ML050250157
| ML050250157 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 12/06/2004 |
| From: | Barrett H, Brewer D, Henneke D Duke Energy Corp |
| To: | Office of Nuclear Reactor Regulation |
| Olshan L N, NRR/DLPM, 415-1419 | |
| References | |
| TAC MC5186, TAC MC5187, TAC MC5188 | |
| Download: ML050250157 (39) | |
Text
laDuke 5fEnergy..
Duke Power Appendix R Reconstitution Oconee (ONS)
Catawba (CNS) 9f 9-9-9--9-9-T McGuire (MNS)
December 06, 2004
liiDulke MVEnergYy Appendix R Reconstitution Duke Participants Appendix R Working Group Harry Barrett - Appendix R Working Group Lead (ONS)
David Goforth - Appendix R Engineer (CNS)
Bob Johansen - Appendix R Engineer (MNS)
Dennis Henneke - PRA Engineer (NGO - Severe Accident Analysis)
James Oldham - Fire BEST Lead (MNS)
Reene' Gambrell, Regulatory Compliance (ONS)
Graham Davenport -Regulatory Compliance Manager (ONS)
George Mc Aninch - Design Basis Group Manager (ONS)
Duncan Brewer - SAA Manager (NGO) 2
Zuuxe Appendix R Reconstitution Agenda Purpose Goals
Background
Safe Shutdown Methodology Manual Action Process Issue Resolution Process Configuration Management Armored Cable Fire Testing Schedule Summary 3
Duke Energy. Purpose of Meeting Duke Power Appendix R Reconstitution Project Establish a Dialog to discuss potential issues Design/Licensing Basis Improvements Multiple Spurious Actuations Manual Actions Armored Cable Fire Testing 4
UUKM Goals of Appendix R r Enerfy Reconstitution Proj ect Strengthen Appendix R Programs to bring clarity Clear Up design and licensing issues
- Improve Design and Licensing Documentation Quality and Completeness Improve safety (do the right thing) 5
Duke Energy5.
B ackground Recent experience with Appendix R Safe Shutdown analysis at all three sites indicated opportunities to improve Started to respond to issues separately at each site ONS performed an Appendix R Program Self Assessment in 2002 ONS Initially Created Reconstitution Project to trace cables and correct documentation deficiencies Audit/Inspection findings and newly identified compliance issues at all units eventually drove the formation of 3-Site Appendix R Working Group Reconstitution planned for all Duke units 6
Energy,,
Background - Continued Duke Unique Features and Approaches Armored Cable Longer time to damage, lower spurious operation probability, no cable-to-cable interactions
- Exclusionary Analysis Did not originally trace all cables, only opposite/available train cables for each fire area Oconee Facility Design Class 1 E Electrical Distribution located in most significant fire area (Turbine Building)
No train separation All trains of EFW in Turbine Building 7
Duke Energy.
Background - Continued Duke Unique Features and Approaches Standby Shutdown Facility Bunkered facility with separate power and provide RCP seal cooling and decay heat
- Single Spurious design basis Single, worst case spurious, addressed in documents but not in SER Three different licensing criteria (Appendix Appendix R and NUREG 0800)
Standardization is difficult control to removal design R, post 8
Appendix R Reconstitution IF g Safe Shutdown Methodology Based on methodology outlined in NEI 00-01
- Incorporates Industry Operating Experience 1-NRC RIS 2004-03
- NEI 00-01 Rev. 1 NEI 04-06 9
bDuke Appendix R Reconstitution Energy.
Safe Shutdown Methodology -
continued Split into Three Phases:
Phase I - Safe Shutdown Equipment List (SSEL) and Logic Diagrams Phase 11 - Cable and Fire Area Analysis -
identifies all cable/component "hits" Phase Ill - Performance Based/Risk Informed analysis of multiple spurious actuations 10
i Duke
'Energy..
Appendix R Reconstitution Safe Shutdown Methodology -
continued Phase I Define Safe Shutdown Functions, Systems and Components Safe Shutdown components listed in a Safe Shutdown Equipment List (SSEL)
System and Component Dependencies are documented on System and Component Logic Diagrams 11
Duke Appendix R Reconstitution Energy. Safe Shutdown Methodology -
continued Safe Shutdown Analysis Phase I Define Appendix R Requirements J
Identify equipment information Related to safe shutdown analysis Identify Safe Shutdown Functions Identify Dependencies between Equipment, support equipment Identify Systems that can perform And systems These Safe Shutdown Functions I
Develop a list of safe shutdown Document Document Equipment in these systems Information Information in System &
in Relational Component Database Logic Diagrams (SSEL) 12
hDuke Appendix R Reconstitution Energy. Safe Shutdown Methodology -
continued Phase I I Identify cables for each component Identify routing for each cable Routing through each Fire Area documented Fire Area damage assessments performed Results of damage assessments used with Logic Diagrams to determine impact on Safe Shutdown Functions Loss of Safe Shutdown Functions addressed through Appendix R Issue Resolution Process for spurious actuations within Design Basis 13
Appendix R Reconstitution Safe Shutdown Methodology -
continued Safe Shutdown Analysis Phase 11 I
SSEL l
Identify circuits required for Operation of each safe Shutdown equipment Identify interlocked circuits And cables whose failure may Cause spurious actuations Assign cables to equipment I Identify routing of cables Identify location of Cables by fire area Determine equipment impacts To safe shutdown functions For fires in each fire area 14
iDuke E :nergy.
Appendix R Reconstitution Safe Shutdown Methodology -
continued
... Phase III Results of Phase 11 are combined with an extensive Multiple Spurious Review to address completeness of multiple spurious population Deterministic Analysis Output (Phase 11)
PRA Cut Set Review Expert Panel Review Loss of shutdown functions outside Design Basis also addressed through Appendix R Issue Resolution Process 15
Duke Appendix R Reconstitution Energy. Safe Shutdown Methodology -
continued Safe Shutdown Analysis Phase Ill Phase 11 Results Qualitative Equipment Impacts Pre-Screening By Fire Area Identify circuits and PRA P&IDs & SSD Logic Expert Panel Routing affecting Review Diagrams review Review Combination Of concern s,_Evaluate risk significance Compile Component Of combination of concern Combinations of I
Concern Appendix R Issue Resolution Process 16
rSM Manual Action Process 3-Site Engineering Guidance Document Feasibility Criteria criteria)
(based on NRC interim
- Thermal-Hydraulic Analysis i-Graphical approach to document timelines (MS Project) 17
k Duke F1 nergy.
Manual Action Process -
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Duke EnergyN. Issue Resolution Process Appendix R Issue Resolution Process Uses Logic Diagram to Direct User to appropriate action Separates Spurious Actuations to Inside License Basis and Outside License Basis
-- Treats Cable Routing/Spurious Actuation Issues as "Missing Fire Barrier"
- Addresses Operability issues for real hardware/performance problems 19
Duke FEnergy. Issue Resolution Process -
Continued mffmmwm!
20
U Energy. Configuration Management Appendix R Reconstitution Project is also intended to address Configuration Management Issues
- Design Documentation Design Change Process Software Quality Assurance for Appendix R Safe Shutdown Analysis Database(s)
Engineering and Management Training on new Appendix R Safe Shutdown Analysis 21
- fwergy, Arnmored Cable Fire Testing Duke plans on performing additional fire testing of armored cable More thoroughly determine robustness of armored cable Determine spurious hot short probability given cable damage
- Use many configurations found in Duke Plants Determine sensitivity to various factors Grounded vs. Ungrounded Large Multi-conductor vs. small 22
Duke Energy. Status/S chedule All three sites have completed Phase I ONS is in process of completing Phase 11 Expect to implement remaining Appendix R Reconstitution tasks in staggered fashion (Dates are approximate):
- -- ONS Phases 11 and Ill complete in 2005 MNS to complete by end of 2006 CNS to complete by end of 2007 Dates may need to change pending decision to transition to NFPA-805 23
lliDuke Energy..
Summary Duke Power plans to institute an Appendix R Reconstitution Project at all three nuclear plant sites Project intended to address programmatic weaknesses, incorporate latest industry guidance and clear up vague design basis Through detailed cable/fire area analyses and risk analysis methods, address multiple spurious actuations Staggered implementation schedule - ONS first, MNS next, CNS last 24
Duke Ifr Lk man tu hg ai SM Transition to NFPA-805 Oconee (ONS)
Catawba (CNS)
McGuire (MNS)
December 6, 2004 1
Duke
'EnergyS Outline a Why are we here?
M Background
- Duke Status on NFPA-805
- Technical Issues
- Administrative Issues 2
Duke Energy. Why are We here?
M a Duke Power continues to be interested in Transitioning to NFPA-805, Performance Based, Risk-informed Fire protection. Our purpose here is to:
- Provide discussion on why we are interested
- Begin discussions with NRR on some of the technical and administrative iss-ues.
a We do not yet have full management buy-in, but are pursuing buy-in and funding.
3
lDulke Energy.
Background
flmz
- Duke Power has been an industry leader in both Fire Protection and Probabilistic Risk Assessment (PRA) for many years.
a Our power plants have unique attributes that could be considered in a risk-informed approach:
° Armored Cable throughout the plant
- Standby Shutdown Facility - SSF 4
t F~ergy Background - Continued
- Our Fire Protection License Basis for all three plants have areas that can be i nterpreted."
- We see the use of NFPA-805 as a method for both clearing up our license basis, and assuring the fire risk at the plants is acceptable, 5
Energyn Present Status on NFPA-805
- Duke is contemplating transitioning to NFPA-805, with the following potential schedule:
- Oconee starting in mid to late 2005
- McGuire starting in mid 2006 to early 2007
- Catawba starting in late 2007 The Appendix R Reconstitution schedule affects NFPA-805 implementation schedule.
a Transition appears to be cost-beneficial a Several Technical Issues outstanding which may affect our decision: Results in uncertainty in cost 6
nert Su Technical Issues Multiple Spurious
- No Clear License Basis for Multiple Spurious
- Will propose a new and clear License Basis in our transition report, which will be consistent for all 3 sites.
Proposed words would be something like the following:
The Safe Shutdown Analysis shall address all single spurious and all potentially risk-significant multiple spurious (See next slide).
7
JbDuke t Enerl Technical Issues - Continued
- Potentially risk-significant:
Risk is above Reg. Guide 1.174 criteria (CDF 1 E-06, LERF > 1 E-07), prior to operator response.
DID or Safety Margins are inadequate per NEI Implementation Guide, prior to operator response.
- New Multiple Spurious scenarios identified are considered outside the license basis, until they are determined to be potentially risk significant.
8
Duke 111 ok Mu ai at WV w 'Technical Issues - Continued Multiple Spurious Combinations that do not meet the "Potentially Risk Significant" Criteria, but have an estimated CDF risk > 1 E-08/year (LERF > 1 E-09/year), are treated as follows:
- Design change or procedure change put in place, if possible
- Procedural actions still meet feasibility criteria, but actions-are not considered "required" 9
Technical Issues - Continued Recovery Actions:
- Present Manual Actions at the plant will transition over as recovery actions: Will need to meet feasibility criteria.
Options during transition:
- Change Analysis is assumed not required for all 1Il.G.2 manual actions:
However, develop deterministic criteria indicating which actions need change analysis. For example:
All Il.G.2 manual actions that directly fail safe shutdown, or following a single spurious.
- Change analysis required: Reevaluate manual actions determined to be low risk when the model is10 updated.
Duke FT erchi s
Technical Issues - Con inued M New for a even to be Requirement in DG-1 139(Section 3.1.2, d Risk Evaluation of each plant change, if the deterministic criteria are met needs clarified:
I)
- Large burden to perform a risk review for a change of any document or system affecting fire safe shutdown.
a Present NEI Change process is reasonable.
- Risk evaluations are then required when deterministic criteria not met, as a part of the change process.
11
A iF'
'r Administrative Issues Duke Power will be performing Full Plant Fire PRAs during the transition to NFPA-805:
- Not required as a part of 805
- Good idea for addressing circuit failures and multiple spurious in a risk-informed way
- PRA will meet Category 11 of the draft Fire PRA standard, for fire areas where quantitative risk assessment is used for change evaluations:
Category I or qualitative evaluation OK if the risk increase from the change is very low.
12
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- ner ml.
Administrative Issues - Cont.
- All three sites have URIs and recent issues including:
- Issues raised during inspections
- Self identified during self assessments, etc.
13
Administrative Issues - Cont.
X Open issues:
- Do previously identified issues receive enforcement discretion, given NFPA-805 implementation being scheduled for 2006-2007 for McGuire and Catawba?
- What about the ONS95-002 inspection scheduled for March 2005?
14
Duke gym Schedule
- Jan. 16th deadline?
M Will need feedback on the above issues by the end of December if date is not extended.
- Reg. Guide and NEI Implementation Guide will not be complete by January 16th. Some details still a concern.
- 2 Year Transition:
- Need to discuss options on delayed transition.
15