NL-13-2180, Edwin Hatch - Letter of Intent to Adopt the 2001 Edition of NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants
| ML13280A299 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/04/2013 |
| From: | Madison D Southern Co, Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-13-2180 | |
| Download: ML13280A299 (3) | |
Text
Dennis R. Madison Vice President - Hatch October 4, 2013 Docket Nos.: 50-321 50-366 Southern Nuclear Operating Company, Inc.
Plant Edwin I. Hatch 11028 Hatch Parkway North Baxley, Georgia 31513 Tel 912.537.5859 Fax 912.366.2077 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant SOUTHERN <<\\
COMPANY NL-13-2180 Letter of Intent to Adopt the 2001 Edition of NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" Ladies and Gentlemen:
This letter serves to inform the NRC of Southern Nuclear Operating Company's (SNC) intent to adopt the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 edition, in accordance with 10 CFR 50.48(c) for Hatch Nuclear Plant Units 1 and 2.
The transition to the performance-based standard for fire protection will commence in the last quarter 2013, and it is expected to take approximately thirty-six months to develop the License Amendment Request (LAR). The schedule is subject to change depending on the extent of physical plant modifications and/or changes to the fire protection program determined necessary to comply with NFPA 805. If necessary, an updated schedule will accompany the License Amendment Request required under 1 OCRF50.48(c)(3)(i).
SNC understands that enforcement discretion for thirty-six months is provided as indicated in Section 9.1 of the Enforcement Policy for the preparation and submittal of a LAR to facilitate the transition to 10 CFR 50.48(c). Once an acceptable LAR is submitted, enforcement discretion will continue to be in place until the NRC dispositions the LAR. As outlined in the Enforcement Policy, enforcement discretion will be in effect beginning from the date of this letter of intent. The Enforcement Policy provides guidelines for enforcement discretion for identified non-compliances. Those non-compliances must be entered into the licensee's Corrective Action Program with appropriate compensatory actions,
must not be associated with findings that the Reactor Oversight Significance Determination Process would evaluate as RED, or would not be categorized as Severity Level 1.
U. S. Nuclear Regulatory Commission NL-13-2180 Page 2 The Hatch Nuclear Plant NFPA 805 transition process consists of three phases:
Phase 1 - Preliminary Assessment of the Fire Protection Program
- Technical and regulatory assessments performed to determine the feasibility and practicality of performing the transition.
Phase 2 - Reviews and Engineering Analysis
- Completion of the Fire Protection Probabilistic Risk Assessment (PRA)
- Fundamental Fire Protection Program and Design Elements Review
- Nuclear Safety Performance Criteria Transition Review
- Non-Power Operational Mode Transition Review
- Radiological Release Transition Review
- Change Evaluations
- License Amendment Request Phase 3-Implementation
- Program Documentation
- Configuration Control
- Monitoring The process will be considered complete upon receipt of the approved license amendment authorizing the transition to NFPA 805. Because the transition to the NFPA 805 performance-based standard is a voluntary initiative, this correspondence contains no regulatory commitments.
If you have any questions, please contact Ken McElroy at 205-992-7369.
Sincerely,
~~~
D.R. Madison Vice President - Hatch DRM/jkb/lac cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. A. Madison, Vice President-Hatch Mr. B. L. lvey, Vice President-Regulatory Affairs Mr. B. J. Adams, Vice President-Fleet Operations RTYPE: CHA02.004
U. S. Nuclear Regulatory Commission NL-13-2180 Page 3 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Hatch Mr. E. D. Morris, Senior Resident Inspector - Hatch