ML13066A740
| ML13066A740 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/07/2013 |
| From: | Pacific Gas & Electric Co |
| To: | Plant Licensing Branch IV |
| Polickoski J | |
| References | |
| TAC MF0687, TAC MF0688 | |
| Download: ML13066A740 (24) | |
Text
Diablo Canyon Power Plant NFPA 805 Transition Project Pre-Submittal Meeting with NRC 03/07/2013
2
Introductions
PG&E Representatives Steve BakerManager, Design Engineering Rasool BaradaranSupervisor, Probabilistic Risk Assessment (PRA)
Michael RichardsonRegulatory Services Paul Bemis....Strategic Projects Oversight (SPO)
John PyoFPRA / FREs Lead (by phone)
Brent Waggener...Independent Verifier (by phone)
Project Consultants - EPM Ted StantonSite Modifications Technical Coordinator Paul Ouellette....Division Manager, Safety & Systems Analysis (by phone)
Mark Crompton.Project Manager (by phone)
Jim Gregerson......Site Project Coordinator (by phone)
Ray Dyer..Site Technical Lead (by phone)
Meeting Objectives 3
- Last Presentation before submittal in June
- Present / Discuss LAR
- Receive feedback from Staff on LAR acceptability and information
Meeting Agenda 4
- Overview of NFPA 805 Transition Background
- Discuss Preliminary Results
- NFPA 805 Chapter 3 Compliance
- Internal Events/Internal Flooding, Fire, Seismic PRAs Peer Reviewed to RG 1.200 rev. 2; Turbine Building Fragilities included
- SSHAC Level 3 Schedule
- Discuss Post-Submittal Implementation
- Proposed Modifications
- Other Implementation Items
- Questions / Discussion / Feedback
Diablo Canyon Power Plant 5
- 2 PWR Units
- 4-Loop Westinghouse NSSS
- 1150 MWe / Unit
- Initial Operating License:
- Unit 1: 1984
- Unit 2: 1985 Owned and Operated by Pacific Gas & Electric Company (PG&E)
6 Current Fire Protection Licensing Basis
- 10 CFR 50.48(a) and (b)
- 10 CFR 50, Appendix A, GDC 3, 1971
- 10 CFR 50, Appendix R, III.G, III.J, III.L, III.O
- License Conditions 2.C.(5) (Unit 1) and 2.C.(4) (Unit 2)
- Branch Technical Position APCSB 9.5-1 Appendix A
- Current Deviations
- 39 Current Deviations
- Current Plan: Transition 11 Deviations
7 NFPA 805 Transition Overview
- License Amendment Request (LAR) submittal date: June 28, 2013
- Program Improvements Realized:
- Multiple Fire Risk Evaluation Iterations
- Seismic Fragilities complete in Turbine Building; remainder in progress
- DCPPs reported Total CDF/LERF represent true overall risk
- Additional 3rd party reviews by Industry/Legal/Academic Experts of:
- PRA (complete)
- Fire Models (complete & planned)
- Circuit Analysis (complete)
- NUREG CR6850 compliance (complete)
- LAR Package (planned)
- LAR Transition Report draft complete
- Preparation and Internal Review in Progress
8 NFPA 805 Transition Guidance
- NEI 04-02, revision 2
- NEI 00-01, revision 2
- Regulatory Guides:
- 1.205 revision 1
- 1.200 revision 2
- 1.174 revision 1
9 NFPA 805 TRANSITION PROJECT ORGANIZATION CHART DIABLO CANYON POWER PLANT
10 Fundamental FP Program & Design Elements (LAR Attachment A)
- 135 Total Sections
- Note: Several Sections Require Two Responses (e.g., Complies with use of Existing Engineering Equivalency Evaluation (EEEE) and Required Action)
- Complies: 84
- Complies with Clarification: 6
- Complies by previous NRC Approval: 10
- Complies with use of EEEE: 13
- Submit for NRC Approval: 6
- Complies with Required Action: 19
11 Non-Power Operations Review (LAR Attachment D)
- High Risk Evolutions
- Consistent with Existing Procedure
- AD8.DC50, Outage Safety Management
- Mid-Loop (Plant Operating State (POS) 2)
- Consistent with FAQ 07-0040
- Pinch Points Identified:
- Unit 1: 45 areas containing pinch points
- Unit 2: 47 areas containing pinch points
12 Radioactive Release Review (LAR Attachment E)
- Evaluated by Fire Area / Fire Zone
- Pre-Fire Plans Revisions & Training Updates Scheduled
- Tracked as Implementation Item (IMP-038)
13 Nuclear Safety Capability Assessment
- 110 Fire Areas in Power Block (LAR Attachment C)
- 44 Deterministic (4.2.3) Fire Areas
- 66 Performance-Based (4.2.4) Fire Areas
- Safe and Stable (LAR Section 4.2.1.2)
- Hot Standby (Mode 3)
- Qualitative Discussion of Long-Term Safe and Stable
14 Recovery Action Transition (LAR Attachment G)
- As of current LAR draft:
- Unit 1:
- 9 Credited Recovery Actions
- Unit 2:
- 9 Credited Recovery Actions
- Additional Defense-in-Depth Actions
- Not Credited in PRA
15 Monitoring Program (LAR Section 4.6)
- FAQ 10-0059 Guidance
- High Safety Significance / FPRA Components:
- System and Program Health Monitoring
- Based on Peer Reviewed Internal Events PRA
- Fire PRA Peer Review (2010)
- Facts and Observations:
- 80% Addressed / Closed
- Remainder scheduled to complete by time of submittal
- No Unreviewed Methods Used
- Peer Reviewed
Overall Plant Risk 17
- Based on Peer Reviewed Models with Additional Refinements
- Includes proposed modifications
- Updates still in progress; will complete by time of submittal
- SSHAC Level 3 to be complete by March 12, 2015 (consistent with 50.54(f) letter)
- Fire CDF: ~5 x 10-5 / unit (still in refinement)
- Overall Plant CDF: ~8.5 x 10-5 / unit (still in refinement)
- Includes Fire, IE/IF, and Seismic
Fire Risk 18
- Based on Fire Risk Evaluations, revision 0
- Includes proposed modifications
- Revision 1 in progress based on self-assessment of Fire PRA and modeling
- Will be complete by time of LAR Submittal
- Fire CDF:
- Unit 1: Goal ~5 x 10-6 (still in refinement)
- Unit 2: Goal ~5 x 10-6 (still in refinement)
- Fire LERF:
- Unit 1: Goal ~5 x 10-7 (still in refinement)
- Unit 2: Goal ~5 x 10-7 (still in refinement)
19 Regulatory Guide 1.174 Risk Assessment
- Planned (post transition, post modification) Risk in Region II
Plant Risk due to VFDR(s) ~5x10-6
~8.5x10-5 Overall Plant Risk
20 Implementation (1/2)
(LAR Attachment S)
- Four Proposed Modifications (each applicable to both units)
- Incipient Fire Detection Installation
- SSPS and Cable Spreading Room Cabinets
- RCP Seal Upgrade
- ERFBS Installation and Circuit Re-Route
- Hot Shutdown Panel Upgrades
21 Implementation (2/2)
(LAR Attachment S)
- 32 Implementation Items
- Significant Implementation items include:
- Finalization of Configuration Control process revisions (in progress)
- Review of PRA model following implementation of modifications
- Incorporation of Code Conformance Review (including Codes of Record) into Engineering Equivalency Evaluation (EEE) program
- Revise Pre-Fire Plans and Training Materials to address Radioactive Release Requirements
- Implementation Items to be Complete prior to Implementation
22 Post-Implementation Program Maintenance
- Change Management Plan
- Per Plant Procedure
- Includes Detailed Plan of Actions and Milestones, Tracked in SAP
- Transition Plan
- Maintain close Fire Protection Engineering group liaison with NFPA 805 Transition Project throughout RAI and Implementation phase
23 Summary
- Complete LAR to be submitted by June 28, 2013
- In-process reviews along with planned reviews by Industry/Legal/Academic experts
- Transition is Based on Peer Reviewed Internal Events/ Internal Flooding, Seismic, and Fire PRAs
- In-house PRA staff intimately involved with PRA development and upgrade; Presented/Responded to Peer Review Teams
- Four Proposed Modifications to improve plant fire risk
- Transition:
- Developing procedure changes and training programs
- Complete modifications not later than 2R20, spring 2018
Comments? 24 Questions?
Feedback?