ML072400025

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NFPA 806 Transition Pilot Plant FAQ Log - July 2007, Revision 2
ML072400025
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 08/23/2007
From:
Nuclear Energy Institute
To:
Office of Nuclear Reactor Regulation
References
Download: ML072400025 (5)


Text

superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed. Approval will be documented in a closure memo.

approved With NRC Approved Closure memo posted on ADAMS Submitter Reviewer Status Approval FAQ # Revision Name Summary Actions and Notes Priority Licensee Plant NRC NEI TF NRC Submittal Date ML # Tentative Memo Contact 06-0001 0 Alternate method for Add in clarification that fire affected train NRC rejected the statements regarding SER Engineering Evaluations manual actions are 'allowed' and approval without Exemptions Harris WITHDRAWN WITHDRAWN therefore do not require evaluation. Submitted to Closed Nuclear Ertman Closed Rev 0 - 4/25/2006 ML061440419 12/14/06 12/14/06 Tentatively approved. NRC Plant ML063480169 ML063480169 Superceded by FAQ 06-0012.

06-0002 1c NEI 04-02 Section 5.3.3 and Change Figure 5-1, text, and Appendix I NRC agreed in principle, however wanted App. I, Order of Questions to ask the Chapter 4 questions before wording clarified to "make clear the distinction for Change Analysis Chapter 3 questions. between Chapter 3 requirements that are Screening 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 Harris Rev 0 - 04/25/2006 ML061440420 CLOSED APPROVED Submited to Form Closed Nuclear Ertman Gallucci Closed Rev 1 - 10/26/2006 ML063170357 01/04/07 01/04/07 NRC Plant Rev 2 - 01/04/2007 ML063350515 ML070030276 ML070030276 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 06-0003 1b Change Analysis Screening Change 'greater than minimal' to Harris CLOSED APPROVED Submited to Rev 0 - 04/25/2006 ML061440422

'potentially greater than minimal' Closed Nuclear Ertman Radlinski Closed 01/04/07 01/04/07 NRC Rev 1 - 10/26/2006 ML063170355 Plant ML070030242 ML070030242 06-0004 0 Clarify NFPA 805 Chapter 4 How fire protection systems and features Note NRC was using NEI 04-02 Revision 2H and 3 relationship for transition is highly dependent on how figures and not figures in FAQ 06-0004

'required' FP they are 'required' to meet the nuclear TF to systems/features safety criteria of Chapter 4. NRC to re-review in appropriate context & Comments Began resubmit in provide status on 10/26/06 M HNP Frumkin provided on Rev 0 - 05/12/2006 ML061440430 Miskiewicz conjunction R0 w/ B.3 tables Received NRC comments 11/29/06. Resubmitted to NRC and returned with comments. Currently under TF review 06-0005 1 Guidance on FPP-related NEI 04-02 does not provide guidance FAQ has been revised.

changes what should be considered a FPP-related change or not. Since failure to obtain Resubmit to NRC 11/30/06 - waiting for NRC NRC pre-approval for using risk response as of June 07 TF waiting reductions from a non-FPP related Plan to Rev 0 - 08/24/2006 ML062350095 H HNP Ertman Barrett for NRC change would be contrary to the NRC tentatively scheduling comments for July comment Rev 1 - 11/30/2006 ML063180544 comments guidance in RG 1.205, additional meeting guidance should be provided to clarify what is considered a FPP-related change once NFPA-805 is implemented 06-0006 2 High-low pressure interface Definition of High-Low Pressure interface Received NRC comments on R1, R2 definition and NEI 00- is not consistent between NFPA 805 and 01/NFPA 805 discrepancies NEI 00-01. Need to provide clarification. Resubmit 12/19/06 - Definition change per NRC Rev 0 - 08/22/2006 request. Draft ML062350109 CLOSED APPROVED Rev 1 - 10/26/2006 Closed Duke Barrett Dinh closure ML063170360 03/12/07 03/12/07 Rev 2 - 12/19/2006 Closure process has begun. Draft closure letter letter issued ML063540308 ML070030117 ML070030117 was commented on by TF.

NRC accepted TF clarification 06-0007 3 NFPA 805 Chapter 3 Need clarification on when NFPA 600 or FAQ to be revised to mark up NEI 04-02 to Rev 0 - 08/22/2006 ML062350121 Requirements for Fire NFPA 1500 apply. Also clarify if show the addition of an appendix for NFPA 805 Comments CLOSED R3 submitted Rev 1 - 12/19/2006 ML070030325 Brigades requiements apply to interior structural clarifications. Closed HNP Holder Moulton provided on 6/21/07 to NRC Rev 2 - 02/15/2007 ML070510442 fire fighting brigade. R2 ML071940375 Rev 3 - 05/21/2007 ML071550408 NRC R2 comments by May 07 Page1 of 5

superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed. Approval will be documented in a closure memo.

approved With NRC Approved Closure memo posted on ADAMS Submitter Reviewer Status Approval FAQ # Revision Name Summary Actions and Notes Priority Licensee Plant NRC NEI TF NRC Submittal Date ML # Tentative Memo Contact 06-0008 5 Alternate method for Many Generic Letter 86-10 evaluations Presented 9/28/06 Engineering Evaluations exist at facilities today. Transition of these existing evaluations is essential for Comments received from NRC on 11/29/06.

the success of the Pilot Plants. In Clarification call scheduled. Resubmit to NRC by Rev 0 - 09/20/2006 addition the use of engineering 02/07 ML062860250 Rev 1 - 02/15/2007 evaluations for Chapter 3 issues post R4a comments received and will incorporate ML070510499 Rev 2 - 03/20/2007 transition needs to be clarified. NRC recommendations. Comments ML070800007 Rev 3 - 03/30/2007 R5 by early May. H NEI Ratchford Barrett R6 planned provided on ML071020160 Rev 3, Att -

R5 ML071020169 03/30/2007 NRC stated at last meeting they would be ML071080099 Rev 4 - 04/09/2007 submitting additional comments. Awaiting NRC ML071340180 Rev 5a - 05/08/2007 comments.

Last round of staff comments - attempting to resolve by July 06-0009 NEI 04-02 Typo Corrections Editorial changes to NEI 04-02 Will submit with overall revision at end of year.

L NEI Kleinsorg 06-0010 Incorporate Regulatory Based on changes to Regulatory Guide Projected submittal 3Q 2007 Guide 1.205 Baseline 1.205, NEI 04-02 needs to reflect the L HNP Ertman concept into NEI 04-02 baseline risk 06-0011 1b Clarify III.G.3 Compliance Alternative Shutdown is not specifically Approved by Task Force Reviewers. Submitted Transition addressed in NFPA 805. to NRC 9/28/06. Under NRC review.

Comments received from NRC on 11/29/06.

Need time for TF review. Rewrite TF waiting Comments w/consideration for NRC comment #2 - for NRC Rev 0 - 09/28/2006 ML062890271 H NEI Jutras Barrett provided on Resubmit Feb. '07. comments on Rev 1b - 02/15/2007 ML070510505 R0 R1b Awaiting NRC closure.

Attempting to provide comments by August 06-0012 4 Clarify Manual Action Some manual actions are either allowed Submitted to NRC 9/28/06. Resubmit 10/26/06 Transition in Appendix B by the current regulation or have been as combined with FAQ 06-0001 Comments received from NRC on 11/30/06. Rev 0 - 08/17/2006 ML062860255 With TF for review. Revision by May '07. NRC Comments Rev 1 - 10/26/2006 ML063170362 CLOSED comments on R2b warrant R3. Will have by May R4 submitted Closed NEI Kleinsorg Qualls provided on Rev 2 - 03/22/2007 ML070850610 6/21/07 07 to NRC R2b Rev 3 - 05/17/2007 ML071380229 ML071940375 Rev 4 - 03/22/2007 ML071570260 Additional internal comments to be included in new FAQ Awaiting NRC final comments/closure 06-0013 Clarify Chapter 4 Will be presented at 2007 HNP Pilot meeting.

Methodology Transition Process Bases on Pilot Plant Duke to submit end of Second Quarter 2007 L HNP Ertman Results Superceded by FAQ 07-0039 06-0014 Cumulative Risk Regulatory Guide 1.205 requires tracking With FPRA TF for comment - 12/14/06 of changes to assess cumulative risk. FPRA TF has L HNP Miskiewicz NEI 04-02 does not provide guidance on FAQ by 4Q 2007 action this issue 06-0015 Guidance on not-red Process for determining if non- Sent to Task Force for review 11/30/06 determination compliances found during the transition process are 'not red' needs to be With FPRA TF for review 12/14/06 simplified.

Ken Heffner to provide regulatory input to this FAQ by 12/14/06 Amir Afzali to provide PRA screening criteria for FPRA TF has

'not red' determination by 12/14/06 H NEI Masterlark action Amir Afzali to discuss with PRA Task Force to increase focus Jim Masterlark to provide revision to Task Force.

Task Force to decide on withdrawing this FAQ Page2 of 5

superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed. Approval will be documented in a closure memo.

approved With NRC Approved Closure memo posted on ADAMS Submitter Reviewer Status Approval FAQ # Revision Name Summary Actions and Notes Priority Licensee Plant NRC NEI TF NRC Submittal Date ML # Tentative Memo Contact 06-0016 1 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for Electrical Source counting guidance for Electrical Cabinets Cabinets in NUREG/CR-6850, supporting Submitted to Task Force 11/30/06.

NFPA-805 Fire PRA application.

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 R1 CLOSED Submitted R1 Rev 0 - 12/19/2006 ML070030348 provided in the FAQ were discussed by Ray Closed HNP Miskiewicz Iqbal accepted. 5/17/07 to NRC Rev 1 - 03/22/2007 ML071020174 Gallucci of the NRC. Closed ML071510425 Kiang Zee provided feedback that the examples were intended to be taken collectively and were intended to be drawn to scale.

Reviewed at 05/17/07 NEI Meeting - Scheduled for closure at public meeting.

06-0017 2 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for High Energy Source counting guidance for High Arcing Faults (HEAF) Energy Arcing Faults (HEAF) in Submitted to Task Force 11/30/06.

NUREG/CR-6850, supporting NFPA-805 Fire PRA application. Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC. Comments Rev 0 - 12/19/2006 ML070030383 CLOSED Submitted R2 Closed HNP Miskiewicz Gallucci provided on Rev 1 - 05/15/2007 ML071350432 6/21/07 Preliminary comments indicated a to NRC R1 Rev 2 - 06/01/2007 ML071570255 ML071940375 recommending splitting of HEAFs into a low voltage and high voltage bins. In addition, a new frequency is being considered for bus ducts.

Reviewed at 06/21/07 NEI Meeting - NRC stated that this FAQ is considered CLOSED.

06-0018 1 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for Main Control Source counting guidance for Main Board (MCB) Control Board (MCB) in NUREG/CR-6850, Submitted to Task Force 11/30/06.

supporting NFPA-805 Fire PRA application Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 R1 CLOSED Submitted R1 Rev 0 - 11/06/2006 ML070030427 Closed HNP Miskiewicz Gallucci accepted. 5/17/07 to NRC Rev 1 - 03/22/2007 ML071020181 Preliminary verbal comments provided by NRC. Closed ML071510425 Preliminary comments indicated more focus on counting just horseshoe cabinets as MCBs.

06-0019 1 Define power block and Define where used in Chapter 3, power Presented to Task Force 11/30/06 plant block and plant are intended to mean areas in which a fire could jeopardize Comments from Task Force to initiator by the ability to meet the performance 12/14/06 Submitted to NRC 12/19/06 criteria described in section 1.5.

Comments to be provided by NRC prior to Feb.

3.3.1.2 Control of Combustible Materials 2007 meeting.

(1)Wood used within the power block Comments R1 submitted Rev 0 - 11/30/2006 ML070030437 shall be listed pressure-impregnated or TF will submit new revision by May 2007 H HNP Holder Dinh provided on to NRC Rev 1 - 05/08/2007 ML071340184 coated with a listed fire-retardant R0 application. NRC concerned about broadness of definition Exception: Cribbing timbers 6 in. by 6 in. (e.g., Turbine building may not be included in (15.2 cm by 15.2 cm) or larger shall not this definition) be required to be fire-retardant treated.

06-0020 1 Definition of applicable (6) Controls on use and storage of Presented to Task Force 11/30/06 Comments CLOSED flammable gases shall be in accordance R1 submitted Rev 0 - 11/30/2006 ML070030443 Closed HNP Holder Dinh provided on 5/17/07 with applicable NFPA standards. CLOSED 5/17/07 to NRC Rev 1 - 05/08/2007 ML071340188 R0 ML071510425 Page3 of 5

superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed. Approval will be documented in a closure memo.

approved With NRC Approved Closure memo posted on ADAMS Submitter Reviewer Status Approval FAQ # Revision Name Summary Actions and Notes Priority Licensee Plant NRC NEI TF NRC Submittal Date ML # Tentative Memo Contact 06-0021 1a Clarify that air drops are 3.3.5.2 - Only metal tray and metal Presented to Task Force 11/30/06 acceptable. conduits shall be used for electrical raceways. Thin wall metallic tubing shall CLOSED 5/17/07 not be used for power, instrumentation, or control cables. Flexible metallic Comments CLOSED R1 submitted Rev 0 - 12/19/2006 ML070030457 conduits shall only be used in short Closed HNP Holder Dinh provided on 5/17/07 to NRC Rev 1 - 05/08/2007 ML071340192 lengths to connect components. R0 ML071510425 HNP as well as other plants have exposed cable drops ~ 3 in length.

06-0022 1 Identify a list of typical flame 3.3.5.3 - Electric cable construction shall Presented to Task Force 11/30/06 propagation tests which are comply with a flame propagation test as considered acceptable. acceptable to the AHJ. Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC. TF waiting Rev 0 - 12/19/2006 M ANO Puckett Moulton for NRC ML070030459 Additional info on applicability of test requested Rev 1 - 08/21/2007 comments by NRC.

Received NRC Review (7/19/07). Initiator reviewing - submittal to Task force by 7/27/07 06-0023 0 Grant exception for Diesel 3.3.8 Bulk Storage of Flammable and Presented to Task Force 11/30/06 Generator Day Tanks located Combustible Liquids - Bulk storage of within Diesel Generator flammable and combustible liquids shall Submitted to NRC 12/19/06 Buildings. not be permitted inside structures Withdrawn WITHDRAWN Proposed containing systems, equipment, or NRC questioned if issue warranted a FAQ since L HNP Holder Iqbal Rev 0 - 12/19/2006 ML070030470 5/17/07 5/17/07 withdraw components important to nuclear safety. it is part of plant systems ML071510425 As a minimum, storage and use shall comply with NFPA 30, Flammable and WITHDRAWN 5/17/07 Combustible Liquids Code 06-0024 1 Define what adequate 3.3.11 Electrical Equipment - Adequate Presented to Task Force 11/30/06 clearance is. clearance, free of combustible material, shall be maintained around energized Submitted to NRC 12/19/06 electrical equipment.

Preliminary verbal comments provided by NRC. TF waiting Need to provide a clearer definition of Rev 0 - 12/19/2006 M HNP Holder Oudinot for NRC ML070030472

'adequate clearance'. Could be based on Initiator resubmitted to Task Force planned Rev 1 - 08/21/2007 comments OSHA 3ft requirement. submittal to NRC first week of July Discussed with Task Force (7/19/07), initiator to resubmit by 8/10/07 06-0025 1b Define minimum acceptable 3.4 Industrial Fire Brigade - 3.4.2.1 - The Presented to Task Force 11/30/06 R1b updated pre-plan scope. plans shall detail the fire area 4/19 configuration and fire hazards to be encountered in the fire area, along with Closed July 19, 2007 any nuclear safety components and fire Comments CLOSED R1 submitted Rev 0 - 12/19/2006 ML070030476 protection systems and features that are Closed HNP Holder Barbadoro provided on 7/19/07 to NRC Rev 1b - 05/08/2007 ML071340194 present. R0 ML072080246 Suggest define more clearly what the minimum acceptable pre-plan scope is.

Consider use of existing guidance 06-0026 0 Clarify NFPA code 3.4.4 Fire-Fighting Equipment - Protective Presented to Task Force 11/30/06 requirements for gear clothing, respiratory protective maintenance equipment, radiation monitoring Comments from Task Force to initiator by equipment, personal dosimeters, and fire 12/14/06 Submitted to NRC 12/19/06 suppression equipment such as hoses, nozzles, fire extinguishers, and other Preliminary verbal comments provided by NRC.

needed equipment shall be provided for Withdrawn the industrial fire brigade. This equipment WITHDRAWN 5/17/07 WITHDRAWN Proposed M HNP Holder Oudinot Rev 0 - 12/19/2006 ML070030480 5/17/07 shall conform with the applicable NFPA 5/17/07 withdraw ML071510425 standards.

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

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superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed. Approval will be documented in a closure memo.

approved With NRC Approved Closure memo posted on ADAMS Submitter Reviewer Status Approval FAQ # Revision Name Summary Actions and Notes Priority Licensee Plant NRC NEI TF NRC Submittal Date ML # Tentative Memo Contact 06-0027 0 Clarify the where provided 3.7 Fire Extinguishers - Where provided, To TF by Feb 07 statement. fire extinguishers of the appropriate number, size, and type shall be provided Not discussed on 1/18/07 in accordance with NFPA 10, Standard for Portable Fire Extinguishers. Extinguishers Rev 0 sent to NRC on 5/17/07 shall be permitted to be positioned outside of fire areas due to radiological Awaiting NRC Review and comments Submitted R0 M ANO Puckett Barrett Rev 0 - 05/17/2007 ML071380236 conditions. to NRC Part of NFPA 10 is placement / travel distances for extinguishers. The 'where provided' statement needs clarification.

06-0028 2 Clarify intent of 3.3.1.1 General Fire Prevention Activities - Presented to Task Force 11/30/06 familiarization with plant (1) Training on fire safety information for fire prevention procedures, all employees and contractors including, Comments from Task Force to initiator by fire reporting, and plant as a minimum, familiarization with plant 12/14/06 Submitted to NRC 12/19/06 Comments Rev 0 - 12/19/2006 ML070030489 CLOSED R2 submitted emergency alarms fire prevention procedures, fire reporting, Closed HNP Holder Oudinot provided on Rev 1 - 05/08/2007 ML071340195 6/21/07 to NRC regarding scope of or depth and plant emergency alarms Not discussed on 1/18/07 R1 Rev 2 - 05/21/2007 ML071550415 ML071940375 of the training.

Clarify the intent of 'familiarization'. Submitted to NRC 5/21/07 06-0029 Clarify zone of influence for FDT spreadsheets are used to provide a Submitted to the task force: 12/19/06 NUREG 6850 Task 8. zone of influence.

Discuss at January 24, 2007 FPRA meeting Withdrawn L HNP Thompson 6/21/07 Not discussed on 1/18/07 ML071940375 WITHDRAWN 6/21/07 07-0030 Risk of recovery actions 4.2.4 Clarification of risk impact of FAQ by 3Q 2007 recovery actions, to include extension of M HNP Masterlark existing HRA scenarios 07-0031 0 Misc Binning Issues Miscellaneous ignition frequency binning Draft to NEI TF for April 2007.

issues. Questions arise during ignition frequency counting, such as: MOV Awaiting NRC review and comments - been sent Submitted R0 M HNP Miskiewicz Gallucci 7/19/2007 Rev 0 - 05/17/2007 ML071380238 motors, Hydraulic actuators for valves, to Research to NRC Transformers Submitted to NRC on 7/19/07 07-0032 0 10CFR 50.48(a) and GDC 3 Clarify that satisfying 10 CFR 50.48(c) will Submitted to NRC 7/12/07 Submitted R0 M HNP Holder Barrett Rev 0 - 05/17/2007 ML071930378 clarification satisfy 10 CFR50.48(a) and GDC3 to NRC 07-0033 0 Review of Existing Discuss how EEEE will be reviewed and Submitted to NRC 7/12/07 Submitted R0 Engineering Equivalency summarized for transition M HNP Holder Frumkin Rev 0 - 07/12/2007 ML071930379 to NRC Evaluations 07-0034 Determination of non-vented Clarification of guidance for determining Draft to NEI TF for May 2007 Cabinets if an electrical cabinet can be dispositioned as non-vented FAQ submitted by June M HNP Miskiewicz TF reviewing Afzali to PRA Task Force by 8/3. Due to NFPA 805 TF by 8/13. To NRC by 8/23.

07-0035 0 Bus Duct counting guidance Split from FAQ 06-0017 - Bus duct July 13 meeting between industy (PRA Task for High Energy Arcing Faults Force) and NRC Task Force Internal to Task Force - definitiions of Sealed Submitted R0 M HNP Miskiewicz Dinh Rev 0 - 06/01/2007 ML071650151 cabinet versus non-vented cabinet Task 11 to NRC versus Task 6 NRC to discuss in panel meeting on 8/17/07 07-0036 0 Define compliance categories NEI 04-02 update to include lessons FAQ sent to task force for review (7/16/07)

Submitted R0 for Table B-1 learned on Table B-1 process H HNP Holder 8/6/2007 to NRC Present to NRC 7/19/07 07-0037 Environmental considerations Provide guiudance regarding Draft FAQ for August 2007 TF Meeting for equipment environmental considerations of other equipment in the fire affected area Task Force withdraws FAQ since issue is already M HNP Holder addressed in NUREG/CR 6850 Section H.2 (page H-10) 07-0038 Lessons learned for OMA, Incorporate pilot lessons learned for Draft FAQ for August 2007 TF Meeting MSO and FPRA preemptive manual actions, MSO expert H HNP Began panel and Fire PRA processes into NEI 04-02 07-0039 Provide update of NEI 04-02 NEI 04-02 update to include lessons Draft FAQ for August 2007 TF Meeting B-2 and B-3 Processes learned on Table B-2 and B-3 processes H HNP Ratchford 07-0040 Clarification on Non-Power Provide clarification on non-power Discussed at August 2007 NFPA 805 Pilot Operations operations transition (e.g., high risk Meeting (Bethesda, MD). This FAQ also should evolution scope, scope of damage to address Change Evaluation Scope for non-power H Duke Goforth KSFs). in a post-transition environment (Parking lot item 22).

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