NL-10-0688, Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request
| ML103120441 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/05/2010 |
| From: | Ajluni M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-10-0688 | |
| Download: ML103120441 (6) | |
Text
Mark J. Ajiluni, P.E.
Southern Nuclear Nuclear Licensing Director Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 November 5, 2010 SOUTHERN zZ~n COMPANY Docket Nos.: 50-348 NL-10-0688 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Units 1 and 2 Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request Ladies and Gentlemen:
In accordance with COMSECY-08-0022 and as approved by Federal Register Notice 73 FR 52705 dated September 10, 2008, Southern Nuclear Operating Company (SNC), the licensee for Farley Nuclear Plant (FNP) Units 1 and 2 respectfully requests that the due date for 10 CFR 50.48(c) License Amendment Request (LAR) be extended until six (6) months past the date of the safety evaluation approving the second pilot plant LAR.
In 2008, SNC decided to transition the fire protection licensing basis for FNP to the Risk-Informed, Performance-Based alternative in accordance with 10 CFR 50.48(c). SNC submitted a letter of intent to the NRC by letter on February 14, 2008 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML080450434) for FNP to adopt NFPA 805 in accordance with 10 CFR 50.48(c).
By letter dated November 3, 2008 (ML082710003), the NRC acknowledged receipt of the letter of intent and granted a three year enforcement discretion period for FNP beginning February 14, 2008 and to expire on February 14, 2011.
In accordance with NRC Enforcement Policy, the enforcement discretion period will continue until NRC approval of the LAR.
Federal, Register Notice 73 FR 52705 dated September 10, 2008 provides for an additional period of enforcement discretion based on substantial progress made in the transition effort. Enclosure 1 to this letter provides the information requested in Federal Register Notice 73 FR 52705. Based upon demonstrated substantial progress toward completion of NFPA 805 transition, SNC requests that enforcement discretion be extended until six (6) months past the date of the safety evaluation approving the second pilot plant LAR and continuing during the period between submittal of the LAR and NRC approval of the FNP LAR. In addition, SNC requests that any noncompliances identified while under enforcement discretion will continue under enforcement discretion between the end of the 6 month extension and submittal of the LAR.
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U. S. Nuclear Regulatory Commission Log: NL-10-0688 Page 2 SNC will submit the FNP LAR no later than March 31, 2012. SNC intends to solve the multiple spurious operation and operator manual action issues as part of the transition to NFPA 805. These items will be resolved using risk informed, performance based approaches allowed by 10 CFR 50.48(c).
This letter contains no NRC commitments. If there are any questions, please contact Mr. N. J. Stringfellow at (205) 992-7037.
Respectfully submitted, M. J. Ajluni Director Nuclear Licensing MJA /GAL/emm : FNP NFPA 805 Transition Progress and Status Report cc:
Southern Nuclear Operatinq Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Ms. P. M. Marino, Vice President - Engineering RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley State of Alabama Dr. D. E. Williamson, State Health Officer
Joseph M. Farley Units 1 and 2 Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request FNP NFPA 805 Transition Progress and Status Report
Joseph M. Farley Units 1 and 2 Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request NFPA 805 Transition Progress Federal Register Notice 73 FR 52705 requested information from licensees on demonstrated progress toward completion of NFPA 805 transition as a condition of granting an extension of enforcement discretion. Southern Nuclear Operating Company (SNC) has made substantial progress with regard to the FNP Units 1 and 2 NFPA 805 transition effort. SNC has a record of continued participation in the NEI NFPA 805 Task Force, Fire PRA Task Force, and Frequently Asked Question (FAQ) process. SNC has made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for FNP associated with NFPA 805 Transition. The "LARITR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LAR/Transition Reports that document the results of the NFPA 805 Transition Reports. As shown in the table below, FNP has demonstrated substantial progress in the NFPA 805 transition process.
LARITR Topic Approximate Current Milestone Reference
% Complete Completion Date N/A Safe shutdown Analysis Update 95%
4th Quarter / 2010 (pre-requisite task) 4.1 Fundamental FP Program 10%1 2 nd Quarter / 2011 Attachment A Elements and Minimum Design Requirements (Table B-i) - Fire Area Specific 4.1 Fundamental FP Program 100% 3 1 st Quarter / 2009 Attachment A Elements and Minimum Design Requirements (Table B-i) - Non-Fire Area Specific 4.2.1 Nuclear Safety Capability 100%3,1 1 s1 Quarter / 2010 Attachment B Assessment - Methodology (Table B-2)
Section 4.2.2 Nuclear Safety Capability 45%1, 3,5 1 st Quarter / 2011 Attachment C Assessment - Fire Area - by - Fire Area Review (Table B-3)
Section 4.3 Non Power Operational Modes 50%2, 5 2 nd Quarter / 2011 Attachment D (Table F-i)
Section 4.4 Radioactive Release (Table G-1) 95%2.4 4th Quarter /2010 Attachment E 4.5.1 Fire PRA Development 41%5 3 rd Quarter/2011 N/A Compilation of LAR documents 0%
1 st Quarter/2012 and review by Site & Corporate personnel E1-1
Joseph M. Farley Units 1 and 2 Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request Note 1 - Completion of these tables contain open items that may require fire PRA to close (fire risk evaluations).
Note 2 - Although required for transition to NFPA 805 this is a new requirement and does not require enforcement discretion Note 3 - Will be revised due to Safe and Stable position - 4 th quarter 2010 Note 4 - Will be revised for Lessons Learned through the pilot process 2nd quarter 2011 Note 5 - Will include resolution of multiple spurious operation and operator manual action issues.
Physical Modifications While physical plant modifications may be identified as part of the transition effort, no physical plant modifications have been performed to address any fire protection issues to date. Any plant modifications identified to be required will be included in the LAR submittal letter and will include a schedule and commitments for the plant modifications.
NFPA 805 Monitoring Program Federal Register Notice 73 FR 52705 requested, as part of the status report for demonstrating substantial progress on the transition, that the status of the NFPA 805 monitoring program be provided. 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 both pilot plants.
Information Available On Site In addition to the information contained in this attachment, Federal Register Notice 73 FR 52705 requests that additional information be compiled /
documented on site and made available for inspection/audit.
Fire protection-related variances from the deterministic requirements have been entered into the site corrective action program and appropriate compensatory measures have been implemented in accordance with the existing fire protection program. This information is contained in the site's corrective action program and is available for review.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02 and FAQ 06-0012) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such actions comply with RIS 2005-07. The feasibility of the Operator Manual Actions has E1-2
Joseph M. Farley Units 1 and 2 Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) License Amendment Request been reviewed and any such action being considered as a compensatory measure is considered feasible. Additional compensatory measures are in place for any Operator Manual Actions with feasibility concerns. The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort. That feasibility review cannot be completed until other transition efforts are complete since the information generated during the transition effort may change required actions or the timing required for the actions. Some of the effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This is consistent with the pilot plants.
In summary, substantial progress has been made with regard to the NFPA 805 effort.
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