ML072780319

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August 2007 - Transition to National Fire Protection Association (NFPA) 805 - Risk-Informed Performance-Based Transition Change Evaluation Process - 8/9/07 Briefing Materials/Meeting Handouts
ML072780319
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 08/09/2007
From: Ertman J
Nuclear Generation Group, Progress Energy Co
To:
Office of Nuclear Reactor Regulation
Oudinot D
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ML072830337 List:
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Download: ML072780319 (26)
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NFPA 805 Transition Harris Nuclear Plant (HNP)

Risk-Informed Performance-Based Transition Change Evaluation Process HNP-ONS Pilot Meeting Bethesda, MD Jeff Ertman Andy Ratchford August 9, 2007 1

Agenda O Background O NFPA 805 Change Evaluation Process O Pilot Plant Process and Observations 2

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Background===

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Background - Change Evaluations Addressed in Different Documents:

Document Section(s) Topic 10 CFR 50.48(c) N/A No specific discussion on change evaluations NFPA 805 2.2(h), 2.2.9, 2.4.4, Change Evaluation 4.2.4, A.2.2(h),

Risk of Recovery Actions (4.2.4)

A.2.4.4, D.5 NEI 04-02 Revision 4.4, 5.3, Appendix Change Evaluation, Change Evaluation Forms (App. I) 1 B, Appendix I, Appendix J Reg. Guide 1.205 2.2, 2.3, 3.2 LAR reporting requirements (B.2.2)

(May 2006)

Risk of operator manual actions (B.2.3)

Change Evaluations (B.3.2)

Circuit Analysis (B.3.3)

PSA Peer Review (B.4.3) 4

Change Evaluations - NFPA 805 2.4.4* Plant Change Evaluation.

A plant change evaluation shall be performed to ensure that a change to a previously approved fire protection program element is acceptable. The evaluation process shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, & safety margins.

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Change Evaluations - NEI 04-02 Change Evaluation Process 4 Subtasks (NEI 04-02 Section 5.3, App. J)

O Defining the Change O Preliminary Risk Screening O Risk Evaluation O Acceptance Criteria 6

Change Evaluations - RG 1.205 Section C.2.2 - LAR O The total risk increase associated with all FPP noncompliances (based on current deterministic FPP regulations) that the licensee does not intend to bring into compliance and the total risk change associated with plant changes planned for the transition to NFPA 805 should be estimated and reported in the LAR.

O The baseline FPP risk for the estimate of the net risk change is that for a plant that is fully compliant with the current deterministic regulations for the FPP, including NRC-approved exemptions/deviations.

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Change Evaluations - RG 1.205 Section C.2.2 - LAR (contd)

O The total change in risk associated with the transition to NFPA 805 should be consistent with the acceptance guidelines in RG 1.174 O Upon completing the transition to an NFPA 805 licensing basis, the baseline FPP risk will be the risk of the plant as-designed and operated according to the NRC-approved FPP licensing basis.

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Change Evaluations - RG 1.205 Section C.3.2 - NFPA 805 FPP Change Evaluation Process O Guidance is more relevant in a post-transition environment.

O Includes guidance on NRC approval (e.g.,

NFPA 805 Ch. 3 requirements and thresholds of post-transition FP license condition) 9

Change Evaluation Process 10

Change Evaluation Process 11

Defining the Change O Process begins by defining the change or altered condition to be examined & the baseline configuration O Baseline (a.k.a. compliant) - Plant condition or configuration that is consistent with the CLB (pre-transition licensing basis)

[FAQ 06-0010 addresses baseline]

O Change - The changed or altered condition or configuration, either as found or proposed by a plant change, that is not consistent with the Licensing Basis O The changes associated with NFPA 805 transition are those non-compliances with the CLB that are not expected to be brought into compliance prior or during the transition process (Ref. RG 1.205) 12

Preliminary Risk Review O Once the definition of the change is established & groupings /

organizations are established, a preliminary risk review is performed to identify & resolve minor changes to the fire protection program.

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Risk Evaluation O Changes are assessed using risk-informed, performance-based techniques O Techniques include, but not limited to fire modeling & PRA O The risk evaluation may be in the form of a limiting or bounding fire modeling / fire risk analysis or a detailed integrated analysis

[Ref.: NFPA 805 Section 4.2.4.2]

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Acceptability Determination O The risk evaluation shall be measured quantitatively for acceptability using the CDF &

LERF criteria O Acceptance criteria are in Regulatory Guide 1.174, as clarified in Section 5.3.5 of NEI 04-02 & RG 1.205 O An evaluation of defense-in-depth &

safety margin shall also be performed 15

Pilot Plant Update &

Observations 16

Progress Energy Update O Project Instruction for Transition Change Evaluations Developed (FPIP-0128)

Z General & specific guidance Z Significant Focus on managing open items, target identification, & fire modeling Z Includes general guidance on MSOs and OMAs Z Submitted to NRC 7/19/07 17

Progress Energy Update Process - Previously Discussed Change Evaluations / Deficiency Resolution Process Overview HNP NFPA 805 Change Evaluation Development -

Draft for Review PRA Fire Modeling- Fire PRA SSA Non- Known B-3 Table Results Fixed and Transient Quantification - full compliances / Hits OMAs / MSOs locations area / risk ranking 7/31/2007 9/3/2007 5/14/2007 Complete Initial review Input Data and Model 10/15/2007 Initial Quantification 8/6/2007 Freeze Date Detailed Scenario Start Detailed Scenarios NRC Pilot Meeting Development Complete Templates /

Master Action Sketches / Initial Fire PRA Information List Drawings Located Ignition source (MAIL) Deficiencies scenario results 11/12/2007 3/31/2008 NRC Final Mod Scope &

5/14/2007 10/15/2007 Fire PRA Scenario Development Pilot Meeting Change Evaluations Complete Initial and Follow-up Follow-up Actions resolution coordination Note: Attendance is as needed, 11/9/2007 but typically SSA, PRA, CLFP, meetings and Fire Modeling personnel Initial Mod Scope 2/15/2008 as a minimum.

10/15/2007 12/1/2007 NRC Fire PRA Audit Start Final Quantification Start Final Complete Heavy Change Evals Coordination Revised CLB Identify Change PRA Model and/or Initial Proposed Between Resolution Evaluation SSA Model Modification Tracks Strategies Scenarios Updates Identification 6/21/2007 10/15/2007 3/31/2008 6/6/2007 8/6/2007 Final Change Evaluation Calculations Roughing in Fire Safety Task Team Meeting NGG Peer Review NRC Pilot Meeting Phase Analysis (FSA) Package Ready Draft 6/26/2007 10/15/2007 5/14/2007 NGG FP 9/3/2007 Initial Scoping Test Cases Started Peer Review Fire PRA Input Data Complete Finishing Additional Data Freeze Date True-up PRA Collection / Input Phase Quantification Revisions Final PRA Quantification MSO Final Check 5/14/2007 10/15/2007 Initial Change Evaluation Preparations General Note: All steps are subject to iteration Progress Energy Harris Plant Final FSA 6/5/2007 Final MSO Dispositions Final OMA Dispositions Final SSA strategies LAR Input Revised 7/16/2007 18

Pilot Plant Update (contd)

O Items of Interest Z Process includes check of discrepancy for appropriate modeling in Fire PRA Z Need to Identify deterministic non-compliances (targets) and use in fire modeling scope Z What to do with risk significant compliances Z Focus of DID-SM 19

Progress FSA Outline 1.0 PURPOSE

2.0 REFERENCES

3.0 BODY OF CALCULATION 3.1 Fire Area Description 3.2 Fire Hazards Analysis 3.3 Nuclear Safety Capability Assessment (NSCA)

Compliance Summary 3.4 Non-Power Operational Modes Compliance Summary 3.5 Radioactive Release Compliance Summary 20

Progress FSA Outline - Cont 3.6 Risk-Informed, Performance-Based Evaluations 3.6.1 Transition Risk-Informed, Performance-Based Evaluations 3.6.2 Post-Transition Risk-Informed, Performance-Based Evaluations 3.7 Probabilistic Risk Assessment - Summary 3.8 Defense-in-Depth 3.9 Safety Margin / Sensitivity Analysis 3.10 Monitoring Program Input

4.0 CONCLUSION

5.0 ATTACHMENTS X 1 - Fire Area 1-A-BAL-C - B-3 Table - Nuclear Safety Capability Assessment Summary X 2 - Fire Area 1-A-BAL-C - Scenario Discussions - Change Evaluations 21

(Iterative - Focusing on areas of greatest risk) 22 Process Insights

Pilot Plant Insights O Simple individual changes are straight forward O Condition can be assessed as unprotected for the as found or changed condition (Case 1)

O Conditions (cables) can be assessed as protected (i.e., wrapped or outside of the fire area) for the baseline compliant case (Case 2)

O Change in risk can be measured 23

Measuring Change in Risk (individual changes) 24

Measuring Change in Risk (pre and post-transition)

Post-Transition Risk (following a post -

transition change )

CDF post transition FPP Noncompliances (that will not be New Post-Transition corrected before / Baseline during Transition ) (including items compliant with pre-CDF during transition transition CLB )

Pre-Transition Baseline Risk (Compliant with CLB) 25

Pilot Plant Insights O Multiple plant changes related to a single area or issue are more challenging to assess and manage O The ability to use CDF estimates for scenarios/fire areas to account for the sum of all changes may be a key factor in effectively assessing change evaluations during transition.

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