ML11152A080

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Summary of March 31, 2011, Meeting with South Carolina Electric and Gas Company to Discuss NFPA-805 License Amendment
ML11152A080
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 06/14/2011
From: Martin R
Plant Licensing Branch II
To:
Office of Nuclear Reactor Regulation
Martin R, , DORL/LPL2-1 415-1493
References
TAC ME5954
Download: ML11152A080 (16)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 14, 2011 LICENSEE: South Carolina Electric and Gas Company, Inc.

FACILITY: Virgil C. Summer Nuclear Station (VCSNS), Unit No.1 SUB~IECT:

SUMMARY

OF MARCH 31, 2011, MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY TO DISCUSS NFPA-B05 LICENSE AMENDMENT (TAC NO. ME5954)

On March 31, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of South Carolina Electric and Gas Company, Inc. (SCE&G, the licensee), at NRC Headquarters in Rockville, Maryland. SCE&G requested the public meeting to discuss the current status of its plans to submit a license amendment request (LAR) based on the National Fire Protection Association Standard B05, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (NFPA-B05). A list of attendees is provided as Enclosure 1.

SCE&G's presentation (see Enclosure 2) included the following topics:

  • NFPA-B05 Project Goals: Submit an LAR to transition VCSNS Unit 1 to a performance based fire protection program via NFPA-B05. This would include eliminating the self induced station blackout (SISBO) strategy, minimization of operator manual actions (OMAs) for fire occurring outside the main control room and addressing all current industry issues concerning multiple hot shorts/spurious events, the feasibility of operator actions and "authorized" use of OMAs.
  • NFPA-B05 Project Status
  • Nuclear Safety Compliance Assessment (NSCA)
  • Major Transition Report Attachments
  • VC Summer Fire PRA Results - The Fire PRA (FPRA) core damage frequency takes credit for modifications on protecting circuits, alternate seal injection, incipient detection and reactor coolant pump shutdown seals.
  • Fire PRA Results Summary including dominant risk sequences
  • Relative improvement value of modifications
  • Significant Peer Findings
  • Performance-Based Solutions
  • Performance-Based Fire Modeling

SCE&G -2

  • General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
  • Nonpower Operations
  • Radioactive Release Analysis
  • Implementation Actions
  • Condition Monitoring
  • NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
  • NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.

The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.

Members of the public representing other utilities and industry groups were in attendance.

Public Meeting Feedback forms were available at the meeting but no comments were received.

j) Robert Martin, s7nt;?~ger Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. List of Attendees
2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation] Staff, March 31, 2011 cc w/encls: Distribution via Listserv

LIST OF ATTENDEES NRC MEETING WITH SOUTH CAROLINA ELECTRIC AND GAS COMPANY, INC. (SCE&G)

REGARDING LICENSE AMENDMENT APPLICATION ON FIRE PROTECTION MARCH 31,2011 NAME AFFILIATION Robert Martin NRC/NRRlDORL Patrick Boyle NRC/NRRlDORL Paul Lain NRC/NRRlDRA Alex Klein NRC/NRRIDRA Doug Pickett NRC/NRRIDORL Donnie Harrison NRC/NRRlDRA Stephen Dinsmore NRC/NRRlDRA Gary Cooper NRC/NRRlDRA Samson Lee NRC/NRRlDRA Dan Gatlin SCE&G George Williams SCE&G Eric Rumfelt SCE&G Gerald LOignon, Jr SCE&G Wayne Stuart SCE&G Gil Williams SCE&G Bruce Thompson SCE&G Michael Kammer SCE&G Tom Basso NEI Via Telephone Conference Bridge Line

  • Robert Layton PNNL Bijan Najafi SAIC Paul Amico SAIC Larry Young Entergy Vesna Dimitrijevic AREVA NP Michael Seaman-Huynh SC Office of Regulatory Staff Sal Dolcemascolo SONGS
  • based on prior notifications Enclosure 1

3/30/2011 NFPA805 Lice"nse //

Am __ .~. 9_ffTein'r~'r1e6'deS March 31,2011 VC Summer Attendees Dan Gatlin Vice President, VC Summer Unit 1 Wayne Stuart General Manager, Engineering Services Bruce Thompson Manager, Nuclear licensing Mike Kammer NFPA 805 Project Manager Gerald Loignon Supervisor, PRA Group Eric Rumfelt Supervisor, Nuclear Licensing George Williams Supervisor, Engineering Programs v.c. SUMMER NUCLEAR STATION Enclosure 2 1

3/30/2011 NFPA805 Project Goals NFPA805 Transition:

  • Successfully submit an LAR to transition VCSummer Unit 1 to a Performance Based Fire protection Program via NFPA80S (10CFRSO.48(c)) [Letter October 2006]

VC Summer Goals (Additional)

  • SISBO: Eliminate the SISBO Strategy

V.C. SUMMER NUCLEAR STATION NFPA805 Project Status Major Tasks

  • NSCA Modell Open Issues
  • FirePRA
  • Performance Based Resolution (VFDR)

- Fire Risk Evaluation

- Performance Based Fire Modeling

  • Non Power Operations
  • NFPA805: NFPA Code Compliance
  • Radioactive Release Analysis

- Administrativel Condition Monitoring V.C. SUMMER NUCLEAR STATION 2

3/30/2011 Nuclear Safety Compliance Assessment (NSCA)

Status/ Updates

  • PCCKS Updates Complete
  • Model Development: Open Issue Complete
  • NSCA Model Review (SCE&G) Complete
  • ECR Package Reviews (SCE&G) Complete
  • NSCA Model Updates Complete
  • Finalize Open Issues (DROID) Complete
  • Finalize Detailed Mod (Detail) Finalizing
  • Documentation/ SCE&G Reviews Finalizing V.C. SUMMER NUCLEAR STATION NSCA Open Items
  • ORal OS: NSCA Open Items
  • VFOR (Green):

Performance Based Solutions

  • Other Solutions
  • Modifications
  • Additional Circuit analysis
  • Model Updates V.C. SUMMER NUCLEAR STATION 3

3/30/2011 Major TR Attachments 1: Chapter 3 Compliance

  • No issues
  • Substantially Complete 2: Transition Shutdown Strategy
  • Issued for Review
  • Adding NFPA Compliance References
  • Note: Not transitioning existing SD strategy 3: Area by Area Assessment
  • Incorporating Fire Risk Evaluations v.c. SUMMER NUCLEAR STATION VC Summer Fire PRA FPRA Peer Reviews Complete Peer Review Comment Resolution May 2011 Documentation/ Final SCE&G review May 2011 V.C. SUMMER NUCLEAR STATION 4

3/30/2011 VC Summer Fire PRA Results Fire PRA*

  • CDF 3.83 E-05/yr
  • LERF 1.47 E-07/yr Internal Events PRA
  • CDF 1.67 E-05/yr
  • Includes credits for modifications V.C. SUMMER NUCLEAR STATION Fire PRA Results Summary Dominant Risk Sequences
  • Loss of RCP Seal Cooling With Seals Susceptible To Failure
  • Fire-induced Safety Injection in conjunction with PORV challenge
  • Consequential Steamline Break with EFW Pump Runout

\l.C. SUMMER NUCLEAR STATION 5

3/30/2011 Relative Improvement: Modifications

  • Protecting Circuits
  • Alternate Seal Injection
  • Incipient Detection
  • RCP Shutdown Seals v.c. SUMMER NUCLEAR STATION VCSNS FPRA Peer Reviews August 2010
  • 30 findings
  • Fire Scenario Selection: Not Reviewed
  • 3 SRs related to "new" procedures: Not Reviewed
  • 3 SRs related to Fa and UNC NR due to FSS NR February 2011: Focused Scope
  • 16 findings
  • Most findings involved providing more specific justification/documentation [Do not affect results]

Licensing Amendment Request

  • Contain all Findings, and
  • How each has been resolved V.C. SUMMER NUCLEAR STATION 6

3/30/2011 Significant Peer Findings FQ: Inability to create "one top" model results in inability to calculate importance measures Status: May 2011 Completion (Cutset reviews)

FSS: Some Main Control Room Abandonment Scenarios not quantified Status: Complete FSS: Dependency between automatic and manual suppression not considered Status: May 2011 Completion UNC: Sensitivity analysis was not completed (for LERF) report was still "draft" Status: May 2011 Completion V.C. SUMMER NUCLEAR STATION Performance Based Solutions General Information Total Fire Areas 71 Total DROIDS 597 Total VFDR 334 Fire Modeling (NFPA805, 4.2.4.1)

Total Fire Areas 5 Fire Areas Fire Risk Evaluations (NFPA805, 4.2.4.2)

Total Fire Area FRE 32 Status > 80%

V.C. SUIIIINIER NUCLEAR STATION 7

3/30/2011 Performance Based Fire Modeling NFPA805, Section 4.2.4.1

  • Maximum Expected Fire Scenario (MEFS)
  • Limiting Fire Scenario (LFS)

Manage "Fire" within Space

  • Address Fire Scenario (s)
  • Fuel Package
  • Fire Location
  • Fire Type Focus: Impact on "Area" Targets
  • Hot Gas Layer
  • Direct Heat Transfer (Radiation, Convective)

V.C. SUMIIIIER NUCLEAR STATION Modification Title General Discussion IProvide protection of tubingl circuits from the effects of NFPA805 Circuit! Tubing Protection fire(Train Separation! Spurious Operation)

NFPA805 RCP Seal Replacement IProvide lower leakage RCP Seals [Risk Reduction! Outage]

IEliminate affects of common TB West fire (TB01) affecting

.NFPA8051DA 115kV Supply Reroute 115kV and 230kV offsite power to 1DAI 1DB (Risk Reduction!

Outage]

NFPA805 Hazard Protection IProvide mitigation strategies to address fire initiators or means to propagate fires

. Provide autostart capability for the Diesel Driven Air NFPAa05 Instrument Air Recovery ICompressor (XACOO14) i Provide altemate backup, protected communication system to NFPA805 Communication Isupport fire event i Provide Incipient Detection System at the top of selected

~FPA805 Incipient Detection electrical panels in the Relay and Upper Cable Spreading i Rooms (Risk Reduction)

IProvide addition high pressure pump! Diesel Generator to Alternate Seal Injection (MSPI)

Imitigate loss of RCP seal cooling (Risk Reduction) 8

3/30/2011 Non Power Operations Preliminary Document Issued Complete SCE&G Internal Review: Complete Current Status May 2011

  • Restraint: Final NSCA Model Updates
  • Addressing Comments! Reissue
  • Finalizing DROIDs! Final SCE&G Review V.C. SUlllllllfER NUCLEAR STATION Radioactive Release Analysis
  • Completed (2009)
  • Readdressing due to FA009-0056 (4th Otr 2011)
  • OutSide Radioactive Release study
  • Radioactive Release Report In Process

- Impact: Fire Preplans and coordination with HPJ Chemistry

- Address Gaseous J Liquid Release V.C. SUMMER NUClEAR STATION 9

3/30/2011 Implementation Actions

  • Modification Scoping
  • Engineering Procedures
  • Condition Monitoring Program FAQ10-0059
  • Fire Preplans
  • Fire Brigade Training Updates
  • Fire Protection Admin Procedures
  • Resolution of Code Requirements / Self Assessments
  • Fire Safety Analysis
  • Operations Procedure/ Training V.C. SUMMER NUCLEAR STATION Condition Monitoring Reliability/ Availability being measured Data back fit for FP Features Procedure/ Model Developed (Samples)
  • FS Detectors
  • FS Alarm System
  • FS Main
  • Fire Pumps Monitoring FAQ10-0059 Resolution V.C. SUMIIIIER NUCLEAR STATION 10

3/30/2011 NFPA 805 Project Issues Project Challenges

  • VC Summer RF19 (April/ May 2011)

Station Management Reviews of NFPA805 LARI Transition Report LAR Significant Issuesl Gaps

  • None identified or expected LARI Transition Report
  • June 28, 2011 v.c. SUMMER NUCLEAR STATION NFPA805 Project Results NFPA805 Transition:

VC Summer Goals (Additional)

  • SISBO: Eliminate the SISBO Strategy [Accomplished]

V.C. SUMMER NUCLEAR STATION 11

3/30/2011 Questions V.C. SUIIIIIIIIER NUCLEAR STATION 12

SCE&G -2

  • General discussion of modifications. SCE&G stated that it will take at least 3 refueling outages (RFOs) after the 2011 RFO to implement the 8 modification groups. RCP seal replacement will take place over 2 to 3 outages. Alternate seal injection will involve provision of an additional high pressure pump/diesel generator.
  • Nonpower Operations
  • Radioactive Release Analysis
  • Implementation Actions
  • Condition Monitoring
  • NFPA-805 Project Issues - including station management review of the transition report and targeted submittal of the LAR by June 28, 2011.
  • NFPA-805 Project Results. SCE&G stated that their goal to eliminate the SISBO strategy had been accomplished. They will go from numerous OMAs with SISBO to no manual actions for fires outside the control room. Most of the operator actions in the current situation are to remove power. They will make modifications to eliminate the need to remove power.

The NRC staff had several questions/comments for consideration by SCE&G in the LAR. The licensee noted that the fire protection audits currently required in the technical specifications will be transferred to the quality assurance program (NQA-1). SCE&G indicated that the following issues would be addressed in the LAR: the self-approval process, performance-based alternatives and the delta-CDF values. SCE&G also noted that the LAR would be on the order of 500 - 1000 pages in length.

Members of the public representing other utilities and industry groups were in attendance.

Public Meeting Feedback forms were available at the meeting but no comments were received.

IRA!

Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. List of Attendees
2. Licensee's Presentation, "NFPA805 License Amendment Request Pre-application Meeting with NRR [Office of Nuclear Reactor Regulation1 Staff, March 31, 2011 cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-1 RtF RidsOgcRp Resource PLain, NRR RidsAcrsAcnw_MailCTR Resource RidsRgn2MailCenter Resource SBush-Goddard, EDO Region 2 RidsNrrDraAfpb Resource RidsNrrDorlLpl2-1 Resource AKlein, NRR RidsNrrLAMOBrienResource RidsNrrPMSummer Resource DPickett. NRR PBoyle, NRR RidsOpaMailResource DHarrison, NRR SDinsmore. NRR GCooper, NRR SLee, NRR ADAMS Accession No ML11152A080 PFFICE DORULPL2-1tPM DORULPL2-1/LA DORULPL2-1/BC DORULPL2-1/PM NAME RMartin MOBrien GKulesa RMartin wtminor changes DATE 06/08/2011 06/06/2011 06/14/2011 06/1412011 OFFICIAL RECORD COpy

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