ML120380257

Request to Reinstate Enforcement Discretion License Amendment Request to Adopt NFPA Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition

ML120380257
Person / Time
Site:	Waterford
Issue date:	03/09/2012
From:	Marilyn Evans Division of Operating Reactor Licensing
To:	Entergy Operations
Kalynanam N, NRR/DORL/LP4, 415-1480
References
TAC ME7602
Download: ML120380257 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 9, 2012 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 - REQUEST TO REINSTATE ENFORCEMENT DISCRETION RE: LICENSE AMENDMENT REQUEST TO TRANSITION TO NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME7602)

Dear Sir or Madam:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated November 17, 2011, as supplemented on January 26, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML113220230 and ML12027A049, respectively), Entergy Operations Inc. (the licensee), submitted a license amendment request (LAR) for the Waterford Steam Electric Station, Unit 3 (Waterford 3). The proposed amendment would transition the fire protection licensing basis for Waterford 3 to the risk-informed, performance-based alternative based on National Fire Protection Association Standard 805 (NFPA 805).

The NRC staff reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to continue its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment. The result of the review was conveyed to you by electronic mail dated February 3, 2012 (ADAMS Accession No. ML120340128).

By letter dated November 17, 2011, you also requested that enforcement discretion for fire protection issues be extended through the remaining period of NRC review of the LAR and upon approval, transitioning implementation period.

-2 In accordance with the NRC Enforcement Policy, Section 9.1, "Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48}," in order to regain enforcement discretion you must: 1) submit an acceptable LAR, and 2) provide appropriate justification. For the initial LAR submittals, the NRC staff determined that since the industry has not completed its review of unreviewed analysis methods (UAMs) utilized in licensees' fire probabilistic risk assessments (PRAs), a sensitivity analysis was needed for each UAM to make the submittal acceptable for review. In a letter dated July 28,2011 (ADAMS Accession No. ML112081640), the licensee identified multiple UAMs within its fire PRA and decided to delay the LAR submittal to prepare a sensitivity analysis for each of these UAMs. The staff has reviewed the LAR, the supplemental information, and the additional UAM sensitivity analyses and determined the LAR package is acceptable for detailed review and the UAM additional analyses provided adequate justification to reinstate enforcement discretion from the date the NRC received the LAR.

Sincerely,

. J . i}

[ viLLUu...-u Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: Distribution via Listserv

ML112081640), the licensee identified multiple UAMs within its fire PRA and decided to delay the LAR submittal to prepare a sensitivity analysis for each of these UAMs. The staff has reviewed the LAR, the supplemental information, and the additional UAM sensitivity analyses and determined the LAR package is acceptable for detailed review and the UAM additional analyses provided adequate justification to reinstate enforcement discretion from the date the NRC received the LAR.

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

LPLIV r/f RidsNrrPMWaterford Resource PUBLIC RidsOeMailCenter Resource RidsAcrsAcnw_MailCTR Resource RidsOgcRp Resource RidsNrrDorl Resource RidsRgn4MailCenter Resource RidsNrrDorlLpl4 Resource DPickett, NRR/DORL RidsNrrDra Resource GGulla,OE RidsNrrDraAfpb Resource JRobinson, NRR/DRNAFPB RidsNrrDraApla Resource LFields, NRR/DRNAFPB RidsNrrLAJBurkhardt Resource PLain, NRR/DRNAFPB ADAMS Accession No. ML120380257 OFFICE NRR/DORLlLPL4/PM NRR/DORLlLPL4/LA NRR/DRAlAFPB/BC NRR/DRAIAPLAlBC AKlein (JRobinson DHarrison NAME NKalyanam JBurkhardt for) JSDinsmore for)

DATE 2/22/12 2/22/12 2/23/12 2/23/12 OFFICE NRR/OE/ NRR/DORLlLPL4/BC NRR/DORLID NAME TACampbeil MMarkley MEvans DATE 3/2/12 3/8/12 3/9/12