ML111530405
| ML111530405 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/26/2011 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Plant Licensing Branch IV |
| Polickoski J, NRR/DORL/LPL4, 415-5430 | |
| References | |
| Download: ML111530405 (26) | |
Text
Callaway Plant NFPA 805 Transition Project 05.26.11 Pre-Application Meeting with NRC
MEETING OBJECTIVES
Introductions
Ameren Missouris NFPA 805 Transition Status Overview Callaway Plant Design Features Fire protection program overview Probabilistic Risk Assessment development/results Discuss Modifications Additi l It ti NRC l
2 Pre-Application Meeting with NRC Additional Items requesting NRC approval Discuss Challenges
INTRODUCTIONS Callaway Plant Representatives
- Michael Fletcher..Consulting Engineer Regulatory Initiatives
- Greg Harris..Consulting Engineer Regulatory Initiatives
- Justin Hiller..Acting PRA Supervisor Regulatory Affairs
- Roger Wink..Supervising Engineer Regulatory Initiatives 3
Pre-Application Meeting with NRC Project Consultants - EPM and Scientech
- Tom Jutras..Fire Protection Engineering Group Manager
- Jeff Julius........ FPRA Technical Manager
- Bob Bertucio.FPRA Technical Lead
PROJECT TEAM (PERSONS NOT PRESENT)
Callaway Plant
- Lee Eitel.Supervising Engineer, Station Fire Protection Engineer
- Sam Cantrell..Fire Protection Engineer
- Emily Fast...Licensing Engineer
- Josh Bollinger.Electrical Design Engineer 4
Pre-Application Meeting with NRC
- Pranavi TellaElectrical Design Engineer
- Stan Putthoff..Retired SRO/training instructor
- Paul Miller...Retired SRO/training instructor
- Jim JohnsonRetired Fire Protection System Engineer
PROJECT TEAM (PERSONS NOT PRESENT)
- Francesco PellizzariTechnical Manager, Electrical/Systems Engineer
- Mark Schairer.Consulting Engineer
- Beth HigginsSenior Staff Engineer
- Jason LeMaireSenior Staff Engineer 5
Pre-Application Meeting with NRC Scientech
- Justin HoweSenior PRA Analyst
AMEREN MISSOURIS NFPA 805 TRANSITION STATUS Ameren Missouri will make a full NFPA 805 LAR submittal in fiscal year 2011
- Working towards submittal by June 29, 2011 with challenges
- Internal reviews are currently underway followed by final Onsite Review Committee Review and Approval 6
Pre-Application Meeting with NRC
- Using the Nuclear Energy Institute (NEI) LAR template
- SharePoint site being pursued for NRC reviewers
- LAR ~ 1500 pages
TRANSITION ACTIVITIES The transition to NFPA 805 includes the following high level activities:
A new Nuclear Safety Capability Assessment (NSCA)
Developed a Fire PRA (FPRA) using NUREG/CR 6850 Control Room Evacuation Thermal Hydraulic Analysis redone 7
Pre-Application Meeting with NRC New SAFE database: repository for NSCA, Fire Scenarios, cable routing information Modifications to the plant NFPA Code Evaluations for required FP systems/features
OVERVIEW CALLAWAY PLANT DESIGN FEATURES
- 4-loop Westinghouse PWR
- 3565 MWth
- Large, dry containment (2.5 million Cu. Ft.)
- 2 physically separated, independently powered safety trains 8
Pre-Application Meeting with NRC
- Ultimate Heat Sink (UHS) consists of a seismic Category I mechanical draft cooling tower (2 cells/train) and retention pond with 30 day inventory
FIRE PROTECTION PROGRAM OVERVIEW Current licensing basis Fire Protection Program Standard License Condition FSAR Section 9.5.1 (Standard plant and Site addendum)
FSAR Fi H
d A l
i / 87 Fi A
9 Pre-Application Meeting with NRC FSAR Fire Hazards Analysis / 87 Fire Areas FSAR Appendix Comparison to BTP APCSB 9.5-1 FSAR Appendix Comparison to 10 CFR 50 Appendix R
FIRE PROTECTION PROGRAM OVERVIEW Callaway Electrical Raceway Fire Barrier System (ERFBS)
Originally utilized Thermo-lag for ERFBS Replaced With Darmatt KM1
- Testing meets GL 86-10 Sup 1 for 1 & 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> ratings 10 Pre-Application Meeting with NRC
- Used on cable tray and conduit 1 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> applications Degraded Darmatt ERFBS applications evaluated as Variances from Deterministic Requirements (VFDRs) following pilot plant process
- 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> wrap on trays with missing termination collar
- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> wrap on conduit with material notch due to interference
FIRE PROTECTION PROGRAM OVERVIEW Halon A Halon system is used as the primary extinguishing agent in selected switchgear rooms The system is activated by cross-zoned ionization detection 11 Pre-Application Meeting with NRC Installed in accordance with the requirements of NFPA 12A, "Standard on Halogenated Fire Extinguishing Agent Systems -
Halon 1301
FIRE PROTECTION PROGRAM OVERVIEW Radiation Release Evaluation Followed FAQ 09-0056 Rev. 2 and NRC Closure Memo guidance Evaluated on a fire area basis Using engineering controls for gaseous/liquid effluents in the permanent RCA 12 Pre-Application Meeting with NRC permanent RCA Using a combination of engineering controls and a bounding analysis in other areas
FIRE PROTECTION PROGRAM OVERVIEW Monitoring Following draft FAQ 10-0059 Rev. 1 Guidance Will utilize existing site monitoring / trending processes for general Fire Protection features 13 Pre-Application Meeting with NRC Will use the FAQ risk achievement worth (RAW) screening criteria to identify risk important features/SSCs for enhanced monitoring supplemented by a new monitoring procedure
FIRE PROTECTION PROGRAM OVERVIEW Non Power Operations (NPO)
Followed FAQ 07-0040 Rev. 4 guidance Fire modeling was not used to eliminate pinch point identification Entry point defined as Mode 4 when RHR is aligned to RCS loops 51 fire areas with no KSF pinch points 15 fire areas use defense in depth risk reduction tools during HREs 14 Pre-Application Meeting with NRC p
g Remaining fire areas use a combination of risk reduction tools during HREs
- Defense in depth
- Pre-fire equipment configuration changes
- Verification of fixed Fire Protection system operability
- Prohibition of Hot Work
FIRE PROTECTION PROGRAM OVERVIEW Attachment C, Table B-3, Fire Area Transition 81 fire areas following transition Fire Safety Analysis (FSA) are in final site acceptance reviews Table B-3 describes on a fire area basis
- Methods for meeting NSPC 15 Pre-Application Meeting with NRC Methods for meeting NSPC
- Licensing Actions
- Existing Engineering Equivalency Evaluations
- Variances from Deterministic Requirements
- Required FP systems and features
FIRE PROTECTION PROGRAM OVERVIEW Recovery Actions (RA)
Described in Attachment G Developed per NEI 04-02, FAQ 07-0030, Rev 5, & RG 1.205 Auxiliary Shutdown Panel is primary control station for alternate shutdown strategy 16 Pre-Application Meeting with NRC The final set of RAs are provided in Table G-1 Have verified RAs feasible and reliable
FIRE PROTECTION PROGRAM OVERVIEW Callaway Safe and Stable Followed NFPA 805 and FAQ 08-0054 Rev. 1 Guidance 17 Pre-Application Meeting with NRC
FPRA DEVELOPMENT/RESULTS FPRA follows guidance of NUREG/CR-6850 Fire PRA Peer Review:
- Performed Oct. 2009 (report issued March, 2010)
- The Findings and Observations (F&Os) and dispositions are provided in Tables V-1 & V-2
- FPRA meets Capability Category II in most but not all cases 31 Fi di d S ti 18 Pre-Application Meeting with NRC
- 31 Findings and Suggestions
- All FPRA Peer Review Findings are addressed
- Table W-2 provides the risk increases associated with VFDRs
- The total change in risk associated with the transition to NFPA 805 meets acceptance criteria
- FPRA builds upon the Internal Events PRA
INTERNAL EVENTS PRA DEVELOPMENT/RESULTS Internal Events PRA Update 4 was the Fire PRA starting point In 2006, the Internal Events PRA underwent a gap assessment against the CC II requirements of the standard To close the identified gaps a large-effort PRA upgrade project was initiated in 2007 All Fi di th t i t th FPRA h b
dd d
d 19 Pre-Application Meeting with NRC
- All Findings that impact the FPRA have been addressed and are summarized in the next slide Internal Events PRA model upgrade project is ongoing
- The objective is to close gaps to meet RG 1.200 Rev 1
- Peer review is scheduled for August, 2011 with model going live after RF18 in November, 2011
INTERNAL EVENTS PRA DEVELOPMENT/RESULTS Since the Fire PRA was developed concurrent with the IE PRA upgrade project, the IE PRA upgrade gaps were categorized as follows:
- Category A - Gaps that could have the highest impact on the fire PRA, and therefore should be addressed prior to the fire PRA peer review
- Category B - Gaps that would likely have a lesser impact on the fire PRA, but should be addressed prior to submittal of the NFPA 805 LAR
- Category C - Gaps that will be addressed as part of the internal events 20 Pre-Application Meeting with NRC PRA upgrade, but would not impact the fire PRA used for the transition to NFPA-805 Category A & B gaps are described, and dispositioned relative to the Fire PRA, in Table U-1 Justification for the Category C gaps is provided in disposition column of Table U-2
FPRA DEVELOPMENT/RESULTS The NFPA 805 transition process is still dynamic. Some adjustments to the list of Recovery Actions may be warranted prior to completion of implementation.
3 Phases:
1)
Pre-LAR submittal: Initial FPRA development, peer review, and application to FREs is complete; resulting in a complete set of plant modifications and recovery actions 2)
LAR re ie phase D ring this phase there likel ill be ind str 21 Pre-Application Meeting with NRC 2)
LAR review phase: During this phase there likely will be industry improvements to FPRA methods and data, there will be routine and potentially targeted improvements to the plant-specific internal events PRA which is the underlying basis for the FPRA, as well as reviewing insights from the FPRA 3)
Implementation: As the plant implements modifications, procedure changes, and training the FPRA will be updated None of the additional adjustments are expected to result in a significant change to the risk profile in the LAR submittal.
MODIFICATIONS COMPLETED Mod number Description MP 10-0032 Installed a non-safety related AFW pump (4th AFW pump) as a diverse backup to the safety related MDAFW and TDAFW pumps. Electrically powered by new offsite alternate emergency supply.
MP 10-0038 Installed 4 non-safety diesel generators (8 MW) at nearby electric cooperative substation. Capable of supplying power to either Safety Related bus and NSAFW pump under SBO conditions 22 Pre-Application Meeting with NRC conditions.
MP 07-0066 The buried carbon steel ESW piping was replaced with HDPE piping. During the piping replacement the cabling associated with EFTE0067A and 68A was relocated to restore the required 20 foot separation criteria.
CAR 201002877 Upgrade sprinkler heads in selected electrical cable chases to the quick response type. Fast acting sprinklers are credited to minimize fire damage assumed by fire modeling.
MODIFICATIONS PLANNED Mod number Description MP 05-3029 Installs lower amperage fuses for various control circuits in the MCR. Prevents damage to cables and prevent secondary fires in MCR MP 07-0151 During a MCR fire, the cables to B train powered equipment are isolated to prevent a MSO hot short from stopping or 23 Pre-Application Meeting with NRC g
starting safety equipment. Additional isolation switches and redundant fuses being added for equipment used in the evacuation procedure MP 09-0025 Reroutes cables to prevent fire damage from potentially causing RWST to drain to containment sump in event of a MSO
ADDITIONAL ITEMS REQUESTING NRC APPROVAL Use of fire protection water supply for off normal plant evolutions other than fire protection Non-rated plenum cabling above suspended ceilings in non-critical areas Removal of the FSAR requirement to enter TS 3.0.3 with an i
bl Fi S
i W t S
t d
b k
fi 24 Pre-Application Meeting with NRC inoperable Fire Suppression Water System and a back up fire suppression water system not provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Main Generator Current Transformer
CHALLENGES Challenges in completing a full submittal by 6/29/11
- Site and Vendor resource constraints
- Final site approval of supporting calculations/documents
- Completing final site reviews and approvals of LAR 25 Pre-Application Meeting with NRC
Questions?
26 Pre-Application Meeting with NRC