ML091030601
| ML091030601 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/2009 |
| From: | Grobe J NRC/NRR/ADES |
| To: | Marion A Nuclear Energy Institute |
| Oudinot D, NRR/DRA, 415-4064 | |
| References | |
| NEI-00-01, Rev 2c | |
| Download: ML091030601 (5) | |
Text
April 15, 2009 Alexander Marion, Vice President Nuclear Operations Nuclear Energy Institute 1776 I Street, N W, Suite 400 Washington, D.C. 20006
SUBJECT:
NUCLEAR REGULATORY COMMISSION COMMENTS ON NUCLEAR ENERGY INSTITUTE 00-01, REVISION 2C, GUIDANCE FOR POST-FIRE SAFE SHUTDOWN CIRCUIT ANALYSIS
Dear Mr. Marion:
On January 13, 2009, you provided the Draft Revision 2c of NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, for the Nuclear Regulatory Commission (NRC) staffs review and comment. Even though NRC prefers to review final as opposed to draft documents, NRC reviewed this draft document in order to minimize any potential delays to the NRCs Fire Protection Stabilization Plan.
The staff of the Office of Nuclear Reactor Regulation (NRR), the Office of Nuclear Regulatory Research (RES), and the Office of New Reactors (NRO), completed the review of NEI 00-01, Revision 2c, and transmitted detailed comments via an electronic markup of NEI 00-01, Revision 2c, on March 17, 2009. Subsequent to that, in order to shorten the ongoing iteration process that will lead to a final version of NEI 00-01, Revision 2c, the staff held a public technical meeting with NEI to discuss the NRC staff comments on March 30, 2009.
In your January 13, 2009, letter, you also indicated that you look forward to NRC endorsement of NEI 00-01, Revision 2c, without exceptions, for industry use. In this letter, we provide preliminary NRC staff views on how NEI 00-01, Revision 2c, may be used by licensees to comply with NRCs fire protection regulations, when NRC staff comments on NEI 00-01 are satisfactorily addressed.
A summary of the NRC staff views on each section of NEI 00-01, Revision 2c, is delineated in. The NRC plans to endorse appropriate sections for regulatory use when NEI satisfactorily dispositions the comments provided in the email dated March 17, 2009, and addresses other issues identified in Enclosure.
As discussed with your staff, we expect that you will provide us a revised NEI 00-01 by April 30, 2009. In order to minimize the staff burden with respect to re-review of NEI 00-01, Revision 2c, please provide the staff an electronic comparison version highlighting all changes, including editorial changes.
We thank you for the efforts expended by NEI in developing a tool that enables licensees to address multiple spurious operations.
Sincerely,
/RA/
John A. Grobe, Associate Director for Engineering and Safety Systems Office of Nuclear Reactor Regulation
Enclosure:
As stated We thank you for the efforts expended by NEI in developing a tool that enables licensees to address multiple spurious operations.
Sincerely,
/RA/
John A. Grobe, Associate Director for Engineering and Safety Systems Office of Nuclear Reactor Regulation DISTRIBUTION PMNS ADAMS HBarrett MSalley JGrobe SWeerakkody MCunningham RRadlinski RidsRgn1MailCenter MGalloway JRogge RidsNrrDraAfpb RidsRgn2MailCenter DFrumkin AKlein RidsRgn3MailCenter RidsRgn4MailCenter ADAMS No. ML091030601 (Letter to NEI)
ADAMS No. ML090750728 (January 13, 2009, NEI letter, transmitting NEI 00-01, Revision 2c)
ADAMS No. ML090780295 Pkg (E-mail to NEI with mark up copy of NEI 00-01, Revision 2c)
ADAMS No. ML090750438 (3-30-09 Meeting announcement)
ADAMS No: ML091030271 (Summary of 3-30-2009 meeting regarding staffs comments)
NRR-106 OFFICE NRR/DRA/AFPB NRR/DRA/ADPB NRR/DRA/ADPB NRR/DRA/ADPB NRR/DRA/ADPB NAME DOudinot DFrumkin AKlein SWeerakkody JGrobe DATE 04 /14/09 04 /14/09 04/14/09 04 /15/09 04/15/09 OFFICIAL RECORD COPY
ENCLOSURE Summary of NRC Staff Views on NEI 00-01, Revision 2c Chapter 1: Introduction This chapter provides useful background information on some issues such as the circuit resolution.
Chapter 2: Appendix R Requirements and Considerations This chapter describes Nuclear Regulatory Commission (NRC rules) and guidance that are useful to licensees. The staff finds this chapter acceptable. However, in the event of potential conflicts, Title 10 of the Code of Federal Regulations Part 50 10 CFR 50.48 and Regulatory Guide (RG) 1.189 would take precedence over this Chapter 2.
Chapter 3: Deterministic Methodology This chapter provides one acceptable way to perform circuit analysis to meet 10 CFR 50.48.
The staffs endorsement of Chapter 3 is predicated on the verification that Chapter 3 and Chapter 5 discussions about multiple spurious operations (MSOs) are consistent. The NRC plans to propose endorsement of Chapter 3 of NEI 00-01, Revision 2c, upon acceptable incorporation of NRC comments.
Chapter 4: Identification and Treatment of Multiple Spurious Operations This chapter provides one acceptable method that licensee may use to treat MSOs. This chapter references Appendices G and H. The staff views with respect to these appendices are delineated below. The NRC plans to propose endorsement of Chapter 4 of NEI 00-01, Revision 2c, upon acceptable incorporation of NRC comments.
Chapter 5: Risk Significance Analysis As mentioned in our previous communications, licensees who choose to use techniques provided in Chapter 5 analysis are required to submit a license amendment or exemption request for the use of risk tools outside of the adoption of National Fire Protection Association Standard (NFPA) 805. The NRC does not endorse the use of the content of this chapter for those licensees who are not transitioning to NFPA 805.
Chapter 6: Definitions The staff has compared the definitions provided in this chapter against the definitions provided in RG 1.189. This chapter provides definitions that are acceptable to NRC. However, established NRC definitions take precedence where differences exist.
Chapter 7: References The staff views with respect to NEI 00-01 does not constitute endorsements of documents referenced in NEI 00-01 Rev. 2c.
Appendix A: Safe Shutdown Analysis as Part of an Overall Fire Protection Program This appendix provides a historical discussion of the Browns Ferry fire and of the events that followed. The staff agrees that this appendix provides useful information regarding safe shutdown analysis.
Appendix B: Deterministic Circuit Failure Criteria This appendix provides the criteria for evaluating circuit failures and serves to identify the type of circuit failures that need to be considered as a part of the deterministic analysis. It also discusses fire tests and insights from fire tests. The staff agrees with the criteria provided in this chapter. The staff agrees that this appendix provides useful information regarding fire tests and insights derived from those fire tests.
Appendix C: High / Low Pressure Interfaces This appendix contains information derived from several existing regulatory documents. It provides a useful summary which the licensees may use in circuit analysis.
Appendix D: Alternative/Dedicated Shutdown Requirements The fire protection rule contains the alternative/dedicated shutdown requirements. RG 1.189 provides additional descriptions with respect to one acceptable method for complying with NRC regulations with respect to 10 CFR 50.48. This appendix contains additional information useful to the licensees.
Appendix E: Acceptance Criteria Operator Manual Actions and Repairs This appendix provides one acceptable method that licensees may use to address operator manual actions and repairs. However, the NRC review guide for post-fire operator manual actions is NUREG-1852 Demonstrating the Feasibility and Reliability of Operator Manual Actions In Response to Fire. Licensees should consider the information in NUREG-1852 prior to applying this Appendix. Also note that application of this Appendix in lieu of defense-in-depth elements of the approved fire protection program (e.g., fire barriers, fire suppression systems),
is not considered sufficient for a no adverse affect on the ability to achieve and maintain safe shutdown as required by the fire protection license condition.
Appendix F: Supplemental Selection Guidance (Discretionary)
The information contained in this appendix may be superseded by RG 1.205 or even Chapter 5 of NEI 00-01. The discretionary aspect of this guidance precludes staffs endorsement.
Appendix G: Generic List of MSOs This appendix provides a generic list of MSOs that will be very useful to the licensees in following the method provided in Chapter 4. The staff does not consider the information provided in Appendix G as exhaustive because it does not ensure all sequences are included.
Therefore, this appendix does not constitute compliance with 10 CFR 50.48. Each licensee must use methods used in Chapter 4 and use additional information provided in Appendix G to generate a list of MSOs for their respective plants.
Appendix H: Required for Hot Shutdown versus Important to SSD Components The appendix provides one acceptable method in defining required for hot shutdown vs important to safe shutdown components. It supplements information provided in the planned update to the RG 1.189, Chapter 5.