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Summary of Mtg. with Progress Energy Carolinas, and Duke Energy Carolinas to Discuss the LARs to Transition the Shearon Harris and Oconee Nuclear Plants to National Fire Protection Association Standard NFPA-805
	ML082060536
Person / Time
Site:	Oconee, Harris
Issue date:	08/07/2008
From:	Vaaler M; NRC/NRR/ADRO/DORL/LPLII-2
To:	;
	Vaaler, Marlayna, NRO/DNRL 415-3178
Shared Package
ML082060554	List: ML082060536; ML082070391;
References
	TAC MD8807, TAC MD8832, TAC MD8833, TAC MD8834
	Download: ML082060536 (5)
	v • d • e

August 7, 2008 LICENSEES:

Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc.

Duke Energy Carolinas, Inc.

FACILITIES:

Shearon Harris Nuclear Plant, Unit 1 Oconee Nuclear Station, Units 1, 2, and 3

SUBJECT:

SUMMARY

OF JULY 17, 2008, MEETING WITH PROGRESS ENERGY CAROLINAS, INC., AND DUKE ENERGY CAROLINAS, LLC, TO DISCUSS THE MAY 29 AND 30, 2008, LICENSE AMENDMENT REQUESTS TO TRANSITION THE SHEARON HARRIS NUCLEAR PLANT, UNIT 1 AND THE OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3, TO NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, PERFORMANCE BASED STANDARD FOR FIRE PROTECTION (TAC NOS. MD8807, MD8832, MD8833, AND MD8834)

On July 17, 2008, the U.S. Nuclear Regulatory Commission (NRC) staff met with representatives of Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc., (Progress Energy) and Duke Energy Carolinas, Inc., (Duke Energy) to discuss the May 29 and 30, 2008, license amendment requests (LARs) to transition the fire protection programs at the Shearon Harris Nuclear Plant, Unit 1 (Harris) and the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee) to risk-informed, performance-based fire protection programs in accordance with Title 10 of the Code of Federal Regulations, Section 50.48(c) and National Fire Protection Association (NFPA) Standard NFPA-805.

NFPA-805 allows the use of performance-based methods, such as fire modeling, and risk-informed methods, such as Fire Probabilistic Risk Assessment (Fire PRA), to demonstrate compliance with the nuclear safety performance criteria. The meeting was held at NRC Headquarters, Two White Flint North, 11545 Rockville Pike, Rockville, MD.

The Progress and Duke Energy representatives provided the staff with an overview of the LARs, including a discussion of the insights and lessons learned during the LAR preparation process, an outline of open items and challenges still to be faced, as well as highlighting the benefits the plants foresee from transition to NFPA-805.

Progress Energy noted the following points of interest regarding the Harris LAR submittal, which can be accessed in the Agencywide Documents Access and Management System (ADAMS) at Accession Nos. ML081560641 (cover letter, Enclosures 1 and 2) and ML08184706 (remainder of publically available LAR):

The development of the Fire PRA represents a substantial amount (approximetely 50 percent) of the total manhours expended to develop the LAR.

During the LAR preparation process, the Harris internal events PRA was also significantly reworked and updated.

Harris is planning to complete implementation of the programmatic NFPA-805 changes within 3 to 4 months of issuance of the NRC staffs safety evaluation report (SER), with all of the physical modifications completed by the end of 2010.

Duke Energy noted the following points of interest regarding the Oconee LAR submittal, which can be accessed in ADAMS at Accession Nos. ML081650475 (cover letter, Enclosure 1, and with Attachments A and B) and ML082041014 (remainder of public LAR):

Approximately 25 percent of the total manhours expended to develop the Oconee LAR were used to reconstitute cable paths and enter them into a tracking database.

Oconee is working to develop a generic Updated Final Safety Analysis Report section that licensees transitioning to NFPA-805 can use to adequately describe the program.

The LAR contains license conditions whose purpose is to ensure that the details to be approved in the future NRC SER are well understood by both the licensee and the staff.

Duke Energy sees a major benefit in transitioning to NFPA-805 for the older generation of nuclear plants, as the risk-informed approach is more conducive to assembling an all encompassing fire protection program for the older plant designs.

Additional observations on preparing the Oconee NFPA-805 LAR are included in the Duke Energy meeting presentation that is attached as Enclosure 3.

The NRC staff gave a presentation on the acceptance review process that the NFPA-805 LARs are currently undergoing, and discussed the overall review process that will take place over the next several months. Details of both processes are included in the presentation in Enclosure 4.

Members of the public were present and made several opposing comments related to the Harris transition to NFPA-805, claiming that staff and licensee resources are still unable to meet the demands associated with developing and implemeting the new fire protection programs.

The meeting agenda is attached as Enclosure 1, a list of meeting attendees is attached as, and the meeting handouts are attached as Enclosures 3 and 4. Please direct any inquiries to Marlayna Vaaler at 301-415-3178, or marlayna.vaaler@nrc.gov.

Sincerely,

/RA/

Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-400, 50-269, 50-270, and 50-287

Enclosures:

As stated cc w/enclosures: See next page