ENOC-08-00042, Entergy Operations, Inc. - Request for Extension of Discretion for the Interim Enforcement Policy for Fire Protection Issues on 10CFR50.48(c), National Fire Protection Association Standard NFPA 805
| ML082540402 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Arkansas Nuclear, Waterford  |
| Issue date: | 08/28/2008 |
| From: | Ford B Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ENOC-08-00042 | |
| Download: ML082540402 (15) | |
Text
SiEntergy Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5516 Bryan S. Ford Manager Nuclear Safety & Licensing 1 0CFR50.48 ENOC-08-00042 August 28, 2008 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Request for Extension of Discretion for the Interim Enforcement Policy For Fire Protection Issues on 10CFR50.48(c), National Fire Protection Association Standard NFPA 805 Arkansas Nuclear One Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38
Dear Sir or Madam:
In accordance with COMSECY-08-0022 and as approved by the NRC Commission on August 19, 2008, Entergy Operations, Inc. and Entergy Nuclear Operations, Inc.
(Entergy) request that the period of subject enforcement discretion be extended until NRC's approval of the License Amendment Requests (LARs) to be submitted for the following Entergy units: Arkansas Nuclear One, Unit 1 (ANO-1), Arkansas Nuclear One, Unit 2 (ANO-2), Palisades Nuclear Plant (Palisades), and Waterford 3 Steam Electric Station (Waterford 3).
As outlined below, Entergy plans to submit the LARs on a staggered basis for each site.
Each Entergy site Isubmitted a letter of intent to adopt National Fire Protection Association (NFPA)I 805 (Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition) in accordance with 10CFR50.48(c). In accordance with Federal Register Notice 71 FR 19905 dated April 18, 2006 (ML060940409), the NRC subsequently granted three years of enforcement discretion for the sites as outlined below.
Entergy submitted a letter of intent for ANO-1 and ANO-2 to the NRC on November 2, 2005 (ML053140128).
By letter dated January 31, 2006 (ML05300434), the NRC acknowledged recei )t of the letter of intent, but did not specifically grant a three year ItDNO
ENOC-08-00042 Page 2 of 3 enforcement discretion period requested in the letter of intent. The NRC specifically granted a third year of enforcement discretion for ANO-1 and ANO-2 by letter dated August 18, 2006 (ML06202058).
Nuclear Management Company, LLC (NMC), the former license holder, submitted a letter of intent for Palisades to the NRC on November 30, 2005 (ML053460342).
By letter dated March 14, 2006 (ML060730265), NMC submitted a supplement which requested an extension of the enforcement discretion period to 48 months. The NRC granted a third year of enforcement discretion by Federal Register Notice 71 FR 19905 dated April 18, 2006 (ML060940409). Consistent with the Federal Register Notice, the NRC did not allow the request for discretion past 36 months and specifically granted a third year of enforcement discretion for Palisades by letter dated September 7, 2006 (ML061500035).
Entergy submitted a letter of intent for Waterford 3 to the NRC on December 21, 2005 (ML060030453) and requested an enforcement discretion window of 42 months. The NRC did not allow the request for discretion past 36 months and specifically granted a third year of enforcement discretion for Waterford 3 that will expire on December 31, 2008, by letter dated April 13, 2006 (ML061000040).
As identified during the NFPA 805 Pilot Plant effort, certain resources required to support selected areas in preparing a basis for the license transition are limited. There is a desire to maintain consistency among the Entergy plants that can only be facilitated by allowing some portions of the transition to be performed in series. To successfully complete this process Entergy plans to levelize the work between the various plants within our fleet to ensure adequate resources, both internally and externally, are available. This approach will benefit both the industry and NRC by not overwhelming the limited resources and is a key component for the length of this extension request.
Entergy plans to submit the LARs on the following staggered schedule for the sites:
ANO-2 6 Months after the Safety Evaluation is issued for the second pilot plant Waterford 3 9 Months after the Safety Evaluation is issued for the second pilot plant ANO-1 12 Months after the Safety Evaluation is issued for the second pilot plant Palisades 19 Months after the Safety Evaluation is issued for the second pilot plant Based upon the demonstrated substantial progress toward completion of NFPA 805 transition as discussed in the attachments to this letter, Entergy requests that enforcement discretion be extended until the LAR is submitted for each site as described above and to continue until the final NRC disposition of the LAR.
There are no new commitments contained in this submittal.
If you have any questions concerning this submittal, please contact Dale James at 479-858-4619.
Sincerely, BSF/slp
ENOC-08-00042 Page 3 of 3 Attachments:
- 1.
Progress on NFPA 805 Transitions for Arkansas Nuclear One, Unit 1
- 2.
Progress on NFPA 805 Transitions for Arkansas Nuclear One, Unit 2
- 3.
Progress on NFPA 805 Transitions for Palisades Nuclear Plant
- 4.
Progress on NFPA 805 Transitions for Waterford 3 Steam Electric Station cc:
Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Mr. James Caldwell Regional Administrator U. S. Nuclear Regulatory Commission Region III Suite 210 2443 Warrenville Road Lisle, IL 60532-4352 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 NRC Senior Resident Inspector Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 NRC Senior Resident Inspector Waterford 3 - W-MSB 17265 Killona, LA Killona, LA 70057-3093 Cynthia A. Carpenter Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
Attachment I ENOC-08-00042 Progress on NFPA 805 Transitions for:
Arkansas Nuclear One, Unit 1 to ENOC-08-00042 Page 1 of 2 COMSECY-08-0022 requested information from licensees on demonstrated progress toward completion of National Fire Protection Association (NFPA) 805 transition, as a condition of granting an extension of enforcement discretion. Entergy Operations, Inc.
(Entergy) has made substantial progress in the Arkansas Nuclear One, Unit 1 (ANO-1)
NFPA 805 transition effort.
Entergy has participated in the Nuclear Energy Institute (NEI) NFPA 805 Task Force and Fire Probabilistic Risk Assessment (PRA) Task Forces.
Entergy also participated in the Frequently Asked Questions (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for ANO-1 associated with NFPA 805 transition. The "LAR/TR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports (TR) that document the results of the NFPA 805 TRs. As shown in the table below, ANO-1 has demonstrated substantial progress in the NFPA 805 transition process.
ILARITR Approximate Current LAR/R Toic Aproxmate Milestone Reference Topic
% Complete Completion N/A Safe Shutdown Analysis Update 100%
Complete (Pre-Requisite Task) 4.1 Fundamental FP Program 60%1 3rd Quarter 2009 Attachment A Elements and Minimum Design Requirements (Table B-i) 4.2.1 Nuclear Safety Capability 80%1 3rd Quarter 2009 Attachment B Assessment - Methodology (Table B-2) 4.2.2 Nuclear Safety Capability 60%1 1st Quarter 2010 Attachment C Assessment - Fire Area - by -
Fire Area Review (Table B-3) 4.32 Non-Power Operational Modes 0%
3ra Quarter 2009 Attachment D (Table F-1) 4.42 Radioactive Release 75%
3r( Quarter 2009 Attachment E (Table G-1) 4.5.1 Fire PRA Development 40%
1st Quarter 2010
'Completion of these tables contain open items that may (changqe evaluation) require fire PRA to close 2Although required for transition to NFPA 805, this is a new requirement and does not require enforcement discretion Physical Modifications While physical modifications may be identified as part of the NFPA 805 transition effort, no physical modifications to the plant have been performed specifically for that purpose since the Entergy decision to transition ANO-1 to NFPA 805. Entergy plans to identify to ENOC-08-00042 Page 2 of 2 any required modifications during the NFPA 805 transition project in the LAR submittal letter and that letter will provide a schedule and commitments for any such modifications. However, while not specifically in response to NFPA 805 analysis, ANO-1 has completed physical modifications to the facility to minimize the number of manual actions based on their complexity or time critical nature. These modifications will reduce overall fire risk and may have been required by the NFPA 805 transition process had they not been implemented.
NFPA 805 Monitoring Program COMSECY-08-0022 requested that as part of the status report for demonstrating substantial progress on the transition that the status of the NFPA 805 monitoring program be provided. The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort.
This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-0022 requested that additional information be compiled/documented on site and available for inspection/audit.
In accordance with NFPA 805 and the enforcement discretion provided, the fire protection related noncompliances associated with the conversion to NFPA 805 have been entered in the Entergy corrective action program and appropriate compensatory measures for those noncompliances have been implemented.
In accordance with COMSECY-08-0022, this information is available for onsite NRC audit/inspection.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such action comply with Regulatory Issue Summary (RIS) 2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements.
The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible.
The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort.
The feasibility review can not be completed until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for certain actions. Some of this effort is tied to the completion.of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants efforts.
ENOC-08-00042 Progress on NFPA 805 Transitions for:
Arkansas Nuclear One, Unit 2 to ENOC-08-00042 Page 1 of 2 COMSECY-08-0022 requested information from licensees on demonstrated progress toward completion of National Fire Protection Association (NFPA) 805 transition, as a condition of granting an extension of enforcement discretion. Entergy Operations, Inc.
(Entergy) has made substantial progress in the Arkansas Nuclear One, Unit 2 (ANO-2)
NFPA 805 transition effort.
Entergy has participated in the Nuclear Energy Institute (NEI) NFPA 805 Task Force and Fire Probabilistic Risk Assessment (PRA) Task Forces.
Entergy also participated in the Frequently Asked Questions (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for ANO-2 associated with NFPA 805 transition. The "LAR/TR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports (TR) that document the results of the NFPA 805 TRs. As shown in the table below, ANO-2 has demonstrated substantial progress in the NFPA 805 transition process.
Current LAR/TR Approximate Milestone Reference Topic
% Complete Completion N/A Safe Shutdown Analysis Update 100%
Complete (Pre-Requisite Task) 4.1 Fundamental FP Program 60%1 3rd Quarter 2009 Attachment A Elements and Minimum Design Requirements (Table B-i) 4.2.1 Nuclear Safety Capability 80%1 3rd Quarter 2009 Attachment B Assessment - Methodology (Table B-2) 4.2.2 Nuclear Safety Capability 80%'
3rd Quarter 2009 Attachment C Assessment - Fire Area - by -
Fire Area Review (Table B-3) 4.32 Non-Power Operational Modes 0%
3rd Quarter 2009 Attachment D (Table F-i) 4.42 Radioactive Release 75%
3rd Quarter 2009 Attachment E (Table G-1) 4.5.1 Fire PRA Development 70%
3rd Quarter 2009
'Completion of these tables contain open items that may (change evaluation) require fire PRA to close 2Although required for transition to NFPA 805, this is a new requirement and does not require enforcement discretion Physical Modifications While physical modifications may be identified as part of the NFPA 805 transition effort, no physical modifications to the plant have been performed specifically for that purpose since the Entergy decision to transition ANO-2 to NFPA 805. Entergy plans to identify any required modifications during the NFPA 805 transition project in the LAR submittal to ENOC-08-00042 Page 2 of 2 letter and that letter will provide a schedule and commitments for any such modifications. However, while not specifically in response to NFPA 805 analysis, ANO-2 has completed physical modifications to the facility to minimize the number of manual actions based on their complexity or time critical nature. These modifications will reduce overall fire risk and may have been required by the NFPA 805 transition process had they not been implemented.
NFPA 805 Monitoring Program COMSECY-08-0022 requested that as part of the status report for demonstrating substantial progress on the transition that the status of the NFPA 805 monitoring program be provided. The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort.
This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-0022 requested that additional information be compiled/documented on site and available for inspection/audit.
In accordance with NFPA 805 and the enforcement discretion provided, the fire protection related noncompliances associated with the conversion to NFPA 805 have been entered in the Entergy corrective action program and appropriate compensatory measures for those noncompliances have been implemented.
In accordance with COMSECY-08-0022, this information is available for onsite NRC audit/inspection.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such action comply with Regulatory Issue Summary (RIS) 2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements.
The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible.
The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort. The feasibility review can not be completed until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for certain actions. Some of this effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants efforts.
ENOC-08-00042 Progress on NFPA 805 Transitions for:
Palisades Nuclear Plant to ENOC-08-00042 Page 1 of 2 COMSECY-08-0022 requested information from licensees on demonstrated progress toward completion of National Fire Protection Association (NFPA) 805 transition, as a condition of granting an extension of enforcement discretion.
Entergy Nuclear Operations, Inc. (Entergy) has made substantial progress in the Palisades Nuclear Plant (Palisades) NFPA 805 transition effort. Entergy has participated in the Nuclear Energy Institute (NEI) NFPA 805 Task Force and Fire Probabilistic Risk Assessment (PRA)
Task Forces.
Entergy also participated in the Frequently Asked Questions (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for Palisades associated with NFPA 805 transition. The "LAR/TR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports (TR) that document the results of the NFPA 805 TRs.
As shown in the table below, Palisades substantial progress in the NFPA 805 transition process.
has demonstrated Current LAR/TR Approximate Milent Reference Topic
% Complete Completion 3 N/A Safe Shutdown Analysis Update N/A N/A (Pre-Requisite Task) 4.1 Fundamental FP Program 27%1 3 rd Quarter 2009 Attachment A Elements and Minimum Design Requirements (Table B-1) 4.2.1 Nuclear Safety Capability 67%1 1st Quarter 2009 Attachment B Assessment - Methodology (Table B-2) 4.2.2 Nuclear Safety Capability 10%1 4t' Quarter 2009 Attachment C Assessment - Fire Area - by - Fire Area Review (Table B-3) 4.32 Non-Power Operational Modes 12%
3rd Quarter 2009 Attachment D (Table F-1) 441 Radioactive Release 0%
2nd Quarter 2009 Attachment E (Table G-l) 4.5.1 Fire PRA Development 26%
3rd Quarter 2010 1Completion of these tables contain open items that may require fire (change evaluation)
PRA to close 2Although required for transition to NFPA 805, this is a new requirement and does not require enforcement discretion 3It should be noted that since the start of the NFPA 805 Transition Palisades has changed ownership from NMC to Entergy in April 2007 resulting in significant changes to the original NFPA 805 transition schedule.
to ENOC-08-00042 Page 2 of 2 Physical Modifications While physical modifications may be identified as part of the NFPA 805 transition effort, since the Entergy decision to transition Palisades to NFPA 805 there have been no physical modifications to the plant performed to address NFPA 805 fire protection issues.
Entergy plans to identify any required modifications during the NFPA 805 transition project in the LAR submittal letter and that letter will provide a schedule and commitments for any such modifications.
NFPA 805 Monitoring Program.
COMSECY-08-0022 requested that as part of the status report for demonstrating substantial progress on the transition that the status of the NFPA 805 monitoring program be provided. The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort.
This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-0022 requested that additional information be compiled/documented on site and available for inspection/audit.
In accordance with NFPA 805 and the enforcement discretion provided, the fire protection related noncompliances associated with the conversion to NFPA 805 have been entered in the Entergy corrective action program and appropriate compensatory measures for those noncompliances have been implemented.
In accordance with COMSECY-08-0022, this information is available for onsite NRC audit/inspection.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such action comply with Regulatory Issue Summary (RIS) 2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements.
The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible. Operator Manual Actions with feasibility that could be challenged also had compensatory fire tours put in place as an additional level of defense. The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort.
The feasibility review can not be completed until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for certain actions.
Some of this effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants efforts.
ENOC-08-00042 Progress on NFPA 805 Transitions for:
Waterford 3 Steam Electric Station to ENOC-08-00042 Page 1 of 2 COMSECY-08-0022 requested information from licensees on demonstrated progress toward completion of National Fire Protection Association (NFPA) 805 transition, as a condition of granting an extension of enforcement discretion. Entergy Operations, Inc.
(Entergy) has made substantial progress in the Waterford 3 Steam Electric Station (Waterford 3) NFPA 805 transition effort.
Entergy has participated in the Nuclear Energy Institute (NEI) NFPA 805 Task Force and Fire Probabilistic Risk Assessment (PRA) Task Forces. Entergy also participated in the Frequently Asked Questions (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for Waterford 3 associated with NFPA 805 transition. The "LAR/TR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports (TR) that document the results of the NFPA 805 TRs.
As shown in the table below, Waterford 3 substantial progress in the NFPA 805 transition process.
has demonstrated Current LAR/TR Approximate Milestone Reference Topic
% Complete Completion N/A Safe Shutdown Analysis Update 100%
Complete (Pre-Requisite Task) 4.1 Fundamental FP Program 60%1 3r" Quarter 2009 Attachment A Elements and Minimum Design Requirements (Table B-1) 4.2.1 Nuclear Safety Capability 80%1 3rd Quarter 2009 Attachment B Assessment - Methodology (Table B-2) 4.2.2 Nuclear Safety Capability 20%1 3rd Quarter 2009 Attachment C Assessment - Fire Area - by - Fire Area Review (Table B-3) 4.32 Non-Power Operational Modes 25%
3rd Quarter 2009 Attachment D (Table F-1) 442 Radioactive Release 50%
4t' Quarter 2008 Attachment E (Table G-1) 4.5.1 Fire PRA Development 30%
3rd Quarter 2009
'Completion of these tables contain open items that may (change evaluation) require fire PRA to close 2Although required for transition to NFPA 805, this is a new requirement and does not require enforcement discretion Physical Modifications While physical modifications may be identified as part of the NFPA 805 transition effort, since the Entergy decision to transition Waterford 3 to NFPA 805 there have been no physical modifications to the plant performed to address NFPA 805 fire protection issues.
Entergy plans to identify any required modifications during the NFPA 805 to ENOC-08-00042 Page 2 of 2 transition project in the LAR submittal letter and that letter would provide a schedule and commitments for any such modifications.
NFPA 805 Monitoring Program COMSECY-08-0022 requested that as part of the status report for demonstrating substantial progress on the transition that the status of the NFPA 805 monitoring program be provided. The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort.
This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-0022 requested that additional information be compiled/documented on site available for inspection/audit.
In accordance with NFPA 805 and the enforcement discretion provided, the fire protection related noncompliances associated with the conversion to NFPA 805 have been entered in the Entergy corrective action program and appropriate compensatory measures for those noncompliances have been implemented.
In accordance with COMSECY-08-0022, this information is available for onsite NRC audit/inspection.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such action comply with Regulatory Issue Summary (RIS) 2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements.
The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible. The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort. The feasibility review can not be completed until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for certain actions. Some of this effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants efforts.