ML092920297
| ML092920297 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/19/2009 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Archie J South Carolina Electric & Gas Co |
| Martin R, NRR/DORL, 415-1493 | |
| References | |
| TAC ME1726 | |
| Download: ML092920297 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 19, 2009 Mr. Jeffrey B. Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Post Office Box 88 Jenkinsville, SC 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION, 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. ME1726)
Dear Mr. Archie:
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." The revised policy 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.
By letter dated July 16, 2009, South Carolina Electric & Gas (SCE&G, the licensee) requested that the period of fire protection enforcement discretion for the Virgil C. Summer Nuclear Station (VCSNS) be extended until 6 months after the NRC's approval of the second pilot plant LAR to transition to the National Fire Protection Association's risk-informed, performance-based standard for light water reactors (NFPA 805). Licensees requesting such an extension should submit information in the categories discussed in the Federal Register Notice. These categories of information and the licensee's assessment of its progress in each category are summarized in the Enclosure.
The NRC staff reviewed SCE&G'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 VCSNS is hereby extended until 6 months after the date of the safety evaluation approving the second pilot plant LAR.
J. Archie
-2 If you have any questions regarding this matter, please contact Bob Martin, at (301) 415-1493.
Sincerely,
'~<j.~
Jo eph G. Giitter, Director
~
. ision of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395 Distribution via ListServ
VIRGIL C SUMMER NUCLEAR STATION Task Progress Reported by the Licensee 1
Required Compile a list of all fire protection related noncompliances and the related compensatory measures for those noncompliances. These lists should be maintained on site and up to date for inspector review.
These are available in the site corrective action program.
The licensee reported that appropriate compensatory measures have been implemented in accordance with the existing Fire Protection Program (FPP).
Document that each Operator Manual Action put in place as compensatory measures are feasible and reliable, in accordance with guidance in Regulatory Issue Summary (RIS) 2005-07. These lists should be maintained on-site and up to date for inspector review Unapproved Operator Manual Actions are considered compensatory measures under the FPP. Currently existing Operator Manual Actions have been evaluated for feasibility and reliability based on existing Safe-Shutdown (SSD) and PRA analyses. Those that will be managed forward upon completion of the NFPA-805 analysis must comply with RIS 2005-07. Their feasibility will be reanalyzed based on the Nuclear Compliance Assessment Fire PRA Analysis and Fire Modeling within the bounds of the NFPA-805 analysis, consistent with the pilot plants, since there may be changes as the transition progresses. This analysis will be performed after the Fire PRA is completed.
Submit a description of the physical modifications performed, if any, to address existing risk-significant fire protection issues.
None have been performed to address fire protection issues. Any that are required will be included in the license amendment request with schedule and commitments.
Submit a status report of the transition, including a schedule of milestones for completing the fire PRA. The status report should be broken down into the following major areas:
Classical fire protection Fundamental FPP Elements and Minimum Design transition (in accordance Requirements (Table B-1) are 95 percent complete with with National Fire completion scheduled for December 2009. Open items may Protection Association's require iterative resolution through CAP, Fire Modeling or (NFPA) 805 Chapter 3).
Fire PRA.
Nuclear Safety Performance Criteria transition (in accordance with NFPA 805 chapters 1,2 and 4).
Nuclear Safety Capability Assessment, Methodology (Table B-2) is 95 percent complete with completion scheduled for December 2009. Nuclear Safety Capability Assessment, Fire Area-by-Fire Area Review (Table B-3) is 10 percent complete with completion scheduled for December 2009.
Non-power operational transitions.
Non-Power Operational Modes (Table F-1) are 35 percent complete with completion scheduled for September 2009.
1 Percentage completion is reported as in the licensee's letter of July 16, 2009.
NFPA 805 monitoring program.
This depends highly on the Fire PRA results and traditional FPP issues, rendering it one of the last items to be completed (consistent with pilot plants).
Fire PRA.
Fire PRA Development is 40 percent complete with completion scheduled for December 2009.
Optional Radioactive Release Radioactive Release (Table G-1) is 100 percent complete.
SSD Analysis Although marked as "N/A" with respect to the Pilot Plant NFPA 805 LARlTransition Reports, it is included as a pre requisite task.
!\\IRC Staff Overall Assessment of Progress:
On balance, the NRC staff finds that the licensee has made substantial progress in its transition effort.
J. Archie
- 2 If you have any questions regarding this matter, please contact Bob Martin, at (301) 415-1493.
Sincerely, IRA!
Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395 Distribution via ListServ DISTRIBUTION PUBLIC Branch Reading 2-1 RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl2-1 Resource RidsNrrDRA Resource RidsNrrLASRohrer Resource RidsNrrPMRMartin Resource RidsOgcMailCenter RidsRgn2MailCenter Resource MCox, EDO R-II AKlein, NRRlDRA ADAMS Accession Number: ML092920297 OFFICE LPL2-1:PM LPL2-1 :LA DRAlAFPB/BC LPL2-1:BC DORUDD NAME RMartin SRohrer AKlein GKulesa JGiitter DATE 10/19/09 10/19/09 10/19/09 10/19/09 10/19/09 OFFICIAL RECORD COPY