HNP-08-061, Request for License Amendment to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

Request for License Amendment to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

ML081560641
Person / Time
Site:	Harris
Issue date:	05/29/2008
From:	Duncan R Progress Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-061, NFPA 805
Download: ML081560641 (7)

Text

ENCLOSURE 3 TO THIS LETTER CONTAINS SENSITIVE INFORMATION SUBMITTED UNDER 10 CFR 2.390(d)(1).

Progress EnergyVice Robert J. Duncan, 11 President Harris Nuclear Plant Progress Energy Carolinas, Inc.

Serial: HNP-08-061 MAY 2 9 2008 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20555-0001 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, "Application of License or Construction Permit," Carolina Power & Light Company (CP&L) doing business as Progress Energy Carolinas Inc. (PEC), requests an amendment to Facility Operating License No. NPF-63 for Shearon Harris Nuclear Power Plant, Unit No. 1 (HNP). Implementation of the regulatory actions presented in the attachments to this License Amendment Request (LAR) will enable HNP to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 0 of Regulatory Guide (RG) 1.205.

As documented in this request, HNP has met all of the NRC's regulatory requirements for the transition of its fire protection licensing basis. In addition, the license amendment does not present a significant hazards consideration and the criteria have been met for a categorical exclusion from the need for an environmental assessment.

Information associated with HNP's transition is provided in the enclosed HNP Transition Report, including the technical and regulatory justifications required to support this LAR. contains the Regulatory Commitments associated with this submittal. contains a listing of the Transition Report sections for which HNP requests specific NRC approval. to this letter provides HNP's Transition Report. Major topics in this Transition Report are presented as Attachments A through V, summarized as follows:

" Attachment A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3) - Security Related Information

" Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment -

Methodology Review

• Attachment C - NEI 04-02 Table B Fire Area Transition - Security Related Information P.O.Box 165 oc New Hill, NC 27562 T> 919.362.2502 F> 919.362.2095

ENCLOSURE 3 TO THIS LETTER CONTAINS SENSITIVE INFORMATION SUBMITTED UNDER 10 CFR 2.390(d)(1).

Serial: HNP-08-061 Page 2

" Attachment D - NEI 04-02 Table F-1 Non-Power Operational Modes Transition- Security Related Information

" Attachment E - NEI 04-02 Table G Radioactive Release Transition

• Attachment F - Fire-Induced Multiple Spurious Operations - Resolution Methodology

" Attachment G - Operator Manual Actions - Transition to Recovery Actions

" Attachment H - NEI 04-02 Frequently Asked Question - Summary Table

" Attachment I - Definition of Power Block

" Attachment J - Existing Engineering Equivalency Evaluation Transition- Security Related Information

• Attachment K - Existing Licensing Action Transition- Security Related Information

• Attachment L - NFPA 805 Chapter 3 Requirements for Approval

" Attachment M - License Condition Changes

" Attachment N - Technical Specification Changes

" Attachment 0 - Orders and Exemptions

" Attachment P - Performance-Based Methods - NFPA 805 Chapter 3 - 10 CFR 50.48.(c)(2)(vii)

" Attachment Q - Risk-Informed, Performance-Based Alternatives to NFPA 805 -- 10 CFR 50.48(c)(4)

" Attachment R - FSAR Changes

• Attachment S - Plant Modifications

" Attachment T - Clarification of Prior NRC Approvals

" Attachment U - No Significant Hazards Consideration

• Attachment V - Environmental Consideration In accordance with the guidance in Regulatory Position C.2.2 of Regulatory Guide 1.205, Revision 0, the total risk change associated with pre-transition fire protection program variances meeting the NFPA 805 performance-based approach (via the change evaluation process) were evaluated.

Upon completion of the plant modifications, as referenced in the Transition Report section 4.8.3, the total change in risk associated with HNP's transition to NFPA 805 will be consistent with the acceptance guidelines in Regulatory Guide 1.174.

ENCLOSURE 3 TO THIS LETTER CONTAINS SENSITIVE INFORMATION SUBMITTED UNDER 10 CFR 2.390(d)(1).

Serial: HNP-08-061 Page 3 The Transition Report provided in section 5.4 contains HNP's proposed implementation schedule for transitioning HNP to the new fire protection licensing basis. Based on this, HNP requests approval of this license amendment in accordance with the NRC's current schedule, with implementation to occur within 180 days of approval.

In accordance with 10 CFR 50.91(b), HNP is providing the state of North Carolina with a copy of the proposed license amendment.

Please refer any questions regarding this submittal to Mr. Dave Corlett at (919) 362-3137.

I declare, under penalty of perjury, that the attached information is true and correct (Executed on WAY 2 9 2008 ).

Si ely, R.J.D an, I Vice President Harris Nuclear Plant RJD/kI

Enclosures:

1. HNP Regulatory Commitments

2. Specific Approval Requested in SER

3. HNP Transition Report, containing Attachments A through V Cc (via CD-ROM):

Ms. B. 0. Hall, N. C. DENR Section Chief Mr. P. B. O'Bryan, NRC Sr. Resident Inspector Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager

Enclosure 1 to SERIAL: HNP-08-061 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

REGULATORY COMMITMENTS Commitment(s) Scheduled Completion Date

1. HNP will complete modifications necessary to The end of Refueling Outage 16 currently support the new licensing basis. scheduled for November 5, 2010 Page Al-1 of I

Enclosure 2 to SERIAL: HNP-08-061 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

SECTIONS REQUESTED FOR SPECIFIC APPROVAL IN LAR In accordance with 10 CFR 50.48(c)(3)(i), Harris Nuclear Plant (HNP), is submitting this License Amendment Request (LAR) to allow HNP to maintain a fire protection program that complies with NFPA 805 as an alternative to the current HNP fire protection license condition. The information provided in the Transition Report contains the information required for submittal, as well as information to facilitate the Nuclear Regulatory Commission (NRC) review and approval of the license amendment.

As stated in Regulatory Position C.2.2 of Regulatory Guide 1.205, HNP requests that certain portions of the Transition Report be reviewed for explicit approval in the HNP 10 CFR 50.48(c) License Amendment/associated Safety Evaluation Report. HNP believes this review and approval will help provide clarity to the new fire protection licensing basis and facilitate future program maintenance and NRC inspection activity.

The following table provides a listing of Transition Report Sections, the Topic, applicable NEI and NRC requirements and guidance, and whether specific approval by the NRC is requested in the License Amendment/associated Safety Evaluation Report.

Specific LAR/TR Topic Requirement/Guidance Approval Reference Requested in SER Section 4.1.2.1 B-i Table RG 1.205 (C.2.4), NEI04-02(2.3, 4.3.1, B.1), Yes Attachment A FAQ 07-0036 Nuclear Safety Capability Section 4.2.1.2 Assessment - Methodology (B- NEI 04-02 (4.3.2, B.2), FAQ 07-0039 Yes 2 Table)

Section 4.2.2.3, Nuclear Safety Capability Assessment - Fire Area - by - NEI 04-02 (4.3.2, B.2), FAQ 07-0039 Yes (1)

Fire Area Review Nuclear Safety Capability Attachment C Assessment - Fire Area - by - NEI 04-02 (4.3.2, B.2), FAQ 07-0039 No Fire Area Review (B-3 Table)

Section 4.3 'Non Power Operations (F-1 NE 04-02 (4.3.3, F), FAQ 07-0040 Yes Attachment D Table)

Section 4.4 Radioactive Release (G-1 Table) NEI 04-02 (4.3.4, G) Yes Attachment E Section 4.5 Change Evaluations NFPA 805, RG 1.205 (C.3.2), NEI 04-02 Yes (2)

(5.3, App I)

Section 4.8.2.1 Fire-Induced Multiple Spurious RG 1.205 (C.3.3), NEI 04-02 (B.2), FAQ 07-Attachment F Operations mtolgy0038resolution Yes methodology Section 4.8.2.2 Operator Manual Actions - RG 1.205 (C.2.2), NEI 04-02 (B.2), FAQ 06- Yes Attachment G Transition to Recovery Actions 0012, FAQ 07-0030 Ye Page A2-1 of 3

Enclosure 2 to SERIAL: HNP-08-061 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

SECTIONS REQUESTED FOR SPECIFIC APPROVAL IN LAR Specific LAR/TR Topic Requirement/Guidance Approval Reference Requested in SER Section 3.4 FAQ Summary Table. (info 10 CFR 50.71(e), NEI 04-02 (4.6.1) No Attachment H only)

Section Atthn4.1.3 4 Definition of Power Block NFPA 805, FAQ 06-0019 Yes Attachment I Section Existing Engineering 4.2.2.2.1 Equivalency Evaluations RG 1.205 (C.2.3), FAQ 07-0033 Yes Attachment J SectionyEvlutin Section NEI 04-02 (4.3.2, B.2), RG 1.205 (C.2.4),

4.2.2.2.2 Licensin Action Transition 07-0039 Attachment K NFPA 805 Chapter 3 Section 4.1.2.2 NEI 04-02 (2.3, 4.3.1), RG 1.205 (C.2.4),

Requirements to be included in FAQ 07-0036 Yes Attachment L the LAR Section 5.2.1 License Condition Changes 10 CFR 50.48(c)(3)(i), 10 CFR 50.90, RG Yes Attachment M i 1.205 (C.3.1), NEI 04-02 (4.6.1)

Section 5.2.2 10 CFR 50.48(c)(3)(i), 10 CFR 50.90, RG Attachment N Technical Specification Changes 1.205 (C.2.2), NEI 04-02 (4.6.1) Yes Section 5.2.3 10 CFR 50.48(c)(3)(i), 10 CFR 50.90, RG 1.205 (C.2.2), NEI 04-02 (4.6.1)

Attachment P Performance Based Methods 10 CFR 50.48(c)(2)(vii), RG 1.205 (C.2.2, Yes C.3.2.3), NEI 04-02 (2.3, 2.4), FAQ 06-0008 Attachment Q Risk-Informed, Performance 10 CFR 50.48(c)(4), RG 1.205 (C.2.2, Yes Based Alternatives to NFPA 805 C.3.2.3), NEI 04-02 (2.3, 4.6.1)

Attachment R FSAR Changes (Governed by 10 RG 1.205 (C.2.2), NEI 04-02 (4.6.1) Yes (3)

CFR 50.71(e))

Section Atthn4.8.3 4 Plant Modifications RG 1.205 (C.2.2), NEI 04-02 (4.6.1)

Attachment S No Attachment T Clarification of Prior NRC NEI 04-02 (2.3, B.2), RG 1.205 (C.2.2) Yes Approval Section 5.3.1 No Significant Hazards 10 CFR 50.91, NEI 04-02 (4.6.1, H) Yes Attachment U Consideration Section 5.3.2 Environmental Consideration 10 CFR 51.22(b), NEI 04-02 (H) Yes Attachment V Fire PRA Peer Review High Section 4.5.1 RG 1.205 (C.4.3) Yes Level Findings Section 5.4 Transition Schedule RG 1.205 (C.2.2), NEI 04-02 (4.6.1) Yes Page A2-2 of 3

Enclosure 2 to SERIAL: HNP-08-061 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

SECTIONS REQUESTED FOR SPECIFIC APPROVAL IN LAR Note 1: Request NRC acceptance of the NSCA results based on the Methodology described in Attachment 2. Acceptance does not preclude self approval of future Fire Protection changes per the FP license condition that is provided in this LAR.

Note 2: Request NRC acceptance of the Change Evaluation results. Acceptance does not preclude self approval of future Fire Protection changes per the FP license condition that is provided in this LAR.

Note 3: Request NRC to approve in concept the level of detail proposed for the FSAR.

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