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 Southern Nuclear Vice President - Hatch Operating Company, Inc.
Plant Edwin I. Hatch 11028 Hatch Parkway North Baxley, Georgia 31513 Tel 912.537.5859 Fax 912.366.2077 SOUTHERN << \
COMPANY October 4, 2013 Docket Nos .: 50-321 NL-13-2180 50-366 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington , D. C. 20555-0001 Edwin I. Hatch Nuclear Plant 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-si x 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 requ ired under 1OCRF50.48(c)(3)(i) .
SNC understands that enforcement discretion for thirty-six months is provided as indicated in Section 9.1 of the Enforcement Pol icy 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