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Category:Letter type:L
MONTHYEARL-24-017, 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative2024-01-24024 January 2024 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative L-23-207, License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2024-01-24024 January 2024 License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs L-23-267, Submittal of Discharge Monitoring Report (Npdes), Permit No. PA00256152023-12-18018 December 2023 Submittal of Discharge Monitoring Report (Npdes), Permit No. PA0025615 L-23-171, CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency2023-12-0808 December 2023 CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-244, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-229, Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports2023-11-29029 November 2023 Request for Additional Information Regarding the Spring 2023 Generic Letter 95-05 Voltage-Based Alternate Repair Criteria and Steam Generator F-Star Reports L-23-247, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-11-17017 November 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-238, Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 202023-11-10010 November 2023 Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 20 L-23-052, Submittal of the Updated Safety Analysis Report, Revision 232023-10-27027 October 2023 Submittal of the Updated Safety Analysis Report, Revision 23 L-23-227, Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 20232023-10-20020 October 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 for Third Quarter 2023 L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan L-23-208, Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA00256152023-09-14014 September 2023 Submittal of Discharge Monitoring Report Cnpdes), Permit No. PA0025615 L-23-167, Twenty-Third Refueling Outage Inservice Inspection Summary Report2023-09-13013 September 2023 Twenty-Third Refueling Outage Inservice Inspection Summary Report L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-206, Ohio National Pollutant Discharge Elimination System (NPDES) Permit 3IB00016 MD2023-09-12012 September 2023 Ohio National Pollutant Discharge Elimination System (NPDES) Permit 3IB00016 MD L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-001, License Amendment Request to Remove the Table of Contents from the Technical Specifications2023-08-0707 August 2023 License Amendment Request to Remove the Table of Contents from the Technical Specifications L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program L-23-174, 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative2023-07-19019 July 2023 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative L-23-179, Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA00256152023-07-18018 July 2023 Submittal of Discharge Monitoring Report, (NPDES) Permit No. PA0025615 L-23-146, License Renewal Application for the Perry Nuclear Power Plant2023-07-0303 July 2023 License Renewal Application for the Perry Nuclear Power Plant L-23-165, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-06-26026 June 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-051, Plan, Nineteenth Inservice Inspection Summary Report2023-06-22022 June 2023 Plan, Nineteenth Inservice Inspection Summary Report L-23-050, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-22022 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-139, Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report2023-06-13013 June 2023 Response to Request for Additional Information Regarding Fall 2022 180-Day Steam Generator Tube Inspection Report L-22-249, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A Revision 2, Change TS 3.8.1. AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener2023-06-0505 June 2023 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A Revision 2, Change TS 3.8.1. AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-055, Submittal of the Updated Final Safety Analysis Report, Revision 342023-05-23023 May 2023 Submittal of the Updated Final Safety Analysis Report, Revision 34 L-23-134, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-23023 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-137, Discharge Monitoring Report (NPDES) Permit No. PA00256152023-05-18018 May 2023 Discharge Monitoring Report (NPDES) Permit No. PA0025615 L-23-125, Cycle 24 Core Operating Limits Report2023-05-17017 May 2023 Cycle 24 Core Operating Limits Report L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection L-23-132, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-10010 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations L-23-129, Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations2023-05-0505 May 2023 Response to Request for Additional Information for 10 CFR 50.55a Request 2-TYP-4-RV-06 for Alternative Repair Methods for Reactor Pressure Vessel Head Penetrations L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 L-23-115, Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological2023-04-27027 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report, 2022 Annual Radiological Environmental Operating Report, and 2022 Annual Environmental Operating Report (Non-Radiological L-23-121, Annual Radiological Effluent Release Report2023-04-26026 April 2023 Annual Radiological Effluent Release Report L-23-122, Annual Radiological Environmental Operating Report2023-04-26026 April 2023 Annual Radiological Environmental Operating Report L-23-126, Discharge Monitoring Report (Npdes), Permit No. PA00256152023-04-22022 April 2023 Discharge Monitoring Report (Npdes), Permit No. PA0025615 L-23-053, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-04-14014 April 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-049, Core Operating Limits Report for Operating Cycle 202023-03-30030 March 2023 Core Operating Limits Report for Operating Cycle 20 L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-058, 180-Day Steam Generator Tube Inspection Report2023-03-27027 March 2023 180-Day Steam Generator Tube Inspection Report 2024-01-24
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FENOC 76 South Main Street FirstEnergy Nuclear Operating Company Akron, Ohio 44308 Gary R. Leidich 330-384-5770 President and Chief Nuclear Officer Fax: 330-384-5669 December 22, 2005 BV-No. L-05-200 DB-Serial Number 3216 PY-CEI/NRR-2926L U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit Nos. 1 & 2, Docket Nos. 50-334 & 50-412 Davis-Besse Nuclear Power Station, Unit No. 1, Docket No. 50-346 Perry Nuclear Power Plant, Unit No. 1, Docket No. 50-440 Information Regarding Proposed Adoption of NFPA 805 "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" The NRC has encouraged licensees to consider the benefits of NFPA 805 (Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition) and transfer the plant's Fire Protection Program to this standard in accordance with 10 CFR 50.48(c). FirstEnergy Nuclear Operating Company (FENOC) recognizes that the overall benefit of NFPA 805 is to ensure optimum focus on enhancing plant safety through the use of performance based standards and risk informed decision-making techniques. This letter provides FENOC's intentions regarding the adoption of NFPA 805 as the regulatory basis for Fire Protection Programs at the Beaver Valley Power Station (BVPS), Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP).
The transition to the performance-based standard for fire protection will be implemented as a fleet initiative, and will commence in a staggered fashion beginning with BVPS Unit Nos. 1 & 2. The current timetable for the proposed initiative provides three years for full implementation activities at each FENOC site, which include the following:
Phase I - Preliminary assessment of the Fire Protection Program:
- Technical and regulatory assessments performed to determine the feasibility and practicality of performing the transition Phase II - Reviews and Engineering Analysis:
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BV-No. L-05-200 DB-Serial Number 3216 PY-CEI/NRR-2926L Information Regarding Proposed Adoption of NFPA 805 "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" Page 2
- Nuclear Safety Performance Criteria Transition review
- Non-Power Operational Mode Transition review
- Radiological Release Transition review
- License Amendment Requ4est Phase III - Implementation:
- Monitoring The process for each site will be considered complete upon implementation of the License Amendment authorizing the transition to 10CFR 50.48(c). The approach described above is subject to change as physical modifications or changes to the Fire Protection Program are determined to be necessary. At all three FENOC sites, newly identified issues involving the potential for fire induced circuit failures will be addressed by applying NFPA-805 risk informed performance based analytical methods to determine appropriate corrective action. This phased and extended transition approach is considered the most appropriate for the following reasons:
- 1) Based on past experience, there is a strong desire to maintain consistency between FENOC sites. If sufficient personnel (either in-house or contractor) are not available to perform the multiple plant transitions in parallel, there is added burden to maintain the analysis consistency and quality.
- 2) Due to developing interpretation of regulations and standards, noncompliances may be identified as the pilot plants and the FENOC plants transition to 10CFR 50.48(c). Thorough investigation and determination of the extent of condition across the FENOC fleet will ensure the most effective application of the new compliance standard.
- 3) Development of Probabilistic Risk Assessment (PRA) for fire protection application, necessary for the transition to a performance-based fire protection program, is expected to take approximately eighteen to twenty-four months.
Therefore, the PRA being developed for the change analysis will not be available until approximately two years after the start of the transition.
- 4) Within FENOC, and in the nuclear industry in general, there is a limited availability of Fire Protection experts needed to support the transition to 10CFR 50.48(c).
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BV-No. L-05-200 DB-Serial Number 3216 PY-CEI/NRR-2926L Information Regarding Proposed Adoption of NFPA 805 "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" Page 3 The NRC Interim Enforcement Policy (69 FR 33684, June 16, 2004, and 70 FR 2662, January 14, 2005) established NRC policy regarding enforcement discretion for certain noncompliances related to fire protection programs and the transition to 10 CFR 50.48(c).
As outlined in the Enforcement Policy, enforcement discretion begins with the licensee's letter of intent. FENOC understands that this letter of intent initiates a window of enforcement discretion for BVPS Unit Nos. 1 & 2, as appropriate, based on the conditions established in the Enforcement Policy. As a follow-up, FENOC will submit implementation schedules for DBNPS and PNPP to establish the beginning of their respective enforcement discretion windows. The Enforcement Policy also provides for extension of the discretion period if adequate justification is provided. Given the challenges resulting in the extended implementation approach described above, it is anticipated that extension of the enforcement discretion period will need to be considered.
Since the transition to the NFPA 805 performance-based standard for fire protection is a voluntary initiative, this correspondence contains no regulatory commitments. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager - FENOC Fleet Licensing, at (330) 315-7243.
Sincerely, k H o cc: NRC Project Manager - Beaver Valley Power Station NRC Project Manager - Davis Besse Nuclear Power Station NRC Project Manager - Perry Nuclear Power Plant NRC Resident Inspector - Beaver Valley Power Station NRC Resident Inspector - Davis Besse Nuclear Power Station NRC Resident Inspector - Perry Nuclear Power Plant NRC Regional Administrator - Region I NRC Regional Administrator - Region III Ms. N. Dragani, Executive Director, OEMA (NRC Liaison)
Mr. D. A. Allaro, Director BRP/DEP Mr. L. E. Ryan, BRP/DEP