ML113130261

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Additional Questions/Comments on the Monitoring Program, Documentation, Etc
ML113130261
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 11/08/2011
From: Lain P
NRC/NRR/DRA/AFPB
To:
Tam P
References
TAC ME6629, TAC ME6630
Download: ML113130261 (2)


Text

DC Cook Site Audit (FM/Prog) 1 Monitoring Program We have the following questions regarding the process by which the monitoring program is being developed:

1. What process will be used for the review that will be conducted of the existing surveillance, testing, maintenance, compensatory measures, and oversight processes to consider the adequacy of scope and the performance criteria for availability and reliability, as discussed in Sections 4.6.1 and 4.6.2 of the CNP Transition Report?
2. What process will be used to identify systems and features relied upon to meet the requirements of Chapters 3 and 4 of NFPA 805 for ensuring their inclusion in the existing inspection, test, and system/program health programs? The answer should include how and whether optimization based on performance will be employed as discussed for Phase 1 of the NFPA monitoring program in Section 4.6.2 of the CNP Transition Report.
3. What process will be used to determine whether Phase 2 of the monitoring program development, as described in the CNP Transition Report, will include reviews of other analysis units that are not risk significant but are included based on plant specific history or operational considerations?
4. What process will be used in Phase 3 of the monitoring program to determine whether failure criteria will be established either by an expert panel or by an evaluation based on assumed level of performance, as discussed in Section 4.6.2 of the CNP Transition Report?
5. In Phase 4 of the NFPA monitoring program as discussed in Section 4.6.2 of the CNP Transition Report, does the appropriate CNP process for establishing action plans refer to the existing corrective action program?
6. Will the periodic assessment of the NFPA monitoring program discussed in Section 4.6.2 of the CNP Transition Report include both internal and external assessments, and at what frequency will these assessments be performed?

Program Documentation What specific documents will comprise the post transition NFPA 805 fire protection program licensing basis as discussed in section 4.7 of the CNP Transition Report?

Configuration Control What changes are anticipated to the CNP configuration control processes to incorporate the requirements of the NFPA 805 fire protection program as discussed in section 4.7.2 of the CNP Transition Report?

Fire Protection Program Manual What changes are anticipated to the Fire Protection Program Manual as a part of the NFPA 805 transition process, including associated training and identification of the recipients of any such training necessary to support the program changes?

DC Cook Site Audit (FM/Prog) 2 Fire Protection Quality Assurance What changes are anticipated to the existing Fire Protection Quality program as a part of the NFPA 805 transition process?

Fire Protection Program Audits Where will requirements for periodic assessments (audits) of the fire protection program reside in the NFPA 805 program documentation and how are these requirements anticipated to differ from current audit requirements regarding procedures for reviews of fire protection program-related performance and trends?

Fire Protection Program Quality Assurance Will NFPA Section 2.7.3, Quality requirements applicable to reviews, verification and validation of calculational models or numerical methods, limitations of use for engineering methods and models, qualifications of users for engineering analyses and numerical models, and uncertainty analyses be applied for all future such actions related to the NFPA 805 fire protection program?

Fire Modeling

1. Fire modeling in support of the DC Cook LAR was performed by EPM. FMDB - Transient Analysis Worksheets, a fire modeling toolkit developed by EPM, was used in lieu of FIVE and FDTs.
a. Why and how did EPM develop FMDB - Transient Analysis Worksheets?
b. How was FMDB - Transient Analysis Worksheets verified and validated?
c. It is stated in the documents on the portal that V&V was based on comparison between calculated results from FMDB - Transient Analysis Worksheets and the results from corresponding routines in FIVE and FDTs. However, this does not mean that the models were used within their range of validity.
2. How was the uncertainty of the results obtained from calculations with FMDB - Transient Analysis Worksheets determined?
3. We would like to review in detail the fire modeling that involved the use of FLASH-CAT to estimate the heat release rate and flame spread of cables in trays.