ML082050390

April 2008 Observation Visit - Shearon Harris - Pilot Plant Transition to NFPA 805 - Fire Safety Analysis/Change Evaluation Update

ML082050390
Person / Time
Site:	Oconee, Harris
Issue date:	04/15/2008
From:	Allen S Nuclear Generation Group, Progress Energy Co
To:	NRC/NRR/ADRA/DRA/AFPB
Oudinot D, NRR/DRA, 415-4064
Shared Package
ML082050482	List: ML082050386 ML082050390 ML082050402 ML082050407
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Download: ML082050390 (14)

Text

Harris Nuclear Plant (HNP)

NFPA 805 Transition Non-Power Operational Fire Safety Analysis (FSA) ModeUpdate Review Status HNP Pilot Meeting Shirelle Allen, CES/FP May 30 - June 1, 2007 Raleigh, NC Harris Oconee Pilot Observation Meeting April 15, 2008 Charlotte, NC Bob Rhodes May 31, 2007

Progress Energy FSA O Status -

Z To date: 2nd round change evaluation team meetings performed to discuss variances and resolve strategy for each fire area transitioned with performance-based approach (approximately 16 fire areas)

Z In Progress: strategy finalization, calculation preparation and design verification, final list of proposed plant modifications

Progress Energy FSA O Purpose: Demonstrate achievement of nuclear safety and radioactive release performance criteria of NFPA 805 as required by 10CFR50.48(c)

O Methodology: FSA is Progress Energys design basis document as described in NFPA 805:2.7.1.2 Z Section 3.1 details steps performed to develop FSA

Progress Energy FSA O Section 3.2 Classical Fire Protection Z Fire Response Strategy Z Construction Z Ventilation Z Detection Z Automatic Suppression Z Manual Suppression

Progress Energy FSA O Section 3.3 Fire Hazards Identification Z Normally expected fire hazards for the fire area Z Area specific classifications/designations O Section 3.4 NSCA Compliance Summary Z Fire area contents Z Approaches utilized to demonstrate compliance X i.e. deterministic, performance-based, combination

Progress Energy FSA O Section 3.5 Non-Power Operational Modes Compliance Summary Z Review conducted using guidance found in NEI 04-02 and FAQ 07-0040 Z Calculation HNP-E/ELEC-0002 presents methodology, pinch points, and description of strategy developed to resolve concern Z High level results of the non-power operations evaluation presented within the FSA for the particular fire area

Progress Energy FSA O Section 3.6 Radioactive Release Compliance Summary Z High level results of fire area radioactive release evaluation O Section 3.7 Probabilistic Risk Assessment -

Summary of Results Z Listing of all fixed ignition sources in the area for which the calculated risk is equal to or above 1E-8/year for CDF Z If the CDF takes into account the assumption that a plant modification will be performed, a narrative description is provided with reference to Attachment 2 (i.e. incipient fire detection, installation of new automatic suppression system, etc.)

Progress Energy FSA O Section 3.8 Risk Informed, Performance-Based Evaluations Z Summary of results for the fire area Z Detailed information found in Attachment 2 - i.e. Transition Change Evaluation O Section 3.9 Defense-in-Depth Z Extent to which fire protection systems and features are provided

Progress Energy FSA O Section 3.10 Monitoring Program Input Z High-level for FSA Z Procedure provides detailed information for methodology O Section 4.0 Conclusions O Section 5.0 Attachments O Attachment 1 - NEI 04-02 Table B Nuclear Safety Capability Assessment Summary

Progress Energy FSA O Attachment 2 - Scenario Discussions -

Change Evaluations:

Z Change Description identifies changes for evaluation in fire area -

X A. Variances from Deterministic Separation Requirements (based on deterministic pre-transition post-fire safe shutdown analysis)

X B. Other Changes Being Evaluated (includes operator manual actions not previously approved/allowed)

X C. ERFBS (i.e. Hemyc, MT)

Progress Energy FSA O Scenario Descriptions and Model Results X Summary of results on a fire scenario basis X Includes listing of all change process targets associated with ignition sources in the area in which the calculated risk is equal to or above 1E-8/year for CDF X Targets addressed were those identified as being in the Zone of Influence (ZOI) of risk significant sources X Resolution options provided on a scenario basis (i.e. incipient detection for a panel to prevent flame and radiant heat energy from igniting cables and causing a hot gas layer)

Progress Energy FSA O Scenario Descriptions and Model Results Z Scenarios below 1E-8 not addressed in evaluation because any change in risk is below the RG 1.205 acceptance criteria which bound the RG 1.174 criteria Z Change process targets that are not within the ZOI are free of fire damage, and therefore, considered acceptable as-is

Progress Energy FSA O Risk Evaluation Z Assessment of Change in CDF and Change in LERF O Impact of Change on Defense-in-Depth O Safety Margin Considerations O Transition Change Evaluation Conclusions

Progress Energy FSA Questions?