Lindy Hughes Fleet Fire Protection Program Engineer Southern Nuclear Operating Company June 4, 2013 Fire Protection.

Lindy HughesFleet Fire Protection Program EngineerSouthern Nuclear Operating Company

June 4, 2013

Fire Protection

Fire Protection Under Deterministic ProgramReg Guide 1.189 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 ManagementQualified 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 ManagementInstructions 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 805NEI 04-02 provides guidance for

implementing the requirements of NFPA 805

Fire Protection Configuration Management Under NFPA 805Plant 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 AcceptanceChange in public health risk from any plant

change shall be acceptable to AHJCDF and LERF shall be used to determine

acceptability

Defense in DepthPlant change evaluation shall ensure

philosophy of defense-in-depth is maintained, relative to fire protection and nuclear safety

Defense in Depth for Fire ProtectionPrevent fires from startingRapidly detect, control, and extinguish fires

that do occurProvide 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 SafetyPrevent core damagePrevent containment failureMitigate consequences

Safety MarginsPlant change evaluation shall ensure

sufficient safety margins are maintained

Fire Protection Configuration Management Under NFPA 805The 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 805Monitoring 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 PRAFire 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 PRAFire PRAs in finalization and/or

development for all SNC operating unitsDuring development of Fire PRA, freeze

date for each plant state is appliedPotential impacts to Fire PRAs must be

documented for post-freeze dateScreening being added to Fire Protection

checklist