ML13084A004

NRR E-mail Capture - ME6818 DAEC Adoption of NFPA-805 - Request for Additional Information

ML13084A004
Person / Time
Site:	Duane Arnold
Issue date:	03/22/2013
From:	Feintuch K Division of Operating Reactor Licensing
To:	Browning T, Swenzinski L NextEra Energy Duane Arnold
References
TAC ME6818
Download: ML13084A004 (5)

Text

1 NRR-PMDAPEm Resource From:

Feintuch, Karl Sent:

Friday, March 22, 2013 5:26 PM To:

Swenzinski, Laura; Browning, Tony Cc:

Pickett, Douglas; Harrison, Donnie; Hamzehee, Hossein; Klein, Alex; Dinsmore, Stephen; ONeal, Daniel; Lain, Paul; Wengert, Thomas

Subject:

ME6818 DAEC Adoption of NFPA-805 - Request for Additional Information Attachments:

ME6818 DAEC APLA RAIs NFPA 805 LAR Round 3 (1).docx By letter dated August 5, 2011, NextEra Energy Duane Arnold, LLC, (the Licensee), submitted a license amendment request (LAR) to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC), from Title 10 of the Code of Federal Regulations (10CFR), Section 50.48(b), to 10CFR50.48(c),

National Fire Protection Association Standard NFPA 805 (NFPA 805).

A review team, consisting of U.S. Nuclear Regulatory Commission (NRC) staff and contractors from Pacific Northwest National Laboratory (PNNL) and the Center for Nuclear Waste Regulatory Analyses (CNWRA) participated in a regulatory audit of the DAEC in Palo, Iowa during the period December 12-16, 2011. In a message dated January 31, 2012, (ADAMS Accession No. ML12031A112) the NRC issued requests for additional information (RAIs). In letters dated April 23, 2012 (ADAMS Accession No. ML12117A052) and May 23, 2012 (ADAMS Accession No. ML12146A094) the licensee provided responses to those RAIs. In messages dated November 8, 2012 (ADAMS Accession No. ML12318A394) and December 5, 2012, (ADAMS Accession No. ML12340A450) the NRC issued additional requests for additional information. In letters dated January 11, 2013 (ADAMS Accession No. ML13015A350), February 12, 2013 (ADAMS Accession No. ML13046A031), and March 6, 2013 (ADAMS Accession No. ML13070A065), the licensee provided additional responses.

The Probabilistic Risk Assessment Licensing (APLA) Branch has reviewed the information provided by the licensee and determined that additional information is needed to complete the review. Please note that review efforts on this task (TAC No. ME6818) are being continued and additional RAIs may be forthcoming.

Please review the attached items for clarification and request a conference call if needed as soon as possible.

Though the items in the attached file are identified as draft in the heading (subject to the need for clarification),

they are firm relative to the information being requested. The NRC staff seeks a 30-day response to the RAI items.

If you have any questions or need any additional information concerning these RAIs, please contact me at 301-415-3079.

Docket No: 50-331 Karl Feintuch Project Manager USNRC 301-415-3079

Hearing Identifier:

NRR_PMDA Email Number:

645 Mail Envelope Properties (Karl.Feintuch@nrc.gov20130322172500)

Subject:

ME6818 DAEC Adoption of NFPA-805 - Request for Additional Information Sent Date:

3/22/2013 5:25:44 PM Received Date:

3/22/2013 5:25:00 PM From:

Feintuch, Karl Created By:

Karl.Feintuch@nrc.gov Recipients:

"Pickett, Douglas" <Douglas.Pickett@nrc.gov>

Tracking Status: None "Harrison, Donnie" <Donnie.Harrison@nrc.gov>

Tracking Status: None "Hamzehee, Hossein" <Hossein.Hamzehee@nrc.gov>

Tracking Status: None "Klein, Alex" <Alex.Klein@nrc.gov>

Tracking Status: None "Dinsmore, Stephen" <Stephen.Dinsmore@nrc.gov>

Tracking Status: None "ONeal, Daniel" <Daniel.ONeal@nrc.gov>

Tracking Status: None "Lain, Paul" <Paul.Lain@nrc.gov>

Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>

Tracking Status: None "Swenzinski, Laura" <Laura.Swenzinski@nexteraenergy.com>

Tracking Status: None "Browning, Tony" <Tony.Browning@nexteraenergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 2295 3/22/2013 5:25:00 PM ME6818 DAEC APLA RAIs NFPA 805 LAR Round 3 (1).docx 29658 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS DUANE ARNOLD ENERGY CENTER (TAC NO. ME6818)

Probabilistic Risk Assessment RAI 82 The NRC staff identified numerous methods that were used in the fire probabilistic risk assessment (FPRA) that have not yet been accepted by the staff. Requests for Additional Information (RAIs) were provided (January 31, 2012 Agencywide Document Access and Management System (ADAMS) Accession No. ML12031A112, October 26, 2012 ADAMS Accession No. ML12304A069, and December 5, 2012, ADAMS Accession No. ML12340A450) about these methods and the responses (April 23, 2012, ADAMS Accession No. ML12117A052, May 23, 2012, ADAMS Accession No. ML12146A094, February 12, 2013, ADAMS Accession No. ML13046A031, and March 6, 2013 (ADAMS Accession No. ML13070A065) have been reviewed.

The staff has determined that some of these methods are unacceptable because justification for the method does not seem to be technically available (e.g., use of severity factors without any supporting data). Other methods are still under review, but additional justification is needed.

Methods that have been accepted are no longer under investigation by the NRC.

Methods in question are as follows:

PRA RAI 01.01: Regarding updating the transient heat release rate (HRR) to use 317kWs.

PRA RAI 01.01c: Regarding determining the HRR of transient fires that differ from those endorsed by the NRC in its letter to NEI dated June 21, 2012 on Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993, Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires (ADAMS Accession No. ML12171A583).

PRA RAI 05: Regarding the need to sum all barrier elements in the Multi-Compartment Analysis (MCA)

PRA RAI 07: Regarding the use of an emergency diesel generator aggressive fire factor PRA RAI 11.01: Regarding turbine generator ignition frequency and credit for manual suppression PRA RAI 12: Regarding the use of excessive Control Power Transformer (CPT) credit.

PRA RAI 14a: Regarding removal of the hot-work pre-initiator factor of 0.01 for hot work administrative controls.

PRA RAI 14b: Regarding the use of a Very Low transient influence factor in the frequency factors for distributing transient frequency.

2 PRA RAI 35.01: Regarding the credit for incipient detection in the main control room.

PRA RAI 69: Regarding modeling of sensitive electronics in cabinet using cable damage criteria instead of sensitive electronics criteria. The response discussed the main control room only; however, any application of this method for sensitive electronics outside the main control room should also be considered in the sensitivity analysis.

PRA RAI 71: Regarding the use a conditional probability of 0.1 PRA RAI 72: Regarding the use of a minimum non-suppression probability of less than 0.001.

The following methods have been identified as deviations or weakness but the review of the proposed method is continuing:

PRA RAI 08.01: Regarding not following NUREG/6850 Step 5.c (Section 11.5.4.5) while determining the extent of fire damage during MCA.

PRA RAI 14.01d: Regarding crediting prompt (i.e., hot work type) suppression for transient fires PRA RAI 70: Regarding credit given to sealed electrical cabinets to prevent fire spread Alternatively, any of these alternative methods may be replaced with a method previously accepted by the NRC by referencing the source of the NRC acceptance and modifying the FPRA to incorporate the method.

As a result of the above, provide the following:

a. Results of a composite analysis that shows the integrated impact on the fire risk (Core Damage Frequency (CDF), Large Early Release Frequency (LERF), delta ()CDF, and LERF) of all of the above method changes analyses. In this composite analysis, for those cases where the individual issues have a synergistic impact on the results, perform a simultaneous analysis. For those cases where no synergy exists, perform a one-at-a-time analysis. In the response, provide justification of how the Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, risk acceptance guidelines are satisfied for the composite analysis of all the issues identified and, if applicable, a description of any new modifications or operator actions being credited to reduce delta risk and the associated impacts of the fire protection program.

b. An additional composite analysis that includes only the analyses believed to be appropriate and justification for not using selected methods. Include justification of how the RG 1.174 risk acceptance guidelines are satisfied.

Probabilistic Risk Assessment RAI 83 In a letter dated May 23, 2012, (ADAMS Accession No. ML12146A094) you responded to Probabilistic Risk Assessment RAI 20 and provided the conditional core damage probabilities

3 (CCDP) and the conditional large early release probabilities (CLERP) but did not provide a discussion of the analysis, assumptions, and ignition frequency as requested.

a. Provide the requested discussion of the analysis, assumptions, and ignition frequency, using the clarification guidance criteria discussed in NEIs letter to NRC dated September 27, 2011 on Recent Fire PRA Methods Review Panel Decision: Clarification for Transient Fires and Alignment Factor for Pump Oil Fires (ADAMS Accession Nos.

ML113130448, ML113130451, ML113130453, ML113130454) and as endorsed by the NRC in its letter to NEI dated June 21, 2012 on Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993, Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires (ADAMS Accession No. ML12171A583).

b. If the heat release rate (HRR) differs from NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, provide a sensitivity study containing the risk and change in risk, using the values in NUREG/CR-6850.