ML13301A673
| ML13301A673 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/24/2013 |
| From: | George Gellrich Calvert Cliffs, Constellation Energy Nuclear Group, EDF Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13301A672 | List: |
| References | |
| Download: ML13301A673 (3) | |
Text
SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 George H. Gellrich Vice President Calvert Cliffs Nuclear Power Plant, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax CENG.
a joint venture of O n-W
-eDF CALVERT CLIFFS NUCLEAR POWER PLANT September 24, 2013 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request re: Transition to 10 Performance Based Standard for Fire Protection CFR 50.48(c) - NFPA 805
REFERENCES:
(a)
Regulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, December 2009 (b)
National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition (c)
Nuclear Energy Institute 04-0 ", "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2, April 2008 (d)
Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 1, November 2002 The Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) hereby requests an Amendment to Renewed Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. 1 and 2, respectively, with the submittal of these proposed changes to the Technical Specifications. The proposed amendment is for adoption of a new risk-informed performance-based 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 1.205 (Reference a), and National Fire Protection Association (NFPA) 805 (Reference b). This amendment request also follows the guidance in Nuclear Energy Institute 04-02 (Reference c).
Upon removal of Attachments C, S and W of Enclosure 1, this submittal is not restricted
Document Control Desk September 24, 2013 Page 2 Information associated with the transition of the CCNPP fire protection licensing basis is contained in the CCNPP Transition Report (Enclosure 1), 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 the Transition Report.
Specifically, proposed changes to the CCNPP operating license and Technical Specifications are provided in Transition Report attachments M and N, respectively.
As documented in Transition Report Attachment Q, CCNPP 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 to support the risk-informed performance-based change evaluations per Regulatory Guide 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 approach (via the fire risk evaluation process) has been evaluated. Upon completion of the plant modifications referenced in Transition Report Attachment S, the total change in risk associated with the CCNPP transition to NFPA 805 will meet the acceptance guidelines in Regulatory Guide 1.174 (Reference d).
Three Attachments (Attachments C, S, and W) to Enclosure 1 contain security-related information and are requested to be withheld from public disclosure under 10 CFR 2.390.
Calvert Cliffs requests approval of the proposed license amendment in accordance with the normal Nuclear Regulatory Commission (NRC) schedule for review of such amendments.
Section 5.5 and Attachment S of the Transition Report discuss the implementation schedule proposed by CCNPP for transitioning to the new fire protection licensing basis.
Specifically, implementation of the new NFPA 805 fire protection program, including the items listed in Transition Report 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 implementation 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 Transition Report Attachment S, Table S-2, will be completed by April 30, 2018. These implementation items and plant modifications may change as a result of the NRC review process.
There are no regulatory commitments associated with this request. Implementation actions have been requested to become license conditions in Appendix C, Additional Conditions, of each CCNPP Renewed Operating License.
Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at (410) 495-5219.
Document Control Desk September 24, 2013 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on September 24, 2013.
Very truly yours, GHG/PSFubjd
Enclosure:
(1) Calvert Cliffs Nuclear Power Plant Transition Report cc:
NRC Project Manager, Calvert Cliffs NRC Regional Administrator, Calvert Cliffs NRC Resident Inspector, Calvert Cliffs S. Gray, MD-DNR