BSEP 14-0134, Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)

Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)

ML15002A260
Person / Time
Site:	Brunswick
Issue date:	12/18/2014
From:	William Gideon Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0134, TAC ME9623, TAC ME9624
Download: ML15002A260 (8)

Text

William R. Gideon Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 December 18, 2014 Serial: BSEP 14-0134 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-BasedStandardfor Fire Protection for Light-Water Reactor Electric GeneratingPlants (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-BasedStandardfor Fire Protectionfor Light Water Reactor Electric GeneratingPlants (2001 Edition), dated December 17, 2012, ADAMS Accession Number ML12362A284

3. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission (Serial: BSEP 14-0122), Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire ProtectionAssociation Standard805 (NRC TAC Nos. ME9623 and ME9624),dated November 20, 2014, ADAMS Accession Number ML14337A725 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.

Attachment M of the original LAR submittal (i.e., Reference 1) provided the proposed replacement to the BSEP fire protection license condition 2.B.(6).

I.

U.S. Nuclear Regulatory Commission Page 2 of 3 The purpose of this letter is to update Attachment M of the LAR to ensure the proposed transition license condition 2.B.(6)(c)(3) appropriately reflects the modifications and implementation items that must be completed to support the transition to National Fire Protection Association (NFPA) Standard 805. These modifications and implementation items are listed in LAR Attachment S, Tables S-1 and S-2, respectively. The final update of LAR Attachment S, Tables S-1 and S-2, was provided by Duke Energy's letter dated November 20, 2014 (i.e., Reference 3). Enclosed is a copy of the updated operating license paragraph for the NFPA 805 fire protection program.

Duke Energy has reviewed the updated fire protection license condition 2.B.(6) and determined that the proposed update does not affect the no significant hazards consideration determination published in the FederalRegister (i.e., 78 FR 49300 dated August 13, 2013).

This document contains no new regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on December 18, 2014.

Sincerely, William R. Gideon

Enclosure:

Revised License Amendment Request Attachment M License Condition 2.B.(6)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc:

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 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 Revised License Amendment Request Attachment M License Condition 2.B.(6)

Duke Enerav Proaress. Inc. Attachment M - License Condition Chanqes Supersede the existing license condition 2.B.(6), in its entirety, as shown below:

(6) Fire Protection Duke Energy Progress, Inc. shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated September 25, 2012, as supplemented by letters dated December 17, 2012, June 28, 2013, July 15, 2013, July 31, 2013, August 29, 2013, September 30, 2013, February 28, 2014, March 14, 2014, April 10, 2014, June 26, 2014, August 15, 2014, August 29, 2014, November 20, 2014, and December 18, 2014, and as approved in the safety evaluation dated December (()), 2014. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at Brunswick. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

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Duke Enerav Proaress. Inc. Aftachment tahetM-Lces M - License Condition odto Chancies hne DukoEem Prqrss Inc

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than lx 0-7/year (yr) for CDF and less than lx 0-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval is not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

"Fire Alarm and Detection Systems" (Section 3.8);

"Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

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Duke Enerav Proaress. Inc. Attachment M - License Condition Chanqes "Gaseous Fire Suppression Systems" (Section 3.10); and "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval is not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated December ((_)), 2014, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c),

as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

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Duke Enerav Proaress. Inc. Attachment M - License Condition Chancles

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless completion falls within an outage window; then, in that case, completion of the implementation items will be 60 days after startup from the scheduled outage. The licensee shall complete implementation LAR Attachment S, Table S-2, Item 9 within 180 days after the startup of the second refueling outage for each unit after issuance of the Safety Evaluation.

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