ML110630175
| ML110630175 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/14/2011 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Peter Dietrich Southern California Edison Co |
| Hall, J R, NRR/DORL/LPL4, 301-415-4032 | |
| References | |
| TAC ME5339, TAC ME5340 | |
| Download: ML110630175 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 14, 2011 Mr. Peter T. Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128
SUBJECT:
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 REQUEST FOR AN EXTENSION OF THE FIRE PROTECTION ENFORCEMENT DISCRETION (TAC NOS. MES339 AND MES340)
Dear Mr. Dietrich:
On September 10,2008, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (73 FR S270S) a revision to its Interim Enforcement Policy regarding enforcement discretion for certain fire protection issues, allowing licensees the option to request an extended enforcement discretion period for submittal of a license amendment request (LAR) if they are pursuing transition to Title 10 of the Code of Federal Regulations (10 CFR)
Section S0.48(c), "National Fire Protection Association Standard NFPA 80S."
This revision states that an additional period of enforcement discretion may be granted on a case-by-case basis if the NRC staff determines that a licensee has made substantial progress in its transition effort. This additional period of enforcement discretion, if granted, would end 6 months after the date of the safety evaluation approving the second pilot plant LAR. These changes are in accordance with COMSECY-08-0022, "Request for an Extension of Discretion for the Interim Enforcement Policy for Fire Protection Issues on 10 CFR Section S0.48(c),
"National Fire Protection Association Standard NFPA 80S," dated July 16, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081830S92), as approved by the Commission on August 19, 2008 (ADAMS Accession No. ML082320S79).
By letter dated December 20, 2010 (ADAMS Accession No. ML 1 03SS0491), Southern California Edison (SCE, the licensee) requested that the period of fire protection enforcement discretion for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, be extended to 6 months past the NRC approval of the second pilot plant LAR to transition to the risk-informed, performance-based standard for light-water reactors, NFPA 80S.
To be granted this extension, a licensee must:
- 1.
Compile a list of all fire protection-related noncompliances and the related compensatory measures for those noncompliances;
P. Dietrich
- 2
- 2.
Document that each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with the guidance in NRC Regulatory Issue Summary 2005-07, "Compensatory Measures to Satisfy the Fire Protection Program Requirements;'dated April 19, 2005 (ADAMS Accession No. ML042360547);
- 3.
Submit a description of the physical modifications performed, if any, to address existing risk-significant fire protection issues; and
- 4.
Submit a status report with milestones of the progress made in the following transition areas:
classical fire protection nuclear safety performance non-power operations the NFPA 805 monitoring program fire probabilistic risk assessment development The lists of noncompliances, compensatory measures, and Operator Manual Action feasibility determinations should be maintained on-site for inspector review and, at the NRC staffs discretion, mayor may not be used for the enforcement discretion extension review.
SCE's letter dated December 20,2010, noted that SUbstantial progress toward the completion of the transition to NFPA 805 has been made and requested that enforcement discretion be extended until 6 months past the approval of the second pilot plant LAR, and continue during the period between submittal of the LAR for SONGS and NRC's approval of that LAR. The 3-year period for enforcement discretion for NFPA 805 for SONGS is currently scheduled to expire on March 28,2011 (ADAMS Accession No. ML082710004).
SCE's enforcement discretion extension request for SONGS is summarized in the enclosed matrix. Based on the information provided in the licensee's letter, the NRC staff has determined that the licensee has addressed the specified criteria and has made sufficient progress towards transitioning to NFPA 805 to grant the extension of enforcement discretion. Accordingly, the enforcement discretion period for the transition to NFPA 805 for SONGS, Units 2 and 3, is hereby extended until 6 months after the date of the NRC safety evaluation approving the second pilot plant LAR, in accordance with the NRC's interim enforcement policy on fire protection.
P. Dietrich
- 3 If you have any questions regarding this matter, please contact the project manager, Randy Hall, at (301) 415-4032.
Sincerely, vv+. -<J ~-tt-~
J seph G. Giitter, Director D vision of Operating Reactor Licensing ffice of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362
Enclosure:
As stated cc w/encl: Distribution via Listserv
SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 Task Document Location Progress Reported by the Licensee Required
- 1. Compile a list of all fire protection-related noncompliances and related compensatory measures.
On-Site The licensee reported that the fire protection-related noncompliances and appropriate compensatory measures are entered in the site corrective action program and available for NRC review.
- 2. Document each Operator Manual Action put in place as a compensatory measure is feasible and reliable, in accordance with guidance in NRC Regulatory Issue Summary 2005-07.
On-Site The licensee reported that Operator Manual Actions that were put in place as compensatory measures were evaluated to ensure they were feasible and reliable and are documented onsite and available for NRC review.
- 3. Submit a description of the physical NRC HQ The licensee reported that while physical modifications that will be modifications performed to address existing required for National Fire Protection Association (NFPA) 805 risk-significant fire protection issues.
compliance have been identified as part of the transition effort, to date, no physical modifications have been installed. The licensee noted that any required plant modifications will be identified in the LAR and include a schedule for completion.
- 4. Submit a status report of the transition, broken down into the following major areas and include a scheduled milestones for completing the fire probabilistic risk assessment (PRA):
Classical Fire Protection Transition (in NRCHQ 55% Fundamental Fire Protection Program Elements and Minimum accordance with NFPA 805, Chapter 3).
Design Requirements (Table B-1), completion is scheduled for February, 2011.
Nuclear Safety Performance Criteria NRCHQ 80% Nuclear Safety Capability Assessment Methodology transition (in accordance with (Table B-2), completion scheduled for December 2010.
NFPA 805, Chapters 1, 2, and 4).
80% Nuclear Safety Capability Assessment, Fire Area-by-Fire Area Review (Table B-3), completion scheduled for April 2011.
Enclosure
- 2 Task Document Location Progress Reported by the Licensee Required Non-power operations.
NRCHQ 35% Non-Power Operations (Table F-1), completion scheduled for second quarter 2011.
NFPA 805 monitoring program.
NRC HQ 0% Monitoring Program, scheduled for late in the transition.
Fire PRA NRC HQ 100% Fire PRA development (peer reviewed July 2010).
5% Fire Risk Evaluations, completion scheduled April 2011.
Optional Radioactive Release On-site 85% on Radioactive Release (Table G-1), completion scheduled for January 2011.
SSD Analysis On-site 80% on Circuit Analysis, completion scheduled for April 2011.
Overall NRC staff assessment of progress: On balance, enough substantial progress has been made based on the overall reported progress taken as a whole.
P. Dietrich
- 3 If you have any questions regarding this matter, please contact the project manager, Randy Hall, at (301) 415-4032.
Docket Nos. 50-361 and 50-362
Enclosure:
As stated cc wlencl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPLIV r/f RidsAcrsAcnw _MaiICTR Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrDraAfpb Resource RidsNrrPMSanOnofre Resource RidsNrrLAJBurkhardt Resource RidsOeMailCenter Resource RidsOgcRp Resource RidsRgn4MailCenter Resource DPickett, NRR/DORLlLPL 1-1 PLain, NRRIDRAJAFPB Nlqbal, NRR/DRAJAFPB GGulla, OE/EB ADAMS Accession No. ML110630175 Sincerely, IRAJ Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
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