ML071630428
| ML071630428 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 04/03/2007 |
| From: | Charles Moulton NRC/NRR/ADRA/DRA/AFPB, Nuclear Energy Institute |
| To: | Jamar B Nuclear Energy Institute |
| References | |
| Download: ML071630428 (101) | |
Text
Brandon, Attached is an advance e-copy of draft comments on FAQ 8 rev 3. This document will be a handout for the 4/26 public meeting. Please distribute it to the task force/writing group. This document is a summary of the comments Dan talked to you about last week.
Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11
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NRC comments on FAQ 8 revision 3 Creation Date 4/3/2007 9:10:48 AM From:
Charles Moulton Created By:
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NRC Response to FAQ 06-0008, Revision 3 [DXF] {4/2/2007}
Dans comments on Rev 3:
Break down section 3.8 (similar to the way they itemized 3.11), since my reading of the chapter 4 exclusion to section 3.8 only applies to 3.8.2. I believe that the other sections of 3.8 fall under the NFPA code exclusion.
3.11.1 is not subject to the Chapter 4 exclusion.
In the table on page 6, it states at the top of the first column 50.48(c) requirement, this should be 50.48(c).2.vii requirement.
In the 1.205 table (on page 7), the statement, "once the process is added..." may be problematic. I don't see this as a show stopper, but the NRC staff needs to look into the implications of this not being complete. There is a cart before the horse issue here; which comes first: the RIS or the updated 04-02/RG 1.205? My thought is that we need to have the process attached to the FAQ so we can say that it is okay in the RIS. Process wise, you may not be able to have open ended statements in this type of document.
o Suggestion: I think the answer to this question on 1.205 is that an alternative method will not be used. c.2.vii does not require an alternative method. So the open ended statement could be replaced with a statement like, "an alternative method is not proposed, the existing performance-based methods will be applied, but will be applied in a very limited fashion to (nfpa codes and listings)." Do you think that this will fly?
The added tables were looked at pretty closely during an older revision, so assuming nothing has changed there, they should be okay.
Thanks you for capturing these comments. We will address these immediately.
Brandon
Original Message-----
From: Charles Moulton [1]
Sent: Tuesday, April 03, 2007 9:11 AM To: JAMAR, Brandon Cc: Daniel Frumkin; Paul Lain; Sunil Weerakkody
Subject:
NRC comments on FAQ 8 revision 3 Brandon, Attached is an advance e-copy of draft comments on FAQ 8 rev 3. This document will be a handout for the 4/26 public meeting. Please distribute it to the task force/writing group. This document is a summary of the comments Dan talked to you about last week.
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.
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RE: NRC comments on FAQ 8 revision 3 Creation Date 4/3/2007 9:21:01 AM From:
"JAMAR, Brandon" <btj@nei.org>
Created By:
btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton)
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- Brandon, Do you have an update on the status of FAQs 16 and 18?
We are still awaiting the final revision of these two. The writing team requested that we hold off closure until we recieved the final revisions, which would fully resolve the AFPB Staff's comments. Sunil is most interested in ensuring that our resolutions are final so they can be included in the RIS.
We expected to have the new revisions by now. Unfortunately, if we can't get the new revisions prior to the telecon, the schedule will force us to go with the closure memos as they exist.
- Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11
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Status of FAQs 16 and 18 Creation Date 4/11/2007 8:47:00 AM From:
Charles Moulton Created By:
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Please find revision 1 to FAQs 06-0016 & 06-0018 which are attached for submittal. Two versions of each are provided. One shows changes and one shows changes accepted.
If you have any questions regarding this transmittal 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
<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.
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FAQ 06-0016, FAQ 06-0018 Rev. 1 Submittals Creation Date 4/11/2007 2:29:08 PM From:
"JAMAR, Brandon" <btj@nei.org>
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FAQ Number 06-0016, Revision 1 1
Plant:
Harris Nuclear Plant (HNP)
FAQ #
06-0016 Submittal Date:
03-22-07 Licensee
Contact:
David Miskiewicz Tele/email 919-546-7588 NRC
Contact:
Tele/email Distribution: Check all that apply (NEI Internal Use)
FPWG RIRWG NSSS OG NFPA 805 TF
Subject:
Clarification/enhancement of Ignition Source counting guidance for Electrical Cabinets in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:
NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 15), states:
Bin 15 - Electrical Cabinets (Plant-Wide Components): Electrical cabinets represent such items as switchgears, motor control centers, DC distribution panels, relay cabinets, control and switch panels (excluding panels that are part of machinery), fire protection panels, etc. Electrical cabinets in a nuclear power plant vary significantly in size, configuration, and voltage. Size variation range from small-wall mounted units to large walk-through vertical control cabinets, which can be 20 to 30 long. The configuration can vary based on number of components that contribute to ignition, such as relays and circuit cards, and combustible loading, which also affects the fire frequency. Voltages in electrical cabinets vary from low voltage (120 V) panels to 6.9 kV switchgears. Even though it is expected that these features affect the likelihood of fire ignition, from a simple analysis of the event data involving the electrical cabinets, it was determined that the variation by cabinet type did not warrant separate frequency evaluation. Therefore, one fire frequency was estimated for the electrical cabinets.
This guidance infers that cabinet size is not a factor for ignition source counting. However, additional guidance states that electrical cabinets should be counted by their vertical segments.... During the presentation of Pilot Project results it was determined that differences related to the definition of segments could result in notable inconsistency between individual users of NUREG/CR-6850.
Deleted: 0b Deleted: 11-6-06
FAQ Number 06-0016, Revision 1 2
The discussion of this issue found that this issue affects only general electrical cabinets and panels. In the case of switchgears, load centers, unit substations, and motor control centers the term segment was uniformly interpreted to be equal to the individual vertical sections that define these types of components. As applied to general electrical cabinets and panels, the term segments could be interpreted to mean different metrics.
A segment could be defined as an enclosed element that is generally independent of size or volume (also referred to as a vertical section).
A segment could be defined as an individual section of an enclosure regardless of whether it was fully enclosed.
A segment could be defined based on a standard or reference sample panel size.
Depending on the metric being used, the counting of electrical cabinets would result in varying results and consequently, different fire ignition frequency values. While NUREG/CR-6850 allows the establishment of plant specific criteria for counting of electrical cabinets, additional guidance is required to achieve a consistent basis for determining the ignition frequencies.
Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
Potentially relevant existing FAQ numbers:
This guidance is specific to the characterization of electrical cabinets for Bin 15 ignition frequency determination. The characterization of switchgear and load center segments for the purposes of high energy arcing faults is addressed by FAQ 06-0017.
Response Section A generalized counting criterion for general electrical cabinets and panels is proposed. This proposed criterion would involve two elements.
For switchgears, load centers, unit substations, and motor control centers the counting for the purposes of NUREG/CR-6850, Task 6, Bin 15 would be based on vertical section. This counting is illustrated in the following examples.
Deleted: 0b
FAQ Number 06-0016, Revision 1 3
Medium Voltage Switchgear 9 Breakers and Sections Count = 9 for Bin 15 Load Center or Unit Substation 16 Breakers in 4 Sections Count = 4 for Bin 15 Motor Control Center 41 Breakers/Starters in 9 Sections Count = 9 for Bin 15 For general electrical cabinets and panels, counting is based on externally apparent vertical sections. No examination of the internal construction is required.
This proposed counting for electrical cabinets and panels is to be applied for a wide range of panel sizes. However, recognizing that the ignition frequency is more a function of the cabinet contents than the cabinet size, a basis is needed to address outlier conditions. It is proposed that each user be required to establish criteria for identifying the outliers and the basis for counting them. As an example, they can be counted by establishing a nominal standard or reference cabinet size. The count could also be based on evaluating the cabinet internals relative to a defined standard or reference configuration.
For example, a particular user may define a cabinet with any horizontal dimension more than 8 feet as an outlier, and a standard cabinet as being nominally 4 feet in length x 3 feet deep. (cabinet height is not generally an issue based on the use of vertical sections). Using this example, the following cabinet and panel examples would be counted as follows:
Deleted: 0b Deleted: For general electrical cabinets and panels, it is proposed that the counting be based on a physically enclosed element. A physically enclosed element means that that the cabinet or panel is fully enclosed by 6 solid elements with the provision that a non-combustible floor or ceiling may represent the bottom or top. The term solid element is not intended to mean that the element is substantially continuous. Consequently, breeches or unsealed penetrations could still be treated as solid. The term solid is intended to prevent a panel that is divided by an element that is substantially open from being treated as two separate panels.¶
FAQ Number 06-0016, Revision 1 4
6 ft Cabinet is not an outlier -
Count = 1 Cabinet is same as standard Count = 1 Externally, the cabinet appears to have 6 vertical sections. The construction of internal dividers is unknown or open.
Count = 6 Internal dividers are solid Count = 6 Three independent cabinets Count = 3 12 feet, 3 ft deep Panel is an outlier, using a 4 standard cabinet -
Count = 3 9 ft long, 6 ft deep Cabinet is an outlier, no evaluation of contents, based on reference cabinet Count = 3 - due to both variation from the standard length and width..
9 ft long, 6 ft deep Walk Through Cabinet Cabinet is an outlier, evaluation of contents shows small set of ignition sources typical of the standard cabinet -
Count = 1 Deleted: 0b Deleted: Internal dividers are not solid¶ Count = 1 Deleted: low cable loading
FAQ Number 06-0016, Revision 1 5
The intent is that a basis for the counting of outliers is required. A volumetric comparison is not required. Also, to prevent any appearance that this treatment is intended to be based on physical measurements, the proposed approach allows only integer counting. The assignment of fractional values would not be allowed. In addition, the proposed methodology retains the option for screening small cabinets resulting in a count of zero for them (as discussed in NUREG/CR-6850). As applied in this case, the user would be allowed to screen cabinets or panels based on defined criteria and exclude them from the overall population count. When performing detailed fire modeling, the fire should be applied to the actual cabinet footprint by vertical section, including outliers.
Basis:
The existing guidance in NUREG/CR-6850 is based on industry data which has only been provided with fidelity adequate to support plant level ignition frequencies for electrical cabinets. Although the guidance does address the broad applicability of the data, it leaves room for variability that can create issues with PRA quality. It is important that the ignition frequency results be of sufficient quality to support not only NFPA-805 transition but also the more broad scope of regulatory inspection and enforcement issues.
The guidance proposed will provide more consistency when determining plant specific electrical cabinet ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.
Deleted: 0b
FAQ Number 06-0016, Revision 1 1
Plant:
Harris Nuclear Plant (HNP)
FAQ #
06-0016 Submittal Date:
03-22-07 Licensee
Contact:
David Miskiewicz Tele/email 919-546-7588 NRC
Contact:
Tele/email Distribution: Check all that apply (NEI Internal Use)
FPWG RIRWG NSSS OG NFPA 805 TF
Subject:
Clarification/enhancement of Ignition Source counting guidance for Electrical Cabinets in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:
NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 15), states:
Bin 15 - Electrical Cabinets (Plant-Wide Components): Electrical cabinets represent such items as switchgears, motor control centers, DC distribution panels, relay cabinets, control and switch panels (excluding panels that are part of machinery), fire protection panels, etc. Electrical cabinets in a nuclear power plant vary significantly in size, configuration, and voltage. Size variation range from small-wall mounted units to large walk-through vertical control cabinets, which can be 20 to 30 long. The configuration can vary based on number of components that contribute to ignition, such as relays and circuit cards, and combustible loading, which also affects the fire frequency. Voltages in electrical cabinets vary from low voltage (120 V) panels to 6.9 kV switchgears. Even though it is expected that these features affect the likelihood of fire ignition, from a simple analysis of the event data involving the electrical cabinets, it was determined that the variation by cabinet type did not warrant separate frequency evaluation. Therefore, one fire frequency was estimated for the electrical cabinets.
This guidance infers that cabinet size is not a factor for ignition source counting. However, additional guidance states that electrical cabinets should be counted by their vertical segments.... During the presentation of Pilot Project results it was determined that differences related to the definition of segments could result in notable inconsistency between individual users of NUREG/CR-6850.
FAQ Number 06-0016, Revision 1 2
The discussion of this issue found that this issue affects only general electrical cabinets and panels. In the case of switchgears, load centers, unit substations, and motor control centers the term segment was uniformly interpreted to be equal to the individual vertical sections that define these types of components. As applied to general electrical cabinets and panels, the term segments could be interpreted to mean different metrics.
A segment could be defined as an enclosed element that is generally independent of size or volume (also referred to as a vertical section).
A segment could be defined as an individual section of an enclosure regardless of whether it was fully enclosed.
A segment could be defined based on a standard or reference sample panel size.
Depending on the metric being used, the counting of electrical cabinets would result in varying results and consequently, different fire ignition frequency values. While NUREG/CR-6850 allows the establishment of plant specific criteria for counting of electrical cabinets, additional guidance is required to achieve a consistent basis for determining the ignition frequencies.
Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
Potentially relevant existing FAQ numbers:
This guidance is specific to the characterization of electrical cabinets for Bin 15 ignition frequency determination. The characterization of switchgear and load center segments for the purposes of high energy arcing faults is addressed by FAQ 06-0017.
Response Section A generalized counting criterion for general electrical cabinets and panels is proposed. This proposed criterion would involve two elements.
For switchgears, load centers, unit substations, and motor control centers the counting for the purposes of NUREG/CR-6850, Task 6, Bin 15 would be based on vertical section. This counting is illustrated in the following examples.
FAQ Number 06-0016, Revision 1 3
Medium Voltage Switchgear 9 Breakers and Sections Count = 9 for Bin 15 Load Center or Unit Substation 16 Breakers in 4 Sections Count = 4 for Bin 15 Motor Control Center 41 Breakers/Starters in 9 Sections Count = 9 for Bin 15 For general electrical cabinets and panels, counting is based on externally apparent vertical sections. No examination of the internal construction is required.
This proposed counting for electrical cabinets and panels is to be applied for a wide range of panel sizes. However, recognizing that the ignition frequency is more a function of the cabinet contents than the cabinet size, a basis is needed to address outlier conditions. It is proposed that each user be required to establish criteria for identifying the outliers and the basis for counting them. As an example, they can be counted by establishing a nominal standard or reference cabinet size. The count could also be based on evaluating the cabinet internals relative to a defined standard or reference configuration.
For example, a particular user may define a cabinet with any horizontal dimension more than 8 feet as an outlier, and a standard cabinet as being nominally 4 feet in length x 3 feet deep. (cabinet height is not generally an issue based on the use of vertical sections). Using this example, the following cabinet and panel examples would be counted as follows:
FAQ Number 06-0016, Revision 1 4
6 ft Cabinet is not an outlier -
Count = 1 Cabinet is same as standard Count = 1 Externally, the cabinet appears to have 6 vertical sections. The construction of internal dividers is unknown or open.
Count = 6 Internal dividers are solid Count = 6 Three independent cabinets Count = 3 12 feet, 3 ft deep Panel is an outlier, using a 4 standard cabinet -
Count = 3 9 ft long, 6 ft deep Cabinet is an outlier, no evaluation of contents, based on reference cabinet Count = 3 - due to both variation from the standard length and width..
9 ft long, 6 ft deep Walk Through Cabinet Cabinet is an outlier, evaluation of contents shows small set of ignition sources typical of the standard cabinet -
Count = 1
FAQ Number 06-0016, Revision 1 5
The intent is that a basis for the counting of outliers is required. A volumetric comparison is not required. Also, to prevent any appearance that this treatment is intended to be based on physical measurements, the proposed approach allows only integer counting. The assignment of fractional values would not be allowed. In addition, the proposed methodology retains the option for screening small cabinets resulting in a count of zero for them (as discussed in NUREG/CR-6850). As applied in this case, the user would be allowed to screen cabinets or panels based on defined criteria and exclude them from the overall population count. When performing detailed fire modeling, the fire should be applied to the actual cabinet footprint by vertical section, including outliers.
Basis:
The existing guidance in NUREG/CR-6850 is based on industry data which has only been provided with fidelity adequate to support plant level ignition frequencies for electrical cabinets. Although the guidance does address the broad applicability of the data, it leaves room for variability that can create issues with PRA quality. It is important that the ignition frequency results be of sufficient quality to support not only NFPA-805 transition but also the more broad scope of regulatory inspection and enforcement issues.
The guidance proposed will provide more consistency when determining plant specific electrical cabinet ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.
FAQ Number 06-0018, Revision 1 1
Plant:
Harris Nuclear Plant (HNP)
FAQ #
06-0018 Submittal Date:
3-22-07 Licensee
Contact:
David Miskiewicz Tele/email 919-546-7588 NRC
Contact:
Tele/email Distribution: Check all that apply (NEI Internal Use)
Deleted: 0b Deleted: 11-6-06
FPWG RIRWG NSSS OG NFPA 805 TF
Subject:
Clarification/enhancement of Ignition Source counting guidance for Main Control Board (MCB) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:
NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
NUREG/CR-6850, Section 6.5.6 The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency, is subject to application inconsistency in the treatment of Main Control Board (Bin 4). The guidance for Task 6 does not provide any specific definition or characterization of what constitutes a Main Control Board (MCB) other than a reference to it being the central element of the room. A discussion amongst the Pilot Plants that included consideration of other plants in their respective fleets found wide variability in the configuration of the main control room. There was a concern that inconsistent treatment of this bin would unnecessarily challenge the completion and review of the Fire PRA. This challenge would be manifested by a notable change in the fire frequency assigned to an individual panel depending on whether it was counted as Bin 4 or Bin 15.
Further review of NUREG/CR-6850 found that a definition of MCB is provided in Appendix L.
However, this Appendix develops a fire modeling treatment of fire behavior within a panel enclosure. There was a concern that absent documented agreement, there could be a future challenge to the use of the definition in Appendix L for the purposes of Task 6, Bin 4 counting.
Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
FAQ Number 06-0018, Revision 1 3
Potentially relevant existing FAQ numbers:
This guidance is specific to the characterization of Main Control Board for Bin 4 determination.
The characterization and counting of electrical cabinets for Bin 15 determination is addressed by FAQ 06-0016.
Response Section It is proposed that the definition of Main Control Board provided in NUREG/CR-6850, Appendix L be accepted as also being applicable for Task 6, Bin 4 counting. Any panel that is detached from the main horseshoe would generally be excluded from this definition of the main control board with few exceptions.
Basis:
The guidance proposed will provide more consistency when determining plant specific control room ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.
Deleted: 0b
FAQ Number 06-0018, Revision 1 1
Plant:
Harris Nuclear Plant (HNP)
FAQ #
06-0018 Submittal Date:
3-22-07 Licensee
Contact:
David Miskiewicz Tele/email 919-546-7588 NRC
Contact:
Tele/email Distribution: Check all that apply (NEI Internal Use)
FPWG RIRWG NSSS OG NFPA 805 TF
Subject:
Clarification/enhancement of Ignition Source counting guidance for Main Control Board (MCB) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:
NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
NUREG/CR-6850, Section 6.5.6 The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency, is subject to application inconsistency in the treatment of Main Control Board (Bin 4). The guidance for Task 6 does not provide any specific definition or characterization of what constitutes a Main Control Board (MCB) other than a reference to it being the central element of the room. A discussion amongst the Pilot Plants that included consideration of other plants in their respective fleets found wide variability in the configuration of the main control room. There was a concern that inconsistent treatment of this bin would unnecessarily challenge the completion and review of the Fire PRA. This challenge would be manifested by a notable change in the fire frequency assigned to an individual panel depending on whether it was counted as Bin 4 or Bin 15.
Further review of NUREG/CR-6850 found that a definition of MCB is provided in Appendix L.
However, this Appendix develops a fire modeling treatment of fire behavior within a panel enclosure. There was a concern that absent documented agreement, there could be a future challenge to the use of the definition in Appendix L for the purposes of Task 6, Bin 4 counting.
Detail contentious points if licensee and NRC have not reached agreement This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
Potentially relevant existing FAQ numbers:
This guidance is specific to the characterization of Main Control Board for Bin 4 determination.
The characterization and counting of electrical cabinets for Bin 15 determination is addressed by FAQ 06-0016.
Response Section It is proposed that the definition of Main Control Board provided in NUREG/CR-6850, Appendix L be accepted as also being applicable for Task 6, Bin 4 counting. Any panel that is detached from the main horseshoe would generally be excluded from this definition of the main control board with few exceptions.
Basis:
The guidance proposed will provide more consistency when determining plant specific control room ignition frequencies while working within the bounds of the exiting data provided by the NUREG. This should facilitate the review and acceptability of the results.
- Brandon, Dan will complete FAQ-06-008.
Phil has completed FAQ-06-012. We will share it on 2/26.
What is the next most important FAQ? FAQ-06-005? FAQ-06-011? Consult with the pilots and let us know asap.
Sunil
Mail Envelope Properties (46236470.D54 : 19 : 10000)
Subject:
Next most important FAQ Creation Date 4/16/2007 7:56:32 AM From:
Sunil Weerakkody Created By:
SDW1@nrc.gov Recipients nei.org btj (Brandon JAMAR) nrc.gov OWGWPO02.HQGWDO01 DXF1 CC (Daniel Frumkin) nrc.gov OWGWPO04.HQGWDO01 ARK1 CC (Alex Klein) nrc.gov TWGWPO01.HQGWDO01 CEM4 CC (Charles Moulton)
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The next highest FAQ priority is FAQ 11.
The following have the next, but equal priorities: FAQs 5, 16, 17, 18 Brandon
Original Message-----
From: Sunil Weerakkody [2]
Sent: Monday, April 16, 2007 7:57 AM To: JAMAR, Brandon Cc: Alex Klein; Charles Moulton; Daniel Frumkin; Phil Qualls; Paul Lain
Subject:
Next most important FAQ
- Brandon, Dan will complete FAQ-06-008.
Phil has completed FAQ-06-012. We will share it on 2/26.
What is the next most important FAQ? FAQ-06-005? FAQ-06-011? Consult with the pilots and let us know asap.
Sunil
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RE: Next most important FAQ Creation Date 4/16/2007 1:19:57 PM From:
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I've attached FAQ 06-0008 Revision 4a for submittal. This file has both the engineering analysis and corresponding NEI 04-02 markup which was combined per Dan's request.
Please let me know if there are any issues with this transmittal. Also, would you please reply to me indicating you successfully received this email?
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.
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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 8 FAQ 06-0008 rev 4a engineering analyses.doc Plant: Harris Date:
4/9/07
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 approach using these types of analyses is needed to allow this flexibility following transition to NFPA 805.
Deleted: An alternative method (approach)
FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 8 FAQ 06-0008 rev 4a engineering analyses.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 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 8 FAQ 06-0008 rev 4a engineering analyses.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 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 8 FAQ 06-0008 rev 4a engineering analyses.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 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 8 FAQ 06-0008 rev 4a engineering analyses.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 3.8.1 Fire Alarm X
3.8.2 Detection 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 (Note 3)
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)
Note 3 - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis.
The process in this FAQ is not applicable.
Deleted: X Deleted: X
FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 6 of 8 FAQ 06-0008 rev 4a engineering analyses.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)(2)(vii) 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 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 7 of 8 FAQ 06-0008 rev 4a engineering analyses.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 process is not considered an alternative method.
Existing risk-informed, performance-based methods will be applied, but for a limited scope of NFPA 805 Chapter 3 sections:
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.
(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.
Formatted: Bullets and Numbering Deleted: 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.
FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 8 of 8 FAQ 06-0008 rev 4a engineering analyses.doc If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
[See attached proposed revision to NEI 04-02]
FAQ 06-0008 rev. 4a - 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. 4a - 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. 4a - 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. 4a - 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. 4a - 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. 4a - 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. 4a - 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. 4a - 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. 4a - 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 3.8.1 Fire Alarm X
3.8.2 Detection 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 (Note 3)
X 3.11.2 Fire Barriers X
3.11.3 Fire Barrier Penetrations X
3.11.4 Through Penetration Fire Stops (Note 2)
X
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 10 Section Title FP Eng. Analysis Process Applicable Chapter 4 Conditional Section FP Eng.
Analysis Process and Chapter 4 Not Applicable 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.
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)
Note 3 - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis.
The process in this FAQ is not applicable.
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:
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 11 10 CFR 50.48(c)(2)(vii) 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.
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 4a - 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 process is not considered an alternative method.
Existing risk-informed, performance-based methods will be applied, but for a limited scope of NFPA 805 Chapter 3 sections:
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.
(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: table bullets Formatted: Bullets and Numbering
- 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 (462E685C.471 : 12 : 9706)
Subject:
Meeting summary for March FAQ meeting (contains ADAMS numbers for handouts)
Creation Date 4/24/2007 4:28:12 PM From:
Charles Moulton Created By:
CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 4/24/2007 4:28:47 PM btj (internet:btj@nei.org) nrc.gov TWGWPO01.HQGWDO01 Delivered 4/24/2007 4:28:12 PM PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 Delivered 4/24/2007 4:28:19 PM SDW1 CC (Sunil Weerakkody)
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Post Office Delivered Route nei.org TWGWPO01.HQGWDO01 4/24/2007 4:28:12 PM nrc.gov TWGWPO04.HQGWDO01 4/24/2007 4:28:19 PM nrc.gov tri-en.com Files Size Date & Time MESSAGE 810 4/24/2007 4:28:12 PM march meeting summary.pdf 76509 4/24/2007 4:27:22 PM Options Auto Delete:
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April 17, 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
SUBJECT:
SUMMARY
OF MARCH 22, 2007, CATEGORY 2 MEETING ON FREQUENTLY ASKED QUESTION PROCESS REGARDING NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 On March 22, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting 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 two FAQs at this meeting and provided a written response to previous NRC staff comments regarding one FAQ. 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 April 17, 2007, via teleconferencing, and that the May meeting should occur on May 17, at Nuclear Energy Institute (NEI) headquarters. The April meeting was subsequently rescheduled to April 26, to accommodate participants schedules.
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 ML070800007 and ML070850610. The response to previous comments is available at ML070850658. The accession numbers for the NRC staff responses are ML070660071, ML070640544, ML070640555, and ML070640562. The NEI 805 Task Force FAQ Log, a meeting handout, is available at ML070800236.
A list of meeting attendees is enclosed with this memorandum.
Enclosure:
As stated CONTACT: Charles Moulton, NRR/DRA 301-415-2751
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
SUBJECT:
SUMMARY
OF MARCH 22, 2007, CATEGORY 2 MEETING ON FREQUENTLY ASKED QUESTION PROCESS REGARDING NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 On March 22, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting 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 two FAQs at this meeting and provided a written response to previous NRC staff comments regarding one FAQ. 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 April 17, 2007, via teleconferencing, and that the May meeting should occur on May 17, at Nuclear Energy Institute (NEI) headquarters. The April meeting was subsequently rescheduled to April 26, to accommodate participants schedules.
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 ML070800007 and ML070850610. The response to previous comments is available at ML070850658. The accession numbers for the NRC staff responses are ML070660071, ML070640544, ML070640555, and ML070640562. The NEI 805 Task Force FAQ Log, a meeting handout, is available at ML070800236.
A list of meeting attendees is enclosed with this memorandum.
Enclosure:
As stated CONTACT: Charles Moulton, NRR/DRA 301-415-2751 DISTRIBUTION: DRA R/F TDinh DFrumkin PLain SWeerakkody CMoulton AKlein RGallucci PBarbadoro ADAMS Accession #: ML071090164 NRC-001 OFFICE NRR/DRA NRR/DRA NAME CMoulton SWeerakoddy DATE 4/ 17 /07 4/ 17 /07 OFFICIAL RECORD COPY
ENCLOSURE NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FREQUENTLY ASKED QUESTION PROCESS LIST OF ATTENDEES March 22, 2007 U.S. Nuclear Regulatory Commission Staff A. Klein C. Moulton D. Frumkin G. MacDonald*
J. Hyslop P. Fillion*
P. Lain R. Gallucci T. Dinh OTHER A. Afzali (PG&E)
A. Holder (Progress)
A. Ratchford (Kleinsorg Group)
B. Jamar (NEI)
C. Worrell (Westinghouse)
D. Miskiewicz (Progress)
E. Kleinsorg (Kleinsorg Group)
F. dePeralta-Meister (Tri-en Corp)
G. Cooper (Constellation)
J. Ertman (Progress)
J. Lattner (Southern Nuclear)
J. Masterlark (NMC)
J. Riley (NEI)
K. Heffner (Progress)*
K. Zee (ERIN)
M. Yungbluth (AmerenUE)
N. Hall (Constellation)
P. Ouellette (EPM)
R. Bertucio (Scientech)
S. Nowlen (SNL)*
T. Jutras (EPM)
T. Shudak (NPPD)
V. Rubano (FPL)
- participated via phone
- Brandon, Attached are NRC handouts for the telecon on Thursday.
Included are comments on FAQs and a sample from the RIS, as well as lists of the ADAMS numbers for FAQ s and FAQ related documents.
There may be additional comments on FAQ 12 ready in time for the call.
Please distribute to the 805 Task Force.
- Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11
Mail Envelope Properties (462E686A.9CD : 12 : 9706)
Subject:
Handouts for the NFPA 805 FAQ telecon.
Creation Date 4/24/2007 4:28:26 PM From:
Charles Moulton Created By:
CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 4/24/2007 4:28:47 PM btj (internet:btj@nei.org) nrc.gov TWGWPO01.HQGWDO01 Delivered 4/24/2007 4:28:26 PM PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 Delivered 4/24/2007 4:28:34 PM SDW1 CC (Sunil Weerakkody)
Opened 4/26/2007 12:48:36 PM Post Office Delivered Route nei.org TWGWPO01.HQGWDO01 4/24/2007 4:28:26 PM nrc.gov TWGWPO04.HQGWDO01 4/24/2007 4:28:34 PM nrc.gov Files Size Date & Time MESSAGE 1204 4/24/2007 4:28:26 PM FAQ ADAMS Numbers.doc 55808 4/24/2007 4:05:02 PM FAQ Meeting Documents ADAMS Numbers.doc 39424 4/24/2007 4:06:46 PM RIS sample.doc 25088 4/24/2007 8:12:12 AM FAQ 06-0008, R3 NRC comments.doc 25088 4/23/2007 10:54:22 AM FAQ 06-0008, R4 NRC comments.doc 23552 4/24/2007 9:23:16 AM FAQ 06-0012, R2 NRC comments.doc 27136 4/24/2007 3:53:44 PM FAQ 06-0024 NRC comments.doc 24576 4/23/2007 11:17:36 AM
FAQ 06-0026 NRC comments.doc 25088 4/23/2007 11:15:44 AM Options Auto Delete:
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Rev.
ADAMS #
06-0001 0
ML061440419 06-0002 0
ML063350515 06-0003 0
ML063170355 06-0004 0
ML061440430 06-0005 0
ML063180544 06-0006 0
ML063540308 06-0007 0
ML070510442 06-0008 0
ML071020160 Att.
ML071080099 06-0011 0
ML070510505 06-0012 0
ML070850610 06-0016 0
ML071020174 06-0017 0
ML070030383 06-0018 0
ML070030427 ML071020181 06-0019 0
ML070030437 06-0020 0
ML070030443 06-0021 0
ML070030457 06-0022 0
ML070030459 06-0023 0
ML070030470 06-0024 0
ML070030472 06-0025 0
ML070030476 06-0026 0
ML070030480 06-0028 0
FAQ Meeting Notices and Summaries Month Doc.
ADAMS #
July MN ML061870560 MS ML062080126 August MN ML062200116 MS ML062400278 September MN ML062510281 MS ML062900031 October MN ML062850488 MS ML063350031 November MN ML063120170 MS ML063410377 December MN ML063390132 MS ML070220420 January MN ML070040380 MS ML070360630 February MN ML070290267 MS ML070640531 March MN ML070640417 MS ML071090164 April MN ML070920255
NRC RIS Sample [CEM] {4/26/2007}
Issue 2: Issue Summary A plant transitioning to the 10 CFR 50.48(c) fire protection licensing basis noted that 10 CFR 50.48(c) appears to require prior NRC approval of all fire protection plant and program changes governed by NFPA 805, Chapter 3. The licensee noted that this appears to be more restrictive than the plants current deterministic requirements which permit fire protection plant and program changes without prior NRC approval when those changes are acceptable based on the standard license condition provided in Generic Letter 86-10, Implementation of Fire Protection Requirements. The licensee requested staff clarifications with respect to (a) deviations from Chapter 3 deterministic requirements which are relied upon meet requirements in Chapter 4, and (b) licensees ability to create processes address lower tier guidance such NFPA and UL in relation to the Chapter 3 deterministic requirements.
Resolution of Issues With respect to Item (a) above, NRC staff concluded that changes to some features of Chapter 3 of NFPA 805 do not need NRC prior approval, There are various sections of Chapter 3 of NFPA 805 that are only required to meet the performance or deterministic requirements of Chapter 4 of NFPA 805. Specifically NFPA 805 Sections 3.8.2, 3.9 through 3.11, excluding section 3.11.1. R.G. 1.205 includes a proposed license condition for making changes to NFPA 805, Chapter 4 requirements. The resolution of this issue is that since the Chapter 3 features are only required due to these features being needed for Chapter 4, these features may be modified without prior NRC approval when the change process, which applies to Chapter 4, is applied to the Chapter 3 changes.
With respect to Item (b) above, the NRC staff concluded that it is acceptable to, following the approval of a license amendment on the subject, allow the licensees to make changes to the requirements of Chapter 3 of NFPA 805 that involve independent listing laboratory certifications and associated NFPA standards. There are various sections of Chapter 3 of NFPA 805 that include references to independent laboratory listings (such as Underwriters Laboratories, Inc.) and to associated NFPA standards. Licensees may submit a license amendment proposing a process by which they may make changes to the listings and NFPA standards described in Chapter 3 of NFPA 805 without prior NRC approval. The process must include the bounds of the application of the process, specifically that it only applies to listings and other NFPA standards, and also an approach meeting 10 CFR 50.48(c).2.vii, (A), (B) and (C). Changes to other portions of Chapter 3 of NFPA 805 would continue to require individual 50.90 amendments addressing the specific deviation.
FAQ 06-0008, Revision X, submitted to the NRC on X/XX/2007, (ADAMS accession number ML07XXXXXXX) is consistent with these resolutions and the current NRC staff positions, which were adopted in RG 1.205.
NRC Response to FAQ 06-0008, Revision 3 [DXF] {4/2/2007}
Dans comments on Rev 3:
Break down section 3.8 (similar to the way they itemized 3.11), since my reading of the chapter 4 exclusion to section 3.8 only applies to 3.8.2. I believe that the other sections of 3.8 fall under the NFPA code exclusion.
3.11.1 is not subject to the Chapter 4 exclusion.
In the table on page 6, it states at the top of the first column 50.48(c) requirement, this should be 50.48(c).2.vii requirement.
In the 1.205 table (on page 7), the statement, "once the process is added..." may be problematic. I don't see this as a show stopper, but the NRC staff needs to look into the implications of this not being complete. There is a cart before the horse issue here; which comes first: the RIS or the updated 04-02/RG 1.205? My thought is that we need to have the process attached to the FAQ so we can say that it is okay in the RIS. Process wise, you may not be able to have open ended statements in this type of document.
o Suggestion: I think the answer to this question on 1.205 is that an alternative method will not be used. c.2.vii does not require an alternative method. So the open ended statement could be replaced with a statement like, "an alternative method is not proposed, the existing performance-based methods will be applied, but will be applied in a very limited fashion to (nfpa codes and listings)." Do you think that this will fly?
The added tables were looked at pretty closely during an older revision, so assuming nothing has changed there, they should be okay.
NRC Response to FAQ 06-0008, Revision 4 [CEM, DXF] {4/26/2007}
NEI Proposed Wording (Page 15, 1st paragraph)
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].
Staff Response It is improper to say that anything is approved by a closure memo. A planned Regulatory Issue Summary will document the agency-wide endorsement.
Replace the above NEI proposal with the following.
Staff Proposed Wording PLACEHOLDER FOR A DESCRIPTION OF NRC POSITION ON THIS FAQ.
NRC Response to FAQ 06-0012, Revision 2 [SDW & PMQ] {4/26/2007}
NEI Proposed Wording (page 8 of 13, near bottom)
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 Staff Response The examples noted in the figures would meet III.G.2 requirements. However, the verbal description leaves open the possibility of examples which would not meet III.G.2 requirements.Section III.G.2 states:
where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided By the NEI verbiage, components directly in a success path would be allowed to maloperate, so long as the credited function is not disabled. This does not meet the prevent operation or cause maloperation requirement of III.G.2 as, for example, a spurious closure of a flowpath valve would prevent operation yet meet the verbiage. The two examples were examples of flow diversions, with the credited flowpath unaffected.
For example, in figure B-8, if one of the MOVs in the credited flowpath maloperated and closed, and could be manually reopened, it could, by analysis, meet the 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 criterion. It would not meet III.G.2 as it would prevent operation or cause maloperation of the required flowpath (timing is not considered).
Staff Proposed Wording (Red - deletions, Blue - additions)
Operator manual actions to address spurious actuations in the that affect the credited safe shutdown success path are allowed, as long as the spurious actuation does not disable the is not directly in the protected train of the credited function (e.g., the main flowpath, as opposed to a diversionary flowpath) 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 Additional Staff Comment Delete paragraphs that paraphrase RIS 2006-10 from the proposed edits to NEI 04-02 sections.
NRC Response to FAQ 06-0024 [DHO] {4/26/2007}
Clarification of Required Space Around Electrical Equipment and Definition of Energized Electrical Equipment, NFPA 805 Section 3.3.11 Summary of issue Clarification of NFPA-805, Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), Chapter 3, Section 3.3.11 Electrical Equipment, "Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment."
Specifically, clarify what is "adequate clearance", and "energized electrical equipment" to be used during reviews associated with Chapter 3 transition.
Proposed Resolution of FAQ and basis for the proposal:
This FAQ asks to clarify the definition of, "Adequate clearance", and "energized electrical equipment", where used in Chapter 3. There is no existing fire protection regulatory guidance to readily lend these definitions. Therefore, adequate clearance would be defined as 3'-0" based on similar guidance found in (OSHA) 29CFR1910.303, Subpart S, Electrical. In the case where a plant has existing administration controls for combustible materials "adequate" would be as defined therein (the procedure having been review, approved and based on some degree of previous evaluation, analysis or defined engineering judgment).
Likewise, "Energized Electrical Equipment", would be defined for the purposes of Chapter 3 transition, to be that equipment identified in Bin 15 of the Fire PRA (ref.:
NUREG 6850, Fire PRA Methodology for Nuclear Power Facilities).
NEI proposed wording Where used in Chapter 3, the term "Adequate Clearance" is defined as, 3'-0" based on similar guidance found in (OSHA) 29CFR1910.303, Subpart S, Electrical.
Where used in Chapter 3, the term "Energized Electrical Equipment", is defined as, equipment identified in Bin 15 of the Fire PRA (ref.: NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities).
Staff Response The licensee proposal is defining the term Adequate Clearance based on OSHA guidelines.
These guidelines apply to workers health and safety; they do not apply to fire hazards at nuclear power plants. During the 1/18/2007 meeting, the licensee agreed that OSHA guidelines were not relevant and also agreed to resubmit this FAQ.
The licensee proposal is defining the term "Energized Electrical Equipment" as equipment identified in Bin 15 of the Fire PRA. What is the basis for using only Bin 15 to define the term "Energized Electrical Equipment"?
NRC Response to FAQ 06-0026 [DHO] {4/26/2007}
Clarification of "conform with the applicable NFPA standards" in regard to fire fighting equipment, NFPA 805 Section 3.4.4 Summary of issue Clarification of NFPA-805, Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), Chapter 3, Section 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."
Specifically, clarify that the intent of "conform with the applicable NFPA standards", is for specification and procurement aspects of the equipment Proposed Resolution of FAQ and basis for the proposal This FAQ asks to clarify that the intent of "conform with the applicable NFPA standards",
as they relate to fire brigade equipment. Applicable NFPA standards are addressed in FAQ #06-0020. Because the NFPA standards related to fire brigade equipment have evolved greatly beyond the CLB for plants, and in light of the fact that nuclear power plant fire fighting equipment is exposed to limited actual field use, it is not reasonable to require some of the maintenance activities and periodicities that are applied to equipment used by municipal fire departments and therefore contained in some NFPA standards. Rather, the industry recognizes and agrees that equipment should be purchased to NFPA standards, in force at the time of purchase. Along with this reasonable care and maintenance of equipment should be determined and implemented based on the actual level of field usage (ref. guidance found in IN-200012, Potential Degradation of Firefighter Primary Protective Garments).
NEI proposed wording Where used in section 3.4.4, the term, "conform with the applicable NFPA standards", is be limited to the specification and procurement of firefighting equipment, and those NFPA standards in effect at the time of purchase for that equipment, care and maintenance will be determined by the licensee based on equipment condition and performance.
Staff Response The staff does not agree with the proposal that: conform with the applicable NFPA standards be limited to specification and procurement, and that care and maintenance be determined by the licensee based on equipment condition and performance.
Deviations from these NFPA standards should use the Fire Protection Engineering Analysis process/method outlined in the resolution of FAQ 06-0008.
Consequently, the staff suggests that FAQ # 06-0026 be withdrawn.
Chuck, I've attached an updated FAQ Log per your request.
Task Force
Participants:
4/26/07 FAQ Telecon B. Jamar, NEI R. Dible, Areva T. Shudak, NPPD A. Ratchford, Kleinsorg Group E. Kleinsorg, Kleinsorg Group G. Cooper, Constellation C. Worrell, Westinghouse V. Rubano, FPL M. Yungbluth, AmerenUE J. Fortman, AmerenUE T. Jutras, EPM J. Vance, Southern J. Ertman, Progress J. Lattner, Southern K. Heffner, Progress D. Miskiewicz, Progress J. Masterlark, NMC D. Goforth, Duke
A. Afzali, PGE Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006
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Updated FAQ Log and NFPA 805 Task Force list of participants
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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 June 2007 in conjunction w/ B.3 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 April 07 H
Harris Nuclear Plant Ertman Frumkin TF waiting for NRC comments Plan to comment 8/24/2006 11/30/2006 Approval Status Revision FAQ #
Summary Submitter Actions and Notes Name Priority Page1 of 6
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 was commented on by TF. NRC accepted TF clarification.
M Duke Barrett Dinh 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. NRC R2 comments by May 07 M
Harris Nuclear Plant Holder Lain Waiting for NRC comments on R2 Comments provided on R1 2/15/2007 06-0008 4a 4a 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 R4a comments received and will incorporate NRC recommendations. R5 by early May.
H1 NEI Ratchford Frumkin R5 planned -
submit by early May Comments provided on R4a 2/15/2007 3/20/2007 3/30/2007 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 3Q 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. Possible closure by May H2 NEI Jutras Frumkin TF waiting for NRC comments on R1b Comments provided on R0 2/15/2007 06-0012 2b 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. NRC comments on R2b warrant R3. Will have by May 07 H3 NEI Kleinsorg Barbadaro R3 planned Comments provided on R2b 9/28/2006 10/26/2006 3/22/07 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 Second Quarter 2007 L
NEI 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 Miskiewicz FPRA TF has action Page2 of 6
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 Afzali FPRA TF has action 06-0016 1
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 Submitted R1 to NRC R1 accepted.
Closed 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 will split the FAQ into two items and resubmit in early May 12/19/2006 06-0018 1
1 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 Submitted R1 to NRC R1 accepted.
Closed 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. TF will submit new revision by May 2007 H
HNP Holder Dinh TF revising FAQ 19 R0c -
submit by May 07 Comments provided on R0 12/19/2006 Page3 of 6
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 -
submit by May 07 Comments provided on R0 12/19/2006 06-0021 0
1a 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, R1 planned -
submit by May 07 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 Plan to comment 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 reviewing withdraw -
decide by May 07 Proposed withdraw 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 reviewing NRC comments on R0 Comments provided on R0 12/19/2006 06-0025 0
1b 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 clearly what the minimum acceptable pre-plan scope is. Consider use of existing guidance.
Presented to Task Force 11/30/06 R1b updated 4/19 H
HNP Holder Barbadaro R1 planned -
submit by May 07 Comments provided on R0 12/19/2006 RESUBMIT March 2007 Page4 of 6
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 reviewing withdraw -
decide by May 07 Proposed withdraw 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
1a 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 R1 planned -
submit by May 07 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 M
HNP Thompson 07-0030 Risk of recovery actions M
07-0031 0
Misc Binning Issues Miscellaneous ignition frequency binning issues. Questions arise during ignition frequency counting, such as:
MOV motors, Hydraulic actuators for valves, Transformers Draft to NEI TF for April 2007.
M HNP Miskiewicz TF reviewing Page5 of 6
07-0032 10CFR 50.48(a) and GDC 3 clarification Clarify that satisfying 10 cfr 50.48(c) will satisfy 10 CFR50.48(a) and GDC3 Draft to NEI TF for May 2007.
M HNP Holder 07-0033 Review of Existing Engineering Equivalency Evaluations Discuss how EEEE will be reviewed and summarized for Draft to NEI TF for May 2007.
M HNP Holder 07-0034 0
Determination of non-vented Cabinets Clarification of guidance for deterining if an electrical cabinet can be dispositioned as non-vented Draft to NEI TF for May 2007.
M HNP Miskiewicz TF reviewing Page6 of 6