ML080280365
| ML080280365 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/07/2008 |
| From: | Ertman J Progress Energy Co |
| To: | Office of Nuclear Reactor Regulation |
| d. oudinot | |
| References | |
| Download: ML080280365 (26) | |
Text
Page 1 Harris Nuclear Plant NFPA 805 Transition License Amendment Request /
Transition Report Jeff Ertman, Progress Energy January 7, 2008 Raleigh, NC
Page 2 HNP LAR / Transition Report O Focus on Submittal O Outline of LAR / Transition Report Specifically focus on issues requiring resolution O Contents of SER
Page 3 Transition Report / LAR Focus on Submittal?
O What level of detail is necessary in the LAR and Transition Report?
Z Will the Transition Report be an attachment, enclosure, submittal, etc.? Using NEI 06-02 as a model, the Transition Report could be used to document all supporting information Z What information, if any, needs to be duplicated in both the LAR and Transition Report?
O How does the previous Licensing Basis get superseded (any key differences between pre and post-1979 plants i.e.,
exemption/SER vs. deviation/SER?).
O What information from the LAR and Transition Report will become living documents (e.g., FSA, UFSAR, etc.)? And how will that be conveyed to inspectors post transition?
Page 4 LAR / Transition Report (TR)
Submittal Topics O FP License Condition O Other License Condition O Technical Specifications O Orders & Exemptions O Use of RI-PB Methods for NFPA 805 Ch. 3 Compliance 10 CFR 50.48(c)(2)(vii)
O Use of RI-PB Alternatives 10 CFR 50.48(c)(4) (non-NFPA 805 methods)
O Risk Impact for Transition O UFSAR Changes O Modifications
Page 5 LAR / Transition Report (TR)
Submittal Topics Continued O Clarification of Prior NRC Approvals O EEEEs O Circuit Analysis Methodology (MSO Resolution)
O OMA transition to Recovery Actions O Power Block Definition O No Significant Hazards Consideration Finding O Categorical Exclusion Finding O Role of the FAQs O FPRA Review High Level Findings and Resolutions O Transition Schedule
Page 6 FP License Condition (TR Attachment M)
O Content Z Standard License Condition from RG 1.205 Z Supplemented by FAQ 06-0008 Info O Process Z Request Replacement of current license condition with RG 1.205 license condition as modified by FAQ 06-008 O Issues Requiring Resolution Z Should we combine the revocation/replacement of the standard fire protection license into Attachment A?
Attachment B would address other license conditions.
Z How do we ensure that All prior fire protection SERs and commitments are superceded by the issuance of the new license condition?
Page 7 FP License Condition (TR Attachment M)
O Suggested Resolution Z List all SER Sections that contain fire protection commitments in the Transition Report Section 2.1 Z List all the submittals made to support those SERs in the Transition Report Section 2.2 Z Since this represents the approved fire protection program any other commitments can clearly be superceded by this new license condition and do not need to be individually listed.
Z Any prior approvals necessary will be documented in the Transition Tables (B-1, B-2, B-3, etc) with enough information to be stand alone and therefore the previous documentation can be superseded.
Page 8 Other License Conditions (TR Attachment M)
O Content Z Currently no other license conditions require revocation/revision O Process Z Review Operating License for any other conditions that may require revision or revocation Z Request revocation / revision of other license conditions O Issues Requiring Resolution Z None
Page 9 Technical Specifications (TR Attachment N)
O Content Z All administrative / audit technical specifications should be revoked Z Remaining equipment technical specifications should be revised as necessary to ensure they are consistent with 10 CFR 50.48(c)
O Process Z Review Tech Specs / Bases for fire protection related items, for example:
X Administrative Requirements X Remote Shutdown X FP Audits Z Request revocation of FP Audits and Administrative Requirements since these are requirements of 10 CFR 50.48(c)
Z Revision to Tech Spec Bases for Remote Shutdown Capability can be changed using 10 CFR 50.59 process O Issues Requiring Resolution Z NRC concurrence with plans for technical specification revisions
Page 10 Orders & Exemptions (TR Attachment O)
O Content Z All orders and exemptions should be revoked Z Remaining equipment technical specifications should be revised as necessary to ensure they are consistent with 10 CFR 50.48(c)
O Process Z Review orders and exemptions for fire protection Z Request revocation of orders / exemptions O Issues Requiring Resolution Z How do we address Security Orders?
Page 11 No Significant Hazards (TR Attachment U)
O Content Z Evaluation that shows the LAR involves no significant hazards O Process Z 10 CFR 50.91 O Issues Requiring Resolution Z None.
Page 12 Environmental Considerations (TR Attachment V)
O Content Z Evaluation that shows that the LAR meets the criteria for categorical exclusion O Process Z 10 CFR 50.22(b) and (c)
O Issues Requiring Resolution Z None
Page 13 RI-PB NFPA 805 Chapter 3 Method (TR Attachment P)
O Content Z FAQ 06-0008 Methodology O Process Z Provided in accordance with10 CFR 50.48(c)(2)(vii)
O Issues Requiring Resolution Z None
Page 14 RI-PB NFPA 805 Alternatives (TR Attachment Q)
O Content Z Provide alternatives to those of NFPA 805 Z Neither Pilots will request alternatives O Process Z Provided in accordance with10 CFR 50.48(c)(4)
O Issues Requiring Resolution Z None
Page 15 FP Changes & Risk Impact (TR Section 4.5)
O Content Z
Current variances with the deterministic fire protection requirements which will meet the NFPA 805 performance based approach (Change evaluations)
Z Estimated Risk associated with transition (one number per RG 1.174)
X The breakdown is as follows (available in site documentation)
W current variances W Modifications to meet performance based requirements W Modifications to meet deterministic requirements W Modifications/plant features not FP related that offset risk when included in the FP program O Process Z
RG 1.205 Position C.2.2 Z
NEI 04-02 Section 4.5 O Issues Requiring Resolution Z
Concurrence with proposed content
Page 16 Proposed UFSAR Changes (TR Attachment R)
O Content Z See Duke slides O Process Z UFSAR change discussion recommended by NEI 04-02 (4.6.1)
Z Process governed by 10 CFR 50.71(e)
O Issues Requiring Resolution Z None
Page 17 Modifications (TR Attachment R)
O Content Z Listing of plant modifications necessary to support the new FP licensing basis Z Schedule for implementation O Process Z Modification listing/description recommended by NEI 04-02 (4.6.1)
O Issues Requiring Resolution Z None
Page 18 Clarification of Prior NRC Approvals (TR Attachment T)
O Content Z Listing of issues for which previous NRC approval is unclear Z NEI 04-02 B-1, B-2, B-3 Tables O Process Z Clarification discussed in NEI 04-02 (2.3, B.2) and RG 1.205 (C.2.2)
O Issues Requiring Resolution Z None
Page 19 Engineering Equivalency Evaluations (TR Attachment J)
O Content Z Listing of Engineering Equivalency Evaluations for fire protection features that do not meet the requirements of NFPA 805 O Process Z RG 1.205 Position C.2.3 O Issues Requiring Resolution Z FAQ 07-0033 Z Concurrence on content
Page 20 MSO Resolution (TR Attachment F)
O Content Z FAQ 07-0038 method Z Results will be part of fire area summaries and change evaluations as necessary Z Expert Panel results will be part of long term compliance documentation available on site O Process Z MSO resolution discussed in NEI 04-02 (B.2) and RG 1.205 (C.3.3)
O Issues Requiring Resolution Z FAQ 07-0038 Z Concurrence on content
Page 21 OMA Transition to Recovery Actions (TR Attachment G)
O Content Z Assumptions, criteria, methodology, and overall results of the operator manual action transition to recovery actions O Process Z OMA resolution discussed in NEI 04-02 (B.2) and RG 1.205 (C.2.3)
Z Additional considerations from FAQ 06-0012, FAQ 06-0011, & FAQ 07-0030 will be included O Issues Requiring Resolution Z FAQ 07-0030 Z Concurrence on content
Page 22 Frequently Asked Questions (FAQs)
(TR Attachment H)
O Content Z Intended to provide clear definition of FAQs used as input for LAR O Process Z List O Issues Requiring Resolution Z None
Page 23 Fire PRA - High Level Findings (TR Section 4.5.1)
O NRC FPRA review addressed in RG 1.205 (C.4.3)
O NRC review high level findings and schedule for completion to be provided (LAR, Att. Q)
Page 24 NFPA 805 Implementation (TR Section 5.0)
O Content Z Post Transition Documentation Roadmap Z Implementation Schedule XFire PRA Update (establishes baseline)
XNew Program Implementation XCompletion of NFPA 805 Modifications O Process O Issues Requiring Resolution Z None
Page 25 Regulatory Evaluation (TR Section 6.0)
O See attachment
Page 26 Contents of SER O Specific approval of Transition Report Tables O Specific approval of implementation schedule O Other specific issues requiring approval Z Change evaluations that meet FP license condition threshold