ML082070391

Meeting Handouts from 7/17/08 Public Meeting on the Harris and Oconee LARs to Transition to NFPA-805

ML082070391
Person / Time
Site:	Oconee, Harris
Issue date:	07/17/2008
From:	Duke Energy Carolinas, Duke Power Co, Office of Nuclear Reactor Regulation
To:
Vaaler, Marlayna, NRR/DORL 415-3178
Shared Package
ML082060554	List: ML082060536 ML082070391
References
TAC MD8807, TAC MD8832, TAC MD8833, TAC MD8834
Download: ML082070391 (26)

Text

Enclosure 3 NFPA-805 Public Meeting Handout Duke Energy Carolinas, Inc.

July 17, 2008 1

Oconee NFPA-805 July 17, 2008 2

David Goforth Duke Energy NFPA 805 Technical Manager 3

Overall Reconstitution B-1 Table B-2 Table B-3 Table Radioactive Release Non-power Ops PRA Configuration Control Documentation LAR and UFSAR 4

Reconstitution Reconstitution should be completed prior to beginning Well documented Safe Shutdown Analysis with open items where deterministic requirements cannot be met Modification reviews 5

B-1 Table (Traditional Fire Protection)

Approved exemptions to the original regulations Limited calculations from original Safe Shutdown Analysis Grey license statements Generation of a new calc for the B-1 Table License Amendment Request (LAR) Appendix T populated with license conditions brought forward for NRC clarification Some open items entered into the Corrective Action Program (CAP) 6

B-2 Table (Methodology)

Should be similar for all three Duke nuclear plants Generated a B-2 calculation Some open items, entered into the CAP 7

B-3 Table (Safe Shutdown Analysis)

Due to Oconee Nuclear Station (ONS) design this was very complicated Final Safe Shutdown Analysis (SSA) for a given fire area turned into an iterative process Open items came out of the fire area analysis Team approach to resolving SSA Need more up front training prior to activating the team Change evaluations developed from this Manual action feasibility Thermal Hydraulic calculations required 8

PRA (Probabilitic Risk Assessment)

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 Fire PRA)

Ideally the PRA model should be built with the new reconstituted SSA PRA/SSA Team interface PRA quality versus Appendix B concerns Separate Change Evaluation calculations 9

Radioactive Release This went fairly smooth This was done by plant personnel Separate calculation generated 10

NPO (Non power Operations)

ONS was very difficult to tie NPO components to Key Safety Functions Balance Of Plant 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.

11

LAR (License Amendment Request)

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.

Change Evaluation summary pending 12

Configuration Control Three site modification review process developed The need for development of controls for new calcs and LAR information Post LAR, pre Safety Evaluation Report (SER) program development Project process controls Integration of the new Final Safety Analysis and Nuclear Safety Capability Assessment into existing Engineering documents 13

Overall Its all about teamwork and communications Lay out the proper sequence for transition - LAR due date versus a completion of the program date 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 14

Enclosure 4 NFPA-805 Public Meeting Handout July 17, 2008 1

The NRC NFPA 805 Acceptance Review Process Harry Barrett, PE Fire Protection Engineer Office of Nuclear Reactor Regulation Tel: 301-415-1402 Email: Harold.Barrett@nrc.gov Public Meeting on NFPA 805 Pilot License Amendment Requests Two White Flint North Rockville, MD July 17, 2008 2

Topics for Discussion

• NFPA 805 Transition Status

• NFPA 805 Pilot Program

• NFPA 805 Pilot License Amendment Requests (LAR)

• NRC Staff Acceptance Review

• NRC Staff Review of LAR

• NRC Infrastructure 3

NFPA 805 Transition Status

• Letters of Intent for 47 Units at 29 Sites.

• 44 Units at 27 Sites are Actively Transitioning.

• 36 Month Discretion Period to Transition.

• 12 Pilot Observation Visits Completed.

• Frequently Asked Question (FAQ) Process.

• 24 Public Meetings w/ NEI 805 Task Force.

• 2 Non-Pilot Workshops 4

NFPA 805 Pilot Program

• Two Pilot Plants identified:

- Oconee

- Shearon Harris

• Facilitated close coordination between industry and NRC staff for identifying issues and transmitting lessons learned to non-pilots

• Process includes:

- Pilot Observation Meetings and associated trip reports

- Public Meetings

- Workshops 5

NFPA 805 Pilot Program- continued

• Transition Implementation Guidance Documents have benefited from this open process

- NEI 04-02

- Regulatory Guide 1.205

- NUREG/CR-6850

• Included the development of the Frequently Asked Question (FAQ) Process

- Monthly public meetings with NEI NFPA 805 Task Force

- Structured avenue to seek NRC staff interpretations and clarifications to guidance documents (NEI 04-02, Regulatory Guide 1.205, NUREG/CR-6850) 6

NFPA 805 License Amendment Request Submittal Formal start of the NRC staff review and approval process Required by regulations Addresses legal requirements as well as technical requirements Includes a detailed record of Fire Protection Licensing Basis going forward 7

NFPA 805 Pilot License Amendment Requests

• On May 29, 2008 Progress Energy submitted a License Amendment Request to transition the Shearon Harris NPP to a Risk-Informed, Performance-Based Fire Protection Program in accordance with 10 CFR 50.48(c) and NFPA 805

• On May 30, 2008, Duke Energy submitted a License Amendment Request to transition the Oconee NPP to a Risk-Informed, Performance-Based Fire Protection Program in accordance with 10 CFR 50.48(c) and NFPA 805 8

NRC Staff LAR Acceptance Review

• High level review of submittal to assess sufficiency for the more detailed review

- Scope

- Level of detail

- Completeness

• Acceptance review will result in letter back to licensee in accordance with the normal NRC acceptance review process (as currently defined in LIC-109) 9

NFPA 805 LAR Review Detailed review of complete submittal package NRC staff will pilot draft Standard Review Plan (SRP) guidance in review process In addition to proof of concept as part of pilot process, the SRP review also fulfills licensing requirements for the pilot plants being reviewed 10

NRC Infrastructure

• As part of the pilot process, the NRC staff is in the process of developing/revising the necessary regulatory documents associated with NFPA 805:

- Regulatory Guide 1.205

- Acceptance Review Guidance

- Standard Review Plan

- Inspection Procedures 11

Summary

• NFPA 805 Transition is well underway

• NFPA 805 Pilot Process has facilitated the process

• NRC Staff is in the process of reviewing the Pilot plant LARs

• Significant effort is underway addressing the regulatory infrastructure to address NFPA 805 transition 12