ML13260A591

Request for Additional Information Email, Nrr/Dra/Afpb 18.01, License Amendment Request to Adopt NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition)

ML13260A591
Person / Time
Site:	Callaway
Issue date:	08/16/2013
From:	Lyon C Plant Licensing Branch IV
To:	Elwood T, Hiller J Ameren Corp, Union Electric Co
Lyon C
References
TAC ME7046
Download: ML13260A591 (3)

Text

From:

Lyon, Fred To:

"Elwood, Thomas B" (TElwood@ameren.com); Hiller, Justin W (JHiller@ameren.com)

Cc:

Maglio, Scott A (SMaglio@ameren.com)

Subject:

FW: RAI for Callaway, Fire Protection Engineering RAI 18.01 Date:

Friday, August 16, 2013 6:35:00 AM Attachments:

ME7046 Callaway AFPB Round 4 RAI NFPA 805 LAR.docx Importance:

High From: Robinson, Jay Sent: Thursday, August 15, 2013 4:32 PM To: Lyon, Fred Cc: Wall, Scott; Pearson, Alayna; Barrett, Harold; Klein, Alex

Subject:

RAI for Callaway, Fire Protection Engineering RAI 18.01

Fred, The staff has a follow-up RAI to Fire Protection Engineering RAI 18 which is attached. Do you think you can get the draft over to the licensee in time for it to be discussed at Mondays phone call? Any questions regarding this RAI should be addressed to Alayna Pearson or Harry Barrett. Thanks, Jay

1

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 CALLAWAY PLANT (TAC NO. ME7046)

Office of Nuclear Reactor Regulation Division of Risk Assessment Fire Protection Branch

Fire Protection Engineering RAI 18.01 In a letter dated August 5, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13218A171), Ameren Missouri responded to Fire Protection Engineering Request for Additional Information (RAI) 18 and stated that Callaway complies with NFPA 805 Section 3.4.1(c).

The response further stated that that the Fire Brigade Leader position may be filled by either an Operating Supervisor or Operations Technician. Based on your description, it does not appear that the training and qualifications of the Operations Technician provides sufficient integrated plant/system operations knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria (NSPC). Consistent with the current guidance provided for non-National Fire Protection Association Standard 805 (NFPA 805) plants (Regulatory Guide 1.189, Revision 2), the Fire Brigade Leader should receive training sufficient to fully understand plant transient response and integrated plant impacts of potential fire/fire suppressant damage to front line and support systems. Although the training and qualifications provided to the Operations Technician includes review of nuclear safety systems and objectives including understanding the purpose, major system flow-paths, operation of major system components, indications, controls, and system operation during normal and off-normal conditions, it does not include higher level objectives that demonstrate integrated knowledge of plant operations.

Provide a revised response that addresses training and qualifications to meet the higher level objectives that demonstrate integrated knowledge of plant operations sufficient to fully understand plant transient response and integrated plant impacts of potential fire/fire suppressant damage to front line and support systems and how they are used to meet the nuclear safety performance criteria.

An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, Revision 2, Section 1.6.4.1, Qualifications:

"The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems."

2

Another option available with regard to this attribute is to maintain your fire protection program consistent with existing commitments and utilize a compliance category of Complies by previous NRC Approval in accordance with NFPA 805 Section 3.1.