ML11334A150

NRR E-mail Capture - ME6818 - DAEC NFPA-805 Adoption - Pre-Audit Discussion - 29 Nov 2011 Conference Call

ML11334A150
Person / Time
Site:	Duane Arnold
Issue date:	11/30/2011
From:	Feintuch K Plant Licensing Branch III
To:	Swenzinski L NextEra Energy Duane Arnold
References
TAC ME6818
Download: ML11334A150 (12)

Text

NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Wednesday, November 30, 2011 11:28 AM To: 'Swenzinski, Laura'; Fields, Leslie; Harrison, Donnie; Klein, Alex; Litkett, Bernard; Daley, Robert; Dinsmore, Stephen; Garill Coles; Iqbal, Naeem; Jason Huczek; Jeff Bailey; Karl Bohlander; Lain, Paul; Langstaff, Ronald; Marc Janssens; ONeal, Daniel; Pat Mackin; Pearson, Alayna; Robert Layton; Robinson, Jay; Steve Short; Patrick Mackin; 'Swenzinski, Laura'; Hyslop, JS; Davis, Kristin; Todd Mintz; Barrett, Harold; Snodderly, Michael; Kaushik Das; Debashis Basu; 'Huczek, Jason P.'; 'Robert Fosdick'; 'Hopkins, Brad'; 'Cross, William';

'Dubois, Jason'; 'Hanson, Roy'; 'Ellis, Gary'; 'Swenzinski, Laura'; Litkett, Bernard; Garill Coles; Jason Huczek; Jeff Bailey; Karl Bohlander; Marc Janssens; Pat Mackin; Robert Layton; Steve Short; Patrick Mackin; 'Huczek, Jason P.'

Cc: Ring, Mark; Murray, Robert; Haeg, Lucas

Subject:

ME6818 - DAEC NFPA-805 adoption - Pre-Audit Discussion - 29 Nov 2011 Conference call Attachments: ME6818 DA NFPA-805 Adoption Audit (12-16Dec2011) Plan Rev 1.docx

===== Final update 2011-11-30-1125 ET =====

The conference call took place as planned. Attending were:

NRC: Karl Feintuch, JS Hyslop, Leslie Fields, Paul Lain, Michael Snodderly, Alayna Pearson, Bernie Litkett, Naeem Iqbal PNNL: Robert Layton, Jeff Bailey, Karl Bohlander, Steve Short CNWRA: Todd Mintz, Pat Mackin, Marc Janssens, Bob Fosdick, Kaushik Das, Debashis Basu DAEC: Gary Ellis, Roy Hanson, Brad Hopkins, Ginna Holt, Vinny Rubano, Laura Swenzinski DAEC contractors: none All bullet items below were discussed. Attached is an Audit Plan addressing details associated with the bullets, as presently determined. Audit questions are being prepared at this time by the auditors.

Points of contact for audit preparation activities:

NRC and its contractor support: Leslie Fields Duane Arnold and its audit support: Laura Swenzinski

===== update 2011-11-28-1600 ET =====

Please discard the original message, which is factually correct except that the O-10B2 is intended as the planned meeting room. I do not know how Outlook substituted the office of an OGC attorney.

===== original message ==============

Timing:

This meeting is scheduled to start at 2:30 PM ET (1:30 PM CT). A nominal one hour meeting is intended however, the conference call line will open at 2:15 PM ET, and the room is reserved until 4 PM to provide overflow time.

Conference calling:

Both the NRC and Duane Arnold are anticipated to require conference calling. Although participants are encouraged to congregate, 25 lines have been reserved.

Call: 800-779-2712. The pass code is: 51575.

Circulating this invitation:

The initial invitation to Fields and Swenzinski is as points of contact for the NRC and Duane Arnold and their respective support organizations. Please forward this invitation to your intended participants.

Agenda:

1

The anticipated topics of discussion are listed below. Some items will provide detailed information. Other items will seek to define the information needs of the other party and when needed. Consequently, later discussions may follow to address these information needs and updates. As presently anticipated the topics are:

• Number of persons in attendance at the audit

• Discussion of audit scope for specific topics, as presently anticipated.

• Dates for onsite tours with the overall audit schedule

• Anticipated audit plan details - status

• Anticipated audit Questions - status

• Provisions for rooms, telecommunication

• Lunch planning

• Discussion of Duane Arnolds further information needs and when it should be forthcoming 2

Hearing Identifier: NRR_PMDA Email Number: 212 Mail Envelope Properties (Karl.Feintuch@nrc.gov20111130112800)

Subject:

ME6818 - DAEC NFPA-805 adoption - Pre-Audit Discussion - 29 Nov 2011 Conference call Sent Date: 11/30/2011 11:28:14 AM Received Date: 11/30/2011 11:28:00 AM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients:

"Ring, Mark" <Mark.Ring@nrc.gov>

Tracking Status: None "Murray, Robert" <Robert.Murray@nrc.gov>

Tracking Status: None "Haeg, Lucas" <Lucas.Haeg@nrc.gov>

Tracking Status: None

"'Swenzinski, Laura'" <Laura.Swenzinski@nexteraenergy.com>

Tracking Status: None "Fields, Leslie" <Leslie.Fields@nrc.gov>

Tracking Status:: Response: None : 11/28/2011 3:55:00 PM "Harrison, Donnie" <Donnie.Harrison@nrc.gov>

Tracking Status: None "Klein, Alex" <Alex.Klein@nrc.gov>

Tracking Status: None "Litkett, Bernard" <Bernard.Litkett@nrc.gov>

Tracking Status: None "Daley, Robert" <Robert.Daley@nrc.gov>

Tracking Status: None "Dinsmore, Stephen" <Stephen.Dinsmore@nrc.gov>

Tracking Status: None "Garill Coles" <garill.coles@pnnl.gov>

Tracking Status: None "Iqbal, Naeem" <Naeem.Iqbal@nrc.gov>

Tracking Status:: Response: None : 11/28/2011 4:55:00 PM "Jason Huczek" <jhuczek@swri.org>

Tracking Status: None "Jeff Bailey" <jeff.bailey@pnnl.gov>

Tracking Status: None "Karl Bohlander" <karl.bohlander@pnnl.gov>

Tracking Status: None "Lain, Paul" <Paul.Lain@nrc.gov>

Tracking Status:: Response: None : 11/29/2011 9:00:00 AM "Langstaff, Ronald" <Ronald.Langstaff@nrc.gov>

Tracking Status: None "Marc Janssens" <marc.janssens@swri.org>

Tracking Status:: Response: None : 11/29/2011 11:41:00 AM "ONeal, Daniel" <Daniel.ONeal@nrc.gov>

Tracking Status: None "Pat Mackin" <patrick.mackin@swri.org>

Tracking Status: None

"Pearson, Alayna" <Alayna.Pearson@nrc.gov>

Tracking Status: None "Robert Layton" <robert.layton@pnnl.gov>

Tracking Status: None "Robinson, Jay" <Jay.Robinson@nrc.gov>

Tracking Status: None "Steve Short" <steve.short@pnnl.gov>

Tracking Status:: Response: None : 11/28/2011 4:31:00 PM "Patrick Mackin" <pmackin@cnwra.swri.edu>

Tracking Status:: Response: None : 11/28/2011 4:14:00 PM

"'Swenzinski, Laura'" <Laura.Swenzinski@fpl.com>

Tracking Status:: Response: None : 11/29/2011 9:32:00 AM "Hyslop, JS" <JS.Hyslop@nrc.gov>

Tracking Status: None "Davis, Kristin" <Kristin.Davis@nrc.gov>

Tracking Status:: Response: None : 11/29/2011 12:45:00 PM "Todd Mintz" <tmintz@cnwra.swri.edu>

Tracking Status: None "Barrett, Harold" <Harold.Barrett@nrc.gov>

Tracking Status: None "Snodderly, Michael" <Michael.Snodderly@nrc.gov>

Tracking Status: None "Kaushik Das" <kdas@cnwra.swri.edu>

Tracking Status:: Response: None : 11/28/2011 4:22:00 PM "Debashis Basu" <dbasu@cnwra.swri.edu>

Tracking Status:: Response: None : 11/28/2011 4:55:00 PM

"'Huczek, Jason P.'" <jason.huczek@swri.org>

Tracking Status:: Response: None : 11/28/2011 5:31:00 PM

"'Robert Fosdick'" <rfosdick@cnwra.swri.edu>

Tracking Status:: Response: None : 11/29/2011 6:22:00 AM

"'Hopkins, Brad'" <Brad.Hopkins@fpl.com>

Tracking Status:: Response: None : 11/29/2011 9:46:00 AM

"'Cross, William'" <WILLIAM.CROSS@fpl.com>

Tracking Status:: Response: None : 11/29/2011 10:01:00 AM

"'Dubois, Jason'" <Jason.Dubois@fpl.com>

Tracking Status:: Response: None : 11/29/2011 10:10:00 AM

"'Hanson, Roy'" <Roy.Hanson@fpl.com>

Tracking Status:: Response: None : 11/29/2011 10:24:00 AM

"'Ellis, Gary'" <Gary.Ellis@fpl.com>

Tracking Status:: Response: None : 11/29/2011 10:29:00 AM

"'Swenzinski, Laura'" <Laura.Swenzinski@nexteraenergy.com>

Tracking Status: None "Litkett, Bernard" <Bernard.Litkett@nrc.gov>

Tracking Status: None "Garill Coles" <garill.coles@pnnl.gov>

Tracking Status: None "Jason Huczek" <jhuczek@swri.org>

Tracking Status: None "Jeff Bailey" <jeff.bailey@pnnl.gov>

Tracking Status: None "Karl Bohlander" <karl.bohlander@pnnl.gov>

Tracking Status: None "Marc Janssens" <marc.janssens@swri.org>

Tracking Status: None "Pat Mackin" <patrick.mackin@swri.org>

Tracking Status: None

"Robert Layton" <robert.layton@pnnl.gov>

Tracking Status: None "Steve Short" <steve.short@pnnl.gov>

Tracking Status: None "Patrick Mackin" <pmackin@cnwra.swri.edu>

Tracking Status:: Response: None : 11/28/2011 4:02:00 PM

"'Huczek, Jason P.'" <jason.huczek@swri.org>

Tracking Status:: Response: None : 11/28/2011 5:31:00 PM Post Office:

Files Size Date & Time MESSAGE 2811 11/30/2011 11:28:00 AM ME6818 DA NFPA-805 Adoption Audit (12-16Dec2011) Plan Rev 1.docx 52492 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

November 29, 2011

SUBJECT:

DUANE ARNOLD ENERGY CENTER - REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED, PERFORMANCE-BASED, FIRE PROTECTION PROGRAM AS ALLOWED BY TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PARAGRAPH 50.48(C) FIRE PROTECTION (TAC NO. ME6818)

The Nuclear Regulatory Commissions (NRCs) Office of Nuclear Reactor Regulation (NRR)

Division of Risk Assessment staff will be conducting an audit of the Duane Arnold Energy Center (DAEC) license amendment request (LAR) to change its fire protection program to one based on the National Fire Protection Association (NFPA) standard NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.48(c), Fire Protection. This message provides in its attachment our audit plan of this LAR.

The audit will take place at the DAEC Administration Building in Palo, IA the week of December 12-16, 2011. Staff from the Fire Protection Branch (AFPB) and the PRA Licensing Branch (APLA) staff, and contractor personnel, will perform the audit. Other NRC staff will also be present at the audit as observers.

Should you have any questions concerning details or clarification of this plan, please contact Paul Lain at 301-415-2346, or Leslie Fields at 301-415-1189 The Point of Contact for staff supporting the NRC effort is Leslie Fields. The licensee Point of Contact for staff supporting the DAEC effort is Laura Swenzinski at 319-851-7724.

Karl Feintuch Project Manager NRR/DORL/LPL3-1 301-415-3079

DUANE ARNOLD ENERGY CENTER REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT THE NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805, PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANT, AS INCORPORATED INTO TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PARAGRAPH 50.48(c) FIRE PROTECTION (ME6818)

DOCKET NO. 50-331 I. BACKGROUND The Duane Arnold Energy Center (DAEC) has submitted a license amendment request, with additional clarification, (LAR) (Reference 1 and 2) to change its fire protection program to one based on the National Fire Protection Association (NFPA) standard NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated into Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.48(c), Fire Protection.

The Nuclear Regulatory Commission (NRC) staffs review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulations (NRR) Office Instruction LIC-101, License Amendments. The NRC staff has determined that a regulatory audit of the DAEC should be conducted in accordance with LIC-111, Regulatory Audits, for the staff to gain a better understanding of the licensees calculations, proposed plant modifications, and other aspects of the LAR.

A regulatory audit is a planned, license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit of licensee information is expected to assist the staff in efficiently conducting its review or gain insights on the licensees processes or procedures.

Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under 10 CFR 50.71 and/or 10 CFR 54.37 that, although not required to be submitted as part of the licensing action, would help the staff better understand the licensees submitted information.

The objectives of this regulatory audit are to:

• Gain a better understanding of the detailed calculations, analyses and bases underlying the NFPA 805 LAR and confirm the staffs understanding of the LAR;

• Identify further information that is necessary for the licensee to submit for the staff to reach a licensing or regulatory decision; this will result in requests for additional information (RAIs)

• Verify that the licensees planned process for self-approval of fire protection program (FPP) changes will meet the proposed NFPA 805 license condition and quality requirements;

• Establish an understanding of proposed plant modifications necessary to implement ENCLOSURE

NFPA 805; and,

• Verify the implementation of processes or procedures that the licensee committed to as part of NFPA 805 implementation.

II. REGULATORY AUDIT BASIS The basis of this audit is the licensees LAR (Reference 1 and 2) and the Standard Review Plan (SRP) Section 9.5.1.2, Risk-Informed, Performance-Based (RI/PB) Fire Protection (Reference 3). References 4 through 8 provide additional information that will be used to support the audit.

III. REGULATORY AUDIT SCOPE OR METHOD The staff will review the licensees NFPA 805 transition as proposed in the LAR. Key to this effort is the licensees risk-informed/performance-based (RI/PB) FPP. The staff will review the fundamental FPP elements and minimum design requirements. A sample of fire protection engineering evaluations may be selected for review. In addition, the staff will review, as necessary, the regulatory basis, references, licensing actions, and existing engineering equivalency evaluations, and issues which the licensee has deemed previously approved.

The scope of the review of nuclear safety performance criteria may include both at-power and non-power operational modes, and may require a sample of procedures and other documentation. The compliance by fire area review will, as necessary, include multiple spurious operations, the transition of operator manual actions to recovery actions (RAs), fire protection engineering evaluations, and NFPA 805 deterministic requirements. The audit may also include alternatives to compliance with NFPA 805, if any are indentified.

The staff may review a sample of fire risk evaluations and plant change evaluations for one or more fire areas, the evaluation of the additional risk of RAs, the licensees process for self-approving post-transition FPP changes, cumulative risk and combined changes, as well as uncertainty and sensitivity analyses. The review may also include licensee risk-informed evaluations to ensure that defense in depth (DID) and safety margins have been evaluated and are maintained.

The staff will also review the licensees assessment of the technical adequacy of the PRA model used for any risk evaluations required to transition to a RI/PB FPP, including resolution of peer review findings and licensee self-assessments. This effort may include auditing a sample of logic models and calculations in the fire PRA model as well as the Internal Events PRA model.

The review will include, as necessary, the licensees processes that have or will be implemented to maintain the quality of the PRA to support self-approval of risk-informed change evaluation after transition is completed.

The scope may also include the licensees NFPA 805 monitoring program which is to establish and monitor acceptable levels of availability, reliability, and performance of fire protection systems and features relied upon for NFPA 805 compliance.

The scope will also include, as appropriate, selected plant modifications to confirm they have been appropriately characterized in the LAR. The staff will review the process for controlling

compensatory measures to confirm their adequacy while they remain in effect until the modifications are completed.

In addition, the audit will review program documentation, configuration control, and the FPP quality assurance program. The FPP design basis document will be reviewed, as well as other documentation of fire hazards identification and nuclear safety capability assessments. The review will include configuration control of the FPP design basis document, the fire PRA methods and model, and other relevant documentation as necessary. The staff may also review the FPP quality assurance program, and sample fire models and fire model calculations.

Walkdowns may be performed as necessary to confirm features of the licensees FPP and design elements.

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC audit team will require access to licensee personnel knowledgeable regarding the technical aspects of the DAEC LAR. As practical, the auditors will provide a description of subject matter needing DAEC expertise support approximately 2-4 hours in advance, to facilitate scheduling. At a minimum, a hardcopy and electronic copy of the following documentation should be available to the audit team:

• Calculational models and supporting documentation for PRA models used in support of the LAR, including peer review history and resolution of peer review significant findings;

• Calculational models and supporting documentation for fire models used in support of the LAR;

• Procedures and calculations that have been modified or developed to transition to the NFPA 805 licensing basis;

• Procedures and calculations that have been modified or developed to maintain the NFPA 805 licensing basis after transition is completed;

• Documentation of changes made to PRA models in support of change analysis;

• Documentation about PRA configuration control and procedures to support self-approval of risk-informed plant changes after transition;

• Documentation of plant modifications or operational changes identified, screened, and considered (or planned for) during the licensees transition to NFPA 805;

• Other documents, which the licensee deems as necessary to support the NRC staffs audit, outlined under audit activities; and,

• Calculations and evaluations used to transition to NFPA 805 such as plant change evaluations, engineering equivalency evaluations, and RA evaluations.

V. TEAM ASSIGNMENTS The audit will be conducted by NRC staff from the Office of Nuclear Reactor Regulation (NRR) and contractors; Pacific Northwest National Laboratory (PNNL) and the Center for Nuclear Waste and Regulatory Analysis (CNWRA). Division of Risk Assessment (DRA) Fire Protection Branch (AFPB) and the PRA Licensing Branch (APLA) staff, and contractor personnel knowledgeable in PRA, safe shutdown and circuits analysis, and fire protection engineering, will comprise the audit team. NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers. Observers at the audit may include NRR Managers and various Regional Inspectors.

The NRC team lead for this audit will be Paul W. Lain, NRR/DRA/AFPB, with support from Steve Short, Pacific Northwest National Laboratory. The tables below show (1) audit milestones and schedule, and (2) planned audit team composition and their assigned areas for review during the audit.

Audit Milestones and Schedule Relative to First Audit Day Onsite (T=0)

Activity Time Frame Comments 12/12/11, Request Licensee provides an NFPA 805 LAR overview Onsite Audit Kick-Off Meeting 1 PM CT presentation with important site specific information.

12/13/11 Onsite Escorted Tour Tour of risk significant power block areas.

12/14/11 Meet with licensee to provide a summary of any significant End of Day Summary Meeting 12/13 - 15/11 findings and requests for additional assistance.

Provide Break-out Areas 12/13 - 15/11 Facilitate discussion between site and staff technical areas.

12/16/11 Reviewers discuss their experience at the licensees facility for Onsite Audit Exit Meeting 9 AM CT the five days.

Audit Summary (see VIII) 1/16/12 To document the audit.

Regulatory Audit Team and Assignments SRP 9.5.1.2 Audit Plan Review Areas Lead Support Section III.1.2 Modifications Team Team III.1.3 Licensee self-approval Alayna Pearson Paul Lain III.2 Fundamental FPP and Design Elements Alayna Pearson Bob Layton, PNNL III.3.1.2 Multiple spurious operation Bernie Litkett Karl Bohlander, PNNL III.3.2 Fire area compliance Team Team III.3.2 Engineering evaluations, EEEEs, previous approval Team Team III.3.2.2 Operations guidance for fire modeling PB method Alayna Pearson Jason Huczek, CNWRA III.3.2.2 Recovery Actions Mike Snodderly Bob Schmidt, PNNL III.3.3 Non-power operation Bernie Litkett Karl Bohlander, PNNL Mike Snodderly, NRC III.5.3-5.6 Risk assessments Dan ONeal Bob Schmidt, PNNL III.5.1 PRA technical adequacy Dan ONeal Bob Schmidt, PNNL III.5.2 DID and safety margins Team Team III.6 Monitoring program Alayna Pearson Pat Mackin, CNWRA III.7.1-7.3 Documentation, Configuration Control, Quality Alayna Pearson Pat Mackin, CNWRA Plant walk-downs As needed As needed

VI. LOGISTICS This regulatory audit is planned to take place during the week of December 12, 2011, and last approximately 5 days. This start date is confirmed between the licensee and the NRC. An entrance meeting for this audit will be held on the first day at 1:00 p.m. and an exit meeting will be held the final audit day at 9:00 a.m. to provide preliminary feedback to the licensee.

Some NRC staff and support contractors will arrive in Cedar Rapids on Sunday, 12/11/11, and expect to start their activity in the morning prior to the entrance meeting.

The NRC audit leader will provide a daily progress update to licensee personnel on the second, third and fourth day of the audit. The exit meeting will be used for an overall summarization of the audit experience. A two-way exchange of information is encouraged.

The audit will take place at the DAEC Administration Building in Palo, IA adjacent to the Protected Area where (1) the necessary reference material and (2) appropriate analysts will be available to support the review. Because the audit scope includes NRC staff walkdowns of selected fire areas, the regulatory audit is being conducted in a location that supports escorted access to the plant protected area.

VII. SPECIAL REQUESTS The regulatory audit team requires the following to support the regulatory audit:

• Escorted access to fire areas within the protected area.

• Two or more computers with internet access.

• Private conference room(s) to support document review, and audit team meetings.

• Access to the FPP documentation, including the Fire Risk Evaluations, Safe Shutdown Analysis, and the fire and internal events PRAs.

• Access to licensee personnel knowledgeable in the FPP, fire modeling, safe shutdown and circuit analysis, fire and internal events PRA, non-power operations, and the NFPA 805 fire protection design-basis document.

VIII. DELIVERABLES A regulatory audit summary, for internal NRC use, will be issued within approximately 30 days of the completion of the audit. The audit summary will likely not contain information that will be used for the formal requests for additional information (RAIs) from the licensee to supplement the LAR. The RAIs will be developed separately and placed in the Agencywide Documents Access Management Systems (ADAMS.) as the public record.of the audit results (that is, the additional information needed on the docket to enable the evaluation of the LAR.

IX. REFERENCES

1. Letter from Peter Wells, NextEra Energy Duane Arnold, LLC, to U.S. Nuclear Regulatory Commission, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (TSCR - 128),

August 5, 2011 (ADAMS Accession Number ML11221A280)

2. Letter from Peter Wells, NextEra Energy Duane Arnold, LLC, to U.S. Nuclear Regulatory Commission, 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) (TSCR - 128),

October 14, 2011 (ADAMS Accession Number ML112870245)

3. U.S. NRC, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, NUREG-0800, Section 9.5.1.2, Risk-Informed, Performance-Based Fire Protection Program, (ADAMS accession no. ML092590527).

4. Title 10 Code of Federal Regulations, Part 50, Section 48 (10 CFR 50.48), Fire Protection.

5. NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Stations, 2001 Edition.

6. Regulatory Guide 1.205, Rev. 1, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, December 2009 (ADAMS accession no.

ML092730314)

7. Nuclear Energy Institute, NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 2, April 2008 (ADAMS accession no. ML081130188)

8. Nuclear Energy Institute, NEI 00-01, Guidance for Post-Fire Safe Shutdown Analysis, Rev.

2, May 2009 (ADAMS accession no. ML091770265)