ML090650597
| ML090650597 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/04/2009 |
| From: | West R Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML090650597 (3) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 March 4, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop OWFN, P1-35 Washington, D.C. 20555-0001 In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 - LETTER OF INTENT TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 805, PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS, 2001 EDITION The purpose of this letter is to inform NRC that TVA intends to adopt NFPA Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," at BFN in accordance with 10 CFR 50.48(c).
BFN is beginning the transition to the performance-based standard for fire protection.
It is expected to take approximately thirty-six months to develop a License Amendment Request to adopt NFPA 805, as required by 10 CFR 50.48(c).
10 CFR 50.48(c), in conjunction with NFPA 805, provides an alternate, performance-based method to comply with NRC fire protection requirements. NRC has encouraged licensees to consider the benefits of transitioning plant fire protection programs from their current prescriptive requirements to the new NFPA 805 standard. TVA recognizes that the overall benefit of NFPA is in ensuring optimum focus on enhancing plant safety through the use of performance-based standards and risk informed decision-making techniques.
The BFN NFPA 805 transition process will consist of three phases:
Phase 1: Preliminary Assessment of the Fire Protection Program
- Assessment to determine the scope of activities and resources needed to perform the transition
U.S. Nuclear Regulatory Commission Page 2 March 4, 2009 Phase 2: Reviews and Engineering Analysis Fire Probabilistic Risk Assessment Fundamental Fire Protection Program and Design Elements Assessment Radioactive Release Assessment Nuclear Safety Capability Assessment Non-Power Operational Modes Assessment Development of Change Evaluations and Transition Report Submittal of License Amendment Request Phase 3: Implementation Completion of Program Document Changes The transition process will be considered complete upon receipt of a License Amendment authorizing the transition to NFPA 805 at BFN.
The NRC Interim Enforcement Discretion Policy (71 FR 19905, April 18, 2006, and Regulatory Guide 1.205, May 2006) established NRC policy regarding enforcement discretion for certain non-compliances related to fire protection programs and the transition to 10 CFR 50.48(c). As outlined in the Enforcement Policy, enforcement discretion begins with the licensee's letter of intent. The Enforcement Policy also provides for extension of the discretion period if adequate justification is provided.
Because the transition to the NFPA performance-based standard is a voluntary initiative, this correspondence contains no regulatory commitments.
If you have any questions or require additional information, please contact F. R. Godwin at (256) 729-2636.
R. G. West Site Vice President cc: see page 3
U.S. Nuclear Regulatory Commission Page 3 March 4, 2009 cc: Ms. Eva Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Ms. Heather J. Gepford, Acting Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970