ML23066A247
| ML23066A247 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/07/2023 |
| From: | NextEra Energy Seabrook |
| To: | Justin Poole NRC/NRR/DORL/LPL1 |
| Poole J, NRR/DORL/LPLI, 415-2048 | |
| References | |
| EPID L-2023-LRM-0013 | |
| Download: ML23066A247 (14) | |
Text
Pre-Submittal Meeting to Discuss Upcoming NextEra Energy License Amendment Request to Revise Emergency Action Level Due to Change in Containment Fire Detection System March 7, 2023
Participants
- Jerry Phillabaum, Principal Engineer - Fleet Licensing, NextEra
- Matthew Levander, Regulatory Affairs Manager - Seabrook
- Kenneth Mack, Fleet Licensing Manager - Fleet Licensing, NextEra
- David Currier, Emergency Preparedness Project Manager - Seabrook
- Michael Finnegan, Emergency Preparedness Senior Analyst - Seabrook
- Rolando Robelin - Project Manager - Enercon
- Brian Fox, Lead Responsible Engineer - Enercon
- Pat Furio, Licensing Consultant - Enercon 2
Agenda
- Purpose
- Regulatory Guidance
- Current Schedule
- Closing Remarks 3
Purpose EAL changes are needed because of the planned change in the Containment Building fire detector system
- Number of detectors changes slightly
- Instrumentation changes provide additional alarm information in the Control Room
- Exception to single fire detector alarm to be continued (EAL HU4 (2))
- Exception to single fire detector alarm expanded to all Modes (EAL HU4 (2))
4
Regulatory Requirements and Guidance
- 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities
- Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors 5
- Current Containment Building Fire Detection System Design
- 9 detection zones, compromised of 137 ionization smoke detectors
- Actuation of a single detector locks a zone in alarm. Additional detectors alarming in the zone will not be annunciated separately. Specific location of an alarming detector is not known precisely, only its zone.
- Zone identification is made on alarm panel outside Control Room
- Future Containment Building Fire Detection System Design
- 120 photoelectric smoke detectors outside the bio-shield wall, 2 linear heat detection cables inside the bio-shield wall
- Addressable system, i.e., each detector alarms individually in the Control Room, giving a precise location of the alarm.
- Upgraded alarm panel provided in Control Room 6
- Current EAL Notes:
A containment fire alarm is considered valid upon receipt of multiple zones (more than 1) actuated on CP-376 panel.
HU4 (2)
- a. Receipt of a single fire alarm (i.e., no other indications of a FIRE)
AND
- b. The FIRE is located within ANY of the Table H2 plant rooms or areas except Containment in MODES 1 and 2 (see Note above)
AND
- c. The existence of a fire is not verified within 30 minutes of alarm receipt.
7
- Proposed EAL Notes:
A containment fire alarm is considered valid upon receipt of multiple detectors zones (more than 1) in alarm actuated on CP-376 panel.
HU4 (2)
- a. Receipt of a single fire alarm (i.e., no other indications of a FIRE)
AND
- b. The FIRE is located within ANY of the Table H2 plant rooms or areas except Containment in MODES 1 and 2 (see Note above)
AND
- c. The existence of a fire is not verified within 30 minutes of alarm receipt.
8
- Reason for the Requested Change Reduction in Effectiveness Multiple alarms within an existing zone would not currently result in a declaration of an Unusual Event, but the new fire detection configuration would allow multiple individual alarms to be recognized within the same area as an existing zone and declaration of an Unusual Event would occur. This could cause an Unusual Event to be declared when the current fire detection scheme would not.
Different than Currently Approved EAL Change of Containment Building exception from Modes 1 and 2 only to all Modes increases the scope of the exception The removal of a specific panel for determining which fire zones are in alarm allows for the use of a fire detector alarm panel located in the Control Room along with a remotely located fire alarm panel to determine which detector(s) is in alarm.
9
- Justification of the Requested Change Timeliness 120 detectors outside the bio-shield wall have same response time as currently 2 linear heat detection cables inside the bio-shield wall have a slight delay in activation.
Analysis determined an overall 30 second longer time for alarm than the smoke detectors.
This is negligible for EAL declaration.
Accuracy Photo-electric smoke detectors are less prone to false alarms than ionization smoke detectors.
Linear heat detection cable is not prone to false alarm unless damaged.
New system can monitor detector sensitivity and disable single detectors, reducing false alarms.
New detector system provides greater assurance that multiple detectors in alarm represent a true fire condition.
10
- Precedent Seabrook Continue the exception for a single fire detector alarm in the Containment Building Is essentially the same as was previously approved for Seabrook. The number of fire detectors has changed slightly, but the justification originally presented for the prior approval remains valid.
St Lucie, Turkey Point Remove the Mode restriction from the exception for a single fire detector Is similar to the approvals granted to St Lucie and Turkey Point. Those HU4 (2) exceptions were granted without any Mode restriction on when the exception was applicable.
11
Current Schedule
- Approval requested within 12 months o Installation of new fire detector system is currently scheduled for the Fall 2024 RFO
- Amendment to be implemented within 60 days of installation of new fire detectors in the Containment Building 12
Closing Remarks 13
Questions