BSEP 14-0122, Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805

Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805

ML14337A724
Person / Time
Site:	Brunswick
Issue date:	11/20/2014
From:	William Gideon Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0122, TAC ME9623, TAC ME9624
Download: ML14337A724 (5)

Text

William R. Gideon Vice President Letter Enclosure 2 Contains Brunswick Nuclear Plant P.O. Box 10429 Security-Related Information - Southport, NC 28461 Withhold in Accordance with 10 CFR 2.390 o: 910.457.3698 November 20, 2014 Serial: BSEP 14-0122 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)

Reference:

1. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S.

Nuclear Regulatory Commission (Serial: BSEP 12-0106), License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants (2001 Edition), dated September 25, 2012, ADAMS Accession Number ML12285A428

2. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S.

Nuclear Regulatory Commission (Serial: BSEP 12-0140), Additional Information Supporting License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), dated December 17, 2012, ADAMS Accession Number ML12362A284

3. Letter from George T. Hamrick (Duke Energy) to U.S. Nuclear Regulatory Commission (Serial: BSEP 13-0083), Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624), dated July 31, 2013, ADAMS Accession Number ML13220B041

4. Letter from George T. Hamrick (Duke Energy) to U.S. Nuclear Regulatory Commission (Serial: BSEP 14-0023), Response to Second Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition),

dated February 28, 2014, ADAMS Accession Number ML14073A168 When Enclosure 2 is removed, this document is no longer Security-Related

U.S. Nuclear Regulatory Commission Page 2 of 3

5. Letter from George T. Hamrick (Duke Energy) to U.S. Nuclear Regulatory Commission (Serial: BSEP 14-0092), Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624),dated August 15, 2014, ADAMS Accession Number M14234A326 Ladies and Gentlemen:

By letter dated September 25, 2012 (i.e., Reference 1), as supplemented by letter dated December 17, 2012 (i.e., Reference 2), Duke Energy Progress Inc., submitted a license amendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fire protection licensing basis for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. As part of July 31,2013 (i.e., Reference 3), and February 28, 2014 (i.e., Reference 4), letters, Duke Energy responded to a request for additional information (RAI) regarding the use of fire watches for hot work activities.

The purpose of this letter is to provide new information regarding the use of a single fire watch for multiple hot work activities. The information in Enclosure 1 of this letter supplements the previous responses to Fire Protection Engineering (FPE) RAI 20. Enclosure 2 provides an updated copy of Attachment S to the LAR that shows the revised implementation action to complete a procedural change for use of a single fire watch for multiple hot work activities. This updated Attachment S supersedes, in its entirety, the Attachment S previously provided as part of Duke Energy's letter dated August 15, 2014 (i.e., Reference 5).

This document contains no new regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager- Regulatory Affairs, at (91 0) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 20, 2014.

William R. Gideon

Enclosures:

1. Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805

2. Updated Final License Amendment Request Attachment S, Modifications and Implementation Items (Security-Related information - Withhold from Public Disclosure)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with Enclosures 1 and 2):

U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 cc (with Enclosure 1 only):

Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

Enclosure 1 Page 1 of 2 Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 By letter dated September 25, 2012, as supplemented by letter dated December 17, 2012, Duke Energy Progress Inc., submitted a license amendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fire protection licensing basis for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. As part of letters dated July 31, 2013, and February 28, 2014, Duke Energy responded to a request for additional information (RAI) regarding the use of fire watches for hot work activities.

The purpose of this letter is to provide new information regarding the use of fire watches for hot work activities. This new information supplements the previous responses to Fire Protection Engineering (FPE) RAI 20.

In response to the portion of the RAI regarding the current practice of allowing for a single, roving fire watch to manage multiple hot work locations, an Attachment S, Table S-2 Implementation Item has been included to revise current fleet procedure AD-EG-ALL-1521, Hot Work Permits, to employ certain limitations and conditions on the use of a single fire watch for multiple hot work activities. These conditions and limitations are contained in NED-M/BMRK-0001, NFPA 51B Code Compliance Calculation, as the justified compliance statement regarding the functional equivalency of the single fire watch. This is supported by the original Attachment "A" Compliance Statement of "Complies," and "Complies via EEEE," for Section 3.3.1.3.1 of NFPA 805.

Functional equivalency for the application of a single (i.e., non-roving) fire watch for multiple hot work activities include the following justification for compliance wording from NED-M/BMRK-0001:

Current procedure, AD-EG-ALL-1521, says "Multiple hot work activities may be covered by a single Hot Work Fire watch provided the hot work is occurring in the same hot work area (approximate 35 foot radius) and are in line of sight of each other."

- That is to say the hot work areas (approximate radius of 35 feet around an activity) overlapping by a large percentage would require only one fire watch for multiple activities.

In addition, factors affecting the overall safety of the hot work still remain the same:

- "Stop work if an adverse condition exists." If any adverse conditions to the hot work area or products of a fire are observed by the fire watch all activities under that fire watch would stop until the situation was remedied.

- "Monitor the Hot Work activity and after Hot Work activity is complete, the Hot Work Firewatch shall remain in the area for 30 minutes after the Hot Work is complete to ensure no outbreak of fire." This means 30 minutes after the last activity is completed under that fire watch.

- "If there is a potential that the Hot Work Area cannot be contained to a single elevation, or the entire Hot Work Area cannot be directly observed by a single Hot Work Firewatch person, then additional Hot Work Firewatches should be established."

Enclosure 1 Page 2 of 2 The use of a single fire watch for multiple activities does not apply when additional fire watches are needed to see the entire hot work area or if there is a chance that slag or sparks cannot be contained to a single elevation.

- A hot work permit will be required for each activity and the 35 foot radius around each activity will be inspected per the requirements listed above. Under Section 1 of AD-EG-ALL-1521, Attachment 4.

This is considered functionally equivalent to the requirements of this code based on the expectation that a fire watch is to view an area of at least 35 ft around a hot work activity to verify that sparks or slag given off from the activity does not start a fire or are able to identify and/or quickly extinguish a fire if one were to occur. The addition of multiple hot work activities in close proximity creates only a minimal alteration to the area the fire watch is expected to cover and the addition of more fire watches to cover the same area has minimal to no impact on the overall safety of the hot work activities.

Accordingly, an Attachment S, Table S-2 Implementation Item has been included to revise current fleet procedure AD-EG-ALL-1521, Hot Work Permits, to employ these limitations and conditions on the use of a single fire watch for multiple hot work activities. Enclosure 2 provides an updated copy of Attachment S of the LAR that shows the revised implementation action to revise fleet procedure AD-EG-ALL-1521 for use of a single fire watch for multiple hot work activities (i.e., Item 10 on page S-10 of Attachment S). This updated Attachment S supersedes, in its entirety, the Attachment S previously provided as part of Duke Energy's letter dated August 15, 2014.