ML072340110
| ML072340110 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/04/2007 |
| From: | Brandon J Nuclear Energy Institute |
| To: | Gallucci R, Charles Moulton, Sunil Weerakkody NRC/NRR/ADES/DRA |
| References | |
| Download: ML072340110 (61) | |
Text
From: "JAMAR, Brandon" <btj@nei.org>
To: "Charles Moulton" <CEM4@nrc.gov>, "Sunil Weerakkody" <SDW1@nrc.gov>, <RHG@nrc.gov> Date: Mon, Jun 4, 2007 8:34 PM
Subject:
FAQ 06-0017 Rev. 2 for submittal Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmittal please contact me directly.
Thank you, Brandon Jamar This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message.
CC: "MARION, Alex" <am@nei.org>, "RILEY, Jim" <jhr@nei.org>
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FAQ 06-0017 Rev. 2 for submittal Creation Date 6/4/2007 8:37:42 PM From: "JAMAR, Brandon" <btj@nei.org>
Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov OWGWPO02.HQGWDO01 RHG (Ray Gallucci) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org jhr CC (Jim RILEY) am CC (Alex MARION)
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FAQ Number 06-0017 FAQ Revision 2 FAQ Title Ignition Source Counting Guidance for High Energy Arching Faults Page 1 of 3 faq 06-0017 - rev 2.doc Plant: Harris Date:June 1, 2007 Contact: Dave Miskiewicz Phone:919.546.7588 Email:David.Miskiewicz@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG FPRATF RIRWG BWROG PWROG Purpose of FAQ:
Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details: NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
The guidance provided in NUREG/CR-6850 for Ta sk 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:
Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy arcing faults are associated with switchgear and load centers. Switchyard transformers and isolation phase buses are not part of this bin. For this bin, similar to electrical cabinets, the vertical segments of the switchgear and load centers should be counted. Additionally, to cover potential explosive failure of oil filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load centers) may be included in vertical segment counts of the switchgear.
Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatment of High Energy Arcing Faults (Bin 16).
Strict interpretation of the guidance is that the HEAF count should mimic the electrical cabinet counts for switchgear and load centers. The application of such a counting method is expected to result in reported High Energy Arcing Fault (HEAF) frequency values for an individual plant being inconsistent with i ndustry experience. The industry experience and consequently the HEAF frequency is based on 3 events occurring on medium voltage FAQ Number 06-0017 FAQ Revision 2 FAQ Title Ignition Source Counting Guidance for High Energy Arching Faults Page 2 of 3 faq 06-0017 - rev 2.doc switchgears and 1/2 event occurring on a 480 VAC Load Center. Because of the relative numbers of switchgears and load centers at an individual plant, it is expected that the resultant frequency may be inappropriately skewed. There is a concern that the occurrence of a HEAF frequency distribution that departs significantly from the 3 to 1/2 ratio would cause results to be challenged.
There is a need to resolve these issues to prevent future rework and to reduce burden associated with uncertainty treatment. This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
Potentially relevant existing FAQ numbers:
This guidance is specific to the characteriz ation of electrical cab inets for Bin 16 HEAF determination. The characterization and counting of electrical cabinets for Bin 15 determination is addressed by FAQ 06-0016.
FAQ 07-0035 addresses counting Bus Duct for HEAF. Response Section:
Proposed resolution of FAQ and the basis for the proposal:
Split fire ignition frequency Bin 16, HEAF, into two bins; namely, "16a - HEAF for low-voltage panels (480-1000V)" and "16b - HEAF for medium-voltage panels (greater than 1000V)." For each bin, the method of panel counting would remain consistent with the guidance for Bin 15 (see FAQ 06-0016). Additionally, MCCs with molded-case circuit breakers should not be counted as HEAF sources unless it is associated with switchgear that is used to directly operate equipment such as load centers.
The net result is a re-partitioning of the "higher-consequence" HEAF events between low and medium-to-high voltage equipment in accordance with the event data. The revised fire frequencies for these two new bins are as follows:
16a: HEAF for Low-Voltage Panels (480 - 1000V)
Mean = 4.8E-04 Variance = 1.4E-03 5% Lower Bound = 1.6E-05 50% (Median) = 2.0E-04 95% Upper Bound = 1.5E-03 16b: HEAF for Medium-Voltage Panels (greater than 1000V) Mean = 1.4E-03 FAQ Number 06-0017 FAQ Revision 2 FAQ Title Ignition Source Counting Guidance for High Energy Arching Faults Page 3 of 3 faq 06-0017 - rev 2.doc Variance = 1.2E-02 5% Lower Bound = 3.8E-05 50% (Median) = 6.2E-04 95% Upper Bound = 4.1E-03
Basis: This FAQ revision includes the respons e proposed by the NRC and the NUREG/CR-6850 writing team.
If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
Thanks. We'll look it over. If OK, we'll incoproate into the close-out memo.
Any feedback on new FAQ 35 (bus ducts and junctions), particularly if the July 13th date is a go for the joint panel to resolve duct counting that I proposed at the last FAQ meeting? This date would enable Steve Nowlen to participate since he'll be in town.
>>> "JAMAR, Brandon" <
btj@nei.org> 06/04/2007 8:37:42 PM >>>
Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmitta l please contact me directly.
Thank you, Brandon Jamar This electronic message transmission co ntains 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 immedi ately by telephone or by electronic mail and permanently delete the original message.
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Re: FAQ 06-0017 Rev. 2 for submittal Creation Date 6/5/2007 10:54:09 AM From: Ray Gallucci Created By:
RHG@nrc.gov Recipients nei.org am CC (Alex MARION) btj (Brandon JAMAR) jhr CC (Jim RILEY) nrc.gov OWGWPO03.HQGWDO01 TQD1 CC (Thinh Dinh) nrc.gov OWGWPO04.HQGWDO01 JSH2 CC (J S Hyslop) nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) pgnmail.com david.miskiewicz CC (david.miskiewicz@pgnmail.com)
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Thank you, Brandon Jamar This electronic message transmission co ntains 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 immedi ately by telephone or by electronic mail and permanently delete the original message.
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FAQ 06-0012 Rev. 4 for submittal Creation Date 6/5/2007 7:13:12 PM From: "JAMAR, Brandon" <btj@nei.org>
Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody) nei.org jhr CC (Jim RILEY) am CC (Alex MARION)
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FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 1 of 12 faq 06-0012 - manual actions - rev 4.doc Plant: Harris Nuclear Plant Date:03/22/2007 Contact: Elizabeth Kleinsorg Phone:704.651.5548 Email:ekleinsorg@haifire.com Purpose of FAQ:
Operator manual actions that are either not allowed under the current regulatory framework or for which there is no previous NRC approval are not compliant with current regulations. The acceptability of the continued use of the actions that are not compliant will be evaluated using the change process. The purpose of this FAQ is to clarify the operator manual actions that will require change evaluations during the transition to NFPA 805.
Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details: NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):
Section B.2.2.4 Recovery Actions Circumstances requiring guidance interpretation or new guidance:
Operator manual actions that are currently credited in Appendix R (NUREG 0800) analyses may be allowed under the current regulation/guidance or may have been approved via an exemption/deviation. These operator manual actions do not require a change evaluation during the transition process.
Subsequent to the submittal of FAQ 06-0001, the following documents were issued by the NRC:
2006-05 Public Meeting Notice 20060609 on Manual Action Clarifications ML061390156 2006-05 Draft NRC Response to 05-03-06 NEI letter - ML061440251 2006-05 Draft NRC Response to 03-29-06 EPM letter - ML061440237 FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 2 of 12 faq 06-0012 - manual actions - rev 4.doc 2006-06 RIS 2006-10 Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions - ML061650389 2006-07 NRC Meeting Summary of 06-09-06 OMA Meeting ML061950327 2006-07 NRC Revision to Draft Response to EPM March 2006 letter - ML061980016 2006-07 NRC Revision to Draft Response to NEI May 2006 letter - ML061980035 In addition the NRC letter to NEI, Use of Manual Actions to Achieve Safe Shutdown for Fire Events, dated 2002-05-16 (ML021410026) provides information not captured in the correspondence above.
These documents provide additional clarification with respect to the acceptability of existing operator manual actions.
Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
None. Potentially relevant existing FAQ numbers:
This FAQ supersedes FAQ 06-0001.
Response Section:
Proposed resolution of FAQ and the basis for the proposal:
The following information will be used as input for a revision to NEI 04-02:
Allowed Operator Manual Actions "With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:
o operation of equipment for which cables are located in fire areas that meet Section III.G.1of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area o manual operation of normally operated manual switches and valves o staff-approved deviations and exemptions for specific manual actions in lieu of meeting the criteria of Section III.G.2 of Appendix R to 10 CFR Part 50 o manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required" FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 3 of 12 faq 06-0012 - manual actions - rev 4.doc (NRC Letter to NEI dated May 16, 2002, Use of Manual Actions to Achieve Safe Shutdown for Fire Events)
Operator Manual Actions on 'Fire Affected Train'. "As discussed during a March 1, 2006, public meeting, if one of the redundant trains in the same fire area is free of fire damage by one of the specified means in paragraph III.G.2, then the use of operator manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to the second train may be considered in accordance with the licensee's 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 bef ore 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 staff's 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.
FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Page 4 of 12 faq 06-0012 - manual actions - rev 4.doc The appropriate regulatory vehicle (in the absence of a rulemaking or plant-specific Order) to provide dispensation from compliance with fire protection requirements is the issuance of an exemption under 10 CFR Part 50.12. Inspection reports, meeting minutes, and letters from licensees are examples of documents that do not provide dispensation from compliance with applicable fire protection requirements.
For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in paragraph III.G.2, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstances of section 50.12(a)(2)(ii), citing the SER as the safety basis, and confirming that the safety basis established in the SER remains valid. The staff expects to grant the exemption on these bases without further review. "(RIS 2006-10)
Plants Licensed to Operate After January 1, 1979 "Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraph III.G.2, a staff decision in an SER that approves the use of manual operator actions does not require exemption under 10 CFR 50.12. Post-1979 licensees may be requested to demonstrate, as part of the NRC Reactor Oversight Process, that the use of an operator manual action would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire consistent with their license." (RIS 2006-10) If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
Revise NEI 04-02 as shown in the attachment.
Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 5 of 12 [Fifth paragraph on page 29 of NEI 04-02 Revision 1] 4.3.2 Nuclear Safety Performance Criteria Transition Review
- Operator manual actions being transitioned to recovery actions that are not allowed under the current regulatory framework or do not have previous NRC approval should be evaluated using the change process. See Appendix B-2 of this document for additional guidance.
Deleted: MDeleted: (credited for III.G.2 compliance)Deleted:
Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 6 of 12 B.2.2.4 Recovery Actions Operator manual actions will be transitioned as "recovery actions" in the new NFPA 805 licensing bases. Repairs will also be transitioned as "recovery actions".
The following information for operator manual actions should be included in the fire area summaries (and referenced as appropriate in Table B-3 Fire Area Assessment Worksheet):
Whether the transitioning recovery action is allowed or was previously reviewed and approved by the NRC's Office of Nuclear Reactor Regulation (NRR). Include reference to documentation that demonstrates prior review and approval by the NRC.
Reference to the feasibility evaluation of the transitioning recovery action.
See discussion below
. Reference to the evaluation of additional risk associated with the use of recovery actions. See section discussion below
. Figure B-4 depicts this general process for determining whether a transitioning operator manual action to NFPA 805 recovery action requires a change evaluation. The 'bin' identifiers are for ease of reference.
Action is taken inside of the Main Control Room?Action is a Normally Manually Operated Switch/ValveAction taken to Achieve &
Maintain Cold Shutdown?Action Credited for App. R Section III.G.3 (NUREG-0800 C.5.c)?Action is Related to 'fire affected' train?Prior NRC Approval Obtained?Action Related to Credited Train, but does not disable Function?Action is Feasible?Bin AOperator Manual Action is ACCEPTABLEBin CBin DBin EBin FBin GBin BFor each Operator Manual Action for a Given Fire AreaOperator Action Not Allowed / Not Approved (Candidate for RI-PB Change Evaluation)Bin H No No No No No No NoYesYesYes Yes YesYesYesYes No Figure B-4 General Process to Transition Operator Manual Actions Deleted: MDeleted: that Deleted: yDeleted: for the fire areaDeleted: isDeleted: : Deleted: 1) wDeleted: operator Deleted: manual Deleted: sDeleted: were Deleted: , and 2) Deleted: RDeleted: ADeleted: sDeleted: t Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 7 of 12 Determining If a Transitioning Operator Manual Action requires a Change Evaluation Operator manual actions that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/safety evaluation report) can be transitioned without the need to use the change evaluation process. Examples of allowed operator manual actions include
- Operator manual operation from the control room or emergency control station(s)
[Bin A] Repairs or operator manual actions credited either for transitioning to or maintaining cold shutdown equipment [Bin B]
Manual operation of normally operated manual switches and valves where separation/protection is provided for redundant safe-shutdown trains in accordance with Section III.G.1 or III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) [Bin C]
NRC Letter to NEI dated May 16, 2002 states: "With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:
manual operation of normally operated manual switches and valves" Operator manual actions credited for compliance with Section III.G.3 of 10 CFR 50, Appendix R (or Section C.5.c of NUREG-0800). [Bin D]
NRC Letter to NEI dated May 16, 2002 states: "With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:
manual operation of equipment used to meet the requirements of Section III.G.3 for Alternative or Dedicated Shutdown of Appendix R to 10 CFR Part 50, where meeting performance criteria of Section III.L is required" RIS 2006-10 states: "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."
Operation of fire affected equipment for fire areas that meet the separation requirements of Section III.G.1of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800). See Figure B-5. [Bin E]
NRC Letter to NEI dated May 16, 2002 states: "With proper analysis, manual actions are allowed for fire safe shutdown activities under the following circumstances:
operation of equipment for which cables are located in fire areas that meet Section III.G.1 of Appendix R to 10 CFR Part 50, by having redundant cables and equipment in a completely different fire area" Deleted: taionDeleted: In some cases the previous approval may not be obvious, yet should be allowed.Deleted: areDeleted: MDeleted: is acceptableDeleted: do not require a change evaluation.Deleted: applicable sectionsDeleted: <#>The operator manual action is currently credited in the Alternate Shutdown Procedure. Although this manual action was NOT specifically mentioned in the SER, the licensee submittal specifically discussed the operator action. This can be considered previously approved¶<#>The operator manual action is currently credited in Non-Alternate Shutdown Procedure. The manual action was specifically discussed as acceptable in the SER however the NRC did not grant an exemption/deviation. This can be considered previously approved.¶<#>Operation of equipment for which cables and equipment for the redundant safe shutdown train are located in separate fire areas thus meeting Section III.G.1of Appendix R to 10 CFR Part 50,¶
<#>Manual operation of normally operated manual switches and valves where III.G.1 separation is provided for redundant safe-shutdown trains¶Deleted: Part Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 8 of 12 Operation of fire affected equipment for fire areas that meet the protection requirements of Section III.G.2 of 10 CFR 50, Appendix R (or applicable sections of NUREG-0800) for redundant trains. See Figure B-6. [Bin E]
RIS 2006-10 states: "As discussed during a March 1, 2006, public meeting, if one of the redundant trains in the same fire area is free of fire damage by one of the specified means in paragraph III.G.2, then the use of operator manual actions, or other means necessary, to mitigate fire-induced operation or maloperation to the second train may be considered in accordance with the licensee's fire protection program and license condition since paragraph III.G.2 has been satisfied."
Operator manual actions to address spurious actuations that affect the credited safe shutdown success path are allowed, as long as the spurious actuation is not directly in the protected train of the credited function (e.g., the main flowpath, as opposed to a diversionary flowpath) and the credited function does not become disabled during the time it takes to perform the operator manual action. See Figures B-7 and B-8 [Bin G} During the June 9, 200 6 public meeting the following example was specifically discussed: Two redundant trains taking suction from a common tank. Provided the manual action can be accomplished prior to the tank volume going below the minimum required volume to support the credited function the action would be allowed and therefore not require a change evaluation.
(Figure B-7)
A second example is the credited function is to inject water to the Steam Generator (reactor) and a spurious actuation causes a diversion from the credited flow path. Provided the minimum required injection flow can be maintained and the operator action can be accomplished prior to the function being disabled. (Figure B-8)
In addition to allowed operator manual actions some manual actions may have been previously reviewed and approved by the NRC [Bin F] (as documented in an approved exemptions/deviations/safety evaluation reports) and can also be transitioned without the need to use the change evaluation process. Guidance for determining previous approval is discussed in Section 2.3.1 and 4.3.2 of this document and in Regulatory Guide 1.205.
In some instances the NRC may have reviewed and approved [Bin F] an operator manual action in an SER without granting an exemption/deviation request. In theses cases, change evaluations would not be required based on the following guidance
- RIS 2006-10 states: "For pre-1979 licensees, a staff decision in a safety evaluation report (SER) that approves the use of operator manual actions, in lieu of one of the means specified in paragraph III.G.2, does not eliminate the need for an exemption. Pre-1979 licensees who have SERs, but not a corresponding exemption, which approve manual actions should request an exemption under 10 CFR Part 50.12, citing the special circumstances of section 50.12(a)(2)(ii), citing the SER as the safety basis, and confirming that the safety basis established in the SER remains valid. The staff expects to grant the exemption on these bases without further review."
During the transition, for pre-1979 licensees who have SERs, but not a corresponding exemption, which approves operator manual actions, should verify that the basis for Formatted: Font: Not Italic Formatted: Indent: Left: 0.25"Deleted: 6Deleted: 6Deleted: 7Deleted: 7Deleted: ODeleted: In some cases the previous approval may not be obvious, yet should be allowed.Deleted: Examples areDeleted: n SERclarification Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 9 of 12 acceptability in the SER is still valid. If the basis for acceptability is still valid, then no change evaluation is required.
RIS 2006-10 states: "Since plants licensed to operate on or after January 1, 1979 (post-1979 licensees), are not required to meet the requirements of paragraph III.G.2, a staff decision in an SER that approves the use of manual operator actions does not require exemption under 10 CFR 50.12. Post-1979 licensees may be requested to demonstrate, as part of the NRC Reactor Oversight Process, that the use of an operator manual action would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire consistent with their license."
Operator manual actions that are not allowed or have not been previously reviewed and approved by the NRC should be addressed for acceptability using the change evaluation [Bin H] process outlined in Chapter 5.3 of this guidance. Examples of operator manual actions that are not allowed are provided in summary of the June 9, 2006 Public Meeting (ML061950327, ML061980016)
Deleted: operator Deleted: Repairs credited for cold shutdown equipment will also be transitioned on a fire area basis. Information that should be summarized includes reference to documentation that demonstrates the equipment necessary for the repair is staged, the repair is proceduralized, and the repair is achievable in the necessary timeframe.¶
¶Operator manual actions that have been previously reviewed and approved by the NRC (as documented in an approved SER) can be transitioned without the need to use the change evaluation process. However, licensees may consider use of the change evaluation process for previously reviewed and approved operator manual actions so that the evaluation is consistent with operator manual actions not previously reviewed and approved by the NRC.¶
¶Deleted: (e.g., those credited for compliance with Appendix R sections III.G.2 and III.G.3)Deleted: thatDeleted: July, 19, 2006 Deleted: The following methodology should be used to optimize this process:
¶ Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 10 of 12 Figure B-5 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.1 Separation Criteria Train BPumpFire Area AFire Area BTrain BPower SupplyTrain B PowerCableTrain APumpTrain APower SupplyTrain A PowerCableTrain A ControlCableTrain B ControlCable3 - hour Rated Raceway Fire BarrierFire Area B meets the separation criteria of 10 CFR 50 Appendix R Section III.G.2.aA postulated fire in Fire Area A could result in the spurious starting of the non-credited Train A pump, which can be mitigated by an operator manual action to de-energize the Train A Power Supply to stop Pump A. This is functionally equivalent to Case in Figure B-5.
Figure B-6 Allowed Operator Manual Action in Fire Area Meeting 10 CFR 50, Appendix R, Section III.G.2 Compliant - Operator Manual Action for Fire Affected Train Deleted: 4Deleted: AcceptableDeleted: 5Deleted: Acceptable Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 11 of 12 Figure B-7 Allowed Operator Manual Action - In Credited Success Path - Common Tank Suction Deleted: 6 Attachment to FAQ 06-0012 Revision 4 Excerpt from NEI 04-02 Revision 1 with Changes Tracked Attachment Page 12 of 12 Figure B-8 Allowed Operator Manual Action - In Credited Success Path - Auxiliary Feedwater Flow Diversion Deleted: 7 Ray, We have created a new FAQ for bus ducts and it is with the task force. I think we should be able to get it to you be fore July. The FAQ as written does not contain a new soluti on to the counting question, but we plan to discuss it at the FPRA task force meeting on June 21. I believe we can support your meeting on July 13 although I am not sure who will be attending. We will have better input after our June meeting.
David Miskiewicz Progress Energy, PSA 919-546-7588
Original Message-----
From: Ray Gallucci [1]
Sent: Tuesday, June 05, 2007 10:54 AM To: Brandon JAMAR; Charles Moulton; Sunil Weerakkody Cc: Alex MARION; Jim RILEY; J S Hyslop; Thinh Dinh; Miskiewicz, David N
Subject:
Re: FAQ 06-0017 Rev. 2 for submittal Thanks. We'll look it ov er. If OK, we'll incoproate into the close-out memo. Any feedback on new FAQ 35 (bus ducts and junctions), particularly if the July 13th date is a go for the joint panel to reso lve duct counting that I proposed at the last FAQ meeting? This date would enable Steve Nowlen to participate since he'll be in town.
>>> "JAMAR, Brandon" <
btj@nei.org
> 06/04/2007 8:37:42 PM >>>
Please find revision 2 to FAQ 06-0017 for submittal. Should you have any problems with this transmitta l please contact me directly.
Thank you, Brandon Jamar
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RE: FAQ 06-0017 Rev. 2 for submittal Creation Date 6/7/2007 7:34:49 AM From: "Miskiewicz, David N" <David.Miskiewicz@pgnmail.com>
Created By: David.Miskiewicz@pgnmail.com Recipients nrc.gov OWGWPO02.HQGWDO01 RHG (Ray Gallucci) nrc.gov OWGWPO04.HQGWDO01 JSH2 CC (J S Hyslop) nrc.gov OWGWPO03.HQGWDO01 TQD1 CC (Thinh Dinh) nrc.gov TWGWPO01.HQGWDO01 CEM4 CC (Charles Moulton) nei.org reb CC (Biff BRADLEY) btj CC (Brandon JAMAR) jhr CC (Jim RILEY) am CC (Alex MARION) pge.com axag CC Post Office Route OWGWPO02.HQGWDO01 nrc.gov OWGWPO04.HQGWDO01 nrc.gov OWGWPO03.HQGWDO01 nrc.gov TWGWPO01.HQGWDO01 nrc.gov nei.org pge.com Files Size Date & Time MESSAGE 1929 6/7/2007 7:34:49 AM Mime.822 3903 Options Expiration Date:
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Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006
> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.
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FAQ 07-0035 Creation Date 6/12/2007 9:06:08 PM From: "JAMAR, Brandon" <btj@nei.org>
Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 (Charles Moulton) nrc.gov OWGWPO02.HQGWDO01 RHG CC (Ray Gallucci) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)
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FAQ Number 07-0035 FAQ Revision 0 FAQ Title Bus Duct Counting Guidance for High Energy Arching Faults Page 1 of 2 FAQ 07-0035 Rev. 0 Plant: Harris Date:June 1, 2007 Contact: Dave Miskiewicz Phone:919.546.7588 Email:David.Miskiewicz@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG FRATF RIRWG BWROG PWROG Purpose of FAQ: Clarification/enhancement of Ignition Source counting guidance for High Energy Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application.
Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details: NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):
New attachment on interpretation issues Circumstances requiring guidance interpretation or new guidance:
Pilot discussions and benchmarking of NUREG/CR-6850 for Task 6, Fire Ignition Frequency, has shown inconsistency in the treatm ent of High Energy Arcing Faults (Bin 16). There is a need to resolve these issues to prevent future rework and to reduce burden associated with uncertainty treatment. This topic has impact on the NFPA-805 pilots, non-pilots and other users of NUREG/CR-6850.
The guidance provided in NUREG/CR-6850 for Ta sk 6, Fire Ignition Frequency (Section 6.5.6, Bin 16), states:
Bin 16 - High-Energy Arcing Faults (Plant-Wide Components): High-energy arcing faults are associated with switchgear and load centers. Switchyard transformers and isolation phase buses are not part of this bin. For this bin, similar to electrical cabinets, the vertical segments of the switchgear and load centers should be counted. Additionally, to cover potential explosive failure of oil filled transformers (those transformers that are associated with 4.16 or 6.9kV switchgear and lower voltage load centers) may be included in vertical segment counts of the switchgear.
FAQ Number 07-0035 FAQ Revision 0 FAQ Title Bus Duct Counting Guidance for High Energy Arching Faults Page 2 of 2 FAQ 07-0035 Rev. 0 The current guidance is silent regarding the treatment of bus duct. Preliminary discussions between the user community and the NUREG authors indicate that some specific guidance is needed to assure more consistent treatment of bus duct.
Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
Potentially relevant existing FAQ numbers:
This guidance is specific to the characteriza tion of bus duct for Bin 16 HEAF determination. The characterization and counting of electrical cabinets for Bin 16 determination is addressed by FAQ 06-0017.
Response Section:
Proposed resolution of FAQ and the basis for the proposal:
Because bus duct terminates at electrical cabinets, the HEAF counted for the electrical cabinet would also include those bus duct ev ents and no further counting is necessary.
Basis: The response is consistent with the gu idance currently provided in NUREG/CR-6850. Without additional guidance provided by the au thors of NUREG/CR-6850, there is no basis for when or how to count bus duct.
If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
Sunil, We had previously discussed hosting the September NFPA 805 FAQ meeting in coordination with this year's Fire Protection Information Forum in New Orleans, LA. We have made the accommodations available with the hotel for the proposed meeting date of September 20. Please let me know if this will be acceptable so I can finalize plans with the 805 task force and the hotel.
Thank you, Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006
> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.
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NFPA 805 FAQ meeting - September 2007 Creation Date 6/13/2007 9:19:22 PM From: "JAMAR, Brandon" <btj@nei.org>
Created By: btj@nei.org Recipients nrc.gov TWGWPO01.HQGWDO01 CEM4 CC (Charles Moulton) PWL CC (Paul Lain) nrc.gov TWGWPO04.HQGWDO01 SDW1 (Sunil Weerakkody)
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Thanks, Brandon This electronic message transmission co ntains 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 immedi ately by telephone or by electronic mail and permanently delete the original message.
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FAQ Monthly Call - June 21 Creation Date Wed, Jun 20, 2007 8:31 PM From: "JAMAR, Brandon" <btj@nei.org>
Created By: btj@nei.org Recipients nrc.gov CEM4 (Charles Moulton) nrc.gov SDW1 CC (Sunil Weerakkody) nei.org jhr CC (Jim RILEY)
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We have no comments ready, but I think we are going to suggest closure of four FAQs today (7, 12, 17, and 28)
I am attaching two handouts that detail updated ADAMS numbers of FAQs and meeting notices/summaries. Please distribute them to the task force.
Thanks, Chuck Charles Moulton Fire Protection Engineer NRR/DRA/AFPB Phone: 415-2751 Mailstop: O11A11
>>> "JAMAR, Brandon" <
btj@nei.org
> 6/20/2007 8:31 PM >>> Chuck, Do you have any FAQ updates (comments, approvals, etc.) you're prepared to share prior to the call tomorrow?
Thanks, Brandon This electronic message transmission co ntains 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 immedi ately by telephone or by electronic mail and permanently delete the original message.
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Re: FAQ Monthly Call - June 21 Creation Date 6/21/2007 11:30:54 AM From: Charles Moulton Created By:
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FAQs FAQ # Rev. ADAMS # 06-0001 0 ML061440419 06-0002 0 ML061440420 1 ML063170357 2 ML063350515 06-0003 0 ML061440422 1 ML063170355 06-0004 0 ML061440430 06-0005 0 ML062350095 1 ML063180544 06-0006 0 ML062350109 1 ML063170360 2 ML063540308 06-0007 0 ML062350121 1 ML070030325 2 ML070510442 3 ML071550408 06-0008 0 ML062860250 1 ML070510499 2 ML070800007 3 ML071020160 Att. ML071020169 4 ML071080099 5 ML071340180 06-0011 0 ML062890271 1 ML070510505 06-0012 0 ML062860255 1 ML063170362 2 ML070850610 3 ML071380228 4 ML071570260 06-0016 0 ML070030348 1 ML071020174 06-0017 0 ML070030383 1 ML071350432 2 ML071570255 06-0018 0 ML070030427 1 ML071020181 06-0019 0 ML070030437 1 ML071340184 06-0020 0 ML070030443 1 ML071340188 06-0021 0 ML070030457 1 ML071340192 06-0022 0 ML070030459 06-0023 0 ML070030470 06-0024 0 ML070030472 06-0025 0 ML070030476 1 ML071340194 06-0026 0 ML070030480 06-0027 0 ML071380236 06-0028 0 ML070030489 1 ML071340195 2 ML071550415 07-0031 0 ML071380238 07-0035 0 ML071650151
FAQ Meeting Notices and Summaries Month Doc. ADAMS # July MN ML061870560 MS ML062080126 August MN ML062200116 MS ML062400278 September MN ML062510281 MS ML062900031 October MN ML062850488 MS ML063350031 November MN ML063120170 MS ML063410377 December MN ML063390132 MS ML070220420 January MN ML070040380 MS ML070360630 February MN ML070290267 MS ML070640531 March MN ML070640417 MS ML071090164 April MN ML070920255 MS ML071420174 May MN ML071220176 MS ML071510425 June MN ML071440064 Chuck, Please find the attached FAQ Log updated per today's meeting. If you have any questions please let me know.
Thanks, Brandon Brandon T. Jamar Project Manager, Engineering Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006
> www.nei.org P: 202-739-8043 F: 202-533-0185 E: btj@nei.org nuclear. clean air energy.
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FAQ Log 21-2007 Creation Date 6/21/2007 9:07:41 PM From: "JAMAR, Brandon" <btj@nei.org>
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Reviewer Submitted Working Plant Licensee ContactNRCNEI TFNRCSubmittal DateTentativeFinal06-000100 Alternate method for Engineering Evaluations Add in clarification that fire affected train manual actions are 'allowed' and
therefore do not require evaluation.
NRC rejected the statements regarding SER approval without Exemptions Tentatively approved.
Su p erceded b y FA Q 06-0012.Closed Harris Nuclear Plant Ertman Submitted to NRCClosed4/25/2006 Closed ML063480169 Closed ML06348016906-00021c1c NEI 04-02 Section 5.3.3 and App. I, Order of Questions
for Change Analysis
Screening Change Figure 5-1, text, and Appendix I to ask the Chapter 4 questions before
Chapter 3 questions.
NRC agreed in principle, however wanted wording clarified to "make clear the distinction
between Chapter 3 requirements that are
subject to Chapter 4 evaluations versus the
Chapter 3 requirement that are independent of
Chapter 4" added clarification to 'boxes' at end
of Questions 1 and 2 in Change Analysis Form NRC added 'included required recovery actions to text of 5.3.3 and added 'including Human
actions' to Question 4.e of Change Analysis
Form Task Force a g rees to first request. Task force is evaluating the addition of NRC rejected the
statements regarding SER approval without
Exemptions Committed to revise based on RIS 2006-10 and NRC Public Meetin g June 9, 2006. See RIS 2006
-12 'human actions' to the risk screening
questions. - tentatively approved - will resubmit
10/26/06 Closed Harris Nuclear PlantErtmanGallucci Submited to NRC Closed 4/25/2006 10/26/200610/26/2006Closed06-00031b1bChange Analysis ScreeningChange 'greater than minimal' to
'potentially greater than minimal' Closed Harris Nuclear Plan tErtmanGallucci Submited to NRC Closed 4/25/2006 10/26/200610/26/2006Closed06-000401 Clarify NFPA 805 Chapter 4 and 3 relationship for
'required' FP
systems/features How fire protection systems and features transition is highly dependent on how
they are 'required' to meet the nuclear
safety criteria of Chapter 4.
Note NRC was using NEI 04-02 Revision 2H figures and not figures in FAQ 06-0004 NRC to re-review in appropriate context &
provide status on 10/26/06 Received NRC comments 11/29/06. Resubmitted to NRC and returned with comments. Currently
under TF review.MHNPErtmanFrumkin TF to resubmit July 2007 in conjunction w/ B.3 tables Comments provided on R0 5/12/200606-000511 Guidance on FPP-related changes NEI 04-02 does not provide guidance what should be considered a FPP-related
change or not. Since failure to obtain
NRC pre-approval for using risk
reductions from a non-FPP related
change would be contrary to the g uidance in RG 1.205, additional g uidance should be provided to clarify what is
considered a FPP-related change once
NFPA-805 i s im p l e m e n ted.FAQ has been revised.
Resubmit to NRC 11/30/06 - waiting for NRC response as of June 07 NRC tentatively scheduling comments for July meetingHHNPErtmanFrumkin TF waitin g for NRC comments Plan to comment 8/24/2006 11/30/200606-000622 High-low pressure interface definition and NEI 00-
01/NFPA 805 discrepancies Definition of High-Low Pressure interface is not consistent between NFPA 805 and
NEI 00-01. Need to provide clarification.
Received NRC comments on R1, R2 Resubmit 12/19/06 - Definition change per NRC request.Closure process has begun. Draft closure letter was commented on by TF.
NRC acce p ted TF clarification.MDukeBarrettDinh Draft closure letter issued 8/24/2006 12/19/2006 1/18/200706-000733 NFPA 805 Chapter 3 Requirements for Fire
Brigades Need clarification on when NFPA 600 or NFPA 1500 apply. Also clarify if
requiements apply to interior structural
fire fighting brigade.
FAQ to be revised to mark up NEI 04-02 to show the addition of an appendix for NFPA 805
clarifications.
NRC R2 comments b y Ma y 0 7MHNPHolderLain R3 submitted to NRC Comments provided on R2 2/15/2007 5/21/2007 6/21/200706-000855 Alternate method for Engineering Evaluations Many Generic Letter 86-10 evaluations exist at facilities today. Transition of
these existing evaluations is essential for
the success of the Pilot Plants. In
addition the use of engineering
evaluations for Chapter 3 issues post
transition needs to be clarified.
Presented 9/28/06 Comments received from NRC on 11/29/06.
Clarification call scheduled. Resubmit to NRC by
02/07 R4a comments received and will incorporate
NRC recommendations.
R5 by early May.
NRC stated at last meeting they would be submitting additional comments. Awaiting NRC
comments.H1NEIRatchfordFrumkinR6 planned Comments provided on R5 2/15/2007 3/20/2007
3/30/2007 5/8/2007 Approval Status RevisionFAQ #Summary Submitter Actions and Notes Name Priority Page1 of 5 06-0009NEI 04-02 Typo Corrections Editorial changes to NEI 04-02Will submit with overall revision at end of year.LNEIKleinsorg 06-0010 Incorporate Regulatory Guide 1.205 Baseline
concept into NEI 04-02 Based on changes to Regulatory Guide 1.205, NEI 04-02 needs to reflect the
baseline risk Projected submittal 3Q 2007LHNPErtman06-00111b1b Clarify III.G.3 Compliance Transition Alternative Shutdown is not specifically addressed in NFPA 805.
Approved by Task Force Reviewers. Submitted to NRC 9/28/06. Under NRC review.
Comments received from NRC on 11/29/06.
Need time for TF review. Rewrite
w/consideration for NRC comment #2 -
Resubmit Feb. '07.
Awaiting NRC closure.AttemptingtoprovidecommentsbyJulyHNEIJutrasFrumkin TF waitin g for NRC comments on R1b Comments provided on R0 2/15/200706-001244 Clarify Manual Action Transition in Appendix B Some manual actions are either allowed by the current regulation or have been Submitted to NRC 9/28/06. Resubmit 10/26/06 as combined with FAQ 06-0001 Comments received from NRC on 11/30/06.
With TF for review. Revision by May '07. NRC
comments on R2b warrant R3. Will have by May
07 Additional internal comments to be included in new FAQAwaitingNRCfinalcomments/closure.HNEIKleinsorgBarbadaro R4 submitted to NRC Comments provided on R2b 9/28/2006 10/26/2006 3/22/07
5/17/07 6/5/07 6/21/2007 06-0013 Clarify Chapter 4 Methodology Transition
Process Bases on Pilot Plant
Results Will be presented at 2007 HNP Pilot meeting.
Duke to submit end of Second Quarter 2007
See FA Q 07-0039LHNPErtman06-00140Cumulative RiskRegulatory Guide 1.205 requires tracking of chan g es to assess cumulative risk. NEI 04-02 does not provide guidance on this
issue With FPRA TF for comment - 12/14/06 FAQ by 4Q 2007LHNPMiskiewicz FPRA TF has action06-00150 Guidance on not-red determination Process for determining if non-compliances found during the transition
process are 'not red' needs to be
simplified.
Sent to Task Force for review 11/30/06 With FPRA TF for review 12/14/06
Ken Heffner to provide regulatory input to this FAQ by 12/14/06 Amir Afzali to provide PRA screening criteria for
'not red' determination by 12/14/06 Amir Afzali to discuss with PRA Task Force to increase focusProvideFAQby1stweekinJuly2007HNEIAfzali FPRA TF has action06-001611 Ignition Source counting guidance for Electrical
Cabinets Clarification/enhancement of Ignition Source counting guidance for Electrical
Cabinets in NUREG/CR-6850, supporting
NFPA-805 Fire PRA application.
Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.
Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.
Potential disagreement on the examples
provided in the FAQ were discussed by Ray
Gallucci of the NRC.
Kiang Zee provided feedback that the examples were intended to be taken collectively and were
intended to be drawn to scale.HHNPMiskiewiczGallucci Submitted R1 to NRC R1 accepted.
Closed 12/19/2006 Page2 of 5 06-001722 Ignition Source counting guidance for High Energy
Arcing Faults (HEAF)
Clarification/enhancement of Ignition Source countin g g uidance for Hi g h Ener g y Arcing Faults (HEAF) in NUREG/CR-6850, supporting NFPA-805 Fire PRA
application.
Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.
Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.
Preliminary comments indicated a recommending splitting of HEAFs into a low
voltage and high voltage bins. In addition, a
new frequency is being considered for bus
ducts. HHNPMiskiewiczReviewer Submitted R2 to NRC Comments provided on R1 12/19/2006 05/15/2007 6/4/2007 6/21/200706-001811 Ignition Source counting guidance for Main Control
Board (MCB)
Clarification/enhancement of Ignition Source counting guidance for Main
Control Board (MCB) in NUREG/CR-6850, supporting NFPA-805 Fire PRA application Presented at November 2006 pilot meeting Submitted to Task Force 11/30/06.
Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.
Preliminary comments indicated more focus on counting just "horseshoe" cabinets as MCBs.HHNPMiskiewiczGallucci Submitted R1 to NRC R1 accepted.
Closed 12/19/200606-001911 Define "power block" and "plant"Define where used in Chapter 3, "power block" and "plant" are intended to mean
"areas in which a fire could j eopardize the ability to meet the performance criteria
described in section 1.5."
3.3.1.2 Control of Combustible Materials (1)Wood used within the power block
shall be listed pressure-impregnated or
coated with a listed fire-retardant
application.
Exception: Cribbing timbers 6 in. by 6 in.
(15.2 cm by 15.2 cm) or larger shall not
be required to be fire-retardant treated.
Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Comments to be provided by NRC prior to Feb.
2007 meeting.
TF will submit new revision by May 2007
Awaiting NRC Final Review and Comments -
estimate July meetingHHNPHolderDinh R1 submitted to NRC Comments provided on R0 12/19/2006 5/8/200706-002011Definition of "applicable"(6) Controls on use and storage of flammable gases shall be in accordance
with applicable NFPA standards.
Presented to Task Force 11/30/06 CLOSED 5/17/07 HHNPHolderDinh R1 submitted to NRC Comments provided on R0 12/19/2006 5/8/200706-00211a1a Clarify that air drops are acceptable.
3.3.5.2 - Only metal tray and metal conduits shall be used for electrical
raceways. Thin wall metallic tubing shall
not be used for power, instrumentation, or control cables. Flexible metallic
conduits shall only be used in short
lengths to connect components.
HNP as well as other plants have exposed cable drops ~ 3' in length.
Presented to Task Force 11/30/06 CLOSED 5/17/07 LLHNPHolderDinh R1 submitted to NRC Comments provided on R0 12/19/2006 5/8/200706-002200a Identify a list of typical flame propagation tests which are
considered acceptable.
3.3.5.3 - Electric cable construction shall comply with a flame propagation test as
acceptable to the AHJ.
Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.
Additional info on applicability of test requested by NRC.MANOPuckettMoulton TF waitin g for NRC comments Plan to comment 12/19/200606-002300 Grant exception for Diesel Generator Day Tanks located
within Diesel Generator
Buildings.
3.3.8 Bulk Storage of Flammable and Combustible Liquids - Bulk storage of
flammable and combustible liquids shall
not be permitted inside structures
containing systems, equipment, or
components important to nuclear safety.
As a minimum, storage and use shall
comply with NFPA 30, Flammable and
Combustible Li q uids Code.
Presented to Task Force 11/30/06 Submitted to NRC 12/19/06
NRC questioned if issue warranted a FAQ since it is part of plant systems WITHDRAWN 5/17/07 LLHNPHolderLain WITHDRAWN 5/17/07 Proposed withdraw 12/19/2006 Page3 of 5 06-002401 Define what "adequate clearance" is.
3.3.11 Electrical Equipment - Adequate clearance, free of combustible material, shall be maintained around energized
electrical equipment.
Need to provide a clearer definition of
'adequate clearance'. Could be based on
OSHA 3ft requirement.
Presented to Task Force 11/30/06 Submitted to NRC 12/19/06
Preliminary verbal comments provided by NRC.
Initiator resubmitted to Task Force planned submittal to NRC first week of July MHNPHolderOudinot TF reviewing R1, planned submittal Comments provided on R0 12/19/200606-00251b1b Define minimum acceptable pre-plan scope.
3.4 Industrial Fire Brigade - 3.4.2.1 - The plans shall detail the fire area
configuration and fire hazards to be
encountered in the fire area, along with
any nuclear safety components and fire
protection systems and features that are
present.Suggest define more clearly what the minimum acceptable pre-plan scope is. Consideruseofexistingguidance.
Presented to Task Force 11/30/06 R1b updated
4/19 Awaiting NRC Review and comments - by July meetingMHNPHolderBarbadaro R1 submitted to NRC Comments provided on R0 12/19/2006 5/8/200706-002600 Clarify NFPA code requirements for gear
maintenance 3.4.4 Fire-Fi g htin g Equipment - Protective clothing, respiratory protective
equipment, radiation monitoring
equipment, personal dosimeters, and fire
suppression equipment such as hoses, nozzles, fire extinguishers, and other
needed equipment shall be provided for
the industrial fire bri g ade. This equipment shall conform with the applicable NFPA
standards.
Clarify that intent is for design and purchase of equipment. NFPA code
requirements for gear maintenance is not
applicable.
Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Preliminary verbal comments provided by NRC.
WITHDRAWN 5/17/07MHNPHolderOudinot WITHDRAWN 5/17/07 Proposed withdraw 12/19/200606-002700 Clarify the "where provided" statement.
3.7 Fire Extinguishers - Where provided, fire extinguishers of the appropriate
number, size, and type shall be provided
in accordance with NFPA 10, Standard for
Portable Fire Extinguishers. Extinguishers
shall be permitted to be positioned
outside of fire areas due to radiological
conditions.
Part of NFPA 10 is placement / travel distances for extinguishers. The 'where
provided' statement needs clarification.
To TF by Feb 07 Not discussed on 1/18/07
Rev 0 sent to NRC on 5/17/07
Awaiting NRC Review and commentsMANOPuckett Submitted R0 to NRC 5/17/200706-002822 Clarify intent of "familiarization with plant fire
prevention procedures, fire
reporting, and plant
emergency alarms"
regarding scope of or depth
of the training.
3.3.1.1 General Fire Prevention Activities -
(1) Training on fire safety information for
all employees and contractors including, as a minimum, familiarization with plant
fire prevention procedures, fire reporting, and plant emergency alarms Clarify the intent of 'familiarization'.
Presented to Task Force 11/30/06 Comments from Task Force to initiator by 12/14/06 Submitted to NRC 12/19/06 Not discussed on 1/18/07
Submitted to NRC 5/21/07MHNPHolderOudinot R2 submitted to NRC Comments provided on R1 12/19/2006 5/8/2007 5/21/2007 6/21/200706-00290a Clarify zone of influence for NUREG 6850 Task 8.
FDT spreadsheets are used to provide a zone of influence.
Submitted to the task force: 12/19/06 Discuss at January 24, 2007 FPRA meeting
Not discussed on 1/18/07
WITHDRAWN 6/21/07 LHNP Thompson WITHDRAWN 6/21/07 07-0030 Risk of recovery actions 4.2.4 Clarification of risk impact of recovery actions, to include extension of
existing HRA scenarios FAQ by 3Q 2007MHNPErtman 07-0031 00 Misc Binning Issues Miscellaneous ignition frequency binning issues. Questions arise during ignition
frequency counting, such as: MOV
motors, Hydraulic actuators for valves, Transformers Draft to NEI TF for April 2007.
Awaiting NRC review and comments - been sent to ResearchMHNP Miskiewicz Submitted R0 to NRC 5/17/2007 07-0032 0 10CFR 50.48(a) and GDC 3 clarification Clarify that satisfyin g 10 CFR 50.48(c) will satisfy 10 CFR50.48(a) and GDC3 Draft to NEI TF for May 2007.
FAQ to be submitted by JuneMHNP HolderTF reviewing Page4 of 5 07-0033 0 Review of Existin g Engineering Equivalency
Evaluation s Discuss how EEEE will be reviewed and
summarized for transitionDraft to NEI TF for May 2007.MHNP HolderTF reviewing 07-0034 0 Determination of non-vented Cabinets Clarification of guidance for deterining if an electrical cabinet can be dispositioned
as non-vented Draft to NEI TF for May 2007.
FAQ submitted by JuneMHNP MiskiewiczTF reviewing 07-0035 00 Bus Duct counting guidance for High Energy Arcing Faults Split from FAQ 06-0017 - Bus duct July 13 meeting between industy (PRA Task Force) and NRC Task ForceMHNP Miskiewicz Submitted R0 to NRC 6/12/2007 07-0036 Define compliance cate g ories for Table B-1 NEI 04-02 update to include lessons learned on Table B-1 p rocessDraft FAQ for June 2007 TF MeetingHHNP Holder 07-0037 Environmental considerations for equipment Provide g uiudance re g ardin g environmental considerations of other
e q ui p ment in the fire affected areaDraft FAQ for August 2007 TF MeetingMHNP Holder 07-0038 Lessosn learned for OMA, MSO and FPRA Incorporate pilot lessons learned for preemptive manual actions, MSO expert
panel and Fire PRA processes into NEI 04-
02Draft FAQ for July 2007 TF MeetingHHNP Ertman 07-0039 Provide update of NEI 04-02 B-2 and B-3 Processes NEI 04-02 update to include lessons learned on Table B-2 and B-3 processesDraft FAQ for July 2007 TF MeetingHHNP Ertman Page5 of 5