ML090620089
| ML090620089 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/09/2009 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Polson K Nine Mile Point |
| Guzman R, NRR/DORL, 415-1030 | |
| References | |
| RIS-05-007, TAC ME0399 | |
| Download: ML090620089 (3) | |
See also: RIS 2005-07
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
Mr. Keith J. Polson
Vice President Nine Mile Point
Nine Mile Point Nuclear Station, LLC
P. O. Box 63
Lycoming, NY 13093
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT NO.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. ME0399)
Dear Mr. Polson:
On September 10, 2008, the 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 (10 CFR) Section 50.48{c),
"National Fire Protection 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 transition
to I\\IFPA 805.
By letter dated January 16, 2009, Nine Mile Point Nuclear Station, LLC (NMPNS) requested that
the period of fire protection enforcement discretion for Nine Mile Point Unit NO.1 (I\\IMP1) be
extended until 6 months after the NRC's approval of both pilot plant LARs to transition to the
NFPA 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.
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."
K. Polson
- 2
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
the 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 NMPNS's request, and has determined that the licensee has made
sufficient progress in their transition to NFPA 805 in order to grant additional enforcement
discretion. Accordingly, the enforcement discretion period for NMP1 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 Richard Guzman, the Project
Manager for NMP1 at (301) 415-1030.
Sincerely,
~~
Jo eph G. Giitter, Director
D' ision of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-220
cc: Distribution via ListServ
K. Polson
-2
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
the 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 NMPNS's request, and has determined that the licensee has made
sufficient progress in their transition to NFPA 805 in order to grant additional enforcement
discretion. Accordingly, the enforcement discretion period for NMP1 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 Richard Guzman, the Project
Manager for NMP1 at (301) 415-1030.
Sincerely,
IRA!
Joseph G. Giitter, Director
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-220
cc: Distribution via ListServ
DISTRIBUTION:
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ADAMS Accession Number: ML090620089
NRR-106
OFFICE LPLI-1\\PM
LPLI-1\\LA
LPLI-1\\BC
DORL/DD
NAME
RGuzman
SLittie
MKowal
JGiitter
DATE
3/04/09
3/05/09
3/09/09
3/09/09
OFFICIAL RECORD COPY