ML112130508

Commitment to Submit a License Amendment Request to Transition to National Fire Protection Association (NFPA) Standard 805, and Request to Extend Enforcement Discretion

ML112130508
Person / Time
Site:	Waterford
Issue date:	08/10/2011
From:	Giitter J Division of Operating Reactor Licensing
To:	Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME6756
Download: ML112130508 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 10, 2011 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - RESPONSE TO REQUEST FOR EXTENDING ENFORCEMENT DISCRETION DEADLINE TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME6756)

Dear Sir or Madam:

By letter dated December 19, 2008 (Agencywide Document Access and Management System (ADAMS) Accession No. ML083530145), the Nuclear Regulatory Commission (NRC) granted a request by Entergy Operations, Inc. (Entergy, the licensee), to extend the period of enforcement discretion for submittal of a license amendment request (LAR) for the transition of Waterford Steam Electric Station, Unit 3 (Waterford 3) to Title 10 of the Code of Federal Regulations Section 50.48(c), "National Fire Protection Standard NFPA 805," until six months after the date of the safety evaluation approving the second pilot plant LAR. With the issuance of the Oconee safety evaluation on December 29, 2010, the NRC fully expected the Waterford 3 LAR to be completed and ready for submittal by June 29, 2011.

In 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 (ADAMS Accession No. ML111101452),

the Commission approved the NRC staff's request to permit sequencing of the NFPA 805 LARs through fiscal year (FY) 2014 to support the limited resources available to the staff so that timely reviews could be conducted. Through a series of public meetings held between industry representatives and the NRC staff earlier this year, a coordinated sequencing of LAR submittals was successfully developed that supported the staff's ability to review seven LARs in FY 2011, ten LARs in FY 2012, ten LARs in FY 2013, with the remaining LARs in FY 2014. During the public meeting of May 18, 2011, representatives of Waterford 3 informed the staff of its intent to submit the LAR in September 2011. While the exact date of the LAR submittal was not considered to be a license commitment, it was the staff's overall expectation that, in the context of supporting the Commission's endorsement of SECY-11-0033, the Waterford 3 LAR would be submitted during FY 2011.

By letter dated July 26,2011 (ADAMS Accession No. ML112081640), Entergy informed the staff of its commitment date to submit its NFPA 805 LAR for Waterford 3 by November 30, 2011.

Entergy requested that enforcement discretion be extended through this proposed submittal date in order to resolve changes to the Fire Probabilistic Risk Assessment (Fire PRA) methods that are currently undergoing review by the industry Fire PRA methods task force.

-2 Consistent with Commission direction in SRM SECY-11-0061, "A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," dated June 10, 2011 (ADAMS Accession No. ML111610616), the NRC staff may grant an extension, with proper justification, of enforcement discretion. While the staff recognizes Entergy's need for additional time to integrate the Task Force review of new methods or to conduct sensitivity analysis of any unreviewed methods, the staff also believes that the Waterford 3 NFPA 805 LAR should have been ready by June 29,2011, and that the concept of sequencing was developed solely to support the resource limitations of the staff. Therefore, in consideration of the above, enforcement discretion is hereby extended through September 30, 2011.

If you have any questions regarding this matter, please contact the project manager, N. Kalyanam, at 301-415-1480 or via e-mail kaly.kalyanam@nrc.gov.

Sincerely, A~{c<f~

\,)sePh G. Glitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: Distribution via Listserv

2 Consistent with Commission direction in SRM SECY-11-0061, itA Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50A8(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," dated June 10, 2011 (ADAMS Accession No. ML111610616), the NRC staff may grant an extension, with proper justification, of enforcement discretion. While the staff recognizes Entergy's need for additional time to integrate the Task Force review of new methods or to conduct sensitivity analysis of any unreviewed methods, the staff also believes that the Waterford 3 NFPA 805 LAR should have been ready by June 29, 2011. and that the concept of sequencing was developed solely to support the resource limitations of the staff. Therefore, in consideration of the above, enforcement discretion is hereby extended through September 30, 2011.

If you have any questions regarding this matter, please contact the project manager, N. Kalyanam, at 301-415-1480 or via e-mail kaly.kalyanam@nrc.gov.

Sincerely, IRAI Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: Distribution via Listserv DISTRIBUTION:

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