Text

Revision 0a, Transition to 10 CFR 50.48(c) - NFPA 805 Performance- Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
	ML080160258
Person / Time
Site:	Harris
Issue date:	01/10/2008
From:	; Progress Energy Carolinas
To:	; Office of Nuclear Reactor Regulation
References
	HNP-07-178
	Download: ML080160258 (49)
	v • d • e

Progress Energy Shearon Harris Nuclear Power Plant Docket 50-400 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standardfor Fire Protection for Light Water ReactorElectric GeneratingPlants, 2001 Edition Transition Report Revision Oa May 31, 2008

Progress Energy HNP NFPA 805 Transition Report TABLE OF CONTENTS Executive Sum m ary .................................................................................................................. 4 1.0 INTRO DUCTIO N ............................................................................................................. 5 1.1 B a c kg ro u n d ............................................. ........................................................................................ 5 1.1.1 NFPA 805 - Requirements and Guidance ......................................................................... 5 1.1.2 HNP Transition to 10 CFR 50.48(c) .............................................................................. 5 1.2 P u rpo s e a n d Sc o p e .......................................................................................................................... 5 2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM ..................................... 5 2.1 Current Fire Protection Licensing Basis ........................................................................................... 5 2.2 Applicable Regulatory Requirements ............................................................................................... 5 2.3 Current Enforcement Discretion ................................................................................................. 5 3.0 TRANSITIO N PROCESS ............................................................................................ 5 3 .1 Ba c kg ro u n d ...................................................................................................................................... 5 3 .2 NF P A 8 0 5 P ro cess ........................................................................................................................... 5 3.3 NEI 04 NFPA 805 Transition Process ................................................................................. 5 3.4 NEI 04-02 Frequently Asked Questions (FAQs) .............................................................................. 5 4.0 DEMONSTRATIONS OF COMPLIANCE WITH NFPA 805 REQUIREMENTS ........... 5 4.1 Fundamental Fire Protection Program Elements and Minimum Design Requirements ............. 5 4.1.1 Overview of Evaluation Process ..................................................................................... 5 4.1.2 Results from Evaluation Process ................................................................................... 5 4.2 Nuclear Safety Performance Criteria Transition Review ............................................................ 5 4.2.1 Nuclear Safety Methodology Review ............................................................................ 5 4.2.2 Fire Area-by-Fire Area Transition ................................................................................... 5 4.3 Non-Power Operational Modes ................................................................................................... 5 4.3.1 Overview of Evaluation Process ................................................................................... 5 4.3.2 Results from Evaluation Process .................................................................................... 5 4.4 Radioactive Release Performance Criteria ................................................................................. 5 4.4.1 Overview of Evaluation Process ................................................................................... 5 4.4.2 Results from Evaluation Process ................................................................................... 5 4.5 Change Evaluations / Plant Modifications .................................................................................... 5 4.5.1 Fire PRA Development and Acceptance ............................................................................ 5 4.5.2 " Risk-Informed, Performance-Based Change Evaluation Process ...................................... 5 4.5.3 Risk-Informed, Performance-Based Change Evaluation Results ................................. 5 4.5.4 Plant Modifications ........................................................................................................ 5 4 .6 Mo n ito rin g P ro g ra m .......................................................................................................................... 5 Page ii - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report 4.6.1 Com pliance with Section 2.6 of NFPA 805 ................................................................... 5 4.7 Program Documentation, Configuration Control, and Quality Assurance ................................... 5 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 ............. 5 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 of NFPA 805 ....... 5 4.7.3 Compliance with Quality Assurance Requirements in Section 2.7.2 of NFPA 805 ..... 5 5.0 POST-TRANSITION FIRE PROTECTION LICENSING BASIS ................................... 5 5.1 HNP License A m endm ent R equest ................................................................................................. 5 5.2 HNP Post-T ransition UFSA R ..................................................................................................... 5 Appendix A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3) .............................................................................. 5 Appendix B - NEI 04-02 Table B Nuclear Safety Capability Assessment -

Methodology Review ..................................................................................................... 5 Appendix C - NEI 04-02 Table B Fire Area Transition .................................................. 5 Appendix D - NEI 04-02 Table F-1 Non-Power Operational Modes Transition ................. 5 Appendix E - NEI 04-02 Table G Radioactive Release Transition .............................. 5 Appendix G - Fire-Induced Multiple Spurious Operations - Resolution Methodology ....... 5 Appendix H - Operator Manual Actions - Transition to Recovery Actions ..................... 5 Appendix I - NEI 04-02 Frequently Asked Question - Summary Table ............................. 5 Appendix J - Definition of Power Block ............................................................................. 5 Page iii - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Executive Summary

[To be completedlater]

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Progress Energy HNP NFPA 805 Transition Report

1.0 INTRODUCTION

The Nuclear Regulatory Commission (NRC) has adopted a voluntary alternative rule for fire protection requirements at nuclear power plants, 10 CFR 50.48(c). Progress Energy has implemented the process for transitioning from its current fire protection licensing basis for the Shearon Harris Nuclear Power Plant (HNP) to compliance with the new requirements. This document describes the transition process that applied by Progress Energy for HNP and the results that demonstrate compliance with the new voluntary requirements.

[Note: A sample Transition Report outline is included in NEI 04-02, Revision 1, Appendix H.

This report used this sample as an initial guide. However, lessons learned from the Pilot Plant transition experience were used to improve the Transition Report content.]

1.1 Background 1.1.1 NFPA 805 - Requirements and Guidance On July 16, 2004 the Nuclear Regulatory Commission amended 10 CFR Part 50.48, Fire Protection,to add a new subsection, 10 CFR 50.48(c), that established acceptable fire protection requirements. The change to 10 CFR 50.48 endorses, with exceptions, the National Fire Protection Association's 805, Performance-BasedStandardfor Fire Protectionfor Light Water ReactorElectric GeneratingPlants- 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b) and Section (f).

As stated in 10 CFR 50.48 (c)(3)(i), any licensee's adoption of a risk-informed, performance-based program that complies with the rule is voluntary. Compliance with this rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48 (b), for plant licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48 (f), plants shutdown in accordance with 10 CFR 50.82(a)(1).

The Nuclear Energy Institute (NEI) developed NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-BasedFire Protection Programunder 10 CFR 50.48(c), to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805. The Nuclear Regulatory Commission (NRC) issued a Regulatory Guide 1.205, Risk-Informed, Performance-BasedFire Protection for Existing Light-Water Nuclear Power Plants, which endorses NEI 04-02, in May 2006.

A depiction of the primary document relationships is shown below:

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Progress ,Energy HNP NFPA 805 Transition Report 10 CFR Incorporation by Reference 50.48(c)

E National Fire Protection Association Standard NFPA 805.

(D JIL JiLL___

NEI 04-02 RG 1.205 I., Endorsement GUIDANCE FOR RI-PB FP FOR EXISTING IMPLEMENTING A RI-PB LIGHT-WATER NUCLEAR FP PROGRAM UNDER 10 POWER PLANTS CFR 50.48(c)

Rev. 1 Mey20OD N

Figure ?? NFPA 805 Transition - Implementation Requirements / Guidance 1.1.2 HNP Transition to 10 CFR 50.48(c) 1.1.2.1 Start of Transition HNP determined to transition its fire protection licensing basis to the performance-based alternative in 10 CFR 50.48(c). A letter of intent was submitted by Progress Energy to the NRC on June 10, 2005 (ADAMS Accession No. ML051720404) for HNP to adopt NFPA 805 in accordance with 10 CFR 50.48(c). This letter of intent also addressed other Progress Energy plants (Brunswick Steam Electric Plant, H.B. Robinson Steam Electric Plant, and Crystal River Unit 3 Nuclear Generating Plant). The letter of intent requested three years of enforcement discretion and proposed that HNP be considered a pilot plant for the NFPA 805 transition process.

The NRC responded to Progress Energy on September 19, 2005 (ADAMS Accession No. ML052140391). In the response, the NRC agreed that HNP should be an NFPA 805 Transition Pilot Plant. The NRC also sent a letter to Progress Energy on April 29, 2007, granting a third year of enforcement discretion (ADAMS Accession No. ML070590625).

1.1.2.2 NFPA 805 Pilot Plant Summary The HNP NPFA 805 transition underwent a series of reviews and observation meetings as part of the Transition Pilot Plant process, with the following goals:

" Increase communication between the NRC and transitioning licensees

Develop transition lesson learned reports from observation visits

" Improve the NFPA 805 Regulatory Guide and Inspection Procedures

" Gain insights on the Enforcement Discretion Policy Page 6 - HNP Transition Report - rev d.doc

Progress Energy EHNP NFPA 805 Transition Report 0 Develop License Amendment Request and Safety Evaluation Report templates A summary of the major Pilot Plant activity is shown below:

Item Date . Location Summary 1 11/7/05-11/11/05 Charlotte, NC Pilot Observation Meeting

[ML060250033, ML060250034]

2 3/27/06-3/30/06 Raleigh, NC Pilot Observation Meeting

[ML061500468, ML061520285]

3 10/16/06-10/19/06 Seneca, SC (Oconee) Pilot Observation Meeting

[ML070280007, ML070320285]

4 11/6/06-11/8/06 Raleigh, NC Pilot Observation Meeting

[ML063330521, ML070820251, ML063310386, ML071210207, ML071060267]

5 3/6/07-3/8/07 Raleigh, NC Pilot Observation Meeting / Public Meeting

[ML070950030, ML070960489, ML071160447]

6 5/30/07-6/1/07 Raleigh/Apex, NC Pilot Observation Meeting / Public Meeting

[ML071930362, ML071930339]

7 7/10/07-7/13/07 Seneca, SC (Oconee) Pilot Observation Meeting / Public Meeting

[ML072270014, ML072610448, ML072610455, ML072140380]

8 8/6/07-8/9/07 Bethesda, MD Pilot Observation Meeting /Public Meeting

[MLX XXXX]

9 11/5/07-11/8/07 Atlanta, GA Pilot Observation Meeting / Public Meeting

[MLXXXXX-XXXX]

tBD tlbD tpB TBD

1.2 Purpose and Scope

The purposes of the HNP Transition Report:

(1) Describe the process implemented by Progress Energy to transition the HNP fire protection program to demonstrate compliance with the requirements in 10 CFR 50.48(c);

(2) Summarize the results of HNP's transition process; (3) Explain the bases for Progress Energy's conclusions that the HNP fire protection program, with certain modifications, comply with those requirements; and (4) To describe the new HNP fire protection licensing basis.

2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1 Current Fire Protection Licensing Basis Progress Energy Harris Nuclear Plant's license condition 2.F states:

"F.Fire Protection Program(Section 9.5.1)

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Progress Energy HNP NFPA 805 Transition Report Carolina Power & Light Company shall implement and maintainin effect all provisions of the approved fire protection program as describedin the Final Safety Analysis Report for the facility as amended and as approved in the Safety Evaluation Report (SER) dated November 1983 (and supplements 1 through 4), and the Safety Evaluation dated January 12, 1987, subject to the following provision below. The licensees may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."

2.2 Applicable Regulatory Requirements The following encompass the pre-transition HNP fire protection program licensing basis:

[provide sunmmary of HNP fire protection nsing basis]

e*i 2.3 Current Enforcement Discretion Federal Register Notice, 71 FR 19905, issued on April 18, 2006, extended enforcement discretion for issues identified during transition from 2 years to 3 years. In 71 FR 19905, the NRC provided the following:

"...Forthose noncompliances identified during the licensee's transitionprocess, this enforcement discretion policy will be in effect for up to 3 years from the date specified by the licensee in their letter of intent to adopt the requirementsin 10 CFR 50.4 8(c), and will continue to be in place, without interruption,until NRC approval of the license amendment request to transition to 10 CFR 50.48(c). This enforcement discretionpolicy may be extended on a case-by-case basis, by request, with adequatejustification, from the licensee....

The NRC also sent a letter to Progress Energy on April 29, 2007, granting a third year of enforcement discretion (ADAMS Accession No. ML070590625). The expiration date of the enforcement discretion per the April 29, 2007 was June 10, 2008.

Based on the above, enforcement discretion will extended until approval of the HNP 10 CFR 50.48(c) License Amendment.

[Inserst*summary4of additional enforcement request related to comple.tion of plant modlifilcations]

3.0 TRANSITION PROCESS 3.1 Background The process for transitioning from compliance with the current fire protection licensing basis to the new requirements is described in general in Section 4.0 of NEI 04-02. It contains the following steps: (1) licensee determination to transition the licensing basis and devote the necessary resources to it; (2) Letter of Intent to the NRC stating the licensee's intention to transition the licensing basis in accordance with a tentative schedule; (3) licensee conduct of the transition process to determine the extent to which the current fire protection licensing basis supports compliance with the new requirements and the extent to which additional analyses, plant and program changes, and alternative methods and analytical approaches are needed; (4)

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Progress Energy HNP NFPA 805 Transition Report filing of License Amendment Request (LAR); and (5) completion of transition activities and adoption of the new licensing basis consistent with the NRC's grant of the license amendment.

3.2 NFPA 805 Process Section 2.2 of NFPA 805 establishes the general process for demonstrating compliance with NFPA 805. The process is illustrated in Figure 2.2 of NFPA 805 (with cross-references to the applicable sections of NFPA 805 Section 2.2).. It shows that except for the fundamental fire protection requirements, compliance can be achieved on a fire area basis either by deterministic or performance-based methods. (The NRC permits licensees to use performance-based methods to comply with the fundamental fire protection requirements but those applications must be approved through the NRC's license amendment process, as discussed above.) HNP implemented this process by first determining the extent to which its current fire protection program supported findings of deterministic compliance with the requirements in NFPA 805.

Risk-informed, performance-based methods were then applied to the requirements for which deterministic compliance could not be shown.

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Progress Energy HNP NFPA 805 Transition Report Establish fundamental fire NFPA 805 Section 22(a) protection elements (Chapter 3)

Identify fire hazards NFPA 805 Section 2.2(b)

Nuclear safety Identify performance criteria to be Life safety NFPA 805 Section 22(c) examined Property damageibusiness Evaluate compliance to (Chapter 1) Interruption performance criteria Identify structures, systems, or components (SSCs) in each fire filFPA 805 Section 2.2(d) area to which the performance criteria applies

, ~~NFPA 806 Section 1ý.)o l Deterministic Approach Performance-BasedApproach Maintain compliance with existing plant Evaluate ability to satisfy performance license basis (10 CFR 50 App. R, Approved requirements Exemptions, Engineering Evaluations) (Chapter 4)

DeterministicBasis Existing Performance Basis Engineering Define fire scenarios ano fire design basis Equivalency for each fire area being considered.

Verity deterministic requirements are met Evaluations Evaluate using, e.g.,

Fire modeling to quantify the fire risk NFPA 805 Section 2.2(t) and margin of safety PSA to examine impact on overall plant risk NFPA 805 Section 2.2(g) 4.

Risk-informed Change Evaluation NFPA 808 Section 2,21(h)

Evaluate risk impact of changes to the approved design basis Yes Design Basis Documents L

Docuenttionandconigurtio *Fire hazards analysis NFPA 805 Section 2.2{j) Documentation and configuration Nuclear safety capability assessment coto Supporting engineering calculations Probabilistic safety analysis Risk-informed change evaluations Establish monitoring program tNPPA 805 Section 2.2(i)

Figure ?? NFPA 805 Process [NEI 04-02 Figure 3-1]

3.3 NEI 04-02 - NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a risk-informed, performance-based fire protection program. NEI 04-02 was developed to provide guidance on the overall process (programmatic, technical, and licensing) of the transition from a traditional fire protection licensing basis to a new one based upon NFPA 805, as shown below in Figure 3-2.

Page 10 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Regulatory Simplified Process Documentation Preliminary Assessment

{Section 4.2}

11 Reviews and Engineering Analyses

{Section 4.3} Letter of Intent

" Fundamental FP Program & Minimum Design Elements

Nuclear Safety Performance Criteria

" Non-Power Operational Modes

" Radioactive Release

'II Change Evaluations

{Section 4.4)

° I oNRC including Defense-in-Depth and Safety Margins License Amendment Request Program Documentation and Maintenance Transition Report

{Section 4.5)

" Program Documentation

" Quality Assurance Configuration Control Monitoring License Amendmer Figure ?? Implementing the New Licensing Basis [NEI 04-02 Figure 3-3]

Section 4.0 of NEI 04-02 describes the detailed process for assessing a fire protection program for the extent to which it supports a showing of compliance with NFPA 805, as shown below in Figure 3-3. HNP conducted the detailed evaluation processes by establishing teams comprised of knowledgeable plant personnel. The assessment processes used by these teams and the results of the assessments are discussed in detail below.

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Progress Energy HNP NFPA 805 Transition Report Proqress Energy HNP NFPA 805 Transition Report Transition Report Transition Report Sect. 4.1 Sect. 4.2 Engineering Analyses

} Transition Report Sect. 4.5 v

Figure?? Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]

3.4 NEI 04-02 Frequently Asked Questions (FAQs)

The NRC staff is worked with two pilot plants (HNP and Oconee Nuclear Station) to refine the infrastructure that facilitated the transition to the new licensing basis. Both the NRC staff and the industry recognized the need for additional clarifications and guidance beyond that provided in Regulatory Guide 1.205 and NEI 04-02, Revision 1. In a letter to the NRC, the NEI requested that the NRC staff establish a process that provides timely clarifications of additional staff positions usually communicated via RG 1.205 and NEI 04-02. The NRC staff accepted an NEI proposal on a proposed process, with several modifications, as described in a July 12, 2006, letter to NEI (ADAMS Accession No. ML061660105). This process was named the NFPA 805 Frequently Asked Question (FAQ) Process. The process was intended to as a structured avenue to seek NRC staff interpretations and clarifications of NEI 04-02 guidance and NFPA 805 requirements, in accordance with 10 CFR 50.48(c), in a timely manner.

Page 12 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Under the FAQ Process, transition issues (referred to as FAQs) requiring additional clarifications were submitted, in accordance with the above proscribed process, to the NEI NFPA 805 Task Force for review, and subsequently presented to the NRC during public FAQ meetings. The process continued with written comments from the NRC, when appropriate, and formal revisions of the FAQs. Once an acceptable FAQ is submitted to the NRC, the NRC staff issued a publicly available memorandum to file which indicated that the revised FAQ is acceptable guidance for transitioning to NFPA 805, and should be incorporated into NEI 04-02.

These closure memos are preliminary extensions of the implementation guidance in NEI 04-02.

Final official closure of the FAQs occurs when an updated Regulatory Guide 1.205, endorsing the revised NEI 04-02, is approved by the NRC.

The FAQs in Table [????.] in Appendix I were used as guidance as part of the HNP transition to NFPA 805.

4.0 DEMONSTRATIONS OF COMPLIANCE WITH NFPA 805 REQUIREMENTS 4.1 Fundamental Fire Protection Program Elements and Minimum Design Requirements The Fundamental Fire Protection Program and Design Elements are established in Chapter 3 of NFPA 805. Section 4.3.1 of NEI 04-02 (Implementing Guide) sets out a systematic process for determining the extent to which the current licensing basis meets these criteria and for identifying the fire protection program changes that would be necessary for complete compliance. Appendix B-1 of the Implementing Guide provides a worksheet tool to document the comparison of the Fire Protection Program Fundamentals of Chapter 3 to NFPA 805 to the appropriate NRC Guidance Documents (BTP9.5-1, NUREG 0800, etc.). The completed worksheet is included as Appendix A to the Transition Report. The results of the transition review are summarized below.

4.1.1 Overview of Evaluation Process The comparison of the HNP Fire Protection Program to NFPA 805 Chapter 3 (NEI 04-02 Table B-i) was performed using the methodology contained in Progress Energy Fire Protection Initiatives Project (FPIP) Project Instruction FPIP-0120, NFPA 805 Chapter 3 Fundamental Transition, and the guidance contained in FAQ 07-0036, Incorporation of Pilot Plant Lessons Learned - Table B-1. The methodology steps, depicted in [Figure ???1i are outlined below.

" Step 1 - Assemble documentation.

" Step 2 - Determine level of compliance. Review each section and subsection of NFPA 805 Chapter 3 against the current fire protection program. Provide specific compliance statements as follows:

o Complies o Complies with Clarification o Complies Via Previous NRC Approval o Complies with Use of Existing Engineering Equivalency Evaluations (EEEEs)

" Step 3 - Document the results of the review.

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Progress Energy HNP NFPA 805 Transition Report Existing Fundamental Fire Protection Program and Design Element In the Compliance Basis In Refereece Document Field provide:

Enter Field provide: *Document References that

'Complies' No additional demonstrate compliance Document any Open in Compliance Statement clanrication Items found during Review Field No teProvide 'Complies with Field pronide:defais on

Documrent demnstateReferences that compliance Document any Open RCelaian tan t lItems found during Review Enter In the Compliance Basis In Reference Document Field provide:

+ Ns 'Complies via Previous Field provide verbatim . Lcensing Document References Cha r3 Deiation Approval' excerpt alson: (Sdbemio l and Apional) Documerntany Open in Compliance Statement cSubmital document

Document References that Items found during Review Field , Apprnnaldocument demnstate compliance S Engieerig es or baisting Engineering

provide:

Document References that ] land desiatinons)mere performed for fir protectiondesign variances such es fire protectiun system designs and trie barrier EgneigEquvialency Evaluation' I* Summary of bases lor demonstrate Basis compliartca Documrent anyField Open

'he InCompliance Fiely In Reference Document providecompnnent deviationesfrom the specil'tc tire protection deterministic requirements. Section 227 of NFPA Ed5 Equivalnecy in Compliance Statement engineering evaluation Items found during Revieew Cnamponl Fies Fe Eie provioe: Crovcde Actnes as appropriate

,.vi- App- ~~~~~~ ~ ~FieldApoa ouetdmntaecmlac tmFurher Action Required' e Ut of Actions to he

Document References Document any Open as fompn Approvalxce S t T ak n d AItems found during Revie" Pfevi~e3

Entr , In Compliance Basis Fled InrReference Doc;ument Ffeld procide:o ___*

e mentequired 'Ucense Amendment I Iprovide:

Summry of bases for

Conrecive Document Actionsm as appropriate References Document any Open hequired in Compliance Statement liense umendment terr found durng Review One Figure ??? - Fundamental Program and Design Elements Transition Process [based on NEI 04-02 Figure 4-2iFAQ 07-0036]

Page 14 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report 4.1.2 Results from Evaluation Process 4.1.2.1 NFPA 805 Chapter 3 Requirements Met or Previously Approved by the NRC Requirements in NFPA 805 Chapter 3 that are met or for which the NRC previously approved alternatives are included in Appendix A to the Transition Report. References to the document(s) that justify that position are included.

4.1.2.2 NFPA 805 Chapter 3 Requirements not Previously Approved by NRC

[tOptional] For the following items in Chapt r3, no previ usN1~approvaIs of alternatives wer'e3 disco'vered.:

,[List]

Compalince forthiese re~quirements was demonstrated-.insome cases.by showing deterministically*that the requirement, could be met by the plant :a*. ryentl configured..

[Liswithexpl. tos Fo*rthe cases where compliance could:not be demonstrated deterministically, risk-informred, performance-based alternatives were used todemonstrate compliance.

[List:each requirement and briefly describe the ,performance-based method used to demoqnstrate compl i-ance]

4.2 Nuclear Safety Performance Criteria Transition Review 4.2.1 Nuclear Safety Methodology Review 4.2.1.1 Overview of Evaluation Process The comparison of the HNP Fire Protection Program to NEI 00-01 Chapter 3 (NEI 04-02 Table B-2) was performed using the methodology contained in Project Instruction FPIP-0127, NFPA 805 Nuclear Safety Capability Assessment Transition Review, and the guidance contained in FAQ 07-0039, Lessons Learned - NEI 04-02 B-2 and B-3 Tables. The methodology steps depicted in [Figure ], are outlined below.

Step 1 - Assemble documentation. Gather industry and plant-specific information.

Step 2 - Determine and document NEI 00-01 applicability of NEI 00-01 sections. Correlate the NFPA 805 2.4.2 section to the corresponding section of NEI 00-01 Chapter 3. Based upon the content of the NEI 00-01 methodology statements, determine if the section is applicable to the plant.

Step 3 - Perform comparison of plant-specific safe shutdown methodology to applicable sections of NEI 00-01. Determine if failure to maintain strict alignment with the guidance in NEI 00-01 could have adverse consequences. Document whether the plant aligns with the NEI guidance and provide the basis for the alignment statement.

Step 4 - Document Open Items associated with the review of the NEI 00-01 guidance.

Page 15 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report step I Asseoble Do-aet~n~

Stop 2 - stp2ADetermn i Appo abi ityand Documnt of NE! 00-01 Iu Striut

? Aliemmary o f Nueets NE!

tyof00-01 Snten NlEo lackOf Rev P c 42.12 R esltsO Pro Nfrrem s ,ltinYe, Rs tJe C plet eIne ed tor ee 3~eOm>se Addres Figure ?-Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039) 4.2.1.2 Results from Evaluation Process

[,T-o be. comnpletledl later]

4.2.2 Fire Area-by-Fire Area Transition 4.2.2.1 Overview of Evaluation Process The Fire Area - by - Fire Area Transition of the HNP Fire Protection Program (NEI 04-02 Table B-3) was performed using the methodology contained in Project Instruction FPIP-0127, NFPA 805 Nuclear Safety Capability Assessment Transition Review, and the guidance contained in FAQ 07-0039, Lessons Learned - NEI 04-02 B-2 and B-3 Tables. The methodology steps for performing the Fire Area - by - Fire Area Transition depicted in [Fig ?I?], are outlined below.

Step 1 - Assemble documentation. Gather industry and plant-specific fire area analysis analytical and licensing basis documents.

Step 2 - Assess accomplishment of performance goals. Document the fulfillment of the NFPA 805 performance goals for the selected fire area. Also document the method of accomplishment in summary level form for the fire area.

Step 3 - Perform Fire Area Licensing Action Review. Perform a review of the licensing aspects of the selected fire area and document the results of the review.

Step 4 - Perform Engineering Evaluation Review. Perform a review of appropriate engineering evaluations to determine and assess the basis for acceptability. Document the purpose of the evaluation and the review.

Page 16 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Step 5 - Document results and define Open Items / Change Evaluations. This step includes documenting Fire Protection Systems and Features Determination, Fire Suppression Activities, and Open Items / Change Evaluations.

Step I -

Step 2 -

Step3*

3 For Each Fire Area (Iterative, based upon resolution of Open Items)

Step 4 FDocument Resuilts and Oefineý Step 5 < Open Items / Change

==Evl!.tions 2

- These steps may be performed early in the process (e.g., prior to Step 1) for project efficiency, if available resources and program documentation facilitate a review before the performance goal assessment.

Figure ?? - Summary of Fire Area-by-Fire Area Review (FAQ 07-0039) 4.2.2.2 Results from Evaluation Process

[To be completed later]

4.3 Non-Power Operational Modes 4.3.1 Overview of Evaluation Process The review of the HNP Fire Protection Program against NFPA 805 requirements for High Risk Evolutions performed during non-power operational modes (NEI 04-02 Table F-i) was performed using the methodology contained in Project Instruction FPIP-0126, Non-Power Page 17 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Operational Modes Transition Review. The methodology steps depicted in [Figure ],. are outlined below.

Step 1 - Review plant outage process. The purpose of this review is to identify those systems and equipment that are relied upon to provide Key Safety Functions (KSF) during each outage evolution.

Step 2 - Identify required equipment. For systems relied upon to achieve, or support, one or more of the outage evolutions, and the Key Safety Functions, identify the components required for each of the high risk outage evolutions.

Step 3 - Perform circuit analysis. For each new electrically operated component that is added to perform, or support, an outage function, a circuit analysis shall be completed and documented.

Step 4 - Identify equipment/cable or recovery action location.

Step 5 - Perform Fire Area Assessment. Identify those areas where a single fire might damage (or impede) all credited paths, or affect recovery actions used to perform a KSF. For those fire areas where a single fire may damage all credited paths used to perform a KSF, consider and incorporate options into the outage management and planning procedures to reduce the risk from fire depending upon the significance of the potential damage:

Step 6 - Prepare documentation. Summarize the results of this fire area assessment, and document the vulnerabilities identified. This report shall also include any recommendation for modifying procedures utilized to manage risk during plant shutdown and outage periods to ensure that Key Safety Functions are not compromised in the event of a fire during high risk evolutions. Include summary of the tasks that were performed to demonstrate that the nuclear safety performance criteria are met for High Risk Evolutions that are performed during non-power operational modes.

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Progress Energy HNP NFPA 805 Transition Report Figure ?? - Non-Power Operational Modes Review Process 4.3.2 Results from Evaluation Process

[To be completed later]

4.4 Radioactive Release Performance Criteria 4.4.1 Overview of Evaluation Process The review of the HNP Fire Protection Program against NFPA 805 requirements for fire event and fire suppression related radioactive release (NEI 04-02 Table G-1) was performed using the Page 19 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report methodology contained in Project Instruction FPIP-0121, Radiological Release Reviews During Fire Fighting Operations. The methodology steps are outlined below.

Step 1 - Perform Pre-Fire Plan review. Review the site pre-fire plans for locations that have the potential for radiological contamination. The review shall be conducted by an "expert panel" to ensure specific steps are included for containment and monitoring of potentially contaminated materials.

Step 2 - Perform Fire Brigade Training Plan review. The site fire brigade training materials shall be reviewed by an "expert panel" to ensure specific steps are included for dealing specifically with containment and monitoring of potentially contaminated materials and monitoring of potentially contaminated fire suppression products following a fire event.

Step 3 - Establish engineering controls. During the expert panel review process, determine if Engineering Controls could be established to minimize the release of radioactive materials (e.g.

smoke and /or contaminated water).

/

Step 4 - Provide documentation.

4.4.2 Results from Evaluation Process

[To be§pcompleted l~ater]

4.5 Change Evaluations / Plant Modifications 4.5.1 Fire PRA Development and Acceptance

[LATER -,Disc uss HNP Fire PRA development,'reviews adI resuIts from the NRC acceptance' review, high level findings, etc. and howthis processestablishes the foundation for the~ new post-transition fire protectionlicense condition and use in-the chfange evaluation process in RG 1.205]

4.5.2 Risk-Informed, Performance-Based Change Evaluation Process Risk-Informed, performance-based change evaluations were performed as part of the HNP NFPA 805 transition. Progress Energy project instruction FPIP-0128, NFPA 805 Change Evaluations, was developed based upon the industry guidance in primary documents NFPA 805, NEI 04-02 Revision 1, and Regulatory Guide 1.205, Revision 0.

Document Section(s) Topic NFPA 805 2.2(h), 2.2.9, 2.4.4, 4.2.4, A.2.2(h), Change Evaluation A.2.4.4, D.5 Risk of Recovery Actions (4.2.4)

NEI 04-02 Revision 1 4.4, 5.3, Appendix B, Appendix I, Change Evaluation, Change Evaluation Appendix J Forms (App. I)

Reg. Guide 1.205 (May B.2.2, B.2.3, C.3.2 LAR reporting requirements (B.2.2) 2006) Risk of operator manual actions (B.2.3)

Change Evaluations (C.3.2)

Circuit Analysis (C.3.3)

PSA Peer Review (C.4.3)

The Plant Change Process consists of the following subtasks:

Page 20 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report

" Change Definition

" Preliminary Risk Review

" Risk Evaluation

" Acceptability Determination 4.5.2.1 Change Definition The Change Evaluation process started with definition of the change or altered condition to be examined and the baseline configuration as defined by the Licensing Basis (current pre-transition licensing basis).

4.5.2.2 Preliminary Risk Review Once the definition of the change is established and groupings/organizations are established, a preliminary risk review was performed to identify and resolve minor changes to the fire protection program.

4.5.2.3 Risk Evaluation For changes that were not determined to be minor, the changes were assessed using risk-informed, performance-based techniques (including, but not limited to fire modeling and PRA).

The risk evaluations, depending upon the nature of the change, were performed as either limiting or bounding fire modeling/fire risk analysis or detailed integrated analyses.

4.5.2.4 Acceptability Determination The risk evaluation shall be measured quantitatively for acceptability using the ACDF and ALERF criteria from Regulatory Guide 1.174, as clarified in Section 5.3.5 of NEI 04-02 and Regulatory Guide 1.205. The results of the acceptability determination were documented in calculations. An evaluation to ensure maintenance of defense-in-depth and safety margins was also performed.

4.5.3 Risk-Informed, Performance-Based Change Evaluation Results HNP's pre-transition post-fire safe shutdown analysis revalidation efforts and the NFPA 805 transition project activities have a identified a number of variances from the pre-transition fire protection licensing basis. These variances have been and are being addressed by a number of plant and programmatic changes to correct the variances and reduce risk.

Following completion of transition activities and planned modifications and program changes outlined in Section 4.5.3, the plant is compliant with 10 CFR 50.48(c).

In accordance with the guidance in Regulatory Position C.2.2 of Regulatory Guide 1.205, the total risk increase associated with all fire protection program noncompliances (based on current

'pre-transition' deterministic regulations) that are not intended to be brought into compliance and the total risk change associated with plant changes planned for NFPA 805 transition was estimated.

In accordance with the requirements and guidance contained in NFPA 805, NEI 04-02 Revision 1 and Regulatory Guide 1.205, the changes associated the HNP transition to NFPA 805 were determined to be acceptable, based upon the following:

Page 21 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report The estimated change in risk associated with transition to NFPA 805 is estimated to be:

" Less than X x 10x change in core damage frequency/year (ACDF/yr)

" Less than X x 10-x change in large early release frequency/year (ALERF/yr)

In addition, the changes associated with transition to NFPA 805 have been assessed for impact on fire protection defense-in-depth and safety margin. Defense-in-depth and safety margins are maintained.

In accordance with the guidance Regulatory Position C.2.2 of Regulatory Guide, the estimated change in risk associated with the HNP transition to NFPA 805 is consistent with the acceptance guidelines of Regulatory Guide 1.174, and therefore, considered acceptable.

4.5.4 Plant Modifications

[To be competed late,r]

4.6 Monitoring Program In order to assess the impact of a transition on the current monitoring program, the HNP fire protection program documentation hierarchy, maintenance program process / procedures and plant change processes were reviewed. Sections 4.5.3 and 5.2 of the NEI 04-02 Implementing Guidance were used during the review. The results of those reviews follow.

4.6.1 Compliance with Section 2.6 of NFPA 805 4.6.1.1 Extent of Reliance on Current Programs

[Summarizegthe extent to wi ie on.]

4.6.1.2 Overview of Additional Program Elements The monitoring program has been upgraded in the following ways:

[Describe upgrades. -Describe a decision process for determining the appropriate responsibility for monitoring thatshould be included for fire protection equipment (i.e.,

does it goin the Maintenance program or the fire protection equipment operability control process).]

4.7 Program Documentation, Configuration Control, and Quality Assurance 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 HNP has [developedlrevised] the Fire Protection Program document that defines the personnel responsible for establishing and implementing the fire protection program and 2) the fire protection policy for the major fire protection program elements (procedures) and 3) the fire protection features (equipment) to which those elements are applied. [This is the document that contains long-term compliance information for the FundamentalElements and Minimum design requirementsand the process portions (monitoring,change process, evaluation method procedures) of NFPA 805]

[Summarize this document]

Page 22 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report HNP has [developed/revised] the Fire Protection Design Basis Document that demonstrates compliance with nuclear safety criteria of NFPA 805. [This is the document that contains long-term compliance information for the Nuclear Safety Criteriaportion of NFPA 805.]

[Summarize this, document]

4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 of NFPA 805

[Summarize the extent towhich current programs/ processes have been reliedon and any modifications to those processes,. The summary maybe brief,as shown in the foIIowing example" . These maynclude, but are not limited ,to, SGiuidance sim ilar*to NEI 02-03rfor assess'ing changes

A procedure for-th' change prpcess-ifthetchange does not paSs aýscreening process.]

4.7.3 Compliance with Quality Assurance Requirements in Section 2.7.2 of NFPA 805

[Summarize the extent to which current programs/processes have been relied o nand any modifications to those processes. The 'slummary may be brief, as shown in the followi.ng example.]

The existing fire protection quality assurance program is sufficient for a risk-informed, performance-based program transition. The scope of fire protection features that fall under the umbrella of the fire protection quality assurance program may change based upon whether the feature(s) will continue to be credited (directly or via defense in depth analyses) under the new risk-informed, performance-based program.]

5.0 POST-TRANSITION FIRE PROTECTION LICENSING BASIS 5.1 HNP License Amendment Request The LAR identified all orders, license conditions, Technical Specifications and their bases that required revision or deletion to permit HNP to comply with the new fire protection requirements.

The following orders, license conditions and Technical Specifications were superseded.

[List]

The following orders and license conditions were revised as follows.

[Insert table of original orders and license conditions with revisions side-by-side]

The following Technical Specifications and their bases were revised as follows.

[Insert table of original Technical Specifications and their bases with revisions side-by side].

5.2 HNP Post-Transition UFSAR

[To be completed later]

Page 23 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Appendix A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFP A 805 Ch. 3 Transition NFPA 905 Ch. 3 Ref. ReqsuirementsGuid ance Compliance Statement Compfiance Basis Reference Document Document Detail 3.1 General 3.1' General. NMA NfA - General statement; No technical HNP-1IVBMRK-0011, Code All This chapter contains the fundamental elements of the fire requirements Compliance Evaluation NFPA protection program and specitfes the minimum design 805,2003., Rev. 000, requirements for ftre protection systerss and features.

These tire protection program elements and rniinmusm design requirements shall not be subject to the performance-based methods pernittted elsewhere in this standard. Previously approved alternatives from the fundamental protection program attributes of thischapter by the AH-IJ take precedence over the requirements oontained herein.

3.2 Fire Protection Plan NIA NIA N/A - General statement; No technical , Rev.,

requirements 3.2.1 Intent 3.2.1 Intent. Compiles No Additional Clarification FPP,001, Fire Protection All A aei-vide fire protection plan shall be established. This Program Manual, Rev. 029, plan shall document management policy and program direction and shall define the responsibilities of those individuals responsible for the plan's implementation. This section establishes the criteria for an integrated combination of components, procedures, and personnel to imrptenrent alltire protection program activities 32.2 rM-anagement Policy 3.2.2' Management Policy Oirection and Responsibility. Complies No Additional Clarification FPP-001, Fire Protection All Direction and Apolicy document shall be prepared that defines Program Manual, Rev. 029, Responssibifty. management authority and responsibilites and establishes the general policy for the site tire protection program.

3.2.2.1 [Management 3.2.2.1' Complies No Additional Clarification FPP-001, Fire Protection All Policy on Senior The policy document shall designate the senior Program Manual, Rev. 029, Management] management position with immediate authority and responsibility for the fire protection program.

3.2.2.2 [Managenment 3.2.2.2* Complies No Additional Clarification FPP-001, Fire Protection Section 4.2.6 Policy on Daily The policy document shall designate a position Program Manual, Rev. 029, Amdrinistration] responsible for Me daily administration anrdcoordination of the fieeprotection program and its implementation.

3.2.2.3 [Management 3.2.2.31 Complies No Additional Claification FPP-001, Fire Protection Section 4.2 Policy on Interiaces] The policy document "all define the fire protection Program Manual, Rev. 029, interfaces vith other organizations and assign responsibilities for the coordination of activities. In addiSon, this policy document shall ideitity the various plant positions having the authority for implementing the various areas of the fire protection program.

3.2.2.4 UManagement 3.2.2.4' Further Action FPP-001, Fire Protection Section 3.2 Policy on AHJ] The policy document shall identify the appropriate AHJ for Required Program Manual, Rev. 029, the various areas of the tre protection program.

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Proaress Enerav HNP NFPA 805 Transition Report Appendix B - NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA .05Sec*ton: 2-4.2.1 Nuclear Safety Capailitly System and Equipment Selection Acon*prehensive list of systems and equipmeret and their interrelationships to be analyzed fora fire event shag be developed. The equipment listshall contain an inventory of those critical comnponents required toact*ieve fie nuclear saftey pertormance critera ofSection 1.5. Comrponents required to achieve and maintain the nuclear safety functions and components w1lose tire4nduced fadure could prevent the operation or result in the iraloperation of those crerponents needed to meet die nuclear safety criteria shall De included. Availability and reiability of equipment selected shall be evaluated.

NEt0t-01 Ref NEI00-01 Guidance 3 Detemtinistic Methodology This section distusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe shutdown analysis to addreess regulatory requirrnents. The plant-specific analysis approved tryNRC is refecIed in the plant's licensing basis. The methodology described inthis section is also an acceptable mRetod ot performing a post-tire safe shutdown analysis. This methodology is indicated inFigure 3-1. Other nrethods acceptable to NRC may also be used. Regardless of the t*ethod selected by an individual icensee. the criteria and assumptions provided tnthis guidance document may apply. The methodology described inSection 31s based oit a cotmiputer database oriented approach, which is u'ttized by several licensees to model Appendix R data relationships. This guidance docunrent, trhovever, does not require the use of a comrputer database oriented approach.

The requirentenis of Appendix R Sectionse Il.G.1,lI.G.2 and Itt.G.3 apply to equipment and cables required for achieving and mainrtaning sate shutdown in any fire area. Although equipment and cables for tiredetection and suppression systers, conrnunications systems and 8-tour enmrency lighting systems are important features, this guidance document does rcoaddress them.

Addtmonal lifofmation is provided in Appendix B to this document.

Apmnicabilite Applic-able Allunnrent Statenment Alioninprlt Pasis L211311=1s Ui efeence Documnet D Aligns with intent Shearon H-ars' sate shutdown methodology HNP SER initialand was sevieweed against the guidelines of Supple.rent 4,, Rae.

NUREG-0800, so references to the requriremrents of specific sections of Appendix R do not apply. The corresponding sections of NURE3-0800 are C.5.1hatid C,5c.

NEt es-01 Ret NEt 00-01 Guidance 3.1 [A.Intro,]Safe Shutdown This section discusses theidentification of systenre available and necessary to perform the required safe shutdown functions. It also provides information on the Systnms arsdPath process for coorli*gtvirrthese systems into sate shuldovwpaths. Appendix R Section III.G.l.a requires that the capabiflty to achieve and maintain hot shutdown he Development free of fire danage. Kis expected that the term 'free of fire damage" willbe further clarified in a forthcoming Regulatory Issue Summrary. Appendix R Section 111G. 1t) requires that repairs to systems and equipesent necessary to achieve and maintain coil shutdown be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It is the intent of the NRC finatrequirerments related to the use of mrurrualoperator actions willtbe addressed its a fotlhcominirgrulenaeking.

[Refer to hard copy of NEI 0-t1 for Figure 3-1)

Lomment Applical4e Alimnment Statement &AUion Unt asis L2M=r=t ocmen Refrece Dc.Duetils Alignrswrthintent The cornesponding guidelines for Haims are IRev. C.ti.bill and(2) found in NUREG-CS00, STP CMEB 9.5-1 Sections C.t5. (1) arsd (2}.

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Progress Energy HNP NFPA 805 Transition Report Appendix C - NEI 04-02 Table B Fire Area Transition Table B-3 Fire Area Transition Unit Fire Area Name Descrintion 1 12-A-SAL REACTOR AUXlLVNRY BUILDING UNITS 1 AND 2 BALANCE Fire Zone. Deriorien 12-A-BAL REACTOR AUXILIARY BUILDINGUNITS 1 AND 2 BALANCE Recrulatory Basis Phase NHFPA 805, Section 4.2.3.2, 4.2.3.3.a Post-Transition NUREG-OCO,BTP CMES 9.5-1, Section C.5.a with deviation Pre-Trania"ion NUREG-.*O0, BTP CMES 9.5-1, Secton C.5.c Pre-Transe,"

Performanece Goal Method of Accomplishmenl Conments Decay Heat Removal - CSD Cood down ustig RHR Train Afor RHR Train B)from Se Control Room. None Decay Heat Removal - HSB Feed MeA(or B or C)Steam Generator(s) using the Train AAFW pump (or Train B or None lurbine-driven AFW pump) from the Control Room.

Process Monitoring Moanitorprocess indication Train A(or B)from the Control Room. None.

RCS Inventory Control Maintain inventory using the normal (or aftemate) charging path and Charging Pump A (or Actions are considered allowable. See Open Item # 214 Train B)from the Control Room and with local manul actions. Maintain RCP seal integrity concerning actions taken in the event the norml charging flow by thermal barrier cooling, control valve tails open due to a loss of instrument air- See Open Item # 215 concerning actions to align CSIP minimum ,tow to the suction of the CSIP vice the VCT.

RCS Pressure Control Control pressure using train A(orTrain B)pressurizer heaters and pressurizer PORVs (or Overpressure protection is provided by die pressurizer safety pressurizer and reactor head vent systems) from the Control Room, valves (HSB) or RHR suction relief valves (CSD).

Reactivity Control Trip reactor from te Control Room. Borate trom the boric acid tank via the emergency See Open Item .60 on Botic acid pump to CSIP Blow path.

horatio*fiowpath. Use Charing Pump CSIPA (or CSIPB) and charge via hotioold leg injection lines 1SI-3, 1SI-4, 151-52, ISI-Bo or 1SI-107 froo the Control Room.

V.al Auxiliares -CCW, ESW, CWS Operate Train A(or Train B)CCW, ESW and CWVS from the Control Room. None.

Vital Auxiliades -Electrical Control Train Aand Train B Off Site Power and Emergency Diesel Generators A-SA and None B-SB from the Control Room.

Vital Auilianries -H-VAC Operate HVAC systesmis froot Control Room. See open item 47 requinrig the use of a dedicated HVAC unte,to coo the PlC room f a fire int12-A-BAL.

Reference Document Document Derail AOP-036. Sate Shutdown Following a Fire, Rev. 39. AOP-036.1 1, Rev. 2 HNP FSSPMD R16 00, Fire Sate Shutdown Program Manager 12-A-BAL Reporns Database, Rev. 016, HNP-EIELEC-O001, Safe Shutdown inCase ofFire and Fire Hazards Attacht-ent 37 Analysis, Rev. 0, 61'j2006 License ActioBsis Deviaton from BTP CMEB 9.5-1, Section C.5 a, in that not all penetrations Deviaton was approved based on the conditions on either s~de oftSe penetrations, the Installed 1'/1l198o are sealed with equivalently rated tiredamper assemblies, door fire protection features, and the physical separation of redundant safe shutdown equipment.

assemblies, or seals.

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Progress Energy HNP NFPA 805 Transition Report Appendix D - NEI 04-02 Table F-1 Non-Power Operational Modes Transition Table F Non-Power Operational Modes Transition Report NFPA M Sabto FPA WS Section 1,3.1 vJdew oSafety Goal Thee nuclear saiy goal Is Woprovtde reasorlatie assur-a-me Maiatame during anryoperational mode and p 3n'.oorifuratzm mi5not prevenst Mie plal;froim ahleie'ga*rt maintaining re NFstIna sa.e ar aýe otrallan Impleironttng Guldance 4.3.3 r&M 1 Re vtsw exit!ling piant outage ;roresass nageTent and outagle risk assewtnerrlIs) to dckeadire L41tprneularetied uporl to pro MaeKey M3113~

ut-rtiotE ti ulu,:1O n*s. afhho ,e eprsderties d. eme me_ aod-a s lni',Irg at Me lnge F. Fcreanpleero aclet*

re ecay Heat Remwai KSF a platd may crtet 0.411 Train A, De., Train 8, HPI T& A., 1-19Train 5, and G*e*y Feed ar Cltnr and Volumne Control.

Review Tet =a Irnluded In thils Rev*ew **cton for mi*Fi-ri'te *mprce.s.

Unit AOnl-ca3ifly 1 Rererenceent Waitane hrrylegmirnttnk Guridance 4.3.3 Item 2 IdeRMtityMM lorliervlree 1)firee may Cause dallragem to Mieecitrn~ent laid Cabti) rrp oeiea atntje, or 2) reow-ely actions credied Mr lire lKSF are perie edtrorthose KF,5S tat are aeMved soIeLy byres=,m-y act=n Le., atIgrnmen!I orfgs*,y reed).

BuvIuW Test dafta I W Wed In UisaI eYMu ecton fo r WsI I m= Ne purposes.

tAtAppllcabll~y 1 Commnents Test data Icldedd In 1151s Comn nts section fr *lirrdata* PUTrpaea8.

Rearreiren Docmente Documrent De02l Innntnnfrulrsne4.3.3 lUen3 ide.ntiy itse areas ,*here a rin.ge filre.m a* e al Oe oredtted ,1V i _ a-rnsMra KSF. Thi may include l~re *0*tres*n to dletenrnlie i1a p*sikted Wre AEMS - LFS) oiuld tie expeced to *=age epir*prnerm TaTAe, d.

Rs'taw Test da [nue*EC Intis Retiew tsection for tlrdatatite pJrlpes.

WlIApplicabuilt 1 RSrArenos DocreM oer~q st lmolernnttnoG Stince 4.3.31555514 Far Ulm-e areas. censider one or mare of the tarywsirg qpxons to rritlasic portential lire dairsgs depenrring, upon the elgnrttoarre of toe potenluri dam1age--

o Rroi_ 1*,, WrlA3nrta -r Iontt slIat In11I R at-*es (k rg p r.o of , ed WsIn

IraiMS2 .ra01r.

o vatier aulln C',opermale detection arld ior suppreesEWD Mthe Wtneralre areas.

o ?soblrtlIon miIlirdtatllo of carrninsetie materalE Intire areas arcing pe ,Ws (f increased vub-er-ut o)oqVrorrnsr aT583111 lijre palromls at elfll Intepiaie or cother appfoprrtme compensactoy measures s(&vcias eurveliarr carneas) during cereasedý,-ratotIN o Use. ofr ecorrerY 2-irone to ntdgate paternnisimEses o Identtl~lto aiý moidtcrtrg MStats igntdn sollrcesftor 'lire preammmore-g.e, eqj~rtteir. teinpstatcies.

fl209 Teet daaIinlud edInthIs Revie41 seCtion for 11 =trete purpose.

UNIt 3olicab~litt 1 CGrnMriraS Test daIStroistica in tIt sminents Fetorm ror iliustiatrwe nposeW-.

ltrtP ?age- I cf2IU1,2W i-tNP OC1A Fetrdaw PE %seer 1,OS 5051109-17m-ODOT Wdairj Gcpymdr8 TraroltitS, Tool Verstoi 1.0A Page 27 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Appendix E - NEI 04-02 Table G Radioactive Release Transition Table G Radioactive Release Transition Report NFPA 885 Section NFPA 805 Section 1.5.2 Radioactive Release Pertormance Criteria Radiation release to any unrestricted area due to the direct effects of fire suppression activities (but not involvng fuel damage) shall be as low as reasonably achievable and shall not exceed applicable 10 CFR, Part 20, Limits.

tmplementino Guidance Appendix G Step 1 Review pre-fire plans-Ensure for locations that have the potential for contamination that specific steps are included for containment and monitoring of potentially contaminated fire suppression water. Update pre-fire plans as necessary.

Review Test data included in this Review section for illustrative purposes.

Unit Applicability Comments Test data included in this Comments section for illustrative purposes.

Reference Document Document Detail Implementing Guidance Appendix G Step 2 Review fire brigade training materials.

Ensure that training materials deal specifically with tthe containment and monitoring of i~olentially contaminated fire suppression water. Update training materials as necessary.

Review Test data included in this Review section for illustrative purposes.

Unit Apolicability 1 Comments Test data included in this Comments section for illustrative purposes.

Reference Document Document Detail HNP Page I of 1 1011112007 HNP_SSCA Review PE ver 1.0.4 Build'i 09-17-2007_Working Copy.mdb Transition Tool Version 1.0.4 Page 28 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Appendix G - Fire-Induced Multiple Spurious Operations - Resolution Methodology

[The rmethodologypovided in NEI 04-02 as modified by FAQ 07-0038 to address multiple spuqrious operations,(MSOs) willibe included inrthis Appendix]

Page 29 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Appendix H - Operator Manual Actions - Transition to Recovery Actions The assumptions, criteria, methodology, and overall results of the operator manual action transition to recovery actions are included in Attachment M. (Regulatory Position A.1and NEI-04-02, Rev. 1, Section 4.6). Operator manual actions and repairs have been transitioned as "recovery actions" in the new NFPA 805 licensing basis. Operator manual actions have been evaluated in accordance with NEI 04-02, Revision 1, for feasibility and reliability. Additional considerations from FAQ 06-0012 (MLX XXXX,FAQ 06-0011 (MLXXX)XX), and FAQ 07-0030 (MLXXX-XXXX) were included in assessment transition of operator manual actions.

[Addfitrinal d:etail to be provided later.]

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Progress Energy HNP NFPA 805 Transition Report PrgesEeryHPNPA85TasiinRpr Appendix I - NEI 04-02 Frequently Asked Question - Summary Table Table [????] - HNP Transition Report- NEI 04-02 FAQs - Status and Reference Table No. Rev. Title FAQ Ref. FAQ NRC Closure Closure In NEI 04-Comment Ref. (Prelim.) (Memo) 02 Rev. 2?

06-0001 0 Alternate method for Engineering ML061440419 ML062060303 WITHDRAWN WITHDRAWN N/A Evaluations 12/14/06 12/14/06 ML063480169 ML063480169 06-0002 1c NEI 04-02 Section 5.3.3 and App. I, ML061440420 ML062060303 CLOSED APPROVED Yes Order of Questions for Change ML063170357 01/04/07 01/04/07 Analysis Screening ML063350515 ML070030276 ML070030276 06-0003 lb Change Analysis Screening ML061440422 ML062060303 CLOSED APPROVED Yes ML063170355 01/04/07 01/04/07 ML070030242 ML070030242 06-0004 0 Clarify NFPA 805 Chapter 4 and 3 ML061440430 ML062060303 Yes relationship for 'required' FP ML063350442 systems/features 06-0005 1 Guidance on FPP-related changes ML062350095 ML072400021 Yes ML063180544 06-0006 2 High-low pressure interface definition ML062350109 ML062890268 CLOSED APPROVED Yes and NEI 00-01/NFPA 805 ML063170360 03/12/07 03/12/07 discrepancies ML063540308 ML070030117 ML070030117 06-0007 3 NFPA 805 Chapter 3 Requirements for ML062350121 ML063170365 CLOSED Yes Fire Brigades ML070030325 ML071380338 6/21/07 ML070510442 ML071940375 ML071550408 Page 31 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Table [??!?] - HNP Transition Report.- NEI 04-02 FAQs - Status and Reference Table No. Rev. Title FAQ Ref. FAQ NRC Closure Closure In NEI 04-Comment Ref. (Prelim.) (Memo) 02 Rev. 2?

06-0008 6 Alternate method for Engineering ML062860250 ML063350442 Yes Evaluations ML070510499 ML071380177 ML070800007 ML071380182 ML071020160 ML072050214 ML071020169 ML072740231 ML071080099 ML071340180 06-0009 NEI 04-02 Typo Corrections N/A Yes 06-0010 Incorporate Regulatory Guide 1.205 N/A No Baseline concept into NEI 04-02 06-0011 2 Clarify III.G.3 Compliance Transition ML062890271 ML072400023 Yes ML070510505 ML072740248 06-0012 4 Clarify Manual Action Transition in ML062860255 ML063350442 CLOSED Yes Appendix B ML063170362 ML071380186 6/21/07 ML070850610 ML071940375 ML071380229 ML071570260 06-0013 Clarify Chapter 4 Methodology SUPERSEDE N/A Transition Process Bases on Pilot Plant D Results FAQ 07-0039 06-0014 Cumulative Risk No 06-0015 Guidance on not-red determination WITHDRAWN N/A 09/21/07 06-0016 1 Ignition Source counting guidance for ML070030348 ML070640555 CLOSED Yes Electrical Cabinets ML071020174 5/17/07 ML071510425 06-0017 2 Ignition Source counting guidance for ML070030383 ML071730038 CLOSED CLOSED Yes High Energy Arcing Faults (HEAF) ML071350432 6/21/07 9/26/07 ML071570255 ML071940375 ML072500300 Page 32 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Table [???,?] - HNP Transition Report - NEI 04-02 FAQs - Status and Reference Table No. Rev. Title FAQ Ref. FAQ NRC Closure Closure In NEI 04-Comment Ref. (Prelim.) (Memo) 02 Rev. 2?

06-0018 1 Ignition Source counting guidance for ML070030427 ML070640562 CLOSED CLOSED Yes Main Control Board (MCB) ML071020181 5/17/07 9/7/07 ML071510425 ML072500273 06-0019 3 Define "power block" and "plant" ML070030437 ML070510365 Yes ML071340184 ML072550063 ML072740255 06-0020 1 Definition of "applicable" ML070030443 ML070510369 CLOSED Yes ML071340188 5/17/07 ML071510425 06-0021 la Clarify that air drops are acceptable. ML070030457 ML070510417 CLOSED Yes ML071340192 5/17/07 ML071510425 06-0022 1 Identify a list of typical flame ML070030459 ML072740236 Yes propagation tests which are considered ML072340055 acceptable.

06-0023 0 Grant exception for Diesel Generator ML070030470 WITHDRAWN N/A Day Tanks located within Diesel 5/17/07 Generator Buildings. ML071510425 06-0024 1 Define what "adequate clearance" is. ML070030472 ML071380189 CLOSED Yes ML072340062 8/23/07 06-0025 lb Define minimum acceptable pre-plan ML070030476 ML070300588 CLOSED Yes scope. ML071340194 7/19/07 ML072080246 06-0026 0 Clarify NFPA code requirements for ML070030480 ML071380194 WITHDRAWN N/A gear maintenance 5/17/07 ML071510425 06-0027 0 Clarify the "where provided" statement. ML071380236 Yes Page 33 - HNP Transition Report - rev d.doc

Progress Energy HNP N1FPA 805 Transition Report Table [ 7 ?] - HNP Transition Report - NEI 04-02 FAQs - Status and Reference Table No. Rev. Title FAQ Ref. FAQ NRC Closure Closure In NEI 04-Comment Ref. (Prelim.) (Memo) 02 Rev. 2?

06-0028 2 Clarify intent of "familiarization with ML070030489 ML070510427 CLOSED Yes plant fire prevention procedures, fire ML071340195 ML071380349 6/21/07 reporting, and plant emergency alarms" ML071550415 ML071940375 regarding scope of or depth of the training.

06-0029 Clarify zone of influence for NUREG WITHDRAWN N/A 6850 Task 8. 6/21/07 ML071940375 07-0030 Risk of recovery actions Yes 07-0031 0 Misc Binning Issues ML071380238 ML072880327 Yes 07-0032 0 10CFR 50.48(a) and GDC 3 ML071930378 Yes clarification 07-0033 0 Review of Existing Engineering ML071930379 ML072700037 Yes Equivalency Evaluations 07-0034 Determination of non-vented Cabinets Yes 07-0035 0 Bus Duct counting guidance for High ML071650151 Yes Energy Arcing Faults 07-0036 0 Define compliance categories for Table ML072320416 ML072700038 Yes B-1 07-0037 Environmental considerations for N/A equipment 07-0038 0 Lessons learned for MSOs ML072740262 Yes 07-0039 0 Provide update of NEI 04-02 B-2 and ML072740268 Yes B-3 Processes 07-0040 Clarification on Non-Power Operations Yes 07-0041 Chapter 3 Codes and Standards Yes Page 34 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Page 35 - HNP Transition Report - rev d.doc

Progress Energy HNP NFPA 805 Transition Report Appendix J - Definition of Power Block For the purposes of establishing the structures included in the HNP fire protection program in accordance with 10 CFR 50.48(c) and NFPA 805, the following plant structures are considered to be part of the 'power block'. The following table provides the clarification that was requested by the NRC as part of FAQ 06-0019, Define Power Block (I(MLXXXXXXXXX).

Building Comments

[LATER]k Page 36 - HNP Transition Report - rev d.doc

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'En ergy FIRE PROTECTION INITIATIVES PROJECT PROJECT PROCEDURE FPIP-0126 NON-POWER OPERATIONAL MODES TRANSITION REVIEW Revision 0 Reichle, Stephen y Began, Keith I:

Jeffery

Digtally signed by Jeffery Ertman A DN: cn=Jeffery Ertman, c=US, Prepared By P Reviewed By ,. IoPrgress Energy, ou=NGG 2007.05.07 07:58:12 -04'00' 2007.05.07 08:02:27 -04'00' Ertman "'0aet 2007.05.07 08:16:03 -04'00' Prepared By / Date Reviewed By / Date Approved By / Date G* G Nuclear Generation G Group I FPIP-0126 I Rev. 0 I Page 1 of 131

TABLE OF CONTENTS SECTION PAGE 1 .0 P UR P O S E ................................................................................................................................. 3

2.0 REFERENCES

........................................................................................................................... 3 3.0 DEFINITIONS ............................................................................................................................ 3 4.0 RESPONSIBILITIES .................................................................................................................. 5 5.0 PREREQUISITES ...................................................................................................................... 6 6.0 PRECAUTIONS AND LIM ITATIONS ..................................................................................... 6 7.0 SPECIAL TOOLS AND EQUIPM ENT ..................................................................................... 6 8.0 ACCEPTANCE CRITERIA ..................................................................................................... 6 9.0 INSTRUCTIONS ........................................................................................................................ 6 9 .1 B a c kg ro u n d ....................................................................................................................... 6 9.2 Plant Outage Process ..................................................................................................... 7 9.3 Identification of Required Equipment ............................................................................ 8 9.4 Circuit Analysis .................................................................................................................. 8 9.5 Identification of Equipment/Cable or Recovery Action Location ..................................... 9 9.6 Fire Area Assessment .................................................................................................. 9 9.7 Documentation ................................................................................................................ 10 1 0 .0 R E C O R DS ............................................................................................................................... 10 ATTACHMENTS 1 NFPA 805 - Non-Power Operational Guidance .................................................................... 11 REVISION SUM MARY ......................................................................................................................... 13 FPIP-0126 Rev. 0 Page 2 of 13

1.0 PURPOSE The purpose of this project procedure is to describe the process used to demonstrate that the nuclear safety performance criteria outlined in NFPA 805 are met for high risk evolutions that are performed during non-power operational modes. This procedure does not include development of new, or modification of existing, procedures to be utilized in managing risk post NFPA 805 transition.

This project procedure follows the guidance provided in Section 4.3.3 of NEI 04-02 (Reference 2.6) for performing a transitional review of high risk evolutions that are performed while the plant is in one of the non-power operational modes, and could impact Key Safety Functions.

The Fire Protection Initiatives Project has issued this instruction for the purpose of providing project level guidance during transition of the Progress Energy nuclear plant fleet to NFPA 805.

At the completion of the tasks covered by this instruction, it will be cancelled or converted to a NGGC procedure as appropriate.

2.0 REFERENCES

2.1 NGG Fire Protection Program Improvement Initiatives Project Plan 2.2 FPIP-0100, Fire Protection Initiatives Project, Project Controls 2.3 FPIP-0104, Safe Shutdown Equipment List and Fault Tree Logics 2.4 FPIP-0105, Safe Shutdown Circuit Analysis 2.5 National Fire Protection Association (NFPA) Standard 805-2001, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, Section B.6 2.6 Nuclear Energy Institute (NEI) 04-02, Revision 1, Guidance for Implementing a Risk-Informed, Performance-Based Program Under 10CFR50.48(c) 2.7 NUREG-1449, Final Report, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United Stated, September, 1993 2.8 NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management 2.9 NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 2.10 OMP-003, Outage Shutdown Risk Management (Harris plant document) 3.0 DEFINITIONS 3.1 High Risk Evolution Outage activities, plant configurations or conditions during shutdown where the plant is more susceptible to an event causing the loss of a key safety function.

(NUMARC 91-06)

IFPIP-0126 I Rev. 0 1 Page 3of 131

3.2 Key Safety Function Those functions required to ensure nuclear safety during shutdown consisting of decay heat removal capability (both when the core is in the vessel AND in the spent fuel pool),

inventory control, power availability, reactivity control, pressure control, and containment.

Specifically the Key Safety Functions to be considered are (OMP-003):

Decay Heat Removal The ability to maintain reactor coolant system (RCS) temperature and pressure, and spent fuel pool (SFP) temperature below specified limits following a shutdown.

Inventory Control Measures established to ensure that irradiated fuel remains covered with coolant to maintain heat transfer and shielding requirements.

Power Availability The ability to provide AC or DC power to the components required to provide the Key Safety Functions.

Reactivity Control Measures established to preclude inadvertent dilutions, criticalities, power excursions or losses of shutdown margin, and to predict and monitor core behavior.

Containment The action to secure primary (PWR) or secondary (BWR) containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.

3.3 Fire Safe Shutdown Program Manager and Database (FSSPMD)

The FSSPM is a software program and database that has been developed for use in managing the post-fire safe shutdown data and analysis for the Progress Energy nuclear fleet. An independent version of this Program has been developed for each Progress Energy nuclear site. The Program contains data and information on components, circuits, and cables that are credited in effecting a safe shutdown at that plant in the event of a fire. The Program is also used to store data on non-power operations and probabilistic risk assessment components, and has the capability to generate the necessary reports that will document how compliance with NRC regulations is maintained.

3.4 Recovery Action Activities to achieve the nuclear safety performance criteria that take place outside of the main control room or outside of the primary control station(s) for the equipment being operated, including the replacement or modification of components.

I FPIP-0126 I Rev. 0 I Page 4 of 131

3.5 Risk Management Integrated process of assessing and reducing the likelihood and/or consequences of an adverse event. (NUMARC 91-06) 3.6 Terms 3.6.1 May Denotes permission, not a requirement or a recommendation.

3.6.2 Shall Denotes a requirement or a mandatory activity.

3.6.3 Should Denotes an expected action unless there is justifiable reason not to perform the action.

4.0 RESPONSIBILITIES 4.1 CES Fire Protection Initiatives Project Manager 4.1.1 Ensuring that work performed under their supervision is performed in accordance with this instruction.

4.1.2 Approval of each plants Transition Report.

4.2 Site Fire Protection Initiative Project Coordinator 4.2.1 Ensuring that Fire Protection Initiative Project tasks and deliverables associated with their plant is performed in accordance with this procedure.

4.2.2 Review and approval of their plant's Transition Report 4.3 Site Safe Shutdown Engineer 4.3.1 Review and approve the list of equipment and circuit analyses required to ensure the ability to achieve Key Safety Functions are not adversely impacted from a fire during non-power operations.

4.4 Safe Shutdown Engineer 4.4.1 Contacting designated individuals within the plant's various departments (Operations, Outage Management, Scheduling, etc.) that are familiar with typical high risk evolutions that are performed during non-power operating modes to identify those systems that need to be considered within the scope of this review.

4.4.2 Identification of equipment required during non-power operations to ensure that Key Safety Functions are maintained.

I FPIP-0126 I Rev. 0 1 Page 5 of 131

4.4.3 Preparation of new and modified circuit analyses for equipment identified in 4.4.1.

4.4.4 Performance of a fire area assessment for non-power operations, and preparation of the Transition Report.

4.5 Fire Protection Engineer 4.5.1 Provide support to the Safe Shutdown Engineers on an as needed basis to assess situations (scenarios) where fire modeling might prove to be a strategy for demonstrating that fire will not affect a Key Safety Function.

4.5.2 Perform fire modeling for scenarios where a Key Safety Functions may not be affected or lost as a result of a fire in a given area.

5.0 PREREQUISITES 5.1 Personnel assigned to prepare or review documents under this Project procedure shall have the required level of training, completed qualifications for a Post-Fire Safe Shutdown Engineer.

6.0 PRECAUTIONS AND LIMITATIONS 6.1 This procedure does not provide guidance on how to control changes to safe shutdown database (e.g. FSSPMD). Changes to the SSEL and the circuit analysis in the database are to be processed using the guidance provided in References 2.3 and 2.4.

7.0 SPECIAL TOOLS AND EQUIPMENT N/A 8.0 ACCEPTANCE CRITERIA 8.1 The equipment selected and/or recovery actions identified demonstrate that the nuclear safety performance criteria can be met.

9.0 INSTRUCTIONS 9.1 Background The nuclear safety goal stated in NFPA 805 is:

"The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition."

Accomplishment of this goal will be through the management of shutdown and fire risk during high risk evolutions.

The concept of protection of equipment from the effects of fire during plant shutdown conditions is discussed in NUREG-1449. In addition, the current industry approaches for evaluating risk during shutdown conditions involves both quantitative and qualitative assessments and is based on guidance provided in NUMARC 91-06 and 93-01. These guidance documents have been considered in the development of procedures used at FPIP-0126 I Rev. 0 I Page 6of 131

each of Progress Energy nuclear plants to manage risk when the plants are in non-power modes or defueled (i.e. OMP-003 used at HNP).

In order to assess the impact of a fire that might originate when the plant is in a shutdown mode, a nuclear safety assessment similar to that performed for safe shutdown components while the plant is at power shall be performed. This assessment shall be focused on those sets of systems and equipment that are required to ensure that Key Safety Functions (KSF) and safe shutdown conditions can be maintained while various outage related functions are performed. While it is expected that the majority of the equipment required to accomplish these functions would have been identified as required to support safe shutdown, there may be additional sets of systems or differences in the functional requirements and time dependencies on decay heat removal system operation for non-power operation than there was for full power operation.

The guidance provided in this document will be used to identify systems, components, and cables required to ensure that these systems necessary to support each KSF will be available, or compliance strategies for maintaining the KSF are developed.

This process should begin with a discussion of the objectives of this assessment with Probabilistic Risk Assessment (PRA), Fire Protection, Operations, and Outage Management Staffs to obtain their input and determine the best way to integrate the fire protection aspects of this assessment into existing Outage Management Processes.

9.2 Plant Outage Process During this step a review of existing plant management and risk assessment processes that are utilized during outages will be conducted. The purpose of this review is to identify those systems and equipment that is relied upon to provide Key Safety Functions (KSF) during each outage evolution. Each outage evolution identifies the diverse methods of achieving the KSF. For example to achieve the Decay Heat Removal KSF a plant may credit DHR Train A, DHR Train B, HPI Train A, HPI Train B, and Gravity Feed and Chemical and Volume Control.

During this phase of the review, it will be necessary to identify those high risk evolutions that are typically performed during an outage in order to bound the number of systems that are credited in maintaining each of the Key Safety Functions. It is important to note that there may be new evolutions identified from outage to outage, but it is expected that the core systems credited to maintain the Key Safety Functions will remain the same, and new nuclear safety analysis will not need to be performed.

9.2.1 Identify the plant procedures, or directives, that are utilized to manage risk when the plant is shutdown.

9.2.2 Review these outage management procedures (or directives) and identify the Key Safety Functions that are considered.

9.2.3 Identify the various shutdown and fuel pool cooling evolutions that are performed during an outage, and categorize them as either low or high risk evolutions.

(NFPA 805, B.6) 9.2.4 For the high risk evolutions determine the methods (procedures) within these evolutions that are used to achieve the KSF.

FPIP-0126 I Rev. 0 1 Page 7 of 13J

9.2.5 Review the procedures utilized to conduct these evolutions to identify the systems and equipment that is credited.

9.3 Identification of Required Equipment 9.3.1 For systems relied upon to achieve, or support, one or more of the outage evolutions, and the Key Safety Functions identified in subsection 9.2, the guidance provided in FPIP-0104 (Reference 2.3) will be utilized in identifying the components required for each of the high risk outage evolutions.

9.3.2 System and plant operating procedures, as well as flow diagrams, and operations training lessons plans should be considered in identification of systems, components, and functions required.

9.3.3 If a component is required to achieve one of the Key Safety Functions, and it is already credited to perform a nuclear safety function (i.e. safe shutdown of plant) when the plant is at power, it should be reviewed to identify any differences in required position and/or function. For example, the existing nuclear safety analysis (Appendix R/NUREG-0800 analysis) may credit the valve in the closed position however; the valve may be required open for shutdown modes of operation.

9.3.4 Components that are required to perform or support an outage function will be identified in the plant's FSSPMD as required for "Non-Power Operation".

9.3.4.1 If the outage related component is not already included in the FSSPMD, a new record shall be added to the SSEL and fields completed as prescribed in FPIP-0104.

9.3.4.2 If the outage related component is already in the FSSPMD as required to support post-fire safe shutdown, and if operating modes are the same as the safe shutdown component, all that is required is to flag the component as required for "Non-Power Operation".

9.3.4.3 If the outage related component is already on the FSSPMD SSEL, but the operating mode for performing the outage evolution is different, a new record shall be created.

9.3.4.4 The key safety function(s) that the component supports will be identified in a separate field. It should be noted that some components such as those for the Emergency Service Water System may support more that one KSF, and each of them should be identified.

9.3.5 Power sources necessary to support the equipment needed for non-power operation modes should also be identified, similar to the method used for power operation in FPIP-0104. These power supplies should also be identified as required for "Non-Power Operations".

9.4 Circuit Analysis 9.4.1 For each new electrically operated component that is added to the SSEL to perform, or support, an outage function a circuit analysis shall be completed and documented in accordance with FPIP-0105 (Reference 2.4). The Circuit FPIP-0126 Rev. 0 Page 8 of 13J

Information Form included in the FSSPMD shall be completed using the input criteria, assumptions, notes, definitions, and standard abbreviations contained in FPIP-0105.

9.4.2 If the component currently has a completed circuit analysis that was performed for a nuclear safety function, but the required position/function of the component to perform its outage function is different that that for safe shutdown, a new circuit analysis utilizing FPIP-0105 shall be performed for the new position since different failures modes will need to be considered.

9.5 Identification of Equipment/Cable or Recovery Action Location 9.5.1 New equipment that is added to the SSEL in the FSSPMD will be identified as to which fire zone it is located when the component is entered into the FSSPMD utilizing Reference 2.3.

9.5.2 Additional cables that are identified for inclusion in the FSSPMD as part of this non-power operations review will be incorporated utilizing the process described in Reference 2.4.

9.5.3 If a recovery (i.e. manual) action is credited to satisfy a KSF (i.e. alignment of gravity feed), the location (fire zone or fire area) of this action shall be identified so that it can be factored into the fire area assessment.

9.6 Fire Area Assessment 9.6.1 Identify those areas ("pinch points") where a single fire might damage (or impede) all credited paths, or affect recovery actions used to perform a KSF. It should be noted that some KSFs may be achieved solely by the performance of some recovery action (i.e. alignment of gravity feed).

9.6.2 Pinch points will be identified using the following process:

9.6.2.1 As previously identified, the FSSPMD will be utilized to store information on components and circuits, as well as their locations within the plant, associated with a specific KSF can not be credited.

9.6.2.2 Reports provided from FSSPMD will identify the components associated with a given KSF in the fire area that may be damaged by a fire and therefore can not be credited.

9.6.2.3 The data outputs will then be reviewed to determine ifthe minimum requirements (components and systems) are met to ensure that the KSF will remain available.

9.6.3 Fire modeling may be used to determine if the postulated fire would be expected to damage required equipment, or impede recovery actions.

9.6.4 In addition to the review of outage planning and assessment processes, the plant's Technical Specifications and any Administrative control procedures that could affect the availability of equipment required during non-power operational modes should be considered.

FPIP-0126 I Rev. 0 Page 9of 13J

9.6.5 Fire protection system operability requirements and transient combustible control programs should be reviewed to identify any practices that are unique to shutdown modes.

9.6.6 For those fire areas where a single fire may damage all credited paths used to perform a KSF, the following options (compliance strategies) should be considered and incorporated into the outage management and planning procedures to reduce the risk from fire depending upon the significance of the potential damage:

Prohibition or limitation of hot work in fire areas during periods of increased vulnerability.

Verification of operable detection and /or suppression in the vulnerable areas.

Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability.

" Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.

" Use of recovery actions to mitigate potential losses of key safety functions.

This could include staging of backup equipment, repair capabilities, or contingency plans to account for increased vulnerability.

Identification and monitoring of in-situ ignition sources for "fire precursors" (e.g., equipment temperatures).

9.7 Documentation 9.7.1 Additional components selected, and circuit analyses performed, shall be entered into the FSSPMD and changes documented utilizing the Change Control process described in Reference 2.2.

9.7.2 A description of the Non-Power operational modes review and it results shall be incorporated into the plant's Shutdown Calculation. This will be performed by preparing a mark-up of the calculation with necessary attachments for incorporation into the calculation at the next update.

9.7.3 Prepare a Transition Report that summarizes the results of this fire area assessment, and documents the vulnerabilities identified. This report shall also include any recommendation for modifying procedures utilized to manage risk during plant shutdown and outage periods to ensure that Key Safety Functions are not compromised in the event of a fire during high risk evolutions.

9.7.4 Included with the Transition Report should be a summary of the tasks that were performed to demonstrate that the nuclear safety performance criteria are met for high risk evolutions that are performed during non-power operational modes.

The accomplishment of these tasks should be documented using the format provided in Table F-1 of Reference 2.6 (see Attachment 1 to this procedure).

10.0 RECORDS Refer to FPIP-01 00 (Reference 2.2) for guidance on electronic storage/filing of project documents.

FPIP-0126 Rev. 0 Page 10of13

ATTACHMENT 1 Sheet 1 of 1 NFPA 805 - Non-Power Operational Guidance Table F-1 NFPA 805 - Non-Power Operational Guidance NFPA 805 Requirements Implementing Guidance Process and Results The nuclear safety goal is to provide

Review existing plant outage processes 0 List the KSFs and the systems /

reasonable assurance that a fire during any (outage management and outage risk components required to support those operational mode and plant configuration will assessments) to determine equipment function.

not prevent the plant from achieving and relied upon to provide Key Safety

Identify those systems / components that maintaining the fuel in a safe and stable Functions (KSF) including support require additional analyses. For example, condition. functions. Each outage evolution a KSF may rely on instrumentation that is identifies the diverse methods of currently not part of the "Safe Shutdown achieving the KSF. For example to Analysis", or a component may have been achieve the Decay Heat Removal KSF a modeled in one position (closed, off, etc.)

plant may credit DHR Train A, DHR Train but to support the KSF it would need to be B, HPI Train A, HPI Train B, and Gravity evaluated in an additional positions (open, Feed and Chemical and Volume Control. on, etc.)

0 For those additional components, perform circuit analysis, location tasks described in Appendix B of NFPA 805. Document the results.

Identify locations where 1) fires may a Evaluate on a fire area basis the loss of cause damage to the equipment (and KSFs. Document those areas cabling) credited above, or 2) recovery actions credited for the KSF are performed (for those KSFs that are achieved solely by recovery action i.e.,

alignment of gravity feed).

Identify fire areas where a single fire may " For the areas identified above, determine if damage all the credited paths for a KSF. a single fire in the area can cause a loss of This may include fire modeling to all credited paths for a KSF.

determine if a postulated fire (MEFS - " Conservatively, assume the entire contents LFS) would be expected to damage of a fire area are lost. If this does not result equipment required. in the loss of all credited paths for a KSF, document success.

" If fire modeling is used to limit the damage in a fire area, document that fire modeling is credited and ensure the basis for acceptability of that model (location, type, and quantity of combustible, etc.) is I FPIP-0126 Rev. 0 Page 11 of 13 I 0Pg Ilf~

I FPP026Rv

ATTACHMENT 1 Sheet I of 1 NFPA 805 - Non-Power Operational Guidance Table F-1 NFPA 805 - Non-Power Operational Guidance NFPA 805 Requirements Implementing Guidance Process and Results documented. These critical design inputs are required to be maintained during outage modes. See next step below.

For those areas consider one or more of

Integrate the results of the analysis the following options to mitigate potential performed above into the plant's outage fire damage depending upon the management process.

significance of the potential damage: N To the extent practical pre-plan the options o Prohibition or limitation of hot work in for achieving the KSF. See list to the left.

fire areas during periods of increased vulnerability o Verification of operable detection and

/or suppression in the vulnerable areas.

o Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability o Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability o Use of recovery actions to mitigate potential losses o Identification and monitoring insitu ignition sources for "fire precursors" (e.g., equipment temperatures).

(The above Table is from NEI 04-02, Revision 1)

FPIP-0126 Rev. 0 Page 12 of13

REVISION

SUMMARY

Sheet I of I Rev. 0 - Initial issue IFPIP-0126 I Rev. 0 1 Page 13 of 131

HNP-07-178, Revision 0a, Transition to 10 CFR 50.48(c) - NFPA 805 Performance- Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition

Contents

Text

1.0 INTRODUCTION

1.2 Purpose and Scope

2.0 REFERENCES

2.0 REFERENCES

SUMMARY

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HNP-07-178, Revision 0a, Transition to 10 CFR 50.48(c) - NFPA 805 Performance- Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition

Text

1.0 INTRODUCTION

1.2 Purpose and Scope

2.0 REFERENCES

2.0 REFERENCES

SUMMARY

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