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{{Adams
#REDIRECT [[BSEP 14-0134, Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)]]
| number = ML15002A260
| issue date = 12/18/2014
| title = Brunswick, Units 1 and 2, Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)
| author name = Gideon W R
| author affiliation = Duke Energy Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person =
| case reference number = BSEP 14-0134, TAC ME9623, TAC ME9624
| document type = Letter
| page count = 8
| project = TAC:ME9623, TAC:ME9624
| stage = Other
}}
 
=Text=
{{#Wiki_filter:William R. GideonVice President ENERGY, Brunswick Nuclear PlantP.O. Box 10429Southport, NC 28461o: 910.457.3698 December 18, 2014Serial: BSEP 14-0134U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001
 
==Subject:==
 
Brunswick Steam Electric Plant, Unit Nos. 1 and 2Renewed Facility Operating License Nos. DPR-71 and DPR-62Docket Nos. 50-325 and 50-324Additional Information Regarding License Amendment Request to AdoptVoluntary Risk Initiative National Fire Protection Association Standard 805 (NRCTAC Nos. ME9623 and ME9624)
 
==Reference:==
: 1. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S.Nuclear Regulatory Commission (Serial:
BSEP 12-0106),
LicenseAmendment Request to Adopt NFPA 805 Performance-Based Standard forFire Protection for Light-Water Reactor Electric Generating Plants(2001 Edition),
dated September 25, 2012, ADAMS Accession Number ML12285A428
: 2. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S.Nuclear Regulatory Commission (Serial:
BSEP 12-0140),
Additional Information Supporting License Amendment Request to Adopt NFPA 805Performance-Based Standard for Fire Protection for Light Water ReactorElectric Generating Plants (2001 Edition),
dated December 17, 2012, ADAMSAccession Number ML12362A284
: 3. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission (Serial:
BSEP 14-0122),
Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National FireProtection Association Standard 805 (NRC TAC Nos. ME9623 andME9624),dated November 20, 2014, ADAMS Accession NumberML14337A725 Ladies and Gentlemen:
By letter dated September 25, 2012 (i.e., Reference 1), as supplemented by letter datedDecember 17, 2012 (i.e., Reference 2), Duke Energy Progress Inc., submitted a licenseamendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fireprotection licensing basis for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.Attachment M of the original LAR submittal (i.e., Reference
: 1) provided the proposedreplacement to the BSEP fire protection license condition 2.B.(6).
I.U.S. Nuclear Regulatory Commission Page 2 of 3The purpose of this letter is to update Attachment M of the LAR to ensure the proposedtransition license condition 2.B.(6)(c)(3) appropriately reflects the modifications andimplementation items that must be completed to support the transition to National FireProtection Association (NFPA) Standard 805. These modifications and implementation itemsare listed in LAR Attachment S, Tables S-1 and S-2, respectively.
The final update of LARAttachment S, Tables S-1 and S-2, was provided by Duke Energy's letter dated November 20,2014 (i.e., Reference 3). Enclosed is a copy of the updated operating license paragraph for theNFPA 805 fire protection program.Duke Energy has reviewed the updated fire protection license condition 2.B.(6) and determined that the proposed update does not affect the no significant hazards consideration determination published in the Federal Register (i.e., 78 FR 49300 dated August 13, 2013).This document contains no new regulatory commitments.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager -Regulatory
: Affairs, at (910) 457-2487.
I declare, under penalty of perjury, that the foregoing is true and correct.
Executed onDecember 18, 2014.Sincerely, William R. Gideon
 
==Enclosure:==
 
Revised License Amendment Request Attachment M License Condition 2.B.(6)
U.S. Nuclear Regulatory Commission Page 3 of 3cc:U.S. Nuclear Regulatory Commission, Region IIATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River RoadSouthport, NC 28461-8869 Chair -North Carolina Utilities Commission P.O. Box 29510Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)Radiation Protection SectionNorth Carolina Department of Health and Human Services1645 Mail Service CenterRaleigh, NC 27699-1645 lee.cox@dhhs.nc.gov Enclosure Revised License Amendment RequestAttachment M License Condition 2.B.(6)
Duke Enerav Proaress.
Inc.Attachment M -License Condition ChanqesSupersede the existing license condition 2.B.(6),
in its entirety, as shown below:(6) Fire Protection Duke Energy Progress, Inc. shall implement and maintain in effectall provisions of the approved fire protection program that complywith 10 CFR 50.48(a) and 10 CFR 50.48(c),
as specified in thelicense amendment request dated September 25, 2012, assupplemented by letters dated December 17, 2012, June 28,2013, July 15, 2013, July 31, 2013, August 29, 2013,September 30, 2013, February 28, 2014, March 14, 2014,April 10, 2014, June 26, 2014, August 15, 2014, August 29, 2014,November 20, 2014, and December 18, 2014, and as approved inthe safety evaluation dated December
[[]], 2014. Except whereNRC approval for changes or deviations is required by 10 CFR50.48(c),
and provided no other regulation, technical specification, license condition or requirement would require prior NRCapproval, the licensee may make changes to the fire protection program without prior approval of the Commission if thosechanges satisfy the provisions set forth in 10 CFR 50.48(a) and10 CFR 50.48(c),
the change does not require a change to atechnical specification or a license condition, and the criteria listedbelow are satisfied.
(a) Risk-Informed Changes that May Be Made Without PriorNRC ApprovalA risk assessment of the change must demonstrate thatthe acceptance criteria below are met. The riskassessment
: approach, methods, and data shall beacceptable to the NRC and shall be appropriate for thenature and scope of the change being evaluated; be basedon the as-built, as-operated, and maintained plant; andreflect the operating experience at Brunswick.
Acceptable methods to assess the risk of the change may includemethods that have been used in the peer-reviewed firePRA model, methods that have been approved by NRCthrough a plant-specific license amendment or NRCapproval of generic methods specifically for use inNFPA 805 risk assessments, or methods that have beendemonstrated to bound the risk impact.1. Prior NRC review and approval is not required forchanges that clearly result in a decrease in risk. Theproposed change must also be consistent with thedefense-in-depth philosophy and must maintainsufficient safety margins.
The change may beimplemented following completion of the plant changeevaluation.
Page 1 Duke Enerav Proaress.
Inc.Aftachment M -License Condition ChanciesDukoEem Prqrss Inc tahetM-Lces odto hne2. Prior NRC review and approval is not required forindividual changes that result in a risk increase lessthan lx 0-7/year (yr) for CDF and less than lx 0-8/yr forLERF. The proposed change must also be consistent with the defense-in-depth philosophy and mustmaintain sufficient safety margins.
The change may beimplemented following completion of the plant changeevaluation.
(b) Other Changes that May Be Made Without Prior NRCApproval1. Changes to NFPA 805, Chapter 3, Fundamental FireProtection Program and Design ElementsPrior NRC review and approval is not required forchanges to the NFPA 805, Chapter 3, fundamental fireprotection program elements and design requirements for which an engineering evaluation demonstrates thatthe alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licenseemay use an engineering evaluation to demonstrate thata change to an NFPA 805, Chapter 3, element isfunctionally equivalent to the corresponding technical requirement.
A qualified fire protection engineer shallperform the engineering evaluation and conclude thatthe change has not affected the functionality of thecomponent, system, procedure, or physicalarrangement, using a relevant technical requirement orstandard.
The licensee may use an engineering evaluation todemonstrate that changes to certain NFPA 805,Chapter 3, elements are acceptable because thealternative is "adequate for the hazard."
Prior NRCreview and approval would not be required foralternatives to four specific sections of NFPA 805,Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3element is adequate for the hazard. A qualified fireprotection engineer shall perform the engineering evaluation and conclude that the change has notaffected the functionality of the component, system,procedure, or physical arrangement, using a relevanttechnical requirement or standard.
The four specificsections of NFPA 805, Chapter 3, are as follows:"Fire Alarm and Detection Systems"(Section 3.8);"Automatic and Manual Water-Based FireSuppression Systems" (Section 3.9);Page 2 Duke Enerav Proaress.
Inc.Attachment M -License Condition Chanqes"Gaseous Fire Suppression Systems"(Section 3.10); and"Passive Fire Protection Features" (Section 3.11).This License Condition does not apply to anydemonstration of equivalency under Section 1.7 ofNFPA 805.2. Fire Protection Program Changes that Have No Morethan Minimal Risk ImpactPrior NRC review and approval is not required forchanges to the licensee's fire protection program thathave been demonstrated to have no more than aminimal risk impact. The licensee may use itsscreening process as approved in the NRC safetyevaluation dated December
[[_]], 2014, to determine that certain fire protection program changes meet theminimal criterion.
The licensee shall ensure that fireprotection defense-in-depth and safety margins aremaintained when changes are made to the fireprotection program.(c) Transition License Conditions
: 1. Before achieving full compliance with 10 CFR 50.48(c),
as specified by 2. below, risk-informed changes to thelicensee's fire protection program may not be madewithout prior NRC review and approval unless thechange has been demonstrated to have no more thana minimal risk impact, as described in 2. above.2. The licensee shall implement the modifications to itsfacility, as described in Table S-1, "Plant Modifications Committed,"
of Duke letter BSEP 14-0122, datedNovember 20, 2014, to complete the transition to fullcompliance with 10 CFR 50.48(c) by the startup of thesecond refueling outage for each unit after issuance ofthe Safety Evaluation.
The licensee shall maintainappropriate compensatory measures in place untilcompletion of these modifications.
Page 3 Duke Enerav Proaress.
Inc.Attachment M -License Condition Chancles3. The licensee shall complete all implementation items,except item 9, listed in LAR Attachment S, Table S-2,"Implementation Items," of Duke letter BSEP 14-0122,dated November 20, 2014, within 180 days after NRCapproval unless completion falls within an outagewindow; then, in that case, completion of theimplementation items will be 60 days after startup fromthe scheduled outage. The licensee shall completeimplementation LAR Attachment S, Table S-2, Item 9within 180 days after the startup of the secondrefueling outage for each unit after issuance of theSafety Evaluation.
Page 4}}

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