ML082050402

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April 2008 Observation Visit - Shearon Harris -Pilot Plant Transition to NFPA 805 - Performance Monitoring Program
ML082050402
Person / Time
Site: Oconee, Harris  Duke Energy icon.png
Issue date: 04/16/2008
From: Began K
Nuclear Generation Group, Progress Energy Co
To:
NRC/NRR/ADRA/DRA/AFPB
Oudinot D, NRR/DRA, 415-4064
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ML082050482 List:
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Download: ML082050402 (16)
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Harris Nuclear Plant (HNP)

NFPA 805 Transition NFPA 805 Monitoring Program Oconee / Harris NFPA 805 Pilot Observation Meeting April 14-16, 2008 Charlotte, NC Keith Began, CES/FP

NFPA 805 Monitoring Program Review from Nov. 2007 Pilot Meeting O Assumptions Z Assumptions that are not subject to change do not need to be monitored (e.g. ceiling height input maintained by configuration control process)

Z Deterministic monitoring may carry forward as current surveillance processes Z The level of monitoring of assumptions and performance should be commensurate with associated risk significance O Considerations Z Align with existing programs and processes 3/4 Eliminate/minimize need for new, separate processes Z Consider the Human Performance aspects of our people in the field Z May use Maintenance Rule-like type program Z One method may not fit all attributes Z Use Leading Indicators (if determined)

Page 2

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Draft Procedure developed Z FIR-NGGC-XXXX (provided to NRC)

Z 4-Phase program implementation process 3/4 Phase 1 - Scoping 3/4 Phase 2 - Establishing Risk Criteria 3/4 Phase 3 - Risk Determination 3/4 Phase 4 - Monitoring Implementation Page 3

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 1 - Scoping (SSCs, Program Elements, Assumptions)

Z Structures, Systems, and Components (SSCs) 3/4 Detection and Alarm Systems 3/4 Fire Suppression Systems 3/4 Water Supply, Hydrants, and Valves 3/4 Fire Pumps 3/4 Stand Pipes, Hose Stations, and Hoses 3/4 Fire Barriers 3/4 Portable Fire Extinguishers 3/4 Equipment supporting recovery actions (Emergency lighting, communications)

Page 4

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 1 - Scoping (SSCs, Program Elements, Assumptions)

Z Program Elements 3/4 Transient Combustible Control Transient Free Zones 3/4 Hot Work Control Administrative Controls 3/4 Fire Watch Programs Program compliance and effectiveness 3/4 Fire Brigade Qualifications, Drills, Training Response Times Page 5

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 1 - Scoping (SSCs, Program Elements, Assumptions)

Z Key Assumptions in Engineering Analyses 3/4 Identify the key assumptions from the risk-informed, performance-based analysis that apply to a fire protection feature.

3/4 For each applicable feature, identify which characteristics require monitoring to ensure the key assumptions are maintained.

3/4 For each performance criteria, identify the monitoring that would be needed to ensure the characteristic is maintained.

3/4 Establish threshold values that would be used to identify when the characteristic is in jeopardy of not being maintained.

ssumptions that are not subject to change do not need to be monitored. The level of monitoring of assumptions should be commensurate with their risk significance.

Page 6

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 2 - Establishing Risk Criteria Z Risk Significant Criteria 3/4 Fire PRA is primary tool Z Performance Criteria 3/4 Established for items within the NFPA 805 monitoring scope, regardless of their ability to be measured using risk significant criteria 3/4 The performance criteria used should be availability, reliability, or condition monitoring, as appropriate Page 7

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 3 - Risk Determination Z Use Fire PRA, or other processes, to determine the risk significant SSCs/fire protection program elements using the criteria established in Phase 2.

Page 8

NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

O Phase 4 - Monitoring Implementation Z Tools 3/4 Tracking database 3/4 Corrective Action 3/4 EGR-NGGC-0008, Engineering Programs 3/4 Existing Procedures Z Assess performance against established criteria 3/4 Refinement of performance goals and criteria 3/4 Analysis of situations where goals are not met, or declining trends 3/4 Address items appropriately via Corrective Action NFPA 805 monitoring program scope is not included in the scope of Maintenance Rule. For convenience, the Maintenance Rule monitoring process will be used to facilitate use of existing programs and processes (e.g., use of tools such as tracking databases).

Page 9

NFPA 805 Monitoring Program Process Flowchart Expert Panel FPRA (primary tool), and other processes Expert Panel

1. Tracking database
2. Corrective Action
3. EGR-NGGC-0008
4. Existing Procedures NFPA 805 Monitoring Process (similar to NUMARC 93-01)

Page 10

Monitoring Scope Example (final determination from Expert Panel)

System / Topic EPRI Risk Measurement? Proposed Type of Monitoring Comments 1006756?

tection and Alarm Systems Yes Yes (NSP) High safety significant fire detection Use fire area/zone risk (detection NUREG/CR-6850 Section systems - Monitoring using system level in areas/zone contributing 90% of 11.5.1.8, App. P unavailability/unreliability performance fire risk) as the high safety criteria significant systems.

Low safety significant fire detection systems EPRI 1006756 provides guidance

- Condition Monitoring using program on determining failures/functional similar to existing surveillance/testing failures and calculation of failure process. Address performance issues via probabilities.

system health reporting process.

e Suppression Systems Yes Yes (NSP) High safety significant fire suppression Use fire area/zone risk (fixed NUREG/CR-6850 Section systems - Monitoring using system level suppression in areas/zone 11.5.1.8, App. P unavailability/unreliability performance contributing 90% of fire risk) as criteria the high safety significant Low safety significant fire suppression systems.

systems - Condition Monitoring. Condition EPRI 1006756 provides guidance Monitoring using program similar to existing on determining failures/functional surveillance/testing process. Address failures and calculation of failure performance issues via system health probabilities.

reporting process.

ter Supply, Hydrants, and Valves Yes Indirectly (part of NSP) Condition monitoring Establishing unavailability and ter Storage and Suction Supply NUREG/CR-6850 Section unreliability criteria for this derground Fire Main 11.5.1.8, App. P manual suppression equipment drants (hydrants) is not considered a e System Valves practical means of monitoring.

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Monitoring Scope Example (final determination from Expert Panel)

System / Topic EPRI Risk Measurement? Proposed Type of Monitoring Comments 1006756?

Pumps Yes Indirectly (part of NSP) May already be part of maintenance rule.

NUREG/CR-6850 Section 11.5.1.8, App. P d Pipes, Hose Stations, and Hoses Yes Indirectly (part of NSP) Condition monitoring Establishing unavailability and NUREG/CR-6850 Section unreliability criteria for this 11.5.1.8, App. P manual suppression equipment is not considered a practical means of monitoring.

Barriers Yes Partial (part of Multi- Condition monitoring Use multi-compartment analysis s, Floors, and Ceilings Compartment Analysis) of Fire PRA to determine inter-Doors NUREG/CR-6850 Section 11.5 area/zone barrier importance.

Dampers Fire wraps credited in areas/zone etration Seals contributing 90% of fire risk or tric Raceway Fire Barrier Systems fire wrap whose failure could Wraps) increase fire risk to be in the top ctural Steel Fire Proofing 90% of areas/zones would be ant Energy Shields considered high safety significant systems.

able Fire Extinguishers Yes Indirectly (part of NSP) Condition monitoring Establishing unavailability and NUREG/CR-6850 Section unreliability criteria for this 11.5.1.8, App. P manual suppression equipment is not considered a practical means of monitoring.

Brigade No Fire Brigade Response Program Effectiveness Monitoring FP Programmatic activity that will NUREG/CR-6850 Section 11 be monitored by FP program procedures, self assessments (EGR-NGGC-0008, CAP-NGGC-0201), system heath reports, etc.

Page 12

Monitoring Scope Example (final determination from Expert Panel)

System / Topic EPRI Risk Measurement? Proposed Type of Monitoring Comments 1006756?

sient Combustible Control No Potential. CDF of transient Program Effectiveness Monitoring FP Programmatic activity that will scenarios be monitored by FP program procedures, self assessments (EGR-NGGC-0008, CAP-NGGC-0201), system heath reports, etc.

Work Hot work-induced transient fires Program Effectiveness Monitoring FP Programmatic activity that will are part of the fire PRA. be monitored by FP program procedures, self assessments, system heath reports, etc.

ear Safety Equipment (systems and No Will be addressed as part of Maintenance rule as appropriate pment needed for reactor safety, maintenance rule. No specific eled in the FPRA) post-transition NFPA 805 monitoring is planned pment supporting recovery actions No Not explicitly modeled Condition Monitoring Emergency lighting should ergency lighting, communications) already be part of maintenance rule.

Communications equipment should be part of routine surveillance program.

Watch No Not explicitly modeled Program Effectiveness Monitoring FP Programmatic activity that will be monitored by FP program procedures, self assessments (EGR-NGGC-0008, CAP-NGGC-0201), system heath reports, etc.

Page 13

Performance Monitoring Group (PMG)

Example (final determination from Expert Panel)

Page 14

Performance Monitoring Group (PMG)

Example (final determination from Expert Panel)

Page 15

NFPA 805 Monitoring Program Questions / Discussion Page 16

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