HNP-10-064, Additional Items Related to License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants.

Additional Items Related to License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants.

ML101670181
Person / Time
Site:	Harris
Issue date:	06/09/2010
From:	Burton C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-10-064, TAC MD8807
Download: ML101670181 (9)

Text

Progress Energy Christopher L.Burton Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.

Serial: HNP-10-064 1JUK 002 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS" (TAC NO. MD8807)

Reference:

Letter from M. Vaaler, Nuclear Regulatory Commission, to C. L. Burton, "Shearon Harris Nuclear Power Plant, Unit 1 - Additional Items Related to the License Amendment Request to Adopt National Fire Protection Association Standard 805, 'Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants' (TAC NO. MD8807)", dated May 18, 2010 Ladies and Gentlemen:

Harris Nuclear Plant (HNP) has reviewed the revised fire protection license condition and list of items to be completed during the implementation of NFPA 805 at HNP as provided in Enclosures 1 and 2 of the above Reference. In accordance with the guidance in this Reference, Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (PEC) is providing assurance via this formal letter of its commitment to (1) implementing the fire protection license condition as stated and (2) completing the outstanding implementation items within the timeframe specified. to this submittal is the license condition to be included in the revised license for the Shearon Harris Nuclear Power Plant, Unit 1, replacing Renewed Operating License No. NPF-63 Condition 2.F. HNP is cognizant that New Transition License Condition 2.F(3)(b), which specifies that the listed modifications will be implemented by December 31, 2010, incorporates Regulatory Commitment # 3 as provided in Licensee Event Report (LER) 2002-004-09, dated October 28, 2005 (ML053070550). to this submittal contains the associated Regulatory Commitments.

Please refer any questions regarding this submittal to Mr. Dave Corlett, Supervisor -

Licensing/Regulatory Programs, at (919) 362-3137.

I declare under penalty of perjury that the foregoing is true and correct. Executed on JUN 0. 2010 P0. Box 165

+0%oa New Hill, NC 27562 T> 9A9.362.2502 F> 919.362.2095

Serial: HNP-10-064 Page 2 Sincerely, Christopher L. Burton CLB/kms

Enclosures:

1. Replacement License Condition 2.F

2. List of Regulatory Commitments Cc: Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Mr. W. L. Cox, III, NC DENR Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager, HNP

Enclosure 1 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LICENSE CONDITION The following license condition is included in the revised license for the Shearon Harris Nuclear Power Plant, Unit 1, and will replace Renewed Operating License No. NPF-63 Condition 2.F:

F. Fire Protection Program Carolina Power & Light Company 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 revised license amendment request dated October 9, 2009, supplemented by letters dated February 4, 2010, and April 5, 2010, and approved in the associated safety evaluation dated June XX, 2010. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c) and NFPA 805, 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.

(1) 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 the plant. Acceptable methods to assess the risk of the proposed change may include methods that have been used in the peer-reviewed Fire PRA model, methods that have been approved by the NRC via a plant-specific license amendment or through NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) 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.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x 1OE-7 per year (/yr) for CDF and less than 1 x 1OE-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.

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Enclosure 1 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LICENSE CONDITION (2) Other Criteria for Changes that May Be Made Without Prior NRC Approval (a) Changes to NFPA 805 Chapter 3, Fundamental Fire Protection Program 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);

• Gaseous Fire Suppression Systems (Section 3.10); and

• Passive Fire Protection Features (Section 3.11).

(b) 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 June XX, 2010, to determine that certain fire protection program changes meet the minimal risk criterion. The licensee shall in all cases ensure that fire Page 2 of 3

I, Enclosure Ito SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LICENSE CONDITION protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

r (c) Unless item (2)(b) above is met, risk-informed changes to the licensee's fire protection program which involve fire areas that credit incipient detection may not be made without prior NRC review and approval until the Harris Fire PRA model has been modified to incorporate an NRC-accepted method for modeling incipient detection.

(3) Transition License Conditions (a) Before achieving full compliance with 10 CFR 50.48(c), as specified by transition license condition (3)(b) 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 item (2)(b) above.

(b) The licensee shall implement the following modifications to its facility in order to complete the transition to full compliance with 10 CFR 50.48(c) by December 31, 2010 (note that each modification is listed by Engineering Change (EC) Number, as described in Attachment S of the Shearon Harris NFPA 805 License Amendment Request Transition Report, and outlined in Table 2.8.1-2 of the associated NRC safety evaluation):

• EC 62343

• EC 69501 0 EC 62820

• EC 69764 0 EC 68645

• EC 69765 0 EC 68646

• EC 70027 0 EC 68648

• EC 70350 0 EC 68658

• EC 70895 0 EC 68769

• EC 71147 (c) The licensee shall maintain appropriate compensatory measures in place until completion of the modifications delineated above.

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Enclosure 2 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LIST OF REGULATORY COMMITMENTS The actions in this document committed to by Progress Energy Carolinas, Inc. (PEC) regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" are identified in the following table. Statements in this submittal, with the exception of those in the table below, are provided for information purposes and are not considered commitments. Please direct any questions regarding this document or any associated regulatory commitments to the Supervisor, Licensing/Regulatory Affairs.

Item Commitment Completion Date 1 The licensee stated that license amendment request (LAR) Table B-2, "Nuclear Safety Capability Assessment," refers to the appropriate circuit coordination studies, and that, with the No later than 180 days after exception of backfeed, all other non-power operation (NPO) the issuance date of the NRC concerns are bounded by the safe shutdown analysis. Safety Evaluation The updating / completion of the coordination study for the backfeed configuration is an outstanding item.

2 Providing additional procedural guidance related to residual heat No later than 180 days after removal flow control recovery actions is an outstanding item. the issuance date of the NRC Safety Evaluation 3 Providing procedural changes to address the 20 generic pinch No later than 180 days after points identified during the NPO review is an outstanding item. the issuance date of the NRC Safety Evaluation 4 Providing procedural changes to address potential spurious valve No later than 180 days after operations identified during the NPO review is an outstanding the issuance date of the NRC item. Safety Evaluation 5 Completion of the NFPA 805 Monitoring Program at HNP is an No later than 180 days after outstanding item. the issuance date of the NRC Safety Evaluation Successful completion/implementation of the monitoring program includes:

0 defining availability, reliability, and performance parameters to be measured for each performance monitoring group

• identifying action levels for availability, reliability, and performance parameters 0 identifying corrective actions to be taken when action levels have been exceeded Page 1 of 4

Enclosure 2 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LIST OF REGULATORY COMMITMENTS Item Commitment Completion Date 6 Completion of the necessary changes to the HNP Fire Protection No later than 180 days after Program Manual is an outstanding item. the issuance date of the NRC Safety Evaluation 7 Revision of post-transition processes and procedures to include No later than 180 days after NFPA 805 requirements for verification and validation is an the issuance date of the NRC outstanding item. Safety Evaluation 8 Revision of post-transition processes and procedures to include No later than 180 days after NFPA 805 requirements for limitations of use is an outstanding the issuance date of the NRC item. Safety Evaluation 9 The licensee stated that a fire modeling qualification and training No later than 180 days after program would be developed to ensure that personnel performing the issuance date of the NRC future modeling activities will meet the requirements for Safety Evaluation qualification of use identified in NFPA 805, Section 2.7.3.4.

The establishment of this fire modeling qualification program and associated training is an outstanding item.

10 Revision of post-transition processes and procedures to include No later than 180 days after NFPA 805 requirements for uncertainty analyses is an the issuance date of the NRC outstanding item. Safety Evaluation 11 Expansion of the Fire Protection Quality Assurance (QA) Program No later than 180 days after to include systems in the power block that were not previously the issuance date of the NRC included in the scope of the QA Program, but which are required Safety Evaluation by NFPA 805 Chapter 4, is an outstanding item.

Specifically, the addition to the QA Program of certain fire protection and safe shutdown systems in the waste processing building, fuel handling building, and the turbine building that are required by NFPA 805 Chapter 4, as identified in LAR Tables 4-8-1 and 4-8-2.

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Enclosure 2 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 LIST OF REGULATORY COMMITMENTS Item Commitment Completion Date 12 The licensee stated that during the implementation of the NFPA No later than 180 days after 805 licensing basis, performance-based surveillance frequencies the issuance date of the NRC will be established as described in Electric Power Research Safety Evaluation Institute (EPRI) Technical Report (TR) 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features."

The performance-based surveillance frequencies will be evaluated in calculation HNP-M/BMRK-0015.

Establishment of the appropriate performance-based surveillance frequency process is an outstanding item.

13 Appropriate modification of plant procedures to meet the No later than 180 days after requirements of the NFPA 805 Chapter 3 element (3.3.10) the issuance date of the NRC regarding hot pipes and surfaces is an outstanding item. Safety Evaluation 14 The development and implementation of an outside yard pre-fire No later than 180 days after plan to address radioactive materials areas and Sea-Land type the issuance date of the NRC container storage is an outstanding item. Safety Evaluation 15 Completion of the revisions to calculation HNP-M/MECH-1127 No later than 180 days after and other affected fire safety analysis calculations to clearly state the issuance date of the NRC how the delta risks were determined is an outstanding item. Safety Evaluation 16 Completion of the revisions to calculation HNP-M/MECH-1 124 to No later than 180 days after incorporate the revised change evaluations documenting that the issuance date of the NRC conduit 14449T and cable 0153E are not within the zone of Safety Evaluation influence (ZOI) of a significant ignition source once the very early warning fire detection system (VEWFDS) is installed is an outstanding item.

17 Completion of the updates to the appropriate change evaluation in No later than 180 days after order to address the relationship of cables 0955C and 0970E to the issuance date of the NRC the ignition source ZOIs in Fire Area 1-A-BAL-B is an outstanding Safety Evaluation item.

18 Completion of the updates to the appropriate change evaluation in No later than 180 days after order to document that cable 2608C is not within the ZOI of a the issuance date of the NRC significant ignition source, as well as revising the compliance Safety Evaluation strategy and associated operator procedure, is an outstanding item.

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Enclosure 2 to SERIAL: HNP-10-064 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 ADDITIONAL ITEMS RELATED TO LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805' LIST OF REGULATORY COMMITMENTS item  ! Commitment Completion Date 19 Completion of the updates to the appropriate change evaluation in No later than 180 days after order to document that cable 0245B is not within the ZOI of a the issuance date of the NRC significant ignition source is an outstanding item. Safety Evaluation 20 Completion of the updates to the appropriate change evaluation No later than 180 days after for Fire Area 1-A-BAL-B in order to document that the new the issuance date of the NRC configuration (i.e., installation of fire rated Meggit TM cable and Safety Evaluation associated analyses, as well as the commitment to install an alternate seal injection system) provides adequate defense-in-depth and safety margin is an outstanding item.

21 Completion of the updates to the appropriate change evaluation in No later than 180 days after order to document that cable 0270C is not within the ZOI of a the issuance date of the NRC significant ignition source is an outstanding item. Safety Evaluation 22 Completion of the updates to the appropriate change evaluation in No later than 180 days after order to document that cable 0153E is not within the ZOI of a the issuance date of the NRC significant ignition source is an outstanding item. Safety Evaluation 23 Since EC 48007 is closed, removing credit for the ionization No later than 180 days after detection system in Fire Zone 5-F-2-FPV1 and Fire Zone 5-F the issuance date of the NRC FPV2 will be reflected in calculation HNP-M/MECH-1188. Safety Evaluation Completion of the revisions to this calculation is an outstanding item.

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