NG-13-0281, 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

ML13189A198
Person / Time
Site:	Duane Arnold
Issue date:	07/02/2013
From:	Richard Anderson NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-13-0281
Download: ML13189A198 (6)

Text

NEXTeraM ENERAY ARNOLD NG-13-0281 10 CFR 50.90 July 2, 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 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 Generatinq 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-1 1-0267, 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 Generatinq Plants (2001 Edition), NG-1 1-0384, dated October 14, 2011

3) Electronic Communication, ME6818 - DAEC Adoption of NFPA-805 - Request for Additional Information (RAI) FPE 14, dated June 14, 2013 (ML13169A238)

In the Reference 1 letter, as clarified by Reference 2, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted a License Amendment Request for the Duane Arnold Energy Center (DAEC) pursuant to 10 CFR 50.90. Subsequently, the NRC Staff requested, via Reference 3, additional information regarding that application. 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 NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-13-0281 Page 2 of 2 This letter makes no new commitments and does not change any existing commitments.

If you have any questions or require additional information, please contact J.

Michael Davis at 319-851-7032.

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

Executed on July 2, 2013 (Rchr L. Andrso n 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)

Attachment to NG-13-0281 Response to Request for Additional Information, License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard For Fire Protection For Liqht Water Reactor Generatinq Plants 3 pages follow

RAI - Fire Protection Engineering 14 DAEC RAI FP 14 With regards to how DAEC complies with the requirements of NFPA 805 Section 3.11.5:

1.

There appears to be discrepancies between LAR Attachment A, Table 4-3 and Attachment C with regard to Electrical Raceway Fire Barrier Systems (ERFBS) credited at DAEC.

Attachment A, Element 3.11.5, Electrical Raceway Fire Barrier Systems (ERFBS)

(page 138 of 138), states that DAEC complies with the requirement and states that "Limited amounts of Darmat KM1 are utilized for ERFBS at DAEC. This product was tested to meet Generic Letter 86-10 Supplement 1." No other ERFBS is discussed.

However, Table 4-3, NFPA 805 Ch 4 Required FP Systems/Features and Attachment C, NEI 04-02 Table B Fire Area Transition both discuss an additional 3-hour ERFBS.

• Table 4-3, Fire Area TB1, Turbine Building, Fire Zones ID 07C (page 64) and 07H (page 66) list "Concrete Chase - Separation Required to protect cables for RHR Service Water, River Water, ESW and Division 2 AC Power."

• Attachment C, Fire Area TB1 (page 154 of 165), under Performance Goal 4, Vital Auxiliaries - Mechanical, includes a Comment "Feeders and control power to portions of the Div 2 electrical distribution credit a 3 hr ERFBS."

• Attachment C, Fire Area TB1 (page 154 of 165), under Performance Goal 4, Vital Auxiliaries - Electrical includes a Comment "Div 2 RHRSW pumps, Div 2 River Water pumps and Div 2 ESW pump credit a 3 hr ERFBS."

• Attachment C, Fire Area TB1 (page 163 of 165), Required Fire Protection Systems and Features table lists "Passive, Concrete Chase, Separation, Required to protect cables for RHR Service Water, River Water, ESW and Division 2 AC Power."

Any ERFBS credited to meet NFPA 805 separation requirements using either a deterministic approach under NFPA 805 Section 4.2.3 or a performance-based approach under NFPA 805 Section 4.2.4 must meet the ERFBS requirements of NFPA 805 Section 3.11.5.

Provide additional information regarding the compliance status of the "concrete chase" used as an ERFBS in the Turbine Building with regard to NFPA 805 Section 3.11.5. Discuss the testing performed on this ERFBS, including the test rating obtained.

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RAI - Fire Protection Engineering 14

2.

Attachment A, Element 3.11.5, Electrical Raceway Fire Barrier Systems (ERFBS), states that DAEC complies with the requirement and states that "Limited amounts of Darmat KM1 are utilized for ERFBS at DAEC. This product was tested to meet Generic Letter 86-10 Supplement 1."

There is no discussion regarding the results of the testing. NFPA 805 Section 3.11.5 states that "The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The fire barrier's ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill and type shall be demonstrated."

Provide a discussion on the results of the fire barrier testing performed in accordance with Generic Letter 86-10, Supplement 1 to meet NFPA 805 Section 3.11.5.

RESPONSE

The following is the DAEC response to the items identified above:

1. The classification of ERFBS in Attachment C, Fire Area TB1 (page 154 of 165) under Performance Goal 4, Vital Auxiliaries - Electrical and Vital Auxiliaries -

Mechanical is incorrect. The deterministic separation for Vital Auxiliaries -

Electrical and Vital Auxiliaries - Mechanical is provided by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier meeting the requirements of NFPA 805 Section 4.2.3.3(a) "Enclosure of cable and equipment and associated non-safety circuits of a redundant success path in a fire barrier having a 3-hour fire resistance rating." The specific configuration is the fire barrier option in NFPA 805 Section 4.2.3.3(a), rather than the ERFBS option. The fire barrier was installed to a Uniform Building Code standard using UL listed material to meet a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance rating. All openings are protected with passive fire protection having a fire-resistive rating equivalent to that of the fire barrier.

Attachment C has been updated to correctly identify that the separation is achieved by meeting the requirements of NFPA 805 Section 4.2.3.3(a).

2. The fire resistive rating of the DARMATT KM-1 Fire Protection system utilized for ERFBS at DAEC as detailed in Attachment A, Element 3.11.5 was established by testing conducted in accordance with the guidance and acceptance criteria of NRC Generic Letter 86-10, Supplement 1 and ASTM El 19 for a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated barrier. The Darmatt testing addressed the design requirements and limitations Rev 0 Page 2 of 3

RAI - Fire Protection Engineering 14 of supports and intervening items and their impact on the fire barrier system rating. The testing also established the fire barrier system's bounding barrier design, raceway size and type, cable size, fill and type.

Attachment A Section 3.11.5 has been updated to identify that the DARMATT was successfully tested to meet Generic Letter 86-10 Supplement 1.

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