W3F1-2011-0061, Commitment to Provide 10 CFR 50.48(c) License Amendment Request and Request for Continued Enforcement Discretion

Commitment to Provide 10 CFR 50.48(c) License Amendment Request and Request for Continued Enforcement Discretion

ML112081640
Person / Time
Site:	Waterford
Issue date:	07/26/2011
From:	Kowalewski J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2011-0061
Download: ML112081640 (5)

Text

W3F1-2011-0061 July 26, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Commitment to Provide 10 CFR 50.48(c) License Amendment Request and Request for Continued Enforcement Discretion Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. NRC Policy Statement, Interim Enforcement Policy for Certain Fire Protection Issues, Federal Register Vol. 76, No. 133, Tuesday July 12, 2011, pages 40777 through 40779.

2. Summary of May 18,2011, Meeting with the Nuclear Energy Institute, Industry Representatives, and Licensees on Transitioning to National Fire Protection Association Standard 805, May 31, 2011.

Dear Sir or Madam:

In accordance with the NRC Interim Enforcement Policy for Certain Fire Protection Issues (Reference 1), Entergy Operations, Inc. (Entergy) commits to submit the license amendment request (LAR) implementing 10 CFR 50.48(c) for Waterford Steam Electric Station, Unit 3 (Waterford 3) by November 30, 2011. This LAR will seek NRC approval to apply the methodology under National Fire Protection Association (NFPA) 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generation Plants.

During a meeting conducted between members of Nuclear Energy Institute (NEI), industry representatives, and the NRC on May 18, 2011 (Reference 2), it was noted that Waterford 3 proposed to submit the LAR by the end of September 2011. It was also discussed in Reference 2, that these dates did not represent licensee commitments. Actual submittal dates would be based on licensee letters formally submitted to the NRC following additional assessment by the licensees.

The Waterford 3 Fire Protection Probabilistic Risk Assessment (PRA) is applying alternate PRA methods to those provided in NUREG/CR-6850 which are currently undergoing review by an EPRI Peer Review Group. Consistent with the NRC desire for these alternate methods to be resolved prior to submittal, Entergy is working toward timely resolution of Joseph A. Kowalewski Vice President, Operations Waterford 3 Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6715 Fax 504-739-6698 jkowale@entergy.com

W3F1-201 1-0061 Page 2 these changes in methods with the EPRI Peer Review Group. The proposed submittal by November 30, 2011 is based upon Entergys evaluation of the resources necessary to ensure the quality and completeness of the license amendment request and to allow for generic approval or plant specific application of these alternative methods.

Entergy believes that the proposed submittal date for the Waterlord 3 NFPA 805 LAR is responsive to the revised Policy Statement. Entergy requests that the enforcement discretion be extended to the LAR submittal commitment date.

This letter contains one new commitment.

If you have any questions or require additional information, please contact William J.

Steelman at 504-739-6685.

Sincerely,

,JS

Attachment:

List of Regulatory Commitments

W3F1-2011-0061 Page 3 cc:

Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 RidsRgn4MailCenter@nrc.gov NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 marlone.davis@nrc.gov Dean.Overland@nrc.gov U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Kaly.Kalyanam@nrc.gov

Attachment to W3F1-2011-0061 List of Regulatory Commitments

Attachment to W3F1-2011-0061 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check One)

COMMITMENT ONE-TIME ACTION CONTINUING COMPLIANCE SCHEDULED COMPLETION DATE (If Required)

Entergy Operations, Inc. (Entergy) commits to submit the License Amendment Request (LAR) implementing 10 CFR 50.48(c) for Waterford Steam Electric Station, Unit 3 (Waterford 3)

X November 30, 2011