L-HU-05-023, Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants. 2001 Edition

Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants. 2001 Edition

ML053460342
Person / Time
Site:	Monticello, Palisades, Point Beach, Prairie Island, Duane Arnold
Issue date:	11/30/2005
From:	Domonique Malone Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
+sispmjr200601, L-HU-05-023
Download: ML053460342 (3)

Text

N Committedto N&ar ExcelIe Nudear Management Company, LLC November 30,2005 L-HU-05-023 10 CFR 50.48 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 205550001 Monticello Nuclear Generating Plant Duane Arnold Energy Center Docket 50-263 Dockets 50-331 and 72-32 License No. DPR-22 License No. DPR-49 Point Beach Nuclear Plant, Units 1 and 2 Palisades Nuclear Plant Dockets 50-266, 50-301 and 72-5 Dockets 50-255 and 72-7 License Nos. DPR-24 and DPR-27 License No. DPR-20 Prairie Island Nuclear Generating Plant, Units 1 and 2

'Dockets 50-282, 50-306 and 72-10 License Nos. DPR-42 and DPR-60 Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805. "Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants. 2001 Edition This letter serves to inform you of our intent to adopt NFPA 805 (Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition) in accordance with 10 CFR 50.48(c) for the following stations:

Point Beach Nuclear Plant, Units 1 and 2 Monticello Nuclear Generating Plant Palisades Nuclear Power Plant e Prairie Island Nuclear Generating Plant, Units 'I and 2 o Duane Arnold Energy Center The transition to the performancebased standard for fire protection is being implemented as a fleet project and begins for all plants with this letter of intent. This transition will be completed in two phases, an initial design phase, followed by a staggered implementation phase. This transition method has been selected due to the industry identified uncertainties related to the following issues:

Uncertainty in the availability of resources and methodology to perform the fire probabilistic risk analysis required for the transition.

Document Control Desk Page 2 a Potential need for modifications to comply with Chapter 3 of NFPA 805-2001.

0 Uncertainty in the resources and methods which will be required to evaluate operator recovery actions associated with the transition.

The initial design phase of the transition will monitor the NFPA 805 pilot plants, and perform technical and regulatory assessments to determine the feasibility and practicality of performing the transition. In addition, during this time period, outstanding issues related to compliance with the current Appendix R, Section II1.G requirements will be evaluated for risk significance. If these modifications are determined to be non-risk-significant, these modifications may be deferred pending completion of the performance based evaluations during the implementation phase.

Pending the results of the initial design phase, NMC intends to transition the stations on a staggered basis, with PBNP being the first to begin the implementation process in the third quarter of 2007. MNGP should be the next to transition to NFPA 805, followed by PNPP, PINGP, and DAEC. This schedule is proposed due to the extensive resource requirements identified by the pilot transition projects. The initial implementation schedule is as follows:

Point Beach Nuclear Plant Units 1 and 2 - Implementationphase start 7/2/2007; complete 7/2/2010.

0 Monticello Nuclear Generating Plant - Implementation phase start 1/1/2010; complete 12/30/2012.

Palisades Nuclear Power plant - lmplementation phase start 1/3/2012; complete 7/3/20 13.

Prairie Island Nuclear Generating Plant Units 1 and 2 - Implementation phase start 7/4/2013; complete 71112016.

0 Duane Arnold Energy Center - lmplementation schedule to be established following completion of pending plant license transfer.

The implementation phase for each station will consist of the following:

Completion of Fire PRA Nuclear Safety Performance Criteria Transition review Non-Power Operational Mode Transition review Radiological Release Transition review Change Evaluations License Amendment Request Program Documentation Configuration Control Process Development Monitoring Process Development

Document Control Desk Page 3 The transition will be considered complete upon receipt of the License Amendment authorizing the transition to NFPA 805.

This proposed schedule is subject to change based on the progress and results of the pilot plant transitions. In addition, as each plant determines what physical modifications or changes to the fire protection program will be required to comply with NFPA 805, further schedule changes may be required. These changes may include changes in the station implementation sequence. An updated schedule will accompany the LAR that each plant will submit as required by 10 CFR 50.48(c)(3)(i).

The NRC interim Enforcement Policy (69 FR 33684, June 16, 2004) provides guidelines for enforcement discretion for identified non-compliances. Those non-compliances must be entered into the licensee's Corrective Action Program, must not be associated with findings that the Reactor Oversight Process Significance Determination Process (SDP) would evaluate as Red, or would not be categorized at Severity Level 1, and appropriate compensatory measures have been taken (non-safety significant). As outlined in the Enforcement Policy, enforcement discretion begins with the licensee's letter of intent.

This letter contains no new commitments and no revisions to existing commitments.

Daniel J. Malone Vice President, Nuclear Operations'Support Nuclear Management Company, LLC cc: Regional Administrator, USNRC, Region l l I NRR Projed Manager, Monticello Nuclear Generating Plant, Point Beach Nuclear Plant, Prairie Island Nuclear Generating Plant, Duane Arnold Energy Center, Palisades Nuclear Plant, USNRC NRC Resident Inspector, Monticello Nuclear Generating Plant, Point Beach Nuclear Plant, Prairie Island Nuclear Generating Plant, Duane Arnold Energy Center, Palisades Nuclear Plant, USNRC