RA-11-019, Request for Extension of Enforcement Discretion and Commitment to Submittal Dates for 10 CFR 50.48(c) License Amendment Requests

Request for Extension of Enforcement Discretion and Commitment to Submittal Dates for 10 CFR 50.48(c) License Amendment Requests

ML11188A058
Person / Time
Site:	Brunswick, Crystal River, Robinson
Issue date:	06/29/2011
From:	Alexander D Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-11-019
Download: ML11188A058 (5)

Text

10 CFR 50.48(c)

PO Box 1551 411 Fayetteville Street Mall Raleigh NC 27602 Serial: RA-11-019 June 29, 2011 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23 REOUEST FOR EXTENSION OF ENFORCEMENT DISCRETION AND COMMITMENT TO SUBMITTAL DATES FOR 10 CFR 50.48(c) LICENSE AMENDMENT REOUESTS

References:

1. 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 April 29, 2011

2. NRC Memorandum, "Staff Requirements - 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

3. Letter from Benjamin C. Waldrep to Nuclear Regulatory Commission (NRC) dated October 17, 2008, "Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition", ADAMS Accession Number ML083030138

4. NRC Letter to Jon A. Franke dated February 19, 2010, "Crystal River Unit 3 -Evaluation of the Request for an Extension of Enforcement Discretion in Accordance With the Interim Enforcement Policy for Fire Protection Issues During Transition to National Fire Protection Standard NFPA 805 (TAC No. ME2738)," ADAMS Accession Number ML100480260

5. NRC Letter to Eric McCartney dated November 18, 2010, "H. B. Robinson Steam Electric Plant, Unit No. 2 - Evaluation of Request for an Extension of Enforcement Discretion in Accordance With the Interim Enforcement Policy for Fire Protection Issues During Transition to National Fire Protection Standard NFPA 805 (TAC No. ME4460)", ADAMS Accession Number ML102670039

RA-1 1-019 Page 2 of 3

6. Letter from Jon A. Franke to NRC dated November 25, 2009 "Crystal River Unit 3 - Request for an Extension of Enforcement Discretion in Accordance with the Interim Enforcement Policy for Fire Protection Issues During Transition to National Fire Protection Standard NFPA 805",

ADAMS Accession Number ML093340428 Ladies and Gentlemen:

In accordance with Reference 1, and as approved by the Commission per Reference 2, Carolina Power

& Light Company, now doing business as Progress Energy Carolinas, Inc., and Florida Power Corporation, now doing business as Progress Energy Florida, Inc., commit to submit License Amendment Requests (LARs) implementing 10 CFR 50.48(c) as follows:

" Brunswick Steam Electric Plant (BSEP, Unit Nos. 1 and 2) by September 30, 2012

" H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP, Unit No. 2) by September 30, 2013

" Crystal River Unit 3 (CR-3) Nuclear Generating Plant by July 1, 2014 This is a change to the schedules identified in References 3, 4, and 5. Enclosure 2 to this letter contains one revision to an existing commitment from Reference 6 and two new commitments.

The requested date for BSEP, Unit Nos. 1 and 2 is September 30, 2012. This date was chosen to allow for completion of the Fire Probabilistic Risk Assessment modeling, completion of NFPA 805 transition Fire Risk Evaluations, and identification of required NFPA 805 modifications.

The requested date for HBRSEP, Unit No 2 is September 30, 2013. This date was chosen to allow for completion of the Fire Probabilistic Risk Assessment modeling, completion of NFPA 805 transition Fire Risk Evaluations, and identification of required NFPA 805 modifications. Some NFPA 805 modifications have been implemented at HBRSEP, Unit No. 2. Enclosure 1 is a list of completed modifications and schedule for proposed modifications at HBRSEP, Unit No. 2.

The requsted date for CR-3 is July 1, 2014. This date was chosen to allow for the Fire Probabilistic Risk Assessment modeling of Extended Power Uprate modifications and the final resolution of the containment issue. CR-3 has been in an outage since the fall of 2009. After cutting an opening in containment to facilitate the replacement of steam generators, workers discovered a delamination in the containment wall. Earlier this year during tendon retensioning following significant analysis and repair efforts, another delamination was discovered. The reactor will remain defueled while repairs are made to the containment structure. The preliminary schedule forecast estimates a return to service sometime in 2014. Negligible fire risk exists while CR-3 is defueled. A list of modifications and the schedule for their implementation will not be finalized until the resolution of the containment issue and will be contained in the LAR.

New program modifications will continue to be identified, designed, and implemented during LAR development for each plant. Associated procedure changes, process updates, and required training will occur, along with modification implementation.

Carolina Power & Light Company and Florida Power Corporation request that the enforcement discretion be extended to correspond to the new submittal commitment dates. Per the enforcement discretion policy, once the LARs are submitted, the enforcement discretion will continue until the NRC dispositions the LARs, consistent with References 1 and 2.

RA-11-019 Page 3 of 3 This letter contains one revised and two new regulatory commitments as identified in Enclosure 2.

Please contact me at (919) 546-5357 if you have any questions Sincerely, Donna Alexander Interim Manager - Nuclear Regulatory Affairs

Enclosures:

1. HBRSEP, Unit No. 2, NFPA 805 Completed and Proposed Plant Modifications

2. List of Regulatory Commitments kmh cc: Victor McCree, Region II Regional Administrator Roy Zimmerman, Director, Office of Enforcement Doug Pickett, Senior Project Manager, Plant Licensing Branch, DORL USNRC Resident Inspector - BSEP, Unit Nos. I and 2 USNRC Resident Inspector - CR3 USNRC Resident Inspector - HBRSEP, Unit No. 2 F. Saba, NRR Project Manager - BSEP, Unit Nos. 1 and 2; CR3 B. Mozafari, NRR Project Manager - HBRSEP, Unit No. 2

RA-11-019 Enclosure I Page 1 of 1 HBRSEP, Unit No. 2, NFPA 805 Completed and Proposed Plant Modifications NFPA 805 Completed Modifications Implementation Description Date Backup Instrument Air for Charging Pumps Speed Control 2004 Appendix R Pressurizer PORV & Charging Pump Make-up 2005 Modification Replacement of Hemyc Fire Barrier Wrap 2006 Appendix R Emergency Lighting Modifications 2007 Evaluation and Modifications of the Hot Shutdown MOVs for IN 92-18 2008 Key Locked Isolation Switch in Control Room to Isolate DC Electrical 2008 Power to Key Auxiliary Panels Evaluation and Modifications of the Cold Shutdown MOVs for 2010 IN 92-18 Protect the E-Bus Incoming Line Breakers from Spurious Operations for 2010 a Postulated Fire in the Turbine Bldg.

Rerouting of ERFIS Cables to Protect Safe Shutdown Equipment 2010 Auto Reload of Battery Chargers on a LOOP 2010 Installation of Fire Walls Between Transformers and Between 2010 Transformers And Turbine Building NFPA 805 Proposed Modifications Description Planned Implementation Auto Start/Auto Load of Dedicated Shutdown Diesel Generator on 3 rd quarter 2011 Loss of All AC Power RO-27, LCV-1 15C (Volume Control Tank Outlet) Power Cable Reroute 2012 February 2012 Protect Steam Generator Wide Range Level Indication From a RO-27, February Postulated Fire in the MDAFW Pump Room and the Turbine Bldg. 2012 Protect Steam Isolation Valve Circuits RO-27, February 2012 New program modifications will continue to be designed and implemented as a result of continued analysis for NFPA 805 transition. Currently a study is being performed to investigate the installation of alternate RCP Seal Injection. Incipient Detection System Modifications are also being considered.

After completion of additional analyses, it will be determined what additional modifications are required for NFPA 805 compliance. A list of modifications and the schedule for their implementation will be finalized with the development of the License Amendment Request.

RA-1 1-019 Enclosure 2 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following tables contain a revised regulatory commitment associated with the Licensing Amendment Request submittal by CR-3 and new regulatory commitments for BSEP, Unit Nos. I and 2 and HBRSEP, Unit No. 2. CR-3 currently has a regulatory commitment to submit a License Amendment Request (LAR) for transitioning to NFPA 805 by June 29, 2011. This letter changes the due date of that regulatory commitment.

Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company and Florida Power Corporation. They are provided to the NRC for the NRC's information and are not regulatory commitments.

Regulatory Commitment Change Due Date CR-3 will submit a License Amendment Request (LAR) for transitioning July 1, 2014 to NFPA 805. The LAR will include a plant-wide assessment to identify fire areas and fire hazards and evaluate compliance with the existing CR-3 fire protection licensing basis. This assessment will be performed in accordance with NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)."

New Regulatory Commitments Due Date BSEP, Unit Nos. I and 2 will submit a License Amendment Request September 30, 2012 (LAR) for transitioning to NFPA 805. The LAR will include a plant-wide assessment to identify fire areas and fire hazards and evaluate compliance with the existing BSEP, Unit Nos. 1 and 2 fire protection licensing basis. This assessment will be performed in accordance with NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)."

HBRSEP, Unit No. 2 will submit a License Amendment Request (LAR) September 30, 2013 for transitioning to NFPA 805. The LAR will include a plant-wide assessment to identify fire areas and fire hazards and evaluate compliance with the existing HBRSEP, Unit No. 2 fire protection licensing basis. This assessment will be performed in accordance with NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)."