CNS-16-002, License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plan, LAR Supplement to Transmit Entire Attachment.

License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plan, LAR Supplement to Transmit Entire Attachment.

ML16011A121
Person / Time
Site:	Catawba
Issue date:	01/07/2016
From:	Henderson K Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-16-002, TAC MF2936, TAC MF2937
Download: ML16011A121 (16)

Text

ENERGYKelvin Henderson Vice President Catawba Nuclear Station Duke Energy CNO1VP I 4800 Concord Road York, SC 29745 CNS-1 6-002 January 7, 2016 o:803.701.4251 f: 803.701.3221 10 CFR 50.90 U.S. Nuclear Regulatory Commission (NRC)Attention:

Document Control Desk Washington, D.C. 20555

References:

Duke Energy Carolinas, LLC (Duke Energy)Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light-Water ReaCtor Generating Plants LAR Supplement to Transmit Entire Attachment 5, "Modifications and Implementation Items"'(TAC Nos. MF2936 and MF2937)Letters from Duke Energy to the NRC, dated September 25, 2013 (ADAMS Accession Number ML13276A503), January 13, 2015 (ADAMS Accession Number ML1 501 5A409), January 28, 2.015 (ADAMS Accession Number ML15029A697), February 27, 2Q15 (ADAMS Accession Number ML1 5065A1 07), March 30, 2015 (ADAMS Accession Number ML15091A339), April 28, 2015 (ADAMS Accession

Number ML15!119A533), July 15, 2015 (ADAMS Accession.

Number ML15198A036), August 14, 2015 (ADAMS Accession Number ML15231A01!0), September 3, 2015 (ADAMS Accession Number ML1 5310GAl23), and December 11, 2015 (ADAMS Accession Number ML1 5350A01 4)The reference letters comprise in their entirety Duke Energy's request for NRC review and approval for adoption of a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Pr'otection for ExiSting Light-Water Nuclear Power 'Plants", Revision 1, dated December 2009. The September 25, 2013 *reference LAR was developed in accordance with the guidance contained in Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)", Revision 2.www.duke-energy.com Document Control Desk Page 2 January 7, 2016 The purpose of this LAR supplement is to transmit the final LAIR Attachment S,"Modifications and Implementation Items" in its entirety.

The NRC requested that the entire Attachment S be transmitted via letter in a telephone conference call on December 14, 2015.The enclosure to this letter provides the entire Attachment S. It has been designated as Revision 4 and all revision bars have been removed. It therefore constitutes a clean copy of Attachment S.The conclusions of the No Significant Hazards Consideration and the Environmental Consideration contained in the September 25, 2013 reference LAR, are unaffected by this LAR supplement.

There are no regulatory commitments contained in this letter or its enclosure.

Pursuant to 10 CFR 50.91, a copy of this LAR supplement is being sent to the appropriate State of South Carolina official.Inquiries on this matter should be directed to L.J. Rudy at (803) 701-3084.I declare under penalty of perjury that the foregoing is true and correct.Executed on January 7, 2016.Very truly yours, Vice President, Catawba Nuclear Station LJR/s Enclosure Document Control Desk Page 3 January 7, 2016 xc (with enclosure):

L.D. Wert Acting Regional Administrator U.S. Nuclear Regulatory Commission

-Region Il Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G.A. Hutto Ill Senior Resident Inspector (Catawba)U.S. Nuclear Regulatory Commission Catawba Nuclear Station G.E. Miller (addressee only)NRC Project Manager (Catawba)U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 S.E. Jenkins Manager Radioactive and Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.Columbia, SC 29201 Enclosure Entire LAR Attachment S, "Modifications and Implementation Items" Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items S. Modifications and Implementation Items 11 Pages Attached Rev 4 Page 5-1 Rev 4 Page S-1 Duke Energy Carolinas, LLCAtahetS-MdfctosndmlmnainIes Attachment S -Modifications and Implementation Items Tables S-I, Plant Modifications Completed, S-2a, Plant Modifications Committed

-Internal Events PRA, and S-2b, Plant Modifications Committed

-Fire PRA, provided below, include a description of the modifications along with the following information:

• A problem statement,* Risk ranking of the modification,* An indication if the modification is currently included in the Fire PRA,* Compensatory Measure in place, and*A risk-informed characterization of the modification and compensatory measure.Table S-1 Plant Modifications Completed Item Rank Unit Problem Statement Proposed ModificationIn cpRiknfre FPRA Measure Characterization NONE Rev 4 Page 5-2 Rev 4 Page S-2 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-2a Plant Modifications Committed

-Internal Events PRA Item Rank Unit Problem Statement Proposed ModificationInCmRiknfre IEPRA Measure Characterization 01 High 1, 2 Auxiliary Shutdown Panels A Harden stairwell doorways and Y N This modification will provide and B are located in the CA associated flow paths to protect the an internal flood risk reductionFeed water) Pump room Auxiliary Feedwater Pump Rooms to offset the Fire PRA risk and are theoretically against water intrusion for both increase post-transition.

susceptible to being rendered Units.non-functional by an internal flood from a pipe break at a Completion Date: higher elevation within the December 31, 2017 Auxiliary Building.02 Deleted via Letter CNS-1 5-101.03 High 1, 2 The current installation and Replace/upgrade turbine building Y N This modification will provide maintenance program of the siding fasteners and institute a an internal events high winds turbine building siding fasteners preventative maintenance program risk reduction to offset the Fire leave the siding susceptible to to periodically inspect the fasteners.

PRA risk increase post-being affected by low speed transition.

(73-114 mph) straight line Completion Date: winds thus increasing the PRA December 31, 2017 risk probability of a LOOP event.Rev 4 Page S-3 Rev 4 Page S-3 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-2b Plant Modifications Committed

-Fire PRA Item Rank Unit Problem Statement Proposed ModificationInCmRiknfre FPRA Measure Characterization 01 High 2 KSI Inverter Modification to Cable 2KSI-SKXP for NY This cable modification is relocate cable in fire area 0ETLPLSKXP will be re-routed from required for NFPA 805.9. SSF shutdown fire area 9 (Unit 2 Battery Room) to non-SSF Compensatory measures will shutdown fire area(s). be established when the NFPA 805 fire protection program Completion Date: becomes effective and remain December 31, 2017 in place until this modification is complete.02 Med I Unit 1 Breaker Coordination Remove the incoming breaker and Y Y This coordination modification issues identified for MCCs connect wiring directly to the MCC is required for NFPA 805.1 EMXA, 1 EMXB, 1 EMXC, bus for the following MCCs: The current coordination study 1 EMXD, 1 EMXI, 1 EMXJ, I1EMXA, 1 EMXB, 1 EMXC, 1 EMXD, is valid for current licensing 1EMXK, and 1EMXL. 1EMXI, 1EMXJ, 1EMXK, and basis.1EMXL.Compensatory measures will Completion Date: be established when the NFPA December 31, 2017 805 fire protection program becomes effective and remain in place until this modification is complete.03 Med 2 Unit 2 Breaker Coordination Remove the incoming breaker and Y Y This coordination modification issues identified for MCCs connect wiring directly to the MCC is required for NFPA 805.2EMXA, 2EMXB, 2EMXC, bus for the following MCCs: The current coordination study 2EMXD, 2EMXI, 2EMXJ, 2EMX(A, 2EMXB, 2EMXC, 2EMXD, is valid for current licensing 2EMXK, and 2EMXL. 2EMXI, 2EMXJ, 2EMXK, and basis.2EMXL.Compensatory measures will Completion Date: be established when the NFPA December 31, 2017 805 fire protection program becomes effective and remain in place until this modification is complete.Rev 4 Page S-4 Duke Energy Carolinas, LLCAtahetS-MdfctosndmlmnainIes Attachment S -Modifications and Implementation Items Table S-2b Plant Modifications Committed

-Fire PRA Item Rank Unit Problem Statement Proposed ModificationInCmRiknfme FPRA Measure Characterization 04 Med 1, 2 Breaker Coordination issues Install fuses on the load side of Y Y This coordination modification identified on load side of EDE EDE and EDF breakers, Involves 4 is required for NFPA 805.and EDF breakers.

breakers on EDE and 3 on EDF. The current coordination study Mount new fuses in each panel. is valid for current licensing basis.Completion Date: December 31, 2017 Compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in place until this modification is complete.05 Med 1, 2 Spurious valve operation with Remove the fuse from the Motor Y Y This spurious operation Breaker Coordination issues Operator Heater circuit for 1 CA modification is required for identified with 600 VAC MCCs. VA0050A and 2CAVA0050A.

NFPA 805. The current deterministic analysis is valid Completion Date: for current licensing basis.December 31, 2017 Compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in place until this modification is complete.06 Med 1, 2 Spurious valve operation with Route new cables for the normally Y Y This spurious operation Breaker Coordination issues energized circuits on 1WLLS5900 modification is required for identified with 600 VAC MCCs. and 2WLLS5900.

NFPA 805. The current deterministic analysis is valid Completion Date: for current licensing basis.December 31, 2017 Compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in place until this modification is complete.Rev 4 Page S-5 Duke Energy Carolinas, LLCAtahetS-Mdfctosndmpenttn es Attachment S -Modifications and Implementation Items Table S-2b Plant Modifications Committed

-Fire PRA Item Rank Unit Problem Statement Proposed ModificationInCmRiknfre FPRA Measure Characterization 07 Med 1, 2 TDCAP is susceptible to fire in Cable routes modified such that the Y Y This modification the ETA/ETB Switchgear TDCAP will remain available in the is required for NFPA 805.Rooms, event of a fire in the ETA or ETB The modification will ensure Switchgear Room. that the TDCAP is available in addition to the already credited Completion Date: opposite train motor driven CA December 31,2017 pump for a lire in the ETA or ETB Switchgear Rooms.Compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in place until this modification is complete.Rev 4 Rev 4Page S-6 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-3, Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NEPA 805 fire protection program. This will occur within 180 days after issuance of the license amendment unless that date falls within a scheduled refueling outage. Then, implementation will occur within 60 days after startup from that scheduled refueling outage. Note Item 13 is associated with modifications in Table S-2b and will be completed 180 days after completion of the last risk related modification.

Table S-3 implementation Items Item Unit Description LAR Section / Source 11, 2 Perform the following recommendations from the Radiological Release 4.4.2 and Attachment E Evaluation:

1. Within each yard area fire strategy, identify radiologically controlled area boundaries within the strategy and any potential escape paths. This includes building sumps and storm drains, where applicable.

For consistency, it is recommended that even hardened barriers are identified.

Examples of these would include: hatches, passage doors, and roll-up doors.2. Enhance the appropriate existing procedures or guidelines, or create a new procedure or guideline, to include more detail on the control measures used to maintain radioactive release limits where monitoring cannot be accomplished.

Examples include:* Water fog streams used for smoke scrubbing* Controlling water runoff during fire suppression activities

• Covering drains and other similar containment measures 3. Enhance Fire Brigade Guidelines (Procedure RP-29) to instruct Radiation Protection personnel to respond to fires where there are radiological concerns inside and outside the Protected Area.4. Enhance the appropriate existing procedures or guidelines, or create a new procedure or guideline, to include guidance for crossing RCA/Radioactive Control Zone boundaries including escape routes.5. Create new fire strategies for yard areas that contain RCAs.This includes the following:

• Retired Steam Generator Storage Facility (Building 7777)Rev 4 Page S-7 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source* Radiation Materials Controi Building (Building 7767)* Hold-Up Ponds* Radiography Vault* Radioactive Materials Containers

• Tents Containing Radioactive Material* Mixed Waste Storage* ISFS1 Storage of non-ISESI Radioactive Materials 6. Within each fire strategy, identify the Radiologically Controlled Area (RCA) or Radioactive Control Zone in the written text.7. Fire Brigade training will be revised to ensure the new guidance proposed in Recommendations 2, 3 and 4 for radioactive release is covered during the established training interval.8. Add a standard statement for smoke and water runoff to all radiologically controlled area fire strategies to prompt measures to avoid radioactive release.9. Incorporate all fire fighting strategies into the electronic records management retrieval system (internally referred to as NEDL). This will provide consistency for current users and the ability to conduct effective reviews to ensure all radioactive release recommendations have been incorporated.

10. Add an appendix to the fire strategies for building sump drainage and site storm drains. This is NOT intended to be a detailed plan, but a site overview that identifies areas where runoff has the potential to route to a storm drain or an automatic sump that will pump without radiation monitoring.

11. Develop administrative guidance in collaboration with radiation protection to support ensuring that radioactive release(s) do not exceed limits in the event of a fire in areas where engineering controls will not contain the potential release. Attachment A contains a flow chart of the various considerations needed for administrative controls that can be directed via one or more plant procedures depending upon the performing group(s).Rev 4 Page S-8 Duke Energy Carolinas, LLC DukeEnegy CrolnasLLCAttachment S -Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section 1 Source 2 1, 2 After the approvaJ of the LAR, in accordance with 10 CFR 50.71(e) and 5.4 approved exemptions, the CNS UFSAR will be revised. The format and content will be consistent with NEI 04-02 FAQ 12-0062.3 1,2 The Design Basis Specification for the Plant Fire Protection, which is the Attachment A, 3.2.2.4 primary fire protection program policy document, will be updated to include the statement that the NRC is the AHJ for fire protection changes requiring approval.4 1,2 Appropriate fire protection program document(s) will be updated to Attachment A, 3.2.3(1)provide a requirement that if a plant elects to implement the methodologies in EPRI Report TR1 006756, that the methodologies will be implemented in their entirety as they pertain to the fire protection systems or features being evaluated.

51,2 The monitoring program required by NFPA 805 Section 2.6 will be 4.6.2, Attachment A, 3.2.3(3)implemented after the LAR approval as part of the fire protection program transition to NFPA 805, in accordance with NFPA 805 FAQ 10-0059, and will include a process that reviews fire protection performance and trends in performance.

Program specifics are provided in LAR Section 4.6.2.6 1,2 Revise station procedures/directives to comply with NFPA 805 Section Attachment A, 3.3.1.2(1

)3.3.1.2(1).

7 1,2 Appropriate station documentation will be updated to include the Attachment A, 3.3.5.1 requirements for installation of cable above suspended ceilings.8 1,2 The Fire Strategies will be reviewed and updated to include any changes Attachment A, 3.4.2.1 to equipment important to nuclear safety and other updates pertinent to the NFPA 805 Transition.

9 1,2 The Fire Protection Design Basis Document described in Section 2.7.1.2 4.7.1 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation.

Appropriate cross references will be established to supporting documents as required by Duke Energy processes.

Rev 4 Rev 4Page S-9 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 10 1, 2 Ensure the CNS configuration control process follows the requirements in 4.7.2 NFPA 805 and the guidance outlined in RG 1.174 which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered.

The configuration control requirements should be implemented in accordance with FAQ 12-0061.11 1, 2 Develop Engineering training guidelines to identify and document 4.7.3 required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.12 1, 2 Revise Shutdown Risk Management procedures to reflect the following 4.3 and Attachment D recommendations during higher risk evolutions from the calculation entitled, "NFPA 805 Transition Non-Power Fire Area Assessments (Pinch Points Analysis)":

• include CNS specific HRPOS definition.

• Limit hot work in affected fire area during Higher Risk Plant Operating States (HRPOS's).

• Prohibit hot work in affected fire areas during Higher Risk Plant Operating States (HRPOS's).

• Verify that the available fire detection systems located in the affected fire areas are functional.

Post firewatch per SL~s in affected fire areas prior to entering Higher Risk Plant Operating States if system(s) are impaired.*Verify that the available fire suppression systems located in the affected fire areas are functional.

Post firewatch per SL~s in affected fire areas prior to entering Higher Risk Plant Operating States if system(s) are impaired.* Limit transient combustible storage in affected fire areas during Higher Risk Plant Operating States (HRPOS's).

• Prohibit transient combustible storage in affected fire areas during Higher Risk Plant Operating States (HRPOS's).

• Provide a firewatch (continuous or periodic) in affected fire areas during Higher Risk Plant Operating States (HRPOS's).

Rev 4 Page S-10 Duke Energy Carolinas, LLC Attachment S -Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section I Source*Activities in affected fire areas should be rescheduled to non-Higher Risk Plant Operating States (HRPOS's) periods.13 1, 2 Following installation of the risk related modifications and the as-built 4.8.2 installation details, additional refinements surrounding the modification and any procedural implementation items (Table S-3 Items 12 and 16) will be incorporated into the Fire PRA model and Internal Events model, as required.

In addition, a verification will be performed to confirm that the risk results are not appreciably changed. If the as-built change-in-risk estimates exceed the RG 1.174 acceptance guidelines, the responsible feature will be identified and evaluated.

Actions taken to address such a case may be one or more of the following:

1) implementing additional modifications, 2) refining the analytical estimates, or 3) requesting that exceeding the guidelines be deemed acceptable in a new LAR.14 1,2 Develop formal training program for nonfire brigade personnel that Attachment A, 3.4.3(b)respond to a fire incident.15 1,2 Revise the QA Topical, as appropriate, to update the definition of QA 3 to match post NFPA 805 criteria.

QA Topical currently defines QA 3 as: "QA Condition 3 covers those systems, components, items, and services which are important to fire protection as defined in the Hazards Analysis for each station. The Hazards Analysis is in response to Appendix A of NRC Branch Technical Position APCSB 9.5-1." 16 1,2 Implementation items resulting from the feasibility evaluation include: Attachment G* Corrective Action to add equipment tags to the petcocks for the CA valves. These equipment numbers will be added to Fire Procedure, AP10lA155001045.

• Corrective Action to revise steps to Fire Procedure, AP10/A/5500/045 to add valve numbers (or descriptive nomenclature) as applicable to the individual steps for throttling the CA valves (valve to isolate air, bleed air).* Corrective Action to revise steps to Fire Procedure, AP/0/A/5500/045 to include requiring operators to obtain a climbing harness prior to throttling the CA valves locally.* Corrective Action to add steps to Fire Procedure Rev 4 Page S-11 Duke Energy Carolinas, LLCAtahetS-MdfctosndmpmnainIes Attachment S -Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section I Source APIOI/N55001045 to trip the NC pumps locally (if unable to trip from the control room).* Corrective Action to add performance of recovery action drills to Operator training.17 1, 2 Update station documentation to indicate requirements for interior floor Attachment A, 3.3.3 finishes.18 1, 2 Ensure procedures are provided for long-term alignments for makeup of 4.2.1.2 fuel oil, feedwater, and reactor coolant.19 1, 2 Evaluate the transient combustible control procedure for additional RAl PRA-1 5b controls in the identified fire areas to account for a larger transient fire heat release rate.Rev 4 Page S-12 Rev 4 Page S-12