ML21021A246

Slides - SNC Slides - Pre-Submittal Meeting on January 26, 2021 - Hatch NFPA-805 LAR

ML21021A246
Person / Time
Site:	Hatch
Issue date:	01/21/2021
From:	Southern Nuclear Operating Co
To:	John Lamb NRC/NRR/DORL/LPL2-1
Lamb J
Shared Package
ML21021A235	List: ML21021A246
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Download: ML21021A246 (14)

Text

Hatch Pre-Submittal Meeting NFPA-805 Supplemental LAR January 2021

Meeting Purpose and Agenda

• Meeting purpose: Discuss proposed license amendment request (LAR) to supplement modifications described in Table S-2, Plant Modifications Committed, of SNC letter NL-19-1475, dated December 13, 2019

• LAR will update Transition License Conditions for both units to refer to updated Table S-2

• Updated Table S-2 will be submitted as part of LAR Agenda

• Issue Background

• Proposed LAR Content 2

Issue Background Issue Background

• June 2020, NRC issued Amendments 304 and 249 to Hatch Units 1 and 2 Renewed Facility Operating License (RFOL) to adopt NFPA-805 performance-based standards

• Amendments contain Transition License Conditions that require SNC to implement modifications described in Table S-2 of December 13, 2019 SNC letter by the startup of the second refueling outage (for each unit) after issuance of NRC Safety Evaluation (SE)

• Unit 2 = by startup of spring 2023 refueling outage 2R27

• Unit 1 = by startup of spring 2024 refueling outage 1R31

• Modifications will complete full compliance with 10 CFR 50.48(c)

• Appropriate compensatory measures required until full compliance achieved 4

Issue Background (continued)

• For equipment not affected by fire, NFPA-805 requires that a fire-induced cable failure on a separate load circuit supplied from the same power source would not affect this equipment

• Subsequent to issuance of Hatch NFPA-805 RFOL Amendments, additional breakers were discovered that lacked proper coordination

• SNC currently finalizing extent of condition to ensure all breaker coordination issues are identified 5

Proposed License Amendment Request

Proposed License Amendment Request LAR will generally follow format prescribed in NEI 06-02:

1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Current Licensing Basis Requirements 2.2 Reason for the Proposed Change 2.3 Description of the Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.2 No Significant Hazards Consideration Determination Analysis 4.3 Conclusions

6.0 REFERENCES

ATTACHMENTS:

M. License Condition Changes S. Modification Items 7

1.0 Summary Description 2.0 Detailed Description 1.0 Summary Description

• Proposed change will revise Hatch Units 1 and 2 RFOL to reference updated Table S-2 for list of required modifications that must be implemented to achieve full compliance with NFPA-805

• Revised RFOL will specify the modifications are required by the startup of the Unit 2 spring 2023 refueling outage, U2R27, and by the startup of the Unit 1 spring 2024 refueling outage, U1R31 2.0 Detailed Description

1. Current Licensing Basis Requirements

• Discuss current RFOL requirements

2. Reason for Proposed Change

• Discuss that current Table S-2 referenced in RFOLs does not contain all required modifications to achieve compliance

3. Description of Proposed Change

• Describe proposed marked-up changes to RFOLs 8

3.0 Technical Evaluation

• Discuss NRC SE conclusions that the SNC approach, methods, and data are acceptable to establish, implement, and maintain the proposed risk-informed performance based (RI/PB) fire protection plan (FPP) in accordance with 10 CFR 50.48(c), subject to the completion of the modifications identified in Table S-2 and the implementation items identified in Table S-3

• 2001 Edition of NFPA-805 provides a comprehensive RI/PB standard for fire protection, and specifies minimum requirements for light-water reactors during all phases of plant operation

• As discussed in Section C.2.1 of RG 1.205, Revision 1, when the NRC issues an NFPA-805 license amendment it will impose a license condition requiring the use of NFPA-805 along with an implementation schedule

• Items identified in Table S-2 and S-3 were credited in LAR supporting analysis, and were relied upon by NRC staff in its review 9

3.0 Technical Evaluation (continued)

• Discuss NFPA-805 requirements for proper breaker coordination, and assumptions used in Fire PRA model

• Discuss that updated Table S-2 will not affect Fire PRA model

• Discuss that the amendment request will not impact the NFPA-805 modification schedule contained in the current RFOL to achieve full compliance with 10 CFR 50.48(c) 10

4.0 Regulatory Evaluation 5.0 Environmental Considerations 6.0 References

• Will use portions of original Hatch NFPA-805 LAR as appropriate to address these sections 11

Attachment M License Condition Changes The licensee shall implement the modifications described in Attachment S2, Table S-2, Plant Modifications Committed, of SNC letter NL-19-1475 NL-21-XXXX, dated December 13, 2019 Month, Day, 2021, to its facility to complete transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage (for each unit) after the issuance of the NRC SE Unit 2 refueling outage 2R27 (spring 2023) and Unit 1 refueling outage 1R31 (spring 2024). The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

12

Attachment S Modification Items Will be consistent with Table S-2 referenced in current RFOLs, with the inclusion of the additional required breaker coordination modifications 13

Questions?