ML11277A285

NRR E-mail Capture - FW: ME6818 - NFPA 805 Adoption Acceptance Review RAIs and Clarification Conference Call of 9/30/2011

ML11277A285
Person / Time
Site:	Duane Arnold
Issue date:	10/03/2011
From:	Feintuch K Division of Operating Reactor Licensing
To:	Swenzinski L NextEra Energy Duane Arnold
References
TAC ME6818
Download: ML11277A285 (4)

Text

NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Monday, October 03, 2011 7:30 PM To: Swenzinski, Laura

Subject:

FW: ME6818 - NFPA 805 adoption acceptance review RAIs and clarification conference call of 9/30/2011 Attachments: DAEC Acceptance Review Agenda.docx Attached is the final agenda and list of RAI items to support the acceptance review. These items were discussed during the 11:30 ET (10:30 CT) clarification conference call on 9/30/2011 between NRC staff and NextEra Energy Duane Arnold staff (Duane Arnold, the licensee) regarding the NFPA 805 LAR acceptance review.

There are no changes from the version issued on Thursday, 9/30/2011, except for improved formatting of text.

At the conclusion of the call, it was mutually agreed that Duane Arnold would respond on or before 10/14/2011.

Attendees:

NRC staff and support staff Duane Arnold staff and NextEra support NRC Laura B. Swenzinski (licensing contact)

Feintuch, Karl (by phone, licensing contact) Anil Julka Lain, Paul Ted Kulczyzky Harrison, Donnie Bill Cross Barrett, Harold Vinny Rubano Dinsmore, Stephen Herb Giorgio ONeal, Daniel Russ Severson Gallucci, Ray Roy Hanson Iqbal, Naeem Gary Ellis Moulton, Charles Howe, Andrew Robinson, Jay (by phone)

Andrukat, Dennis PNNL Short, Steve Layton, Robert JR Coles, Garill Bohlander, Karl CNWRA Mintz, Todd Janssen, Marc Karl Feintuch USNRC 301-415-3079 1

Hearing Identifier: NRR_PMDA Email Number: 165 Mail Envelope Properties (Karl.Feintuch@nrc.gov20111003192900)

Subject:

FW: ME6818 - NFPA 805 adoption acceptance review RAIs and clarification conference call of 9/30/2011 Sent Date: 10/3/2011 7:29:49 PM Received Date: 10/3/2011 7:29:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients:

"Swenzinski, Laura" <Laura.Swenzinski@nexteraenergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1256 10/3/2011 7:29:00 PM DAEC Acceptance Review Agenda.docx 28298 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Duane Arnold Energy Center NFPA 805 LAR Acceptance Review Clarification Call Agenda

1) Two incomplete or incompletely reported sensitivity analyses on un-reviewed analysis methods a) Page V-3: A qualitative argument was used as the acceptability basis for use of a hot work pre initiator factor of 0.01. The LAR states that this was only applied in the Cable Spreading Room bounding fire scenario which has a relatively low contribution to fire risk of 9.85E-07/yr b) Page V-3: A quantitative sensitivity estimate is used as the acceptability basis for the transient heat release rate. The LAR states transient fires contribute 1% to overall CDF and LERF and a best estimate sensitivity study showed that using the NUREG/CR-6850 heat release rate would increase CDF and LERF by no more than 1%.

Demonstration of a completed sensitivity study should include at least a brief description of the licensees model/method and the general model/method employed for the sensitivity study to which the licensees model was compared. The results of the sensitivity study in terms of maximal expected changes to the change-in-risk results should be provided.

2) Insufficient information to determine whether the discussion of the focused-scope peer review met the endorsed description of a focused scope review.

Page U-2: The LAR states, This DAEC Focused PRA Peer Review assessed all previous 2007 full-scope peer review findings and suggestions, including the adequacy of their dispositions. A brief description of the focused scope peer review and how that review was consistent with the definition of focused scope peer review in the ASME standard as endorsed by RG 1.200 is needed.

3) Insufficient information to determine that the Monitoring Program is acceptable for review.

It appears, based on the description provided in section 4.6 of the LAR, the Duane Arnold NFPA 805 monitoring program will be separate and independent from the Maintenance Rule program. If this is so, more detailed information is needed to explain how monitoring will be accomplished for Nuclear Safety systems, structures and components.

4) Completion status of the Fundamental Fire Protection Program review Attachment S, Table S-2, Implementation Items, item numbers 10 and 11 indicate that Code Compliance evaluations to NFPA 72 and NFPA 90A have not been completed. A discussion is needed regarding the extent of condition and the level of compliance of the DAEC fire protection program if these code compliance reviews are incomplete.

September 30, 2011 10:30 CT/11:30 ET

Duane Arnold Energy Center NFPA 805 LAR Acceptance Review Clarification Call Agenda

5) Gap Assessment Consistent with Regulatory Issue Summary (RIS) 2007-06, licensees are currently expected to address the standards and guidance documents endorsed by Regulatory Guide (RG) 1.200, Revision 2, commensurate with the associated risk-informed applications. The licensee describes the peer review of the fire PRA against this regulatory guide. However, the licensee does not address if this peer review, or another peer review or self-assessment, was also performed to this revision of RG 1.200 for the internal events PRA, on which the fire PRA is developed. Please describe how the Duane Arnold Internal Events PRA comports with RG 1.200, Revision 2.

6) SharePoint Portal The staff requests the licensee provide a SharePoint Portal for site documents. The staff will provide a list of references they would like to review and a list of reviewers requiring a need-to-know. This portal will be beneficial to identify only the specific site information required to be submitted to the NRC for the staff to make the license amendment safety evaluation.

7) Site Audit The staff request the licensee schedule a site audit for December 12-16, 2011, at its Duane Arnold Energy Center Facility, located in Palo, IA, near Cedar Rapids, IA. This site audit will facilitate the license amendment review and may require a walkdown of the reactor facilities. The staff will provide an audit plan, outlining the specific needs of the audit.

September 30, 2011 10:30 CT/11:30 ET