ML072400025
| ML072400025 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| 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superceded / withdrawn with Task Force Closed: NRC considers the FAQ closed.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 Reviewer Plant Licensee Contact NRC NEI TF NRC Submittal Date ML #
Tentative Memo 06-0001 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Superceded by FAQ 06-0012.
Closed Harris Nuclear Plant Ertman Submitted to NRC Closed Rev 0 - 4/25/2006 ML061440419 WITHDRAWN 12/14/06 ML063480169 WITHDRAWN 12/14/06 ML063480169 06-0002 1c NEI 04-02 Section 5.3.3 and App.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 Rev 0 - 04/25/2006 Rev 1 - 10/26/2006 Rev 2 - 01/04/2007 ML061440420 ML063170357 ML063350515 CLOSED 01/04/07 ML070030276 APPROVED 01/04/07 ML070030276 06-0003 1b Change Analysis Screening Change 'greater than minimal' to
'potentially greater than minimal' Closed Harris Nuclear Plant Ertman Radlinski Submited to NRC Closed Rev 0 - 04/25/2006 Rev 1 - 10/26/2006 ML061440422 ML063170355 CLOSED 01/04/07 ML070030242 APPROVED 01/04/07 ML070030242 06-0004 0
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
HNP Began Miskiewicz Frumkin TF to resubmit in conjunction w/ B.3 tables Comments provided on R0 Rev 0 - 05/12/2006 ML061440430 06-0005 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 June 07 NRC tentatively scheduling comments for July meeting H
HNP Ertman Barrett TF waiting for NRC comments Plan to comment Rev 0 - 08/24/2006 Rev 1 - 11/30/2006 ML062350095 ML063180544 06-0006 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 Closed Duke Barrett Dinh Draft closure letter issued Rev 0 - 08/22/2006 Rev 1 - 10/26/2006 Rev 2 - 12/19/2006 ML062350109 ML063170360 ML063540308 CLOSED 03/12/07 ML070030117 APPROVED 03/12/07 ML070030117 06-0007 3
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 Closed HNP Holder Moulton R3 submitted to NRC Comments provided on R2 Rev 0 - 08/22/2006 Rev 1 - 12/19/2006 Rev 2 - 02/15/2007 Rev 3 - 05/21/2007 ML062350121 ML070030325 ML070510442 ML071550408 CLOSED 6/21/07 ML071940375 Approval Status FAQ #
Summary Submitter Actions and Notes Name Priority Revision 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 Reviewer Plant Licensee Contact NRC NEI TF NRC Submittal Date ML #
Tentative Memo Approval Status FAQ #
Summary Submitter Actions and Notes Name Priority Revision 06-0008 5
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.
NRC stated at last meeting they would be submitting additional comments. Awaiting NRC comments.
Last round of staff comments - attempting to resolve by July H
NEI Ratchford Barrett R6 planned Comments provided on R5 Rev 0 - 09/20/2006 Rev 1 - 02/15/2007 Rev 2 - 03/20/2007 Rev 3 - 03/30/2007 Rev 3, Att -
03/30/2007 Rev 4 - 04/09/2007 Rev 5a - 05/08/2007 ML062860250 ML070510499 ML070800007 ML071020160 ML071020169 ML071080099 ML071340180 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 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
HNP Ertman 06-0011 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.
Awaiting NRC closure.
Attempting to provide comments by August H
NEI Jutras Barrett TF waiting for NRC comments on R1b Comments provided on R0 Rev 0 - 09/28/2006 Rev 1b - 02/15/2007 ML062890271 ML070510505 06-0012 4
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 Additional internal comments to be included in new FAQ Awaiting NRC final comments/closure Closed NEI Kleinsorg Qualls R4 submitted to NRC Comments provided on R2b Rev 0 - 08/17/2006 Rev 1 - 10/26/2006 Rev 2 - 03/22/2007 Rev 3 - 05/17/2007 Rev 4 - 03/22/2007 ML062860255 ML063170362 ML070850610 ML071380229 ML071570260 CLOSED 6/21/07 ML071940375 06-0013 Clarify Chapter 4 Methodology Transition Process Bases on Pilot Plant Results Will be presented at 2007 HNP Pilot meeting.
Duke to submit end of Second Quarter 2007 Superceded by FAQ 07-0039 L
HNP Ertman 06-0014 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 FAQ by 4Q 2007 L
HNP Miskiewicz FPRA TF has action 06-0015 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 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 H
NEI Masterlark FPRA TF has action 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 Reviewer Plant Licensee Contact NRC NEI TF NRC Submittal Date ML #
Tentative Memo Approval Status FAQ #
Summary Submitter Actions and Notes Name Priority Revision 06-0016 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.
Reviewed at 05/17/07 NEI Meeting - Scheduled for closure at public meeting.
Closed HNP Miskiewicz Iqbal Submitted R1 to NRC R1 accepted.
Closed Rev 0 - 12/19/2006 Rev 1 - 03/22/2007 ML070030348 ML071020174 CLOSED 5/17/07 ML071510425 06-0017 2
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.
Reviewed at 06/21/07 NEI Meeting - NRC stated that this FAQ is considered CLOSED.
Closed HNP Miskiewicz Gallucci Submitted R2 to NRC Comments provided on R1 Rev 0 - 12/19/2006 Rev 1 - 05/15/2007 Rev 2 - 06/01/2007 ML070030383 ML071350432 ML071570255 CLOSED 6/21/07 ML071940375 06-0018 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.
Closed HNP Miskiewicz Gallucci Submitted R1 to NRC R1 accepted.
Closed Rev 0 - 11/06/2006 Rev 1 - 03/22/2007 ML070030427 ML071020181 CLOSED 5/17/07 ML071510425 06-0019 1
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 NRC concerned about broadness of definition (e.g., Turbine building may not be included in this definition)
H HNP Holder Dinh R1 submitted to NRC Comments provided on R0 Rev 0 - 11/30/2006 Rev 1 - 05/08/2007 ML070030437 ML071340184 06-0020 1
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 CLOSED 5/17/07 Closed HNP Holder Dinh R1 submitted to NRC Comments provided on R0 Rev 0 - 11/30/2006 Rev 1 - 05/08/2007 ML070030443 ML071340188 CLOSED 5/17/07 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 Reviewer Plant Licensee Contact NRC NEI TF NRC Submittal Date ML #
Tentative Memo Approval Status FAQ #
Summary Submitter Actions and Notes Name Priority Revision 06-0021 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 CLOSED 5/17/07 Closed HNP Holder Dinh R1 submitted to NRC Comments provided on R0 Rev 0 - 12/19/2006 Rev 1 - 05/08/2007 ML070030457 ML071340192 CLOSED 5/17/07 ML071510425 06-0022 1
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.
Received NRC Review (7/19/07). Initiator reviewing - submittal to Task force by 7/27/07 M
ANO Puckett Moulton TF waiting for NRC comments Rev 0 - 12/19/2006 Rev 1 - 08/21/2007 ML070030459 06-0023 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 WITHDRAWN 5/17/07 L
HNP Holder Iqbal WITHDRAWN 5/17/07 Proposed withdraw Rev 0 - 12/19/2006 ML070030470 Withdrawn 5/17/07 ML071510425 06-0024 1
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.
Initiator resubmitted to Task Force planned submittal to NRC first week of July Discussed with Task Force (7/19/07), initiator to resubmit by 8/10/07 M
HNP Holder Oudinot TF waiting for NRC comments Rev 0 - 12/19/2006 Rev 1 - 08/21/2007 ML070030472 06-0025 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 Closed July 19, 2007 Closed HNP Holder Barbadoro R1 submitted to NRC Comments provided on R0 Rev 0 - 12/19/2006 Rev 1b - 05/08/2007 ML070030476 ML071340194 CLOSED 7/19/07 ML072080246 06-0026 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.
WITHDRAWN 5/17/07 M
HNP Holder Oudinot WITHDRAWN 5/17/07 Proposed withdraw Rev 0 - 12/19/2006 ML070030480 Withdrawn 5/17/07 ML071510425 Page4 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 Reviewer Plant Licensee Contact NRC NEI TF NRC Submittal Date ML #
Tentative Memo Approval Status FAQ #
Summary Submitter Actions and Notes Name Priority Revision 06-0027 0
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 Rev 0 sent to NRC on 5/17/07 Awaiting NRC Review and comments M
ANO Puckett Barrett Submitted R0 to NRC Rev 0 - 05/17/2007 ML071380236 06-0028 2
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 Submitted to NRC 5/21/07 Closed HNP Holder Oudinot R2 submitted to NRC Comments provided on R1 Rev 0 - 12/19/2006 Rev 1 - 05/08/2007 Rev 2 - 05/21/2007 ML070030489 ML071340195 ML071550415 CLOSED 6/21/07 ML071940375 06-0029 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 WITHDRAWN 6/21/07 L
HNP Thompson Withdrawn 6/21/07 ML071940375 07-0030 Risk of recovery actions 4.2.4 Clarification of risk impact of recovery actions, to include extension of existing HRA scenarios FAQ by 3Q 2007 M
HNP Masterlark 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.
Awaiting NRC review and comments - been sent to Research Submitted to NRC on 7/19/07 M
HNP Miskiewicz Gallucci Submitted R0 to NRC 7/19/2007 Rev 0 - 05/17/2007 ML071380238 07-0032 0
10CFR 50.48(a) and GDC 3 clarification Clarify that satisfying 10 CFR 50.48(c) will satisfy 10 CFR50.48(a) and GDC3 Submitted to NRC 7/12/07 M
HNP Holder Barrett Submitted R0 to NRC Rev 0 - 05/17/2007 ML071930378 07-0033 0
Review of Existing Engineering Equivalency Evaluations Discuss how EEEE will be reviewed and summarized for transition Submitted to NRC 7/12/07 M
HNP Holder Frumkin Submitted R0 to NRC Rev 0 - 07/12/2007 ML071930379 07-0034 Determination of non-vented Cabinets Clarification of guidance for determining if an electrical cabinet can be dispositioned as non-vented Draft to NEI TF for May 2007 FAQ submitted by June Afzali to PRA Task Force by 8/3. Due to NFPA 805 TF by 8/13. To NRC by 8/23.
M HNP Miskiewicz TF reviewing 07-0035 0
Bus Duct counting guidance for High Energy Arcing Faults Split from FAQ 06-0017 - Bus duct July 13 meeting between industy (PRA Task Force) and NRC Task Force Internal to Task Force - definitiions of Sealed cabinet versus non-vented cabinet Task 11 versus Task 6 NRC to discuss in panel meeting on 8/17/07 M
HNP Miskiewicz Dinh Submitted R0 to NRC Rev 0 - 06/01/2007 ML071650151 07-0036 0
Define compliance categories for Table B-1 NEI 04-02 update to include lessons learned on Table B-1 process FAQ sent to task force for review (7/16/07)
Present to NRC 7/19/07 H
HNP Holder Submitted R0 to NRC 8/6/2007 07-0037 Environmental considerations for equipment Provide guiudance regarding environmental considerations of other equipment in the fire affected area Draft FAQ for August 2007 TF Meeting Task Force withdraws FAQ since issue is already addressed in NUREG/CR 6850 Section H.2 (page H-10)
M HNP Holder 07-0038 Lessons learned for OMA, MSO and FPRA Incorporate pilot lessons learned for preemptive manual actions, MSO expert panel and Fire PRA processes into NEI 04-02 Draft FAQ for August 2007 TF Meeting H
HNP Began 07-0039 Provide update of NEI 04-02 B-2 and B-3 Processes NEI 04-02 update to include lessons learned on Table B-2 and B-3 processes Draft FAQ for August 2007 TF Meeting H
HNP Ratchford 07-0040 Clarification on Non-Power Operations Provide clarification on non-power operations transition (e.g., high risk evolution scope, scope of damage to KSFs).
Discussed at August 2007 NFPA 805 Pilot Meeting (Bethesda, MD). This FAQ also should address Change Evaluation Scope for non-power in a post-transition environment (Parking lot item 22).
H Duke Goforth Page5 of 5