ML061530193
| ML061530193 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Harris, Brunswick, Crystal River, Robinson  |
| Issue date: | 03/27/2006 |
| From: | Duke Energy Corp, Duke Power Co, Nuclear Generation Group, Progress Energy Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML061530193 (163) | |
Text
Handout Reference 1 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
NFPA 805 Pilot Observations Meeting Progress Energy Transition Status Meeting Topic 2, March 27, 2006 Jeff Ertman, CES Tony Maness, HNP Mike Fletcher, HNP Jack Curham, CR3 Richard Hightower, RNP Steve Hardy, BNP Nudear Generation Group k Progress Energy Page 1
PE NFPA 805 Transition Status Discussion Points
- General project information
" Harris Transition plant status
- Transition status other PE plants
" PE plans to address generic letters
- Summary of outlook next six months P PE Goals of the Meeting
% Page 2
- Progrems Energy
PE NFPA 805 Transition Status General Information - Scope
- Project Scope includes three major work areas P Complete SSN/Appendix R Reconstitution (started in 2003) primarily using NEI 00-01 as guidance o Develop Fire PRAs using NUREG 6850 as guidance and revise Internal Events PRA to support it o Transition to 10CFR50.48(c) / NFPA 805 using NEI 04-02 Guidance 0
PE NFPA 805 Transition Status General Information - Priorities
- SSA Validation
- NFPA 805 Transition
- Modifications Page 4 Progress Energy
PE NFPA 805 Transition Status General Information - Goals
- Transition to risk informed, performance based licensing basis for an improved safety focus
- Establish a common Fire Protection Program across fleet - as soon as practical
- Address recent NRC guidance relative to SSA Circuit Analysis and Manual Operator Actions
- Advance Fire Protection and PSA personnel skill and knowledge Page 5 PmrmgS EneWg
PE NFPA 805 Transition Status General Information - Fleet Plan
" CR3 LAR August 2009
- BNP LAR August 2011 d % Page 6 @Proges Energ
PE NFPA 805 Transition Status General Information - Project Planning
" Rolling Wave project planning method utilized P Plan includes all four plants P Lessons learned from lead plant will be applied across the fleet
- Dedicated resources at corporate level e Committed resources at site level e Funding at the Fleet Initiative leve I Page 7 Pf=wgrs Eeg
PE NFPA 805 Transition Status General Information - Target
, I
- *Ii~
NGG Fire Pro Plant License Conditio dJ 10 CFR 50.48 (c)/
.o.*,
NFPA 805 4: NRC Security .,. -ws Energ r'e A M~
Harris NFPA 805 Transition Status SSA Validation Update
.14 SSA Validation Tasks P Majority of Tasks Completed P Final Task Scheduled Complete 5/31/06 P EC Approval
. Revised Analysis - Prior to NFPA 805 P Procedure Updates P Operations Training P Implement Selected Modifications d % Page 9 0 Progress Energy
Harris NFPA 805 Transition Status SSA Validation Deficiencies
. Selected Modifications Needed Due to:
P Requ ired SSD Cables Affected By Fires P Non-feasible Manual Actions i Compliance
- Lighting
+Manual Actions Not Approved d % Page 10 SProgress Energy
Harris NFPA 805 Transition Status SSA Validation Deficiencies
- R12 (on line) - 5 Modifications
" R13 (on line) - 7 Modifications
" R14 (on line) - 17 Proposed Modifications P 10 High Oper**tional Impacts (PNSC Concurred)
- 7 Medium Operational Impacts (PNSC Follow up)
Page 11 a Progress Energy
Harris NFPA 805 Transition Status SSA Validation Deficiencies (cont)
SR1 5 - R16 - Remaining Deficiencies P Approximately 15 Potential Modifications o NFPA 805 Impact - Disposition additional proposed deviations and potential manual actions
- b Page 12 Pro- essEnergy
Harris NFPA 805 Transition Status NFPA 805 Transition
- Current and Near Term Activities P NFPA 805 Chapter 3 Manual Firefighting Transition P Fire PRA Fire Ignition Source Walkdowns o Internal Events Gap Assessment P Establish FP QA Interfaces with Fire PRA Quality requirements c~ih Page 13 0rogrss Energy
Harris NFPA 805 Transition Status Hemyc- Current Status
- Comp measures on Hemyc is hourly fire watch with increased controls for transient combustible, same areas as SSD deficiencies.
o MT not considered inoperable but hourly fire watch is in place for conservatism.
Page 14 Pmrmg SEnewg
Harris NFPA 805 Transition Status Hemyc - PE Generic Letter Response
- Due out in 1st Qtr 06 with a 30 day and 60 day response
- 30 Day response will identify need for completion extension past December 07 due to NFPA 805 transition
- 60 day response will provide detailed information on applications, compensatory measures, impact on plant safety and resolution plan
- Safety impact evaluation plan includes the following:
P Utilize methods described in the "Risk Significance of Hemyc Electrical Raceway Fire Barrier System Failures", by Raymond Gallucci P Utilize the aggregate risk determination process developed by HINP.
Harris NFPA 805 Transition Status Hemyc - Three Phase Resolution Plan e Phase One -Establish Fire Barrier Worth P Testing barriers to GL 86-10 SI. MT test scheduled for May 06. Hemyc tests tentatively schedule for July 06.
P Testing will address plant specific configurations not included in NRC or NEI tests.
P Testing will be used to apply a barrier rating to the Hemyc and MT applications.
d Page 16 PurmgS Enmwg
Harris NFPA 805 Transition Status Hemyc - Three Phase Resolution Plan
. Phase Two - Evaluate Fire Barriers o Will use NFPA 805 Change Process o Acceptable applications adequate for hazards addressed per NFPA 805, NEI 04-02 Page 17 &P3 orss EUerw
Harris NFPA 805 Transition Status Hemyc - Three Phase Resolution Plan
- Phase Three - Post NFPA 805 Mods P Will address any applications found not acceptable in Phase 2 P Will begin modification process soon a applications are identified P Modifications may include alternatives such reroute of circuits, replacing ERFB with another fully qualified system, addition of components or use of Meggitt fire rated cable.
Page 18 Q PrgreSSENmrg
Robinson NFPA 805 Transition Status SSA/Appendix R Validation
- SSA Validation Project is preliminary step to for development of LAR and transition to NFPA-805 P CAFTA Fault Tree Logic has been developed P Electrical Circuit Analysis Task to complete second quarter 2006.
P Safe Shutdown Database (which includes additional electrical cables resulting from Circuit Analysis) to be complete second quarter 2006.
P Fire Area Compliance Analysis using CAFTA and new Database to commence Second quarter of 2006.
P Transition Analysis for NFPA 805 to commence mid 2007.
Page 19 PmgreSSEnegy
Brunswick NFPA 805 Transition Status SSA Validation Deficiencies
. Safe Shutdown Revalidation I Safe Shutdown Equipment List Complete I SSEL Circuit Analysis Complete I SSA Database Life Cycle Document Complete
- Planned 2006 Activities P Perform Engineered Safety Features Evaluation P Perform Raceway Validations P Conduct SSA Compliance Strategy Evaluations d % Page 20 0 Pgess Eeg
Crystal River 3 NFPA 805 Transition Status
- SSA Validation Project Status:
P CAFTA Fault Tree Logic has been developed.
P Electrical Circuit Analysis Task will complete second quarter 2006.
P New Safe Shutdown Database will also be completed second quarter 2006.
P Fire Area Compliance Analysis using CAFTA Fault Tree Logic and the new Safe Shutdown Database will commence the second or third quarter of 2006.
P Transition Analysis for NFPA 805 to commence late 2006 to early 2007.
doii Page 21 roigmsS Eneg
PE NFPA 805 Transition Status PE plans to address generic letters
- Generic Letters, other Scheduled responses:
+ Circuit Analysis (draft), multiple spurious v Fleet response planned
- Manual Actions FRN, 6 months to develop plan v Fleet response planned Page 22 0 Progress Energy
PE NFPA 805 Transition Status Summary -Outlook Next 6 Months
" Continue SSA Area Analysis at all plants in prep for NFPA 805 Fire Area Transition
" Harris Chapter 3 Transition in full swing by end of 2006
" Harris Fire PRA Equipment Selection and related tasks
- Respond to Generic Letters/FRN:
P Hemyc GL P Circuit Failures GL P Manual Actions corrective action plan Page 23 a Prges neg
PE NFPA 805 Transition Status Goals for This Meeting
- Resolution of Parking Lot items
- Discussion of specific transition technical areas:
P Chapter 3, Manual Firefighting P FP Quality requirements vs. PSA Quality P FP/Appendix R performance criteria vs. PSA success Criteria
" Identification of new Parking Lot items
- Items that require additional communications with the staff Page 24 ~P ~~Energy
Handout Reference 2 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
PDuke VEnergy.
Duke Power NFPA-805 Transition Pilot Observation Project Status 9r ggr1rr gOconee (ONS)
Harry Barrett March 27, 2006
PDuke vEnergy. Agenda
" Reconstitution Project Status
" NFPA-805 Project Status
" Fire PRA Status
" Duke 3-Site Transition Schedule
- Oconee Transition Schedule
" NearTerm Tasks 2
- Duke Reconstitution VEnergy. Project Status
" All three sites have funding approved with contracts in place
- ONS Unit 2 /Common Reconstitution Analysis is complete
" MNS is approximately 70% complete with expected completion date of Sept 2006
" ONS Unit 3 is approximately 50% complete with expected completion date of August 2006
" CNS is approximately 26% complete with expected completion date of June 2007 3
ADuke OEnergy. NFPA-805 Transition Status Nuclear Safety Performance Criteria Transition (Chapter 4)
" Have completed mapping Appendix R (NEI 00-01) methodology to NFPA-805
" Looking at more effective ways to present this information
" Table format may not be most effective way to communicate methodology
" Looking at possibility of using Engineering Guidance Document as vehicle to record method 4
Duke NFPA-805 Transition lEnergy. Status - continued
" Nuclear Safety Performance Criteria Transition (Chapter 4) - continued
" Completed Oconee Multiple Spurious Operations (MSO) Expert Panel
" Working on Recovery Action Feasibility
" Non-Power Operational Mode Transition
" Developed Philosophy and Methodology
- Working on final list of components to be added to the Appendix R Safe Shutdown Equipment List (SSEL) for additional analysis 5
PDuke VEnergy. Fire PRA Status
- Sub-Task 5.1 - Plant Boundary Definition and Partitioning
- Complete. Need to complete documentation. Will be included in the Fire Ignition Frequency Calculation
" Sub-Task 5.2 - Fire Ignition Frequencies
- Complete.
- Transient Fire Calculation is complete
" Sub-Task 5.3 - Fire PRA Component Selection
- In Progress. Completed BEMAP (PRA to Basic Event Mapping)
" Still working on evaluating the differences between Appendix R (ARTRAK) database and PRA
" Recommendations for additional tracing of non-Appendix R, PRA components is complete
" Sub-Task 5.4 - Fire PRA Cable Selection m Waiting on final component list from Sub-Task 5.3
" Sub-Task 5.5 - Qualitative Screening
- Not going to perform Qualitative Screening (will quantify all Fire Compartments) 6
PDuke VEnergy. Fire PRA Status
- Sub-Task 5.6- Fire-Induced Risk Model
- Sub-Task 5.7 - Quantitative Screening
- Sub-Task 5.8- Scoping Fire Modeling
- Sub-Task 5.9- Detailed Circuit Failure Analysis (combined w/
5.10)
- Sub-Task 5.10 - Circuit Failure Mode Likelihood Analysis
- Sub-Task 5.11 - Detailed Fire Modeling
- Sub-Task 5.12 - Post-Fire Human Reliability Analysis
- Sub-Task 5.13 - Seismic-Fire Interactions Assessment
" Sub-Task 5.14 - Fire Risk Quantification
" Sub-Task 5.15 - Uncertainty and Sensitivity Analysis
" Sub-Task 5.16 - Fire PRA Documentation 7
- Duke Armored Cable VEnergy. Fire Testing We are in the final preparations to perform additional fire damage testing to more accurately determine spurious actuation probabilities for our armored cable
- Testing will be performed at Intertek Testing Laboratories (Omega Point Labs) in Texas
" Test Plan was reviewed and commented on by NRC
" Testing will likely occur in late April or early May
" NRC will have opportunity to observe 15
PDuke Duke 3-Site VEnergy..
Transition Schedule ONS I ,111 0, . 'mM 'r I, 0M.WWW" wo . I L MN*
CNS 1 2 3 20 4th = ,f12072008 1
Ist 2d ad 2
3 d
4th lt
" 2 d20d 3 4th I" 2" 3r 3r 4t 4th is 2009 1't 22d 3rd 3
ONS Unit 0/2 ONS Unit 3 Reconstitution (Jun 05- Jul
- ONS Transition to NFPA-805 (Mar 05 - Mar 07) -
ONS Fire PRA (Jun 05 - Dec 06) -.-
- M Re1-nstituti (feb05 W,-
MNS Transltion to NFPA-80W(-Apr 06- Dc 08) '
CNS Reconstitto. (DecO"05* -.....
Jui*~07) ..
. i CNS Transition to NFPA-805 (Jul06- Sept 09),
II~ ICNS MNS and CNS Fire PRA Tasks have been extended by 6 months due to Peer Review Fire PRA (Jul 07 - Dec 08)
MNS and CNS Transition have been extended 9 months beyond PRA to allow time for addressing major peer review issues and submittal of LAR 9
PDuke Oconee NFPA-805 vEnergy.
Transition Schedule Mod
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PDuke Near Term Tasks IEnergy.
(Next Six Months)
" Armored Cable Fire Testing (2nd Qtr 2006)
" Chapter 3 Non-Fire Area Specific Transition
" Transient Analysis
" Manual Action Feasibility
- CAFTA Logic Pilot 11
Handout Reference 3 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
Status of th A iePA Standar Denns E Senk Brnd Weave Duk Poe Coman
"SA Scp vesuPA Scope some "AN Fir PRA Stnad-Sau Duk Poe r 3/2/0
Armored Cable Fire Testing Variable Base Tests 1 - 4 Tests 5 -8
- Tests 9 - 12 Cable type 8/c 8/c 8/c
(# of conductors)
Cable armor Jacketed Unjacketed Jacketed overall, Jacketed or Un-jacketed
- ofrows of fill 3 3 3 within the'tray_
- of monitored 3, 2,3 3, 2,3 3, 2,3 cables in rows 1,2, and 3
. Control power 120 VAC CPT 120 VAC CPT 120 VAC CPT source description secondary secondary secondary winding, winding, winding, Ungrounded Ungrounded Grounded IK
Armored Cable Fire Testing Variable Tests 13 - 16 Tests 17 -20 Cable type 8/c 37/c
(#of conductors)
Cable armor overall Jacketed Jacketed Jacketed or Un-jacketed .
.j~1
- of rows of fill within 3 2 *T the tray
- of monitored cables in 3,2,3 rows 1, 2, and 3 Control power 125 VDC 120 VAC CPT source description Source (Ungrounded) secondary winding, Ungrounded
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Test 1 -4:
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" Tess 5-8 Reea of14 ua naktd aktsol aen fet
" Tet 13-16:0S ga
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Duke Po wer 3/80
MutAl Spur ous LB mutil s puiu inS th Fir S*
PRA.
The prpoe nwL fo ultpe'pri isO listed "The~~U Saf Shtdw Anlsssal0drs l Duk oe n 3/2/0
deie as follows:
-Rs isabo eRe..ud 1.17 crtra are indqut per NI Implmenatio Gude prio to oprtrrepne Duke VV Powe. 3/28/06 5
Multip0 Spums L Gra Area Mutil Spriu 0o bnain that 00 no mee th "Ptntal Ris Sinfiat Crtra u aea gesiae CDF ris >
08/.a (LR > 10 E.9ya retetda 00lo s Duke Pwe - 3/2/0
MultmpleSpurious= L Afec of th prpsdLcneCniin(ot tansition):- -
Sinc o1 1E-0/yea
-7/ear ara icluds cedi fo a ul cin teo l m lil suiu reore woul be: -.-
SMutpe spriu in the gre ara wtno souin Mulipl spuiu abv oritegeyaeata abv 1 CD S-/ya (1 Ea8ya LEF Duke SSS~ ~ S- S Po er 3/28/63
Geea Meho fo Modlin Spriu Operato in th PR~A The genra inust esrR co peesvl moel mulipl spuriou Fire Saf Shtdw Recnsituio co pnet an scSnrio Pre~sen PR 0oeig nldn cnro and ompoent Exer Pae nu 9uke
3ositiO wIng of. Mmultiple Spur 1%
.1 Safe Shutdown Analysis Reconstitution List of
..... tJmLL Scenarios
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Multiple Spurious p.J Expert Panel List of Scenarios Operations List of
................. t....................
Scenario (nt I
- 01 C: I Other Scenarios (PRA, Corrective Action I--
PRA for Multiple Reports, etc.) Spurious QInfion J
Potentia -lly F isk i i
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.- I J Sianificant In the License Basis Not in the License Basis o ' L'J*'
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Duke-1oer 3/28/06a
Duke POI A-- 3/2/0
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PRA Scp vru SA Are 2:SA Co pnnt0o odldi th PRnA will bervee teemn
-SCold Shutdow 680.
Duke Poe r 3/28/0
P A Scp vru S A Ara3 R omoeto in th SA wl need to be trae in on of seerlwas
- PR co i ponet notin equecesthatarefir-inue (SG Tub Rutr) Nohn reurd
-Asu e to Fai fo-l fie (suiu icue)
-Asue Se rotn Srules. NU E/R65 5 Peror A Cal Rouin (Ae 3a):
" Liel fo imotn PR co pnns adin the to th SS 5 Po er 3/28/06 **a a
PRA Scp vru SA teSA shw ogl tefloig
-20% wer lo FV Lo RA for CD and Us .0 Vad10 RAW wihsm veiiain CCD <m 1 E-3 WP<1 -4
-10 nee to be traed Duke Poe r, 3/2/0
PA Scp essSA Unqu *- noecltr fo som SA
- Adjs tePA mapig asnedd
-S A list doe not inld a itoalsb comonets Reay fo at-str ofS u ps Cale were lite agans th pum braebtPA lit th ely Abou 20 o PA copnet nonSA were Dukdtr e to' be aculyrcd Poe r, 3/2/6
AN F 'Ar PR Stand~* -ard mi-00000-- .
Labs, and Contaco Support
- Mos Key Mebr fro NRG-6850
-Bot a Wrtn and Seprt Reie Group Pwer, 3/2/0
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Base onrcn Etra Evet and Shudow Stadr Exprene weS dono byte en ofs.06
- 0S Fior R Sadr 680.
- Mutil Spuiu Ss cosdrain SS geerll 2 intating event an prtratos Duke .. ~*
Po er 3/80
Handout Reference 4 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
Duke VEnergy.
Duke Power Non-Power Operations Transition Oconee (ONS)
Harry Barrett Liz Kleinsorg March 28, 2006 1
PDuke VEnergy. Purpose Present General Overview of Non-Power Operational Modes Transition nDiscuss Methodology for establishing Non-Power Operational Modes Component List 2
RDuke Overall Non-Power Operational VEnerW. Mode Philosophy 7 Consistent with industry guidance and the state of the art with respect to shutdown risk
- Modify existing shutdown risk management structure to manage fire risk during high risk evolutions
- Uses existing tools, training and experience to focus on those times when fire would have the highest impact on safety r NUMARC 91-06 already requires fire risk to be managed throughout the outage
- Our current outage management process requires us to consider fire risk in the overall outage management process 3
Duke Non-Power Operational Mode IEnergy. Methodology - NFPA-805 n NFPA-805 Nuclear Safety Goal:
M"The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition." (emphasis added) rn Reasonable Assurance is accomplished through the Management of Shutdown Risk during High Risk Evolutions (HREs) 4
0 Duke Non-Power Operational Mode rfEnergy. Methodology - NEI 04-02 n NEI 04-02, Section 4.3.3, "Non-Power Operational Modes Transition Review"ý n Based on maintaining Defense in Depth during low power and shutdown conditions n Builds on industry approaches to shutdown risk management
Duke VEnergy. NEI 04 continued NEI-04 continued
,Focus on managing fire risk Qualitatively during High Risk Evolutions (HREs) m NEI 91-06 defines High Risk Evolutions as follows:
,, Outage activities, plant configurations or conditions during shutdown where the plant is more susceptible to an event causing the loss of a key safety function.
6
PDuke VEnergy. NEI 04 continued n Detailed methodology provided in NEI 04-02, Appendix F:
n Review existing plant outage processes to determine equipment relied upon to provide Key Safety Functions n Compare list of SSCs required to maintain KSFs with those analyzed for Safe Shutdown at Power 7
Duke IEnergy. NEI 04 continued
- NEI-04 continued n For those SSCs not already credited, perform circuit/cable/routing analysis to determine where these SSCs can be impacted by fire Identify locations where fire may impact shutdown safety
- Pinch points where fire damage may prevent achieving KSFs
- recovery actions credited for KSFs are performed r Identify fire areas where a single fire may damage all the credited paths for a KSF r, May include fire modeling 8
Duke VEnergy. NEI 04 continued rn NEI-04 continued For those areas where investigation indicates a high risk, consider various options to reduce fire risk:
" Prohibition or limitation of hot work in fire areas during periods of increased vulnerability
" Verification of operable detection and /or suppression in the vulnerable areas.
R Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability
- Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability
- Use of recovery actions to mitigate potential losses of key safety functions.
- Identification and monitoring insitu ignition sources for "fire precursors" (e.g., equipment temperatures).
9
- [Energy.
Duke Non-Power Methodoloyv V .M~ W ~ ~ ~
Operational
'~S. ~ ~ ~ ~ .1
- D1ike
-~ ~p.a -
Mode w
n NSD-403, "Shutdown Risk Management (Modes 4, 5, 6, and No-Mode) per 10 CFR 50.65 (a)(4)"
-nSite Directive 1.3.5, "Shutdown Protection Plan"7 10
- Duke Non-Power Operational Mode Energy. Methodology - Duke
, NSD-403, "Shutdown Risk Management (Modes 4, 5, 6, and No-Mode) per 10 CFR 50.65 (a)(4)"
ri Outage Risk Management Outage plan includes detailed planning of HREs Complex Evolution Plans
. Critical Evolution Plans Independent Review Team (IRT)
Defense in Depth Sheets Spreadsheets that automatically indicate risk color based on Defense in Depth 11
PDuke vEnergy. Outage Risk Management - Duke rDefinition of Risk Thresholds n Example Oconee Outage Summary Schedule 71 Example Oconee Defense-in-Depth Sheet n Example Oconee Configuration Sheet 12
- Duke VEnergy.Outage Risk Management n Pre-determined risk thresholds of shutdown risk are:
Color Description Green The KEY SAFETY FUNCTION is at minimum risk.
Yellow. The KEY SAFETY FUNCTION is in a reduced condition. The plant's ability to perform the associated safety function is reduced but still acceptable.
Orange The KEY SAFETY FUNCTION is degraded and steps should be taken to minimize the amount of time in this condition. RISK MANAGEMENT PLAN is required prior to a planned entry. Planned entry is not allowed without PORC approval RED The KEY SAFETY FUNCTION is severely threatened. IMMEDIATE restoration is required. Planned entry is not allowed without PORC approval.
Planned entry into a Red condition is not standard Duke practice and a Red condition is not normally entered voluntarily as noted in Appendix A.2.
13
PUEnergy.Outage Duke Risk Management n Easy way to see High Risk Evolutions for each outage is to look at Summary Schedule See attached 2EOC21 Summary Schedule 14
PDuke Example of Oconee Outage
,nergy. Summary Schedule F12. Revs20n Oconee Unit 2, EOC-21 Summary Schedule Outage Manager October 12. 2005 Michaoel Parker BaMa~P.Ah T
2005 2005 C~~~~flfiO~~~~~~~Ii~~~~i~ hSI N TT EUE S*SIE IL ~e.IOsIw I --
I 15 C-,y C-fid-ii - Nt - Elt-11 DiWl- T1,11S ISI#OTTOfflýUSEOASA SCHEWU
P Duke VEnergy. Defense in Depth Sheet n Tool used to control Defense in Depth during outages is the Defense in Depth Sheets iTool provides a quick and easy method to determine shutdown risk status based on available components and systems and how they impact KSFs ri Used in conjunction with Plant Configuration Sheet 16
PDuke VEnergy. Oconee DID Sheet AUEChIWfl &.3S O.,w. h Dspt A.P naf Sh $et m
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£nerg. Non-Power Methodology - Duke Operations n Site Directive 1.3.5, "Shutdown Protection Plan"Y n Provides site specific guidance that implements NSD-403 at Oconee
,i Provides methodology for determining proper inputs to Defense in Depth Sheets Plant Configuration Sheets m Determines Time to Boil
- Time for Spent Fuel Pool to reach 210°F
- Time to Close Equipment Hatch 18
PDuke Oconee Plant VEnergy.
Configuration Sheet I UNIT: - MODE: 5 6 NO MODE Prteimd by___.,
Rcvicwed by:.
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P DUke Non-Power Methodology Operations
- Duke
~ Site Directive 1.3.5, "Shutdown Protection Plan" - continued r' High Risk Evolutions require use of Risk Management Plans r, Approved compensatory actions designed to:
- Maintain Defense in Depth by alternate means
- Restore Defense in Depth when system availability decreases below the planned Defense in Depth
- Minimize the likelihood of a loss of KSF during HRE 20
PhDuke Non-Power Operations Methodology - Duke Site Directive 1.3.5, "Shutdown Protection Plan" - continued ri Risk Management Plans are required:
When a planned activity puts KSF in "Orange" or "Red" During any defined HRE Any time an opening of >1.25 inches exists in Aux Bldg piping (CCW, LPSW, HPSW)
" Any time Main Feeder Bus is removed from service
" Any time unplanned entry into "Orange" > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or "Red"> 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 21
P DUke Non-Power Methodology- Operations Duke n Site Directive 1.3.5 continued Risk Management Plans will include one or more actions to reduce fire risk during these evolutions
" Prohibition or limitation of hot work in choke point areas
" Verification of operable detection and /or suppression in the vulnerable areas.
Prohibition or limitation of combustible materials in pinch point areas Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras)
" Use of recovery actions to mitigate potential losses of key safety functions.
" Identification and monitoring insitu ignition sources for "fire precursors" (e.g., equipment temperatures) 22
RfEnergy.
Duke Non-Power Methodology Operations
- Duke r Site Directive 1.3.5 continued PrIt is important to note that no one of these should be considered "permanent" or "required" in a normal sense of the word n It is unlikely that we would have an outage or a HRE that would require all of these items n Outages are unique; no two outages are alike; management of fire risk will have to be tailored for each outage based on planned work, equipment taken out of service, schedule, etc.
n What works for one outage may not be effective for the next outage.
23
RDuke UEnerg. Non-Power Operational Component Selection m Reviewed NSD 403 n Listed KSFs for Oconee:
" INVENTORY CONTROL REACTIVITY CONTROL
- CONTAINMENT CONTROL n SPENT FUEL POOL COOLING
- POWER AVAILABILITY For each KSF, identified systems/components
'utilized' during High Risk Evolutions 24
IDuke VEnergy., Non-Power ComponentOperational Selection mReviewed Operations Procedures ri Normal Operating Procedures
, Low Pressure Injection System Draining and Nitrogen Purging RCS Filling and Venting RCS Quench Tank Operations Abnormal Procedures Loss of Decay Heat Removal Emergency Procedures EP/X/A/1800/001, Enclosure 5.38 25
RUrEnerg.
Duke Non-Power ComponentOperational Selection SComponents used to implement these procedures were then compared to the Safe Shutdown Equipment List (SSEL) to determine if the component had been previously analyzed
- Review included comparison of component position required for Hot Standby and Cold Shutdown from SSEL to the position required for outage tasks 26
Duke P rEnergy. Non-Power Operational Component Selection SExamples of Components which may require routing information':
mReactor Coolant System Level instruments used during shutdown (LT-5 and associated indicators) n Containment Purge Valves (PR-1, 2, 3 & 4) n Coolant Storage Pumps and Valves
- Bleed Holdup Tanks Bleed Transfer Pumps Borated Water Storage Tank Level instruments 27
PDuke Non-Power Operational Mode vEnergy Component Selection Examples of Components which will not 1Examples of Components which will not require 'routing information':
r Spent Fuel Pool Cooling m-Containment Closure 28
Duke VEnergy. Summary ri Non-Power Operation Transition methodology will dovetail with existing shutdown risk management process r Approach focuses on managing fire risk during High Risk Evolutions in order to protect the ability to achieve the Key Safety functions required to keep the fuel in a safe and stable condition n Fire risk may be addressed through a variety of methods, which may change from outage to outage and time in outage based on things that affect fire risk (work planned, equipment available, potential fire impact, etc.)
29
Handout Reference 5 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
PDuke VEnergy.
Duke Power Multiple Spurious Operations (MSO)
HExpert Panel Oconee (ONS)
Harry Barrett Dennis Henneke March 28, 2006
PDuke V Energy. Purpose
" Present General Overview of the Oconee Multiple Spurious Operations (MSO) Expert Panel
- Discuss lessons learned from Expert Panel 2
PDuke lEnergy. MSO Expert Panel
" Expert Panel review for new Multiple Spurious Operations (MSO):
" Uses NEI 00-01 Appendix F methodology
- Takes into consideration issues/scenarios from NEI 04-06 Draft Rev. L
" Expert Panel met once to test the method:
m Identified a combination of concern involving failure of injection and cooling to 1 RCP.
3
PDuke lEnergy. MSO Expert Panel N Expert Panel Makeup
" Site Fire Protection Engineer
- 3-Site Fire Protection Engineering Lead
" Appendix R Engineers (all three sites)
" Operations (SRO licensed)
" PRA Engineer
- Consultant experienced at other stations
" System Engineering
" Electrical Engineering
" Component Engineering (Valves) 4
PDuke VEnergy. Methodology N List Safe Shutdown Functions
- For these Safe Shutdown Functions, identify possible failure mechanisms N Using various tools, identify potential component combinations that could defeat safe shutdown through the previously identified failure mechanisms
" Oconee Flow Diagrams (P&IDs)
" Safe Shutdown Logic Diagrams
- PRA Fault Tree Logic m Build these combinations into fire scenarios to be investigated 5
PDuke Safe Shutdown UEnergy.
Functions (SSDFs)
" Reactivity Control
" Inventory Control
" Pressure Control
" Process Monitoring
- Support Functions 6
PDuke SSDF UEnergy.
Failure Mechanisms m Loss of RCS Inventory U Excessive RCS Injection U
Loss of RCS Pressure Control U RCS Overcooling U Loss of SG Cooling Um Loss of Reactivity Control 7
- Duke SSDF
[Energy. Failure Scenarios m Loss of RCS Inventory
" Stuck Open Pressurizer Safety Valve
" Spurious Opening of Head/High Point Vents
" Failure of RCMUP due to RB Flooding
" Spurious Opening of Letdown Line
- Total Loss of Electrical Power n Excessive RCS Injection
- Spurious HPI injection beyond SSF Letdown with failure of Pzr Safety Valve open 8
PDuke SSD Failure Scenarios VEnergy. - continued
- Loss of RCS Pressure Control
" Spurious Aux Pressurizer Spray
" Spurious Pressurizer Heater Actuation
- Spurious start of RCP with subsequent pump heat
" Spurious start of RCP with spurious Normal Pressurizer Spray a RCS Overcooling m Excessive feedwater flow
" Spurious EFW actuation with spurious EFW Control Valve opening
" Failure to trip/isolate Main FDW/Hotwell/Booster Pumps m Excessive steam flow
" Spurious Turbine Bypass Valve actuation
- Failure to isolate SSRH with loss of IA 9
PDuke SSD Failure Scenarios IEnergy. e continued m Loss of SG Cooling
" Spurious isolation of ASW/FDW flow path
" Loss of Electrical Power m Loss of Reactivity Control m Boron Dilution 10
- Duke Oconee Issues Identified VEnergy Prior to Expert Panel
" Single spurious start of HPI C pump resulting in full HPI injection through normally open injection valve
" Single spurious full HPI injection through normally closed HPI injection valve
- Spurious actuation of ES channel 7 or 8 resulting in RB Spray Actuation resulting in flooding out RCMUP (two hot shorts)
" Spurious ES channel 1 or 2 actuation resulting in full HPI injection after transferring control to SSF (two shorts to ground)
- Spurious EFW actuation after transferring control to SSF (multiple shorts/hot shorts)
" Spurious opening of both Reactor Head Vent and Reactor Head Vent block valve and/or Reactor High Point Vent and associated block valves (two hot shorts in same wireway inside Main Control Board)
" Failure to trip/isolate Main FDW with spurious opening of Main Feed Regulating Valve
" SSF MOVs could be damaged by Turbine Building Fire prior to transfer 11
- aEnergy° Duke Lessons Learned nera, in Expert Panel m Knowledge of current Operating Experience ensures more complete coverage of issues
" Loss of cooling water to Letdown Heat Exchangers could cause loss of all operating HPI pumps due to low NPSH
" Exposure fire may impact instrumentation tubing inside Reactor Building
- Potential fire impacts on Nuclear Instruments (NIs) in redundant shutdown areas (Reactor Building and West Penetration Room) 12
Lessons Duke Expert Panel - continued Learned in IfA oEnergy.
N Expert Panel generated numerous action items for further investigation
" Level of detail in existing procedures
- Investigate if RCP restart could cause seal failure
- Determine if RCMUP can keep up with all pressurizer heaters in service
" Determine failure mode of coolant makeup valves
- Determine reactivity addition rate of deborating demin
" Determine assumptions related to SSF Submersible Pump timing
" Verify SSF electrical system separation from Unit 2
- Verify NI cables do not run through West Penetration Room
" PRA Group to roll expert panel results into Fire PRA 13
PDuke VEnergy. Summary
" Duke has successfully completed the MSO Expert Panel for Oconee
- Process was successful in identifying numerous scenarios for further study
- Process also identified numerous action items requiring further investigation 14
Handout Reference 6 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
DISCUSSION OF THERMAL-HYDRAULIC ANALYSES JILL C. WATSON Nuclear Generation Group ~ Progress Energy
Thermal-Hydraulic Analyses I What it is ? How it is used I Nuclear Safety Performance Criteria I Tools to be usE d Page 2 0Progress Energy
What is it? How is it used?
- Purpose P Estimate plant behavior and response to fire events
- Method P Bounding approach to optimize effort using input from loss profile and timing of fire event
" Uses o Input to determining the acceptability of meeting the nuclear safety performance criteria P Input to determining acceptability of recovery actions Page
- P ess aEnergy
Nuclear Safety Performance Criteria
- NFPA 805 Section 1.5.1 "Fireprotection features shall be capable of providing reasonableassurance that, in the event of a fire, the plant is not placed in an unrecoverable conition. To demonstrate this, the following pefomnce criteria shall be met.
- o Reactivity Control Reactivity control shall be capable of inserting negative reactivityto achieve and maintain subcriticalconditions. Negative reactivity inserting shall occur rapidly enough such that fuel design limits are not exceeded.
- o Inventory and PressureControl. With fuel in the reactorvessel, head on and tensioned, inventory and pressure control shall be capable of controlling coolant level such that subcooling is maintainedfor a PWR and shall be capable of maintainingor rapidly restoringreactorwater level above top of active fuel for a BWR such that fuel clad damage as a result of a fire isprevented.
S:. Decay Heat Removal. Decay heat removal shall be capable of removing sufficient heat from the reactorcore or spent fuel such that fuel is maintainedin a safe and stable condition.
o:o Vital Auxiliaries. Vital auxiliariesshall be capable of providing the necessary auxiliarysupport equipment and systems to assure that the systems requiredunder a), b), c), and e) are capable of performing their requirednuclearsafety function.
- . Process Monitoring. Processmonitoring shall be capable of providing the necessary indication to assure the criteriaaddressedin a) through d) have been achieved and are being maintained."
Page 4 0 Progres Energ
PRA Acceptance Criteria e Supports additional success path such as feed and bleed cooling (as long as not sole protected method)
" Allows RCP Seal LOCA without core damage being assumed
" Increases time window for operator response and allows for probability that operator actions will fail
" Acceptability based on NEI 04-02 and Regulatory Guide 1.205
" Uses CDF and LERF as Figures of Merit d % Page 5 Page 5 ~PorsEner
Nuclear Safety Performance Criteria
- Temporary deviations allowed as long as "fuel damage as a result of the fire is prevented."
P Consistent with RI-PB approach P Consistent with Reasonable Assurance that the plant is not placed in an 'unrecoverable condition' [NFPA 805 1.5.1]
P PB approach to establish performance and results that a "...failure to meet a performance criteria, while undesirable, will not in and of itself constitute or result in an immediate safety concern." [NFPA 805 1.6.45]
Page 6 @ g~SEwWg
Tools
Handout Reference 7 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
PE DEVELOPMENT AND DISCUSSION FOR HFEs IN THE FIRE PSA ROBERT RISHEL Nuclear Generaton Group Progress Energy
Extension of Existing Human Reliability Analysis for Fire Scenerios
- Based upon discussion in CR 6850 Chapter 12
- HRA tool is based upon existing PSA HRA methodology; P Time based Human Cognitive Reliability with Operator Reliability Experiments (HCR/ORE)
P Caused Based method using Performance Shaping Factors with decision trees that could affect operator response P Execution phase using Techniques for Human Error Rate Prediction (THERP)
Page 2 0 EWSE8
Potential HFEs Interactions P Different context or timing for a particular operator response during a fire than during the internal events PSA P New HFEs that are specifically required by the fire procedure (e.g. pre-emptive actions)
P Logic models may require consideration of HFEs and other human actions not previously considered P Effects of fire may result in unintended actions by the operating staff Page 3 OW eSEweFO
Fire HRA Considerations
- As discussed in CR 6850 there are many inputs to evaluate i Number of operators available may change due to the fire P Location of operator actions outside the control room compared to fire and smoke interaction o Change in time available or response time o Fire impact on Control Room indications
+ May need to trace circuits beyond SSA circuits Page 4 0 Progres Energy
HRA Screening Same as in CR 6850 P Screening values used to determine need for further analysis.
P Detailed analysis is likely to be a lot more effort than the internal events HRA and thus need to limit the effort.
Page 5 ~PlS EN8Yy
HRA and Instrumentation
- Need to considered fire induced instrument failures P Considered for in mal-operations P Identify redundant instruments P Procedure guidance on instrumentation to be used Page 6 PorsEnemgy
Local Actions - Considerations Detailed Analysis
" Local actions would be credited only if:
P Input from Operators that the local action would be attempted based on fire procedures P Fire would allow access to equipment P Equipment itself would not be involved with fire or suppression measures P Adequate time to put on the SCBA and any other protective gear and still complete action within allowed time.
o Amount if any obscured vision due to smoke
- Delay in execution of local actions due to slower communication
- Impact on error recovery due to fire distractions Page7 OPrg Ejss neMjy
Need to Adjust Time Impact due to Fire e For Control Room Fire that does not result in abandonment P Consider using a two point analysis, for example:
- Ten minute fire
" Twenty minute fire P After Fire suppressed - Add time to the response time to reflect residual distractions P Scenarios where some control room indications are known to be lost could increase response time to allow time to determination of correct indications P Scenarios where all control room indications lost would typically fail the action without specific additional information.
(~i*Ii Page 8 0 Proes Energ
Adjust Cause Based Factors
- Performance Shaping Factors the could affect response for example: (others PSFs may be applicable)
P Data not available (pca)
P Data not attended to (pcb)
P Data misread or miscommunicated (pcc)
P Information misleading (pcd)
P Procedure step skipped (poe)
P Stressor would also be applied as applicable Page 9 PrIgbSSEneqy
Additional Considerations to Assess Execution Actions
" Fewer operators to support local actions P Could also make multiple actions completely dependent P Reduce review of execution actions
- Loss of STA or other extra control room staff
- Strongly encouraged to observe an fire simulator scenarios, walk-thru, or talk-through to understand crew dynamics, use of peer checks etc.
Page 10 rPugleziEnergyf
Handout Reference 8 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
NFPA 805 Transition Chapter 3 - Manual Firefighting Alan Holder, CES Alan Griffin, HNP Mike Fletcher, HNP March 29, 2006 SProgress Energy Page 1
PE Manual FirefightingI Fire Brigade Initiatives
- Gap Analysis of applicable standards P NFPA-805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants P NFPA-600, Standard on Industrial Fire Brigades P NFPA-1 500, Standard on Fire Department Occupational Safety and Health Program P NFPA-1403, Standard on Live Fire Training Evolutions
- Review of Pre-Fire Plans, Engineering Controls and Fire Brigade Training Materials to ensure specific identification of containment and monitoring of contaminated fire suppression water.
Page2 ItPm EfeW
PE Manual FirefightingI Fire Brigade Initiatives Table G-1 NFPA 805 - Radioactive Release Transition Review Guidance NFPA 805 Requirements Implementing Guidance Results (Example)
Radiation release to any unrestricted area Review pre-fire plans. Review of Pre-Fire Plans is underway to determine due to the direct effects of fire suppression Ensure for locations that have the potential for adequacy of guidance for containment and monitoring of activities (but not involving fuel damage) contamination that specific steps are included for potentially contaminated fire suppression water (run-off) shall be as low as reasonably achievable containment and monitoring of potentially for applicable plant areas. Review results to be provided to and shall not exceed applicable 10 CFR, contaminated fire suppression water. Update pre- site FP PM for inclusion in Pre-Fire Plans.
Part 20, Limits. fire plans as necessary.
Review fire brigade training materials. A systematic review of fire brigade training materials is Ensure that training materials deal specifically underway within NGG Fire Protection Training PEER with the containment and monitoring of Group. A focused approach to fire brigade training has potentially contaminated fire suppression water. aligned the current fire brigade training schedule as well as Update training materials as necessary. the NFPA-805 transition process utilizing a rolling wave method beginning with the HNP and providing lesson learned for incorporation at all PE sites.
Page 3 ~PmreBMWrg
PE Manual Firefighting I Fire Brigade Initiatives 1403 600 805 1081 Ventilation X Overhaul X Fire Behavior X Fire Safety X PPE X Fire Extinguishers X Fire Detection X Fire Suppression Systems X ICS X Hose, Nozzles &Appliances X Water Supply X Forcible Entry X Search and Rescue X Ladders X Radiological X Offsite Page 4 Page 4 ~~~pmrsneg
PE Manual Firefighting I Fire Brigade Initiatives e NFPA 1403 Lesson Plan Topics Review Schedule 3/06 Portable Extinguishers 4/06 Fire Hose, Appliances, Streams & Foam 5/06 Safety 6/06 Ladders 7/06 Ventilation 8/06 Fire Behavior 9/06 PPE 10/06 Forcible Entry 11/06 Overhaul 12/06 Water Supply Page 5 PagePmgressEner 5Q
PE Manual Firefighting I Fire Brigade Initiatives 0 1/Q '06, Fire Pre-Plans & Fire Extinguishers P 2/Q '06, Fire Detection & Foam P 3/Q '06, Fire Fighting Strategy & Tactics P 4/Q '06, Interior Fire Attack, Annual Practice P 1/Q '07, Chemistry & Physics of Combustion P 2/Q'07, Personal Protective Equipment, Search & Rescue, Annual Practice P 3/Q '07, Fire Protection Systems P 4/Q'07, Flammable/Combustible Liquids &
Gases, Transformer Fires Page 6 ~PWWgSEneWU
PE Manual Firefighting/
Fire Brigade Initiatives
- What "Success" Looks Like P Element of "Rolling Wave" project, includes all four sites, supports HNP as pilot, with lessons learned applied to other sites.
P Brigade Training Program topical revisions coincide with HNP training schedule and incorporate radiological release containment and monitoring.
P End product is an up-to-date, NFPA compliant, fleet-wide program, which meets our training needs and regulatory requirements.
Page 7 &1PrmgWSEnewg
Handout Reference 9 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
NFPA 805 NRC Pilot Observation Meeting NFP-805 Product Quality David Miskiewicz, CES March 29, 2006 Nudear Generation GGmup ~Progress Energy Page 1
First try Page 2 Page 2~ Proges Energ
Product Quality - Topics for Discussion
- Internal Events PRA
- Fire PRA
- Product Forms
- Software A% Page 3 Page~~ 3w ~PorsEner
- Approved controls will be maintained consistent with existing requirements for Fire Protection products P Circuit Analysis P Fire Modeling P Thermal Hydraulic Analysis P Fault-Tree Analysis for SSA P Database Page 4 ~Pmgrm EmWg
Internal Events PRA
" Method 1: Perform full assessment against the ASME Standard (an NEI GAP assessment can be used)
P Identify SRs which do not meet Category II and evaluate need to update PRA based on the application(s) to be implemented ("B" level F&Os)
" Method 2: Determine those areas which should meet ASME Capability Category II for the application desired P Perform assessment of those SRs only and update PRA accordingly Page 5 fPtgrm EnmW
Internal Events PRA (cont.)
- A peer review should be obtained for significant upgrades SCan be completed in parallel with development of Fire PRA information Page 6 fPtgreSSEnGF
Fire PRA
" Follow NUREG/CR-6850 Guidance
Standard will be needed eventually
- Data supporting the Fire PRA can be developed using the same methods as those supporting the internal events PRA
" Data which is also directly input to the SSA should be developed to SSA standards P Identification of ignition sources P Component selection P Circuit routing Page 7 PmgrmssEner Page 7a
PRA Products
- PRA analyses and results are not committed to Fire Protection standards even though they can be used to support SSA and NFPA-805 changes o Calculations P Engineering Changes P Software
" PRA product documentation is controlled using approved procedures that support the requirements of the applications Page8 ftq= EmM
Software / Databases
- Software and Databases that primarily support the SSA will be qualified for Fire Protection Program use P CAFTA P Fire Modeling 0 FSSPM (Database)
" Software and Databases that primarily support PRA analysis only will be qualified for PSA use P R&R Workstation Tools (includes CAFTA features not used for SSA) 0 T-H (success criteria, HRA timing)
P PRA models Page 9 ~PWW13SSEmVY
Second Try IAll products to be developed and controlled by existing approved plant procedures:
T m Thermal Hydraulics Hydraulics - Englneern Changes Fire Modeling - Cacuations sub. Firs (system success Softare cooling, etc) HRA timing -Databases CDFILERF)
Shared Database Informnation:
. Ignition Sources / targets
- Component Selection
- Cable/Circult Routing Plant Changes FHA SSA Spgif Database Shared 11nputDat NFPA-80 change process CDF/LERP merc (includes non-power risk considerations)
Industry Standards and Related Guidance:
Augmented QualIty Non-Safety-Related - ASME RA-Sb-2005 (tedcnical adequacy (technical adequacy ANS 58.23 controlled by Corp. QA based on inu- NUREG/CR-80 Manual and Site Standads with NE104.02 Cormittments) Pow Reviews)
Page 10 ~mrs~eg
Handout Reference 10 NFPA 805 Pilot Observation Visit Trip Report - ML061500468 March, 2006
NFPA 805 NRC Pilot Observation Meeting Change Process Jeff Ertman, CES Harry Barrett, Duke Power Liz Kleinsorg, KGRS March 29, 2006 Duke
'Energy. SProgress Energy Page 1
Change Process - Topics for Discussion
- Regulatory Guide 1.205 Issues Related to Change Analysis
- NEI 04-02 Revision 2 Proposed Revisions Related to Change Analysis
" Change Analysis Examples
- NEI 04-02 Updates envisioned P Duke dwEnergy. Page 2 Pagrs Energ
Regulatory Guide 1.205 Issues Related to Change Analysis License Condition Prior Approval Thresholds
- 90-day NRC Approval 'Process'
- Circuit Analysis (RG 1.205 Section 3.3 vs.
- Cumulative Risk of Changes
- Related vs. Unrelated Changes PWDuke Progres- Energ 4WEnergy_ Page 3
NEI 04-02 Revision 2 Proposed Revisions Related to Change Analysis
- Nuclear Safety &Radioactive Release now Precede Fundamental Element / Minimum Design Requirements on Sample Form
- Emphasized Relationship between NFPA 805 Chapter 4 Requirements and Chapter 3
" Changed Screening to "Potentially" Greater than Minimal
- Added Provision for Risk Decreases SPaDuke afrEn ergW. Page 4
NEI 04-02 Revision 2 Proposed Revisions Related to Change Analysis (Figure 5-1) 3111 Defining the Change
- 0 (5.3.2)
- 0 License Compliel No with Chap:
Amendment previously ap; Request Aftemativi Duke PDEnergy. Page 5 Progress EnergyMyLicense Am#-nrfrn#
NEI 04-02 Revision 2 Proposed Revisions (Appendix I)
Pai of~
UICINSUENAMIt UffimS
[3 SrA D srs D smc 1OvUit, uS, 2 UD i:3 wuS ACTIVITY 1-a4LOCUMMKIrREVIS1ON Campdol A~dwct* ,I mdmmcrke inwal below.
CHANGE EVALUATION
SUMMARY
RISK EVALUATION
SUMMARY
o The chane Isediwurlul or vbltommature.
(Scrleng per Section 1a. 2a. or 3a)
[0 The chump en be evaluated winga PRELMINARY RISK SCREEN (Section 4) o IleChangeaftheomplotmewithl 0Nuclear Sofe"y Criteria of NFPA 305 as defined Int 0 Yes 13 No 1lmet reT c to the mpl pratie decumcetl 0 The RISK EVALUATION demembtt t AM A (Section I). CDF/LERF are ac*eptabce and deeMae.ldepth I safety O Yes Ne marg&iare mibllmd. Thervfre.the chaneb acceqhibie.
o The champ fh compliahnce wth ft Radioactive Refea Criteria t Nt PA 05 Th RISK EVALUATION dtesumraft that either th A CDF/LERF are vmaccepble med/or deftse-I-deinh I defined is lierd rehreace to the spal opsdate safeWy margit are mot waluftoe& Tkrefom Ike clae 4 do tl (Sctio n.
3 Yes [3 No Is NOT aceptable.
o The choamt afftms comptiance with arequired Fundamental Elemen IMinimum Desg Reqlrment of NFITA SNS Chapt*r 3 (See.
3).
Umlcew AmemN*eva Required?
D Yes 13 No Prht Nmom DATE SCREEtN PREPARER' Wrist Name
- DATE SCIEtN REVMW"R P Duke 4tEnergy. Page 6 -Progress Energy
Engineering Evaluation History
- GL 86-10 clarified need for prior NRC approval of engineering evaluations
- Primary Applications are: Fire Barriers, Code Evaluations, and Coverage
" Regulatory Guide 1.189 re-iterated acceptability of these types of engineering evaluations
- NFPA 805 recognized past and future use of these types of engineering evaluations (Figure 2-2 and 2.2.7)
Duke PDEnergy. Page 7 a MuressEner
Figure 2.2 of NFPA 805 Es Identif NFPA 805 Section 2.2(c)
Evaluate compliance to performance criteria Ident comp area P Duke a Energy. Page 8 8Progress EnerMf
NFPA 805 Chapter 3 Alternate Methodology LAR
- NFPA 805 does not allow performance based option
- 10 CFR 50.48(c) allows for use of RI-PB methods for Chapter 3 and alternatives with a LAR
- Planned development of alternate methodology to allow:
P Transition of existing engineering evaluations without submitting LAR I Performance of evaluations post-transition without PfEnergy. Page 9 0Prges Enemy
Alternate Methodology
- Alternate Methodology to include:
P Scope and limitations P Methodology 0 Acceptance Criteria
- Alternate Methodology will be included in NEI 04-02 I Endorsed by NRC I Referenced by Licensees in LAR submittal P Duke 4tEnergy. Page 10 Q Progesnerg
Change Analysis Examples 1 Security conduit in a fire door 0
- 2. Install a transfer switch for a pump power supply
- 3. Change to Thermal Hydraulic supporting calculation
- 4. Fire Brigade training change
- 5. QA program change P Duke nPors~eg a Energy. Page 11
Example 1 -Security Conduit in a Fire Door
- If fire barrier is required, then NFPA 805 Chapter 3 Requirements in effect
- May not meet NFPA 80 Requirements
- Prior code compliance evaluation or GL 86-10 evaluation may not have addressed configuration
- Preliminary Risk Screening may yield 'No impact' or 'Minimal Impact'
" NFPA 80 code of record may allow evaluation
" Alternative approach per Transition LAR will allow 'adequate for the hazard' evaluations DukPage PWEnergy.Po 12
- ProgN Energy
Example 2 - Install A Transfer Switch for a Pump Power Supply
" Assuming pump is a Nuclear Safety Pump
" New switch (and flexibility) SHOULD improve risk
- Reliability (potential failure) of switch could counterbalance flexibility
- Operator manipulation of switch would need to be considered
" Risk decrease identified during Preliminary Screening
" Should consider addition to model
- Even if not installed due to fire considerations, can still be characterized as FP program change Duke PEnergyPge1 Page 13 EnProgr
Example 3 - Change To Thermal Hydraulic Supporting Calculation
" Assume calculation addresses valve maloperation
- Re-analysis reduces time to unacceptable conditions by 10 minutes
- Assumed not to pass preliminary screening due to change (changed from 40 minutes to 30 minutes)
- Detailed change evaluation would assess sequences related to valve maloperation
- Acceptability of change measured using NEI 04-02 processes
- Prior approval determined by RG 1.205 license condition risk thresholds PEnergy_ PDukeae1 ae1 Progress Energy
Example 4 - Fire Brigade Training Change
" Would compare against NFPA 805 Section 3.4 and transitioned Licensing basis
- Could potentially affect 'Suppression Capability' in preliminary screening
- If 'Potentially Greater than Minimal', then perform analysis to quantify change (manual suppression factor)
- May need to have the ability to see how 'manual suppression' is credited in the Fire PRA
" Also could potentially affect radioactive release Energy. Page 15 OPIgreSSEMMY
Example 5 - QA Program Change
- Program change would not necessarily comply or fail to comply with NFPA 805
- Judgment would apply based upon anticipated results or relationship with NFPA 805 requirements DukePage P4WEn erg y.Pae1 16 ProgrssErgy
Effects on Non-Power Operational Modes
- Non-Power Analysis focuses on identifying 'pinch-points' to be managed during High Risk Evolutions
- Permanent plant or procedure changes need to be evaluated post-transition for their effect on the analysis
- Examples of changes that may affect the Non-Power Analysis 0 Change to DID Equipment or Success Path P Change that effects failures of DID Equipment 0 Change to occupancy of a 'pinch point' area that affects fire modeling that had been done to establish no storage/no welding zones 4 En4erg y.Pae1 Page 17DProgress Energy
Effects on Non-Power Operational Modes
- Continued
- So given the change how we do the change evaluation?
P This is a work in progress 4Energy. Page 18 0Progress Energy
Future Updates for NEI 04-02 related to Change
" Additional Questions for Non-power operational modes
- Examples added to Appendix I
" Consistency with Regulatory Guide 1.205
" Unrelated / Related Change Clarification (parking lot)
Ene Page 19 EmM