ML18158A129

R.E. Ginna Nuclear Power Plant - License Amendment Request: Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition

ML18158A129
Person / Time
Site:	Ginna
Issue date:	06/05/2018
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18158A129 (5)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www exeloncorp com 10 CFR 50.90 June 5, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

License Amendment Request - Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition

References:

1. Render, Diane, U.S. Nuclear Regulatory Commission, letter to Hanson, Bryan, Exelon Generation Company, LLC, "R.E. Ginna Nuclear Power Plant - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in accordance with Title 1O of the Code of Federal Regulations Section 50.48(c) (CAC No. MF1393)," dated November 23, 2015 (ADAMS Ar.cession No.

ML15271A101).

2. Pacher, Joseph, E., Exelon Generation Company, LLC, letter to U.S.

Nuclear Regulatory Commission, "R.E. Ginna Nuclear Power Plant, Renewed Facility Operating License No. DPR-18, Docket No. 50-244, Response to Request for Additional Information," dated August 7, 2015.

3. Pacher, Joseph, E., Exelon Generation Company, LLC, letter to U.S.

Nuclear Regulatory Commission, "R.E. Ginna Nuclear Power Plant, Renewed Facility Operating License No. DPR-18, Docket No. 50-244, Response to Request for Additional Information," dated June 11, 2015.

4. Pacher, Joseph, E., Constellation Energy Nuclear Group, letter to U.S.

Nuclear Regulatory Commission, "R.E. Ginna Nuclear Power Plant, Docket No. 50-244, License Amendment Request Pursuant to 1O CFR 50.90:

Adoption of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," dated March 28, 2013 (ADAMS Accession No. ML13093A064).

5. Barstow, James, Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory Commission, "License Amendment Request - Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition,"

dated June 30, 2017.

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition June 5, 2018 Page2

6. Sreenivas V., U.S. Nuclear Regulatory Commission Email to Loomis, Thomas and Helker, David, Exelon Generation Company, LLC, "Ginna: Request for Additional Information (RAI) for NFPA-805 LAA that proposed to not complete modification, remove overcurrent protection for its emergency diesel generators," dated October 2, 2017.

7. Barstow, James, Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory Commission, "License Amendment Request - Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition,"

dated October 25, 2017.

In the Reference 5 letter, Exelon Generation Company, LLC (EGG) requested a change to the commitments associated with the implementation of items listed in Attachment S of Reference 3. Specifically, the commitment to install overcurrent protection (modification ESR-12-0141) is no longer required in the modification scope. This commitment was approved in the U.S. Nuclear Regulatory Commission Safety Evaluation Report (Reference 1). Attached is a clarification to License page 5 which adds a reference to the original Reference 1 U.S. Nuclear Regulatory Commission Safety Evaluation Report.

Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the U.S.

Nuclear Regulatory Commission in the Reference 5 letter. The supplemental information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 1O CFR 50.92. In addition, Exelon has concluded that the information provided in this supplemental response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th of June 2018.

Respectfully, David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Revised License Page

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition June 5, 2018 Page3 cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, Ginna USNRC Senior Project Manager, Ginna A. L. Peterson, NYSERDA

Attachment Revised License Page

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 3.1 O); 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 November 23, 2015, 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.

(c) Transition License Conditions

1. Before achieving full compliance with 1O CFR 50.48(c) , as specified by (c)2 and (c)3 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 (b)2 above.

2. The licensee shall implement the modifications to its facility, as described in LAR Attachment S, Table S-2, "Plant Modifications Committed," of Exelon Generation letter dated June 11, 2015, as modified by the Exelon Generation letter dated June 30, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than prior to startup from the second refueling outage greater than 12 months after receipt of the safety evaluation dated November 23, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

R. E. Ginna Nuclear Power Plant Amendment No.