Change Notice 00-020

Issue Date: 09/22/00


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Number Date Number Date
1. IP 71111.05 04/03/00 IP 71111.05 09/22/00
TRAINING: No special training requirements have been identified for any documents issued with this change notice.
REMARKS: 71111.05 (Fire Protection) has been revised in response to industry initiative (BWR Owners Group and NEI). This revision is the result of concerns expressed by licensees regarding inconsistences in the design bases that address circuit analyses requirements. Specifically, the handling of hot shorts within associated circuits and the resulting spurious actuation of equipment designated for safe shutdown. The industry effort consisted of developing a methodology for testing and analyzing circuit behavior during a fire. This process will be reviewed by the NRC and should be completed within a one year period.
For the interim period we will continue to implement the inspection procedure with the stated restrictions. Comments have been incorporated from all the regional fire protection inspectors. Technical support will be available from the Plant Systems Branch (SPLB) through telephone contacts. The following changes have been incorporated in the procedure.
The scope has been reduced while criteria for review of fire-induced circuit failures of associated circuits is the subject of a voluntary industry initiative. Temporarily, the inspector is not required to address associated circuits issues as a direct line of inquiry nor develop associated circuits inspection findings (with certain exceptions contained in Section 02.03 of this procedure). However, in certain instances. associated circuits issues may arise unavoidably and indirectly during the inspector's review of safe shutdown system selection, redundant train separation, and the provision of independent alternative shutdown capabilities ("byproduct" associated circuits issues). These byproduct associated circuits issues shall be documented as unresolved items (URIs) awaiting generic resolution of the related associated circuits issues. The inspection report should reflect the temporary limitation in inspection scope, and the potential for "byproduct" associated circuits issues to exist as long-term (>180 day) unresolved items (URIs).
The inspector is not precluded from developing findings related to purely deficient licensee performance in these areas. Thus for example, findings are not precluded where they are associated with mathematical errors or invalid plant configuration assumptions. Neither is the inspector precluded from developing findings in the specific associated circuits area of fuse/breaker coordination. However, the restriction does extend to IN 92-18 and multiple high impedance fault (MHIF) concerns (subjects of the current voluntary industry initiative).
Section 02.03 of this procedure has been modified to reflect the sampling nature of the inspection program. The inspectors should conduct an assessment of fuctionality of selected aspects of the alternate shutdown path and the associated fire protection features. This constitutes a fully completed triennial inspection effort for the alternate shutdown path.


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