ML101670523

NRC Fire Protection Screening Criteria, Brunswick Nuclear Plant

ML101670523
Person / Time
Site:	Brunswick
Issue date:	06/08/2010
From:	Progress Energy Co
To:	NRC/NRR/DIRS/IRIB
Jeremy Bowen, 415-3471
Shared Package
ML101670555	List: ML101670428 ML101670490 ML101670501 ML101670520 ML101670523 ML101670548
References
Download: ML101670523 (18)

Text

Enclosure 3 Brunswick Nuclear Plant Presentation Meeting Summary of the 6/8/2010 Meeting with NRC/SNC/FPL/SCE&G Dated June 17, 2010

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• Opening Remarks

• Operator Manual Actions

• NRC Fire Protection Screening Criteria

• Fire Probabilistic Risk Assessment

• Program Oversight

• NFPA 805 Transition

• Screening Criteria Summary

• Summary

~ 2 06/04/10 ~ Progress Energy

• OMA Feasibility Study conducted

• Conducted Drills and Validated Timeliness with each operating shift and implemented improvements

• Reviewed Training Material and created new Job Performance Measures (JPMs)

• Performed black-out testing of Emergency Lighting units to ensure adequate lighting

• Enhanced aiming and revised drawings to provide additional detail

• Performed comparison between Safe Shutdown Analysis and Alternate Safe Shutdown (ASSD)

Procedures

• Identified differences and made changes to ensure alignment

• Smoke model developed to address smoke movement

• Several Operator Manual Actions were eliminated

~ 3 06/04/10 ~ Progress Energy

Screening Criteria #1: Large number of OMAs

• Total III.G.2 OMAs Unit 1 = 30 and Unit 2 = 29

• 6 are common to both units

• Totallll.G.2 Fire Areas with Hot Shutdown (HSD)

OMAs for both Units: 9 Unit 1 III.G.2 Fire Areas OMAs Unit 2 III.G.2 Fire Areas OMAs CB-09: 1 CB-07: 3 DG-08 (Train "A" Shutdown): 7 DG-04: 7 DG-08 (Train "B" Shutdown): 3 DG-06: 3 DG-09: 7 DG-12: 7 DG-13: 3 DG-16E: 9 (3 are unit specific)

DG-16E: 9 (3 are unit specific)

~ 4 06104/10 ~ Progress EnergV

Screening Criteria #1: Large number of OMAs

• Confident our manual action are feasible and can be successfully implemented

• Small number of III.G.2 HSD OMAs per fire area

• Brunswick believes the risk of these OMAs is very small

~ 5 06/04/10 ~ Progress Energy

Screening Criteria #2: Single Fire affecting more than one Unit

• Criteria applies

• Brunswick is a dual unit plant

• OMA Feasibility Study addressed dual unit shutdown and ensured timeliness of actions

• Periodic Training, Evaluation and Drills conducted to ensure effectiveness

~ 6 06/04/10 ~ Progress Energy

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• Screening Criteria #6: Complex OMAs and insufficient time to complete OMAs

• Brunswick III.G.2 OMAs are simple straightforward prescriptive actions

• No Coordination required with other operators

• Single discrete actions

+ If MOV does not open from Main Control Board ...

Then Open breaker and manually open valve

• Do not require diagnosis or complex decisions

• Manipulations are used in normal operation and for routine maintenance clearances

• One Time-Critical OMA to block open 6 Diesel Building doors - time validated

~ 8 06/04/10 ~ Progress Energy

Screening Criteria #6: Complex OMAs and insufficient time to complete OMAs

• Totallll.G.2 OMAs Unit 1 = 30 and Unit 2 = 29 (6 are common to both units)

• 6 QMAs block open 6 Diesel Building doors (common to both units)

• 11 OMAs monitor Condensate Storage Tank level

• 18 OMAs open breakers (4 MOVs per unit)

• 18 OMAs manually operate valves (4 MOVs per unit)

• Operator Initial and Continuing Training developed using the Systematic Approach to Training

• Periodic training, evaluation and drills conducted

• Over a 2 year Training Cycle

• Classroom

• Simulator/In-plant drills

. JPMs

~ 9 06/04/10 ~ Progress Energy

Screening Criteria #7: Mitigation requires cross-tying electrical or mechanical systems

• Criteria applies

• Brunswick can require cross-tying electrical systems for some fire areas

• Systems and components are operated in accordance with their design function

• Electrical cross-ties are part of original plant design

• The ability to cross-tie provides significant risk benefit

~ 10 06/04/10 ~ Progress Energy

Screening Criteria #8: Symptom-based procedures with complex OMAs

• ASSD procedures are event based

• Continuous Use Procedures

• Procedure Placekeeping required (circle and slash)

• None of the OMAs are considered complex

• Addressed in Screening Criteria #6

~ 11 06/04/10 ~ Progress Energy

• III.G.2 actions do not disable any equipment

• OMAs Human Reliability Analysis (HRA)

Probability of success is very high

• Based upon NFPA 805 Transition results at Harris and Crystal River, OMAs may be deleted from procedures in future

• Many Fires do not damage the cables in the associated fire areas

~ 12 06/04/10 ~ Progress Energy

• Program Self Assessment with Industry Peers

• NFPA 805 will re-evaluate OMAs

• Independent Corporate Oversight

• NRC Inspections

~ 13 06/04/10 ~ Progress Energy

• Appendix R is current Licensing Basis

• OMAs reviewed per NRC Regulatory Issue SummarY 2006-10, "Regulatory Expectations with App.endix R Paragraph n1.G.2 Operator Manual Actions"

• Progress Energy submitted letter of intent to adopt NFPA 805

• Brunswick scheduled to submit the License Amendment Request by August 2011

• One of NFPA 805 transition goals is to reduce dependence on OMAs

• Implementation of NFPA 805 will improve the overall safety

~ 14 06/04/10 ~ Progress Energy

1. A large number of Operator Manual Actions (OMAs) used to YES NO mitigate cable separation issues

2. A single fire could affect more than one unit. YES YES

3. The use of thermoplastic cable . NO NO

4. Limited documentation of cable routing within the plant. NO NO

5. A Self-Induced Station Slack-Out (SISSO) strategy (isolating all YES NO on-site power to basically everything except the protected train to prevent spurious actuations) for fires in areas without adequate cable separation .

6. The OMAs are very complicated, not high confidence that YES NO operators would be able to implement them in fire conditions.

7. Mitigation of a fire requires the use of systems from multiple YES YES units (electrical or mechanical cross-unit ties) .

8. Symptom-based fire response procedures with complex OMAs. YES NO

~ 15 06/04/10 ~ Progress Energy

• Single fire could affect more than one unit

• Mitigation can require cross-tying electrical systems between units

• Do not have a large number of OMAs per Fire Area

• Not a SISBO strategy plant

• OMAs

• Simple, not complex

• OMAs do not require diagnosis or complex decisions

• Risk impact of OMAs is expected to be very small

• Periodic Training and Evaluation is conducted

• Brunswick is in compliance with current NRC requirements and are fully committed to transitioning to NFPA 805

~ 16 06/04/10 ~ Progress Energy

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