L-2014-203, Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001...

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Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001...
ML14198A087
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 07/14/2014
From: Jensen J
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-203
Download: ML14198A087 (27)
v • d • e


Text

July 14, 2014 FPL. L-2014-203 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

References:

1. FPL Letter L-2013-099 dated March 22, 2013: Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)
2. NRC letter dated December 26, 2013: Request for Additional Information on License Amendment Request to Adopt National Fire Protection Association Standard 805 Perfornmance-Based Standard for Fire Protection (TAC Nos. MF 1373 and MF 1374)
3. FPL Letter L-2014-056 dated February 24, 2014: Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) -

NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

4. FPL Letter L-2006-272 dated December 19, 2006: Supplemental Response to Generic Letter 2006-03
5. NRC letter dated June 17, 2014: St. Lucie Plant - Request for Additional (RAI) on License Amendment Request (LAR) to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection (FP) (TAC Nos. MF1373 and MF1374)

Per Reference 1 above, Florida Power and Light Company (FPL) requested an amendment to the Renewed Facility Operating License (RFOL) for St. Lucie Units 1 and 2. The License Amendment Request (LAR) will enable FPL to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205.

Florida Power & Light Company y~y 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-203 10 CFR 50.90 Per Reference 3 FPL responded to specific requests for additional information received by FPL via Reference 2 to clarify aspects of the LAR submittal.

By letter dated June 17, 2014 (Reference 5) NRC Staff requested additional information regarding the LAR. This includes follow-up questions related to the St Lucie response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" (Reference 4), where FPL proposed to resolve the issues related to the use of Hemyc in the St. Lucie Unit 2 containment during its transition to NFPA 805.

The enclosure to this letter provides the detailed responses to the requests for additional information and a correction to a typographical error found in the LAR. The information provided in this submittal does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2013-099.

This letter makes no new commitments or changes to existing commitments.

Should you have any questions regarding this application, please contact Mr. Eric Katzman, Licensing Manager, at 772-467-7734.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on JulyJq , 2014.

Respectfully sub itted, Site *ce President St. Lucie Plant JJ/rcs : St Lucie Units 1 and 2 NFPA 805 LAR RAI Response cc: Ms. Cindy Becker, Florida Department of Health

Enclosure 1 to L-2014-203 Page 1 of 25 Enclosure I St Lucie Units 1 and 2 NFPA 805 LAR RAI Response Response to Request for Additional Information Regarding License Amendment Request for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)

PSL SSA 01.01 .a PSL SSA 01.01.b PSL SSA 01.01 .c PSL SSA 01.01 .d PSL SSA 01.01 .e PSL FPE 12

Enclosure 1 to L-2014-203 Page 2 of 25 PSL RAI SSA 01.01.a, b & c In a letter dated February 24, 2014, the licensee responded to SSA RAI 01 (ADAMS Accession No. ML14070A097), and indicated that there are a diverse number of Operator actions defined as Primary Control Station (PCS) actions for alternate shutdown.

The licensee stated that their analysis regarding Primary Control Stations was done in accordance with Regulatory Guide 1.205 and FAQ 07-0030.

Based on its review the NRC staff could not determine whether all the actions the licensee defined as PCS enabling actions for alternate shutdown meet the feasibility criteria as described in FAQ 07-0030, "Establishing Recovery Actions," (ADAMS Accession No. ML110070485) which states that the actions must be feasible and take place in sufficient time to allow the primary control station(s) to be used to perform the intended function.

Due to the total number of required actions and the numerous locations of those actions, provide the following information:

a) A detailed description of the process used to enable the PCSs including the Hot Shutdown Control Panel; b) The number of qualified Operators per shift that will be available to perform these actions, and the timeline for each Operator and the transit process for each; and c) A justification for high confidence that all required actions can be completed within the required time. In particular, provide details of the fire protection program (for example training, component labeling, etc.) that support this conclusion.

RESPONSE

Minimum Available Staff Section 6.2.2 of the Units 1 and 2 Technical Specifications define the minimum staff needed to operate each unit during power operations. This section references 10 CFR 50.54(m) and additionally identifies two non-licensed Operators (NLO). The minimum shift complement at St.

Lucie would occur when one unit is at power and the other in the cold shutdown or refueling mode. This minimum shift complement consists of three licensed Operators (one Senior Reactor Operator (SRO), two Reactor Operators (ROs)), two NLOs, and a shared Shift Manager (SM) and Shift Technical Advisor (STA). The STA and SM perform activities related to the implementation of the Emergency Plan and monitoring safety parameters and system conditions and, therefore, will not be available to perform post fire local manual actions. The Narrative Logs within the ESOMS (Electronic Shift Operations Management System) Program and procedure 1-OSP-100.27, Schedule of Periodic Tests, Checks and Calibrations, identify three additional NLOs shared between the units. One of the Senior Nuclear Plant Operator (SNPO) qualified NLOs is assigned as the Control Room Inaccessibility SNPO (CRI SNPO) and is dedicated to performing local manual actions during the Control Room evacuation fire event.

Thus, up to three licensed Operators and one NLO are available to perform actions for a Control Room evacuation for each unit and are excluded from fire brigade duties. The Operators are identified below:

2

Enclosure 1 to L-2014-203

. Page 3 of 25 Individual Title 1 Senior Reactor Operator (SRO) Unit Supervisor (US) 1 Reactor Operator (RO) Desk RCO (DRCO) 1 Reactor Operator (RO) Board RCO (BRCO) 1 Non-Licensed Operator (NLO) Control Room Inaccessibility Senior I Nuclear Plant Operator (CRI SNPO)

The actions taken in the process of abandoning the Control Room and transferring plant control to the primary control station(s) require the four individuals identified above.

Control Room Abandonment Process Abandonment of the Control Room on each unit is controlled by procedure 1-ONP-100.02, "Control Room Inaccessibility," (Unit 1) and 2-ONP-100.02, "Control Room Inaccessibility," (Unit 2). Unit 1 and Unit 2 are independent units with completely separate Control Rooms. As such, only one Control Room abandonment would take place at any time with the opposite unit being unaffected. The above procedures are also used for non-fire Control Room issues requiring abandonment of a unit's Control Room. The entry condition for these procedures is "unable to maintain plant control due to a fire in the Control Room or Cable Spread Room." These procedures have steps to place the plant in a stable condition prior to leaving the Control Room if time permits (e.g. trip the reactor and reactor coolant pumps, trip the turbine, close the PORV block valves, negate automatic control for the PORVs, isolate letdown, close the MSIVs, etc.).

However, no credit is given to the success of the Control Room actions, and the Control Room actions are backed up by actions either in the process of transferring control to the hot shutdown control panel (HSCP) (the primary control station (PCS) location for Control Room abandonment) or with controls at the HSCP.

Once the decision is made to evacuate the Control Room, each of the above individuals concurrently perform their procedurally assigned duties to execute the critical steps (i.e. as indicated in Tables 1 and 2) to support transferring plant control to and enabling the PCS(s).

Each of the above Operators executes the steps in separate Appendices to enable the PCS and transfer control to the HSCP. These critical steps require no coordination or communication except to report to the HSCP when the critical steps in that Appendix are complete. Each switch and breaker that needs manipulation in these Appendices has a specific tag indicating that this is required for Control Room abandonment. These tags are unique. They are pink in color, and that color is not used elsewhere in the plant for any reason. This pink color is easily identifiable in the plant and is specifically called out in the procedure and associated Operator training material.

For Unit 1, the protected train for alternate shutdown is the B train. As a consequence, any B train transfer switch isolates the circuit from the Control Room and Cable Spread Room and switches control power to a new set of fuses. This ensures that the controls on the HSCP will function should the fire blow the control power fuse prior to activating the HSCP. For A train and AB train components, the transfer switches will isolate the circuit from the Control Room, but there is no second control power fuse. Therefore, while controls exist on the HSCP, the controls may not function due to loss of control power. However, the majority of the transfer actions leave the components in the A and AB trains in the required state for post fire recovery.

Additional actions may be required to regain control of the A and AB trains, but those actions are not considered to be at the PCS and would be recovery actions.

3

Enclosure 1 to L-2014-203 Page 4 of 25 For Unit 2, the protected train for alternate shutdown is the A train. As a consequence, any A train transfer switch isolates the circuit from the Control Room and Cable Spread Room and switches control power to a new set of fuses. This ensures that the controls on the HSCP will function should the fire blow the control power fuse prior to activating the HSCP. For B train and AB train components, the transfer switches will isolate the circuit from the Control Room, but there is no second control power fuse. Therefore, while controls exist on the HSCP, the controls may not function due to loss of control power. However, the majority of the transfer actions leave the components in the B and AB trains in the required state for post fire recovery.

Additional actions may be required to regain control of the B and AB trains, but those actions are not considered to be at the PCS and would be recovery actions.

The tables provided in the initial SSA RAI-01 response are provided below with the actions grouped in sequence by the individual performing these required critical steps. There are two tables provided, one for each unit.

TABLE 1 UNIT 1 PCS Description from Operator Transfer of Location (all Remarks LAR Attachment G Control or Power locations are on (energizelde- Unit 1) energize) lAB Isolation Panel DRCO Transfer of Control Cable Spread Transfer Switch (Control Room fires only) Room transfer located in the Cable panels Spread Room.

Normal/Isolate switches Sound Powered Phone DRCO Transfer of Control 1A Switchgear Transfer Switch Isolation Box RAB 1-2 Room transfer located in the A panels Switchgear Room.

Normal/Isolate switches 1A Isolation Panel located DRCO Transfer of Control 1A Switchgear Transfer Switch in the A Switchgear Room. Room transfer Normal/Isolate switches panels 1B Isolation Panel located DRCO Transfer of Control 1B Switchgear Transfer Switch in the B Switchgear Room. Room transfer Normal/Isolate switches panels 480V MCC 1 B6 DRCO Transfer of Control 1B Switchgear Transfer Switch Normal/Isolate Switches Room transfer located in the B panels Switchgear Room Communications Isolation DRCO Transfer of Control 1B Switchgear Transfer Switch Panel B-1609 located in Room transfer the B Switchgear Room. panels Normal/Isolate switches 1Al 6.9kV Switchgear BRCO Transfer of Control Turbine Building Transfer Switch located in the Turbine Transfer Building Switchgear Switches/Panel Room. Local switch for breaker 1-30102 4

Enclosure 1 to L-2014-203 Page 5 of 25 UNIT I PCS Description from Operator Transfer of Location (all Remarks LAR Attachment G Control or Power locations are on (energizelde- Unit 1) energize)

WA16.9kV Switchgear BRCO De-energization to Turbine Building Simple breaker located in the Turbine allow HSCP to Transfer action in the Building Switchgear function Switches/Panel vicinity of the Room. Breaker trip for transfer panel breakers 1-30103, 1- (fuse blocks 30104, and 1-30105 designed to be (including pulling fuse pulled without blocks) tools). Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 1A2 4 kV Switchgear BRCO Transfer of Control Turbine Building Transfer Switch located in the Turbine Transfer Building Switchgear Room Switches/Panel Normal/Isolate switches 1 B2 4 kV Switchgear BRCO Transfer of Control Turbine Building Transfer Switch located in the Turbine Transfer Building Switchgear Switches/Panel Room. Normal/Isolate switches 1 B1 6.9 kV Switchgear BRCO Transfer of Control Turbine Building Transfer Switch located in the Turbine Transfer Building Switchgear Switches/Panel Room. Local switch for breaker 1-30202 1B1 6.9 kV Switchgear BRCO De-energization to Turbine Building Simple breaker located in the Turbine allow HSCP to Transfer action in the Building Switchgear function Switches/Panel vicinity of the Room. Breaker trip for transfer panel breakers 1-30203, 1- (fuse blocks 30204, and 1-30205 designed to be (including pulling fuse pulled without blocks) tools). Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 lAB 480V MCC US Transfer of Control Cable Spread Transfer Switch Normal/Isolate switches Room transfer (for Control Room fires panels only) located in the Cable Spread Room 1B3 Pressurizer Heater US Transfer of Control Cable Spread Transfer Switch 1B3 480V load center Room transfer Normal/Isolate switches panels (Control Room fire only) located in the Cable Spread Room 5

Enclosure 1 to L-2014-203 Page 6 of 25 UNIT I PCS Description from Operator Transfer of Location (all Remarks LAR Attachment G Control or Power locations are on (energize/de- Unit 1) energize) 1A3 Pressurizer Heater US Transfer of Control Cable Spread Transfer Switch 1A3 480V load center Room transfer Normal/Isolate switches panels (Control Room fire only) located in the Cable Spread Room 480V MCC 1A6 US Transfer of Control 1A Switchgear Transfer Switch Normal/Isolate switches Room transfer located in the A panels Switchgear Room 480V MCC 1A6 located in US De-energization to 1A Switchgear Simple breaker the A Switchgear Room allow HSCP to Room transfer action in the breakers 1-41311, 1- function panels vicinity of the 41316, and 1-41321 to the transfer panel.

off position Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 1A2 480V Load Center US Transfer of Control 1A Switchgear Transfer Switch Normal/Isolate switches Room transfer located in the A panels Switchgear Room 1A2 480V Load Center US De-energization to 1A Switchgear Simple breaker located in the A allow HSCP to Room transfer action in the Switchgear Room function panels vicinity of the breakers 1-40207 and 1- transfer panel.

40210 to the open position Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 480V MCC 1A5 US Transfer of Control 1A Switchgear Transfer Switch Normal/Isolate switches Room transfer located in the A panels Switchgear Room 480V MCC 1A5 located in US De-energization to 1A Switchgear Simple breaker the A Switchgear Room allow HSCP to Room transfer action in the breakers 1-41202, 1- function panels vicinity of the 41272, 1-41254, 1-41260 transfer panel.

to the off position Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 1A3 4160V Switchgear US Transfer of Control 1A Switchgear Transfer Switch Normal/Isolate switches Room transfer located in the A panels Switchgear Room 6

Enclosure 1 to L-2014-203

.Page 7 of 25 UNIT I PCS Description from Operator Transfer of Location (all Remarks LAR Attachment G Control or Power locations are on (energize/de- Unit 1) energize) 1A3 4160V Switchgear trip US De-energization to 1A Switchgear Simple breaker of breakers 1-20204 and allow HSCP to Room transfer action in the 1-20212 located in the A function panels vicinity of the Switchgear Room transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 1 B3 4160V Switchgear US Transfer of Control 1B Switchgear Transfer Switch Normal/Isolate switches Room transfer located in the B panels Switchgear Room 1B3 4160V Switchgear US Energize equipment 1B Switchgear Simple breaker located in the B to allow for HSCP Room transfer action in the Switchgear Room, close control (de-energize panels vicinity of the breakers 1-20404 and 1- for a Cable Spread transfer panel.

20410, and close breaker Room fire) Therefore, meets 1-20403 (Control Room the definition in fire) or trip 1-20403 (Cable RG 1.205 Spread Room fire) Revision 1 and FAQ 07-0030 1 B2 480V Load Center US Transfer of Control 1B Switchgear Transfer Switch Normal Isolate switches Room transfer located in the B panels Switchgear Room 1B2 480V Load Center US Energize and de- 1B Switchgear Simple breaker located in the B energize equipment Room transfer action in the Switchgear Room to allow for HSCP panels vicinity of the breakers 1-40503, 1- control transfer panel.

40505, and 1-40506 to the Therefore, meets closed position with the definition in breaker 1-40507 to the RG 1.205 open position Revision 1 and FAQ 07-0030 1 B5 480V MCC US Transfer of Control 1B Switchgear Transfer Switch Norma/Isolate switches Room transfer located in the B panels Switchgear Room 1B5 480V MCC located in US De-energize 1B Switchgear Simple breaker the B Switchgear Room equipment to allow Room transfer action in the breakers 1-42016, 1- for HSCP control panels vicinity of the 42017, 1-42018, 1-42068, transfer panel.

1-42035, and 1-42040 to Therefore, meets the off position the definition in RG 1.205 Revision 1 and FAQ 07-0030 7

Enclosure 1 to L-2014-203 Page 8 of 25 UNIT I PCS Description from Operator Transfer of Location (all Remarks LAR Attachment G Control or Power locations are on (energizelde- Unit 1) energize)

B PORV and RCS Gas CRI B PORV-Transfer of 1B Penetration Transfer Switch Vent Isolation switches in SNPO Control Room transfer the 1 B Electrical RCS Gas Vent panel Penetration Room Isolation valves-De-energize and close A PORV and RCS Gas CRI De-energize and 1A Penetration Transfer Switch Vent Isolation switches in SNPO close Room transfer the 1 A Electrical panel Penetration Room 4160V Switchgear lAB CRI Transfer of Control lAB Switchgear Transfer Switch Normal/Isolate switches SNPO Room Transfer located in the AB Panels Switchgear Room 4160V Switchgear lAB CRI De-energize lAB Switchgear Simple breaker located in the AB SNPO equipment to allow Room Transfer action in the Switchgear Room trip for HSCP control Panels vicinity of the breakers 1-20502 and 1- transfer panel.

20503 Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 lAB 480V Load Center CRI Transfer of Control lAB Switchgear Transfer Switch Normal/Isolate switches SNPO Room Transfer located in the AB Panels Switchgear Room 1 B Diesel Generator CRI Transfer of Control 1B EDG Transfer Transfer Switch Isolate switches located in SNPO panel (part of the B the 1B Diesel Generator EDG Control Panel)

Room 8

Enclosure 1 to L-2014-203 Page 9 of 25 TABLE 2 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energize/de- locations are energize) on Unit 2) 2B3 4160V Switchgear DRCO Transfer of Control 2B Switchgear Transfer Switch Normal/Isolate switches Room Transfer located in the B Panels Switchgear Room 2B3 4160V Switchgear DRCO De-energize equipment 2B Switchgear Transfer Switch located in the B to allow for HSCP Room Transfer Switchgear Room trip control Panels breakers 2-20405, 2-20407, and 2-20408 including pulling fuse blocks 2B transfer panel DRCO Transfer of Control 2B Switchgear Transfer Switch Normal/Isolate switches Room Transfer located in the B Panels Switchgear Room 2B2 480V Load Center DRCO Transfer of Control 2B Switchgear Transfer Switch Normal/Isolate switches Room Transfer located in the B Panels Switchgear Room 2B5 480V Load Center DRCO Transfer of Control 2B Switchgear Transfer Switch Normal/Isolate switch Room Transfer located in the B Panels Switchgear Room 2B5 480V Load Center DRCO De-energize equipment 2B Switchgear Simple breaker located in the B to allow for HSCP Room Transfer action in the Switchgear Room breaker control Panels vicinity of the 2-40511 to open transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 9

Enclosure 1 to L-2014-203 Page 10 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energizelde- locations are energize) on Unit 2) 2B9 MCC fan cooler DRCO See Remarks 2B Switchgear Simple switch switches to fast located in Room Transfer operation similar the B Switchgear Room Panels to transfer switch.

No dependence on communication or other actions.

Equivalent to simple breaker operation to energize equipment to allow HSCP function.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A 125 VDC bus breakers DRCO Energize HSCP control In the vicinity of Simple breaker to on position for breakers the 2B action in the 2-60166, 2-60123, and 2- Switchgear vicinity of the 60139 located in the 2A Room Transfer transfer panel.

Battery Charger Room Panels Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2AB transfer panel DRCO Transfer of Control In the vicinity of Transfer Switch Normal/Isolate switches the 2B located in the 2AB Battery Switchgear Charger Room Room Transfer Panels 10

Enclosure 1 to L-2014-203 Page 11 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energizelde- locations are energize) on Unit 2)

MCC 2A9 MCC DRCO See Remarks 2B Switchgear Simple switch containment fan cooler Room Transfer operation similar switches to fast located in Panels to transfer switch.

the B Switchgear Room No dependence on communication or other actions.

Equivalent to simple breaker operation to energize equipment to allow HSCP function.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A5 480V Load Center DRCO Transfer of Control 2B Switchgear Transfer Switch Normal/Isolate switch Room Transfer located in the B Panels Switchgear Room Communication isolation DRCO Transfer of Control 2B Switchgear Transfer Switch switches located in the B Room Transfer Switchgear Room Panels 2C AFW pump room BRCO Transfer of Control AFW Pump Transfer Switch Normal/Isolate switches Area Transfer located in the 2C AFW Panels Pump Room 2A and 2B AFW pump BRCO Transfer of Control AFW Pump Transfer Switch room Normal/Isolate Area Transfer switches located in the 2A Panels and 2B AFW Pump Room 2A1 6.9 kV Switchgear BRCO De-energize equipment Turbine Building Simple breaker breakers to trip position to allow for HSCP Switchgear action in the located in the Turbine control Transfer Panels vicinity of the Building Switchgear transfer panel Room for breakers 2- (fuse blocks 30105, 30104, and 30103 designed to be including pulling fuse pulled without blocks tools). Therefore, meets the definition in RG 1.205 Revision 1

.and FAQ 07-0030 2A2 4160V Switchgear BRCO Transfer of Control Turbine Building Transfer Switch Normal/Isolate switches Switchgear located in the Turbine Transfer Panels Building Switchgear Room II

]1

Enclosure 1 to L-2014-203 Page 12 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energize/de- locations are energize) on Unit 2) 2B2 4160V Switchgear BRCO Transfer of Control Turbine Building Transfer Switch Normal/Isolate switches Switchgear located in the Turbine Transfer Panels Building Switchgear Room 2B1 6.9 kV Switchgear BRCO De-energize equipment Turbine Building Simple breaker position breakers to trip to allow for HSCP Switchgear action in the position located in the control Transfer Panels vicinity of the Turbine Building transfer panel Switchgear Room for (fuse blocks breakers 2-30203, 2- designed to be 30204, and 2- 30205 pulled without including pulling fuse tools). Therefore, blocks meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 MCC 2AB Normal/Isolate US Transfer of Control Cable Spread Transfer Switch switches located in the Room Transfer Cable Spreading Room Panels (Control Room fire only)

MCC 2AB position US De-energize equipment Cable Spread Simple breaker breaker 2-42406 to off to allow for HSCP Room Transfer action in the located in the Cable control Panels vicinity of the Spreading Room (Control transfer panel.

Room fire only) Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A3 480V Load Center US Transfer of Control Cable Spread Transfer Switch Normal/Isolate switches Room Transfer located in the Cable Panels Spread Room (Control Room fires only) 2A3 480V Load Center US De-energize equipment Cable Spread Simple breaker position breaker 2-40305 to allow for HSCP Room Transfer action in the to off located in the Cable control Panels vicinity of the Spread Room (Control transfer panel.

Room fires only) Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2B3 480V Load Center US Transfer of Control Cable Spread Transfer Switch Normal/Isolate switches Room Transfer located in the Cable Panels Spread Room (Control Room fires only) 12

Enclosure 1 to L-2014-203 Page 13 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energizelde- locations are energize) on Unit 2) 2B3 480V Load Center US De-energize equipment Cable Spread Simple breaker position breaker 2-40602 to allow for HSCP Room Transfer action in the to off located in the Cable control Panels vicinity of the Spread Room (Control transfer panel.

Room fires only) Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 MCC 2A6 Normal/Isolate US Transfer of Control 2A Switchgear Transfer Switch switches located in the A Room Transfer Switchgear Room Panels MCC 2A6 position US De-energize equipment 2A Switchgear Simple breaker breakers 2-41310 and 2- to allow for HSCP Room Transfer action in the 41319 to off located in the control Panels vicinity of the A Switchgear Room transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A2 480V Load Center US Transfer of Control 2A Switchgear Transfer Switch Normal/Isolate switches Room Transfer located in the A Panels Switchgear Room 2A2 480V Load Center US De-energize equipment 2A Switchgear Simple breaker position breaker 2-40212 to allow for HSCP Room Transfer action in the to open located in the A control Panels vicinity of the Switchgear Room transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 MCC 2A5 Normal/Isolate US Transfer of Control 2A Switchgear Transfer Switch switches located in the A Room Transfer Switchgear Room Panels MCC 2A5 position US De-energize equipment 2A Switchgear Simple breaker breaker 2-41202 to off to allow for HSCP Room Transfer action in the located in the A control Panels vicinity of the Switchgear Room transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A3 4160V Switchgear US Transfer of Control 2A Switchgear Transfer Switch Normal/Isolate switches Room Transfer located in the A Panels Switchgear Room 13

Enclosure 1 to L-2014-203 Page 14 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energize/de- locations are energize) on Unit 2) 2A3 4160V Switchgear US De-energize and 2A Switchgear Simple breaker position breakers 2- energize equipment to Room Transfer action in the 20201, 2-20203, and 2- allow for HSCP control Panels vicinity of the 20205 to trip including transfer panel pulling fuse blocks, and (fuse blocks position breakers 2- designed to be 20204, 2-20210, 2-20213, pulled without 2-20206, and 2-20207 to tools). Therefore, close located in the A meets the Switchgear Room definition in RG 1.205 Revision 1 and FAQ 07-0030 2A Transfer Panel US Transfer of Control 2A Switchgear Transfer Switch Normal/isolate switches Room Transfer located in the A Panels Switchgear Room LT-9012 transfer switch US Transfer of Control 2A Switchgear Transfer Switch located in the A Room Transfer Switchgear Room Panels MCC 2B6 Normal/Isolate US Transfer of Control 2B Switchgear Transfer Switch switches located in the B Room Transfer Switchgear Room Panels MCC 2B6 position US De-energize equipment 2B Switchgear Simple breaker breaker 2-42118 to off to allow for HSCP Room Transfer action in the located in the B control Panels vicinity of the Switchgear Room transfer panel.

Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 MCC 2B5 Normal/Isolate US Transfer of Control 2B Switchgear Transfer Switch switches located in the B Room Transfer Switchgear Room Panels MCC 2B5 position US De-energize equipment 2B Switchgear Simple breaker breakers -42004, 2- to allow for HSCP Room Transfer action in the 42012, 2-42033, 2-42036, control Panels vicinity of the 2-42037, and 2-42052 to transfer panel.

off located in the B Therefore, meets Switchgear Room the definition in RG 1.205 Revision 1 and FAQ 07-0030 B PORV and RCS gas CRI De-energize and close 2B Penetration Transfer Switch vent isolation located in SNPO Room Transfer the 2B Electrical Panels Penetration Room 14

Enclosure 1 to L-2014-203 Page 15 of 25 UNIT 2 PCS Description from Operator Transfer of Control or Location (All Remarks LAR Attachment G Power (energizelde- locations are energize) on Unit 2)

A PORV and RCS gas CRI De-energize and close 2A Penetration Transfer Switch vent isolation located in SNPO Room Transfer the 2A Electrical Panels Penetration Room 2AB 4160 Switchgear CRI Transfer of Control 2AB Switchgear Transfer Switch Normal/Isolate switches SNPO Room Transfer located in the AB Panels Switchgear Room 2AB 4160 Switchgear CRI Energize equipment to 2AB Switchgear Simple breaker located in the AB SNPO allow for HSCP control Room Transfer action in the Switchgear Room close Panels vicinity of the breakers 2-20502 and transfer panel.

20503 Therefore, meets the definition in RG 1.205 Revision 1 and FAQ 07-0030 2AB 480V Load Center CRI Transfer of Control 2AB Switchgear Transfer Switch Normal/Isolate switches SNPO Room Transfer located in the AB Panels Switchgear Room 2AB 480V Load Center CRI De-energize equipment 2AB Switchgear Simple breaker located in the AB SNPO to allow for HSCP Room Transfer action in the Switchgear Room position control Panels vicinity of the breakers 2-40702, 2- transfer panel.

40706, and 2-40707 to Therefore, meets open the definition in RG 1.205 Revision 1 and FAQ 07-0030 2A Diesel Generator CRI Transfer of Control 2A EDG Transfer Switch Normal/Isolate switches SNPO Transfer Panel located in the 2A Diesel (part of 2A EDG Generator Room control anel )

Upon completion of these steps, the process to enable the PCSs, including the HSCP, is complete.

The action locations are identified for each location. The transit process for each Operator is summarized below. All paths begin in the Control Room area (EL 62').

Timeline and Transit Process Unit I

  • DRCO - down one elevation to Cable Spread Room (EL 43'), adjacent 1A Switchgear Room, adjacent 1 B Switchgear Room
  • BRCO - direct to Turbine Building ground floor 15

Enclosure 1 to L-2014-203 Page 16 of 25

  • US - down one elevation to Cable Spread Room (EL 43'), adjacent 1B Switchgear Room, adjacent 1A Switchgear Room
  • CRI SNPO - down two elevations to 1 B Electrical Penetration Room (EL 19.5'), adjacent 1A Electrical Penetration Room, adjacent lAB Switchgear Room (EL 19.5'), 1B Diesel Generator Building (EL 20')

Unit 2

  • DRCO - down one elevation to 2B Switchgear Room (EL 43'), adjacent 2AB Battery Charger space, back to 2B Switchgear Room
  • BRCO - 2C AFW Pump Room (EL 19.5' - ground floor), adjacent 2A & 2B AFW Pump Room, Turbine Building ground floor
  • US - down one elevation to Cable Spread Room (EL 43'), adjacent 2A Switchgear Room, adjacent 2B Switchgear Room
  • CRI SNPO - down two elevations to 2B Electrical Penetration Room (EL 19.5'), adjacent 2A Electrical Penetration Room, adjacent 2AB Switchgear Room (EL 19.5'), 2A Diesel Generator Building (EL 22.67')

The more time sensitive functions are identified in Table 3 below. These timelines are applicable to both Units 1 and 2. The timeline to establish control at the HSCP is 15-minutes.

Actions not associated with the items identified in Table 3 are subject to this 15 minute timeline.

TABLE 3 ACTION TIMING TABLE Action Max Time Allowed (min)

PORV Closure 4 Establish AFW 30 Letdown Isolation 15 Establish Charging 60 Isolate SGs 30 Trip all four RCPs 10 The critical steps from Tables 1 and 2 above associated with these timelines that are considered to support transferring plant control to and enabling the PCS(s) are described below.

1. PORV closure is the first action performed by the CRI SNPO in the Electrical Penetration Rooms. These rooms are adjacent to each other two elevations down from the Control Room.
2. Tripping all four RCPs is accomplished by the BRCO at the 6.9 kV Switchgears located in the Turbine Building. All of the Switchgears located in the Turbine Building are in very close proximity to each other.
3. Letdown isolation is accomplished by the DRCO by operation of the isolation switches 16

Enclosure 1 to L-2014-203 Page 17 of 25 located at the 1 B Isolation Panel located in the B Switchgear Room. This switch de-energizes a letdown isolation valve solenoid and fails the valve closed for Unit 1. The switches on the HSCP are maintained in the closed position for Unit 2. Therefore, the letdown valves will close when transfer of control to the HSCP is established.

4. Establishing AFW flow to the credited B Steam Generator from the Motor Driven AFW Pump B for Unit 1 and the credited A Steam Generator from the Motor Driven AFW Pump A for Unit 2 includes restoration of Train B (Unit 1) and Train A (Unit 2) essential AC power from the B/A EDG (if offsite power has been lost), isolating un-desired flow to the Steam Generator, tripping the Main Feedwater pumps at the 6.9 kV Switchgear, and operation of various isolation and transfer switches at the Isolation Panels, 4 kV SWGR, and 480V MCCs. These actions are accomplished by all the above Operators concurrently. The actions to establish charging are bounded by those to establish AFW.

A high degree of confidence exists that all these actions can be completed within the required time based on the following feasibility criteria attributes outlined in Appendix B.5.2 of NFPA 805:

  • Accessibility - All breakers and switches are easily accessible, require no special tools or access to energized compartments, nor transit through the fire affected area. All of the switch and breaker tags are pink in color to more readily identify components that require repositioning.
  • Procedural implementation- All required actions are contained in procedures 1(2)-ONP-100.02
  • Lighting - All actions and access/egress thereto are provided with 8-hour backed emergency lighting. Correct aiming for the lights is checked monthly by procedure.
  • Time and Manpower - The actions are concurrently performed by four Operators immediately following Control Room evacuation. All locations are in close proximity to each other, and most are in adjacent areas.

" Habitability - No smoke, radiation or fire suppression concerns are associated with the locations in which the actions are taken. The actions are one time, low exertion efforts taken immediately following evacuation, and therefore any loss of HVAC for a given room or area will not adversely affect the ability to perform the action,

" Communications - There are no inter-dependent actions which require coordination, therefore face-to-face communications are sufficient.

  • Training - Attributes of the training program specific to the actions identified in Tables 1 and 2 above are identified below.

a) Classroom training is provided every 4 years. This training includes the entire process applicable to safe shutdown to cold shutdown conditions from the HSCP.

b) Simulator training is provided every 2 years regarding plant control from the HSCP.

This includes timed field walkdowns of the actions.

c) Job Performance Measures (JPM) are implemented for all the actions.

  • Verification and Validation - In addition to the timed walkdowns performed every two years as identified in Training item b above, the St. Lucie Time Critical Action Program confirms that all of the manual actions have been subjected to timed walkdowns and can 17

Enclosure 1 to L-2014-203 Page 18 of 25 be accomplished within the required time as identified in Table 3, "Action Timing Table" every 4 years.

In addition to the above Feasibility Criteria attributes, monthly channel checks of the HSCP instrumentation are performed as well as functional testing of the components controlled from the HSCP every 18 months.

PSL RAI SSA 01.01.d In a letter dated February 24, 2014, the licensee responded to SSA RAI 01 (ADAMS Accession No. ML14070A097), and indicated that there are a diverse number of Operator actions defined as Primary Control Station (PCS) actions for alternate shutdown.

The licensee stated that their analysis regarding Primary Control Stations was done in accordance with Regulatory Guide 1.205 and FAQ 07-0030.

Based on its review the NRC staff could not determine whether all the actions the licensee defined as PCS enabling actions for alternate shutdown meet the feasibility criteria as described in FAQ 07-0030, "Establishing Recovery Actions," (ADAMS Accession No. ML110070485) which states that the actions must be feasible and take place in sufficient time to allow the primary control station(s) to be used to perform the intended function.

Due to the total number of required actions and the numerous locations of those actions, provide the following information:

d) Identify any components that are controlled locally (that is, not at the Hot Shutdown Control Panel) after the "transfer" is completed, including actions related to diesel generators, actions taken in the electrical penetration rooms, and actions taken in the auxiliary feedwater rooms, which appear to fall in this category based on the initial RAI response.

RESPONSE

Unit 1- These actions are performed by the CRI SNPO. There are no actions taken in the Auxiliary Feedwater (AFW) Pump Rooms.

TABLE 4 Transfer Switch Component Control Function Location SS-117-2 PORV V1404 Transfer control to HSCP-1B 1B Electrical Penetration SS-3/1256 RCGVS V1 445 De-energize and fail closed Room SS-4/1256 RCGVS V1 449 De-energize and fail closed SS-117-1 PORV V1 402 De-energize and fail closed 1A Electrical Penetration SS-3/1256 RCGVS V1 445 De-energize and fail closed Room S33 1B EDG Isolate manual voltage control DG 1B Control Panel, 1B at RTGB-101 EDG Room SS/966 1B EDG Isolate SIAS block of non-essential EDG trips from EDG LO relay 18

Enclosure 1 to L-2014-203 Page 19 of 25 Transfer Switch Component Control Function Location S3/967 1B EDG Isolate manual EDG start control from RTGB-101 and auto start S34 1B EDG Isolate manual EDG voltage control from RTGB-101 Unit 2- The actions in the Electrical Penetration and 2A EDG Rooms are performed by the CRI SNPO. The actions in the AFW Pump Rooms are performed by the DRCO.

TABLE 5 Transfer Component Control Function Location Switch SS/1630 PORV V1 475 De-energize and fail closed 2B Electrical Penetration SS/1464 RCS Vent vlv De-energize and fail closed Room V1464 SS/1466 RCS Vent vlv De-energize and fail closed V1466 I I SS/1629 PORV V1 474 De-energize and fail closed 2A Electrical Penetration SS/1465 RCS Vent vlv De-energize and fail closed Room V1465 SS-ISOL- 2A EDG Isolate manual EDG voltage DG 2A Control Panel, 2A 2/1608 control from RTGB-20, insert EDG Room.

redundant fuses SS-ISOL- 2A EDG Isolate manual EDG start/stop 3/956 control from RTGB-201, insert redundant fuses SS-ISOL- 2A EDG Isolate manual EDG frequency 1/958 control from RTGB-201, insert redundant fuses SS/1625-3 MV-08-19A Transfer control of ADV 2C AFW Pump Room SS/1626-3 MV-08-18A Transfer control of ADV SS/1627-3 MV-08-19B Transfer control of ADV 2A & 2B AFW Pump Room SS/1628-3 MV-08-18B Transfer control of ADV PSL RAI SSA 01.01.e In a letter dated February 24, 2014, the licensee responded to SSA RAI 01 (ADAMS Accession No. ML14070A097), and indicated that there are a diverse number of Operator actions defined as Primary Control Station (PCS) actions for alternate shutdown.

The licensee stated that their analysis regarding Primary Control Stations was done in accordance with Regulatory Guide 1.205 and FAQ 07-0030.

Based on its review the NRC staff could not determine whether all the actions the licensee defined as PCS enabling actions for alternate shutdown meet the feasibility criteria as described in FAQ 07-0030, "Establishing Recovery Actions," (ADAMS Accession No. ML110070485) 19

Enclosure 1 to L-2014-203 Page 20 of 25 which states that the actions must be feasible and take place in sufficient time to allow the primary control station(s) to be used to perform the intended function.

Due to the total number of required actions and the numerous locations of those actions, provide the following information:

e) In accordance with the definition of PCS actions provided in Regulatory Guide 1.205, "Risk-Informed Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants," Rev. 1, one of the criteria for a PCS location is that "more than one component should be controlled from this location (a local control station provided to allow an individual component to be locally controlled, as in local handwheel on a motor-operated valve, does not meet this definition)." For the actions identified in d) above, it is the staff's position that these actions do not meet the definition of PCS actions and that they should be analyzed as recovery actions. In light of this position, provide updated LAR information regarding these actions as appropriate (for example attachments G, W, etc.)

RESPONSE

Unit 1 (Refer to Table 4)

There are no components controlled locally from the Unit 1 Electrical Penetration and 1 B EDG Room locations. Operation of the identified switches disables equipment, isolates circuits from the fire affected areas (Control Room, Cable Spread Room) and/or transfers control in order to allow the alternative shutdown location to function. Therefore, these actions meet the criteria for actions considered as taking place at PCS(s). With switch S3/967 in the ISOLATE position, 1A EDG will require local manual start if offsite power is lost. A hot short on a cable 10966F prior to isolation with SS/966 could actuate the 1 B EDG Lockout Relay. This relay would need to be reset locally, but these actions are NOT identified as an action taken at the PCS. Once started, automatic voltage and frequency control remain available.

Unit 2 (Refer to Table 5)

There are no components controlled locally from the Unit 2 Electrical Penetration and 2A EDG Room locations. The control switch positions for the ADVs on the HSCP are manual and closed (similar to the Control Room position for the same switches), therefore on transfer of control to the HSCP it is expected that the ADVs will be closed. Closure of an unexpected open ADV is a recovery action. In addition, control from the HSCP to open the ADVs for cooldown may not be possible due to loss of DC power. However, opening these valves is part of cooldown and not required for safe and stable conditions. The only control function in the AFW Pump Rooms is operation of the Steam Generator Atmospheric Dump Valves to establish and maintain RCS cooldown. Operation of the identified switches disables equipment, isolates circuits from the fire affected areas (Control Room, Cable Spread Room) and/or transfers control in order to allow the alternative shutdown location (HSCP) to function. Therefore, these actions meet the criteria for actions considered as taking place at PCS(s). The 2A EDG will automatically start and regulate on an undervoltage signal after the above identified isolation switches are operated.

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Enclosure 1 to L-2014-203 Page 21 of 25 Based on the fact that the above discussion shows that the actions taken in the Electrical Penetration Rooms, EDG buildings and AFW Pump Room (Unit 2) only meet the definition for PCS, no changes are required to the LAR or its attachments.

PSL RAI FPE 12 In the supplemented response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" (ADAMS Accession No. ML063630038), the licensee proposed to resolve the issues related to the use of Hemyc in the St. Lucie Unit 2 containment during its transition to NFPA 805. Specifically, the licensee committed to "examine any required corrective actions associated with the Hemyc installation in the St. Lucie Unit 2 containment as part of the St. Lucie transition to NFPA 805."

Provide the following information regarding the resolution of the Hemyc installations at St. Lucie:

a) A summary of the resolution of the Hemyc-related deficiencies.

b) If a performance-based method was used, provide sufficient information to conclude that the performance-based method was acceptable for this application at this particular plant, including a discussion of safety margin and defense-in-depth.

c) Identify and briefly describe any related plant modifications, including an update to Attachment S of the license amendment request, as necessary.

RESPONSE

Hemyc fire retardant material was used only at St. Lucie Unit 2 in the Reactor Containment Building (RCB) which is Fire Area 2K. As part of the original licensing basis, the material was applied to the bottom tray of two (2) different stacks of cable trays which contain essential cables required for Appendix R Post Fire Safe Shutdown. The original configuration was that the Hemyc blanket was installed on the bottom and sides of the lowest tray in the stack of trays that contained essential cables to serve as Flame Impingement Shield (FIS).

a) The resolution of the Hemyc related issues in St. Lucie Unit 2 RCB is based on analysis documented in Attachment C and Attachment G of the NFPA 805 LAR which concluded that protection is not required for any of the essential cables identified in the cable tray stacks presently protected by the FIS (Hemyc). The materials relied upon for the NFPA 805 PRA are Radiant Energy Shields (RES). The RES installed in Fire Area 2K (Unit 2 Containment) are not constructed of Hemyc.

b) A Performance-Based Approach was used as permitted by NFPA 805 Paragraph 4.2.4, specifically subparagraph 4.2.4.2, which allows the use of a Fire Risk Evaluation. The conclusions of the Fire Risk Evaluation were based on an integrated assessment of the acceptability of risk, defense in depth, and safety margins. The acceptability of the risk for Fire Area 2K (Unit 2 Containment) reported in the LAR in Attachment W and the 21

Enclosure 1 to L-2014-203 Page 22 of 25 VFDRs are documented in Table C-1. As documented in the LAR in section 4.5.2.2 the Fire Risk Approach used by St. Lucie is described in detail. A description of the risk evaluation, fire modeling used to support the risk evaluation, defense-in-depth, and safety margin is as follows:

RISK EVALUATION The risk evaluation involved the application of fire modeling analyses and risk assessment techniques to obtain a measure of the changes in risk associated with the proposed change. The acceptance criteria for Fire Area 2K was met as stipulated in NFPA 805 paragraph 2.4.4.

FIRE MODELING Fire modeling performed for the Unit 1 Containment in support of the existing Unit 1 K1 Appendix R exemption was used to support analysis of the Unit 2 RCB. Validation and verification (V&V) of the fire modeling used for the Unit 1 Containment was addressed in the FPL response to PSL FM RAI 03a (refer to FPL Letter L-2014-083 (90-day RAI responses) dated March 25, 2014), which specifically included revision to Attachment J to address the V&V required. The revision to Attachment J of the license amendment was provided within FPL Letter L-2014-109 (120-day RAI responses) as pages 63 through 106 of Enclosure 1 to the letter. This markup of Attachment J supported the response to numerous RAIs including:

90 day RAIs PSL RAI FM03a PSL RAI FM03c 120 day RAIs PSL RAI FMO1a PSL RAI FMO0b PSL RAI FMO1d PSL RAI FMO1e PSL RAI FMO1f PSL RAI FM01h PSL RAI FMO1i.i PSL RAI FMO1i.iii PSL RAI FMO1i.iv PSL RAI FM01j PSL RAI FMO1I The original text in Attachment J, which provided a basis for use of the fire modeling of the Unit 1 RCB to support the exemption for lack of 20 ft. separation between redundant trains, was deleted from the revised Attachment J provided in FPL Letter L-2014-109 (refer to Enclosure 1, page 86). The following basis supports our use of the Unit 1 RCB (Fire Area 1K) Fire Modeling for the Unit 2 RCB (Fire Area 2K):

22

Enclosure 1 to L-2014-203 Page 23 of 25 The detailed cable tray separation analysis for the Unit 1 Containment Building is also used to credit the cable tray separation in the Unit 2 Containment Building. The basis for the Unit 2 credit is that the Unit 1 configuration is similar to or bounds the Unit 2 configuration in terms of fuel load, the cable tray separation, the cable flame spread rate, and the cable heat release rate per unit area (e.g. Unit 1 has non-rated thermoplastic cables and Unit 2 has IEEE 383 rated cables which include thermoset and thermoplastic cables.).

SAFETY MARGIN The safety margin documented for Fire Area 2K in license amendment Attachment C, Table C-1 (pages 411 - 422) on page 416 of 499 states:

"All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained as discussed in Section 4.1."

DEFENSE IN DEPTH (DID)

Fire Area 2K includes Fire Zone 2-14. The defense in depth maintained as documented for Fire Area 2K in license amendment Attachment C, Table C-1 (pages 411 - 422) on page 416 of 499 states:

"A review of defense in depth and risk evaluation results shows that risk acceptance criteria are met and that the balance of defense in depth is maintained. The risk acceptance criteria are met with margin to account for analytical methods associated with fire scenarios. The scenarios bound potential fuel packages which can reasonably be expected to occur in this fire area.

In fire area 2K, automatic suppression (not available) is not modeled in the Fire PRA.

Fire detection is installed in the fire area and required to meet the risk and DID criteria to initiate fire brigade response. Radiant energy shields are installed and required to meet this risk criteria. Installed dedicated conduit in Fire Zone 2-14 is required to meet risk criteria. Portable extinguishers and fire hose stations are available for fire brigade use and do not require additional DID enhancement. Existing administrative controls are determined adequate given the nature of combustibles in the area and the quantified scenarios captured in the fire PRA results. Recovery action(s) are required to meet DID criteria to preserve charging/inventory function. There are no modifications or other required systems or features relied on to meet the DID criteria of NFPA 805."

DID: Recovery Actions The DID Recovery actions documented in license amendment Attachment G, Table G-1, page G-108 are to manually open valve V2340, located in Fire Area N at the +7' elevation and V3519 located in Fire Area M at the -3' elevation. These actions are associated with restoring charging.

23

Enclosure 1 to L-2014-203 Page 24 of 25 DID: Radiant Energy Shields The Fire Protection Systems and Features in areas of the St. Lucie Plant are identified as required for a variety of reasons, as cited in section 4.8.1 (page 60) as well as on page 1 of Attachment C. The reasons include, but are not limited to, separation, risk, required to support an engineering evaluation, etc. The Radiant Energy Shields identified for Fire Area 2K are documented in license amendment Attachment C, Table C-2 on page 18 of 23, and they are identified as - Radiant Energy Shields for support of an engineering evaluation and risk. The Radiant Energy Shields identified below are needed for both engineering evaluation and risk in Fire Area 2K:

23090A (protects pressurizer level LT-1 11 OX and LT-1 105) 25018Y (protects pressurizer pressure PT-1 103; PT-1 104 and PT-1 108) 23091A (Protects pressurizer pressure PT-11-5; PT-11-6 and PT-1107)23176C (Protects Pressurizer Pressure Control: I-SE-02-1 Charging Isolation Valve) 23176E (Protects Pressurizer Pressure Control: I-SE-02-2 Charging Isolation Valve) 23189L (Protects Pressurizer Pressure Control: I-SE-02-4 Aux. Spray Isolation Valve)

Wall Assembly between Penetration Groups 5 and 6 upon entering Fire Area 2K c) There are no updates required for Attachment S. There are no modifications associated with the corrective actions for Hemyc, and this RAI response does not alter that conclusion.

Additionally, as documents were reviewed to respond to this RAI, a typographical error was identified regarding the use of RES in Table C-2 for Fire Area 2K. Based on a review of source documentation, it was identified that the LAR designation of ERFBS for 23090A-F14-RB was incorrectly stated; this conduit is protected by a RES. The RES in Fire Area 2K are provided to support risk results (R) as well as to support an evaluation (E). The subject evaluation is an evaluation of physical separation (S) in Fire Area 2K, therefore the designation in Table C-2 will be enhanced to add "S" to the RES identification. A markup of LAR Attachment C, Table C-2 page 18 of 23 is attached to correct these typographical errors. See attached markup.

24

Enclosure 1 to L-2014-203 Page 25 of 25 Attachment C Table C-2 NFPA 805 Table 4-3 Required Fire Protection Systems and Features Fire Area ID: 2J -Fire Area 2J Compliance Basis: NFPA 805. Section 4.2.4.2. Performance-Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (AD) Area Wide None None D ProcedureslRecovery Actions: D 2-24 RAS Pipe Tunnel and Pipe None E, R E Combustible Loading: E Penetration Room Detection System. Unit 2 Zone 1: E R Detection System, Unit 2 Zone 5A: E R 2-38 ECCS 9B Ventilation Room None E.R None Detection System, Unit 2 Zone 105: E R Fire Area ID. 2JJ - Fire Area 2JJ Compliance Basis: NFPA 805, Section 4.2.3-2 Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-10 Condensate Storage Tank None None None None Enclosure Fire Area ID: 2K - Fire Area 2K Compliance Basis: NFPA 805, Section 4.2.4.2. Performance-Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (AD) Area Wide None None D Procedures/Recovery Actions: D 2-14 Reactor ContainmentlShteld Nnnp E. R, D E. R. S. N Combustible Loading: E Building Dedicated Conduit: R S N Detection Systemn, Unit 2 Zone I1A: E RD Detection System, Unit 2 Zone 11B: E RD

-Typo 1 Detection System. Unit 2 Zone 13A:

Detection System, Unit 2 Zone 13B:

E R0 E R D Detection System, Unit 2 Zone 14A: E RD Detection System. Unit 2 Zone 14B: E RD Detection System. Unit 2 Zone 15A: E RD Detection System. Unit 2 Zone 15B: E R D ERedin, EeyShA-l'4-R.Sid Radiant Energy Shields: E RH< lIIy Fire Safety Analysis Data Manager (4.129 FPL - St Luciee Run: 0311&2013 02:55 Page: 18 of 23

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