NG-13-0318, Response to Revised License Condition for the License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generation Plants

Response to Revised License Condition for the License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generation Plants

ML13219A113
Person / Time
Site:	Duane Arnold
Issue date:	08/05/2013
From:	Richard Anderson NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-13-0318
Download: ML13219A113 (4)

Text

NEXTeraM EN ERC7-GYA August 5, 2013 A' ýARNOLD NG-13-0318 10 CFR 50.90 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 Revised License Condition For The License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard For Fire Protection For Liaht Water Reactor Generatina 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-1 1-0384, dated October 14, 2011

3) Letter, K. Feintuch (NRC) to R. Anderson, Revised License Condition For The License Amendment Request to Adopt National Fire Protection Association Standard 805, "Performance-Based Standard For Fire Protection For Light Water Reactor Generatina Plants." dated July 30. 2013 (ML13210A458)

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 proposed, via Reference 3, revised Operating License conditions. The NRC Staff also requested that NextEra Energy Duane Arnold provide concurrence with the revised Operating License conditions.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-13-0318 Page 2 of 2 This letter confirms that NextEra Duane Arnold is prepared to implement the fire protection license condition as stated within the timeline specified, as described in Reference 3. The enclosure to this letter contains a clean typed page 5 of the Operating License which reflects the revised operating license conditions. Please note, that NextEra Energy Duane Arnold also proposes a change to Operating License condition (1) of Section C.(3). Operating License condition (1) references Operating License condition (2). The proposed changes to Operating License conditions (2) and (3) result in an administrative change to Operating License condition (1) such that it now references Operating License conditions (2) and (3).

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 August 5, 2013 Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Attachment:

Revised Page 5 Of Operating License Changes (Clean, typed) cc: M. Rasmusson (State of Iowa)

Attachment to NG-1 3-0318 Revised Page 5 Of Operating License Changes (Clean, typed) 1 page follows

" Fire Alarm and Detection Systems (Section 3.8);

" Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

" Gaseous Fire Suppression Systems (Section 3.10); and,

" Passive Fire Protection Features (Section 3.11).

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated _ to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the modifications to its facility, as described in Enclosure 2, Attachment S, Table S-1, "Plant modifications Committed," of DAEC letter NG-13-0287, dated July 2, 2013, to complete the transition to full compliance with 10 CFR 50.48(c) by December 31, 2014. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

(3) The licensee shall implement the items listed in Enclosure 2, Attachment S, Table S-2, "Implementation Items," of DAEC letter NG-13-0287, dated July 2, 2013, by ,2014.

(4) The licensee is authorized to operate the Duane Arnold Energy Center following installation of modified safe-ends on the eight primary recirculation system inlet lines which are described in the licensee letter dated July 31, 1978, and supplemented by letter dated December 8, 1978.

(5) Physical Protection NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, Renewed License No. DPR-49 Amendment