ML13322B311
| ML13322B311 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/13/2013 |
| From: | FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| Brown, Eva NRR/DORL 415-2315 | |
| References | |
| Download: ML13322B311 (13) | |
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Davis-Besse NFPA 805 Transition
- Tom Lentz Manager, FENOe Fleet Licensing Ken Byrd Director, Davis-Besse Site Engineering
- Dennis Blakely Supervisor, Davis-Besse Engineering Analysis
- Jon Hook Manager, Davis-Besse Design Engineering Colin Keller Manager, FENOe Fleet Engineering FENOC NRC Meeting November 13, 2013 2
Davis-Besse NFPA 805 Transition Objectives
- Discuss current status of the Davis-Besse NFPA 805 transition project Project status and major milestones Status of existing nonconformances
- Discuss NFPA 805 design modifications and their interaction with Fukushima initiatives
- Propose revised License Amendment Request submittal schedule FENOC NRC Meeting November 13, 2013
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Davis-Besse NFPA 805 Project Status
- Transition Project Status Detailed fire modeling is complete 44 fire compartments modeled Followed NUREG/CR 6850 guidance - no unapproved analysis methods used Satisfactory Fire PRA peer review in June, 2013 35 findings, 13 suggestions and 2 best practices identified 19 findings resolved and 11 suggestions implemented to date
- Fire Risk Evaluations (FREs) are on-going to support resolution of Variations From Deterministic Requirements (VFDRs)
FENOC NRC Meeting November 13, 2013 4
Davis-Besse NFPA 805 Project Status
- Current Project Milestones
- FPRA peer review finding resolution: November 2013
- Fire Risk Evaluation completion: December 2013 Draft Transition Report ready for project team and oversight committee reviews: December 2013
- Transition Report approval: March 2014
- Regulatory commitment for LAR submittal: July 1, 2014 FENOC NRC Meeting November 13, 2013 5
Status of Existing Nonconformances Description/Status Safety Significance Compensatory Measures Failure to provide procedure for Cold Shutdown repair Identified in NRC IR2013-008, enforcement discretion applied Planned correction through procedure modification with no reliance on NFPA 805 Very low None Un-fused direct current ammeter circuit Identified in NRC IR2013-008, enforcement discretion applied Planned correction through design modification with no reliance on NFPA 805 Not high (Less than RED)
Hourly fire watch established Inadequate cable separation for Pressurizer, Steam Generator instrumentation. Identified in DBNPS Corrective Action Program Planned resolution through NFPA 805 Transition Not high (Less than RED)
Hourly fire watch established FENOC NRC Meeting November 13, 2013
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Status of Existing Nonconformances Operator Manual Actions (OMA)
- Utilized as compensatory measures for non-compliances with 10CFR50 Appendix R,Section III,G.2
- Incorporated into DBNPS approved operating procedures
- Acknowledged in the Safety Evaluation Report for the DBNPS Fire Protection Program
- Verified to be achievable through time-line studies, operator heat stress reviews, and equipment access and radiological assessments Provide reasonable assurance of safe shutdown capability
Analysis of spurious operations was provided in the DBNPS Fire Hazards Analysis Report.
Analysis of spurious operations was acknowledged in the Safety Evaluation Report for the DBNPS Fire Protection Program.
Applicable multiple spurious operation scenarios were evaluated in the DBNPS Fire PRA.
Compensatory measures were established for highest-risk fire compartments to provide reasonable assurance of safe shutdown capability.
- All OMA/MSO issues are to be resolved through NFPA 805 Transition.
FENOC NRC Meeting November 13, 2013 7
Davis-Besse N FPA 805 Design Modifications
- Risk-beneficial design modifications in support of NFPA 805 transition
- Emergency Feedwater System Planned installation in Spring 2016 refueling outage Significant reduction in Core Damage Frequency expected
- Enhanced RCS makeup capability (FLEX Charging Pumps)
Planned installation in spring 2016 refueling outage Additional reduction in Core Damage Frequency expected FENOC NRC Meeting November 13, 2013 8
NFPA 805 Effect on Fukushima Initiatives
- Design modifications are intended to provide necessary risk improvements for both FLEX and NFPA 805 transition initiatives.
- Identified in DBNPS Overall Integrated Plan in response to NRC Order regarding Mitigation Strategies for Beyond Design Basis External Events (FLEX Order), submitted to NRC on February 27, 2013
- Currently in initial design - schedule is under development
- Effective coordination of design modifications in response to FLEX initiatives and NFPA 805 transition is essential.
FENOC NRC Meeting November 13, 2013
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Revised License Amendment Request Submittal Schedule
- Proposed LAR Submittal Schedule
- NFPA 805 LAR submittal after implementation of FLEX/NFPA 805 related modifications
- Proposed schedule will support prompt full irnplementation of NFPA 805 fire protection program upon approval, without reliance on license conditions for design improvement.
FENOC NRC Meeting November 13, 2013 10
Revised License Amendment Request Submittal Schedule Justification for Proposed Schedule FENOC will continue to maintain fire safety at DBNPS in accordance with License Condition 2.C(4) of the operating license.
Existing nonconformances are identified in the Corre-ctive Action Program. Appropriate compensatory measures are in place.
FENOC is committed to the full transition to NFPA 805 Fire Protection Program following implementation of FLEXlNFPA 805 modifications for DBNPS.
- FENOC will continue high level of management and staff involvement in fire protection program improvements.
FENOC NRC Meeting November 13, 2013 11
Davis-Besse NFPA 805 Transition
- Moving Forward
- FENOC has evaluated the NRC enforcement alternatives outlined in SECY-12-0031.
- FENOC is evaluating a change to the current regulatory commitment.
Formal notification would be submitted by January, 2014.
If appropriate, submittal will include a request for extension of enforcement discretion.
FENOC NRC Meeting November 13, 2013 12
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