Lindy Hughes Fleet Fire Protection Program Engineer Southern Nuclear Operating Company June 4, 2013 Fire Protection
Fire Protection Under Deterministic Program Reg Guide was developed to provide a comprehensive fire protection guidance document and to identify the scope and depth of fire protection that the NRC would consider acceptable for nuclear power plants
Fire Protection Configuration Management Qualified personnel review new designs and plant modifications, including fire protection systems, must be reviewed to ensure inclusion of appropriate fire protection requirements
Fire Protection Configuration Management Instructions and procedures for design, installation, inspection, test, maintenance, modification, and administrative controls must be reviewed to ensure proper FP requirements are addressed, including – Control of ignition sources and combustibles – Provisions for backup fire protection capability – Disablement of FP system – Restrictions on material substitutions
Fire Protection Configuration Management Under NFPA 805 NEI provides guidance for implementing the requirements of NFPA 805
Fire Protection Configuration Management Under NFPA 805 Plant Change Evaluation Shall be performed to ensure that a change to a previously approved fire protection program element is acceptable Process shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins Impact of proposed change shall be monitored
Risk Acceptance Change in public health risk from any plant change shall be acceptable to AHJ CDF and LERF shall be used to determine acceptability
Defense in Depth Plant change evaluation shall ensure philosophy of defense-in- depth is maintained, relative to fire protection and nuclear safety
Defense in Depth for Fire Protection Prevent fires from starting Rapidly detect, control, and extinguish fires that do occur Provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished will not prevent the safe shutdown of the plant
Defense in Depth for Nuclear Safety Prevent core damage Prevent containment failure Mitigate consequences
Safety Margins Plant change evaluation shall ensure sufficient safety margins are maintained
Fire Protection Configuration Management Under NFPA 805 The fire prevention activities shall include but not be limited to the following program elements: (3) Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized
Fire Protection Configuration Management Under NFPA 805 Monitoring Program Ensures availability and reliability of FP systems and features are maintained Assesses performance of FP program in meeting performance criteria Ensures assumptions in engineering analysis remain valid
Fire PRA Fire PRAs do not always use traditional fire area boundaries when developing Physical Analysis Units (PAUs) Non fire rated boundaries can be credited Modified or new equipment / components can introduce new ignition sources or hazards
Fire PRA Fire PRAs in finalization and/or development for all SNC operating units During development of Fire PRA, freeze date for each plant state is applied Potential impacts to Fire PRAs must be documented for post-freeze date Screening being added to Fire Protection checklist