ML13093A064

License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

ML13093A064
Person / Time
Site:	Ginna
Issue date:	03/28/2013
From:	Joseph Pacher Constellation Energy Nuclear Group, EDF Group, Ginna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13093A064 (5)

Text

This letter forwards Security-related Information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-Security Related Information upon the removal of Enclosure 3.

Joseph E. Pacher Site Vice President R.E. Ginna Nuclear Power Plant, LLC C ENG 1503 Lake Road Ontario, New York 14519-9364 a joint venture of 585.771.5200 Cocnstellation 4.# F J585.771.3943 Fax EneDgJoseph.Pacher@cengllc.com Energy March 28, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

RE. Ginna Nuclear Power Plant Docket No. 50-244 License Amendment Request Pursuant to 10 CFR 50.90:

Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

Pursuant to 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna) hereby requests an amendment to the Ginna Renewed Facility Operating License DPR-18. The proposed amendment is for adoption of a new risk-informed performance-based (RI-PB) fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and 10 CFR 50.48(c); the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,"

Revision 1, and National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. This amendment request also follows the guidance in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2.

This letter forwards Security-related Information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-Security Related Information upon the removal of Enclosure 3.

A, e~

Document Control Desk March 28, 2013 Page 2 Information associated with the transition of the Ginna fire protection licensing basis is contained in the Ginna Transition Report (Enclosures 2 and 3), including the technical and regulatory justifications to support the amendment request. Consistent with the industry template for NFPA 805 transition requests, major topics in the Transition Report are presented in Attachments A through W of Enclosures 2 and 3. Specifically, proposed changes to the Ginna operating license and Technical Specifications are provided in Attachments M and N, respectively. As documented in Attachment Q, Ginna has concluded that the activities associated with the proposed amendment represent no significant hazards consideration under the standards set forth in 10 CFR 50.92.

A Fire Probabilistic Risk Assessment (PRA) to support the RI-PB change evaluations per RG 1.205, Regulatory Positions C.2.2 and C.4.3, has been completed, as discussed in Section 4.5 of the Transition Report. In accordance with the guidance in Regulatory Position C.2.2.4.2, the total risk change associated with pre-transition fire protection program variances for meeting the NFPA 805 RI-PB approach (via the fire risk evaluation process) has been evaluated. Upon completion of the plant modifications referenced in Attachment S of the Transition Report, the total change in risk associated with the Ginna transition to NFPA 805 will meet the acceptance guidelines in RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis." Enclosure 3 contains security-related sensitive information and is requested to be withheld from public disclosure under 10 CFR 2.390 and in accordance with Regulatory Issue Summary 2005-26, "Control of Sensitive Unclassified Nonsafeguards Information Related to Nuclear Power Reactors."

A redacted version of the Transition Report with the security-related sensitive information removed is provided in Enclosure 2.

Ginna requests approval of the proposed license amendment in accordance with the normal NRC schedule for review of such amendments. Section 5.5 and Attachment S of the Transition Report discuss the implementation schedule proposed by Ginna for transitioning Ginna to the new fire protection licensing basis. Specifically, implementation of the new NFPA 805 fire protection program, including the items listed in Attachment S, Table S-3 (i.e., procedures changes, process updates, training of affected plant personnel), will occur within 180 days after NRC approval of the license amendment request. However, if that date falls within a scheduled refueling outage, then implementation will occur within 60 days after plant startup from that scheduled refueling outage. Implementation of the plant modifications associated with the transition to NFPA 805, identified in Attachment S, Table S-2, will be completed by no later than the first refueling outage more than 12 months after NRC approval of the license amendment request. These implementation items and plant modifications may change as a result of the NRC review process. The regulatory commitments associated with this request are listed in Enclosure 1. Pursuant to 10 CFR 50.91(b)(1), Ginna has

Document Control Desk March 28, 2013 Page 3 provided a copy of this license amendment request, with Enclosure 2, to the appropriate state representative.

If there are any questions regarding this submittal, please contact Thomas Harding at 585-771-5219 or Thomas.HardingJr@cengllc.com.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 26. day of l*laf-cl, 2013.

Sincerely, Joseph E. Pacher JAJ/kmc

Enclosures:

1. List of Regulatory Commitments

2. Constellation Energy Nuclear Group, R.E. Ginna Nuclear Power Plant, Transition Report (Redacted Version)

3. Constellation Energy Nuclear Group, R.E. Ginna Nuclear Power Plant, Transition Report cc: Regional Administrator, Region I, NRC (w/o Enclosure 2)

Project Manager, NRC Resident Inspector, NRC (w/o Enclosure 2)

A. L. Peterson, NYSERDA (w/o Enclosure 3)

ENCLOSURE 1 LIST OF REGULATORY COMMITMENTS

ENCLOSURE 1 LIST OF REGULATORY COMMITMENTS The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE Ginna will implement the plant modifications identified in the No later than the first Ginna Transition Report, Attachment S, Table S-2, "Plant refueling outage more Modifications Committed" than 12 months after NRC approval of the license amendment request.

Ginna will implement the fire protection licensing basis Within 180 days after including items listed in the Ginna Transition Report, NRC approval of the Attachment S, Table S-3, "Implementation Items" license amendment request. However, if that date falls within a scheduled refueling outage, then implementation will occur within 60 days after plant startup from that scheduled refueling I outage.

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