LIC-11-0054, Notification of Extension of Commitment to Submit License Amendment Request (LAR) to Adopt NFPA 805 and Status Change of Enforcement Discretion at Fort Calhoun Station (Fcs), Unit No. 1

Notification of Extension of Commitment to Submit License Amendment Request (LAR) to Adopt NFPA 805 and Status Change of Enforcement Discretion at Fort Calhoun Station (Fcs), Unit No. 1

ML111610160
Person / Time
Site:	Fort Calhoun
Issue date:	06/09/2011
From:	Faulhaber H Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-11-0054, TAC ME6242
Download: ML111610160 (4)

Text

444 South 16th Street Mall Omaha, NE 68102-2247 LIC-11-0054 June 9, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

References:

1. Docket No. 50-285

2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk),

Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, dated June 9, 2008 (LIC-08-0069) (ML081620232)

3. NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Electric Power Research Institute - EPRI 1011989, Final Report, September 2005

4. NUREG/CR-6850, Supplement 1, Fire Probabilistic Risk Assessment Methods Enhancements, Supplement 1 to NUREG/CR-6850 and EPRI 1011989, Electric Power Research Institute - EPRI 1019259, Technical Report, September 2010

5. NRC Memorandum, Forthcoming Pre-Licensing Teleconference with Omaha Public Power District (TAC No. ME6242), dated May 16, 2011 (NRC-11-0050) (ML111330643)

6. Teleconference between NRC (L. E. Wilkins, et. al.) and OPPD (B. R.

Hansher, et. al.), NRC Relay of Information to OPPD on NFPA 805 Transition LAR Pre-Submittal Teleconference Presentation Slide 16, May 27, 2011

7. NRC Staff Requirements Memorandum, SRM-SECY-11-0033, Proposed NRC Staff Approach to Address Resource Challenges Associated with Review of a Large Number of NFPA 805 License Amendment Requests, dated April 20, 2011

SUBJECT:

Notification of Extension of Commitment to Submit License Amendment Request (LAR) to Adopt NFPA 805 and Status Change of Enforcement Discretion at Fort Calhoun Station (FCS), Unit No. 1 The Omaha Public Power District (OPPD) is notifying the Nuclear Regulatory Commission (NRC) of its extension of the June 9, 2011, commitment to submit the license amendment request (LAR) to adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. In Reference 2, OPPD submitted its letter of intent to adopt NFPA 805 at Fort Calhoun Station (FCS), Unit No. 1.

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U.S. Nuclear Regulatory Commission LIC-11-0054 Page 2 According to Reference 2, it was expected to take approximately 36 months to develop the NFPA 805 transition LAR; thus, OPPD requested enforcement discretion for 36 months.

This enforcement discretion expires on June 9, 2011, and should be extended in accordance with the NRCs Enforcement Policy as discussed in Reference 7.

As requested by the NRC in Reference 5, on May 26, 2011, OPPD participated in a public pre-licensing teleconference with the NRC to discuss the NFPA 805 transition LAR.

Subsequent to the pre-licensing teleconference, the NRC requested a follow-up teleconference with OPPD staff in order to relay additional information related to slide 16 of the presentation slides provided during the Reference 5 teleconference. Per discussion with Messrs. Donnie Harrison and Alex Klein during the follow-up teleconference on May 27th (Reference 6), the NRC indicated that it would be a more efficient use of the NRC resources as discussed in Reference 7, if the NRCs review of the LAR submittal did not include review of alternative fire probabilistic risk assessment (PRA) methods.

Prior to LAR submittal, the alternative methods will be reviewed by the Industry New Methods Peer Review Panel to demonstrate their acceptability for use in a fire PRA.

OPPD used NUREG/CR-6850 (Reference 3) and NUREG/CR-6850, Supplement 1 (Reference 4), in the development of the fire PRA model and the NFPA 805 transition LAR.

Reference 4 states, in part, Although these FAQs [frequently asked questions] represent interim solutions, it should be noted that not all solutions require longer-term research to develop a lasting and more complete solution. In addition, EPRI 1011989, NUREG/CR-6850 represents one way to develop a fire PRA. Alternative methods may be acceptable provided they can be supported by the state of the art in fire PRA model development.

OPPD used the draft version of frequently asked question (FAQ) 08-0050, Non-Suppression Probability, which was the version available at the time the fire PRA task was being performed. The current FAQ version, incorporated in NUREG/CR-6850, Supplement 1, was reviewed and it is qualitatively judged that implementation of this version will not impact the conclusions of the LAR. This judgment is primarily based on the low frequency of fire events where the FCS fire PRA credits manual suppression.

In addition to the draft FAQ 08-0050, OPPD used three alternative methods in the development of the FCS fire PRA model for severity factor/non-suppression probability for electrical cabinets; pump fire frequency; and diesel generator severity factor/non-suppression probability.

Therefore, based on the discussions with the NRC, OPPD is extending the commitment to transition to NFPA 805 until the alternative methods are approved by the industry review panel and the impact, if any, can be determined and incorporated into the FCS fire PRA model. OPPD will submit the LAR for transitioning to NFPA 805 no later than 90 days after the industry review panel completes its reviews of the alternative methods.

U.S. Nuclear Regulatory Commission LI C-11-0054 Page 3 As a result of the extension to the commitment for submitting the LAR for transitioning to NFPA 805 at FCS, it is also necessary to extend the existing enforcement discretion in accordance with the NRC's Enforcement Policy as discussed in Reference 7. As stated in Reference 7, OPPD understands that until such time as the Commission's decision on the revisions to the Enforcement Policy is enshrined in a resultant Staff Requirements Memorandum, the current enforcement discretion should be extended. Based on the revised NFPA 805 Transition LAR submittal commitment date, enforcement discretion should be extended accordingly. provides the one regulatory commitment being made in this letter. OPPD will submit the license amendment request for transitioning to NFPA 805 no later than 90 days from the industry review panel's completion of its review of the final alternative method proposed in the development of the FCS fire PRA model.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at 402-533-6894.

Sincerely, er Division Manager - Nuclear Construction and Projects HJF/JLM/dll

Attachment:

1. Regulatory Commitment c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

LIC-11-0054 Page 1 REGULATORY COMMITMENT Commitment(s) / Scheduled Completion Date OPPD will submit the license amendment request for transitioning to NFPA 805 no later than 90 days from the industry review panels completion of its review of the final alternative method proposed in the development of the FCS fire PRA model. [AR 48249].