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
Shared Package
ML082050482 List:
References
Download: ML082050402 (16)


Text

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

Page 2 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 3 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 4 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)

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

Page 5 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 NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

Page 6 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.

Assumptions 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.

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

Page 7 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 NFPA 805 Monitoring Program Program Development (Update since Nov. 2007 )

Page 8 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.

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

Page 9 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).

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

Page 10 NFPA 805 Monitoring Program Process Flowchart NFPA 805 Monitoring Process (similar to NUMARC 93-01)

Expert Panel FPRA (primary tool), and other processes Expert Panel

1. Tracking database
2. Corrective Action
3. EGR-NGGC-0008
4. Existing Procedures

Page 11 NFPA 805 Monitoring Program Monitoring Scope Example (final determination from Expert Panel)

System / Topic EPRI 1006756?

Risk Measurement?

Proposed Type of Monitoring Comments Detection and Alarm Systems Yes Yes (NSP)

NUREG/CR-6850 Section 11.5.1.8, App. P High safety significant fire detection systems - Monitoring using system level unavailability/unreliability performance criteria Low safety significant fire detection systems

- Condition Monitoring using program similar to existing surveillance/testing process. Address performance issues via system health reporting process.

Use fire area/zone risk (detection in areas/zone contributing 90% of fire risk) as the high safety significant systems.

EPRI 1006756 provides guidance on determining failures/functional failures and calculation of failure probabilities.

Fire Suppression Systems Yes Yes (NSP)

NUREG/CR-6850 Section 11.5.1.8, App. P High safety significant fire suppression systems - Monitoring using system level unavailability/unreliability performance criteria Low safety significant fire suppression systems - Condition Monitoring. Condition Monitoring using program similar to existing surveillance/testing process. Address performance issues via system health reporting process.

Use fire area/zone risk (fixed suppression in areas/zone contributing 90% of fire risk) as the high safety significant systems.

EPRI 1006756 provides guidance on determining failures/functional failures and calculation of failure probabilities.

Water Supply, Hydrants, and Valves Water Storage and Suction Supply Underground Fire Main Hydrants Fire System Valves Yes Indirectly (part of NSP)

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

Page 12 Fire Pumps Yes Indirectly (part of NSP)

NUREG/CR-6850 Section 11.5.1.8, App. P May already be part of maintenance rule.

Stand Pipes, Hose Stations, and Hoses Yes Indirectly (part of NSP)

NUREG/CR-6850 Section 11.5.1.8, App. P Condition monitoring Establishing unavailability and unreliability criteria for this manual suppression equipment is not considered a practical means of monitoring.

Fire Barriers Walls, Floors, and Ceilings Fire Doors Fire Dampers Penetration Seals Electric Raceway Fire Barrier Systems (Fire Wraps)

Structural Steel Fire Proofing Radiant Energy Shields Yes Partial (part of Multi-Compartment Analysis)

NUREG/CR-6850 Section 11.5 Condition monitoring Use multi-compartment analysis of Fire PRA to determine inter-area/zone barrier importance.

Fire wraps credited in areas/zone contributing 90% of fire risk or fire wrap whose failure could increase fire risk to be in the top 90% of areas/zones would be considered high safety significant systems.

Portable Fire Extinguishers Yes Indirectly (part of NSP)

NUREG/CR-6850 Section 11.5.1.8, App. P Condition monitoring Establishing unavailability and unreliability criteria for this manual suppression equipment is not considered a practical means of monitoring.

Fire Brigade No Fire Brigade Response NUREG/CR-6850 Section 11 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.

System / Topic EPRI 1006756?

Risk Measurement?

Proposed Type of Monitoring Comments NFPA 805 Monitoring Program Monitoring Scope Example (final determination from Expert Panel)

Page 13 Transient Combustible Control No Potential. CDF of transient scenarios 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.

Hot Work Hot work-induced transient fires are part of the fire PRA.

Program Effectiveness Monitoring FP Programmatic activity that will be monitored by FP program procedures, self assessments, system heath reports, etc.

Nuclear Safety Equipment (systems and equipment needed for reactor safety, modeled in the FPRA)

No Will be addressed as part of maintenance rule. No specific post-transition NFPA 805 monitoring is planned Maintenance rule as appropriate Equipment supporting recovery actions (Emergency lighting, communications)

No Not explicitly modeled Condition Monitoring Emergency lighting should already be part of maintenance rule.

Communications equipment should be part of routine surveillance program.

Fire 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.

System / Topic EPRI 1006756?

Risk Measurement?

Proposed Type of Monitoring Comments NFPA 805 Monitoring Program Monitoring Scope Example (final determination from Expert Panel)

Page 14 NFPA 805 Monitoring Program Performance Monitoring Group (PMG)

Example (final determination from Expert Panel)

Page 15 NFPA 805 Monitoring Program Performance Monitoring Group (PMG)

Example (final determination from Expert Panel)

Page 16 NFPA 805 Monitoring Program Questions / Discussion