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)

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Non-Power Operational Mode Review Status Bob Rhodes May 31, 2007 HNP Pilot MeetingMay 30 -June 1, 2007 Raleigh, NC ShirelleAllen,CES/FP Harris OconeePilotObservationMeeting April15,2008Charlotte,NC HarrisNuclearPlant(HNP)NFPA805Transition FireSafetyAnalysis(FSA)Update Progress Energy FSA Status - To date: 2 nd 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) In Progress: strategy finalization, calculation preparation and design

verification, final list of proposed plant

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

design basis document as described in

NFPA 805:2.7.1.2 Section 3.1 details steps performed to develop FSA Progress Energy FSA Section 3.2 Classical Fire Protection Fire Response Strategy Construction Ventilation Detection Automatic Suppression Manual Suppression Progress Energy FSA Section 3.3 Fire Hazards Identification Normally expected fire hazards for the fire area Area specific classifications/designations Section 3.4 NSCA Compliance Summary Fire area contents Approaches utilized to demonstrate

compliance i.e. deterministic, performance-based, combination Progress Energy FSA Section 3.5 Non-Power Operational Modes Compliance Summary Review conducted using guidance found in NEI 04-02 and FAQ 07-0040 Calculation HNP-E/ELEC-0002 presents

methodology, "pinch points", and

description of strategy developed to

resolve concern High level results of the non-power

operations evaluation presented within

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

Summary of Results Listing of all fixed ignition sources in the area for which the calculated risk is equal to or above 1E-

8/year for CDF If the CDF takes into account the assumption that a plant modification will be performed, a narrative description is provided with reference to (i.e. incipient fire detection, installation of new automatic suppression system, etc.)

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

and features are provided Progress Energy FSA Section 3.10 Monitoring Program Input High-level for FSA Procedure provides detailed information for methodology Section 4.0 Conclusions Section 5.0 Attachments Attachment 1 -NEI 04-02 Table B Nuclear Safety Capability Assessment Summary Progress Energy FSAAttachment 2 -Scenario Discussions -

Change Evaluations: Change Description identifies changes for evaluation in fire area - A. Variances from Deterministic Separation Requirements (based on deterministic pre-

transition post-fire safe shutdown analysis) B. Other Changes Being Evaluated (includes operator manual actions not previously approved/allowed) C. ERFBS (i.e. Hemyc, MT)

Progress Energy FSA Scenario Descriptions and Model Results Summary of results on a fire scenario basis 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 Targets addressed were those identified as

being in the Zone of Influence (ZOI) of risk significant sources 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 Scenario Descriptions and Model Results 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 Change process targets that are not

within the ZOI are free of fire damage, and therefore, considered acceptable "as-is" Progress Energy FSA Risk Evaluation Assessment of Change in CDF and Change in LERF Impact of Change on Defense-in-Depth Safety Margin Considerations Transition Change Evaluation Conclusions Progress Energy FSA Questions?