NEI 04-02, August 2007 - Transition to National Fire Protection Association (NFPA) 805 - NEI 04-02 FAQs Pathway to Resolution - Progress Energy - Briefing Materials/Meeting Handouts

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August 2007 - Transition to National Fire Protection Association (NFPA) 805 - NEI 04-02 FAQs Pathway to Resolution - Progress Energy - Briefing Materials/Meeting Handouts
ML072780138
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Site: Harris Duke Energy icon.png
Issue date: 08/06/2007
From: Ertman J
Nuclear Generation Group, Progress Energy Co
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Office of Nuclear Reactor Regulation
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NEI 04-02
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Page 1 NEI 04-02 Frequently Asked Questions Pathway to ResolutionJeff Ertman August 6, 2007 Page 2 Frequently Asked Questions (FAQ)

Status as of August '07 11FAQsw/ NEI 805 Task Force for Review / Resolution 10FAQsw/ NRC for Review / Resolution 18Total FAQsResolved or Withdrawn 39Total FAQsGenerated Page 3FAQsunder Development and T.F. Review FAQ 06-0004(Began / Miskiewicz)PurposeClarify NFPA 805, Chapter 3 & 4 relationship for "required" FP Systems and Features.Resolution PlanHow fire protection systems and features transition is highly dependent their requirements to meet nuclear safety performance criteria of NFPA 805, Chapter 4.Proposed categorization of systems by use in program analysis:NFPA 805 credited: B-3, Defense-in-Depth, Change EvaluationNot NFPA 805 credited: Other FP systems in PRA -subject to PRA change process / cyclic update processNFPA 805 Credited systems clearly identified in FSA -new CLBMonitoring process addressed separate from this FAQ ScheduleExpect to submit Rev. 1, 2007 3 rdQuarter.

Page 4FAQsunder Development and T.F. Review FAQ 06-0009 (Kleinsorg)Purpose Administrative correction of typo-graphical errors noted in NEI 04-02, Rev 1. Resolution Plan Placeholder for editorial corre ctions to be submitted in NEI 04-02, Rev. 2 ScheduleExpect to submit FAQ Rev. 0, January 2008 Page 5FAQsunder Development and T.F. Review FAQ 06-0010(Ertman/Ratchford)Purpose Incorporate Regulatory Gu ide 1.205 Baseline concept into NEI 04-02. Resolution Plan Changes to Reg. Guide 1.205, NEI 04-02 indicate

need to reflect baseline risk. Will update NEI 04-02 with baseline risk, baseline compliance discussion fr om Oconee Pilot meeting Schedule Expect to submit Rev. 0, 2007, 3 rd Quarter Page 6FAQsunder Development and T.F. Review FAQ 06-0014(Miskiewicz)PurposeCumulative Risk Resolution Plan Reg. Guide 1.205 requires tracking of changes to assess cumulative risk.FAQ currently with Progress Energy for development. Schedule Expect to submit Rev.

0, in September, 2007 Page 7FAQsunder Development and T.F. Review FAQ 06-0015(Masterlark)Purpose Guidance on "Not Red" determination Resolution Plan Process needs simplifica tion for determining if non-compliances found during t he transition process are "Not Red". Schedule Expect to submit Rev. 0, 2007, 3 rd Quarter Page 8FAQsunder Development and T.F. Review FAQ 06-0022(Puckett -ANO)Purpose Identify a list of flame propa gation tests which will be considered acceptable dur ing NFPA 805, Chapter 3 reviews. Resolution Plan Review and incorporation of NRC Office of Research listing of acceptable tests.NEI Task Force to provide updated revision. ScheduleExpect to resubmit to NRC staff by 8-23-07.

Page 9FAQsunder Development and T.F. Review FAQ 06-0024(Holder)Purpose Define "adequate clearance" and "energized electrical equipment" as applied in NFPA 805 Chapter 3. Resolution Plan Provide "process" for determining adequate clearance rather than a s patial parameter. ScheduleExpect to resubmit to Task Force by 8-10-07, and NRC staff by 8-23-07.

Page 10FAQsunder Development and T.F. Review FAQ 07-0030(Masterlark)PurposeDefine Risk of Recovery Actions Resolution Plan Clarification is needed for evaluating the risk impact of recovery actions, including HRA scenarios, when

these actions result in the use of a performance based approach as described in NFPA 805, Section 4.2.4. Schedule Expect to submit Rev. 0, 2007, 3 rd Quarter Page 11FAQsunder Development and T.F. Review FAQ-07-0034(Miskiewicz)PurposeClarification for treatment of non-vented electrical cabinets. Resolution Plan Provide new attachment on interpretation issues fro

NEI 04-02. Schedule Expect to submit Rev. 0, to Task Force 8-13-07, and to NRC staff by 8-23-07.

Page 12FAQsunder Development and T.F. Review FAQ 07-0038 (Began)Purpose Lessons Learned for Operator Manual Actions (OMA), Multiple Spurious Operat ions (MSO) and Fire PRA (FPRA). Resolution Plan Incorporate pilot plant lessons learned into NEI 04-02, Rev 2. Schedule Expect to submit Rev. 0, to Task Force by end of August, 2007.

Page 13FAQsunder Development and T.F. Review FAQ 07-0039 (Ratchford)Purpose Update of NEI 04-02, Rev. 1, Tabl es B-2 and B-3 and associated process. Resolution Plan Incorporate lessons learned from Pilot Plants during Tables B-2 and B-3 development, into NEI 04-02, Rev 2 . Schedule Expect submittal to NEI Task Force 8-23-07.

Page 14FAQscurrently with NRC for Review FAQ 06-0005, R1 Purpose Guidance on FPP related changes. Resolution Plan NEI 04-02 does not provide guidance for what should be considered a FPP-relat ed change or not. Since failure to obtain NRC pre-approval for using risk reductions from a non-FPP related change would be contrary to the guidance in RG 1.205, additional guidance should be provided to clarify what is considered a FPP-related change once NFPA-805 is implemented. Schedule NRC has indicated expectation for closure by 9-30-07 Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 15FAQscurrently with NRC for Review FAQ 06-0008, R5 PurposeAlternate Method for Engineering Evaluations Resolution Plan Many Generic Letter 86-10 evaluations exist at facilities today. Transition of these existing evaluations is essential for the success of the Pilot Plants. In addition the use of engine ering evaluations for Chapter 3 issues post transition needs to be clarified. Schedule TF preparing draft Rev 6, based on feedback, for submittal to NRC. NRC has indicated expectation for closure by 9-30-07. Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 16FAQscurrently with NRC for Review FAQ 06-0011, R1bPurpose Clarify 10CFR50, Appendix R, Section III.G.3 Compliance Transition Resolution Plan Provide specific details to address Alternate Shutdown in NEI 04-02. ScheduleNRC has indicated expectation for issuance of

comments by 8-23-07, and closure by 9-30-07. Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 17FAQscurrently with NRC for Review FAQ 06-0019, R1Purpose Define "Power Block" and "Plant" Resolution Plan Define where used in Chapter 3, "power block" and "plant" are intended to mean "areas in which a fire could jeopardize the ability to meet the nuclear safety performance criteria descr ibed in section 1.5." NRC has indicated concern ed about "broadness" of definition (e.g., Turbine building may not be included in this definition). ScheduleNRC anticipates issuance of additional comments. Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 18FAQscurrently with NRC for Review FAQ 06-0027, R0Purpose Clarify the descriptive term "where provided" in NFPA 805, Chapter 3. Resolution Plan Clarify the term "where provided" to be those locations

that exist at present as part of the des ign, or as documented through a Code Compliance review document, or lacking same in accordance with applicable NFPA code. Schedule Expect resolution for inclusion in NEI 04-02, Rev. 2.

Page 19FAQscurrently with NRC for Review FAQ 06-0031, R0Purpose Miscellaneous Binning Issues Resolution Plan Questions arise during ig nition frequency counting, such as which bins are appr opriate for: MOV motors, Hydraulic actuators for valves, Transformers. Schedule With NRC Office of Research Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 20FAQscurrently with NRC for Review FAQ 06-0032, R0Purpose 10CFR50.48(a) and GDC 3 clarification Resolution Plan Clarify language in NEI 04-02, to reference or restate the guidance found in Federal Register Notice 69 FR

33536, such that satisfying 10CFR50.48(c) will satisfy 10CFR50.48(a) and GDC 3. Schedule Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 21FAQscurrently with NRC for Review FAQ 06-0033, R0PurposeReview of Existing En gineering Equivalency Evaluations (EEEEs) Resolution Plan Describes how EEEEswill be reviewed and

summarized for transition. Schedule Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 22FAQscurrently with NRC for Review FAQ 06-0035, R0Purpose Bus Duct counting guidance for High Energy Arcing Faults Resolution Plan Split from original FAQ 06-0017, to only address method for counting Bus Ducts. ScheduleNRC to discuss in panel meeting 8-17-07 Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 23FAQscurrently with NRC for Review FAQ 06-0036, R0Purpose Provide definitions of "compliance categories" used during development of NEI 04-02, Table B-1. Resolution Plan Revise sections 4.3.1 and Table B-1 of NEI 04-02 based on feedback from pilot plants observation meeting reviews of draft Table B-1 products. Schedule Expect resolution for inclusion in NEI 04-02, Rev. 2 Page 24 What's Next?

NEI 04-02, Revision 2 FAQ proposed cut-off date, September 2007FAQsto be incorporated need approval by January 2008 NEI 04-02, Revision 2 needs approval to support

May 2008 License Amendment Request (LAR)

submittals from Pilot Plants. Follow-up Regulatory Guide revision providing endorsement.

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