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| | number = ML13175A393 | | | number = ML13175A393 |
| | issue date = 06/27/2013 | | | issue date = 06/27/2013 |
| | title = Duane Arnold Energy Center - Request for Additional Information for Review Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC ME6818) | | | title = Request for Additional Information for Review Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 |
| | author name = Feintuch K D | | | author name = Feintuch K |
| | author affiliation = NRC/NRR/DORL/LPLIII-1 | | | author affiliation = NRC/NRR/DORL/LPLIII-1 |
| | addressee name = Anderson R L | | | addressee name = Anderson R |
| | addressee affiliation = NextEra Energy Duane Arnold, LLC | | | addressee affiliation = NextEra Energy Duane Arnold, LLC |
| | docket = 05000331 | | | docket = 05000331 |
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| | document type = Letter, Request for Additional Information (RAI) | | | document type = Letter, Request for Additional Information (RAI) |
| | page count = 11 | | | page count = 11 |
| | project = TAC:ME6818, TAC:ME6818 | | | project = TAC:ME6818 |
| | stage = Other | | | stage = RAI |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2013 Mr. Richard L. Anderson, Site Vice President NextEra Energy Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785 SUBJECT: DUANE ARNOLD ENERGY CENTER-REQUEST FQR ADDITIONAL INFORMATION FOR REVIEW REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME6818) Dear Mr. Anderson: By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 11221A280), NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request. The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC), from Title 10 of the Code of Federal Regulations (1 0 CFR), Section 50.48(b) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on June 11, 2013, it was.agreed that you would submit an updated AttachmentS, Table S-2, Implementation Items, and that you would provide a response to this request for additional information by July 3, 2013. During a discussion with your staff on June 18, 2013, it was further agreed that you would add two implementation items to Table S-2. These items include (1) changing the heat release rate assigned to transient fires to comply with an NRC-accepted method1, and (2) discontinuing the use of the reduction in the likelihood estimates for circuits containing a control power transformer (CPT) compared to circuits without a .CPT that is described in Task 10 in NUREG/CR 68502, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, 1 The two currently acceptable methods include 1) the use of 981h percentile 317'rWV HRR as described in Table E-1 NUREG/CR 6850, "EPRIINRC-RES Fire PRA Methodology for Nuclear Power Facilities, April 2005," and 2) use of a different value supported by justification as endorsed by the NRC in its letter to NEI dated June 21, 2012 ori "Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993, 'Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires."' 2 The values in Tables 10-1 and 10-3 of NUREG/CR 6850 include a factor of 2 reduction compared to the same parameter values in Tables 10-2 and 10-4. Recent experiments have indicated that this factor of 2 cannot be demonstrated and Tables 10-2 and 10-4 should be used until new Tables have been developed and found acceptable by the NRC. | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2013 Mr. Richard L. Anderson, Site Vice President NextEra Energy Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785 |
| R. Anderson -2-April 2005." An example of these types of implementation items can be found in Table 2.9-1, Item 41 of the Safety Evaluation issued to Oconee Nuclear Station Units 1, 2, and 3, regarding transition to risk-informed, performance based fire protection program in accordance with 10 CFR 50.48(c) dated December 29, 2010 (ADAMS Accession No. ML 103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade. The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff and contribute toward the NRC's goal of efficient and effective use of staff resources. Please contact Carolyn Faria at (301) 415-4050, if you have any questions. Docket No. 50-331 Enclosures: Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ Sincerely, Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 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 DUANE ARNOLD ENERGY CENTER NEXTERA ENERGY DOCKET NO. 50-331 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System \ADAMS) Accession No. ML 11221A280}, NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request (LAR). The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC}, from Title 10 of the Code of Federal Regulations (1 0 CFR}, Section 50.48(b) to 10 CFR 50.48(c}, National Fire Protection Association Standard 805 (NFPA 805). To complete its revieW, the NRC staff requests additional information as discussed below. 1. The table enclosed summarizes modifications made to the probabilistic risk assessment (PRA) in response to several previous requests for additional information (RAI) issued during the review of the LAR to transition to NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition. Address the individual modifications as expressed in PRA RAI84 Table 1 to confirm the completion of each. 2. In licensee's letter dated February 12, 2013 (ADAMS Accession No. ML 13046A031}, in response to RAI 58.01, DAEC states that a full update of the NFPA 805 fire PRA application will be performed prior to transition. Propose a response that includes a regulatory process (e.g., a general license condition or implementation item) that provides assurance that all the proposed changes including those listed in PRA RAI84 Table 1 will be made and all associated documentation will be finalized before the PRA is used to support future self-approval. 3. An integrated analysis is provided in Table 5 of the response to RAI 82 dated May 1, 2013, (ADAMS Accession No. ML 13122A045). The results include fire scenarios for the main control room (MCR). Please provide the MCR abandonment fire scenarios total core damage frequency and large early release probability (CDF/LERF) and delta CDF/LERF from this analysis. If there is a difference between the total and delta risk for these fire scenarios, explain the R. Anderson -2-reason for the difference and provide justification for not including the entire MCR abandonment risk in the calculation of delta risk. Discuss how the delta risk is calculated for the MCR abandonment scenarios for the different conditional core damage probabilities (CCDPs), which are discussed in the response to RAI 64 (ADAMS Accession No. ML 13015A350), and how the MCR abandonment recovery actions are included in the delta risk calculation for each CCDP. For example, it is not clear from the response to RAI 64 how the failure to recover probability and the 0.1 probability of failure of success path equipment are used in the compliant case versus .the variant case. Please include additional description of how the compliant versus variant CDF/LERF are estimated for the same scenario. | | |
| RAI FM 01 PRA05 PRA07 PRA RAI84 Table 1 Description of Modification and Request for Additional Information In the licensee's letter dated October 15, 2013 (ADAMS Accession No. ML 122910950), DAEC states that: The DAEC Fire PRA-NFPA 805 RAJ Model Update Quantification Report has been updated to include the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets. This change will be incorporated in the updated FPRA model in response to RAI-01. Please confirm that the PRA includes the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See Jetter dated February 12, 2013, ADAMS Accession No. ML 13046A031). Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML 12146A094), included a revised multi-compartment analysis (MCA) in which barrier elements were summed. The revised MCA is included in the composite analysis. DAEC also stated that they would revise Appendix C of the Fire Scenario Report to include barrier elements as discussed in RAJ PRA-5. Confirm that the PRA includes a revised MCA in which barrier elements were summed, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML 12146A094), included a revised analysis without using a severity factor of 0.01 for the diesel generator rooms. The revised analysis is included in the composite analysis. DAEC also stated that they would update Appendix C of the Fire Scenario Report to reflect changes in MCA scenarios as discussed in RAJ PRA-7. Confirm that the PRA no longer uses a severity factor of 0.01 for the diesel generator rooms, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). Enclosure 2
| | ==SUBJECT:== |
| -2-RAI Description of Modification and Request for Additional Information PRA 08.01 By letter dated March 6, 2013, (ADAMS Accession No. ML 13070A065), DAEC included a revised MCA to include NUREG/CR-6850 Step 5.c (Section 11.5.4.5) while determining whether combinations of MCA should be screened out. The letter also stated that the revised analysis is included in the composite analysis (ADAMS Accession No. ML 13122A045), Table 4-3 of the License Amendment Request (ADAMS Accession No. ML 11221A280) and will be updated to include the automatic suppression system required for risk. Confirm that the PRA screens combinations of MCAs based on NUREG/CR-6850, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA10 By letter dated April23, 2012, (ADAMS Accession No. ML 12117A052), DAEC responded that during transition to NFPA 805, the monitoring program will be enhanced to satisfy new requirements. Please confirm that the monitoring program will be enhanced to satisfy new requirements and, to the extent applicable, these new requirements will be reflected in the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA 11.01 By letter dated March 6, 2013, (ADAMS Accession No. ML 13070A065), DAEC included a revised analysis without manual suppression credit. The letter also stated that the revised analysis is included in the composite analysis. (See letter dated April 23, 2012, ADAMS Accession No. ML 12117A052 and ML 13122A045). Confirm that the PRA does not include manual suppression credit and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031 ). PRA13 By letter dated April 23, 2012 (ADAMS Accession No. ML 12117 A052), DAEC stated that they would revise Section 2 and Table 2.2-2 of the Plant Partitioning and Fire Ignition Frequency report to reflect the expanded justification provided in response to RAI PRA-13. Please confirm that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031).
| | DUANE ARNOLD ENERGY CENTER- REQUEST FQR ADDITIONAL INFORMATION FOR REVIEW REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME6818) |
| -3-RAI Description of Modification and Request for Additional Information PRA 14a Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML 12146A094), included a revised cable spreading room (CSR) analysis that removed a hot work pre-initiator factor of 0.01. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA no longer includes a hot work pre-initiator factor of 0.01, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031 ). PRA 14b Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML 12146A094), included a revised CSR analysis with the use of a "Very Low" ranking consistent with Frequently Asked Question (FAQ) 12-0064, Hot Work/Transient Fire Frequency Influence Factors (ADAMS Accession No. ML 12346A488). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA's CSR analysis uses the "Very Low" ranking consistent with FAQ 12-0064, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031 ). PRA 14.01 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML 12146A094), included a revised CSR analysis that: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes alternate shutdown capability (ASC) is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies large early release frequency (LERF). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes ASC is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies LERF, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031).
| | |
| -4-RAI Description of Modification and Request for Additional Information PRA16 By letter dated April23, 2012 (ADAMS Accession No. ML 12117A052), DAEC stated that Table 3.3-1 of the Fire Model Development Report, the human reliability analysis (HRA) and the basic event probability will be updated to reflect the lack of a cue and that the operator action is not credited in the FPRA. In addition, DAEC stated that the basic event probability will be applied in the updated FPRA model in response to RAI PRA 01. Confirm that the HRA in the PRA and any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA33 By letter dated April 23, 2012 (ADAMS Accession No. ML 12117 A052), DAEC stated that they would revise Section 6 of the Fire Model Development Report to include the details regarding the evaluation of long term operator actions on LERF provided in response to RAI PRA-33. Confirm that the missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA 35.01 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML 13070A065), included justification for incipient detection credit and the results of a sensitivity study without incipient detection credit. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that no credit for incipient detection is included in the composite analysis. Confirm that the PRA includes no credit for incipient detection and that conforming changes will be completed for all documentation during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA57 Licensee's letter dated April 23, 2012 (ADAMS Accession No. ML 12117A052), included a response to RAI 57 that included a table that listed each PRA level 2 basic event and identified the potential fire impact for each event. The letter also stated that DAEC would revise the Fire Model Development Report to include the table provided in response to RAI PRA-57. Confirm the documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 under cover letter dated February 12, 2013 (ADAMS Accession No. ML 13046A031).
| | ==Dear Mr. Anderson:== |
| -5-RAI Description of Modification and Request for Additional Information PRA69 In a letter dated March 6, 2013, (ADAMS Accession No. ML 13070A065), it was stated by DAEC that the FPRA adequately evaluates electronics in the MCR as described in NUREG/CR-6850. In a letter dated May 1, 2013 (ADAMS Accession No. ML 13122A045), in response to a follow-on question related to RAI 69 in RAI 82, a summary was provided related to an evaluation of electronics outside of the MCR that included walkdowns and use of NUREG/CR-6850 damage temperatures. Confirm that: (1) the PRA includes the results of evaluation inside and outside of the MCR that are consistent with the methods as described in NUREG/CR-6850, and (2) that documentation will incorporate the relevant discussion during the full update of the NFPA 805 fire PRA application, as stated in response'to RAI 58.01 under cover letter dated February 12, 2013. PRA70 Licensee's letter dated February 12, 2013 (ADAMS Aqcession No. ML 13046A031 ), identified that the credit given to sealed electrical cabinets to prevent fire spread was consistent with the treatment in FAQ 08-0042, Fire Propagation From Electrical Cabinets, (ADAMS Accession No. ' ML09211 0537). Confirm that the PRA evaluates sealed cabinets according to FAQ 08-0042, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). PRA 71 RAI 71 questioned the use of a conditional probability of 0.1 for transient combustibles located near the MCR, and the response to RAI 82 indicated that this probability had been removed. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA no longer includes the conditional probability, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031 ). PRA72 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML 13070A065), included a revised analysis that used a minimum non-suppression probability of 0.001. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA uses a minimum non-suppression probability of 0.001, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031).
| | |
| -6-RAI Description of Modification and Request for Additional Information PRA 83b In response to the RAJ 83b dated May 1, 2013 (ADAMS Accession No. ' ML 13122A045), it was clarified by DAEC that the heat release rate (HRR) used in the updated CSR analysis was based on NUREG/CR-6850 guidance. In the response to RAJ 82 dated May 1, 2013 (ADAMS Accession No. ML 13122A045), it was stated that the revised analysis is included in the composite analysis. Confirm that the PRA uses an updated CSR analysis using a HRR based on NUREG/CR-6850 guidance and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). LAR TableV-The disposition of these Facts and Observations (F&Os) is that fire scenario 3 F&O 1 OE-F45 sensitivity case refined the use of the electric panel factor approach 4-22, 4-23, 4-to use of the Hughes Generic Fire Modeling results for critical separation 25 distances based on HRR. dispositions Confirm that the PRA. uses the Hughes Generic Fire Modeling results for critical separation distances based on HRR, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML 13046A031). Also confirm that the electric panel factor approach had not been used in the results reported for RAJ 82. RAI64 A detailed HRA was performed as a basis for justifying that the MCR conditional core damage probability of 0.1 is bounding. This HRA is related to a recovery action in the LAR to start the emergency diesel generator SBDG1 to power the vital bus for ASC. The HRA evaluation was provided in response to RAJ 64 in a letter dated. January 11, 2013 (ADAMS Accession No. ML 13015A350). Confirm that the inputs to the detailed HRA have been evaluated in both the LAR Attachment G, Step 4, "Evaluate the Feasibility of Recovery Actions," and Step 5;"Evaluate the Reliability of Recovery Actions".
| | By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11221A280), |
| R. Anderson -2-April2005." An example of these types of implementation items can be found in Table 2.9-1, Item 41 of the Safety Evaluation issued to Oconee Nuclear Station Units 1, 2, and 3, regarding transition to risk-informed, performance based fire protection program in accordance with 10 CFR 50.48(c) dated December 29, 2010 (ADAMS Accession No. ML 103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade. The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. Please contact Carolyn Farra at (301) 415-4050, if you have any questions. Docket No. 50-331 Enclosures: Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ DISTRIBUTION: PUBLIC RidsNrrOd Resource Sincerely, /RAJ Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrDorl Resource RidsNrrDorllpl3-1 Resource RidsOeMaiiCenter Resource RidsNrrPMDuaneArnoldResource RidsNrrDraApla Resource KFeintuch, NRR ADAMS Accession No
| | NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request. |
| * ML 13175A393 .. *concurrence via e-mail dated 6/11/13 OFFICE LPL3-1/PM LPL3-1/PM LPL3-1/LA NRR/APLA/BC . LPL3-1/BC LPL3-1/PM NAME CFaria KFeintuch SRohrer H.Hamzehee* RCarlson KFeintuch DATE 06/11/13 06/12/13 06/25113 06/11/13 06/27113 06/27/13 OFFICIAL RECORD COPY | | The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC), from Title 10 of the Code of Federal Regulations (1 0 CFR), |
| }} | | Section 50.48(b) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). |
| | The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on June 11, 2013, it was.agreed that you would submit an updated AttachmentS, Table S-2, Implementation Items, and that you would provide a response to this request for additional information by July 3, 2013. |
| | During a discussion with your staff on June 18, 2013, it was further agreed that you would add two implementation items to Table S-2. These items include (1) changing the heat release rate assigned to transient fires to comply with an NRC-accepted method 1 , and (2) discontinuing the use of the reduction in the likelihood estimates for circuits containing a control power transformer (CPT) compared to circuits without a .CPT that is described in Task 10 in NUREG/CR 68502 , "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, 1 1 The two currently acceptable methods include 1) the use of 98 h percentile 317'rWV HRR as described in Table E-1 NUREG/CR 6850, "EPRIINRC-RES Fire PRA Methodology for Nuclear Power Facilities, April 2005," and 2) use of a different value supported by justification as endorsed by the NRC in its letter to NEI dated June 21, 2012 ori "Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993, 'Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires."' |
| | 2 The values in Tables 10-1 and 10-3 of NUREG/CR 6850 include a factor of 2 reduction compared to the same parameter values in Tables 10-2 and 10-4. Recent experiments have indicated that this factor of 2 cannot be demonstrated and Tables 10-2 and 10-4 should be used until new Tables have been developed and found acceptable by the NRC. |
| | |
| | R. Anderson April 2005." An example of these types of implementation items can be found in Table 2.9-1, Item 41 of the Safety Evaluation issued to Oconee Nuclear Station Units 1, 2, and 3, regarding transition to risk-informed, performance based fire protection program in accordance with 10 CFR 50.48(c) dated December 29, 2010 (ADAMS Accession No. ML103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade. |
| | The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff ~eview and contribute toward the NRC's goal of efficient and effective use of staff resources. |
| | Please contact Carolyn Faria at (301) 415-4050, if you have any questions. |
| | Sincerely, Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331 |
| | |
| | ==Enclosures:== |
| | Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ |
| | |
| | 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 DUANE ARNOLD ENERGY CENTER NEXTERA ENERGY DOCKET NO. 50-331 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System\ADAMS) Accession No. ML11221A280}, |
| | NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request (LAR). The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC}, from Title 10 of the Code of Federal Regulations (1 0 CFR}, |
| | Section 50.48(b) to 10 CFR 50.48(c}, National Fire Protection Association Standard 805 (NFPA 805). To complete its revieW, the NRC staff requests additional information as discussed below. |
| | : 1. The table enclosed summarizes modifications made to the probabilistic risk assessment (PRA) in response to several previous requests for additional information (RAI) issued during the review of the LAR to transition to NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition. |
| | Address the individual modifications as expressed in PRA RAI84 Table 1 to confirm the completion of each. |
| | : 2. In licensee's letter dated February 12, 2013 (ADAMS Accession No. ML13046A031}, in response to RAI 58.01, DAEC states that a full update of the NFPA 805 fire PRA application will be performed prior to transition. |
| | Propose a response that includes a regulatory process (e.g., a general license condition or implementation item) that provides assurance that all the proposed changes including those listed in PRA RAI84 Table 1 will be made and all associated documentation will be finalized before the PRA is used to support future self-approval. |
| | : 3. An integrated analysis is provided in Table 5 of the response to RAI 82 dated May 1, 2013, (ADAMS Accession No. ML13122A045). The results include fire scenarios for the main control room (MCR). |
| | Please provide the MCR abandonment fire scenarios total core damage frequency and large early release probability (CDF/LERF) and delta CDF/LERF from this analysis. If there is a difference between the total and delta risk for these fire scenarios, explain the |
| | |
| | R. Anderson reason for the difference and provide justification for not including the entire MCR abandonment risk in the calculation of delta risk. |
| | Discuss how the delta risk is calculated for the MCR abandonment scenarios for the different conditional core damage probabilities (CCDPs), which are discussed in the response to RAI 64 (ADAMS Accession No. ML13015A350), and how the MCR abandonment recovery actions are included in the delta risk calculation for each CCDP. For example, it is not clear from the response to RAI 64 how the failure to recover probability and the 0.1 probability of failure of success path equipment are used in the compliant case versus .the variant case. Please include additional description of how the compliant versus variant CDF/LERF are estimated for the same scenario. |
| | |
| | PRA RAI84 Table 1 RAI Description of Modification and Request for Additional Information FM 01 In the licensee's letter dated October 15, 2013 (ADAMS Accession No. ML122910950), DAEC states that: The DAEC Fire PRA- NFPA 805 RAJ Model Update Quantification Report has been updated to include the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets. This change will be incorporated in the updated FPRA model in response to RAI-01. |
| | Please confirm that the PRA includes the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See Jetter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA05 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised multi-compartment analysis (MCA) in which barrier elements were summed. The revised MCA is included in the composite analysis. DAEC also stated that they would revise Appendix C of the Fire Scenario Report to include barrier elements as discussed in RAJ PRA-5. |
| | Confirm that the PRA includes a revised MCA in which barrier elements were summed, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA07 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised analysis without using a severity factor of 0.01 for the diesel generator rooms. The revised analysis is included in the composite analysis. DAEC also stated that they would update Appendix C of the Fire Scenario Report to reflect changes in MCA scenarios as discussed in RAJ PRA-7. |
| | Confirm that the PRA no longer uses a severity factor of 0.01 for the diesel generator rooms, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | Enclosure 2 |
| | |
| | RAI Description of Modification and Request for Additional Information PRA 08.01 By letter dated March 6, 2013, (ADAMS Accession No. ML13070A065), |
| | DAEC included a revised MCA to include NUREG/CR-6850 Step 5.c (Section 11.5.4.5) while determining whether combinations of MCA should be screened out. The letter also stated that the revised analysis is included in the composite analysis (ADAMS Accession No. ML13122A045), Table 4-3 of the License Amendment Request (ADAMS Accession No. ML11221A280) and will be updated to include the automatic suppression system required for risk. |
| | Confirm that the PRA screens combinations of MCAs based on NUREG/CR-6850, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA10 By letter dated April23, 2012, (ADAMS Accession No. ML12117A052), |
| | DAEC responded that during transition to NFPA 805, the monitoring program will be enhanced to satisfy new requirements. |
| | Please confirm that the monitoring program will be enhanced to satisfy new requirements and, to the extent applicable, these new requirements will be reflected in the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA 11.01 By letter dated March 6, 2013, (ADAMS Accession No. ML13070A065), |
| | DAEC included a revised analysis without manual suppression credit. The letter also stated that the revised analysis is included in the composite analysis. (See letter dated April 23, 2012, ADAMS Accession No. ML12117A052 and ML13122A045). |
| | Confirm that the PRA does not include manual suppression credit and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ). |
| | PRA13 By letter dated April 23, 2012 (ADAMS Accession No. ML12117A052), |
| | DAEC stated that they would revise Section 2 and Table 2.2-2 of the Plant Partitioning and Fire Ignition Frequency report to reflect the expanded justification provided in response to RAI PRA-13. |
| | Please confirm that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | |
| | RAI Description of Modification and Request for Additional Information PRA 14a Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised cable spreading room (CSR) analysis that removed a hot work pre-initiator factor of 0.01. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA no longer includes a hot work pre-initiator factor of 0.01, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ). |
| | PRA 14b Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised CSR analysis with the use of a "Very Low" ranking consistent with Frequently Asked Question (FAQ) 12-0064, Hot Work/Transient Fire Frequency Influence Factors (ADAMS Accession No. ML12346A488). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA's CSR analysis uses the "Very Low" ranking consistent with FAQ 12-0064, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ). |
| | PRA 14.01 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised CSR analysis that: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes alternate shutdown capability (ASC) is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies large early release frequency (LERF). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes ASC is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies LERF, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | |
| | RAI Description of Modification and Request for Additional Information PRA16 By letter dated April23, 2012 (ADAMS Accession No. ML12117A052), |
| | DAEC stated that Table 3.3-1 of the Fire Model Development Report, the human reliability analysis (HRA) and the basic event probability will be updated to reflect the lack of a cue and that the operator action is not credited in the FPRA. In addition, DAEC stated that the basic event probability will be applied in the updated FPRA model in response to RAI PRA 01. |
| | Confirm that the HRA in the PRA and any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA33 By letter dated April 23, 2012 (ADAMS Accession No. ML12117A052), |
| | DAEC stated that they would revise Section 6 of the Fire Model Development Report to include the details regarding the evaluation of long term operator actions on LERF provided in response to RAI PRA-33. |
| | Confirm that the missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA 35.01 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML13070A065), included justification for incipient detection credit and the results of a sensitivity study without incipient detection credit. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that no credit for incipient detection is included in the composite analysis. |
| | Confirm that the PRA includes no credit for incipient detection and that conforming changes will be completed for all documentation during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA57 Licensee's letter dated April 23, 2012 (ADAMS Accession No. ML12117A052), included a response to RAI 57 that included a table that listed each PRA level 2 basic event and identified the potential fire impact for each event. The letter also stated that DAEC would revise the Fire Model Development Report to include the table provided in response to RAI PRA-57. |
| | Confirm the documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 under cover letter dated February 12, 2013 (ADAMS Accession No. ML13046A031). |
| | |
| | RAI Description of Modification and Request for Additional Information PRA69 In a letter dated March 6, 2013, (ADAMS Accession No. ML13070A065), it was stated by DAEC that the FPRA adequately evaluates electronics in the MCR as described in NUREG/CR-6850. In a letter dated May 1, 2013 (ADAMS Accession No. ML13122A045), in response to a follow-on question related to RAI 69 in RAI 82, a summary was provided related to an evaluation of electronics outside of the MCR that included walkdowns and use of NUREG/CR-6850 damage temperatures. |
| | Confirm that: (1) the PRA includes the results of evaluation inside and outside of the MCR that are consistent with the methods as described in NUREG/CR-6850, and (2) that documentation will incorporate the relevant discussion during the full update of the NFPA 805 fire PRA application, as stated in response'to RAI 58.01 under cover letter dated February 12, 2013. |
| | PRA70 Licensee's letter dated February 12, 2013 (ADAMS Aqcession No. |
| | ML13046A031 ), identified that the credit given to sealed electrical cabinets to prevent fire spread was consistent with the treatment in FAQ 08-0042, Fire Propagation From Electrical Cabinets, (ADAMS Accession No. |
| | ' ML092110537). |
| | Confirm that the PRA evaluates sealed cabinets according to FAQ 08-0042, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | PRA 71 RAI 71 questioned the use of a conditional probability of 0.1 for transient combustibles located near the MCR, and the response to RAI 82 indicated that this probability had been removed. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA no longer includes the conditional probability, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ). |
| | PRA72 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML13070A065), included a revised analysis that used a minimum non-suppression probability of 0.001. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA uses a minimum non-suppression probability of 0.001, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | |
| | RAI Description of Modification and Request for Additional Information PRA 83b In response to the RAJ 83b dated May 1, 2013 (ADAMS Accession No. |
| | ' ML13122A045), it was clarified by DAEC that the heat release rate (HRR) used in the updated CSR analysis was based on NUREG/CR-6850 guidance. In the response to RAJ 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis. |
| | Confirm that the PRA uses an updated CSR analysis using a HRR based on NUREG/CR-6850 guidance and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). |
| | LAR TableV- The disposition of these Facts and Observations (F&Os) is that fire scenario 3 F&O 1OE-F45 sensitivity case refined the use of the electric panel factor approach 4-22, 4-23, 4- to use of the Hughes Generic Fire Modeling results for critical separation 25 distances based on HRR. |
| | dispositions Confirm that the PRA. uses the Hughes Generic Fire Modeling results for critical separation distances based on HRR, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). Also confirm that the electric panel factor approach had not been used in the results reported for RAJ 82. |
| | RAI64 A detailed HRA was performed as a basis for justifying that the MCR conditional core damage probability of 0.1 is bounding. This HRA is related to a recovery action in the LAR to start the emergency diesel generator SBDG1 to power the vital bus for ASC. The HRA evaluation was provided in response to RAJ 64 in a letter dated. January 11, 2013 (ADAMS Accession No. ML13015A350). |
| | Confirm that the inputs to the detailed HRA have been evaluated in both the LAR Attachment G, Step 4, "Evaluate the Feasibility of Recovery Actions," |
| | and Step 5;"Evaluate the Reliability of Recovery Actions". |
| | |
| | ML103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade. |
| | The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. |
| | Please contact Carolyn Farra at (301) 415-4050, if you have any questions. |
| | Sincerely, |
| | /RAJ Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331 |
| | |
| | ==Enclosures:== |
| | Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ DISTRIBUTION: |
| | PUBLIC RidsNrrOd Resource RidsNrrDorl Resource RidsNrrDorllpl3-1 Resource RidsOeMaiiCenter Resource RidsNrrPMDuaneArnoldResource RidsNrrDraApla Resource KFeintuch, NRR ADAMS Accession No ..* ML13175A393 *concurrence via e-mail dated 6/11/13 OFFICE LPL3-1/PM LPL3-1/PM LPL3-1/LA NRR/APLA/BC . LPL3-1/BC LPL3-1/PM NAME CFaria KFeintuch SRohrer H.Hamzehee* RCarlson KFeintuch DATE 06/11/13 06/12/13 06/25113 06/11/13 06/27113 06/27/13}} |
Letter Sequence RAI |
|---|
|
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance
|
MONTHYEARML1017602192010-06-22022 June 2010
NFPA 805 Transition Pilot Plant FAQ 07-0030, Revision 1
Project stage: Request
ML1026401142010-09-16016 September 2010
NFPA 805 Transition Pilot Plant FAQ 07-0030, Revision 4
Project stage: Request
ML1030802102010-11-0404 November 2010
NRC Staff Response to NFPA 805 Transition Pilot Plant FAQ 07-0030, Revision 4
Project stage: Request
ML1030906022010-11-0404 November 2010
NFPA 805 Transition Pilot Plant FAQ 07-0030, Revision 5
Project stage: Request
ML1035103792010-12-17017 December 2010
NFPA 805 Transition Pilot Plant FAQ 08-0054, Revision 1
Project stage: Request
ML1100704852011-02-0404 February 2011
Close-out of National Fire Protection Association Frequently Asked 07-0030 on Establishing Recovery Actions
Project stage: Request
ML1111804812011-04-21021 April 2011
NFPA 805 Transition FAQ 10-0059, Rev 1
Project stage: Request
NG-11-0267, 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)2011-08-0505 August 2011
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)
Project stage: Request
L-2011-312, Point Beach and St. Lucie, Units 1 and 2 and Turkey Point, Units 3 and 4 - Regarding Online Reference Portal2011-08-0505 August 2011
Point Beach and St. Lucie, Units 1 and 2 and Turkey Point, Units 3 and 4 - Regarding Online Reference Portal
Project stage: Request
ML11277A2852011-10-0303 October 2011
NRR E-mail Capture - FW: ME6818 - NFPA 805 Adoption Acceptance Review RAIs and Clarification Conference Call of 9/30/2011
Project stage: RAI
NG-11-0384, 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)2011-10-14014 October 2011
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)
Project stage: Request
ML11304A1242011-10-27027 October 2011
NRR E-mail Capture - ME6818 - Duane Arnold - LIC-109 Acceptance Review Results - Transition to 10 CFR 50.48(c) - Adoption of NFPA 805 Performance-Based Fire Protection Standard
Project stage: Acceptance Review
ML11304A1482011-10-28028 October 2011
NRR E-mail Capture - ME6818 - Duane Arnold Adoption of NFPA-805 - Generic List of Documents Requested for the Sharepoint Portal
Project stage: Other
ML11334A1502011-11-30030 November 2011
NRR E-mail Capture - ME6818 - DAEC NFPA-805 Adoption - Pre-Audit Discussion - 29 Nov 2011 Conference Call
Project stage: Other
ML12031A1122012-01-31031 January 2012
NRR E-mail Capture - ME6818 - DAEC Adoption of NFPA-805 - Afpb, Ihpb, Apla Request for Additional Information (RAI)
Project stage: RAI
ML12058A5702012-02-24024 February 2012
NRR E-mail Capture - ME6818 Record of Duane Arnold RAI Clarification Call - Wednesday, February 22, 2012 2:15 PM-3:15 PM ET
Project stage: RAI
ML12058A5722012-02-27027 February 2012
NRR E-mail Capture - ME6818 - Clarification Conference Call of 2/22/2012 - Licensee and NRC Attendance - Supplemental Record
Project stage: Other
ML12079A2322012-03-19019 March 2012
NRR E-mail Capture - ME6818 DAEC 60/90 Day Matrix - RAI Processing Identifier Syntax
Project stage: RAI
NG-12-0177, 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 Generational Plants2012-04-23023 April 2012
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 Generational Plants
Project stage: Response to RAI
ML12115A0782012-04-24024 April 2012
NRR E-mail Capture - FW: ACRS July 2012 NFPA-805 Subcommittee Meeting - Invitation for DAEC Participation
Project stage: Meeting
ML1214300352012-05-21021 May 2012
NFPA 805 Transition FAQ 12-0062, Revision 1
Project stage: Request
NG-12-0225, 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 Plants2012-05-23023 May 2012
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
Project stage: Response to RAI
ML12284A0212012-10-0808 October 2012
NRR E-mail Capture - ME6818 Duane Arnold NFPA-805 - Second Audit Visit Questions (Retrieved Copy)
Project stage: Other
NG-12-0419, Response to Second 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 Plants2012-10-15015 October 2012
Response to Second 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
Project stage: Request
ML12304A0692012-10-26026 October 2012
NRR E-mail Capture - ME6818, Additional RAIs for Duane Arnold Energy Center, LAR to Adopt NFPA 805
Project stage: RAI
ML12318A3942012-11-0808 November 2012
NRR E-mail Capture - ME6818 - DAEC Adoption of NFPA-805 - Record of RAI Clarification Conference Call Conducted on 11/08/2012
Project stage: RAI
ML12340A4502012-12-0505 December 2012
NRR E-mail Capture - ME6818 - DAEC Adoption of NFPA 805 - Request for Additional Information (RAI) Items - Round 2 (More)
Project stage: RAI
ML12355A0722012-12-19019 December 2012
NRR E-mail Capture - FW: ME6818 - DAEC NFPA-805 Adoption - Record of Revisions to RAI Items, Expected Response Schedule, Participants List for Meetings on 17-18 December 2012
Project stage: RAI
ML12361A0192012-12-23023 December 2012
NRR E-mail Capture - Supplement to ML12355A072 (RAI Issed as an Email on 12/19/2012, at 4:08 PM ET)
Project stage: RAI
NG-12-0502, 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 Plants2013-01-11011 January 2013
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
Project stage: Response to RAI
NG-13-0056, Response to RAI, License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants2013-02-12012 February 2013
Response to RAI, License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants
Project stage: Response to RAI
NG-13-0102, 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 Plants2013-03-0606 March 2013
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
Project stage: Response to RAI
ML13070A0352013-03-0808 March 2013
NRR E-mail Capture - ME6818 - DA - NFPA-805 Adoption - Request for Portal Locations to Selected RAI Responses
Project stage: RAI
ML13084A0042013-03-22022 March 2013
NRR E-mail Capture - ME6818 DAEC Adoption of NFPA-805 - Request for Additional Information
Project stage: RAI
ML13098B0722013-04-0707 April 2013
NRR E-mail Capture - ME6818 - DAEC Adoption of NFPA-805 - Request for Additional Information (Revised)
Project stage: RAI
ML13119A2202013-04-26026 April 2013
NRR E-mail Capture - FW: ME6818-DAEC-Adoption of NFPA-805- RAI Dated 4/7/2013 - Record of Clarification Call of April 11, 2013
Project stage: RAI
NG-13-0182, 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 Plants2013-05-0101 May 2013
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
Project stage: Response to RAI
ML13129A0742013-05-0808 May 2013
NRR E-mail Capture - ME6818 - DAEC - Adoption of NFPA 805 - Request for Additional Information (RAI)
Project stage: RAI
NG-13-0240, 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 Plants2013-05-29029 May 2013
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
Project stage: Response to RAI
ML13175A3932013-06-27027 June 2013
Request for Additional Information for Review Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805
Project stage: RAI
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 Plants2013-07-0202 July 2013
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
Project stage: Response to RAI
NG-13-0287, 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 Plants2013-07-0202 July 2013
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
Project stage: Response to RAI
ML13210A4582013-07-30030 July 2013
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 Electric Generating Plants
Project stage: Other
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 Plants2013-08-0505 August 2013
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
Project stage: Request
NG-13-0341, 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 Generating Plants2013-08-28028 August 2013
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 Generating Plants
Project stage: Request
ML13210A4492013-09-10010 September 2013
Issuance of Amendment Regarding Transition to a Risk-Informed Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)
Project stage: Approval
2012-02-27
[Table View] |
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Category:Letter
MONTHYEARML24240A1692024-09-18018 September 2024
Cy 2023 Summary of Decommissioning Trust Fund Status
ML24249A1362024-09-0404 September 2024
EN 57304 - Westinghouse Electric Company, LLC, Final Report - No Embedded Files. Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21
ML24163A0012024-08-0505 August 2024
LTR-24-0119-1-1 Response to Nh Letter Regarding Review of NextEras Emergency Preparedness Amendment Review
ML24193A2432024-07-12012 July 2024
– Interim Audit Summary Report in Support of Review of License Amendment Requests Regarding Fleet Emergency Plan
ML24149A2862024-06-12012 June 2024
NextEra Fleet - Proposed Alternative Frr 23-01 to Use ASME Code Case N-752-1, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section X1, Division 1 (EPID L-2023-LLR-0009) - Letter
ML24151A6482024-06-0303 June 2024
Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities
NG-24-0004, 2023 Annual Radiological Environmental Operating Report2024-05-0808 May 2024
2023 Annual Radiological Environmental Operating Report
NG-24-0003, Submittal of 2023 Annual Radioactive Material Release Report2024-04-24024 April 2024
Submittal of 2023 Annual Radioactive Material Release Report
ML24072A0292024-03-29029 March 2024
Nextera Energy Duane Arnold, Llc. Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)
NG-24-0002, 2023 Annual Exposure Report - Form 5s2024-03-0606 March 2024
2023 Annual Exposure Report - Form 5s
NG-24-0001, 2024 Annual Decommissioning and Spent Fuel Management Funding Status Report and Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Financial Assurance Update2024-03-0606 March 2024
2024 Annual Decommissioning and Spent Fuel Management Funding Status Report and Independent Spent Fuel Storage Installation (ISFSI) Decommissioning Financial Assurance Update
L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024
Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)
NG-23-0010, Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-12-0606 December 2023
Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule
NG-23-0009, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023
Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule
ML23201A0872023-08-0303 August 2023
Audit Plan in Support of Review of License Amendment
NG-23-0006, Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-05-23023 May 2023
Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update
ML23137A1672023-05-11011 May 2023
Submittal of 2022 Annual Radiological Environmental Operating Report
NG-23-0004, 2022 Annual Radioactive Material Release Report2023-04-25025 April 2023
2022 Annual Radioactive Material Release Report
NG-23-0003, 2022 Annual Exposure Report - Form 5s2023-04-21021 April 2023
2022 Annual Exposure Report - Form 5s
NG-23-0001, 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report2023-03-27027 March 2023
2023 Annual Decommissioning and Spent Fuel Management Funding Status Report
NG-23-0002, 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report2023-03-27027 March 2023
10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report
L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023
and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)
ML22361A1022023-02-24024 February 2023
Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities
ML22339A0012022-12-22022 December 2022
Acceptance of Requested Licensing Action Amendment Request for Common Emergency Plan
IR 05000331/20220032022-12-13013 December 2022
NRC Inspection Report No. 05000331/2022003 (Drss)
ML22285A0072022-10-13013 October 2022
NRC Analysis of NextEra Energy Duane Arnold'S Decommissioning Funding Status Report, Docket No. 50-331
IR 05000331/20220022022-07-13013 July 2022
NRC Inspection Report Nos. 05000331/2022002(DNMS) and 07200032/2022002(DNMS)
ML22090A1922022-05-26026 May 2022
Letter to B. Coffey, FPL from M. Doell - Duane Arnold Post Shutdown Activities Report Review Letter
ML22132A2872022-05-24024 May 2022
ISFSI DQAP Approval Letter
ML22111A0332022-05-20020 May 2022
Operating License Page Correction Letter to B. Coffey, Florida Power and Light, from M. Doell
NG-22-0055, Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan2022-05-20020 May 2022
Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan
ML22089A0492022-05-12012 May 2022
Sfmp Review Letter
NG-22-0053, 2021 Annual Radiological Environmental Operating Report2022-05-0606 May 2022
2021 Annual Radiological Environmental Operating Report
NG-22-0052, Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative2022-05-0404 May 2022
Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative
IR 05000331/20224012022-04-27027 April 2022
Decommissioning Security Inspection Report 05000331/2022401
NG-22-0050, Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 02022-04-26026 April 2022
Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 0
NG-22-0049, 2021 Annual Radioactive Material Release Report2022-04-26026 April 2022
2021 Annual Radioactive Material Release Report
ML22066A7632022-04-25025 April 2022
ISFSI-Only Emergency Plan License Amendment Approval
L-2022-068, NextEra Energy Duane Arnold Quality Assurance Topical Report (FPL-3) Revision 22022-04-25025 April 2022
NextEra Energy Duane Arnold Quality Assurance Topical Report (FPL-3) Revision 2
NG-22-0035, Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 02022-04-13013 April 2022
Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 0
NG-22-0047, Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2022-04-11011 April 2022
Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool
NG-22-0042, Registration of Independent Spent Fuel Installation Storage Casks2022-04-0808 April 2022
Registration of Independent Spent Fuel Installation Storage Casks
NG-22-0041, and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report2022-03-31031 March 2022
and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report
NG-22-0030, Registration of Independent Spent Fuel Installation Storage Casks2022-03-23023 March 2022
Registration of Independent Spent Fuel Installation Storage Casks
NG-22-0031, 2021 Annual Exposure Report - Form 5s2022-03-23023 March 2022
2021 Annual Exposure Report - Form 5s
ML22080A1822022-03-22022 March 2022
Letter to B. Coffey from M. Doell - Duane Arnold ISFSI QAPD RAI Letter
L-2022-012, Florida Power & Light Company Nuclear Property Insurance - 10 CFR 50.54(w)(3)2022-03-16016 March 2022
Florida Power & Light Company Nuclear Property Insurance - 10 CFR 50.54(w)(3)
ML22059A7462022-03-10010 March 2022
ISFSI-Only Physical Security Plan License Amendment Approval
NG-22-0025, Registration of Independent Spent Fuel Installation Storage Casks2022-03-0808 March 2022
Registration of Independent Spent Fuel Installation Storage Casks
IR 05000331/20220012022-03-0404 March 2022
Subject: NRC Inspection Report Nos. 05000331/2022001(DNMS) and 07200032/2022001(DNMS)
2024-09-04
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML24193A2432024-07-12012 July 2024
– Interim Audit Summary Report in Support of Review of License Amendment Requests Regarding Fleet Emergency Plan
ML22005A0862022-01-0404 January 2022
1-4-2022 Email Communication to Duane Arnold Regarding Its ISFSI Related Exemption Request on Supplemental Information Needed
ML21335A0712021-12-0101 December 2021
Request for Additional Information - Duane Arnold Energy Center ISFSI Only Emergency Plan
ML21335A0702021-12-0101 December 2021
Cover Letter to B. Coffey from K. Conway - Duane Arnold Energy Center RAI Re License Amendment Request for ISFSI Only Emergency Plan
ML21250A3002021-09-0808 September 2021
Defueled Physical Security Plan RAI Cover Letter
ML21006A4052021-01-0606 January 2021
NRR E-mail Capture - Final RAI - Duane Arnold - Post-Shutdown Decommissioning Activities Report
ML20316A0212020-11-10010 November 2020
NRR E-mail Capture - Final RAI - Duane Arnold - Duane Arnold Amendment for Proposed Defueled EP and EAL Scheme
ML20153A3772020-05-28028 May 2020
NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center Quality Assurance Topical Report (FPL-3) - EPID L-2020-LLQ-0002)
ML20141L8132020-05-19019 May 2020
NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center (DAEC) - Exemption Request for Security Training Requirements Due to COVID-19 Pandemic - EPID L-2020-LLE-0042 to 45, L-2020-LLE-0051
ML20133K0482020-05-14014 May 2020
Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection
ML20127H8662020-05-0505 May 2020
NRR E-mail Capture - Duane Arnold Energy Center (DAEC) - Request for Additional Information (RAI) - Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 1O CFR 50.75(h)(1)(iv) - EPID L-2020-LLE-0011
ML19280A0352019-10-0404 October 2019
NRR E-mail Capture - Final - RAI Related to License Amendment Request (TSCR-182) for Proposed Changes to the Emergency Plan for Permanently Defueled Conditions at Duane Arnold Energy Center (DAEC) - L-2019-LLA-0075
ML18283B0522018-10-0909 October 2018
NRR E-mail Capture - Final Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420
ML18255A2922018-09-11011 September 2018
NRR E-mail Capture - Draft Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420
ML18247A2002018-08-21021 August 2018
E-Mailed Request for Information for Duane Arnold, Dated 08/21/18 (DRS-M.Holmberg)
ML18166A2982018-06-15015 June 2018
NRR E-mail Capture - Draft Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420
ML18088A0102018-03-28028 March 2018
NRR E-mail Capture - Final RAI for Duane Arnold (DAEC) 5th-10 Year ISI (RR-05)
ML18058A0522018-02-27027 February 2018
Enclosurequest for Additional Information (Letter: RAI Regarding Florida Power and Light/Nextera Decommissioning Funding Plan Updates for St. Lucie, Units 1 & 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach, Units 1 and 2)
ML18037B0032018-02-0606 February 2018
NRR E-mail Capture - Draft Request for Additional Information - Duane Arnold Energy Center (DAEC) - License Amendment Request (TSCR-170), Revision to Technical Specification 3.5.1, ECCS-Operating - EPID L-2017-LLA-0288
ML17347A8752017-12-12012 December 2017
NRR E-mail Capture - Second Round of Request for Additional Information - Duane Arnold Energy Center (DAEC) - LAR to Adopt TST-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829
ML17277A3652017-10-0404 October 2017
NRR E-mail Capture - Final Request for Additional Information - Duane Arnold - Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829
ML17240A0082017-08-25025 August 2017
NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center (DAEC) - Fifth Ten Year Service Inspection Interval - Relief Request No. RR-04, Rev. 0 - Proposed Alternative for Seal Weld Procedure Qualification - MF937
ML17220A3332017-08-0808 August 2017
NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center - Relief Request No. RR-03 - Alternative Requirements for Nozzle Inner Radius and Nozzle-To-Shell Welds - CAC No. MF9374
ML17159A7962017-06-0707 June 2017
17 Duane Arnold Energy Center - Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection (Mxg)
ML17068A0632017-03-0808 March 2017
NRR E-mail Capture - Final - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - Revision to Staff Augmentation Times in the Duane Arnold Energy Center (DAEC) Emergency Plan (Eplan) - MF8390
ML16333A4622016-11-28028 November 2016
NRR E-mail Capture - Final Request for Additional Information - Duane Arnold Energy Center - LAR - SFP Criticality - MF7486
ML16326A0092016-11-18018 November 2016
NRR E-mail Capture - Request for Additional Information Re. Nextera/Fpl LAR to Adopt TSTF-545 - CACs MF8203, MF8204, MF8208, and MF8209
ML16313A0742016-11-0808 November 2016
NextEra Audit Plan Nov 2016 (DAEC SFP Criticality LAR)
ML16075A0032016-03-14014 March 2016
NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center - LAR to Reduce the Reactor Steam Dome Pressure Specified in the Technical Specifications 2.1.1, Reactor Core Safety Limits - MF6618
ML16074A3142016-03-14014 March 2016
NRR E-mail Capture - Second Round RAIs - Duane Arnold Energy Center - LAR (TSCR-143) to Extend Containment Leakage Test Frequency - MF6619
ML16022A0092016-01-21021 January 2016
NRR E-mail Capture - Request for Additional Information - LAR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617
ML16021A0122016-01-21021 January 2016
Request for Additional Information by the Containment & Ventilation Branch and PRA Licensing Branch License Amendment Request - Extension of the 10 CFR 50 Appendix J Containment Type a & Type C Test Intervals
ML16014A6962016-01-0707 January 2016
E-Mail: Duane Arnold, MOD/50.59 Inspection Request for Information (Jsp)
ML16005A6082015-12-24024 December 2015
E-Mail: Duane Arnold Request for Information; December 24, 2015 (AAS)
ML15175A0652015-06-23023 June 2015
Ltr. 06/23/15 Duane Arnold Energy Center - Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000331/2015003 (Axd)
ML14057A7562014-02-25025 February 2014
14 Duane Arnold CDBI Request for Information
ML14031A1462014-01-29029 January 2014
Update to NextEra Energy Duane Arnold, Llc'S Response to NRC Request for Additional Information Associated with Near-Term Task Force Recommendations
ML13323B4432013-11-26026 November 2013
Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
ML13255A1982013-09-16016 September 2013
Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML13175A3932013-06-27027 June 2013
Request for Additional Information for Review Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805
ML13154A5112013-06-0404 June 2013
Rai'S Following Ifib Analysis of NextEra Energy'S 2013 Decommissioning Funding Status Reports for Duane Arnold Energy Center and Point Beach Units 1 and 2
ML12107A0592012-04-11011 April 2012
NRR E-mail Capture - ME7246 - DAEC - Request for Additional Information (RAI) Relief Requests NDR-R003, R010, R011, R014, R015
ML12056A0502012-03-12012 March 2012
Enclosure 4 - Recommendation 2.3: Flooding
ML12056A0482012-03-12012 March 2012
Enclosure 2 - Recommendation 2.1: Flooding
ML12056A0472012-03-12012 March 2012
Enclosure 1 - Recommendation 2.1: Seismic
ML12056A0492012-03-12012 March 2012
Enclosure 3 - Recommendation 2.3: Seismic
ML12056A0512012-03-12012 March 2012
Enclosure 5 - Recommendation 9.3: Emergency Preparedness
ML1201203182012-01-17017 January 2012
Request for Additional Information Amendment to Change Emergency Action Levels
ML12011A0602012-01-0404 January 2012
NRR E-mail Capture - ME6508 - DAEC - Emergency Action Level (EAL) Changes
ML1132105812011-11-28028 November 2011
Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, Mitigating Strategies.
2024-07-12
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2013 Mr. Richard L. Anderson, Site Vice President NextEra Energy Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785
SUBJECT:
DUANE ARNOLD ENERGY CENTER- REQUEST FQR ADDITIONAL INFORMATION FOR REVIEW REGARDING LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (TAC NO. ME6818)
Dear Mr. Anderson:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11221A280),
NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request.
The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC), from Title 10 of the Code of Federal Regulations (1 0 CFR),
Section 50.48(b) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805).
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on June 11, 2013, it was.agreed that you would submit an updated AttachmentS, Table S-2, Implementation Items, and that you would provide a response to this request for additional information by July 3, 2013.
During a discussion with your staff on June 18, 2013, it was further agreed that you would add two implementation items to Table S-2. These items include (1) changing the heat release rate assigned to transient fires to comply with an NRC-accepted method 1 , and (2) discontinuing the use of the reduction in the likelihood estimates for circuits containing a control power transformer (CPT) compared to circuits without a .CPT that is described in Task 10 in NUREG/CR 68502 , "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, 1 1 The two currently acceptable methods include 1) the use of 98 h percentile 317'rWV HRR as described in Table E-1 NUREG/CR 6850, "EPRIINRC-RES Fire PRA Methodology for Nuclear Power Facilities, April 2005," and 2) use of a different value supported by justification as endorsed by the NRC in its letter to NEI dated June 21, 2012 ori "Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993, 'Evaluation of Peak Heat Release Rates in Electrical Cabinet Fires."'
2 The values in Tables 10-1 and 10-3 of NUREG/CR 6850 include a factor of 2 reduction compared to the same parameter values in Tables 10-2 and 10-4. Recent experiments have indicated that this factor of 2 cannot be demonstrated and Tables 10-2 and 10-4 should be used until new Tables have been developed and found acceptable by the NRC.
R. Anderson April 2005." An example of these types of implementation items can be found in Table 2.9-1, Item 41 of the Safety Evaluation issued to Oconee Nuclear Station Units 1, 2, and 3, regarding transition to risk-informed, performance based fire protection program in accordance with 10 CFR 50.48(c) dated December 29, 2010 (ADAMS Accession No. ML103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade.
The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff ~eview and contribute toward the NRC's goal of efficient and effective use of staff resources.
Please contact Carolyn Faria at (301) 415-4050, if you have any questions.
Sincerely, Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosures:
Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ
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 DUANE ARNOLD ENERGY CENTER NEXTERA ENERGY DOCKET NO. 50-331 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System\ADAMS) Accession No. ML11221A280},
NextEra Energy Duane Arnold, LLC (the licensee) submitted a license amendment request (LAR). The licensee requested to transition their fire protection licensing basis at the Duane Arnold Energy Center (DAEC}, from Title 10 of the Code of Federal Regulations (1 0 CFR},
Section 50.48(b) to 10 CFR 50.48(c}, National Fire Protection Association Standard 805 (NFPA 805). To complete its revieW, the NRC staff requests additional information as discussed below.
- 1. The table enclosed summarizes modifications made to the probabilistic risk assessment (PRA) in response to several previous requests for additional information (RAI) issued during the review of the LAR to transition to NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition.
Address the individual modifications as expressed in PRA RAI84 Table 1 to confirm the completion of each.
- 2. In licensee's letter dated February 12, 2013 (ADAMS Accession No. ML13046A031}, in response to RAI 58.01, DAEC states that a full update of the NFPA 805 fire PRA application will be performed prior to transition.
Propose a response that includes a regulatory process (e.g., a general license condition or implementation item) that provides assurance that all the proposed changes including those listed in PRA RAI84 Table 1 will be made and all associated documentation will be finalized before the PRA is used to support future self-approval.
- 3. An integrated analysis is provided in Table 5 of the response to RAI 82 dated May 1, 2013, (ADAMS Accession No. ML13122A045). The results include fire scenarios for the main control room (MCR).
Please provide the MCR abandonment fire scenarios total core damage frequency and large early release probability (CDF/LERF) and delta CDF/LERF from this analysis. If there is a difference between the total and delta risk for these fire scenarios, explain the
R. Anderson reason for the difference and provide justification for not including the entire MCR abandonment risk in the calculation of delta risk.
Discuss how the delta risk is calculated for the MCR abandonment scenarios for the different conditional core damage probabilities (CCDPs), which are discussed in the response to RAI 64 (ADAMS Accession No. ML13015A350), and how the MCR abandonment recovery actions are included in the delta risk calculation for each CCDP. For example, it is not clear from the response to RAI 64 how the failure to recover probability and the 0.1 probability of failure of success path equipment are used in the compliant case versus .the variant case. Please include additional description of how the compliant versus variant CDF/LERF are estimated for the same scenario.
PRA RAI84 Table 1 RAI Description of Modification and Request for Additional Information FM 01 In the licensee's letter dated October 15, 2013 (ADAMS Accession No. ML122910950), DAEC states that: The DAEC Fire PRA- NFPA 805 RAJ Model Update Quantification Report has been updated to include the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets. This change will be incorporated in the updated FPRA model in response to RAI-01.
Please confirm that the PRA includes the new self-ignited fire scenarios and the change in input for fire scenarios with thermoplastic cable targets, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See Jetter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA05 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised multi-compartment analysis (MCA) in which barrier elements were summed. The revised MCA is included in the composite analysis. DAEC also stated that they would revise Appendix C of the Fire Scenario Report to include barrier elements as discussed in RAJ PRA-5.
Confirm that the PRA includes a revised MCA in which barrier elements were summed, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA07 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised analysis without using a severity factor of 0.01 for the diesel generator rooms. The revised analysis is included in the composite analysis. DAEC also stated that they would update Appendix C of the Fire Scenario Report to reflect changes in MCA scenarios as discussed in RAJ PRA-7.
Confirm that the PRA no longer uses a severity factor of 0.01 for the diesel generator rooms, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
Enclosure 2
RAI Description of Modification and Request for Additional Information PRA 08.01 By letter dated March 6, 2013, (ADAMS Accession No. ML13070A065),
DAEC included a revised MCA to include NUREG/CR-6850 Step 5.c (Section 11.5.4.5) while determining whether combinations of MCA should be screened out. The letter also stated that the revised analysis is included in the composite analysis (ADAMS Accession No. ML13122A045), Table 4-3 of the License Amendment Request (ADAMS Accession No. ML11221A280) and will be updated to include the automatic suppression system required for risk.
Confirm that the PRA screens combinations of MCAs based on NUREG/CR-6850, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA10 By letter dated April23, 2012, (ADAMS Accession No. ML12117A052),
DAEC responded that during transition to NFPA 805, the monitoring program will be enhanced to satisfy new requirements.
Please confirm that the monitoring program will be enhanced to satisfy new requirements and, to the extent applicable, these new requirements will be reflected in the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA 11.01 By letter dated March 6, 2013, (ADAMS Accession No. ML13070A065),
DAEC included a revised analysis without manual suppression credit. The letter also stated that the revised analysis is included in the composite analysis. (See letter dated April 23, 2012, ADAMS Accession No. ML12117A052 and ML13122A045).
Confirm that the PRA does not include manual suppression credit and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ).
PRA13 By letter dated April 23, 2012 (ADAMS Accession No. ML12117A052),
DAEC stated that they would revise Section 2 and Table 2.2-2 of the Plant Partitioning and Fire Ignition Frequency report to reflect the expanded justification provided in response to RAI PRA-13.
Please confirm that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
RAI Description of Modification and Request for Additional Information PRA 14a Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised cable spreading room (CSR) analysis that removed a hot work pre-initiator factor of 0.01. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA no longer includes a hot work pre-initiator factor of 0.01, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ).
PRA 14b Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised CSR analysis with the use of a "Very Low" ranking consistent with Frequently Asked Question (FAQ) 12-0064, Hot Work/Transient Fire Frequency Influence Factors (ADAMS Accession No. ML12346A488). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA's CSR analysis uses the "Very Low" ranking consistent with FAQ 12-0064, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ).
PRA 14.01 Licensee's letter dated May 23, 2012 (ADAMS Accession No. ML12146A094), included a revised CSR analysis that: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes alternate shutdown capability (ASC) is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies large early release frequency (LERF). In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA: (1) assumes at least a plant trip for CSR fires; (2) identifies the contribution from the loss of offsite power; (3) assumes ASC is not available; (4) does not credit prompt suppression for general transient fires; and (5) quantifies LERF, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
RAI Description of Modification and Request for Additional Information PRA16 By letter dated April23, 2012 (ADAMS Accession No. ML12117A052),
DAEC stated that Table 3.3-1 of the Fire Model Development Report, the human reliability analysis (HRA) and the basic event probability will be updated to reflect the lack of a cue and that the operator action is not credited in the FPRA. In addition, DAEC stated that the basic event probability will be applied in the updated FPRA model in response to RAI PRA 01.
Confirm that the HRA in the PRA and any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA33 By letter dated April 23, 2012 (ADAMS Accession No. ML12117A052),
DAEC stated that they would revise Section 6 of the Fire Model Development Report to include the details regarding the evaluation of long term operator actions on LERF provided in response to RAI PRA-33.
Confirm that the missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA 35.01 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML13070A065), included justification for incipient detection credit and the results of a sensitivity study without incipient detection credit. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that no credit for incipient detection is included in the composite analysis.
Confirm that the PRA includes no credit for incipient detection and that conforming changes will be completed for all documentation during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA57 Licensee's letter dated April 23, 2012 (ADAMS Accession No. ML12117A052), included a response to RAI 57 that included a table that listed each PRA level 2 basic event and identified the potential fire impact for each event. The letter also stated that DAEC would revise the Fire Model Development Report to include the table provided in response to RAI PRA-57.
Confirm the documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 under cover letter dated February 12, 2013 (ADAMS Accession No. ML13046A031).
RAI Description of Modification and Request for Additional Information PRA69 In a letter dated March 6, 2013, (ADAMS Accession No. ML13070A065), it was stated by DAEC that the FPRA adequately evaluates electronics in the MCR as described in NUREG/CR-6850. In a letter dated May 1, 2013 (ADAMS Accession No. ML13122A045), in response to a follow-on question related to RAI 69 in RAI 82, a summary was provided related to an evaluation of electronics outside of the MCR that included walkdowns and use of NUREG/CR-6850 damage temperatures.
Confirm that: (1) the PRA includes the results of evaluation inside and outside of the MCR that are consistent with the methods as described in NUREG/CR-6850, and (2) that documentation will incorporate the relevant discussion during the full update of the NFPA 805 fire PRA application, as stated in response'to RAI 58.01 under cover letter dated February 12, 2013.
PRA70 Licensee's letter dated February 12, 2013 (ADAMS Aqcession No.
ML13046A031 ), identified that the credit given to sealed electrical cabinets to prevent fire spread was consistent with the treatment in FAQ 08-0042, Fire Propagation From Electrical Cabinets, (ADAMS Accession No.
' ML092110537).
Confirm that the PRA evaluates sealed cabinets according to FAQ 08-0042, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
PRA 71 RAI 71 questioned the use of a conditional probability of 0.1 for transient combustibles located near the MCR, and the response to RAI 82 indicated that this probability had been removed. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA no longer includes the conditional probability, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031 ).
PRA72 Licensee's letter dated March 6, 2013 (ADAMS Accession No. ML13070A065), included a revised analysis that used a minimum non-suppression probability of 0.001. In the response to RAI 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA uses a minimum non-suppression probability of 0.001, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAI 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
RAI Description of Modification and Request for Additional Information PRA 83b In response to the RAJ 83b dated May 1, 2013 (ADAMS Accession No.
' ML13122A045), it was clarified by DAEC that the heat release rate (HRR) used in the updated CSR analysis was based on NUREG/CR-6850 guidance. In the response to RAJ 82 dated May 1, 2013 (ADAMS Accession No. ML13122A045), it was stated that the revised analysis is included in the composite analysis.
Confirm that the PRA uses an updated CSR analysis using a HRR based on NUREG/CR-6850 guidance and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031).
LAR TableV- The disposition of these Facts and Observations (F&Os) is that fire scenario 3 F&O 1OE-F45 sensitivity case refined the use of the electric panel factor approach 4-22, 4-23, 4- to use of the Hughes Generic Fire Modeling results for critical separation 25 distances based on HRR.
dispositions Confirm that the PRA. uses the Hughes Generic Fire Modeling results for critical separation distances based on HRR, and that any missing documentation will be completed during the full update of the NFPA 805 fire PRA application, as stated in response to RAJ 58.01 (See letter dated February 12, 2013, ADAMS Accession No. ML13046A031). Also confirm that the electric panel factor approach had not been used in the results reported for RAJ 82.
RAI64 A detailed HRA was performed as a basis for justifying that the MCR conditional core damage probability of 0.1 is bounding. This HRA is related to a recovery action in the LAR to start the emergency diesel generator SBDG1 to power the vital bus for ASC. The HRA evaluation was provided in response to RAJ 64 in a letter dated. January 11, 2013 (ADAMS Accession No. ML13015A350).
Confirm that the inputs to the detailed HRA have been evaluated in both the LAR Attachment G, Step 4, "Evaluate the Feasibility of Recovery Actions,"
and Step 5;"Evaluate the Reliability of Recovery Actions".
ML103630612). This example includes direction to conduct a focused scope peer review and that all findings of this review be dispositioned if the modification made is an upgrade.
The NRC considers that timely responses to requests for additional information help ensure sufficient time is available for the NRC staff review and contribute toward the NRC's goal of efficient and effective use of staff resources.
Please contact Carolyn Farra at (301) 415-4050, if you have any questions.
Sincerely,
/RAJ Karl Feintuch, Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosures:
Request for Additional Information and PRA RAI 84 Table 1 cc w/encls: Distribution via ListServ DISTRIBUTION:
PUBLIC RidsNrrOd Resource RidsNrrDorl Resource RidsNrrDorllpl3-1 Resource RidsOeMaiiCenter Resource RidsNrrPMDuaneArnoldResource RidsNrrDraApla Resource KFeintuch, NRR ADAMS Accession No ..* ML13175A393 *concurrence via e-mail dated 6/11/13 OFFICE LPL3-1/PM LPL3-1/PM LPL3-1/LA NRR/APLA/BC . LPL3-1/BC LPL3-1/PM NAME CFaria KFeintuch SRohrer H.Hamzehee* RCarlson KFeintuch DATE 06/11/13 06/12/13 06/25113 06/11/13 06/27113 06/27/13
