ML063520409
| ML063520409 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 01/19/2007 |
| From: | John Lubinski Plant Licensing Branch III-2 |
| To: | Archie J South Carolina Electric & Gas Co |
| Dinh T, NRR/DRA, 415-2149 | |
| References | |
| RIS-05-007 | |
| Download: ML063520409 (3) | |
See also: RIS 2005-07
Text
January 19, 2007
Mr. Jeffrey B. Archie
Vice President, Nuclear Operations
Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsville, South Carolina 29065
SUBJECT:
NRC RESPONSE TO LETTER OF INTENT TO ADOPT TITLE 10 OF
THE CODE OF FEDERAL REGULATIONS, PART 50, SECTION 50.48(c) FOR
VIRGIL C. SUMMER NUCLEAR STATION
Dear Mr. Archie:
I am writing in response to your letter dated October 19, 2006 (Agencywide Documents Access
and Management System Accession No. ML062990453), in which you informed the U.S.
Nuclear Regulatory Commission (NRC) that South Carolina Electric & Gas Company intends to
adopt National Fire Protection Association (NFPA) Standard 805, NFPA 805,
Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generation
Plants, 2001 Edition, pursuant to Section 50.48(c) of Part 50 of Title 10 of the Code of Federal
Regulations, at the Virgil C. Summer Nuclear Station (VCSNS).
In your October 19 letter, you informed us that the transition to the performance-based standard
for fire protection at VCSNS is expected to commence in January of 2007 and be completed in
approximately 36 months. The transition process will proceed in three phases:
Phase I - Preliminary Assessment of the Fire Protection Program
Phase II - Reviews and Engineering Analysis
Phase III - Implementation
The process is considered to be completed upon receipt of the licensing amendment
authorizing the transition to NFPA 805.
On April 18, 2006, the NRC published in the Federal Register (71 FR 19905) a revision to its
enforcement policy extending the NFPA 805 transition discretion period from 24 to 36 months.
Therefore, a 36-month discretion period for VCSNS is granted. The NRC considers the
discretion period for VCSNS to begin on October 19, 2006, and will expire on October 19, 2009.
The enforcement discretion period, however, will continue while the NRC staff is reviewing your
submitted request for the license amendment.
Please note that in order to receive enforcement discretion, you must: (a) evaluate the risk
significance of all noncompliances to assure that they do not constitute Red (or a Severity
Level I) findings under the NRCs Reactor Oversight Process, (b) enter them into your
corrective action program, and (c) implement and maintain appropriate compensatory
J. Archie
-2-
measures, until the NRC staff approves your license amendment request and issues its safety
evaluation. You should refer to NRC Regulatory Issue Summary 2005-07, Compensatory
Measures to Satisfy the Fire Protection Program Requirements, for additional NRC staff
guidance on appropriate compensatory measures. In response to requests made by a number
of licensees, which are not pilots for NFPA 805, for meetings with the NRC staff to discuss their
transition issues, the NRC staff plans to hold periodic workshops on NFPA 805 implementation
issues at the regional offices or onsite at units transitioning to the new standard. The staff will
inform the nuclear plant licensees of the schedules of these workshops.
If you have any questions regarding this matter, please contact Robert E. Martin, Project
Manager, at (301) 415-1493.
Sincerely,
/RA/
John W. Lubinski, Acting Director
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-395
NRR-106
OFFICE
DRA/AFPB
LPLII-1/PM
LPLII-1/LA
DRA/AFPB/BC
OE/BC
NAME
TDinh
RMartin
RSola
SWeerakkody
DSolorio
DATE
12/20/06
01/17/07
01/05/07
01/09/07
01/12/07
OFFICE
LPLII-1/BC
NRR/DORL/D(A)
NAME
EMarinos
JLubinski
DATE
01/17/07
01/19/07