ML102430172

Trip Report on Observing the National Fire Protection Association 805 Readiness Self Assessment Performed at the Shearon Harris Nuclear Plant

ML102430172
Person / Time
Site:	Harris
Issue date:	10/05/2010
From:	Barrett H, Vaaler M, Robert Vettori Office of Nuclear Reactor Regulation
To:	Klein A Office of Nuclear Reactor Regulation
barrett H, NRR/DRA/AFPB 415-1402
References
Download: ML102430172 (4)

Text

October 5, 2010 MEMORANDUM TO: Alexander R. Klein, Chief Fire Protection Branch Office of Nuclear Reactor Regulation FROM: Harold T. Barrett /RA/

Fire Protection Branch Office of Nuclear Reactor Regulation Robert Vettori /RA/

Fire Protection Branch Office of Nuclear Reactor Regulation Marlayna Vaaler /RA/

Division of Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

TRIP REPORT ON OBSERVING THE NATIONAL FIRE PROTECTION ASSOCIATION 805 READINESS SELF ASSESSMENT PERFORMED AT THE SHEARON HARRIS NUCLEAR PLANT On June 7 - June 10, 2010, the U. S Nuclear Regulatory Commission (NRC) staff (Harry Barrett, Bob Vettori, Marlayna Vaaler, from the office of Nuclear Reactor Regulation (NRR) and Norm Merriweather of Region II) traveled to the Shearon Harris nuclear plant in New Hill, NC in order to observe the licensee perform a self assessment audit of their fire protection program.

The purpose of the self assessment was to determine the readiness of the site to implement a risk-informed, performance-based fire protection program in accordance with National Fire Protection Association (NFPA) 805.

The self assessment audit was performed under the requirements of the quality assurance program at the Harris plant. The self assessment audit was performed by a diverse, multi-disciplinary team that included both Progress Energy and industry expert personnel.

The self assessment audit team utilized a draft version of the NFPA 805 license amendment request safety evaluation as the basis of the audit. The primary focus of the audit was the CONTACT: Harold Barrett, NRR.DRA/APFB (301) 415-1402

A. Klein planned activities to close those items called out in the safety evaluation that had not been completed at the time the safety evaluation was drafted (identified in the safety evaluation as Implementation Items).

The licensees audit team found that in general, Progress Energy was ready to implement the NFPA 805 program. However, the team did have audit findings that were communicated to management. The audit findings broke down into findings (deficiencies) and recommendations.

There were three findings and one recommendation. The first finding related to the awareness of the NFPA 805 Fire Protection Program outside the Fire Protection Group at Harris. The second finding identified numerous procedure issues, including significant issues related to the Fire Protection Program Change Process. The third finding identified issues related to the design and installation of the Incipient Fire Detection System modification. The recommendation suggested that the licensee consider developing a high level roadmap or flowchart for the NFPA 805 process.

The staff noted that it is important for the licensee to inform station staff about the NFPA 805 Program in the early stages of the NFPA 805 pilot program, so they understand their new responsibilities under NFPA 805 to assure compliance.

The NRC staff observed that the licensee had several hundred procedure revisions and numerous calculations that needed to be revised. The licensee indicated that their plans were to complete this work before the fall refueling outage at Harris.

It is also noteworthy that the licensee is planning a significant change to their combustible control program prior to the refueling outage. The staff observed that there are several fire areas at Harris that rely on the lack of combustibles to maintain the risk to an acceptable level.

Making a significant change to the combustible control program immediately prior to a refueling outage will require diligence and good communications.

The NRC staff was interested to see how the licensee completed the NFPA 805 Monitoring Program at Harris. At the time of the Readiness Self-Assessment, only some of the monitoring program tasks had been completed. Based on the completion status and the remaining work to be done, the staff expressed interest in observing the completion of the monitoring program later in the implementation window.

A. Klein Based on the volume of work that needs to be done, and the nature of some of the tasks, the staff recommends that NRR staff plan a visit to Harris later in the implementation window to observe progress and learn any additional lessons with respect to NFPA 805 implementation.

ML102430172 OFFICE NRR/DRA/AFPB NRR/DRA/AFPB NRR/DORL NRR/DRA/AFPB NAME HBarrett RVettori MVaaler A Klein DATE 08/ 31 /2010 08/ 31 /2010 09/ 03 /2010 10/ 05 /2010