Text

NFPA 805 Transition Pilot Plant FAQ Process: Substantive E-Mails; October 2006
	ML071630401
Person / Time
Issue date:	10/13/2006
From:	Charles Moulton; NRC/NRR/ADRA/DRA/AFPB
To:	Jamar B; Nuclear Energy Institute
References
	Download: ML071630401 (97)
	v • d • e

Brandon, Could you send us a word version of FAQ 06-0008? It would speed our review (and annotation) of this very long document.

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

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Subject:

Request for MSWord version of FAQ 06-0008 Creation Date Fri, Oct 13, 2006 2:22 PM From: Charles Moulton Created By: CEM4@nrc.gov Recipients Action Date & Time nei.org btj (internet:btj@nei.org) Transferred 10/13/06 2:23 PM nrc.gov PWL CC (Paul Lain) Delivered 10/13/06 2:22 PM Opened 10/13/06 2:49 PM nrc.gov RFR1 CC (Robert Radlinski) Delivered 10/13/06 2:23 PM Opened 10/13/06 2:26 PM nrc.gov SDW1 CC (Sunil Weerakkody) Delivered 10/13/06 2:23 PM Opened 10/17/06 11:48 AM Post Office Delivered Route nei.org nrc.gov nrc.gov nrc.gov Files Size Date & Time MESSAGE 809 Friday, October 13, 2006 2:22 PM Options Auto Delete: No Expiration Date: None Notify Recipients: No Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened

Paul/Sunil, I've attached the subject FAQs for submittal for Thursday's meeting. I plan on sending revision to FAQ 06-0005 by COB tomorrow.

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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Subject:

FAQs 06-0002/3/6/12 Creation Date Tue, Oct 24, 2006 2:59 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 PWL (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov TWGWPO04.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 755 Tuesday, October 24, 2006 2:59 PM FAQ 06-0002 - Chap 4 Questions First - Rev 1b.pdf 111294 FAQ 06-0003 - Potentially Greater than Minimal - Rev 1b.pdf 119495 FAQ 06-0006 - Hi-Lo Low Pressure Interface - Revision 1a.pdf 133137 FAQ 06-0012 - Manual Actions - Rev 1a.pdf 83359 Mime.822 616723 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard

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@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG

Subject:

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):

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 1b.doc

FAQ Number 06-0002 Revision 1 Page 1 of ____

LlCENSEE NAME UNIT(S) Deleted: UTILITY SITE A SITE B SITE C Unit 1 Unit 2 Unit 3 ACTIVITY TITLE/DOCUMENT/REVISION Complete each section and summarize results below.

CONCLUSIONS CHANGE EVALUATION :

SUMMARY

RISK EVALUATION

SUMMARY

The change is editorial or trivial in nature. The change can be evaluated using a PRELIMINARY (Screening per Section 1.a, 2.a, or 3.a) RISK SCREEN (Section 4)

The change affects compliance with the Nuclear Yes No Safety Criteria of NFPA 805 as defined in

[insert reference to the appropriate document] The RISK EVALUATION demonstrates that (Section 1). CDF/LERF are acceptable and defense-in-depth / safety Yes No margin are maintained. Therefore, the change is acceptable.

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

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

The change affects compliance with a required Fundamental Elements / Minimum Design Requirements of NFPA 805 Chapter 3 (Section 3). Deleted: 1 License Amendment Required?

Yes No Deleted: ¶ SIGNOFFS The change affects compliance with the Nuclear Safety Criteria of NFPA 805 as defined in [insert Print Name DATE reference to the appropriate document]

Signature (Section 2).¶ 1 Yes No¶ SCREEN PREPARER The change affects compliance with the Radioactive Release Criteria Print Name DATE of NFPA 805 as defined in [insert Signature reference to the appropriate document]

SCREEN REVIEWER (Section 3).¶ Yes No CHANGE DESCRIPTION Provide a brief description of what is being changed and why.

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

1 Signoffs should be consistent with the Licensees 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 1b.doc

FAQ Number 06-0002 Revision 1 NUCLEAR SAFETY COMPLIANCE STRATEGY 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).

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

Yes - Proceed to Question 1.a.

No - Document basis and proceed to Question 2.

_

_______________________________________________________________________________

____________________________________________________

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

o No Proceed to Question 1.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o Yes Document basis and complete remaining sections.

o No Proceed to Question 1.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. Deleted: (See Attachment 2) o Yes Document basis and complete remaining sections.

o No Perform a Risk Evaluation.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

Changes to Fire Protection Program Fundamental element / minimum design requirements that are required for compliance with NFPA 805 Chapter 3 or to meet the Nuclear Safety Comment [EK1]: Added based on Performance Criteria must be evaluated in Section 3. NRC Comments Page 4 of 8 faq 06-0002 - chap 4 questions first - rev 1b.doc

FAQ Number 06-0002 Revision 1 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).

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

Yes - Proceed to Question 2.a.

No - Document basis and proceed to risk screening.

_

_______________________________________________________________________________

____________________________________________________

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

o No Proceed to Question 2.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o Yes Document conclusions and proceed to risk screening.

o 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 Yes Document conclusions and proceed to risk screening o No Perform a Risk Evaluation.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

Changes to Fire Protection Program Fundamental element / minimum design requirements 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 Comments Page 5 of 8 faq 06-0002 - chap 4 questions first - rev 1b.doc

FAQ Number 06-0002 Revision 1 FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT / MINIMUM DESIGN REQUIREMENT CHANGE QUESTIONS 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).

3. Does the proposed change involve an NFPA 805 Chapter 3 requirement as defined in [Insert Deleted: 1 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: 1

Yes - Proceed to Question 3.a.

No - Document basis and proceed to Question 2

_

_______________________________________________________________________________

____________________________________________________

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

Deleted: 1 o No Proceed to Question 3.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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 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 1b.doc

FAQ Number 06-0002 Revision 1 Deleted: ¶ PRELIMINARY RISK SCREENING NUCLEAR SAFETY COMPLIANCE STRATEGY CHANGE QUESTIONS

... [1]

Considering the proposed change, answer the following questions. The nature of the change should enable you to 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 No Impact o Minimal Impact o Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Greater than minimal Page 7 of 8 faq 06-0002 - chap 4 questions first - rev 1b.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 No Impact o Minimal Impact o 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 No. The Fire Protection Program Plant change meets the risk-informed acceptance criteria of NFPA 805 Section 2.4.4.

o Yes, a detailed quantitative risk evaluation is required.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

Page 7: [1] Deleted Liz Kleinsorg 10/23/2006 9:04:00 AM NUCLEAR SAFETY COMPLIANCE STRATEGY 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).

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

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)

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?

Yes Document basis and complete remaining sections.

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.

__________________________________________________________

____________________________________________________________________

____________

Page Break 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]?

Yes - Proceed to Question 3.a.

No - Document basis and proceed to risk screening.

___________________________________________________________________

________________________________________________________________________

_______

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

Yes Document basis and stop.

No Proceed to Question 3.b.

__________________________________________________________

____________________________________________________________________

____________

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

Yes Document conclusions and proceed to risk screening.

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)

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

__________________________________________________________

____________________________________________________________________

____________

Page Break

FAQ Number 06-0003 Revision 1 Plant: Harris Nuclear Plant Submittal Date: 10/26/06 Submitter

Contact:

Jeff Ertman Phone: 919.546.3681 Submitter Email: jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG

Subject:

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):

NEI 04-02, Section 5.3 and Appendix I.

Circumstances requiring guidance interpretation or new guidance:

Change Question 4.f to potentially greater than minimal versus greater than minimal in Section 5.3 and the change process sheets in Appendix I of NEI 04-02.

Also factor risk decreases into the process 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 06-0002 Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Page 1 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 Revise NEI 04-02 Section 5.3 and Appendix I, to reflect revision.

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

See attached revision.

Page 2 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 5.3.3 Preliminary Risk Screening Once the definition of the change is established, a screening is then performed to identify and resolve minor changes to the fire protection program. This screening is consistent with fire protection regulatory review processes in place at nuclear plants under traditional licensing bases. This screening process is modeled after the NEI 02-03 process. This process will address most administrative changes (e.g., changes to the combustible control program, organizational changes, etc.).

The characteristics of an acceptable screening process that meets the assessment of the acceptability of risk requirement of Section 2.4.4 of NFPA 805 are:

The quality of the screen is sufficient to ensure that potentially greater than minimal risk increases receive detailed risk assessments appropriate to the level of risk.

The screening process must be documented and be available for inspection by the NRC.

The screening process does not pose undue evaluation or maintenance burden.

If any of the above is not met, proceed to Section 5.3.4 Risk Evaluation.

Appendix I contains an example of a screening process. The screening process is divided into assessing if the change is trivial (Sections 1.a, 2.a, 3.a) and performing a risk screen in Section 4.0. The risk screen identifies and documents the factors that contribute to the risk associated with the change. In general, these factors include changes in: a) frequency of all fire scenarios which are affected by the change, b) magnitude of expected fires, c) detection capability, d) suppression capability, and e) post-fire capability of plant systems to prevent damage to the core.

The impact of the plant change on each of these factors can be evaluated (either qualitatively or quantitatively) and categorized as: no impact, minimal impact or potentially greater than minimal impact. The nature of the change would enable a licensee to choose among the three categories. A licensee may refer to their IPEEE, the fire protection SDP, or other documents to determine whether the change could have minimal or potentially greater than minimal impact. The licensee should document the basis for the conclusion. For those changes that do not meet the screening criteria a more detailed Risk Evaluation is required.

If a plant change could cause a potentially greater than minimal impact with respect to more than one of the above factors, or could result in a common cause impact on more than one of the above factors ((a) frequency of all fire scenarios which are affected by the change, b) magnitude of expected fires, c) detection capability, d) suppression capability, and e) post-fire capability of plant systems to prevent damage to the core) licensees are encouraged to perform risk Comment [EK1]: editorial assessments of the more detailed, quantitative variety.

The preliminary risk screening and risk evaluations should also identify decreases in risk that are associated with the change. Depending upon the nature and magnitude of the decrease, consideration should be given to updating the risk model to account for the decrease.

Page 3 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 Plant Change Evaluation Form Page 1 of ____

UTILITY NAME UNIT(S)

SITE A SITE B SITE C Unit 1 Unit 2 Unit 3 ACTIVITY TITLE/DOCUMENT/REVISION Complete each section and summarize results below.

CONCLUSIONS CHANGE EVALUATION :

SUMMARY

RISK EVALUATION

SUMMARY

The change is editorial or trivial in nature. The change can be evaluated using a PRELIMINARY (Screening per Section 1.a, 2.a, or 3.a) RISK SCREEN (Section 4)

The change affects compliance with a Yes No Fundamental Elements / Minimum Design Requirements of NFPA 805 Chapter 3 (Section The RISK EVALUATION demonstrates that 1). CDF/LERF are acceptable and defense-in-depth / safety License Amendment Required? margin are maintained. Therefore, the change is Yes No acceptable.

The change affects compliance with the Nuclear The RISK EVALUATION demonstrates that either the Safety Criteria of NFPA 805 as defined in CDF/LERF are unacceptable and/or defense-in-depth /

[insert reference to the appropriate document] safety margin are not maintained. Therefore, the change (Section 2). is NOT acceptable.

Yes No The change affects compliance with the Radioactive Release Criteria of NFPA 805 as defined in [insert reference to the appropriate document] (Section 3).

Yes No SIGNOFFS Print Name DATE Signature SCREEN PREPARER1 Print Name DATE Signature SCREEN REVIEWER CHANGE DESCRIPTION Provide a brief description of what is being changed and why.

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

1 Signoffs should be consistent with the Licensees 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 4 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT / MINIMUM DESIGN REQUIREMENT 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).

1. Does the proposed change involve an NFPA 805 Chapter 3 requirement as defined in [Insert 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 2.0 and 3.0, respectively.

Yes - Proceed to Question 1.a.

No - Document basis and proceed to Question 2

_

_______________________________________________________________________________

____________________________________________________

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

o No Proceed to Question 1.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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 Yes Document conclusions, complete remaining sections.

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

Complete remaining sections.

_______________________________________________________________________

___________________________________________________________________________

Page 5 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 NUCLEAR SAFETY COMPLIANCE STRATEGY 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).

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

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) o Yes Document basis and stop.

o No Proceed to Question 2.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o Yes Document basis and complete remaining sections.

o 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) o Yes Document basis and complete remaining sections.

o No Perform a Risk Evaluation.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

Page 6 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 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]?

Yes - Proceed to Question 3.a.

No - Document basis and proceed to risk screening.

_

_______________________________________________________________________________

____________________________________________________

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

o No Proceed to Question 3.b.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o Yes Document conclusions and proceed to risk screening.

o 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) o Yes Document conclusions and proceed to risk screening o No Perform a Risk Evaluation.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

Page 7 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 PRELIMINARY RISK SCREENING Considering the proposed change, answer the following questions. The nature of the change should enable you to 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 potentially 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 No Impact o Minimal Impact o Potentially Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Potentially Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Potentially Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

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

o No Impact o Minimal Impact o Potentially Greater than minimal Page 8 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 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 No Impact o Minimal Impact o Potentially Greater than minimal

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

f. Do any of the risk screening questions have Potentially greater than minimal impact, then a Deleted: G detailed quantitative risk evaluation may be required.

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

o Yes, a detailed quantitative risk evaluation is required.

_______________________________________________________________________

___________________________________________________________________________

_____________________________________________________

Note: Changes that clearly decrease risk should be identified during the review for potential updates to the risk model.

Page 9 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 ATTACHMENT 3 - PRELIMINARY RISK SCREENING EXAMPLES Frequency of fire scenarios: A like-kind replacement of fire protection equipment or systems has no impact on fire frequencies. Installing an electrical cabinet in a switchgear room could cause minimal or potentially greater than minimal impact on the fire Deleted: -

frequency. Changing administrative procedures to allow welding in an area where it was Deleted: -

previously prohibited could cause a potentially greater than minimal increase in the Deleted: -

frequency of fire. Deleted: -

Magnitude of expected fires: Replacing a cable with one of equivalent combustible loading and type has no impact on the magnitude of the expected fires. Routing a new cable through a switchgear room could cause minimal increase in the fire magnitude. Storing a drum of oil in the emergency diesel generator room could cause a potentially greater than Deleted: -

minimal increase in the magnitude of expected of fire. Deleted: -

Detection capability: Changes to safe shutdown equipment generally have no impact on the detection capability. A decrease in the normal area occupancy level where manual suppression and automatic detection are available could cause a minimal decrease in the fire detection capability. A decrease in normal area occupancy level where manual suppression is available but no automatic detection is provided could cause a potentially greater than minimal decrease in the fire detection capability. A discovery of an NFPA code compliance issue can be evaluated and may or may not have a potentially greater than minimal impact on risk.

Suppression capability: Adding a few new cables to a cable tray without reducing the separation between redundant trains or adding an obstacle to a sprinkler spray-down path has no impact on the suppression capability. A decrease in the number of fire extinguishers available to fight fires or an equipment change that creates a minor obstruction to a suppression system spray pattern could cause minimal decrease in the fire suppression capability. Converting an automatic suppression system to a fixed manual fire suppression system could cause a potentially greater than minimal reduction in the fire suppression capability. A discovery of an NFPA code compliance issue can be evaluated and may or may not have a potentially greater than minimal impact on risk.

Post-fire capability of plant systems to prevent damage to the core: Replacing a component with a similar component will typically have no impact on plant systems post-fire capability to prevent damage to the core, as long as the location of the component and cable routing remain unchanged. Rerouting one cable associated with a very low risk-significant system could cause minimal decrease in the plant systems capability to prevent damage to the core. Rerouting cables of a safety-related or a risk- significant system where separation is reduced or replacing a check valve with a motor- operated valve could cause a potentially greater than minimal decrease in the plant systems capability to prevent damage to the Deleted: G core. (Procedural changes should also be evaluated as part of this evaluation factor.)

Addition of minor amounts of cable to a cable tray, where margin is provided in combustible control programs (assuming no impact on the nuclear safety criteria)

Changing a handwheel on a valve to a similar type.

Relocating a fire extinguisher several feet due to planned modifications (as long as it is within allowable travel distances)

Page 10 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ Number 06-0003 Revision 1 Sealing a wall penetration with an approved rated material that is commensurate with the hazard Changing the one type of approved fire hoses with another that is appropriate for the hazards in the area.

Changing a fire protection feature (e.g., barrier, detection, or suppression system) in an area with no potential for impact on nuclear safety or radioactive release (e.g., warehouse or office areas)

Changing a protective device setting on a power supply credited for post-fire nuclear safety, within the limits for acceptable coordination (as long as the setting was based on the limit and not on the setting)

Rewiring a circuit for a component credited for ensuring nuclear safety. The rewiring does not result in any new or more likely failure modes due to fire in any plant fire area.

Discovery of an unrated penetration in a barrier that has been previously evaluated as adequate for the hazard under a Generic Letter 86-10 fire area boundary evaluation. If the particular penetration is bounded by the current evaluation.

Page 11 of 11 faq 06-0003 - potentially greater than minimal - rev 1b.doc

FAQ TEMPLATE Plant: Harris Nuclear Plant (HNP) FAQ # 06-0006 Submittal Date: 08-??-06 Licensee

Contact:

Jeff Ertman Tele/email 919-546-3681 NRC

Contact:

Tele/email Distribution: Check all that apply (NEI Internal Use)

FPWG RIRWG NSSS OG NFPA 805 TF

Subject:

Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:

NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):

NEI 04-02 Section 4.3.2 NEI 04-02 Appendix B, Section B.2.1 Circumstances requiring guidance interpretation or new guidance:

Section 4.3.2 of NEI 04-02 Revision 1 discusses the process for the Nuclear Safety Performance Criteria Transition Review. This section includes the process for the safe shutdown methodology review, evaluates the existing post-fire safe shutdown analyses against the guidance provided in Section 2.42 of NFPA 805. Appendix B-2 of NEI 04-02 provides details regarding the transition review. Section 2.1 of NEI 04-02 states:

The review should be conducted against the methodology provided in NEI 00-01. This review is intended to ensure that the transitioning nuclear safety analysis meets basic established criteria for identification and analysis of equipment and cables. Exceptions and clarifications identified during the transition review should be documented in order to provide a well-established baseline for future changes.

During a pilot plant review of the post-fire safe shutdown methodology against NEI 00-01 methodology. It was noted that the definition of high-low pressure interface provided in NEI 00-01 Revision 1 Appendix C, is not in strict alignment with the definition provided in NFPA Deleted:

805 (2001 edition) section 1.6.31.

Deleted: It is noted that the NFPA 805 Since this has historically been an area of varying interpretations, it is recommended that the text (Section 1.6.31) contains the definition of high-low pressure interface.

NEI 00-01 Revision 1 interpretation be utilized as part of the NEI 04-02 Revision 1 nuclear However, the remainder of the NFPA 805 safety performance criteria methodology review. text does not include guidance or requirements related to high-low pressure interfaces. The only technical guidance Detail contentious points if licensee and NRC have not reached agreement on the subject is provided in Appendix B to NFPA 805, which has not been Pilot plant meetings yielded no disagreement on this topic. This is Parking Lot Item 4 from the endorsed by the NRC.¶

November 2005 Pilot Meeting (NRC meeting notes - ADAMS Accession No. ML060250034, Att. 2) and the March 2006 Pilot Meeting.

This topic has been a subject of varying interpretations for years. A consistent definition moving forward will avoid future confusion and interpretation by licensees, NRC inspectors, and NRR staff.

Potentially relevant existing FAQ numbers:

None Response Section Proposed Resolution of FAQ and the basis for the proposal:

Revise Section B.2.1 of NEI 04-02 to state (underlined section is the proposed resolution):

Tables B-2 and B-3 of this Appendix outline a recommended method to review the acceptability of a program for transition by examining the basic components of a nuclear safety capability assessment. These worksheets organize the transition of the pre-transitional safe shutdown analysis to the nuclear safety analysis as follows:

1. Nuclear Safety Capability System and Equipment Selection

2. Nuclear Safety Capability Circuit Analysis

3. Nuclear Safety Equipment and Cable Location

4. Fire Area Assessment The review should be conducted against the methodology provided in NEI 00-01. This review is intended to ensure that the transitioning nuclear safety analysis meets basic established criteria for identification and analysis of equipment and cables. Exceptions and clarifications identified during the transition review should be documented in order to provide a well-established baseline for future changes.

The definition in NEI 00-01 for high-low pressure interfaces is not in strict alignment with NFPA 805 (2001 edition, Section 1.6.31) and NEI 00-01, Revision 1, Appendix C). For the purpose of the methodology review, the methodology presented in NEI 00-01 could be used as the basis for acceptability for high-low pressure interfaces involving downstream piping for intersystem LOCAs. Reactor coolant boundary valves whose spurious opening could cause Deleted: ¶ loss of inventory that could not be mitigated in sufficient time to achieve the nuclear safety The methodology in NEI 00-01 for post-performance criteria should be considered as part of the plant's nuclear safety analysis, and need fire safe shutdown analyses may require additional clarification if the not be evaluated in the same stringent manner as high-low pressure interfacing systems are corresponding information in NFPA 805 analyzed in NEI 00-01. is not in strict alignment (e.g., definition of high low pressure interfaces in NFPA 805, 2001 edition, Section 1.6.31, and If the existing licensing basis is vague or silent on the methodologies identified, then a licensing NEI 00-01, Revision 1, Appendix C).

For the purposes of the methodology basis should be clearly defined during the transition period. For example, if the existing review, the methodology in NEI 00-01 licensing basis is vague or silent on the methodology for circuit analysis (selection and/or should be used as the basis for acceptability.¶

protection of circuits) or evaluation of the failures of circuits within a fire area (single failure, any and all, one-at-a-time, sequential/concurrent, cumulative effects) a licensing basis should be established against which changes can be assessed post transition.

Basis:

A consistent definition moving forward will avoid future confusion and interpretation by licensees, NRC inspectors, and NRR staff.

The interpretation of high-low pressure interface components is provided in NEI 00-01, Appendix C:

Based on the above guidance, the following criterion is established to determine if a RCPB valve is considered a high/low pressure interface valve component: A valve whose spurious opening could result in a loss of RPV/RCS inventory and, due to the lower pressure rating or other breaches such as relief valve operations on the downstream piping, an interfacing LOCA (i.e., pipe rupture in the low pressure piping).

The NRC has endorsed the methodology for safe shutdown analysis in NEI 00-01 on several occasions, most notably:

NRC Regulatory Issue Summary (RIS) 2005-30, Clarification of Post-Fire Safe-Shutdown Circuit Regulatory Requirements, dated December 20, 2005 (ADAMS Accession No.

ML053360069) pages 1 and 2, states:

This RIS also gives the NRC staffs views on the use of NEI guidance document NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1 (ML050310295), in complying with Appendix R. The deterministic methodology presented in NEI 00-01, when applied in accordance with the regulatory expectations described in this RIS, is one acceptable approach to the analysis of post-fire, safe-shutdown circuits.

In addition, the Draft Generic Letter 2006-XX, NRC Generic Letter 2006-XX: Post-Fire Safe-Shutdown Circuit Analysis Spurious Actuations (May 2006, ADAMS Accession No.

ML061280517), page 7, states:

The deterministic methodology in NEI 00-01, Rev. 1 (January 2005), Guidance for Post-Fire Safe Shutdown Circuit Analysis, Chapter 3 (including the associated appendices), for analysis of post-fire safe-shutdown circuits, in conjunction with the guidance provided in this GL, is one acceptable approach to achieving regulatory compliance with post-fire safe-shutdown circuit protection requirements for multiple spurious actuations. Licensees should assume that the fire may affect all unprotected cables and equipment within the fire area simultaneously and address all cable and equipment impacts affecting the required safe-shutdown path in the fire area. All potential impacts within the fire area should be addressed.

Section B-2.1 of NEI 04-02 also states:

The NRC staff has reviewed Revision 1 of NEI 00-01 and concluded that Chapter 3 provides an acceptable way to select circuits, and Chapter 4 provides an acceptable way to determine risk- significance of circuit findings.

NEI 04-02 has been formally endorsed, with exceptions noted by Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, May 2006 (ADAMS Accession No. ML0601100174). Besides endorsement of NEI 04-02, the following statement is also provided in Section 3.3 of Regulatory Guide 1.205:

Industry guidance document NEI 00-01, Revision 1, Guidance for Post-Fire Safe Shutdown Circuit Analysis, used in conjunction with NFPA 805 and this regulatory guide, provides one acceptable approach to circuit analysis for a plant that has transitioned to a 10 CFR 50.48(c) licensing basis.

FAQ Number 06-0012 Rev 1 Plant: Harris Nuclear Plant Submittal Date: 10/26/06 Submitter

Contact:

Elizabeth Kleinsorg Phone 704.651.5548 Submitter Email: Insert email Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG

Subject:

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:

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

Deleted: faq template.doc Page 1 of 6 faq 06-0012 - manual actions - rev 1a.doc

FAQ Number 06-0012 Rev 1 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:

Revise Section B.2.2.4, Recovery Actions to clarify the following:

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. Deleted: faq template.doc Page 2 of 6 faq 06-0012 - manual actions - rev 1a.doc

FAQ Number 06-0012 Rev 1 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.

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 attachment.

Deleted: faq template.doc Page 3 of 6 faq 06-0012 - manual actions - rev 1a.doc

Attachment to FAQ 06-0012 Revision 0 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 information for operator manual actions that should be included in the summary for the fire area is: 1) whether the operator manual actions are currently allowed or were previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR), and 2) reference to documentation that demonstrates prior review and approval by the NRC. Operator manual actions that are currently allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation) can be transitioned without the need to use the change evaluation process. In some cases the previous approval may not be obvious, yet should be allowed.

Examples include: Deleted: are Deleted: <#>The operator manual Operation of fire affected equipment for fire areas that meet the separation action is currently credited in the requirements of Section III.G.1of 10 CFR Part 50, Appendix R (or applicable sections Alternate Shutdown Procedure. Although this manual action was NOT specifically of NUREG-0800). See Figure B-4 mentioned in the SER, the licensee submittal specifically discussed the Operation of fire affected equipment for fire areas that meet the protection operator action. This can be considered requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of previously approved¶

<#>The operator manual action is NUREG-0800) for redundant trains. See Figure B-5. currently credited in Non-Alternate Shutdown Procedure. The manual action Manual operation of normally operated manual switches and valves (valves de- was specifically discussed as acceptable energized during normal operation can be considered manual valves) where in the SER however the NRC did not grant an exemption/deviation. This can separation/protection is provided for redundant safe-shutdown trains in accordance be considered previously approved.¶ with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of <#>Operation of equipment for which cables and equipment for the redundant NUREG-0800). safe shutdown train are located in separate fire areas thus meeting Section Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, III.G.1of Appendix R to 10 CFR Part 50,¶

<#>Manual operation of normally Appendix R (or applicable sections of NUREG-0800). operated manual switches and valves where III.G.1 separation is provided for Operator manual actions to address spurious actuations in the credited safe shutdown redundant safe-shutdown trains¶ success path are allowed, as long as the spurious actuation does not disable the Formatted: Bullets and Numbering credited function during the time it takes to perform the operator manual action action.

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 Section III.G.2 of 10 CFR 50, Appendix R, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves manual actions, should verify that the basis for acceptability in the SER is still valid. If the basis for acceptability is still valid, then no change evaluation is required.

Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of Section III.G.2 of 10 CFR 50, Appendix R, a staff decision in an SER that approves the use of manual operator actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

Attachment Page 4 of 6

Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Repairs or operator manual actions credited either for transitioning to or maintaining cold Deleted: for shutdown equipment will also be transitioned on a fire area basis and do not require a change evaluation. Information that should be summarized includes reference to documentation that demonstrates the equipment necessary for the repair/action is staged, the repair/action is proceduralized, and the repair/action is achievable in the necessary timeframe.

Operator manual actions are not allowed or have not been previously reviewed and Deleted: Operator manual actions that have been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation approved by the NRC (as documented in process outlined in Chapter 5.3 of this guidance. The following methodology should be an approved SER) can be transitioned without the need to use the change used to optimize this process: 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 Attachment Page 5 of 6

Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Figure B-4 Acceptable Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria 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 a manual operator action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-1.

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

Brandon, Attached are the Staff's comments on FAQ 06-0007 for the conference call.

Paul

>>> "JAMAR, Brandon" <btj@nei.org> 10/26/2006 8:21 AM >>>

I have the revision, but waiting on confirmation from the group that's it's ready to submit. Should have it to you in the next few hours. Sorry about the delay.

Original Message-----

From: Paul Lain [1]

Sent: Thursday, October 26, 2006 8:18 AM To: JAMAR, Brandon

Subject:

Re: FAQs 06-0002/3/6/12 Any progress on FAQ 06-0005-Revision 1?

>>> "JAMAR, Brandon" <btj@nei.org> 10/24/2006 2:59 PM >>>

Paul/Sunil, I've attached the subject FAQs for submittal for Thursday's meeting. I plan on sending revision to FAQ 06-0005 by COB tomorrow.

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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October 26, 2006 Staff Comments to FAQ 06-0007

Background:

From NFPA 805 (2001 Edition):

3.4 Industrial Fire Brigade 3.4.1 On-Site Fire-Fighting Capability. All of the following requirements shall apply.

(a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting)

(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Programs (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department Physicians FAQ Questions:

Based on section 3.4 of NFPA-805, is it correct to interpret that;

1. NFPA-600 would apply only to plants with a traditional fire brigade made up of employees from one or more plant departments?

2. NFPA-1500 and 1582 would apply only to those plants which utilize a fire department organization?

Staff Comments:

NFPA divides fire brigades into two types, based on organization and duties: AIndustrial Fire Brigades@ and AIndustrial Fire Departments.@ Practically, this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)

Basis:

From NFPA 600 (2000 Edition):

1-1.1 This standard contains minimum requirements for organizing, operating, training, and equipping industrial fire brigades. It also contains minimum requirements for the occupational safety and health of industrial fire brigade members while performing fire fighting and related activities.

1

October 26, 2006 Staff Comments to FAQ 06-0007 1-1.2* This standard shall apply to any organized, private, industrial group of employees having fire fighting response duties, such as emergency brigades, emergency response teams, fire teams, and plant emergency organizations.

A-1-1.2 This standard is intended to meet or exceed the industrial fire brigadeBrelated requirements of OSHA, 29 CFR 1910, Chapter XVII, Subpart L, AFire Protection.@ Further, this standard is intended to ensure the industrial fire brigade member with an appropriate degree of occupational safety and health while performing industrial fire brigade response duties just as NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, ensures an appropriate degree of occupational safety and health for the municipal fire department member. Y From NFPA 1500 (1997 Edition):

1-1.3 This standard does not apply to industrial fire brigades or industrial fire departments meeting the requirements of NFPA 600, Standard on Industrial Fire Brigades Industrial fire brigades or fire departments shall also be permitted to be known as emergency brigades, emergency response teams, fire teams, plant emergency organizations, or mine emergency response teams.

A-1-5 Industrial Fire Department. The vast majority of industrial fire brigades are not industrial fire departments. Industrial fire departments are those few brigades that resemble and function as municipal fire departments. These are generally found only at large industrial facilities and at industrial facilities that also perform municipal fire fighting, usually where the plant is located far from municipalities with organized fire departments. Industrial fire departments are organized and equipped for interior structural fire fighting similar to municipal fire departments. Their apparatus is similar to that used by municipal fire departments.

Industrial fire brigades that provide rescue services are industrial fire departments. Industrial facilities can have separate organizations, covered by separate organizational statements, operating as industrial fire brigades and operating as rescue teams providing rescue not related to fire incidents. Membership in these two organizations can overlap.

From NFPA 1582 (2000 Edition):

1-1.3 This standard shall not apply to industrial fire brigades that also can be known as emergency brigades, emergency response teams, fire teams, plant emergency organizations, or mine emergency response teams.

2

October 26, 2006 Staff Comments to FAQ 06-0007 FAQ Question:

3. Reference in section 3.4.1(a)(1), to A(interior structural fire fighting)@ limits the applicable sections of NFPA-600 (2000 edition) to Chapters 2 and 5, (excluding incipient stage fire fighting, and advanced exterior fire fighting, Chapters 3, 4, 6)?

Staff Comment:

NFPA 805 Section 3.4.1(a) states AA fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site.@ For interior fire fighting, at a minimum, the licensee shall meet the requirements noted in NFPA 600, Chapters 5, Industrial Fire Brigades That Perform Interior Structural Fire Fighting Only. For exterior fires that could jeopardize the ability to meet the performance criteria described in NFPA 805, Section 1.5, the licensee shall be able to demonstrate their ability to control and extinguish those fires.

Request:

The Staff requests NEI to revise FAQ 06-0007, documenting the actual concerns regarding this FAQ and the proposed resolution or clarification for NEI 04-02.

3

Per your request: FAQ 06-0012 Rev. 1a in MS word format attached.

Please let me know if this does not work for you and I can mail you a hard copy, or fax.

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 Number 06-0012 Rev 1 Plant: Harris Nuclear Submittal 10/26/06 Plant Date:

Submitter Elizabeth Phone 704.651.5548

Contact:

Kleinsorg

Submitter Insert email Email:

Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG

Subject:

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:

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 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 Page 1 of 7 attachment1 for 10-26-06 16.04 email.doc

FAQ Number 06-0012 Rev 1 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 These documents provide additional clarification with respect to the acceptability of existing 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:

Revise Section B.2.2.4, Recovery Actions to clarify the following:

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 Page 2 of 7 attachment1 for 10-26-06 16.04 email.doc

FAQ Number 06-0012 Rev 1 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.

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 Page 3 of 7 attachment1 for 10-26-06 16.04 email.doc

FAQ Number 06-0012 Rev 1 Revision:

Revise NEI 04-02 as shown in attachment.

Page 4 of 7 attachment1 for 10-26-06 16.04 email.doc

Attachment to FAQ 06-0012 Revision 0 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 information for operator manual actions that should be included in the summary for the fire area is: 1) whether the operator manual actions are currently allowed or were previously reviewed and approved by the NRCs Office of Nuclear Reactor Regulation (NRR), and 2) reference to documentation that demonstrates prior review and approval by the NRC. Operator manual actions that are currently allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation) can be transitioned without the need to use the change evaluation process. In some cases the previous approval may not be obvious, yet should be allowed.

Examples include: Deleted: are Deleted: <#>The operator manual Operation of fire affected equipment for fire areas that meet the separation action is currently credited in the requirements of Section III.G.1of 10 CFR Part 50, Appendix R (or applicable sections Alternate Shutdown Procedure. Although this manual action was NOT specifically of NUREG-0800). See Figure B-4 mentioned in the SER, the licensee submittal specifically discussed the Operation of fire affected equipment for fire areas that meet the protection operator action. This can be considered requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of previously approved¶

<#>The operator manual action is NUREG-0800) for redundant trains. See Figure B-5. currently credited in Non-Alternate Shutdown Procedure. The manual action Manual operation of normally operated manual switches and valves (valves de- was specifically discussed as acceptable energized during normal operation can be considered manual valves) where in the SER however the NRC did not grant an exemption/deviation. This can separation/protection is provided for redundant safe-shutdown trains in accordance be considered previously approved.¶ with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of <#>Operation of equipment for which cables and equipment for the redundant NUREG-0800). safe shutdown train are located in separate fire areas thus meeting Section Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, III.G.1of Appendix R to 10 CFR Part 50,¶

<#>Manual operation of normally Appendix R (or applicable sections of NUREG-0800). operated manual switches and valves where III.G.1 separation is provided for Operator manual actions to address spurious actuations in the credited safe shutdown redundant safe-shutdown trains¶ success path are allowed, as long as the spurious actuation does not disable the Formatted: Bullets and Numbering credited function during the time it takes to perform the operator manual action action.

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 Section III.G.2 of 10 CFR 50, Appendix R, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approves manual actions, should verify that the basis for acceptability in the SER is still valid. If the basis for acceptability is still valid, then no change evaluation is required.

Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of Section III.G.2 of 10 CFR 50, Appendix R, a staff decision in an SER that approves the use of manual operator actions does not require an exemption under 10 CFR 50.12. No change evaluation is required.

Attachment Page 5 of 7

Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Repairs or operator manual actions credited either for transitioning to or maintaining cold Deleted: for shutdown equipment will also be transitioned on a fire area basis and do not require a change evaluation. Information that should be summarized includes reference to documentation that demonstrates the equipment necessary for the repair/action is staged, the repair/action is proceduralized, and the repair/action is achievable in the necessary timeframe.

Operator manual actions are not allowed or have not been previously reviewed and Deleted: Operator manual actions that have been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation approved by the NRC (as documented in process outlined in Chapter 5.3 of this guidance. The following methodology should be an approved SER) can be transitioned without the need to use the change used to optimize this process: 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 Attachment Page 6 of 7

Attachment to FAQ 06-0012 Revision 0 Excerpt from NEI 04-02 Revision 1 with changes tracked Figure B-4 Acceptable Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria 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 a manual operator action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-1.

Figure B-5 Acceptable Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Manual Action for Fire Affected Train Attachment Page 7 of 7

Per your request: FAQ 06-0008 in MS Word attached.

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 06-008 - Alternate Method for Engineering Evaluations - MS WORD Creation Date 10/26/2006 2:55:15 PM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 PWL (Paul Lain) nrc.gov TWGWPO03.HQGWDO01 RFR1 (Robert Radlinski) nrc.gov TWGWPO04.HQGWDO01 SDW1 CC (Sunil Weerakkody)

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Figure 1 FAQ TEMPLATE FAQ Number:_06-0008 Plant: _____NEI___________________ Submittal Date: ____9/20/06_____

Submitter

Contact:

Brandon Jamar____ Tel/email: (202) 739-8043 / btj@nei.org Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG

Subject:

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):

Various sections (to be completed following initial FAQ review and feedback.

Circumstances requiring guidance interpretation or new guidance:

NFPA 805 Chapter 3, Fundamental Fire Protection Program and Design Elements, does not provide much flexibility for interpretation and engineering judgment on a number of fire protection systems/features. The use of engineering evaluations is not specifically allowed in NFPA 805, Chapter 3, in many instances, to allow judgment of acceptability.

Additionally, there is overlap between NFPA 805 Chapters 3 and 4 regarding which requirements are in effect and potential confusion with respect to the need for NRC approval of risk-informed, performance-based evaluations.

Refer to FAQ 06-004 for more detail and clarification on the relationship between NFPA 805 Chapters 3 and 4.

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

1

Engineering evaluations (e.g., Generic Letter 86-10 evaluations) have been an integral part of fire protection programs for over 20 years. The transition of existing engineering equivalency evaluations under the deterministic approach is part of the foundation of the safe today, safe tomorrow concept (See Figure 2.2, Section 2.2.7, and A2.2.7 of NFPA 805). The inability of licensees to be able to perform engineering evaluations without submitting an LAR for prior approval could pose a significant burden post transition for items that have low risk significance.

Potentially relevant existing FAQ numbers:

Refer to FAQ 06-004 for more detail and clarification on the relationship between NFPA 805 Chapters 3 and 4.

FAQ 06-011 provides clarification on the transition of alternative shutdown fire areas deterministically. FAQ 06-008 states that engineering evaluations assessing the adequacy of separation and protection of the area, room, or zone under consideration for fire areas previously considered alternative shutdown under 10 CFR 50, Appendix R Section III.G.3 would not need prior approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

Refer to attached report, NFPA 805 - Engineering Evaluations - Transition and Alternative Methods, for background and supporting information related to this FAQ.

The purpose of the attached report is to provide:

An alternative approach to allow performance-based engineering evaluations to be performed post-transition for fire protection features and elements addressed in NFPA 805, Chapter 3. This process should be requested as part of the transition License Amendment Request to meet the requirements outlined in 10 CFR 50.48(c)(vii) and 10 CFR 50.48(c)(4). This approach is discussed in Section 4 of the report.

A clarification to allow transition of adequate existing engineering evaluations that address fire protection features and elements addressed in NFPA 805, Chapter 3. The approach would allow engineering evaluations that have been made in accordance with an appropriate application of the guidelines of Generic Letter 86-10, and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition (Fire Protection Program Regulatory Reviews), to be acceptable for transition to the new fire protection licensing basis without the need for a change evaluation or NRC review and approval. This approach is discussed in Section 5 of the report.

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

2

Various sections will be updated to reflect the content of this FAQ (to be completed following initial FAQ review and approval of the concept from the NRC). It is anticipated that the main text of the attached report and Appendix C would become a new Appendix to NEI 04-02.

3

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods Table of Contents 1.0 Issue .................................................................................................................... 2 2.0 Purpose ............................................................................................................... 2 3.0 Background......................................................................................................... 3 4.0 Post Transition Engineering Evaluations......................................................... 3 4.1 ALTERNATIVE APPROACH - APPROVAL PROCESS ............................................................................ 3 4.1.1 Scope of Engineering Evaluations under Alternative Approach ......................................... 4 4.1.2 Engineering Evaluations Not Requiring Alternative Methodology ...................................... 5 4.2 GUIDANCE FOR PERFORMING ENGINEERING EQUIVALENCY EVALUATIONS ........................................ 5 5.0 Existing Engineering Evaluations..................................................................... 6 5.1 TRANSITION OF EXISTING ENGINEERING EVALUATIONS - APPROVAL PROCESS ................................. 6 5.2 GUIDANCE FOR TRANSITION OF EXISTING ENGINEERING EQUIVALENCY EVALUATIONS ....................... 7 5.2.1 NEI 02-03 Guidance............................................................................................................ 7 5.2.2 Engineering Equivalency Evaluations - Adequacy Determination ..................................... 7 Appendices Appendix A - Industry Document Excerpts Appendix B - Types of Engineering Evaluations/References Appendix C - Guidance for Performing Engineering Evaluations 1

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods 1.0 Issue NFPA 805 Chapter 3, Fundamental Fire Protection Program and Design Elements, does not provide much flexibility for interpretation and engineering judgment on a number of fire protection systems/features. The use of engineering evaluations is not specifically allowed in NFPA 805, Chapter 3, in many instances, to allow judgment of acceptability.

Additionally, there is overlap between NFPA 805 Chapters 3 and 4 regarding which requirements are in effect and potential confusion with respect to the need for NRC approval of risk-informed, performance-based evaluations. Refer to FAQ 06-004 for more detail and clarification on the relationship between NFPA 805 Chapters 3 and 4.

Engineering evaluations (e.g., Generic Letter 86-10 evaluations) have been an integral part of fire protection programs for over 20 years. The transition of existing engineering evaluations under the deterministic approach is part of the foundation of the safe today, safe tomorrow concept (See Figure 2.2, Section 2.2.7, and A2.2.7 of NFPA 805). The inability of licensees to be able to perform engineering evaluations without submitting an LAR for prior approval could pose a significant burden post transition for items that have low risk significance.

The process outlined below will be utilized as a guide for new post-transition engineering evaluations and during the review of existing engineering evaluations (e.g., Generic Letter 86-10 evaluations) during the transition process.

2.0 Purpose The purpose of this document is to provide:

An alternative approach to allow performance-based engineering evaluations to be performed post-transition for fire protection features and elements addressed in NFPA 805, Chapter 3.

This process should be requested as part of the transition License Amendment Request to meet the requirements outlined in 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4). This approach is discussed in Section 4.

A clarification to allow transition of existing engineering evaluations that address fire protection features and elements addressed in NFPA 805, Chapter 3. The approach would allow engineering evaluations that have been made in accordance with an appropriate application of the current deterministic guidelines (e.g., Generic Letter 86-10), and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition (Fire Protection Program Regulatory Reviews), to be transitioned to the new fire protection licensing basis without the need for a change evaluation or NRC review and approval. This approach is discussed in Section 5.

Two primary options appear to be appropriate for this process to be approved and utilized consistently by plants transitioning to a new fire protection licensing basis. These options are:

Approval of the process in this FAQ. This will result in a future revision to NEI 04-02 (along with the other FAQs), with future endorsement by the NRC in a revision to Regulatory Guide 1.205. Individual plants would refer to the standard process described in NEI 04-02 and Regulatory Guide 1.205 in their plant-specific LAR.

Approval of this process via a Topical Report and subsequent Safety Evaluation Report.

Individual plants would refer to the standard process described in Topical Report in their 2

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods plant-specific LAR. Use of Topical Reports to support the License Amendment process is discussed in Section 2.4 of NEI 04-02, Revision 1.

3.0 Background The following documents provide discussion on engineering evaluations with respect to NFPA 805 transition:

NFPA 805 (2001), Section 2.2.7 and its explanatory material allow the use of existing engineering evaluations to transition as part of the deterministic approach for meeting NFPA 805 Chapter 4 criteria. This concept is also depicted in Figure 2.2 of NFPA 805. The transition of existing engineering evaluations under the deterministic approach is part of the foundation of the safe today, safe tomorrow concept.

10 CFR 50.48(c)(2)(vii) allows the use of performance-based methods for NFPA 805 Chapter 3, Fundamental Fire Protection Program and Design Elements via the license amendment process. In addition, 10 CFR 50.48(c)(4) provides a mechanism for risk-informed or performance-based alternatives to compliance with NFPA 805 via the license amendment process.

NEI 04-02 Revision 1, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, provides guidance on the transition of engineering evaluations that have been made in accordance with the correct application of the current deterministic guidelines (e.g., Generic Letter 86-10), and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition. NEI 04-02 Revision 1, Section 4.3.2, Nuclear Safety Performance Criteria Transition Review, provides similar guidance on the transition of engineering evaluations.

Section 5.3.2 of NEI 04-02, Revision 1, Defining the Change, provides guidance on how changes to NFPA 805 Chapter 3 items may be addressed. However, even with the guidance in NEI 04-02 Revision 1, there is still potential confusion over what types of engineering evaluations would require approval via the license amendment process.

Regulatory Guide 1.205 Section 3.2 re-iterates the requirements and guidance in NFPA 805, 10 CFR 50.48(c), and NEI 04-02 regarding existing engineering evaluations. In addition, Regulatory Guide 1.205 provides guidance on acceptable existing engineering evaluations with reference to NUREG-0800 Section 9.5.1 and Regulatory Guide 1.189. Regulatory Guide 1.205 Section 3.2.2 also re-iterates the 10 CFR 50.48(c) process for use of the license amendment process for deviations from NFPA 805 Chapter 3 and alternative change evaluation methodologies.

Refer to Appendix A for the details contained in the referenced documents.

4.0 Post Transition Engineering Evaluations 4.1 Alternative Approach - Approval Process As part of the License Amendment Request process, permission to use methods previously allowed by the current deterministic guidance (e.g., Generic Letter 86-10 and reiterated in Regulatory Guide 1.189) should be requested. The license amendment request should request permission to use performance-based processes, in accordance with Section 2.4 of NFPA 805, to address post-transition changes to Fundamental Fire Protection Program and Design Elements in accordance with 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

3

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods In cases where the specific requirements of NFPA 805 Chapter 3 are not met for a required system/feature, an engineering technical evaluation may be performed to determine if the condition is acceptable. Technical evaluations may be performance-based and/or deterministic evaluations.

Post-transition engineering evaluations to address cases where the specific requirements of NFPA 805, Chapter 3 are not met shall be evaluated using the Fire Protection change process. In accordance with Section 2.4.4 of NFPA 805, the change evaluation shall be performed to ensure that a change to a previously approved fire protection program element is acceptable. The change evaluation process shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins.

In accordance with 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4), this alternative process is intended to:

(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

4.1.1 Scope of Engineering Evaluations under Alternative Approach Examples of engineering evaluations related to NFPA 805 Chapter 3 that are proposed under this alternative methodology include the program and design elements discussed below. However, the proposed evaluation scope is not limited to the following items, which are those that typically require engineering evaluation for technical adequacy. Other fire protection program and design elements in NFPA 805 Chapter 3 are also proposed to be included under the alternative approach. In order to ensure the acceptability of any proposed evaluations, engineering evaluations that address cases where the specific requirements of NFPA 805, Chapter 3 are not met shall be evaluated using the Fire Protection change process, which shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins.

Passive Fire Protection Features [NFPA 805 Section 3.11] - Engineering evaluations will assess passive fire features for their adequacy in performing their intended function during and following a fire. This includes:

Building Separation [NFPA 805 Section 3.11.1]

Fire Barriers (walls, ceilings, floors) [NFPA 805 Section 3.11.2]

Through Penetration Fire Stops [NFPA 805 Section 3.11.4]

Electrical Raceway Fire Barrier Systems [NFPA 805, Section 3.11.5]

Note: Section 3.11.3 of NFPA 805 has an exception that allows performance-based analysis where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries.

NFPA Code Deviations - Engineering evaluations will be allowed to demonstrate that NFPA code deviations do not adversely affect fire protection system and feature performance during and following a fire. Typical NFPA code deviation evaluations that can be performed include:

4

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods Water Supply (NFPA 20, 22, 24) [NFPA 805 Section 3.5]

Standpipe and Hose Stations (NFPA 14) [NFPA 805 Section 3.6]

Portable Extinguishers (NFPA 10) [NFPA 805 Section 3.7]

Fire Alarm and Detection Systems (NFPA 72) [NFPA 805 Section 3.8]

Automatic and Manual Water-Based Fire Suppression Systems (NFPA 13, 15, 750, 16)

[NFPA 805 Section 3.9]

Gaseous Fire Suppression Systems (NFPA 12, 12A, 2001) [NFPA 805 Section 3.10]

Engineering evaluations may also be performed to address NFPA code for other codes referenced in NFPA 805 Chapter 3.

4.1.2 Engineering Evaluations Not Requiring Alternative Methodology The following types of engineering evaluations should not require use of alternative methodology under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4), since there are not specific provisions in NFPA 805 Chapter 3 for these items.

Suppression and Detection System Coverage Evaluations - Coverage of detection and suppression systems is specified in the deterministic approach of NFPA 805 section 4.2.3. If coverage is specified in an NFPA code, then the alternative methodology could be applied as described above. If coverage is not specified, then engineering evaluations could be performed using the standard approaches for evaluations without the need for prior approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

Intervening Combustibles between Redundant Trains in the Same Fire Area - Lack of intervening combustibles or fire hazards is specified in the deterministic approach of NFPA 805 section 4.2.3. There is no specific NFPA 805 Chapter 3 correlation to this protection scheme.

Engineering evaluations could be performed using the standard approaches for evaluations without the need for prior approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

Alternative Shutdown Fire Area, Room, or Zone Under Consideration - Evaluations may exist that assess the adequacy of separation and protection of the area, room, or zone under consideration for fire areas previously considered alternative shutdown under 10 CFR 50, Appendix R Section III.G.3. These evaluations may transition deterministically in accordance with guidance in NEI 04-02 Appendix B.2 as part of the basis for acceptability (e.g.,

detection/suppression or fire barriers related to the area, room, or zone under consideration).

These evaluations would typically not be in conflict with any NFPA 805 Chapter 3 requirements, and therefore, would not need prior approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

Fire Barrier Penetrations - Section 3.11.3 of NFPA 805 has an exception that allows performance-based analysis where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries. Therefore, these evaluations would not need prior approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

4.2 Guidance for Performing Engineering Equivalency Evaluations Guidance for preparation and development of engineering evaluations under the alternative approach is provided in Appendix C of this document. This guidance is based upon Appendix A 5

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods to NEI 02-03, Guidance for Performing a Regulatory Review of Proposed Changes to the Approved Fire Protection Program (June 2003). The purpose of Appendix A to NEI 02-03 is to provide guidance for the preparation and development of engineering evaluations to determine if changes resulting in a deviation(s) from applicable regulatory requirements, guidance documents, or the fire protection licensing basis are acceptable. The guidance may also be utilized to evaluate deviations from applicable NFPA codes. The guidance is consistent with the information contained in Generic Letter 86-10.

Although NEI 02-03 was developed for use under a traditional fire protection licensing basis, most of the guidance for performing engineering evaluations is directly applicable to a licensee that has transitioned to a new NFPA 805 licensing basis.

A proposed change to Appendix A to NEI 02-03 is included in Appendix C of this document.

The proposed change to NEI 02-03 is as follows:

Acceptance criteria and processes have been modified to be consistent with NFPA 805 and its guidance documents Interface with the risk-informed, performance-based change evaluation process was added.

References to engineering evaluations for addressing operator manual actions (recovery actions) were removed. This is an industry issue addressed by other processes.

References to engineering evaluations related to fire protection program or administrative control requirements were removed, since these topics are addressed by other processes.

5.0 Existing Engineering Evaluations 5.1 Transition of Existing Engineering Evaluations - Approval Process As part of the license amendment process, it is proposed that engineering evaluations that have been made in accordance with an appropriate application of the current deterministic guidelines (e.g., Generic Letter 86-10), and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition (Fire Protection Program Regulatory Reviews), be considered acceptable for transition to the new fire protection licensing basis. These engineering evaluations would not be considered a change for the purposes of a transition change evaluation. These evaluations may be associated with fire protection systems and features addressed in NFPA 805, Chapter 3.

Acceptable uses of engineering evaluations that can be transitioned to a new licensing basis, without prior approval and without the need for a transition change evaluation include, but are not limited to:

Fire Area Boundary Evaluations NFPA Code Deviations Suppression and Detection System Coverage Evaluations Electrical Raceway Fire Barrier System Evaluations Intervening Combustibles between Redundant Trains in the Same Fire Area Alternative Shutdown Fire Area, Room, or Zone Under Consideration Refer to the table in Appendix B for a listing of engineering evaluations addressed by Generic Letter 86-10, RG 1.189, with cross references to applicable NFPA 805 sections.

6

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods Transition of the engineering evaluations as part of the current licensing basis is not allowed under the following conditions:

Engineering evaluations based solely on quantitative risk evaluations (PRA based calculations with decisions based solely on impact of an item/issue on core damage frequency, without consideration for fire protection regulatory requirements, licensing basis, defense-in-depth, and safety margins) do not meet the threshold for self approval and must be submitted as part of license amendment request process.

Engineering evaluations that are judged to be of unacceptable quality.

Inappropriate use of the engineering evaluation process (e.g., for a pre-1979 plant, judging that 15 feet of separation between redundant trains with suppression and detection meets 10 CFR 50, Appendix R, Section III.G.2.b would not be an appropriate use of an engineering evaluation).

5.2 Guidance for Transition of Existing Engineering Equivalency Evaluations NEI 04-02 and Regulatory Guide 1.205 discuss the process for determination of acceptability of engineering evaluations. Specific details are not provided on how to make this determination.

5.2.1 NEI 02-03 Guidance NEI 02-03, Appendix A, provides guidance for the preparation and development of engineering evaluations to determine if changes result in a deviation from applicable regulatory requirements, guidance documents, or the fire protection licensing basis are acceptable. The guidance may also be utilized to evaluate deviations from applicable NFPA codes. The guidance in NEI 02-03 is consistent with the information contained in Generic Letter 86-10. The evaluation criteria and considerations in Appendix A to NEI 02-03 should be utilized in the decision-making process regarding the adequacy of engineering evaluations for transition. These criteria and considerations should also be utilized in upgrading engineering evaluations or performing additional engineering evaluations prior to transition.

5.2.2 Engineering Equivalency Evaluations - Adequacy Determination The following process should be used to determine if an existing engineering equivalency is adequate to transition:

Engineering evaluation should not be based solely on quantitative risk evaluations.

The engineering evaluation should be an appropriate use of the engineering evaluation process (e.g., for a pre-1979 plant, judging that 15 feet of separation between redundant trains with suppression and detection meets 10 CFR 50, Appendix R, Section III.G.2.b would not be an appropriate use of an engineering evaluation).

Evaluation has been evaluated against the criteria in the pre-transition standard fire protection license condition, 10 CFR 50.59, or plant specific process used to determine the impact of the change/condition on the ability to achieve and maintain post-fire safe shutdown.

Based upon the judgment of the reviewer, the evaluation contains an appropriate level of rigor and bases. Basic attributes include:

o Assumptions, methods, results are clearly stated and valid (refer to discussion of NEI 02-03).

7

Attachment to FAQ 06-0008 - NFPA 805 - Engineering Evaluations -

Transition and Alternative Methods o Evaluations reflect the current plant configuration or are clearly bounded to reflect changing plant conditions.

The results of the engineering evaluations will require judgment. The results of the transition evaluation should be formally documented as part of the transition report. This documentation should consist of a listing of each evaluation (document reference, revision no., related fire areas, etc.) and the results of the adequacy review. Existing engineering evaluations that are deemed to be necessary to support transition to the new licensing basis but are determined to be inadequate can be:

Updated to an acceptable level before transition and transitioned over to the new licensing basis, or, Evaluated during the transition process as part of the change evaluation process. (Note:

Depending upon the significance of the adequacy determination, the item under consideration may need to be addressed via the corrective action process and/or may require compensatory measures.)

8

Attachment to FAQ 06-0008 Appendix A - Industry Document Excerpts A.1 NFPA 805 Section 2.2.7, Existing Engineering Equivalency Evaluations NFPA 805 (2001), Section 2.2.7 states:

2.2.7* Existing Engineering Equivalency Evaluations. When applying a deterministic approach, the user shall be permitted to demonstrate compliance with specific deterministic fire protection design requirements in Chapter 4 for existing configurations with an engineering equivalency evaluation. These existing engineering evaluations shall clearly demonstrate an equivalent level of fire protection compared to the deterministic requirements.

The explanatory material in Appendix A to NFPA 805 provides the following additional information:

A.2.2.7 Refer to existing engineering equivalency evaluations (previously known as Generic Letter 86-10 evaluations, exemptions, deviations) performed for fire protection design variances such as fire protection system designs and fire barrier component deviations from the specific fire protection deterministic requirements.

Once NFPA 805 is adopted for a facility, future equivalency evaluations (previously known as Generic Letter 86-10 evaluations) are to be conducted using a performance-based approach. The evaluation should demonstrate that the specific plant configuration meets the performance criteria in the associated with the same fire scenario.

A.2 NEI 04-02 Revision 1 Approach NEI 04-02 Revision 1, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, provides guidance on the transition of engineering evaluations that have been made in accordance with the correct application of the guidelines of Generic Letter 86-10, and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition:

It is important that the previously approved alternatives be clearly determined in order to understand the level of review and potential upgrades necessary to meet the requirements in Chapter 3 of NFPA 805. Fire protection program features and systems, although previously reviewed and approved by the NRC, may have been changed since initial NRC approval. Such changes are part of the CLB if they have been made in accordance with the correct application of the guidelines of Generic Letter 86-10, an evaluation of plant changes under the requirements of 10 CFR 50.59, or the fire protection standard license condition (NEI 02-03). The fire protection standard license condition allows changes to the approved fire protection program without prior approval of the Commission if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Where the changes from the original NRC review and approval have been made appropriately using an approved change process, the changes are considered an acceptable part of the CLB. Licensees may rely on these changes to claim compliance but the NRC may inspect those changes and conclude that they do not comply with NFPA 805. However, they are not considered previously approved by the NRC for the purposes of superseding requirements in Chapter 3.

NEI 04-02 Revision 1, Section 4.3.2, Nuclear Safety Performance Criteria Transition Review, provides similar guidance:

Just as in the Fundamental Fire Protection Program and Design Elements review discussed in Section 4.3.1, Fire protection program features and systems, associated with a pre-transitional licensing basis, although previously reviewed and approved by the NRC, may have been changed since initial NRC approval. Such changes are part of the Licensees approved Fire Protection 9

Attachment to FAQ 06-0008 Appendix A - Industry Document Excerpts Program if they have been made in accordance with the correct application of the guidelines of Generic Letter 86-10, and evaluated under the requirements of 10 CFR 50.59, or the fire protection standard license condition (Fire Protection Program Regulatory Reviews). The fire protection standard license condition allows changes to the approved fire protection program without prior approval of the Commission if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Where the changes from the original NRC review and approval have been made appropriately using an approved change process, the changes are considered an acceptable part of the CLB. Licensees may rely on these changes to claim compliance but the NRC may inspect those changes and conclude that they do not comply with NFPA 805. However, they are not considered previously approved by the NRC for the purposes of superseding requirements in Chapter 3 and as such should be submitted to the NRC for approval as a license amendment request.

Additional discussion in Section 4.3.2 of NEI 04-02 clearly states that these evaluations performed appropriately under the CLB can be transitioned to the new licensing basis.

Appendix B.1 of NEI 04-02, Revision 1, Transition of Fundamental Fire Protection Program and Design Elements, states:

Existing Generic Letter 86-10 evaluations, which evaluate deviations from NFPA 805 Chapter 3 requirements, must be submitted to the NRC for approval as a license amendment if they do not meet the License Amendment Request threshold discussed in Section 5.3.2.

Section 5.3.2 of NEI 04-02, Revision 1, Defining the Change, provides the following:

Additional consideration should be given to changes to Fundamental Program Elements and Minimum Design Requirements. 10 CFR 50.48(c)(2)(vii) allows licensees to use performance-based methods to demonstrate compliance with NFPA 805 Chapter 3 requirements. However, these alternate methods must be approved via the license amendment process (10 CFR 50.48(c)(4)).

Most changes to the Fundamental Program Elements and Minimum Design Requirements should not require a License Amendment request, since they are evaluations that demonstrate compliance with requirements of Chapter 3 of NFPA 805. Licensees can deviate from the NFPA standards referenced in NFPA 805 Chapter 3 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 (e.g., Nothing in this standard is intended to restrict new technologies or alternate arrangements, providing the level of safety prescribed by the standard is not lowered. - Excerpt from 1985 edition of NFPA 13) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection systems). Examples of changes that would not require a License Amendment are:

o Replacing a fire rated component (e.g., penetration seal, door, wrap, etc.) with a different component/material having the same or greater fire rating. This does not require a license amendment because it meets the appropriate code.

o Changing the surveillance frequency of a fire protection feature or system based on NFPA standard as long as the underlying basis for the NFPA standard frequency is the same. This does not require a license amendment because the surveillance frequency would satisfy that specified in the current edition of NFPA codes for providing reasonable assurance that the system or component is maintained in an operable condition.

o Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of NFPA 805 and the referenced code do not dictate where a sprinkler system should be 10

Attachment to FAQ 06-0008 Appendix A - Industry Document Excerpts installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.

o Evaluating a broken/missing hanger on a fire suppression system. The acceptability of this deviation can be evaluated to show that the support of the system is still adequate with the broken/missing hanger and is therefore equivalent to a code compliant system as allowed by the code of record.

o Conversely, examples of changes that would require a License Amendment are:

o Revision of concentration of an agent to a value less than that required by the respective code or previously approved value.

o Reducing the number of fire brigade members required on-site to below five.

o Elimination of the Fire Prevention Program at the plant A.3 10 CFR 50.48(c) - Alternative Methods Requirements 10 CFR 50.48(c)(2)(vii) states:

vii) Performance-based methods. Notwithstanding the prohibition in Section 3.1 against the use of performance-based methods, the fire protection program elements and minimum design requirements of Chapter 3 may be subject to the performance-based methods permitted elsewhere in the standard. Licensees who wish to use performance-based methods for these fire protection program elements and minimum design requirements shall submit a request in the form of an application for license amendment under § 50.90. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the performance-based approach; 10 CFR 50.48(c)(4) states:

(4) Risk-informed or performance-based alternatives to compliance with NFPA 805. A licensee may submit a request to use risk-informed or performance-based alternatives to compliance with NFPA 805. The request must be in the form of an application for license amendment under § 50.90 of this chapter. The Director of the Office of Nuclear Reactor Regulation, or designee of the Director, may approve the application if the Director or designee determines that the proposed alternatives:

(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

A.4 Regulatory Guide 1.205 A.4.1 Regulatory Guide 1.205, Existing Engineering Equivalency Evaluations Section 2.3, Existing Engineering Equivalency Evaluations, of Regulatory Guide 1.205 states:

Section 2.2.7 of NFPA 805 describes the application of existing engineering equivalency evaluations (EEEEs) when using a deterministic approach during the transition to an NFPA 805 FPP. One type of EEEE, commonly referred to as a Generic Letter 86-10 (GL 86-10) evaluation, allows licensees who have adopted the standard 11

Attachment to FAQ 06-0008 Appendix A - Industry Document Excerpts fire protection license condition (under their current FPP and in accordance with GL 86-

10) to make changes to the approved FPP without prior NRC approval if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. With the exception of evaluations of certain recovery actions and any deviations from NFPA 805 requirements, a GL 86-10 evaluation showing no adverse effect on safe shutdown and permitted under the licensees current licensing basis is one acceptable means of meeting the NFPA 805 EEEE acceptance criterion of an equivalent level of fire protection compared to the deterministic requirements. However, EEEEs performed prior to transitioning to a performance-based FPP must be based on deterministic methods. If based on a risk calculation, the EEEE will have to be evaluated using the licensees approved NFPA 805 change evaluation process.

Operator manual actions credited for protection of redundant trains, in lieu of Appendix R III.G.2 protection, do not meet the deterministic requirements in Chapter 4 of NFPA 805. Consequently, unless specifically approved by the NRC, these operator manual actions should be addressed as plant changes in accordance with Section 2.4.4 of NFPA 805 using performance-based methods. The change process must include an evaluation of the risk impact associated with the operator manual action (either qualitative or quantitative), as appropriate. Quantitative risk calculations should be in accordance with Section 4.2.4.2 of NFPA 805 (a bounding calculation approach is acceptable). Recovery actions (NFPA 805 terminology for operator manual actions and repairs) that meet the required performance criteria of NFPA 805 and the criteria in this regulatory guide for making changes without prior NRC review and approval do not need to be submitted to the NRC for approval.

NEI 04-02, Section 4.1.1, Transition Process Overview, notes that the licensee will review EEEEs during the transition process to ensure the quality level and basis for acceptability are still valid. Except as noted above, satisfactory results from this review will provide adequate basis to transition EEEEs as meeting the deterministic requirements of Chapter 4 of NFPA 805. Guidance for acceptable EEEEs is provided in NUREG-0800, Section 9.5.1, Fire Protection, and in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants.

EEEEs that support deviations from the requirements and methods of NFPA 805 must be submitted for NRC approval in accordance with 10 CFR 50.48(c) and NFPA 805.

Regulatory Position 3.2.4 also provides specific guidance regarding submittal requirements. Of the EEEEs that must be approved by the NRC, those that are preexisting and those performed during the transition to an NFPA 805 licensing basis should be submitted with the fire protection license amendment request.

A.4.2 Regulatory Guide 1.205 Deviations from NFPA 805 Chapter 3 Requirements and Alternative Change Evaluation Methodologies The following guidance is provided in Regulatory Guide 1.205 (May 2006), Section 3.2.2, for the use of alternative risk-informed, performance-based processes:

10 CFR 50.48(c)(2)(vii) allows a licensee to request NRC approval (by license amendment) of the use of NFPA 805 performance-based methods in determining the licensees compliance with the fire protection program elements and minimum design 12

Attachment to FAQ 06-0008 Appendix A - Industry Document Excerpts requirements in Chapter 3 of NFPA 805. 10 CFR 50.48(c)(4) allows a licensee to request NRC approval (by license amendment) of the use of alternative risk-informed or performance-based methods (i.e., methods that differ from those prescribed by NFPA 805, to demonstrate compliance with 10 CFR 50.48(c).

Performance-based methods, including proposed alternative methods, applied to the licensees FPP, including evaluation of changes to the program, must ensure the following:

(a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.

(b) Safety margins are maintained.

(c) Fire protection defense-in-depth is maintained.

Alternative risk-informed, performance-based methods should be described in a license amendment request and must be approved by the NRC prior to incorporation in the licensees FPP. In addition to the guidance in NEI 04-02, Section 2.4, the license amendment request should include, as a minimum, the following:

(a) detailed description of the alternative risk-informed, performance-based method (b) description of how the method will be applied, the aspects of the FPP to which it will applied, and the circumstances under which it will be applied (c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when determining whether the results of an evaluation that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria (d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy for evaluation of the changes to which it will be applied (e) for PSA-based methodologies, a description of the peer review and how the review findings have been addressed The license amendment request should include complete and concise details of the proposed methodology to minimize the potential for misinterpretations. Where the alternative methods have been adequately described in the license amendment request and have been accepted by the NRC in an SER, these methods may be applied to the licensees FPP. A licensee may apply these approved methods within the limits specifically described in the licensing basis to implement plant changes that affect the FPP without prior NRC review and approval.

The types of plant changes that may be approved without prior review and approval will be limited to those for which the risk assessment methods are adequate to demonstrate that any increase in risk will be below the appropriate thresholds. In addition, subsequent changes to the approved alternative methodology must be submitted for NRC review and approval (via a license amendment request) prior to being applied to the licensees FPP.

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Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference Fire Area 3.11.1 Building Encl 1, Item 4 4.1.2.1, App. A GL 86-10, Enclosure 1 Boundaries Separation (A-2)

4. GL 86 Fire Area Boundaries 3.11.2 Fire Barriers Encl. 2, The term "fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated 3.11.3 Fire Barrier Questions 3.1.1, with the area and, as necessary, to protect important equipment within the area from a fire outside the area. In order Penetrations 3.1.2 to meet the regulation, fire area boundaries need not be completely sealed floor-to-ceiling, wall-to-wall boundaries.

However, all unsealed openings should be identified and considered the evaluating the effectiveness of the overall 3.11.4 Through barrier. Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the Penetration Fire Stops fire rating required of the boundaries, licensees must perform an evaluation to assess the adequacy of fire 3.11.4 Through boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area. This Penetration Fire Stops analysis must be performed by at least a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations for staff review and concurrence. However, if certain cable penetrations were identified as open SER items at the time Appendix R became effective,Section III.M of the rule applies (see 10 CFR 50.48(b)), and any variation from the requirements of Section III.M requires an exemption. In any event, these analyses must be retained by the licensees for subsequent NRC audits.

Structural Fire 3.11.2 Fire Barriers Encl. 2, 4.2.1 RG 1.189 Barriers Questions 3.2.2 3.11.3 Fire Barrier (implies ERFBS) 4.2.1 Structural Fire Barriers Penetrations Fire barriers are those components of construction (walls, floors, and their supports), including beams, joists, columns, penetration seals or closures, fire doors, and fire dampers that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire. Where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria.

a. The continuity of the fire barrier material is maintained;

b. The thickness of the barrier is maintained;

c. The nature of the support assembly is unchanged from the tested configuration;

d. The application or "end use" of the fire barrier is unchanged from the tested configuration;

e. The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protection.

See Regulatory Position 4.1.2 for additional guidance on the design of fire barriers relative to compartmentation and separation of equipment. 4.2.1.1 Wall, Floor, and Ceiling Assemblies. Wall, floor, and ceiling construction should be noncombustible (see Regulatory Position 4.1.1). NFPA 221, "Standard for Fire Walls and Fire Barrier Walls," can be used as guidance for construction of fire barrier walls. Materials of construction for walls, floors, and ceilings serving as fire barriers should be rated by approving laboratories in hours of resistance to fire. Building design should ensure that openings through fire barriers are properly protected. Openings through fire barriers that separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself.

The construction and installation techniques for penetrations through fire barriers should be qualified by fire endurance tests (see Regulatory Position 4.2.1.5, Testing and Qualification).

14

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference Fire Doors 3.11.3 Fire Barrier Encl. 2, 4.2.2 GL 86 Enclosure 2 Penetrations Questions 3.2.3 3.2.3 Fire Door Modifications QUESTION Where labeled and rated fire doors have been modified to incorporate security hardware or for flooding protection, is an exemption from Appendix R required?

RESPONSE Where a door is part of a fire area boundary, and the modification does not effect the fire rating (for example, installation of security "contacts"), no further analysis need be performed. If the modifications could reduce the fire rating (for example, installation a vision panel), the fire rating of the door should be reassessed to ensure that it continues to provide adequate margin considering the fire loading on both sides. Since this reassessment pertains to the establishment of a valid fire area boundary, an exemption is not required. See Section

4 of the "Interpretations of Appendix R."

ERFBS 3.11.5 Encl. 2, N/A GL 86-10 Enclosure 2 Questions 3.2.2 3.2.2 Deviations from Tested Configurations QUESTION Due to obstructions and supports, it is often impossible to achieve exact duplication of the specific tested configuration of the one-hour fire barriers which are to be placed around either conduits or cable trays. For each specific instance where exact replication of a previously tested configuration is not and cannot be achieved, is an exemption necessary in order to avoid a citation for a violation?

RESPONSE

No. Where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria:

The continuity of the fire barrier material is maintained.

The thickness of the barrier is maintained.

The nature of the support assembly is unchanged from the tested configuration.

The application or "end use" of the fire barrier is unchanged from the tested configuration. For example, the use of a cable tray barrier to protect a cable tray which differs in configuration from those that were tested would be acceptable. However, the use of structural steel fire proofing to protect a cable tray assembly may not be acceptable.

The configuration has been reviewed by a qualified fire protection engineer and found to provide an equivalent level of protection.

15

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference ERFBS 3.11.5 Encl. 2, 4.3.2 GL 86-10 Enclosure 2 Questions 3.3.4 3.3.4 Cable Tray Support Protection QUESTION Should cable tray supports be protected if there is a sprinkler system in the fire area? Under what conditions may cable tray supports be unprotected? Do unprotected supports require an exemption?

RESPONSE In general, cable tray supports should be protected, regardless of whether there is a sprinkler system.

However, they need not be protected if (1) the qualification tests were performed on wrapped cable trays with unprotected supports, and the supports are shown to be adequate, or (2) an analysis is performed, which takes into account the fire loading and automatic suppression available in the area, and which demonstrates that the unprotected support(s) will not fail and cause a loss of the cable tray fire barrier required for the postulated fire. An exemption is not required; however, the qualification tests and applicability or the structural evaluation should be documented and available for audit.

ASD Fire Area, Not specifically Encl 1, Item 6 5.6.1 GL 86-10 Enclosure 2 Room, Zone addressed

6. Alternative or Dedicated Shutdown Section III.G.3 of Appendix R provides for "alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration." While "independence" is clearly achieved where alternative shutdown equipment is outside the fire area under consideration. This is not intended to imply that alternative shutdown equipment in the same fire area but independent of the room or the zone cannot result in compliance with the regulation. The "room" concept must be justified by a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdown equipment and the alternative shutdown capability.

16

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference ASD Fire Area, Not specifically Encl 2, Question 5.6.1 GL 86-10 Enclosure 2 Room, Zone addressed 3.1.5 3.1.5 Fire Zones QUESTION Appendix R,Section III.G.3 states "alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area room or zone under consideration...." What is the implied utilization of a room or zone concept under Section III.G of Appendix R? The use of the phraseology "area, room or zone under consideration" is used again at the end of the Section III.G.3. Does the requirement for detection and fixed suppression indicate that the requirement can be limited to a fire zone rather than throughout a fire area? Under what conditions and with what caveats can the fire zone concept be utilized in demonstrating conformance to Appendix R?

RESPONSE Section III.G was written after NRC's multi-discipline review teams had visited all operating power plants. From these audits, the NRC recognized that it is not practical and may be impossible to subdivide some portions of an operating plant into fire areas. In addition, the NRC recognized that in some cases where fire areas are designated, it may not be possible to provide alternate shutdown capability independent of the fire area and, therefore, would have to be evaluated on the basis of fire zones within the fire area. The NRC also recognized that because some licensees had not yet performed a safe shutdown analysis, these analyses may identify new unique configurations.

To cover the large variation of possible configurations, the requirements of Section III.G were presented in three Parts:

Section III.G.1 requires one train of hot shutdown systems be free of fire damage and damage to cold shutdown systems be limited.

Section III.G.2 provides certain separation, suppression and detection requirements within fire areas; where such requirements are met, analysis is not necessary.

Section III.G.3 requires alternative dedicated shutdown capability for configurations that do not satisfy the requirements of III.G.2 or where fire suppressants released as a result of fire fighting, rupture of the system or inadvertent operation of the system may damage redundant equipment. If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration.

Section III.G recognizes that the need for alternate or dedicated shutdown capability may have to be considered on the basis of a fire area, a room or a fire zone. The alternative or dedicated capability should be independent of the fire area where it is possible to do so (See Supplementary Information for the final rule Section III.G). When fire areas are not designated or where it is not possible to have the alternative or dedicated capability independent of the fire area, careful consideration must be given to the selection and location of the alternative or dedicated shutdown capability to assure that the performance requirement set forth in Section III.G.1 is met. Where alternate or dedicated shutdown is provided for a room or zone, the capability must be physically and electrically independent of that room or zone. The vulnerability of the equipment and personnel required at the location of the alternative or dedicated shutdown capability to the environments produced at that location as a result of the fire or fire suppressant's must be evaluated. These environments may be due to the hot layer, smoke, drifting suppressants, common ventilation systems, and common drain systems or flooding. In addition, other interactions between the locations may be possible in unique configurations.

If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration. Compliance with Section III.G.2 cannot be based on rooms or zones. See also Sections #5 and #6 of the "Interpretations of Appendix R."

17

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference Coverage of No specific reference to Encl 1, Item 5 3.1, App. A (A-3) GL 86-10 Enclosure 1 Detection and coverage in NFPA 805 Suppression Ch. 3 5. Automatic Detection and Suppression Sections III.G.2.b and III.G.2.c of Appendix R state that "In addition, fire Systems detectors and automatic fire suppression system shall be installed in the fire area..." Other provisions of Appendix R also use the phrase "fire detectors and an automatic fire suppression system in the fire area..." (see e.g.,Section III.G.2.e).

Detection and suppression coverage In order to comply with these provisions, suppression and detection sufficient to protect against the hazards of the throughout the fire area must be installed. In this regard, detection and suppression providing less than full area coverage may be area is specified in the adequate to comply with the regulation. Where full area suppression and detection is not installed, licensees must deterministic approach perform an evaluation to assess the adequacy of partial suppression and detection to protect against the hazards in in NFPA 805 Section the area. The evaluation must be performed by a fire protection engineer and, if required, a systems engineer.

4.2.3 Although not required, licensees may submit their evaluations to the staff for review and concurrence. In any event, the evaluations must be retained for subsequent NRC audits. Where a licensee is providing no suppression or detection, and exemption must be requested.

Coverage of No specific reference to Encl. 2, 3.1, App. A (A-3) GL 86-10 Enclosure 2 Detection and coverage in NFPA 805 Question 3.4.2 Suppression Ch. 3 3.4.2 NRC Consultation Systems QUESTION Section 4.1.2 of NFPA-STD-13 allows for "partial installations" or partial coverage. The standard states that "the authority having jurisdiction shall be consulted in each case." With the NRC as authority in this instance, Detection and must consultation occur only through the exemption process?

suppression coverage throughout the fire RESPONSE No. The staff is always available to consult with utility representatives and provide guidance as to the area is specified in the acceptability of a particular fire protection configuration in individual plant areas. See also Section #5 of the deterministic approach "Interpretations of Appendix R."

in NFPA 805 Section 4.2.3 Coverage of No specific reference to Encl. 2, App. A (A-3) GL 86-10 Enclosure 2 Detection and coverage in NFPA 805 Question 3.4.3 Suppression Ch. 3 3.4.3 Sprinkler Location Systems QUESTION How does a suppression system designer know whether the term "throughout the area" means that sprinkler heads must be above or below cable trays when, in his judgment, the hazard of concern is a floor based Detection and fire?

suppression coverage throughout the fire RESPONSE Section C.6.c(3) of BTP CMEB 9.5-1 states: "(3) Fixed water extinguishing systems should conform to area is specified in the requirements of appropriate standards such as NFPA-13, "Standard for the Installation of Sprinkler Systems," and deterministic approach NFPA-15, "Standard for Water Spray Fixed Systems". This question pertains to those sprinkler systems covered by in NFPA 805 Section NFPA-13. Chapter 4 of NFPA-13 provides guidance as to the location of sprinkler heads in relation to common 4.2.3 obstructions. In general, to achieve complete area wide coverage, sprinklers should be located at the ceiling, with additional sprinklers provided below significant obstructions such as wide HVAC ducts and "shielded" or solid bottom stacked cable trays. To the extent that an existing or proposed sprinkler system design deviates from this concept, the design would have to be justified by a fire hazards analysis. See also Section #5 of the "Interpretations of Appendix R."

18

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference Coverage of No specific reference to Encl. 2, App. A (A-3) GL 86-10 Enclosure 2 Detection and coverage in NFPA 805 Question 3.4.4 Suppression Ch. 3 3.4.4 Fixed Suppression System In Fire Area Systems QUESTION Are fixed suppression systems required by Section III G.3 to be throughout the fire area, room or zone under consideration?

Detection and suppression coverage RESPONSE No, but partial coverage must be properly justified and documented. See Item #5 of the throughout the fire "Interpretations of Appendix R." "...suppression less than full area coverage may be adequate to comply with the area is specified in the regulation. Where full area suppression and detection is not installed, licensees must perform an evaluation to deterministic approach assess the adequacy and necessity of partial suppression and detection in an area. The evaluation must be in NFPA 805 Section performed by a fire protection engineer and, if required, a systems engineer. Although not required, licensees may 4.2.3 submit their evaluations to the staff for review and concurrence. In any event, the evaluations must be retained for subsequent NRC audits..."

Intervening 4.2.3.3.(b), 4.2.3.4(a) Encl. 2, 3.6.1 Negligible Quantities of Intervening Combustibles Combustibles Questions 3.6.1 between QUESTION Twenty feet of separation with absolutely no intervening combustibles is a rare case in most Redundant nuclear plants. What is the most acceptable method of addressing intervening combustibles? How are various Trains utilities addressing this subject, and what would be sufficient justification to support an exemption request?

RESPONSE If more than negligible quantities of combustible materials (such as isolated cable runs) exist between redundant shutdown divisions, an exemption request should be filed. [Negligible quantity" is an admittedly judgmental criterion, and this judgment should be made by a qualified fire protection engineer and documented for later NRC audit.] Justifications for such exemptions have been based on the following factors:

1. A relatively large horizontal spatial separation between redundant divisions; all cables qualified to IEEE-383.

2. The presence of an automatic fire suppression system over the intervening combustible (such as a cable tray fire suppression system);

3. The presence of fire stops to inhibit fire propagation in intervening cable trays;

4. The likely fire propagation direction of burning intervening combustibles in relation to the location of the vulnerable shutdown division;

5. The availability of compensating active and passive fire protection. Any future changes in the cable configuration due to modifications could be handled under 50.59. See the provisions of the license condition in the response to question 8.2.

19

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference Intervening 4.2.3.3.(b), 4.2.3.4(a) Encl. 2, GL 86-10 Enclosure 2 Combustibles Question 3.6.2 between 3.6.2 In-Situ Exposed Combustibles Redundant QUESTIONS Within Appendix R,Section III.G.2.b, the phrase "twenty feet with no intervening combustible or fire Trains hazards" is utilized. What is the definition of "no intervening combustible?" Is the regulation focused predominantly on the absence of fixed combustibles?

RESPONSE There is no specific definition of "no intervening combustible." The regulation is focused on the absence of in-situ exposed combustibles. Non combustible materials would not be considered as "Noncombustible Material a. A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat. b. Material having a structural base of noncombustible material, as defined in a., above, with a surfacing not over 1/8-inch thick that has a flame spread rating not higher than 50 when measured using ASTM E-84 Test "Surface Burning Characteristics of Building Materials." In Generic Letter 83-33, we state: "Staff Position: Section III.G.2.b requires the "separation

...with no intervening combustibles ..." To meet this requirement, plastic jackets and insulation of grouped electrical cables, including those which are coated, should be considered as intervening combustibles." For fire protection, "no intervening combustibles" means that there is no significant quantities of in-situ materials which will ignite and burn located between redundant shutdown systems. The amount of such combustibles that has significance is a judgmental decision. As with other issues, if the licensees fire protection engineer is concerned that the quantity of combustibles between shutdown divisions may not be considered insignificant by an independent reviewer, an exemption could be requested or the staff consulted. Transient materials are not considered as an intervening combustible; however, they must be considered as part of the overall fire hazard within an area. Cables that are in cable trays which are either open or fully enclosed should also be considered as intervening combustibles. Cables coated with a fire retardant material are also considered as intervening combustibles. However, cables coated with a fire retardant material, or cables in cable trays having solid sheet metal bottom, sides and top, if protected by automatic fire detection and suppression systems and if the design is supported by a fire hazards analysis, have been found acceptable under the exemption process.

20

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference NFPA Code Various Encl. 2, 1.87 GL 86-10 Enclosure 2 Deviations Questions 3.8.1, 8.9 3.8.1 Fire Protection Features NFPA Conformance QUESTION Should the fire protection features required by Section III.G conform to the NFPA Codes?

RESPONSE

Yes. For example,Section III G.2 requires an automatic suppression system. Our guidelines would recommend that the systems be in accordance with an NFPA Code. If deviations are made from the Code, they should be identified in the FSAR or FHA.

8.9 NFPA Code Deviation QUESTION Is an exemption/deviation required for deviations from NFPA Codes?

RESPONSE

Deviations from the codes should be identified and justified in the FSAR or FHA. An exemption is not required for NFPA codes. NRC guidelines reference certain NFPA codes as guidelines to the systems acceptable to the staff, and therefore such codes may be accorded the same status as Regulatory Guides.

When the applicant/licensee states that its design "meets the NFPA codes" or, "meets the Intent of the NFPA Codes" and does not identify any deviations from such codes, NRR and the Regions expect that the design conforms to the code and the design is subject to inspection against the NFPA codes.

21

Attachment to FAQ 06-0008 Appendix B - Types of Engineering Evaluations/References Topic NFPA 805 Section GL 86-10 RG 1.189 Reference Information Reference Reference NFPA Code Various Encl. 2, 1.87 RG 1.189 Deviations Questions 3.8.1, 8.9 1.8.7 NFPA Code and Standard Deviation Evaluations For those fire protection structures, systems, and components installed to satisfy NRC requirements designed to NFPA codes and standards, the code edition in force at the time of the design and installation is the code of record to which the design is evaluated. Deviations from the codes should be identified and justified in the FSAR or FHA.

Deviations should not degrade the performance of fire protection systems or features. The code of record is determined by the licensee.

A licensee may apply the equivalency concept in meeting the provisions of the NFPA codes and standards. Nothing in the NFPA codes or standards is intended to prevent the use of methods, systems, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety as alternatives to those prescribed by the codes or standards, provided technical documentation demonstrates equivalency and the method, system, or device is listed or approved for the intended purpose.

An exemption is not required for deviation from NFPA codes. NRC guidelines reference certain NFPA codes as providing guidance acceptable to the staff, and therefore such codes may be accorded the same status as regulatory guides.

When the applicant/licensee states that its design "meets the NFPA code(s)" or "meets the intent of the NFPA code(s)" and does not identify any deviations from such codes, the NRC expects that the design conforms to the codes and the design is subject to inspection against the NFPA codes.

The Authority Having Jurisdiction as described in NFPA documents refers to the Director, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, or designee, consistent with the authority specified in 10 CFR 1.43. The guidance in Regulatory Position 1.8.7 is based on GL 86-10.

22

Attachment to FAQ 06-0008 Appendix C - Guidance for Performing Engineering Evaluations 1.0 PURPOSE This appendix provides guidance for the preparation and development of engineering evaluations to determine if changes resulting in a deviation(s) from applicable regulatory requirements, guidance documents, or the fire protection licensing basis are acceptable.

The guidance may also be utilized to evaluate deviations from applicable NFPA codes.

The guidance is consistent with the information contained in Generic Letter 86-10, Implementation of Fire Protection Requirements.

This guidance is intended for licensees who have transitioned to a new fire protection licensing basis under NFPA 805. This guidance is intended to support use of alternative approaches for use of performance-based methods for addressing NFPA 805 Chapter 3 items under a license amendment in accordance with 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4). This guidance, however, may also be used to perform engineering evaluations that do not require prior NRC approval under a license amendment.

This guidance is based upon NEI 02-03, Guidance for Performing a Regulatory Review of Proposed Changes to the Approved Fire Protection Program, Revision 0 (June 2003).

2.0 SCOPE The guidance provided in this document may be used to analyze configurations associated with deviations from the approved fire protection program, including the fire protection and nuclear safety capability systems, components, and strategies; administrative requirements and technical controls; organization; and other plant features associated with the program. Examples include, but are not limited to, the following:

2.1 Adequacy of Separation of Redundant Systems/Components Required for Post Fire Nuclear Safety Capability A. Fire area, zone or room boundaries that (1) are not completely sealed floor-to-ceiling or wall-to-wall by fire-rated construction, or (2) have fire rated construction/components for which the fire rating is less than that required by the regulation or the approved fire protection program. Where fire boundaries are not wall-to-wall or floor-to-ceiling with all penetrations sealed to the required fire rating, the evaluation should assess the adequacy of the boundaries to determine if they will withstand the hazards associated with the area and protect important equipment from a fire outside the area. (Reference GL 86-10, Enclosure 1, Item 4 and Questions 3.1.1 and 3.1.2)

B. Passive fire-rated components (i.e., penetration seals, fire wraps, structural steel fire proofing, etc.) that deviate from the design and/or tested configuration, including test acceptance criteria. (Reference GL 86-10 Questions 3.2.1, 3.2.2, and 3.3)

C. Active fire-rated components (i.e., doors, dampers, etc.) that deviate from the design and/or tested configuration. (Reference GL 86-10, Question 3.2.3)

D. The adequacy of the separation provided between normal shutdown equipment and alternative shutdown capability located within the same 23

Attachment to FAQ 06-0008 Appendix C - Guidance for Performing Engineering Evaluations area (Reference GL 86-10, Enclosure 1, Item 6). Note: This would only be applicable for a alternative shutdown fire area transitioned under a deterministic approach. Performing this type of evaluation does not specifically require prior NRC approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

E. The significance of combustible materials present (i.e., intervening combustibles) located between redundant nuclear safety capability success paths that are not separated by rated fire barriers (i.e., spatial separation).

(Reference GL 86-10 Questions 3.6.1, 3.6.2, and 3.6.3). Note:

Performing this evaluation does not specifically require prior NRC approval under 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4).

2.2 The adequacy of suppression and detection systems, including partial coverage protecting nuclear safety capability cables and equipment and other required circuits of redundant success paths. (Reference GL 86-10, Enclosure 1, Item 5, and Questions 3.4.2, 3.4.3, and 3.4.4) 2.3 Deviations from applicable NFPA codes and standards. (Reference GL 86-10 Questions 3.8.1, 8.9) 3 LIMITATIONS 3.1 The process for preparing technical evaluations should be performed in accordance with the licensees engineering calculation program (or similar program).

3.2 A fire protection engineer should perform or review the technical evaluation. In addition, if determined necessary by the fire protection engineer, a systems engineer should assist with the evaluation. (Reference GL 86-10, Enclosure 1, Item 4). The general qualifications for a fire protection engineer are described in Generic Letter 82-21. NEI 04-02 provides additional guidance on the qualifications for individuals practicing fire modeling and quantitative fire protection risk assessments.

3.3 Technical evaluations must be available for NRC review during audits or inspections (Reference GL 86-10, Enclosure 1, Items 4 and 5, NFPA 805 Section 2.7).

4.0 DEFINITIONS Free of Fire Damage The structure, system, or component under consideration is capable of performing its intended function during and after the postulated fire, as needed.

(Reference NFPA 805, Section 1.6.29) 5.0 EVALUATION CRITERIA AND CONSIDERATIONS 5.1 Acceptance Criteria 24

Attachment to FAQ 06-0008 Appendix C - Guidance for Performing Engineering Evaluations 5.1.1 Although the level of detail and analysis will vary based upon the nature and complexity of the item under evaluation, the following conditions must be assessed and documented as part of alternative approach allowed by 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4):

(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

5.1.2 The goals for nuclear safety and radioactive release, from section 1.3 of NFPA 805, are as follows:

o Nuclear Safety Goal. The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.

o Radioactive Release Goal. The radioactive release goal is to provide reasonable assurance that a fire will not result in a radiological release that adversely affects the public, plant personnel, or the environment.

The performance objectives and performance criteria for nuclear safety and radioactive release are contained in Sections 1.4 and 1.5 of NFPA 805.

5.1.3 If the engineering evaluation is associated with a change, the change will be evaluated and processed using the risk-informed, performance-based change process outlined in Section 5.3 and Appendices I and J of NEI 04-02, as clarified by Regulatory Guide 1.205. The acceptance criteria in NEI 04-02, as clarified in Regulatory Guide 1.205, will apply to all applicable changes, including those discussed in this guidance document.

5.2 General Methodology When fire protection features are evaluated, the postulated fire for the area, zone, or room affected by the change should be considered, and the overall protection scheme should be kept in perspective. The defense-in-depth principles of the fire protection program provide an adequate balance between the different features. Strengthening any one can compensate for weaknesses in others.

5.3 Adequacy of Separation of Redundant Systems/Components Required for Nuclear Safety Capability When evaluating the adequacy of a fire barrier, the fire areas, zones, or rooms on each side of the barrier are to be individually analyzed for the impact of a fire on either side of the barrier on the redundant nuclear safety capability, including the likely spread of fire.

The effectiveness of the barrier should be evaluated to demonstrate the adequacy of a barrier commensurate with the fire hazards in the area such that the barrier provides a level of protection equivalent to that provided by the deterministic requirements. A specific description of the fire protection features in the areas, zones, or rooms being 25

Attachment to FAQ 06-0008 Appendix C - Guidance for Performing Engineering Evaluations analyzed is required to justify the change. Low fire loading alone is not a sufficient basis for the evaluation. If it is determined that each fire barrier of concern is capable of protecting the nuclear safety equipment/cables protected by the barrier (i.e., within and/or adjacent to the opposite side of the barrier), the analysis and justification for the acceptability of the fire barrier shall be documented.

In performing the engineering evaluation each of the components of fire damage mitigation described below may be considered either individually or in aggregate. For example, a passive barrier can be evaluated as an acceptable separation barrier based on its own details of construction, (e.g., 18 inch thick reinforced concrete wall with only a few open penetrations), limited in-situ combustibles in the vicinity of any open penetrations and installed automatic fire suppression and detection on the side of the barrier with the combustible materials in the vicinity of the open penetration. Whenever suppression and/or detection is credited as a part of the engineering evaluation, the effectiveness of the suppression and/or detection in terms of coverage and code compliance should be evaluated as necessary using the processes outlined in Sections 5.4 and 5.5 below.

Additionally, provisions should be made for controlling and compensating for any of the components credited in the engineering evaluation. For example, if low in-situ combustibles are credited as a component of the engineering evaluation, provisions should be included in combustible control program to limit in-situ combustibles to a level that is consistent with the engineering evaluation. Similarly, if automatic suppression is credited, provisions should be included in the plant administrative control process to properly compensate for the lack of the suppression system when it is taken out of service or determined to be inoperable.

5.3.1 If evaluating passive fire-rated components, the evaluation should determine, as a minimum, that:

o The temperature on the unexposed side of the barrier is sufficiently below the ignition temperature of the penetrating items.

o The continuity and thickness of the fire barrier material is maintained.

o The nature of the support assembly is equivalent to the tested configuration.

o The application or "end use" of the fire barrier is unchanged from the tested configuration. For example, the use of structural steel fire proofing to protect a cable tray assembly may not be acceptable.

5.3.2 If evaluating active fire rated components, then the evaluation should determine if the component provides an adequate level of separation considering a fire on both sides.

5.3.3 If evaluating the significance of combustible materials (e.g., type, quantity, distribution, etc.) located between redundant success paths that are not separated by rated fire barriers (i.e., intervening combustibles), then the evaluation should consider the following factors to determine whether circuits or components, including other required circuits for nuclear safety capability, could be adversely affected or whether a new hazard / element is being introduced:

26

Attachment to FAQ 06-0008 Appendix C - Guidance for Performing Engineering Evaluations o The horizontal spatial separation between redundant success paths.

o Cable qualification (IEEE-383).

o The presence of an automatic fire suppression system over the intervening combustible.

o The likely fire propagation direction of burning intervening combustibles in relation to the location of the vulnerable success path.

o The availability of other active and passive compensating fire protection features provided.

Note: For fire protection, "no intervening combustibles" means that there are not significant quantities of in-situ materials that will ignite and burn located between redundant nuclear safety success paths. Significant quantity is a judgmental criterion, and the judgment of whether or not intervening combustibles are significant should be made by a fire protection engineer and documented.

5.4 Suppression and Detection System Coverage When evaluating the adequacy of partial suppression and/or detection coverage, the hazards in the fire areas, zones, or rooms of concern should be considered. The effectiveness of the system should be judged based on the location of the system components (i.e., detector, sprinklers, etc.) relative to the hazards, including the likely spread of fire, and should determine whether or not the system is commensurate with the fire hazards in the area. A specific description of the fire protection features in the areas, zones, or rooms being analyzed is required to justify the change. Low fire loading alone is not a sufficient basis for the evaluation.

5.5 NFPA Code Deviations As a minimum, applicable NFPA code deviations should be evaluated and justified by a qualified fire protection engineer based on engineering judgment. Guidance, considerations, and criteria provided throughout this document may be utilized when determined to be applicable by the evaluating engineer.

27

See attached.

Original Message-----

From: Paul Lain [2]

Sent: Thursday, October 26, 2006 4:27 PM To: JAMAR, Brandon

Subject:

FAQ 06-0011

Brandon, Can't seem to find an electronic copy of FAQ 06-0011. Could you send me one?

Paul 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.

Mail Envelope Properties (4541EE5F.38E : 11 : 9102)

Subject:

RE: FAQ 06-0011 Creation Date 10/27/2006 7:32:57 AM From: "JAMAR, Brandon" <btj@nei.org>

Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 PWL (Paul Lain)

Post Office Route TWGWPO01.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 859 10/27/2006 7:32:57 AM FAQ 06-0011 Rev. 0.pdf 112228 Mime.822 157209 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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FAQ TEMPLATE Plant: D. C. Cook FAQ # 06-0011 Rev. 0 Submittal Date: 09-28-06 Licensee

Contact:

Thomas Jutras (EPM) Tele/email 508-875-2121 x 215 NRC

Contact:

Tele/email Distribution: Check all that apply (NEI Internal Use)

FPWG RIRWG NSSS OG X NFPA 805 TF

Subject:

Interpretation of guidance? Yes Proposed new guidance not in NEI 04-02? Yes Details:

NEI 04-02 Guidance needing interpretation (include section, paragraph number, and line number):

NEI 04-02, Appendix B, Section B.2.2., (Page B-7, last paragraph)

Circumstances requiring guidance interpretation or new guidance:

The subject of transitioning Appendix R III.G.3/III.L areas is discussed in Section B.2.2 of NEI 04-02. However, the wording is not entirely clear. Clarification is requested regarding the deterministic transition of areas that currently comply with Section III.G.3 of Appendix R (with or without associated engineering evaluations and exemptions) to NFPA 805 without the need for a change evaluation.

The original intent (based on input from NFPA 805 Committee Members) was that III.G.3 compliant areas could be transitioned as in compliance with existing plant license basis. This is completely in agreement with the philosophy of safe-today, safe-tomorrow. Per NFPA 805 Figure 2.2 this is considered the deterministic approach. However, the deterministic approach sections of NPFA 805 Chapter 4, do not appear to specifically address the III.G.3 compliance option. According to NFPA 805 committee members, alternate shutdown was just considered another success path and that was the reason a specific paragraph was not included for III.G.3 in the deterministic approach.

The suggested clarifications to NEI 04-02 are also in line with other parts of NEI 04-02 and Reg. Guide 1.205.

Examples:

From Section 4.3.2 of NEI 04-02, The deterministic branch of Figure 2.2 of NFPA 805 recognizes the new fire protection licensing basis may include components of the existing plant Fire Protection Program (including approved exemptions / deviations, and correctly implemented 10 CFR 50.59 and Fire Protection Regulatory reviews) that can be shown to comply with Chapters 1, 2 and 4. This would be considered compliance with deterministic compliance in NFPA 805 Chapter 4. Otherwise, additional Fire Protection Regulatory reviews may be used to demonstrate equivalence.

From RG 1.205 Section 2.3, Section 2.2.7 of NFPA 805 describes the application of existing engineering equivalency evaluations (EEEEs) when using a deterministic approach during the transition to an NFPA 805 FPP.

Detail contentious points if licensee and NRC have not reached agreement:

N/A Potentially relevant existing FAQ numbers:

FAQ 06-008 states that alternative shutdown areas transition deterministically in accordance with NEI 04-02 and would not need prior approval.

Response Section Proposed Resolution of FAQ and the basis for the proposal:

Revise NEI 04-02, Section B.2.2 to address the transition of III.G.3 areas deterministically.

Previous analysis has demonstrated the ability to achieve the safe shutdown performance criteria for these areas. Maintaining the philosophy of safe-today, safe-tomorrow, further evaluation is not necessary and a change evaluation should not be required until post-transition changes occur.

If appropriate, provide proposed rewording of guidance for inclusion in next revision.

Revise NEI 04-02, Section B.2.2 (second paragraph) to state the following:

Transition of a fire area that is governed by Sections III.G.3/III.L of 10 CFR 50 Appendix R is not treated differently than other plant fire areas. While alternative or dedicated shutdown capability was omitted from the deterministic requirements in Chapter 4 of NFPA 805, the transition of a III.G.3 fire area can be completed deterministically given the recovery actions are feasible and the safe shutdown compliance strategy is clearly documented. A change evaluation to address the transition would, therefore, not be necessary. This is consistent with the deterministic approach as depicted in Figure 2.2 of NFPA 805 and is consistent with the safe-today, safe-tomorrow

philosophy. However, the current licensing basis for an alternative/dedicated shutdown fire area may Deleted: fire area is not different.

be more explicit than other fire areas, since many licensees have detailed alternative/dedicated shutdown Safety Evaluation Reports. It may require more detailed documentation to ensure future change evaluations accurately capture the baseline configuration. For example, a dedicated shutdown methodology may credit a unique power source or pump that is not part of the plants safety systems or post-fire safe shutdown program. Post-transition changes to this equipment or methodology would need to be accurately captured for assessment of risk impact.

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