RNP-RA/13-0090, (Hbrsep), Unit 2, License Amendment Request (LAR) to Adopt NFPA 805 Performance-Based Stantard for Fire Protection for Light Water Reactor Generating Plant (2001 Edition)
| ML13267A211 | |
| Person / Time | |
|---|---|
| Site: | Robinson  (DPR-023) |
| Issue date: | 09/16/2013 |
| From: | William Gideon Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/13-0090 | |
| Download: ML13267A211 (2) | |
Text
DUKE Sensitive Information - Withhold from Public Disclosure Under 10 CFR 2.390 W.R. GiReon KNERGY Bo Robinson Steam W ~LI~fl~V Elecric Plant Unit 2
- ENERGY, ISite Vice President PROGRESS Duke Energy Progress 3581 West Entrance Road Hartsville. SC 29550 0: 843 857 1701 F: 843 857 1319 Randy.Gideonaduke-ener*am.e, Serial: RNg-RA/I3-0090 SEP 1 2013 10 CFR 50.90 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT (HBRSEP), UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 LICENSE AMENDMENT REQUEST (LAR) TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)
Ladies and Gentlemen:
Duke Energy Progress, Inc., formerly known as Carolina Power and Light Company, Inc., requests an amendment to the H. B. Robinson Steam Electric Plant (HBRSEP) Unit No. 2 Renewed Facility Operating License No. DPR-23. This LAR requests the Nuclear Regulatory Commission (NRC) review and approval for adoption of a new fire protection licensing basis that complies with the requirements in 10 CFR 50.48(a),
10 CFR 50.48(c), the guidance in Regulatory Guide (RG) 1.205, Revision 1, Risk-Informed Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, and National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001). The LAR also follows the applicable guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2.
The transition includes the following high-level activities: Complete Safe Shutdown Analysis Reconstitution, a new Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850 and EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities as guidance, a revision to the Internal Events PRA to support the Fire PRA and completion of activities required for transitioning the licensing basis to 10 CFR 50.48(c) as specified in NEI 04-02, Revision 2 and RG 1.205.
Enclosure I contains the HBRSEP Unit No. 2 Transition Report and its supporting attachments. The Transition Report provides the required technical and regulatory assessments to enable the NRC to complete the review and approval of the new licensing basis. Duke Energy Progress, Inc. considers Attachments C, D, G, S and W of the Transition Report to be sensitive information and requests they be withheld from public disclosure pursuant to 10 CFR 2.390.
The Fire PRA to support the Risk-Informed, Performance-Based (RI-PB) fire risk evaluations per Regulatory Positions 2.2 and 4.3 of RG 1.205 has been completed. The Fire PRA was developed in accordance with ASME/ANS RA-Sa-2009 and the guidance in NUREG/CR-6850/EPRI TR-1011989 and the NFPA FAQs.
The HBRSEP Unit No. 2 Internal Events PRA was peer reviewed in October 2009 and the Fire PRA was peer reviewed during the period of March 2013. The focused peer review was conducted during the period of July 2013; this is further discussed in Section 4.5 of Enclosure 1.
Attachments C, D, G, S and W of Enclosure 1 transmitted herewith contain sensitive information.
When separated from these enclosures, this transmittal document is non-controlled.
(p Sensitive Information - Withhold from Public Disclosure Under 10 CFR 2.390
Sensitive Information - Withhold from Public Disclosure Under 10 CFR 2.390 Serial RNP-RA/I3-0090 Page 2 of 2 A number of variances were identified during the development of the NFPA 805 Nuclear Safety Capability Assessment and dispositioned using performance-based methods. These methods include fire modeling and fire risk evaluation (NFPA 805, Section 4.2.4.2) processes. Variances were assessed against the quantitative risk acceptance criteria and maintenance of defense-in-depth, and safety margin criteria were ensured as required by Section 5.3.5 of NEI 04-02, Revision 2 and RG 1.205. The results are summarized in Attachment C of Enclosure 1.
Attachment S of Enclosure I contains a list of plant modifications and implementation items to support transitioning to the new fire protection licensing basis. Enclosure 2 contains the HBRSEP Unit No. 2 list of regulatory commitments related to the transition to NFPA 805. Enclosures 3 and 4 contain the marked-up and re-typed HBRSEP Unit No. 2 Technical Specification pages related to the transition to NFPA 805, respectively.
Duke Energy Progress, Inc. has notified the State of South Carolina in accordance with 10 CFR 50.91.
Duke Energy Progress, Inc. requests implementation of the amendment to occur within 180 days of approval.
This letter contains only those new regulatory commitments listed in Enclosure 2. If you have any questions concerning this matter, please contact Richard Hightower at (843) 857-1329.
I declare under penalty of perjury that the foregoing is true and correct. Executed on C1 Sinceey W. R. Gideon Site Vice President Enclosures (4)
- 1. Transition Report
- 2. HBRSEP Unit No. 2 List of Regulatory Commitments
- 3. Technical Specifications Pages (Mark-up)
- 4. Technical Specifications Pages (Re-typed)
WRG/jmw c:
Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management (SC)
Mr. V. M. McCree, NRC, Region II Mr. Siva P. Lingam, NRC Project Manager, NRR NRC Resident Inspectors, HBRSEP Unit No. 2 Mr. A. Wilson, Attorney General (SC)