ML13078A245

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03/21/2013 Licensee Meeting Slides Re Joseph M. Farley Nuclear Plant NFPA 805 Fire Modeling LAR Submittal - Session 1 (3/19)
ML13078A245
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 03/19/2013
From: Branum J
Southern Nuclear Operating Co
To: Ellen Brown
Plant Licensing Branch II
Brown E
Shared Package
ML13078A284 List:
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Download: ML13078A245 (18)


Text

FNP NFPA 805 LAR AUDIT March 19, 2013 Session 1 - LAR Overview Jeff Branum

LAR Overview

  • Background
  • T Transition/LAR iti /LAR PProcess
  • Results/Conclusions

/C 2

Joseph M. Farley Nuclear Plant Units 1 & 2

  • Location: Near Dothan in Southeast Alabama.
  • Operating Licenses: Issued -June 25, 1977 and March 31, 1981 for Units 1 and 2, respectively.
  • Renewed License Issued - May 12, 2005
  • License Expires: June 25, 2037 (Unit 1) & March 31, 2041 (Unit 2)
  • Licensed MWe: 900 (Unit 1) & 920 (Unit 2)
  • Containment Type: Dry, Ambient, Pressure 3

Current FNP FP Licensing Basis

  • FNP FP Licensing Basis is based on:

- 10 CFR 50.48(a), 10 CFR 50.48(b),

- 10 CFR 50, Appendix pp R, Sections III.G, III.J, and III.O

- FP License Condition

  • Branch Technical Position APCSB 9.5-1, Appendix A
  • 81 exemptions (Unit 1)/deviations (Unit 2) 4

NFPA 805 LAR

  • NFPA 805 Letter of Intent Sent 2/14/2008
  • LAR Submitted on 9/25/2012
  • NRC Requested Supplemental Info 12/12/12
  • Supplemental Info Provided 12/20/2013
  • LAR Accepted 1/24/2013 5

Process for Transition and LAR

  • SNC and Contractor Team
  • Active Participation in NFPA 805 Task Force and LAR Template Development
  • Adjusted Transition Activities as Process Evolved

- Fire PRA Methods

- Fire Risk Evaluations

  • Addressed and Considered Non-Pilot Generic Issues 6

NFPA 805 Chapter 3

  • LAR Section 4.1 and Att. A - B-1 Table document results and conclusions
  • The vast majority of Chapter 3 elements Comply or Comply via Engineering Evaluation (most evaluations are NFPA code compliance).
  • There is 1 instance where FNP utilized compliance via previous NRC Approval.
  • Two pplant modifications resulted from the reviews of NFPA 805 Chapter 3 (Detection replacement and CO2).

7

Nuclear Safety Capability Assessment

  • Attachment B - B-2 Table documents NSCA methodologygy

- Gap Assessment performed between revision 1 and revision 2 of NEI 00-01

  • Safe and stable

- Defined as Mode 3, with the ability to cool down and d place l RHR system t iin service i if necessary.

Once on RHR, long term actions are related to replenishment of EDG fuel oil, replenishment of borated injection water or replenishment of condensate supplies.

8

Nuclear Safety Capability Assessment

  • Recovery Actions

- Followed FAQ 07-0030 process

- Recovery actions defined as required for risk or DID in Attachment G.

- Followed FAQ 07-0038 process (LAR Attachment F)

- MSO Scenarios integrated into NSCA and Fire PRA 9

Nuclear Safety Capability Assessment

  • Attachment C - B-3 Table documents NSCA Fire Area Results Results.

- NSCA evaluated for both units for each Fire Area

- There are 163 total Fire Areas in Farley Farley, Units 1 and 2

- Of the 163 Fire Areas, 51 Fire Areas had impact to both units (FRE performed for impact on Unit 1 and Unit 2) - Total of 214 FREs

- Performance-Based approach utilized Fire Risk Evaluation (Section 4 4.2.4.2 2 4 2 of NFPA 805)

  • Engineering Evaluation Transition

- None of the transitioning EEEEs require NRC approval.

10

Nuclear Safety Capability Assessment

  • Licensing Action Transition

- No Licensing Actions are to be transitioned to the new licensing basis 11

NPO and Radioactive Release

  • Non-Power Operational Modes (NPO)

- LAR Section 44.3 3 and Attachment D document methodology and results.

- Utilized FAQ 07-0040 process.

p

  • Radioactive Release
  • LAR Section 4.4 and Attachment E document methodology and results.
  • Utilized FAQ 09-0056 process.

12

Other Transition Topics

  • Monitoring

- Addressed in LAR Section 4.6

- Will utilize FAQ 12-0059 Process

  • Program Documentation, Configuration Control and Quality Assurance

- Addressed in LAR Section 4.7.

- FAQ 12-0061, 12 0061 ChChange E Evaluations l ti ((under d

development) will be utilized for post-transition changes.

- SNC will met the requirements of NFPA 805 Section 2.7.3 13

Fire PRA and Fire Risk Evaluations

- Peer-Reviewed Fire PRA used to support FREs

- PRA Quality addressed in LAR Section 4 4.7 7 and Attachments U and V.

- Fire Risk Insights addressed in LAR Attachment W 14

Fire PRA and Fire Risk Evaluations

  • Fire Risk Evaluations

- Process from FAQ 0808-0054 0054 utilized

- Integrated assessment of change in risk, DID, and SM

- Change in risk and maintenance of DID and SM addressed for each fire area utilizing performance-based approach.

- Results summarized in LAR Attachment W.

- Required fire protection systems and features provided in LAR Attachment C C, Table C-2 C-2.

15

Overall Results

  • Overall results concluded acceptable change in risk defense in depth adequate risk, adequate, and safety margin maintained, based upon:

- Plant design, and

- Reliance on recovery actions

- Plant modifications (completed and committed)

- Implementation items 16

Overall Results

  • LAR dated September, 2012 discussed overall risk decrease related to transition transition.

R1

- Additional refinements and corrections during LIC-109 review indicate a small risk increase associated with transition.

  • Additional reviews and refinements will be performed as part of RAI response.

17

Slide 17 R1 Don't know if this is true or not.

Rebecca, 3/12/2013

Implementation Items and Modifications

  • 30 Implementation Items Identified
  • Primarilyy associated with p procedure and documentation updates, such as:

- Non-Power Operational Modes Analysis

- Radioactive Release Analysis y

- Monitoring Program

- Safe Shutdown Procedures

- Fire Brigade g

- FP Program Documents and Training

- Fire PRA Model Update after Modifications

  • Will use the criteria in FAQ 61 for overall risk change
  • 11 Committed Modifications (Table S-2) 18