ML072610455

NFPA 805 Observation Visit Trip Report

ML072610455
Person / Time
Site:	Oconee
Issue date:	09/24/2007
From:	NRC/NRR/ADES
To:
Oudinot, D.H., NRR/DRA, 415-4064
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ML072610460	List: ML072610455
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Download: ML072610455 (52)

Text

Enclosure NFPA 805 OBSERVATION VISIT TRIP REPORT Date: July 10 - 13, 2007 Location: Oconee Nuclear Station, Seneca, South Carolina Attendees: Representatives from the following organizations attended the meetings:

Duke Power NRC Headquarters Progress Energy NRC Region II ERIN Engineering and Pacific Northwest National Laboratory Research Inc (PNNL)

NEXUS Kleinsorg Group

Subject:

Risk-Informed, Performance-Based Fire Protection Transition Pilot-Plant Observation Visit - Oconee Nuclear Station Agenda: See Attachment 1 Summary:

A Nuclear Regulatory Commission (NRC) transition pilot plant observation visit for implementation of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(c) was held with representatives from Duke Power and Progress Energy in Seneca, South Carolina, at the Oconee Nuclear Station. Other industry representatives were also present to observe the public and non-public proceedings. The meetings on July 10, 11, and 12, 2007, were closed to the public. These meetings covered Safeguards and/or Sensitive Homeland Security Information. The public meetings were held the morning of July 13. Duke Power presented the status of their transition projects and specific topics related to 10 CFR 50.48(c) implementation. provides the topics and agenda. Attachment 2 provides a list of issues raised by the observation visit participants and is called the Parking Lot. This list documents and tracks transition issues from visit to visit. The NFPA 805 Frequently Asked Question (FAQ) process is often used to close the Parking Lot issues. Attachment 3 refers to the presentations given during the meetings that are security-related and not released to the public under 10 CFR 2.390. Attachment 4 refers to the presentations given during the meetings that are not security-related. Attachment 5 provides the Issue Summary Sheets. These summaries provide clarification and detail of lessons learned from the NFPA 805 Transition Pilot Program. provides a summary of the issues and their resolution status.

General Discussion:

The general objective of the observation visits is to facilitate communications between NRC staff (the staff) and the pilot plant licensees in order to: (1) gain experience with plant specific application of risk-informed, performance-based methods, including validation of the approach and methods of Nuclear Energy Institute (NEI) 04-02, and Regulatory Guide (RG) 1.205; (2) identify regulatory and licensing issues that may impact implementation; and (3) identify improvements and lessons learned to be considered in future inspection procedures and inspector training.

This trip supported the NRC observation visit for on-going pilot plant activities by Progress Energy and Duke Power (Duke) involving the transition from their current fire protection programs to risk-informed, performance-based fire protection programs that meet 10 CFR 50.48(c) and NFPA 805, as endorsed therein.

Specific Visit Topics:

This section of the trip report summarizes the specific topics identified in the agenda and includes information that resulted in identification of new Parking Lot issues, lessons learned, or other information that have the potential to influence regulatory or industry processes or guidance for implementation of NFPA 805. Attachment 5 identifies, by number, the Issue Summary Sheets associated with the agenda topics.

Agenda Topic 1, Plant Walkdown:

Oconee Nuclear Station (ONS) plant tour conducted with participants from NRC, industry, and contractors.

Agenda Topic 2, Introductions, Meeting Kickoff (Handout Reference 1 and 2):

ONS reported that a project budget increase from $2.5 million to $8 million is necessary to complete the work. They expect similar budgets for work on other fleet units. Duke is currently using four contractors (Kleinsorg Group, ERIN Engineering, NEXUS Engineering, and AREVA) as well as dedicated company staff to complete the work. This team will work on all the Duke NFPA 805 projects. The work schedule shows Fire PRA work completion at the end of the first quarter 2008 with a transition at the end of second quarter 2008.

Agenda Topic 3, Technical Update (Handout References 3):

Current activities at ONS include Fire PRA modeling, Appendix R Reconstitution, NEI 04-02 Tables B-1, 2, and 3 population and updating, and non-power operations. Careful configuration control is required to keep the LAR current and correct and will run in parallel with the current license and NFPA 805. A dedicated licensing person is now part of the team and is working the requirements as well as providing input on the licensing viewpoint.

Agenda Topic 4, NFPA 805 Chapter 3 Transition (Handout Reference 4):

This agenda topic covered ONS efforts to populate NEI 04-02 Table B-1, Transition of Fundamental Fire Protection Program and Design Elements. ONS reports that the electronic searches for fire protection documents were not as productive as hoped because their system has no global search, and the fire protection design basis document (DBD) was written in 1996 as a historical document and is not kept as a living document. The effort generates a substantial amount of supporting information that is not conducive to inclusion in a table format. ONS and its contractors stipulated the best way to capture and present the information required for Table B-1 is to capture the supporting information in a database and to populate Table B-1 with high-level summaries, which reference a report section that provides the additional detail. This modification included removal of the column that mapped to original licensee commitments.

ONS will submit an FAQ to remove the BTP column from Table B-1. An additional FAQ is required to define the minimum level of detail required in Table B-1. Issue Summary Sheet 42 documents this issue.

In addition to the above possible improvements to Table B-1, ONS also noted that FAQ 07-0036 provides six standardized definitions for Method of Compliance annotated in Table B-1.

ONS noted lessons learned from its Table B-1 efforts include keeping relevant documents in one place, providing searchable indices to documents, integrating them with the existing document and configuration management system, and developing a good program document that comprehensively references and summarizes the Fire Protection Program.

Issue Summary Sheet No. 45 documents these lessons learned.

Agenda Topic 5, NFPA 805 Chapter 3 Transition Fire Protection Feature and Ignition Source Database (Handout Reference 5):

NEXUS led the discussion on the ONS fire protection feature and ignition source database.

Discussions included consistency issues between fire area/zone definitions in a pre-NFPA 805 and post-NFPA 805 program at ONS, due to the large and open fire areas at ONS. Specifically, compartment has a different meaning in NUREG/CR-6850 (preferred for NFPA 805 Fire PRA, as physically enclosed rooms) from the Individual Plant Examination for External Events (IPEEE) (not necessarily physically enclosed rooms). ONSs fire areas tend to be compartments in the 6850 sense, while zones more closely match the IPEEE definition.

Issue Summary Sheet No. 20 already tracks the issue of fire zone and compartment definitions.

The key point of the discussion was to ensure that the data for analysis (cable locations, barriers, etc.) is sufficient to meet all program needs.

Agenda Topic 6, Oconee NFPA 805 NEI 04-02 B-2 Tables (Handout Reference 6):

Kleinsorg Group led the discussion on the review of ONS Table B-2 , Nuclear Safety Methodology Transition. Discussions included issues with the ability to claim prior approval for items related to methodology (the example used was inter-cable hot shorts). This was a similar discussion to that held during the March 2007 meeting and Issue Summary Sheet 40 documents this issue.

Attendees asked NRC staff whether the general process and level of detail for the B-2 Table were acceptable. The NRC staff expressed general agreement on the process and level of detail. Industry agreed to submit an FAQ (FAQ 07-0039) that incorporates the lessons learned for Table B-2, which will be used to document staff concurrence.

Agenda Topic 7, Oconee NFPA 805 NEI 04-02 B-3 Tables (Handout References 7 and 8):

Kleinsorg Group led the discussion on the review of ONS Table B-3 , Fire Area-by-Fire Area Transition.

Attendees asked NRC staff whether the general process and level of detail for the B-3 Table were acceptable. The NRC staff expressed general agreement on the process and level of detail. Industry agreed to submit an FAQ (FAQ 07-0039) that incorporates the lessons learned for Table B-3 which will be used to document staff concurrence. Issue Summary Sheet 42 documents this issue.

Agenda Topic 8, Progress Energy Update (Handout Reference 9):

Progress Energy provided an update on Progress Energy activities. Current focus includes completing the B-3 Table, addressing non-power operations, processing changes during transition, and developing the draft LAR. The transition change evaluation process discussion prompted a commitment from HNP to provide sample information on the change evaluation process before the August 2007 project meeting. Issue Summary Sheet 42 documents this issue.

Discussions of the status of HNP efforts led to a dialog concerning incorporation of FAQs into the timetable for the next revision to NEI 04-02. Industry indicated they expect to have selected FAQs to the NRC by September 2007 with a resulting draft NEI 04-02 revision to the NRC by mid-January 2008.

Agenda Topic 9, Review of NRC Issue Summary Sheets (Enclosure 5):

Attendees reviewed the NRC Issues Summary from the March 2007 pilot meeting.

Future Issue Summaries in NRC trip reports (including this trip report) will incorporate the agreed changes (See Enclosure 5)

Agenda Topic 10, Non-power Operations (Handout Reference 10):

Kleinsorg Group led a presentation on non-power operational modes. NFPA 805 requires the evaluation of the effects of fire during any operational mode and plant configuration. The pilot plants, and, it is expected, most of industry, do not have Fire PRAs for non-power modes of operation. Appendix F of NEI 04-02 provides a detailed methodology that is centered on Key Safety Functions (KSFs). The pilot plants are managing fire risk qualitatively during High Risk Evolutions (HREs) using the NUMARC 91-06 definition for HREs. A project instruction was written for the pilot plants to ensure consistency between their approaches.

Questions were raised by the NRC on the scope of the review and definition of HREs. NRC attendees postulated specific failure scenarios and questioned whether they would be assessed using the proposed process. The NRC expected that comments from Progress Energy on non-power operational modes would be presented at the NFPA 805 task force meeting on July 19, 2007. Issue Summary Sheet 41 documents this issue.

Agenda Topic 11, Oconee Fire PRA Model (Handout Reference 11):

ERIN led a presentation on the ONS Fire PRA Model. Discussions concerning detailed issues with the Fire PRA models included quantification using a Unit 3 model and the development of a Unit 2 specific model, and the proposed screening process for HEPs inside the control room. These and other model specific comments will be documented and provided during the NRCs detailed review of the Fire PRA.

Attendees identified a potential issue introduced via the planned ANS Fire PRA Standard concerning the treatment of instrumentation and diagnostic equipment. Specifically, how will new instrumentation requirements in the ANS Fire PRA standard be addressed in a Fire PRA used for NFPA 805 transition? Issue Summary Sheet 46 documents this issue.

Agenda Topic 12, NFPA 805 Change Evaluations (Handout Reference 11):

Section 2.2.4 of NFPA 805 states, a plant change evaluation shall be performed to ensure that a change to a previously approved fire protection program element is acceptable.

The evaluation process shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins. Kleinsorg Group provided an overview of the change evaluation process, followed by ERIN providing ONS example applications of the change evaluation process.

Agenda Topic 13, Oconee Fire PRA - Next Steps (Handout Reference 11):

ERIN provided an overview of the next steps in the Oconee Fire PRA process. This includes refinements to the Unit 3 work as well as collection of information and subsequent development of models for Units 1 and 2.

Agenda Topic 14, FRANC Demonstration:

ERIN led a demonstration of the use of FRANC in Fire PRA modeling and analysis.

Agenda Topic 15, Parking Lot Review (Enclosure 2):

Kleinsorg Group led the discussion on the Parking Lot Issues. See Enclosure 2 Agenda Topic 16, Public Meeting (Handout Reference 12):

Paul Lain of the NRC and David Goforth of Duke provided introductions for the Category 2 Public Meeting. The outline followed the topics discussed at the Pilot Observation Meeting.

Parking Lot:

The Parking Lot (see Attachment 2) was initiated at the first observation visit in November 2005. It documents the issues and needs identified during observation visit presentations and related discussions. NRC and Industry use the Parking Lot to track issues, revise existing items as necessary, and open new items for issues identified during follow on observation visits.

The July 2007 observation visit identified two new items. Additional details on actions taken, a short summary of the visits discussions on the specific issues, and whether an FAQ is associated with an item are included in the Updated Parking Lot (Attachment 2).

Issue Summary Sheets The Issue Summary Sheets were initiated at the second observation visit in March 2006. The NRC staff determined that additional information, clarification, and detail (to that provided in the Parking Lot Issues table) were needed to convey pilot-plant identified issues and lessons learned to the non-pilot licensees and other interested parties. provides the Issue Summary Sheets combined with the related Parking Lot Issues.

Plans for Next Observation Meeting:

The NRC and industry representatives discussed future observation visits. The next observation visit will be in Washington DC during August 2007.

Attachments:

1. Topics and Agenda. NFPA 805 Transition Observation Visit at Duke Power Oconee Nuclear Station, Seneca, South Carolina. July 10 - 13, 2007.

2. Updated Parking Lot (Meeting Agenda Topic #XX). NFPA 805 Transition Observation Visit at Duke Power Oconee Nuclear Station, Seneca, South Carolina. July 10 - 13, 2007.

3. Security-Related Handouts. NFPA 805 Transition Observation Visit at Duke Power Oconee Nuclear Station, Seneca, South Carolina. July 10 - 13, 2007.

4. Non Security-Related Handouts. NFPA 805 Transition Observation Visit at Duke Power Oconee Nuclear Station, Seneca, South Carolina. July 10 - 13, 2007.

5. NFPA Pilot-Plant Implementation Issue Summary Sheets

6. Summary of Issue Identification and Resolution Table Handout

References:

1. Introductions/Overview, David Goforth and David Leslie, Duke Power, July 11, 2007 -

Meeting Agenda Topics 2 - Slide Presentation.

2. Three Site Timeline, David Goforth, Duke Power, July 11, 2007 - Meeting Agenda Topic 2 - Table.

3. Technical Update, David Goforth, Duke Power, July 11, 2007 - Meeting Agenda Topic 3

- Slide Presentation.

4. NFPA 805 Chapter 3 Transition, Rob Jackson, Harold Lefkowitz, James Oldman, Duke Power, July 11, 2007 - Meeting Agenda Topic 4 - Slide Presentation (Sensitive).

5. NFPA 805 Chapter 3 Transition Fire Protection Feature and Ignition Source Database, Robe Jackson, Harold Lefkowitz, James Oldham, Duke Power, July 11, 2007 - Meeting Agenda Topic 5 - Slide Presentation (Sensitive).

6. Oconee NFPA 805 NEI 04-02 B-2 Tables, Elizabeth Kleinsorg, Kleinsorg Group, July 11, 2007 - Meeting Agenda Topic 6 - Slide Presentation (Sensitive).

7. Oconee NFPA 805 NEI 04-02 B-3 Tables, Elizabeth Kleinsorg, Kleinsorg Group, July 11, 2007 - Meeting Agenda Topic 7 - Slide Presentation (Sensitive).

8. Oconee NFPA 805 NEI 04-02 B-3 Tables, Elizabeth Kleinsorg, Kleinsorg Group, July 11, 2007 - Meeting Agenda Topic 7 - Tables (Sensitive).

9. NFPA 805 NRC Pilot Observation Visit Progress Energy Update, Jeff Ertman, Progress Energy, July 11, 2007 - Meeting Agenda Topic 8 - Slide Presentation.

10. Oconee NFPA 805 Non-Power Operation Transition, Liz Kleinsorg, Kleinsorg Group, July 12, 2007 - Meeting Agenda Topic 10 - Slide Presentation (Sensitive).

11. Duke Power FPRA Pilot Meeting, Ed Simbles, ERIN Engineering, July 12, 2007 -

Meeting Agenda Topic 11 - Slide Presentation (Sensitive).

12. Public Meeting Presentations, July 13, 2007 - Meeting Agenda Topic 16 - Slide Presentation.

to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007 NFPA 805 Meeting for Oconee Pilot Plant NRC Observation Meeting Topics and Agenda, Duke Power, Oconee Nuclear Station, Seneca, SC - July 10 - July 13, 2007 Topic Lead Presenter Topic Notes Tuesday Plant Walkdowns N/A Topic 1 July 10 Wednesday 0800 - 0815 Introductions, Meeting Kickoff David Goforth Topic 2, References 1 and 2 July 11 0815 - 0830 Technical Update David Goforth Topic 3, Reference 3 0830 - 0930 NFPA 805 Chapter 3 Transition Rob Jackson Topic 4, Reference 4 0945 - 1045 NFPA 805 Chapter 3 Transition Fire Rob Jackson Topic 5, Reference 5 Protection Feature and Ignition Source Database 1200 - 1315 Oconee NFPA 805 NEI 04-02 B-2 Liz Kleinsorg Topic 6, Reference 6 Tables 1330 - 1500 Oconee NFPA 805 NEI 04-02 B-3 Liz Kleinsorg Topic 7, References 7 and 8 Tables 1515 - 1550 Progress Energy Update Jeff Ertman Topic 8, Reference 9 1600 - 1730 Review of NRC Issue Summary Sheets Tye Blackburn Topic 9, Enclosure 5 Thursday 0800 - 0830 Non-power operations Liz Kleinsorg Topic 10, Reference 10 July 12 0830 - 0940 Oconee Fire PRA Model Ed Simbles Topic 11, Reference 11 0955 - 1130 1230 - 1330 1345 - 1455 NFPA 805 Change Evaluations Andy Ratchford Topic 12, Reference 11 Ed Simbles 1455 - 1505 Oconee Fire PRA - Next Steps Ed Simbles Topic 13, Reference 11 1520 - 1550 FRANC Demonstration Ed Simbles Topic 14 1550 - 1615 Parking Lot Review Andy Ratchford Topic 15, Enclosure 2 1 -

NFPA 805 Meeting for Oconee Pilot Plant NRC Observation Meeting Topics and Agenda, Duke Power, Oconee Nuclear Station, Seneca, SC - July 10 - July 13, 2007 Topic Lead Presenter Topic Notes Friday Public Meeting Paul Lain Topic 16, Reference 12 July 13 Public Meeting 2 -

Attachment 2 to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007 NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 1 How will Reactor Oversight Process Duke / ROP (new) / Feb. 2008 NRC (Paul Lain) Concerns and questions were raised about the process Potential deal with multiple spurious Progress NEI 04-02 (Ertman) presented and the burden associated with URIs.

operations? Low significance vs. flowchart for high significance. Methodology for unevaluated Expert Panel Multiple Spurious Look at minor violation questions for MC 0612 - to see Philosophical approach for RI-PB Update operations on if potential multiple spurious operation findings are treatment of multiple spurious 03/27/06. It adequately addressed.

operations is in NEI 04-02. Markup to P. Lain included a Endorsement of process will be 3/28/06 flowchart screening 1E-08 threshold for screening. Is it an appropriate accomplished via Reg. Guide. process that value to use and consistent with the ROP? (NEI 04-02, Review of MC included CAP NUREG-6850. RG 1.205) 0612 and comp.

measure Pilot plants to provide comments on NRC flowchart inclusion, and and potential changes to NEI 04-02.

documentation of the issue as a Pilot Plants to provide Update by Feb. 2008 potential URI based upon risk significance.

2 Consider Fussell-Vesely risk [CLOSED] Refer to previous version of parking lot No importance criteria for spurious for details.

operations in the gray area.

3 Clarify approved/unapproved Closed to FAQ manual actions for change analysis. 06-0001 and 06-0012 October 2006 4 NRC feedback on high-low pressure Closed to FAQ interface methodology and other 06-0006 items. October 2006 5 Submittal/approval relative to Fire [CLOSED] Refer to previous version of parking lot No PRA peer review. Will the peer for details.

review be a prerequisite for license amendment submittal / approval.

6 Non-power operational modes PRA [CLOSED] Refer to previous version of parking lot No requirements will be a show for details.

stopper.

1 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 7 NEI 04-02 needs to be clearer on Closed to FAQ the relationship between NFPA 805 06-0004 Chapter 3 and 4 requirements.

October 2006 8 Recommend making nuclear safety Closed to FAQ questions first in screening reviews. 06-0002 October 2006 9 Clean up all change evaluation [CLOSED to Item 10] Refer to previous version of No examples and send to NRC. parking lot for details.

10 Modify NEI 04-02 to show the path Closed to FAQ through fire area boundary 06-0008 qualification. October 2006 11 Guidance for performing preliminary [CLOSED] Refer to previous version of parking lot No risk screening. for details.

12 Change Question 4.f to potentially Closed to FAQ greater than minimal vs. greater 06-0003 than minimal October 2006 13 How should the screening question [CLOSED] Refer to previous version of parking lot be reviewed by the PRA for details.

engineers?

14 Consider having others serve as [CLOSED to No. 10] Refer to previous version of role of AHJ with respect to prior parking lot for details.

approval of Ch. 3 anomalies.

15 Match up NEI 04-02 with RG 1.205 Closed to FAQ for baseline (Section 2.2 of Draft 06-0010 RG 1.205) October 2006 16 How are interim changes to [CLOSED] Refer to previous version of parking lot NEI 04-02 and issues going to be for details.

handled administratively?

17 Impact of circuit failure draft [CLOSED] Refer to previous version of parking lot proposed RIS (May 2005) and for details.

Generic Letter (October 2005)

Items started at PE Pilot (March 2006) 18 Format for NEI 04-02 Appendix B [CLOSED] Closed to FAQ NSPA methodology transition 06-0013 process. October 2006 2 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 19 Need to provide definitions and [CLOSED] Closed to FAQ examples of related and unrelated 06-0005 changes. October 2006 20 NRC provide any specific needs for NRC and Provide proposed 11/6/06 Item closed based on PE strawman schedule for 2007 None in progress Fire PRA Peer Review Progress schedule at Nov. presented at 11/7/06 meeting. New item 31 (related)

This is relative to NRC stated intent 2006 Pilot Mtg for created.

to credit the observation process in NRC review of instead of a Peer Review. PRA task [CLOSED]

documents (estimated Jan. -

Feb. 2007) 21 Reconciliation of different risk Duke / Table of data and 09/30/07 Discussed at Oct. 2006 Pilot Mtg. Guidance will be Yes acceptance thresholds (RG 1.205, Progress recommendations (Began) developed during or post-performance of change ROP acceptance, MSO for change. evaluations.

acceptance). Create FAQ 22 Update Appendix I of NEI 04-02 to NEI Create FAQ to 09/30/07 Yes include non-power operational provide specific (Began) mode change evaluation. guidance.

23 Discussion was held over wording [CLOSED] Closed to FAQ related to FPP systems and 06-0005 features for the purposes of an FPP October 2006 change.

24 NRC expressed concern over [CLOSED] Closed to FAQ dividing up individual changes that 06-0014 are small. October 2006 3 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To Items started at ONS Pilot (October 2006) 25 ONS Fire PRA are based on the fire Duke Provide TBD 11/7/06 Update Potential zones as defined in the FP clarification on Closed due to change in Duke approach. PE will Program, which are not necessarily methodology. create similar item if issues arise at the PE sites.

based on physical barriers or features that are subject to any [CLOSED]

rigorous treatment. The discussion with the NRC highlighted concerns with respect to the treatment of such compartment in the Fire PRA and the consistency of that treatment with the guidance provided in NUREG/CR-6850. Questions arose over impact of this approach on other tasks and level of documentation needed to justify this approach.

26 The NUREG/CR- 6850 Duke Provide 11/6/06 High priority FAQ 06-0018 methodology includes a specific clarification on (HNP Pilot [CLOSED]

frequency Bin for the treatment of methodology Mtg.) [CLOSED]

the main control board in the Main (FAQ?)

Control Room (Bin 4 of Table 6-1).

While the general description of this board by making Reference to the horseshoe, is generally correct, there are control room layout details that create some ambiguity, and the potential to characterize other electrical panels/cabinets as Bin 15.

The guidance in NUREG 6850 is not clear enough to result in consistent application.

4 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 27 NUREG/CR-6850 does not provide Duke and Provide 11/6/06 High priority FAQ 06-0016 explicit guidance for the counting of Progress clarification on (HNP Pilot [CLOSED]

plant electrical cabinets. Two basic methodology Mtg.) FAQ 06-0016 presented at the meeting.

approaches were debated. The (FAQ?)

Method 1 approach would count [CLOSED]

each individual electrical cabinet based on the physical boundaries of that cabinet independent of size or length. Method 2 would count electrical cabinets based solely on size.

28 The overall counting method Duke / Provide 11/6/06 High priority FAQ 06-0017 guidance for switchgears, load Progress clarification on (HNP Pilot centers, unit substations, and bus methodology Mtg.) 11/8/06 Update ducts is not completely clear. The (FAQ?)

concern is that counting these FAQ 06-0017 presented at the meeting.

component types for Bin 16 using the Bin 15 method could result in a [CLOSED] - Closed to FAQ 06-0017 fire frequency distribution for HEAFs for switchgears and load centers that is inconsistent with industry experience in that the HEAF on the load centers and load centers would be much more frequent as compared to switchgears. A proposed change to the counting method for this Bin is proposed so that the HEAF frequency for low voltage equipment would be weighted to a lesser degree.

29 Miscellaneous ignition frequency Duke / Provide 12/31/06 High priority FAQ 07-0031 binning issues. Questions arise Progress clarification on during ignition frequency counting, methodology [CLOSED] - Closed to FAQ 07-0031 such as: (FAQ?)

o MOV motors o Hydraulic actuators for valves o Transformers.

5 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 30 There is potential confusion over the Progress Provide 05/31/07 11/7/06 HNP Pilot Discussion FAQ 07-0032 role of 10 CFR 50.48(a) for a plant clarification on Discussion held on information available in that is transitioning to NFPA 805. the role of promulgation of 10 CFR 50.48(c) on 6/8/04 [ADAMS This may impact the scope of the 10 CFR 50.48(a) Accession No. ML041340086]. New FAQ to be issued transition and post-transition with a post- to update NEI 04-02.

program management. transition fire [CLOSED] - Closed to FAQ 07-0032 protection program.

Items started at PE Pilot (November 2006) 31 NRC to provide feedback to PE on NRC / Develop plan for Added 11/7/06 Closed based strawman 2007 schedule for Duke / peer review schedule provided interim review of deliverables (in Progress 3/22/07 - Progress Energy has developed a schedule particular, the PRA activities). Duke and considers item closed to provide NRC with PRA schedule information to plan peer review [CLOSED]

activities.

32 What to do about the new Duke / Provide proposed Added 11/8/06 Closed based on B1 requirement for seismic hose Progress resolution. review stations (NFPA 805 Section 3.6.4, [CLOSED]

considering info in 10 CFR 50.48(c))

33 What to do about the new Duke / Provide proposed Added 11/8/06 Closed based on B1 requirement for suppression for the Progress resolution. review diesel fire pump (NFPA 805 Section [CLOSED]

3.9.4).

34 What to do about the new Duke / Create FAQ to Added 11/8/06 Closed to FAQ requirement for qualified cable Progress provide specific 06-0022 (NFPA 805 Section 3.3.5.3, guidance. Closure to FAQ 06-0022.

considering info in 10 CFR 50.48(c)) [CLOSED]

35 Need additional discussion on FAQ Duke / Provide proposed Added 11/8/06 Closed to FAQ 06-0011 (ASD area transition). Progress resolution. 06-0011 Discussion was held at the 11/8/06 [CLOSED]

meeting on how an ASD fire area (in particular operator manual actions) transition over. Confusion was voiced over the characterization of ASD fire areas as deterministic, while recovery actions are defined in NFPA 805 as performance-based. This issue needs additional clarification.

6 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 36 Discussion was held on assessing Duke / Added 11/9/06 Closed to FAQ the risk of recovery actions Progress 07-0030 (operator manual actions) and the [CLOSED] February 2007 need/methods to perform/report this information as part of transition.

Reference Section 4.2.4 of NFPA 805. NRC expressed concerns over risk significant operator manual actions.

37 Determine whether the NRC plans NRC / Added 11/9/06 to endorse the ANS Fire PRA NEI standard in RG 1.200 or wait for an The NRC is going to use the ANS FPRA Standard for integrated standard. The impact on the Pilot Plants. The integration of the PRA standards non-pilots requiring peer review will not alter the technical requirements from the needs to be understood. individual ASME and ANS Standards.

[CLOSED]

38 Determine information sharing Duke / PE [CLOSED]

between task force members / NEI (details of project / products).

39 Question was raised on allowing the NEI [CLOSED]

NRC to have some specific access to the NEI NFPA 805 webboard.

40 With respect to getting NEI / [CLOSED]

acknowledgment from the NRC, NEI Duke /

stated that working level task Progress progress could be posted on the NEI Webboard. This could be used to get information out on specific tasks to the non-pilot plants.

Items started at PE Pilot (March 2007) 41 Technical paper on Fire Protection NEI/ Create FAQ to Added 03/08/07 Closed to FAQ Engineering Analysis (FPEA) Duke/ provide specific Related to FAQ 06-0008. FPEAs were part of 06-0008 & 07-0033 Progress guidance. industrys proposed FAQ 0008. It is proposed that NEI provide a technical paper that better describes and defines FPEAs Closure to FAQ 06-0008 & FAQ 07-0033.

[CLOSED]

7 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 42 Both industry and NRC have NEI/ Revision 2 will be issued that incorporates changes in FAQ 06-0008 proposed resolutions to Duke/ Revision 0 and 1 as well as the industry and NRC FAQ 06-0008. Progress proposed resolutions.

[CLOSED]

43 Revise NEI 04 02 to clarify existing NEI/ The plants indicated that the EEEE guidance in NEI 04 FAQ 07-0033 engineering equivalency evaluations Duke 02 still requires further clarification (in addition to that (EEEE) guidance Progress being provided as part of FAQ 06 0008) and plans to propose changes.

[CLOSED] - Closed to FAQ 07-0033 44 Consider establishing a NEI site for NEI NEI to determine Submittals Consideration is being given to setting up a location at U.S. Nuclear Regulatory logistics and due July NEI to allow NRC staff and contractors to review pilot-Commission (NRC) review of pilot capability. Need 28, 2007 plant material. This will enhance the review of required material for the August (Heffner) material while allowing the plants proprietary, security, 2007 Pilot and business sensitive information maintained under Observation appropriate controls. Staff recommended process Meeting used previously for Reg Guide 1.200.

45 Define boundary versus qualitative NEI/ Discussions where held concerning whether to count FAQ not needed.

counting Duke items in structures and compartments that screened The 805 pilots do not Progress out earlier as part of the process. It was stipulated at disagree with the this meeting that once the analysis boundaries are set NRC understanding then all components within a bin that is within the of NUREG/CR-6850 boundaries should be counted. This means that the on this issue as possibility exists that the sum of all compartments will discussed at the not be equal to the sum of all the given generic March 8 HNP pilot frequencies meeting.

[CLOSED]

46 Transformer threshold NEI/ NUREG/CR 6850 has several bins into which FAQ 07-0031 Duke transformers fit (e.g., Bin 16, Bin 23 and Bin 29). While Progress the criteria for counting transformers in Bin 16 and Bin 29 is adequately clear, the lower bound on Bin 23 transformers is not clear and needs further definition.

[CLOSED] - Closed to FAQ 07-0031 8 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 47 Resolve NUREG/CR 6850 versus NRC No action There are differences between the fire modeling done [CLOSED]

Fire Protection Significance necessary. as part of a FPSDP and that done as part of Determination Process (FPSDP) NUREG/CR 6850. This is likely to raise multiple differences for fire modeling questions by inspectors as work progresses and licenses are amended. NUREG/CR 6850 is the guiding requirement for the NFPA 805 efforts and as such is the appropriate modeling approach. Additional work in anticipation of this issue is needed to assist plants and inspectors in dealing with the differences.

[CLOSED]

48 Environmental considerations for NEI/ Create FAQ to August It was not clear to attendees if the current fire modeling Yes other equipment in fire affected Duke/ provide specific 2007 was properly accounting for environmental compartments. Progress guidance. (Holder) considerations for other equipment in a fire impacted compartment. The fire modeling accounts for sources and targets and zones of influence (ZOI), but it is not clear if other equipment outside of the ZOI, which could be impacted from fire secondary effects (e.g., smoke and temperature), is being addressed in the fire modeling being conducted as part of the NFPA 805 transition.

49 NUREG/CR 6850 Kerite FR is NRC NRC Provide July 2007 NUREG/CR 6850 Table H 3 and H 4 incorrectly lists NA 237°C not 372°C information to (Fletcher) the Kerite failure temperatures as being between public domain 372°C -382°C with a Recommended Failure Threshold July 2007) and of 372°C. The recommended Failure Threshold for eventually Kerite should be 237°C. The tables need to be provide errata reviewed and an errata/revision issued for the sheet. NUREG/CR.

50 Multiple spurious operation (MSO) NEI/ Distribution of There is not currently a single standard by which to [CLOSED]

expert elicitation industry guidance Duke Project hold an expert elicitation as part of bounding the MSO required Progress Instructions possibilities. Both of the pilot-plants have pursued detailing acquiring expert opinions on the subject as part of their application of the NFPA 805 efforts. An industry standard and/or expert panel for guidance on how to conduct such a meeting as well as MSO. how to handle and process knowledge gained is needed.

Closure based on PIs (FPIP-0122) forwarded to NRC

& NEI Non-Pilot Transitional Plants.

[CLOSED]

9 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 51 Harris has source/target database Progress Harris Nuclear Plant (HNP) has developed a database [CLOSED]

that they are willing to share. as part of its NUREG/CR 6850 Task 8 efforts that is used to record source and target information for later use in the fire modeling and Fire PRA. HNP has offered to share this tool with interested non-pilot transition plants.

[CLOSED]

52 Potential coordination issues Progress Progress Energy August The Harris Nuclear Plant (HNP) will be submitting a between License Renewal point of contact 2007 LRA that will be reviewed between 10/08 - 06/09. The Application (LRA) and NFPA 805 K. Heffner. (Heffner) current schedule for the NFPA 805 LAR is for submittal transitions (License Amendment Developing a in 06/08 with review through 12/08. An LRA locks Request [LAR]) detailed plan and down a license (i.e., an LAR would not be considered schedule. prior to approval of a submitted LRA. This scheduling conflict has not been resolved for HNP.

Items started at PE Pilot (May-June 2007) 53 Incorporate Lessons Learned for Progress Create FAQ to July 2007 Pilot observation presentations indicated the need to 07-0038 preemptive manual actions, MSO update NEI 04-02 (Ertman) define the expert panel review process for MSO and to expert panel, and Fire PRA include specific guidance in NEI 04-02.

processes into NEI 04-02

[CLOSED]

54 Define schedule for revision of NEI NEI NEI to coordinate January Observation meeting discussion indicated the need to NA 04-02, and identify which FAQs will schedule for 2008 project the next revision to NEI 04-02 to incorporate be included. submittals (Ertman) previously approved FAQs and upcoming RIS.

55 Update templates for Tables B-1, B- NEI Create FAQ to July 2007 Pilot plants have identified specific enhancements from Yes 2, B-3 in NEI 04-02 update NEI 04-02 (Holder) first use of the B-1,2,3 tables which should be incorporated in NEI 04-02 to ensure consistent submittal products.

56 Include Fire Area (1-A-BAL-C) as Progress Include sample 7-28-07 Discussion indicated need to provide a completed NA pilot sample for B-3 Table @ HNP. fire area for submittal product sample for an actual fire area incorporating August Pilot (Maness) reviews through Table B-3.

Observation Meeting 57 Submit revision of OMP-003, Progress Provide next Post Non- Based on previous discussions recommend submittal NA Outage Shutdown Risk revision when Power of OMP-003 for staff review and comment as part of Management to NRC staff for available Operation pilot process.

review and comment. Task (Began) 10 -

NFPA 805 Transition Observation Visit Oconee Nuclear Station - July 10 - July 13, 2007 - Updated Parking Lot No. Topic Assigned Action Schedule Action Taken Meeting Discussion FAQ Action To 58 Include Table B-3 binning Progress Create FAQ to To NEI Pilot observation presentations indicated the need to Closed to FAQ information in NEI 04-02. update NEI 04-02 T.F. include the Table B-3 Binning details in NEI 04-02. 06-0012 5-31-07 Staff recommended this be included in Rev 4 of FAQ 06-0012.

[CLOSED]

59 Provide update of NEI 04-02 to Progress/ Create FAQ to August To be Included in FAQ 07-0030. Yes include extension of existing HRA NEI update NEI 04-02 2007 scenarios. (Ertman)

Items started at Duke-ONS Pilot (July 2007) 60 Previous approval of Chapter Duke / Refine as part of 2methodology example (no cable NEI the Pilot process to cable hot shorts). Clarify whether nuclear safety methods can be brought forward and clarify what that means with respect to a change evaluation. Clarify what being brought forward into the new licensing basis means.

61 HRA in general Duke / Forward to PRA New requirements for instrumentation related to NEI task force. operator actions in the PRA are being introduced in the Questions arose of HEP screening ANS FPRA standard. These requirements exceed values in NUREG/CR-6850. those in NUREG/CR-6850. Questions were raised on the manner in which this new information will be How are the new instrumentation implemented in an NFPA 805 Fire PRA.

requirements in the new proposed revision to the ANS Fire PRA standard going to be addressed in a fire PRA used for NFPA 805 transition?

11 -

to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007 Security Handout References Located in ADAMS Accession No. ML072130443 1 -

to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007 Non-Security Handout References Located in ADAMS Accession No. ML072530476 1 -

to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007 Issue Summary Sheets 1 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 1 Topic: Multiple Spurious Operation - Treatment of newly identified multiple spurious operations in Reactor Oversight Process (ROP) prior to risk significance determination Associated Observation Meeting Parking Lot Item(s): 1

==

Description:==

NEI 04-02, Appendix B-2 describes the proposed industry approach to evaluating multiple spurious operations, which in turn, references NEI 00-01. The proposed approach is to analyze all single spurious operations and risk-significant multiple spurious operations. The approach includes a provision that newly identified multiple spurious operations will not be considered part of the licensing basis unless determined to be risk significant. The issue requiring further evaluation is how the reactor oversight process (ROP) will exclude newly discovered multiple spurious circuits from the license basis, until they are determined to be risk significant.

Status: OPEN. The November 2005 pilot-plant observation visit initially identified this issue. The NRC Staff reviewed the ROP relative to the treatment of newly identified multiple spurious operations that have unknown risk significance.

At the March 2006 pilot plant observation visit, the Staff presented a flow chart, illustrating how newly found multiple spurious circuits identified during an inspections, could be treated (See flow chart below). In addition to the flowchart, the following information was discussed:

• If circuits identified by an inspector and its related contributors were omitted, and their contribution to risk; are greater than Green OR constitute a violation of defense-indepth or safety margins, in spite of using an appropriate screening tool, the issue would constitute a minor violation. If the inspector determines that the licensees screening tool is flawed, that would constitute a violation. Here related contributors are those that are associated via the same root cause, fire scenario, or fire area.

• If the circuit issue identified by the inspector and its related contributors that were also omitted are less than Green AND do not constitute a violation of defense-in-depth or safety margins AND the licensee has used an appropriate screening tool, no further action is warranted. However, if the inspector determines that the licensees screening tool is flawed, that would constitute a minor violation.

The process outlined in the flowchart documents (new) unevaluated multiple spurious operations as unresolved items (URI) and proposes a risk threshold below which the multiple spurious operation is screened (a potential threshold for such treatment of 1 E-08/yr delta-CDF

[1 E-09/yr delta LERF] was offered for discussion). Industry raised the concern that documenting all multiple spurious operations as URIs pending evaluation will create a significant cost and resource impact because all URIs must be formally dispositioned and even those classified as minor can require 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. Industrys preference would be to not treat the new multiple spurious as a URI, but to disposition the issue within the fire probabilistic safety assessment (PSA) process. Consensus was to review the minor questions in Inspection Manual Chapter (IMC) 0612, and suggest development of new questions if necessary such that multiple spurious operations below a certain threshold could be relegated to minor and treated accordingly.

2 -

Resolution Action(s)/Action Party: OPEN. Industry and pilot-plant participants agreed to review the flowchart, IMC 0612 questions, screening thresholds and provide feedback to the NRC at the next observation meeting. The industry may also submit an FAQ on the issue.

Associated FAQ: Planned, but not submitted.

Lesson Learned: Pending resolution of issue.

3 -

Figure 1. Multiple Spurious Post-Transition Inspections 4 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 2 Topic: Multiple spurious operations - screening criteria Associated Observation Meeting Parking Lot Item(s): 2

==

Description:==

Duke Power presented its methodology for identification and analysis of multiple spurious operations during the November 2005 observation visit (See November 2006 Trip Report Handout Reference 4). During the visit, the participants held considerable discussion with regard to screening and treatment of newly identified multiple spurious operations. The Duke Power approach considers newly identified spurious operations as outside the license basis until risk significance is determined. One suggested approach to establishing risk significance was the use of Fussell-Vesely (F-V) risk importance criteria.

This topic arose from a more general discussion on a proposed method to perform an acceptable transition change evaluation. A fire PSA that represents the plant going forward (GF) would be performed, i.e., crediting any modifications/changes to be implemented as part of the transition. This would be compared against an ideal fire risk if all-deterministic compliance were strictly met, yielding a fire delta-CDF (using CDF as the risk metric) = (fire-CDF-GF) minus (fire-CDF-ideal). The fire-CDF-ideal need not be calculated from a separate full fire PSA, but rather using the F-V risk importance measures (indicating the fractional contribution of fire induced failures to the fire CDF) associated with non-compliance as determined from the fire-CDF-GF. The sum of these F-V values would conservatively bound the delta-CDF. In the case where this bounding technique proved too conservative, Issue Summary Sheet 13 discusses some relaxations.

Resolution Action(s)/Action Party: CLOSED. The spurious operations evaluation methodology continues to evolve, and this specific issue was determined to be no longer relevant during the March 2006 meeting.

Associated FAQ: None.

Lesson Learned: As experience grows during transitioning the pilot-plants to a risk-informed, performance-based fire protection program, PSA methods and application to analyze spurious operations and plant change continue to evolve. As the PSA methods and process output become finalized and confirmed by peer review, NEI 04-02 will be revised, as appropriate, to provide the necessary guidance for implementing/applying these methods. At this time, no specific changes to the guidance were proposed.

5 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 3 Topic: Transition of operator manual actions (OMA) to NFPA 805 Recovery Actions Associated Observation Meeting Parking Lot Item(s): 3

==

Description:==

NEI 04-02, Revision 1, Section 2.3.1 and Appendix B-2 discuss the direct transition of previously approved program elements to the new program. Elements that do not meet the previous approval criteria should be addressed via the change evaluation process.

Specific concerns have been expressed by industry with regard to transition of OMAs currently relied on to demonstrate compliance with 10 CFR 50, Appendix R, III.G.2, and the approval of which may be explicitly or implicitly addressed in a NRC Safety Evaluation Report (SER).

(Ideally, OMA approval would be documented within an SER.) The NRC has established the position that OMAs are not an acceptable method to demonstrate compliance with 10 CFR 50, Appendix R, III.G.2; do not meet the deterministic criteria of NFPA 805, Chapter 4; and therefore must be addressed via a plant change evaluation. The NRCs position is in Regulatory Guide (RG) 1.205, Section 2.3, and Regulatory Issue Summary (RIS) 2006-10.

Considerable discussion was held during the November and March pilot-plant observation visits regarding transition of OMAs for safe shutdown, what documentation constitutes NRC approval of those OMAs, and how to disposition those Resolution Action(s)/Action Party: CLOSED. Based on approval of FAQs 06-0001 and 06-0012.

Associated FAQ: 06-0001 and 06-0012 Lesson Learned: Transition of OMAs to NFPA 805 Recovery Actions will be documented in Revision 2 to NEI 04-02..

6 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 4 Topic: Spurious Operations - Risk informed, performance-based treatment of high-low pressure interface components Associated Observation Meeting Parking Lot Item(s): 4

==

Description:==

During the November 2005 observation visit, Duke Power presented their NFPA 805, Chapter 4, methodology for transition. Included in this presentation was a discussion of the treatment of high-low pressure interface components. Duke Powers presentation identified that there are some differences in how high-low pressure interfaces are defined between NFPA 805 and NEI 00-01. NEI 00-01 is the circuit analysis methodology referenced in NEI 04-02. NFPA 805 establishes the requirements by reference in 10 CFR 50.48(c), and the guidance must be consistent with the standard.

Resolution Action(s)/Action Party: CLOSED. Based on closure FAQ 06-0006.

Associated FAQ: FAQ 06-0006 Lesson Learned: By reference in 10 CFR 50.48(c), NFPA 805 establishes the requirements of the rule and supersedes any implementation guidance.

7 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 5 Topic: Fire PSA Peer Review Associated Observation Meeting Parking Lot Item(s): 5, 20, 37

==

Description:==

During the November 2005 observation visit, Oconees fire PSA effort was identified as their critical path. The current schedule for completion of the PSA and submittal of the license amendment for adopting 10 CFR 50.48(c) and NFPA 805 would not support completion of an industry-developed fire PSA Peer Review prior to submittal. The Staff endorsed a position that a fire PSA Peer Review is part of the license amendment request to transition to NFPA 805.

While an ANS Fire PSA Standard is under development, and state-of-the-art guidance on performing fire PSA exists via NUREG/CR-6850 (EPRI TR-1011989), fire PSA remains (and will remain) in a state of development, rendering a final baseline against which to measure quality difficult. A peer review process analogous to that performed for internal event PSAs is under development by NEI and the Owners Groups to coincide roughly with the issuance of the fire PSA standard. However, it is unlikely that the Standard and the NEI peer review process will be completed and endorsed on a schedule that will fully support pilot-plant transition. Relief may come with the extension of enforcement discretion and Oconee may extend their pilot program for another year.

Discussion of this issue indicated that NRC oversight of the pilot-plant PSA effort would provide confidence in the quality of the PSA as part of the transition program. The pilot plants requested that the NRC perform intermediate PSA audits as the various elements of their fire PSAs are completed, rather than waiting to do a single audit during the license amendment review, to provide assurance that they are heading along the right path and provide lessons learned for non-pilot plants. The NRC agreed to accomplish this through several visits focused specifically on the fire PSA and a roll-up of these audits will substitute for an endorsed, industry-developed Fire PSA Peer Review for the pilot plants.

During the November 2006 pilot-plant observation visit, industry noted NRCs endorsement/non-endorsement of ANS Fire PRA standard in RG 1.200 will impact non-pilot plants. Issues may arise from a lack of endorsement Resolution Action(s)/Action Party: OPEN. The NRC incorporated peer review guidance in RG 1.205, Section 4.3, was a discussion point at the March 2006 observation visit. The Regulatory Guide states that licensees should subject their fire PRA to a peer review to the extent that adequate industry guidance is available to support the transition process. Absent of industry guidance, the NRC will review the quality of the PRA for acceptability.

During the March 2006 observation visit, the NRC staff was asked to identify any specific needs they may have to perform the PRA Peer Review and what documentation will be necessary or provided that will constitute the record of this review and the acceptability of the PRA.

Associated FAQ: None.

Lesson Learned: The NRC Staff will assess the quality of the pilot-plants fire PRA during the pilot in-process review of the PRA development. Until current efforts to establish fire PRA peer 8 -

review standards and processes are completed, non-pilot plants transitioning to NFPA 805 may choose to have their fire PRA reviewed by an independent group against available guidance to minimize impacts to transition schedules and reduce uncertainty in fire PRA application acceptability (e.g., in change analysis). As experience is gained with the pilot-plant reviews, additional lessons learned information would be provided.

9 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 6 Topic: PSA and change evaluations for Low-Power/Shutdown (LP/SD) modes Associated Observation Meeting Parking Lot Item(s): 6, 22

==

Description:==

During the November 2005 pilot-plant observation visit, industry representatives indicated that any requirement for a LP/SD mode fire PSA would be cost prohibitive. There are no current guidance/methods for performing a LP/SD fire PSA. Although LP/SD fire PSAs exist, development of a standard is in progress and NRC/EPRI are considering a joint effort to develop guidance for shutdown fire PSA. Resources are not likely to be committed by utility management and the development of methods and performance of a LP/SD fire PSA would not support the transition schedules.

The NRC provided specific examples of LP/SD risk assessments under RG 1.174 plant change applications for licensees to consider in their NFPA 805 evaluations. The guidance in NEI 04-02 addresses LP/SD risk via the defense-in-depth approach currently used for outage management. This approach relies on the identification of high-risk evolutions and key safety functions associated with those evolutions (See NEI 04-02, Rev. 1, Section 4.3.3). The meeting attendees suggested that implementing guidance for meeting 10 CFR 50.48(c) should explicitly indicate the NRCs expectations for assessing fire risk in LP/SD modes.

The change evaluation process must address risk for changes that affect LP/SD modes.

However, NEI implementation guidance (NEI 04-02) currently does not address the method to use in performing change evaluations for these operational modes.

Resolution Action(s)/Action Party: OPEN. In RG 1.205, the NRC staff accepted the approach described in NEI 04-02, Revision 1, for managing risk of LP/SD modes of operation. NEI will revise NEI 04-02 to address the performance of plant change evaluations for non-power modes.

Associated FAQ: Planned but not submitted.

Lesson Learned: At this time, a separate LP/SD fire PSA is not required, because there are currently no standards, methods or guidance available. Until these LP/SD fire PSA methods are developed and accepted, manage the fire risks during LP/SD modes according to established methods for outage risk management. Plants should identify high-risk evolutions and key safety functions and evaluate the associated structures, systems, and components as described in the endorsed NEI 04-02.

10 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 7 Topic: NFPA 805 Chapter 3 - Chapter 4 related requirements Associated Observation Meeting Parking Lot Item(s): 7, 8, 9

==

Description:==

During pilot-plant efforts to transition NFPA 805 Chapter 3 requirements and further develop and implement the guidance for plant change evaluations, the pilot plants identified concerns relative to the dependence of Chapter 3 fire protection design features on Chapter 4 required systems. Specifically, Chapter 3 requirements for detection, suppression, and fire barriers are dependent on these fire protection elements required by Chapter 4. During the November 2005 observation visit, the attendees determined that there was some confusion over the application of these requirements, particularly when applying a performance-based approach. In addition, because of the dependence of Chapter 3 on the requirements of Chapter 4, the change evaluation process should establish the Chapter 4 required systems before evaluating those systems against the Chapter 3 requirements.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQs. NEI needs to revise NEI 04-02 to clarify the application of these requirements. NEI has submitted a proposed revision and NRC Staff are reviewing the FAQs.

Associated FAQ: 06-0004 Lesson Learned: Before doing Chapter 3 code compliance, determine which fire protection systems and elements Chapter 4 requires.

11 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 8 Topic: Performance-based alternative for fire area boundary evaluation Associated Observation Meeting Parking Lot Item(s): 10

==

Description:==

NFPA 805 includes provision for using existing engineering equivalency evaluations (i.e., GL 86-10 evaluations), but does not contain similar requirements for evaluation of fire protection features (e.g., fire barriers) using a risk-informed, performance-based approach. NFPA 805, Section 1.7, describes the general requirement for demonstrating equivalency in meeting the requirements of the standard. Section 1.7 states that the Authority Having Jurisdiction (i.e., the NRC) must approve alternative approaches. The rule (10 CFR 50.48(c)(2)(vii)) requires NRC approval of performance-based approaches to demonstrating compliance with NFPA 805, Chapter 3 requirements.

The Pilot Plants identified a need to revise NEI 04-02 to provide additional methodologies for performing engineering equivalency analyses that licensees could reference in their license amendment request.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQ. NEI developed proposed changes to NEI 04-02 to include a methodology and process for performing engineering equivalency evaluations. NEI Submitted a FAQ containing the proposed changes for NRC review.

Associated FAQ: 06-0008, 07-0033 Lesson Learned: Risk-informed, performance-based applications to fire protection under NFPA 805 needs a methodology for performing engineering equivalency evaluations, similar to current GL 86-10 evaluations.

12 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 9 Topic: Plant change evaluations - Preliminary risk screening Associated Observation Meeting Parking Lot Item(s): 11

==

Description:==

NEI 04-02, Revision 1, Section 5.3.3, Appendix I, and Appendix J address the use of preliminary screening with regard to evaluation of changes to the fire protection program. The attendees at the November 2005 observation visit held considerable discussion regarding the criteria to apply in the preliminary screening process and the need for additional guidance and examples in NEI 04-02.

Early in the development of NEI 04-02, NEI advocated a qualitative approach by which plant changes, which clearly would not influence risk, could be dispositioned without any quantification. Ultimately, the ACRS resisted this approach and therefore, all plant change processes would at least have a preliminary risk screen with some minimal level of quantification. Essentially a qualitative approach whereby changes that clearly did not increase risk, or did so at some to a negligible level, need not undergo any formal risk evaluation beyond a statement as to why any effect could be dismissed. Appendix I of NEI 04-02 listed some examples of these types of plant changes and Progress Energy provided example evaluations at the first observation visit.

Resolution Action(s)/Action Party: CLOSED. NRC and industry agreed that this would be a living part of NEI 04-02, whereby subsequent versions of NEI 04-02, for illustrative purposes, could include additional examples encountered in the transition process.

Associated FAQ: None submitted.

Lesson Learned: NEI will supplement the NEI 04-02 plant change evaluation process with examples identified during the pilot-plant transition.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 10 Topic: Plant change evaluations - Preliminary screening criteria and form corrections.

Associated Observation Meeting Parking Lot Item(s): 12

==

Description:==

While NEI originally proposed that the RG 1.174 thresholds be applied for determining acceptable increases in risk (measured via CDF and LERF) for NFPA 805 self approvals by licensees (i.e., without prior NRC review), the fact that RG 1.174 was conditioned on NRC review made adoption of equivalent thresholds untenable. Eventually, thresholds as outlined in RG 1.205, NRC included a grey area where the NRC review would be at NRCs discretion.

NEI 04-02, Appendix I, contains the plant change evaluation form. Section 4 of this form addresses the preliminary risk screening and includes qualitative criteria. Discussion during the November 2005 observation visit concluded that greater than minimal criteria should be revised to potentially greater than minimal when determining if more quantitative risk analysis is needed for the change. RG 1.205, Section 3.2.5, provides additional guidance with regard to risk thresholds to apply in the plant change evaluation process, and clarifies the terminology, such as minimal, used in NEI 04-02, in determining the acceptability of the change and the need for NRC approval.

Resolution Action(s)/Action Party: CLOSED. Approved FAQ-0003 contains changes to NEI 04-02, Sections 5.3 and Appendix I that provide additional guidance on performance of preliminary screening and correct the change evaluation form with regard to applying the potentially greater than minimal criteria.

Associated FAQ: 06-0003 Lesson Learned: None 14 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 11 Topic: Plant change evaluation - PSA engineer reviews of screens Associated Observation Meeting Parking Lot Item(s): 13

==

Description:==

During the November 2005 observation visit, the Pilot Plants held considerable discussion regarding whether or not a PRA engineer should review the preliminary risk screening performed for plant changes. This topic is similar with some of the previous discussions regarding qualitative risk screening and involves the level of licensee review, if any, by the licensee PRA staff. The NRC advocates that the plant PRA staff see all plant changes, such that even the most trivial could be a simple sentence in the record. Licensees favored screening by fire protection personnel for such trivial items (using guidance developed with input from the plant PSA staff, perhaps in the form of screening questions), such that no PSA staff notification would be required.

In follow-up discussions of this topic during the March 2006 observation visit, it was determined that the interface between the PSA staff and fire protection program change evaluation screening process is plant specific and did not warrant tracking as a parking lot issue.

Resolution Action(s)/Action Party: CLOSED. No action taken.

Associated FAQ: None.

Lesson Learned: The interface between the PSA and fire protection staff during the fire protection program screening process for plant change evaluations is plant-specific, but it should ensure that all necessary communication between these respective disciplines occurs as part of the screening process.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 12 Topic: Authority having jurisdiction (AHJ) - NFPA Code deviations Associated Observation Meeting Parking Lot Item(s): 14

==

Description:==

The NRC is the Authority Having Jurisdiction (AHJ) for determining acceptability of fire protection program elements to meet the requirements of NFPA 805. Chapter 3 of NFPA 805 references other NFPA codes that apply to administrative and design elements of the fire protection program (e.g., those that apply to suppression, detection, and water supply) that are managed day-to-day by the licensee but also contain responsibilities and requirements for AHJ approval. A compliance approach that applies the AHJ authority (as described in the NFPA Standards) as strictly meaning NRC approval could burden the NRC with reviewing fire protection system design changes and administrative procedures that implement NFPA code provisions requiring AHJ approval. Minor deviations to code compliance would also require possible NRC review. Licensees would be burdened by costs and delays associated with the review and approval process.

NFPA 805, Section 1.8 addresses Code of Record, which allows licensees to meet the version of the standard applicable to the fire protection element or design feature at the time it was designed or otherwise committed to the AHJ. Plants should follow the approval authorities granted by the code-of-record, with the recognition that the AHJ is the NRC as described in RG 1.205, Regulatory Position C.1.

Resolution Action(s)/Action Party: CLOSED. RS 1.205 incorporates the NRC position on AHJ. Parking Lot Item 10 (See Issue Summary Sheet No. 8 above) involves development of a process similar to the existing engineering equivalency evaluation (NFPA 805, Section 2.2.7 and GL 86-10) and is currently under review as an FAQ.

Associated FAQ: None.

Lesson Learned: NRC is the AHJ as described in RG 1.205, but the code-of-record for a given plant fire protection feature may allow licensees certain authority to establish applicable requirements that may differ (i.e., equivalency evaluations) from the versions cited in NFPA 805.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 13 Topic: Transition baseline risk.

Associated Observation Meeting Parking Lot Item(s): 19, 24

==

Description:==

The Pilot Plants discuss an issue regarding the cumulative impact of changes to the fire protection program that occur during the transition process. The new baseline risk established at the completion of implementation should incorporate these impacts. From the November 2005 observation visit, this issue is a spin-off of an industry concern with how and to what extent the difference between the going forward and deterministically fully compliant risks will be evaluated for transition. This issue is somewhat related to Topics 2 and 24. Based on the recent NRC clarifications with respect to vital fire protection program elements, especially circuit spurious operations (any and all, one at a time) and operator manual actions for redundant trains in the same fire area (Appendix R, III.G.2), industry is concerned as to what would serve as the deterministically fully compliant baseline risk against which to measure the increase going forward.

While calculating the going forward fire risk is relatively straightforward, doing likewise for the deterministically fully compliant risk could require essentially a second full fire PSA for ideal conditions. NRC proposed a multi-step analytic approach whereby the licensees could proceed from the most to least conservative (least to most realistic) estimate of the risk increase due to the transition, with the ability to stop the analysis at whatever step provides an estimate of an acceptable risk increase.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQs. RG 1.205, Section C.3.2.6, provides the staff position on treatment of individual and cumulative changes in risk, as well as the use of risk reductions associated with unrelated plant changes to offset increases in fire protection risks. NEI 04-02 will be updated to clarify that the baseline fire protection program risk, post-transition, will be the risk of the plant as designed and operated according to the NRC-approved licensing basis. This position is RG 1.205 and NEI will revise NEI 04-02 to address screening, processing, and tracking of changes.

Associated FAQ: 06-0010, 06-0014.

Lesson Learned: Pending submittal and final resolution of FAQs. Transitioning plants must establish baseline fire protection risk to support plant change evaluations post-transition.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 14 Topic: Regulatory position on interim guidance changes Associated Observation Meeting Parking Lot Item(s): 16

==

Description:==

RG 1.205 endorses NEI 04-02, Revision 1. The pilot-plant implementation activities and observation visits have identified a number of changes that are necessary to clarify, update, or revise the implementing guidance in NEI 04-02. As pilot-plant implementation progresses, it is expected that the need to make these types of changes will continue. The processes for revising and reissuing these documents are neither efficient nor timely enough to support the on-going transition activities. Administrative mechanisms are necessary to allow guidance changes to be accumulated (e.g., as errata) between official/approved revisions. The ability to apply interim changes to the guidance is potentially problematic because of the Regulatory Guide revision and approval process and the direct endorsement of a specific revision of NEI 04-02 within the Regulatory Guide.

At the March 2006 pilot-plant observation visit, the industry proposed a Frequently Asked Question (FAQ) process as a means to address this issue. The Maintenance performance indicators process FAQs is the baseline for the NFPA 805 process. The NRC Staff agreed this may be a viable approach, but suggested that the utilities formally submit their requests by letter to initiate the FAQ process.

Resolution Action(s)/Action Party: CLOSED. By letter dated May 2, 2006, NEI submitted a letter with a draft description of the FAQ process for NRC review. The NRC responded with proposed changes in a letter to NEI dated July 12, 2006.

Associated FAQ: None. See referenced letters.

Lesson Learned: The NRC established a FAQ process to provide timely NRC review of changes to NFPA 805 implementing guidance. NEI will be incorporate approves FAQs in revisions to NEI 04-02. The NRC will revise RG 1.205, as appropriate; to endorse this revised NEI guidance.

18 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 15 Topic: Circuit analysis Generic Letter and RIS - Compliance issues for transition Associated Observation Meeting Parking Lot Item(s): 17

==

Description:==

This issue has significant implications related to implementation of NFPA 805.

Specifically, the circuit analysis RIS and draft Generic Letter require a level of compliance for deterministic circuit analysis (associated with current fire protection programs) that is not currently achieved by most plants. A comparison between the NFPA 805 risk analyses against the deterministic case is required (NFPA 805, Section 4.2.4.2). Licensees that plan to transition to NFPA 805 do not plan to bring their plants into compliance with the RIS and GL provisions prior to transitioning to NFPA 805.

The NRC staff presented a suggested process by which licensees could establish an ideal risk baseline for the compliant deterministic case.

Resolution Action(s)/Action Party: CLOSED. This issue is related to others issues establishing the PRA baseline for the performance of plant change evaluation (See Issue Summary Sheets 13 and 18).

Associated FAQ: None planned.

Lesson Learned: None. Other parking lot issues and associated lessons learned will address this issue.

19 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 16 Topic: NEI 04-02, Appendix B, methodology changes Associated Observation Meeting Parking Lot Item(s): 18

==

Description:==

Pilot-plant transition activities at the Oconee Nuclear Station have determined that the comparison tables of NEI 04-02, Appendix B, do not adequately communicate the compliance status and transition of current fire protection program elements to the nuclear safety performance criteria of NFPA 805. The pilot-plants and NEI will incorporate in NEI 04-02 an alternative methodology. The NRC staff expressed concern that NEI should communicate these types of issues with the existing (endorsed) guidance to non-pilot plants.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQ. NEI to develop alternative methods to comparison tables in NEI 04-02, Appendix B.

Associated FAQ: 06-0013 Lesson Learned: Transition activities for ONS identified that the current tabular method for transition of nuclear safety performance criteria, as described in NEI 04-02, Appendix B, is not an effective means of communicating the necessary information to demonstrate compliance with NFPA 805.

20 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 17 Topic: Risk acceptance thresholds.

Associated Observation Meeting Parking Lot Item(s): 21

==

Description:==

There is a number of risk acceptance thresholds for fire PSA-related applications among various documents and programs, specifically the Reactor Oversight Process (ROP), the Significance Determination Process (SDP), RG 1.174 (and, by incorporation, NFPA 805),

NEI 04-02 and RG 1.205. The Pilot Plants need to develop a reconciliation of these various thresholds for clarity and application of transition processes.

Resolution Action(s)/Action Party: OPEN. Guidance is required before performance of change evaluations.

Associated FAQ: Planned but not submitted.

Lesson Learned: Pending final resolution of the issue.

21 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 18 Topic: Definition for fire protection program change Associated Observation Meeting Parking Lot Item(s): 23

==

Description:==

During the March 2006 observation visit, the Pilot Plants held a discussion regarding what constitutes a change to the fire protection program. The attendees noted that plant changes not related to the fire protection program might influence the program. Installation of some fire protection systems and features are for protective purposes not related to demonstrating compliance with NFPA 805. Are these systems and features within the scope of the fire protection program that is subject to evaluation under the NFPA 805-required plan evaluation change process? The discussion identified a need to better define the boundaries of the fire protection program for the purposes of configuration control and application of the change evaluation process.

Resolution Action(s)/Action Party: OPEN. Pending resolution of FAQ. Industry drafted a methodology and examples of what constitutes a fire protection program change.

Associated FAQ: 06-0005.

Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 19 Topic: Tracking of Cumulative Risk from Post-Transition Plant Changes Associated Observation Meeting Parking Lot Item(s): 15, 24

==

Description:==

At the March 2006 observation visit, three specific items discussed were relevant to this topic:

Is a license amendment request needed post-transition to credit existing Systems, Structures, and Components (SSCs) to lower fire risk, i.e., taking credit for these not as offsets to risk increases but purely as decreases; If both risk increases and decreases are due to related changes, such that the net increase is

<10 E-7/yr delta-CDF (<10 E-8/yr delta-LERF), the changes need not be submitted for prior NRC approval. However, if they are unrelated (e.g., one is part of the fire protection program while the other is not), then prior NRC approval is needed; and If an initial change results in a risk increase below some threshold value, the licensee needs to track future changes or be exempt from future tracking. What would be the appropriate threshold value, as determined through a screening process? Clarification is needed in the implementing guidance (i.e., Regulatory Guide or NEI 04-02) as to whether the tracking of the impacts of these changes needs to be continued post-transition or whether tracking of cumulative impacts begins when the new baseline risk is established.

RG 1.205 uses RG 1.174 as a risk acceptance template and requires that cumulative increases in risk be tracked over time and that increases in risk attributable to related program changes be aggregated to determine their total impact even if separated over time. Both of these imply that, no matter how widely separated in time these increases may be, they need to be summed and measured against the original baseline, i.e., the initial going forward fire risk, even if a fire PSA re-baselining is periodically performed. NRC distributed a graphic to illustrate the difference between the RG 1.174 approach and another where the going forward fire risk is reset after each periodic update (essentially shifting the time axis). The latter, although somewhat simpler, is not consistent with RG 1.174. However, except for related changes, tracking of the cumulative risk increase can be accomplished by considering the total risk rather than by segregating the changes into separate entities requiring individual aggregation.

However, separate tracking for related changes over the life of the plant is a requirement. The Pilot Plants discussed screening methods to simplify this latter process, whereby risk increases of sufficiently low magnitude could be considered too small to merit retention for future tracking as part of a series of related changes (they would still be tracked implicitly through the total plant risk).

Resolution Action(s)/Action Party: OPEN. Pending resolution of FAQ. RG 1.205, Section C.3.2.6, provides the staff position on treatment of individual and cumulative changes in risk, as well as the use of risk reductions associated with unrelated plant changes to offset increases in fire protection risks. As stated in RG 1.205, NEI will revise NEI 04-02 to clarify that the baseline fire protection program risk, post-transition, will be the risk of the plant as designed and operated according to the NRC-approved licensing basis. NEI will also revise NEI 04-02 to address the screening, processing, and tracking of changes.

23 -

Associated FAQ: FAQs 06-0010, 06-0014.

Lesson Learned: Pending submittal and final resolution of FAQs. Licensees must establish baseline fire protection risk to support plant change evaluations post-transition.

24 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 20 Topic: Fire Zones/Compartment Definitions Associated Observation Meeting Parking Lot Item(s): 25

==

Description:==

During the October 2006 visit, Pilot Plants held discussion regarding what constitutes an acceptable Fire PSA compartment. For the purposes of fire PRA, plants portioning divides the plant into the Fire Compartments as defined in NUREG/CR-6850. Fire Compartments map fire areas and zones into compartments defined by fire damage potential.

Defining many Fire Compartments within zones are that are not necessarily based on physical barriers or features can lead to the need to do substantial multi-compartment analysis. This is inconsistent with the guidance provided in NUREG/CR-6850 and raises concerns with the difficulty in managing and reviewing an analysis that relies on such complexities. Questions arose over impact of this approach on other tasks and level of documentation needed to justify this approach Resolution Action(s)/Action Party: CLOSED. Industry changed approach to be consistent with NUREG/CR-6850 guidance.

Associated FAQ: None.

Lesson Learned: NUREG/CR-6850 provides adequate guidance concerning development of Fire Compartments for Fire PRA purposes.

25 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 21 Topic: Ignition Frequency Binning Issues Associated Observation Meeting Parking Lot Item(s): 26, 27, 28, 29

==

Description:==

NUREG/CR-6850 Task 6, Fire Ignition Frequencies provides a procedure for estimating fire-ignition frequencies for use in the Fire PSA. During the October 2006 observation visit, the pilot plants held presentations regarding the definitions and boundaries associated with binning of different components into appropriate collections to appropriate the fire ignition frequencies correctly compartment. Specifically questions arose concerning:

a) Main control board definition: The delineation between Bin 4 (main control board) and Bin 15 (electrical panels/cabinets) has some ambiguity that could lead to inconsistent application of the guidance (Parking Lot Item 26).

b) Electrical cabinets: NUREG/CR-6950 needs explicit guidance on counting of plant electrical cabinets. Presentations on two different approaches; one that counts electrical cabinet based on physical boundaries regardless of size or length and another that counts solely based on cabinet size (Parking Lot Issue 27).

c) HEAF frequency for low voltage equipment: Counting Bin 16 equipment using the Bin 15 method can result in a fire frequency distribution for HEAF for switchgears and load centers that are inconsistent with industry experience (Parking Lot Item 28).

d) Miscellaneous Binning Issues: Questions arose concerning ignition county frequency for MOV motors, hydraulic actuators for valves, and transformers (Parking Lot Item 29).

Resolution Action(s)/Action Party: OPEN. Pending resolutions of FAQs. Industry will provide clarification on the methodology. Note: FAQs 06-0016, 06-0017, and 06-0018 have been approved. FAQs 07-0031 and 07-0035 are still under consideration/discussion.

Associated FAQ: 06-0016, 06-0017, 06-0018, 07-0031, 07-0035.

Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 22 Topic: Transition and Post-Transition Program Management Associated Observation Meeting Parking Lot Item(s): 30

==

Description:==

During the October 2006 visit, discussion was held regarding the role of 10 CFR 50.48(a) for a plant that is transition to NFPA 805 Resolution Action(s)/Action Party: OPEN. Clarification information is available in the promulgation of 10 CFR 50.48(c) on 06/08/04 (ADAMS Accession No. ML041340086). Industry will provide clarification on the issue.

Associated FAQ: 07-0032.

Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 23 Topic: New Requirements in NFPA Chapter 3/Table B-1 Issues Associated Observation Meeting Parking Lot Item(s): 32, 33, 34

==

Description:==

Participants of the November 2006 meeting discussed the 82 paragraphs of Chapter 3. Industry reports based on pilot-plant experience, that seventeen paragraphs appear to be new requirements (e.g., NFPA 805 Section 3.94 requirement for suppression for the diesel fire pump). Clarification of some paragraphs may be required. Industry also noted that additional clarification/standardization of terms used in NEI 04 02 Tables B-1, B-2, and B-3 may also be necessary. Industry stipulated the table formats are not rigid (i.e., database, other report formats are acceptable).

Resolution Action(s)/Action Party: CLOSED. There are new requirements that each plant will need to address. It is expected that each plant will document their resolution of the new requirements in their Table B-1.

Associated FAQ: None.

Lesson Learned: There are new requirements embedded in Chapter 3 that each plant will need to address on a case-by-case basis. Table B-1 provides a mechanism for documenting these issues.

28 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 24 Topic: Assessing Risk of Recovery Actions Associated Observation Meeting Parking Lot Item(s): 35, 36

==

Description:==

Participants of the November 2006 meeting discussed assessing the risk of recover actions (operator manual actions) and the need/methods to perform/report this information as part of transition (NFPA 805 Section 4.2.4). Risk significant operator manual actions are a concern to the NRC.

Resolution Action(s)/Action Party: OPEN. Discussions held at the November 2006 meeting concerning how an ASD fire area (in particular operator manual actions) transition over. Meeting participants voiced confusion over the characterization of ASD fire areas as deterministic, while NFPA 805 defines recovery actions as performance-based. Industry will provide clarification on the issue.

Associated FAQ: 07-0030 Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 25 Topic: Mapping efforts to10 CFR 50.48(a) requirements Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

Participants of the March 2007 meeting discussed mapping their efforts to 10 CFR 50.48(a). Specifically 10 CFR 50.48(b) and 10 CFR 50.48(c) constitute ways for a plant to satisfy the requirements of 10 CFR 50.48(a).

Resolution Action(s)/Action Party: OPEN. Pending acceptance of FAQ Associated FAQ: 07-0032.

Lesson Learned: 10 CFR 50.48(c) meets the requirements in 10 CFR 50.48(a).

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 26 Topic: clarify existing engineering equivalency evaluations (EEEE) guidance Associated Observation Meeting Parking Lot Item(s): 43

==

Description:==

The plants indicated the EEEE guidance in NEI 04 02 still requires further clarification (in addition to that being provided as part of FAQ 06-0008) and plan to propose changes.

Resolution Action(s)/Action Party: OPEN. Industry will provide clarification on the issue.

Associated FAQ: 07-0033.

Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 27 Topic: Properly accounting for Kerite cables impacts on targets within a zone of influence (ZOI)

Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

Kerite cables are a Thermoset sheathed cable, but the Kerite cables performance is more in line with Thermoplastic cable. Correctly accounting for Kerite cables as Thermoplastic cable results in additional targets within the zone of influence (ZOI).

Resolution Action(s)/Action Party: CLOSED. No further actions required.

Associated FAQ: No FAQ is required.

Lesson Learned: Plants must ensure they properly account for Kerite cables when establishing targets within the zone of influence (ZOI).

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 28 Topic: Define boundary with respect to the counting of fire ignition sources Associated Observation Meeting Parking Lot Item(s): 45

==

Description:==

Discussions during the March 2007 meeting highlighted issues with counting items in structures and compartments that screened out as part of the NEI 04-02 process. Once the analysis boundaries are set, then counting should include all components within a bin that are within the boundaries. This means that the possibility exists that the sum of the frequencies for all components in all compartments will not be equal to the total given generic frequencies in NUREG/CR-6850. The issue is strongly related to the establishment of the global analysis boundary of the plant. One concern is that components unrelated to the safety of the plant could dilute the fire ignition frequency for those areas important to safety. Another is that failure to include components within the boundaries, but located in screened compartments, could lead to overestimates of the frequency contribution from that class of components, thereby distorting the risk importance profile.

Resolution Action(s)/Action Party: CLOSED. After consideration, pilot-plants agree with the NRC understanding of NUREG/CR-6850.

Associated FAQ: Not required.

Lesson Learned: None.

33 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 29 Topic: Transformer threshold Associated Observation Meeting Parking Lot Item(s): 46

==

Description:==

Discussions during the March 2007 meeting identified an issue with the minimum size of transformer included during component counting. NUREG/CR 6850 has several bins into which transformers fit (e.g., Bin 16, Bin 23 and Bin 29). While the criteria for counting transformers in Bin 16 and Bin 29 is adequately clear, the lower bound on Bin 23 transformers is not clear and needs further definition.

Resolution Action(s)/Action Party: OPEN. Industry will provide clarification on the issue.

Associated FAQ: 07-0031.

Lesson Learned: The lower bound on Bin 23 transformers is not clear and needs further definition.

34 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 30 Topic: Modular Accident Analysis Program (MAAP) versus Reactor Excursion and Leak Analysis Program (RELAP) review of Thermal-Hydraulic success criteria.

Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

Discussions during the March 2007 meeting raised issues concerning use of Modular Accident Analysis Program (MAAP) versus Reactor Excursion and Leak Analysis Program (RELAP) for review of Thermal-Hydraulic success criteria. Staff noted that many utilities (Progress Energy included) use MAAP to model for success criteria. While MAAP has been part of the internal events PRAs at many facilities the NRC has not endorsed the code.

Resolution Action(s)/Action Party: CLOSED. No action required.

Associated FAQ: None Lesson Learned: Plants can expect to be questioned on their use of MAAP for determining PRA success criteria 35 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 31 Topic: Screening ignition sources (NUREG/CR 6850 Task 8).

Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

NUREG/CR 6850 Task 8 allows for the screening of certain ignition sources through scoping fire modeling. Additionally, Task 8 allows for the development of a severity factor based upon those scoping fire modeling estimates. Harris Nuclear Power plant indicated during the March 2007 meeting, that they had determined this second phase screening effort was not worth the effort or worth generating questions that might be raised later. HNP decided not to screen ignition sources in this second phase of the process, but rather to bring those ignition sources that did not screen from the basic scoping fire modeling forward. Keeping ignition sources, rather than screening them, is a conservative approach to fire PRA.

Resolution Action(s)/Action Party: CLOSED. No action required.

Associated FAQ: None Lesson Learned: Skipping screening of certain ignition sources as allowed as part of NUREG/CR 6850 Task 8 is desirable under some circumstances.

36 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 32 Topic: Difference in fire modeling between NUREG/CR 6850 and the Fire Protection Significance Determination Process (FDSDP)

Associated Observation Meeting Parking Lot Item(s): 47

==

Description:==

There are differences between the fire modeling done as part of a FPSDP and that done as part of NUREG/CR 6850 (e.g., the designation of initial HRRs for a few types of fire ignition sources). This is likely to raise multiple questions by inspectors as work progresses and licenses. NUREG/CR 6850 is the guiding requirement for the NFPA 805 efforts and as such is the appropriate modeling approach. Clarification in anticipation of this issue will assist plants and inspectors in dealing with the differences.

Resolution Action(s)/Action Party: CLOSED. NUREG/CR 6850 is the guiding requirement for NFPA 805.

Associated FAQ: No FAQ required.

Lesson Learned: NRC inspectors are used to FPSDP and its methods, yet NUREG/CR 6850 is the appropriate modeling approach for NFPA 805 activities.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 33 Topic: Environmental considerations for other equipment in fire affected compartments.

Associated Observation Meeting Parking Lot Item(s): 48

==

Description:==

During the March 2007 meeting, it was not clear to attendees if the current fire modeling was properly accounting for environmental considerations for other equipment in a fire-impacted compartment. The fire modeling accounts for sources and targets and zones of influence (ZOI), but it is not clear if other equipment outside of the ZOI, which could be impacted from fire secondary effects (e.g., smoke and temperature), is being addressed in the fire modeling being conducted as part of the NFPA 805 transition.

Resolution Action(s)/Action Party: OPEN. Industry will provide clarification on the issue.

Associated FAQ: 07-0037 Lesson Learned: Pending final resolution of this issue.

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NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 34 Topic: Multiple spurious operation (MSO) expert elicitation guidance.

Associated Observation Meeting Parking Lot Item(s): 1, 50, 53

==

Description:==

During the March 2007 meeting, comparison of methods used by plants to conduct MSO expert elicitation highlighted the need for standardized guidance. There is not currently a single standard to which to hold an expert elicitation as part of bounding the MSO possibilities. Both of the pilot-plants have pursued acquiring expert opinions on the subject as part of their NFPA 805 efforts. An industry standard and/or guidance is needed on the process and criteria for establishing important MSO possibilities as well as how to handle and process the knowledge that is gained at such elicitation meetings.

Resolution Action(s)/Action Party: OPEN. Industry will revise NEI 04-02 to incorporate the lessons-learned from the pilot-plant expert panels.

Associated FAQ: 07-0038 Lesson Learned: Pending final resolution of this issue.

39 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 35 Topic: Potential coordination issues between License Renewal Application (LRA) and NFPA 805 transitions (License Amendment Request [LAR])

Associated Observation Meeting Parking Lot Item(s): 52

==

Description:==

During the March 2007 meeting the Harris Nuclear Plant (HNP) noted its LRA will be reviewed between 10/08 - 06/09. The current schedule for the NFPA 805 LAR is for submittal in 06/08 with review through 12/08. An LRA locks down a license (i.e., an LAR would not be considered prior to approval of a submitted LRA. This scheduling conflict has not been resolved for HNP.

Resolution Action(s)/Action Party: CLOSED. Plants must coordinate their LAR and LRA submittals Associated FAQ: None Lesson Learned: There are potential coordination issues between LRA and NFPA 805 transitions LAR that must be resolved between plants and the NRC.

40 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 36 Topic: NUREG/CR 6850 Kerite FR listed temperature Associated Observation Meeting Parking Lot Item(s): 49

==

Description:==

NUREG/CR 6850 Table H 3 and H 4 incorrectly list the Kerite failure temperatures as being between 372 C -382°C with a Recommended Failure Threshold of 372°C. The recommended Failure Threshold for Kerite should be 237°C.

Resolution Action(s)/Action Party: OPEN. NRC to issue an errata/revision for the NUREG/CR Associated FAQ: None Lesson Learned: . Pending final resolution of this issue.

41 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 37 Topic: Consistent use of pre-defined definitions Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

NFPA 805, NEI 04 02, and NUREG/CR 6850 all contain specialized language and definitions. It is important that as plants develop procedures and documentation for this effort that they use the definitions and language from the references. This ensures their procedures are consistent with the accepted guidance (and thus also helps reduce review comments). There is no need to word smith or invent new phrases, definitions, and language.

Resolution Action(s)/Action Party: CLOSED. No action required Associated FAQ: None Lesson Learned: Use of standardized definitions and languages from project references ensures consistency and enhances reviewability.

42 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 38 Topic: Define Fire Protection Engineering Analysis (FPEA)

Associated Observation Meeting Parking Lot Item(s): 41

==

Description:==

Part of the industries proposed FAQ 06-0008 and 07-0033 resolution includes FPEAs.

Resolution Action(s)/Action Party: OPEN. Industry will provide clarification on the issue.

Associated FAQ: 06-0008, 07-0033.

Lesson Learned: Pending final resolution of this issue.

43 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 39 Topic: Source and Target Database Associated Observation Meeting Parking Lot Item(s): 51

==

Description:==

Progress Energy developed a database as part of the NUREG/CR 6850 Task 8 efforts that records source and target information for later use in the fire modeling and Fire PRA.

HNP offered to share the tool with interested non-pilot transition plants Resolution Action(s)/Action Party: CLOSED. HNP is willing to share this database with interested organizations.

Associated FAQ: None.

Lesson Learned: HNP is will to share its fire source and target database with interested organizations.

44 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 40 Topic: Crediting Outdated SER Exclusions and/or Exemptions Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

During the May 2007 meeting, discussions indicated the licensee plans to bring forward existing SER exclusions and/or exemptions that, while acceptable when issued, are now seen as outdated. For the risk-based reviews, expectations are that this would not be an issue; however, for the deterministic reviews the staff expects to question these types of issues, while the licensees position appears to be that, if a condition is currently acceptable, it will be acceptable post-transition. The staff suggested to the plants that they not try to bring forward outdated SER exclusions and/or exemptions as part of their deterministic post-transition basis (thereby rendering the question moot), as staff reviewers will question these if they are based on outdated premises.

Resolution Action(s)/Action Party: CLOSED. The staff will question the legitimacy of existing SER exclusions and/or exemptions that are brought forward if their underlying basis is no longer an accepted practice or condition.

Associated FAQ: None.

Lesson Learned: Plants can expect to be questioned and required to defend SER exclusions and/or exemptions brought forward as part of the transition that appear to be based on now outdated premises.

45 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 41 Topic: Limited LP/SD Risk Review Associated Observation Meeting Parking Lot Item(s): None

==

Description:==

During the May 2007 meeting, discussions indicated pilot plants do not expect to consider fire and fire effects when first defining the high risk evolutions (HREs) used as part of a Low Power/Shutdown (LP/SD) review. The staff expressed concern that this approach would allow the screening of potentially significant fire-induced HREs, should fire or fire effects be ignored in the development of these HREs.

Pilot-plants interpret NEI 04-02 as not requiring this level of examination, while the staff noted that, in order to meet the requirements of 10 CFR 50.65(a)(4), some sort of risk assessment, at least bounding quantitative, be performed on all LP/SD configurations with regard to potential fires and fire effects. Per the staffs initial understanding and the fact that licensees are not planning on developing LP/SD fire PRAs at this time, an enhanced qualitative approach (at least as a surrogate for bounding quantitative) is deemed acceptable.

The prime reason for the staff concern is that, unlike the at-power operational mode analysis, there is a lack of a blue box (fire PRA) assurance that potentially risky items within the red box (deterministic analysis) will be identified for disposition during LP/SD. Due to this lack, apparently permitted by NFPA-805s non-requirement that fire PRA be performed for all plant modes, including LP/SD, the staff must rely on the licensees red box analyses to provide the assurance that potentially risky items will be identified and properly dispositioned during LP/SD. As NEI 04-02 is apparently being currently interpreted, the staff is not assured that this safety valve is in place.

Resolution Action(s)/Action Party: OPEN. NRC will examine this issue and lead further discussion at a future pilot-plant meeting.

Associated FAQ: None.

Lesson Learned: Pending final resolution of this issue 46 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 42 Topic: NEI 04-02, Appendix B, Table B-1, B-2, B-3 Template improvements Associated Observation Meeting Parking Lot Item(s): 55

==

Description:==

During the May 2007 meeting, the pilot-plants demonstrated specific enhancements to NEI 04-02, Appendix B, Tables B-1, B-2, and B-3 that should be incorporated into NEI 04-02.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQ, NEI will propose changes to NEI 04-02, Appendix B, Tables B-1, B-2, and B-3 based on pilot-plant experience.

Associated FAQ: 07-0039 planned but not yet submitted.

Lesson Learned: The plants have substantially refined the tables of NEI 04-02 Appendix B.

Non-pilot-plants will benefit from the lessons learned by the pilot-plants in their use of these tables.

47 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 43 Topic: NEI 04-02 Table B-3 Binning Information Associated Observation Meeting Parking Lot Item(s): 3, 58

==

Description:==

During the May 2007 meeting, it was noted that standardized language/binning is required to ensure consistency between plants in their use of NEI 04-02, Table B 3.

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQ, NEI will update NEI 04-02 to include standardized binning language.

Associated FAQ: 06-0012.

Lesson Learned: Standardized binning language for use with NEI 04-02, Table B-3, will enhance reviewability.

48 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 44 Topic: Extension of existing HRA scenarios Associated Observation Meeting Parking Lot Item(s): 36, 59

==

Description:==

During the May 2007 meeting, discussions indicated an update to NEI 04-02 is warranted to include extension of existing HRA scenarios to address fire initiators and manual actions (both preventative and reactive).

Resolution Action(s)/Action Party: OPEN. Pending approval of FAQ, NEI will propose to include these changes as part of an existing planned FAQ (07-0030).

Associated FAQ: 07-0030 Lesson Learned: To be determined based on the resolution of FAQ 07-0030.

49 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 45 Topic: Use of existing Configuration Management and Document Control systems in the NFPA 805 project Associated Observation Meeting Parking Lot Item(s): NA

==

Description:==

During the July 2007 meeting, discussions indicated lessons learned from Table B-1 efforts include keeping relevant documents in one place, providing searchable indices to documents, integrating them with the existing document and configuration management system, and developing a good program document that comprehensively references and summarizes the Fire Protection Program.

Resolution Action(s)/Action Party: CLOSED. Lesson-Learned by Pilot Plants Associated FAQ: None Lesson Learned: Non-pilot plants will benefit from the lessons learned by the pilot plants to integrate their NFPA 805 transition information into their existing document management and configuration control systems.

50 -

NFPA 805 Pilot-Plant Implementation Issue Summary Sheet No. 46 Topic: Impact of new ANS Fire PRA Standard requirements for instrumentation related to operator actions in the PRA.

Associated Observation Meeting Parking Lot Item(s): 61

==

Description:==

During the July 2007 meeting, discussions indicated new instrumentation requirements are included in the ANS Fire PRA standard. The impact and resolution of this issue with regard to a Fire PRA used for NFPA 805 transition is not clear.

Resolution Action(s)/Action Party: OPEN. Pending submittal and approval of FAQ.

Associated FAQ: FAQ planned but not yet submitted.

Lesson Learned: Pending final resolution of this issue 51 -

Attachment 6 to the Trip Report Pilot Plant Observation Visit July 10 - 13, 2007

• Issue Summary Sheet: The Issue Summary Sheets provide additional information, clarification, and detail about pilot plant identified issues and lessons learned to the non-pilot licensees and other interested parties

• Associated Parking Lot Item: The NRC and Industry use the Parking Lot table to track the resolution status of issues identified during visits presentations and related discussions

• Associated FAQ: The NRC and Industry use the Frequently Asked Question (FAQ) Process to develop NRC staff interpretations and clarifications of NEI 04-02 guidance and NFPA 805 requirements.

NFPA 805 Transition Observation Visit July 10 - 13, 2007 Summary of Issue Identification and Resolution No. Issue Summary Sheet (Status) Associated Parking Lot Item (Status) Associated FAQ (Status) 1 Multiple Spurious Operation (MSO) - Treatment of Newly Identified MSO in 1 (open) Planned ROP Prior to Risk Significance Determination (open) 2 Multiple Spurious Operations - Screening Criteria (closed) 2 (closed) None 3 Transition of Operator Manual Actions to NFPA 805 Recovery Actions 3 (closed to FAQs) FAQ 06-0001 (closed)

(closed) FAQ 06-0012 (closed) 4 Spurious Operations - Risk Informed, Performance-based Treatment of 4 (closed to FAQ) FAQ 06-0006 (closed)

High/Low Pressure Interface Components (closed) 5 Fire PSA Peer Review (open) 5 (closed), 20 (closed), 37 (closed) None 6 PSA and Change Evaluations for Low-Power/Shutdown Modes (open) 6 (closed), 22 (open) Planned 7 NFPA 805 Chapter 3 - Chapter 4 Related Requirements (open) 7 (closed to FAQ) FAQ 06-0004 (open) 8 (closed to FAQ) FAQ 06-0002 (closed) 9 (closed) 8 Performance-based Alternative for Fire Area Boundary Evaluation (open) 10 (closed to FAQ) FAQ 06-0008 (open)

FAQ 07-0033 (open) 9 Plant Change Evaluations - Preliminary Risk Screening (closed) 11 (closed) None 10 Plant Change Evaluations - Preliminary Screening Criteria and Form 12 (closed to FAQ) FAQ 06-0003 (closed)

Corrections (closed) 11 Plant Change Evaluation - PSA Engineer Reviews of Screens (closed) 13 (closed) None 12 Authority Having Jurisdiction - NFPA Code Deviations (closed) 14 (closed) None 13 Transition Baseline Risk (open) 19 (closed to FAQ) FAQ 06-0005 (open) 24 (closed to FAQ) FAQ 06-0014 (to be submitted) 14 Regulatory Position on Interim Guidance Changes (closed) 16 (closed) None 1 -

NFPA 805 Transition Observation Visit July 10 - 13, 2007 Summary of Issue Identification and Resolution No. Issue Summary Sheet (Status) Associated Parking Lot Item (Status) Associated FAQ (Status) 15 Circuit Analysis Generic Letter and RIS - Compliance Issues for Transition 17 (closed) None (closed) 16 NEI 04-02, Appendix B, Methodology Changes (open) 18 (closed to FAQ) FAQ 06-0013 (to be submitted) 17 Risk Acceptance Thresholds (open) 21 (open) Planned 18 Definition for Fire Protection Program Change (open) 23 (closed to FAQ) FAQ 06-0005 (open) 19 Tracking of Cumulative Risk from Post - Transition Plant Changes (open) 15 (closed to FAQ) FAQ 06-0010 (to be submitted) 24 (closed to FAQ) FAQ 06-0014 (to be submitted) 20 Fire Zones/Compartment Definitions (closed) 25 (closed) None 21 Ignition Frequency Binning Issues (open) 26 (closed to FAQ) FAQ 06-0018 (closed) 27 (closed to FAQ) FAQ 06-0016 (closed) 28 (closed to FAQ) FAQ 06-0017 (closed) 29 (closed to FAQ) FAQ 07-0031 (open)

FAQ 07-0035 (open) 22 Transition and Post-Transition Program Management (open) 30 (closed to FAQ) FAQ 07-0032 (open) 23 New Requirements in NFPA Chapter 3/Table B-1 Issues (closed) 32 (closed), 33 (closed) 34 (closed to FAQ) FAQ 06-0022 (open) 24 Assessing Risk of Recovery Actions (open) 35 (closed to FAQ) FAQ 06-0011 (open) 36 (closed to FAQ) FAQ 07-0030 (to be submitted) 25 Mapping Efforts to 10 CRF 50.48(a) Requirements (open) None FAQ 07-0032 (open) 26 Clarify Existing Engineering Equivalency Evaluations Guidance (open) 43 (closed to FAQ) FAQ 07-0033 (open) 27 Properly Accounting for Kerite Cables Impacts on Targets within a Zone of None None Influence (closed) 28 Define Boundary with Respect to the Counting of Fire Ignition Sources 45 (closed) None (closed) 29 Transformer Threshold (open) 46 (closed to FAQ) FAQ 07-0031 (open) 30 Modular Accident Analysis Program Versus Reactor Excursion and Leak None None Analysis Program for Review of Thermal-Hydraulic Success Criteria (closed) 31 Screening Ignition Sources (NUREG/CR 6850 Task 8) (closed) None None 32 Difference in Fire Modeling Between NUREG/CR 6850 and the Fire Protection 47 (closed) None Significance Determination Process (closed) 33 Environmental Qualification Considerations for Other Equipment in Fire 48 (open) Planned Affected Compartments (open) 34 Multiple Spurious Operation Expert Elicitation Guidance (open) 1 (open) Planned 50 (closed) 53 (closed) FAQ 07-0038 (open) 35 Potential Coordination Issues Between License Renewal Application and 52 (open) None NFPA 805 Transitions (License Amendment Request) (closed) 36 NUREG/CR 6850 Kerite FR Listed Temperature (open) 49 (open) None 37 Consistent Use of Pre-defined Definitions (closed) None None 2 -

NFPA 805 Transition Observation Visit July 10 - 13, 2007 Summary of Issue Identification and Resolution No. Issue Summary Sheet (Status) Associated Parking Lot Item (Status) Associated FAQ (Status) 38 Define Fire Protection Engineering Analysis (open) 41 (closed to FAQs) FAQ 06-0008 (open) and FAQ 07-0033 (open) 39 Source and Target Database (closed) 51 (closed) None 40 Applicability of Licensees Current Licensing Basis to New NFPA 805 None None Licensing Basis (closed) 41 Limited LP/AD Risk Review (open) None None 42 NEI 04-02, Appendix B, Table B-1, B-2, B-3 Template Improvements (open) 55 (open) Planned 43 NEI 04-02 Table B-3 Binning Information (open) 3 (closed to FAQs 06-0001 & 06-0012) FAQ 06-0001 (closed) 58 (closed to FAQ 06-0012) FAQ 06-0012 (closed) 44 Extension of Existing HRA Scenarios (open) 36 (closed to FAQ) FAQ 07-0030 (open) 59 (included in FAQ 07-0030) 45 Use of existing Configuration Management and Document Control systems in None None the NFPA 805 project (closed) 46 Impact of new ANS Fire PRA standard requirements for instrumentation 61 (open) Planned related to operator actions in the PRA (open).

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