ML081840744

NFPA-805 Workshop Handouts - Oconee NFPA-805 Lessons Learned

ML081840744
Person / Time
Site:	Oconee
Issue date:	06/19/2008
From:	Goforth D Duke Energy Corp
To:	Office of Nuclear Reactor Regulation
Shared Package
ML081840360	List: ML081840398 ML081840534 ML081840731 ML081840735 ML081840744
References
NFPA 805
Download: ML081840744 (16)

Text

Oconee NFPA-805 Lessons Learned June 19, 2008 1

David Goforth Duke Energy NFPA 805 Technical Manager 2

How did all this begin?

In a nuclear era long, long ago Duke to the NRC: We would like to build a nuclear power plant.

NRC back to Duke: OK 3

What did we have to work with?

Oconee Nuclear Station:

Three units, B&W design, very little separation (plant equipment or SSF)

Quick responding RCS No MSIVs or feedwater isolation Wide open plant areas Safety related gear located in the turbine building Very loosely written license basis 4

NFPA 805 Concern?

Paul Lain to David Goforth in a long forgotten pilot meeting:

Hey, if you can transition Oconee, you can transition anyone 5

Overall Reconstitution B-1 Table B-2 Table B-3 Table Radioactive Release Non-power Ops PRA Configuration Control Documentation LAR and UFSAR 6

Reconstitution Reconstitution should be completed prior to beginning Well documented Safe Shutdown Analysis with open items where deterministic requirements cannot be met Modification reviews 7

B-1 Table Many exemptions to the BTP Few calculations Many Grey license statements Very little suppression and detection for the hazard Generation of a new calc for the B-1 Table LAR Appendix T populated with many license conditions brought forward for NRC clarification Some open items entered into the CAP 8

B-2 Table Should be similar for all three Duke nuclear plants Generated a B-2 calculation Some open items, entered into the CAP 9

B-3 Table Due to ONS design this was very complicated Final SSA for a given fire area turned into an iterative process Many open items came out of the fire area analysis Team approach to resolving SSA Need more up front training prior to activating the team Special cases for fire areas turn up in some cases Change evaluations developed from this Manual action feasibility Thermal Hydraulic calculations required 10

PRA ONS required separate models due to unit differences - not originally envisioned NUREG 6850 turned out to be somewhat conservative (however NUREG 6850 provides a good foundation to build a FPRA)

Ideally the PRA model should be build with the new reconstituted SSA PRA/SSA Team interface PRA quality versus Appendix B concerns Separate Change Evaluation calculations 11

Radioactive Release This went fairly smooth This was done by plant personnel Separate calculation generated 12

NPO ONS was very difficult to tie NPO components to KSFs BOP Fire Area can present concerns as a pinch point Process submitted for approval FAQ 07-0040 was a very intense process to develop. Approval to be done via the LAR.

13

LAR More up front training needed for review team Not enough time was allotted for review -

much overtime worked by all involved Station management review required two sessions for approval - nuclear safety versus completeness and accuracy.

Change Evaluation summary pending 14

Configuration Control Three site modification review process developed The need for development of controls for new calcs and LAR information Post LAR, pre SER program development Project process controls Integration of the new FSA and NSCA into existing Engineering documents 15

Overall Its all about teamwork and communications Lay out the proper sequence for transition - LAR due date versus a completion of the program date Duke personnel were next to impossible to obtain Plant personnel frequently required for maintenance of running units or outage support Different level of details in UFSAR for nuclear plants present some challenges to a generic NFPA 805 UFSAR This is a very complicated process and will be new to plant personnel Reluctance to implement software in place of the traditional paperwork 16