ML081840398

NFPA-805 Workshop Handouts - Beaver Valley Rules-Based Presentation

ML081840398
Person / Time
Site:	Beaver Valley
Issue date:	06/20/2008
From:	FirstEnergy Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML081840360	List: ML081840398 ML081840534 ML081840731 ML081840735 ML081840744
References
NFPA 805
Download: ML081840398 (13)

Text

NFPA 805 Public Workshop June 19 & 20, 2008 Beaver Valley Rule-Based Approach to Transition

Presenter Mike Roder FENOC NFPA 805 Project Lead Tools for converting the knowledge based transition project to a rule based process.

Considerations

• Regulatory guidance and industry guidance, such as RG 1.205 and NEI 04-02 is available

- however, need to translate into detailed procedures that dove-tail into the sites administrative processes.

• Processes and tools need to support a multi-user, multi-location environment

• Balancing level of detail

- Sufficient detailed to support

• On-site and off-site reviews

• Configuration management

• LAR submittal

• triennial inspection

- Quality and content considerations

• Need to Manage Action Items - real time

• Completeness and Accuracy requirements need to be built in on the front end.

• Need processes to efficiently review and approve a large LAR submittal with minimum rework at the end

Beaver Valley Approach Rule-Based Methodology

- Fleet administrative procedures

- Business Practices,

• establish process

- Software tool,

• manage data

- Desktop guides,

• improve quality and consistency

Beaver Valley Approach Business Practices

- Implements higher order guidance (NEI 04-02, NFPA 805, Fleet administrative procedures, etc.)

- Developed for NEI 04-02 sections/tasks

- Integrated with transition software tool

- Establishes record based review process and controls

Business Practice Example Step 5.4 Document the fulfillment of the NFPA 805 Nuclear Safety Performance Criteria (NSPC) for the selected fire compartment. To complete the NSPC documentation for the fire compartment:

5.4.1 Select the appropriate NSPC for evaluation.

5.4.2 Enter name and record status in the appropriate locations in WebTRAN for the record being prepared.

5.4.3 Document the Method of Accomplishment in summary level form for the fire compartment. Include licensing bases (e.g., Exemptions, SERs, etc) and/or design bases that are used to support the Method of Accomplishment. Attempt to use concise, consistent terminology that provides a high level summary of credited strategies. This consistency should be utilized for statements within a given fire compartment and for similar statements in different fire compartments.

Note: The information documented in WebTRAN is intended to be summary level information that provides a concise summary of information, with references to specific supporting analyses and documents.

Beaver Valley Approach Transition Software

- Allows for multi-user, multi-location environment

- Data integrity is ensured

- Implements record based review and approval process

- Completeness and Accuracy

• V&V or Calculation - output

- Balances level of Detail

• summary level for transition report

• link to reference document files for detailed review

- Project Management tools integrated with transition review

- Action Items efficiently managed

- Word features - edit, format, spell check features integrated into Software

- Help Screens (consistency and aid)

Beaver Valley Approach Desktop guides

- Consistency

- Quality

- Captures learned techniques and lessons.

Desktop Guide Process Monitoring First review NRC Information Notice 84-09, particularly Section IX, page 6 of 9 and NFPA 805 Ch 2 record 3.1.2.5. Use the headings listed to outline the component mark numbers of the actual instruments the site has analyzed to use for their post-fire recovery, and then discuss and explain any site deviations from these NRC expectations.

For a PWR, the headings in this NSPC are:

a. Pressurizer pressure and level.

b. Reactor coolant hot leg temperature or exit core thermocouples, and cold leg temperature.

c. Steam generator pressure and level (wide range).

d. Source range flux monitor.

e. Diagnostic instrumentation for shutdown systems.

f. Level indication for all tanks used (e.g., CST).

For a BWR, the headings in this NSPC are:

a. Reactor water level and pressure.

b. Suppression pool level and temperature.

c. Emergency or isolation condenser level.

d. Diagnostic instrumentation for shutdown systems.

e. Level indication for all tanks used.

• Comments