ML11102A005

Progress Energy - Slides for NFPA 805 Pre-LAR Application Meeting April 12, 2011

ML11102A005
Person / Time
Site:	Brunswick, Crystal River, Robinson
Issue date:	04/12/2011
From:	Ertman J, Heffner K, Lavin K, Miskiewicz D Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Saba F
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ML11102A004	List: ML11102A005
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Download: ML11102A005 (36)

Text

NFPA 805 Pre-LAR Application Meeting April 12, 2011 Jeff Ertman - NFPA 805 Project Manager Dave Miskiewicz - PRA Principal Engineer Kelly Lavin - Project Engineer Ken Heffner - NGG Licensing

NFPA 805 Fleet Submittal Schedule Current LAR Submittal Schedule:

Crystal River 3 (CR3) Initial Submittal - June 2011 Robinson (RNP) Initial Submittal - June 2011 Crystal River 3 Planned Supplement - 3rd Qtr 2011 Brunswick (BNP) Initial Submittal - October 2011 Robinson Planned Supplement 1 - 1st Qtr 2012 Brunswick Planned Supplement - 1st Qtr 2012 Robinson Planned Supplement 2 - 3rd Qtr 2012 2

NFPA 805 Fleet Submittal Schedule PRA Peer Review Schedule:

All Internal Events Peer Reviews Completed CR3 Fire PRA Peer Review Completed BNP Fire PRA Peer Review - July 2011 RNP Fire PRA Peer Review - 2nd Qtr 2012 3

Target Mod Completion Dates Per Current Plan CR3 - 2014 BNP - 2014 RNP - 2014 Individual Modifications Scheduled on a Case by Case Basis 4

Prioritization Philosophy Complete SSA Re-Analysis Identify VFDRs- Comp Measures B-1,2,3 Tables Modifications Scope FPRA NFPA 805 FPRA Application Calc FRE EEEEs Radiation Release NPO FSA 5

Fleet Prioritization NFPA 805 Transition Crystal River 3 Brunswick Robinson 6

FLEET DISCUSSION 7

Fleet FP Project Goals Improve Safety Focus Through the Performance Based, Risk Informed Approach Address Industry FP Issues Operator Manual Action (OMAs)

Fire Induced Multiple Spurious Operations (MSOs)

Raceway Fire Barrier Wrap (e.g. HEMYC at HNP)

Establish a Common Fire Protection Program Across Fleet Advancement of Fire Protection and PRA Personnel Knowledge and Skills 8

Project Organization 9

Project Philosophy Internal Resources Increased PRA Staff (4 FTE)

Increased Fire Protection Staff (4 FTE)

External Resources Managed at Both Corporate and Site Level by Progress Energy Staff 10

Fleet Strengths VFDRs are Known and Comp Measures are In Place Addresses MSO and OMA Issues Use of LAR Template For Remaining Plants Incorporation of Lessons Learned and Processes from Pilot Plants - HNP and Oconee Many Mods at Both RNP and CR3 are Scheduled and Completed - Not Waiting on LAR/SE 11

Fleet Challenges More Than Average Amount of Work Performed with Internal Resources Resource Priority Challenges Emergent Plant Issues Industry Issues External Resources Continual Competition for These Resources -

Particularly PRA and SSA 12

Fleet Challenges HNP 805 Transition Oversight of New Program Self Assessment 1st NFPA 805 Triennial Inspection (Sept)

Other Triennials Inspections in 2011 CR3 2nd Quarter BNP 4th Quarter Plant Outages 13

INDIVIDUAL SITE UPDATES 14

CR3 Scope and Status Initial Submittal Planned Supplement - Potential Drivers Non-Power Operations MOV Weak Link Analysis Thermo-hydraulic Analysis Other Open Items 15

CR3 Plant Specifics Number of Fire Areas - 47 Projected Number of Performance Based Areas - 47 Fire PRA Peer Review F&Os Resolution Nearing Completion Focused Peer Review Not Required Fire Modeling is Used to Support PRA 16

CR3 Projected Modifications Address Fire Protection NFPA Code Compliance Findings Enhance Long Standing Control Complex Ventilation System Fire Mitigation Capabilities Implement Additional Plant Fire Protection Barrier Modifications Implement Circuit Modifications/Reroutes to Address Fire Induced Circuit Failures - MSOs 17

CR3 Projected Modifications Improve MOV Capability to Maintain Functionality During and After Fire Events Seal/Fire Harden Existing Plant Equipment (MCCs or Breaker Cabinets)

Re-Credit Previously Abandoned Raceway Wrap Add Incipient Detection Systems 18

CR3 Challenges EPU Coordination LARs are Independent NFPA 805 LAR Will Describe Expected Qualitative Impact of EPU Modifications Evaluated Case by Case as They are Developed Process Similar to Any Other Mod Base FPRA Model Does Not Include EPU Changes Extended Outage Due to Containment Delamination 19

CR3 Impact on Safety NFPA 805 Performance Based Program, Including NPO, is an Improvement to the Current Program Current Issues with MOVs, Thermo-hydraulic Analyses, Unapproved OMAs and MSOs Have Been Entered Into CAP With Appropriate Comp Measures Overall Plant Risk Will be Quantified Plant Fire Risk Evaluations Will be Complete 20

CR3 Summary Targeting One Submittal Will Likely Have One Supplement No Safety Impact from Extending Final Transition to Allow for More Complete Analysis Modifications Schedule Not Impacted by LAR/SE Dates 21

BNP Scope and Status Initial Submittal Current Target is One Submittal Supplement if Needed Non-Power Operations Specific Open Items (Currently None Identified) 22

BNP Plant Specifics Number of Fire Areas - 32 Projected Number of Performance Based Areas - 31 Fire PRA Peer Review Planned for July 2011 Fire Modeling is Used to Support PRA Modifications Yet to be Identified Initial Modification List Scheduled June 2011 23

BNP Challenges Dual Unit Plant Many Previously Approved III.G.3 Areas Cross Unit Power Supply Internal Resource Challenges 24

BNP Impact on Safety NFPA 805 Performance Based Program, Including NPO, is an Improvement to the Current Program The Analysis Will be Complete Approximately 5 Months After the Original Submittal Overall Plant Risk Will be Known Plant Fire Risk Evaluations Will be Complete 25

BNP Summary Targeting One Submittal May Have One Supplement No Safety Impact 26

RNP Scope and Status Initial Submittal NSCA - B-2 and B-3 Tables Classical Fire Protection - B-1 Table VFDR List Initial Modification List Planned Supplement 1 Radiation Release Non-Power Operations Planned Supplement 2 Fire PRA Results MSO Results Recovery Action Results Fire Risk Evaluations Final Modification List 27

RNP Plant Specifics Number of Fire Areas - 21 Projected Number of Performance Based Areas - 13 Fire PRA Fire Modeling is Used to Support PRA 28

RNP Projected Modifications Modifications Completed Backup Instrument Air for Charging Pumps Speed Control Pressurizer PORV Electrical Isolation & Alt. Control Scheme for RWST Make-Up to Charging Pumps Modifications to IN 92-18 MOVs (both Hot and Cold Shutdown Credited Valves)

Replacement of Hemyc Fire Barrier Wrap Electrical Isolation for EDG Local Test Circuits Isolation Relays for Emergency Electrical Buses Breakers Rerouting of ERFIS Cables to Protect Safe Shutdown Equipment Auto Reload of Battery Chargers on a LOOP Installation of Fire Walls Between Main Trans., Aux Trans.

And Turbine Building 29

RNP Projected Modifications Modifications Pending Key Locked Isolation Switch in Control Room to Isolate DC Electrical Power to Key Auxiliary Panels Auto Start/Auto Load of Dedicated Shutdown Diesel Generator on Loss of All AC Power LCV-115C (Volume Control Tank Outlet) Power Cable Reroute Protect Steam Generator Wide Range Level Indication Protect Steam Isolation Valve Circuits Alternate RCP Seal Injection Study (Potential Mod) 30

RNP Challenges Cable Spread Room and Switchgear Room Fire Modeling in Support of PRA is Being Developed in These Areas Fire PRA Completion - Methods Needed EPRI Developing Method for Cabinets Area Wide Incipient Detection Use Cable Coating Treatment Being Updated Incorporate Lessons Learned 31

RNP Challenges Fire Induced Control Load Shed Original Licensing Basis Requirement for the Safe Shutdown Strategy Fire Induced Control Load Shed Status Revised SSA Analysis (In Progress)Included Deterministic Offsite Power Analysis to Reduce Reliance on this Strategy Further Reduction May be Possible Based on the PRA Insights Gained from NFPA-805 32

RNP Impact on Safety For RNPs Initial LAR Submittal VFDRs Will be Developed Overall Methodology Will be Described Fire PRA and Fire Modeling Will be Completed to the Original Fleet Schedule Modifications Schedule Not Impacted 33

RNP Summary Initial Submittal with 2 Planned Supplements No Safety Impact Modifications Schedule Not Impacted by LAR/SE Dates 34

Summary CR3 June 29th Submittal Near Term Supplement BNP October 17th Submittal Potential Near Term Supplement RNP June 29th Initial Submittal 2 Planned Supplements Monitoring NRC Approval of Staggered Approach 35

Acronyms FPRA - Fire Probabilistic Risk Assessment FRE - Fire Risk Evaluation FSA - Fire Safety Analysis VFDR - Variance From Deterministic Requirements EEEE - Existing Engineering Equivalency Evaluations FTE - Full Time Equivalent NPO - Non-Power Operations PORV - Power Operated Relief Valve RWST - Refueling Water Storage Tank LOOP - Loss of Offsite Power ERFIS - Emergency Response Facility Information System EDG - Emergency Diesel Generator RCP - Reactor Coolant Pump EPU - Extended Power Uprate F&O - Findings and Observations MOV - Motor Operated Valve MSO - Multiple Spurious Operations 36