ML090350062
| ML090350062 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 01/16/2009 |
| From: | Brandi Hamilton Duke Energy Carolinas, Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML090350062 (5) | |
Text
like BRUCE HHAMILTON or e Energy Vice President McGuire Nuclear Station Duke Energy Corporation MG01VP / 12700 Hagers Ferry Road Huntersviyle, NC 28078 January 16, 2009 704-875-5333 704-875-4809 fax U. S. Nuclear Regulatory Commission bhhamilton@duke-energy.com ATTN: Document Control Desk.
Washington, D.C. 20555-0001
Subject:
Duke Energy Carolinas, LLC (Duke)
McGuire Nuclear Station (McGuire), Units 1 and 2 Docket Nos. 50-369 and 50-370 Request for Extension of Enforcement Discretion and Revised Submittal Schedule for 10 CFR 50.48(c) License Amendment Request By letter dated March 13, 2008, Duke informed the Nuclear Regulatory Commission (NRC) of its plan to submit the 10 CFR 50.48(c) License Amendment Request (LAR) for McGuire by April 18, 2009. In accordance with the August 19, 2008 NRC approval of the NRC Enforcement Policy change proposed by the staff inr COMSECY-08-0022, Duke requests that enforcement discretion and the due date for the 10 CFR 50.48(c) LAR for McGuire be extended to six (6) months past the date of the safety evaluation approving the second pilot plant LAR but no earlier than May 31, 2010.
Duke has committed to transitioning all three of its nuclear stations to 10 CFR 50.48(c) including Oconee Nuclear Station which was one of the pilot plants. The resources being utilized for preparing the transition LAR for McGuire are the same as were used in preparing the transition LAR for Oconee. Due to the unforeseen complexity of preparing the LAR for Oconee, and insights gained from the NRC staff as they observed the transition preparation, a supplemental LAR submittal was required. This further delayed the contractor resources to begin their focus on McGuire. The updated McGuire schedule for submitting the transition LAR, which includes the lessons learned from the Oconee pilot process, now places the submittal date at May 31, 2010.
In keeping with the assessment criteria outlined in COMSECY-08-0022, Duke bases this request on the "substantial progress" that has been made on the NFPA transition tasks that are not resource-limited with respect to fire probabilistic risk assessment technical expertise. Substantial progress toward completion of NFPA 805 transition is discussed in the attachment to this letter.
Please contact P. T. Vu at (704) 875-4302 or David J. Goforth at (704) 382-2659 if there are any questions concerning this submittal.
Very truly yours, Bruce H. Hamilton Attachment www. duke-energy.corn
U. S. Nuclear Regulatory Commission January 16, 2009 Page 2 xc:
L. A. Reyes, Regional II Administrator U. S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center, 23 T85 61 Forsyth St., SW Atlanta, GA 30303-8931 J. H. Thompson, Project Manager U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8G-9A Rockville, MD 20852-2738 P. W. Lain U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-A11 A11 Rockville, MD 20852-2738 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station
Attachment McGuire Nuclear Station Units I and 2 NFPA 805 Transition Progress
U. S. Nuclear Regulatory Commission Attachment January 16, 2009 Page 1 of 2 Duke Energy McGuire Nuclear Station NFPA 805 Transition Progress COMSECY-08-0022 requested information from licensees on demonstrated progress toward completion of NFPA 805 transition, as a condition of granting an extension of enforcement discretion. Duke has made substantial progress in the McGuire Nuclear Station NFPA 805 transition effort. Duke has participated in the NEI NFPA 805 Task Force, Fire PRA Task Forces, and the Frequently Asked Question (FAQ) process and has 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 McGuire Nuclear Station associated with NFPA 805 Transition. The "LAR/TR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports that document the results of the NFPA 805 Transition Reports. As shown in the table below, McGuire Nuclear Station has demonstrated substantial progress in the NFPA 805 transition process.
LAR/TR Reference Topic Approximate % Current Milestone 2 Complete Completion Schedule N/A Safe shutdown 90 % February 2009 Analysis Update (pre-requisite task) 4.1 Attachment A Fundamental FP 33 % I August 2009 Program Elements and Minimum Design Requirements (Table B-I) 4.2.1 Attachment B Nuclear Safety 80 % August 2009 Capability Assessment -
Methodology (Table B-2)
Section 4.2.2 Nuclear Safety 25 %' March 2009 Attachment C Capability Assessment - Fire Area-by-Fire Area Review (Table B-3)
Section 4.3 Non Power 5% September 2009 Attachment D Operational Modes (Table F-1)
Section 4.4 Radioactive Release 5% September 2009 Attachment E (Table G- 1) 4.5.1 Fire PRA 10 % September 2009 Development
U. S. Nuclear Regulatory Commission Attachment January 16, 2009 Page 2 of 2 Note 1 - Completion of these tables contain open items that may require fire PRA to close (change evaluation).
Note 2 - Schedule dates are milestones and do not constitute commitments.
Physical Modifications While physical modifications may be identified as part of the transition effort, no physical modifications have been performed to address any fire protection issues. Any modifications required will be identified 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 required additional information to be compiled/documented on site and available for inspection/audit.
All non-compliances with the existing fire protection program have been entered into the site corrective action program and appropriate compensatory measures in accordance with the existing fire protection program have been implemented. This information is contained within the site's corrective action program and is available for review.
Un-allowed 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 actions comply with RIS 2005-07. 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. Therefore, the existing feasibility determination may require modification and/or revision due to information generated by the NFPA 805 transition effort. This review can not be completed until most other transition efforts, including the fire PRA effort, are completed since the information generated during the transition effort may change which actions are required or the timing required for required actions. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort.
This approach is consistent with the pilot plants.