ML072270014

07/13/2007 Summary of Meeting with Duke Power Regarding Pilot Plant Transition to National Fire Protection Association Standard 805

ML072270014
Person / Time
Site:	Oconee
Issue date:	09/14/2007
From:	Oudinot D H NRC/NRR/DRA/FPB
To:	Weerakkody S D NRC/NRR/DRA/FPB
Oudinot, D.H., NRR/DRA, 415-4064
Shared Package
ML072270303	List: ML072140380 ML072270014
References
Download: ML072270014 (5)

Text

September 14, 2007MEMORANDUM TO: Sunil D. Weerakkody, ChiefFire Protection Branch Division of Risk Assessment Office of Nuclear Reactor RegulationFROM:Daniele H. Oudinot, Reactor Systems Engineer /RA/Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUMMARY

OF JULY 13, 2007, PUBLIC MEETING WITH DUKEPOWER REGARDING PILOT PLANT TRANSITION TO NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805On July 13, 2007, the U.S. Nuclear Regulatory Commission staff from Headquarters andRegion II participated in a public meeting with Duke Power to discuss Oconee Nuclear Station transition to the National Fire Protection Association (NFPA) Standard 805.

The meeting took place at the Oconee site in Seneca, South Carolina. This public meeting followed a non-public NFPA 805 observation visit also held at the Oconee site on July 10, 11, and 12, 2007. Enclosed are a list of the meeting participants (Enclosure 1) and a summary of the discussiontopics and status (Enclosure 2). The publically available documents handed out during the meeting are available in the Agencywide Documents Access and Management System (ADAMS) Accession No. ML072140380.

Enclosures:

1. Meeting participants

2. Summary Topics and StatusCONTACT: Daniele Oudinot, NRR/DRA (301) 415-4064 MEMORANDUM TO: Sunil D. Weerakkody, ChiefFire Protection Branch Division of Risk Assessment Office of Nuclear Reactor RegulationFROM:Daniele H. Oudinot, Reactor Systems EngineerFire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUMMARY

OF JULY 13, 2007, PUBLIC MEETING WITH DUKEPOWER REGARDING PILOT PLANT TRANSITION TO NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805On July 13, 2007, the U.S. Nuclear Regulatory Commission staff from Headquarters andRegion II participated in a public meeting with Duke Power to discuss Oconee Nuclear Station transition to the National Fire Protection Association (NFPA) Standard 805.

The meeting took place at the Oconee site in Seneca, South Carolina. This public meeting followed a non-public NFPA 805 observation visit also held at the Oconee site on July 10, 11, and 12, 2007. Enclosed are a list of the meeting participants (Enclosure 1) and a summary of the discussiontopics and status (Enclosure 2). The publically available documents handed out during the meeting are available in the Agencywide Documents Access and Management System (ADAMS) Accession No. ML072140380.

Enclosures:

1. Meeting participants

2. Summary Topics and Status

DISTRIBUTION

DRA r/f RGallucci JCircle PLainJSHyslopEMcCannSWeerakkody SwalkerMSalleyHBarrett SLaurADAMS Accession # (Package): ML072270303ADAMS Accession # (Cover memo with encl.): ML072270014 ADAMS Accession # (Handouts): ML072140380OFFICENRR/DRA/AFPBNRR/DRA/AFPBNRR/DRA/AFPBNAMEPLainDOudinotAKleinDATE09/ 13 /200709/ 14 /200709/ 14 /2007OFFICIAL RECORD COPY ENCLOSURE 1PUBLIC MEETING REGARDING PILOT PLANT (OCONEE) TRANSITION TO NATIONAL FIRE PROTECTIONASSOCIATION STANDARD 805List of ParticipantsU.S. Nuclear Regulatory Commission StaffS. WalkerJ.S. Hyslop E. McCann P. Lain J. Circle R. Gallucci S. Laur H. BarrettStakeholdersDuke Power RepresentativesMembers of the Public Industry Representatives Consultants to the Industry Progress Energy Representatives Nuclear Energy Institute Representatives ENCLOSURE 2PUBLIC MEETING (July 13, 2007)Category 2Paul Lain - introduction; good progress by both pilots; upcoming Nuclear Energy Institute(NEI)Task Force meeting that can reveal some of the more sensitive material not available as part of public meetingsDavid Goforth - status of Oconee transition (presentation)AREVA completing App. R reconstitution Tables B-1, B-2 and B-3 ready or under development Emergency Planning preparing radioactive release analysis Non-power operations analysis on hold awaiting the Nuclear Regulatory Commission (NRC)presentation at the NEI Frequently Asked Questions (FAQ) meeting on July 19 thConfiguration control requires maintaining both current Fire Protection Program (FPP) andupcoming National Fire Protection Association (NFPA)-805 FPP; Oconee is performing many major modifications (using AREVA to track)Documentation of all the above, especially configuration control License Amendment Request (LAR) supported by Duke Licensing; impacts on the updatedfinal safety analysis report; LAR submittal aimed for May 2008All three Duke sites are now officially in NFPA-805 transition (last, Catawba, entered July 2 nd)Harold Lefkowitz - Table B-1 (presentation)Classical FP; supported by NEXUS Providing input for Fire Probabilistic Safety Assessment (FPSA) under NUREG/CR-6850 onignition sourcesTable B-1 shows alignment with classical Fire Protection (FP) in NFPA-805 Chapter 3.

Walkdown throughout plant to create current Fire Hazards Analysis Compliance status assessed with respect to NFPA-805 Chapter 3 requirements; supportedby supplementary report to Table B-1Liz Kleinsorg - Tables B-2 and B-3; Non-power operations (presentations)Implications of "non-alignment" with NEI 00-01 (only guidance) - assess for "adverseconsequences"Oconee currently has licensing basis exempting them from spurious actuations during first10 min of a fire (analogous to Harris' SER assumption of no intercable interactions)Table B-3 addresses interface with NFPA-805 Chapter 4 (and when there is need toevaluate against Chapter 3), including Engineering Equivalency Evaluations; B-3summarizes but does not provide detailsNeed to know where the difference between deterministic and performance-based analysislies for existing compliancesProject Instructions address (1) development of Table B-3, (2) assessing accomplishment ofNFPA-805 performance goals, (3) review of fire area licensing actions ("bring forward"),

2(4) review of Engineering Equivalency Evaluations (FAQ 07-0033), (5) documentingresults and defining open itemsNEI 04-02, App. F, lays out methodology to address non-power operations focusing only oncomplete loss of key safety functions via pinch pointsOconee and Harris exclude spent fuel pool from high risk evolution due to plentitude of timeto replace water if necessaryEd Simbles and Andy Ratchford - Duke FPSA and Plant Change Evaluations (presentation)Multi-compartment analysis washes out problems with compartment definition As FPSA is being developed, Oconee-3 internal events Probabilitistic Safety Assessment(PSA) is undergoing upgrade to meet RG-1.200Human Error Probability (HEP) screening methodology differs from NUREG/CR-6850 American Nuclear Society FPSA Standard is requiring more extensive treatment of fire-induced loss of instrumentation than advocated in NUREG/CR-6850So far, no assumption that trip of one unit causes trip of another Credit has not yet been taken for suppression

0.3 probability

factor for armored cable hot shorts is "only used when needed" FP defense-in-depth and safety margin is well addressed in NEI 04-02 and RG-1.205Andy Ratchford - Parking LotBringing forward approved Safety Evaluation Reports assumptions - red box FP vs. bluebox PSADuke's HEP screening vs. NUREG/CR-6850