View source for L-HU-08-018, Units 1 and 2, Request for Extension of Enforcement Discretion for a Revised Date for 10 CFR 50.48(C) License Amendment Request Submittal

{{Adams
| number = ML082400208
| issue date = 08/26/2008
| title = Units 1 and 2, Request for Extension of Enforcement Discretion for a Revised Date for 10 CFR 50.48(C) License Amendment Request Submittal
| author name = Reddemann M
| author affiliation = Nuclear Management Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000263, 05000282, 05000306, 07200010
| license number = DPR-022, DPR-042, DPR-060
| contact person = 
| case reference number = L-HU-08-018
| document type = Letter type:L
| page count = 6
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Committed to Nuclear Excellence                              Nuclear Management Company, LLC August 26,2008                                                                L-HU- 08-018 10 CFR 50.48 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Prairie Island Nuclear Generating Plant,           Monticello Nuclear Generating Plant Units 1 and 2                                      Docket 50-263 Dockets 50-282, 50-306 and 72-10                   License No. DPR-22 License Nos. DPR-42 and DPR-60 REQUEST FOR EXTENSION OF ENFORCEMENT DISCRETION FOR A REVISED DATE FOR 10 CFR 50.48(C) LICENSE AMENDMENT REQUEST SUBMITTAL

==References:==

Letter from NMC to NRC "Letter of lntent to Transition to 10CFR 50.48 (c) -
National Fire Protection Association Standard NFPA 805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition", dated November 30, 2005.
Letter from NMC to NRC "Revision of and Supplement to Letter of lntent Transition to 10CFR 50.48 (c) - National Fire Protection Association Standard NFPA 805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition", dated March 14, 2006.
Letter from NRC to NMC, "Letter of lntent to Adopt Title 10 of the Code of Federal Regulations, Part 50.48(c) for Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, Units 1 and 2, and Prairie Island Nuclear Generating Plant, Units 1 and 2" (TAC Nos. MC 9289 through MC9294), dated September 7, 2006.
In 2005, NMC decided to transition the fire protection licensing basis for PINGP and MNGP to the alternative in 10 CFR 50.48(c). NMC submitted a letter of intent for PINGP and MNGP to the NRC on November 30,2005 (Reference I ) (ML053460342) to adopt NFPA 805 in accordance with 10 CFR 50.48(c). Please note that NMC is no longer the operating authority for Palisades Nuclear Plant, Point Beach Nuclear Plant and Duane Arnold Energy Center.
By letter dated March 14, 2006 (Reference 2), NMC revised the response dated November 30, 2005 proposing a new schedule for the transition of the NMC plants. In NRC correspondence dated September 7, 2006 (Reference 3), the staff did not grant extensions beyond the 36 months for MNGP and PINGP.
414 Nicollet Mall, MP-4 Minneapolis, MN 55401

Document Control Desk Page 2 As of August 19, 2008, the Commission has approved the staff's proposed revision to the NRC Enforcement Policy and its publication in the Federal Register (COMSECY 022). This revision will extend the existing enforcement discretion period for a period of six months beyond the date of the safety evaluation approving the second pilot plant license amendment request to transition to NFPA 805. The extension is not automatic, and would be granted on a case-by-case basis, and only after a licensee demonstrates substantial progress in its NFPA 805 transition efforts.
As requested in COMSECY-08-022 and subsequent Commission approval, NMC is requesting that enforcement discretion be granted for PlNGP and MNGP until 6 months after the Safety Evaluation is issued for the second pilot plant based upon the demonstrated substantial progress toward completion of NFPA 805 transition.
Enclosures 1 and 2 provide the requested information for PlNGP and MNGP respectively demonstrating substantial progress in NMC's NFPA 805 transition efforts.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
Vice President- Nuclear Operations Support Nuclear Management Company, LLC

==Enclosures:==
2 Cc:     Administrator, USNRC, Region Ill USNRC NRR Project Manager, PlNGP USNRC Senior Resident Inspector, PlNGP ,
USNRC NRR Project Manager MNGP               I USNRC Senior Resident Inspector, MNGP I

Enclosure 1 Page 1 of 2 Prairie Island Nuclear Generating Plant Progress on NFPA 805 Transition COMSECY-08-022 requested information from licensees on demonstrated progress toward completion of NFPA 805 transition, as a condition of granting an extension of enforcement discretion. NMC has made substantial progress in the PlNGP NFPA 805 transition effort. NMC has participated in the NEI NFPA 805 Task Force and Fire PRA task forces and Frequently Asked Question (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for PlNGP associated with NFPA 805 Transition. The "LARITR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LARITransition Reports that document the results of the NFPA 805 Transition Reports. As shown in the table below, PlNGP has demonstrated substantial progress in the NFPA 805 transition process.
Prairie Island NFPA 805 Pronress Table LARITR                                             Approximate       Current Milestone Topic Reference                                            % Complete          Schedule Date Not Applicable    Manual Action Compliance Review         100%
(per RIS 2006-10) 4.1              Fundamental FP Program             100%'
Attachment A       Elements and Minimum Design Requirements (Prepare Table B-I )
4.2.1             Nuclear Safety Capability          100%'
Attachment B        Assessment - Methodology (Prepare Table B-2)
Section 4.2.2         Nuclear Safety Capability          45%'                9126108~
Attachment c     Assessment - Fire Area - by - Fire Area Review (Prepare Table 8-3)
Section 4.3       Non Power Operational Modes            25%               11I15108~
Attachment D            (Prepare Table F-I)
Section 4.4            Radioactive Release               70%                9126108~
Attachment E            (Prepare Table G-I) 4.5.1              Fire PRA Development               40%                6126109~
Note 1 -The purpose of task is to complete the appropriate table. Upon completion, open items will exist that may require fire PRA to resolve.
Note 2 - Schedule dates are milestones and do not constitute commitments.

Enclosure 1 Page 2 of 2 Prairie Island Nuclear Generating Plant Physical Modifications While physical modifications may be identified as part of the transition effort, no physical modifications have been performed to address any fire protection issues. Any modifications required will be identified in the LAR submittal letter and that letter will provide a schedule and commitments for any such modifications.
NFPA 805 Monitoring Program The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort. This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-022 required additional information to be compiledldocumented on site and available for inspectionlaudit.
Fire protection-related non-compliances have been entered into the site corrective action program and appropriate compensatory measures in accordance with the existing fire protection program have been implemented. This information is contained within the site's corrective action program and is available for review.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such actions comply with RIS 2005-07. The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible. The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification andlor revision due to the information generated by the NFPA 805 transition effort. That feasibility review can not be complete until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for required actions. Some of that effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This approach is consistent with the pilot plants.

Enclosure 2 Page 1 of 2 Monticello Nuclear Generating Plant Progress on NFPA 805 Transition COMSECY-08-022 requested information from licensees on demonstrated progress toward completion of NFPA 805 transition, as a condition of granting an extension of enforcement discretion. NMC has made substantial progress in the MNGP NFPA 805 transition effort. NMC has participated in the NEI NFPA 805 Task Force and Fire PRA task forces and Frequently Asked Question (FAQ) process and made significant efforts in performing work activities in an effective manner, while utilizing the lessons learned from the Pilot Plant process.
The following table represents the major work activities for MNGP associated with NFPA 805 Transition. The "LARTTR Reference" column refers to the referenced section of the Pilot Plant NFPA 805 LARTTransition Reports that document the results of the NFPA 805 Transition Reports. As shown in the table below, MNGP has demonstrated substantial progress in the NFPA 805 transition process.
Monticello NFPA 805 Proqress Table LARrrR                                             Approximate       Current Milestone Topic Reference                                            % Complete          Schedule Date Not Applicable    Manual Action Compliance Review         100%
(RIS 2006-10) 4.1             Fundamental FP Program              90%'              10/30/2008~
Attachment A       Elements and Minimum Design Requirements (Prepare Table B-I )
4.2.1             Nuclear Safety Capability          100%'
Attachment B        Assessment - Methodology (Prepare Table 8-2)
Section 4.2.2         Nuclear Safety Capability          40%'               11126108~
Attachment c     Assessment - Fire Area - by - Fire Area Review (Prepare Table B-3)
Section 4.3       Non Power Operational Modes            30%               11/26/08~
Attachment D            (Prepare Table F-I)
Section 4.4            Radioactive Release               45%                9126108~
Attachment E            (Prepare Table G-I) 4.5.1              Fire PRA Development               34%                7131109~
Note 1 -The purpose of task is to complete the appropriate table. Upon completion, open items will exist that may require fire PRA to resolve.
Note 2 - Schedule dates are milestones and do not constitute commitments.

Enclosure 2 Page 2 of 2 Monticello Nuclear Generating Plant Physical Modifications While physical modifications may be identified as part of the transition effort, no physical modifications have been performed to address any fire protection issues. Any modifications required will be identified in the LAR submittal letter and that letter will provide a schedule and commitments for any such modifications.
NFPA 805 Monitoring Program The NFPA 805 monitoring program is highly dependent on fire PRA results as well as the traditional fire protection program issues. Therefore, the monitoring program is one of the last items to be completed during the transition effort. This is consistent with the manner in which both pilot plants are proceeding.
Information Available On Site In addition to the information contained in this attachment, COMSECY-08-022 required additional information to be compiled/documented on site and available for inspectionlaudit.
Fire protection-related non-compliances have been entered into the site corrective action program and appropriate compensatory measures in accordance with the existing fire protection program have been implemented. This information is contained within the site's corrective action program and is available for review.
Unallowed Operator Manual Actions (those designated as bin H under NEI 04-02) are considered compensatory measures according to the fire protection program. The fire protection program requires that any such actions comply with RIS 2005-07. The feasibility of the Operator Manual Actions has been reviewed and any such action being considered as a compensatory measure is considered feasible. The feasibility review for these actions was done based on the existing safe shutdown analysis. This feasibility may require modification and/or revision due to the information generated by the NFPA 805 transition effort. That feasibility review can not be complete until most other transition efforts are complete since the information generated during the transition effort may change which actions are required or may change the timing required for required actions. Some of that effort is tied to the completion of the fire PRA. Therefore, the feasibility of some of these actions will be reviewed at the completion of the fire PRA effort. This approach is consistent with the pilot plants.}}