ML072780138
| ML072780138 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/06/2007 |
| From: | Ertman J Nuclear Generation Group, Progress Energy Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML072830337 | List:
|
| References | |
| NEI 04-02 | |
| Download: ML072780138 (24) | |
Text
Page 1 NEI 04-02 Frequently Asked Questions Pathway to Resolution Jeff Ertman August 6, 2007
Page 2 Frequently Asked Questions (FAQ)
Status as of August 07 11 FAQs w/ NEI 805 Task Force for Review / Resolution 10 FAQs w/ NRC for Review /
Resolution 18 Total FAQs Resolved or Withdrawn 39 Total FAQs Generated
Page 3 FAQs under Development and T.F. Review FAQ 06-0004 (Began / Miskiewicz)
O Purpose Z Clarify NFPA 805, Chapter 3 & 4 relationship for required FP Systems and Features.
O Resolution Plan Z How fire protection systems and features transition is highly dependent their requirements to meet nuclear safety performance criteria of NFPA 805, Chapter 4.
Z Proposed categorization of systems by use in program analysis:
X NFPA 805 credited: B-3, Defense-in-Depth, Change Evaluation X Not NFPA 805 credited: Other FP systems in PRA - subject to PRA change process / cyclic update process Z NFPA 805 Credited systems clearly identified in FSA - new CLB Z Monitoring process addressed separate from this FAQ O Schedule Z Expect to submit Rev. 1, 2007 3rd Quarter.
Page 4 FAQs under Development and T.F. Review FAQ 06-0009 (Kleinsorg)
O Purpose Z Administrative correction of typo-graphical errors noted in NEI 04-02, Rev 1.
O Resolution Plan Z Placeholder for editorial corrections to be submitted in NEI 04-02, Rev. 2 O Schedule Z Expect to submit FAQ Rev. 0, January 2008
Page 5 FAQs under Development and T.F. Review FAQ 06-0010 (Ertman/Ratchford)
O Purpose Z Incorporate Regulatory Guide 1.205 Baseline concept into NEI 04-02.
O Resolution Plan Z Changes to Reg. Guide 1.205, NEI 04-02 indicate need to reflect baseline risk.
Z Will update NEI 04-02 with baseline risk, baseline compliance discussion from Oconee Pilot meeting O Schedule Z Expect to submit Rev. 0, 2007, 3rd Quarter
Page 6 FAQs under Development and T.F. Review FAQ 06-0014 (Miskiewicz)
O Purpose Z Cumulative Risk O Resolution Plan Z Reg. Guide 1.205 requires tracking of changes to assess cumulative risk.
Z FAQ currently with Progress Energy for development.
O Schedule Z Expect to submit Rev. 0, in September, 2007
Page 7 FAQs under Development and T.F. Review FAQ 06-0015 (Masterlark)
O Purpose Z Guidance on Not Red determination O Resolution Plan Z Process needs simplification for determining if non-compliances found during the transition process are Not Red.
O Schedule Z Expect to submit Rev. 0, 2007, 3rd Quarter
Page 8 FAQs under Development and T.F. Review FAQ 06-0022 (Puckett - ANO)
O Purpose Z Identify a list of flame propagation tests which will be considered acceptable during NFPA 805, Chapter 3 reviews.
O Resolution Plan Z Review and incorporation of NRC Office of Research listing of acceptable tests.
Z NEI Task Force to provide updated revision.
O Schedule Z Expect to resubmit to NRC staff by 8-23-07.
Page 9 FAQs under Development and T.F. Review FAQ 06-0024 (Holder)
O Purpose Z Define adequate clearance and energized electrical equipment as applied in NFPA 805 Chapter 3.
O Resolution Plan Z Provide process for determining adequate clearance rather than a spatial parameter.
O Schedule Z Expect to resubmit to Task Force by 8-10-07, and NRC staff by 8-23-07.
Page 10 FAQs under Development and T.F. Review FAQ 07-0030 (Masterlark)
O Purpose Z Define Risk of Recovery Actions O Resolution Plan Z 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.
O Schedule Z Expect to submit Rev. 0, 2007, 3rd Quarter
Page 11 FAQs under Development and T.F. Review FAQ-07-0034 (Miskiewicz)
O Purpose Z Clarification for treatment of non-vented electrical cabinets.
O Resolution Plan Z Provide new attachment on interpretation issues fro NEI 04-02.
O Schedule Z Expect to submit Rev. 0, to Task Force 8-13-07, and to NRC staff by 8-23-07.
Page 12 FAQs under Development and T.F. Review FAQ 07-0038 (Began)
O Purpose Z Lessons Learned for Operator Manual Actions (OMA),
Multiple Spurious Operations (MSO) and Fire PRA (FPRA).
O Resolution Plan Z Incorporate pilot plant lessons learned into NEI 04-02, Rev 2.
O Schedule Z Expect to submit Rev. 0, to Task Force by end of August, 2007.
Page 13 FAQs under Development and T.F. Review FAQ 07-0039 (Ratchford)
O Purpose Z Update of NEI 04-02, Rev. 1, Tables B-2 and B-3 and associated process.
O Resolution Plan Z Incorporate lessons learned from Pilot Plants during Tables B-2 and B-3 development, into NEI 04-02, Rev 2.
O Schedule Z Expect submittal to NEI Task Force 8-23-07.
Page 14 FAQs currently with NRC for Review FAQ 06-0005, R1 O Purpose Z Guidance on FPP related changes.
O Resolution Plan Z NEI 04-02 does not provide guidance for what should be considered a FPP-related change or not. Since failure to obtain NRC pre-approval for using risk reductions from a non-FPP related change would be contrary to the guidance in RG 1.205, additional guidance should be provided to clarify what is considered a FPP-related change once NFPA-805 is implemented.
O Schedule Z NRC has indicated expectation for closure by 9-30-07 Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 15 FAQs currently with NRC for Review FAQ 06-0008, R5 O Purpose Z Alternate Method for Engineering Evaluations O Resolution Plan Z Many Generic Letter 86-10 evaluations exist at facilities today. Transition of these existing evaluations is essential for the success of the Pilot Plants. In addition the use of engineering evaluations for Chapter 3 issues post transition needs to be clarified.
O Schedule Z TF preparing draft Rev 6, based on feedback, for submittal to NRC.
Z NRC has indicated expectation for closure by 9-30-07.
Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 16 FAQs currently with NRC for Review FAQ 06-0011, R1b O Purpose Z Clarify 10CFR50, Appendix R, Section III.G.3 Compliance Transition O Resolution Plan Z Provide specific details to address Alternate Shutdown in NEI 04-02.
O Schedule Z NRC has indicated expectation for issuance of comments by 8-23-07, and closure by 9-30-07.
Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 17 FAQs currently with NRC for Review FAQ 06-0019, R1 O Purpose Z Define Power Block and Plant O Resolution Plan Z 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 described in section 1.5.
Z NRC has indicated concerned about broadness of definition (e.g., Turbine building may not be included in this definition).
O Schedule Z NRC anticipates issuance of additional comments.
Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 18 FAQs currently with NRC for Review FAQ 06-0027, R0 O Purpose Z Clarify the descriptive term where provided in NFPA 805, Chapter 3.
O Resolution Plan Z Clarify the term where provided to be those locations that exist at present as part of the design, or as documented through a Code Compliance review document, or lacking same in accordance with applicable NFPA code.
O Schedule Z Expect resolution for inclusion in NEI 04-02, Rev. 2.
Page 19 FAQs currently with NRC for Review FAQ 06-0031, R0 O Purpose Z Miscellaneous Binning Issues O Resolution Plan Z Questions arise during ignition frequency counting, such as which bins are appropriate for: MOV motors, Hydraulic actuators for valves, Transformers.
O Schedule Z With NRC Office of Research Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 20 FAQs currently with NRC for Review FAQ 06-0032, R0 O Purpose Z 10CFR50.48(a) and GDC 3 clarification O Resolution Plan Z 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.
O Schedule Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 21 FAQs currently with NRC for Review FAQ 06-0033, R0 O Purpose Z Review of Existing Engineering Equivalency Evaluations (EEEEs)
O Resolution Plan Z Describes how EEEEs will be reviewed and summarized for transition.
O Schedule Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 22 FAQs currently with NRC for Review FAQ 06-0035, R0 O Purpose Z Bus Duct counting guidance for High Energy Arcing Faults O Resolution Plan Z Split from original FAQ 06-0017, to only address method for counting Bus Ducts.
O Schedule Z NRC to discuss in panel meeting 8-17-07 Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 23 FAQs currently with NRC for Review FAQ 06-0036, R0 O Purpose Z Provide definitions of compliance categories used during development of NEI 04-02, Table B-1.
O Resolution Plan Z 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.
O Schedule Z Expect resolution for inclusion in NEI 04-02, Rev. 2
Page 24 Whats Next?
NEI 04-02, Revision 2 O FAQ proposed cut-off date, September 2007 O FAQs to be incorporated need approval by January 2008 O NEI 04-02, Revision 2 needs approval to support May 2008 License Amendment Request (LAR) submittals from Pilot Plants.
O Follow-up Regulatory Guide revision providing endorsement.