ML13078A248
| ML13078A248 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/19/2013 |
| From: | Southern Nuclear Operating Co |
| To: | Ellen Brown Plant Licensing Branch II |
| Brown E | |
| Shared Package | |
| ML13078A284 | List: |
| References | |
| Download: ML13078A248 (20) | |
Text
FNP NFPA 805 LAR AUDIT March 19, 2013 Session 3 - Configuration Control and Session 3 Configuration Control and Modifications Chip Westberry
Configuration Control
- Program Documentation, Configuration Control and Quality Assurance Quality Assurance
- Addressed in LAR Section 4.7.
- FAQ 12-0061, Change Evaluations (under development) will be utilized for post-transition changes.
SNC will met the requirements of NFPA 805 Section
- SNC will met the requirements of NFPA 805 Section 2.7.3
- Existing configuration control procedures and processes governing the various FNP documents and databases will be revised to include the new NFPA 805 licensing will be revised to include the new NFPA 805 licensing bases requirements such as NSCA and NPO controls.
Slide 2
Configuration Control
- Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the internal events PRA model.
of the internal events PRA model.
Slide 3
Quality Assurance
- SNC will maintain the existing Fire Protection Quality SNC will maintain the existing Fire Protection Quality Assurance program.
- Analyses, calculations, and evaluations performed in support of compliance with 10 CFR 50.48(c) are performed in accordance with SNC procedures that performed in accordance with SNC procedures that require independent review.
Slide 4
Implementation
- Attachment S, Table S-3 provides items necessary for development during the implementation period to ensure development during the implementation period to ensure configuration controls are maintained:
- Development of a monitoring and trending program f
i d
t d f t
for required systems and features, Slide 5
Implementation (Continued)
- Revision of appropriate plant procedures and processes to ensure the requirements of Table B-1 processes to ensure the requirements of Table B 1 are met such as:
- Plant work controls
- Fire Brigade Pre-Fire Plans
- Fire Brigade Training,
- Outage management procedures are revised to incorporate requirements of NPO, Slide 6
Implementation (Continued)
- Update of procedures, processes and/or documentation necessary to meet the new documentation necessary to meet the new requirements of Radiological Release, including
- training,
- Revise procedures to ensure the requirements to maintain Safe and Stable are met,
- Revision of operations procedures to ensure all requirements of the HRA are met requirements of the HRA are met, Slide 7
Implementation (Continued)
- Development of a Fire Protection Design Basis
- Document, Document,
- Job Performance Records will be revised to identify d d t
i d t i i d
t i
t and document required training and mentoring to ensure individuals are appropriately qualified,
- Following installation of modifications and the as-built installation details, additional refinements surrounding the modifications will be incorporated into the Fire the modifications will be incorporated into the Fire PRA model (the Fire PRA will verify the validity of the reported change-in-risk on as-built conditions after the modifications are completed) if necessary.
Slide 8
Committed Modifications
- There are 11 committed modifications in the LAR, Attachment S, Table S-2
- Two plant modifications resulted from the reviews of Two plant modifications resulted from the reviews of NFPA 805 Chapter 3 (Detection upgrade and CO2 System upgrades)
- Compensatory measures will be established when NFPA 805 becomes effective and will remain until the 805 becomes effective and will remain until the modification is completed I
t ll ti A
ifi d i Att h
t S ll
- Installation: As specified in Attachment S, all modifications will be completed by November 6, 2017.
Slide 9
Installation of Incipient Detection
- Problem: Panels in both units contain equipment that ld lt i i
ifi t i k i t
could result in significant risk impacts
- Proposed Modification: Install incipient detection in panels in 6 fire areas.
panels in 6 fire areas.
- Risk Rank: High
- Included in FPRA Slide 10
- Problem: 92-18 hot short analysis-problems in two RHR/LHSI t RCS C ld L it RHR/LHSI to RCS Cold Leg per unit.
- Proposed Modification: Rewire the MCC to protect against bypassing the torque and limit switch against bypassing the torque and limit switch
- Risk Rank: Medium
- Not included in the FPRA Slide 11
Instrument Air to MDAFW
- Problem: The MDAFW flow control valves requires q
instrument air for remote operation and fail open upon loss of air P
d M difi ti E
i ill b t d t
- Proposed Modification: Emergency air will be routed to the MDAFW flow control valves
- Risk Rank: Low Risk Rank: Low
- Not included in the FPRA Slide 12
Power to RCS T
t R
d Temperature Recorder
- Problem: Loss of Train A power results in a loss of RCS
- Problem: Loss of Train A power results in a loss of RCS hot-leg and cold-leg temperature indication for all 3 steam generators.
- Proposed Modification: Provide Train B power.
- Risk Rank: Low
- Not included in the FPRA Slide 13
Replace Trip Devices
- Problem: Current 125VDC breaker coordination needs improvement in the instantaneous region improvement in the instantaneous region.
- Proposed Modification: Replace current GE EC-2 Trip device with properly coordinated trip devices (such as p
p y
p
(
GE EC-1 Trip devices).
- Risk Rank: Medium I
l d d i th FPRA
- Included in the FPRA Slide 14
Cable Tray and Circuit Protection
- Problem: Cables and trays require protection to prevent fire damage in various fire areas.
- Proposed Modifications: 12 fire areas require protection for various cables and trays for various cables and trays.
- Risk Rank: High
- Included in the FPRA c uded e
Slide 15
Upgrade CO2 Systems
- Problem: Required CO2 systems are impaired.
- Proposed Modification: Replacement of failed mechanical timers and improvement of heat detection.
- Risk Rank: Medium
- Risk Rank: Medium
- Included in the FPRA Slide 16
- Problem: Unprotected shunt cable could overheat and cause damage to vital DC components required to support ASD from the HSP.
- Proposed Modification: Provide fuse or other electrical
- Proposed Modification: Provide fuse or other electrical isolation device for specified cables.
- Risk Rank: High
- Included in the FPRA Slide 17
Circuit Overcurrent Protection at DC Shunt Connections
- Problem: Unprotected shunt cable could overheat and cause damage to vital DC components required to g
p q
support ASD from the HSP.
- Proposed Modification: Provide over-current protection f
f t l t d b tt h
t bl for safety-related battery charger ammeter cables.
- Risk Rank: High
- Not included in the FPRA
- Not included in the FPRA Slide 18
Seal Motor Control Centers
- Problem: MCCs require sealing to prevent fire propagation.
- Proposed Modification: Seal MCCs in 6 fire areas.
Ri k R k Hi h
- Risk Rank: High
- Included in the FPRA Slide 19
Upgrade the Fire Detection System System
- Problem: Detection is a required system in many fire areas and currently does not meet NFPA 72.
- Proposed Modification: Upgrade the fire detection system to meet the requirements of NFPA 72 system to meet the requirements of NFPA 72.
- Risk Rank: Low
- Not included in the FPRA o
c uded e
Slide 20