ML101020521
| ML101020521 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/16/2010 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | George Gellrich Calvert Cliffs |
| pickett , NRR/DORL, 415-1364 | |
| References | |
| TAC ME3304, TAC ME3305 | |
| Download: ML101020521 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 111, 2010 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702
SUBJECT:
EVALUATION REGARDING REQUEST FOR ADDITIONAL FIRE PROTECTION ENFORCEMENT DISCRETION FOR: CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 (TAC NOS. IVIE3304 AND ME3305)
Dear Mr. Gellrich:
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 Section 50.48( c), "National Fire Protection Association [NFPA] 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 (Agencywide Documents Access and Management System (ADAMS)
Accession Nos. ML081830602 and ML081830607), 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 LAR to transition to NFPA 805.
By letter dated January 28,2010 (ADAMS Accession No. ML100320428), Calvert Cliffs Nuclear Power Plant, LLC, the licensee, requested the period of fire protection enforcement discretion for Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (CCNPP), be extended to 6 months past the NRC approval date of the second pilot plant LAR to transition to NFPA's risk-informed, performance-based standard for light-water reactors, NFPA 805.
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, and in accordance with the guidance in Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements. "
G. Gellrich -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 has reviewed the enforcement discretion extension request for CCNPP and documented their findings in the enclosed matrix. Based on the information provided by the licensee, the staff has determined that the licensee has made sufficient progress in their transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period for CCNPP 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 Douglas Pickett at (301) 415 1364.
Sincerely,
. I x:: ~ AlA' kl !U~l v.
V"?f~V\.'<J . ~:"'A/l--,
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Jo eph G. Glitter, Director D' ision of Operating Reactor Licensing ffice of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
Enclosure:
As stated cc w/encl: Distribution via Listserv
NFPA 805 Enforcement Discretion Extension Evaluation CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 & 2 Task Document Progress Reported by the Licensee*
Location Required Compile a list of all fire protection related On-site or These are available in the site corrective action program. The licensee noncompliances and the related NRCHO reported that appropriate compensatory measures have been compensatory measures for those implemented in accordance with the existing Fire Protection Program noncompliances. (FPP).
Document that each Operator Manual Action On-site or Disallowed Operator Manual Actions are considered compensatory put in place as compensatory measures are NRCHO measures under the FPP. These actions are required by the FPP to be feasible and reliable, in accordance with in accordance with the guidance in RIS 2005-07. Currently existing guidance in Regulatory Issue Summary (RIS) Operator Manual Actions have been evaluated for feasibility and 2005-07. reliability based on existing Safe-Shutdown (SSD) and Probabilistic Risk Analysis (PRA) analyses. 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 NRCHO None have been performed to address fire protection issues. Any that modifications performed to address existing are required will be included in the license amendment request with risk-significant fire protection issues. schedule and commitments.
I Submit a status report of the transition, NRCHO The status report was provided in the licensee's letter dated including a schedule of milestones for January 28,2010.
completing the fire PRA. The status report should be broken down into the following major areas:
- Classical fire protection transition (in On-site -75% on Fundamental FPP Elements and Minimum Design accordance with National Fire Requirements (Table B-1) (completion scheduled for March 2010)
Protection Association's (NFPA) 805 open items may require iterative resolution through Fire PRA.
Chapter 3).
ENCLOSURE
NFPA 805 Enforcement Discretion Extension Evaluation
- Nuclear Safety Performance Criteria On-site -25% on Nuclear Safety Capability Assessment, Methodology (Table transition (in accordance with NFPA B-2) - open items may require iterative resolution through Fire PRA 805 chapters 1, 2 and 4). (completion scheduled for July 2010); -0% on Nuclear Safety Capability Assessment, Fire Area-by-Fire Area Review (Table B-3)
(comoletion scheduled for September 2010).
- Non-power operational transitions. On-site -20% on Non-Power Operational Modes (Table F-1) - (completion scheduled for July 2010)
- NFPA 805 monitoring program. On-site This depends highly on the Fire PRA results and traditional FPP issues, rendering it one of the last items to be completed (consistent with oilot nlants),
Optional Radioactive Release On-site 100% on Radioactive Release (Table G-1)
SSD Analysis On-site -75% - (completion scheduled for June 2010)
Plant Change Evaluations N/A 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.
- The referenced sections in this column refer to the pilot plant NFPA 805 License Amendment RequestlTransition Reports that document the results of the NFPA 805 transition reports.
Overall Assessment of Progress:
In balance, enough substantial progress has been made based on the overall reported progress taken as a whole.
2
G. Gellrich -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 has reviewed the enforcement discretion extension request for CCNPP and documented their findings in the enclosed matrix. Based on the information provided by the licensee, the staff has determined that the licensee has made sufficient progress in their transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period for CCNPP 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 Douglas Pickett at (301) 415 1364.
Sincerely, IRA!
Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
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