ML101670523

06/08/2010 - 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 0 6/0 4/1 0 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 1 0 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 1 2 0 6/04/10 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 1 4 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 comple x 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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