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| | issue date = 12/18/2014 | | | issue date = 12/18/2014 |
| | title = Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624) | | | title = 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 name = Gideon W |
| | author affiliation = Duke Energy Corp | | | author affiliation = Duke Energy Corp |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:William R. Gideon Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 December 18, 2014 Serial: BSEP 14-0134 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 | | {{#Wiki_filter:William R. Gideon Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 December 18, 2014 Serial: BSEP 14-0134 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
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| ==Subject:== | | ==Subject:== |
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| ==Reference:== | | ==Reference:== |
| : 1. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S.Nuclear Regulatory Commission (Serial: BSEP 12-0106), License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants (2001 Edition), dated September 25, 2012, ADAMS Accession Number ML12285A428 | | : 1. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S. |
| : 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 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), dated December 17, 2012, ADAMS Accession Number ML12362A284 | | Nuclear Regulatory Commission (Serial: BSEP 12-0106), License Amendment Request to Adopt NFPA 805 Performance-BasedStandardfor Fire Protection for Light-Water Reactor Electric GeneratingPlants (2001 Edition), dated September 25, 2012, ADAMS Accession Number ML12285A428 |
| : 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 Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624),dated November 20, 2014, ADAMS Accession Number ML14337A725 Ladies and Gentlemen: | | : 2. Letter from Michael J. Annacone (Carolina Power & Light Company) to U.S. |
| By letter dated September 25, 2012 (i.e., Reference 1), as supplemented by letter dated December 17, 2012 (i.e., Reference 2), Duke Energy Progress Inc., submitted a license amendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fire protection licensing basis for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.Attachment M of the original LAR submittal (i.e., Reference | | Nuclear Regulatory Commission (Serial: BSEP 12-0140), Additional Information Supporting License Amendment Request to Adopt NFPA 805 Performance-BasedStandardfor Fire Protectionfor Light Water Reactor Electric GeneratingPlants (2001 Edition), dated December 17, 2012, ADAMS Accession Number ML12362A284 |
| : 1) provided the proposed replacement to the BSEP fire protection license condition 2.B.(6).
| | : 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 Fire ProtectionAssociation Standard805 (NRC TAC Nos. ME9623 and ME9624),dated November 20, 2014, ADAMS Accession Number ML14337A725 Ladies and Gentlemen: |
| I.U.S. Nuclear Regulatory Commission Page 2 of 3 The purpose of this letter is to update Attachment M of the LAR to ensure the proposed transition license condition 2.B.(6)(c)(3) appropriately reflects the modifications and implementation items that must be completed to support the transition to National Fire Protection Association (NFPA) Standard 805. These modifications and implementation items are listed in LAR Attachment S, Tables S-1 and S-2, respectively. | | By letter dated September 25, 2012 (i.e., Reference 1), as supplemented by letter dated December 17, 2012 (i.e., Reference 2), Duke Energy Progress Inc., submitted a license amendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fire protection licensing basis for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. |
| The final update of LAR Attachment 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 the NFPA 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. | | Attachment M of the original LAR submittal (i.e., Reference 1) provided the proposed replacement to the BSEP fire protection license condition 2.B.(6). |
| 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 on December 18, 2014.Sincerely, William R. Gideon | | |
| | I. |
| | U.S. Nuclear Regulatory Commission Page 2 of 3 The purpose of this letter is to update Attachment M of the LAR to ensure the proposed transition license condition 2.B.(6)(c)(3) appropriately reflects the modifications and implementation items that must be completed to support the transition to National Fire Protection Association (NFPA) Standard 805. These modifications and implementation items are listed in LAR Attachment S, Tables S-1 and S-2, respectively. The final update of LAR Attachment 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 the NFPA 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 FederalRegister (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 on December 18, 2014. |
| | Sincerely, William R. Gideon |
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| ==Enclosure:== | | ==Enclosure:== |
| | Revised License Amendment Request Attachment M License Condition 2.B.(6) |
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| | U.S. Nuclear Regulatory Commission Page 3 of 3 cc: |
| | U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only) |
| | Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov |
| | |
| | Enclosure Revised License Amendment Request Attachment M License Condition 2.B.(6) |
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| | Duke Enerav Proaress. Inc. Attachment M - License Condition Chanqes Supersede 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 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 license amendment request dated September 25, 2012, as supplemented 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 in the safety evaluation dated December (()), 2014. 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. |
| | (a) 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 Brunswick. 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. |
| | : 1. 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. |
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| | Duke Enerav Proaress. Inc. Aftachment tahetM-Lces M - License Condition odto Chancies hne DukoEem Prqrss Inc |
| | : 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than lx 0-7/year (yr) for CDF and less than lx 0-8/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. |
| | (b) Other Changes that May Be Made Without Prior NRC Approval |
| | : 1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval is 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 an 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. |
| | 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); |
| | Page 2 |
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| | 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 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 is 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 December ((_)), 2014, 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 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 Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications. |
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| Revised License Amendment Request Attachment M License Condition 2.B.(6)
| | Duke Enerav Proaress. Inc. Attachment M - License Condition Chancles |
| U.S. Nuclear Regulatory Commission Page 3 of 3 cc: U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov Enclosure Revised License Amendment Request Attachment M License Condition 2.B.(6)
| | : 3. 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 NRC approval unless completion falls within an outage window; then, in that case, completion of the implementation items will be 60 days after startup from the scheduled outage. The licensee shall complete implementation LAR Attachment S, Table S-2, Item 9 within 180 days after the startup of the second refueling outage for each unit after issuance of the Safety Evaluation. |
| Duke Enerav Proaress. | |
| Inc.Attachment M -License Condition Chanqes Supersede 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 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 license amendment request dated September 25, 2012, as supplemented 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 in the safety evaluation dated December [[]], 2014. 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.(a) 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 Brunswick. | |
| 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.1. 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.
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| Page 1 Duke Enerav Proaress.
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| Inc.Aftachment M -License Condition Chancies DukoEem Prqrss Inc tahetM-Lces odto hne 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than lx 0-7/year (yr) for CDF and less than lx 0-8/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.(b) Other Changes that May Be Made Without Prior NRC Approval 1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval is 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 an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement.
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| 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 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);Page 2 Duke Enerav Proaress.
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| 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 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 is 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 December [[_]], 2014, to determine that certain fire protection program changes meet the minimal criterion.
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| 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
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| : 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 Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the Safety Evaluation.
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| The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
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| Page 3 Duke Enerav Proaress.
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| Inc.Attachment M -License Condition Chancles 3. 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 NRC approval unless completion falls within an outage window; then, in that case, completion of the implementation items will be 60 days after startup from the scheduled outage. The licensee shall complete implementation LAR Attachment S, Table S-2, Item 9 within 180 days after the startup of the second refueling outage for each unit after issuance of the Safety Evaluation.
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Letter Sequence Request |
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MONTHYEARBSEP 12-0106, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)2012-09-25025 September 2012 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) Project stage: Request ML13004A3382013-01-0808 January 2013 Acceptance for Review of License Amendment Request for NFPA Standard 805 (TAC Nos. ME9623 and Me9624) Project stage: Acceptance Review ML13123A2312013-05-15015 May 2013 Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: RAI ML13141A6222013-05-23023 May 2013 RAI Re. Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (EA-12-051) Project stage: RAI BSEP 13-0066, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052013-06-28028 June 2013 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Response to RAI BSEP 13-0070, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052013-07-15015 July 2013 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Response to RAI ML14079A2372013-07-16016 July 2013 Fourth Quarter 2011 Fire Protection Program Health Report, Enclosure 5 Project stage: Other ML14079A2382013-07-16016 July 2013 Fourth Quarter 2012 Fire Protection Program Health Report, Enclosure 6 Project stage: Other BSEP 13-0083, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052013-07-31031 July 2013 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Response to RAI ML13246A2772013-08-28028 August 2013 Enclosure 3 - Revised Brunswick NFPA 805 Transition Report, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, Transition Report, August Project stage: Other BSEP 13-0097, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard (NFPA) 8052013-08-29029 August 2013 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard (NFPA) 805 Project stage: Response to RAI ML13277A0412013-09-19019 September 2013 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Project stage: Other BSEP 13-0107, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard (NFPA) 805 (NRC TAC Nos. ME9623 and ME9624)2013-09-30030 September 2013 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard (NFPA) 805 (NRC TAC Nos. ME9623 and ME9624) Project stage: Response to RAI ML14079A2352014-01-0909 January 2014 FIR-NGGC-0009, NFPA 805 Transient Combustibles and Ignition Source Controls Program, Enclosure 3 Project stage: Other ML13365A3202014-01-14014 January 2014 Second Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: RAI ML14079A2362014-01-24024 January 2014 Fourth Quarter 2013 Fire Protection Program Health Report, Enclosure 4 Project stage: Other ML14028A1782014-02-12012 February 2014 Second Set of Probabilistic Risk Assessment Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: RAI BSEP 14-0023, Response to Second Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)2014-02-28028 February 2014 Response to Second Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624) Project stage: Request BSEP 14-0029, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052014-03-14014 March 2014 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Response to RAI BSEP 14-0035, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052014-04-10010 April 2014 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Response to RAI ML14079A2342014-04-30030 April 2014 BNP-PSA-086, Bnp Fire PRA - Fire Scenario Data, Enclosure 2, Attachment 25 Project stage: Other ML14155A2092014-06-0404 June 2014 E-mail Re. Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: RAI BSEP 14-0076, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624)2014-06-26026 June 2014 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624) Project stage: Response to RAI ML14205A5922014-07-24024 July 2014 Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (TAC Nos. ME9623 and ME9624) Project stage: RAI ML14220A2132014-08-0808 August 2014 E-mail Re. Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: RAI BSEP 14-0092, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC ME9623 and ME9624)2014-08-15015 August 2014 Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC ME9623 and ME9624) Project stage: Response to RAI BSEP 14-0100, Response to Request Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 8052014-08-29029 August 2014 Response to Request Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Other ML14297A2662014-10-24024 October 2014 Record of Review, Brunswick Steam Electric Plant, Units 1 and 2, LAR Attachment U- Table U-1 Internal Events PRA Peer Review- Facts and Observations (F&Os), 10/24/14 Project stage: Other BSEP 14-0122, Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 8052014-11-20020 November 2014 Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 Project stage: Request 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)2014-12-18018 December 2014 Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC Nos. ME9623 and ME9624) Project stage: Request ML14310A8082015-01-28028 January 2015 Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(C) Project stage: Approval 2014-01-09
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Category:Letter type:BSEP
MONTHYEARBSEP 19-0012, Submittal of 2018 Sea Turtle Annual Report2019-01-17017 January 2019 Submittal of 2018 Sea Turtle Annual Report BSEP 18-0052, Annual Radiological Environmental Operating Report - 20172018-05-10010 May 2018 Annual Radiological Environmental Operating Report - 2017 BSEP 18-0051, Annual Radioactive Effluent Release Report - 20172018-04-26026 April 2018 Annual Radioactive Effluent Release Report - 2017 BSEP 18-0045, Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time2018-04-25025 April 2018 Request for License Amendment: Technical Specification 3.8.3, Diesel Fuel Oil, One-Time Extension of Main Fuel Oil Storage Tank Completion Time BSEP 18-0054, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential.2018-04-24024 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential. BSEP 18-0048, Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-04-11011 April 2018 Response to Request for Additional Information Regarding Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0044, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-04-11011 April 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0046, Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-04-10010 April 2018 Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0047, Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test2018-04-0505 April 2018 Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test BSEP 18-0041, Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report2018-04-0404 April 2018 Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report BSEP 18-0043, Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D2018-03-31031 March 2018 Application of Dissimilar Metal Weld Full Structural Overlay - Reactor Pressure Vessel Nozzles N4A and N4D BSEP 18-0035, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-29029 March 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0042, Cycle 22 Core Operating Limits Report (COLR)2018-03-27027 March 2018 Cycle 22 Core Operating Limits Report (COLR) BSEP 18-0040, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test2018-03-23023 March 2018 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test BSEP 18-0039, Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D2018-03-19019 March 2018 Proposed In-Service Inspection Alternative for Application of Dissimilar Metal Weld Full Structural Overlay - Nozzles N4A and N4D BSEP 18-0034, Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-16016 March 2018 Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0032, Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-14014 March 2018 Additional Testing Information Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 18-0026, Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2018-03-0707 March 2018 Additional Information Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 18-0014, Fifth 10-Year Inservice Testing Program Plan2018-02-19019 February 2018 Fifth 10-Year Inservice Testing Program Plan BSEP 18-0021, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure2018-02-0505 February 2018 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865). Without Proprietary Enclosure BSEP 18-0017, Revision to Radiological Emergency Response Plan and Implementing Procedure2018-01-30030 January 2018 Revision to Radiological Emergency Response Plan and Implementing Procedure BSEP 18-0015, Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations2018-01-23023 January 2018 Inservice Inspection Program Proposed Alternative ISI-09 in Accordance with 10 CFR 50.55a(z)(1) Regarding Reactor Pressure Vessel Circumferential Shell Weld Examinations BSEP 18-0013, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-23023 January 2018 Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 18-0001, Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements2018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-551, Revise Secondary Containment Surveillance Requirements BSEP 18-0012, Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.32018-01-23023 January 2018 Application to Revise Technical Specifications to Adopt TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.3 BSEP 18-0009, 2017 Sea Turtle Annual Report2018-01-15015 January 2018 2017 Sea Turtle Annual Report BSEP 17-0098, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2018-01-10010 January 2018 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors BSEP 17-0119, Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program2018-01-10010 January 2018 Snubber Program Plan for Fifth 10-Year Interval Inservice Testing Program BSEP 17-0115, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-01-0404 January 2018 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control BSEP 17-0110, Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2017-12-20020 December 2017 Seventh Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions BSEP 17-0121, Post-Examination Documentation and Comments for Operator Retake Initial Examination2017-12-14014 December 2017 Post-Examination Documentation and Comments for Operator Retake Initial Examination BSEP 17-0120, Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension..2017-12-12012 December 2017 Withdrawal of Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension.. BSEP 17-0118, Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel..2017-12-0707 December 2017 Supplement to Response to Request for Additional Information Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel.. BSEP 17-0117, Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources..2017-12-0606 December 2017 Response to Request for Additional Information (Probabilistic Risk Assessment and Human Performance Branches) Regarding Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1 AC Sources.. BSEP 17-0116, Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of ..2017-12-0404 December 2017 Response to Request for Additional Information Regarding Request for Risk- Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of .. BSEP 17-0104, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination2017-11-29029 November 2017 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Reactor Pressure Vessel Nozzle-to-Vessel Weld Examination BSEP 17-0111, Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-28028 November 2017 Request for Risk-Informed Exigent License Amendment - Technical Specification 3.8.1, AC Sources Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0109, Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And.2017-11-24024 November 2017 Response to Request for Additional Information Regarding Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times And. BSEP 17-0108, Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements2017-11-22022 November 2017 Request for Emergency License Amendment - Technical Specification 3.8.1, AC Sources - Operating, One-Time Extension of Emergency Diesel Generator Completion Times and Suspension of Surveillance Requirements BSEP 17-0017, Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material2017-11-15015 November 2017 Submittal of Request for License Amendment for Performance-Based Fire Protection Alternative for Thermal Insulation Material BSEP 17-0100, Fifth 10-Year Inservice Testing Interval2017-11-0202 November 2017 Fifth 10-Year Inservice Testing Interval BSEP 17-0089, Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0093, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0078, Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.52017-10-0303 October 2017 Request for License Amendment - DC Sources - Operating Surveillance Requirement (SR) 3.8.4.5 BSEP 17-0076, Registration for Use of General License Spent Fuel Casks2017-09-0606 September 2017 Registration for Use of General License Spent Fuel Casks BSEP 17-0081, Revision to Radiological Emergency Response Plan Implementing Procedures2017-09-0505 September 2017 Revision to Radiological Emergency Response Plan Implementing Procedures BSEP 17-0039, Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements2017-08-15015 August 2017 Submittal of Response to Inspection Report 05000324/2015404 and 05000325/2015404, Dated March 30, 2015, Inspection of Interim Cyber Security Milestones 1-7 and Target Set Requirements BSEP 17-0071, ISFSI - Registration for Use of General License Spent Fuel Casks2017-08-15015 August 2017 ISFSI - Registration for Use of General License Spent Fuel Casks BSEP 17-0064, Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N92017-07-10010 July 2017 Application of Dissimilar Metal Weld Full Structural Overlay on Reactor Pressure Vessel Nozzle N9 BSEP 17-0060, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.2017-06-29029 June 2017 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control. 2019-01-17
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William R. Gideon Vice President ENERGY, Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 December 18, 2014 Serial: BSEP 14-0134 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Additional Information Regarding License Amendment Request to Adopt Voluntary Risk Initiative National Fire Protection Association Standard 805 (NRC TAC 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), License Amendment Request to Adopt NFPA 805 Performance-BasedStandardfor Fire Protection for Light-Water Reactor Electric GeneratingPlants (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 805 Performance-BasedStandardfor Fire Protectionfor Light Water Reactor Electric GeneratingPlants (2001 Edition), dated December 17, 2012, ADAMS Accession 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 Fire ProtectionAssociation Standard805 (NRC TAC Nos. ME9623 and ME9624),dated November 20, 2014, ADAMS Accession Number ML14337A725 Ladies and Gentlemen:
By letter dated September 25, 2012 (i.e., Reference 1), as supplemented by letter dated December 17, 2012 (i.e., Reference 2), Duke Energy Progress Inc., submitted a license amendment request (LAR) to adopt a new, risk-informed, performance-based (RI-PB) fire protection 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 proposed replacement to the BSEP fire protection license condition 2.B.(6).
I.
U.S. Nuclear Regulatory Commission Page 2 of 3 The purpose of this letter is to update Attachment M of the LAR to ensure the proposed transition license condition 2.B.(6)(c)(3) appropriately reflects the modifications and implementation items that must be completed to support the transition to National Fire Protection Association (NFPA) Standard 805. These modifications and implementation items are listed in LAR Attachment S, Tables S-1 and S-2, respectively. The final update of LAR Attachment 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 the NFPA 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 FederalRegister (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 on December 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 3 cc:
U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)
Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov
Enclosure Revised License Amendment Request Attachment M License Condition 2.B.(6)
Duke Enerav Proaress. Inc. Attachment M - License Condition Chanqes Supersede 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 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 license amendment request dated September 25, 2012, as supplemented 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 in the safety evaluation dated December (()), 2014. 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.
(a) 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 Brunswick. 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.
- 1. 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.
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Duke Enerav Proaress. Inc. Aftachment tahetM-Lces M - License Condition odto Chancies hne DukoEem Prqrss Inc
- 2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than lx 0-7/year (yr) for CDF and less than lx 0-8/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.
(b) Other Changes that May Be Made Without Prior NRC Approval
- 1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval is 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 an 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.
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);
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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 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 is 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 December ((_)), 2014, 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 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 Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the Safety Evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
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Duke Enerav Proaress. Inc. Attachment M - License Condition Chancles
- 3. 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 NRC approval unless completion falls within an outage window; then, in that case, completion of the implementation items will be 60 days after startup from the scheduled outage. The licensee shall complete implementation LAR Attachment S, Table S-2, Item 9 within 180 days after the startup of the second refueling outage for each unit after issuance of the Safety Evaluation.
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