ML082880455
| ML082880455 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/30/2008 |
| From: | Division of Operating Reactor Licensing |
| To: | |
| References | |
| Download: ML082880455 (32) | |
Text
Preliminary Oconee LAR Acceptance Review Matrix Sufficient SRP Requirement/Review Attribute for Comments Review?
II1.1.1 Review the Licensee's submittal and verify that it includes an evaluation of the risk impact associated with major issues such as the operator manual No While Duke discusses their plans to submit this material, it is actions, Hemyc, and circuit analysis of possible multiple spurious i not yet provided.
actuations (either quantitative or qualitative) as appropriate.
Review the Transition Report, ifone is included in the Licensee's submittal, to verify that it meets the minimum content as defined in NEI 04-02 See below, Sections 3.4, 4.6.2, and RG 1.205 Verify that each of the topic areas below is addressed in either the LAR ort other submitted supplemental information (e.g., a transition report as .
-defined in NEI 04-02, section 4.6.2). This review will confirm the licensee , See below has identified the necessary changes to the license condition, orders, and technical specifications as applicable.
a) Specific Attributes Required by 10CFR50.48(c) 1 Feed and Bleed:10 CFR 50.48(c)(2)(iii) specifically notes that use of feed-and-bleed as the sole fire-protected safe shutdown path for maintaining Table 5-3 states that "Feed and bleed is not utilized as the reactor coolant inventory, pressure control, and decay heat removal sole fire-protected safe shutdown methodology at ONS." It is capability is not permitted for pressurized-water reactors (PWRs). This isi Yes also acknowledged that there is a need to maintain a - -
noted in section 2.2 of NEI 04-02. Verify that a statemri~ent to this effelct as* sufficient vent path for feed and bleed during Plant Operating well as a description of any dependence on feed-and-bleed in the fire>1*. State 2 of non-power operations (Section 4.3.1.2).
protection program is included in the LA,.
2 Existing Cables: [10CFR50.48(c)(2)(v)] A LARis acceptable if the licens&-Th Table 5-3 states that "Electrical cable construction at ONS states that the cable installed in-:thet plant mee&tsafl:*me propagatio t Ys complies with a flame propagation test that was found that is acceptable to the AHJ. FAQ 06ý-0022 documents flame propagation acceptable to the NRC as documented in NEI 04-02 Table B-tests that are acceptableto thelNRC.-, -, 1." FAQ 06-0022 is also referenced in Table H-1.
If the cable installed inth~eplant does not mee'ta flame propagation test that is acceptable to the'NRC,the licensee has the choice of providing a Yes See above flame retardant coating on the cables, or providing an automatic fixed suppression system covering'ali cables that do not meet the requirements.
Page 1 of 32
Preliminary Oconee LAR Acceptance Review Matrix Water Supply and Distribution: [10CFR50.48(c)(2)(vi)]: This paragraph provides that a "provisional" manual fire-fighting standpipe/hose station Table B-i, with regard to NFPA-805 Section 3.6.4, states system may not be used in place of seismically qualified standpipes and station system shall be capable of providing manual fire-hose stations unless previously approved in the licensing basis. Licensees sta sttion she abeof pring manuals ire-who wish to use the italicized exception in Section 3.6.4 of NFPA 805 must supporting andtecmaintaiin the noucpleart scafetysfuimpornt t submit a request for a license amendment in accordance with paragraph Yes bescapable of being implemented in a timely manner follow anplemcnee ing intifes in et (c)(2)(vii). However, because the NRC considers seismically qualified standpipes and hose stations of such importance, the NRC believes that following an SSE." Oconee also identifies in this table that, licensees who wish to use the exception in Section 3.6.4 of NFPA 805 via a except for those in the Reactor Building and Units 1/2 and 3 license amendment may have difficulty satisfying the three criteria in Cbseisrn ioa!o designed.
paragraph (c)(2)(vii). seismicallydesigned.
Note that Appendix A to BTP APCSB 9.5-1 made separate provisions for' operating plants and plants with construction permits issued prior to July 1, See above. Oconee also provides references in Table B-1 1976, and did not require seismically qualified standpipes and host stations for the fact that the requirement in Section 3.6.4 of NPFA 805 for those plants. Therefore, the requirement in Section 3.6.4 of NFPA 805 Yes is not applicable to licensees with non-seismic standpipes is not applicable to licensees with non-seismic standpipes and hose and hose stations previously approved in accordance with stations previously approved in accordance with Appendix A to0BTP Appendix A to BTP APCSB 9.5-1.
APCSB 9.5-1.
b) Modifications If the licensee proposes to implement modificationsas part of the transition, to a risk-informed, performance-based fire pro ttion program, verify that
- for each modification proposed, the LAR contains a description of the . Duk modification, a schedule for implementation of the modification and a risk- Duke only states the following: "Upon completion of the informed ofte justification, cedl frtheincluding compensatory modification. Regula*toryactions, for the acceptability Issue Summary 2005-(07T*{ No change evaluations, any necessary ONS will Modifications modifications. be in a positionrequired to determine will be of. the schedule for th oiiain eltr su umr 050,identified in the supplement to the LAR."
"Compensatory Measures to Satisfy the Fifre-Protection Program Requirements," provides guidance-oncompensatory measures acctpIvable to the NRC.
c) Transition Schedule Section 4.6.1 of NEI 04-,02states that the LAR should incl*de an "updated transition schedule". The licensee should provide not only a-transition Duke only states the following: "Uponcompletion of the schedule, but also a risk-informed justification for the timing of the schedule, demonstrating that the transition will be6completed in a timely No change evaluations, ONS will be in a position to determine any necessary modifications. Modifications required will be enough manner to avoid unacceotable.arisk due.
enuh.anr.oaoi.ncc exin non-compliances ue. existing no-omlane identified in the supplement to the LAR."
with the current fire protection program that will not be resolved until transition is complete.
d) Fire Protection License Condition Page 2 of 32
Preliminary Oconee LAR Acceptance Review Matrix Verify that the Licensee's submittal package documents the plant's risk-informed fire protection license condition. One acceptable approach would Yes Duke provides the standardized license condition from NEI be to use the standard license condition from RG 1.205, if necessary 04-02, which includes the risk acceptance criteria.
supplemented by FAQ 06-0008.
rPevious NRC-approved SER references are provided in the D÷ Th*ble B-1 clarification field to justify those sections and sub-Verify that all prior fire protection SERs and commitments are superseded section where ONS does not meet the specific NFPA 805, by the issuance of the new license condition. Review the Licensee's Yes Chapter 3, requirements. Table B-1 also includes ONS submittal package and tcurrentnfire verify that it includes a listing of all SER sections current fire protection program elements with clarification protectioncprogrammelements.with.clarification that contain fire protection commitments. statements,previous licensee evaluations, elements with further action required (open items), and items submitted for NRC approval on NFPA 805, Chapter 3, requirements.
Previous NRC-approved SER references are provided in the Table B-1 clarification field to justify those sections and sub-section where ONS does not meet the specific NFPA 805, Verify that the Licensee's submittal package includes a list of all submittals Yes° Chapter 3, requirements. Table B-1 also includes ONS made to support those SERS. current fire protection program elements with clarification
.statements, previous licensee evaluations, elements with fu:rther action required (open items), and items submitted for
,~*,NRC approval on NFPA 805, Chapter 3, requirements.
Verify that the Licensee's submittal package includes a discussion of the existing "approved fire protection program"so it can be siperseded by the LRA No. 2008-01, Section 4.1, and Attachment A, Table B-i, hew license conditions. Verify that the Li6ensee's submittal package Yes NFPA 805 Ch. 3 Transition," provide a point-by-point
.includes all prior approvals, documented ihnthe transition tables (B-i, B-2, comparison of the ONS current fire protection program to and B-3) with enough information to be standalone and thlerefore NFPA 805, Chapter 3, and NEI 04-02, Table B-1.
supersede the previous documentations.
e) Other License Conditions Attachment M states that "ONS implemented the following process for determining that these are the only license
. , conditions required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c): A review was Verify that the Licensee's submittai,,package documents how the plant meets the process used to identify any other license ':-',*,conditions,:*--:*!:DPR-47, for fire Yes dRctad DPR-55, by ofRthe and by ONSON licensing ensing staff st andDPA-80 NFPA 805 protection Transition Team. The review was performed by reading the Operating License and performing electronic searches.
Outstanding License Amendment Requests that have been submitted to the NRC were also reviewed for potential impact on the license conditions."
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Preliminary Oconee LAR Acceptance Review Matrix Attachment M states that "License condition 3.D shall be superseded with the exception of the SER dated April 28, 1983: '3.D. Fire Protection Program - Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program as
.described in the UFSAR for the facilityand as approved in Ithe SER's dated August 11, 1978, and April 28, 1983; October 5, 1978, and June 9, 1981 Supplements to the SER In accordance with 10 CFR 50.48(c)(3)(i), the LAR should contain a list of dat*d August 11, 1978; and exemptions dated February 2, any other license conditions that need to be revised or suspended, the 1982; August 31, 1983; December 27, 1984; December 5, necessary revisions to these other license conditions, and an explanation Yes 1988; and-August 21, 1989 subject to the following provision:
of why these revisions are adequate to accomplish the plants' adoption of The licensee may. make changes to the approved fire NFPA 805. protection prpogram without prior approval of the Commission only if those chianges would not adversely affect the ability to achieve and main']ntain safe shutdown in the event of a fire.' It is Duke's understanding that implicit in the revocation of this license condition, all prior Fire Protection Program SERs and commitments (with the exception of the SER dated April 28, 1983) have been superseded in their entirety by the revised license condition. No other license conditions need to be revised or superseded."
Verify that the Licensee's submittal package documents not only identify the other license conditions, but also describe the process used to identify., Yes See above the other license conditions.
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Preliminary Oconee LAR Acceptance Review Matrix f) Technical Specifications Attachment N states as follows: "Delete the following Technical Specification: Section 5.4.1 Written procedures shall.be established, implemented, and maintained covering
- dhe following activities: d. Fire Protection Program implementation. Revise the following Technical Specification
. Bases: Technical Specification 3.10.1, Standby Shutdown Faciity (SSF) need to remain as is to ensure the functional capability and availability of the facility as credited in the fire Verify that the Licensee's submittal package discusses which Technical protecti6oinand other programs. However, the bases shall be Specifications needing modification were identified, and the process used revised to delete the reference to 10 CFR50 Appendix R for their identification. Verify that the package includes: (1) all since it will noi longer apply. No other Technical administrative/audit technical specifications needing to be revoked, (2) Yes Specifications need to be revised or deleted. ONS equipment technical specifications to be revised and ensure they are p-implemented the following process for determining that these consistent with 10 CFR 50.48(c), and (3) revised technical specification are the only Technical Specifications required to be revised sections and their associated bases. or deleted to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c). A review was conducted of the ONS Technical Specifications, by Duke licensing and NFPA 805 Transition Team. The review was performed by reading the Technical
-Specifications and performing electronic searches.
Outstanding Technical Specification changes that have been submitted to the NRC were also reviewed for potential impact on the license conditions."
The reviewer should be aware that there will likely be otherrequirements that must be met with regard to Remote Shutdown capabilityto meet GDC
- 19. Make sure that the licensee does not inadvertentl*ydelete Remote+ No No specific statement regarding requirement.
Shutdown requirements for the ability tosafely shut down from outsidt, the control room required by otherregulatioins, g) Orders and Exemptions Attachment 0 states that "ONS implemented the following process for making this determination [that] mo Orders need Verify that the Licensee's submittal package documents the process used Yes to ONSbe docketed superseded or revised: A review correspondence by ONSwas conducted licensing staff.ofThe the to identify orders and exemptions related to fire protection.
",;*-,,* *"::-::,/"review was performed by reviewing the correspondence files and performing electronic searches of internal ONS records and the NRC's ADAMS document system."
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Preliminary Oconee LAR Acceptance Review Matrix Verify that the Licensee's submittal package documents a list of any orders and exemptions that need to be revised or suspended, the necessary Attachment 0 lists several exemptions that are superseded, revisions to these orders and exemptions, and an explanatioh of why these Yes with details on the exemptions in Attachment K. No orders revisions are adequate to accomplish the plants' adoption of NFPA 805, in need to be superseded or revised.
accordance with 10 CFR 50.48(c)(3)(i).
Verify that the Licensee's submittal package documents not only identify the orders and exemptions, but also describe the process used to identify Yes See above the orders and exemptions. .
h) Significant Hazards Consideration Verify that the Licensee's submittal package documents include a Section 5.3.1. states that "Pursuant to 10 CFR 50.91, Duke statement on No Significant Hazards Consideration, in accordance with has made ithe determination that this amendment request 10 CFR 50.91 and 10 CFR 50.92. Appendix H of NEI 04-02 provides one Yes involves a 'No Significant Hazards Consideration' by applying acceptable statement to the NRC staff that shows that the Licensee's the standards established by the NRC regulations in 10 CFR submittal package, including the LAR meets the criteria for No Significant - *50.92. This amendment does notinvolve a significant Hazards Consideration. hazards consideration for the following reasons."
i) Environmental Considerations (Categorical Exclusion Finding).-
Section 5.3.2 states that "Duke has evaluated this LAR
- against the criteria for identification of licensing and Verify that the Licensee's submittal package documents includes a regulatory actions requiring environmental assessment in statement on Environmental Considerations in accordance with Yes accordance with 10 CFR 51.21. Duke has determined that 10 CFR 51.22(b) and (c). Appendix H of NEI 04-02 provides one example this LAR meets the criteria for a categorical exclusion set of an acceptable statement. -. forth in 10 CFR 51.22(c)(9). This determination is based on
.-* the fact that this change is being proposed as an amendment
-_.___-,to a license issued pursuant to 10 CFR 50."
j) Changes to the UFSAR The Executive Summary states that "UFSAR changes Verify that the Licensee's submittal package documents how the planti. necessitated by the license amendment will be submitted in meets the requirements of 10 CFR5O,48(c),(3)(i), which requires licensees accordance with 10 CFR 50.71 (e). An example of the content include discussion of any changes Updated Final Safety Analysis Report and detail of the proposed changes to the UFSAR shall be (UFSAR). submitted in the supplement to the LAR." This supplement has not yet been provided.
Verify that the Licensee's subrIittal package documents include discussion Attachment R states that "An example of the content and of any changes to UFSAR necessitated by the license amendment and a level of detail of the proposed changes to the Updated Final statement that the changes will be made in accordance with 10 CFR No Safety Analysis Report (UFSAR) necessitated by the license 50.71 (e) As per NEI 04-02 Section 4.6.,1. Furthermore, verify the adequacy amendment will be included in the supplement to the LAR."
of the commitment made by the licensee-to-make changes to the UFSAR.. This Attachment is not yet provided. (Also see above)
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Preliminary Oconee LAR Acceptance Review Matrix k) Frequently Asked Questions (FAQ)
NRC established the FAQ process in accordance with RIS 2007 19 - Under potential operator manual actions, there is a reference "Process For Communicating Clarifications of Staff Positions Provided in to FAQ-06-0012 bin H for those actions that are disallowed.
Regulatory Guide 1.205 Concerning Issues Identified During the Pilot Licensee states that the feasibility will be evaluated as per Application of National Fire Protection Association Standard 805" to clarify Yes NEI-00-01 with additional consideration from FAQ-06-0011 issues encountered during the pilots transition. Therefore, licensees may and FAQ-06-0012. A discussion with NRC staff was rely on FAQ resolutions to comply with 10 CFR 50.48(c). Relying on FAQs documented in FAQ-07-0030.
is acceptable to the NRC staff within the constraints defined in the FAQs.
Verify that the Licensee's submittal package includes, a Fire Protection License Condition that provides risk acceptance criteria for risk-informed, performance-based changes to the fire protection program. To be considered acceptable, the license condition must require the licenseet[c .Duke provides thne 7 iandardized license condition from NEl implement and maintain in effect all provisions of the approved fire Yes 04-02, which includes the risk acceptance criteria.
protection program, with specific references to the NFPA 805 transition license submittal and subsequent Safety Evaluation Report. The license condition must also provide acceptance criteria for self approved and NRC approved changes.
II1.1.1. Use of Performance-Based Methods to make changes to Fundamental Fire 2.1 Protection Program and Design Elements must be requested through the submittal of a LAR. Review of LARs submitted in accordance with 10 CFR 50.48(c)(2)(vii) will focus on review of the technlial aspects of the Yes Included as Attachment A of the LAR.
approach or method proposed by the licensee compared to the requirement(s) in Chapter 3 and the performance goals,0objectives and criteria of NFPA 805.:[iiii: ..:i ~*: :....
criteria of NFPA-LAR 805. 2008-01, Section 4.4, and Attachment E, Table G-1, Radioactive Release Transition Report," provide a qualitative evaluation of radioactive release to any unrestricted area due to release of liquid effluents from fire suppression activities, for compliance with the requirements of NFPA 805, Section Regulation o4.3. This evaluation follows guidance in NEI 04-02 and RG The Director of the Office Nuclear Reactor Regulation or d6signee, may1.205, with the exception of the 10 CFR Part 20 release approve the application if: sati'sfies the performanc~e goals, performance Yes limits. Table G-1 includes a review of ONS fire brigade pre-objectives and performance criteria specified in iFPA 805 related to fire plans and fire brigade training materials for evaluation.
nuclear safety and radiological release; Maintainis Safety Margins; and This table refers to ONS radiological release evaluation from fire suppression activities. This evaluation is based on the prior NRC approval for the concentration of radioactive material that's limited to 10 times the effluent concentrations specified in 10 CFR Part 20.
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Preliminary Oconee LAR Acceptance Review Matrix Table 5-3 states "that the performance-based approach ...
Maintains safety margins; and Maintains fire protection defense-in-depth (fire prevention, fire detection, fire Maintains fire protection defense-in-depth (fire prevention, fire detection, Yes suppression, mitigation, and post-fire safe shutdown fire suppression, mitigation, and post-fire safe shutdown capability). capa*bility).
capabilit nIn this Table, the LLAP requests tisable, rst the s the use of setof performance-based methods in accordance with FAQ 06-0008 (pending NRC approval).
Attachment P states that use of performance-based methods Verify the adequacy of methods and licensee's evaluation and conclusions will ensure the requirement that fire protection defense-in-with regard to meeting the margins of safety and defense-in-depth criteria Yes depth wilbe maintained by "using the RI-PB change process of NFPA 805. in NEI 0 , 4-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Regulatory Position C.3.2."
The licensee may utilize the NFPA 805 Change Evaluation process as defined in NEI 04-02 (including consideration of Defense-in-Depth and Safety Margins), as the process for determining acceptability for minor 'Yes See above (pending NRC approval of FAQ 06-0008) changes to NFPA 805 Chapter 3 requirements that are implemented through referenced codes, standards and listings. FAQ 06-Q008 describes an approach that is acceptable to the NRC staff.
II1.1.1. 10 CFR 50.48(c) allows licensees to request approval to use riskinformed 2.2 or performance-based alternatives to compliance with NFPA 805-..A licensee may submit a LAR to use risk-informed or performance-based Yes Included as Attachment A of the LAR.
alternatives to compliance with NFPA 805. Verify the adequacy of methods and licensee's evaluation and conclusions with r*egard to meeting the margins of safety and defense-in-depth criteria of NFPA 805. _____
111.1.1. Licensees may use performance-based Fire Protection Engineering 2.3 Evaluations to demonstrate compliance to FundamentalFire Pr'otection Yes Included as Attachment A of the LAR.
Program and Design Elements during transition.
Section 4.2.2.2.1 states that "The EEEE review was Verify that a Fire Protection< En'gineering Evaluation (FPEE) meets the performed using the methodology contained in FAQ 07-0033, following attributes to be considered acceptable:: Transition of Existing Engineering Equivalency Evaluations.
FPEEs performed todeiionstrate that a given fire protc-6fiin feature is The methodology for performing the EEEE review includes "adequate for the hazard" in',hiccordance with thýeexisting Standard Fire the following: [1] Determination that the EEEE is not based Protection License Conditior" must meet the criteria that they must not have solely on quantitative risk evaluations, [2] Determination that an .adverse affect on the ability to achieve and maintain safe shutdown; the EEEE is an appropriate use of an engineering FPEE is not be based solely on"'qi'ntitative risk evaluations; equivalency evaluation, [3] Determination that the EEEE is of FPEE is an appropriate use of the"FPEE proc*SS; appropriate quality, [4] Determination that the standard FPEE is judged of acceptable quality; § " " license condition is met, [5] Determination that the EEEE is FPEE reflects the as-built, and as-operalted"plant. technically adequate, and [6] Determination that the EEEE reflects the plant as-built condition."
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Preliminary Oconee LAR Acceptance Review Matrix 111.1.1. An acceptable process for implementing Fire Protection Engineering 2.4 Evaluations (FPEEs) on NFPA 805 Chapter 3 attributes that are implemented through referenced codes, standards and listings is provided in FAQ 06-0008. The licensee must evaluate post-transition FPEEs using While it may be inferred that, through use of NEI 04-02 and
.... i t may b e i sted th a wilg be of N EI is nd the NFPA 805 Change Evaluation Process. Verify that the Change Evaluation Process meets the following acceptance criteria: satisfies the No FAQ 07-0033, the listed criteria will be satisfied, there is not
- .ii'a specific citation as such, nor does there appear to be one performance goals, performance objectives and performance criteria <ia seiicn he referenced FAQ.
specified in NFPA 805 related to nuclear safety and radiological release; r
,ir.t.e endA maintains Safety Margins; and maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
111.1.2 Review of LARs submitted in accordance with 10 CFR 50.48(c)(4) will focus on review of the technical aspects of the approach or method proposed as alternatives to compliance with NFPA 805. These shall meet an equivalent level of protection to that established by NFPA 805. Review a Table 5-3 states that "No risk-informed or performance-sample of calculations to verify that the licensee's evaluationrand Yes based alternatives to compliance with NFPA 805 (per 10 conclusions with regard to meeting the margins of safety and dofense-in- CFa 50.48(c)(4)) were utilized by ONS."
depth criteria are acceptable. Proposed alternatives are subjected to.the theruizb CFR same evaluation criteria (e.g., verification and validation) as the endorsd methods. The review will also evaluate the licensee submittal to determine if-these evaluations were adequately performed and documented. .
The NRC approved requirements and industry guidelines established for implementation of a risk-informed, performace-based/fireprotectionYeSea program form the foundational basis for comparison of alternative methods and the review procedures.
111.1.3 a) Attachment F - MSO Resolution. The licensee's proposed
....,,:;*:::'".*: " ... methodology for MSO is: (1 .) Identify potential MSOs of Verify that the Licensee's submittal packageus methodology d ...... a summary documents of the cnittwthconcern meto from SO for SSA, ientifyapotent generic resuof lists, self-assessment results, MSO MS methodology ehdlg sd The used:; *methodology-used shold The... shouldi be be. consistent
. with PRA guidance from the supplemental discretionary selection lessons learned from pilot Iplant non-pilot guidance (-o- and operatinexerience.tNot and implement ciiisa pln the elce*ntecagsfo h andrpreceding A rcsa guidance (NEI-00-01), and operating experience. Note:
plant activitiesLicensee should also consider NEI-00-01, Section 3.1.11 for applicable to the applicant'slparticular situation.it iihould contain sufficient firesi a n ultple unsites (2.) C n ctian expert f information concerning methods tools, and acceptance criteria used to fires impacting multiple unit sites. (2.) Conduct an. expert enable the staff to determine theacqeptability of heicensee's Yes panel review as per NEI-00-01, Section F.4.2. Licensee will menabethe s togdtherina tshouldeaerabeilt ormed and arranged by use physical cable routing, if known. (3.) Update the fire PRA methodology. The analysis enerally performed and NSCA models to account forthe MSO by (a) identifying Fire Areas, although in some cases an alternrative spatial approach may prove to be more practical. If an expert panelI process was used, it should equipment (as per Task 2 of NUREG/CR-6850), (b) be documented with results clearly presented. The MSO analysis should identifying cables that, if damaged by fire, could result in generally conform with requirements found in NEI 04-02 B.2.1.3 and spurious operation, (c) identifying routing of the cables ge conform wit3 ridentified above. (4.) Evaluate for NFPA-805 compliance (For RG 1 .205, C.3.3 the performance-based approach, recovery actions can be "feasible and reliable;" under potential operator manual Page 9 of 32
Preliminary Oconee LAR Acceptance Review Matrix actions, there is a reference to FAQ-06-0012 bin H for those actions that are disallowed.). (5.) Document the results. The licensee (1) still needs to identify those cables for which they do not have specific routing; (2) should identify whether an MSO*can cause a modeled initiating event; (3) mention if planning to follow the guidance in Section 3.4 of NEI-00-01 (there is no mention of treatment of interlocks as in the NEI guidance or mention of power feeds); (4) include potential operator manual actions in the LAR that may be disallowed (FAQ*-06-0012, bin H); (5) provide the promised documentation with the submittal update. In Attachment F -
MSO Resolution, the licensee notes that R.G. 1.205, position C.4.3 contains acceptable methods to performing the circuit analysis. However, there is no mention of this in the current regulatory guide."The licensee states that, going forward, the process of selecting MSOs would be simplified without any explanation of the anticipated process.
b) Operator Manual Action (OMA) Transition to Recovery Actions (RA)
Verify that the Licensee's submittal package documents assumptions,-
criteria, methodology, and overall results of the OMA transition torecovery No:To be provided later.
actions. In accordance with NFPA 805, Sectionr4.2?4A1.6, all recovery l-a actions shall be feasible.
Verify that the Licensee's methodology includes a feasibility determination, including an evaluation of egress and task lighting. An evaluation of the risk impact associated with the operator.manual actions (either qualitativ.e.
or quantitative), must be described and included as app:5ropriate.
Quantitative risk calculations should be in accordancae w-ith SectionS4.2.4.2 of NFPA 805 (a bounding calculation approach is acceptable). The oLOMA tb"recovery action should include: 1) description of the transitionf whether the operator manual'actions are currently allowed or were No To be provided later.
previously reviewed ahd approved by the NRC's Office of:!\Nuclear Reactor Regulation (NRR), and 2),r!ference to documehntation that demonstrates prior review and approval by the-NRC. Operator":rrnual actions that are currently allowed and/or have beenpreviously reviewed and approved by the NRC (as documented in an aproved exemption/deviation) can be transitioned without a change evaluation, (the risk associated with their use must still be evaluated). __"_____.____:_______-______
One acceptable approach for OMA transitirf0 to recovery action is in No See above accordance with NEI 04-02, B.2, RG 1.205, C.2.3.
[NOTE: Section may need updating to reflect FAQ 07-0030 upon approval and incorporation into NEI 04-02]
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Preliminary Oconee LAR Acceptance Review Matrix C) Clarification of prior NRC Approvals Verify that the Licensee's submittal package clearly documents previously Attachment A includes Tables B-i, B-2 and B-3, with the Attachmddressin gus "pre s approvand O the approved alternatives to the fundam ental fire protection program requirements of NFPA 805 Chapter 3 that are being carried forward to the "Yresious approvals" are presented in Attachments J and K.
NFPA 805 Licensing Basis, in the LAR.
Verify that the Licensee's submittal package documents all previously Section 4.1.2.1 states that "Requirements in NFPA 805 approved variations, and the documentation which demonstrates prior NRC Sc.. tio 3.1that tave been dRetuirermineto ico y or c approval of an alternative to Chapter 3 requirements, as well as approval of Yes apter 3 that have been determined to'comply' or'complies Yes b re vious to the oum entls) in th ment A.
noncompliance with existing license regulatory requirements, is referenced.
Any items for which previous NRC approval is unclear should be listed and References to the document(s) that justify that position are evaluated via a plant change analysis. included iniAttachment A."
The reviewer can reference NEI 04-02 Tables B-1, B-2, B-3 and should Attachment ,Ainicludes Tables B-i, B-2 and B-3, with the verify that prior NRC approvals are documented in accordance with Yes latter addressing specific "previous approvals." Other NEI 04-02 2.3, B.2 and RG 1.205, C.2.2. "previous approvals" are presented in Attachments J and K.
d) Existing Engineering Equivalency.Evaluations (EEEE)
If Existing Engineering Equivalency Evaluations are used, the licensee must affirm in the LAR that they.of appropriate quality, or, provide Yesý Included as Attachment J of the LAR.
documentation as part of the LAR for staff review.
If the documents are not submitted as part of the LAR, the revieWwill confirm that the documents are of adequate quality by reviewing &asampl Yes See above of documents during the Post-LAR Audit.
Duke provides statements assuring that DID and SM will be considered and maintained. In addition, Section 4.2.2.2.1 states that "The EEEE review was performed using the In judging the appropriateness, the reviewer* should consider the following methodology contained in FAQ 07-0033, Transition of guidance:1) The evaluation is not be based solely on quantitative risk Existing Engineering Equivalency Evaluations. The evaluations but also on considerations of defense-in-depth and safety: methodology for performing the EEEE review includes the margin; 2) The evaluation ishan appropriate use of an engineering following: [1] Determination that the EEEE is not based solely equivalency evaluation;.3.)The evaluation-"isobf appropriate quality; 4) The on quantitative risk evaluations, [2] Determination that the evaluation provides deftrmi'nation that the standard license.econdition is EEEE is an appropriate use of an engineering equivalency met; and5) The evaluation'ldemonstrates that the evaluation reflects the evaluation, [3] Determination that the EEEE is of appropriate plant as-built condition. ' quality, [4] Determination that the standard license condition is met, [5] Determination that the EEEE is technically adequate, and [6] Determination that the EEEE reflects the plant as-built condition."
The licensee must document those EEEEs f6r fire protection features that Yes Attachment J provides specific EEEEs.
do not meet the requirements of NFPA 80.5."m RG 1.205, C.2.3. provides one acceptable approach to the NRC. No While this may be inferred, there is no specific citation.
[NOTE: Section may need updating to reflect FAQ 07-0033 upon approval of the FAQ and incorporation into NEI 04-02]
Page 11 of 32
Preliminary Oconee LAR Acceptance Review Matrix e) Fire Protection Program Changes Verify that the LAR has described any current variances with deterministic fire protection requirements that will be carried over to the NFPA 805 performance-based licensing basis. The total risk increase associated with all fire protection program non-compliances (based on current deterministic No To be provided later.
fire protection program regulations) that the licensee does not intend to bring into compliance and the total risk change associated with plant changes planned for the transition to NFPA 805 should be estimated and reported. _ ___
f) Risk Impact of Transition Verify that the Licensee's submittal package documents the impact of the transition on plant risk. The analysis of the change in risk should include; a) an estimate of the change in risk as a result of the transition, b) an evaluation of the consequences of maintaining current variances, c) a risk evaluation of modifications to meet performance based requirements, d) an No To be provided later.
evaluation of the consequence of modifications needed to meet deterministic requirements, and e) a risk evaluation of modifications and/or plant features not fire protection related that offset risk when iiciluded in the fire protection program. "
Verify that the Licensee's submittal package documents a perfdnmance monitoring program, including a description and rationale for its Yes Duke discusses their plans for establishing a monitoring implementation and the performance monitoring strategy for the proposed Ye program, including acceptable methods.
licensing basis change in accordance with RG 1.1 74.i .
Verify that the licensee's procedures supp ortmaintenance ofthe Yen g os a performance monitoring program during thePost-LAR Site Audit. Ya n t The Executive Summary states that "The Fire PRA for all three ONS Units to support the RI-PB Change Evaluations RG 1.205, C.2.2. provides one.acceeptable approach to the staff. Yes per Regulatory Positions C.2.2 and C.4.3 of Regulatory Guide (RG) 1.205 has not been completed." Nonetheless, it is indicated that, when completed, it will follow Regulatory
-Position C.2.2.
Also, refer to "Draft LAR Technical Acceptance Review Criteria for NFPA 805," ADAMS Acces'sion"aNo. ML0814204523) for additional clarifications.
Page 12 of 32
Preliminary Oconee LAR Acceptance Review Matrix g) Fire PRA Peer Review of High Level Findings and Their Implemenidd or Proposed (with Commitment) Resolutions Verify that the Licensee's submittal package states that the Fire PRA peer Although stating .that this material "is considered draft due to review contains the following elements: a) a review of the methods used in th'e fact that it is based on draft results of the NRC staff the PRA and a determination of whether the application of those methods rev;iew The NRC Fire PRA Review of the ONS Fire PRA was was done correctly in the Fire PRA baseline model, b) a comparison of the co6nducted March 17-21, 2008," Duke identifies the high PRA models against the plant design and procedures to validate that they Yes levlJ.findings from the NRC Fire PRA Review and reflect the as-built and as operated plant, 3) a review of key assumptions to sum*rnarizes their resolutions. Furthermore, they state that determine if they are appropriate and to assess their impact on the PRA 'most fthe findings from the NRC review have either been results, 4) a check of the PRA results for fidelity with the model structure addressed or deemed to have no impact on FPRA and for consistency with the results from other PRAs. quantification-.
1, ,Although stating that this material "is considered draft due to
"*:*:-:*:".,*::%5! he fact that it is1based on draft results of the NRC staff Verify that the Licensee's submittal package documents: 1) a description of review The NRC Ftire PRA Review of the ONS Fire PRA was during the peer review . ... rve T Fe.
high level findings, 2) details of questions arising and any findings and their implemented or proposed (with commitment) conducted March 17-21, 2008," Duke identifies the high resolution, 3) the findings related to the pedigree of the model and their Yes level findings from the NRC Fire PRA Review and relationship to current/planned plant configuration. As need~lri i*the . .summarizes their resolutions. Furthermore, they state that relationst-R Sto cudent/plthat the licensee has properly duspo -he . "most of the findings from the NRC review have either been Post-LAR Site Audit, verify edisoitioned :addressed or deemed to have no impact on FPRA findings that affect the risk-informed changes. quantification. As required, a corrective action was generated to track completion of the open item."
The reviewer can reference NEI 04-02, 5.1.3, and RG 1.205, C.4.3 for on*e acceptable approach, related to Peer Review.W Verify that the Licensee's submittal package documents h*6 the plant defines the term "Power Block' The definitioLshould be compatible with the one given in the glossary of NFPA 805 defines Power Block as1.6.46*
Power Block. Structures that have equipment required for nucler plant Described in Section 4.1.3 and included in Attachment I of operations. The interpretation of thisterim has significant implications on Yes the licensing basis of thelicensee. Therdfpire, the licensees are required to describe the boundaries of -the power block as a part of their submittal to the NRC (One acceptable-approach of interplreting the definition acceptable to the staff is provided in resolution of FAQ 06-19 (MML 070510O365).
111.2 CONFORMANCE TO NFPA,805 111.2.1 FUNDAMENTAL FIRE PROTECTION PROGRAM AND DESIGN ELEMENTS (NFPA 805 CHAPTER*3), ,ý,
The Fundamental Fire Protection Program":andDesign Elements are established in Chapter 3 of NFPA 805. Sectio'n 4.3.1 of NEI 04-02 sets out Described in Section 4.1 and included in Attachment A of the a systematic process for determining the extent to which the current Yes LAR.
licensing basis meets these criteria and for identifying the fire protection.
program changes that would be necessary for complete compliance.
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Preliminary Oconee LAR Acceptance Review Matrix Verify that the LAR documents comparison of the fire protection program fundamentals to appropriate NRC guidance documents, Apperdix B-i of The documentation in LAR No. 2008-01, Table B-i, is NEI 04-02 describes one acceptable approach on documenting the Yes sufficient to compare the elements of fire protection program comparison of the fire protection program fundamentals of Chapter 3 to requirements of NFPA 805, Chapter 3, with ONS current fire NFPA 805 to the appropriate NRC guidance documents (Including BTP9.5- protection program licensing basis.
1, NUREG 0800, and NEI 04-02 section 4.3.1.).
111.2.2 NUCLEAR SAFETY PERFORMANCE CRITERIA METHODOLOGY TRANSITION (NFPA 805 CHAPTER 2)
The licensee followed the guidance for submittal template of Appendix H in NEI-04-02 for Section 4 of the LAR submittal.
Using the following steps: (1.) Assemble documentation gathering inidustry and plant-specific information. (2.)
.....*..-*,;.'Determine tl*e.~p.plicability to Chapter 3 of NEI-00-01 and Decorrelate theat pi cabiectiton 2.4. of NFP (3 015 The Methodology to be used to implement a performance-based Fire Protection Program is provided in NFPA 805 Chapter 2. Section 4.3.2 sets correlate that with Section 2.4.2 of NFPA-805. (3.) Perform coparisonsof t safe1e using the following out a systematic process for evaluating the existing post-fire safe shutdowni analysis against the methodology requirements provided in NFPA 805 Yes applicable sections'of NEI-00-0 Chapter 2. Regulatory Guide 1.205 endorses the deterministic safe disposition: (a.) Aligns with the NEl guidance. (b.) Aligns with shutdown analysis methodology provided in Chapter 3 of NEI 00-01, intent. (c.) Does not align. (d.) Does not align but, has Revision 1NE..... previous approval. (4.) Document open items associated with R.the review of the NEI 00-01 guidance. NOTE: Licensee states that not all sections of NEI-00-01 will be used since there is no regulatory requirement set forth in the document.
Also: Described in Section 3.2 and included as Attachment A of the LAR.
The licensee presents results in Attachment B. Areas that the licensee does not align with the methodology in NEI 01 are: (1) Attachment F contains the licensee's
. -, methodology on assessing multiple spurious operations Verify that the licensee's submiitta-l package-documents a systematic (MSO). (2) Attachment G contains the licensee's suplemntlymthoolgyhoeleineennNIe0-0'o approach to transitioning to the post-fire satfe sutdown analysis methodology
'nerqiemn......0. supplemental methodology to the one in N El-00-01 on assessing operator manual actions (OMA). NOTE: Circuit to the new requirements--in.NFPA 805 Chapte~r2. AppendixB-2 ofcoordination Yscodnto requires eursa an update pae potential oeta fire iedmgdamae one accepol:}abe approach to documeinting tlhe comparison of 02 describes 02 descibestong e acceutdowb.lsis appcthodologi~,tinthere mpariments of impactinng manual operation of valves has not been an existing safe shutdow 'ahalysis methodology to the requirements of specifically evaluated. In Attachment B - Table B-2 (Nuclear NFPA 805 Chapter 2 and industiryguidance document NEI 00-01. /.. Capability Cpabiity Assessment essmen Mt Methodology),
t the he licensee le also also needs to provide all safe shutdown diagrams including the safe shutdown analysis EIR 51-5044354-002, "Oconee Appendix R fire Safe Shutdown Analysis", Rev. 2, 4/7/2008.
Otherwise there is no way of reviewing safe shutdown paths.
111.2.3 NUCLEAR SAFETY PERFORMANCE CRITERIA TRANSITION (NFPA 805 CHAPTER 4)
Page 14 of 32
Preliminary Oconee LAR Acceptance Review Matrix The Nuclear Safety Performance Criteria are established in NFPA 805, Section 1.5.. NFPA 805, Chapter 4, provides the methodol6gj i6deierming Yes Described in Section 4.2.1 and included in Attachment B of the fire protection systems and features required to achieve the the LAR.
performance criteria outlined in Section 1.5.
Section 4.3.2 of NEI 04-02 sets out a systematic process for determining the extent to which the current licensing basis meets these criteria and for Yes ,Described in Section 4.2.1 and included in Attachment B of identifying the fire protection program changes that would be necessary for ,the LAR.
complete compliance. . _____________ ________
Verify that the Licensee's submittal package documents the methodology for performing the Fire Area-by-Fire Area Transition of its Fire Protection ..... . in S t 4... and int Program. NEI 04-02 Table B-3 is one acceptable approach (additional Yes' Describedin Section 4.2.1 and included in Attachment B of guidance is contained in FAQ 07-0039, Lessons Learned - NEI 04-02 B-2* *< the LAR.
and B-3 Tables).. _- __:____
111.2.4 NON-POWER OPERATIONS TRANSITION __..:___
Licensees are not required to prepare a complete PRA to model non-power operations; instead they can use a simplified approach of maximizing Section 4.3 described the NPO analysis approach, as per outage safety by focusing on the availability of systems that provide and Yes Revision 2 of FAQ 07-0040. This will need to be updated to support key safety functions as well as on measures that can reduce both reflect the close-out Revision 4.
the likelihood and consequences of adverse events.
RG 1.205 endorses the approach documented in NEI 04 02. Section 4.3,3.
of NEI 04 02, Revision 1 ,states that the-nuclear safety goal of N-FPA 805 requires evaluation of the effects of a fire 'during any operational mode and plant configuration. NEI 04 02 Section 4.3.3 furthier goes on to provide a Yes See above strategy that "...demonstrate[s] that the nuclear safety performance criteria are met for High(er) Risk Evolutions (HRE) (HREs as defined by NUMARC 91-06) during non-power operational mrnd,..."
Review the Licensee's submittal package to v6erify that thelicensee demonstrates that the nuclear safety performance criteria are metdluring Attachment D, yet to be provided, states that "The results of Higher Risk Evolutions. To accomplish this. objective* verify that the No the. Non-Power Operational Modes Transition will be included licensee has documented the following tasks, using NEI 04-02, Table F-1 with the supplement to the LAR."
and the additional guidance provided in FAQ 07-0040:
Review of existing plaht outage processes (outage management and outage risk assessments) to determine equipment relied upon to provide Key Safety Functions (KSF) in*duding support functions during the required POSs.
. Comparison of the equipment credited for achieving these KSFs against the equipment credited for nuclear safety. .
. For those components not already credited (or credited in a different way e.g., on versus off, open versus closed, etc.) analysis of the circuits in accordance with the nuclear safety methodology.
Page 15 of 32
Preliminary Oconee LAR Acceptance Review Matrix
. Identification of locations where 1) fires may cause damage to the equipment (and cabling) credited above, or 2) recovery actions credited for the KSF are performed
. Identification of fire areas where a single fire may damage all the credited paths for a KSF.
. For the above-mentioned areas the licensee may consider combinations of the following options to reduce fire risk depending upon the significance of the potential damage:
o Prohibition or limitation of hot work in fire areas during periods of increased vulnerability o Verification of operable detection and /or suppression in the vulnerable<,
areas.
O Prohibition or limitation of combustible materials in fire areas during-periods of increased vulnerability O Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability O Use of recovery actions to mitigate potential losses of key safetyiA>..
functions.
O Identification and monitoring in-situ ignition sources for "fire precursors" (e.g., equipment temperatures).
- NUMARC 91-06 discusses the development of outge plans and schedules. A key element of that process isto ensure the KSFs perfrim as needed during the various outage evoluihons. The results of the fire area_ý analysis of those components relied upon to maintain dffense- in-depth should be factored into the plant's existing outage planning process 111.2.5 RADIOACTIVE RELEASE TRANSITION Verify that the Licensee's, submiittal package, documents that radiation release to any unrestricted -area due to the-direct effect* of fire protection activities (but not involving fuel damage) remiainas low as reasonable achievable, not to exceed.10 CFR Part 20 limits.*ll0 CFR 50.48(c)(3)(i) requires licensees transitioh in'g-to NFPA 805 satisf* performance goals, objectives, and criteria provided in:NFPA 805. Se6tions 1 .3.2, 1.4.2, and Described in Section 4.4 and included in Attachment E of the 1.5.2 of NFPA 805 provide goals, performance objectives, and Yes LAR performance criteria associated with this regulatory requirement, respectively. Section 4.3 of Appendix H 'itoNEI0*4 02 provides one acceptable approach to documenting information that must be provided to the NRC in the LAR for staff evaluation. Appendix G of NEI 04 02 provides evaluations which the reviewer can consult as part of this review.
111.2.6 PROGRAMMATIC TRANSITION Page 16 of 32
Preliminary Oconee LAR Acceptance Review Matrix 111.2.6. FIRE PROTECTION PROGRAM DESIGN BASIS DOCUMENT (NFPA 805 1 SECTION 2.7.1.2)
Fire-by-fire area transition methodology: (1.) Assemble documentation. (2.) Assess accomplishment of performance goals. This will include the methods employed to accomplish this for each area. A description of key SSD analysis
'assumptions will be included. This is contained in Verify that the licensee has created a document that includes fire hazards Attachment C as Table B-3. (3.) Perform licensing action identification and nuclear safety capability assessment, on a fire area Yes reviews. (4.) Perform engineering evaluation reviews to basis, for all fire areas that could affect the nuclear safety or radioactive Ye assess the basis for the acceptability. (5.) Document results release performance criteria defined in NFPA 805 Chapter 1. and define open items or change evaluations. Table B-3 (Fire AreaFire Area Transition) does contain dispositions however, no further explanation of open items. The licensee claims that the further disposition of open items will be part of
,the Change Evaluation process.
111.2.6. CONFIGURATION CONTROL (NFPA 805 SECTION 2.7.2)
..........."*::*: :*;::*";. Section 4.7 addresses Program Documentation, place a .... 47ad se Pr amD c nt io During the Post-LAR Site Audit, verify that the licensee has in configuration management process that will maintain the design basis Configuration Control, and Quality Assurance in compliance document up-to-date as a controlled document. cwith Sections pending 2.7.1-2.7.3 the post-LAR siteofaudit.
NFPA 805. Verification is During the post-LAR Site Audit, verify that the process addresses changes affecting the design, operation, or maintenance of the plant so that they are Yes See above reviewed to determine if these changes impact the fire protection program documentation.
111.2.6. QUALITY (NFPA 805 SECTION 2.7.3) 3 Section 4.7.3 states that, in accordance with "NFPA 805 Verify that the licensee has stated in the LAR that each analysis, Section 2.7.3.1 - Review - Analyses, calculations, and calculationor perford ws evaluation . ri. Yes evaluations performed in support of compliance with 10 CFR caclandependently ewed. 50.48(c) are performed in accordance with Duke procedures that require independent review."
ri',fy that the licensee processes used to Section 4.7.3 states that "During the transition to 10 CFR During the post-LAR Site Audite 50.48(c), ONS performed work in accordance with the quality perform the engineering analyses to support NFPA,*805 transition were Yes requirements of Section 2.7.3 of NFPA 805." Verification is performed with adequate quality. .pending the post-LAR site audit.
Page 17 of 32
Preliminary Oconee LAR Acceptance Review Matrix 111.3 RISK-INFORMED, PERFORMANCE-BASED CHANGES TO THE FIRE PROTECTION LICENSING BASIS 111.3.1 High-Level Guidance The LAR does not contain results for addressing non-compliances. Discussions related to NRC comparison of the fire PRA to the draft ANS standard should be clarified.
.Setion 4.5.1 of the submittal discusses the quality (technical adequacy) of the fire PRA. the submittal mischaracterizes the NRCiMarch 17-21, 2008, assessment of the Oconee fire PRA against the draft ASME fire PRA standard as, "the NRC fire PRA revie~w of the ONS fire PRA required by RG 1.205."
Vfae
,.' hi i ae ld This statemeti*s not an accurate description of the task Verify that the LAR has identified acceptable draft or final standards asdig the NRC site audit. Oconee is a pilot as draft or final regulatory guides (or similar regulatory guidance) that NoacopihduigteNRsteui.Oonesaplt served as a basis for addressing non-compliances through a fire PRA. 50.48(c) applicatinia and therefore, as described in RG 1.205, an assessment of the Oconee PRA against the requirements of the draft fire PRA standard was performed by NRC personnel in lieu of a-review by independent industry analysts which is normally required by RG 1.200 prior to a risk informed submittal. The submittal should be modified to clarify that the NRC audit compared the draft fire PRA to the draft fire PRA standard instead of a requiring a peer review or self assessment which normally would have performed the same task.
The LAR does not contain results for addressing non-compliances. Discussions related to NRC comparison of the fire PRA to the draft ANS standard should be clarified.
Section 4.5.1 of the submittal discusses the quality (technical adequacy) of the fire PRA. The submittal mischaracterizes the NRC March 17-21, 2008, assessment of the Oconee fire PRA against the draft ASME fire PRA standard as, "the NRC fire PRA review of the ONS fire PRA required by RG 1.205."
Verify that the LAR has identified acceptable draft or final PRA standards This statement is not an accurate description of the task used to determine that the fire PRA is of sufficient technical quality to No accomplished during the NRC site audit. Oconee is a pilot support addressing non-complilrices during transition to NFPA 805. 50.48(c) application and therefore, as described in RG 1.205, an assessment of the Oconee PRA against the requirements of the draft fire PRA standard was performed by NRC personnel in lieu of a review by independent industry analysts which is normally required by RG 1.200 prior to a risk informed submittal. The submittal should be modified to clarify that the NRC audit compared the draft fire PRA to the draft fire PRA standard instead of a requiring a peer review or self assessment which normally would have performed the Page 18 of 32
Preliminary Oconee LAR Acceptance Review Matrix same task.
Discussions related to NRC comparison of the fire PRA to the draft ANS standard should be clarified. Section 4.5.1 of the submittal discusses the quality (technical adequacy) of Verify that licensee has submitted documentation for staff review, in theAfire PRA. The submittal mischaracterizes the NRC accordance with the guidance outlined in Section 4.2 of Regulatory Guide 41,rch. 17-21, 2008, assessment of the Oconee fire PRA 1.200, for NRC review as they apply to NFPA 805 LARs. For example, the against the draftASME fire PRA standard as, "the NRC fire non-pilot plants must provide all "Significant[11" Facts & Observations . PRA review of the ONS fire PRA required by RG 1.205."
("Findings") from the peer review(s) conducted for the Fire PRA, their This statement is not an accurate description of the task resolution (or plan for resolution, with schedule and commitments) and a accomplished during the NRC site audit. Oconee is a pilot list of all Significant Facts and Observations (F&Os)[ 2]'[
31 from the internal No 50.48(c) application and therefore, as described in RG 1.205, events PRA peer reviews, (including supplemental or "focused-scope" an assessrent of the Oconee PRA against the requirements reviews) that have the potential to impact the Fire PRA, and their of the draft firiePRA standard was performed by NRC resolutions The submittal shall also include significant findings from personnel in lii*iu f a review by independent industry assessments against the endorsed PRA Quality Standards and their I: analysts which is normally required by RG 1.200 prior to a resolutions, if the peer reviews were not conducted in conformance with the risk informed submittal. The submittal should be modified to endorsed standards and RG 1.200. clarify that the NRC audit compared the draft fire PRA to the draft fire PRA standard instead of a requiring a peer review or self assessment which normally would have performed the same task.
111.3.2 PRA Quality:
Discussions justifying the quality of the PRA evaluation used to develop the required change in risk estimates should be completed to address the adequacy of the baseline model.
Table 4-2 in the submittal includes a brief discussion of findings identified during the NRC audit of the fire PRA. The summary in Table 4-2 is an incomplete description of the adequacy of the baseline model. Adequacy of the baseline model (including both the internal events PAR and the fire modifications to it) may be demonstrated by identifying those Rev. 1 of Regulatory Guide 't.200(ADAMS Accession No. ML070240001), aspects of the baseline PRA model important to the January 2007, provides guidance on a set of acceptable methods and No application, and demonstrating that all finding related to the approaches the Quality of the base PRA model tocomply with section supporting requirements associated with those aspects are 2.4.3.3 of the NFPA code. satisfactorily resolved. This would require an evaluation to identify the important aspect using a method such as that described in Chapter 3 RA-Sb-2005. Alternatively, a licensee may identify all findings identified in previous reviews and address the resolution of each finding against the PRA as used in the specific application. The submittal should be modified to provide one of these two alternatives to demonstrate the adequacy of the baseline model. If important supporting requirements are first identified, Duke should describe its method and summarize its findings Page 19 of 32
Preliminary Oconee LAR Acceptance Review Matrix consistent with the guidance in Chapter 3 of RA-Sb-2005 and Section 3.1 of RG 1.200. Alternatively, Duke should expand table 4-2 to include all 39 F&O's and 44 Maracor findings including a brief discussion of each. The adequacy of Duke's resb6lution or unimportance of the requirement addressed by
- thefinriding, for this application should be explained based on
. eht types of changes modeled in support of the change in risk assessments developed'for transition to NFPA 805.
Regulatory Guide 1.200 has endorsed industry documents (NEI 00-02) and industry standards (ASME-RA-Sa-2003) with respect to internal events. RG 1.200 has not endorsed the American Nuclear Society Fire PRA Standard (ANS 58.23) or the fire section of the Combined ASME PRA Standard (ASME/ANS-RA-S-2007). However, the NRC staff published tentative positions on the combined standard in a memorandum from Mark -÷ Cunningham to distribution (ML080250107) dated March 18, 2008. " ______
Verify that the LAR provides information about the processes that the licensee has established in order to ensure that PRA and fire modeling ..... Duke calculations in support of changes that it may choose to implement after Dukereferenc section -2.7.3.5mof NFPA 805 transitioning to the NFPAYes transitioning......
A85liesn to*;, regarding post-transition quality requirements, which include ais th eiwasapeo h requirements on both the PRA and fire modeling.
processes established by the licensee, during the post-LAR Site Audit to, r en ntedfm g confirm.
Page 20 of 32
Preliminary Oconee LAR Acceptance Review Matrix 111-3.3 1 Channe
... AnaIvsiks:-
. - ________L_________1 I i Duke indicates that CDF and LERF will be the risk metrics used for evaluation, but has not yet provided the. results.
Incomplete change in risk characterizations: Section 4.5.2.1 in the submittal defines a change as a variance from the deterministic requirements as defined by the current licensing basis. Section 4.5.2.3 in the submittal states that changes requiring a risk evaluation will be assessed using risk-*informed, performance based methods. Section 4.5.3 in the submittal states that the, "results of the change evaluations are scheduled to be submitted to the NRC in the
[October] Suppfemental LAR." The change in risk evaluation Section 3.2.4 of Regulatory Guide 1.205 lists fire protection program
. calculations thlawill be performed and included in the changes that require prior NRC approval.
- supplemental submittal are ill-defined and may, or may not, address all the change in risk calculations required by the Regulatory Guide 1.205 (ADAMS accession No. ML061100174) and, by rule. Three calculations are required by the rule as reference, Revision 1 of Regulatory Guide 1.174 (ADAMS Accession No.
described in NFPA 805. The calculation in Chapter 2 must ML023240437) provide guidance on a set of acceptable methods *and be completed prior to implementation of the NFPA 805 approaches to the NRC staff, with respect to risk acceptance criteria fo:r program as required by 10CFR50.48(c)(3)(ii). The complying with Section 2.4.4 "Plant Change Evaluation," of the NEPA 805 calculations in Chapter 4 must be completed to develop the code. program that will be implemented and therefore must also be No completed before the program is implemented. These Regulatory Guide 1.200 does not provide guidance on how the base PRA calculations are: (1) The difference in risk (change in CDF is revised to address specific changes in support of NFPA 805 transition.
and LERF) between features required by the previously Staff must refer to Regulatory Guide 1.17i4and SRP 19.2 for general approved fire protection program (i.e., the current licensing guidance on review criteria on plant-spcfic changes.
basis) and features in the proposed program (NFPA 805 Section 2.2.9). (2) The difference in risk (change in CDF and For each item of non-compliance that is carried forwardtoNFPA805 LERF) between features required by the deterministic licensing basis as a risk-inforrfidperfo*rmance- based change, verify thaat requirements in NFPA and features in the proposed program the licensee has provided th.i*diffeerIcejn CDF and LERF for the plant, (NFPA 805 Section 4.2.4). (3) The additional risk (change i~n with and without the ite m!beirig in complianmle[ 6 1 Review a sample of CDF and LERF) presented by the use of recovery actions licensee's calculations-.-.
instead of deterministic requirements in the proposed program (NFPA 905 Section 4.2.4). The submittal identifies the NFPA 805 section describing all three change in risk calculations in its Table 4-4 (i.e., Section.2.2.9 and 4.2.4),
Change Evaluation Guidance Summary Table. Section 4.5.2.1 in the May 30, 2008, submittal describes a change evaluation consistent with the change in risk estimate in NFPA 805 Section 2.2.9. The June 30, 2008, letter states that an additional risk from recovery actions as described in NFPA 805 is scheduled for completion by October 31, 2008.
Neither of the submittals reported the results from the two Page 21 of 32
Preliminary Oconee LAR Acceptance Review Matrix changes in risk evaluations and it is unclear if the licensee intends to report the results. The submittal should be modified to provide all three required change in risk estimates and documentation summarizing the evaluation us4d p develop the estimates. Adequacy of the PRA
.e'viuation used to estimate the change in risk needs to be i defnonstrated. The LAR must estimate the change in risk
' a!*sociated with the facility change for which approval is bein'i, requested. Section 2.4.3.3 requires that the PRA approach, methods and data shall be acceptable to the NRC.
None of the standards and guidance documents (RA-Sb-2005, the draft fire standard, RG 1.200) describes acceptable cause-effect relationships between the baseline PRA model (including the baseline fire PRA) and the requested alternative to the deterministic requirement. For example, if fire protection wrap rated for 30 minutes is intended to be used instead of wrap rated for 3 hours0.125 days <br />0.0179 weeks <br />0.00411 months <br />, a cause effect relationship between fire wrap rating and the risk associated
. ,.-~ with a particular location is needed to estimate the risk associated with using the 30 minute rated wrap instead of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated wrap. The submittal should be modified to
'i*rclude the following information: (1) A summary of the risk
. ..... assessment methodology describing how the base PRA models was modified to appropriately model the risk impact of each type of deterministic requirement that was replaced using a risk-informed, performance-based approach; (2)
Identification of the key assumptions and approximations relevant to the results estimated for each type of deterministic requirement.
For each item of non-compliance that is ca~rr~ied forwa'rd to NFPA805 pn'c°-ris ati r dfedt oNa 05 taDuke states that "the proposed changes are evaluated to licensing basis as a risk-informed, - verify that thelicenseehas addressddefense-in-depth :safetV* mar"gins*,--.-i as Yes ensure that risk and safety margins are kept within acceptable limits. Therefore, the transition does not involve a required by Sections 4.2.4.2 ofNFPA 805 Code. :Review of sample of significant reduction in the margin of safety."
licensee's evaluations.
Verify that the licensee has provided the cumulativ4,difference in CDF and Dk ttsta adsuso fters hnedet h LERF associated with all non-compliances (cre~dit Ifor non-fire-related LERF associatedwia m c r ne results of the NFPA 805 Transition will be submitted to the decreases in CDF and LERF may be takenas;:per Regulatory Guide 1.205, No but only during the transition), from that oftde CODF and LERF for the fully NRC in the supplement to the LAR." The supplement is compliant plant. Review for accuracy, if al5Propriate. pending.
Page 22 of 32
Preliminary Oconee LAR Acceptance Review Matrix If necessary, verify that licensee has provided the total CDF and LERFi8 l (internal events and external events) of the plant as it will be configured upon completion of the transition, including all modifications to which the licensee commits in the LARW91 (licensee may use guidance provided in RG No To be provided later.
1.174 to use qualitative and quantitative information), to enable NRC staff to make decisions with respect to acceptability of plant changes using criteria provided in RG 1.174. Review a sample of licensee's calculations for accuracy.
Discussion is needed to identify the types of changes that Duke is proposing to make using its license conditions that is proposed ihAttachment M. In order to fulfill Section 2.4.3's requirementiOconee must identify which types of deterministic changes it will make in the future using the
,license condition and described the approach and methods it 7 will use to estimate the change in risk as required by the licensee condition. Each approach and method that will be Verify that the baseline PRA model for the post-transition planthas .. used in the future must be acceptable to. the NRC; both the, incorportate baselne d or the post-trations, and produpralha adequacy of the baseline models and the modification of the changes that address non-comp lances with respect to currentt lcesin-. baseline model to estimate the risk impact. NRC acceptance chne.htadesnncmlacswt g<requires epc ocretlin an NRR safety evaluation. Insofar as the methods basis, (b) completed or planned modifications including which the licensee No Nre used to support the LAR, Oconee need not repeat the has implemented to reduce risk, and (c) non-compliances (with respect to description but must identify those that it will use in the current licensing basis) that have been carried forward without plant dfuture. The submittal should be modified to include a changes, during the transition, with risk justifctions.'*i*- future.: Th umta hudb oiidt nld c e r h n n t k i ndescription of every type of change analysis that Duke propose to make under its proposed licensing condition and an accompanying description demonstrating that the resolution of review findings will fulfill the baseline technical adequacy requirements. Duke should also identify and describe the administrative procedures will be used to ensure that evaluations of future changes done under the license condition will only use approaches and methods that have been accepted by the NRC.
Item (c) above should generally consist of llI.G.2 Operator Manual Action, Hemyc or other fire barriers which do not meet the acceptance criteria, and While Duke discusses their plans to submit this material, it is deviation from the assumption of.m-multiple-spurious actuations. Item (c) may No consist of any other non-compliances-With deterministic requirements that are carried forward to the post-transitiobbplant.
For each change (e.g., deviations from assuming multiple spurious actuations, relying on III.G.2 operator manual actions), verify that the licensee has provided the change in CDF and LERF computed using the baseline PRAil iI Page 23 of 32
Preliminary Oconee LAR Acceptance Review Matrix Verify that the licensee has provided the cumulative change in CDF and LERF associated with all non-compliances (credit for non-fire-related decreases in CDF and LERF may be taken as per Regulatory Guide 1.205, No To be provided later.
but only during the transition), relative to the base line CDF and LERF for the fully compliant plant.
While Duke discusses the capability categories resulting from Verify that the licensee has identified and justified the Capability Category No the staff review of the standard supporting requirements, of the PRA used in support of the changes. these cannot yet be linked to the plant changes since the latter have yet to be provided.
NEI 04-02, Section 5.3 describes one acceptable approach to providing information to the NRC in the LAR for staff evaluation of the plant change I process. NEI 04-02 sections 5.3.2, 5.3.3, 5.3.4, and 5.3.5 describe . No To be provided later.
additional details as follows: defining the change, preliminary risk screening, risk evaluation, acceptance criteria. _________.
The NRC staff will utilize the guidance provided in Regulatory Guide 1.174 to determine the acceptability of the proposed changes. Acceptance criteria for stated delta-risk are given graphically in NEI 04-02 figure 5-2 and 5-3. These figures are identical to their equivalents provid-ed in RG 1.174. Although not required unless the changes in risk exceed No To thresholds specified in Regulatory Guide 1.174, licensees are encouragied No T be provided later.
to provide the total CDF and LERF of the post-transition plants to demonstrate any safety gains achieved by transitiopning to NFPA 805. NRC_:
staff may request licensee to provide estimate of the total CDF of the plant in its current condition to justify the committedschedule.
If a licensee has stated that it compliedcwit**10 CFR 50.48(c), using guidance provided in Section of 4.3 of Reguatory Guide 1.205, the staff may review information provided in the LAR (or a post LAR audit) to verify*,
that the licensee has followed the staff guidance. Sjome spe'cifieswhich are critical to N.PA 805 are: (a) the licnsee's, reviewof internal event-based The Executive Summary states that "The Fire PRA for all PSA model to assure its appliclb~iity toN.FPA 805 requirements, (b) if a three ONS Units to support the RI-PB Change Evaluations licensee has used pastlPElEEs in supportoPbfýNFPA 805 implementation, No the licensee's review of past analysis to determihe theircdontinued per Regulatory Positions C.2.2 and C.4.3 of Regulatory applicability, (c) the method§'*used by licensees' t 6reconsid.r scenarios Guide (RG) 1.205 has not been completed."
previously screened from analysis, if changes a~sobiated with NFPA 805 requirements or compliance alter the scope of the0original analysis, (d) steps taken to avoid non-conservative double counting of "modification factor" or "severity factor" in relationhto*detectior. *a.nad suppression.
Page 24 of 32
Preliminary Oconee LAR Acceptance Review Matrix SuDDortina Documentation 1~ I. -I Section 4.5.1.1 states that "In January 2008, Duke performed a self-assessment of the ONS PRA against RG 1.200, An Approach for Determining the Technical Adequacy of 10 CFR 50.48(c) endorsed Section 2.7.2.2 "Supporting Documentation," of Pr6babilistic Risk Assessment Results for Risk-Informed NFPA 805 without exceptions. Section 2.7.2.2 states that detailed SActivities, Revision 1 ... The assessment indicated that there supporting documentation shall be retrievable records. Section 4.5 of are forty-four ASME PRA Standard Supporting Requirements Appendix H NEI-04-02 also states licensee's responsibilities with respect to (SRs) that are not fully met. Of these, thirty-six pertain to the No program documentation. The reviewer should verify that the licensee has need9to*enhance documentation ... The results and stated that it complied with 10 CFR 50.48(c) with respect to archival conclusions of Duke's self assessment against RG 1.200 will documentation per guidance provided in Section 4.1 of Regulatory Guide be docurm*ented in a Duke Calculation entitled, 'PRA Quality 1.200 or other acceptable standard. Self-Assessment.' Completion of this calculation is being tracked in the corrective action program." While Section 4.7
'addresses program documentation, it can only be inferred that the reauirements of RG 1.200. or eauivalent will be met.
Verify that the LAR provide a paragraph or statement confirming that the licensee is in possession of archival documentation in accordance with guidance outlined in Section . 4.1 of Regulatory Guide 1.200 for*,NRC autdit.
If the licensee's archival documentation deviates from the guidance provided in Section 4.1 of Regulatory Guide 1. 200, determine the No See above adequacy for the justification.
During the post-LAR Site Audit, review a sample of docuimn:rits to confirm No See above (also pending post-LAR site audit) that the licensee is I possession of archival documentation.
111.3.3. DEFENSE-IN-DEPTH 1
The staff must verify thtlat tte result of the proposed changes satisfy defense-in-depth considerations. In general, the defenseii-ý-depth requirement is satisfied if ftiheproposed change does not result in a The LAR does not discuss the need to prevent the imbalance substantial imbalance in: preventing fires from starting, detecting fires among the three requirements for proposed changes other quickly and extinguishing those thatoccur, thereby limiting damage, and No that stating in Section 4.5.2.4 that "The proposed change providing adequate level of fire protection for structures, systems and must also be consistent with the defense-in-depth philosophy components important to safety so thlat a fire that is not promptly and must maintain sufficient safety margins.."
extinguished will not prevent essential plant safety functions from being performed.
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Preliminary Oconee LAR Acceptance Review Matrix Regulatory Guide 1.174 and NEI 00-01 provide the following guidance with respect to maintaining defense-in-depth: "Consistency with the defense-in-depth philosophy is maintained if the following acceptance guidelines, or their equivalent, are met: a reasonable balance is preserved among 10 CFR 50 Appendix R DID elements, over-reliance and increased length of time or risk in performing programmatic activities to compensate for Section 5.3.1 on "No Significant Hazards Consideration" weaknesses in plant design is avoided, pre-fire nuclear safety system states that "NFPA 805 continues to protect public health and redundancy, independence, and diversity are preserved commensurate s*fety and the common defense and security because the with the expected frequency and consequences of challenges to the overall approach of NFPA 805 is consistent with the key system and uncertainties (e.g., no risk outliers). (This should not be principles for evaluating license basis changes, as described construed to mean that more than one safe shutdown train must be in RG 1. 174, is consistent with the defense-in-depth maintained free of fire damage), independence of defense-in-depth No philosophy, and maintains sufficient safety margins."
elements is not degraded, defenses against human errors are preserved, Adherence to the 'RG-1.174 criteria can only be inferred.
and the intent of the General Design Criteria in Appendix A to 10 CFR Part' Also, Section 5.1 states that "The voluntary adoption of 10 50 is maintained. It should be noted that all elements of fire protection DID' CFR 50.48(c) by ONS does not eliminate the need to comply may not exist for beyond design basis fire scenarios. For example, a CDP with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, GDC 3, of 1 .0 is possible if enough fire barriers are breached. Such beyond design Fire Protection."
basis scenarios, however, should be demonstrated to be of less risk significance, with certainty. A scenario with all elements of DID, anid aCDF of 9E-08/year would be treated differently than a scenario withl a'CDPo&f 1.0, and a CDF of 9E-08/year. In the end, the balance results inhF!
consideration of all aspects of the component combination, including the risk, DID, SM, uncertainty, and other relevant isý'-ues."'-- '* -
111.3.3. SAFETY MARGINS The staff must verify that the result of the proposed changes satisfy safety margin considerations. NFPA 805 AppendixA, SectionA.?2.4.4.3.,n-) pro s Section 4.5.2.4 states "The Change Evaluations are an example of maintaining sufficient safety margins as "..when the assessed quantitatively for acceptability using the ACDF existing calculated margin between-the analysis.6 n the performance (change in core damage frequency) and ALERF (change in criteria compensates for the uncertaintie* associated with the analysis and large early release frequency) criteria from Section 5.3.5 of data. Another way that safety. margins ar'e maintained: is through the NEI 04-02 and RG 1.205. The results of the acceptability application of codes and standards. Consensus codes and standards are determination are documented in calculations. The proposed typically designed to ensure.such safety margins exist." One acceptable change must also be consistent with the defense-in-depth approach for the treatment of Safety Margins is-provided in.NEI 04-02, philosophy and must maintain sufficient safety margins."
Section 5.3.5.3. '
111.3.4 FIRE MODELING CALCULATIONS, 111.3.4. ACCEPTABLE MODELS " .'
Only fire models that are acceptable to-the au'ith*rity having jurisdiction No discussions, methodology, applications, nor detailed shall be used in fire modeling calculations.lThe models currently evaluated analyses of fire modeling calculations and results are by the NRC for use in NFPA 805 transition are as follows: Fire Dynamics No documented in the LAR No. 2008-01. There is only an Tools (FDT) as documented in NUREG-1 805, Fire-Induced Vulnerability acknowledgement that the fire modeling was performed in Evaluation (FIVE), Revision 1, Consolidated Fire Growth and Smoke compliance with NFPA 805 requirements. Also, no Page 26 of 32
Preliminary Oconee LAR Acceptance Review Matrix Transport Model, CFAST, MAGIC, and Fire Dynamics Simulator (FDS). assessment concerning specific high energy arcing fault Verify that the licensee has identified the fire modeling tools that they have scenarios has been provided.
used.
111.3 LIMITATIONS OF USE The reviewer should verify that the licensee has stated that the fire models The documentation in LAR No. 2008-01 for the fire modeling used have been used within the scope, limitations and assumptions review is neither adequate nor sufficient to proceed with its prescribed for that method. The reviewer should use NUREG-1824 in No detailed technical review. Documentation is needed on making this determination. During the post-LAR site visit, review a sample . detailed fire modeling calculations and tool/approaches of calculations to determine the adequacy of licensee's calculations. used for each plant area being modeled.
111.3.4. VERIFICATION AND VALIDATION 3
The five fire models that have bee inapproved for use by the NRC have ,"LAR No. 2008-01,Section 4.7.3, indicates compliance with been verified and validated by a joint effort by NRC Researchand the the quality requirements of NFPA 805, Section 2.7.3.2, Yes Verification and Validation," Section 2.7.3.2, "Limitations of Electric Power Research Institute (EPRI). This verification a.d validation Use," Section 2.7.3.4, "Qualification of User," and Section
- effort has been documented in NUREG-1824/EPRI 1011999;i . 2.7.3.5, "Uncertainty Analysis."
During the post-LAR site visit, review a sample of calculations to (determine Yes Se.bv pnigps-A ieadt the adequacy of licensee's calculations. Yes See above (pending post-LAR site audit) 111.3.4. QUALIFICATION OF USERS 4
Section 4.7.3 states that "During the transition to 10 CFR provided documentation that Verify that the licensee has stated and/or personnel 50.48(c), ONS performed work in accordance with the quality performing.. fe m g arequirements of Section 2.7.3 of NFPA 805 ... NFPA 805 experienced in the application ofdthel e methods as thýeyrelateltodnuclear Yes Section 2.7.3.4 - Qualification of Users - Cognizant xpoerienced lnthe applicationpofer lathesemotecthodsasthpowey plant ....... Y personnel who use and apply engineering analysis and power plants, nuclear power :ilaht fire protection and power plant nmrclmtosi upr fcmlac ih1 F operations. numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805."
111.3.5 FIRE RISK EVALUATIONS':.7,,> _______
111.3.5. MEASURES Verify that the licensee has used coe damage freqency (CDF) and Large Duke indicates that CDF and LERF will be the risk metrics Early Release Frequency (LERF) asormeasuresqfencr y No used for evaluation, but has not yet provided the results.
Page 27 of 32
Preliminary Oconee LAR Acceptance Review Matrix 111.3.5. RISK CONTRIBUTORS 2
Verify that the licensee has addressed the risk contribution associated with all potentially risk-significant fire scenarios by reviewing the methods and No , I, provided later.
NT, podlt approaches, and/or sample of calculations provided by the licensee in its LAR.
111.3.5. APPROACH, METHODS AND DATA 3
111.3.5. USE OF FIRE PSA 4
Verify that the change evaluation process used by the licensee for the performance-based approach consists of an integrated assessment of the. Duke provides statements assuring that DID and SM will be acceptability of risk, defense-in-depth and safety margins by reviewing the' Yes .considered and mintained.
methods and approaches, and/or a sample of calculations provided by the.c licensee in its LAR.
111.3.5. RISK EVALUATION PROCESS 5
Review a sample of licensee's calculations to verify that the evaluation process used by the licensee compared the risk associated with, implementation of the deterministic requirements with the proposed alternative by reviewing the methods and approaches, and/or a slmple of No To be provided later.
calculations provided by the licensee in its LAR. lsoi verify that the difference in risk between the two approac~hesmeets the risk acceptancre criteria described in RG 1.205, Regulatory-Position,3.2.
111.3.6 UNCERTAINTIES Section 2.7.3.5 of NFPA 805 Code requires licensee to perform an uncertainty analysis to provide reasonable assurahce that the performance criteria have been met. Review a samp*J*le of analysis to evaluate the adequacy of the uncertainty analysis relatinrg' to issues such as fire modeling, and hazard analysis. Also, verify thatthe licensee has performed appropriate uncertainty¢ nalyses i to provide reasonable assurance that the No To be provided later.
performance criteria have been met by reviewing the methods and approaches, and/or a sample6ofcalculations provided by the licensee in its LAR. Section 5.3.5.4 of NEI 04-02 provides addi*ional details on uncertainty considerations. ... ___ __ ____.... ____-_ __ ___ __
Page 28 of 32
Preliminary Oconee LAR Acceptance Review Matrix 111.3.7 MONITORING (NFPA 805 SECTION 2.6) +
Duke discusses their plans for establishing a monitoring program, including acceptable methods. However, the monitoring program should be defined. Section 4.6 in the submittal provides an overview of the Oconee's proposed During post-LAR site audit, verify that the licensee has established a post-transition monitoring program. The overview describes monitoring program to ensure that the availability and reliability of the fire Oconee's plans to define, establishing, and implement a protection systems and features are maintained and to assess monii*oring program. The current description in the submittal performance of the fire protection program in meeting the performance providing an overview of the plan to develop the program
~No~ does not fulfill 10CFR50.48(c)(3)(ii) requirement that the criteria. Monitoring shall ensure that the assumptions in the engineering analyses remain valid. The reviewer must verify that the licensee has licensee complete all required evaluations and analyses in programs I included a statement in the LAR verifying that such monitoring Chapter 2 of NFPA 805 before changing its fire protection have been established. program. The submittal should be modified to summarize the acceptance guidelines, described how these guidelines have been developed, and summarize the methods that have been developed to monitor plant performance and return to established levels if the acceptance guidelines are exceeded.
i 3.7.1 AVAILABILITY, RELIABILITY AND PERFORMANCE LEVELS i I i Duke discusses their plans for establishing a monitoring program, including acceptable methods. However, the monitoring program should be defined. Section 4.6 in the submittal provides an overview of the Oconee's proposed post-transition monitoring program. The overview describes Oconee's plans to define, establishing, and implement a monitoring program. The current description in the submittal Section 2.6.1 of the NFPA 805 Code requires licenseesto estabhisl providing an overview of the plan to develop the program No does not fulfill 10CFR50.48(c)(3)(ii) requirement that the acceptable levels of availability; reliability and rperforriance.
licensee complete all required evaluations and analyses in Chapter 2 of NFPA 805 before changing its fire protection program. The submittal should be modified to summarize the acceptance guidelines, described how these guidelines have been developed, and summarize the methods that have been developed to monitor plant performance and return to
________ +/- ___________
established levels if the acceptance guidelines are exceeded.
Page 29 of 32
Preliminary Oconee LAR Acceptance Review Matrix Section 4.6.2 states that "The following process will be established for monitoring post-transition ... A flowchart of the overall process for NFPA 805 monitoring implementation is shown in Figure 4-7 ... These performance criteria will be Verify that the levels of availability, reliability and performance ustablished established for items within the NFPA 805 monitoring scope, by the licensee are acceptable by evaluating the approaches used by the No regardless of their ability to. be measured using risk licensee to establish them. ,significant criteria. The performance criteria used should be
. availability, reliability, or condition, as appropriate." However, no specific values or the means of establishing them are
. . ..... __ presented.
3.7.2 MONITORING AVAILABILITY, RELIABILITY AND PERFORMANCE LEVELS Duke discussestheir plans for establishing a monitoring program, including acceptable methods. However, the monitoring program should be defined. Section 4.6 in the submittal provides an overview of the Oconee's proposed post-transition monitoring program. The overview describes Oconee's plans to define, establishing, and implement a monitoring program. The current description in the submittal NFPA 805, Section 2.6.2, requires the licensee to establish rnethod* .........
top ..............**!*providing an overview of the plan to develop the program monitor availability, reliability and performance. These methods sihaIl No does not fulfill 1CFR50.48(c)(3)(ii) requirement that the consider the plant operating experience and industry operating experience. -licensee complete all required evaluations and analyses in Chapter 2 of NFPA 805 before changing its fire protection program. The submittal should be modified to summarize the acceptance guidelines, described how these guidelines have been developed, and summarize the methods that have been developed to monitor plant performance and return to established levels if the acceptance guidelines are exceeded.
The overview describes Oconee's plans to define,
- .. . establishing, and implement a monitoring program. The current description in the submittal providing an overview of the plan to develop the program does not fulfill 10CFR50.48(c)(3)(ii) requirement that the licensee complete Verify that the licensee has included a statement in the LAPRverifying that No all required evaluations and analyses in Chapter 2 of NFPA such methods have been established. 805 before changing its fire protection program. The submittal should be modified to summarize the acceptance guidelines, described how these guidelines have been developed, and summarize the methods that have been developed to monitor plant performance and return to established levels if the acceptance guidelines are exceeded.
During the post-LAR site audit, review a sample of calculation to confirm that that the licensee has established procedures at the site to meet No See above
.requirements of Section 2.6.2.
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Preliminary Oconee LAR Acceptance Review Matrix 3.8 CORRECTIVE ACTION (NFPA 805 SECTION 2.6.3)
Section 2.6.3 of NFPA 805 requires the licensee to establish appropriate corrective actions, if the established levels of availability, reliability and Duke discusses their plans for establishing a monitoring performance are not met, to return to the established levels. It also require Yes program, including acceptable methods and corrective licensee to establish monitoring to ensure that the corrective actions are actio*ns.
effective. .
As stated in Section 4.6.1, "The intent of the [monitoring]
review will be to confirm (or modify as necessary) the adequacy of the existing surveillance, testing, maintenance, Verify that the licensee has provided a statement in its LAR confirming that compensatory measures, and oversight processes for it has established procedures at the site to meet requirements of Section Yes transition toNFPA 805. This review will consider the..
2.6.3. adequacy of the, plant corrective action program in determining causes of equipment and programmatic failures and in minimizing their recurrence." Reference to PIP-0 2163 on corrective actions is cited throughout Table B-1.
During the post-LAR site audit/, review a sample of procedures and confirm that that the licenseehas established procedures at the sitedto meet Yes See above (pending verification by the post-LAR site audit) requirements of Section 2.6.3.
3.9 RECOVERY ACTIONS In reviewing LARs for transition to a performance-based fire protection M n g r b se r s program, particular attention should be paid to any operator manual actions OMA (including repair) will be classified as recovery actions.
credited for protection of redundant trains in Iieiuof Appe*dix R, III.G.2 Licensee states that the feasibility will be evaluated as per protection. Unless these operator actions iere specifically2approved by NEI-00-01 with additional consideration from FAO-06-0011 NRC they should be treated as plant changes per section 2-A.4 of . and FAQ-06-0012. A discussion with NRC staff was ManuaJop-rator Yes documented in FAQ-07-0030. The licensee acknowledges N FPA 805, using performance based methiods. Manual o~perator *actionsi*,i, Nmay 805, usingred apperformaned based meCrates e t ia a that the guidance in NEI-04-02 suggests that these may be considered approved if NRC granted an exemption fromparagraph assumptions, criteria, methodology and overall results be IeI.G.2 of Appendix R, or if thepynariua[ actions are associated with included for NRC to determine the acceptability of the equipment above and beyondthe.credied..tr.ain with protection as specified methodology.
in paragraph IlI.G.2 of A ppendix R as described in RIS 2006-10.
Review a sample of licensee's analysis to ensure that th*eibensee has Duke to provide the required information in a supplemental No submita by tober 30, 2008.
identified IlI.G.2 manual acti6ns in accordance with guidance provided in submittal by October 30, 2008.
3.9.1 RISK NFPA 805 Section 4.2.4 requires the licensee ,to evaluate the additional Section 4.8.2.2 states that "the determination of the risk imposed when performance-based approach are used to justify additional risk presented by the use of recovery actions as a recovery actions in lieu of meeting with the deterministic requirements No compliance strategy have not been completed. These tasks provided in Section 4.2.3 of NFPA 805. Review a sample of licensee's are scheduled for completion and the results will be evaluations to verify that the licensee has complied with this requirement. submitted to the NRC in the supplement to the LAR."
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Preliminary Oconee LAR Acceptance Review Matrix Where the recovery actions have been previously approved by the NRC using staff SERs, those recovery actions constitute part of the licensee's current licensing basis. Transition of such pre-approved actions to an.
NFPA 805 licensing basis does not constitute changes to the licensing NoSe.bv basis. Consequently, the staff should treat the changes in CDF and LERF attributed to such recovery actions as zero.
3.9.2 OPERATIONAL GUIDANCE NFPA 805 Section 4.2.4.1.6 requires the licensee to provide guidance to App. F (MSOs): The performance-based approach may plant personnel that details the credited success path(s) for each fire area, include the use of feasible and reliable recovery actions.
including the performance of recovery actions and repairs. During the During transition, if the recovery actions are deemed post-LAR site audit, the review a sample of licensee's procedures to verify No unallow*ed per the pre-transition licensing basis (Bin H for that (a) the guidance meets the NRC acceptance criteria, and (b) the NO FAQ 06-0012), a RI-PB Change Evaluation may be used as licensee's processes ensures that licensee continues to provide guidance potential means of demonstrating NFPA 805 compliance.
to plant personnel when licensee implements changes to the fire protection However, this does not appear to constitute provision of the program after receiving the NFPA 805 license. required guidance.
Verify that the licensee has provided a statement in the LAR confirming that the operational guidance required by NFPA 805. Implicit inithis requirement is that all recovery actions are feasible. Criteria b**sed No See above (note there is no mention of NUREG-1 852) judging feasibility of recovery actions are provided in NUREG 1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in.
Response to Fire."
Page 32 of 32