ML14115A298

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Supplement to License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805, Performance -Based Standard for Fire Protection for Light Water Reactor Generating Plants
ML14115A298
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/10/2014
From: Cortopassi L
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14115A296 List:
References
LIC-14-0042, TAC ME7244
Download: ML14115A298 (4)
v • d • e


Text

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

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ujjjju Omaha Public Power District 444 South 1ffh Street Mall Omaha, NE 68102-2247 LI C-14-0042 April 10, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Supplement to License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Sfation

References:

See Pages 3 and 4 The purpose of this letter is to supplement License Amendment Request (LAR) 10-07 proposing to adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)" at Fort Calhoun Station (FCS), Unit No.1. As noted in Reference 23, the Omaha Public Power District (OPPD) committed to revise Attachments M, N, and S, which were submitted with LAR 10-07 (Reference 1). As discussed during a March 10, 2014 conference call with NRC staff, OPPD is requesting a 12-month implementation period and Attachments M, N, S, and Section 5.4 of the NFPA 805 Transition Report have been revised accordingly. contains the revised page from the NFPA 805 Transition Report and Attachments M, N, and S, which supersede those provided by LAR 10-07 (Reference 1). Please note that Attachment N as provided with this letter does not include the sections marked Technical Specification Changes" or "Markup Pages" provided with LAR 10-07 as the NRC has already reviewed them. Attachment N as provided with this letter includes only the "Clean Pages." describes additional updates and clarifications to Attachment S, which were discussed with NRC Staff on March 12, 2014.

With the exception of the emergency operating procedures (EOP) and abnormal operating procedures (AOP), the procedures referenced in Attachment S, Table S-3 are transitioning to Exelon fleet procedures. The current plan is to revise those procedures prior to the transition.

However, there may be some that transition to the Exelon fleet procedure prior to incorporating Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

Employment with Equal Opportunity

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LI C-14-0042 Page 2 the NFPA 805 requirements. In that case, the changes listed in Table S-3 will be incorporated into the Exelon procedure that replaces the FCS procedure.

A brief history of prior correspondence related to LAR 10-07 is as follows:

The NRC reviewed OPPD's application (Reference 1) as supplemented by References 2 through 4 and determined that additional information was required in order to complete their review. References 5, 9,12, 14, 16,20, and 22 contain NRC requests for additional information regarding the NFPA 805 LAR. OPPD responded to the NRC RAls in References 6, 7, 8, 10, 11, 13,15,17,18,19,21, and 23.

In References 6 and 7, OPPD committed to supplement the NFPA 805 transition LAR (Le.,

Reference 1) to incorporate the applicable information delineated in those letters and any subsequent RAI responses.

In Reference 23, OPPD notified the NRC that supplementing Reference 1 in its entirety was unwarranted as the necessary information was contained in OPPD's RAI responses (Le., References 6,7,8,10,11, 13, 15, 17, 18, 19,21, and 23). On February 28, 2014 (Reference 24), OPPD docketed information previously placed on the Share Point Portal in response to Safe Shutdown Analyses (SSA) RAI 06. Several updates were made to Table B-3 at that time as well.

In accordance with 10 CFR 50.91, a copy of this letter, without Enclosure 1, Attachment S, is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Supervisor-Nuclear Licensing, at 402-533-6894.

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

Executed on April 10, 2014.

Louis P. Cortopassi Site Vice President and CNO LPC/BJV /mle Enclosures

1. Supplement to License Amendment Request 10-07
2. Clarifications and/or Corrections to License Amendment Request 10-07 c: Manager Radiation Control Program, Nebraska Health & Human Services, R & L Public Health Assurance, State of Nebraska (w/o Enclosure 1, Attachment S)

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LlC-14-0042 Page 3 Reference List

1. Letter from OPPD (J. A. Reinhart) to NRC (Document Control Desk), License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated September 28, 2011 (ML112760660) (LlC 0099)
2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Supplement to License Amendment Request (LAR) 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun
Station, dated December 19, 2011 (ML113540334) (LlC-11-0130)
3. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Clarification of Supplement to License Amendment Request (LAR) 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated December 22, 2011 (ML11363A077) (LlC-11-0136)
4. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Submittal of Fire Dynamic Input Files in Response to NRC NFPA 805 Transition License Amendment Request Audit Team Request at Fort Calhoun Station, dated March 20, 2012 (ML12083A147) (LlC-12-0033)
5. Letter from the NRC (L. E. Wilkins) to OPPD (David J. Bannister), Fort Calhoun Station, Unit No.1 - Request for Additional Information Re: License Amendment Request to Adopt National Fire Protection Agency Standard NFPA 805 (TAC No. ME7244), dated April 26, 2012 (ML121040048) (NRC-12-0041)
6. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, dated July 24, 2012 (ML12208A131) (LlC-12-0083)
7. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, dated August 24, 2012 (ML12240A151) (LlC-12-0120)
8. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, September 27, 2012 (ML12276A046) (LlC-12-0135)
9. Email from NRC (L. E. Wilkins) to OPPD (D. L. Lippy), DRAFT: Fort Calhoun NFPA 805, Second Round (ME7244), dated February 22,2013 (ML13053A226) (NRC-13-0014)
10. Letter from OPPD (M. J. Prospero) to NRC (Document Control Desk), Responses to Second Request for Additional Information Re: License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME 7244), dated April 23, 2013 (ML13116A015) (LlC-13-0033)

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LlC-14-0042 Page 4

11. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Remaining Responses to Second Request for Additional Information Re: License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME7244), dated May 21, 2013 (ML13144A814) (LlC-13-0060)
12. Email fromNRC(J.M.Sebrosky)toOPPD(D.L.LippY).FortCalhounNFPA805.Third Round of RAls (ME7244), dated June 27, 2013 (ML13178A035) (NRC-13-0081)
13. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Responses to Third Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME7244), dated July 29, 2013 (ML13211A055) (LlC-13-0096)
14. Email fromNRC(L.E.Wilkins)toOPPD(D.L.Lippy).FortCalhounNFPA805.Third Round, Second Part, of RAls (ME 7244), dated August 14, 2013 (ML13226A122) (NRC-13-0102)
15. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Safe Shutdown Analysis (SSA) RAI Response - NFPA-805 Transition (ME7244), dated September 12, 2013 (ML13256A110) (LlC-13-0129)
16. Email from NRC (L. E. Wilkins) to OPPD (M. L. Edwards), Fort Calhoun Fourth Round RAls for NFPA 805 LAR (ME7244), dated September 27, 2013 (ML13270A287) (NRC-13-0130)
17. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Probabilistic Risk Assessment (PRA) RAI Response -

NFPA-805 Transition (ME 7244), dated October 11, 2013 (ML13288A139) (LlC-13-0142)

18. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Probabilistic Risk Assessment (PRA) RAI Responses 19.01, 24, and 26 - NFPA-805 Transition (ME 7244), dated November 4,2013 (ML13309A634) (LlC-13-0158)
19. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Safe Shutdown Analysis (SSA) RAI 17.02 Response - NFPA-805 Transition (ME7244), dated November 11,2013 (ML133178618) (LlC-13-0167)
20. Email from NRC (L. E. Wilkins) to OPPD (8. R. Hansher), Fort Calhoun Station RAls Re:

NFPA-805 (ME7244), dated November 15, 2013 (ML13322A020) (NRC-13-0146)

21. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Probabilistic Risk Assessment (PRA) RAI Responses 01.j.04, 01.j.05, and 01.j.06 - NFPA-805 Transition (ME7244), dated December 18, 2013 (ML13353A569) (LlC-13-0179)
22. Email from NRC (L. E. Wilkins) to OPPD (8. R. Hansher), Fort Calhoun Station RAls Re:

NFPA-805 (ME7244), dated December 23,2013 (ML13358A100)

23. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Probabilistic Risk Assessment (PRA) RAI Responses 26.01 and 24.01 - NFPA-805 Transition (ME7244), dated January 24,2014 (ML14024A657) (LlC-14-0004)
24. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Supplemental Response to Safe Shutdown Analyses (SSA) Request for Additional Information (RAI) 06 -

NFPA-805 Transition (ME7244), dated February 28,2014 (ML14070A591) (LlC-14-0009)

Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390, Attachment S contains security-related information.

Upon removal of Enclosure 1, Attachment S, this letter is Decontrolled.

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