M080717, M080717-Commission Briefing Slides/Exhibits Briefing on Fire Protection
| ML082000991 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Harris, Wolf Creek  |
| Issue date: | 07/17/2008 |
| From: | Baxter D, Canavan K, Donahue J, Muench R Duke Energy Carolinas, Electric Power Research Institute, Progress Energy Carolinas, Wolf Creek |
| To: | NRC/SECY |
| References | |
| M080717 | |
| Download: ML082000991 (40) | |
Text
COMMISSION BRIEFING SLIDES/EXHIBITS BRIEFING ON FIRE PROTECTION JULY 17, 2008
Nuclear Regulatory Commission Briefing on Fire Protection July 17, 2008 Mr. Richard A. Muench President and CEO Wolf Creek Nuclear Operating Corporation 1
Discussion Topics
- Fire Induced Circuit Failures
- NFPA 805 Transition 2
- Licensees working to complete corrective actions by March of 2009
- NFPA 805 transition and resolution of fire induced multiple spurious circuit failure issue impacts resolution of many operator manual action items 3
Fire Induced Circuit Failures
- Status Agreement on conceptual approach Implementation details addressed in future meetings
- Use of risk to address associated circuit issues without exemption or LAR must be included 4
Fire Induced Circuit Failures
- Industry I NRC meetings will continue
- Industry actions in the interim Developing implementation details Guiding use of risk insights for resolution of issues Preparing draft revision to industry guidance
- Goal - receive NRC endorsement 5
Fire Induced Circuit Failures
- Use of risk to address fire induced circuit failures in associated circuits
- Regulations do not prohibit
- Use of risk is consistent with the Commission's Policy Statement on use of PRA (60FR42622)
- Failure to allow could result in
- actions that could raise overall plant risk,
- need for new exemptions or LAR's and/or
- costly modifications for low risk and low safety-significance items 6
NFPA 805 Transition
- Pilot plants (Oconee and Harris) license amendment requests submitted
- Activities necessary to enhance regulatory certainty
- Refinement of LAR template
- Resolve PRA issues Minimize requests for additional information 7
Fire PRA
- Fire PRA is a challenge
- Preliminary results are conservative
- Goal in PRA is to be more realistic
- Industry and NRC Staff addressing items seen as main contributors to conservatism
- Goal. is to resolve by late 2008 8
N*FPA 805 Enforcement Discretion
- Extension to enforcement discretion is important
- Limited qualified resources
- Incorporate lessons learned from pilot plants
-Assure consistent licensing bases
- Near term Commission decision requested 9
N Acronyms
" NFPA National Fire Protection Association
" LAR License Amendment Request
- PRA Probability Risk Assessment
/
10
NFPA 805 Lessons Learned Shearon Harris Nuclear Plant.
July 17, 2008 Joe Donahue Vice President Engineering I0 N tICI Progress Energy 1
Fire Protection Defense In Depth o Prevent Fires o Prompt Detection Of Fires o Prompt Control and Suppression Of Fires o Separation Of Safety Systems QProgress Energy 0 Ný Page 2
Fire PRA Implementation o Extensive Walkdowns Identified Potential Fire Sources o 4000+ Fire Scenarios Evaluated o NRC Team Review o Industry Expert Peer Review c~NudL A.A G
G Ottr Criiv UProgress Energy Page 3
Fire PRA Implementation
- Fire PRA Is Acceptable For Use
- Other Inputs are Used for Decision Making
- Process Improvements Provided To NRC and Industry NLICI I CProgress Energy Page 4
Harris NFPA 805 Fire Protection o Implements classical requirements o Implements nuclear safety performance criteria o Addresses fire safety during, non-power operations o License amendment request submitted o Transition resources were greater than originally estimated
'10,ip;,, Progress Energy Page 5
Generic Issues Addressed o Hemyc/MT Fire Wrap Qualification o Operator Manual Actions o Multiple Spurious Operations CProgress Energy Page 6
Harris Physical Plant Changes o New Cable Raceway Wrap o New Fire Rated Cable o Upgrades To Hemyc/Mt Wrap o Additional Equipment Separation o Additional Incipient Fire Detection In Critical Electrical Panels K Progress Energy Page 7
Summary o Transition To NFPA 805 Is Improving Fire Protection Program D Resolution Of Generic Fire Protection Issues D Physical Plant Modifications Already Completed D Additional Modifications Being Implemented Np
- Progress Energy Page 8
b Summary NFPA 805 License Amendment Request Submitted C On Track To Complete Implementation By End Of 2010 6ou Nue CProgress Energy Page 9
NFPA 805 Lessons Learned Oconee Nuclear Station July 17, 2008 David Baxter Site Vice President
,Duke
'Energy
NFPA 805 Lessons
- Oconee showed that NFPA 805. is an excellent fit for the older -nuclear stations.
- A good solid Safe Shutdown Analysis documenting deviations with Fire Regulations should be in place to start transition
- Duke 7;Energy
NFPA 805 Lessons
- The pilot process was very complicated, time consuming and expensive.
- Document and calculation reviews took much longer than expected due to new program.
Duke
~Energya
NFPA 805 Lessons
- Oconee required separate Fire PRA models.
oNUREG-6850 turned out to be somewhat conservative, but provided a good foundation to build on.
6iDuke
!FEnergy
D NFPA 805 Lessons
- Although further tuning is planned, the Fire PRA's models realistically modeled the plant.
- The process of transition is very man-power intensive Duke 7Energy
r ELECTRIC POWER R RESEARCH INSTITUTE BRIEFING ON FIRE PROTECTION ISSUES Ken Canavan Senior Program Manager Risk and Safety Management July 2008
- Consistent with the PRA Policy Statement "Use of the PRA technology should be increased in all regulatory matters to the extent supported by the state of the art ... "
- Committed to supporting a risk-informed, performance based approach to fire protection
- Realistic methods
- Realistic input
- Monitoring and feedback process 2 I VS' C IE
© 2008 Electric Power Research Institute, Inc. All rights reserved.
Fire PRA Methodology Development
- NUREG/CR-6850 is guidance for developing a Fire PRA
- NRC-RES / EPRI collaboration (EPRI 1011989)
- Only pieces piloted (initially) 0 Two Fire PRA Pilots
- Initial results are conservative
- Not unexpected
- Result of individual minor to moderate conservatisms ELECTRIC IPOW E
© 2008 Electric Power Research Institute, Inc. All rights reserved. 8m ira REEACHINTITUTE
Fire PRA Methodology Issues,
- Fire Ignition Frequencies
" Credit for Incipient Detection
" Treatment of Large Oil Fires
" Fire Growth and Propagation Models
" Credit for Fire Suppression
" -Hot Short Susceptibility, Probability and Duration
- High Energy Arching Faults
" Cable Tray Fire Modeling
©0I ELETRICPPWýTR (D 2008 Electric Power Research Institute, Inc. All rights reserved. 4_ = 0 RESEACH INSTITUJTE
Other Issues, Progress and Challenges
- Other Issues
- Shortage of Trained Risk Personnel
- Practical modeling limitations
- -Progress
- Education of Risk Professionals and Fire PRA Methods Training
- EPRI / NRC-RES working to refine Fire PRA methods Challenges
- Available resources
- Time constraints
© 2008 Electric Power Research Institute, Inc. All rights reserved.
'2IELECT111POWER RE SEARHIN~STITUTE
SU.S.NRC Uniiced Staces Nuclear Regulatory Cormmission ProtectingPeople and the Environment Commission Briefing on Fire Protection Issues July 17, 2008
Agenda
" Introduction
-Jack Grobe, NRR
" Current Issues
- Mark Cunningham, NRR
- Summary
- Jack Grobe, NRR 2
Introduction
- Fire protection at operating reactors
- Steering Committee activities
- Remaining issues
- Fire barrier performance
- Fire-induced circuit failures
- Implementation of NFPA 805 3
Fire Barrier Performance
- Protection of electrical equipment required
" Inspections and research identified deficiencies
" Actions were taken
" Documenting closure 4
" Inspections identified inconsistencies RIS 2006-10 clarified regulatory positions
" Completing closure
- Plant-specific resolution
- Staff follow up 5
Fire-Induced Circuit Failures
- SECY-08-0093 provides approach
- Methods for protecting safe shutdown capability
- Enforcement discretion proposal
- Achieving closure
- Finalize and implement guidance
- Complete direct current circuits research
- Implementing closure plan 6 I
NFPA 805 Implementation
- Alternative approach
- Risk informed
- Performance based
- 47 units committed to transition
- Pilot plant license amendments under acceptance review 7'
NFPA 805 Implementation
- Infrastructure being finalized
- Technical methods and standards
- Regulatory Guidance Resource planning and allocation Communications 8
I NFPA 805 Implementation
- Implementing closure plan
-Finalize guidance
- Standardize review process
- Share lessons learned
- Receive and review amendments Licensees implement changes Staff inspects implementation 9
Summary
- Maintain a stable and predictable regulatory environment
- Communicate with licensees and public 10