PNP 2011-050, Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request

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

ML111790133
Person / Time
Site:	Palisades
Issue date:	06/27/2011
From:	Kirwin T Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
PNP 2011-050
Download: ML111790133 (3)

Text

,.Entergy

-===-

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Thomas P Kirwin Acting Site Vice President PNP 2011-050 June 27, 2011 10 CFR 50.48(c) u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request Palisades Nuclear Plant Docket 50-255 License No. DPR-20

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 Staff Requirements Memorandum - 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. Entergy Nuclear Operations letter to the NRC, Request for Extension of Discretion for the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805 - Supplement, dated November 14, 2008 (ADAMS Accession Number ML083400226)

4. Entergy Nuclear Operations letter to the NRC, Request for Extension of Discretion for the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805 - Supplement, dated November 25, 2008 (ADAMS Accession Number ML083370155)

5. NRC letter, Summary of Telephone Conference Call Held on June 30, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Operations, Inc. Regarding Progress on National Fire Protection Association Standard 805 Transition Activities, dated July 24, 2009 (ADAMS Accession Number ML091950413)

Document Control Desk Page 2

Dear Sir or Madam:

In accordance with Reference 1, and as approved by the Nuclear Regulatory Commission per Reference 2, Entergy Nuclear Operations, Inc. (ENO) commits to submit the license amendment request (LAR) implementing 10 CFR 50.48(c) for Palisades Nuclear Plant (PNP), by December 31,2012. This is a change to the ENO LAR submittal schedule in Reference 3 that committed to submit a LAR no later than six months after a NRC safety evaluation was issued for an amendment for the second pilot plant.

ENO requests that enforcement discretion be extended to correspond to the submittal commitment date. Per the enforcement discretion policy, once the LAR is submitted, the enforcement discretion would then continue until the NRC dispositions the LAR to transition to NFPA 805, consistent with Reference 1.

ENO is working on optimization of the Fire Probabilistic Risk Assessment to support the LAR. Work is in progress to develop and assess modification strategies, which include both physical plant and programmatic modifications, to determine appropriate changes.

The selected modifications will be reflected in the LAR.

Additionally, in Reference 4, ENO committed to monthly teleconference progress updates on the Palisades NFPA 805 transition activities. With the agreement of the NRC staff, as described in Reference 5, the monthly conference calls later became calls every two months. Because of the decision to allow a staggered approach for submittal of a LAR on the NFPA 805 transition activities and as concurred with by the NRC staff, ENO is withdrawing the commitment for the periodic conference calls. provides the revised commitment and the withdrawn commitment.

Should you have any questions concerning this submittal, please contact Jim Kuemin at 269-764-2728.

Sincerely, V ---..

~~~

tpk/jlk

Attachment:

1. Regulatory Commitments cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC Director, Office of Enforcement, USNRC Attn: Nicholas Hilton Senior Project Manager, Plant Licensing Branch, USNRC Attn: Douglas Pickett

ATTACHMENT 1 REGULATORY COMMITMENTS One revised commitment, from that in Reference 3 of the cover letter, is as follows:

Entergy Nuclear Operations, Inc. (ENO) will submit a license amendment request for implementation of 10 CFR 50.48(c), for the Palisades Nuclear Plant (PNP), no later than December 31, 2012.

One commitment, identified in Reference 4 and amended in Reference 5 of the cover letter, is withdrawn. The withdrawn commitment is as follows:

ENO will conduct a monthly [amended to every two months] teleconference with the NRC staff to discuss progress on the PNP National Fire Protection Association (NFPA) 805 transition activities. The teleconferences will continue until ENO submits the license amendment request to support the NFPA transition or until the NRC determines they are no longer necessary.

Page 1 of 1