NG-17-0111, Duane Arnold Energy Center, Revision 24 to Updated Final Safety Analysis Report, Chapter 13, Conduct of Operations

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Duane Arnold Energy Center, Revision 24 to Updated Final Safety Analysis Report, Chapter 13, Conduct of Operations
ML17157B687
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Site: Duane Arnold NextEra Energy icon.png
Issue date: 05/22/2017
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NextEra Energy Duane Arnold
To:
Office of Nuclear Reactor Regulation
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NG-17-0111
Download: ML17157B687 (48)


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UFSAR/DAEC-1 T13.1-1 Revision 23 - 5/15 Table 13.1-1 Deleted UFSAR/DAEC-1 T13.1-2 Revision 23 - 5/15 Table 13.1-2 MINIMUM SHIFT CREW PERSONNEL AND LICENSE REQUIREMENTS Reactor Mode DAEC Job Title Other Than

Cold Shutdown

Cold Shutdown Operations Shift Manager 1 - SRO1,4 1 - SRO 1 Control Room Supervisor 1 - SRO1,2,4 Nuclear Station Operating Engineer 1 - RO 3 1 - RO Assistant Nuclear Station Operating

Engineer 1 - RO 3 Nuclear Station Plant Equipment Operator 2 1

Shift Technical Advisor Position 12,4 None Required Minimum Total Personnel 7 4 3 SRO - Senior Reactor Operator RO - Reactor Operator

Substitutions - without changing minimum total personnel requirements: a. Individuals with senior reactor operator license may substitute for reactor operator or nonlicensed position. b. Individuals with reactor operator license may, if otherwise qualified, substitute for nonlicensed position.

_______________________

NOTES

1. Does not include the SRO or SRO Limited to Fuel Handling, Supervising Core Alterations
2. Not required while in the Refuel Mode
3. Only one RO is required during the Refuel Mode with an additional RO required to be assigned the responsibilities of movement of fuel during Core Alterations
4. Per Technical Specification Issuance of Amendment, dated October 2, 2002, Section 3.1 Changes to TS 5.2.2.g (portion Amendment 248), the individual assigned to provide technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis (i.e. the Shift Technical Advisor position) may be provided by either a separate individual or the individual who also fulfills another role in the shift command structure, provided that individual meets the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. If this allowance is utilized, the Minimum Total Personnel for the shift is 6 (six).

2013-006 2013-006 2013-006 2013-006 2013-006 UFSAR/DAEC-1 13.2-1 Revision 23 - 5/15 13.2 TRAINING 13.

2.1 INTRODUCTION

The Duane Arnold Energy Center (DAEC) training programs have been established to provide qualified personnel to operate and maintain the plant in a safe manner and to comply

with technical specifications and applicable regulations. The training programs provide reasonable assurance that fully trained and qualified operations, maintenance, engineering support, chemistry technician and radiation protection personnel are available to ensure the safe and efficient operation of DAEC. These training programs meet the requirements of 10CFR50.120 and 10CFR55. These programs shall consist of both retraining and replacement training elements and shall meet or exceed the minimum provisions outlined in ANSI/ANS 3.1-1978. The detailed content and conduct of these training programs are described in division, plant, and training department procedures. The operations, maintenance, engineering support, chemistry technician and radiation protection training programs are based on a systematic approach to training and result in performance-based training. The systematic process includes analysis, design, development, implementation and evaluation phases. These training programs are accredited by the National Academy for Nuclear Training and are periodically evaluated to ensure they continue to meet accreditation standards. The DAEC Site-Specific simulator was certified in 1991. 13.2.2 GENERAL TRAINING 13.2.2.1 General Employee Training The General Employee Training program is required for all plant personnel (including contractors, corporate support personnel, etc.) prior to unescorted access within the protected

area. The initial training includes web-based content and evaluation (1) on the general description of the DAEC, radiation protection practices, quality assurance program, regulatory reporting requirements, security program, industrial safety practices, and site emergency plan.

Requalification training (2) is provided for all plant personnel granted unescorted access within the protected area. This training includes refr esher training on initial training topics, and updates on applicable administrative policies and procedures followed by an evaluation. (1) The term "evaluation" means one or more type of post-training examination such as online or written exam, practical demonstration, simulator scenario, etc. (2) The term "requalification training" is used when satisfactory completion is required, by either administrative procedure or federal regulation, to maintain qualification for specified job positions. Otherwise, the term "continuing training" is used.

2013-004 UFSAR/DAEC-1 13.2-2 Revision 23 - 5/15 13.2.2.2 Fitness for Duty Training The Fitness for Duty program is required for all plant personnel. Initial training includes classroom instruction and evaluation on the hazards of substance abuse, company substance abuse policies, and the consequences of failure to comply with those policies.

Requalification training is provided for all plant personnel. This training includes refresher training on initial training topics, updates on new policies and procedures, and an evaluation. 13.2.2.3 Asbestos Worker Training Asbestos Worker training is required for all personnel who will work with asbestos. Initial training includes classroom instruction and evalua tion on the uses of asbestos, health effects, personal protection, safe work practices, environmental monitoring, and applicable regulations. Continuing training is designed to maintain and improve the asbestos worker knowledge and skills developed during initial training. It includes classroom instruction and evaluation. 13.2.2.4 Hazardous Materials Training Hazardous Materials training is required for all personnel who will be exposed to health hazards or hazardous material, with varying levels of training depending on their duties. Initial training includes classroom instruction and evaluation on information that will allow employees to perform their duties in a safe, healthful manner, and to protect the environment and public. Continuing training is designed to maintain and improve hazardous material worker knowledge and skills developed during initial training. It includes classroom instruction and evaluation. 13.2.2.5 Instructor Training Instructors for accredited training programs are selected for their technical expertise in the subjects which they teach. They receive initial training in subjects such as the Systematic

Approach to Training process, education theory, and instructional techniques. Instructors who will be performing training on the plant specific simulator receive training on the simulator computer controls. Initial training includes an evaluation of the instructor/trainee's classroom presentation abilities.

Instructor continuing training provides instruct ors with additional training on instructional skills, procedure changes, changes in regulatory requirements, and changes in industry

guidelines when applicable. Instructors also attend selected continuing training courses, as designated by their supervisor, with the trainee(s) in their respective training program and are expected to maintain their technical skills and in-plant proficiency.

UFSAR/DAEC-1 13.2-3 Revision 23 - 5/15 13.2.3 OPERATOR TRAINING PROGRAMS 13.2.3.1 Nuclear Station Plant Equipm ent Operator (NSPEO) Training The NSPEOs are generally responsible for systems located outside the control room. This classification includes two watchstanders; one operator who works mainly in the Turbine Building and the buildings outside the power block, and another who works mainly in the

Reactor Building.

NSPEO initial training is designed to provide the knowledge, skills and abilities necessary to monitor and operate the in-plant systems and equipment under both normal and emergency conditions. Training and evaluation are performed in the classroom and on the job. Continuing training is designed to maintain and improve the required plant knowledge, skills, and abilities developed during initial training and ensures the NSPEOs are aware of plant

physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. Topics are selected for refresher training based on identified performance needs and input from line management. 13.2.3.2 Reactor Operator (RO) Initial Training Candidates enter the Reactor Operator program after meeting the regulatory requirements for education, physical condition and general health, and power plant experience.

Reactor Operator Initial Training includes courses in reactor theory, heat transfer and fluid flow, and thermodynamics and is designed to provide the knowledge and skills and abilities necessary to monitor and operate plant systems and equipment from the control room under both normal and emergency conditions. Training and evaluation are performed in the classroom, on the job, and in the plant simulator. The final evaluation is a responsibility of the Nuclear Regulatory Commission (NRC), which issues a Reactor Operator License to successful candidates. 13.2.3.3 Senior Reactor Operator (SRO) Initial Training Candidates enter the Senior Reactor Operator program after meeting the regulatory requirements for education, physical condition and general health, and power plant experience.

Senior Reactor Operator initial training includes the same courses provided Reactor Operators but with higher order learning objectiv es. The course also includes training on control room management , nuclear fuel handling, regulatory requirements, Security and Fire Plans, and SRO responsibilities during emergencies. Training and evaluation are performed in the classroom, on the job, and in the plant simulator. The final evaluation is a responsibility of

the NRC, which issues a Senior Reactor Operator License to successful candidates.

UFSAR/DAEC-1 13.2-4 Revision 23 - 5/15 13.2.3.4 Licensed Operator Requalification Training Licensed Operator Requalification training is a ttended by Reactor Operators, Senior Reactor Operators, Shift Technical Advisors, and Opera tions Instructors with an SRO Certification.

The Licensed Operator Requalification training program is designed to continually enhance the fundamental plant knowledge, skills and abilities developed during initial training. Training and evaluation are performed in the classroom, in the plant, and in the plant simulator. The program content is based on both fixed and flexible components:

  • The fixed component is a projected plan of lectures and plant manipulations derived from performance trends.
  • The flexible component is based on emerging issues such as feedback from trainee critiques or Manager/Supervisor Evaluations, applicable modifications to plant equipment or procedures, lessons learned from industry and in-house operating experiences, observation of operator performance in plant, and the results of evaluations. 13.2.3.5 Shift Technical Advisor (STA) Training Candidates entering the STA Training program should have a bachelors degree in engineering or physical science, work experien ce, or sufficient courses to provide a background for understanding the design and operation of nuclear power plants.

STA initial training provides the candidate with specific training in plant design, plant response, and analysis of the plant for transients and accidents. Training and evaluation are performed in the classroom, on the job, and in the plant simulator.

Continuing training consists of participation in Licensed Operator Requalification Training with additional training and evaluation on the oversi ght role of the STA. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.3.6 Control Room Supervisor (CRS) Training The Control Room Supervisors are the senior utility management representatives stationed in the control room. This position requires completion of SRO initial training. The Control Room Supervisors also receive additional technical, supervisory, and management training. Training and evaluation are performed in the classroom, on the job, and in the plant simulator.

Continuing training consists of participation in Licensed Operator Requalification Training with additional professional development traini ng. Topics are selected for refresher training based on identified performance needs and input from line management.

UFSAR/DAEC-1 13.2-5 Revision 23 - 5/15 13.2.4 MAINTENANCE TRAINING PROGRAMS 13.2.4.1 Mechanical Maintenance Training Nuclear station mechanic training is designed to provide the knowledge, skills and abilities to install, repair, adjust, and maintain plant mechanical equipment. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the fundamental plant knowledge, skills, and abilities developed during initial training and ensures the mechanics are aware of

plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.4.2 Electrical Maintenance Training Nuclear station electrician training is designed to provide the knowledge, skills, and abilities to install, repair, adjust, and maintain plant electrical equipment. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the fundamental plant knowledge, skills, and abilities developed during initial training and ensures the electricians are aware of

plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.4.3 Instrumentation and Control (I&C) Technician Training Nuclear station I&C technician training is designed to provide the knowledge, skills, and abilities to install, repair, adjust, and maintain plant equipment. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the fundamental plant knowledge, skills, and abilities developed during initial training and ensures the I&C technicians are aware

of plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating expe rience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management.

UFSAR/DAEC-1 13.2-6 Revision 23 - 5/15 13.2.4.4 Maintenance Department Head Training Maintenance Department Heads for the Mechanical, Electrical, and I&C shops and the Fix It Now (FIN) Supervisor receive additional technical, supervisory, and management training.

This training is designed to enhance the supervisors knowledge of integrated plant operations and organizational needs of interfacing departments. In addition to the maintenance supervisory training, the FIN Supervisor receives periodic mu ltidiscipline training by attending craft specific training session. Continuing training is designed to maintain and improve the required knowledge, skills and abilities to perform the Maintenance Supervisor role. Topics include both technical and supervisory development aspects and are selected based on identified performance needs, industry issues and input from management.

13.2.5 RADIATION PROTECTION TRAINING PROGRAMS 13.2.5.1 Health Physics Technician Training Health Physics Technician training is designed to provide the knowledge, skills and abilities necessary to perform radiological and environm ental health protection duties. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the required plant knowledge, skills, and abilities developed during initial training and ensures the Health Physics technicians

are aware of plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.5.2 Chemistry Technician Training Chemistry Technician training is designed to provide the knowledge, skills and abilities necessary to perform chemical and radiochemical analyses on plant systems and to maintain analysis equipment. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the required plant knowledge, skills, and abilities developed during initial training and ensures the Chemistry technicians are

aware of plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experi ence when applicable. Topics are selected for continuing training based on identified performance needs and input from line management.

2013-004 2013-004 UFSAR/DAEC-1 13.2-7 Revision 23 - 5/15 13.2.5.3 Radwaste Systems Operator Training Radwaste systems operator training is designed to provide the knowledge, skills and abilities necessary to safely transfer, process, package, store, release and ship radioactive waste. Training and evaluation are performed in the classroom, lab, and on the job. Advancement from apprentice to journeyman takes approximately four years and progress is systematically tracked. Continuing training is designed to maintain and improve the required plant knowledge, skills, and abilities developed during initial training and ensures the radwaste systems operators are aware of plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.6 ENGINEERING AND ENGINEERING SUPPORT TRAINING 13.2.6.1 Engineering Support Training (EST)

Initial training for Engineering and Engineering support personnel is designed to provide the knowledge and skills necessary to perform assigned duties. This training includes classes in basic plant operation, plant organization and administration, codes and standards, and the discipline(s) related to specific positions. Training and evaluation are performed in the classroom and in the plant, when appropriate. Continuing training is designed to maintain and improve job performance, develop a broader scope and depth of job-related knowledge and skills and ensure that EST training participants are

aware of plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating expe rience when applicable. Topics are selected for continuing training based on identified performance needs and input from line management. 13.2.7 EMERGENCY PREPAREDNESS TRAINING 13.2.7.1 Emergency Preparedness Training Emergency preparedness training provides each member of the Emergency Response Organization (ERO) with the knowledge and skills necessary to perform assigned duties. The training program addresses emergency response plan s and procedures and explains the structure of the ERO and it's facilities. Each member of the ERO receives initial indoctrination training, as well as facility-specific and position-specific training. Continuing training for emergency response personnel is achieved through participation in drills, exercises or classroom instruction. Continuing tr aining includes a review of significant changes to emergency plans, implementing procedures, emergency facilities and equipment. This

training will also include significant lessons learned from industry events and/or in-house experience, when applicable.

2013-004 2013-004 UFSAR/DAEC-1 13.2-8 Revision 23 - 5/15 13.2.8 FIRE PROTECTION TRAINING 13.2.8.1 Fire Brigade Training Fire brigade initial training meets the requirements of NFPA 805 and NFPA 600. Initial training includes classroom instruction on the DAEC Fire Plan, fire behavior and extinguishment, the use of fire fighting equipment, the use of self contained breathing apparatus, and search and rescue techniques. It also in cludes Live Fire training which is a series of practical exercises designed to provide fire brigade leaders and members with experience in fire extinguishment and the use of Self Containe d Breathing Apparatus under those conditions found in firefighting. Continuing training is designed to maintain and improve the fire fighting knowledge and skills developed during initial training and ensures that the Fire Brigade members are aware of

plant physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house operating experience when applicable. It includes classroom

instruction, Live Fire training, and participation in fire drills. Topics are selected for refresher training based on identified performance needs and input from line management. 13.2.9 SECURITY TRAINING 13.2.9.1 Security Training Security personnel are provided training in accordance with a NRC approved training and qualification plan prior to assignment to security force duties. Initial training includes classroom

instruction on the DAEC Security Plan and field instruction on weapons. Continuing training is designed to maintain and improve the security knowledge and skills developed during initial training and ensures the Security Guards are aware of plant

physical and procedural changes, changes to regulatory requirements, and lessons learned from industry and in-house security experience when applicable. It includes classroom instruction, field instruction, and participation in security drills. Topics are selected for refresher training based on identified performance needs and input from line management.

2013-013 UFSAR/DAEC - 1 13.3-1 Revision 17 - 10/03 13.3 EMERGENCY PLANNING The Duane Arnold Energy Center Emergency Plan has been submitted to the NRC as a separate document.

Provisions have been made for periodic review and updating of the Emergency Plan. Provisions have also been made for informing a ll concerned persons of significant revisions to the Emergency Plan and procedures. Revisions to the Emergency Plan and procedures are also submitted to the NRC.

meet the requirements of Section 8 of Supplement 1 to NUREG-0737.

UFSAR/DAEC - 1 13.5-1 Revision 22 - 5/13 13.5 PLANT PROCEDURES

13.5.1 ADMINISTRATIVE PROCEDURES

The DAEC administrative procedures are contained in the 1400 Manual, Administrative Control Document.

13.5.2 OPERATING AND MAINTENANCE PROCEDURES

13.5.2.1 Control Room Operating Procedures

13.5.2.1.1 Original Operating Procedures

The original operating and maintenance procedures are discussed in Section 13.6

of the original FSAR.

13.5.2.1.2 Current Operating Procedures

Integrated Plant Operating Instructions (IPOIs) exist to provide integrated procedures for major plant evolutions such as startup, power operation, reactor scram, and special operations as required.

Operating instructions (OIs) exist for individual plant systems.

The Technical Specifications list the areas which are to be covered by detailed written plant operating and maintenance procedures. These procedures, and changes

thereto, are reviewed as required by the QATR and site procedures.

The DAEC has implemented procedures for limiting access to the control room to

authorized individuals in accordance with the NUREG-0578, Section 2.2.2.a, NRC

position, and shift turnover procedures in accordance with the NUREG-0578, Section

2.2.1.c, NRC position.

The NRC in Supplement 1 to NUREG-0737 (Generic Letter 82-33) required licensees to develop a set of human factored, symptom-based, emergency operating procedures (EOPS) to improve human reliability and the ability to mitigate the consequences of a broad range of initiating events and subsequent multiple failures or operator errors to respond to potential accident situations. The BWR Owner's Group UFSAR/DAEC - 1 13.5-2 Revision 22 - 5/13 (BWROG) developed a set of Emergency Procedure Guidelines (EPGs) which could be utilized by individual licensees in their development of plant-specific EOPs. The EPGs

have been updated to include Severe Accident Guidelines (SAGs) beyond that previously covered in EOPs. This updated guidance was issued by the BWROG as EPG/SAG Revision 1, and amended by Revision 2. This guidance maintained the same symptom-based approach as the previous revisions to the EPGs. DAEC implemented EPG/SAG

Revision 2 such that any steps or actions in the SAG flowcharts are beyond the plant's

design and licensing basis. The current EOP flowcharts have also been updated from the guidance in EPG/SAG Revision 2.

13.5.2.2 Other Procedures

13.5.2.2.1 Maintenance and Testing Procedures

Maintenance and testing procedures, checklists, and other necessary records to satisfy routine inspections, preventive maintenance program, and license requirements, are developed by qualified plant staff members.

The Technical Specifications specify that detailed written procedures, including applicable check-off lists and instructions, are to be prepared for surveillance and testing requirements and preventive and corrective maintenance operations which could have an effect on the nuclear safety of the facility.

The maintenance procedures can be found in the Maintenance Procedures Manual

and the surveillance and testing procedures are listed in a controlled database. The

procedures can be divided into the following categories:

1. Routine Testing of Engineered Safeguards and Equipment as Required by the Facility License and the Technical Specifications is directed by the Manager, Procedures Department and is completed at the specified frequency. Written

procedures and checklists are provided for these operations.

2. Routine Testing of Standby and Redundant Equipment

Routine testing of standby and redundant equipment is directed by the Work Management Manager. The frequency of testing follows normal steam plant

practice.

3. Routine Inspection and Preventive Maintenance

Routine inspection and preventive maintenance of equipment is directed by the Mechanical Maintenance Department Head, Electrical Maintenance Department Head and Instrumentation and Controls Maintenance Department Head. The frequency and scope of inspections are in accordance with normal steam 2013-004 UFSAR/DAEC - 1 13.5-3 Revision 22 - 5/13 plant practices. Plant operating history and manufacturer's recommendations are also used in determining specific inspection and maintenance schedules. Routine inspection, calibration, and preventive maintenance of instruments are directed by the Instrumentation and Controls Maintenance Department Head. The frequency and scope of this work are established according to normal plant practice, operating history, and manufacturer's recommendations.

4 . Special Testing

Special testing encompasses all testing not covered by items 1, 2, and 3 above.

Some items in this category are:

a. Operational testing of equipment after overhaul.
b. Testing of equipment for proposed changes to operational procedures.
c. Testing of equipment for proposed design changes to equipment.

Special testing will be under the direction of the Engineering Director and the Operations Site Director. When necessary, appropriate procedures will be written by qualified members of the plant staff with review and approval by the On-site Review

Group.

13.5.2.2.2 Emergency Planning Procedures

Organized emergency procedures outlining the actions and responsibilities of

plant personnel and offsite support groups have been developed and are contained in the DAEC Emergency Plan and the Emergency Plan Implementing Procedures (EPIPs). These procedures implement the Emergency Plan discussed in Section 13.3.

The purposes of these emergency procedures are to classify emergencies

according to severity, assign responsibilities, and outline the actions to be taken to

confine and reduce the hazard in order to protect both the general public and plant

personnel.

In the implementation of the Emergency Plan, detailed procedures have been prepared to specify the manipulation of controls and equipment to place the facility in a safe condition and to prescribe other appropriate protective measures to be taken by the employees. These implementing procedures are available at the site for review by the NRC. This section describes the principal features of the implementing procedures as follows:

1. 2013-004 UFSAR/DAEC - 1 13.5-4 Revision 22 - 5/13
2. 3.
4.
5.
6.
7.
8.
9.
10.

Controlled copies of the DAEC Emergency Plan Implementing Procedures (EPIP) are provided to the NRC Region III office.

UFSAR/DAEC - 1 13.5-5 Revision 22 - 5/13 13.5.2.2.3 Refueling Operations

Detailed refueling procedures are used to ensure a safe and orderly refueling. The procedures specify or make reference to other system operation documents that specify periodic shutdown margin checks, detailed channeling and fuel-handling techniques, and

other precautionary steps to ensure that the facility license and Technical Specifications

are not violated.

When fuel is being inserted, removed, or rearranged in the core or when control rods are being installed, removed, or manipulated, licensed operators will be in the control room. Senior Reactor Operators (SROs) or SROs limited to fuel handling will be present on the Refuel Floor during core alterations. Technical personnel may provide guidance where necessary. Core verification will be performed after the refueling operations are completed.

Fuel and control rod identifications are tracked using Spent Fuel Pool and core locations. The serial numbers on both the fuel and control rods are matched to these locations and records are kept for these items as lifetime records.

Core alterations are performed using fuel handling procedures and fuel moving plans that are developed from analysis of the previous cycle's fuel exposure and taking into account shutdown margin.

Other refueling operations include the replacement of control rods and incore monitors, channeling operations, fuel sipping when necessary, and the inspection of selected portions of the reactor vessel and primary system.

13.5.2.2.4 Radioactive Materials Safety Procedures

Procedures for the handling and monitoring of radioactive materials are contained in plant procedures and manuals. The provisions of these procedures are designed to conform to the standards of the Code of Federal Regulations, particularly those

applicable in Title 10 and Title 49. These procedures are approved by the On-site

Review Group.

13.5.2.2.5 Radiological Procedures

Procedures for personnel radiation protection are prepared consistent with the requirements of 10 CFR 20 and are to be approved, maintained, and adhered to for all

operations involving personnel radiation exposure.

UFSAR/DAEC - 1 13.5-6 Revision 22 - 5/13 REFERENCES FOR SECTION 13.5

1. NRC Safety Evaluation Report - BWROG EPG, Revision 4, September 1988.
2. Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter 82-33), December 17, 1982.
3. NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures Resolution of Comments on NUREG-0799, August 1982.
4. NRC Safety Evaluation of the DAEC Procedures Generation Package, dated May 9, 1990.
5. BWR Owner's Group Emergency Procedur e and Severe Accident Guidelines, Revision 2, March 2001.

UFSAR/DAEC - 1 13.6-1 Revision 18 - 10/05 13.6 INDUSTRIAL SECURITY

The DAEC plans for physical protection of the facility are described in the Facility Operating License No. DPR-49 and are withheld from public disclosure pursuant to 10 CFR 73.21, "Requirements for the Protection of Safeguards Information." The Facility Operating License was revised by NRC letter dated October 28, 2004, incorporating the DAEC Physical Security Plan, Revision 0. This administrative License change became effective on that date. Detailed security measures for the physical protection of Nuclear Power Plants ar e required by 10 CFR 50.34(c), "Licensing of Production and Utilization Facilities," and applicable sections of 10 CFR 73, "Physical

Protection of Plants and Materials."

UFSAR/DAEC-1 13.7-1 Revision 23 - 5/15 13.7 FIRE PROTECTION PROGRAM 13.7.1 FIRE PROTECTION PROGRAM The fire protection program is based on the NRC requirements and guidelines, Nuclear Electric Insurance Limited (NEIL) Property Loss Prevention Standards and related industry standards. With regard to NRC criteria, the fire protection program meets the requirements of 10 CFR 50.48(c), which endorses, with exceptions, the National Fire Protection Association's (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. DAEC has further used the guidance of NEI 04- 02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)" as endorsed by Regulatory Guide 1.205, "Risk-Informed, Performance Fire Protection for Existing Light-Water Nuclear Power Plants."

Adoption of NFPA 805, "Performance-Based St andard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition in accordance with 10 CFR 50.48(c) serves as the method of satisfying 10 CFR 50.48(a) and General Design Criterion 3. Prior to adoption of NFPA 805, General Design Criterion 3, "Fire Protection" of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Licensing of Production and Utilization Facilities," was followed in the design of safety and non-safety related structures, systems, and components, as required by 10 CFR 50.48(a).

NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(f). Those regulatory requirements conti nue to apply. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements are met may be different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter 1 performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805.

A Safety Evaluation was issued on September 10, 2013 by the NRC, that transitioned the existing fire protection program to a risk-informed, performance-based program based on NFPA 805, in accordance with 10 CFR 50.48(c).

13.7.1.1 Design Basis Summary 13.7.1.1.1 Defense-in-Depth The fire protection program is focused on protecting the safety of the public, the environment, and plant personnel from a plant fire and its potential effect on safe reactor operations.

2013-013 UFSAR/DAEC-1 13.7-2 Revision 23 - 5/15 13.7.1.1.2 NFPA 805 Performance Criteria 2013-013 UFSAR/DAEC-1 13.7-3 Revision 23 - 5/15 13.7.1.1.3 Codes of Record The codes used for the design and installation of credited fire protection systems are listed in Table 13.7-1. For specific applications a nd evaluations of codes refer to FP-AB-100 Fire Protection Program.

13.7.1.2 System Description 13.7.1.2.1 Required Systems Nuclear Safety Capability Systems, Equipment, and Cables Fire Protection Systems and Features 2013-013 UFSAR/DAEC-1 13.7-4 Revision 23 - 5/15 Radioactive Release 13.7.1.2.2 Definition of "Power Block" Structures 13.7.1.3 Safety Evaluation 13.7.1.4 Fire Protection Program Documentation, C onfiguration Control and Quality Assurance 2013-013 UFSAR/DAEC-1 13.7-5 Revision 23 - 5/15 2013-013 UFSAR/DAEC-1 13.7-6 Revision 23 - 5/15 REFERENCES FOR SECTION 13.7

1. Safety Evaluation by the Office of Nuclear Reactor Regulation Transition to a Risk-Informed, Performance-Based Fire Protection Program In Accordance With 10 CFR 50.48(c) Amendment No. 286 to Renewed Facility Operating License No. DPR-49 Nextera Energy Duane Arnold, LLC Duane Arnold Energy Center Docket No. 50-331, 9/10/2013, (ML13210A449)
2. License Amendment Request, August 5, 2011, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (ML11221A280)
3. National Fire Protection Association Standards, NFPA 805, Performance-Based Standard for Fire Protection for Light Water React or Electric Generating Plants, 2001 Edition
4. Regulatory Guide 1.205, Risk-Informed, Performa nce-Based Fire Protection for Existing Light-Water Nuclear Power Plants, Revision 1, December 2009
5. NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c), Revision 1, September 2005
6. FAQ 12-0062, Updated Final Safety Analysis Re port (UFSAR) Standard Level of Detail, Revision 1, May 21, 2012 2013-013 2013-013 UFSAR/DAEC-1

T13.7-1 Revision 23 - 5/15 Table 13.7-1 FIRE PROTECTION CODE OF RECORD Code Title Year NFPA 10 Standard for Portable Fire Extinguishers 1975 NFPA 12 Standard on Carbon Dioxide Extinguishing Systems 1975 NFPA 13 Standard for the Installation of Sprinkler Systems System dependent, see Fire Protection Program NFPA 14 Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems 1985 NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection System dependent, see Fire Protection Program NFPA 20 Standard for the Installation of Stationary Pumps for Fire Protection 1970 NFPA 24 Standard for the Installation of Private Fire Service Mains and their Appurtenances 1969 NFPA 30 Flammable and Combustible Liquids Code 1969 NFPA 51B Standard for Fire Prevention During Welding, Cutting, and other Hot Work 1977 NFPA 72 Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems System dependent, see Fire Protection Program NFPA 80 Standard for Fire Doors and Fire Windows 1967 NFPA 90A Standard for the Installation of Air-Conditioning and Ventilating Systems System dependent, see Fire Protection Program NFPA 600 Standard on Industrial Fire Brigades 2005 2013-013 UFSAR/DAEC-1 T13.7-2 Revision 23 - 5/15 Table 13.7-2 POWER BLOCK BUILDINGS 2013-013