ML12314A371
| ML12314A371 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/13/2012 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | |
| Chawla M | |
| References | |
| Download: ML12314A371 (31) | |
Text
Entergy - Palisades Nuclear Plant NFPA 805 License Amendment Request Pre-Submittal Meeting November 13, 2012 1
Attendees
- Barry Davis General Manager of Engineering
- Neil Lane Projects Manager
- Keith Smith Project Manager, NFPA 805
- Jeff Voskuil PRA
- Tom Swiecicki Fire Protection Lead
- Otto Gustafson Licensing Manager
- Amy Hazelhoff Licensing Lead
- Bob White ERIN Engineering (PRA) via phone 2
Agenda
- Overview of PNP
- Current Fire Protection Licensing Basis
- NFPA 805 Transition Project Overview
- Compliance with NFPA 805
- PRA Development & Results
- Schedule
- LAR Submittal
- Implementation Overview 3
Overview of PNP
- PWR Single Unit
- 2565.4 MWt, 805 MWe
- Systematic Evaluation Program (SEP) Plant
- NSSS/Turbine-Generator Supplier - Combustion Engineering/Westinghouse Electric
- AE/Constructor - Bechtel Power Corporation 4
Current Fire Protection Licensing Basis
- Fire Protection Program Standard License Condition
- 10 CFR 50.48(a) and (b)
- Branch Technical Position APCSB 9.5-1, Appendix A
- Six Current Appendix R Exemptions 5
NFPA 805 Transition Project Overview
- LAR Commitment Date = December 31, 2012
- Revision 1L
- Incorporating some of 1N and 1O revisions as applicable
- Active involvement on NEI NFPA 805 Task Force
- LAR preparation and internal review activities are in progress 6
NFPA 805 Transition Project Overview
- Fire Protection Program Transition
- License Condition being revised
- Technical Specification Section 5
- Minor revision
- Reviewed existing exemptions
- Six current Appendix R exemptions
- Transitioning one exemption
>> PCP Oil Collection System 7
Compliance with NFPA 805
- Power Block
- Review performed using NEI 04-02, Revision 2 guidance supplemented by FAQ 06-0019
- Attachment I of the LAR
- Includes fire areas needed for Safe and Stable
- Power Block structures and all associated Fire Areas identified
- Fire Areas that are excluded from the Power Block are identified in the supporting documentation 8
Compliance with NFPA 805
- NFPA 805 Chapter 3 Compliance
- Review performed using NEI 04-02, Rev 2 guidance as supplemented by FAQ 07-0036
- Review documented in Table B-1 (Attachment A of the LAR)
- Results
- Mods
- Barrier Modifications (Doors, Dampers, Penetrations)
- Detection System Replacement
- Transformer Nozzle Adjustment (Complete) 9
Compliance with NFPA 805
- NFPA 805 Chapter 3 Compliance (continued)
- Results
- EEEEs
- Code Conformance
- Barriers
- Majority Comply
- Several items submitted for NRC Approval
- Eleven Attachment L requests
>> Associated with fourteen Table B-1 records 10
Compliance with NFPA 805
- Nuclear Safety Capability Assessment
- Review performed using NEI 04-02, Revision 2 guidance supplemented by FAQ 07-0039
- Review documented in Table B-2 (Attachment B of the LAR)
- Methodology Review
- Automatic System Initiation
- Breaker Coordination
- Multiple Spurious Operations Review
- Offsite Power Evaluation 11
Compliance with NFPA 805
- Nuclear Safety Capability Assessment (continued)
- Gap Analysis performed on NEI 00-01
- Revision 1 vs Revision 2
- B-2 Results
- Safe and Stable is defined to be Hot Shutdown
- 40 Fire Areas that are included as part of Power Block
- No Fire Areas to be transitioned deterministically
- Fire Areas to be transitioned using RI-PB method 12
Compliance with NFPA 805
- Fire Area Transition
- Review performed using NEI 04-02, Revision 2 guidance supplemented by FAQ 08-0054
- Review documented in Table B-3 (Attachment C of the LAR) 13
Compliance with NFPA 805
- Fire Area Transition (continued)
- SAFE
- Upgrade from Appendix R Program Manager Computer Based Analysis Tool Expanded capability.
- Direct evaluation of Offsite Power Availability
Identification
- Output identifies possible VFDRs based on cable failures
- Independent Check performed 14
Compliance with NFPA 805
- Fire Area Transition (continued)
- Fire Risk Evaluations (FRE)
- Performance Based Evaluations for all Power Block fire areas
- Input from 805 Transition and PRA Insights
- VFDRs and associated resolutions
- Table B-3
- FRE documents disposition of VFDRs
- Table B-3 summarizes Each Fire Area providing:
- NSCA for each criterion
- EEEE Summary
- Suppression Effects summary
- VFDRs and associated resolutions 15
Compliance with NFPA 805
- Non-Power Operations
- Review performed using NEI 04-02, Revision 2 guidance as supplemented by FAQ 07-0040
- Attachment D of the LAR
- Results of Review
- Identifying Key Safety Functions
- Identifying Success Paths
- Identifying High Risk Evolutions
- Identifying Pinch Points
- Administrative Controls 16
Compliance with NFPA 805
- Radioactive Release
- Review performed using NEI 04-02, Revision 2 guidance supplemented by FAQ 09-0056
- Attachment E of the LAR
- Plant evaluated on a Fire Area Basis
- Credit existing engineering controls for gaseous and liquid effluents
- Revise pre-fire plans and training material to clarify monitoring and control requirements
- Potential radioactive release quantitatively evaluated by Radiation Protection
- Procedure changes identified to ensure future design or operational changes comply with NFPA 805 17
Compliance with NFPA 805
- Monitoring Program
- Review performed using NEI 04-02, Revision 2 guidance as supplemented by FAQ 10-0059
- LAR Section 4.6
- Scoping systems and components to be monitored based on results of the transition analysis
- Required components to be added to Maintenance Rule Program or something similar 18
Compliance with NFPA 805
- Clarification of Prior NRC Approvals
- Attachment T of the LAR
- Two requests:
- NFPA 805, Section 3.5.11 - Clarification of the specific approval of a single active failure in the charging pump room that would impair both the primary and backup fire suppression systems.
- NFPA 805, Section 3.5.5 - Clarification of the specific approval of the actual separation distance between the diesel fire pump and the service water pumps and the wrap for the control and annunciator cables for the diesel fire pump.
19
Compliance with NFPA 805 Requests for NRC Approval Attachment L of the LAR Eleven Requests:
1.
NFPA 805, 3.3.1.3.1 - Allow a deviation from the requirements associated with NFPA 51B, Section 3.2(b), which prohibits hot work in sprinkled buildings while such protection is impaired.
2.
NFPA 805, 3.3.5.1 - Allow the presence of the cables located above suspended ceilings that do not meet the requirements of NFPA 805 Section 3.3.5.1.
3.
NFPA 805, 3.3.5.2 - Allow the use of embedded and underground plastic conduit and for the use of EMT.
20
Compliance with NFPA 805 Requests for NRC Approval (continued) 4.
NFPA 805, 3.3.7.2 - Allow the configuration of the outdoor hydrogen bulk storage cylinders, which do not meet the requirements of NFPA 805, Section 3.3.7.2.
5.
NFPA 805, 3.5.16 - Allow the use of the fire water system for emergency and maintenance activities.
6.
NFPA 805, 3.11.4(b) - Allow an alternate conduit fire and smoke sealing criteria.
7.
NFPA 805, 3.5.3 - Allow for an alternate fire pump exhaust piping size 21
Compliance with NFPA 805 Requests for NRC Approval (continued) 8.
NFPA 805, 3.5.6 - Allow for a manual stop feature in the Control Room for the diesel fire pumps 9.
NFPA 805, 3.3.1.2(1) - Allow for the use of untreated wood
- 11. NFPA 805, 3.2.3(1) - Allow the use of the EPRI Technical Report TR-1006756 for performance based methods to establish the appropriate inspection, testing, and maintenance frequencies.
22
Compliance with NFPA 805
- Attachment S - Plant Modifications and Items to be Completed During Implementation
- Table S-1
- Three completed modifications
- 2400 VAC Breaker Fusing
- Transformer Deluge Nozzle Angles
- Fire Pump Control Cable Fusing 23
Compliance with NFPA 805
- Attachment S - Plant Modifications and Items to be Completed During Implementation
- Table S Examples of Modifications
- Independent AFW pump/piping/valves/controls
- Independent breakers for 2400 VAC Safeguards & Startup Power (Offsite Power)
- Alternate primary coolant pump breaker trip capability
- Passive long term AFW inventory capability
- Code Compliance Modifications 24
Compliance with NFPA 805
- Attachment S - Plant Modifications and Items to be Completed During Implementation
- Table S-3
- Process/Procedure Changes
- Station Personnel Training
- NFPA 805 Monitoring Program 25
- Full Power Internal Events & Fire PRA Peer Review
- FPIE PRA
- ASME/ANS RA-S-2008a
- Attachment U of the LAR
- Status of F&Os
- Fire PRA
- ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008
- Attachment V of the LAR
- Status of F&Os
- No unreviewed methods used 26
- Fire PRA
- Palisades Facts:
- Pre-GDC, pre-separation requirements, 1st C-E NSSS
- Two train design with asymmetry and overlap
- Large population of air operated valves
- Cable spreading room with many ignition sources
- Non-IEEE-383 qualified cable, non-separated cable routing
- Small rooms
- Detailed model
- Risk Insights (Attachment W of the LAR)
- Initial insights
- Modifications beyond compliance are needed
- Calculated compliant plant risk is conservative
- Focus on risk significant modifications
- Delta Risk
- Post-Transition Plant - Compliant Plant = -
- Recovery Actions
- Review performed using NEI 04-02, Revision 2 guidance supplemented by FAQ 07-0030
- Attachment G of the LAR
- Primary Control Stations (excluding control room)
- Auxiliary Hot Shutdown Panel EC-150
- Auxiliary Hot Shutdown Monitoring Panel EC-150A
- Recovery Actions
- Table G-1: Recovery Actions (Risk)
- Table G-2: Recovery Actions (DID)
- Table G-3: Operator Actions (Additional Risk Reduction)
- Table G-4: Operator Actions (Non-Control Room Primary Control Station) 29
NFPA 805 Schedule
- Schedule
- LAR Submittal
- Commitment to Submit no later than December 31, 2012
- LAR Implementation
- Table S-2 Schedule
- Two full operating cycles beyond SE issuance
>> Expecting SE in December 2014
- Table S-3 Schedule
- Six months beyond SE issuance
>> Six months after refueling outage if in progress at time of SE issuance 30
Summary
- Discussion 31