ML071570260

NFPA 805 Transition Pilot Plant FAQ 06-0012, Revision 4

ML071570260
Person / Time
Site:	Harris
Issue date:	03/22/2007
From:	Kleinsorg E Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
References
06-0012, Rev. 4
Download: ML071570260 (12)

Text

FAQ Number 06-0012 Revision 4 FAQ Title Determining Manual Actions that Require a Change Evaluation during Transition Plant: Harris Nuclear Plant Date: 03/22/2007

Contact:

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

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

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

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

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

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

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

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

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

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

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

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

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

None.

Potentially relevant existing FAQ numbers:

This FAQ supersedes FAQ 06-0001.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

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

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

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

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

Operator Manual Actions on Fire Affected Train.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Revise NEI 04-02 as shown in the attachment.

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

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

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

4.3.2 Nuclear Safety Performance Criteria Transition Review

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

Attachment Page 5 of 12

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

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

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

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

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

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

not disable Function?

Bin G Bin F Bin E No Action is Feasible?

Yes Operator Action Not Allowed /

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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