ML072340110

NFPA 805 Transition Pilot Plant FAQ Process: Substantive E-Mails; June 2007

ML072340110
Person / Time
Site:	Harris
Issue date:	06/04/2007
From:	Brandon J Nuclear Energy Institute
To:	Gallucci R, Charles Moulton, Sunil Weerakkody NRC/NRR/ADES/DRA
References
Download: ML072340110 (61)

Text

From: "JAMAR, Brandon" <btj@nei.org>

To: "Charles Moulton" <CEM4@nrc.gov>, "Sunil Weerakkody" <SDW1@nrc.gov>,

<RHG@nrc.gov>

Date: Mon, Jun 4, 2007 8:34 PM

Subject:

FAQ 06-0017 Rev. 2 for submittal Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmittal please contact me directly.

Thank you, Brandon Jamar This electronic message transmission contains information from the Nuclear Energy Institute, Inc.

The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

CC: "MARION, Alex" <am@nei.org>, "RILEY, Jim" <jhr@nei.org>

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FAQ 06-0017 Rev. 2 for submittal Creation Date 6/4/2007 8:37:42 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov OWGWPO02.HQGWDO01 RHG (Ray Gallucci) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org jhr CC (Jim RILEY) am CC (Alex MARION)

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Contact:

Dave Miskiewicz Phone: 919.546.7588 Email: David.Miskiewicz@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG FPRATF RIRWG BWROG PWROG Purpose of FAQ:

Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:

The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:

Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy arcing faults are associated with switchgear and load centers. Switchyard transformers and isolation phase buses are not part of this bin. For this bin, similar to electrical cabinets, the vertical segments of the switchgear and load centers should be counted. Additionally, to cover potential explosive failure of oil filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load centers) may be included in vertical segment counts of the switchgear.

Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of High Energy Arcing Faults (Bin 16).

Strict interpretation of the guidance is that the HEAF count should mimic the electrical cabinet counts for switchgear and load centers. The application of such a counting method is expected to result in reported High Energy Arcing Fault (HEAF) frequency values for an individual plant being inconsistent with industry experience. The industry experience and consequently the HEAF frequency is based on 3 events occurring on medium voltage Page 1 of 3 faq 06-0017 - rev 2.doc

FAQ Number 06-0017 FAQ Revision 2 FAQ Title Ignition Source Counting Guidance for High Energy Arching Faults switchgears and 1/2 event occurring on a 480 VAC Load Center. Because of the relative numbers of switchgears and load centers at an individual plant, it is expected that the resultant frequency may be inappropriately skewed. There is a concern that the occurrence of a HEAF frequency distribution that departs significantly from the 3 to 1/2 ratio would cause results to be challenged.

There is a need to resolve these issues to prevent future rework and to reduce burden associated with uncertainty treatment. This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

Potentially relevant existing FAQ numbers:

This guidance is specific to the characterization of electrical cabinets for Bin 16 HEAF determination. The characterization and counting of electrical cabinets for Bin 15 determination is addressed by FAQ 06-0016. FAQ 07-0035 addresses counting Bus Duct for HEAF.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Split fire ignition frequency Bin 16, HEAF, into two bins; namely, 16a - HEAF for low-voltage panels (480-1000V) and 16b - HEAF for medium-voltage panels (greater than 1000V). For each bin, the method of panel counting would remain consistent with the guidance for Bin 15 (see FAQ 06-0016). Additionally, MCCs with molded-case circuit breakers should not be counted as HEAF sources unless it is associated with switchgear that is used to directly operate equipment such as load centers.

The net result is a re-partitioning of the higher-consequence HEAF events between low and medium-to-high voltage equipment in accordance with the event data. The revised fire frequencies for these two new bins are as follows:

16a: HEAF for Low-Voltage Panels (480 - 1000V)

Mean = 4.8E-04 Variance = 1.4E-03 5% Lower Bound = 1.6E-05 50% (Median) = 2.0E-04 95% Upper Bound = 1.5E-03 16b: HEAF for Medium-Voltage Panels (greater than 1000V)

Mean = 1.4E-03 Page 2 of 3 faq 06-0017 - rev 2.doc

FAQ Number 06-0017 FAQ Revision 2 FAQ Title Ignition Source Counting Guidance for High Energy Arching Faults Variance = 1.2E-02 5% Lower Bound = 3.8E-05 50% (Median) = 6.2E-04 95% Upper Bound = 4.1E-03 Basis:

This FAQ revision includes the response proposed by the NRC and the NUREG/CR-6850 writing team.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Page 3 of 3 faq 06-0017 - rev 2.doc

Thanks. We'll look it over. If OK, we'll incoproate into the close-out memo.

Any feedback on new FAQ 35 (bus ducts and junctions), particularly if the July 13th date is a go for the joint panel to resolve duct counting that I proposed at the last FAQ meeting? This date would enable Steve Nowlen to participate since he'll be in town.

>>> "JAMAR, Brandon" <btj@nei.org> 06/04/2007 8:37:42 PM >>>

Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmittal please contact me directly.

Thank you, Brandon Jamar This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

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Re: FAQ 06-0017 Rev. 2 for submittal Creation Date 6/5/2007 10:54:09 AM From: Ray Gallucci Created By: RHG@nrc.gov Recipients nei.org am CC (Alex MARION) btj (Brandon JAMAR) jhr CC (Jim RILEY) nrc.gov OWGWPO03.HQGWDO01 TQD1 CC (Thinh Dinh) nrc.gov OWGWPO04.HQGWDO01 JSH2 CC (J S Hyslop) nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) pgnmail.com david.miskiewicz CC (david.miskiewicz@pgnmail.com)

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Chuck, Please find revision 4 to FAQ 06-0012 for submittal. Should you have any problems with this transmittal please contact me directly.

Thank you, Brandon Jamar This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

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FAQ 06-0012 Rev. 4 for submittal Creation Date 6/5/2007 7:13:12 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org jhr CC (Jim RILEY) am CC (Alex MARION)

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Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Plant: Harris Nuclear Plant Date: 03/22/2007

Contact:

Elizabeth Kleinsorg Phone: 704.651.5548 Email: ekleinsorg@haifire.com Purpose of FAQ:

Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

Section B.2.2.4 Recovery Actions Circumstances requiring guidance interpretation or new guidance:

Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.

Subsequent to the submittal of FAQ 06-0001, the following documents were issued by the NRC:

2006-05 Public Meeting Notice 20060609 on Manual Action Clarifications ML061390156 2006-05 Draft NRC Response to 05-03-06 NEI letter - ML061440251 2006-05 Draft NRC Response to 03-29-06 EPM letter - ML061440237 Page 1 of 12 faq 06-0012 - manual actions - rev 4.doc

FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition 2006-06 RIS 2006-10 Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions - ML061650389 2006-07 NRC Meeting Summary of 06-09-06 OMA Meeting ML061950327 2006-07 NRC Revision to Draft Response to EPM March 2006 letter -

ML061980016 2006-07 NRC Revision to Draft Response to NEI May 2006 letter -

ML061980035 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.

These documents provide additional clarification with respect to the acceptability of existing operator manual actions.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

None.

Potentially relevant existing FAQ numbers:

This FAQ supersedes FAQ 06-0001.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

The following information will be used as input for a revision to NEI 04-02:

Allowed Operator Manual Actions With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required Page 2 of 12 faq 06-0012 - manual actions - rev 4.doc

FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)

Operator Manual Actions on Fire Affected Train.

As discussed during a March 1, 2006, public meeting, if one of the redundant trains in the same fire area is free of fire damage by one of the specified means in paragraph III.G.2, then the use of operator manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to the second train may be considered in accordance with the licensees fire protection program and license condition since paragraph III.G.2 has been satisfied.(RIS 2006-10)

Additional clarification was provided at the June 9, 2006 Public Meeting and was summarized in a subsequent NRC Internal Memorandum (July, 19, 2006 ML061950327, ML061980016)

Conversion of Compliance Strategy from III.G.2 to III.G.3.

Paragraph III.G.2 allows the licensee to use the alternative shutdown method described in paragraph III.G.3 of Appendix R if the licensee cannot meet the requirements of paragraph III.G.2.(RIS 2006-10)

Exemptions from Paragraph III.G.2 for Plants Licensed to Operate Before January 1, 1979 The regulations in 10 CFR Part 50.48(b) impose the requirements of paragraph III.G.2 of Appendix R on plants licensed to operate before January 1, 1979 (pre-1979 licensees). As originally issued, 10 CFR 50.48, Fire Protection, allowed licensees to request an exemption from compliance with one or more of the provisions of Appendix R if the licensee justified the exemption on the basis that the required modifications would not enhance fire protection safety in the facility or that the modifications might be detrimental to overall facility safety.

The staffs current basis for approving an exemption is provided in 10 CFR 50.12 Specific Exemptions. In order for the NRC to approve such an exemption request, a licensee would have to identify all relevant credited operator manual actions by fire area or fire scenario.

The NRC has reviewed and granted exemption requests for the use of operator manual actions in lieu of the separation criteria of paragraph III.G.2 where the exemption criteria were met. These exemptions are specific to the licensee and the situation discussed in the exemption. Exemptions granted for specific conditions cannot be applied under other conditions. Although the rationale for an exemption may appear to be applicable to a similar situation for a second licensee, the staff cautions that NRC review and approval by issuance of an exemption would be necessary for the second licensee.

Page 3 of 12 faq 06-0012 - manual actions - rev 4.doc

FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition The appropriate regulatory vehicle (in the absence of a rulemaking or plant-specific Order) to provide dispensation from compliance with fire protection requirements is the issuance of an exemption under 10 CFR Part 50.12.

Inspection reports, meeting minutes, and letters from licensees are examples of documents that do not provide dispensation from compliance with applicable fire protection requirements.

For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in paragraph III.G.2, does not eliminate the need for an exemption.

Pre-1979 licensees who have SERs, but not a corresponding exemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstances of section 50.12(a)(2)(ii), citing the SER as the safety basis, and confirming that the safety basis established in the SER remains valid. The staff expects to grant the exemption on these bases without further review. (RIS 2006-10)

Plants Licensed to Operate After January 1, 1979 Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraph III.G.2, a staff decision in an SER that approves the use of manual operator actions does not require exemption under 10 CFR 50.12. Post-1979 licensees may be requested to demonstrate, as part of the NRC Reactor Oversight Process, that the use of an operator manual action would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire consistent with their license. (RIS 2006-10)

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Revise NEI 04-02 as shown in the attachment.

Page 4 of 12 faq 06-0012 - manual actions - rev 4.doc

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked

[Fifth paragraph on page 29 of NEI 04-02 Revision 1]

4.3.2 Nuclear Safety Performance Criteria Transition Review

Operator manual actions being transitioned to recovery actions that are not allowed under Deleted: M the current regulatory framework or do not have previous NRC approval should be Deleted: (credited for III.G.2 compliance) evaluated using the change process. See Appendix B-2 of this document for additional guidance. Deleted:

Attachment Page 5 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked B.2.2.4 Recovery Actions Operator manual actions will be transitioned as recovery actions in the new NFPA 805 Deleted: M licensing bases. Repairs will also be transitioned as recovery actions.

The following information for operator manual actions should be included in the fire area Deleted: that summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Deleted: y Worksheet): Deleted: for the fire area Whether the transitioning recovery action is allowed or was previously reviewed and Deleted: is approved by the NRCs Office of Nuclear Reactor Regulation (NRR). Include Deleted: :

reference to documentation that demonstrates prior review and approval by the NRC. Deleted: 1) w Reference to the feasibility evaluation of the transitioning recovery action. See Deleted: operator discussion below. Deleted: manual Reference to the evaluation of additional risk associated with the use of recovery Deleted: s actions. See section discussion below. Deleted: were Deleted: , and 2)

Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation. The bin Deleted: R identifiers are for ease of reference. Deleted: A Deleted: s For each Operator Manual Action for a Given Fire Area No Action is a Normally No Action Credited for App. No Action is taken inside of Action taken to Achieve & No Manually Operated R Section III.G.3 the Main Control Room? Maintain Cold Shutdown?

Switch/Valve (NUREG-0800 C.5.c)?

Bin A Bin B Bin C Bin D Yes Yes Yes Yes Yes Yes Yes No Action Related to No No Prior NRC Approval Action is Related to fire Credited Train, but does Obtained? affected train?

not disable Function?

Bin G Bin F Bin E No Action is Feasible?

Yes Operator Action Not Allowed /

Operator Manual Action is Not Approved (Candidate for RI-ACCEPTABLE PB Change Evaluation)

Bin H Deleted: t Figure B-4 General Process to Transition Operator Manual Actions Attachment Page 6 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Determining If a Transitioning Operator Manual Action requires a Change Deleted: taion Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include: Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

Operator manual operation from the control room or emergency control station(s) Deleted: are

[Bin A] Deleted: M Repairs or operator manual actions credited either for transitioning to or maintaining Deleted: is acceptable cold shutdown equipment [Bin B] Deleted: do not require a change evaluation.

Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) [Bin C]

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of normally operated manual switches and valves Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Deleted: applicable sections Appendix R (or Section C.5.c of NUREG-0800). [Bin D]

NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:

manual operation of equipment used to meet the requirements of Section III.G.3 Deleted: <#>The operator manual action is currently credited in the for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where Alternate Shutdown Procedure. Although meeting performance criteria of Section III.L is required this manual action was NOT specifically mentioned in the SER, the licensee submittal specifically discussed the RIS 2006-10 states: Paragraph III.G.2 allows the licensee to use the alternative operator action. This can be considered shutdown method described in paragraph III.G.3 of Appendix R if the licensee cannot previously approved¶

<#>The operator manual action is meet the requirements of paragraph III.G.2. currently credited in Non-Alternate Shutdown Procedure. The manual action Operation of fire affected equipment for fire areas that meet the separation was specifically discussed as acceptable requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of in the SER however the NRC did not grant an exemption/deviation. This can NUREG-0800). See Figure B-5. [Bin E] be considered previously approved.¶

<#>Operation of equipment for which NRC Letter to NEI dated May 16, 2002 states: With proper analysis, manual cables and equipment for the redundant actions are allowed for fire safe shutdown activities under the following safe shutdown train are located in separate fire areas thus meeting Section circumstances: III.G.1of Appendix R to 10 CFR Part 50,¶

<#>Manual operation of normally operation of equipment for which cables are located in fire areas that meet operated manual switches and valves where III.G.1 separation is provided for Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and redundant safe-shutdown trains¶ equipment in a completely different fire area Deleted: Part Attachment Page 7 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6. [Bin E]

Deleted: 6 RIS 2006-10 states: As discussed during a March 1, 2006, public meeting, if one of the redundant trains in the same fire area is free of fire damage by one of the specified means in paragraph III.G.2, then the use of operator manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to the second train may be considered in accordance with the licensees fire protection program and license condition since paragraph III.G.2 has been satisfied.

Operator manual actions to address spurious actuations that affect the credited safe shutdown success path are allowed, as long as the spurious actuation is not directly in the protected train of the credited function (e.g., the main flowpath, as opposed to a diversionary flowpath) and the credited function does not become disabled during the Deleted: 6 time it takes to perform the operator manual action. See Figures B-7 and B-8 [Bin G}

Deleted: 7 During the June 9, 2006 public meeting the following example was specifically Deleted: 7 discussed: Two redundant trains taking suction from a common tank. Provided the manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation. (Figure B-7)

A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path.

Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)

In addition to allowed operator manual actions some manual actions may have been Deleted: O previously reviewed and approved by the NRC [Bin F] (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205. Deleted: In some cases the previous approval may not be obvious, yet should be allowed.

In some instances the NRC may have reviewed and approved [Bin F] an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance: Deleted: Examples are RIS 2006-10 states: For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in paragraph III.G.2, does not eliminate the need for an exemption.

Pre-1979 licensees who have SERs, but not a corresponding exemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstances of section 50.12(a)(2)(ii), citing the SER as the safety basis, and confirming that the safety basis established in the SER remains valid. The Formatted: Font: Not Italic staff expects to grant the exemption on these bases without further review.

During the transition, for pre-1979 licensees who have SERs, but not a corresponding Formatted: Indent: Left: 0.25" exemption, which approves operator manual actions, should verify that the basis for Deleted: n SERclarification Attachment Page 8 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked acceptability in the SER is still valid. If the basis for acceptability is still valid, then no change evaluation is required.

RIS 2006-10 states: Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraph III.G.2, a staff decision in an SER that approves the use of manual operator actions does not require exemption under 10 CFR 50.12. Post-1979 licensees may be requested to demonstrate, as part of the NRC Reactor Oversight Process, that the use of an operator manual action would not adversely affect the ability to achieve and Deleted: operator maintain safe shutdown in the event of a fire consistent with their license.

Operator manual actions that are not allowed or have not been previously reviewed and Deleted: Repairs credited for cold shutdown equipment will also be approved by the NRC should be addressed for acceptability using the change evaluation transitioned on a fire area basis.

[Bin H] process outlined in Chapter 5.3 of this guidance. Examples of operator manual Information that should be summarized includes reference to documentation that actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting demonstrates the equipment necessary for (ML061950327, ML061980016) the repair is staged, the repair is proceduralized, and the repair is achievable in the necessary timeframe.¶

¶ Operator manual actions that have been previously reviewed and approved by the NRC (as documented in an approved SER) can be transitioned without the need to use the change evaluation process. However, licensees may consider use of the change evaluation process for previously reviewed and approved operator manual actions so that the evaluation is consistent with operator manual actions not previously reviewed and approved by the NRC.¶

¶ Deleted: (e.g., those credited for compliance with Appendix R sections III.G.2 and III.G.3)

Deleted: that Deleted: July, 19, 2006 Deleted: The following methodology should be used to optimize this process:¶ Attachment Page 9 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Deleted: 4 Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Deleted: Acceptable 3 - hour Rated Raceway Fire Barrier Train A Train B Pump Pump Train B Power Train A Power Cable Train A Control Train B Control Cable Cable Cable Train A Train B Power Supply Power Supply Fire Area A Fire Area B Fire Area B meets the separation criteria of 10 CFR 50 Appendix R Section III.G.2.a A postulated fire in Fire Area A could result in the spurious starting of the non-credited Train A pump, which can be mitigated by an operator manual action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-5.

Deleted: 5 Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train Deleted: Acceptable Attachment Page 10 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Deleted: 6 Suction Attachment Page 11 of 12

Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Deleted: 7 Feedwater Flow Diversion Attachment Page 12 of 12

Ray, We have created a new FAQ for bus ducts and it is with the task force.

I think we should be able to get it to you before July. The FAQ as written does not contain a new solution to the counting question, but we plan to discuss it at the FPRA task force meeting on June 21. I believe we can support your meeting on July 13 although I am not sure who will be attending. We will have better input after our June meeting.

David Miskiewicz Progress Energy, PSA 919-546-7588

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Original Message-----

From: Ray Gallucci [1]

Sent: Tuesday, June 05, 2007 10:54 AM To: Brandon JAMAR; Charles Moulton; Sunil Weerakkody Cc: Alex MARION; Jim RILEY; J S Hyslop; Thinh Dinh; Miskiewicz, David N

Subject:

Re: FAQ 06-0017 Rev. 2 for submittal Thanks. We'll look it over. If OK, we'll incoproate into the close-out memo.

Any feedback on new FAQ 35 (bus ducts and junctions), particularly if the July 13th date is a go for the joint panel to resolve duct counting that I proposed at the last FAQ meeting? This date would enable Steve Nowlen to participate since he'll be in town.

>>> "JAMAR, Brandon" <btj@nei.org> 06/04/2007 8:37:42 PM >>>

Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmittal please contact me directly.

Thank you, Brandon Jamar

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RE: FAQ 06-0017 Rev. 2 for submittal Creation Date 6/7/2007 7:34:49 AM From: "Miskiewicz, David N" <David.Miskiewicz@pgnmail.com>

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Please find FAQ 07-0035, Rev. 0 attached for submittal. If you should have any questions please contact me directly (via email).

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

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FAQ 07-0035 Creation Date 6/12/2007 9:06:08 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov OWGWPO02.HQGWDO01 RHG CC (Ray Gallucci) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

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Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled FAQ Number 07-0035 FAQ Revision 0 FAQ Title Bus Duct Counting Guidance for High Energy Arching Faults Plant: Harris Date: June 1, 2007

Contact:

Dave Miskiewicz Phone: 919.546.7588 Email: David.Miskiewicz@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG FRATF RIRWG BWROG PWROG Purpose of FAQ:

Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:

Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of High Energy Arcing Faults (Bin 16).

There is a need to resolve these issues to prevent future rework and to reduce burden associated with uncertainty treatment. This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.

The guidance provided in NUREG/CR-6850 for Task 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:

Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy arcing faults are associated with switchgear and load centers. Switchyard transformers and isolation phase buses are not part of this bin. For this bin, similar to electrical cabinets, the vertical segments of the switchgear and load centers should be counted. Additionally, to cover potential explosive failure of oil filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load centers) may be included in vertical segment counts of the switchgear.

Page 1 of 2 FAQ 07-0035 Rev. 0

FAQ Number 07-0035 FAQ Revision 0 FAQ Title Bus Duct Counting Guidance for High Energy Arching Faults The current guidance is silent regarding the treatment of bus duct. Preliminary discussions between the user community and the NUREG authors indicate that some specific guidance is needed to assure more consistent treatment of bus duct.

Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

Potentially relevant existing FAQ numbers:

This guidance is specific to the characterization of bus duct for Bin 16 HEAF determination.

The characterization and counting of electrical cabinets for Bin 16 determination is addressed by FAQ 06-0017.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Because bus duct terminates at electrical cabinets, the HEAF counted for the electrical cabinet would also include those bus duct events and no further counting is necessary.

Basis:

The response is consistent with the guidance currently provided in NUREG/CR-6850.

Without additional guidance provided by the authors of NUREG/CR-6850, there is no basis for when or how to count bus duct.

If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Page 2 of 2 FAQ 07-0035 Rev. 0

Sunil, We had previously discussed hosting the September NFPA 805 FAQ meeting in coordination with this year's Fire Protection Information Forum in New Orleans, LA. We have made the accommodations available with the hotel for the proposed meeting date of September 20. Please let me know if this will be acceptable so I can finalize plans with the 805 task force and the hotel.

Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

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NFPA 805 FAQ meeting - September 2007 Creation Date 6/13/2007 9:19:22 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 CC (Charles Moulton)

PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

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Chuck, Do you have any FAQ updates (comments, approvals, etc.) you're prepared to share prior to the call tomorrow?

Thanks, Brandon This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

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FAQ Monthly Call - June 21 Creation Date Wed, Jun 20, 2007 8:31 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov CEM4 (Charles Moulton) nrc.gov SDW1 CC (Sunil Weerakkody) nei.org jhr CC (Jim RILEY)

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Brandon, It looks like we are going to have relatively little for today...

We have no comments ready, but I think we are going to suggest closure of four FAQs today (7, 12, 17, and 28)

I am attaching two handouts that detail updated ADAMS numbers of FAQs and meeting notices/summaries. Please distribute them to the task force.

Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11

>>> "JAMAR, Brandon" <btj@nei.org> 6/20/2007 8:31 PM >>>

Chuck, Do you have any FAQ updates (comments, approvals, etc.) you're prepared to share prior to the call tomorrow?

Thanks, Brandon This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the

addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

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Re: FAQ Monthly Call - June 21 Creation Date 6/21/2007 11:30:54 AM From: Charles Moulton Created By: CEM4@nrc.gov Recipients Action Date & Time nei.org Transferred 6/21/2007 11:31:12 AM btj (Brandon JAMAR)

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No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened FAQs FAQ # Rev. ADAMS # 06-0023 0 ML070030470 06-0001 0 ML061440419 06-0024 0 ML070030472 06-0002 0 ML061440420 06-0025 0 ML070030476 1 ML063170357 1 ML071340194 2 ML063350515 06-0026 0 ML070030480 06-0003 0 ML061440422 06-0027 0 ML071380236 1 ML063170355 06-0028 0 ML070030489 06-0004 0 ML061440430 1 ML071340195 06-0005 0 ML062350095 2 ML071550415 1 ML063180544 07-0031 0 ML071380238 06-0006 0 ML062350109 07-0035 0 ML071650151 1 ML063170360 2 ML063540308 06-0007 0 ML062350121 1 ML070030325 2 ML070510442 3 ML071550408 06-0008 0 ML062860250 1 ML070510499 2 ML070800007 3 ML071020160 Att. ML071020169 4 ML071080099 5 ML071340180 06-0011 0 ML062890271 1 ML070510505 06-0012 0 ML062860255 1 ML063170362 2 ML070850610 3 ML071380228 4 ML071570260 06-0016 0 ML070030348 1 ML071020174 06-0017 0 ML070030383 1 ML071350432 2 ML071570255 06-0018 0 ML070030427 1 ML071020181 06-0019 0 ML070030437 1 ML071340184 06-0020 0 ML070030443 1 ML071340188 06-0021 0 ML070030457 1 ML071340192 06-0022 0 ML070030459 FAQ Meeting Notices and Summaries Month Doc. ADAMS #

July MN ML061870560 MS ML062080126 August MN ML062200116 MS ML062400278 September MN ML062510281 MS ML062900031 October MN ML062850488 MS ML063350031 November MN ML063120170 MS ML063410377 December MN ML063390132 MS ML070220420 January MN ML070040380 MS ML070360630 February MN ML070290267 MS ML070640531 March MN ML070640417 MS ML071090164 April MN ML070920255 MS ML071420174 May MN ML071220176 MS ML071510425 June MN ML071440064

Chuck, Please find the attached FAQ Log updated per today's meeting. If you have any questions please let me know.

Thanks, Brandon Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006

<http://www.nei.org> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.

This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.

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FAQ Log 21-2007 Creation Date 6/21/2007 9:07:41 PM From: "JAMAR, Brandon" <btj@nei.org>

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Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled Revision Submitter Reviewer Status Approval FAQ # Name Summary Actions and Notes Priority Licensee Submitted Working Plant NRC NEI TF NRC Submittal Date Tentative Final Contact 06-0001 0 0 Alternate method for Add in clarification that fire affected train NRC rejected the statements regarding SER Engineering Evaluations manual actions are 'allowed' and approval without Exemptions Harris therefore do not require evaluation. Submitted to Closed Closed Closed Nuclear Ertman Closed 4/25/2006 Tentatively approved. NRC ML063480169 ML063480169 Plant Superceded by FAQ 06-0012.

06-0002 1c 1c NEI 04-02 Section 5.3.3 and Change Figure 5-1, text, and Appendix I NRC agreed in principle, however wanted App. I, Order of Questions to ask the Chapter 4 questions before wording clarified to "make clear the distinction for Change Analysis Chapter 3 questions. between Chapter 3 requirements that are Screening subject to Chapter 4 evaluations versus the Chapter 3 requirement that are independent of Chapter 4" added clarification to 'boxes' at end of Questions 1 and 2 in Change Analysis Form NRC added 'included required recovery actions to text of 5.3.3 and added 'including Human actions' to Question 4.e of Change Analysis Harris Form Submited to 4/25/2006 Closed Nuclear Ertman Gallucci Closed 10/26/2006 Closed NRC 10/26/2006 Plant Task Force agrees to first request. Task force is evaluating the addition of NRC rejected the statements regarding SER approval without Exemptions Committed to revise based on RIS 2006-10 and NRC Public Meeting June 9, 2006. See RIS 2006-12 'human actions' to the risk screening questions. - tentatively approved - will resubmit 10/26/06 06-0003 1b 1b Change Analysis Screening Change 'greater than minimal' to Harris Submited to 4/25/2006

'potentially greater than minimal' Closed Nuclear Ertman Gallucci Closed 10/26/2006 Closed NRC 10/26/2006 Plant 06-0004 0 1 Clarify NFPA 805 Chapter 4 How fire protection systems and features Note NRC was using NEI 04-02 Revision 2H and 3 relationship for transition is highly dependent on how figures and not figures in FAQ 06-0004

'required' FP they are 'required' to meet the nuclear TF to systems/features safety criteria of Chapter 4. NRC to re-review in appropriate context & resubmit July Comments provide status on 10/26/06 M HNP Ertman Frumkin 2007 in provided on 5/12/2006 conjunction R0 Received NRC comments 11/29/06. Resubmitted w/ B.3 tables to NRC and returned with comments. Currently under TF review.

06-0005 1 1 Guidance on FPP-related NEI 04-02 does not provide guidance FAQ has been revised.

changes what should be considered a FPP-related change or not. Since failure to obtain Resubmit to NRC 11/30/06 - waiting for NRC NRC pre-approval for using risk response as of June 07 TF waiting for reductions from a non-FPP related Plan to 8/24/2006 H HNP Ertman Frumkin NRC change would be contrary to the NRC tentatively scheduling comments for July comment 11/30/2006 comments guidance in RG 1.205, additional guidance meeting should be provided to clarify what is considered a FPP-related change once NFPA-805 is implemented.

06-0006 2 2 High-low pressure interface Definition of High-Low Pressure interface Received NRC comments on R1, R2 definition and NEI 00- is not consistent between NFPA 805 and 01/NFPA 805 discrepancies NEI 00-01. Need to provide clarification. Resubmit 12/19/06 - Definition change per NRC request. Draft 8/24/2006 M Duke Barrett Dinh closure 1/18/2007 12/19/2006 Closure process has begun. Draft closure letter letter issued was commented on by TF.

NRC accepted TF clarification.

06-0007 3 3 NFPA 805 Chapter 3 Need clarification on when NFPA 600 or FAQ to be revised to mark up NEI 04-02 to show Requirements for Fire NFPA 1500 apply. Also clarify if the addition of an appendix for NFPA 805 Comments R3 submitted 2/15/2007 Brigades requiements apply to interior structural clarifications. M HNP Holder Lain provided on 6/21/2007 to NRC 5/21/2007 fire fighting brigade. R2 NRC R2 comments by May 07 06-0008 5 5 Alternate method for Many Generic Letter 86-10 evaluations Presented 9/28/06 Engineering Evaluations exist at facilities today. Transition of these existing evaluations is essential for Comments received from NRC on 11/29/06.

the success of the Pilot Plants. In Clarification call scheduled. Resubmit to NRC by addition the use of engineering 02/07 2/15/2007 Comments evaluations for Chapter 3 issues post R4a comments received and will incorporate 3/20/2007 H1 NEI Ratchford Frumkin R6 planned provided on transition needs to be clarified. NRC recommendations. 3/30/2007 R5 R5 by early May. 5/8/2007 NRC stated at last meeting they would be submitting additional comments. Awaiting NRC comments. Page1 of 5

06-0009 NEI 04-02 Typo Corrections Editorial changes to NEI 04-02 Will submit with overall revision at end of year.

L NEI Kleinsorg 06-0010 Incorporate Regulatory Based on changes to Regulatory Guide Projected submittal 3Q 2007 Guide 1.205 Baseline 1.205, NEI 04-02 needs to reflect the L HNP Ertman concept into NEI 04-02 baseline risk 06-0011 1b 1b Clarify III.G.3 Compliance Alternative Shutdown is not specifically Approved by Task Force Reviewers. Submitted Transition addressed in NFPA 805. to NRC 9/28/06. Under NRC review.

Comments received from NRC on 11/29/06. TF waiting for Need time for TF review. Rewrite Comments NRC w/consideration for NRC comment #2 - H NEI Jutras Frumkin provided on 2/15/2007 comments on Resubmit Feb. '07. R0 R1b Awaiting NRC closure.

Attempting to provide comments by July 06-0012 4 4 Clarify Manual Action Some manual actions are either allowed Submitted to NRC 9/28/06. Resubmit 10/26/06 Transition in Appendix B by the current regulation or have been as combined with FAQ 06-0001 Comments received from NRC on 11/30/06.

9/28/2006 With TF for review. Revision by May '07. NRC Comments 10/26/2006 comments on R2b warrant R3. Will have by May R4 submitted H NEI Kleinsorg Barbadaro provided on 3/22/07 6/21/2007 07 to NRC R2b 5/17/07 6/5/07 Additional internal comments to be included in new FAQ Awaiting NRC final comments/closure.

06-0013 Clarify Chapter 4 Will be presented at 2007 HNP Pilot meeting.

Methodology Transition Process Bases on Pilot Plant Duke to submit end of Second Quarter 2007 L HNP Ertman Results See FAQ 07-0039 06-0014 0 Cumulative Risk Regulatory Guide 1.205 requires tracking With FPRA TF for comment - 12/14/06 of changes to assess cumulative risk. NEI FPRA TF has L HNP Miskiewicz 04-02 does not provide guidance on this FAQ by 4Q 2007 action issue 06-0015 0 Guidance on not-red Process for determining if non- Sent to Task Force for review 11/30/06 determination compliances found during the transition process are 'not red' needs to be With FPRA TF for review 12/14/06 simplified.

Ken Heffner to provide regulatory input to this FAQ by 12/14/06 FPRA TF has H NEI Afzali Amir Afzali to provide PRA screening criteria for action

'not red' determination by 12/14/06 Amir Afzali to discuss with PRA Task Force to increase focus Provide FAQ by 1st week in July 2007 06-0016 1 1 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for Electrical Source counting guidance for Electrical Cabinets Cabinets in NUREG/CR-6850, supporting Submitted to Task Force 11/30/06.

NFPA-805 Fire PRA application.

Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 R1 Preliminary verbal comments provided by NRC. Submitted R1 H HNP Miskiewicz Gallucci accepted. 12/19/2006 Potential disagreement on the examples to NRC Closed provided in the FAQ were discussed by Ray Gallucci of the NRC.

Kiang Zee provided feedback that the examples were intended to be taken collectively and were intended to be drawn to scale.

Page2 of 5

06-0017 2 2 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for High Energy Source counting guidance for High Energy Arcing Faults (HEAF) Arcing Faults (HEAF) in NUREG/CR-6850, Submitted to Task Force 11/30/06.

supporting NFPA-805 Fire PRA application. Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Comments 12/19/2006 Submitted R2 Preliminary verbal comments provided by NRC. H HNP Miskiewicz Reviewer provided on 05/15/2007 6/21/2007 to NRC R1 6/4/2007 Preliminary comments indicated a recommending splitting of HEAFs into a low voltage and high voltage bins. In addition, a new frequency is being considered for bus ducts.

06-0018 1 1 Ignition Source counting Clarification/enhancement of Ignition Presented at November 2006 pilot meeting guidance for Main Control Source counting guidance for Main Board (MCB) Control Board (MCB) in NUREG/CR-6850, Submitted to Task Force 11/30/06.

supporting NFPA-805 Fire PRA application Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 R1 Submitted R1 H HNP Miskiewicz Gallucci accepted. 12/19/2006 to NRC Preliminary verbal comments provided by NRC. Closed Preliminary comments indicated more focus on counting just horseshoe cabinets as MCBs.

06-0019 1 1 Define power block and Define where used in Chapter 3, power Presented to Task Force 11/30/06 plant block and plant are intended to mean areas in which a fire could jeopardize the Comments from Task Force to initiator by ability to meet the performance criteria 12/14/06 Submitted to NRC 12/19/06 described in section 1.5.

Comments to be provided by NRC prior to Feb.

3.3.1.2 Control of Combustible Materials 2007 meeting.

(1)Wood used within the power block Comments R1 submitted 12/19/2006 shall be listed pressure-impregnated or TF will submit new revision by May 2007 H HNP Holder Dinh provided on to NRC 5/8/2007 coated with a listed fire-retardant R0 application. Awaiting NRC Final Review and Comments -

Exception: Cribbing timbers 6 in. by 6 in. estimate July meeting (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

06-0020 1 1 Definition of applicable (6) Controls on use and storage of Presented to Task Force 11/30/06 Comments flammable gases shall be in accordance R1 submitted 12/19/2006 H HNP Holder Dinh provided on with applicable NFPA standards. CLOSED 5/17/07 to NRC 5/8/2007 R0 06-0021 1a 1a Clarify that air drops are 3.3.5.2 - Only metal tray and metal Presented to Task Force 11/30/06 acceptable. conduits shall be used for electrical raceways. Thin wall metallic tubing shall CLOSED 5/17/07 not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short Comments R1 submitted 12/19/2006 lengths to connect components. LL HNP Holder Dinh provided on to NRC 5/8/2007 R0 HNP as well as other plants have exposed cable drops ~ 3 in length.

06-0022 0 0a Identify a list of typical flame 3.3.5.3 - Electric cable construction shall Presented to Task Force 11/30/06 propagation tests which are comply with a flame propagation test as considered acceptable. acceptable to the AHJ. Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 TF waiting for Plan to M ANO Puckett Moulton NRC 12/19/2006 comment Preliminary verbal comments provided by NRC. comments Additional info on applicability of test requested by NRC.

06-0023 0 0 Grant exception for Diesel 3.3.8 Bulk Storage of Flammable and Presented to Task Force 11/30/06 Generator Day Tanks located Combustible Liquids - Bulk storage of within Diesel Generator flammable and combustible liquids shall Submitted to NRC 12/19/06 Buildings. not be permitted inside structures WITHDRAWN Proposed containing systems, equipment, or NRC questioned if issue warranted a FAQ since it LL HNP Holder Lain 12/19/2006 5/17/07 withdraw components important to nuclear safety. is part of plant systems As a minimum, storage and use shall comply with NFPA 30, Flammable and WITHDRAWN 5/17/07 Combustible Liquids Code.

Page3 of 5

06-0024 0 1 Define what adequate 3.3.11 Electrical Equipment - Adequate Presented to Task Force 11/30/06 clearance is. clearance, free of combustible material, shall be maintained around energized Submitted to NRC 12/19/06 electrical equipment. TF reviewing Comments Preliminary verbal comments provided by NRC. M HNP Holder Oudinot R1, planned provided on 12/19/2006 Need to provide a clearer definition of submittal R0

'adequate clearance'. Could be based on Initiator resubmitted to Task Force planned OSHA 3ft requirement. submittal to NRC first week of July 06-0025 1b 1b Define minimum acceptable 3.4 Industrial Fire Brigade - 3.4.2.1 - The Presented to Task Force 11/30/06 R1b updated pre-plan scope. plans shall detail the fire area 4/19 configuration and fire hazards to be encountered in the fire area, along with Awaiting NRC Review and comments - by July any nuclear safety components and fire meeting Comments R1 submitted 12/19/2006 protection systems and features that are M HNP Holder Barbadaro provided on to NRC 5/8/2007 present. R0 Suggest define more clearly what the minimum acceptable pre-plan scope is.

Consider use of existing guidance.

06-0026 0 0 Clarify NFPA code 3.4.4 Fire-Fighting Equipment - Protective Presented to Task Force 11/30/06 requirements for gear clothing, respiratory protective maintenance equipment, radiation monitoring Comments from Task Force to initiator by equipment, personal dosimeters, and fire 12/14/06 Submitted to NRC 12/19/06 suppression equipment such as hoses, nozzles, fire extinguishers, and other Preliminary verbal comments provided by NRC.

needed equipment shall be provided for the industrial fire brigade. This equipment WITHDRAWN 5/17/07 WITHDRAWN Proposed M HNP Holder Oudinot 12/19/2006 shall conform with the applicable NFPA 5/17/07 withdraw standards.

Clarify that intent is for design and purchase of equipment. NFPA code requirements for gear maintenance is not applicable.

06-0027 0 0 Clarify the where provided 3.7 Fire Extinguishers - Where provided, To TF by Feb 07 statement. fire extinguishers of the appropriate number, size, and type shall be provided Not discussed on 1/18/07 in accordance with NFPA 10, Standard for Portable Fire Extinguishers. Extinguishers Rev 0 sent to NRC on 5/17/07 shall be permitted to be positioned outside of fire areas due to radiological Awaiting NRC Review and comments Submitted R0 conditions. M ANO Puckett 5/17/2007 to NRC Part of NFPA 10 is placement / travel distances for extinguishers. The 'where provided' statement needs clarification.

06-0028 2 2 Clarify intent of 3.3.1.1 General Fire Prevention Activities - Presented to Task Force 11/30/06 familiarization with plant fire (1) Training on fire safety information for prevention procedures, fire all employees and contractors including, Comments from Task Force to initiator by reporting, and plant as a minimum, familiarization with plant 12/14/06 Submitted to NRC 12/19/06 Comments 12/19/2006 R2 submitted emergency alarms fire prevention procedures, fire reporting, M HNP Holder Oudinot provided on 5/8/2007 6/21/2007 to NRC regarding scope of or depth and plant emergency alarms Not discussed on 1/18/07 R1 5/21/2007 of the training.

Clarify the intent of 'familiarization'. Submitted to NRC 5/21/07 06-0029 0a Clarify zone of influence for FDT spreadsheets are used to provide a Submitted to the task force: 12/19/06 NUREG 6850 Task 8. zone of influence.

Discuss at January 24, 2007 FPRA meeting WITHDRAWN L HNP Thompson Not discussed on 1/18/07 6/21/07 WITHDRAWN 6/21/07 FAQ by 3Q 2007 4.2.4 Clarification of risk impact of 07-0030 Risk of recovery actions recovery actions, to include extension of M HNP Ertman existing HRA scenarios 0 0 Draft to NEI TF for April 2007.

Miscellaneous ignition frequency binning issues. Questions arise during ignition Awaiting NRC review and comments - been sent Submitted R0 07-0031 Misc Binning Issues frequency counting, such as: MOV to Research M HNP Miskiewicz 5/17/2007 to NRC motors, Hydraulic actuators for valves, Transformers 0 Draft to NEI TF for May 2007.

10CFR 50.48(a) and GDC 3 Clarify that satisfying 10 CFR 50.48(c) will 07-0032 M HNP Holder TF reviewing clarification satisfy 10 CFR50.48(a) and GDC3 FAQ to be submitted by June Page4 of 5

0 Review of Existing Discuss how EEEE will be reviewed and 07-0033 Engineering Equivalency Draft to NEI TF for May 2007. M HNP Holder TF reviewing summarized for transition Evaluations 0 Clarification of guidance for deterining if Determination of non-vented Draft to NEI TF for May 2007.

07-0034 an electrical cabinet can be dispositioned M HNP Miskiewicz TF reviewing Cabinets FAQ submitted by June as non-vented 0 0 Bus Duct counting guidance July 13 meeting between industy (PRA Task Submitted R0 07-0035 Split from FAQ 06-0017 - Bus duct M HNP Miskiewicz 6/12/2007 for High Energy Arcing Faults Force) and NRC Task Force to NRC Define compliance categories NEI 04-02 update to include lessons 07-0036 Draft FAQ for June 2007 TF Meeting H HNP Holder for Table B-1 learned on Table B-1 process Provide guiudance regarding Environmental considerations 07-0037 environmental considerations of other Draft FAQ for August 2007 TF Meeting M HNP Holder for equipment equipment in the fire affected area Incorporate pilot lessons learned for Lessosn learned for OMA, preemptive manual actions, MSO expert 07-0038 Draft FAQ for July 2007 TF Meeting H HNP Ertman MSO and FPRA panel and Fire PRA processes into NEI 04-02 Provide update of NEI 04-02 NEI 04-02 update to include lessons 07-0039 Draft FAQ for July 2007 TF Meeting H HNP Ertman B-2 and B-3 Processes learned on Table B-2 and B-3 processes Page5 of 5