COMMISSION BRIEFING SLIDES/EXHIBITS

BRIEFING ON FIRE PROTECTION

JULY 17, 2008
Nuclear Regulatory Commission

Briefing on

Fire Protection

July 17, 2008

Mr. Richard A. Muench

President and CEO

Wolf Creek Nuclear

Operating Corporation

1
Discussion Topics

* Operator Manual Actions

* Fire Induced Circuit Failures

* NFPA 805 Transition

2
Operator Manual Actions

* Licensees working to complete

corrective actions by March of

2009

* NFPA 805 transition and

resolution of fire induced

multiple spurious circuit failure

issue impacts resolution of many

operator manual action items

3
Fire Induced Circuit Failures

* Status

Agreement on conceptual approach

Implementation details addressed

in future meetings

* Use of risk to address associated

circuit issues without exemption

or LAR must be included

4
Fire Induced Circuit Failures

* Industry I NRC meetings will

continue

• Industry actions in the interim

Developing implementation details

Guiding use of risk insights for

resolution of issues

Preparing draft revision to industry

guidance

* Goal - receive NRC endorsement

5
Fire Induced Circuit Failures

* Use of risk to address fire induced

circuit failures in associated

circuits

- Regulations do not prohibit

- Use of risk is consistent with the Commission's

Policy Statement on use of PRA (60FR42622)

* Failure to allow could result in

- actions that could raise overall plant risk,

- need for new exemptions or LAR's and/or

- costly modifications for low risk and low safetysignificance items

6
NFPA 805 Transition

* Pilot plants (Oconee and Harris)

license amendment requests

submitted

* Activities necessary to enhance

regulatory certainty

- Refinement of LAR template

- Resolve PRA issues

Minimize requests for additional

information

7
Fire PRA

• Fire PRA is a challenge

- Preliminary results are conservative

- Goal in PRA is to be more realistic

* Industry and NRC Staff addressing

items seen as main contributors

to conservatism

* Goal. is to resolve by late 2008

8
N•FPA 805 Enforcement

Discretion

• Extension to enforcement

discretion is important

- Limited qualified resources

- Incorporate lessons learned from

pilot plants

-Assure consistent licensing bases

• Near term Commission decision

requested

9
N Acronyms

" NFPA

" LAR

* PRA

National Fire Protection Association

License Amendment Request

Probability Risk Assessment

/ 10
NFPA 805

Lessons Learned

Shearon Harris Nuclear Plant.

July 17, 2008

Joe Donahue

Vice President Engineering

N tICI I0 Progress Energy

1
Fire Protection Defense In Depth

o Prevent Fires

o Prompt Detection Of Fires

o Prompt Control and Suppression Of

Fires

o Separation Of Safety Systems

0 Ný

QProgress Energy

Page 2
Fire PRA Implementation

o Extensive Walkdowns Identified

Potential Fire Sources

o 4000+ Fire Scenarios Evaluated

o NRC Team Review

o Industry Expert Peer Review

c~NudLG Criiv

A.A G Ott r

UProgress Energy

Page 3
Fire PRA Implementation

* Fire PRA Is Acceptable For Use

* Other Inputs are Used for Decision Making

* Process

Industry

Improvements Provided To NRC and

N L IC II

CProgress Energy

Page 4
Harris NFPA 805 Fire Protection

o Implements classical requirements

o Implements nuclear safety performance

criteria

o Addresses fire safety during, non-power

operations

o License amendment request submitted

o Transition resources were greater than

'10,ip;,, originally estimated Progress Energy

Page 5
Generic Issues Addressed

o Hemyc/MT Fire Wrap Qualification

o Operator Manual Actions

o Multiple Spurious Operations

CProgress Energy

Page 6
Harris Physical Plant Changes

o New Cable Raceway Wrap

o New Fire Rated Cable

o Upgrades To Hemyc/Mt Wrap

o Additional Equipment Separation

o Additional Incipient Fire Detection In Critical

Electrical Panels

K Progress Energy

Page 7
Summary

o Transition To NFPA 805 Is Improving

Fire Protection Program

D Resolution Of Generic Fire Protection

Issues

D Physical Plant Modifications Already

Completed

D Additional Modifications Being

Implemented

Np • Progress Energy

Page 8
b

Summary

NFPA 805 License Amendment Request

Submitted

C On Track To Complete Implementation

By End Of 2010

Nue

6ou

CProgress Energy

Page 9
NFPA 805

Lessons Learned

Oconee Nuclear Station

July 17, 2008

David Baxter

Site Vice President

,Duke 'Energy®
NFPA 805 Lessons

* Oconee showed that NFPA 805. is an

excellent fit for the older -nuclear

stations.

*A good solid Safe Shutdown Analysis

documenting deviations with Fire

Regulations should be in place to start

transition

: Duke

7;Energy®
NFPA 805 Lessons

* The pilot process was very

complicated, time consuming and

expensive.

*Document and calculation reviews took

much longer than expected due to new

program.

Duke

~Energya®
NFPA 805 Lessons

* Oconee required separate Fire PRA

models.

oNUREG-6850 turned out to be

somewhat conservative, but provided a

good foundation to build on.

6iDuke

!FEnergy®
D

NFPA 805 Lessons

*Although further tuning is planned, the

Fire PRA's models realistically modeled

the plant.

*The process of transition is very manpower intensive

Duke

7Energy®
--r ELECTRIC POWER R RESEARCH INSTITUTE

BRIEFING ON FIRE

PROTECTION

ISSUES

Ken Canavan

Senior Program

Risk and Safety

Manager

Management

July 2008
EPRI Fire PRA Philosophy

* Consistent with the PRA Policy Statement

"Use of the PRA technology should be increased in

all regulatory matters to the extent supported by the

state of the art ..."

* Committed to supporting a risk-informed,

performance based approach to fire

protection

- Realistic methods

- Realistic input

- Monitoring and feedback process

© 2008 Electric Power Research Institute, Inc. All rights reserved. 2 I VS' C IE
Fire PRA Methodology Development

* NUREG/CR-6850 is guidance for

developing a Fire PRA

0

- NRC-RES / EPRI collaboration (EPRI 1011989)

- Only pieces piloted (initially)

Two Fire PRA Pilots

- Initial results are conservative

- Not unexpected

- Result of individual minor to moderate conservatisms

ELECTRIC IPOW E

© Power Research Institute, Inc. All rights reserved. 8m ira REEACHINTITUTE 2008 Electric
Fire PRA Methodology Issues,

* Fire Ignition Frequencies

" Credit for Incipient Detection

" Treatment of Large Oil Fires

" Fire Growth and Propagation Models

" Credit for Fire Suppression

" -Hot Short Susceptibility, Probability and

Duration

* High Energy Arching Faults

" Cable Tray Fire Modeling

©0I ELETRIC PPWýTR

(D 2008 Electric Power Research Institute, Inc. All rights reserved. 4_ = 0 RESEACH INSTITUJTE
Other Issues, Progress and Challenges

• Other Issues

- Shortage of Trained Risk Personnel

- Practical modeling limitations

*-Progress

- Education of Risk Professionals and Fire PRA

Methods Training

- EPRI / NRC-RES working to refine Fire PRA

methods

Challenges

- Available resources

- Time constraints

'2IELECT111POWER

RE SEARHIN~STITUTE © 2008 Electric Power Research Institute, Inc. All rights reserved.
SU.S.NRC

Uniiced Staces Nuclear Regulatory Cormmission

Protecting People and the Environment

Commission Briefing on

Fire Protection Issues

July 17, 2008
Agenda

" Introduction

-Jack Grobe, NRR

" Current Issues

- Mark Cunningham, NRR

* Summary

- Jack Grobe, NRR

2
Introduction

* Fire protection at operating

reactors

* Steering Committee activities

* Remaining issues

- Fire barrier performance

- Operator manual actions

- Fire-induced circuit failures

- Implementation of NFPA 805

3
Fire Barrier Performance

* Protection of electrical equipment

required

" Inspections and research

identified deficiencies

" Actions were taken

" Documenting closure

4
Operator Manual Actions

" Inspections identified

inconsistencies

RIS 2006-10 clarified regulatory

positions

" Completing closure

- Plant-specific resolution

- Staff follow up

5
Fire-Induced Circuit Failures

* SECY-08-0093 provides approach

- Methods for protecting safe

shutdown capability

- Enforcement discretion proposal

* Achieving closure

- Finalize and implement guidance

- Complete direct current circuits

research

- Implementing closure plan

6 I
NFPA 805 Implementation

• Alternative approach

- Risk informed

- Performance based

* 47 units committed to transition

• Pilot plant license amendments

under acceptance review

7'
NFPA 805 Implementation

* Infrastructure being finalized

- Technical methods and standards

- Regulatory Guidance

Resource planning and allocation

Communications

8
I

NFPA 805 Implementation

* Implementing closure plan

-Finalize guidance

- Standardize review process

- Share lessons learned

- Receive and review amendments

Licensees implement changes

Staff inspects implementation

9
Summary

* Maintain a stable and predictable

regulatory environment

* Communicate with licensees and

public

10