ML082710004

Response to Letter of Intent to Adopt NFPA 805

ML082710004
Person / Time
Site:	San Onofre
Issue date:	11/02/2008
From:	Giitter J Division of Operating Reactor Licensing
To:	Ridenoure R Southern California Edison Co
Vaaler, Marlayna, NRR/DORL 415-3178
References
Download: ML082710004 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 November 2, 2008 Mr. Ross T. Ridenoure Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 RESPONSE TO LETTER OF INTENT TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805

Dear Mr. Ridenoure:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 28, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080920132),

Southern California Edison (SCE), informed the NRC staff of its intent to adopt National Fire Protection Association (NFPA) Standard 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 to Title 10 of the Code of Federal Regulations, at the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS).

SCE's letter stated that it intends to transition to the performance-based standard for fire protection at SONGS, and that the period of transition was to commence on March 28, 2008.

SCE also requested an enforcement discretion period of three years in accordance with the NRC's enforcement policy.

On April 18, 2006, the NRC published in the Federal Register (71 FR 19905) a revision to its enforcement policy extending the I\JFPA 805 transition discretion period from 24 to 36 months.

Therefore, the requested 36-month discretion period for SONGS is granted. As such, the NRC considers the discretion period for SONGS to begin on March 28, 2008, and to expire on March 28, 2011. In addition, in accordance with the Enforcement Policy, the discretion will continue past the 36-month period while the NRC staff is reviewing the license amendment request for transitioning to NFPA 805.

It should be noted that in order to receive enforcement discretion, a licensee must, in part:

(a) evaluate the risk significance of all noncompliances to assure that they do not constitute "Red" (or Severity Levell) findings under the NRC's reactor oversight program, (b) enter all noncompliances into a corrective action program, and (c) implement and maintain appropriate compensatory measures until the corrective actions are completed, or until the NRC staff issues the license amendment with its associated safety evaluation. Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements," provides additional guidance regarding appropriate compensatory measures.

R.T. Ridenoure -2 If you have any questions regarding this matter, please contact N. Kaly Kalyanam, Project Manager for SON GS, at 301-415-1480.

Sincerely, Jo eph G. Giitter, Director

. ision of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: See next page

November 2, 2008 R.T. Ridenoure -2 If you have any questions regarding this matter, please contact N. Kaly Kalyanam, Project Manager for SONGS, at 301-415-1480.

Sincerely, IRAI Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: See next page DISTRIBUTION:

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