ML14132A199
| ML14132A199 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/09/2014 |
| From: | Costanzo C Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14132A193 | List: |
| References | |
| TAC ME8899 | |
| Download: ML14132A199 (11) | |
Text
This letter forwards Security-Related Information in accordance with 10 CFR 2.390.
The balance of this letter is considered non-Security Related upon removal of Attachment 2.
AChristopher Costanzo Exelon Generation,. Site Vice President - Nine Mile Point P.O. Box 63 Lycoming, NY 13093 315-349-5200 Office www.exeloncorp.com Christopher.costanzo@exeloncorp.com May 9, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 Docket No. 50-220
Subject:
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) - Response to NRC Information Request (TAC No. ME8899)
References:
(1) Letter from K. Langdon (NMPNS) to Document Control Desk (NRC), dated June 11, 2012, 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)
(2) Email from B. Vaidya (NRC) to E. Perkins (NMPNS), dated April 8, 2014, Nine Mile Point Unit 1, ME8899, Amendment Request Re: NFPA-805 Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted request for an amendment to Nine Mile Point Unit 1 (NMP1) Renewed Operating License DPR-63. The initial request, dated June 11, 2012 (Reference 1), proposed the 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.
The supplemental information, provided in Attachments 1 and 2 to this letter, responds to the information request documented in an email from B. Vaidya (NRC) to E. Perkins (NMPNS)
(Reference 2). On April 3 0th, 2014, NMPNS and the NRC staff held a conference call to discuss the requested information. NMPNS and the NRC staff agreed that the requested information would be submitted by May 9th, 2014. Attachments 1 and 2 to this letter contain final versions of Attachments M and S of the LAR incorporating all changes made since the LAR was initially submitted.
This letter forwards Security-Related Information In accordance with 10 CFR 2.390. '
The balance of this letter is considered non-Security Related upon removal of Attachment 2.
U. S. Nuclear Regulatory Commission May 9, 2014 Page 2 The supplemental information contained in this letter does not affect the No Significant Hazards Consideration Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(1), NMPNS is also providing a copy of this supplemental information to the appropriate state representative.
There are no regulatory commitments contained in this letter.
Should you have any questions regarding the information in this submittal, please contact Everett (Chip) Perkins, Director-Licensing, at (315) 349-5219.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May 9, 2014.
Sincerely, CRC/BTV Attachments: (1) Clean copy of Attachment M (2) Clean copy of Non-Redacted Attachment S cc: Regional Administrator, Region I, USNRC Project Manager, USNRC Resident Inspector, USNRC A. L. Peterson, NYSERDA (w/o Attachment 2)
I ATTACHMENT (1)
CLEAN COPY OF A'TACHMENT M
T T Constellation Energy Nuclear Group Attachment M - License Condition Changes M. License Condition Changes 7 Pages Attached Page M-1
I V Constellation Energy Nuclear Group Attachment M - License Condition Changes Replace the current NMP1 fire protection license condition 2.D(7) with the standard license condition from Regulatory Guide 1.205, Regulatory Position 3.1, modified as shown below.
It is NMPNS understanding that implicit in the superseding of this license condition, all prior fire protection program SERs and commitments have been superseded in their entirety by the revised license condition.
No other license conditions need to be revised or superseded.
NMP1 implemented the following process for determining that these are the only license conditions required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c). A review was conducted of the NMP1 Facility Operating License DPR-63. The review was performed by reading the Operating License and performing electronic searches.
Outstanding LARs that have been submitted to the NRC were also reviewed for potential impact on the license condition.
Supersede License Condition 2.D(7):
"2.D(7)Fire Protection Nine Mile PointNuclear Station, LLC shall implement and maintain in effect all provisions of the approved Fire ProtectionProgramas describedin the Final Safety Analysis Report (Updated)for the facility and as approved in the Fire Protection Safety Evaluation Report dated July 26, 1979, and in the fire protection Exemption issued March 21, 1983, subject to the following provision:
Nine Mile Point Nuclear Station, LLC may makes changes to the approved Fire ProtectionProgramwithout priorapprovalof the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."
Page M-2
Constellation Energy Nuclear Group Attachment M - License Condition Changes New License Condition:
Nine Mile Point Nuclear Station, LLC, shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee's amendment request dated
, supplemented by letters dated , and as approved in the safety evaluation report dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than I xl 0 7 /year (yr) for CDF and less than 1xl 04 /yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
Page M-3
Constellation Energy Nuclear Group Aftachment M - License Condition Changes The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is uadequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
" Fire Alarm and Detection Systems (Section 3.8);
" Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
" Gaseous Fire Suppression Systems (Section 3.10); and
" Passive Fire Protection Features (Section 3.11).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
(2) The licensee shall implement the modifications to its facility, as described in Table S-A, "Plant Modifications Committed," of NMPNS letter dated XX/XX/2014, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup from the first refueling outage following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
(3) The licensee shall implement the items listed in Table S-2, "Implementation Items,"
of NMPNS letter dated XX/XX/2014, 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then the due date will be 60 days following startup from the scheduled refueling outage.
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Constellation Energy Nuclear Group pAttachmnt ContelatonE....Nucea M - License onIIInn t'hnma Proposed Changes to Facility Operating License - Markup The current version of Facility Operating License page 5 has been marked up to reflect the proposed change.
Page M-5
Constellation Energy Nuclear Group Attachment M - License Condition Changes Constellation Energy Nuclear Group Attachment M License Condition Changes
- c. The licensee shall update the collective occupational dose estimate weekly. Ifthe updated estimate exceeds the 1908 person-rem estimate by more than 10%, the licensee shall provide a revised estimate, including the reasons for such changes, to the NRC within 15 days of determination.
- d. Progress reports shall be provided at 90-day intervals from June 30, 1982 and due 30 days after close of the interval, with a final report within 60 days after completion of the repair. These reports will conclude:
(1) a summary of this occupational dose received to date by major task, and (2) a comparison of estimated doses with the doses actually received.
(7) Fire Protection Nino Molo Poi*nt- NuloWlar Station. LLC= shail imolo~mont adMeiini I- 1- 1- - - I.T. ý -1. -q docrGibodi~~in "7 tho Final
~nv ; 4 Safetyn;_R-Analysis Roport (Updated) for the facility 1 Insert M-1 F > and ae, approved in the Fire Protoctin Safety Evaluation Report dated
" U' ,
us a ,' . ,. . I. .."l l I l -'--.*.;;;;.;;;;*;; ;;..;.,L;*;,.; ;*,';;.;;;.;;; * ;.
1083, subjoct to the follow in proI- ion:Mw Nine Mile Point Nuclear StaIon, ILLC may makes changoc to th approved Fire Protection ProgramA Without prior approval ofto Commiciononly if these rchangec would not advorcely affoct the ability to achieveA and-maintain Safe ohlutdwnAI in tlhe event of a fire.
(8) Hot Process Pipe Penetrations Hot Process Pipe Penetrations in the Emergency Condenser Steam Supply (2 each), Main Steam (2 each), Feedwater (2 each), Cleanup Suction (1 each), and Cleanup Return (1 each) piping systems have been identified as not fully in conformance with FSAR design criteria.
This anomaly in design condition from the original design is approved for the duration of Cycle 8 or until March 31, 1986, whichever occurs first, subject to the following conditions:
(a) An unidentified leakage limit of a change of 1 gallon per minute in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit operation will be imposed by administrative control (Standing Order) at the facility for the interim period.
Renewed License No. DPR-63 Amendment No.
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Constellation Energy Nuclear Group Attachment M - License Condition Changes Insert M-1:
Nine Mile Point Nuclear Station, LLC, shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee's amendment request dated
,_supplemented by letters dated , and as approved in the safety evaluation report dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than I x 107 /year (yr) for CDF and less than I x 104 /yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
Page M-7
"I Constellation Energy Nuclear Group Attachment M - License Condition Changes The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
" Fire Alarm and Detection Systems (Section 3.8);
" Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
" Gaseous Fire Suppression Systems (Section 3.10); and
" Passive Fire Protection Features (Section 3.11).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
(2) The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of NMPNS letter dated XX/XX/2014, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup from the first refueling outage following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
(3) The licensee shall implement the items listed in Table S-2, "Implementation Items,"
of NMPNS letter dated XX/XX/2014, 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then the due date will be 60 days following startup from the scheduled refueling outage.
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