ML13169A238

ME6818-DAEC- Adoption of NFPA 805- Request for Additional Information (RAI) Fpe 14

ML13169A238
Person / Time
Site:	Duane Arnold
Issue date:	06/14/2013
From:	Feintuch K D Division of Operating Reactor Licensing
To:	Swenzinski L NextEra Energy Duane Arnold
References
ME6818
Download: ML13169A238 (3)

Text

1 NRR-PMDAPEm Resource From:Feintuch, Karl Sent: Friday, June 14, 2013 5:21 PM To: Bob.Murrell@nexteraenergy.com; Swenzinski, Laura Cc: Faria-Ocasio, Carolyn

Subject:

ME6818-DAEC- Adoption of NFPA 805- Request fo r Additional Information (RAI) FPE 14 Follow Up Flag:

Follow up Due By: Monday, July 01, 2013 1:30 PM Flag Status:

FlaggedBy letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 5, 2011 (Agencywide Documents Access and Management System 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 (CFR), Section 50.48(b), to 10CFR50.48(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 below. A clarification call was held with your staff on June 10, 2013.

Attending the June 10, 2013 conference call were:

• For NRC - Leslie Fields, Alayna Pearson, Paul Lain, Harold Barrett, Bernard Litkett, Scott Wall, and Carolyn Faría

• For DAEC - Laura Swenzinski, William Cross, Jeff Kuehl, Roy Hanson, Thomas Carmody, and Mike Saunders (ERIN Eng)

Fire Protection Request for Additional Information (RAI) FPE 14 With regards to how DAEC complies with the requirements of NFPA 805 Section 3.11.5:

1. There appears to be discrepancies between LAR Attachment A, Table 4-3 and Attachment C with regard to Electrical Raceway Fire Barrier Systems (ERFBS) credited at DAEC. Attachment A, Element 3.11.5, Electrical Raceway Fire Barrier Systems (ERFBS) (page 138 of 138), states that DAEC complies with the requirement and states that "Limited amounts of Darmat KM1 are utilized for ERFBS at DAEC". This product was tested to meet Generic Letter 86-10 Supplement 1". No other ERFBS is discussed.

However , Table 4-3, NFPA 805 Ch 4 Required FP Systems/Features and Attachment C, NEI 04-02 Table B Fire Area Transition both discuss an additional 3-hour ERFBS.

• Table 4-3, Fire Area TB1, Turbine Building, Fire Zones ID 07C (page 64) and 07H (page 66) list "Concrete Chase - Separation Required to protect cables for RHR Service Water, River Water, ESW and Division 2 AC Power."

• Attachment C, Fire Area TB1 (page 154 of 165), under Performance Goal 4, Vital Auxiliaries - Mechanical, includes a Comment "Feeders and control power to portions of the Div 2 electrical distribution credit a 3 hr ERFBS."

2* Attachment C, Fire Area TB1 (page 154 of 165), under Performance Goal 4, Vital Auxiliaries - Electrical includes a Comment "Div 2 RHRSW pumps, Div 2 River Water pumps and Div 2 ESW pump credit a 3 hr ERFBS."

• Attachment C, Fire Area TB1 (page 163 of 165), Required Fire Protection Systems and Features table lists "Passive, Concrete Chase, Separati on, Required to protect cables for RHR Service Water, River Water, ESW and Division 2 AC Power." Any ERFBS credited to meet NFPA 805 separation requirements using either a deterministic approach under NFPA 805 Section 4.2.3 or a performance-based approach under NFPA 805 Section 4.2.4 must meet the ERFBS requirements of NFPA 805 Section 3.11.5.

Provide additional information regarding the compliance status of the "concrete chase" used as an ERFBS in the Turbine Building with regard to NFPA 805 Section 3.11.5. Discuss the testing performed on this ERFBS, including the test rating obtained.

2. Attachment A, Element 3.11.5, Electrical Raceway Fire Barrier Systems (ERFBS), states that DAEC complies with the requirement and states that "Limited amounts of Darmat KM1 are utilized for ERFBS at DAEC. This product was tested to meet Generic Letter 86-10 Supplement 1." There is no discussion regarding the results of the testing. NFPA 805 Section 3.11.5 states that "TheERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The fire barrier's ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill and type shall be demonstrated."

Provide a discussion on the results of the fire barrier testing performed in accordance with Generic Letter 86-10, Supplement 1 to meet NFPA 805 Section 3.11.5.

It was agreed that you would provide a response by July 3, 2013. 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 Faría at (301) 415-4050, if you have any questions.

Sincerely, Karl Feintuch

Project Manager USNRC Hearing Identifier: NRR_PMDA Email Number: 725 Mail Envelope Properties (26E42474DB238C408C94990815A02F09CAC511BA41)

Subject:

ME6818-DAEC- Adoption of NFPA 805- Request for Additional Information (RAI) FPE 14 Sent Date: 6/14/2013 5:21:10 PM Received Date: 6/14/2013 5:21:12 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients: "Faria-Ocasio, Carolyn" <Carolyn.Faria-Ocasio@nrc.gov> Tracking Status: None "Bob.Murrell@nexteraenergy.com" <Bob.Murrell@nexteraenergy.com> Tracking Status: None "Swenzinski, Laura" <Laura.Swenzinski@fpl.com> Tracking Status: None Post Office: HQCLSTR01.nrc.gov

Files Size Date & Time MESSAGE 4894 6/14/2013 5:21:12 PM

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: Follow up By 7/1/2013 1:30:00 PM