ML110691134

E-mail from B. Metzger, NRR to K. Sullivan, BNL on Operator Manual Actions Reviews

ML110691134
Person / Time
Site:	Indian Point, Wolf Creek, Oyster Creek
Issue date:	08/31/2009
From:	Brian Metzger NRC/NRR/DRA/AFPB
To:	Sullivan K Brookhaven National Lab (BNL)
References
FOIA/PA-2011-0069
Download: ML110691134 (3)

Text

Metzger, Brian From: Metzger, Brianflo-11L Sent: Monday, August 31, 2009 5:14 PM To: 'ks@bnl.gov'

• Cc: Frumkin, Daniel

Subject:

Operator Manual Actions Reviews

Ken, I am working with Dan Frumkin on the completing the operator manual action reviews that I understand your group will be assisting us with. As you may have heard we are under a very tight schedule at this point so I wanted to pass along some front-end work that we have done to help give you a jump start on the reviews you will be doing.

I have attached a spreadsheet containing some notes that we made following cursory reviews of the plants.

Please select the tabs for the plants you will be reviewing (Wolf Creek, Indian Point and Oyster Creek) as well as the summary pages. From this, you may notice how we plan to approach the reviews and subsequent RAIs. I have also shared a draft of what we are generally referring to as "generic" RAIs below that will apply to most, or all, of the licensees in this group of exemption/amendment requests.

"Generic" RAIs RAI-01 Circumstances for Review Option 1 Provide a justification of the circumstances that warrant the consideration of these License Amendment requests. Include a technical justification of how the proposed changes affect safe shut down capabilities and how the proposed means of compliance are effective in mitigating that affect.

Option 2 Indicate what special circumstances (see 50.12.2), aside from potentially incurred costs or effort, are present that constitute the necessity for an exemption. If it is the licensee's opinion that such costs represent undue hardship and are significantly in excess of those contemplated when the regulation was adopted, then provide a cost analysis substantiating this claim. Additionally, demonstrate how the underlying purpose of the rule is met through the use of the proposed OMAs.

RAI-02 Regulatory Deficiency Provide a detailed description of the deficiencies that exist with regard to fire detection, suppression, intervening combustibles and spatial separation and explain how the deficiencies are mitigated with other forms of defense-in-depth measures. For example, if the 20-ft spatial separation between redundant equipment trains is not provided, provide a description of the separation that is provided and a justification for how the established level of safety and protection is maintained.

The licensee's response should also include a technical explanation to justify how the proposed methods will result in a level of protection that is consistent with that intended by III.G.2. For example, demonstrate that defense-in-depth is provided such that operators are able to safely and reliably shut down the plant from the control room. Note that it is the Nuclear Regulatory Commission (NRC) staffs position that operator manual actions alone, regardless of their feasibility and reliability, do not meet the underlying purpose of the rule without specific consideration of the overall defense-in-depth methodology in place in a particular fire area.

RAI-03 Ensuring That One of the Redundant Trains Is Free of Fire Damage K . .,

1

If redundant equipment is co-located in a fire area and all of the equipment in that fire area is assumed lost during a fire event, this is inconsistent with III.G.2, which states that measures must be taken to ensure that one of the redundant trains remains free of fire damage. Furthermore, the use of OMAs, in lieu of the three options provided in III.G.2, is not explicitly included as a means of compliance with III.G.2.

RAI-04 Other Evaluations Fire areas may have other license amendments or engineering evaluations that affect fire protection systems or safe shutdown capabilities.

Provide a discussion of any other amendments or evaluations that impact this request in any way and a justification for why such impact should be considered acceptable.

RAI-05 Standards and Listings for Systems and Barriers Where fire protection features such as detection and suppression systems and fire rated assemblies are installed, describe the technical basis for such installations including the applicable codes, standards and listings. In addition, provide a technical justification for any deviations from codes, standards and listings by independent testing laboratories in the fire areas that could impact this evaluation. Additionally, provide a technical justification for any non-rated fire protection assemblies.

For example:

Fire Area (FA) 27 is noted as having ionization smoke detectors installed throughout the area. State whether the detectors have been installed and maintained in accordance with a particular design standard or basis, e.g.

National Fire Protection Association 72: National Fire Alarm Code, 1985 Edition.

Section 3.1 of the March 3, 2009, request states that the fire barriers that enclose Fire Zone Z127 do not contain 3-hour rated doors. Additionally, no description is provided for the water-tight door in Fire Zone Z1 09.

Fire Zone Z1 39 is noted as having an automatic wet pipe sprinkler system installed over areas of concentrated cabling. State whether the sprinklers have been installed and maintained in accordance with a particular design standard or basis, e.g. National Fire Protection Association 13: Standard for the Installation of Sprinkler Systems, 1985 Edition.

RAI-06 Time and Sequence Assumptions The requests lack a detailed description of the series of events that may occur prior to initiating the Operator Manual Action (OMA) procedures.

Describe the circumstances and assumptions needed to enter the OMA procedure. For example, describe the amount of time, and the technical basis, that has been assumed for detection and assessment of a postulated fire. Additionally, provide an analysis and a technical justification to evaluate scenarios where components fail, or damage occurs, before a fire has been detected.

Hopefully this information will help you formulate your RAls. If you have any questions or suggestions, please feel free to contact me at your convenience.

OMA Exemptions Table.xls

Regards, Brian Metzger Fire Protection Engineer, NRR/DRA/AFPB, 2

Phone: 301-415-3972 Location: O-10G13 Mail Stop: O-10C15

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