ML100320428
| ML100320428 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/28/2010 |
| From: | George Gellrich Calvert Cliffs |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML100320428 (5) | |
Text
George H. Gellrich Calvert Cliffs Nuclear Power Plant, LLC Vice President 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495-3500 Fax CENG a joint venture of f Constellation w Energy , -.-
CALVERT CLIFFS NUCLEAR POWER PLANT January 28, 2010 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Request for Extension of Enforcement Discretion for a Revised Date of 10()(FR S(_4R(c'* l.icen~e Amendment Reanie~t Siihmittal
REFERENCES:
(a) Letter from Mr. J. M. Heffley (CGG) to Document Control Desk (NRC),
dated April 17, 2006, Letter of Intent to Adopt NFPA 805 - Performance-Based Standard for Fire Protection for Light Water Reactor Generation Plants, 2001 Edition (b) Letter from Ms. C. Haney (NRC) to Mr. J. M. Heffley (CGG), dated May 31, 2006, Response to Letter of Intent to Adopt National Fire Protection Association (NFPA) Standard 805, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, and Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 (c) Letter from Mr. J. A. Grobe (NRC) to Mr. A. Marion (NEI), dated July 1, 2009, Change in Review Schedule for the Second Pilot Plant Adopting NFPA 805 Calvert Cliffs Nuclear Power Plant, LLC (CCNPP) requests an extension of the enforcement discretion period, pending transition to the National Fire Protection Association (NFPA) Standard 805 for CCNPP Units 1 and 2. We request that the due date for the 10 CFR 50.48(c) License Amendment Request (LAR) be extended to six months after the date of the safety evaluation approving the second pilot plant LAR to transition to NFPA 805, and continue until the NRC approval of the LAR.
ADDoc
Document Control Desk January 28, 2010 Page 2 A letter of intent to adopt NFPA 805 in accordance with 10 CFR 50.48(c) was submitted on April 17, 2006 (Reference a). That letter requested a three year transition period. Reference (b) acknowledged receipt of the letter of intent and approved the three year transition period.
As published in the Federal Register, Volume 73, Page 52705, the enforcement discretion period has been reset to six months after the date of the safety evaluation approving the second pilot plant LAR to transition to NFPA 805. Further, as indicated in Reference (c), CCNPP Units I and 2 are identified as plants that because of the schedule change for the second pilot plant, are now eligible to apply for an enforcement discretion extension in accordance with the enforcement policy in 73 FR 52705. Therefore, we request that the enforcement discretion period be extended for submittal of the CCNPP Units I and 2 10 CFR 50.48(c) LAR to six months after the date of the safety evaluation approving the second pilot plant LAR, and continue until the NRC approval of the LAR. We understand that approval of this extension request is based upon our demonstrated substantial progress toward completion of the NFPA 805 transition. The progress to date is discussed in Attachment (1) to this letter.
Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at (410) 495-5219.
Very truly yours, GHG/ALS/bjd
Attachment:
(1) Calvert Cliffs Nuclear Power Plant Units 1 and 2 Progress on NFPA 805 Transition cc: D. V. Pickett, NRC Resident Inspector, NRC S. J. Collins, NRC S. Gray, DNR
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 PROGRESS ON NFPA 805 TRANSITION Calvert Cliffs Nuclear Power Plant, LLC January 28, 2010
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 PROGRESS ON NFPA 805 TRANSITION PROGRESS ON NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 805 TRANSITION The Nuclear Regulatory Commission (NRC), in Federal Register Volume 73, Page 52705 (73 FR 52705),
allowed application for a change of enforcement discretion on a case-by-case basis, and also reset the enforcement discretion period to six months after the date of the safety evaluation approving the second pilot plant license amendment request to transition to NFPA 805. As indicated in Reference 1, Calvert Cliffs Nuclear Power Plant (CCNPP) Units I and 2 are identified as plants that because of a schedule change for the second pilot plant are now eligible to apply for an enforcement discretion extension in accordance with the enforcement policy in 73 FR 52705.
The NRC, in approving COMSECY-08-022, required that licensees provide demonstrated progress toward completion of NFPA 805 transition as a condition of granting an extension of enforcement discretion. Calvert Cliffs Nuclear Power Plant has made substantial progress in the NFPA 805 transition effort for CCNPP Units 1 and 2. We have participated in the Nuclear Energy Institute NFPA 805 Task Force and Fire Probabilistic Risk Analysis (PRA) task forces and Frequently Asked Questions process and have made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the pilot plant process.
Table 1 below represents the major work activities associated with NFPA 805 transition. The "LAR/TR Reference" column refers to the referenced section of the pilot plant NFPA 805 License Amendment Request/Transition Reports that document the results of the NFPA 805 transition reports. As shown in Table 1, CCNPP has demonstrated substantial progress in the transition process.
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 License Amendment Request submittal letter and that letter will provide a schedule and commitment for any such modifications.
NFPA 805 MONITORING PROGRAM 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 Fire protection-related non-compliances, as they are identified, are or will be entered into the station corrective action program, and appropriate compensatory measures in accordance with the existing fire protection program have or will be implemented, as necessary. This information is contained within the station's corrective action program and is available for review.
Disallowed operator manual actions are considered compensatory measures according to the fire protection program. The fire protection program requires that any such actions be in accordance with the guidance of Reference 2. The feasibility of operator manual actions have been reviewed and any such action being considered as a compensatory measure is considered feasible. The feasibility review for these actions was performed based on the pre-NFPA 805 safe shutdown analysis. The post-NFPA 805 feasibility study may require modification and/or revision due to the information generated by the NFPA 805 transition effort. The post-NFPA 805 feasibility review cannot be completed until most other transition efforts are complete since the information generated during the transition may change which
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 PROGRESS ON NFPA 805 TRANSITION actions are required or may change the timing for required actions. This effort is tied to the completion of the fire PRA. Therefore, the post-NFPA 805 feasibility study of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants' approach.
REFERENCES:
- 1. Letter from Mr. J. A. Grobe (NRC) to Mr. A. Marion (NEI), dated July 1, 2009, Change in Review Schedule for the Second Pilot Plant Adopting NFPA 805
- 2. Regulatory Issue Summary 2005-07, dated April 19, 2005, Compensatory Measures to Satisfy the Fire Protection Program Requirements Table 1 CCNPP Units 1 and 2 Progress on NFPA 805 Tasks LA/TR Approximate % Current Milestone Reference Topic Complete Schedule Date )
N/A Safe Shutdown Analysis Update (pre- 75% 6/30/2010 requisite task) 4.1 Fundamental FP Program Elements and 75% (2) 3/31/2010 Attachment A Minimum Design Requirements (Table B-i) 4.2.1 Nuclear Safety Capability Assessment - 25% (2) 7/8/2010.
Attachment B Methodology (Table B-2) 4.2.2 Nuclear Safety Capability Assessment - 0% 9/21/2010 Attachment C Fire Area - by - Fire Area Review (Table B-3) 4.3 Non-Power Operational Modes 20% 7/28/2010 Attachment D (Table F-1) 4.4 Radioactive Release (Table G- 1) 100% Complete Attachment E 4.5.1 Fire PRA Development 5% 11/30/2010 NOTES:
(I) Schedule dates are approximate and do not constitute commitments.
(2) The purpose of the task is to complete the appropriate table. Upon completion, open items will exist and may require Fire PRA to resolve.
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