ML062370512
| ML062370512 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/19/2006 |
| From: | Lain P NRC/NRR/ADRA/DPR/PFPB |
| To: | Sunil Weerakkody NRC/NRR/ADRA/DRA/AFPB |
| Lain P.W., NRR/ADRA/DRA, 415-2346 | |
| Shared Package | |
| ML062410430 | List: |
| References | |
| FOIA/PA-2009-0089 | |
| Download: ML062370512 (10) | |
Text
September 19, 2006 MEMORANDUM TO: Sunil Weerakkody, Branch Chief Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM:
Paul Lain, Fire Protection Engineer /RA/
Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 24 & 25, 2006, CATEGORY 3 PUBLIC MEETING REGARDING THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 805 TRANSITION WORKSHOP On July 24 & 25, 2006, the U.S. Nuclear Regulatory Commission (NRC) staff held a workshop with stakeholders and the public to discuss aspects of Donald C. Cook Nuclear Power Plants (DC Cook) transition to the new risk-informed, performance-based fire protection licensing basis for nuclear power plants, pursuant to Title 10 of the Code of Federal Regulations Part 50.48(c)) (10 CFR 50.48(c)). The meeting was held at the American Electric Power (AEP)
Nuclear Generation Groups office in Buchanan, Michigan. DC Cook management and fire protection staff, their contractors, Callaway Nuclear Power Plant staff, and the NRC staff made presentations. Other Utilities, NRC Regional and Headquarter Staff, Nuclear Energy Institute (NEI), contractors, and the public were given opportunities to ask questions and join in the discussion through-out the workshop.
The NRC staff took the following issues for its consideration:
Ability to complete transition within the 3 years of discretion with resource constraints.
Updated RIS 2006-10 to reflect technical issues discussed at the June 9, 2006 mtg.
Change analysis requirements for manual actions in III.G.1 and III.G.3 areas.
Methodology for transitioning III.G.3 areas to NFPA 805 (safe today = safe tomorrow).
Methodology for transitioning indicators (e.g., valve positions) to NFPA 805.
Methodology for transitioning self-ignited cable fires.
Performance-based transition, disconnected from the fire Probabilistic Safety Assessment.
The meeting agenda is attached as Enclosure 1, list of attendees is attached as Enclosure 2, meeting notes are attached as Enclosure 3, and the handouts are Enclosure 4 and are in ADAMS Accession # ML062370502.
CONTACT: Paul W. Lain, P.E.
415-2346
FROM:
Paul Lain, Fire Protection Engineer Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 24 & 25, 2006, CATEGORY 3 PUBLIC MEETING REGARDING THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 805 TRANSITION WORKSHOP On July 24 & 25, 2006, the U.S. Nuclear Regulatory Commission (NRC) staff held a workshop with stakeholders and the public to discuss aspects of Donald C. Cook Nuclear Power Plants (DC Cook) transition to the new risk-informed, performance-based fire protection licensing basis for nuclear power plants, pursuant to Title 10 of the Code of Federal Regulations Part 50.48(c)) (10 CFR 50.48(c)). The meeting was held at the American Electric Power (AEP)
Nuclear Generation Groups office in Buchanan, Michigan. DC Cook management and fire protection staff, their contractors, Callaway Nuclear Power Plant staff, and the NRC staff made presentations. Other Utilities, NRC Regional and Headquarter Staff, Nuclear Energy Institute (NEI), contractors, and the public were given opportunities to ask questions and join in the discussion through-out the workshop.
The NRC staff took the following issues for its consideration:
Ability to complete transition within the 3 years of discretion with resource constraints.
Updated RIS 2006-10 to reflect technical issues discussed at the June 9, 2006 mtg.
Change analysis requirements for manual actions in III.G.1 and III.G.3 areas.
Methodology for transitioning III.G.3 areas to NFPA 805 (safe today = safe tomorrow).
Methodology for transitioning indicators (e.g., valve positions) to NFPA 805.
Methodology for transitioning self-ignited cable fires.
Performance-based transition, disconnected from the fire Probabilistic Safety Assessment.
The meeting agenda is attached as Enclosure 1, list of attendees is attached as Enclosure 2, meeting notes are attached as Enclosure 3, and the handouts are Enclosure 4 and are in ADAMS Accession # ML062370502.
DISTRIBUTION:
PUBLIC AFPB R/F JLyons TQuay MTschiltz SWeerakoddy RGibbs JLara JRogge CPayne LSmith DSolori o
RLangstaff PKoltay RGallucci RRadlinski DStarkey PLain CMoulton MSalley SDinsmore JCircle S-MWong ADAMS Package No. : ML062410430 ADAMS Memo No.: ML062370512 ADAMS Handouts No.: ML062370502 OFFICE AFPB/FPE AFPB/BC NAME PLain SWeerakoddy DATE 09/06/06 09/19/06
OFFICIAL RECORD COPY NFPA 805 TRANSITION WORKSHOP July 24-26, 2006 AEP Nuclear Generation Group - Buchanan Office AGENDA PURPOSE:
To discuss aspects of Donald C. Cook Nuclear Plants transitioning to the new fire protection licensing basis, 10 CFR 50.48(c) (NFPA 805 Rule).
Monday July 24, 2006 1:00 Introduction Welcome, Introductions, Agenda, etc.
1:15 Region 3 Plant Status Cook & Callaway Overview, Give other plants the opportunity to identify progress to date 2:00 Regulatory Status NRC - RG 1.205, Enforcement Discretion, Regulatory Information Summaries, Generic Letters, etc 3:00 Break 3:15 Fundamental Elements Prior Approvals, Code compliance/deviations, Alternate Transition methods for GL 86-10s, Systems/features req. to meet Chap. 3 4:30 Adjourn Tuesday July 25, 2006 8:30 Nuclear Safety III.G.1, 2 & 3 Area Transitions, deterministic vs.
Capability Transition performance - based, need for change evaluation, etc 9:30 Recovery Actions Existing manual actions and prior approval, HSD vs. CSD actions, Feasibility criteria, Regulatory Information Summary, Recovery actions identified during transition, Change evaluations for credited recovery actions, etc 10:30 Break 10:45 Non-Simple Fires Self-ignited cable fires, Transient Fires, Hot Work, High Energy Arcing Faults 12:00 Lunch 1:00 Fire PRA PRA Component list development, Fire ignition frequencies, PRA Model issues, Annunciation/alarm circuits 2:30 Break 2:45 Multiple Spurious Double Break Design, Initial Risk Screening, Use of Fire Operations Modeling, Expert Panel, Generic Letter 4:30 Adjourn Wednesday July 26, 2006 8:00 Non-Power Operation Scope of systems and components, NEI 04-02 Appendix F changes, Level of analysis - Qualitative Approach, Shutdown PRA requirement 9:15 Break 9:30 Open Dialog with NRC Topics include Fire PRA Peer Reviews, NFPA 805 Standard License Condition, etc 11:30 Adjourn
ENCLOSURE 2 ENCLOSURE 1 DC COOK NFPA 805 WORKSHOP LIST OF ATTENDEES July 24 & 25, 2006 NRC J. Lara (RIII)
R. Langstaff (RIII)
P. Lain (HQ)
G. Hausman (RIII)
M. Mimir (RIII)
R. Gallucci (HQ)
D. Szwarc (RIII)
D. Passehl (RIII)
P. Koltay (HQ)
B. Olimene (RIII)
H. Abuseini (RIV)
A. Dahbur (RIII)
D. Schrum (RIII)
G. Peck (RIV)
Industry & Public D. Fadel (AEP)
W. Larson (EPM)
E. Kleinsorg (KG)
R. Gray (AEP)
R. Kalantari (EPM)
A. Ratchford (RDS)
D. MacDougall (AEP)
T. Jutras (EPM)
K. Zee (ERIN)
R. Pletz (AEP)
P. Ouellette (EPM)
S. Hunt (HAI)
S. Cherba (AEP)
R. Bertucio (Scientech)
F. Meister (TRI-ENS)
Y. Shen (AEP)
S. Meyer (Scientech)
S. Solhdoost (ARS)
R. Baradaran (AEP)
E. Hollis (Scietech)
P. Boulden (ARS)
M. Ma (AEP)
T Raimondo (NISYS)
A. Afzali (PG&E)
P. Schoepf (AEP)
J. Masterlark (NMC)
M. Unruh (NPPD)
A. Marion (NEI)
J. Olvera (NMC)
T. Shudak (NPPD)
P. Gaffney (Progress)
T. Swiecicki (NMC)
J. Reddington (FENOC)
J. Ertman (Progress)
D. Mershon (Nexus)
J. Fortman (Ameren-UE)
H. Barrett (Duke)
ENCLOSURE 3 DC Cook Workshop Notes Monday July 24, 2006 1:00 Introduction Welcome, Introductions, Agenda, etc.
Dan Fadel (DC Cook) 1:10 Region 3 Plant Status Cook & Callaway Overview, Give other plants opportunity to identify progress Richard Gray (DC Cook)
Likely will ask for 3-yr transition Joe Fortman (Callaway)
No findings so far (at least not reportable)
Likely will ask for 3-yr transition Jim Masterlark (NMC) [no handout]
Fire PSAs initiated in 2005, based on draft NUREG/CR-6850 Fleet transition team in place Non-compliance identified and reported to Region 3 Point Beach on schedule for 3-yr transition Prairie Island has requested 3.5 yrs Monticello and Palisades have requested 4 yrs Utilizing same databases as Cook and Callaway Tracking non-compliances based on type (higher level are reportable and tracked programmatically for NRC); lower level ones tracked internally Manual actions and circuits issues are driving transition (no need for formal cost/benefit analysis) 1:25 Regulatory Status NRC - RG 1.205, Enforcement Discretion, RIS 2006-XX, GL 2006-XX, etc Paul Lain (NRC)
RG 1.205 endorses both NEI 04-02 and NEI 00-01, Revisions 1 Currently NRC is not granting >3-yrs of NFPA-805 enforcement discretion (those who requested 2-yrs need to submit letter to extend to 3-yr); plants wanting >3-yr will be reviewed on plant-specific basis as 3-yr transition period nears its end Inspection Procedures: During transition have been issued; Post transition are in draft Next Pilot Plant Observation Visit is at Oconee, 10/16-18, for Fire PSA, with a public meeting on 10/19 FAQ Program: First meeting on 7/20; next meeting during week of 8/21 New RISs issued: 2205-30 on Circuits Issues (12/2005) and 2006-10 on Manual Actions (6/2006)
New GLs: 2006-03 on Hemyc/MT (4/2006) and 2006-xx on Circuits Issues (expected 8/2006)
Non-controversial FAQs so far, mostly just updates to NEI 04-02 to align with RG 1.205 (4 given to NRC, 4 with NEI Task Force)
Revising RG 1.205 will require at least a year (CRGR, ACRS, etc.);
FAQ program will enable interim approval; FAQ approval requires at least 3 months Pilot meetings will not be public, but there will be a public meeting on the last day to summarize (e.g., 10/19), likely with handouts available from the pilot meeting Possibly a Rev. 1 to RG 1.205 before majority of LARs are submitted NRC will be overloaded with NFPA-805 LARs and new COLs in 2008-09 time frame, so were hiring more people and using National Labs
ENCLOSURE 3 Project authorization has been approved for NSSS Owners Groups to develop draft FPSA Peer Review Process by end of 2006 CRGR, ACRS, and Commission to review integration of multiple RISs and GLs that are being issued fairly concurrently?
1:45 Break 2:05 Fundamental Elements Transition Prior Approvals, Code compliance / deviations Alternate methodology/guidance for 86-10s Systems/features required to meet Chapter 3 Handout #2 Dan MacDougall (DC Cook)
Differences between Appendix R and NFPA 805: (1) all operating modes; (2) safe and stable fuel condition Chapter 4 review precedes Chapter 3 FAQs are not final until incorporated in Revision of RG 1.205, but should be quite close Cook: Limited progress to date on mapping BTP 9.5-1, Appendix A, to Chapter 3 of NFPA-805; Column 2 of NEI 04-02, Table B-1, currently being completed (Columns 3 and 4 await) - see Handout #2 Must be current as to plant configuration via walk-downs, not just paper review Cook relying on approval of FAQ 06-0004, as proposed, to determine systems/features required to meet Chapter 3 FAQ 06-004 process allows deterministic transitions because risk is below threshold(s)
Is multiple spurious operation being considered during this FAQ 06-0004 transition screening - not in the beginning, so it may be necessary to unscreen some of these initially screened systems/features that have been based on meeting risk threshold(s)
No non-compliances so far as per licensing basis (not evaluated vs. new RISs and GLs)
SER approving Halon suppression at 5% for 10 minutes for deep-seated fires conflicts with NUREG/CR-3656 - must address post-approval (post-SER) basis; should this be an LAR or just part of the transition report (i.e., documented in Table B-1 of NEI 04-02)? Plant change process is cleanest way to handle these, but licensees claim this will not be considered in the FPSA 2:45 Nuclear Safety Capability Transition III.G.1, 2 & 3 Area Transitions, deterministic vs. performance based, Need for change evaluation, etc Handout #3 Richard Gray (DC Cook)
Shift in focus from Appendix A criteria Tried to follow table B-2 of NEI 04-02, but required an expansion to include aspects of NEI 00-01 (see Handout #2); new Table B.2-1 based on NEI 00-01, Section 3.0, in Column 1 instead of NFPA-805; pilot plants having same experience, possibly a new FAQ from both pilots and non-pilots Table B-3 from NEI 04-02 requires greater detail than indicated in NEI 04-02, although no new columns; instead of just listing documents, include relevant material from documents, at least in summary form; two phases: (1) concurrent evaluations, with holes, (2) return to table and fill in the holes Assessment worksheet accompanies Table B-3 for each analysis area
ENCLOSURE 3 Transition goals: (1) efficiency; (2) simple and streamlined; (3) performance based to address controversial issues (e.g., multiple spurious)
III.G.1 fire areas (~30 over two units) will be transitioned deterministically to the extent possible (no plant change evaluations),
given 3-hr barrier and one success path (includes exemptions)
III.G.2 fire areas (~5 over two units) will be transitioned deterministically to the extent possible, as above, provided III.G.2 (a-c) provisions are met; no manual actions III.G.3 fire areas (~25 over two units) can be transitioned deterministically based on NEI 04-02, Section B.2.2, except where fire modeling is needed to address spurious actuations and manual actions via performance-based analyses; goal is to reduce need for manual actions for III.G.3 (via fire modeling)
Transition summary for each fire analysis area Changes to transitioned, performance-based FPP will required plant change evaluations Long discussion on whether or not change in Appendix R assumption, but not change in actual configuration or credit, merits a plant change evaluation; if you make no changes to your completely compliant FPP, do you need a FPSA for transition (delta-risk is zero)?
3:45 Adjourn Tuesday July 25, 2006 8:30 Recovery Actions Existing manual actions and prior approval, HSD vs. CSD Actions, Feasibility Criteria and RIS 2006-XX, Recovery actions identified during transition, change evaluations for credited recovery actions, etc.
Richard Gray (Cook) Handout #3 NEI wants NRC to supplement RIS 2006-10 more formally FAQ to address manual actions concerns Long discussion on what constitutes feasible (and reliable) manual actions for transition without HRA (concern over whether some arbitrary time margin would be applied)
Unreliable manual action (e.g., HEP approaching 1) can still be part of a cutset with a very low CDF (due to low ignition frequency, etc.); is this manual action acceptable even if unreliable?
Do plants that cannot maintain hot shutdown indefinitely have to be able to go to cold shutdown? Some plants cannot maintain hot shutdown for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and need to transition to cold shutdown; this may merit a FAQ (not really addressed in NEI 04-02)
Allowed III.G.3 manual action implies feasibility and reliability 9:25 Break 9:45 Non-Simple Fires Self-ignited cable fires, Transient Fires, Hot Work High Energy Arcing Faults Dan MacDougall (DC Cook) Handout #3 (Continued)
Fire modeling effort will begin in 2007 with screening, based on feedback from pilot plants Does NUREG/CR-6850 discount self-ignited cable fires in the same way that the FPSDP does (only possible in thermoplastic and non-qualified thermoset)? May need to be resolved after completion of NUREG/CR-
ENCLOSURE 3 6850 pilots (no sooner than end of 2006)
What voltage is the threshold for a power cable (can it go as low as 120V)? This is relevant to dismissing self-induced cable fires in power cables (or other cables as well)
Point Beach has had to review nearly all cables, not just power, for self-ignition because they are unqualified (pre-date IEEE-383)
If fire is impossible in an area that previously required postulating an Appendix-R fire for compliance, does this require a plant change evaluation?
Safe shutdown analysis and FPSA can be conducted independently, so long as both are wrapped together in the end to ensure that something that may have been eliminated by one but not by the other gets recaptured and returned to the transitioned FPP, and gets documented via a plant change analysis; SSA and FPSA should serve as checks on one another, and the FPP should be the union, not intersection, of the items in both (reference Duke/Progress Venn diagrams showing overlap among SSA, FPSA, etc.)
Electrical engineers consider MCCs and load centers to be different and therefore can be treated differently with respect to high-energy arcing faults (MCCs can only generate 200kW secondary fires, not the initial high-energy arcing fault)
NUREG/CR-6850 authors may revise it to limit HEAFs to >1000V non-MCC devices What if MCC also feeds more than just an MOV (e.g., FW pump)?
Consider for 200W secondary fire, but not HEAF 11:05 Break 11:30 Multiple Spurious Operations Double Break Design, Initial Risk Screening, Use of Fire Modeling, Expert Panel, GL 2006-XX Richard Gray (Cook) Handout #3 (continued)
Double break design for MOVs and SOVs (unique to Cook?); licensing basis excludes need to address multiple spurious operations (for MOVs and SOVs) due to low likelihood based on this design Double break design approved via SER Both intra-and intercable multiple shorting requires contacts between specific conductors in the cables 12:00 Lunch 1:15 Fire PRA PRA Component List Development, Fire Ignition Frequencies, PRA Model issues, Annunciation/alarm circuits Handout #3 (continued)
Jim Hawley (DC Cook) Handout #4 Appendix R fire areas and zones are essentially compartments as required under NUREG/CR-6850 (or readily convertible into compartments)
Internal events PSA F&Os have all been addressed (with internal flooding pending)
Cook, with an Ice Condenser containment, considers penetrations as small as 2-in in diameter for containment integrity; hydrogen explosion dominates LERF because of the low containment pressure (~12 psi)
Containment spray, although not modeled in the FPSA, will be cable-traced for the pump function to ensure they do not spuriously start
ENCLOSURE 3 LERF model may be updated from newly completed, detailed Level-2 model Frequency-based screening for spurious operations should already assume probabilities = 1 for any random failures that could be fire-induced; 1E-9/y screening criterion does not include CCDP; anything that does not get screened out requires cable tracing 2:30 Break 2:50 Non-Power Operation Scope of systems and components, NEI 04-02 Appendix F changes, Level of analysis - Qualitative Approach, Shutdown PRA not required Dan MacDougall (DC Cook) Handout #3 (continued)
Dry run for benchmarking high-risk evolutions during next outage Progress in non-power operation analysis for NFPA 805 transition will be addressed during upcoming NEI FPIF 3:05 Open Dialog with NRC Fire PRA Peer Reviews, NFPA 805 Standard License Condition, etc.
Handout #3 (continued)
NEI has asked Owners Groups to develop FPSA Peer Review guidance, with draft by end of 2006 NEI wants to request increase in enforcement discretion; one possibility is a 6-month window after the pilot LARs are approved; does voluntary nature of the rule allow more flexibility?
NEI should develop staggered submittal schedule for LAR submittals to relieve burden on NRC staff Pilots need to be complete before others are comfortable to sign on Even though sign-up for NFPA 805 officially began in 2004, licensees did not seriously consider it until late 2005, beyond the budget cycle (early spring) for 2006, meaning many licensees have no budget available until 2007 MCR evacuation will preclude re-establishing Westinghouse RCP seal cooling within 13-min time window, leading to a seal LOCA with probability ~ 0.2 (procedures dictate stoppage of charging pumps, perhaps inadvisably) 3:50 Action Items
- 1. NRC: update RIS 2006-10 to include conclusions from 6/9/06 public meeting on recovery actions
- 2. NRC & NEI: review guidance on self-ignited cable fires from various technical sources
- 3. NEI: enhance FAQ on manual actions
- 4. NRC: Baggage associated with converting a III.G.2 to III.G.3 area and adding manual actions that are, by regulation, allowed without prior NRC approval (or plant change evaluation); difference for pre-vs. post-79 plants?
- 5. NRC & NEI: increase enforcement discretion period
ENCLOSURE 4 NFPA 805 WORKSHOP July 24 & 25, 2006 HANDOUTS ADAMS No. ML062370502