ML20149K625

NRR E-mail Capture - RAIs for SNC Fleet Fire Protection Exemption Requests

ML20149K625
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	05/27/2020
From:	John Lamb NRC/NRR/DORL/LPL2-1
To:	Lowery K Southern Nuclear Operating Co
References
Download: ML20149K625 (3)

Text

From: Lamb, John Sent: Wednesday, May 27, 2020 10:00 AM To: Lowery, Ken G.

Subject:

RAIs for SNC Fleet Fire Protection Exemption Requests Importance: High

Ken, By letter dated May 22, 2020, Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted exemption requests for the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2; Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2; and Vogtle Electric Generating Plant (Vogtle), Units 1 and 2 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20143A253). The exemption requests are related to the quarterly fire brigade drills and the annual live fire fighting training.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed your application and determined that additional information is needed to complete its detailed technical review to make an independent assessment regarding the acceptability of the proposed exemptions in terms of regulatory requirements. Below is the request for additional information.

1. The regulation Title 10 of the Code of Federal Regulations (10 CFR) 50.12, Specific exemptions, states: The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are

• Hatch, Units 1 and 2, are licensed under Appendix R. Identify which requirements in Appendix R SNC is requesting exemptions from for the quarterly fire brigade drills and annual live fire fighting training.

• Farley, Units 1 and 2, are licensed under National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. Identify which requirements in NFPA 805 SNC is requesting exemptions from for the quarterly fire brigade drills and annual live fire fighting training.

• Vogtle, Units 1 and 2, are licensed under Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.51 under SER (NUREG-1137) through Supplement 5. The Vogtle Fire Protection license condition states: Southern Nuclear shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, and submittals dated July 2, August 4 and 13, October 10 and 24, November 5, and December 19, 1986, and January 2, 1987, as approved in the SER (NUREG-1137) through Supplement 5 subject to the following provision: Southern Nuclear may make changes to the approved fire protection program without prior approval of the Commission, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Identify which requirement SNC is seeking an exemption from for the quarterly fire brigade drills and annual live fire fighting training. Explain the process SNC followed that resulted in determining that an exemption is appropriate for Vogtle, rather than self-approval per Vogtles fire protection license condition, or a license amendment request.

2. In the letter dated May 22, 2020, SNC stated: The facilities used to conduct live fire fighting training are unable to staff critical positions to provide, or support, due to the COVID-19 PHE. SNC will work with the live fire facilities to reschedule the annual live fire exercises as soon as practical after the PHE has ended. Indicate, which, if any of the SNC plants have the capability to perform live fire fighting training onsite. State which practices recommended by the Center for Disease Control and Prevention (CDC) to limit the spread of Coronavirus Disease 2019 (COVID-19) would prevent SNC from performing live fire fighting training onsite.

3. Provide the dates that each unit will be out of compliance with the regulations for quarterly fire brigade drills.

4. SNC is requesting the fire protection exemptions by June 2, 2020; however, the letter states for the annual live fire fighting training: The associated annual requirements will not be met on 12/31/2020. For each plant, provide the dates when it will no longer be in compliance with the particular requirement.

Hearing Identifier: NRR_DRMA Email Number: 608 Mail Envelope Properties (CH2PR09MB4444CA688063533730DCE9DCFAB10)

Subject:

RAIs for SNC Fleet Fire Protection Exemption Requests Sent Date: 5/27/2020 10:00:15 AM Received Date: 5/27/2020 10:00:00 AM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:

"Lowery, Ken G." <KGLOWERY@southernco.com>

Tracking Status: None Post Office: CH2PR09MB4444.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4025 5/27/2020 10:00:00 AM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: