NG-13-0240, Response to 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

Response to 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

ML13150A103
Person / Time
Site:	Duane Arnold
Issue date:	05/29/2013
From:	Richard Anderson NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-13-0240
Download: ML13150A103 (4)

Text

May 29, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 NG-13-0240 10 CFR 50.90 Response to 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

References:

1) License Amendment Request (TSCR-128): Transition to 10 CFR 50.48(c)- NFPA 805, Performance-Based Standard For Fire Protection For Light Water Reactor Generating Plants (2001 Edition), NG-11-0267, dated August 5, 2011 (ML11221A280)

2) Clarification of Information Contained in License Amendment Request (TSCR-128): Transition to 10 CFR 50.48(c)- NFPA 805, Performance-Based Standard For Fire Protection For Light Water Reactor Generating Plants (2001 Edition), NG-11-0384, dated October 14,2011

3) Response to 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, NG 0182, dated May 1, 2013

4) Electronic Communication, ME6818 - DAEC Adoption of NFPA-805 - Request for Additional Information (revised), dated May 8, 2013 (ML13129A074)

In the Reference 1 letter, as clarified by Reference 2, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted a License NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, lA 52324

Document Control Desk NG-13-0240 Page 2 of 2 Amendment Request for the Duane Arnold Energy Center (DAEC) pursuant to 10 CFR 50.90. Subsequently, the NRC Staff requested, via Reference 4, additional information regarding that application and the Reference 3 RAI response. The Attachment to this letter contains the requested information.

This additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in the referenced application.

This letter makes no new commitments and withdraws the following commitment.

Implementation item number 8 of Table S-2 of AttachmentS of Reference 1 is retracted as described in the Attachment to this letter.

If you have any questions or require additional information, please contact Tom Byrne at 319-851-7929.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 29, 2013 R;;d
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Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Attachment:

Response to 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 cc:

M. Rasmusson (State of Iowa)

1 page follows Attachment to NG-13-0240 Response to 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

DAEC Fire Brigade RAI Rev A.

Page 1 of 1 DAEC RAI The compliance statement for LAR Table B-1, Element 3.4.1 (c) [On-Site Fire-Fighting Capability] is complies. The associated implementation item no. 8 (Attachment S, Table S-2) states that fire brigade requirements will be updated to include a third person from Operations or to provide a dedicated operations advisor to the fire brigade.

Describe how the requirements of NFPA 805 Section 3.4.1(c) are met, specifically the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria.

RESPONSE

Currently, each fire brigade consists of a fire brigade leader and four fire brigade members. The fire brigade leader is a Licensed Reactor Operator. The remaining four members include:

two from Maintenance one from Security, and one Radwaste Operator.

The two fire brigade members from Maintenance and Radwaste have completed training that includes the study of nuclear safety systems, their function, location and safety significance. As such, NextEra Energy Duane Arnold complies with the NFPA 805 Section 3.4.1(c) requirement that the fire brigade leader and at least two brigade members have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria.

In addition to the fire brigade, personnel from the Operations crew are available to support the fire brigade. The first fire response is made by a non-licensed operator (NSPEO) who is a qualified fire brigade member. The NSPEO responds to the scene, evaluates the situation, communicates with the Control Room and attempts to extinguish the fire if conditions allow. A second non-licensed operator on each Operations crew is available to assist the brigade subject to direction from the Control Room. These non-licensed operators are available to assist the fire brigade with operational advice pending plant conditions and event response needs of the Control Room.

In implementation item no. 8 of Table S-2 of Attachment S of the original License Amendment Request (ML11221A280), NextEra Energy Duane Arnold committed to revise the fire brigade requirements/guidance to include a third person from Operations or provide a dedicated operations advisor to the fire brigade. As discussed above, NextEra Energy Duane Arnold currently complies with the NFPA 805 Section 3.4.1(c) requirement that the fire brigade leader and at least two brigade members have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria. Therefore, Implementation item no. 8 of Table S-2 of Attachment S of the original License Amendment Request (ML11221A280) is hereby retracted.