ML082000991

M080717-Commission Briefing Slides/Exhibits Briefing on Fire Protection

ML082000991
Person / Time
Site:	Oconee, Harris, Wolf Creek
Issue date:	07/17/2008
From:	Baxter D, Canavan K, Donahue J, Muench R Duke Energy Carolinas, Electric Power Research Institute, Progress Energy Carolinas, Wolf Creek
To:	NRC/SECY
References
M080717
Download: ML082000991 (40)

Text

COMMISSION BRIEFING SLIDES/EXHIBITS BRIEFING ON FIRE PROTECTION JULY 17, 2008

Nuclear Regulatory Commission Briefing on Fire Protection July 17, 2008 Mr. Richard A. Muench President and CEO Wolf Creek Nuclear Operating Corporation 1

Discussion Topics

• Operator Manual Actions

• Fire Induced Circuit Failures

• NFPA 805 Transition 2

Operator Manual Actions

• Licensees working to complete corrective actions by March of 2009

• NFPA 805 transition and resolution of fire induced multiple spurious circuit failure issue impacts resolution of many operator manual action items 3

Fire Induced Circuit Failures

• Status Agreement on conceptual approach Implementation details addressed in future meetings

• Use of risk to address associated circuit issues without exemption or LAR must be included 4

Fire Induced Circuit Failures

• Industry I NRC meetings will continue

• Industry actions in the interim Developing implementation details Guiding use of risk insights for resolution of issues Preparing draft revision to industry guidance

• Goal - receive NRC endorsement 5

Fire Induced Circuit Failures

• Use of risk to address fire induced circuit failures in associated circuits Regulations do not prohibit Use of risk is consistent with the Commission's Policy Statement on use of PRA (60FR42622)

• Failure to allow could result in

- actions that could raise overall plant risk,

- need for new exemptions or LAR's and/or

- costly modifications for low risk and low safety-significance items 6

NFPA 805 Transition

• Pilot plants (Oconee and Harris) license amendment requests submitted

• Activities necessary to enhance regulatory certainty

- Refinement of LAR template

- Resolve PRA issues Minimize requests for additional information 7

Fire PRA

• Fire PRA is a challenge

- Preliminary results are conservative

- Goal in PRA is to be more realistic

• Industry and NRC Staff addressing items seen as main contributors to conservatism

• Goal. is to resolve by late 2008 8

N*FPA 805 Enforcement Discretion

• Extension to enforcement discretion is important

- Limited qualified resources

- Incorporate lessons learned from pilot plants

-Assure consistent licensing bases

• Near term Commission decision requested 9

N Acronyms

" NFPA

" LAR

• PRA National Fire Protection Association License Amendment Request Probability Risk Assessment

/

10

NFPA 805 Lessons Learned Shearon Harris Nuclear Plant.

July 17, 2008 Joe Donahue Vice President Engineering N tICI I0 Progress Energy 1

Fire Protection Defense In Depth o Prevent Fires o Prompt Detection Of Fires o Prompt Control and Suppression Of Fires o Separation Of Safety Systems 0

Ný QProgress Energy Page 2

Fire PRA Implementation o Extensive Walkdowns Identified Potential Fire Sources o 4000+ Fire Scenarios Evaluated o NRC Team Review o Industry Expert Peer Review c~NudL G

Criiv A.A G Ott r UProgress Energy Page 3

Fire PRA Implementation

• Fire PRA Is Acceptable For Use

• Other Inputs are Used for Decision Making

• Process Industry Improvements Provided To NRC and N L I C I I CProgress Energy Page 4

Harris NFPA 805 Fire Protection o Implements classical requirements o Implements nuclear safety performance criteria o Addresses fire safety during, non-power operations o License amendment request submitted o Transition resources were greater than originally estimated

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Progress Energy Page 5

Generic Issues Addressed o Hemyc/MT Fire Wrap Qualification o Operator Manual Actions o Multiple Spurious Operations CProgress Energy Page 6

Harris Physical Plant Changes o New Cable Raceway Wrap o New Fire Rated Cable o Upgrades To Hemyc/Mt Wrap o Additional Equipment Separation o Additional Incipient Fire Detection In Critical Electrical Panels K Progress Energy Page 7

Summary o Transition To NFPA 805 Is Improving Fire Protection Program D Resolution Of Generic Fire Protection Issues D Physical Plant Modifications Already Completed D Additional Modifications Being Implemented Np Progress Energy Page 8

b Summary NFPA 805 License Amendment Request Submitted C On Track To Complete Implementation By End Of 2010 Nue 6ou CProgress Energy Page 9

NFPA 805 Lessons Learned Oconee Nuclear Station July 17, 2008 David Baxter Site Vice President

,Duke

'Energy

NFPA 805 Lessons

• Oconee showed that NFPA 805. is an excellent fit for the older -nuclear stations.

• A good solid Safe Shutdown Analysis documenting deviations with Fire Regulations should be in place to start transition

Duke 7;Energy

NFPA 805 Lessons

• The pilot process was very complicated, time consuming and expensive.

• Document and calculation reviews took much longer than expected due to new program.

Duke

~Energya

NFPA 805 Lessons

• Oconee required separate Fire PRA models.

oNUREG-6850 turned out to be somewhat conservative, but provided a good foundation to build on.

6iDuke

!FEnergy

D NFPA 805 Lessons

• Although further tuning is planned, the Fire PRA's models realistically modeled the plant.

• The process of transition is very man-power intensive Duke 7Energy

--r ELECTRIC POWER R RESEARCH INSTITUTE BRIEFING ON FIRE PROTECTION ISSUES Ken Canavan Senior Program Risk and Safety Manager Management July 2008

EPRI Fire PRA Philosophy

• Consistent with the PRA Policy Statement "Use of the PRA technology should be increased in all regulatory matters to the extent supported by the state of the art..."

• Committed to supporting a risk-informed, performance based approach to fire protection

- Realistic methods

- Realistic input

- Monitoring and feedback process

© 2008 Electric Power Research Institute, Inc. All rights reserved.

2 VS' I

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Fire PRA Methodology Development

• NUREG/CR-6850 is guidance for developing a Fire PRA 0

NRC-RES / EPRI collaboration (EPRI 1011989)

Only pieces piloted (initially)

Two Fire PRA Pilots Initial results are conservative Not unexpected Result of individual minor to moderate conservatisms ELECTRIC IPOW E

Power Research Institute, Inc. All rights reserved.

8m ira REEACHINTITUTE

© 2008 Electric

Fire PRA Methodology Issues,

• Fire Ignition Frequencies

" Credit for Incipient Detection

" Treatment of Large Oil Fires

" Fire Growth and Propagation Models

" Credit for Fire Suppression

" -Hot Short Susceptibility, Probability and Duration

• High Energy Arching Faults

" Cable Tray Fire Modeling

©0I ELETRIC PPWýTR (D 2008 Electric Power Research Institute, Inc. All rights reserved.

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0 RESEACH INSTITUJTE

Other Issues, Progress and Challenges

• Other Issues Shortage of Trained Risk Personnel Practical modeling limitations

• -Progress Education of Risk Professionals and Fire PRA Methods Training EPRI / NRC-RES working to refine Fire PRA methods Challenges

- Available resources

- Time constraints

'2IELECT111 POWER RE SEARHIN~STITUTE

© 2008 Electric Power Research Institute, Inc. All rights reserved.

SU.S.NRC Uniiced Staces Nuclear Regulatory Cormmission Protecting People and the Environment Commission Briefing on Fire Protection Issues July 17, 2008

Agenda

" Introduction

-Jack Grobe, NRR

" Current Issues

- Mark Cunningham, NRR

• Summary

- Jack Grobe, NRR 2

Introduction

• Fire protection at operating reactors

• Steering Committee activities

• Remaining issues

- Fire barrier performance

- Operator manual actions

- Fire-induced circuit failures

- Implementation of NFPA 805 3

Fire Barrier Performance

• Protection of electrical equipment required

" Inspections and research identified deficiencies

" Actions were taken

" Documenting closure 4

Operator Manual Actions

" Inspections identified inconsistencies RIS 2006-10 clarified regulatory positions

" Completing closure

- Plant-specific resolution

- Staff follow up 5

Fire-Induced Circuit Failures

• SECY-08-0093 provides approach

- Methods for protecting safe shutdown capability

- Enforcement discretion proposal

• Achieving closure

- Finalize and implement guidance

- Complete direct current circuits research

- Implementing closure plan 6 I

NFPA 805 Implementation

• Alternative approach

- Risk informed

- Performance based

• 47 units committed to transition

• Pilot plant license amendments under acceptance review 7'

NFPA 805 Implementation

• Infrastructure being finalized

- Technical methods and standards

- Regulatory Guidance Resource planning and allocation Communications 8

I NFPA 805 Implementation

• Implementing closure plan

-Finalize guidance

- Standardize review process

- Share lessons learned

- Receive and review amendments Licensees implement changes Staff inspects implementation 9

Summary

• Maintain a stable and predictable regulatory environment

• Communicate with licensees and public 10