ML121090395

04/7/2011 Summary of Meeting with Southern California Edison to Discuss Future San Onofre, Units 2 and 3, License Amendment Submittal Related to Adoption of Risk-Informed NFPA-805

ML121090395
Person / Time
Site:	San Onofre
Issue date:	06/07/2012
From:	Hall J Plant Licensing Branch IV
To:	Plant Licensing Branch IV
Hall, J R, NRR/DORL/LPL4, 301-415-4032
References
TAC ME5875, TAC ME5876
Download: ML121090395 (4)

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• • • • ~ June 7, 2012 LICENSEE: Southern California Edison Company FACILITY: San Onofre Nuclear Generating Station, Units 2 and 3

SUMMARY

OF APRIL 7,2011, MEETING WITH SOUTHERN CALIFORNIA EDISON COMPANY ON PLANNED LICENSE AMENDMENT REQUEST TO IMPLEMENT NFPA-80S AT THE SAN ONOFRE NUCLEAR GENERAriNG STATION, UNITS 2 AND 3 (TAC NOS. MES87S AND MES876)

On April 7, 2011, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with representatives of Southern California Edison Company (SCE) at NRC Headquarters in Rockville, Maryland. SCE requested the pre-application meeting to brief the NRC staff about its planned submittal of a license amendment request (LAR) for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. The list of meeting participants is enclosed. SCE's presentation slides are available through the NRC's Agencywide Documents Access and Management System (ADAMS), at ADAMS Accession No. ML110970641. The meeting was noticed on March 22, 2011.

SCE discussed its plans to submit the LAR to revise the fire protection requirements in the Technical Specifications (TS) for SONGS, Units 2 and 3. The planned revisions are intended to adopt the risk-informed, performance-based alternative described in "National Fire Protection Association Standard NFPA 80S," as permitted by paragraph S0.48(c) of Title 10 of the Code of Federal Regulations (10 CFR). This meeting was one of a series of meetings between the NRC staff and operating reactor licensees to help the staff in assessing the industry's readiness to submit LARs for the implementation of NFPA 80S.

SCE previously indicated its intention to adopt NFPA 80S in a letter to the NRC dated March 28, 2008 (ADAMS Accession No. ML080920132). By letter dated November 2,2008 (ADAMS Accession No. ML082710004), the NRC confirmed that, based on SCE's commitments, enforcement discretion for fire protection issues would be in effect for a period of up to 36 months (until March 28, 2011), pending the licensee's submittal of an LAR to transition to NFPA 80S. On December 20,2010 (ADAMS Accession No. ML 103SS0491), SCE requested that the period of fire protection enforcement discretion be extended to a date 6 months past the NRC's approval of the second pilot plant LAR to transition to NFPA 80S (effectively June 29, 2011). The NRC granted the request in a letter dated March 14, 2011 (ADAMS Accession No. ML 11 063017S).

During the meeting, SCE described the detailed status of the analyses and reviews needed to transition to the risk-informed, performance-based approach of NFPA 80S, including the quality of the fire protection probabilistic risk analysis (PRA) for SONGS and peer review efforts, the fire modeling performed, the fire risk evaluations completed and planned, the preliminary results, and challenges to moving forward. The licensee stated that it intended to submit its LAR by

-2 June 29, 2011, but that certain actions could not be completed until after that date, such as containment walkdowns and PRA updates.

The NRC staff emphasized the importance of a high-quality fire PRA, and the need for the licensee to fully address the resolution of all findings and observations from independent reviews. The staff also emphasized the need for SCE to demonstrate that plant modifications are correctly modeled, in order to justify any estimated reductions in risk.

Shortly after this meeting, the NRC revised its approach to implementing NFPA 805. The Commission provided new direction to the staff in SRM-SECY-11-0061, "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 (ADAMS Accession No. ML111610616). By letter dated June 24,2011 (ADAMS Accession No. ML111780512). SCE committed to submit a LAR for SONGS by March 31, 2013, to transition to National Fire Protection Association Standard NFPA 805 in accordance with 10 CFR 50.48(c). In a response dated July 28,2011 (ADAMS Accession No. ML112020559), the NRC granted SCE's request to extend enforcement discretion, in accordance with the NRC's "Interim Enforcement Policy Concerning Enforcement Discretion for Certain Fire Protection Issues," as published in the Federal Register on July 12, 2011 (76 FR 40777).

No Public Meeting Feedback Forms were submitted for this meeting.

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JaUs R. Hall, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES NRC MEETING WITH SOUTHERN CALIFORNIA EDISON ON PROPOSED LICENSE AMENDMENT TO IMPLEMENT NFPA-805 AT SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 APRIL 7,2011 NAME AFFILIATION Alex Klein NRC/NRRIIDRNAFPB Paul Lain NRC/NRRIIDRNAFPB Randy Hall NRC/NRR/DORL Steven Laur NRC/NRR/DRA Steven Dinsmore NRC/NRR/DRNAPLA Greg Pick* NRC/RIV Neil O'Keefe* NRC/RIV Linda Conklin Southern California Edison (SCE)

Gary Chung SCE Robert Richter Jr. SCE Sal Dolcemascolo SCE Cyrus Vadoli* SCE Tom Basso NEI Bijan Najafi*1 SAIC Francisco Joglar*1 SAIC Steve Hardy*1 KGRS Group Fleur Meister*1 Tri-en Corporation Jenny Linger* Progress Energy William Cross* FP&L Robert Layton* PNL Peter Mazzaferro* Constellation Energy Mike Lilly* Constellation Energy Brent Waggoner* PG&E John Peale* PG&E Francy Mantine* FENOC Jim Belfiore* FENOC Larry Young* ANO Phil Bradley* Dominion Power

• Participated by telephone 1 Consultant to SCE Enclosure

ML111610616). By letter dated June 24, 2011 (ADAMS Accession No. ML111780512), SCE committed to submit a LAR for SONGS by March 31, 2013, to transition to National Fire Protection Association Standard NFPA 805 in accordance with 10 CFR 50.48(c). In a response dated July 28,2011 (ADAMS Accession No. ML112020559), the NRC granted SCE's request to extend enforcement discretion, in accordance with the NRC's "Interim Enforcement Policy Concerning Enforcement Discretion for Certain Fire Protection Issues," as published in the Federal Register on July 12, 2011 (76 FR 40777).

No Public Meeting Feedback Forms were submitted for this meeting.

IRA!

James R. Hall, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrPMSanOnofre Resource SLaur, NRR/DRA Branch Reading RidsNrrLAJBurkhardt Resource GPick, RIV RidsAcrsAcnw_MailCTR Resource RidsOgcRp Resource NOKeefe , RIV RidsNrrDorl Resource RidsOpaMail Resource PLain, NRR/DRAlAFPB RidsNrrDorlLpl4 Resource RidsRgn4MailCenter Resource SDinsmore, NRR/DRAIAPLA RidsNrrDra Resource TWertz, NRR WMaier, RIV RidsNrrDraAfpb Resource VDricks, OPA RIV RidsNrrDraApla Resource MMcCoppin, EDO RIV ADAMS Accession No. Meeting Notice ML110800582, Meeting SummarY: ML121090395x , Handouts ML110970641 OFFICE DORULPL4/PM DORULPL4/LA NRRlDRAlAFPB/BC DORULPL4IBC DORULPL4IPM IDATE NAME JRHall 5/17/12 JBurkhardt 4/26/12 AKlein (DFrumkin for) MMarkley 6/6112 6/7/12 JRHall 6/7/12