L-MT-10-031, Notice of Withdrawal of Letter of Intent to Transition to 10CFR50.48(c)

Notice of Withdrawal of Letter of Intent to Transition to 10CFR50.48(c)

ML102000433
Person / Time
Site:	Monticello
Issue date:	07/16/2010
From:	O'Connor T Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-10-031
Download: ML102000433 (2)

Text

feXcel Energya Monticello Nuclear Generating Plant 2807 W County Road 76 Monticello, MN 55362 July 16, 2010 L-MT-10-031

'lo CFR 50.48 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 Notice of Withdrawal of Letter of Intent to Transition to I0 CFR 50,48(c]

References:

I ) Letter from NMC to NRC, "Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA-805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," dated November 30,2005 (ADAMS Accession ML053460342)

2) Letter from NMC to NRC,"Request for Extension of Enforcement Discretion for a Revised Date for 10 CFR 50,48(c) License Amendment Request Submittal," dated August 26, 2008 (ADAMS Accession ML082400208)

3) Letter from NRC to NMC, "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," dated November 21, 2008 (ADAMS Accession ML083110707)

In Reference I,Nuclear Management Company (NMC), LLC, a predecessor license holder to the Northern States Power Company, a Minnesota corporation (NSPM), submitted a letter of intent to transition the fire protection licensing basis for Prairie Island Nuclear Generating Plant (PINGP) and Monticello Nuclear Generating Plant (MNGP) to the voluntary alternative in 10 CFR 50.48(c) to adopt NFPA 805.

In Reference 2, NMC submitted a request to extend enforcement discretion for a revised date for 10 CFR 50.48(c) license amendment request submittal, In Reference 3, the NRC staff granted the addjtional eliforcement discretion period requested for MNGP and PINGP.

Subsequent to this letter, NSPM has proceeded with NFPA-805 transition activities for both MNGP and PINGP. Upon issuance of Regulatory Guide (RG) 1.189, "Fire Protection for Nuclear Power Plants, Revision 2, NSPM reconsidered the decision to transition MNGP to NFPA-805. NSPM plans to address circuit issues related to multiple spurious operations in accordance with the guidance contained in RG 1.189, Revision 2 at MNGP. NSPM will cotnply with the guidance provided in Enforcement Guidance Memorandum (EGM) 09-002, "Enforcement Discretion for Fire Induced Circuit Faults." Also, NSPM will complete a Fire PRA in confortnance with RG 1.200 Rev.

Document Control Desk Page 2 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities,"

In comparison to peer plants, MNGP has a high degree of train separation by design. In addition, an Alternate Shutdown System (ASDS) was designed and installed at MNGP shortly after the issuance of 10 CFR 50, Appendix R, Therefore, considering the high degree of train separation and the ASDS, NSPM has determined that it is appropriate for MNGP to retain the existing licensing basis of compliance with 'lo CFR 50.48(a) and 10 CFR 50.48(b).

Therefore, by this letter NSPM is notifying the NRC that transition to 10 CFR 50,48(c) forthe MNGP will not be completed. NSPM intends to retain the existing licensing basis and hereby withdraws the H e r of intent to voluntarily implement 10 CFR 50.48(c) for the MNGP. PlNOP is continuing efforts to transition the licensing basis to 10 CFR 50.48(c).

Summarv of Commitments

/

new commitments and no revisions to existing commitments.

Northern States Power Company-Minnesota cc: Regional Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticeilo Nuclear Generating Plant, USNRC