to be submitted in the LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Post-transition, licensees will use this process/method to self approve acceptable fire protection engineering analyses.

Is this Interpretation of guidance?

Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

Sections 2.3, 2.4, 4.3.1, 4.6.1, 5.3.2, Appendix H, and Appendix I of NEI 04-02 Revision 1.

Circumstances requiring guidance interpretation or new guidance:

Risk-informed, performance-based fire protection engineering analyses are an acceptable alternative to the deterministic approaches in NFPA 805 Chapter 4. Some sections of Chapter 3 are conditional based upon Chapter 4 requirements; therefore, risk-informed, performance-based methods are allowed for those sections under NFPA 805 / 10 CFR 50.48 (c). Risk-informed, performance-based fire protection engineering analyses may also be needed to document the acceptability of fire protection systems and features addressed in NFPA 805 Chapter 3 sections that are not conditional based upon Chapter 4 requirements. Current licensing basis allows flexibility to use performance-based technical analysis per Generic Letter 86-10. An alternative method (approach) is needed to allow this flexibility following transition to NFPA 805.

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

The fire protection program elements and minimum design requirements of NFPA 805 Chapter 3 may be subject to the performance-based methods permitted elsewhere in NFPA 805 per 10 CFR 50.48(c)(2)(vii), as long as the appropriate regulatory processes (i.e., a license amendment request) are utilized.

A process for a 10 CFR 50.48(c)(2)(vii) License Amendment Request has not yet been agreed upon.

Potentially relevant existing FAQ numbers:

FAQ 06-0004 includes a process for defining fire protection systems and features required to meet NFPA 805 Chapter 3 criteria.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c),

is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) to develop a process to maintain the current flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.

BACKGROUND 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this FAQ to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4. These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

PROCESS Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205):

Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.

Licensees may also perform change evaluations for deviations from the NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following provides the sections of NFPA 805 that will utilize this process/method. Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Column Heading Definition:

Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.

Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this FAQ is not applicable and would be outside the scope of the associated LAR.

Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.1 General X

3.2 Fire Protection Plan X

3.2.1 Intent X

3.2.2 Management Policy Direction and Responsibility X

3.2.3 Procedures X

3.3 Prevention X

3.3.1 Fire Prevention for Operational Activities X

3.3.2 Structural X

3.3.3 Interior Finishes X

3.3.4 Insulation Materials X

3.3.5 Electrical X

3.3.6 Roofs X

3.3.7 Bulk Flammable Gas Storage X

3.3.8 Bulk Storage of Flammable and Combustible Liquids X

3.3.9 Transformers X

3.3.10 Hot Pipes and Surfaces X

3.3.11 Electrical Equipment (Note 1)

X 3.3.12 Reactor Coolant Pumps (Note 1)

X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X

3.4.2 Pre-Fire Plans X

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.

Analysis Process and Chapter 4 Not Applicable 3.4.3 Training and Drills X

3.4.4 Fire Fighting Equipment X

3.4.5 Off-Site Fire Department Interface X

3.4.6 Communications X

3.5 Water Supply X

3.6 Standpipe and Hose Stations X

3.7 Fire Extinguishers X

3.8 Fire Alarm and Detection Systems X

3.9 Automatic and Manual Water-Based Fire Suppression Systems X

3.10.

Gaseous Fire Suppression Systems X

3.11 Passive Fire Protection Features X

3.11.1 Building Separation X

3.11.2 Fire Barriers X

3.11.3 Fire Barrier Penetrations X

3.11.4 Through Penetration Fire Stops (Note 2)

X 3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS)

X Note 1 - Separate FAQs will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.

Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 6 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc EXAMPLE Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

JUSTIFICATION Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives /

criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to NFPA 805 Chapter 4 conditional sections and the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

The method will ensure that the following requirements are met:

10 CFR 50.48(c) Requirement Method of Accomplishment (a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.

The fire protection engineering analysis process includes the assessment of impact on NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.

(b) Safety margins are maintained.

Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

(c) Fire protection defense-in-depth is maintained.

Maintaining fire protection defense-in-depth will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

FAQ Number 06-0008 FAQ Revision 3d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 7 of 7 FAQ 06-0008 rev 3d engineering analyses_changes accepted.doc The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:

RG 1.205 Guidance Method of Accomplishment (a) detailed description of the alternative risk-informed, performance-based method The alternative method will be described in the LAR in detail, or a reference to NEI 04-02 will be provided once the process is added to this document.

(b) description of how the method will be applied, the aspects of the FPP to which it will applied, and the circumstances under which it will be applied Risk-informed, performance based fire protection engineering analyses will be allowed to be applied When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805 (c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when determining whether the results of an evaluation that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria Acceptance criteria for changes will use the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J (and supplemented by RG 1.205 Section 3.2).

(d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy for evaluation of the changes to which it will be applied Technical adequacy of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

(e) for PSA-based methodologies, a description of the peer review and how the review findings have been addressed Peer review of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.

CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

[See attached proposed revision to NEI 04-02]