ML063170357

NFPA-805 Transition Pilot Plant FAQ-06-0002, Revision 1

ML063170357
Person / Time
Site:	Harris
Issue date:	10/26/2006
From:	Ertman J Carolina Power & Light Co
To:	Office of Nuclear Reactor Regulation
References
FAQ 06-0002, Rev. 1
Download: ML063170357 (11)

Text

FAQ Number 06-0002 Revision 1 Plant: Harris Nuclear Plant Submittal Date: 10/26/06 Submitter

Contact:

Jeff Ertman Phone: 919.546.2662 Submitter Email: jeffrey.ertman@p nmai!.com Distribution: (NEI Internal Use) 0 805 TF E] FPWG [: RATF El RIRWG F] BWROG LI PWROG

Subject:

Interpretation of guidance? Ve-s No Proposed new guidance not in NEI 04-02? FYe / No Details:

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

NEI 04-02, Section 5.3 and Appendix I.

Circumstances requiring guidance interpretation or new guidance:

Recommend making nuclear safety and radioactive release questions first in screening reviews in order to determine necessity for Chapter 3 features and systems.

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

N/A Potentially relevant existing FAQ numbers:

Related to FAQ 06-0003 Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Page 1 of 8 faq 06-0002 - chap 4 questions first - rev 1b.doc

FAQ Number 06-0002 Revision 1 Revise NEI 04-02 Section 5.3 and Appendix I, to reflect the revised order of questions.

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

See attached revision.

Page 2 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision I Page Iof.__

'ICENSEE NAME... . .......... . .u NIT(S. -f Deleted: UTILITY El SITEA El SITE B El SITEC E[ Uniti El Unit2 El Unit3 ACTIVITY TITLE/DOCUMENT/REVISION Complete each section and summarize results below.

CONCLUSIONS,`

CHANGE EVALUATION :

SUMMARY

RISK EVALUATION

SUMMARY

E] The change is editorial or trivial in nature. El The change can be evaluated using a PRELIMINARY (Screening per Section L.a, 2.a, or 3.a) RISK SCREEN (Section 4)

H The change affects compliance witlh the Nuclear 0l Yes E] No Safety Criteria of NFPA 805 as defined iii linsert reference to the appropriate documentl El The RISK EVALUATION demonstrates that A (Section 1). CDF/LERF are acceptable and defense-in-depth / safety Yes - No margin are maintained. Therefore, the change is acceptable.

with the Fl The change affects compliance Radioactive Release Criteria of N FPA 805 as defined in [insert reference to the appropriate El The RISK EVALUATION demonstrates that either the A documentl (Section 2). CDF/LERF are unacceptable and/or defense-in-depth /

] Yes [7 No safety margin are not maintained. Therefore, the change is NOT acceptable.

El The change affects compliance with a required Fundamental Elements / Minimum Design Requirements of NFPA 805 Chapter 3 (Section

-f Deleted: I License Amendment Required?

E] Yes El No.------------------------------------------------ Deleted: ¶ SIGNOFFS E] The change affects compliance with the Nuclear Safety Criteria of NFPA 805 as defined in [insert Print Name Signature DATE reference to the appropriate documenti (Section 2).¶ SCREEN PREPARER I

El Yes [] No¶ El The change affects compliance with the Radioactive Release Criteria Print Name Signature DATE of NFPA 805 as defined in linsert reference to the appropriate documentf SCREEN REVIEWER (Section 3).¶ El Yes El No CHANGE DESCRIPTION Provide a brief description of what is being changed and why.

REERENCES List applicable references. Include sufficient identifying detail to facilitate independent review and retrieval.

Signoffs should be consistent with the Licensee's processes. For example it may be necessary for a fire protection engineer, PRA engineer, or safe shutdown engineer to have signature authority on the Plant Change Evaluation.

Page 3 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision 1

.. .... ": " ;; */: NUCL.EARSAFETYCOMPLIANCESTRATEGkYCHANGE QUESTIONS - ------

Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed chance does or does not satisfy the referenced document(s).

I. Does the proposed change involve a Nuclear Safetv Compliance Strategy requirement as defined in [Insert appropriate document referencel?

• F"- Yes - Proceed to Question L.a.

• F1 No Document basis and nroceed to Onestion 2.

a. Is the change editorial or trivial intnature? (See Attachment 1) o F] Yes Document basis and stop.

o El No Proceed to Question I.b.

b. Does the change meet the deterministic requirements of Chapter 4 of NFPA 805?

o F- Yes Document basis and complete remaining sections.

o F-- No Proceed to Question I.c.

c. Is the change equivalent to the NFPA 805 Chapter 4 compliance strategy as defined in rInsert appropriate document referencel? Ensure documentation for determination of equivalency is included and meets NEI 04-02 recquirements for documentation - Deleted: (See Attachmnent 2) o -- Yes Document basis and complete remaining sections.

o F- No Perform a Risk Evaluation.

Changes to Fire Protection Program Fundamental element / minimum design requirements that are required !for compliance with NFPA 805 Chatpter- 3ý6..oo meet the Nticlear Safety

• Comment [EK1]: Added based on, Perfonrance Criteria must be evaluated in Section 3. NRC Comments Page 4 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision 1 S ,, . RADIOACTIVE RELEASE CHANGE QUESTIONS C~onsidering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensingt basis, or NFPA document(s). and a brief description of why the proposed change does or does not satisfis the referenced document(s).

2. Does the proposed change involve a Radioactive Release requirement as defined in [Insert appropriate document referencel?

" F1 Yes- Proceed to Question 2.a.

" F-] No - Document hasis and rrocced to risk screenint.

a. Is the change editorial or trivial in nature? (See Attachment I) o F- Yes Document basis and stop.

o Fl No Proceed to Question 2.b.

b. Does the change meet the requirements of the Radioactive Release criteria?

o F- Yes Document conclusions and proceed to risk screening.

o0 l No Proceed to Question 2.c.

c. Is the change equivalent to the Radioactive Release compliance strategy as defined in [Insert appropriate document reference]? Ensure documentation for determination of equivalency is included and meets NEI 04-02 requirements for documentation Deleted: (See Attachment 2) o F- Yes Document conclusions and'proceed to risk screening o F- No Perform a Risk Evaluation.

Changes to Fire Protection Program Fundamental element/ mninimum design reqiuirements that are required !for compliance with NFPA 805 Chapter 3 or to meet the Radioactive Comment [EK2]: Added based on Release Performance Criteria must be evaluated in Section 3. NRC CommentsI Page 5 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision I FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT/ MINIMUM DESIGN REQUIRIREMEN T CHANGE QUESTION I Formatted Table Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

Does o the proposed change involve an NFPA 805 Chapter 3 reqo3irement as defined in [lnsert appropriate document reference]? For those fire protection program changes that involve a Nuclear Safety Compliance Strategy requirement or a Radioactive Release requirement,.ensure the effect of the change is evaluated in Appendix I, Sections 1.0 and 2.0. respectively.

Deleted: I

• D Yes - Proceed to Question la. ............

FD No - Document basis and proceed to Question 2

a. Is the change editorial or trivial in nature? (See Attachment 1) o D Yes Document basis and stop.

LDeleted:

oW No Proceed to Question3b_.

b. Does the change meet NFPA 805 Chapter 3 requirements or the previously approved alternative as defined in [Insert appropriate document reference]?

Changes that deviate from the NFPA standards referenced in NFPA 805 Chapter 3 can be made without NRC approval if allowed by the code of record (so long as the evaluated condition is in accordance with the terms of the code of record) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection systems). Ensure documentation for determination of acceptability is included and meets NEI 04-02 requirements for documentation. (See Attachment 2) o F- Yes ' Document conclusions, complete remaining sections.

o [] No License Amendment Request must be processed for NRC approval.

Complete remaining sections.

Page 6 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision I

... . .. . . .. . .. . . . . . . . .. . . . . . . .. . . . . Deleted: ¶ PRELIMINARY RIS*

SRISK SCREENING NUCLEAR SAFETY COMPLIANCE

[STRATEGY CHANGE QUESTS ni the change should enable you to Considering the proposed change, answer the following questions. The nature of choose among the three categories. Refer to the IPEEE, a plant-specific fire PRA, or other documents to determine whether the change could have "no", "minimal" or "greater than minimal" impact. Document the basis for the conclusion. The potential for common cause effects of a given plant change on the above factors should be considered. For example, an increase in combustible loading in an area can impact all of the factors. See for examples.

4.0 Can the change be evaluated using a preliminary risk screen?

a. Does the proposed change impact the FIRE FREQUENCY of any fire scenarios affected by the change?

o Li No Impact o LI Minimal Impact o Li Greater than minimal

b. Does the proposed change impact the MAGNITUDE OF THE EXPECTED FIRES for any fire scenarios affected by the change?

o Li No Impact o LI Minimal Impact o LI Greater than minimal

c. Does the proposed change impact the DETECTION CAPABILITY for any fire scenarios affected by the change?

o F! No Impact o LI Minimal Impact o LI Greater than minimal

d. Does the proposed change impact the SUPPRESSION CAPABILITY for any fire scenarios affected by the change?

o LI No Impact o LI Minimal Impact o LI Greater than minimal Page 7 of 8 faq 06-0002 - chap 4 questions first - rev lb.doc

FAQ Number 06-0002 Revision 1

e. Does the proposed change impact the POST-FIRE CAPABILITY OF PLANT SYSTEMS TO PREVENT CORE DAMAGE (including fire affected human actions) during any mode of operation for any fire scenarios affected by the change'?

o nI No Impact o [] Minimal Impact o LI Greater than minimal

f. Do any of the risk screening questions have "Greater than minimal" impact, then a detailed quantitative risk evaluation may be required.

o LI No. The Fire Protection Program Plant change meets the risk-informed acceptance criteria of NFPA 805 Section 2.4.4.

o 'LI Yes, a detailed quantitative risk evaluation is required.

Page 8 of 8 faq 06-0002 - chap 4 questions first - rev Ib.doc

10/23/2006 9:04:00 AM Page 7:

Page [1] Deleted 7: [1] Deleted Liz Kleinsorg Liz Kleinsorg 10/23/2006 9:04:00 AM SNUCiLAR*SAFETY COMPLIANC* STRATEGY CHANGE QUESTIONS*  ;*jA

• Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

2. Does the proposed change involve a Nuclear Safety Compliance Strategy requirement as defined in [Insert appropriate document reference]?

g Yes - Proceed to Question 2.a.

[ No - Document basis and proceed to Question 3.

a. Is the change editorial or trivial in nature? (See Attachment 1) 9 Yes Document basis and stop.

[* No Proceed to Question 2.b.

b. Does the change meet the deterministic requirements of Chapter 4 of NFPA 805?

1 Yes Document basis and complete remaining sections.

1 No Proceed to Question 2.c.

c. Is the change equivalent to the NFPA 805 Chapter 4 compliance strategy as defined in [Insert appropriate document reference]? Ensure documentation for determination of equivalency is included and meets NEI 04-02 requirements for documentation.

(See Attachment 2)

[ Yes Document basis and complete remaining sections.

] No Perform a Risk Evaluation.

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.RADIOACTIVE RELEASE CHANGE QUESTIONS .

Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

3. Does the proposed change involve a Radioactive Release requirement as defined in

[Insert appropriate document reference]?

Ej Yes - Proceed to Question 3.a.

E3 No - Document basis and proceed to risk screening.

a. Is the change editorial or trivial in nature? (See Attachment 1)

E3 Yes Document basis and stop.

E No Proceed to Question 3.b.

b. Does the change meet the requirements of the Radioactive Release criteria?

E Yes Document conclusions and proceed to risk screening.

1 No Proceed to Question 3.c.

c. Is the change equivalent to the Radioactive Release compliance strategy as defined in

[Insert appropriate document reference]? Ensure documentation for determination of equivalency is included and meets NEI 04-02 requirements for documentation. (See Attachment 2)

[D Yes Document conclusions and proceed to risk screening E3 No Perform a Risk Evaluation.

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