ML110700084
| ML110700084 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/01/2009 |
| From: | Daniel Frumkin NRC/NRR/DRA/AFPB |
| To: | Brian Metzger NRC/NRR/DRA/AFPB |
| References | |
| FOIA/PA-2011-0069, Job Code J4242, TAC ME0756 | |
| Download: ML110700084 (10) | |
Text
Metzger, Brian From: Frumkin, Daniel 114, Sent: Thursday, October 01, 2009 3:34 PM To: Metzger, Brian
Subject:
Attachments: RAI 1 OCNGS (DRAFT KS).doc From: Sullivan, Kenneth <ksabnl.gov> , Y1* /L To: Frumkin, Daniel Sent: Thu Oct 01 15:32:43 2009
Subject:
Dan Attached is a draft RAI developed for the Oyster Creek Phase 1 OMA submittal A final version will follow shortly pending completion of our internal review cycle As stated in the report, I did not find any linkage between the OMAs listed in the submittal and prior staff approval in the referenced SERs Acknowledgement of OMAs in an SER, by itself, does not demonstrate approval since the staff may have been referring to OMAs related to the non-protected train of equipment.
As you are aware, such actions would typically not be reviewed by the staff.
Give me a call if you have any questions Thanks Ken Sullivan BNL
Energy Sciences and Technology Department BROPKHR EN Building 130 P.O. Box 5000 NATION-KL LABORATORY Upton, NY 11973-5000 Phone 631 344-7915 ks&-bnI.aov managed by Brookhaven Science Associates for the U.S. Department of Energy www.bnl.qov Mr. Daniel Frumkin U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Risk Assessment, Fire Protection Branch (NRR/DRA / AFPB)
Washington, DC 20555-0001
Reference:
JCN No. J-4242, Task Order No. 1, Exelon Generation Company, Oyster Creek Nuclear Generating Station TAC No. ME0756.
Dear Mr. Frumkin :
By letter to the Nuclear Regulatory Commission (NRC) dated March 3, 2009, Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50, Section Ill.G, "Fire Protection of Safe Shutdown Capability," for Oyster Creek Nuclear Generating station.
In accordance with the scope of work described in Task 1 of Project 4242, I have reviewed the request submitted by the licensee and identified a need for additional information, as set forth in the Enclosure.
Of primary concern is that although the licensee's submittal states that basis for the request is prior approval by the NRC in Safety Evaluation Reports (SER) dated March 24, 1986 and June 25, 1990, for reasons discussed in RAI KS-OC1 -4 of the Enclosure, I find that the licensee does not provide a suitable justification to support this statement. If the licensee is unable to provide a clear link between the referenced SERs and the requested OMAs, a more comprehensive evaluation demonstrating conformance of the requested OMAs to the feasibility and reliability criteria of NUREG 1852 may be necessary.
Ifyou have any questions, please contact me at (631) 344-7915.
Sincerely, Kenneth Sullivan cc: B. Grenier, NRC D. Diamond J. Higgins Project File J4242., Task 1 REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM 10 CFR 50 APPENDIX R. SECTION III.G OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 By letter to the Nuclear Regulatory Commission (NRC) dated March 3, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML090630132), Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50, Section IlI.G, "Fire Protection of Safe Shutdown Capability," for Oyster Creek Nuclear Generating Station (OCNGS). The NRC staff has reviewed the request for exemption the licensee provided in the March 3, 2009 submittal.
The licensee is requesting that the NRC approve an exemption request for manual actions previously approved in an NRC Fire Protection Safety Evaluation Report (SER). As described in Regulatory Issue Summary 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," an approved exemption is required for all operator manual actions for compliance with 10 CFR Part 50, Appendix R Section 1II.G.2, even those that were accepted in a previously-issued NRC SER for plants licensed before January 1, 1979. This exemption request is limited to those manual actions that the licensee states were previously-accepted in an NRC SER for OCNGS. of the March 3, 2009 OCNGS exemption request lists the manual actions, in a table format, for which exemptions are being requested. To confirm that the safety basis established in the Safety Evaluation (SE) dated March 24, 1986 and June 25,1990 remains applicable to OCNGS, a response to the following request for additional information (RAI) is requested:
RAI KS-OCI-1 Technical Justification Review Criteria The evaluation presented in your March 3, 2009 submittal, was performed using inspection guidance contained in IP 71111.05. Provide information which demonstrates that your evaluation adequately bounds the feasibility criteria contained in NUREG 1852.
Your March 3, 2009 submittal states that your evaluation was based on criteria contained in NRC Inspection Procedure IP 71111.05, "Fire Protection." Inspection procedures do not provide appropriate guidance for evaluating the acceptability of alternative methods of complying with regulatory requirements. The OMA guidance presented in IP 71111.05, was developed to provide inspectors with interim guidance while rulemaking was in progress. As clearly stated in the procedure, authority to approve a licensee's methodology that does not meet NRC regulations is not delegated to the inspectors.
NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," provides guidance on the acceptability of post-fire operator manual actions (OMA). Specifically, this report addresses the unique aspects of fire and associated operator manual actions to guide the NRC staff in determining whether operator manual actions, proposed by operating plants for use in achieving and maintaining hot shutdown, are feasible and can reliably be performed in response to fire.
The evaluation presented in your March 3, 2009 submittal, was performed using inspection guidance contained in IP 71111.05. As described above, NUREG 1852 contains the appropriate review guidance for evaluating the feasibility of OMAs.
Provide information which demonstrates that the evaluation presented in your March 3, 2009 submittal satisfies the OMA feasibility criteria contained in NUREG 1852.
In addition, we note that the March 3, 2009 submittal incorrectly references procedure number "IP 71111.05". The correct reference for the Triennial Fire Protection Inspection Procedure is "1P71111.05T."
RAI KS-OCl -2 Prompt Actions Define "Prompt Action" Various sections of the March 3, 2009 submittal use the term "prompt actions" For example Page 36 of Attachment 1 states:
If there are any "prompt"actions that are needed to restore an instrument for a fire in that area (i.e., those that need to be performed within 45 minutes), the applicable FSP identifies the action(s) as "prompt."
Provide a clear definition of the term "prompt action." Identify all fire areas/ zones where prompt actions are needed, identify the "prompt" actions to be performed in each zone, and provide a more detailed description of criteria used to determine the need for "prompt" operator actions, describe how they are integrated into the applicable FSPs and provide a technical justification for their use.
RAI KS-OCl1-3 Diagnostic Instrumentation From the discussion presented in the March 3, 2009 submittal it is difficult to discern which OMAs are "preventive" (taken immediately, in response to a confirmed fire), and which are "reactive" (taken in response to observed plant parameters in the control room).
In discussing how the criteria for diagnostic instrumentation is met, Attachment 1 Page 36 of the March 3, 2009 submittal states that diagnostic instrumentationis consistent with the guidance in Generic Letter 81-12, "Fire ProtectionRule (45 FIR 76602, November 19, 1980), " and Information Notice 84-09, "Lessons Learned From NRC Inspections of Fire ProtectionSafe Shutdown Systems (10 CFR 50, Appendix R)."
For fire areas identified as satisfying the requirements of Section III.G.2 of Appendix R, one train of systems necessary to achieve and maintain hot shutdown conditions are protected from the effects of fire. If this level of protection is provided, there should be no need to perform manual operator actions to ensure the operability of the credited / protected train of shutdown equipment. This view is reflected in the guidance provided in both of the references identified in the March 3, 2009 submittal, which specifically address alternative shutdown capability.
Specifically, in I&E Information Notice 84-09, the staff provides a listing of instrumentation acceptable to and preferred by the staff to demonstrate compliance with Section IIl.L.2.d of Appendix R, and, as clearly stated in the second paragraph of Generic Letter 81-12, its purpose was to clarify information needed for the staff to perform a review of the alternative safe shutdown capability.
In addition, the staff's response to Question 5.3.9 of Generic Letter 86-10, states:
"Diagnosticinstrumentationis instrumentation,beyond that previously identified in Attachment I to I&E Information Notice 84-09, that is needed to assure proper actuation and functioning of safe shutdown equipment and support equipment (e.g., flow rate, pump dischargepressure).
The diagnosticinstrumentationneeded depends on the design of the alternativeshutdown capability. Diagnostic instrumentation,if needed, will be evaluated during the staff's review of the licensee's proposal for the alternative shutdown capability."
Therefore, it is not sufficient to protect only the instrumentation needed to show conformance to IN 84-09. As discussed in Section of NUREG 1852, in addition to the SSCs needed to directly perform the desired shutdown functions, the equipment needs to include diagnostic indications relevant to the desired operator manual actions. These indications, to the extent required by the nature of the operator manual action, may be needed to (1) enable the operators to determine which manual actions are appropriate for the fire scenario, (2) direct the personnel performing the manual actions, and (3) provide feedback to the operators, if not already directly observable, to verify that the manual actions have had their expected results and the manipulated equipment will remain in the desired state. These indications include those necessary to detect and diagnose the location of the fire.
As described in NUREG 1852, Preventive actions are taken immediately, upon entering a fire procedure to mitigate the potential effects of possible fire-related failures. Once the fire has been detected and located, the fire procedure will direct personnel to execute the action to ensure the availability of equipment to achieve its function during the given fire scenario. Since
the presence of the fire itself is the only criterion for initiating these actions, there is no need for diagnostic instrumentation.
Several sections of Attachment 1 state that the need for the OMA can be "readilydiagnosed from the Control Room due to the numerous indicationsand symptoms available." In addition, Page 42 of Attachment 1 states: Most actions have a significant time available to perform, and thus are performed on a symptomatic basis, with the Control Room determining the priority and sequencing of actions based on actualplant conditions For actions that are not taken until undesired changes in plant conditions or other unexpected symptoms are observed in the control room (i.e., reactive actions), provide documentation (e.g.
tabular listing) that identifies the action, the fire area / zone where a postulated fire could initiate the need for the action, and the related diagnostic instruments / indications that will be available in the control room (i.e., assured to remain free of fire damage). For each identified action describe its purpose (e.g., fire induced perturbation that created the need for the action), the time available to perform the action once detected by operators, the time demonstrated to be available to perform the action, and the impact on safe shutdown capability if the action is not accomplished as intended. In addition, for each perturbation (fire impact) provide a technical justification which supports the acceptability of the identified diagnostic instrumentation. This justification should demonstrate that the credited instrumentation or control room indications:
(a) will permit operators to promptly detect and diagnose potential fire impacts as they occur; (b) will enable operators to confirm that the manual action, once taken, has achieved the desired objective; (c) will remain unaffected by fire damage and (d) are identified in the shutdown procedures.
RAI KS-OCI-4 Exemption Request Basis Provide objective evidence to support your contention that the OMAs identified in Attachment 2 of the March 3, 2009 submittal were previously approved by the staff in an SER. Alternatively, demonstrate conformance of each OMA to the feasibility and reliability review criteria contained in NUREG 1852.
In Attachment 1,Section II, "Basis for Exemption Request," the March 3, 2009 submittal states that the request is limited to those operator manual actions credited for 10 CFR 50, Appendix R, Section III.G.2 compliance that were previously found acceptable for OCNGS by the NRC in Safety Evaluation Reports (SER) dated March 24, 1986 and June 25, 1990.
In Section III, Attachment 1 states that manual actions required for each fire area/zone (listed in of the submittal) were discussed in the "Fire Hazards Analysis Report [FHAR] and Appendix R,Section III.G Safe Shutdown Evaluation" which was submitted for staff review.
This section further states that in the March 24, 1986 SER the NRC accepted the OCNGS FHAR, and, hence, the fire protection program in its entirety including OMAs required for safe
shutdown in III.G.2 fire areas. Item 5 of Section III further states that the March 24, 1986 SER approves the overall post fire safe shutdown capability. Item 7 of Section III states that in the June 25, 1990 SER the staff "acknowledges" that manual actions are performed outside the area of the fire.
From the above, the basis for this exemption appears to be as follows:
- all manual actions indentified in Attachment 2 of the request were described in various revisions of the FHAR which was submitted to the staff
" staff approval of the FHAR, and hence, the entire fire protection program including the overall post fire safe shutdown capability ( Sections III.G.2, III.G.3 and III.L of Appendix R), is documented in the March 24, 1986 SER
" The June 25, 1990 SER "acknowledges" that OMAs were being performed outside the fire affected area.
The various documents submitted for staff review, including the FHAR may have identified the need for OMAs as a result of fire in areas not requiring an alternative shutdown capability (III.G.2 fire areas). However, the referenced SERs do not contain any evidence to support your contention that the staff reviewed and approved the FHAR in its entirety, and, thereby, the OMAs listed in Attachment 2 of your submittal. While the SERs "acknowledge" that OMAs may need to be performed outside a fire affected area, they do not specifically "approve" any of the OMAs.
In addition, the referenced SERs do not contain any evidence to support your contention that the staff approved the overall post fire safe shutdown capability (i.e., compliance with Sections III.G.2, III.G.3 and Il.L) via its review and approval of the FHAR. The 1986 SER specifically states that the scope of the staff's review was limited to alternative shutdown capability under Sections III.G.3 and III.L. Specifically, Section 8.0, Safe Shutdown Capability, states:
"By letter dated April 3, 1985, the licensee submitted the revised Fire Hazard Analysis Report and Section IlI. G Safe Shutdown Evaluation describing the means by which safe shutdown can be achieved in the event of fire and the proposed modifications to Oyster Creek to meet the requirements of Appendix R, Items ///.G.3 and ///.L. The licensee's revised safe shutdown analysis for a fire event has demonstratedthat adequate redundancy and/or alternate safe shutdown methods exist for those systems requiredto effect hot or cold shutdown utilizing the alternateshutdown methods."
Section 8.1.2, states that alternate safe shutdown capabilityhas been provided for areas where redundant safe shutdown equipment and cabling cannot meet the requirements of Appendix R Section /l1. G.2. For all other areas, Section 8.1.3 states: "the licensee states that that all other areas of the plant not requiredto have an alternatesafe shutdown will comply with the
requirements of Section III. G.2 of Appendix R, unless an exemption request has been approved by the staff" Based on our review of the referenced SERs we find:
- In all but a few instances (e.g., exemption requests related to alternative shutdown under III.G.3, and those related to the pull-pit areas which are filled with sand) the staff's evaluation of each fire area requiring an exemption states that required shutdown cables and equipment are protected by rated fire barriers.
" Contrary to statements contained in the March 3, 2009 submittal, the scope of staff's review of was specifically limited to alternative shutdown (III.G.3 and Ill.L) and several requested exemptions. In addition, in Section 8.1.2 of the 1986 SER the staff specifically states that its acceptance of compliance to Section III.G.2 is based solely on statements made by OCNGS. Therefore, the acceptability of the use of OMAs, or any other fire protection feature provided to comply Section III.G.2 of Appendix R was clearly beyond the scope of the evaluation.
- With the exception of areas provided with an alternative shutdown capability and areas where requested exemptions were approved, Section 8.1.3 of the 1986 SER, clearly states the staff expectation that all remaining areas of OCNGS meet the requirements of Section III.G.2.
In addition, although the March 3, 2009 submittal states that the staff has "acknowledged" the use of OMAs in general, it does not provide sufficient information to confirm that the staff approved the OMAs listed in Attachment 2 of the submittal An acknowledgement of OMAs in the SER, without further evaluation or specific approval, could be indicative of the staff's understanding that the OMAs were being performed to mitigate the effects of fire damage to the fire affected train of equipment. OMAs of this type would not be expected to be reviewed by the staff. As a result, there is no clear link between the SERs and the OMAs identified in of the March 3, 2009 submittal.
The March 3, 2009 submittal states that the basis for the exemption is that the OMAs identified in Attachment 2 of the submittal were previously found to be acceptable by the staff in Safety Evaluation Reports. For reasons discussed above, we find that the submittal does not provide a sufficient justification of this basis.
Additional information is needed to confirm that the OMA was previously approved by the staff in an SER. For each OMA identified in the March 3, 2009 submittal, provide a clear linkage between the action and the stated basis for the exemption (i.e., prior approval in an SER). This may be accomplished by providing a tabular cross-reference between each OMA and its related SER. For each OMA this list should identify whether the component requiring action is associated with the fire protected train or non-protected train. For those OMAs performed on the
fire protected train, identify the specific section in the SER where the action is evaluated and approved by the staff. Alternatively, the request should be supported by an evaluation which demonstrates full conformance to the feasibility and reliability criteria contained in NUREG 1852.
RAI KS-OC1-5 Hot Shutdown Repairs Operator manual actions (OMAs) are defined as actions performed by operators to manipulate components and equipment from outside the MCR to achieve and maintain postfire hot shutdown, but do not include "repairs." Provide confirmation that the OMAs described in your March 3, 2009 submittal meet this definition.
RAI KS-OCI-6 Time Available to Perform OMAs The time available to perform an OMA is defined as the time period from a presentation of a cue for an action to the time of adverse consequences if the action is not taken..An action is considered feasible if it is shown that it can be performed within the available time The feasibility of OMAs is demonstrated by showing that actions meeting the criteria can be completed in the available time, documents the feasibility; For every operator manual action, analyses should show that there is adequate time for the operators to diagnose the need for the actions, travel to action location(s), perform the actions, and confirm the expected response before an undesired consequence occurs, as dictated by the plant staff's determination of the time available to avoid the undesired consequence.
Our primary concern is with fire scenarios which may require operators to successfully complete OMAs in the initial stages of a fire event (i.e., within the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following fire initiation).
For such "time critical actions" provide a technical justification to support your conclusion that an adequate amount of time is available for operators to complete the actions before the occurrence of adverse consequences. This technical justification should demonstrate that criteria similar to that contained in Sections 3.2.1 and 4.2.1 of NUREG 1852 are satisfied.