ML083500030

From kanterella
Jump to navigation Jump to search

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
ML083500030
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 12/19/2008
From: Giitter J
Division of Operating Reactor Licensing
To: Stall J
Florida Power & Light Co
Paige, Jason, NRR,301-415-5888
References
TAC ME0063, TAC ME0064
Download: ML083500030 (3)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 19, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 SUB.JECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - 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 NOS. ME0063 AND ME0064)

Dear Mr. Stall:

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. Per this guidance, if a licensee successfully submits their NFPA 805 LAR within the 6-month timeframe, 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 11,2008, Florida Power & Light Company (FPL or the licensee) requested that the period of fire protection enforcement discretion for the St. Lucie Plant, Units 1 and 2, 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 noncompliances and the related compensatory measures for those noncompliances.
2.

Document that each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the gUidance in Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements."

J. Stall

- 2

3.

Submit a description of the physical modi'fications performed to address existing risk-significant fire protection noncompliances.

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 nonpower operation transitions the NFPA 805 monitoring program fire PRA development The lists of noncompliances, compensatory measures, and operator manual action feasibility determinations should be maintained on-site and up to date for inspector review.

The NRC staff reviewed FPL's request, and has determined that the licensee has made substantial enough progress in their transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period for the St. Lucie Plant, Units 1 and 2, 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 Brenda Mozafari, the project manager for the St. Lucie Plant, at (301) 415-2020.

Sincerely, Q~-xY?-

J seph G. Giitter, Director ivision of Operating Reactor Licensing Office of l\\Juclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc: Distribution via Listserv

December 19, 2008 J. Stall

- 2

3. Submit a description of the physical modifications performed to address existing risk-significant fire protection noncompliances.
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
  • nonpower operation transitions
  • fire PRA development The lists of noncompliances, compensatory measures, and operator manual action feasibility determinations should be maintained on-site and up to date for inspector review.

The I\\JRC staff reviewed FPL's request, and has determined that the licensee has made substantial enough progress in their transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period for the S1. Lucie Plant, Units 1 and 2, 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 Brenda Mozafari, the project manager for the S1. Lucie Plant, at (301) 415-2020.

Sincerely, IRA!

Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket l\\Jos. 50-335 and 50-389 cc: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsOgcRp PLain, NRR LPLlI-2 R/F RidsAcrsAcnw&mMailCenter HBarrett, NRR RidsNrrDorlLplll-2 RidsRgn2MailCenter CMoulton, NRR Ridsl\\JrrLABClayton Ridsl\\JrrDraAfpb (AKlein)

RGallucci, NRR RidsN rrPMBMozafari MVaaler, NRR JPaige RidsNrrDorl Accession Number: ML083500030 OFFICE LPLlI-2:PE LPLlI-2:PM LPLlI-2:LA DRAlAFPB/BC LPLlI-2:BC DORL: D NAME

..IPaiqe BMozafari BClayton AKlein*

TBoyce JGiitter DATE 12/16/08 12/16/08 12/16/08 11/13/08 12/18/08 12/19/08

  • by memo dated 11/13/08 OFFICIAL RECORD COPY