NL-08-0138, Letter of Intent to Adopt the 2001 Edition of NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants
| ML080450434 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/14/2008 |
| From: | David Jones Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-0138 | |
| Download: ML080450434 (2) | |
Text
David H. Jones Southefn Nucleaf Vice President Opefating Company, Inc.
Engineering 40 Invemess Center Parkway Birmingham, Alabama 35242 Tel 205.992.5984 Fax 205.992.0341 SOUTHEuA February 14, 2008 COMPANY Energy to Serve YOurWorld'"
Docket Nos.: 50-348 NL-08-0138 50-364 U. S. Nuclear RegUlatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Units 1 and 2 Letter of Intent to Adopt the 2001 Edition of NFPA 805 "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" Ladies and Gentlemen:
This letter serves to inform the NRC of Southern Nuclear Operating Company's (SNC) intent to adopt the 2001 edition of National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" in accordance with 10 CFR 50.48(c) for Farley Nuclear Plant Units 1 and 2.
The transition to the performance-based standard for fire protection will commence in February 2008 and it is expected to take approximately thirty-six months to develop the license amendment request.
SNC requests enforcement discretion for thirty-six months, allowable as indicated in the April 18, 2006 Federal Register Notice (71 FR 19905). The Federal Register Notice described the NRC Interim Enforcement Discretion 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 will be in effect beginning from the date of the licensee's letter of intent. The Enforcement Policy also provides for extension of the discretion period if adequate justification is provided.
The Farley Nuclear Plant NFPA 805 transition process consists of three phases:
Phase 1 - Preliminary Assessment of the Fire Protection Program
- Technical and regulatory assessments performed to determine the feasibility and practicality of performing the transition. This phase is now complete.
- u. S. Nuclear Regulatory Commission Log: NL-08-0138 Page 2 Phase 2 - Reviews and Engineering Analysis
- Completion of the Fire Protection Probabilistic Risk Assessment (PRA)
- Fundamental Fire Protection Program and Design Elements Review
- Nuclear Safety Performance Criteria Transition Review
- Non-Power Operational Mode Transition Review
- Radiological Release Transition Review
- Change Evaluations
- License Amendment Request Phase 3 -Implementation
- Program Documentation
- Configuration Control
- Monitoring The process will be considered complete upon receipt of the License Amendment authorizing the transition to NFPA 805.
Because the transition to the NFPA 805 performance-based standard is a voluntary initiative, this correspondence contains no regulatory commitments.
If you have any questions, please advise.
D. H. Jane Vice Presi ent - Engineering DHJ/JLS/phr cc:
Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. H. Jones, Vice President - Engineering RTYPE: CFA04.054; LC# 14718 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Acting Regional Administrator Ms. K. R. Cotton, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley