ML17298B444

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

ML17298B444
Person / Time
Site:	Ginna
Issue date:	10/25/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF1393
Download: ML17298B444 (15)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 October 25, 2017 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 Accession 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 10 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 October 25, 2017 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 LAR that proposed to not complete modification, remove overcurrent protection for its emergency diesel generators," dated October 2, 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). In Reference 6, the U. S. Nuclear Regulatory Commission requested additional information. Attached is our response.

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 25th of October 2017.

Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Response to Request for Additional Information

2) M. License Condition Changes cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, Ginna USNRC Senior Project Manager, Ginna A. L. Peterson, NYSERDA

Attachment 1 Response to Request for Additional Information

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page 1

RAI 1

In its letter dated June 30, 2017 the licensee submitted a license amendment request (LAR) that proposed to not complete the modification to install overcurrent protection for its emergency diesel generators as required by its current fire protection license condition issued through amendment 119 on November 23, 2015 (ADAMS Accession No. ML15271A101 ). The NRC staff found that the licensee proposed several additional changes unrelated to the proposed change to not install the overcurrent protection. The NRC staff is requesting that the licensee:

1. Clarify each of the proposed changes identified below in regards to whether NRC approval is being requested and provide additional justification/explanation for each proposed change.

2. Indicate whether each of the proposed changes identified below resulted in changes to the probabilistic risk assessment, and if so, provide the overall impact on risk for all changes in the LAR, and the impact on safety margin and defense-in-depth (DID) for each change to the plant leading to a change in the PRA, including changes to procedures. Indicate if the new risk results meet the acceptance guidelines of Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant Specific Changes to the Licensing Basis," (ADAMS Accession No. ML100910006), and discuss the adequacy of the resulting safety margin and DID.

Question:

A. Enclosure C, Attachment C, Table C-1, Page C-2: The change from "new charging system" and "standby charging pump" to "alternate RCS injection system" and "alternate RCS injection pump."

Response

This is a name change only. The function and modeling of the pump is unaltered from that approved in the Ginna Safety Evaluation Report (ML15271A101 ).

Question:

B. Enclosure C, Attachment G, Table G-1, Pages G-7 through G-12: The change in several recovery actions from "new charging system" "new RCS injection system." In addition, this change does not align with the change described in "A" above.

Response

Alternate Reactor Coolant System (RCS) Injection System is the formal name. The "new RCS Injection System" and "new charging system" refer to the same equipment approved in the Ginna Safety Evaluation Report (ML15271A101 ). The water source for the new RCS Injection System has changed from a small stand alone tank to the spent fuel pool. This is discussed in the response to RAI 01-C.f.

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page2 Question:

C. Enclosure C, Attachment S, Tables S-1, S-2, and S-3:

a. The change that moved modifications 7 and 13 from Table S-2 to Table S-1.

Response

No additional approval is required. These modifications were already approved in the Ginna Safety Evaluation Report (ML15271A101). Modifications 7 and 13 have already been installed.

Question:

b. The change from "pressurizer" to "Reactor Coolant System" in Modification 2 in Table S-2.

Response

This is a name change only. The functional modeling in the PAA remains the same as that approved in the Ginna Safety Evaluation Report (ML15271A101).

Question:

c. The change in ESR number in Modification 3 in Table S-2.

Response

Engineering Service Requests (ESRs) 12-0125, 12-0126, and 12-0128 are all being completed under a combined ESR. There are no functional or modeling changes. Site Engineering can change an ESR number for tracking purposes, but the functional requirements will not be altered.

Question:

d. The change in ESR number and additional new text in Modification 4 in Table S-2.

Response

Engineering Service Requests (ESRs) 12-0125, 12-0126, and 12-0128 are all being completed under a combined ESR. There are no functional or modeling changes. The new text refers to an improvement in the actuation logic of the Main Steam Isolation Valves (MSIVs). The MSIVs will be closed by either low RCS pressure or Steam Generator (SG) water level. The improvement is credited in the Attachment W delta-risk results. There is no impact on safety margin or defense-in-depth.

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page 3 Question:

e. The changed text in Modification 8 in Table S-2.

Response

This is a name change only for RCS injection. The functional modeling in the PAA remains the same. Regarding the battery chargers, the intent was always that the FLEX equipment could support either battery charger (whichever charger is not damage by the fire). There is no impact on safety margin or defense-in-depth.

Question:

f. The changed text in Modification 9 in Table S-2.

Response

The manually initiated borated water source is now the spent fuel pool. This change is reflected in the updated attachments provided including the delta-risk calculations (i.e.,

Attachment W). This is considered to be a risk improvement.

The original modification, as approved in the Ginna Safety Evaluation Report (ML15271A101 ), would have included a 10,000 gallon tank as the water source with procedures in place to align a skid mounted boration system once the 10,000 gallon tank is depleted. The current spent fuel pool option provides enough water to last for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a skid-mounted boration system is required. The spent fuel pool configuration does require a booster pump. To ensure the same level of redundancy as that of the approved Ginna Safety Evaluation Report, these redundant booster pumps will be located in the SAFW complex along with the Alternate RCS Injection Pump. As such, no new fire areas can cause the loss of the spent fuel pool option.

Further, these booster pumps use the same ultimate power sources as the Alternate RCS Injection Pump. Therefore, no new power dependencies are introduced. This change is reflected in the Attachment W delta-risk calculations. There is no impact on defense-in-depth. The plant procedures will ultimately reflect this change once the modification is installed.

Question:

g. The change that added implementation items 10, 11, 12, 13, 14, 23, and 24 to the list of implementation items that will be completed after modifications are complete in Table S-3.

Response

Implementation actions 1O through 14 represent the feasibility evaluation of each new action added to the fire mitigation procedures. Implementation actions 1O through 14 have been done for Implementation Items 16, 17, 18, 20, and 22. But, as stated in

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page 4 Implementation Item 9, those changes conditional on the completion of the modifications cannot be completed until the modifications are fully installed.

Therefore, Implementation Items 23 and 24 will be implemented when the modifications are completed. This will include the feasibility evaluations (i.e.,

Implementation Items 10 through 14) for Implementation Items 23 and 24.

Implementation Item 23, requires the new Alternate RCS Injection System to be fully installed before we can add a procedure step to disable the charging system.

Implementation Item 24 is partially implemented. The procedure changes are in place, but, the success of this action will rely on the new RCS pressure indication. This new indication will either require new training on the indication or specific indication direction in the procedure. This cannot be fully implemented until the indication modification is completed.

Question:

h. The changed text in Implementation Items 5, 20, and 24 in Table S-3.

Response

For Implementation Item 5, the procedure name changed to the Exelon standard naming structure. The function of the procedures remains the same. Although the procedure names may change, the NFPA 805 change control requirements will remain unaltered.

For Implementation Item 20, Operations identified a faster way to locally secure the Motor Generator Sets than original credited. This is functionally equivalent to the original modeling. There is no impact on safety margin or defense-in-depth. The plant procedures will ultimately reflect this change once the modification is installed.

Implementation Item 24 represents a name change only. The functional modeling of the PRA remains unaltered.

RAI 02

In Enclosure 2, Attachment M, of its letter dated June 30, 2017, the licensee submitted its proposed changes to its fire protection license condition. The NRC staff identified the following errors:

Question:

A. The first paragraph used "R.E. Ginna Nuclear Power Plant" instead of "Exelon Generation."

Response

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page 5 The first paragraph reference has been change to "Exelon Generation."

Question:

B. Transition license conditions 2 and 3 used "CENG" instead of "Exelon Generation."

Response

Transition license conditions have been changed to Exelon Generation.

Question:

C. The June 30, 2017 LAR was not added to the first paragraph of the license condition.

Response

The June 30, 2017 date has been added to the New License Condition.

Question:

D. A placeholder for the additional safety evaluation generated from June 30, 2017 LAR was not added to the first paragraph of the license condition.

Response

A placeholder has been added.

Question:

The NRC staff requests that the licensee correct the identified errors and resubmit Attachment M.

Response

Attachment 2 contains a revised draft Attachment M.

RAI 3

The letter dated March 2, 2016 from Joseph G. Giitter, and Anne Boland, NRC, to Michael 0.

Tschiltz, Nuclear Energy Institute (NEI) (ADAMS Accession No. ML16015A416), provided guidance for licensee's to follow when seeking changes to license conditions established in amendments to adopt 10 CFR 50.48(c) (NFPA 805). In the letter, three options were provided. The licensee's LAR dated June 30, 2017 did not indicate which option the licensee used in its submittal. However, Section 3.3 of this LAR does indicate those changes that have been made to the PRA model.

U.S. Nuclear Regulatory Commission License Amendment Request Revised Commitment Associated with Implementation of NFPA 805, 2001 Edition October 25, 2017 Page 6 Aside from the changes identified in Section 3.3, please confirm that the LAA conforms to the criteria to meet Option A. If methods beyond those accepted in the Ginna NFPA 805 SE and beyond those in Section 3.3 were used, specify whether option B or C is appropriate for these additional methods.

Response

Option B was used. Section 3.3 of the License Amendment Request lists the high-level changes. As listed in Section 3.3, only approved methods/approaches were used. This includes the use of the approved Appendix L to NUREG/CR-6850 regarding the main control board analysis method which is a new method for Ginna. Consistent with the ASME/ANS PAA standard, this new method was reviewed by a focused scope peer review with no findings.

These changes have been made to the PAA model. Further, these changes are reflected in the new delta-risk results provided in the updated Attachment W.

RAl4:

In its LAA dated June 30, 2017, the licensee indicated that the heat release rates (HRRs) have been incorporated consistent with NUREG-2178, "Refining and Characterizing Heat Release Rates From Electrical Enclosures During Fire (RACHELLE-FIRE) - Volume 1: Peak Heat Release Rates and Effect of Obstructed Plume, Final Report," April 2016, (ADAMS Accession No. ML16110A140), and that the data in NUREG-2178 offsets the risk increase associated with electrical cabinets.

The NRG staff requests that the licensee indicate if any electrical cabinets to which the obstructed plume model of NUREG-2178 is applied have the fire placed at an elevation of less than one-half of the cabinet. According to NUREG-2178, the obstructed plume model is not applicable to cabinets in which the fire is placed at elevations of less than one-half of the cabinet. Justify any cases where the obstructed plume model is credited where the fire is located at less than one half of the cabinet's height, or remove credit for the obstructed plume model and recalculate the risk and compare it with AG 1.174 acceptance guidelines.

Response

The fire location for an electrical cabinet is no lower than one foot below the top of the cabinet.

In some cases, when the venting is within a foot of the top of a cabinet, the fire location is at the highest vent. None of the panels that credit an obstructed plume is less than two feet tall.

Therefore, no cabinets where obstructed plume are credited are less than one-half of the cabinet height.

Attachment 2 M. License Condition Changes

Exelon Generation Attachment M - License Condition Changes M. License Condition Changes 5 Pages Attached Ginna LAA Rev 2 Page M-1

Exelon Generation Attachment M - License Condition Changes Replace the current fire protection license condition 2.C(3) with the standard license condition from Regulatory Guide 1 .205, Regulatory Position 3.1 , modified as shown below.

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.

Exelon Generation 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 Ginna Facility Operating License DPR-18.

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.C(3):

"Fire Protection (a) The licensee shall implement and maintain in effect all fire protection features described in the licensee's submittals referenced in and as approved or modified by the NRC's Fire Protection Safety Evaluation (SE) dated February 14, 1979, and SE supplements dated December 17, 1980, December 17, 1980, June 22, 1981, February 27, 1985, and March 21, 1985 or configurations subsequently approved by the NRG, subject to provision (b) below.

(b) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(c) Deleted" Ginna LAR Rev 2 Page M-2

Exelon Generation Attachment M - License Condition Changes New License Condition:

Fire Protection Program Exelon Generation 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 March 28, 2013, supplemented by letters dated December 17, 2013; January 29, 2014; February 28, 2014; September 5, 2014; September 24, 2014; December 4, 2014; March 18, 2015; June 11, 2015; August 7, 2015; June 30, 2017, and as approved in the safety evaluation reports dated November 23, 2015 and . 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 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.

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.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 o*7/year (yr) for CDF and less than 1x1 o-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 Prior NRC review and approval are not required for changes to the NFPA 805, Ginna LAR Rev 2 Page M-3

Exelon Generation

• Attachment M - License Condition Changes 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 the 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 concl~de 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.

Ginna LAA Rev 2 Page M-4

Exelon Generation Attachment M - License Condition Changes (c) Transition License Conditions

1. Before achieving full compliance with 10 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 NRG 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.

The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete the implementation items listed in LAR Attachment S, Table S-3, "Implementation Items," of Exelon Generation letter dated June 11, 2015, as modified by Exelon Generation letter dated June 30, 2017, except Implementation Items 9, 10, 11, 12, 13, 14, 15, 19, 21, 23, and 24 by 180 days after NRG approval unless that date falls within a scheduled refueling outage, then implementation will occur 60 days after startup from that scheduled refueling outage. These implementation items are associated with modifications described in Table S-2 and will be completed once the related modifications are installed and validated in the PRA model.

Ginna LAA Rev 2 Page M-5