ML18067A121
| ML18067A121 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/15/2018 |
| From: | South Carolina Electric & Gas Co |
| To: | Shawn Williams Division of Operating Reactor Licensing |
| Williams S, NRR/DORL/LPLII-1 | |
| References | |
| Download: ML18067A121 (21) | |
Text
VC Summer NFPA 805 LAR Pre-Application Meeting March 15, 2018 1
Agenda
- Introduction
- Meeting Purpose
- Background
- 2018 LAR Scope
- 2018 LAR Submittal Schedule 2
Introduction - VC Summer Team
- Wayne Stuart - General Manager, Engineering Services
- Bruce Thompson - Manager, Nuclear Licensing
- Jody Galloway - Supervisor, Design Engineering
- Ken Leonelli - Supervisor, Nuclear Fuels & Analysis
- Justin Bouknight - Engineer, Nuclear Licensing
- Francisco Joglar - Consultant, JENSEN HUGHES
- Andy Ratchford - Consultant, JENSEN HUGHES 3
Meeting Purpose
- Discuss Background on NFPA 805 Transition and implementation challenges
- Discuss scope of the 2018 LAR
- Address comments and questions
- Discuss the submittal schedule 4
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Background===
- Transition License Conditions included completion of plant modifications by 12/31/15
- Final Implementation Items for full compliance by 3/31/16
- Implementation Item 22 included update of Fire PRA to reflect as-built modifications and implementation items 5
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Background===
- Reviews in 2016 indicated that certain committed modifications had not been completed as described in the LAR/RAIs
- Several self-identified Fire PRA and Fire Protection issues warranted updates and refinement
- NRC inspection identified issues warranted an update
- Ongoing industry Fire PRA treatments were in the approval stages and warranted inclusion in the Fire PRA 6
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Background===
- Fire PRA model was updated and refined in 2016
- De-scoped modifications
- Self-identified issues addressed
- NRC identified issues addressed
- Update for industry Fire PRA treatments
- Demonstrated transition change in risk is within RG 1.174 criteria
- De-scoped modifications require LAR submittal 7
2018 LAR Goal
- Obtain review and approval of de-scoped modifications
- Reconcile completion of the Transition License Condition
- Attain approval for a new performance-based method for treatment of thermal insulation materials 8
2018 LAR Scope
- Apply guidance from NRC letter to NEI dated 3/2/16 for modification changes
- Option B was chosen since changes to PRA approaches have been included
- Incorporate current regulatory methods
- NUREG-2180 for new treatment of incipient detection
- NUREG-2169 for new ignition frequencies
- NUREG-2178 for new electrical cabinet HRRs 9
2018 LAR Scope 3/2/16 NRC Letter to NEI, Option B
- Summary of modification changes
- Summary of PRA model changes
- New LAR Attachments
- Att. M - License Condition
- Att. S - Modifications
- Att. W - Fire PRA Fire Area Change in Risk
- Defense-in-Depth, Safety Margin
- PRA Methods
- Demonstration of Acceptability of Methods
- New/Removed VFDRs and Recovery Actions 10
2018 LAR Scope
- Specifics planned for inclusion in the 2018 LAR:
- 10 CFR 50.48(c)(2)(vii) for Thermal Insulation Materials
- Fire Door - NRC Inspection Issue (B-1 Table Revision)
- RCP Lube Oil Collection System - NRC Inspection Issue 11
2018 LAR Scope - Modification Changes
- Original LAR Attachment S provided very general description of committed plant modifications
- RAI responses provided more detail with respect to cable numbers, protection methods, related VFDRs, etc.
- Over course of transition activities, certain modification details were de-scoped using risk-informed methods without proper NRC approval 12
LAR Scope - Modification Changes 13
2016 Fire PRA Updates and Refinements
- Updated the ignition frequency calculations due to the addition of new ignition sources to selected fire zones
- Updated the scenario target sets due to cable re-routes or the construction of electrical raceway fire barrier systems
- Detailed fire modeling of selected ignition sources
- Screening of multi compartment scenarios using detailed fire modeling techniques
2016 Fire PRA Updates and Refinements
- Revised use of QRecover rules and FRANX excluded gates features
- Additional refinement in MCR abandonment model to provide more realistic abandonment and non-abandonment treatment
- More detailed treatment of containment isolation paths
- Refinements in HRA dependency analysis
- More explicit modeling of disconnect switches used for electrical isolation 15
- NUREG-2180 - Incipient Detection - Change from approved FAQ 08-0046 approach to new approach results in significant change in quantified risk. Additional refinements needed to attain realism.
- NUREG-2169 - Ignition Frequencies - Change to implement new values results in significant change in quantified risk. Additional refinements needed to attain realism.
- NUREG-2178 - Electrical Cabinet HRRs. Application has provided more realistic treatment.
16
2018 LAR Scope - Other PRA Topics
- Current Status of Seismic PRA
- Submittal on track for September 2018
- Internal Events/Internal Flooding Peer Review 17
2018 LAR Scope - Other Changes
- Changes to the NSCA (e.g., VFDRs and Recovery Actions) will be included in the 2018 LAR:
- Fire Areas crediting approved Performance-Based Fire Modeling (NFPA 805 Section 4.2.4.1) now assessed using approved Fire Risk Evaluation approach (NFPA 805 Section 4.2.4.2)
- Several additional Fire Areas credit local trip of RCP breakers
- Changes associated with completion of plant modifications
Submittal Schedule
- LAR is planned for submittal by June 30, 2018 19
Questions?
20
Acronyms HRA - Human Reliability Analysis HRR - Heat Release Rate LAR - License Amendment Request MCR - Main Control Room MSO - Multiple Spurious Operation NEI - Nuclear Energy Institute NFPA - National Fire Protection Association NRC - Nuclear Regulatory Commission NSCA - Nuclear Safety Capability Assessment PRA - Probabilistic Risk Assessment RAI - Request for Additional Information RCP - Reactor Coolant Pump RG - Regulatory Guide RWST - Refueling Water Storage Tank SE - Safety Evaluation VFDR - Variance from Deterministic Requirements 21