ML12223A191
| ML12223A191 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/21/2012 |
| From: | Boska J Plant Licensing Branch II |
| To: | Duke Energy Carolinas |
| Boska, J P | |
| Shared Package | |
| ML12223A142 | List: |
| References | |
| TAC ME8814, TAC ME8815, TAC ME8816 | |
| Download: ML12223A191 (32) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Augus t 21, 2012 LICENSEE: Duke Energy Carolinas, LLC FACILITY: Oconee Nuclear Station, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF JULY 19, 2012, MEETING WITH DUKE ENERGY CAROLINAS, LLC, TO DISCUSS NFPA-B05IMPLEMENTATION AT OCONEE NUCLEAR STATION, UNITS 1,2, AND 3 (TACS MEBB14, MEBB15, AND MEBB16)
On July 19, 2012, a Category 1 public meeting was held between the U.S . Nuclear Regulatory Commission (NRC) and representatives of Duke Energy Carolinas, LLC (the licensee) at NRC Headquarters, One White Flint North , 11555 Rockville Pike, Rockville, Maryland . A list of attendees is enclosed. The purpose of the meeting was to allow the licensee to update the NRC staff on the status of the implementation of their new fire protection program based on National Fire Protection Association Standard B05 (NFPA-B05) at the Oconee Nuclear Station, Units 1, 2, and 3 (ONS 1/2/3). The licensee had committed to implement NFPA-B05 in order to demonstrate compliance with the NRC fire protection regulations, Title 10 of the Code of Federal Regulations, Part 50, Section 50.4B . The NRC staff had completed its review of the license amendment requesting approval of the transition to NFPA-B05, and issued the license amendments approving the transition on December 29, 2010 (ADAMS Accession No. ML103630612).
The licensee's presentation is in the attached handout. The licensee reported delays in the installation of their new Protected Service Water (PSW) system, which they had committed to install as part of implementing NFPA-B05. The PSW system is a diverse system to other plant systems for the mitigation of fires and high-energy line breaks (HELBs) . The PSW system consists of new electrical power supplies for existing plant safety systems, as well as a replacement pump for the station auxiliary service water pump, which adds water to the steam generators in order to remove decay heat from the reactor coolant system once the reactor is shutdown, if the normal plant systems are not available. The installation of the PSW system will reduce the overall plant risk in the event of a fire or HELB at the Oconee site. During the meeting , the licensee indicated that although the majority of the system has been installed, they are experiencing delays in completing the PSW system installation. The licensee will submit a license amendment request to the NRC to extend the required completion date of January 1, 2013. The licensee also plans to ask for extensions to the completion dates for other modifications, such as upgrading the penetrations in the wall between the turbine building and the auxiliary building, and installing additional fire detection equipment in ONS3.
-2 The licensee proposed to complete a partial implementation of the PSW system by the end of 2012. This would allow the PSW switchgear in the new PSW Building to be energized from two separate power sources, and would allow the Standby Shutdown Facility to be energized from the PSW building if the diesel generator in the SSF malfunctioned . The licensee stated that the risk benefit from a partial implementation of PSW should be sufficient to meet the risk reduction that the NRC staff had credited for implementation of PSW. The NRC staff stated that if quantitative risk estimates were to be relied on to support the request, this would be a risk informed submittal. A risk-informed submittal would require a review of the technical adequacy of the probabilistic risk assessment (PRA) . The NRC staff also noted that such a license amendment request would not appear to follow the guidance of NRC Regulatory Guide 1.200, in that the PRA results for large early release frequency for radioactive releases from the reactor containment building did not yet have a focused peer review. Therefore, the licensee should expect to receive a detailed review of the PRA, which may delay the staff's decision on a license amendment request. The licensee indicated that they would consider a simple request for an extension of time that does not rely on quantitative risk estimates, which may allow a quicker review by the NRC staff.
Public Meeting Feedback forms were made available at the meeting. As of the date of this meeting summary, no feedback forms have been received .
Please direct any inquiries to me at 301-415-2901, or by email to John.Boska@nrc.gov.
v.~
hn P. Boska, Senior Project Manager lant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosures:
- 1. List of Attendees
- 2. Licensee Handout cc w/encls : Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION MEETING ATTENDANCE FORM
Subject:
Oconee Nuclear Station, Modification of NFPA-805 License Condition Date: July 19, 2012 Location: OWFN, room 0-486 PLEASE PRINT LEGIBLY NAME ORGANIZA TION
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Fire Protection License Amendment NFPA 805 National Fire Protection Association Protected Service Water Partial ScoDe Implementat July 19, 2012
Introductions
NFPA805 Fire Protection Project
- David Baxter - Vice President Nuclear Engineering
- Richard Freudenberger - Regulatory Affairs Manager
- David Goforth - NFPA 805 Technical Manager
- Ed Simbles - Fire PRA
- Reene' Gambrell- Regulatory Compliance Information Only
'=y~ 2
Agenda R~~!o~!~ 4
- Opening Remarks
- Oconee Nuclear Station (ONS) Implementation Status
- Protected Service Water (PSW) Overview
- PSW Partial Scope Implementation
- PSW Risk Benefit
- Peer Review for Fire Probabilistic Risk Assessment (PRA)
- Internal Events PRA
- Modification Commitment Changes
- PSW Implementation Items Info rmation Only I::::"YG 3
Agenda (cont'd) NFPA805 Fire Protection Project
- Implementation Item Commitment Changes
- Contingency License Amendment Request (LAR)
- Summary
- Closing Informatio n Only tt=Jf<J 4
NFPA805 Opening Remarks
- Progress made on PSW modification and National Fire Protection Association (NFPA) 805 program implementation
- Objective for this LAR
- Clarify implementation item table to support close out by end of year
- Complete PSW Partial Scope implementation to offset VFDR risk
- Adjust modifications that extend past NFPA 805 implementation date and compensatory actions
- Does not include self-approval Information Only 1::!:"1'fIY~ 5
NFPA805 Protected Service Water - Overview Fire Protection Project
- PSW is 'V86% Complete
- Major activities coming up Back-up feed from the PSW building to the SSF Power from Keowee to the PSW building equipment PSW pump and piping installation PSW Licensing Activities
- Project Challenges Equipment procurement delays Environmental temperature qualification issues
=y~
Information Only 7
Protected Service Water Overview (cont'd) NFPA805 Fire Protection Project Photos from 6/28/12 PSW Cable Tray Installation PSW Pipe Installation Auxiliary Building Auxiliary Building
!tB:::-I'fW~
Information Only 8
Protected Service Water Overview (cont'd) NFPA805 Fire Protection Project Photos from 6/28/12 PSW Building Equipment PSW Duct bank Manhole Cover Information Only e:=.,Yo 9
Protected Service Water Overview (cont'd) NFPA805 Fire Protection Project Photos from 6/28/12 First Equipment energized in PSW PSW Pump Building: Motor Control Center XPSW Information Only Ie"Jfa 10
Protected Service Water Overview (cont'd)
Photos from 6/28/12 Breakers at Keowee PSW Booster Pump
=Jf~
Information Only 11
Protected Service Water NFPA805 Fire Protection Project Partial Scope Implementation
- PSW Partial Scope implementation Risk benefit sufficient to meet NFPA 805 requirements PSW Partial Scope includes:
- Power from lOOkV sou rce
- Power from Keowee Hydro Units
- Backup Power to Standby Shutdown Facility
- PSW Switchgear 10CFRSO.S9 review of PSW Partial Scope in progress NRC review / approval may be necessary
- Contingency Plan - NFPA 805 License Conditions Will submit LAR to change License Conditions by 7/31/12
- Self approval requires LAR submittal upon full scope implementation of PSW
'=y~
Information Only 12
Protected Service Water Overview NFPA805 (RED=PSW Partial Scope, BLUE=PSW Full Scope) Fire Protection Project Keowee Diagram for PSW Inslall new circuli breakers for PSW Civil & Electrical Power Scope ACB -9 ACB -10 1 13.8 KV Power Feeder Circuit Existing Underground 15 KV Cable fRee Is Keowoe 13.8 KV PSW Power Feed 100 KV CT-4 Xfmr "Lee" line to Blockhouse Central Pwr to U 11213 PSW Aft Turbine Loads & BacJcu.p Power to
'IJle following AS Eqpt Bldg , lUl l U 21U 3 HPI Pump" Power Feed 2IUlIU2/U.Vltall &c FromLe"
~ ____________________________________-+____ ~ea~I~~~~C~h~.~rg~
.~~ __~~ Una SSF I Backup Pwr for SSF Diesel Gene",{or InformatIon Only
=Y.. 13
NFPA 805 Protected Service Water Overview (cont'd) Fire Protection Project (RED=PSW Partial Scope, BLUE=PSW Full Scope)
Diagram for PSW Keowee Instrumentation & Control Scope Re-route Keowee Emergency Start Cables out of Turbine Bldg U1 & 2 Blockhouse MCR Ctrls for New PSW MCR Ctrls for New Turbine Bldg Pmp. SWitchgear & U1/U2 PSW U 3 Specific Eqpt .
Specific Eqpt . NewPSWXfmr
& Switchgear Bldg U1,125 U3,125 VDCBus VDCBus Aux Bldg Re-route Vital I &C Primary & Backup Power Cables out of Turbine Bldg Information Only 1
=11& 14
NFPA 805 Protected Service Water Overview (cont'd)
(RED=PSW Partial Scope, BLUE=PSW Full Scope)
Remove abandoned G
Diagram for PSW Keowee mechanical eqpt Mechanical Scope
. . . - - to make space for new Keowee PSW electrical eqpt Turbine Bldg ew ptp lng tsotallon \tlv.
'=y~
Information Only 15
NFPA805 Protected Service Water Risk Benefit Fire Protection Project
- Simplified PSW modeling assumptions applied in Fire PRA
- Risk offset (Core Damage Frequency (CDF) benefit) greater than 3E-OS per unit with full PSW
- Risk benefit expected to increase as installation details replace conservative assumptions
- Partial PSW Installation
- PSW risk offset crediting only PSW power to the SSF is greater than iE-OS per unit
- Cumulative Variance From Deterministic Requirement (VFDR) delta risk is less than iE-OS (delta CDF) per unit Information Only
'B:::"rgy<l 16
Peer Review For Fire PRA
- The ONS NFPA 805 Safety Evaluation (SE) included a License Condition to obtain a full-scope fire PRA peer review (Implementation Item 42)
- Peer review performed November of 2011 against requirements of Section 4 of Combined Standard using process defined in NEI 07-12
- Nine (9) findings generated against Supporting Requirements (SRs) which met Capability Category I; only four (4) SRs judged as not meeting the Standard
- All findings and suggestions have been addressed and are considered closed Information Only I~G 17
NFPA805 Internal Events PRA Fire Protection Project
- The ONS NFPA 805 SE included a License Condition to resolve Internal Events review findings and address Human Reliability Assessment (HRA) related concerns (Implementation Item 41)
- Updated the model to Oconee Revision 4 (or4)
- or4 closed the gaps relative to standard
- LERF Methodology Independent Self-Assessment versus Peer Review
- no gaps to Capability Category II (except for internal flooding & HELB)
Information Only I:::"rgy(l 18
NFPA805 Modification Commitment Changes
- Modification #1 PSW
- Split into modifications 1a & 1b
- la - Partial implementation scope
- lb - Full implementation scope
- Partial Implementation scope will complete December 31, 2012
- Full implementation scope managed by PSW Project commitment 8T
- Submit Self-Approval LAR after PSW full implementation
=y~
Information Only 19
NFPA805 Modification Commitment Changes (cont'd) Fire Protection Project
- Modification #2 Upgrade the Penetrations in the TB/AB Wall
- Address penetrations and sleeves below elevation 796 (scope increase)
- Will complete all work by December 2013. (June 2013)
- Modification #5 Fire Detection
- Extensive area of plant impacted by modification
- Requires extensive planning and coordination
- Will complete all work by Spring 2016 (Fall 2015)
"=y~
Information Only 20
NFPA805 Protected Service Water Implementation Items 9 Attachment A: Pre-fire Plans will be updated to include any changes to equipment LAR Table S-2, , and Section 3.4.2.1 important to nuclear safety and other updates pertinent to the NFPA 805 Attachment A Transition. Subsection 3.4.2.1 32 Attachment D: Incorporate the PSW partial scope modification into FPP site documents LAR Attachment C Fire Area PSW after the modification is implemented.
41 Section 3.4.3 With regard to the Internal Events PRA, complete the following: lAR section 4.5, PRA Quality -Determine whether the HRA model needs to be updated or upgraded. RAI Response
-Update/Upgrade the HRA model. (Reference 59)
-If HRA model was upgraded conduct a focus-scope peer review of the revised internal events PRA model with respect to HRA. Complete
-Disposition all findings from the peer review and revise the internal events PRA, as appropriate.
1:::"1'fW~
Information Only 1
Protected Service Water Implementation Items (cont'd)
F~~!~O~!~ . 4 42 Section 3.4.3 With regard to the Fire PRA, complete the following: Complete Update/upgrade the Fire PRA as appropriate to resolve NRC staff review finings in SE Attachment C, Table 3.4-2. F&Os have been Complete an industry full-scope peer review of the revised Fire PRA that dispositioned.
is performed to the ASME/ANS RA-Sa-2009 PRA standard, as endorsed by RG 1.200, Rev. 2. The full-scope peer review will include specific focus on the following elements:
Influence on the target set from fire propagation beyond the ignition source due to intervening combustibles and cables on:
Expanding the zone of influence (ZOI), both vertically and horizontally, and Hot gas layer (HGL) formation, including the effects on fire detection and brigade response.
Modeling of high-energy arcing faults on 4160/6900 volt (V) TB bus ducts.
Deviation from NUREG/CR-6850 guidance and as modified by closed FAQs will be treated as described in NEI 07-12 (Fire Probablistic Risk Assessment Peer Review Guidelines) and the fire aspects of ASME/ANS PRA Standard, as endorsed by RG 1.200.
Disposition findings from the full-scope Fire PRA peer review and revise the Fire PRA as appropriate.
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Information Only 22
Protected Service Water Implementation Items NFPA805 Fi re Protection Proj (cont'd)
- 43. Section 3.4.6 Confirm that the risk decrease from the as-built PSW partial scope modification LAR Section 4.2, RAI Cumulative Risk continues to bound the cumulative VFDR transition risk once the partial scope Response and Combined PSW modifications are installed. (Reference 52)
Changes
- 44. Section 3.2.1; The breaker coordination study will be updated to include all new NFPA 805 SSD LAR Section 4.2, RAI Section 3.3.1.7; equipment list {SSEL)-related power supplies (Le., PSW partial scope) for power Response Section 3.3.3.3; and non-power operations, and additional plant modification will be defined if (Reference 52)
Section 3.5.2.4; necessary to ensure that the assumptions of the Fire PRA and NSCA remain valid.
Section 3.5.2.5 Complete I::::rY~
Information Only 23
NFPA805 Implementation Item Commitment Changes Fire Protection Project
- Minor wording changes due to verbatim compliance
- Implementation Item 10 - Standard operating guidelines (SOG) will be updated to include a SOG with the location of the pre-fire plans.
- SOGs are not controlled so this information will be provided in a Fire Strategy Manual that is controlled
- Commitment changed to reflect this information Information Only
'I::!:::,Ya 24
Implementation Item Commitment Changes (cont'd)
R~~!!.8!~ 4
]
- Deletion of Implementation Items Implementation items redundant
- Implementation Item 16 addressed by Implementation Item 36 Implementation Items no longer necessary
- Implementation Item 22 - recovery actions are no longer being credited for Non-Power Operations so access to motor-operated valves are no longer necessary.
- Implementation items completed by December 31, 2012
- NFPA 805 implemented with exception of self-approval Information Only IB::::;,V., 25
NFPA 805 Contingency License Amendment Request Fi re Protection Project
- Submit 7/31/12
- Cover Letter
- Enclosure 1
- Attachments
- Fire PRA Insights (Update to Attachment W of ONS LAR dated April 14, 2010)
- Fire PRA Quality (Update to Attachment V of ONS LAR dated April 14, 2010)
- Internal Events PRA Quality
- Plant Modification Commitment Changes
- Implementation Items
~~
Information Only 26
Summary NFPA805 Fire Protection Project
- Protected Service Water Partial Scope Implementation
- PSW Risk Benefit
- Peer Review for Fire Probabilistic Risk Assessment (PRA)
- Modification/Implementation Items Commitment Changes
- LAR to be submitted 7/31/12 I::!::w~
Information Only 27
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ML12223A142 Notice ML12184A104 Summary ML12223A191 OFFICE DORLlLPL2-1/PM DORLlLPL2-1/LA DRAlAFPB/BC DRAlAPLAlBC NAME JBoska SFigueroa AKlein SDinsmore for BBeasley DATE 08/14/12 08/13/12 08/17/12 8117112 OFFICE DORULPL2-11,ac DORLlLPL2-1/PM NAME NSalgado ~ JBoska ::rs DATE 3 f 21 fnil I' 17.1 I, 2