ML101440046

Notice of Public Meeting to Discuss Fire Protection Screening Criteria Identified at Browns Ferry and Their Implications to Brunswick Steam Electric Plant - Docket Nos. 05000325 and 05000324

ML101440046
Person / Time
Site:	Brunswick
Issue date:	05/21/2010
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Annacone M Progress Energy Carolinas
References
Download: ML101440046 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 May 21, 2010 Mr. Michael J. Annacone Vice President Brunswick Steam Electric Plant P.O. Box 10429 Southport, NC 28461-0429

SUBJECT:

PUBLIC MEETING TO DISCUSS FIRE PROTECTION SCREENING CRITERIA IDENTIFIED AT BROWNS FERRY AND THEIR IMPLICATIONS TO BRUNSWICK STEAM ELECTRIC PLANT - DOCKET NOS. 05000325 AND 05000324

Dear Mr. Annacone:

The Nuclear Regulatory Commission (NRC) requests your participation in a Category 2 public meeting on June 8, 2010, in Atlanta, GA. The purpose of the meeting is to update you on recent NRC efforts to evaluate certain plants against screening criteria developed using Browns Ferry and other greater-than-Green findings related to fire protection; and to provide you an opportunity to update the NRC on how these criteria may have been addressed at your site.

The meeting notice, which will be available on the NRC public web site, provides specific details regarding the logistics of the meeting.

As documented in a letter dated April 19, 2010, the NRC recently issued a final significance determination for a fire protection inspection at Browns Ferry Nuclear Plant (ML101090503).

One of the findings identified during this inspection dealt with multiple cable separation issues that was determined to have substantial safety significance. Subsequently, an NRC working group was created to identify the factors that led to the safety significance of the Browns Ferry finding, and to identify other plants that may have characteristics similar to those at Browns Ferry.

The focus of the working group was on protection and separation of safe shutdown equipment for scenarios that do not involve control room evacuation; therefore, the evaluation started with a screening question to determine whether a unit has potential issues with protection or separation. Subsequent to this entry condition, the working group conducted a review of the circumstances surrounding the historical greater-than-Green fire protection findings (including the findings at Browns Ferry) in order to identify the major contributing factors to the greater-than-Green findings. Eight screening criteria were identified as the more significant contributors to fire risk. The group then identified plants with known cable separation issues and further evaluated each of these plants against the eight additional screening criteria.

CP&L 2 The working group utilized existing and readily-available information in their initial evaluation.

Limited data gathering was only performed in a few cases. The evaluations were based on the results of the most recent triennial inspection along with inspector(s) knowledge of the site. The screening criteria are:

1. A relatively large number of operator manual actions (OMAs) used to mitigate cable separation issues.

2. A single fire that could affect more than one unit. A multi-unit site with significant cross-unit distribution of safety-related and safe shutdown electrical loads while at power may necessitate multi-unit shutdowns for a fire in a single area, making operator response more complex.

3. The use of thermoplastic cable insulation. In postulated fires, damage to such cables occurs at lower temperature and longer distances from the fire source, compared to the more commonly used thermoset cables.

4. Limited documentation of cable routing within the plant. Licensees possessing limited information regarding the routing of all cables could result in higher reliance on safe shutdown strategies with elevated risk.

5. A Self-Induced Station Black-Out (SISBO) strategy (isolating on-site power to basically everything except the protected train to prevent spurious actuations) for fires in areas without adequate cable separation. This strategy may unnecessarily remove equipment that may not be damaged by the fire and therefore might otherwise be available for safe shutdown. The working group considered this strategy sufficiently important that they decided to double-weight this criterion. The SISBO strategy was only considered where the entire plant was de-energized downstream of the startup transformers. Plants that had breaker realignments due to coordination problems or limited equipment isolation were not considered as using the SISBO strategy.

6. Use of complex OMAs. Complex OMAs are those which require several steps to restore a function or require coordination between more than one operator in different locations.

Whether or not operators would have sufficient time to complete the OMAs was also a consideration when determining if the OMAs could be implemented in a fire scenario.

7. Mitigation of a fire requires cross-tying electrical or mechanical systems from multiple units in order to achieve safe shutdown for a fire in a single area.

8. Symptom-based fire response procedures with complex OMAs. Requiring operators to identify and diagnose multiple equipment damage scenarios in order to select the appropriate responses increases the complexity and operator stress involved, potentially reducing the reliability of the OMAs. Also, because of the potential for fragmented responses through use of these procedures, initial actions may be disrupted by later operator actions.

In addition to the entry condition of having potential issues with protection or separation, the working group preliminarily determined that your plant may share the conditions described in criteria 1, 2, 5, 6, 7, and 8 above.

CP&L 3 During the June 8, 2010 public meeting the NRC staff will be available to discuss these screening criteria in more detail and will provide you with an opportunity to present any information on the applicability of these criteria to your plant. For example, these criteria may have been identified and appropriately mitigated through your plants transition to NFPA 805. It would be beneficial if an individual familiar with your fire protection safe shutdown program and fire PRA attended the meeting.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of the Agencywide Document Access Management System (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this meeting, please contact me at 404-997-4530.

Sincerely,

/RA/

Rebecca L. Nease, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 cc: See page 4

CP&L 4 cc w/encl:

R. J. Duncan, II Annette H. Pope Vice President Supervisor, Licensing/Regulatory Programs Nuclear Operations Brunswick Steam Electric Plant Carolina Power & Light Company Progress Energy Carolinas, Inc.

Electronic Mail Distribution Electronic Mail Distribution Director Site Operations Senior Resident Inspector Brunswick Steam Electric Plant U.S. Nuclear Regulatory Commission Electronic Mail Distribution Brunswick Steam Electric Plant U.S. NRC Edward L. Wills, Jr. 8470 River Road, SE Plant General Manager Southport, NC 28461 Brunswick Steam Electric Plant Progress Energy Carolinas, Inc. John H. O'Neill, Jr.

Electronic Mail Distribution Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Christos Kamilaris Washington, DC 20037-1128 Director Fleet Support Services Peggy Force Carolina Power & Light Company Assistant Attorney General Electronic Mail Distribution State of North Carolina P.O. Box 629 Joseph W. Donahue Raleigh, NC 27602 Vice President Nuclear Oversight Chairman Carolina Power and Light Company North Carolina Utilities Commission Electronic Mail Distribution Electronic Mail Distribution Brian C. McCabe Robert P. Gruber Manager, Nuclear Regulatory Affairs Executive Director Progress Energy Carolinas, Inc. Public Staff - NCUC Electronic Mail Distribution 4326 Mail Service Center Raleigh, NC 27699-4326 Phyllis N. Mentel Manager, Support Services Brunswick County Board of Commissioners Brunswick Steam Electric Plant P.O. Box 249 Progress Energy Carolinas, Inc. Bolivia, NC 28422 Electronic Mail Distribution James Ross Michael S. Williams Nuclear Energy Institute Manager, Training Electronic Mail Distribution Brunswick Steam Electric Plant Progress Energy Carolinas, Inc. (cc contd - See page 5)

Electronic Mail Distribution (Vacant)

Manager License Renewal Progress Energy Electronic Mail Distribution

CP&L 5 (cc contd)

Public Service Commission State of South Carolina P.O. Box 11649 Columbia, SC 29211 W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Warren Lee Emergency Management Director New Hanover County Department of Emergency Management 230 Government Center Drive Suite 115 Wilmington, NC 28403

Letter to Michael J. Annacone from Rebecca L. Nease dated May 21, 2010.

SUBJECT:

PUBLIC MEETING TO DISCUSS FIRE PROTECTION SCREENING CRITERIA IDENTIFIED AT BROWNS FERRY AND THEIR IMPLICATIONS TO BRUNSWICK STEAM ELECTRIC PLANT - DOCKET NOS. 05000325 AND 05000324 Distribution:

RIDSNRRDIRS PUBLIC RidsNrrPMBrunswick Resource G PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE G NON-SENSITIVE ADAMS: G Yes ACCESSION NUMBER:_________________________ G SUNSI REVIEW COMPLETE OFFICE RII:DRS RII:DRS RII:DRS RII:DRS RII:DRP RII:DRP SIGNATURE RA RA RA RA NAME STAPLES NEASE CHRISTENSEN MUSSER DATE 5/20/2010 5/21/2010 5/21/2010 5/21/2010 5/ /2010 5/ /2010 5/ /2010 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: S:\DRS\ENG BRANCH 2\BRUNSWICK LTR TO LICENSEE(STAPLES).DOCX