ML083380731
| ML083380731 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/08/2008 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Heflin A Union Electric Co |
| Thadani, M C, NRR/DORL/LP4, 415-1476 | |
| References | |
| TAC ME0060 | |
| Download: ML083380731 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - EVALUATION OF THE REQUEST FOR AN EXTENSION OF ENFORCEMENT DISCRETION IN ACCORDANCE WITH THE INTERIM ENFORCEMENT POLICY FOR FIRE PROTECTION ISSUES DURING TRANSITION TO NATIONAL FIRE PROTECTION STANDARD NFPA 805 (TAC NO. ME0060)
Dear Mr. Heflin:
On September 10,2008, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (73 FR 52705) a revision to its Interim Enforcement Policy regarding enforcement discretion for certain fire protection issues, allowing licensees the option to request an extended enforcement discretion period for submittal of a license amendment request (LAR) if they are pursuing transition to Title 10 of the Code of Federal Regulations Section 50.48(c),
"National Fire Protection Association Standard NFPA 805."
This revision states that an additional period of enforcement discretion may be granted on a case-by-case basis, if a licensee has made substantial progress in its transition effort. This additional period of enforcement discretion, if granted, would end 6 months after the date of the safety evaluation approving the second pilot plant LAR. These changes are in accordance with COMSECY-08-0022, as approved by the Commission on August 19, 2008. The enforcement discretion will continue in place, without interruption, until NRC disposition of the site's LAR to transition to NFPA 805.
By letter dated September 29, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082820327), Union Electric Company (the licensee) requested that the period of fire protection enforcement discretion for the Callaway Plant, Unit 1, be extended until 6 months after the NRC's approval of both pilot plant LARs to transition to the National Fire Protection Association's risk-informed, performance-based standard for light-water reactors (NFPA 805). Per the new interim fire protection enforcement policy outlined above, licensees may request an extension of their evaluation period beyond the 3 years of enforcement discretion previously provided.
To be granted this extension, a licensee must:
- 1.
Compile a list of all fire-protection-related non-compliances and the related compensatory measures for those non-compliances.
A. Heflin
- 2
- 2.
Document that each operator manual action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in NRC Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements."
- 3.
Submit a description of the physical modifications performed to address existing risk-significant fire protection non-compliances.
- 4.
Submit a status report of the transition, including a schedule of milestones, for completing the fire probabilistic risk assessment (PRA). The status report should describe the progress made in the following areas:
classical fire protection transition nuclear safety performance criteria transition non-power operation transitions NFPA 805 monitoring program fire PRA development The lists of non-compliances, compensatory measures, and operator manual action feasibility determinations should be maintained on-site and up to date for inspector review.
The NRC staff reviewed Union Electric Company's request, and has determined that the licensee has made substantial enough progress in its transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period for the Callaway Plant, Unit 1, site is hereby extended until 6 months after the date of the safety evaluation approving the second pilot plant LAR.
If you have any questions regarding this matter, please contact Mohan C. Thadani, the NRC Project Manager for the Callaway Plant, Unit 1, at (301) 415-1476, or by electronic mail at Mohan.Thadani@nrc.gov.
Sincerely,
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(JePh G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483 cc: Distribution via Listserv
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