ML080920132
| ML080920132 | |
| Person / Time | |
|---|---|
| Site: | San Onofre |
| Issue date: | 03/28/2008 |
| From: | Ridenoure R Edison International Co, Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NFPA 805 | |
| Download: ML080920132 (2) | |
Text
SOUTHERN CALIFORNIA Ross T. Ridenoure EDISONI° VP and Site Manager V 1 EuDISO -
San Onofre Nuclear Generating Station An EDISON INTERNATIONALI Company March 28, 2008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
Docket Nos. 50-361 and 50-362 Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition San Onofre Nuclear Generating Station, Units 2 and 3
Dear Sir or Madam:
This letter is to confirm that Southern California Edison (SCE) intends to adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, in accordance with 10 CFR 50.48(c) for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.
SONGS is beginning the transition to the performance-based standard for fire protection in March, 2008. It is expected to take approximately thirty-six months to develop the license amendment request.
The SONGS NFPA 805 transition consists of three phases:
Phase 1 - Preliminary Assessment of the Fire Protection Program
- Assessment to determine the scope of activities and resources needed to perform the transition Phase 2 - Reviews and Engineering Analysis
" Fire Probabilistic Risk Assessment Fundamental Fire Protection Program and Design Elements Assessment Radioactive Release Assessment Nuclear Safety Capability Assessment
" Non-Power Operational Modes Assessment
" Development of Change Evaluations and Transition Report Submittal of License Amendment Request Mail Drop D45 P.O. Box 12846 San Clemente, CA 92672 949-368-6255 PAX 86255 Fax: 949-368-6183 Ross.Ridenoure@sce.com
Document Control Desk March 28, 2008 Phase 3 - Implementation Completion of Program Documentation Changes The process will be considered complete upon receipt of the License Amendment authorizing the transition to NFPA 805.
The NRC Interim Enforcement Discretion Policy (71 FR 19905, April 18, 2006, and Regulatory Guide 1.205, May 2006) 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. The Enforcement Policy also provides for extension of the discretion period if adequate justification is provided.
For additional information, please contact Ms. Linda T. Conklin at 949-368-9443.
Sincerely, cc:
E. E. Collins, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 & 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 & 3